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Home My WebLink AboutAIO 003 CAREA INJECTION ORDER 3C Prudhoe Bay Unit Prudhoe Bay Oil Pool North Slope, Alaska 1. July 24, 2018 BPXA’s request for amendment AIO3B to authorize downhole commingling of injection between two pools 2. November 18, 2018 Notice of public hearing, affidavit of publication, email distribution list, and mailings 3. December 16, 2019 Administrative Approval to continue water injection PBU A-03 (aio3C-001) 4. April 16, 2020 Administrative Approval to continue water injection PBU W-35 (aio3C-002) 5. March 9, 2020 BPXA request to amend defined inner annulus normal operating limits on injectors operating under administrative approval 6. October 2, 2020 AOGCC approval of March 9, 2020 request 7. June 29, 2021 Request for Administrative Approval to continue WAG Injection Operations (AIO C3.003) 8. October 12, 2021 Request for Administrative Approval to Continue WAG Injection Operations 9. October 25, 2021 Request for admin approval to continue water injection for PBU S-41A (AIO 3C.004) 10. January 05, 2022 Request for Administrative Approval to continue PWI with slow tubing x inner annulus communication (AIO 3C.005) 11. May 2, 2023 Request for admin approval PBU W-20 (AIO 3C.006) 12. January 11, 2024 Request for admin approval PBU Z-14B (AIO 3C.007) 13. September 22, 2025 Request for admin approval PBU Y-10B (AIO 3C.008) 14. October 14, 2025 Hilcorp request for cancellation of AIO 3C.002 (AIO 3C.002 Cancellation) ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 71" Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF BP Exploration (Alaska) Inc. for amendments to Area Injection Order 3B to authorize the downhole commingling of injection between the Prudhoe Oil Pool and the Aurora Oil Pool and between the Prudhoe Oil Pool and the Borealis Oil Pool. IT APPEARING THAT: Docket Number: AIO-18-035 Area Injection Order No. 3C Prudhoe Bay Unit Western Operating Area including the Drill Site K Area Prudhoe Oil Pool North Slope Borough, Alaska April 3, 2019 1. By application received July 24, 2018, BP Exploration (Alaska) Inc. (BPXA) in its capacity of operator of the Prudhoe Bay Unit (PBU) requested that Area Injection Order (AIO) 3B be amended to allow downhole commingling of injection between the Prudhoe Oil Pool (POP) and the Aurora Oil Pool (AOP) and between the POP and Borealis Oil Pool (BOP). 2. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) scheduled a public hearing for December 19, 2018. On November 16, 2018, the AOGCC published notice of that hearing on the State of Alaska's Online Public Notice website and on the AOGCC's website, electronically transmitted the notice to all persons on the AOGCC's email distribution list, and mailed printed copies of the Notice of Public Hearing to all persons on the AOGCC's mailing distribution list. On November 18, 2018, the notice was published in the Anchorage Daily News. 3. No one requested that the hearing be held or submitted comments on BPXA's application. BPXA provided sufficient information to make a decision so the hearing was vacated. FINDINGS: Operator and Owners: BPXA is the operator of the leases in the portion of the PBU within the Affected Area of this order. BPXA, ExxonMobil, CPAI, and Chevron are the Working Interest Owners, and the State of Alaska, Department of Natural Resources (DNR) is the landowner of the Affected Area, which is located within the North Slope Borough, along Alaska's northern coastline. 2. Affected Area: The Affected Area is defined in AID 3B, and it remains unchanged for this amended order. 3. AOGCC Authority: The U.S. Environmental Protection Agency (EPA) has granted the AOGCC regulatory primacy limited to underground injection control (UIC) Class II wells. 4. Prudhoe Oil Pool: The POP is a massive, highly productive reservoir that has multiple enhanced recovery injection projects occurring simultaneously in different portions of the pool. These recovery projects include: lean and miscible gas injection, conventional water Area Injection Order 3C April 3, 2019 Page 2 of 6 injection, gas cap water injection, and water -alternating -gas injection. The POP lies beneath several smaller pools in the Kuparuk and Schrader Bluff formations and it lies above the Lisburne Oil Pool. Many POP wells encounter two or more pools on the way to total depth. 5. Aurora Oil Pool: The AOP is one of the oil pools in the Kuparuk formation that overlies the POP in the Drill Site S area of the PBU. The AOP is authorized for lean and miscible gas injection as well as water injection for enhanced recovery purposes. Commingled injection between AOP and POP is authorized in wells PBU S-09 and PBU S-3 IA. 6. Borealis Oil Pool: The BOP is another Kuparuk formation oil pool that overlies the POP in the Drill Sites L, V, and Z area of the PBU. The BOP is authorized for lean and miscible gas injection as well as water injection for enhanced recovery purposes. Commingling of injection between the BOP and POP is not currently authorized in any wells. 7. Gas Source: The lean and miscible gas used for injection in the POP, AOP, and BOP is sourced from the PBU Central Gas Facility and Central Compression Plant. Drill Sites L, S, V, and service AOP/BOP and POP wells, so the gas available for enhanced recovery injection is the same for both POP and Kuparuk formation injection. 8. Maximization of Ultimate Recovery: Many POP wells penetrate the AOP or BOP in a location that could be advantageous for providing enhanced recovery injection operations for that pool. Some of these locations have insufficient reserves to justify a standalone injection well, so commingling injection with the POP provides an opportunity to enhance recovery that otherwise would not be available. 9. Injection Conformance: Downhole chokes can be installed between the AOP/BOP and POP to ensure the proper amount of injection fluid for each pool. Additionally, a plug or tubing patch can be installed to shut off all injection to the POP or AOP/BOP respectively in the event one pool no longer needs injection support. 10. Prevention of Crossflow: During injection operations crossflow between the AOP/BOP and POP will not be possible. During extended shut in periods crossflow could occur, but this can be prevented by setting a plug in the tubing between the AOP/BOP and POP. 11. Allocation of Injection Volumes: Injectivity profiles can be developed by obtaining injection rate and pressure data for one zone and differentially determining the injection rate in the other zone. Within 60 days of commencing commingled injection, and within 60 days of the initial swap of injection fluid, an injection survey or multi -rate injection profile would be run on each well to develop the injectivity profile. Additional injection surveys or multi -rate injectivity tests would be conducted as injection performance dictates, or upon AOGCC request. CONCLUSIONS: 1. Amendment of AIO 3B is necessary to authorize commingled injection between the POP and AOP and the POP and BOP on a pool -wide basis. 2. Commingled injection will allow for improved recovery from the PBU by making enhanced recovery injection possible in portions of the AOP or BOP where it isn't currently economically feasible to drill dedicated injection wells for those pools. Area Injection Order 3C April 3, 2019 Page 3 of 6 3. Waste will be minimized by providing proper injection conformance and by setting plugs or patches to prevent crossflow on wells that are shut in for extended periods of time. 4. Injection volumes can be properly allocated by developing injectivity profiles for individual injection wells. NOW, THEREFORE, IT IS ORDERED: AIO 3, AIO 3A, and AIO 3B and all associated Administrative Approvals (except AID 003.011, AIO 003.012, AIO 003.016, AIO 003.019, AIO 003.022, AIO 003.024, AIO 003.025, AIO 003.029, AIO 003.030, AIO 3B.001, AIO 313.002, AIO 3B.003, AIO 313.005 amended, AIO 3B.006, AIO 313.007, AIO 3B.008, and AIO 38.009 which remain in effect) are hereby revoked and replaced by this order. All information related to AIO 3, AIO 3A, and AIO 3B is hereby incorporated by reference into the record for this order. The following rules, in addition to the statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), govern Class II injection operations in the affected area described below: Affected Area: Umiat Meridian Townshil2 and Range Sections TION R12E Sections 1 through 4: All Sections 10 through 12: All TION R13E Sections 1 through 16: All Section 24: All TION R14E Sections 5 through 8: All Sections 17 throw 20: All Tl 1N R11E Sections 1 through 4: All Sections 9 through 15: All Sections 24 and 25: All TI 1N R12E Entire Township TI IN R13E Entire Township TI IN R14E Sections 3 through 8: All Sections 17 through 20: All Sections 29 through 32: All T12N R10E Sections 13 and 24: All T12N RI IE Sections 9 through 30: All Sections 32 throw 36: All T12N R12E Section 7: All Section 17 through 36: All T12N R13E Sections 19 through 23: All Sections 26 through 36: All T12N R14E Sections 27 through 29: All Sections 31 through 34: All Rule 1. Authorized Iniection Strata and Fluids for Enhanced Recovery (Source: AIO 3B) Within the affected area and in the strata defined as those strata which correlate with the strata found in ARCO Alaska Inc. (Atlantic -Richfield -Humble) Prudhoe Bay State Well No. 1 between the measured depths of 8110 feet and 8680 feet the following fluids may be injected for purposes Area Injection Order 3C April 3, 2019 Page 4 of 6 of pressure maintenance and enhanced oil recovery: (a) Produced water and gas from Prudhoe Bay Unit processing facilities; (b) CO2 and other GTP effluent gases from sources within or outside the Prudhoe Bay Unit; (c) Enriched hydrocarbon gas; (d) Non -hazardous water and water based fluids — (specifically seawater, source water, freshwater, domestic wastewater, equipment washwater, sump fluids, hydrotest fluids, firewater, and water with trace chemicals, and other water based fluids with a pH greater than 2 and less than 12.5 and flashpoint greater than 140 degrees F); (e) Fluids introduced to production facilities for the purpose of oil production, plant operations, plant/piping integrity or well maintenance that become entrained in the produced water stream after oil, gas, and water separation in the facility. Specifically: i. Freeze protection fluids; ii. Fluids in mixtures of oil sent for hydrocarbon recycle; iii. Corrosion/scale inhibitor fluids; iv. Anti-foams/emulsion breakers; V. Glycols; vi. Radioactive tracer survey fluids (f) Non -hazardous glycols and glycol mixtures; (g) Fluids that are used for their intended purpose within the oil production process. Specifically: i. Scavengers; ii. Biocides (h) Fluids to monitor or enhance reservoir performance. Specifically: i. Tracer survey fluids; ii. Well stimulation fluids; iii. Reservoir profile modification fluids. Rule 2 Authorized Iniection Strata for Disposal (Source: AIO 3.001) Within the affected area, non -hazardous oil field fluids may be injected for the purpose of fluid disposal into strata defined as those strata which correlate with the strata found in SAPC's Prudhoe Bay Unit Well No. C-11 between the measured depths of 3416 feet and 6293 feet. Rule 3. Fluid Iniection Wells (Source: AIO 3) The underground injection of fluids must be: (i) through a new well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005; (ii) through an existing well that has been approved for conversion to a service well for injection in conformance with 20 AAC 25.280; or (iii) through a well that existed as a service well for injection purposes on the date of July 11, 1986 Area Injection Order 3C April 3, 2019 Page 5 of 6 Pumping of excess non -hazardous fluids that are developed solely from well operations or necessary to control the fluid level of reserve pits, into surface/production casing annuli is exempted from the above requirements. Rule 4. Monitoring the Tubing -Casing Annulus Pressure Variations (Source: AIO 3A) The tubing by casing annulus pressure and injection rate of each injection well must be checked at least weekly to confirm continued mechanical integrity. Rule 5 Reporting the Tubing/Casing Annulus Pressure Variations (Rescinded: AIO 3A) Rule 6. Demonstration of Tubing -Casing Annulus Mechanical Integrity (Source: AIO 3A) The mechanical integrity of an injection well must be demonstrated before injection begins, and before returning a well to service following a workover affecting mechanical integrity. An AOGCC-witnessed mechanical integrity test must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter (except at least once every two years in the case of a slurry injection well). The AOGCC 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 AOGCC, mechanical integrity must be demonstrated by a tubing by casing annulus pressure test using a surface pressure of 1500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 -minute period. Results of mechanical integrity tests must be readily available for AOGCC inspection. Rule 7. Well Integrity Failure (Source: AIO 3A) Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the Operator shall notify the AOGCC by the next business day and submit a plan of corrective action on a Form 10-403 for AOGCC 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 AOGCC. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule 8. Plugging and Abandonment of Fluid Iniection Wells (Source: A10 3) An injection well located within the affected area must not be plugged or abandoned unless approved by the AOGCC. Rule 9. Wells Authorized for Downhole Commingled Iniection with the Aurora and Borealis Oil Pools (Source: Revised this order) Injection into the AOP and POP and the BOP and POP within the same wellbore is authorized, subject to the following conditions. (a) An Application for Sundry Approval (Form 10-403) must be approved by the AOGCC for each well prior to commencement of commingled injection. (b) Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey Area Injection Order 3C April 3, 2019 Page 6 of 6 or separate -pool, multi -rate injectivity test to determine the proper allocation of injected fluids. Thereafter as long as the well continues commingled injection, allocation will be based on use of differential injectivity profiles or injection surveys unless significant changes in total injectivity occur, or the AOGCC so orders, whereupon an injection survey or separate pool injectivity test will be performed. (c) Annual and total cumulative volumes injected by pool and results of logs, surveys, or separate pool multi -rate injectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP and BOP. Rule 10. Administrative Relief (Source: AIO 3B) Upon proper application, or its own motion, and unless notice and public hearing are otherwise required, the AOGCC may administratively waive the requirements of any rule stated herein or administratively amend this order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. DONE at Anchorage, Alaska and dated April 3, 2019. • t Daniel T. Seamount, Jr. J94ie L. Chmielowski Commissioner missioner 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 ran 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 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 71" Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF BP Exploration ) Docket Number: AIO-18-035 (Alaska) Inc. for amendments to Area ) Area Injection Order No. 3C Injection Order 3B to authorize the ) downhole commingling of injection between ) Prudhoe Bay Unit the Prudhoe Oil Pool and the Aurora Oil ) Western Operating Area including Pool and between the Prudhoe Oil Pool and ) the Drill Site K Area the Borealis Oil Pool. ) Prudhoe Oil Pool North Slope Borough, Alaska April 3, 2019 IT APPEARING THAT: I . By application received July 24, 2018, BP Exploration (Alaska) Inc. (BPXA) in its capacity of operator of the Prudhoe Bay Unit (PBU) requested that Area Injection Order (AIO) 3B be amended to allow downhole commingling of injection between the Prudhoe Oil Pool (POP) and the Aurora Oil Pool (AOP) and between the POP and Borealis Oil Pool (BOP). 2. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) scheduled a public hearing for December 19, 2018. On November 16, 2018, the AOGCC published notice of that hearing on the State of Alaska's Online Public Notice website and on the AOGCC's website, electronically transmitted the notice to all persons on the AOGCC's email distribution list, and mailed printed copies of the Notice of Public Hearing to all persons on the AOGCC's mailing distribution list. On November 18, 2018, the notice was published in the Anchorage Daily News. 3. No one requested that the hearing be held or submitted comments on BPXA's application. BPXA provided sufficient information to make a decision so the hearing was vacated. FINDINGS: 1. Operator and Owners: BPXA is the operator of the leases in the portion of the PBU within the Affected Area of this order. BPXA, Exxonklobil, CPA], and Chevron are the Working Interest Owners, and the State of Alaska, Department of Natural Resources (DNR) is the landowner of the Affected Area, which is located within the North Slope Borough, along Alaska's northern coastline. 2. Affected Area: The Affected Area is defined in AIO 313, and it remains unchanged for this amended order. 3. AOGCC Authority: The U.S. Environmental Protection Agency (EPA) has granted the AOGCC regulatory primacy limited to underground injection control (UIC) Class II wells. 4. Prudhoe Oil Pool: The POP is a massive, highly productive reservoir that has multiple enhanced recovery injection projects occurring simultaneously in different portions of the pool. These recovery projects include: lean and miscible gas injection, conventional water Area Injection Order 3C April 3, 2019 Page 2 of 6 injection, gas cap water injection, and water -alternating -gas injection. The POP lies beneath several smaller pools in the Kuparuk and Schrader Bluff formations and it lies above the Lisburne Oil Pool. Many POP wells encounter two or more pools on the way to total depth. Aurora Oil Pool: The AOP is one of the oil pools in the Kuparuk formation that overlies the POP in the Drill Site S area of the PBU. The AOP is authorized for lean and miscible gas injection as well as water injection for enhanced recovery purposes. Commingled injection between AOP and POP is authorized in wells PBU S-09 and PBU S-3 IA. 6. Borealis Oil Pool: The BOP is another Kuparuk formation oil pool that overlies the POP in the Drill Sites L, V, and Z area of the PBU. The BOP is authorized for lean and miscible gas injection as well as water injection for enhanced recovery purposes. Commingling of injection between the BOP and POP is not currently authorized in any wells. 7. Gas Source: The lean and miscible gas used for injection in the POP, AOP, and BOP is sourced from the PBU Central Gas Facility and Central Compression Plant. Drill Sites L, S, V, and service AOP/BOP and POP wells, so the gas available for enhanced recovery injection is the same for both POP and Kuparuk formation injection. 8. Maximization of Ultimate Recovery: Many POP wells penetrate the AOP or BOP in a location that could be advantageous for providing enhanced recovery injection operations for that pool. Some of these locations have insufficient reserves to justify a standalone injection well, so commingling injection with the POP provides an opportunity to enhance recovery that otherwise would not be available. 9. Iniection Conformance: Downhole chokes can be installed between the AOP/BOP and POP to ensure the proper amount of injection fluid for each pool. Additionally, a plug or tubing patch can be installed to shut off all injection to the POP or AOP/BOP respectively in the event one pool no longer needs injection support. 10. Prevention of Crossflow: During injection operations crossflow between the AOP/BOP and POP will not be possible. During extended shut in periods crossflow could occur, but this can be prevented by setting a plug in the tubing between the AOP/BOP and POP. 11. Allocation of Injection Volumes: Injectivity profiles can be developed by obtaining injection rate and pressure data for one zone and differentially determining the injection rate in the other zone. Within 60 days of commencing commingled injection, and within 60 days of the initial swap of injection fluid, an injection survey or multi -rate injection profile would be run on each well to develop the injectivity profile. Additional injection surveys or multi -rate injectivity tests would be conducted as injection performance dictates, or upon AOGCC request. CONCLUSIONS: 1. Amendment of AIO 3B is necessary to authorize commingled injection between the POP and AOP and the POP and BOP on a pool -wide basis. 2. Commingled injection will allow for improved recovery from the PBU by making enhanced recovery injection possible in portions of the AOP or BOP where it isn't currently economically feasible to drill dedicated injection wells for those pools. Area Injection Order 3C April 3, 2019 Page 3 of 6 3. Waste will be minimized by providing proper injection conformance and by setting plugs or patches to prevent crossflow on wells that are shut in for extended periods of time. 4. Injection volumes can be properly allocated by developing injectivity profiles for individual injection wells. NOW, THEREFORE, IT IS ORDERED: AIO 3, AIO 3A, and AIO 3B and all associated Administrative Approvals (except AID 003.011, AIO 003.012, AIO 003.016, AIO 003.019, AIO 003.022, AIO 003.024, AIO 003.025, AIO 003.029, AIO 003.030, AIO 313.001, AIO 313.002, AIO 313.003, AIO 313.005 amended, AID 313.006, AIO 313.007, AIO 313.008, and AIO 313.009 which remain in effect) are hereby revoked and replaced by this order. All information related to AIO 3, AIO 3A, and AIO 3B is hereby incorporated by reference into the record for this order. The following rules, in addition to the statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), govern Class 11 injection operations in the affected area described below: Affected Area: Umiat Meridian Townshig and Range Sections Tl ON R12E Sections 1 through 4: All Sections 10 through 12: All T10N R13E Sections I through 16: All Section 24: All TION R14E Sections 5 through 8: All Sections 17 through 20: All Ti 1N RI 1E Sections 1 through 4: All Sections 9 through 15: All Sections 24 and 25: All Tl 1N R12E Entire Township Tl 1N R13E Entire Township TI IN R14E Sections 3 through 8: All Sections 17 through 20: All Sections 29 through 32: All T12N R10E Sections 13 and 24: All T12N RI IE Sections 9 through 30: All Sections 32 through 36: All T12N R12E Section 7: All Section 17 through 36: All T12N R13E Sections 19 through 23: All Sections 26 through 36: All T12N R14E Sections 27 through 29: All Sections 31 through 34: All Rule 1. Authorized Infection Strata and Fluids for Enhanced Recovery (Source: AIO 3B) Within the affected area and in the strata defined as those strata which correlate with the strata found in ARCO Alaska Inc. (Atlantic -Richfield -Humble) Prudhoe Bay State Well No. I between the measured depths of 8110 feet and 8680 feet the following fluids may be injected for purposes Area Injection Order 3C April 3, 2019 Page 4 of 6 of pressure maintenance and enhanced oil recovery: (a) Produced water and gas from Prudhoe Bay Unit processing facilities; (b) CO2 and other GTP effluent gases from sources within or outside the Prudhoe Bay Unit; (c) Enriched hydrocarbon gas; (d) Non -hazardous water and water based fluids — (specifically seawater, source water, freshwater, domestic wastewater, equipment washwater, sump fluids, hydrotest fluids, firewater, and water with trace chemicals, and other water based fluids with a pH greater than 2 and less than 12.5 and flashpoint greater than 140 degrees F); (e) Fluids introduced to production facilities for the purpose of oil production, plant operations, plant/piping integrity or well maintenance that become entrained in the produced water stream after oil, gas, and water separation in the facility. Specifically: i. Freeze protection fluids; ii. Fluids in mixtures of oil sent for hydrocarbon recycle; iii. Corrosion/scale inhibitor fluids; iv. Anti-foams/emulsion breakers; V. Glycols; vi. Radioactive tracer survey fluids (f) Non -hazardous glycols and glycol mixtures; (g) Fluids that are used for their intended purpose within the oil production process. Specifically: i. Scavengers; ii. Biocides (h) Fluids to monitor or enhance reservoir performance. Specifically: i. Tracer survey fluids; ii. Well stimulation fluids; iii. Reservoir profile modification fluids. Rule 2 Authorized Infection Strata for Disposal (Source: AIO 3.001) Within the affected area, non -hazardous oil field fluids may be injected for the purpose of fluid disposal into strata defined as those strata which correlate with the strata found in SAPC's Prudhoe Bay Unit Well No. C-11 between the measured depths of 3416 feet and 6293 feet. Rule 3. Fluid Infection Wells (Source: A10 3) The underground injection of fluids must be: (i) through a new well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005; (ii) through an existing well that has been approved for conversion to a service well for injection in conformance with 20 AAC 25.280; or (iii) through a well that existed as a service well for injection purposes on the date of July 11, 1986 Area Injection Order 3C April 3, 2019 Page 5 of 6 Pumping of excess non -hazardous fluids that are developed solely from well operations or necessary to control the fluid level of reserve pits, into surface/production casing annuli is exempted from the above requirements. Rule 4. Monitoring the Tubing -Casing Annulus Pressure Variations (Source: AIO 3A) The tubing by casing annulus pressure and injection rate of each injection well must be checked at least weekly to confine continued mechanical integrity. Rule 5. Reporting the Tubing/Casing Annulus Pressure Variations (Rescinded: AIO 3A) Rule 6. Demonstration of Tubing -Casing Annulus Mechanical Integrity (Source: AIO 3A) The mechanical integrity of an injection well must be demonstrated before injection begins, and before returning a well to service following a workover affecting mechanical integrity. An AOGCC-witnessed mechanical integrity test must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter (except at least once every two years in the case of a slurry injection well). The AOGCC 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 AOGCC, mechanical integrity must be demonstrated by a tubing by casing annulus pressure test using a surface pressure of 1500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 -minute period. Results of mechanical integrity tests must be readily available for AOGCC inspection. Rule 7. Well Integrity Failure (Source: AIO 3A) Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the Operator shall notify the AOGCC by the next business day and submit a plan of corrective action on a Form 10-403 for AOGCC 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 AOGCC. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule S. Plugging and Abandonment of Fluid Infection Wells (Source: AIO 3) An injection well located within the affected area must not be plugged or abandoned unless approved by the AOGCC. Rule 9. Wells Authorized for Downhole Commingled Iniection with the Aurora and Borealis Oil Pools (Source: Revised this order) Injection into the AOP and POP and the BOP and POP within the same wellbore is authorized, subject to the following conditions. (a) An Application for Sundry Approval (Form 10-403) must be approved by the AOGCC for each well prior to commencement of commingled injection. (b) Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey Area Injection Order 3C April 3, 2019 Page 6 of 6 or separate -pool, multi -rate injectivity test to determine the proper allocation of injected fluids. Thereafter as long as the well continues commingled injection, allocation will be based on use of differential injectivity profiles or injection surveys unless significant changes in total injectivity occur, or the AOGCC so orders, whereupon an injection survey or separate pool injectivity test will be performed. (c) Annual and total cumulative volumes injected by pool and results of logs, surveys, or separate pool multi -rate injectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP and BOP. Rule 10. Administrative Relief (Source: AIO 3B) Upon proper application, or its own motion, and unless notice and public hearing are otherwise required, the AOGCC may administratively waive the requirements of any rule stated herein or administratively amend this order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. DONE at Anchorage, Alaska and dated April 3, 2019. //signature on file// Daniel T. Seamount, Jr. Commissioner //signature on file// Jessie L. Chmielowski Commissioner 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.mon the next day Bernie Karl K&K Recycling Inc. Gordon Severson Penny Vadla P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave. Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 W/1 THE STATE °fALASKA GOVERNOR MIKE DUNLEAVY Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO. 3C.001 Mr. Ryan Daniel Well Integrity Engineering Team Leader BP Exploration (Alaska), Inc. P.O. Box 196612 Anchorage, AK 99519-6612 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.cogcc.alaska.gov Re: Docket Number: AIO-19-040 Request for administrative approval to allow well A-03 (PTD 1710380) to be online in water only injection service with a shallow packer depth and known tieback liner pressure communication Prudhoe Bay Unit (PBU) A-03 (PTD 1710380) Prudhoe Bay Field Prudhoe Oil Pool Dear Mr. Daniel: By letter dated December 16, 2019 BP Exploration (Alaska), Inc. (BPXA) requested administrative approval to continue water only injection in the subject well. In accordance with Rule 10 of Area Injection Order (AIO) 3C.000, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS BPXA's request for administrative approval to continue water only injection in the subject well. BPXA reported a shallow annuli pressure communication to AOGCC on April 18, 2012. The shallow set 9-5/8" scab liner set inside the 13-3/8" production casing was in communication and AOGCC gave permission to continue injection operations. Subsequent MIT reporting has resulted in confusion on the barrier status and nomenclature which this administrative order will clarify. The AOGCC finds it prudent to designate the inner annulus (IA) as the annulus between the 7" tubing and the 9-5/8" scab liner x 13-3/8" casing. With the pressure communication present between the 13-3/8" casing and 9-5/8" tieback liner, they are effectively combined and should be considered one barrier/annuli. The primary barrier to the release of injection pressure is the 7"x5-1/2" production tubing (T) with the production packer set at 9343 ft MD (7085 ft TVD). AIO 3C.001 December 19, 2019 Page 2 of 3 The secondary barrier, now designated as the IA, is the 13-3/8" x 9-5/8" combined casing with the 9-5/8" casing shoe set at 10,022 ft MD. The tertiary barrier, now designated as the outer annulus (OA), is the 18-5/8" x 20" surface casing x 13-3/8"x9-5/8" casing with the 20" surface casing shoe set at 2297 ft MD. However, since the production packer is set at 9343 ft MD and the uppermost perforation is at 11640 ft MD, this does not meet the requirement that an injection well be equipped with a packer set not more than 200' measured depth above the top of the perforations (20 AAC 25.412(b)). This well configuration results in the well integrity being unmonitorable daily below 9343 ft MD. If injection does not occur into, through, or above freshwater, 20 AAC 25.450 authorizes less stringent well construction and integrity requirements if AOGCC determines the reduction in requirements will not result in an increased risk of movement of fluids into freshwater. BPXA completed a passing state witnessed Mechanical Integrity Test of the new Inner Annulus (MITIA) on November 17, 2019 which indicates that A-03 exhibits at least two competent barriers to the release of well pressure. 