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Home My WebLink AboutAIO 022 FAREA INJECTION ORDER 22F Prudhoe Bay Unit Aurora Oil Pool North Slope, Alaska 1. July 24, 2018 BPXA’s request for amendment AIO22E 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 31, 2019 BPXA’s request for Administrative Approval to continue water injection operations into S-10714. 4. March 9, 2020 BPXA request to amend defined inner annulus normal operating limits on injectors operating under administrative approval 5. October 2, 2020 AOGCC approval of March 9, 2020 request 6. January 05, 2022 Hilcorp’s request to amend AIO 22F.001 to allow WAG Injection Operations 7. January 7, 2022 Emails between Hilcorp and AOGCC 8. January 21, 2022 Administrative Approval to amend AIO 22F.001 9. November 21, 2024 Hilcorp Request for Administrative Approval to allow WAG injection operations (AIO 22F.002) 10. June 10, 2025 Hilcorp Request for Administrative Approval to allow WAG injection operations for Aurora Well S-104 (PTD 200-196) (AIO 22F.003) 11. July 3, 2025 Hilcorp Request for Administrative Approval to allow WAG injection operations for well S-09A (PTD 214-097) (AIO 22F.004) 12. November 21, 2025 Hilcorp for continued WAG injection with a high-set Packer (AIO 22F.001 Cancelled & AIO 22F.005) ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7'h Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF BP Exploration ) Docket Number: AIO-18-033 (Alaska) Inc. for amendments to Area ) Area Injection Order No. 22F Injection Order 22E to authorize the ) downhole commingling of injection between ) Prudhoe Bay Unit the Prudhoe Oil Pool and the Aurora Oil ) Aurora Oil Pool Pool. ) North Slope Borough, Alaska April 3, 2019 IT APPEARING THAT: 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) 22E be amended to allow downhole commingling of injection between the Prudhoe Oil Pool (POP) and the Aurora Oil Pool (AOP). 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, 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 AIO 22E, 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. Aurora Oil Pool: The AOP, one of several oil pools in the Kuparuk formation that overlie the POP, is present 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 currently authorized in wells PBU S-09 and PBU S-3 IA. Area Injection Order 22F April 3, 2019 Page 2 of 6 5. 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 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 PBU/POP wells encounter two or more pools on the way to total depth. 6. Gas Source: The lean and miscible gas used for injection in the POP and AOP is sourced from the PBU Central Gas Facility and Central Compression Plant. Drill Site S contains AOP and POP wells, so the gas available for enhanced recovery injection is the same for both the AOP and the POP. 7. Maximization of Ultimate Recovery: Several POP wells penetrate the AOP 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. 8. Iniection Conformance: Downhole chokes can be installed between the AOP 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 respectively in the event one pool no longer needs injection support. 9. Prevention of Crossflow: During injection operations crossflow between the two pools 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 and POP. 10. 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. If deemed necessary, additional injection surveys or multi -rate injectivity tests would be conducted as injection performance dictates or upon AOGCC's request. CONCLUSIONS: 1. Amendment of AIO 22E is necessary to authorize pool wide commingled injection between the AOP and POP. 2. Commingled injection will allow for improved recovery from the PBU by making enhanced recovery injection possible in portions of the AOP where it isn't currently economically feasible to drill a dedicated injection well to this pool. 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. Area Injection Order 22F April 3, 2019 Page 3 of 6 NOW, THEREFORE, IT IS ORDERED: In addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), the following rules govern Class II injection operations in the affected area described below and supersede and replace the rules adopted in Area Injection Order No. 22E dated August 22, 2011, as amended: AFFECTED AREA Township Range,UM Sections T11N-R12E Sec 2: WI/2 Sec 3: All Sec 4: E 1/2, NW 1/4, E 1/2 SW 1/4 Sec 5: E 1/21/2NE1/4 Sec. 9: NE1/4, N1/2SE1/4 Sec 10:NW1/4SW1/4, W1/2NW1/4 T12N-R12E Sec 15: S1/2SE1/4, SWI/4 Sec 16: NWl/4, S1/2 Sec 17: S1/2, NE 1/4 Sec 18: SETA Sec 19: Nl/2, NE 1/4 Sec 20: El/2, N1/2NW 1/4 Sec 21: All Sec 22: All Sec 23: S1/2, S1/2NW1/4, S1/2NE1/4 Sec 25; S1/2, S1/2NW1/4 Sec 26; All Sec 27: All Sec 28: All Sec 29: E1/2NE1A, SE1A Sec 32: EI/2 Sec 33: All Sec 34: All Sec 35: All Sec 36: All Rule 1. Authorized Iniection Strata for Enhanced Recovery (Source: AIO 22) Injection is permitted into the accumulation of hydrocarbons that is common to, and correlates with, the interval between 6765'- 7765' measured depth ("MD") in the Mobil Oil Corporation Mobil -Phillips North Kuparuk State No. 26-12-12 well. Rule 2 Infection Pressures (Source: AIO 22B) The injection operations shall not allow fractures to propagate into the confining intervals. Surface wellhead injection pressures shall be limited to 2800 psi for water and 3800 psi for gas. Rule 3. Fluid Iniection Wells (Source: AIO 22C) Area Injection Order 22F April 3, 2019 Page 4 of 6 a. The underground injection of fluids must be through a well permitted for drilling as a service well for injection in conformance with 20 AAC 25.005, or through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280. b. An application to drill or convert a well for injection must be accompanied by the information required by 20 AAC 25.402(c), and must include cementing records, cement quality log or formation integrity test records. Rule 4. Monitoring the Tuhing-Casing Annulus Pressure Variations (Source: AIO 22D 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. Demonstration of Tubing -Casing Annulus Mechanical Integrity (Source: AIO 22D) 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 6. Well Integrity Failure (Source: AIO 22D 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 7. Notification of Improper Class II Iniection (Source: AIO 22C) The operator shall notify the AOGCC if it learns of any improper injection of fluids into a Class Il well. Additionally, compliance with the notification requirements of any other State or Federal agency remains the operator's responsibility. Rule 8. Other conditions (Source: AIO 22D) a. It is a condition of the authorization granted by this Order that the operator shall comply with all applicable AOGCC regulations. Area Injection Order 22F April 3, 2019 Page 5 of 6 b. The AOGCC may immediately suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection strata. Rule 9. Authorized Fluids for Enhanced Recovery (Source: AIO 22B, renumbered this order The fluids authorized by this Order for injection and conditions of the authorization are as follows: a. produced water from the AOP or Prudhoe Bay Unit processing facilities; b. source water from the Prince Creek formation provided that the water is shown to be compatible with the AOP formation and administrative approval to inject is obtained from the AOGCC; c. enriched hydrocarbon gas processed within the Prudhoe Bay Unit processing facilities, with the following conditions: 1. reservoir pressure must be maintained to ensure miscibility of the injectant, and 2. expansion of injection outside of the North of Crest and West Blocks