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Home My WebLink AboutO 221Other Order 221 Docket Number: OTH-25-031 Badami Unit 1. ------------------ Background information 2. May 27, 2025 AOGCC notice of proposed enforcement action 3. June 2, 2025 CEI request for informal review 4. June 17, 2025 CEI documents and response following informal review 5. August 22, 2025 CEI request for hearing 6. September 2, 2025 AOGCC notice of public hearing 7. October 30, 2025 Mustang Holding comments 8. October 30, 2025 Hearing transcript, presentations, and sign in sheet 9. December 1, 2025 CEI post hearing brief STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Badami Unit VRU Flaring Event ) ) ) ) ) ) Docket Number: OTH-25-031 Other Order 221 Final Badami Unit January 23, 2026 FINAL DECISION AND ORDER On May 27, 2025, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice1) to Cook Inlet Energy (CIE) regarding the flaring of produced gas which was unable to be recovered in Badami’s production system due to a non- functioning vapor recovery unit (VRU) from October 2024 to March 2025. The Notice proposed a $357,905 civil penalty under AS 31.05.150(d). CIE requested an informal review which was held at the AOGCC office on June 17, 2025. During the informal review, CIE acknowledged the flaring but contested the determination that the flaring was considered waste, contested being fined, and contested the fine amount. During the informal review meeting, CIE provided a document (Informal Review Handout), enumerating its points. Following the informal review, CIE also supplied the AOGCC with a second document, titled “Response following Informal Hearing – Docket Number: OTH-25-031 – Badami VRU Flaring Event” (Informal Review Response) on June 17, 2025. Following the informal review, the AOGCC issued Other Order 221 (OO 2212) on August 14, 2025, which assessed a civil penalty of $357,905. Pursuant to 20 AAC 25.535(d), OO 221 would have become a final order had CIE not filed a request for a hearing within 10 days, in which case OO 221 would have taken no effect. CIE, by letter dated August 22, 2025, timely filed a request for hearing. A public hearing on the matter was held October 30, 2025. During the hearing, CIE was requested to provide additional information, so the record was left open through December 1, 2025. On December 1, 2025, CIE emailed the information (Post-Hearing Brief) to the AOGCC. The record closed that day at 5 PM. This final decision and order now follow. 1 Findings and conclusions within that Notice, that are not inconsistent with this Final Order, are adopted and incorporated by reference in this Final Order. 2 Findings and conclusions within that Order, that are not inconsistent with this Final Order, are adopted and incorporated by reference in this Final Order. Other Order 221 Final January 23, 2026 Page 2 of 9 FINDINGS AND CONCLUSIONS: 1. During the informal review, the hearing, and in its Post-Hearing Brief, CIE posited that the ~134-day flaring event was emergency- and safety-driven and hence not subject to waste categorization as per 20 AAC 25.235(d)(5)(B). CIE cited VRU failure, power turbine failure, arctic conditions, Nutaaq Pipeline flow assurance, personnel safety, and facility integrity as key drivers. As stated in OO 221, the AOGCC agrees that the primary cause of the flaring was the failure of the VRU unit, for which CIE had no backup unit to provide redundancy. However, arctic conditions are prevalent across the Alaska North Slope and are thus a reality faced by all North Slope operators for much of each year. Good oilfield practices are expected to be followed throughout the year by all operators, regardless of weather challenges. During the informal review, in its Informal Review Response, throughout its hearing testimony, and in its Post-Hearing Brief, CIE repeatedly conflated flaring due to the VRU failure with issues related to the power turbine failure. As stated in OO 221, the AOGCC recognizes Badami’s VRU failure and the power turbine outage as separate events. As documented in Forms 10-422, Facility Report of Produced Gas Disposition, and Forms 10- 405, Monthly Production Reports, all Badami wells were shut in during the power turbine outage, and no gas was flared. As such, any emergency situation caused by the power turbine outage does not justify Badami’s flaring associated with the extended VRU failure. Flared gas volumes addressed in this order are related solely to the VRU failure. While Badami production was completely shut in during the 23-day power turbine outage, Badami’s diesel generators provided sufficient electricity to power the Point Thomson (Nutaaq) pipeline systems at Badami, including communications, leak detection, and pipeline valves. During the 23-day power turbine outage, no corresponding reduction in Point Thomson production occurred. According to an email the AOGCC received on April 10, 2025, from the operator of the Point Thomson Unit (Hilcorp Alaska, LLC), Point Thomson production via the Nutaaq pipeline does not rely on oil production from Badami, but rather only on power for pipeline systems. For over 3 years prior to well B1-33A coming online, Badami field-wide oil production averaged just over or less than 1,000 barrels of oil per day (BOPD), and for 2 years prior to B1-33A coming online, Badami fieldwide gas production averaged less than 600 thousand cubic feet per day (600 MCFPD). The production facilities were capable of operating at this lower level of production throughout all weather conditions. Thus, full Badami well stock production is not necessary to maintain Nutaaq pipeline flow assurance. The AOGCC agrees that personnel safety and facility integrity are important considerations for any operator; however, these considerations cannot be used as blanket justifications for a facility to operate at full production and remain in continuous flaring status for nearly half a year. In its Informal Review Response, CIE stated “…CIE’s flaring was conducted to preserve existing oil production, maintain the operation of the Nutaaq Pipeline, and prevent life-threatening freeze-ups at the Badami facility during turbine outages in extreme Arctic winter…” As detailed above, flaring did not occur during the power turbine outage and therefore had no direct relation to personnel safety concerns or the prevention of life- threatening conditions. Rather, the evidence demonstrates that preserving existing oil Other Order 221 Final January 23, 2026 Page 3 of 9 production was a primary driver for the flaring, as CIE elected to maintain full production throughout the flaring period. Accordingly, the AOGCC disagrees that the flaring was entirely an emergency- and safety-driven response. 