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 PBU A-03 is conditioned upon the following: 1. BPXA shall record wellhead pressures and injection rate daily; 2. BPXA 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. BPXA shall perform a mechanical integrity test of the inner annulus (with the 13-3/8" casing and 9-5/8" scab liner combined) every 2 years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1500 psi; 4. BPXA shall perform a mechanical integrity test of the tubing every 2 years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1500 psi; 5. BPXA shall limit the well's IA operating pressure to 2000 psi; 6. BPXA 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 MIT anniversary date is November 17, 2019. A10 3C.001 December 19,2019 Page 3 of 3 DONE at Anchorage, Alaska and dated December 19, 2019. Daniel T. Seamount, Jr. Jes ie L. Chmielowski Commissioner Commissioner 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. THE STATE °ALASKA GOVERNORMICHAEI. I. DUNLEAVY ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO. 3C.002 Mr. Oliver Sternicki Well Integrity Engineer BP Exploration (Alaska), Inc. P.O. Box 196612 Anchorage, AK 99519-6612 Re: Docket Number: AIO-20-010 Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.olaska.gov Request for administrative approval to allow well W-35 (PTD 1880330) to be online in water alternating gas (WAG) injection service with a known inner annulus repressurization Prudhoe Bay Unit (PBU) W-35 (PTD 1880330) Prudhoe Bay Field Prudhoe Oil Pool Dear Mr. Sternicki: By letter dated April 16, 2020 BP Exploration (Alaska), Inc. (BPXA) requested administrative approval to continue WAG injection in the subject well. In accordance with Rule 10 of Area Injection Order (AIO) 3C.000, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS BPXA's request for administrative approval to continue WAG injection in the subject well. BPXA reported an anomalous inner annulus (IA) repressurization to AOGCC in April 2020 and initiated additional diagnostics and monitoring. BPXA completed a passing state waived witnessed Mechanical Integrity Test of the Inner Annulus (MITIA) on April 10, 2020 which indicates that W-35 exhibits at least two competent barriers to the release of well pressure. The well has an IA build up rate of approximately 8 psi/day and AOGCC finds that BPXA is able to manage the IA pressure with periodic pressure bleeds. BPXA has installed wireless gauges on W - Pad that allow for real time monitoring of the IA and outer annuli. Accordingly, the AOGCC believes that the well's condition does not compromise overall well integrity so as to threaten human safety or the environment. AIO 3C.002 April 27, 2020 Page 2 of 2 AOGCC's approval to continue WAG injection in PBU W-35 is conditioned upon the following: 1. BPXA shall record wellhead pressures and injection rate daily; 2. BPXA 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. BPXA shall perform a mechanical integrity test of the inner annulus (MITIA) every 2 years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1500 psi; 4. BPXA shall limit the well's IA operating pressure to 2000 psi; 5. BPXA shall continue to maintain wireless pressure gauges and real time electronic monitoring of the well annuli; 6. BPXA 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 MIT anniversary date is April 10, 2020. DONE at Anchorage, Alaska and dated April 27, 2020. Jeremy M. ,'MWM PAW Price 142. Lfitlp Jeremy M. Price Chair, Commissioner DanielT. Seamount Jr. Daniel T. Seamount, Jr Commissioner g9l" siger° WMMeL Ieuie LChmi .i1i OH.. ...: .. Jessie L. Chmielowski Commissioner 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 derrying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 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 NO. 3C.002 CANCELLATION Mr. Torin Roschinger PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-026 Request to cancel Area Injection Order (AIO) 3C.002 Prudhoe Bay Unit (PBU) W-35 (PTD 1880330), Prudhoe Oil Pool Dear Mr. Roschinger: By emailed letter dated October 14, 2025, Hilcorp North Slope, LLC (Hilcorp) requested cancellation of administrative approval (AA) AIO 3C.002. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS Hilcorp’s request to cancel the AA. Former operator BP Exploration (Alaska), Inc. (BPXA) reported an anomalous inner annulus repressurization to AOGCC in April 2020. On April 27, 2020, AOGCC issued AIO 3C.002. AOGCC determined that water alternating gas (WAG) injection could safely continue if BPXA, and subsequently Hilcorp as the new operator of the PBU, complied with the restrictive conditions set out in the AA. Hilcorp has now sidetracked W-35, creating W-35A under a new Permit to Drill 2250760. AA AIO 3C.002 is hereby CANCELLED. DONE at Anchorage, Alaska and dated October 23, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.10.23 09:03:09 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.10.23 09:42:02 -08'00' AIO 3C.002 Cancellation October 23, 2025 Page 2 of 2 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. From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 3C.002 Cancellation (Hilcorp) Date:Thursday, October 23, 2025 9:53:26 AM Attachments:AIO3C.002 Cancellation.pdf Docket Number: AIO-25-026 Request to cancel Area Injection Order (AIO) 3C.002 Prudhoe Bay Unit (PBU) W-35 (PTD 1880330), Prudhoe 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 THE STATE °fALASKA WV FRNOR MIKI M NI_IIAV Y Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO.3C.003 July 7, 2021 Mr. Stan Golis PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-21-018 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Injection Operations Prudhoe Bay Unit N-OIA (PTD 204113), Prudhoe Oil Pool Dear Mr. Golis: By letter dated June 29, 2021, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water alternating gas (WAG) injection in the subject well. In accordance with Rule 10 of Area Injection Order (AIO) 3C.000, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp's request for administrative approval to continue WAG injection in the subject well. On June 21, 2021, Hilcorp reported that the well experienced possible slow tubing by inner annulus (TxIA) pressure communication while on gas injection. Hilcorp performed diagnostics and monitoring including a passing state -witnessed Mechanical Integrity Test (MIT) of the inner annulus on June 25, 2021, which indicates that N-OIA exhibits at least two competent barriers to the release of well pressure. 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 WAG iniection in N-01A is conditioned upon the following: 1. Hilcorp shall record wellhead pressures and injection rate daily; 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; AIO 3C.003 July 7, 2021 Page 2 of 2 3. Hilcorp shall perform a MIT of the 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 2100 psi, and the outer annulus operating pressure to 1000 psi; 5. Hilcorp shall monitor the inner and outer annulus pressures with wireless pressure gauges; 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 MIT shall be completed before or during the month of June 2023. 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 July 7, 2021. Jeremy Digitally sigmd by le,mrygna Price W.W21A70' 12:57:12o1Vga Jeremy M. Price Chair, Commissioner Daniel Sea=unt lyflgr Mby panlel Seamount _gSgg't°ui iz:ta:s: ao Daniel T. Seamount, Jr. 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. Bernie Karl Gordon Severson Richard Wagner K&K Recycling Inc. 3201 Westmar Cir. P.O. Box 60868 P.O. Box 58055 Anchorage, AK 99508-4336 Fairbanks, AK 99706 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 d "L Salazar, Grace (CED) From: Salazar, Grace (CED) <grace.salazar@alaska.gov> Sent: Wednesday, July 7, 2021 1:20 PM To: AOGCC Public Notices Subject: [AOGCC Public_Notices] AOGCC Area Injection Order No. 3C.003 Attachments: AIO 3C.003.pdf Please see attached. Re: Docket Number: AIO-21-018 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Injection Operations Prudhoe Bay Unit N-OIA (PTD 2041130), Prudhoe Oil Pool Respectfully, M. Grace Salazar, Special Assistant Alaska Oil and Gas Conservation Commission 333 West 71h Avenue Anchorage, AK 99501 Direct: (907) 793-1221 Email: grace.salazar@alaska.gov httys://www.commerce.alaska.gov/web/aoacc/ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: grace.salazar@alaska.gov Unsubscribe at: http:Hlist.state.ak.us/mailman/options/aogcc_public_notices/grace.salazar%40alaska.gov 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 3C.004 October 25, 2021 Mr. Stan Golis, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-21-025 Request for Administrative Approval to Area Injection Order 3C: Water Injection Prudhoe Bay Unit S-41A (PTD 2101010), Prudhoe Oil Pool Dear Mr. Golis: By emailed letter dated October 12, 2021, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water only injection in the subject well. In accordance with 20AAC 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 only injection in the subject well. Hilcorp reported a potential tubing by inner annulus (TxIA) pressure communication to AOGCC on August 20, 2021, while the well was injecting miscible injectant. Hilcorp confirmed the TxIA communication after swapping the well to water injection. Hilcorp performed diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus on September 2, 2021, which indicates that S-41A exhibits at least two competent barriers to the release of well pressure. AOGCC believes Hilcorp can safely manage the TxIA communication by maintaining the inner annulus to a pressure not to exceed 2,100 psi 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 S-41A is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; 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; AIO 3C.004 October 25, 2021 Page 2 of 2 3) Hilcorp shall perform a MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,000 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 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 MIT shall be completed before or during the month of September 2023. DONE at Anchorage, Alaska and dated October 25, 2021. Jeremy M. Price Daniel T. Seamount, Jr. Jessie L. Chmielowski Chair, Commissioner 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. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2021.10.25 14:17:51 -08'00' Dan Seamount Digitally signed by Dan Seamount Date: 2021.10.25 14:28:33 -08'00' Jeremy Price Digitally signed by Jeremy Price Date: 2021.10.25 15:05:08 -08'00' 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 3C.005 January 21, 2022 Mr. Stan Golis, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-22-003 Request for Administrative Approval to Area Injection Order 3C: Water Injection Prudhoe Bay Unit W-44 (PTD 1891000), Prudhoe Oil Pool Dear Mr. Golis: By emailed letter dated January 5, 2022, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water only injection in the subject well. In accordance with 20AAC 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 only injection in the subject well. Hilcorp reported a potential tubing by inner annulus (TxIA) pressure communication to AOGCC on December 13, 2021, while the well was injecting water. Hilcorp performed diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus on December 18, 2021, which indicates that W-44 exhibits at least two competent barriers to the release of well pressure. AOGCC believes Hilcorp can safely manage the TxIA communication by maintaining the inner annulus to a pressure not to exceed 2,100 psi 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 W-44 is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; 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; AIO 3C.005 January 21, 2022 Page 2 of 2 3) Hilcorp shall perform a MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,000 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 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 MIT shall be completed before or during the month of December 2023. DONE at Anchorage, Alaska and dated January 21, 2022 . Jeremy M. Price Daniel T. Seamount, Jr. Jessie L. Chmielowski Chair, Commissioner 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. Dan Seamount Digitally signed by Dan Seamount Date: 2022.01.21 10:46:55 -09'00' Jeremy Price Digitally signed by Jeremy Price Date: 2022.01.21 13:06:46 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2022.01.21 13:20:29 -09'00' AOGCC 333 W 7th Avenue, Anchorage, AK 99501 TO: BERNIE KARL K&K RECLYCLING, INC. PO BOX 58055 FAIRBANKS, AK 99711 Mailed 1/21/22gs 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. From:Salazar, Grace (OGC) To:Abbie Barker; sgolis@hilcorp.com Cc:Wallace, Chris D (OGC) Subject:Area Injection Order No. 3C.005 Date:Friday, January 21, 2022 1:49:00 PM Attachments:AIO 3C.005.pdf The Alaska Oil and Gas Conservation Commission has issued the attached Area Injection Order No. 3C.005, granting Hilcorp North Slope, LLC’s request to continue water only injection into Prudhoe Bay Unit Well W-44 (PTD 1891000). If you have any questions, please contact Mr. Chris Wallace, Senior Petroleum Engineer, at (907) 793-1250 or via email at chris.wallace@alaska.gov. Grace ____________________________________ Respectfully, M. Grace Salazar, Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 Direct: (907) 793-1221 Email: grace.salazar@alaska.gov https://www.commerce.alaska.gov/web/aogcc/ From: Carlisle, Samantha J (OGC) <samantha.carlisle@alaska.gov> Sent: Thursday, January 6, 2022 4:21 PM To: Salazar, Grace (OGC) <grace.salazar@alaska.gov> Subject: FW: PBU W-44 (PTD # 189-100) Request for Administrative Approval From: Abbie Barker <Abbie.Barker@hilcorp.com> Sent: Thursday, January 6, 2022 4:20 PM To: AOGCC Permitting (CED sponsored) <aogcc.permitting@alaska.gov> Cc: PB Wells Integrity <PBWellsIntegrity@hilcorp.com>; Oliver Sternicki <Oliver.Sternicki@hilcorp.com>; Stan Golis <sgolis@hilcorp.com>; Brodie Wages <David.Wages@hilcorp.com>; Wyatt Rivard <wrivard@hilcorp.com> Subject: PBU W-44 (PTD # 189-100) Request for Administrative Approval Hello, Please find the attached Request for Administrative Approval to continue PWI Operations for PBU W-44 (PTD # 189-100). If you have any questions, please contact Stan Golis at 907-777-8356 or Ryan Holt / Andy Ogg at (907) 659-5102. Thanks, Abbie Abbie Barker Regulatory Tech, Prudhoe Bay West Team Hilcorp North Slope Email: Abbie.Barker@hilcorp.com Office: (907)564-4915 Cell: (907)351-2459 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 herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately 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 the onward 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. 