must be administratively approved prior to long-term injection; d. immiscible hydrocarbon gas from the AOP or Prudhoe Bay Unit processing facilities provided that AOGCC approval of the associated depletion strategy and surveillance plans is obtained prior to start of injection; e. tracer survey fluid to monitor reservoir performance; and f. non -hazardous filtered water collected from AOP well house cellars and well pads. Rule 10. Wells Authorized for Downhole Commingled Infection with the Prudhoe Oil Pool (Source: Revised and renumbered this order) Injection into the AOP and POP within the same wellbore is authorized for each well, subject to the following conditions. a. An Application for Sundry Approval (Foran 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 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 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 injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP. Rule 11. Administrative Action (Source: AIO 22B, renumbered this order) Unless notice and public hearing are otherwise required, the AOGCC may administratively waive the requirements of any rule herein or administratively amend any rule 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. Area Injection Order 22F April 3, 2019 Page 6 of 6 DONE at Anchorage, Alaska and dated April 3, 2019. Daniel T. Se ount, Jr. Jes e L. Chmielowski Commissioner C missioner RECONSIDERATION AND 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 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. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 THE STATE °fALASKA GoVERNOR MIKE DUNLEAVY Mr. Oliver Stemicki Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO. 22F.001 Well Integrity Engineer BP Exploration (Alaska), Inc. P.O. Box 196612 Anchorage, AK 99519-6612 Re: Docket Number: AIO-19-041 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov Request for administrative approval to allow well S-107 (PTD 2011130) to be online in water only injection service with a known inner annulus repressurization Prudhoe Bay Unit (PBU) S-107 (PTD 2011130) Prudhoe Bay Field Aurora Oil Pool Dear Mr. Stemicki: By letter dated December 31, 2019 BP Exploration (Alaska), Inc. (BPXA) requested administrative approval to continue water only injection in the subject well. In accordance with Rule 11 of Area Injection Order (AIO) 22F.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 an anomalous inner annulus (IA) repressurization to AOGCC in March 2019 while the well was on miscible gas injection. BPXA completed monitoring and diagnostics including a passing leak detect log while on gas injection on May 20, 2019 and a passing non -state witnessed Mechanical Integrity Test of the Inner Annulus (MITIA) on May 22, 2019. BPXA placed the well on produced water injection and completed a passing state witnessed MITIA on December 20, 2019 which indicates that S-107 exhibits at least two competent barriers to the release of well pressure. BPXA has installed wireless gauges on S -pad wells that allow for real time monitoring and alarm notifications of IA and outer annulus (OA) pressures. AOGCC finds that BPXA is able to manage the IA pressure 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. AIO 22F.001 January 7, 2020 Page 2 of 2 AOGCC's approval to continue water injection only in PBU S-107 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 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 immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; After well shut in due to a change in the well's mechanical condition, shall be required to restart injection; and The MIT anniversary date is December 20, 2019. DONE at Anchorage, Alaska and dated January 7, 2020. y o� �` \Je , y, Price Daniel T. Seamount, Jr. Je ie�ieloN C ai issioner Commissioner Commissioner AOGCC approval 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 K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 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 22F.001 AMENDED 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-22-002 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit (PBU) S-107 (PTD 2011130), Aurora Oil Pool Dear Mr. Golis: By emailed letter dated January 5, 2022, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to amend Area Injection Order (AIO) 22F.001 to include water alternating gas (WAG) injection with a known inner annulus (IA) repressurization. In accordance with 20AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp’s request to amend the administrative approval to continue WAG injection in the subject well. Then-BP Exploration (Alaska), Inc. (BPXA) first reported a potential IA repressurization to AOGCC in March 2019, while the well was on miscible gas injection (MI). BPXA performed diagnostics and confirmed the IA repressurization was only present during gas injection. AOGCC issued AIO 22F.001 on January 7, 2020, restricting the well to water-only injection. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 3,412 psi which is greater than the anticipated gas injection pressure of 2,800 psi) on December 9, 2021. This indicates that S-107 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 remove the original water-only restriction and re-authorize gas injection. AOGCC believes Hilcorp can safely manage the IA repressurization with periodic pressure bleeds by maintaining the inner annulus to a pressure not to exceed 2,100 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 22F.001 Amended January 21, 2022 Page 2 of 2 AOGCC’s approval to continue WAG injection in PBU S-107 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 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 11:44:11 -09'00' Jeremy Price Digitally signed by Jeremy Price Date: 2022.01.21 12:36:53 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2022.01.21 13:21:40 -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 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 22F.001 CANCELLATION Mr. Torin Roschinger, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-030 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit S-107 (PTD 201113) and S-107A (PTD 225083), Aurora Oil Pool Dear Mr. Roschinger: By emailed letter dated November 21, 2025, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to amend Area Injection Order (AIO) 22F.001, which authorizes water alternating gas (WAG) injection with a known inner annulus (IA) repressurization, to also include the new coil tubing sidetrack S-107A and a high-set packer that reduces the monitorable IA. The packer design doesn’t meet the requirement of 20 AAC 25.412(b) that “an injector be equipped with tubing and a packer… the packer must be placed within 200 feet measured depth above the top of the perforations…” In accordance with 20AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC), upon its own motion, hereby GRANTS CANCELLATION of AIO 22F.001. AOGCC will separately approve a new AIO 22F.005, under this Docket, as it relates to injection operations of the new S-107A well. Hilcorp has plugged and abandoned S-107 and coil tubing sidetracked the well creating the new well now designated as S-107A. AA AIO 22F.001 is hereby CANCELLED. DONE at Anchorage, Alaska and dated November 2, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.11.25 07:12:13 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.11.25 08:18:12 -09'00' AIO 22F.001 Cancellation November 2, 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 Orders 22F.001 Cancellation and 22F.005 Date:Tuesday, November 25, 2025 12:42:07 PM Attachments:AIO22F.001 Cancellation.pdf AIO22F.005.pdf Docket Number: AIO-25-030 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit S-107 (PTD 201113) and S-107A (PTD 225083), Aurora Oil Pool Docket Number: AIO-25-030 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit S-107 (PTD 2011130) and S-107A (PTD 2250830), Aurora 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 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. 