2. When asked during the informal review what specific actions had been taken to minimize the volume of gas flared, CIE stated it had not run HYSYS3 modeling to support flare- reduction assumptions. Later, when asked during the hearing what specific actions had been taken to minimize the volume of gas flared, CIE responded that HYSYS modeling had been used to determine the effect of shutting in wells on the volume of gas flared and that the impact would be very small. After further questioning, CIE acknowledged that the HYSYS modeling had only been performed following the informal review, after the six- month flaring event had concluded. When asked whether, at any time, a producing well had been shut in to evaluate whether a reduction in gas flaring would occur, and which well or wells had been shut in, CIE did not provide a clear or specific response. 20 AAC 25.235(c) states, in relevant part: “The operator shall take action in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air.” A review of CIE’s production data, including the number of wells online, produced oil volumes, and produced gas volumes during the periods before, during, and after the VRU failure, shows no discernible effort to reduce the volume of gas flared. 20 AAC 25.235(b) states, in relevant part: “The operator shall submit a written supplement for any flaring or venting incident exceeding one hour. The supplement must describe why the gas was flared or vented, list the beginning and ending time of the flaring or venting, report the volume of gas flared or vented, and describe actions taken to comply with (c) of the section.” A review of the actions taken by CIE to minimize the volume flared, as described in Form 10-422 supplemental narrative reports, repeatedly state: “Continue with maintenance on VRU until back online.” For an unusually long flaring duration extending across six months, during which the facility remained at full production, this stated action is insufficient to qualify as an action to minimize the volume of gas flared. Accordingly, CIE provided no evidence demonstrating that it took actions in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. Based on the above findings and email correspondence between CIE and the AOGCC dated January 31, 2025, and April 1, 2025, it appears that CIE’s operational decisions were production-based, with no demonstrable attempts made to minimize the volume of gas flared, in violation of 20 AAC 25.235(c). 3. During the hearing and in its Post-Hearing Brief, CIE stated that the AOGCC did not grant its request to operate and flare the gas of producer well B1-33A during the 23-day power turbine outage, and that the AOGCC’s refusal led to multiple operational consequences, including alleged reservoir damage, negatively affecting the ultimate recovery from B1- 33A. Additionally, in its Informal Review Response and during the hearing, CIE asserted that it was being treated differently from other operators, referencing the AOGCC’s 3 AspenTech’s Aspen HYSYS (name derived from “Hyprotech Systems”) is a chemical process simulator used in the oil industry for processing plant and refinery systems modeling. Other Order 221 Final January 23, 2026 Page 4 of 9 decision in Other Order 1944 (OO 194), which allowed Great Bear Pantheon’s Alkaid #2 well to be flared for economic justification in addition to well testing. The applicable statutes and regulations are clear and allow only one circumstance under which the AOGCC may pre-authorize the flaring or venting of gas: for the purpose of testing a well before regular production.5 “Regular production” is defined in 31.05.170(14) as: “Regular production means continuing production of oil or gas from a well into production facilities and transportation to market, but does not include short term testing, evaluation, or experimental pilot production activities that have been approved by permit or order of the commission.” Well B1-33A had been in regular production via the permanent Badami production facility for approximately 134 days prior to the power turbine outage. This fact precluded pre- authorization of the flaring or venting of gas from that well. Accordingly, any gas vented or flared would have been subject to evaluation through the Facility Report of Produced Gas Disposition (Form 10-422) review process. While any operator may apply for authorization to flare gas for the purpose of testing a well prior to regular production, and the AOGCC may, in its discretion, grant such authorization pursuant to 20 AAC 25.235(d)(6), CIE did not request authorization to flare B1-33A for well testing purposes, nor did CIE request approval from the AOGCC to operate B1-33A during the power turbine outage. Instead, CIE elected to shut in B1-33A on its own accord, forgoing its previously identified option to lift the well with nitrogen during the power turbine outage, as communicated to the AOGCC by email on January 29, 2025. With respect to the AOGCC’s approval of Great Bear Pantheon’s flaring of the Alkaid #2 well, the Conclusions of OO 194 state: “A long-term production test is necessary to determine