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 NO. 3C.006 Mr. Torin Roschinger, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-23-011 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Injection Prudhoe Bay Unit (PBU) W-20 (PTD 1880460), Prudhoe Bay Oil Pool Dear Mr. Roschinger: Byemailedletter dated May 2, 2023, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water alternating gas (WAG) injection with a known inner annulus (IA) to formation pressure communication. In accordance with 20AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp’s request for administrative approval to continue WAG injection in the subject well. Hilcorp reported to AOGCC on April 27, 2023, a slow IA pressure decrease and placed the well on a 28-day monitoring period. Hilcorp confirmed the IA pressure decrease occurs without a corresponding increase to the outer annulus (OA) pressure and as such AOGCC believes the communication is IA to formation. Hilcorp performed diagnostics including a passing state witnessed mechanical integrity test (MIT) of the inner annulus on May 1, 2023, which indicates that W-20 exhibits at least two competent barriers to the release of well pressure. Hilcorp maintains live transmitters on the inner and outer annulus and alarm and remote shut down functions in the Supervisory Control and Data Acquisition (SCADA) system that create layers of protection from an over-pressure event. These inner and outer annulus alarms combined with the planned inner and outer annulus operating pressure limits enable AOGCC to continue to authorize gas injection. AOGCC believes Hilcorp can safely manage the IA to formation pressure communication with periodic pressure bleeds by maintaining the inner annulus to a pressure not to exceed 2,100 psi and the outer annulus not to exceed 1,000 psi. Accordingly, the AOGCC believes that the well’s condition does not compromise overall well integrity so as to threaten human safety or the environment. AIO 3C.006 June 2, 2023 Page 2 of 2 AOGCC’s approval to continue WAG injection in W-20 is conditioned upon the following: 1. Hilcorp shall record wellhead pressures and injection rate daily; 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 MIT of the 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 2,100 psi and the outer annulus to 1,000 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 SCADA system; 6. Hilcorp shall maintain the Production Control Center (PCC) remote shut down capability for W-20 when on gas or miscible injectant (MI) operation. During gas/MI injection, the IA protocols will include a drill site operator and PCC alarm set at 2,100 psi, and a high alarm set at 3,000 psi that will prompt the PCC to remotely shut in the well; 7. Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 8. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 9. The next required MIT shall be completed before or during the month of May 2025. 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 June 2, 2023. Brett W. Huber, Sr Jessie L. Chmielowski Gregory C. Wilson Chair, Commissioner 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. Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2023.06.02 13:30:00 -08'00' Gregory Wilson Digitally signed by Gregory Wilson Date: 2023.06.02 14:22:37 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2023.06.02 15:05:57 -08'00' From:Carlisle, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 3C.006 (PBU) Date:Friday, June 2, 2023 4:08:39 PM Attachments:aio3C.006.pdf Docket Number: AIO-23-011 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Injection Prudhoe Bay Unit (PBU) W-20 (PTD 1880460), Prudhoe Bay Oil Pool Samantha Carlisle 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.carlisle@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.carlisle%40alaska.gov Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 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 3C.007 Mr. Torin Roschinger PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-24-003 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-14B (PTD 2060990), Prudhoe Oil Pool Dear Mr. Roschinger: By emailed letter dated January 11, 2024, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continuewater alternating gas (WAG) injection with a known tubing by inner annulus (TxIA) pressure communication. 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 WAG injection in the subject well. Hilcorp reported a potential TxIA pressure communication to AOGCC on December 28, 2023 when the well was on miscible gas injection. Hilcorp performed diagnostics and extended monitoring which confirmed the TxIA. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 3,212 psi) on December 31, 2023. This indicates that Z-14B exhibits at least two competent barriers to the release of well pressure. Hilcorp maintains live transmitters on the inner and outer annulus and alarm functions in the Supervisory Control and Data Acquisition (SCADA) system that create layers of protection from an over-pressure event. These inner and outer annulus alarms combined with the planned inner and outer annulus operating pressure limits enable AOGCC to continue to authorize gas injection. AOGCC believes Hilcorp can safely manage the TxIA communication with periodic pressure bleeds by maintaining the IA to a pressure not to exceed 2,100 psi and OA to a pressure not to exceed 1,000 psi. 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 WAG injection in PBU Z-14B is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; AIO 3C.007 February 6, 2024 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 MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,000 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 SCADA system; 6) Hilcorp shall maintain the Production Control Center (PCC) remote shut down capability for Z-14B when on gas or miscible injectant (MI) operation. During gas/MI injection, the IA protocols will include a drill site operator and PCC alarm set at 2,100 psi, and a high alarm set at a maximum of 3,000 psi that will prompt the PCC to remotely shut in the well; 7) Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 8) After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 9) The next required MIT shall be completed before or during the month of December 2025. DONE at Anchorage, Alaska and dated February 6, 2024. Brett W. Huber, Sr. Jessie L. Chmielowski Chair, 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. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.02.06 09:23:34 -09'00' Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2024.02.06 10:22:09 -09'00' From:Carlisle, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 3C.007 (Hilcorp) Date:Tuesday, February 6, 2024 10:46:49 AM Attachments:aio3C.007.pdf Docket Number: AIO-24-003 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-14B (PTD 2060990), Prudhoe Oil Pool Samantha Carlisle 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.carlisle@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.carlisle%40alaska.gov 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 3C.008 Mr. Torin Roschinger, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-023 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Prudhoe Bay Unit (PBU) Y-10B (PTD 2120210), Prudhoe Oil Pool Dear Mr. Roschinger: By emailed letter dated September 22, 2025, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water alternating gas (WAG) injection with a known tubing by inner annulus (TxIA) pressure communication. 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 WAG injection in the subject well. Hilcorp reported a potential TxIA pressure communication to AOGCC on April 3, 2025, when the well was on water injection. Hilcorp performed diagnostics and extended monitoring which confirmed the TxIA. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 2400 psi) on August 27, 2025. This indicates that Y-10B exhibits at least two competent barriers to the release of well pressure. Hilcorp maintains live transmitters on the inner and outer annulus and alarm functions in the Supervisory Control and Data Acquisition (SCADA) system that create layers of protection from an over-pressure event. These inner and outer annulus alarms combined with the planned inner and outer annulus operating pressure limits enable AOGCC to continue to authorize gas injection. AOGCC believes Hilcorp can safely manage the TxIA communication with periodic pressure bleeds by maintaining the IA to a pressure not to exceed 2,100 psi and OA to a pressure not to exceed 1,000 psi. Accordingly, the AOGCC believes that the well’s condition does not compromise overall well integrity so as to threaten human safety or the environment. AIO 3C.008 September 25, 2025 Page 2 of 2 AOGCC’s approval to continue WAG injection in PBU Y-10B is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; 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 MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,000 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 SCADA system; 6) Hilcorp shall maintain the Production Control Center (PCC) remote shut down capability for Y-10B when on gas or miscible injectant (MI) operation; 7) Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 8) After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 9) The next required MIT shall be completed before or during the month of August 2027. DONE at Anchorage, Alaska and dated September 25, 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. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.25 08:16:08 -08'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.25 15:10:45 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 3C.008 (Hilcorp) Date:Thursday, September 25, 2025 4:49:02 PM Attachments:AIO3C.008.pdf Docket Number: AIO-25-023 Request for Administrative Approval to Area Injection Order 3C: Water Alternating Gas Prudhoe Bay Unit (PBU) Y-10B (PTD 2120210), Prudhoe 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 INDEXES 14 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 10/14/2025 Commissioners – Jessie Chmielowski, Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Field, Prudhoe Oil Pool, W-35 (PTD #188033) Request for Cancelation of AIO 3C.002 Dear Commissioner Chmielowski and Commissioner Wilson, Hilcorp North Slope, LLC requests cancelation of AIO 3C.002 for well W-35 (PTD# 188033) dated 04/27/2020. This administrative approval was granted for continued WAG injection service with known inner annulus (IA) repressurization. On 09/19/2025, W-35 was rotary sidetracked and completed as W- 35A under PTD #225076. As part of this sidetrack the tubing was replaced and a new production packer set. The new well PTD is no longer relevant to the original AA, therefore the cancelation of AIO 3C.002 is requested. If you have any questions, please call me at 406-570-9630 or Oliver Sternicki at 907-564-4891. Sincerely, Torin Roschinger PBW Operations Manager Attachments Wellbore Schematic By Samantha Coldiron at 9:06 am, Oct 15, 2025 Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662) Date: 2025.10.15 08:17:28 - 08'00' Torin Roschinger (4662) 13 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 09/22/25 Commissioners – Jessie Chmielowski, Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Well Y-10B (PTD #212021). Request for Administrative Approval to allow WAG injection operations. Dear Commissioner Chmielowski and Commissioner Wilson, Hilcorp North Slope, LLC requests administrative approval to allow for WAG injection into Prudhoe well Y-10B with slow tubing x inner annulus (IA) communication. Y-10B was reported to the AOGCC to have suspected slow IA re-pressurization on 04/03/25 while on produced water injection (PWI). After an extended monitoring period due to the slow repressurization rate the well was placed under evaluation on 8/24/25. The maximum currently anticipated injection pressure for Y-10B is the PWI header pressure for Y-pad which is approximately 2050 psi. An AOGCC witness MIT-IA was conducted on 8/27/25 and passed to 2400 psi. Hilcorp North Slope, LLC has determined that well Y-10B is safe to operate in its current condition and requests administrative approval based on the following conditions: x IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. x Passing pressure test of the primary and secondary barriers. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 406-570-9630 or Oliver Sternicki at 907-564-4891. Sincerely, Torin Roschinger PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic By Samantha Coldiron at 11:52 am, Sep 23, 2025 Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662) Date: 2025.09.23 05:52:54 - 08'00' Torin Roschinger (4662) Prudhoe Well Y-10B Technical Justification for Administrative Approval Request 09/22/25 Well History and Status Y-10 was originally drilled and completed as a producer in July 1981 and converted to a water injector in 1991. The well was then CTD sidetracked to Y-10A in 2005 as a WAG injector and then rig sidetracked to its current Y- 10B location as a WAG injector in 2014. Y-10B was placed under evaluation in late 2018 for suspected slow TxIA communication while shut-in and the tubing stacked out to MI. Extended packing dummy gas lift valves were set to resolve the TxIA repressurization and the well was made operable again on 5/16/19. The AOGCC was initially notified of possible slow TxIA communication while on water injection on 4/3/25. After an extended monitoring period the well was placed under evaluation on 8/24/25 for slow TxIA communication on water injection. An AOGCC witnessed MIT-IA passed to 2400 psi on 8/27/25. Extended packing dummy gas lift valves were pulled and replaced in the well on 9/4/25, but continued monitoring shows that there is persistent slow TxIA repressurization while on water injection. Recent Well Events: 9/4/25 Extended packing DGLVs set. 8/27/25 AOGCC MIT-IA passed to 2400 psi. 8/25/25 PPPOT-T passed to 4850 psi. 8/25/25 Well placed Under Evaluation, AOGCC notified. 4/3/25 AOGCC initially notified of possible slow TxIA repressurization. 4/15/23 AOGCC MIT-IA passed to 2341 psi. Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing online pressure test conducted on 8/27/25 to 2400 psi, which tested both barriers, demonstrates competent primary and secondary barrier systems. Due to the low IA repressurization rate, no logging or further repair attempt is planned at this time due to the low likelihood of locating the leak point. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rates daily; 2. 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. Perform a MITIA every two years to the greater of the maximum anticipated wellhead injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4. Limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 5. Limit the well’s outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 6. Monitor the inner and outer annulus pressures in real time with SCADA system; 7. Maintain the PCC remote shut down capability for Y-10B when on gas or miscible injectant (MI) operation. 8. Immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 9. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; TIO/ Injection Plot Wellbore Schematic 12 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 01/11/2024 Chairman Brett Huber, Sr Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Well Z-14B (PTD #206099). Request for Administrative Approval to allow WAG injection operations. Dear Chairman Huber, Hilcorp North Slope, LLC requests administrative approval to allow for WAG injection into Prudhoe Bay well Z- 14B with slow tubing x inner annulus (IA) communication. Z-14B was reported to have slow IA re-pressurization on 12/28/23 while on Miscible Gas Injection (MI). The maximum anticipated injection pressure for Z-14B would be the maximum MI header pressure for Z-pad which is approximately 3,000 psi. An AOGCC witness MIT-IA was conducted on 12/31/23 and passed to 3,212 psi. Hilcorp North Slope, LLC has determined that well Z-14B is safe to operate in its current condition and requests administrative approval based on the following conditions: x IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. x Passing pressure test of the primary and secondary barriers. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 406-570-9630 or Oliver Sternicki at 907-564-4891. Sincerely, Torin Roschinger PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662), ou=Users Date: 2024.01.11 12:52:44 -09'00' Torin Roschinger (4662) Prudhoe Bay Well Z-14B Technical Justification for Administrative Approval Request 01/11/2024 Well History and Status Well Z-14B is a WAG injector that was originally drilled as an Ivishak producer in 1988. It was sidetracked in 1998 and again in August 2006. The well was converted to a WAG injector in November 2022 under Sundry 322-610. The well went under evaluation on 12/28/23 for IA re-pressurization and passed all diagnostics including an AOGCC witnessed MIT-IA to 3,212 psi with the well on online on 12/31/23. Recent Well Events: 11/30/22 Sundry 322-610 approved for WAG conversion 02/04/23 AOGCC witnessed Offline MIT-T passed to 3612 psi and MIT-IA passed to 3672 psi 02/10/23 Placed on MI injection 02/14/23 Online AOGCC witnessed MIT-IA passed to 3672 psi 12/28/23 Classified as Under Evaluation and reported to AOGCC for IA re-pressurization 12/31/23 Online AOGCC MIT-IA passed to 3212 psi 01/02/24 PPPOT-T passed to 5000 psi Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing online pressure test conducted on 12/31/2023, to 3,212 psi, which tested both barriers, demonstrates competent primary and secondary barrier systems. Due to the low IA repressurization rate, no logging or repair attempt is planned at this time due to the low likelihood of locating the leak point. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rates daily; 2. 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. Perform a MITIA every two years to the greater of the maximum anticipated wellhead injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4. Limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 5. Limit the well’s outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 6. Monitor the inner and outer annulus pressures in real time with SCADA system; 7. Maintain the PCC remote shut down capability for Z-14B when on gas or miscible injectant (MI) operation. 8. Immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 9. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; TIO/ Injection Plot Wellbore Schematic 11 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 05/02/2023 Chairman Brett Huber, Sr. Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Well W-20 (PTD# 188046). Request for Administrative Approval to continue WAG Injection Operations. Dear Chairman Huber, Hilcorp North Slope, LLC requests administrative approval for continued WAG injection into Prudhoe well W-20 with slow inner annulus (IA) leakage. WAG injector W-20 was found to have slow inner annulus pressure loss and was reported to the AOGCC on 4/27/2023 and placed under evaluation. There is no indication of tubing by inner annulus communication or inner annulus by outer annulus communication based on pressure trends. The well had a passing AOGCC witnessed online MIT-IA on 05/1/2023 to 3454 psi which confirms both the primary and secondary well barrier integrity. Hilcorp North Slope, LLC has determined that well W-20 is safe to operate in its current condition and requests an AA for WAG injection based on the following: x MIT-IA passed to 3454 psi. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 907-564-4887 or Oliver Sternicki at 907-564-4891. Sincerely, Torin Roschinger PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662), ou=Users Date: 2023.05.03 10:46:36 -08'00' Torin Roschinger (4662) Prudhoe Well W-20 Technical Justification for Administrative Approval Request 05/02/2023 Well History and Status Well W-20 was originally drilled as a producer in June 1988 and converted to a WAG injector in August 2003. The tubing was replaced during a RWO in May 2004 due to failing tubing pressure tests. Prior to the recent discovery of the IA pressure anomaly on W-20, the most recent AOGCC witnessed MIT-IA passed to 2430 psi on 08/14/2020. On 04/27/2023, W-20 was found to have slow IA pressure loss and was reported to the AOGCC and placed under evaluation. Based on analysis of the annulus and tubing pressure trends the IA does not appear to be in communication with the tubing or the OA. An AOGCC witnessed MIT-IA passed to 3454 psi on 05/01/2023. Recent Well Events: 05/01/2023 AOGCC witnessed MIT-IA passed to 3454 psi. 04/27/2023 IA pressure leakage flagged and notification sent to the AOGCC. 02/27/2023 PPPOT-IC passed to 3500 psi. 08/14/2020 AOGCC witnessed MIT-IA passed to 2430 psi. Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing pressure test of the inner annulus to 3454 psi on 05/01/2023, which tests both barriers, demonstrates competent primary and secondary barrier systems. No further diagnostics/ repair will be pursued at this time due to the low likelihood of being able to determine the leakage point based on the low fall-off rate. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rates daily; 2. 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. Perform a MITIA every two years to the greater of the maximum anticipated wellhead injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4. Limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 5. Limit the well’s outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 6. Monitor the inner and outer annulus pressures in real time with its SCADA system; 7. Maintain the Production Control Center (PCC) remote shut down capability for W-20 when on gas or miscible injectant (MI) operation; 8. Immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 9. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; TIO/ Injection Plot Wellbore Schematic Hilcorp North Slope, LLC Stan Golis, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 01/05/2022 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Well W-44 (PTD# 189100).Request for Administrative Approval to continue PWI Operations. Dear Mr. Price, Hilcorp North Slope, LLC requests administrative approval for continued PWI into Prudhoe Bay well W-44 with slow tubing x inner annulus (IA) communication. PWI W-44 was found to have slow tubing x inner annulus pressure communication and reported to the AOGCC on 12/13/2021 at which time the well was placed under evaluation. A passing pack off test on the tubing test void on 12/16/21 demonstrates integrity of the wellhead seals. The well had a passing AOGCC witnessed online MIT-IA on 12/18/2021 to 2075 psi which confirms both the primary and secondary well barrier integrity. Hilcorp North Slope, LLC has determined that well W-44 is safe to operate in its current condition and requests an AA for PWI based on the following: x MIT-IA passed to 2075 psi. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 907-777-8356 or Ryan Holt/ Andy Ogg at 659- 5102. Sincerely, Stan Golis PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic Digitally signed by Stan Golis (880) DN: cn=Stan Golis (880), ou=Users Date: 2022.01.06 15:45:43 -09'00' Stan Golis (880) Prudhoe Bay Well W-44 Technical Justification for Administrative Approval Request 01/05/2022 Well History and Status Well W-44 is PWI that was originally drilled in October 1989. W-44 was initially on gas injection but was converted to water injection in 2001. Prior to the recent discovery of the IA pressure anomaly on W-44 the most recent AOGCC witnessed MIT-IA passed to 2267 psi on 08/08/2021. On 12/13/2021 W-44 was found to have slow tubing x IA pressure communication and was reported to the AOGCC and placed under evaluation. An AOGCC witnessed MIT-IA passed to 2075 psi on 12/18/2021. Recent Well Events: 12/18/2021 AOGCC witnessed MIT-IA passed to 2075 psi. 12/15/2021 PPPOT-T Passed to 5000 psi 12/13/2021 TxIA pressure communication noted and notification sent to the AOGCC 08/08/2021 AOGCC witnessed MIT-IA passed to 2267 psi Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing pressure test of the inner annulus to 2075 psi on 12/18/2021, which tests both barriers, demonstrates competent primary and secondary barrier systems. No further diagnostics/ repair will be pursued at this time due to the low likelihood of being able to determine the leakage point. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rate daily. 2. Submit a report monthly of well pressures and injection rates to the AOGCC. 3. Perform a 2-year MIT-IA to 1.0x maximum anticipated injection pressure or 0.25 x packer TVD, whichever is greater. 4. IA MOASP= 2100 psi, OA MOASP= 1000 psi 5. The well will be shut-in and the AOGCC notified if there is any change in the wells mechanical condition. 6. After well shut-in due to a change in the well’s mechanical condition, AOGCC approval shall be required to restart injection. TIO/ Injection Plot Wellbore Schematic By Samantha Carlisle at 10:25 am, Oct 13, 2021 Digitally signed by Stan Golis (880) DN: cn=Stan Golis (880), ou=Users Date: 2021.10.13 10:18:51 -08'00' Stan Golis (880) LV LW \ V & Hilcorp North Slope, LLC Stan Golis, PBW Operations Manager 3800 Centerpoinl Dr, Suite 1400 Anchorage, Alaska 99503 RECEIVED By Grace Salazar at 2:16 pm, Jun 29, 2021 06/29/2021 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West 7'h Avenue Anchorage, Alaska 99501 Subject: Prudhoe Well N-01A (PTD# 204113) Request for Administrative Approval to continue WAG Injection Operations Dear Mr. Price, Hilcorp North Slope, LLC requests administrative approval for continued WAG injection into Prudhoe well N-01A with slow tubing by inner annulus communication. No increase to Maximum Operating Annulus Surface Pressure (MOASP) is required. N-01A was flagged on 06/21/2021 as having possible slow TxIA communication while on MI and was placed under evaluation at which time it was reported to the AOGCC. To confirm the primary and secondary barriers a passing AOGCC witnessed MIT -IA was conducted on 06/25/2021 to 3231 psi while on MI. Hilcorp North Slope, LLC has determined that well N-01A is safe to operate in its current condition and requests an AA for continued WAG injection based on the following: • IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. • MIT -IA passed to 3231 psi. • IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 907-564-5231 or Ryan Holt/ Andy Ogg at 659- 5102. Sincerely, P t4'�- ' `' Stan Golis� PBW Operations Manager h Attachments Technical Justification TIO/Injection Plot Wellbore Schematic Prudhoe Well N-01A Technical Justification for Administrative Approval Request 06/29/2021 Well History and Status Well N-01A is a WAG injector that was originally drilled in July 1970, worked over in August 1987 to repair damaged thermocase and sidetracked in August 2004. N-01A was flagged on 06/21/2021 as having possible slow TxIA communication due to increased IA pressure and subsequently bleeding off a small amount of gas from the IA while the well was on MI. At that time N-01A was reported to the AOGCC and placed under evaluation. A PPPOT-T passed on 06/21/2021 to 5000 psi and to confirm the primary and secondary barriers a passing AOGCC witnessed MIT -IA was conducted on 06/25/2021 to 3231 psi while on MI. Based on the very slow repressurization rate of the IA it is unlikely that a leak detection log would be able to locate the communication point so no further diagnostics are planned at this time. Recent Well Events: 06/25/2021 AOGCC witnessed MIT -IA passed to 3231 psi. 06/21/2021 PPPOT-T passed to 5000 psi while on MI. 06/21/2021 IA pressure anomaly noted and reported to AOGCC. 10/08/2018 AOGCC witnessed MIT -IA passed to 2546 psi. Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing pressure test of the inner annulus to 3231 psi on 06/25/2021, which tests both barriers, demonstrates competent primary and secondary barrier systems. No further diagnostics/ repair attempts are proposed at this time due to the low probability of success in being able to locate the communication point based on the low leak rate. Pressure on the inner annulus will be maintained below MOASP of 2100 psi when the well is on-line with periodic bleeds of the IA. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rate daily. 2. Submit a report monthly of well pressures and injection rates to the AOGCC. 3. Perform a 2-year MIT -IA to maximum anticipated injection pressure. 4. IA MOASP= 2100 psi, OA MOASP= 1000 psi 5. The well will be shut-in and the AOGCC notified if there is any change in the wells mechanical condition. 1310 )� $ y `f 2 I ) \� ..,|, ! �....l. § Wellbore Schematic TFFI - 4• GN V.fi1N-A0= LtEVOV ARLLSTOR= M RC KO HLV = fi21O RL ❑ , = 43.19 KOP- 3800 44.A,pb= 66•@621r DMM3- war r1W Wo= flow S3 /33Ar c9O, 669. K-55. D-/2 H5• W - TM 'T"m 9) - 9.tt" Q 9186 4UYCRIER RESTRICTION o-5ro•NwsTocK 7a/s• _- 9-50.4Y.G6A61• -7316' H#OMTION SLIAVJTY 163 LOG. SWS WIM ON IONV70 (N0111 AK EATTOPRW 6r@93W Mo lilw M Po.WnOB W Ms Ml POO 440 SIZE SPF N162VAL SNDT I WE I S02 T-3—ff 6 9355.9375 O 07J2506 2-7Ar 8 9000-9394 O 0426'O6 2-Tar B sm-9420 O 09n604 2.7xr 6 9394.9417 O 00Ji6A16 2.7Ar 6 9430-9455 O 09J21A4 N -01 A SAfE OCkA I S:...000A 1W91440 CMMAl( IMTOODA 1200 P61'•' •••4-1d' OfROME 113Q'• 3.72• m NOLE ST (0M ?) 922W GAS LFT WAIa13.S 2 FM7906 527 0 JIIM� KBG2 � I SKBIC I 0 jollsw O80OL94 OVIVID Ir NC LIA MCR O.626r MILLOUTWENDOW 1316'•7aa2' PRL6NDE 8AY my WELL "IA PEM.9T Wo/2041130 AP W 50O29-MM4)l N , Pdom Slope." 95r THE STATE °fALASKA GOVERNOR MIKE DUNLEAVY October 2, 2020 Mr. Oliver Sternicki Well Integrity Engineer Hilcorp North Slope, LLC. 3800 Centerpoint Drive Anchorage, AK 99503 Re: Docket Number: AIO-20-005 Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.olaska.gov Request to amend the maximum allowable inner annulus operating limits on injectors which operate under existing administrative approvals. Area Injection Orders 3C, 4G, 22F, and 24B Prudhoe Bay Unit (PBU) Dear Mr. Stemicki: By letter dated March 9, 2020, BP Exploration (Alaska) Inc. (BPXA) requested administrative approval to change the inner annulus (IA) maximum operating pressure on 36 wells. This was requested in parallel with a BPXA request to increase the IA operating pressure for producing wells under Conservation Order CO 492. After the initial request was received from BPXA, Hilcorp North Slope, LLC (HNS) acquired BPXA North Slope assets July 1, 2020 and became operator of the PBU. On July 29, 2020, AOGCC received an email from HNS stating "Hilcorp, as the new operator of the BPXA assets has reviewed and approve of the submitted request to the AOGCC pertaining to increasing IA NOL in GPB." AOGCC issued CO 492A on October 1, 2020 that increased the notification IA operating pressure from 2000 psi to 2100 psi for PBU wells not processed through the Lisburne Production Facility. In accordance with Rule 9 of Area Injection Order (AIO) 4G and 24B, Rule 10 of AIO 3C, and Rule l I of AIO 22F, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS HNS's request for administrative approval to change the maximum IA operating pressure for the 36 wells to 2100 psi as detailed in the accompanying table. The administrative action rules contained within the Area Injection Orders allow the AOGCC to administratively waive or amend the requirements of any rule as long as the change does not promote waste of jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. DONE at Anchorage, Alaska and dated October 2, 2020. Jeremy IM,M'IAPfice M. Price L1,:1Bm9P Jeremy M. Price Chair, Commissioner Daniel T. YumvM1p Seamount, Jr.mSp10O:ox,w: Daniel T. Seamount, Jr. Commissioner Jessie L. r.an,mi°w,u Chmielowski mrr°xv°m Pcasar Jessie L. Chmielowski Commissioner 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 sball 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 m 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 gnums 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 