22F.002 Mr. Torin Roschinger PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-24-034 Request for Administrative Approval to Area Injection Order 22F: Water Alternating Gas Injection Prudhoe Bay Unit (PBU) Aurora S-122 (PTD 2050810), Aurora Oil Pool Dear Mr. Roschinger: By letter dated November 21, 2024, 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 September 12, 2024, while the well was injecting miscible injectant. Hilcorp performed diagnostics and monitoring including a passing state witnessed mechanical integrity test (MIT) of the inner annulus to 3,426 psi on November 2, 2024. This indicates that S-122 exhibits at least two competent barriers to the release of well pressure. AOGCC believes Hilcorp can safely manage the TxIA pressure communication with periodic pressure bleeds by maintaining the inner annulus to a pressure not to exceed 2,100 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 Aurora S-122 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 22F.002 December 5, 2024 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 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 PCC remote shut down capability for S-122 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 November 2026. DONE at Anchorage, Alaska and dated December 5, 2024. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2024.12.05 09:45:44 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.12.05 11:26:35 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 2F.002 (Hilcorp NS) Date:Thursday, December 5, 2024 11:35:58 AM Attachments:aio22F.002.pdf Docket Number: AIO-24-034 Request for Administrative Approval to Area Injection Order 22F: Water Alternating Gas Injection Prudhoe Bay Unit (PBU) Aurora S-122 (PTD 2050810), Aurora 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 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. 22F.003 AREA INJECTION ORDER NO. 25A.030 Mr. Torin Roschinger PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-016 Request for Administrative Approval to Area Injection Order 22F: Water Alternating Gas Injection, Aurora Oil Pool Request for Administrative Approval to Area Injection Order 25A: Water Alternating Gas Injection, Polaris Oil Pool Prudhoe Bay Unit (PBU) S-104 (PTD 2001960) Dear Mr. Roschinger: By letter dated June 10, 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 slow TxIA pressure communication to AOGCC on March 31, 2025, while the well was injecting miscible injectant. Hilcorp performed diagnostics and extended monitoring including a passing statewitnessed mechanical integrity test (MIT) of the inner annulus to 3,709 psi on May 30, 2025. This indicates that S-104 exhibits at least two competent barriers to the release of well pressure. AOGCC believes Hilcorp can safely manage the TxIA pressure communication with periodic pressure bleeds by maintaining the inner annulus to a pressure not to exceed 2,100 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 S-104 in Aurora Oil Pool and Polaris Oil Pool is conditioned upon the following: 1. Hilcorp shall record wellhead pressures and injection rate daily; AIO 22F.003 AIO 25A.030 June 16, 2025 Page 2 of 2 2. Hilcorp shall submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3. Hilcorp shall perform a 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 PCC remote shut down capability for S-104 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 May 2027. DONE at Anchorage, Alaska and dated June 16, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.06.16 10:11:11 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.06.16 10:19:12 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 22F.003 and 25A.030 (Hilcorp) Date:Monday, June 16, 2025 10:32:43 AM Attachments:AIO22F.003_AIO25A.030.pdf Docket Number: AIO-25-016 Request for Administrative Approval to Area Injection Order 22F: Water Alternating Gas Injection, Aurora Oil Pool Request for Administrative Approval to Area Injection Order 25A: Water Alternating Gas Injection, Polaris Oil Pool Prudhoe Bay Unit (PBU) S-104 (PTD 2001960) Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL AREA INJECTION ORDER 22F.004 Mr. Bo York PBE Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-017 Request for Administrative Approval to Area Injection Order 22F; Water Alternating Gas Injection (WAG) Prudhoe Bay Unit (PBU) S-09A(PTD 2140970), Aurora Oil Pool, Western Operating Area Dear Mr. York: By emailed letter dated July 3, 2025, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue 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 March 14, 2025, when the well was on miscible gas injection (MI). Hilcorp performed diagnostics and monitoring which confirmed slow TxIA. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 3,466 psi) on April 27, 2025. This indicates that S-09A 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 with remote shut down capabilities that create layers of protection from an over pressure event. These inner and outer annulus alarms and shut in protocols 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 slow TxIA communication with periodic pressure bleeds by maintaining the IA to a pressure not to exceed 2,100 psi and OA 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 22F.004 July 15, 2025 Page 2 of 3 AOGCC’s approval to continue WAG injection in PBU S-09A 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 perform a MIT of the tubing every two years to the greater of the maximum anticipated injection pressure or 1,500 psi. 5) Hilcorp shall perform a waterflow log or equivalent every two years to detect any flow migrating out of the approved injection zone. 6) 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; 7) Hilcorp shall monitor the inner and outer annulus pressures in real time with its SCADA system; 8) Hilcorp shall maintain the PCC remote shut down capability for S-09A when on gas or miscible injectant (MI) operation; 9) Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 10) After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 11) The next required MIT shall be completed before or during the month of April 2027. DONE at Anchorage, Alaska and dated July 15, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.07.15 08:53:01 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.07.15 08:55:31 -08'00' AIO 22F.004 July 15, 2025 Page 3 of 3 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 22F.004 (Hilcorp) Date:Tuesday, July 15, 2025 9:08:38 AM Attachments:AIO22F.004.pdf Docket Number: AIO-25-017 Request for Administrative Approval to Area Injection Order 22F; Water Alternating Gas Injection (WAG) Prudhoe Bay Unit (PBU) S-09A (PTD 2140970), Aurora Oil Pool, Western Operating Area Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL AREA INJECTION ORDER 22F.005 Mr. Torin Roschinger, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-030 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit (PBU) S-107 (PTD 2011130) and S-107A (PTD 2250830), Aurora Oil Pool Dear Mr. Roschinger: By emailed letter dated November 21, 2025, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to amend Area Injection Order (AIO) 22F.001, which authorizes water alternating gas (WAG) injection with a known inner annulus (IA) repressurization, to also include the new coil tubing sidetrack S-107A and a high-set packer that reduces the monitorable IA. The packer design doesn’t meet the requirement of 20 AAC 25.412(b) that “an injector be equipped with tubing and a packer… the packer must be placed within 200 feet measured depth above the top of the perforations…” In accordance with 20AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS IN PART, subject to conditions, Hilcorp’s request. Upon its own motion, AOGCC modifies Hilcorp’s request and GRANTS, subject to conditions, a new AIO 22F.005 administrative approval to continue WAG injection in the new S-107A well. AOGCC will separately cancel AIO 22F.001, under this Docket, as it relates to the now plugged and abandoned S-107 well. BP Exploration (Alaska), Inc (BPXA) first reported a potential IA repressurization to AOGCC in March 2019, while the well was on miscible gas injection (MI). BPXA performed diagnostics and confirmed the IA repressurization was only present during gas injection. AOGCC issued AIO 22F.001 on January 7, 2020, restricting the well to water-only injection. AOGCC amended AIO 22F.001 on January 21, 2022, to allow WAG injection to occur. Hilcorp has now completed a coil tubing sidetrack from the S-107 motherbore and the new sidetrack is designated S-107A. When the well comes back online and once stabilized, Hilcorp will perform additional diagnostics including passing state-witnessed mechanical integrity test (MIT) of the inner annulus and MIT of AIO 22F.005 November 2, 2025 Page 2 of 3 the tubing. Passing MIT’s will indicate that S-107A 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 remove the original water-only restriction and re-authorize gas injection. AOGCC believes Hilcorp can safely manage the IA repressurization with periodic pressure bleeds by maintaining the inner annulus to a pressure not to exceed 2,100 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 S-107A 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 perform a MIT of the tubing 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; 5) 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; 6) Hilcorp shall maintain the PCC remote shut down capability for S-107A when on gas or miscible injectant (MI) operation; 7) Hilcorp shall monitor the inner and outer annulus pressures in real time with its SCADA system; 8) Hilcorp shall 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; and 10) The next required MITIA is to be after the well is placed on injection and injection conditions (temperature, pressure, rate etc.) have stabilized. 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 November 2, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.11.25 07:15:53 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.11.25 08:20:22 -09'00' AIO 22F.005 November 2, 2025 Page 3 of 3 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 Orders 22F.001 Cancellation and 22F.005 Date:Tuesday, November 25, 2025 12:42:07 PM Attachments:AIO22F.001 Cancellation.pdf AIO22F.005.pdf Docket Number: AIO-25-030 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit S-107 (PTD 201113) and S-107A (PTD 225083), Aurora Oil Pool Docket Number: AIO-25-030 Request to Amend Area Injection Order 22F.001: Water Alternating Gas Injection Operations Prudhoe Bay Unit S-107 (PTD 2011130) and S-107A (PTD 2250830), Aurora 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 12 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 11/21/2025 Commissioners – Jessie Chmielowski, Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Unit, Aurora Oil Pool well S-107 (PTD #201113). Request for amendment to AIO 22F.001 due to coil tubing drilling sidetrack to Prudhoe Bay Unit, Aurora Oil Pool well S-107A (PTD #225083). Request for continued WAG injection with a high-set packer. Dear Commissioner Chmielowski and Commissioner Wilson, Hilcorp North Slope, LLC requests amendment to AIO 22F.001 to allow for continued WAG injection into the Aurora Oil Pool well S-107A which is a recent in-pool coil tubing drilling (CTD) sidetrack from the S-107 bore. Hilcorp North Slope, LLC also requests for continued WAG injection with a high-set packer, limiting the monitorable well inner annulus. S-107 (PTD# 201113) operated as a WAG injector under AIO 22F.001 for slow IA repressurization in the Aurora Oil Pool. On 11/6/2025, the in-zone, CTD sidetrack to S-107A was completed under PTD# 225083, abandoning the previous slotted liner completion. The primary barrier, consisting of the tubing and packer and associated jewelry were not altered during this CTD sidetrack other than temporarily removing the tubing patch previously set from 10863’-10877’ MD to allow the S-107A sidetrack to be drilled. Prior to recommencing injection, the tubing patch will be reinstalled and pressure tested to maximum anticipated injection pressure and an online MIT-IA will be conducted after the well is placed on injection. The S-107/ S-107A completion is configured in such a way that that upper packer is set at 11718’ MD, which is greater than 200’ MD above the top of the perforations. This does not meet the requirements of 20 AAC 25.412(b) and creates a reduced monitorable annulus. An additional 2-year pressure test of the tubing is proposed to ensure ongoing injection isolation. Hilcorp North Slope, LLC has determined that well S-107A is safe to operate in its current condition and requests an amendment to AIO 22F.001 for WAG injection based on the following: x Passing pressure tests of the primary and secondary barriers. x IA and OA pressures will be monitored with wireless pressure gauges. Proposed Operating and Monitoring Plan: 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-IA 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 perform a MIT-T 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; 5. Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 6. Hilcorp shall limit the well’s outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; By Samantha Coldiron at 7:17 am, Nov 24, 2025 7. Hilcorp shall maintain the PCC remote shut down capability for S-107A when on gas or miscible injectant (MI) operation; 8. Hilcorp shall monitor the inner and outer annulus pressures in real time with its SCADA system; 9. Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 10. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection. 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 Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662) Date: 2025.11.21 11:41:56 - 09'00' Torin Roschinger (4662) Wellbore Schematic 11 Hilcorp North Slope, LLC Bo York, PBE Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 07/03/2025 Commissioners –Jesse Chmielowski, Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Well S-09A (PTD #214097). 