if Great Bear has made an economic discovery and to be able to design production facilities for a full field development if it is determined that it has a viable project…” This finding reflects the basis for authorizing the flaring of an exploration well, namely, the absence of permanent production facilities, which is a distinguishing and determinative factor in the AOGCC’s decision to pre-authorize flaring. A material difference between the B1-33A and Alkaid #2 wells is that B1-33A is connected to a permanent production facility which is connected by pipeline to the Trans Alaska Pipeline System (TAPS), with facilities capable of injecting gas. In contrast, Alkaid #2 relied on temporary production facilities with no gas injection capability, and produced liquids were required to be trucked to another field for final processing prior to transportation through TAPS to market. CIE also appears to confuse the usage of the word “economics”. In the case of Great Bear Pantheon, the flaring was needed to help determine project economics. In the case of CIE, the flaring was used to contribute to its bottom-line economics. 4. During the hearing, CIE claimed that it had been penalized in a manner inconsistent with that of other operators and stated in its Post-Hearing Brief that Badami received the only gas waste enforcement action across the North Slope and Cook Inlet. In support of its claim, 4 Other Order 194, issued by the AOGCC November 23, 2022, authorized Great Bear Pantheon LLC to flare gas from the Alkaid #2 exploration well, for the purposes of a long-term production test. 5 20 AAC 235(d)(6). Other Order 221 Final January 23, 2026 Page 5 of 9 CIE compared Badami’s VRU-related flaring event to flaring events at other North Slope facilities occurring during the same period. 20 AAC 25.235(b) states, in relevant part: “Any release, burning, or escape into the air of gas other than incidental de minimis venting as authorized under (d)(4) of this section must be reported as flared or vented on the Facility Report of Produced Gas Disposition (Form 10-422). The operator shall submit a written supplement for any flaring or venting incident exceeding one hour. The supplement must describe why the gas was flared or vented, list the beginning and ending time of the flaring or venting, report the volume of gas flared or vented, and describe actions taken to comply with (c) of this section.” When reviewing flaring or venting of gas and determining whether any volume of gas flared or vented constitutes waste under 20 AAC 25.235(c), the AOGCC considers the written supplement submitted pursuant to 20 AAC 25.235(b). Specifically, the AOGCC evaluates the cause of the flaring or venting, the duration of the event, and the actions taken by the operator to minimize flaring or venting. For example, a single-day emergency shutdown of a Prudhoe Bay gathering center may result in a large volume of flared gas that is not classified as waste due to the sudden and unforeseen nature of the shutdown and the operator’s actions to minimize flaring by shutting in wells feeding the gathering center. In contrast, CIE’s flaring at Badami consisted of a months-long flaring event attributable to equipment failure, with no evidence of meaningful efforts to minimize flaring. Consistent with the waste determination made in OO 221, Other Order 226 6 was issued to a North Slope operator for a processing facility fin-fan bundle gas leak, resulting in the imposition of a civil penalty for gas permitted to escape into the air over a ten-month period. The duration of the release was a material factor in the waste determination in both orders. The AOGCC finds that CIE misunderstands both the waste determination process and the intent of the gas disposition regulations, which focus on event duration and mitigating actions taken by the operator, rather than solely on the volume of gas flared or vented. 5. During the hearing and in its Post-Hearing Brief, CIE cited 20 AAC 25.235(d)(5) and asserted that the AOGCC is required to review Form 10-422, Facility Report of Produced Gas Disposition, within 90 days of receipt. Based on this assertion, CIE claimed that the only valid review period for OO 221 was the flaring that took place during February and March 2025, thereby excluding earlier months within the flaring period, which spanned from October 2024 to March 2025. As written in 20 AAC 25.235(d)(5), after receipt of a Form 10-422, the AOGCC has the discretion within 90 days to authorize flaring or venting that exceeds one hour. Absent such authorization, gas flared or vented for a duration exceeding one hour is subject to classification as waste until authorization is granted. This 90-day period provides the AOGCC with time to evaluate whether authorization of flaring events exceeding one hour is warranted under the applicable regulatory standards. 6 Other Order 226, issued by the AOGCC December 26, 2024, was an enforcement action against Hilcorp Alaska, LLC for a months-long gas leak, from October 2023 to July 2024, in a fin-fan bundle at the Milne Point Central Facility Pad. Other Order 221 Final January 23, 2026 Page 6 of 9 CIE’s interpretation of the 90-day period in 20 AAC 25.235(d)(5) is incorrect, as is its assertion that Badami’s flaring volumes from October 2024, November 2024, December 2024, and January 2025 are excluded from review solely because the Notice was issued on May 27, 2025. Accordingly, the time frame addressed in this final order is the same as that specified in OO 221: October 9, 2024, to March 9, 2025. 