my 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 ofthe event or default after which the designated period begins to tun 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 sate holiday. AIO # PTD Well AA Date AA mandated max IA pressure (psi) New AA mandated max. IA pressure (psi) 3C.001 1710380 A-03 12/19/2019 2000 2100 4E.024 1750690 RG q/29/2007 2500 2100 4E.032 1760140 NGI-05 6/9/2008 2500 2100 4F.002 1810740 17-08 4/3/2015 2000 2100 4G.009 1811770 11-07 12/12/2019 2000 2100 4F.006 1820260 13-17 12/7/2015 2000 2100 4F.008 1831700 14'27 5/23/2016 2000 2100 4G.001 1840280 09'25 8/2/2016 2000 2100 3B.001 1880700 W 24 3/15/2016 2000 2100 4E.017 1931850 14-01 2/21/2007 2000 2100 40130 04-43 4/6/2017 2000 2100 61440 X-33 4/11/2016 2000 2100 72180 73-06 7/9/2015 2000 2100 82060 W19912250 R-11 1/25/2017 2000 2100 2140 5-25 10/2/2015 2500 2100 90530 5-11 3/6/2018 2000 2100 1250 X-24 8/2/2016 2000 2100 4E.020 1991310 17'15 3/17/2007 2000 2100 3.025 2000090 N-08 1/14/2011 2000 2100 3.029 2001570 6-22 4/28/2010 2000 2100 22F.001 2011130 S-107 1/7/2020 2000 2100 4F.001 2021240 PSI -09 3/6/2015 2000 2100 3.015 2051380 P-06 3/13/2007 2000 2100 4G.003 2051600 13-31 9/1/2016 2000 2100 36.006 2061050 2-19 2/14/2017 2000 2100 3B.009 2080930 V-05 11/14/2018 2000 2100 4E.039 2091390 03-37 9/6/2011 2000 2100 38.002 2101010 5-41 8/2/2016 2000 2100 24B.006 2111240 2-116 3/5/2019 2000 2100 4G.008 2141640 R-22 2/15/2018 2000 2100 3.03 2150660 P-10 9/11/2015 2000 2100 3C.002 1880330 W-35 4/27/2020 2000 2100 4G.008 2141640 7/23/2020 2000 2100 4G.008 2141650 R'22A1-1 7/23/2020 2000 2100 4G.010 2021450 PSI -01 8/10/2020 2000 2100 4G.011 2050200 17-13A 8/10/2020 2000 2100 Bernie Karl Gordon Severson Richard Wagner K&K Recycling Inc. 3201 Westmar Cir. P.O. Box 60868 P.O. Box 58055 Anchorage, AK 99508-4336 Fairbanks, AK 99706 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 BP Exploration (Alaska) Inc. Ryan Daniel, Well Integrity Engineering Team Lead Post Office Box 196612 Anchorage, Alaska 99519-6612 March 9, 2020 LLILIVED Mr. Jeremy Price MAR 0 9 2020 Alaska Oil and Gas Conservation Commission /'� 333 West 7th Avenue AI,JGCC Anchorage, Alaska 99501 Subject: Request to amend defined inner annulus normal operating limits on injectors operating under administrative approval. Dear Mr. Price, BP Exploration (Alaska) Inc. requests an amendment to the injection well administrative approvals listed in Table 1 such that the inner anulus (IA) normal operating limits (NOL) are changed to 2100 psi. The request to amend the IA NOLs of the wells listed in Table 1 is in parallel with a request to amend CO 492 such that IA NOL can be increase to 2100 psi for the majority of development wells in the Prudhoe Bay field. For consistency across the field the intent is to change IA NOL for all injection wells excluding: Class I disposal wells, Lisburne Injection wells, Well 09-16 (PTD: 1770370). Upon review of the AIOs governing Class II injection wells operated by BPXA there is no defined IA NOL except in the case of some select administrative approvals that have been granted. These defined IA NOLs are listed in Table 1. ORIGINAL Table 1: Administrative Approval List If you have any questions, please call me at 564-5430 Sincerely, Ryan Daniel BPXA Well Integrity Team Lead Attachments: Technical Justification 3C.001 1710380 A-03 12/19/2019 2600 2006 4E.024 1750696 NGI-04 4/29/2007 2500 2006 4E.032 1760140 NGI-05 6/9/2008 2500 2066 4F.002 1810740 17-08 4/3/2015 2000 2000 46.009 1811770 11-07 12/12/2019 2000 2000 4F.006 1820250 1317 12/7/2015 2000 2000 4F.008 1831700 14.27 5/23/2016 200D 2000 4G.001 1846280 0525 8/2/2016 200D 2000 38.001 1680700 W-24 3/15/2016 2000 2000 4E.017 1931850 14-01 2/21/2007 2000 2DD6 46.006 1940130 INF43 4/6/2017 2000 2000 4F.007 1%1440 X-33 4/11/2016 2000 2000 4F.004 972180 13-06 7/9/2015 2000 2000 3.024 1982066 R-11 1/25/2017 2600 2600 4F.005 1982140 5-25 10/2/2015 2500 2000 38.008 990530 5-11 3/6/2018 2000 2000 38.003 1991250 X-24 8/2/2016 2000 2000 4E.020 1991310 17-15 3/17/2007 2000 2000 3.025 2000090 N -D8 1/14/2011 200D 2000 3.029 26D154 B-22 4/28/2010 2006 2000 22F.001 11136 5-10' 1/7/2020 2006 2000 4F.001 1240 PSI -09 3/6/2015 20DD 2000 3.015 1386 P-06 3/13/2007 2000 2000 G.003 1600 13-31 9/1/2016 2600 2000 36.006 2061650 2-15 2/14/2017 200D 20DD 38.009 v-05 11/14/2018 2000 2000 4E.039 1390 3-37 9/6/2011 2000 2000 38.002 161010 5dt 8/2/2016 2000 2000 246.006 111240 2-116 3/5/2019 2000 2000 4G.008 - 141640 R-22 2/15/2018 2000 2060 3.03 50650 P-10 9/11/2015 2000 2000 If you have any questions, please call me at 564-5430 Sincerely, Ryan Daniel BPXA Well Integrity Team Lead Attachments: Technical Justification Technical Justification for Administrative Approval Amendment March 9, 2020 History and Status: BPXA is currently in the process of requesting an amendment to Conservation Order No. 492 rule 3(a) and 6(a) (Docket Number: CO -20-004) to facilitate the increase of IA NOL to 2100 psi for Prudhoe Bay field development wells excluding those processed through the Lisburne Processing Center and jet pump wells based on the following. Gas lift header pressure at many of the drill sites and pads in the Prudhoe Bay field (excluding wells processed through the Lisburne Process Center) regularly exceeds the 2000 psi IA NOL set for development wells. Gas lift compressor outlet pressures are commonly set at 2100 psi. Historical gas lift pressures can be seen in Figure 1 & 2 for reference. The legacy IA NOL value of 2000 psi was set to remain compliant with Conservation Order No. 492 rule 3(a) and 6(a). Prior to the installation and monitoring of wireless annulus pressure gauges this was not as large of a problem due to one IA pressure read being recorded via mechanical gauge daily per well. If a pressure read exceeded the 2000 psi NOL it was reported to Well Integrity and evaluated to determine if the excursion was SCP or not. Currently all wells in the Prudhoe Bay field have the inner annulus pressures monitored in real-time by either the EOA or WOA production center board operators. The board operators are notified with an alert when the IA pressure of a well exceeds the set NOL value of 2000 psi. This ensures a timely notification and response to any potential excursion event. With the utilization of the wireless annulus pressure gauge alerting it has become an ongoing problem where wells supplied with gas lift pressure are regularly setting off alerts due to the gas lift supply pressure exceeding the 2000 psi NOL and not due to SCP as intended. This excessive alerting has the potential to desensitize workers to possible hazardous occurrences. Increasing IA NOL from 2000 psi to 2100 psi for development wells would eliminate the majority of these false NOL excursion alerts and allow resources to be more focused on response and evaluation of probable SCP events. All development wells are included in this request in an effort to reduce the complexity of the IA NOL change and management across the Prudhoe Bay field. This reasoning for reduced complexity in management of IA NOLs extends to injection wells in the Prudhoe Bay field. Alignment with the change applied to development wells is important to minimize variability of IA NOLs and simplify the management of all wells. The majority of injection wells in the Prudhoe Bay field currently have IA NOLs set to 2000 psi. This 2000 psi NOL was applied by BPXA for consistency across the field and is not tied to a requirement in an Area Injection Order other than for specific Administrative Approvals on individual wells listed in Table 1 which is what BPXA is requesting amendment to. The intent is to change IA NOLs for all injectors to 2100 psi excluding Class I disposal wells, Lisburne Injection wells and Well 09-16 (PTD: 1770370). This increase of 100 psi to the IA NOL is well within the design parameters of injection wells across the Prudhoe Bay field and the IA NOL increase would not reduce the ability to identify possible annular communication in these wells. Figure 1- EOA DS Gas Lift Header Pressure EOA Gas Lift Pressure as x 3i!z/m�s 3.6DJ Ol mumis 3/lnoa 6/xnROvs 6/9/3016 9RUm13 z4v1/1a1 UErxm6 va. Figure 2- WOA Pad Gas Lift Header Pressure WOA Gas Lift Pressure zlzuml6 s/uzms 611mm15 t lir � 9)9/."013 9/R4ID35 C.b V.n.6 —osoz —D303 —0305 —0301 —0309 —OS 11 —0313 —m vs —D316 —nP, —eP.a i P. —oPm —uP.e —xP,e P P.9 —SVtl —uove a wP.e li XP� NE P.9 BP Exploration (Alaska) Inc. by Oliver Sternicki, Well Integrity Engineer Post Office Box 196612 Anchorage, Alaska 99519-6612 0 April 16, 2020 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West 711 Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Well W-35 (PTD # 188033) Request for an Administrative Approval for WAG Injection Operations Dear Mr. Price, BP Exploration (Alaska) Inc. requests Administrative Approval (AA) to continue water alternating gas (WAG) injection into Prudhoe Bay well W-35 with known inner annulus (IA) repressurization. No increase to IA normal operating limit (NOL) is required. Well W-35 was identified as having anomalous IA repressurization in April 2020. The repressurization rate is approximately 8 psi/day. In preparation for the administrative approval request, an online MIT -IA passed to 3,056 psi on 04/10/20. The AOGCC Inspector waived witnessing the test. Wireless gauges have been installed on W -pad wells that allow for real time monitoring of IA and OA pressures. BPXA has determined that well W-35 is safe to operate in its current condition and requests an AA for continued WAG injection based on the following: • IA pressure can be maintained below NOL by managing the IA repressurization with periodic annular bleeds. • MIT -IA passed to maximum anticipated injection pressure. • IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 907-350-0759 or Ryan Holt/Adrienne McVey at 659-5102. Sincerely, Oliver Sternicki Digitally signed by Oliver Sterril l Date: 2020.09.3212:08:18-0890' Oliver Sternicki BPXA Well Integrity Engineer Attachments Technical Justification TIO Plot Injection Plot Wireless Gauge Plot Wellbore Schematic Prudhoe Bay Well W-35 Technical Justification for Administrative Approval Request April 16, 2020 Well History and Status Well W-35 (PTD# 188033) previously operated on produced water injection only under AIO 3.027 for known TxIA communication on MI, granted 05/13/09. This TAA communication was found to be at the SSSV Nipple (1983' MD) and a patch was set over the leak to repair on 07/16/09. An AOGCC witnessed MIT -IA to 4000 psi passed on 09/12/09 and AIO 3.027 was canceled on 01/03/11 after cycling the well between produced water and MI with no apparent pressure communication between the tubing and IA. The tubing patch was pulled on 07/27/15 to facilitate a coiled tubing fill clean out and reset on 06/03/16. In April of 2020 Well W-35 was identified as having anomalous IA repressurization of —8 psi/day. An online MIT -IA passed to 3,056 psi on 04/10/20 (AOGCC waived witness), and a PPPOT-T passed on 04/11/20. Due to the low leak rate, and the low probability of successfully locating and repairing the leak, BPXA does not plan to pursue further leak diagnostics at this time. Wireless gauges are installed on Well W-35 and allow for real time monitoring of IA and OA pressures. Recent Well Events: 04/11/20 PPPOT-T passed. 04/10/20 Online (AOGCC witness waived) MIT -IA Passed to 3056 psi. 04/07/20 Well Under Evaluation for anomalous IA repressurization. 10/30/19 Placed on MI. 12/07/17 AOGCC witnessed MIT -IA passed to 2261 psi. 06/03/16 Patch reset. 07/27/15 Patch pulled for coiled tubing FCO. 04/14/11 Placed on PWI. 01/03/11 AIO 3.027 canceled. 09/20/09 Placed on MI injection with AOGCC permission to evaluate for IA repressuization post patch install. 09/12/09 Online AOGCC witnessed MIT -IA Passed to 4000 psi. 07/16/09 Patch set across SSSV Nipple (1983' MD) to repair TxIA comm. 05/13/09 AID 3.027 granted for PWI only due to TxIA repressurization on MI. On PWI Injection. Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing MIT -IA to 3056 psi on 04/10/20 demonstrates competent primary and secondary barrier systems. Pressure on the inner annulus will be maintained below the normal operating limit of 2000 psi when the well is on-line. Proposed Operating and Monitoring Plan 1. WAG injection (including MI). 2. Record wellhead pressures and injection rate daily. 3. Submit a report monthly of well pressures, injection rates and bleeds to the AOGCC. 4. Perform an MIT -IA to maximum anticipated injection pressure every 2 years. 5. The well will be shut-in and the AOGCC notified if there is any change in the well's mechanical condition. r : 8D0e■ 5 e e e a o 0 0 0 o e e e e e o o a e a o 5 {F�6Fu$o Illllli M11UIM! IYi dlW TIS: 41718 CW SAFETY NOTES: HU WADLNOS AVIPAGE 125 ppm LWaIwLD- IIII W35 AcnATOR= SAKERC rY J - WNW ON MI. WELL REOUARE3 ASSSVWHERON [Me. KB. BEV = WAS W ELFV = 5433' -_. -- -- 16]9'•197r 1s 0066101 FLOGAL{DMTd/wn-79- NOP= 3200 -M;g %NP, RLR D-2A8-(060MG) 1IAr1Sb= BOW De{oMD= 10218' 1951' 2-79'%MNFNIdITALI'S�D=2.31 7' O{mND= BBDO SS 1993' z-778• NA �F1D� D=x.13• 1967' Cllr OTb no 58SV W,, 10.3.813— /3310'C6Q Se{, L-SO,D•ix.HS' 2182'_ GAS LST&VI 6T MD ND DEV IYIE VlV U701 FORT 481E e 2021 x33 s DTs ox wA 7 s71s 5249 37 DTs DL/ RA 6877 e eES1 0048 35 DTs DW RA Minimum ID = 2.313" @ 1981' 5 727! 8481 34 016 OW 2-7/8" HES X NIP IN PATCH ew7 floo b rns Dltr wA x 8170 eD+4 a DTs 943r I 4 O= XA%A"SLV.D• SHS'f T00SEAL ASSY x123 SSS{' S-LS X4412'71W 008688 PKR,D•I.0 TIbNG R7'%3110N1596t 9666'-6661. RA 0668' 417!016% NP, D=3.013• 967r cTTA 'ATR►lL®{rvs1®tm6ens� 9691' 4VYDTB%NNP, D• 3725' 1FT', /2.48, L-S0. ft23' .01626p1, D•30fis' 11:52 9623' 4/n'TBOTAL,D=3.858' T17POF 7'LMt 9163' 9626' d1OTi LOGG®08D791 4618' CS4 470, LaO, D • 6801' 9501' IODiT 4NR®t.f00/7 F6SORATDN SLS&%RY REF LOG: BHCS ON M01A48 ? FSH-1•in'TB F7406t112/1398) ANGLEATTOPFEW 348®10513 hbl� Refer b RoduCbn ici pM dab 1030T FSH- FWt RESER SEE SPF N(62VADATE 51 5 10312 -10012995 3-W 8 10316 - 103060695 3-39- 6 10335 - 1030172ON5 3-39• 6 10346 - 103OSM5953-38• 6 10364-103050059'5S-SW 100SM5195 4 10400-1004am3-W 4 10430-100411W 169777'LMk2W.L-W.0.03838• 19620' DALE REV 6Y COWENB DATE fEV6Y CONIENIS PRW110E 611YL1Mf WiOFIF1 DRV OILAiMAL Cfi1�LElNM1 OSHT96 NDBV TUSSID PUNCN SRS YeELL WK Oigl�Ot RNRP COWIECIDNS 10800/6 RCF/ILH PA7CNPlAII]] 27/16 PE ffw:.1630330 D5DIM'SV�C7RH FBH 102780 SWTLH F6IWLWYl1ED S APIN• 50@¢2118945 •, 003D9e 1(J6ISV 6ETPAlCH(D7/i6O8) 08,0{'18 DB1A10 BET PAWH•61NP{w•cmrl= 6EC21,T11N.R12E, 1251'fiNL{1151'AEL DN1d11 ld U D ADDED SSSV 6AFETYNME 0100!90 CJNAIYD CORREC7DN W e1D BLV L0120+12;1MW.le48 ADDED H25 SAFEIYM7IE _ WEp°�°A(�•) RA ♦ 7806 6877 3• 016 DNf RA 3 ew7 7408 b rns Dltr wA x 8170 eD+4 a DTs L1K RA 9327 x123 uO1sOw RA K BP Exploration (Alaska) Inc. Attn: Well Integrity Coordinator, PRB-20 Post Office Box 196612 Anchorage, Alaska 99519-6612 December 16, 2019 Mr. Jeremy Price Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Unit Well A-03 (PTD # 1710380) Request for Administrative Approval to Continue Water Injection Dear Mr. Price, BP Exploration (Alaska) Inc. requests approval for continued water injection operations into Prudhoe Bay well A-03 (PTD #1710380). The well exhibits tieback liner by production casing communication that was previously reported as IAxOA. A combination pressure test of the two annuli passed to 2,500psi proving competency of the primary and secondary well barriers. Due to the unique well completion it is requested that the annuli previously reported as the inner and outer annulus be considered a single annulus with all future reporting referring to this as the inner annulus. This annulus operates below the maximum allowable pressure limit and does not require frequent bleeds. Consequently, no repairs are planned at