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 Bay well S- 09A with slow tubing x inner annulus (IA) communication. S-09A was reported to have suspected slow IA re-pressurization on 03/14/25 while on Miscible Gas Injection (MI). The maximum anticipated injection pressure for S-09A would be the maximum MI header pressure for S-pad which is approximately 3,300 psi. An AOGCC witness MIT-IA was conducted on 04/27/25 and passed to 3466 psi. Hilcorp North Slope, LLC has determined that well S-09A 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 907-777-8345 or Oliver Sternicki at 907-564-4891. Sincerely, Bo York PBE Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic Digitally signed by Bo York (1248) DN: cn=Bo York (1248) Date: 2025.07.03 08:57:44 - 08'00' Bo York (1248) Prudhoe Bay Well S-09A Technical Justification for Administrative Approval Request 07/03/2025 Well History and Status Rig sidetrack S-09A was originally drilled as an Ivishak injector in 2015. The Ivishak was abandoned and the well was converted to a Kuparuk injector in August/ September of 2024 under Sundry 324-258. The well went under evaluation on 03/24/25 for IA repressurization and passed a tubing wellhead seal pressure test to 5000 psi on 04/15/25. On 04/27/25 the well passed an AOGCC witnessed MIT-IA to 3466 psi. An extended packing dummy gas lift valve was set in the only non-cemented gas lift mandrel on 06/06/25 in an attempt to repair the IA repressurization, but no apparent change in the IA repressurization rate was seen. Recent Well Events: 09/08/24 Online AOGCC witnessed MIT-IA passed to 2544 psi 03/24/25 Classified as Under Evaluation and reported to AOGCC for IA re-pressurization 04/15/25 PPPOT-T passed to 5000 psi 04/27/25 Online AOGCC witnessed MIT-IA passed to 3466 psi 06/06/25 Set extended packing DGLVs 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 04/27/25 to 3466 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 S-09A 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; 10 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 06/10/25 Commissioners –Jesse Chmielowski, Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Polaris/ Aurora Well S-104 (PTD #200196). 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 Polaris/ Aurora well S- 104 with slow tubing x inner annulus (IA) communication. S-104 was reported to have suspected slow IA re-pressurization on 03/31/25 while on Miscible Gas Injection (MI). The maximum anticipated injection pressure for S-104 would be the maximum MI header pressure for S-pad which is approximately 3300 psi. An AOGCC witness MIT-IA was conducted on 05/30/25 and passed to 3709 psi. Hilcorp North Slope, LLC has determined that well S-104 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 11:42 am, Jun 10, 2025 Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662) Date: 2025.06.10 11:22:31 - 08'00' Torin Roschinger (4662) Polaris/ Aurora Well S-104 Technical Justification for Administrative Approval Request 06/10/25 Well History and Status S-104 was drilled as a multi-pool injector in 2001 with access to the Polaris and Aurora pools. In 2013 a leak was found in the tubing at 6480’ MD, this was repaired with a patch and the well was made operable in late 2014. On 06/07/19 another tubing leak was discovered at 6501’ MD, just below the existing patch. The old patch was replaced with a slightly longer one to cover the two tubing leaks and the well was made operable again on 07/19/20. The well was placed under evaluation while on MI service on 09/16/24 due to suspected slow TxIA communication. Extended packing dummy gas lift valves were installed in October and December of 2024 to repair the TxIA communication and the well was eventually made operable on 02/02/25. The AOGCC was notified of possible TxIA communication on 03/31/25 and after an extended monitoring period the well again went under evaluation on 05/26/25. The well recently passed an online AOGCC witnessed MIT-IA to 3709 psi on 05/30/25. Recent Well Events: 08/09/24 AOGCC MIT-IA pass to 1740 psi. 09/16/24 Well placed under evaluation for possible TxIA comm on MI. 09/17/24 Tubing pack-off test passed to 5000 psi. 10/17/24 Extended packing DGLV set in station #5. 12/27/24 Extended packing DGLV set in station #4. 02/02/25 Well made operable after eval period, no signs of TxIA comm. 03/31/25 Notification sent to AOGCC of possible TxIA on MI. 05/26/25 Well placed under evaluation for possible TxIA comm on MI. 05/30/25 AOGCC witnessed online MIT-IA passed to 3709 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 05/30/25 to 3709 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 S-104 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 9 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 11/21/2024 Chairman Brett Huber, Sr Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Prudhoe Bay Well S-122 (PTD #205081). 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 S-122 with slow tubing x inner annulus (IA) communication. S-122 was reported to have slow IA re-pressurization on 09/12/24 while on Miscible Gas Injection (MI). The maximum anticipated injection pressure for S-122 would be the maximum MI header pressure for S-pad which is approximately 3,300 psi. An AOGCC witness MIT-IA was conducted on 11/02/24 and passed to 3,426 psi. Hilcorp North Slope, LLC has determined that well S-122 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 12:21 pm, Nov 25, 2024 Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662) Date: 2024.11.21 16:23:57 - 09'00' Torin Roschinger (4662) Prudhoe Bay Well S-122 Technical Justification for Administrative Approval Request 11/21/2024 Well History and Status Well S-122 is a WAG injector that was originally drilled as a Kuparuk producer in 2005. The well has a ~2000ft horizontal 4-1/2” cemented liner in the Kuparuk that had 1140’ of perforations in 12 intervals. To shut-off the high water cut perforations, a RWO was completed on 6/19/23 to insert a 3-1/4” scab liner deployed via 4-1/2” tubing inside the existing 4-1/2” production liner. The 3-1/4” scab liner was cemented in place with service coil to isolate all existing perforations. Then, coil perforated 30’ at the toe. A single stage toe frac and subsequent coil FCO were complete in October 2023. The well was converted to a WAG injector in May 2024 under Sundry 324-268. The well went under evaluation on 09/12/24 for IA repressurization and passed a tubing wellhead seal pressure test to 5000 psi on 9/14/24. Extended packing dummy gas lift valves were set in all gas lift mandrels on 10/24/24 in an attempt to repair the IA repressurization, but no change in the IA repressurization rate was seen. The well then passed an online AOGCC witnessed MIT-IA to 3,426 psi on 11/02/24. Recent Well Events: 05/06/24 Sundry 324-268 approved for WAG conversion 07/17/24 AOGCC witnessed Offline MIT-T passed to 3374 psi and MIT-IA passed to 3400 psi 08/28/24 Placed on MI injection 09/03/24 Online AOGCC witnessed MIT-IA passed to 2474 psi 09/12/24 Classified as Under Evaluation and reported to AOGCC for IA re-pressurization 09/14/24 PPPOT-T passed to 5000 psi 09/21/24 Change out DGLV 10/24/24 Set extended packing DGLVs 11/02/24 Online AOGCC MIT-IA passed to 3426 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 11/02/24 to 3,426 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 S-122 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 CAUTION: This email originated from outside the State of Alaska mail system. From:Salazar, Grace (OGC) To:Abbie Barker; sgolis@hilcorp.com Cc:Wallace, Chris D (OGC) Subject:Area Injection Order No. 22F.001 Amended Date:Friday, January 21, 2022 1:40:00 PM Attachments:AIO 22F.001 Amended.pdf The Alaska Oil and Gas Conservation Commission has issued the attached Area Injection Order No. 22F.001 (Amended), granting Hilcorp North Slope, LLC’s request to amend AIO 22F.001 to allow Prudhoe Bay Aurora Well S-107 (PTD 2011130) Water Alternating Gas Injection Operations. 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 S-107 (PTD# 201-113) Request to Amend AIO 22F.001 to allow WAG Injection Operations From: Abbie Barker <Abbie.Barker@hilcorp.com> Sent: Thursday, January 6, 2022 4:12 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 S-107 (PTD# 201-113) Request to Amend AIO 22F.001 to allow WAG Injection Operations Do not click links or open attachments unless you recognize the sender and know the content is safe. Hello, Please find the attached Request to Amend AIO 22F.001 to allow WAG Injection Operations for PBU S-107 (PTD# 201-113). If you have any questions, please contact Stan Golis at 907-777-8356 or Oliver Sternicki at 907-564- 4891. Thank you, 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 hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently 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. 