6. During the hearing and in its Post-Hearing Brief, CIE emphasized that flared gas volumes had been accurately and timely reported. The AOGCC agrees with CIE that Forms 10-422, Facility Report of Produced Gas Disposition, were timely submitted. However, CIE did not accurately report flared gas volumes exceeding one hour, because purchased gas is not to be included in reported flared volumes pursuant to the Instructions for Form 10-422. Those instructions are published on the AOGCC website at https://www.commerce.alaska.gov/web/Portals/18/pub/Forms/10- 422%20Instructions.pdf. The inclusion of purchased Endicott gas in the reported over-one- hour flared volumes resulted in confusion and led to an inflated initial waste determination volume by the AOGCC (see Finding 8, below). The AOGCC does not treat the incorrect volumes reported on the Forms 10-422 as a separate violation for purposes of this final order. However, CIE is expected to re-submit any prior gas disposition reports that erroneously included purchased Endicott gas volumes reported in boxes 6 through 13. Concordantly, all future Forms 10-422 are not to include purchased gas volumes in these boxes. 7. During the hearing and in its Post-Hearing Brief, CIE asserted that the AOGCC improperly included sub-one-hour flaring in the waste determination of gas flared volumes, arguing that such flaring is explicitly allowed under 20 AAC 25.235(d). The AOGCC has reviewed the Badami sub-one-hour flaring volumes for the period at issue. The causes of the sub-one-hour flaring during the period under review are indistinguishable from the underlying VRU failure that resulted in continuous flaring exceeding one hour. Because the flaring event as a whole exceeded one hour, the exceptions for sub-one-hour flaring set forth in 20 AAC 235(d)(1) and (2) are inapplicable. Moreover, even if those exceptions were applicable, the AOGCC finds the flaring would nonetheless be subject to classification as waste pursuant to 20 AAC 25.235(e). Accordingly, all gas flaring volumes associated with this event are included in this waste determination. 8. During the informal review and the hearing, CIE stated that it purchased gas from Endicott to meet its facility power needs. CIE further explained that its production accounting system allocated all flared gas as gas purchased from Endicott and, therefore, that all flared gas volumes had been paid for, such that a waste determination should not apply to gas purchased from Endicott. During the hearing, CIE was requested to provide both a process flow diagram for Badami’s production train and a material balance explanation for a portion of its gas handling system. CIE provided both on December 1, 2025, as Exhibit 6, Process Flow Diagram – Gas Disposition, and Exhibit 7, Material Balance – Gas Disposition. Other Order 221 Final January 23, 2026 Page 7 of 9 While CIE’s production accounting system may allocate all flared gas volumes as gas purchased from Endicott, CIE’s Exhibits 6 and 7 demonstrate that purchased gas from Endicott is commingled with native gas produced at Badami within the overall fuel gas supply. Using the average volumes provided in Exhibit 7, approximately one-eighth of the total gas flared is gas purchased from Endicott, and approximately seven-eighths is native Badami gas. As stated in Other Order 191,7 the AOGCC agrees that gas purchased from Endicott is not subject to a waste determination because that gas has already been metered by a custody transfer meter. Accordingly, any volume of flared gas classified as waste during the VRU failure must be reduced by one-eighth. The AOGCC finds that, between October 2024 and March 2025, CIE flared a total volume of 51,015 MCF of gas, based on CIE’s submitted Forms 10-422. Accordingly, the volume of flared gas determined to constitute waste is reduced to 44,638 MCF, calculated as follows: (7/8)x(51,015 MCF) = 44,638 MCF. 9. During the informal review, in the Informal Review Handout, in the Informal Review Response, during the hearing testimony, and in the Post-Hearing Brief, CIE argued that the gas valuation methodology used by the AOGCC to determine the fair market value of the flared gas resulted in an overstated value. Rather, CIE asserted that the appropriate benchmark was the purchase price CIE paid for fuel gas from Endicott during the time period at issue, approximately $2.60 per MCF. CIE repeatedly requested that it be treated the same as other operators. The gas price information provided by CIE is for fuel gas from Endicott. As stated in Finding 8 above, the portion of the flared gas that was gas purchased from Endicott is not subject to a waste determination. In addition, CIE testified that the gas purchased from Endicott contains a higher level of impurities, implying that it may be of lower value than the native Badami gas. CIE did not provide evidence demonstrating that the Endicott fuel gas price was representative of fair market value of the native Badami gas, including evidence that the transaction was conducted at arm’s length and was not influenced by non-market considerations that may have affected the purchase price. Moreover, and inconsistent with this position, in its Informal Review Handout CIE assigned no market value to Badami gas, stating that it was for onsite use only. As stated in OO 221: “Resource conservation, including that of reducing or eliminating gas flare volumes, is of utmost importance to the State of Alaska, with lack of a current export path or current unrealized royalties being immaterial.” North Slope gas has intrinsic value. At present, that value may be realized through uses such as reservoir pressure maintenance and voidage replacement, reservoir enhanced oil recovery (EOR) applications, and artificial lift. In the future, these uses may continue, in addition to potential commercial gas sales. 