this time. If you have any questions, please call me at 564-5430 or Josh Stephens/ Andy Ogg at 659-8110. Sincerely, Ryan, Daniel BPXA Well Integrity & Compliance Team Leader Attachments: Technical Justification TIO Plot Injection Plot Wellbore Schematic ORIGINAL DEC 16 _19 A0G1 rf% � Prudhoe Bay Well A-03 Technical Justification for Administrative Approval Request December 16, 2019 Well History and Status Prudhoe Bay PWI injection well A-03 (PTD #1710380) exhibits annuli communication between a shallow set 9-5/8" tieback casing string and the 13-3/8" production casing string. The annuli communication was originally reported to the AOGCC April 18, 2012 and permission to continue injection operations was granted on the same day. Subsequent AOGCC MIT reporting has resulted in confusion on the barrier status of the well and on November 15, 2019 the AOGCC requested that an Administrative Approval be pursued for future clarification. The well has no other know mechanical integrity issues. Recent Well Events: > 11/17/19: AOGCC CMIT-IAxOA Passed to 1,966psi > 12/09/18: Bleed OA for UIC > 05/03/17: Bleed OA for UIC > 11/22/15: AOGCC CMIT-IAxOA Passed to 2,500psi > 06/09/12: Leak path evaluation of IC hanger passed with primary seal integrity > 04/17/19: CMIT-IAxOA Passed to 2,500psi > 01/09/12: MIT -T Passed to 2,500psi > 12/20/11: AOGCC MIT -IA passed to 2,500psi Barrier Evaluation The primary barrier envelope consists of 7" x 5.5" production tubing with the production packer set at 9,343' MD (7,085 TVD). The secondary barrier envelope consisted of 13- 3/8" x 9-5/8" casing with the 9-5/8" casing shoe set at 10,022' MD. A 9-5/8" Tieback liner was run in 1989 to replace a thermocasing string that was part of the original completion. The tieback liner is between the production tubing and production casing and terminates at the 9-5/8" x 13-3/8" cross over in the production casing at 1,998'. The tie back liner x production casing annulus has been traditionally considered an outer annulus and maintained integrity until early 2012. In March of 2012 pressure communication was observed across the tie back liner. Diagnostic pressure testing performed on 4/17/2012 proved competency of secondary barrier via a passing CMIT- IAxOA to 2,500psi. Subsequent regulatory MITs have been done via CMIT-IAxOA. Proposed Operating Plan Record wellhead pressure and injection rate daily. The annuli created by the tieback liner by production casing will be reported as the inner annulus. The annuli created between the surface casing and production casing will be reported as the outer annulus. F, 3. Perform a 4 -year MIT -IA to 1.1 times the maximum anticipated injection pressure. During the pressure test the annuli created by the tieback liner will be tied together at the wellhead. The well will be shut -n and the AOGCC notified if there is any change in the well's mechanical condition. Prudhoe Bay Well A-03 TIO Plot Well. A-03 51K Prudhoe Bay Well A-03 Injection Plot Well A-03 TIO Plot 200 f Tbg 11:2411° ...- - —1^MIP pr! 611 — GI — — Other — On ■ IA 150 0 —4 IA a a OA 0 iCQ e _ On 50 ■ Bleed Operable t Not Oper ♦ Under Eval Temperature 11:2411° ...- - —1^MIP pr! 611 — GI — — Other — On 1. Eli1l = H FV = A-03 SAEET7• NOTES: I= RE, NGSSSS AVENGE 176 ppm WNE1 ON ML WELL REO(ARES A V WHEN ON M L Nfl.L0ONY-0M'A 11 E0rA3CN SLFSONT£95!0' CSG DONT FWS9JRE TEST TIE9-5;'8'II WERFORI I3(rcc xmit I 100' OVER F'SL g hew D- 11740 �IS fig*( . D' SS VM.- fl80%.58, K-558115. u v w5- 550• TFTNOH I W 470 680 K'Cf.. 0772 by!, 9) BCAI- 1118•CSli. 71/(N80ul .0 12347' 2P O 1330 K 55 SW U - 18 150 - -TBG, 250, IMS. L-80. 0.783 bpf D 1341' 1 I4E LUG, O31.L ON19BS ANOLEATT0PRJ4f 30'(911640 tale Ref" b P r .Eon lB fm Mlorcdl pod Acta SIZE SFF NTMAI 13W 129' x 166f0•XO. L) IIGtS' I 1810' 13316-Xw&w Tw PAR v RFHK 5LV, 0-9� H S07 }318' 4 11&0-11670 O 07079/80 10� �65JP W11797W 179UL WPL U -t 19� rU1Fi'FCl SssIftw U-5%7 1 01A)SW 1 6Y8' 4 1178611808 S 059799 3.ya 4 11816-1187D S 059799 r1412• HRO N51". 1)-3013(07N91891 1998' 11880 IWO S 05017/99 T_ — 19911�- I1341'x 94A•xn n -Amt• S MA799 3-316' 4 11918 - 11936 S 20/8' 7187' 713P 5S9'cac Minimum ID - 3.813"@ 1996' '4-12" HRQ SSSV INSERT I(%'tA r i nit 1 9823' 51/7 TUG,l ft. L SO IL'AS, 4232 bpf, 13 - 4 897 1 19-Sf8' MONO. NIU. SLAL LOOT, 0773w.U-8681' FEWMATICN SUAMA W I4E LUG, O31.L ON19BS ANOLEATT0PRJ4f 30'(911640 tale Ref" b P r .Eon lB fm Mlorcdl pod Acta SIZE SFF NTMAI C .Gw SHOT S07 }318' 4 11&0-11670 O 07079/80 3-YB' 4 11721 - 11186 O 01A)SW 6Y8' 4 1178611808 S 059799 3.ya 4 11816-1187D S 059799 }W 4 11880 IWO S 05017/99 3-3q4 4 11915 11928 S MA799 3-316' 4 11918 - 11936 S 08/1290 FUTG r Lw M. N W. SEAL LOLL( 0371 Ep1, U - 5 184' •`9791--I5 12•oT15 SLD SLy. U - 4 58r I 935Y -irX5112- o.D=48007� 939T S 117 one x Nv, D= 4567 1819' I9 12' OTB'xN w D - 4 4SS' 9137-{.'>fYY VALCQ D=4.BiZ 9926'_ I-fH.W IIIO(LiLj)QN xtJ%IIfJLY ' 1466' I+uVB'%r IAV'PI W/W RM�7 ® 1NYINIxtU LNt 14`!GR 11619' { r www JIJNIJ FATE ftv Bv'- COWBi15 DATE LiV BY ODNAU4fS — -� RBDIDC BAYU!f YM1L A03 Man 1710:180 APIW 56@52011300 Sac 35. TI IN, R35E 209r Rl8 923 FEL i2ow?l RDW 261NMLCOMPLEnON O2J73112 JD IOOFWJCRONG ow:igigil NiFS INTO YI/017 H56VJC G';G, H40 KiFNi UOL68t:I x1N 01110(12 LEG PJC' SCT mO PLUG(WI 2) 0312114 TAO'JNOAUDEDSAFLTY NDIL O7l17I12 TMY.IMh ALS K+S SAF7lY NOTE 02/1(W16 IWAD F""E) SAFEFY 101E 01D 1/12 JAU'JNO� I18S EA 10129!12) BP Explwatsm(Alrxa) 02/13/121 WI:JNU' IALLID NEO it 610208112) _ N Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Numbers: AIO 18-033, AIO 18-034, and AIO 18-035 Prudhoe Bay Unit, Aurora, Borealis, and Prudhoe Oil Pools The application of BP Exploration (Alaska) Inc (BPXA) for amendments to existing area injection orders in accordance with 20 AAC 25.215 authorizing the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools. BPXA, by letter dated July 24, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend area injection orders no. 313, 22E, and 24B in accordance with 20 AAC 25.215 to authorize the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools for all injection wells in those pools. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 10:00 a.m. at 333 West 7`h Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than December 17, 2018. Hollis S. French Chair, Commissioner Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Numbers: AIO 18-033, AIO 18-034, and AIO 18-035 Prudhoe Bay Unit, Aurora, Borealis, and Prudhoe Oil Pools The application of BP Exploration (Alaska) Inc (BPXA) for amendments to existing area injection orders in accordance with 20 AAC 25.215 authorizing the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools. BPXA, by letter dated July 24, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend area injection orders no. 313, 22E, and 24B in accordance with 20 AAC 25.215 to authorize the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools for all injection wells in those pools. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 10:00 a.m. at 333 West 7'" Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7" Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than December 17, 2018. //signature on file// Hollis S. French Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CERTWMD AFFWAVTF OF PUBLICATION WON ATTACHED COPY OF ADVERTISMEN'T. ADVERTISING ORDER NUMBER p 1 AO-19-014 FROM: Alaska Oil and Gas Conservation Commission AGENCY CONTACT: Jody Colombie/Samantha Carlisle DATE OF A.O.AGENCY 11/162018 PHONE: (907) 279-1433 333 West 7th Avenue Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: (907) 276-7542 TO PUBLISHER: Anchorage Daily News, LLC SPECIAL INSTRUCTIONS: PO Bos 140147 Anchorage, Alaska 99514-0174 TYPE OF ADVERTISEMENT: r LEGAL I DISPLAY P CLASSIFIED r OTHER (Specify below) DESCRIPTION PRICE AIO 19-033,034 and AID, 18-035 Initials of who prepared AO: Alaska Non -Taxable 92-600185 SUDMIT INVOICE BROWING AP.�'ERTI$IpG: :--',ORp5R NO;,GFRT,IFIFD p:FF1UAYlTdi:;! �PDaucA'Iroy.WITaATTACHGIYCOPti.'dI?:: ApveartsMEtrvro;. AOGCC 333 West 7th Avenue Anchorage, Alaska 99501 Pa e I of 1 Total of All Pa es $ REF Type Number Amount Date Comments I PVN VCO21795 2 AO AO-19-014 3 4 FIN AMOUNT SV Act. Template I PGM LGR Object FY DIST LIQ 1 19 A14100 3046 19 2 3 4 Pureh si A h ri e: ill : Purchasing Authority's Signature Telephone Number 1. 'vi ero y name must at`ppear or, all invoices and comments relating to this purchase. Th stale is registeretl far tar tree transactions under Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and not for sal RIBUT3D,N, blvwon FiscaVOrigmal A.Q , :,Copies: Publisher (lased) .Dnt.mn l ileal, Receiving:; Form: 02-901 Revised: 11/16/2018 Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 ANCHORAGE DAIIN NEWS AFFIDAVIT OF PUBLICATION Account0: 270227 Orderft 0001430662 ST OFAWAK OIL AND GAS Cost $239.06 CONSERVATION COMMISSION 333 WEST 7TH AVE STE 100 nnirunwnrc Av oognrvguo STATE OF ALASKA THIRD JUDICIAL DISTRICT Sarah Jennett being first duly sworn on oath deposes and says that he/she is a representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on November 18, 2018 and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate cl*rg-Ad private 6cribed and swopAbefore me 19th day of Nov ber, 2018 Notary Public i and for The State 6LAFaska. Third Division Anchorage, Alaska MY COMMISSION EXPI Notary Public BRITNEY L. THOMPSON State of Alaska My Commission Expires Feb 23, 2019 Product ADN -Anchorage Daily News Placement 0300 Position 0301 Nearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Numbers: AID 18-033, AID 18-034, and AID 18-035 Prudhoe Bay Unit, Aurora, Borealis, and Prudhoe Oil Pools The application of BP Exploration (Alaska) Inc (BPxA) for amenrlPments to existing area Injection orders in accordance with 20 AAC 25.215 authorizing the downhole comminglinS of injection between the Aurora. and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools. BPXA, by letter dated July 24, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend area injection orders no. 3B, 22E, and 24B in accordance with 20 AAC 25.215 to authorize the downhole commingling of injection between the Aurora and Prudhoe oil Pools and the Borealis and Prudhoe oil Pools for all injection wells in those pools. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 10:00 a.m. at 333 West 7th Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 -p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the Issuance of an order without a hearing. To learn d the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability; special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombia, at (907) 793-1221, no later than December 17, 2018. Publsihed: November Chair, 7 BP Exploration (Alaska), Inc. 900 East Benson Boulevard Post Office Box 196612 Anchorage, Alaska 99519-6612 Telephone (907) 564 581 July 24, 2018 Mr. Hollis French, Chair Alaska Oil and Gas Conservation Commission 333 West 7h Avenue, Suite 100 Anchorage, AK 99501 0 by RECEIVEED JUL 3 0 2018 RE: Application for Amendment to Area Injection Orders 22E, 24B and 3B to authorize Downhole commingling of Injection between Two Pools Dear Chair French, In its capacity as Operator of the Aurora Oil Pool (AOP), Borealis Oil Pool (BOP) and the Prudhoe Oil Pool (POP), BP Exploration (Alaska) Inc. (`BP") hereby requests approval to commingle WAG injection between the AOP and POP, and between the BOP and POP, in the same wellbore of each injection well within these pools. BP respectfully submits that the requested commingling of injection will not cause waste or result in an increased risk of fluid movement into an underground source of drinking water, but rather will allow for recovery of a greater quantity of oil, and that such injection can be properly allocated. BP therefore requests administrative approval to amend Area Injection Orders 22E, 24B and 3B to authorize the referenced commingling of WAG injection within the same well -bore. Subject to commission approval, BP plans to commence commingling of WAG injection between the BOP and POP in Well Z-25 and between the AOP and POP in Well S -22B by the third quarter of 2018. Enclosed with this letter is additional information supporting this application, including BP's proposed allocation methodology and proposed amendments to the Injection Orders. ORIGINAL Application for Administrative Approval Amendment of AIO's 22E, 24B and 36 July 24, 2018 If the commission has questions or desires more information please contact Bill Bredar at 564-5348, william.bredar@bp.com. Sincerely, &VZ I ivy—e—r/ Diane Richmond Alaska Reservoir Development, BPXA Enclosure: Additional Information in Support of Application cc: Mr. Eric Reinbold, ConocoPhillips Alaska, Inc. Mr. Hank Jamieson, ExxonMobil Alaska, Production Inc. Mr. Jeffery Farr, ExxonMobil Alaska, Production Inc. Mr. Dave White, Chevron USA 2/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 July 24, 2018 Additional Information in Support of Application Introduction Area Injection Orders ("AIO") 313, 22E and 24B currently authorize commingling of WAG injection between AOP and POP, and BOP and POP, only for the specific wells identified in each AIO. However, each of the AIOs authorizes the commission to administratively amend the order as long as: the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. BP respectfully submits that the information provided with this application satisfies the above requirements, and is requesting that the commission administratively approve BP's application and authorize commingling of WAG injection between the AOP and POP, and the BOP and POP, for each injection well within those pools. AOGCC would continue to retain the ability to approve individual wells via the 10-403 Application for Sundry Approval process. Supplemental information to support that waste will not occur and outline of surveillance and allocation measures are included in Appendices I (Aurora and Prudhoe Oil Pool commingling in WAG Injector S -22B) and 2 (Borealis and Prudhoe Oil Pool commingling in WAG injector Z-25). Proposed Alternative Allocation Methodology An alternative allocation methodology is also proposed to enable allocation of injection between zones using injection data based injectivity profiles. By obtaining injection pressure and rate data from at least one zone separately, differential injection rates between the pools 3/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 can be determined with knowledge of the injection pressure. Where injection rates are such that friction impacts the injectivity, the same methodology can be used with calculated bottom hole pressure. An example of this methodology is shown for S-31 A which had commingled WAG injection in 2010 between the Prudhoe (Sag) and Aurora Oil Pools. 4000 3800 S -31A Aurora -Prudhoe Oil Pool Commingled MI injection Splits per differential injectivity methodology (shown): 82% Aurora, 18% Prudhoe Splits per 3/6/101PROF with MI Inj @ 2975psi WHIP: 83% Aurora, 17% Prudhoe 2200 y = 0.2082X+ 2638 .gp Ako'L I V i Me O —'' y =0.1652x + 2649 M O Commingled MI Injection Mdr Jun 2010 A Aurora Only MI Injection Oct 2009 -- —- Linear (Commingled MI Injection Mar -jun 2010) — — Linear (Aurora Only MI Injection Oct 2009) 0 560 1000 1500 2000 2500 3000 3500 4009 4500 5000 MI Injection Rate (mscf/d) This proposed methodology allows for regular monitoring and allocation of splits between pools based on data obtained daily. Significant deviation in commingled injection slope trend over time are notable. It is also proposed that when major changes in commingled injectivity occur that are not explained by metering calibration checks or planned mechanical modification, an injection survey or an updated separate pool multi -rate injectivity test be obtained for purposes of injection allocation between pools. This would eliminate the annual necessity for entering the well to obtain a survey or isolate a zone for separate injection test unless triggered by a significant injectivity change. 