7 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:Oliver Sternicki To:Wallace, Chris D (OGC) Cc:PB Wells Integrity Subject:RE: [EXTERNAL] RE: S-107 (PTD# 201113) and W-44 (PTD# 189100) AA requests- Continued injection while processing request. Date:Friday, January 7, 2022 3:47:38 PM Below are the alarms for S-107. The High and High High alarms are monitored by the board operators continually. The alarms are not tied to an automatic shut-in, but alert the board operator and in turn the pad operator to take action to bleed the well and make notifications. Annulus High High High (MOASP) IA 2000 psi 2100 psi OA 900 psi 1000 psi Oliver Sternicki Hilcorp Alaska, Hilcorp North Slope LLC Well Integrity Engineer Office: (907) 564 4891 Cell: (907) 350 0759 Oliver.Sternicki@hilcorp.com From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Friday, January 7, 2022 3:22 PM To: Oliver Sternicki <Oliver.Sternicki@hilcorp.com> Cc: PB Wells Integrity <PBWellsIntegrity@hilcorp.com> Subject: [EXTERNAL] RE: S-107 (PTD# 201113) and W-44 (PTD# 189100) AA requests- Continued injection while processing request. Oliver, Each well can remain on injection while the administrative approval requests are being processed. For S-107 (MI injection) what alarms or shut down protocols are in place to accompany the wireless IA and OA monitoring? Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information 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 the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Oliver Sternicki <Oliver.Sternicki@hilcorp.com> Sent: Friday, January 7, 2022 1:54 PM To: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Cc: PB Wells Integrity <PBWellsIntegrity@hilcorp.com> Subject: S-107 (PTD# 201113) and W-44 (PTD# 189100) AA requests- Continued injection while processing request. Mr. Wallace, Administrative Approval requests were submitted to the AOGCC on 1/6/22 for two wells: W-44: Continued produced water injection with slow TxIA communication. S-107: Amendment to AIO 22F.001 to allow for WAG service. Hilcorp request permission for W-44 to remain on water injection and S-107 to remain on MI injection while the AA requests are processed by the AOGCC. Oliver Sternicki Hilcorp Alaska, Hilcorp North Slope LLC Well Integrity Engineer Office: (907) 564 4891 Cell: (907) 350 0759 Oliver.Sternicki@hilcorp.com The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that 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. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby 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 Aurora Well S-107(PTD# 201113) Request to amend AIO 22F.001 to allow WAG Injection Operations Dear Mr. Price, Hilcorp North Slope, LLC requests approval to amend AIO 22F.001 to allow WAG injection into Prudhoe Bay Aurora well S-107(PTD# 201113) with intermittent slow tubing by inner annulus communication. No increase to Maximum Operating Annulus Surface Pressure (MOASP) is required. S-107 currently operates under AIO 22F.001 for continued water injection with slow TxIA communication, approved on 1/7/2020. On 11/17/2020, S-107 was approved by the AOGCC to be place under evaluation to monitor for TxIA communication when on MI service. The well was placed on MI on 9/13/2021 for an initial 60-day evaluation period. An additional 60-day evaluation was approved on 11/4/2021 due to seeing no anomalous IA repressurization in the first 60 days. Over the course of the evaluation period one IA bleed was performed on 12/22/2021. This bleed was all fluid and was likely a result of fluid packing the annulus for the passing AOGCC witness MIT-IA to 3412 psi on 12/09/2021. Hilcorp North Slope, LLC has determined that well S-107 is safe to operate in its current condition and requests amendment to AIO 22F.001 for continued WAG service based on the following: x IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. x AOGCC witnessed MIT-IA passed to 3412 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 Oliver Sternicki at 907-564-4891. Sincerely, Stan Golis PBW Operations Manager Attachments TIO/ Injection Plot Wellbore Schematic Digitally signed by Stan Golis (880) DN: cn=Stan Golis (880), ou=Users Date: 2022.01.06 15:50:15 -09'00' Stan Golis (880) Prudhoe Bay Aurora Well S-107 Technical Justification for Administrative Approval Amendment Request 01/05/2022 Well History and Status Well S-107 was drilled and completed as a WAG injector in August 2001. The well was on Miscible Gas Injection when IA repressurization occurred in March of 2019 and the wells was classified as Not Operable in May of 2019. A WAG swap occurred in September 2019 and the well was placed on produced water injection on 12/10/19. The well passed an AOGCC witnessed MIT-IA to 3,242 psi on 12/20/19 and was approved for water only service by the AOGCC under AIO 22F.001 on 1/7/2020. The well was placed on temporary MI service to evaluate TxIA communication for up to 120 days beginning 9/13/2021. Very little IA repressurization has been see over the course of the under evaluation period with most IA pressure changes associated with MI rate changes. To confirm the primary and secondary barriers a passing AOGCC witnessed MIT-IA was conducted on 12/09/2021 to 3412 psi while on MI. Recent Well Events: 12/22/2021 IA pressure bled from 920 psi to 350 psi in 2 min. 0.3 bbls bled 12/09/2021 Online AOGCC witnessed MIT-IA passed to 3421 psi 11/04/2021 Additional 60-days approved by AOGCC 9/13/2021 60-day under evaluation period began 11/17/2020 AOGCC approved temporary MI service to evaluate TxIA communication 1/7/2020 AIO 22F.001 approved for continued water only injection 12/20/2019 AOGCC MIT-IA Passed to 3242 psi 5/22/2019 Offline MIT-IA Passed to 2448 psi 5/20/2019 LDL did not identify any leak 3/28/2019 PPPOT-T Passed 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 3412 psi on 12/09/2021, which tests both barriers, demonstrates competent primary and secondary barrier systems. No further diagnostics/ repair attempts are proposed at this time. 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 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. 