7 Other Order 191, issued by the AOGCC January 20, 2022, addressed a petition that contended a months-long gas leak from fuel line in Cook Inlet should have been defined as waste by the AOGCC and treated accordingly. In the order, the AOGCC concluded that oil or gas that has been severed from its originating property and metered via a custody transfer meter does not constitute waste under the statutory definition at AS 31.05.170(15). Other Order 221 Final January 23, 2026 Page 8 of 9 AS 31.05.150(d) mandates that a waste “penalty shall be twice the fair market value of the natural gas at the point of waste.” The methodology used to determine the fair market value of Badami’s flared waste gas is the same methodology historically applied by the AOGCC to operators across the North Slope8: the prevailing value of North Slope gas published quarterly by the Alaska Department of Revenue, at https://tax.alaska.gov/programs/oil/prevailing/northold.aspx. The Department of Revenue’s publication states that “[t]his prevailing value is the weighted average sales price of gas to publicly regulated utilities in the north slope area.” The AOGCC finds that this publication provides an appropriate and reasonable basis for determining the fair market value of flared gas for purposes of AS 31.05.150(d). 10. Based on the above Findings and Conclusions, the AOGCC finds that CIE’s primary purpose for maintaining all Badami wells online and flaring associated low-pressure produced gas for a period of approximately six months was financially motivated. CIE made no demonstrable effort to reduce flared volumes. Accordingly, 44,638 MCF of Badami gas sent to flare is classified as waste and is subject to a civil penalty pursuant to AS 31.05.150(d), calculated as follows: 11. As stated in OO 221, the AOGCC recognizes that CIE has experienced repeated operational issues with the Badami VRU and that CIE has identified a significant inefficiency in the facility’s eductor system, resulting in substantially greater flaring volumes when the VRU is offline than would otherwise occur. Accordingly, the AOGCC will allow CIE a period of one year from the effective date of this final order to complete the upgrade or replacement of both the VRU and the eductor system to prevent future failures. Expenditures incurred for such upgrades or replacements will be credited against the $313,166 civil penalty. Costs associated with routine maintenance or repairs to either system shall not be credited against the penalty. 8 Recent Orders issued by the AOGCC with gas valuation referenced from the Alaska Department of Revenue are Other Order 200, issued July 19, 2023, which addressed the Colville River Unit Alpine CD1 drillsite subsurface blowout and gas release, and Other Order 226, issued December 26, 2024, which addressed a months-long gas release at the Milne Point Central Facility Pad. Quarter, Year Month Total waste gas (MCF) Fair market value, $/MCF Total ($) x2 ($) Qtr 4, 2024 October 8,223 3.503 28,805 57,610 Qtr 4, 2024 November 9,755 3.503 34,172 68,344 Qtr 4, 2024 December 10,027 3.503 35,125 70,249 Qtr 1, 2025 January 8,286 3.516 29,134 58,267 Qtr 1, 2025 February 5,764 3.516 20,266 40,532 Qtr 1, 2025 March 2,583 3.516 9,082 18,164 44,638 TOTAL: 313,166 Other Order 221 Final January 23, 2026 Page 9 of 9 NOW THEREFORE IT IS ORDERED THAT: CIE is assessed a civil penalty in the amount of $313,166 for the violation detailed within this final order. If this final order is not appealed, the penalty must be paid within 365 days of issuance. If appealed, the penalty will be held in abeyance until the appeal process is complete. The penalty amount specified above may be reduced by an amount equal to documented expenditures incurred on upgrading or replacing (does not include minor or major repairs) Badami’s VRU and eductor system over the one-year period following issuance of this final order. Documentation supporting any requested penalty reduction, including a description of the system upgrades or replacements and invoices for parts and labor, must be submitted to the AOGCC. CIE shall provide corrected Forms 10-422, Facility Report of Produced Gas Disposition, as detailed in Finding 6 above, such that purchased gas volumes are not included in boxes 6 through 13 on the forms. CIE shall complete the revised Forms 10-422 within three months of the issuance of this final order, unless the AOGCC approves an extension of this deadline. CIE shall also submit future Forms 10-422 such that purchased gas volumes are not included in boxes 6 through 13 on the forms. DONE at Anchorage, Alaska and Dated January 23, 2026. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner cc: Wade Boman Phoebe Brooks RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2026.01.23 10:17:08 -09'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2026.01.23 10:24:59 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Other Order 221 Final (CIE) Date:Friday, January 23, 2026 10:43:01 AM Attachments:OTHER221 Final.pdf Badami Unit VRU Flaring Event 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 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Badami Unit VRU Flaring Event ) ) ) ) ) ) Docket Number: OTH-25-031 Other Order 221 Badami Unit August 14, 2025 DECISION AND ORDER On May 27, 2025, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice1) to Cook Inlet Energy (CIE). The Notice was sent via certified mail and was delivered and signed for on May 28, 2025. The Notice proposed a $357,905 civil penalty under AS 31.05.150(d). SUMMARY OF PROPOSED ENFORCEMENT ACTION CIE violated AS 31.05.095, 20 AAC 25.235(c), and 20 AAC 25.235(d), by flaring produced gas which was unable to be recovered in Badami’s production system due to a non-functioning vapor recovery unit (VRU). Flaring of said gas occurred from October 2024 to March 2025, with a total flared volume of 51,015 MCF, according to CIE’s submitted Forms 10-422 Facility Report of Produced Gas Disposition. For this violation, the AOGCC proposed to impose a civil penalty on CIE of twice the fair market value of the flared gas under AS 31.05.150(d) in the amount of $357,905. FINDINGS AND CONCLUSIONS On June 2, 2025, CIE responded to the Notice and requested an informal review. The informal review was held at the AOGCC office on June 17, 2025. During the review, CIE acknowledged the flaring and contested the determination that the flaring was considered waste, contested being fined, and contested the fine amount. CIE’s points made during the review are below, along with AOGCC’s responses to each point made: 1.CIE acknowledged that the flaring occurred and was reported as required per 20 AAC 25.235. CIE stated that the flaring was not waste but a safety-driven response to equipment failure during arctic winter conditions. The AOGCC agrees that the flaring was duly reported on Facility Reports of Produced Gas Disposition (Form 10-422). The AOGCC defines this flaring as waste and does not agree that CIE’s response was purely safety driven, as all wells that were producing before the VRU failure were kept online after the failure for several months until the VRU was back online. 