4/14 3690 a m 3400 N 0 3200 a 0 —�� 3000 d C 2800 M d 3 O 2400 2200 y = 0.2082X+ 2638 .gp Ako'L I V i Me O —'' y =0.1652x + 2649 M O Commingled MI Injection Mdr Jun 2010 A Aurora Only MI Injection Oct 2009 -- —- Linear (Commingled MI Injection Mar -jun 2010) — — Linear (Aurora Only MI Injection Oct 2009) 0 560 1000 1500 2000 2500 3000 3500 4009 4500 5000 MI Injection Rate (mscf/d) This proposed methodology allows for regular monitoring and allocation of splits between pools based on data obtained daily. Significant deviation in commingled injection slope trend over time are notable. It is also proposed that when major changes in commingled injectivity occur that are not explained by metering calibration checks or planned mechanical modification, an injection survey or an updated separate pool multi -rate injectivity test be obtained for purposes of injection allocation between pools. This would eliminate the annual necessity for entering the well to obtain a survey or isolate a zone for separate injection test unless triggered by a significant injectivity change. 4/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 July 24, 2018 Conclusion BP requests approval for well -bore commingling of WAG injection for AOP and POP commencing with Well S -22B and WAG injection for BOP and POP commencing with well Z-25. During the first 60 days of commingled injection an injection survey or separate pool multi -rate injectivity test will be obtained for purposes of allocation of injection by pool. An injection survey or separate pool multi -rate injectivity test will again be obtained within 60 days of the well injecting its other WAG phase. It is requested that differential injectivity profiles be approved as an allocation methodology for injection between pools. The proposed AIO amendments include the specific wells referenced in the Appendices. However, if the commission would consider poolwide commingling between the Aurora and Prudhoe Oil Pools and between the Borealis and Prudhoe Oil Pools, future opportunities could more efficiently be progressed though still require individual well approval through a 10-403 for perforating of a new pool and prior to commencing of commingled injection. Proposed Amendments to Area Injection Orders Note: Use of'[ ]'s denotes the deletion of existing order text. Use of underline denotes proposed new text. Amendment to Prudhoe Bay Unit Western Operating Area AIO 3B Rule 9: Rule 9. Wells Authorized for Downhole Commingled Injection [with the Aurora Oil Pool] Injection into the AOP and POP within the same wellbore is authorized for each well[s PBU S-09 and S -31A] into the BOP and POP within the same wellbore, subject to the following conditions. 5/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 (a) An approved Application for Sundry Approval (Form 10-403) is required for each well prior to commencement of commingled injection. (b) Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of injected fluids. [Additional injection surveys shall be conducted on each well at least once per year t] Thereafter as long as the well continues commingled injection, allocation will be based on use of differential injectivity profiles or injection survey unless significant changes in total injectivity occur whereby an injection survey or separate pool injectivity test will be performed. (c) Annual and total cumulative volumes injected by pool and results of logs, [or ]surveys, or separate pool multi -rate injectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP and BOP. Amendment to Aurora Oil Pool AID 22E Rule 9: Rule 11. Wells Authorized for Downhole Commingled Injection with the Prudhoe Oil Pool Injection into the AOP and POP within the same wellbore is authorized for each well[s PBU S-09 and S -31A], subject to the following conditions. a. An approved Application for Sundry Approval (Form 10 -403) is required for each well prior to commencement of commingled injection. b. Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of injected fluids. [Additional injection surveys shall be conducted on each well at least 6/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 July 24, 2018 once per year t] Thereafter as long as the well continues commingled injection, allocation will be based on use of differential iniectivity profiles or injection survey unless significant changes in total iniectivity occur whereby an injection survey or separate pool injectivity test will be performed. c. Annual and total cumulative volumes injected by pool and results of logs, [or ]surveys, or separate pool multi -rate iniectivitytests ests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP. Amendment to Borealis Oil Pool AIO 24B: Rule X. Wells Authorized for Downhole Commingled Iniection with the Prudhoe Oil Pool Injection into the BOP and POP within the same wellbore is authorized for each well subject to the following conditions. a. An approved Application for Sundry Approval (Form 10 -403) is required for each well prior to commencement of commingled injection. b. Within 60 days of commencement of commingled injection in a well or upon initial switching from one injection fluid to the other. BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of iniected fluids. Thereafter as long as the well continues commingled iniection allocation will be based on use of differential injectivity profiles or injection survey unless significant changes in total injectivity occur whereby an injection survey or separate pool injectivity test will be performed. c. Annual and total cumulative volumes injected by pool and results of logs surveys or separate pool multi -rate injectivity tests used for determining the allocation of iniected fluids between pools must be supplied in the Annual Surveillance Report for the BOP. 7/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 8/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 36 July 24, 2018 Appendix 1: Borealis and Prudhoe Oil Pool commingling in WAG Injectors Waste Will Not Occur 1. Injection Considerations Well Z-25 penetrates BOP in an ideal location for WAG injection due to its proximity to offset producers Z-100 and Z-113. Reservoir modeling indicates significant improvement in areal sweep to the offset producers as a result of placing an injection point at Z -25's Kuparuk penetration. While the size of the target does not justify a new well, the incremental benefits to the field are such that a workover for commingled injection in this well and potentially other wells is an attractive prospect. 2. Impacts on Current Well Utility Well Z-25 was drilled in 1989 and functioned as a Prudhoe Oil Pool producer from 1989 until 2003, at which time it was converted to an injector. Injection commenced in early 2005, and the well has been an active WAG injector ever since. One workover has taken place — the tubing was swapped out in 2009 due to a failed packer. Four slugs of MI have been injected to -date. When on water, the well injects approximately 7000 bwpd into POP. The forecasted injection rate into BOP is 1000-2000 bwpd, which will not adversely impact the ability to inject into POP. Injectivity into POP is anticipated to be higher than BOP, so an inline orifice choke is planned to be set below the BOP interval to allow for the desired injection splits between pools. This choke will be sized using best engineering practices, and the resulting injection splits will be confirmed via an injection profile log or separate pool multi rate injectivity test. Due to the planned workover preserving the 4-1/2" tubing design, the POP and BOP can each be isolated in the future via a plug or a patch, respectively. This maximizes future utility and ensures the future injection needs in each pool from this well can be met. During periods of prolonged well downtime, a mechanical plug can be set 9/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 between zones to prevent crossflow. July 24, 2018 Appropriate Surveillance and Injection Allocation Will Be Assured Appropriate surveillance and injection allocation measures will be undertaken to meet reservoir management objectives and to provide an acceptable allocation methodology. 1. Injection Allocation Stand-alone injectivity data in the BOP will be obtained prior to commingling injection. This will allow for an initial pressure vs. rate relationship to be established for the BOP, to assist in allocating zonal splits once both pools are open to injection. Once commingled, injection into the POP will be regulated via a downhole choke and zonal splits will be confirmed via an injection profile or separate pool multi -rate injectivity test within the first 60 days. An injection profile or separate pool multi -rate injectivity test will also be obtained within 60 days of the well's first change of injection service to inform zonal splits of the other WAG phase. 2. Reservoir Surveillance Long-term development plans for BOP and POP pools include water -flood and Enhanced Oil Recovery using "Miscible Injectant" (or "MI") from the Prudhoe Bay Miscible Gas Project. Reservoir pressure and communication with offset producers will be determined by monitoring injection trends and WAG interactions in both pools. To aid in long-term reservoir management, static pressures from each pool can be measured with the use of down -hole plugs and pressure gauges. If it is determined that a completion in one pool is adversely affecting injection to the other pool, that completion can be isolated as necessary to ensure waste does not occur. 3. Zonal Isolation To confirm injected fluids are contained in the intended zone in the BOP, a cement log of the 10/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 casing is planned during the workover. If the log indicates cement quality that does not meet established minimums for zonal isolation, a remedial squeeze will be executed, and the log will be repeated prior to running the completion. Conclusion BP requests approval for well -bore commingling of WAG injection for BOP and POP, commencing with Well Z-25. During the first 60 days of commingled injection an injection survey log or separate pool multi rate injectivity test for purposes of allocation of injection by pool will be obtained. Thereafter, it is proposed that injection surveys or separate pool multi - rate injectivity test be taken on an as needed basis. 11/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 Appendix 2: Aurora and Prudhoe Oil Pool commingling in WAG Injectors Waste Will Not Occur 1. Injection Considerations Well S -22B penetrates AOP in an ideal location for WAG injection due to its proximity to offset producers S -42A and S-118. The Kuparuk penetration of S -22B is in an ideal location to provide WAG support to the toe of S -42A. A prior attempt to provide injection support to S -42A involved the unsuccessful coil tubing sidetrack of S-112 in April 2016. Unfortunately, it was not possible to complete the S-112 sidetrack as planned due to unanticipated faults. Commingled injection into S -22B is a fallback alternative to the unsuccessful S-112 sidetrack. There is a large upside case if the S -22B Kuparuk injection re -complete provides injection support to S-118 to the south. S-118 is currently a non-operable producer with collapsed tubing and TxIA communication. A RWO to restore TxIA communication in S-118 is also being worked. There are also potential incremental benefits to the field to a workover for commingled injection in other wells within these pools. 2. Impacts on Current Well Utility S -22B was sidetracked to its current location in 07/97 and initially brought on line as a pre - produced injector in 1998. S -22B failed an MIT prior to the well conversion from a producer to injector. A RWO to replace corroded tubing was performed in June 2001 and the well was subsequently converted to injection. There is remaining value in the POP injection location, so commingled injection in both zones is desirable. Five slugs of MI have been injected to - date. When on water, the well injects approximately 3500 bwpd into POP. The forecasted injection rate into AOP is 1250 bwpd, which will not adversely impact the ability to inject into POP. 12/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 38 July 24, 2018 Injectivity into POP is anticipated to be higher than AOP, so an inline orifice choke is planned to be set below the AOP interval to allow for the desired injection splits between pools. This choke will be sized using best engineering practices, and the resulting injection splits will be confirmed via an injection profile log or a separate pool multi -rate injectivity test. Due to the planned workover preserving the 4-1/2" tubing design, the POP and AOP can each be isolated in the future via a plug or a patch, respectively. This maximizes future utility and ensures the future injection needs in each pool from this well can be met. During periods of prolonged well downtime, a mechanical plug can be set between zones to prevent crossflow. Appropriate Surveillance and Injection Allocation Will Be Assured Appropriate surveillance and injection allocation measures will be undertaken to meet reservoir management objectives and to provide an acceptable allocation methodology. 1. Injection Allocation Stand-alone injectivity data in the AOP will be obtained prior to commingling injection. This will allow for an initial pressure vs. rate relationship to be established for the AOP, to assist in allocating zonal splits once both pools are open to injection. Once commingled, injection into the POP will be regulated via a downhole choke and zonal splits will be confirmed via an injection profile or separate pool multi -rate injectivity test within the first 60 days. An injection profile or separate pool multi -rate injectivity test will also be obtained within 60 days of the well's first change of injection service to inform zonal splits of the other WAG phase. 2. Reservoir Surveillance Long-term development plans for AOP and POP pools include water -flood and Enhanced Oil 13/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 July 24, 2018 Recovery using "Miscible Injectant" (or "MI") from the Prudhoe Bay Miscible Gas Project. Reservoir pressure and communication with offset producers will be determined by monitoring injection trends and WAG interactions in both pools. To aid in long-term reservoir management, static pressures from each pool can be measured on an as -needed basis with the use of down -hole plugs and pressure gauges. If it is determined that a completion in one pool is adversely affecting injection to the other pool, that completion can be isolated as necessary to ensure waste does not occur. 3. Zonal Isolation To confirm injected fluids are contained in the intended zone in the AOP, a cement log of the casing is planned during the workover. If the log indicates cement quality that does not meet established minimums for zonal isolation, a remedial squeeze will be executed and the log will be repeated prior to running the completion. Conclusion BP requests approval for well -bore commingling of WAG injection for AOP and POP, commencing with Well S -22B. During the first 60 days of commingled injection an injection survey or separate pool multi -rate injectivity test for purposes of allocation of injection by pool will be taken. An injection survey or separate pool multi -rate injectivity test will again be obtained within 60 days of the well injecting its other WAG phase. Thereafter, it is proposed that injection surveys or separate pool multi -rate injectivity test be taken on an as - needed basis. 14/14