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 Plots Wellbore Schematic I'HE S`1'A'I'E Alaska Oil and Cas olALASKA Conservation Commission GOVERNOR A1IKE DUNLEAVY 333 west Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.00gcc.alaska.gov 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 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. Sternicki: 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 AID 3C, and Rule i 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°"" Daniel T. ,ro"mww+a, Jessie L. rrmmi�aP„sa Mpne°"' °'"`"kmxirom M. Price Seamount,Jr. °tea"''°°'°"`°' Chmielowski °e1i030.1amo9�p:.: 9B"° ,:,,,eawoa Jeremy M. Price Daniel T. Seamount, Jr. Jessie L. Chmielowski Chair, Commissioner Commissioner 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 most set out the respem in which the order or decision is believed in 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 in 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 in superior court. The appeal MUST be filed within 33 days after the dam 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 dam on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of nine above, the date ofthe 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. AID 11 PTD Well --A--03 AA Date AA mandated max IA pressure (psi) New AA mandated max. IA pressure (psi) 3C.001 1710380 12/19/2019 2000 2100 4E.024 1750690 4G1-04 4/29/2007 2500 2100 4E.032 1760140 FG I-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 36.001 1880700 W-24 3/15/2016 2000 2100 4E.017 1931850 14-01 2/21/2007 2000 2100 4G.006 1940130 0`�3 4/6/2017 2000 2100 4F.007 1961440 X-33 q/11/2016 2000 2100 4F.004 1972180 13 7/9/2015 2000 2100 3.024 1982060 R-11 1/25/2017 2000 2100 4F.005 1982140 5-25 10/2/2015 2500 2100 311.008 0530 5-11 3/6/2018 2000 2100 36.003 1ss199125o 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 38.006 2061050 Z-19 2/14/2017 2000 2100 38.009 2080930 V-05 11/14/2018 2000 2100 4E.039 2091390 03-37 9/6/2011 2000 2100 36.002 2101010 5-41 8/2/2016 2000 2100 24B.006 2111240 2-116 I3/5/2019 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 R -22A 7/23/2020 2000 2100 4G.008 2141650 R-22AL1 7/23/2020 2000 2100 4G.010 2021450 PS1-01 8/10/2020 2000 2100 4G.011 2050200 17-13A 8/10/2020 2000 2100 BP Exploration (Alaska) Inc. Ryan Daniel, Well Integrity Engineering Team Lead Post Office Box 196612 Anchorage, Alaska 99519-6612 March 9, 2020 bp 0 RECEIVED Mr. Jeremy Price MAR 0 9 2020 Alaska Oil and Gas Conservation Commission 333 West 7th Avenue AOGCC 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 Date AA mandated 1A pressure max Current 1A NOL (psi) (psi) 3C.001 1710380 A-03 12/19/2019 2000 12000 4E.024 1750690 NGI-04 4/29/2007 2500 2000 4E.032 1760140 NGI-05 6/y/2008 2500 2000 4F.002 1810740 17-08 4/3/2015 2000 20DO 46.009 1811770 11-07 12/12/2019 2DDO 2000 4F.006 1820260 13-17 12/7/2015 2000 2000 4F.008 1831700 14-27 5/23/2016 2000 20DO 46.001 1840280 09-25 8/2/2016 200D 2000 3B.001 1880708 'N-24 3/15/2016 2000 2000 4E.017 1931850 14-01 2/21/2007 2000 2000 4G.006 1940130 5A3 4/6/2017 2000 2DW 4F.007 19G1440 X-33 4/11/2016 2000 2000 4F.004 1972180 13-06 7/9/2015 2000 2000 3.024 1982060 R-11 1/25/2017 2000 2000 4F.005 1982140 S-25 10/2/2015 250D 2000 38.008 1990530 S-11 3/6/2018 2000 2000 38.003 1991250 X-24 8/2/2016 20DD 2000 4E.020 1991310 1715 3/17/2007 20DO 20DO 3.025 20DD9D Na 1/14/2011 20DO 2DDD 3.029 2DD1570 B-22 4/28/2010 2001' 2000 22F.001 2011130 S-107 1/7/2020 20W 2000 4F.001 21240 PSI09 3/6/2015 2000 2000 3.015 2051380 P-06 3/13/2007 2000 2000 G.003 2051600 1331 9/1/2016 2000 2000 38.006 2061050 Z-19 2/14/2017 20W 2000 38.009 2080930 0-05 11/14/2018 2000 2000 4E.039 1390 n137 9/6/2011 2000 2000 38.002 2101010 Sal 8/2/2016 200 2D00 24B.006 111240 Z-116 3/5/201920DD 2000 46.008 141640 R-22 2/15/2018 2000 2000 3.03 2150660 P-10 9/11/2015 120DO 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. s rzcccm r i ��krd ,3UNIli zmom tPmm 3n:;mu Figure 1- EOA DS Gas Lift Header Pressure EOA Gas Lift Pressure i 3;1(xm1 613NID15 ei I., WIW.33 11 IMM MI.. 3(l�mt6 Figure 2- WOA Pad Gas Lift Header Pressure WOA Gas Lift Pressure z;uzms 6;zv:Dls TV, rA,, 1 Irl e,Pnms s;za-mu luvnms v6(xms v3s•m16 w,. —Oi of —os ox —mos —m m osm —M31 —DS 13 —DS,< —DS 16 —DSI] —evatl —DPs1 X Petl —JP.E —1 PaY —xPaa —vPm 9 PSE —SPtl —D P.E E.� .P. .P.tl I NE I P.E 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 IZoZo ��I �L BP Exploration (Alaska) Inc. Oliver Sternicki, Well Integrity Engineer Post Office Box 196612 Anchorage, Alaska 99519-6612 December 31, 2019 bp 0 R",�'+k"�9gpa"16x1 Mr. Jeremy Price, Chair JAN 0 2 2020 Alaska Oil and Gas Conservation Commission n ,/�+ 333 West 7th Avenue A®CCC Anchorage, Alaska 99501 Subject: Prudhoe Bay Well S-107 (PTD # 2011130) Request for an Administrative Approval to continue Water Injection Operations Dear Mr. Price, BP Exploration (Alaska) Inc. requests an Administrative Approval (AA) for continued water injection into Prudhoe Bay well S-107. No increase to normal operating limit (NOL — formerly MOASP) is required. S-107 was identified to have anomalous IA repressurization in March 2019 while on Miscible Gas Injection. A Leak Detect Log was performed on 05/20/19 while the well was on gas injection but did not identify any active leaks. On 05/22/19 with the well offline, a passing MIT -IA was performed to 2,448 psi. In preparation for the Administrative Approval request, the well was placed on Produced Water Injection Under Evaluation and an AOGCC witnessed MIT -IA passed to 3,242 psi on 12/20/19. Wireless gauges have been installed on S -pad wells that allow for real time monitoring of IA and OA pressures. BPXA has determined that well S-107 is safe to operate in its current condition and requests an AA for water injection based on the following: • IA pressure can be maintained below NOL by managing the IA re pressurization with periodic annular bleeds. • MIT -IA passed to 1.1 times maximum anticipated injection pressure. • IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 907-564-4301 or Ryan Holt at 659-5102. Sincerely, Oliver Sternicki BPXA Well Integrity Engineer Attachments Technical Justification TIO Plot Injection Plot Wireless Gauge Plot Wellbore Schematic Prudhoe Bay Well S-107 Technical Justification for Administrative Approval Request December 31, 2019 Well History and Status Well S-107 is a WAG injector that was drilled and completed in August 2001. The well was on Miscible Gas Injection when IA repressurization occurred in March of 2019 and was classified as Not Operable in May of 2019. A WAG swap occurred in September 2019 and the well was placed on produced water injection on 12/10/19. The well passed an AOGCC witnessed MIT -IA to 3,242 psi on 12/20/19. It is currently classified as Under Evaluation to pursue an AA for water only injection. Recent Well Events: 12/20/2019 AOGCC MIT -IA Passed to 3242 psi 5/22/2019 Offline MIT -IA Passed to 2448 psi 5/20/2019 LDL did not identify any leak 3/28/2019 PPPOT-T Passed 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 2,448 psi on 05/22/19, which tests both barriers, 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. Water injection only 2. Record wellhead pressures and injection rate daily. 3. Submit a report monthly of well pressures and injection rates to the AOGCC. 4. Perform a 2 -year MIT -IA to 1.1 x maximum anticipated injection pressure. 5. The well will be shut-in and the AOGCC notified if there is any change in the wells mechanical condition. B 9 -EV - E ELLV = 110 114' CSG 45.5#. L-80. D = 9.980' - 4265' DKRKOPATC1/,U=245'(UWII 19) i 10863'-IOB78_- Minimum ID=2.31" @ 12250' i 4-12" x 2-718" NIPPLE REDUCER FERFORATxx4 SUk"R( REFLOG: SF$SO'-S IA0%DOND7728101 ANOI.FATTOPMW W@11730 - NOW Rifw To ProdmWn CB for IisWriCal pert data SME SPF N161VAL OpDisD2 DATE KA 4 11730-11732 S 07117MI NA 6 W35-11737 O 0713/X}1 NA 6 11850-11852. O 07131101 4518' 5 11900 - 12150 O 07131001 NA 4 11950- 11952 5 07117i01 4 -SW SLTD 15127- 15938 O 08l MI 14 117 TBG. 12 60, L 80.0152 6pT D = 3.958' 1 1 12262' S_ O SAFETY NOTPS: WS RBADINGS AVERAGE 125 pp. OMB/ ON MI. WELL REQUIRES A SSSV WHEN ON ML WELL>70-a 12485. Tlffi�29273r 4-1/2' NL410UO SSSVR D=3.813' 11827r•x+1rr BKH PNLN PKR. 9)-38Mr 1196r 6611. 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D18122 �- x4-12' LIR 120M, L -0a, .0152 Opf, D - 0250• IAit RLV DY I (7JI.R£RIS DATE I RFV BY I CL*SEW5 AURDRA IJU VAIL 5-107 PPEFW W: 201113 APIM W4D29-23023.00 SEC 35, T12K R12F 455V NK 84496' Y*L ow(191111 ORGWAL COMPLETION 01M9112 T►WJAO ADEEDHZSSAFETY NOTE 102271 R ..'PJC URAF1 ODRFECM : 10/17117 BTNAO SETBKRDP(1004'17) 0901108' KSEVPJC GLV 00(07127X18) 01/10718 GBIJ D RLL®BP(01/05118) 03+1909 'iI fd4VSV SETPATf;F1(03111/09) 04+07XNJ' OABISV SETHpffwxTR(OHY3X19) BP Blploratitm(AISNa) (RJ75Ht hflUMD ACO(3)SSSV SAf-m IUTE su M 2 �N HY TIO Plot 11,11 , 1p1 X. �� 19 c W, * (I —C., 19 C£,I '..q9 0>6 015 1711" 1 11 ir�il I W 10 TIO PI., Tb, IA OA WA ♦ WOA On ■ Bl. 0,,.bW + W op., ♦ U.d., E.