2.CIE pointed out that regulatory compliance was maintained, as all events were reported via Form 10-422, Facility Reports of Produced Gas Disposition, along with supplemental reporting, and that direct communications were maintained with the AOGCC. Other Order 221 August 14, 2025 Page 2 of 4 The AOGCC agrees that CIE reported flaring volumes via Form 10-422 per 20 AAC 25.235. The AOGCC points out that all operators are required to report gas disposition in this manner per production facility, regardless the nature of a production facility’s operations, be they “normal” or otherwise. Failure to report was and is not in question. The AOGCC agrees that supplemental reporting via email and direct telephone communication did take place. This being said, as the VRU troubles “rolled into” power turbine issues, initial communication from CIE did not make it clear that a separate issue had developed. Additionally, 20 AAC 25.235(b) and (c) require an operator to describe actions taken to minimize the volume of gas flared. CIE’s Form 10-422s for the period in question do not detail actions taken to minimize volume, only repeating the description of the flaring events. 3. CIE pointed out that the primary cause of the flaring was the failure of the VRU unit that had no backup unit to provide redundancy, and that the VRU failure was unexpected. CIE further pointed out that power turbine outages compounded the situation, leaving only diesel power, arguing that flaring was essential to avoid freeze-up and loss of life or infrastructure. The AOGCC agrees that the primary cause of the flaring was the failed VRU. However, justifying flaring due to turbine outages and the reliance on diesel generators is misleading, as this combination of events was only over a 2-week period of the 6 calendar months that the VRU associated flaring commenced. Additionally, this argument is baseless due to the fact that while both power generating turbines were offline, all production wells were shut- in, leaving no facility gas to flare. 4. CIE argued that the flaring was justified under 20 AAC 25.235(d)(5), due to the flaring being required for repairs and facility operations, emergency response to -40F conditions, and the ultimate recovery from new well B1-33A. The AOGCC points out that allowances detailed in 20 AAC 25.235 for flaring or venting of gas for a period exceeding 1 hour are by the AOGCC’s discretion (20 AAC 25.235 (d)(5)). When considering authorizing flaring for facility operations, emergencies, or for ultimate recovery, many things are considered, not least of all the time span of such flaring. CIE’s flaring at Badami extended across 2 yearly quarters and 6 different months, making careful consideration of a waste determination necessary. Moreover, even if flaring could be justified under the criteria listed in 20 AAC 25.235(d)(5), if there is no evidence of actions to minimize the flaring as required under 20 AAC 25.235(c), the AOGCC may classify the flaring as waste pursuant to 20 AAC 25.235(e). 5. CIE referenced Other Order 194 as a precedent previously set by the AOGCC for the allowed flaring volumes. Other Order 194 authorized the flaring of gas from a new production well on a lone drillsite lacking permanent production facilities. Applying for the authorization for flaring for purposes of testing a well before regular production is within rights of any operator. Upon application, the AOGCC, in its discretion, may authorize such flaring pursuant 20 AAC 25.235(d)(6). Authorization, past or present, for flaring of gas for well testing prior to regular production is not precedent for the same or another operator’s flaring of gas from regular production due to processing facility operations. Other Order 221 August 14, 2025 Page 3 of 4 6. CIE pointed out that the State received $4.76 million in royalties from Badami production during the VRU flaring event. CIE also pointed out that during the same time period 787,944 barrels of oil flowed down the Nutaaq Pipeline from Point Thomson. CIE claimed that shutting in Badami production would have halted all production. Other than considering whether flaring is necessary to prevent loss of ultimate recovery pursuant to 20 AAC 25.235(d)(5)(c), the AOGCC does not take royalties or other economic factors into account when enforcing Alaska Oil & Gas statutes. When Badami experienced the loss of power turbine generating capacity, and all production wells were shut-in, the emergency diesel generators were enough to supply power to keep the Nutaaq Pipeline operating. Also, this argument proposes a false dilemma, as shutting in some production wells was an option that was not pursued, as across all 6 months (minus the 2 weeks during the power turbine outage) the same production wells were kept online. 7. CIE made the point that flaring gas does not equate to lost royalties of the state, adding that the gas is for onsite use only and has no market value or export path. Resource conservation, including that of reducing or eliminating gas flare volumes, is of utmost importance to the State of Alaska, with lack of a current export path or current unrealized royalties being immaterial. 8. CIE argued that the gas valuation used to determine the overall value of the gas flared is overstated; that the only viable benchmark is CIE’s cost of gas when purchasing gas from Endicott for use at Badami. AS 31.05.150(d) mandates that a waste “penalty shall be twice the fair market value of the natural gas at the point of waste.” When determining the fair market value for waste determinations, the AOGCC has consistently utilized the prevailing value of North Slope gas published by the Alaska Department of Revenue, at https://tax.alaska.gov/programs/oil/prevailing/northold.aspx. The Department of Revenue’s publication states that “[t]his prevailing value is the weighted average sales price of gas to publicly regulated utilities in the north slope area.” The AOGCC concludes that this publication is an accurate method of calculating the fair market value of the flared gas. The AOGCC finds that CIE committed the violation as initially alleged in the Notice1 and that the proposed $357,905 penalty represents “twice the fair market value of the natural gas” flared as required by AS 31.05.150(d). However, the AOGCC recognizes that CIE is having repeated issues with the Badami VRU, and that CIE has identified a significant inefficiency in the plant’s eductor system, causing much more gas to go to flare when the VRU is down than the VRU normally captures. Accordingly, the AOGCC will give CIE one year from the date of this Order to complete the upgrade/replacement of both the VRU and eductor system that will prevent future failures, with expenditures within the year being credited against the $357,905 penalty. Costs for repairs to either will not be credited against the penalty amount. 1 The findings and conclusions within that Notice are adopted and incorporated by reference in this Order. Other Order 221 August 14, 2025 Page 4 of 4 NOW THEREFORE IT IS ORDERED THAT: 1. Cook Inlet Energy, LLC is assessed a civil penalty in the amount of $357,905 for the violation detailed within this Order. 2. If this Order is not appealed, the fine must be paid within 365 days of issuance. If appealed, the fine will be held in abeyance until the appeal process is complete. 3. The penalty amount specified above may be reduced by equal amount that is spent on upgrading/replacing (does not include minor or major repairs) Badami’s VRU and eductor system over the next year. Details of system upgrades, along with invoices for parts and work, will be required for such reductions. As an Operator involved in an enforcement action, Cook Inlet Energy, LLC is required to preserve documents concerning the above action until after resolution of the proceeding. DONE at Anchorage, Alaska and dated August 14, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE Pursuant to 20 AAC 25.535(d), this order becomes final 11 days after it is issued unless within 10 days after it is issued the person files a written request for a hearing, in which case the proposed decision or order is of no effect. If the person requests a hearing, the commission will schedule a hearing under 20 AAC 25.540. As provided in AS 31.05.080(a), within 20 days after this order becomes final as discussed above, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.08.14 10:30:07 -08'00' Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.08.14 10:54:14 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Other Order 221 (CIE) Date:Thursday, August 14, 2025 1:54:41 PM Attachments:OTHER221.pdf Badami Unit VRU Flaring Event Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v 9 From:David Pascal To:Coldiron, Samantha J (OGC) Cc:Stephen Ratcliff Subject:Response following Formal Hearing - Docket Number: OTH-25-031 - Badami VRU Flaring Event Date:Monday, December 1, 2025 1:37:30 PM Attachments:Exhibit 0 GLA Post Hearing Memorandum.pdf Exhibit 1 VRU Repair Timeline Summary Table.pdf Exhibit 2 VRU Maintenance Work Orders 2020-2025.xlsx - Read-Only.pdf Exhibit 3 VRU Internal Efforts after Failure.pdf Exhibit 4 VRU Repair Costs.pdf Exhibit 5 Freeze up issues during diesel use.pdf Exhibit 6 Process Flow Diagram Gas Disposition.pdf Exhibit 7 Material Balance Gas Disposition.pdf Exhibit 8 Fair Market Value of Gas at Badami.pdf Exhibit 9 Badami Flaring Formal Presentation.pdf Hi Samantha, Please give me confirmation on receipt of the document package Regards David Pascal Cover Letter December 1, 2025 From: Cook Inlet Energy, LLC Post-Hearing Submission Cover Letter Badami VRU Flaring Event – Docket OTH-25-031 To: Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue Anchorage, Alaska 99501 Re: Post-Hearing Submission – Badami VRU Flaring Event, Docket OTH-25-031 Dear Commissioners Chmielowski and Wilson, Cook Inlet Energy, LLC (CIE), a subsidiary of Glacier Oil & Gas Corporation, respectfully submits this post-hearing filing following the October 30, 2025 formal hearing. This letter accompanies the full memorandum and appendix package prepared at the request of the Commission. The attached memorandum consolidates CIE’s technical, regulatory, and operational positions, rebuts elements of AOGCC’s late-submitted presentation, and formally responds to information requested by the Commission during and after the hearing. We respectfully request that this filing remain confidential to the extent possible until a final decision is issued. I would also like to amend a statement that I made during my testimony. I incorrectly stated that I had 27 years of experience, when it should be actually be 17 years. The Badami unit first production has been 27 years. Please cross reference my testimony to make sure I did not swap the two numbers and correct accordingly. Sincerely, David Pascal Chief Operating Officer Glacier Oil & Gas Corporation 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 2 of 17 E. Comparative enforcement shows inconsistency .......................................... 