•I Tempemw� Injection Plot V1.11 s I., V .n1 X, 1.0, 19 N, :7 15 1 i N f e.l 7, Ta 111 11 Il. 1 .1215 Wireless Gauge TIO Plot Real time pressure data during same time frame, transmitted via wireless gauges. rt }!A • i8v. • iBA � &SO I eA - en B40 e� .x 1Ua Ufa LL eUL PLLf 9]0U �-U "S4 <4LC uU4U 34JU -��L y4J Wireless Gauge TIO Plot Real time pressure data during same time frame, transmitted via wireless gauges. i 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`h 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. 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 71h 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 fileH Hollis S. French Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CERTIFIED '�m'f� OF PUBLICATION WITH ATTACHED COPY OF ADVERTISMENT. ADVERTISNG ORDER NUMBER 1 A AO -19-014 FROM: AGENCY CONTACT: Jody Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OFA.O.AGENCY PHONE: 333 West 7th Avenue 11/16/2018 (907 279-1433 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: (907) 276-7542 TO PUBLISHER: SPECIAL INSTRUCTIONS: Anchorage Daily News, LLC PO Box 140147 Anchorage, Alaska 99514-0174 TYPE OF ADVERTISEMENT: W LEGAL DISPLAY W CLASSIFIED r OTHER (Specify below) DESCRIPTION PRICE AIO 19-033, 034 and AIO 18-035 Initials of who prepared AO: Alaska Non -Taxable 92-600185 :0RMIT#NW10E SBDWTntG APVERTISlyG: :;;QRP6RNlly G4`R'fIRI�DA;FfYUAY1T OF:; :ht;181,:(ration:wlre;ATrn,'cdslr,rQpoF:; AOGCC 333 West 71h Avenue Anchorage, Alaska 99501 Pae 1 of I Total of All Pastes $ REF Type Number Amount Date Conmmnts I PvN VCO21795 2 AO AO -19-014 3 4 FN AMOUNT SY Act. Template PGM LGR Object FY DIST LIQ I 19 A14100 3046 19 2 3 q Porch si A ri e: d: Purchasing Authority's Signature Telephone Number ivi ency name must ap on all invoices and documents relating to this purchase. late is registered for tar free ImnsaGicns under Chapter 32. IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and not fa 6aRTh RIBUTION ....... ..... . . . AG : Caples Pu6l cher (faxedj",:Dlvlslon Fiscal, Rece#wng::: Form: 02-901 Revised: 11/16/2018 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. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 ANCHORAGE DMIXN8 AFFIDAVIT OF PUBLICATION Account#: 270227 Order# 0001430662 Product ADN -Anchorage Daily News ST OF AK/AK OIL AND GAS Cost $239.06 Placement 0300 CONSERVATION COMMISSION Position 0301 333 WEST 7TH AVE STE 100 aurunoar:F avootninGgo 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 cfXrFgd private indivigluals. kcribed and swo before me 19th day of Noylafter, 2018 Notary Public i and for The Stated ska. Third Division Anchorage, Alaska MY Notary Public BRITNEY L. THOMPSON State of Alaska My Commission Expires Feb 23, 2019 , STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Numbers: AID 18-033, AIG 18-034, and AID 18-035 Prudhoe Bay Unit, Aurora, Borealis, and Prudhoe Oil Pools The application of BP Exploration (Alaska) Inc (SPXA) 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. 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 701 Avenue, Anchors a, Alaska 99501. To request that the tentatively scheduled hearinS 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 ahearing. 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 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. Hsignature on file// Hollis S. French Chair, Commissioner ANCHORAGE DAILYN-11%8vs AFFIDAVIT OF PUBLICATION Account#: 270227 ST OF AWAK OILAND GAS CONSERVATION COMMISSION 333 WEST 7TH AVE STE 100 eurunoenc AK 0aSni gggo 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 ct�rg d private indivi;ruals. Scribed and swo before me 19th day of NovViber, 2018 Notary Public III and for The State dtb4ska. Third Division Anchorage, Alaska MY Order# 0001430662 Product ADN -Anchorage Daily News Cast $239.06 Placement 0300 Position 0301 Notary Public BRITNEY L. THOMPSON State of Alaska My Commission Expires Feb 23, 2019 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket 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 amendments to existing area Injection orders in accordance with 20 AAC 25.215 authorizing the downhole commingling of injectionbetween 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, Anchors a, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be flied 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 t0 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. //signature on file// Hollis S. French Chair, Commissioner Publsihed: November 18, 2018 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 7`h Avenue, Suite 100 Anchorage, AK 99501 RECEIVE® JUL 3 0 2018 AOGCC 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 313 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, jjvr-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 38 July 24, 2018 Additional Information in Support of Application Introduction Area Injection Orders ("AIO") 3B, 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-2213) 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. 2 en3I01 ;Soo U0191 S -31A Aurora -Prudhoe Oil Pool Commingled MI Injection Splits per differential injectivity methodology (shown): 82%Aurora, 18% Prudhoe Splits per 3/6/101 PROF with MI Inj @ 2975psi WHIP: 83% Aurora, 17% Prudhoe 3400 y = 0.2082x + 2638 -' 3200 y = 0.1652x + 2649 3000�� O o O 00 2800 X090' 0 2600 O 11 2200 WE ♦ + O Commingled MI Injection Mar -Jun 2010 ♦ Aurora Only MI Injection Oct 2009 -- —— Linear (Commingled MI Injection Mar -Jun 2(1 — — - Linear (Aurora Only MI Injection Oct 2009) 500 1000 1500 2000 2500 3000 3500 MI Injection Rate (mscf/d) 4000 4500 5W, 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 36 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[ J'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-31 A] 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 iniectivity 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 iniectivity profiles or injection survey unless significant changes in total iniectivity occur whereby an injection survey or separate pool infectivity test will be performed. (c) Annual and total cumulative volumes injected by pool and results of logs, [or ]surveys, or separate pool multi -rate iniectivity 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: AIO 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-31 A], 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 iniectivity 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 AI0's 22E, 24B and 3B July 24, 2018 once per year t] Thereafter as long as the well continues commingled injection, allocation will be based on use of differential injectivity profiles or iniection 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. Amendment to Borealis Oil Pool AlO 24B: Rule X. Wells Authorized for Downhole Commingled Injection 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 iniection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of infected fluids. 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 stearate 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 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 38 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 36 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 315 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