11 1. Badami’s flaring volumes were minimal in comparison. ............................ 13 2. AOGCC formally deemed larger volumes as “safety” or “lease-use.” ......... 13 3. Other operators kept wells online during compressor outages without NOVs. .................................................................................................................. 13 4. AOGCC has not issued NOVs for numerous high volume events. ............... 13 5. AOGCC has not consistently applied 20 AAC 25.235(c). ............................ 13 F. AOGCC’s claim that CIE could have shut in wells is technically incorrect ...... 14 G. CIE acted in full good faith .......................................................................... 14 H. Rebuttal to AOGCC’s Presentation .............................................................. 14 1. “Relative flaring vs production volumes” is not supported by regulation ..... 15 2. Numerous operators flare large volumes under the same conditions without NOVs .......................................................................................................... 15 3. AOGCC’s claim that wells should have been shut in is technically incorrect .................................................................................................................. 15 4. AOGCC minimized the turbine outage’s impact ........................................ 15 5. AOGCC did not account for all gas being purchased and royalty-paid ........ 15 VIII. RELIEF REQUESTED ..................................................................................... 16 A. Withdraw the Notice of Violation ................................................................. 16 B. Eliminate the proposed $357,905 penalty .................................................... 16 IX. CONCLUSION ............................................................................................... 16 Exhibits .............................................................................................................. 17 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 3 of 17 I. INTRODUCTION Cook Inlet Energy, LLC (“CIE”), a subsidiary of Glacier Oil & Gas Corporation, submits this Post-Hearing Brief pursuant to AOGCC procedures following the formal hearing held on October 30, 2025, regarding the Commission’s Notice of Violation (“NOV”) and proposed administrative penalty of $357,905 for alleged waste of gas related to the Badami Vapor Recovery Unit (“VRU”) failure and subsequent flaring from October 2024 through March 2025. This filing consolidates the complete factual record, technical analyses, engineering evidence, regulatory interpretation, comparative enforcement data, and hearing presentation material submitted by CIE before, during, and after the hearing. It also addresses claims and arguments raised for the first time in the Commission’s presentation at the hearing. The record shows that the Badami flaring was: • Required for safety, • Authorized under 20 AAC 25.235(d)(5), • Fully and transparently reported, • Minimized to the maximum extent practicable, • Overstated in the NOV due to regulatory timing errors, • Valued using a gas price not reflective of actual cost, and • Penalized in a manner inconsistent with the Commission’s treatment of similarly situated operators. For the reasons explained herein, CIE requests the Commission: 1. Withdraw the NOV, and 2. Eliminate the proposed penalty, because it includes categories of flaring expressly allowed under 20 AAC 25.235, the NOV is based on volumes outside the regulatory review period, , is inconsistent with enforcement treatment of similarly situated Operators, and relies on an inflated gas valuation methodology. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 4 of 17 II. PROCEDURAL HISTORY • On October 9, 2024, Badami’s 3rd-stage VRU compressor suffered a catastrophic mechanical failure. All gas was immediately diverted to the flare to prevent over pressure, freeze-up, and facility hazards. • CIE submitted accurate Form 10-422 monthly gas disposition reports for all flaring associated with the Badami VRU outage from October 2024–March 2025, in accordance with AS 31.05 and 20 AAC 25.235. • On May 27, 2025AOGCC issued a Notice of Proposed Enforcement Action citing 51,015 MCF of flaring from October 2024–March 2025. Of note, the date of issuance falls outside the (90) day regulatory review period dictated in 20 AAC 25.235(d)(5) for October 2024-January 2025. • CIE timely requested an informal hearing and submitted supporting materials. • The informal hearing occurred June 2025, where CIE presented initial engineering and regulatory arguments. • AOGCC subsequently issued the NOV and proposed penalty. • CIE requested a formal hearing on OTHER 221, which was granted. • The formal hearing was conducted October 30, 2025, during which the Commission introduced new claims not previously disclosed. At the hearing: • AOGCC presented a new slide deck, provided to CIE less than 24 hours before the hearing began. • Several new technical assertions and comparative arguments were raised that included but were not limited to Badami’s operation solely on diesel generators, relative volumes of gas flared by other operators, and the granting of exploration flaring not exclusively related to well testing. • The Commissioners requested additional modeling, PFDs, mass balances, documentation, and VRU repair details; majority of which CIE has supplied previously. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 5 of 17 This Post Hearing Brief is timely submitted following the Commission’s request to keep the record open until December 01, 2025 CIE is providing: • Freeze-up documentation • VRU repair invoices and logs • Separator gas mechanics analysis • Updated PFDs • HYSYS modeling • Comparative enforcement database analysis • Corrected NOV volume calculations • Gas valuation evidence III. ISSUES PRESENTED 1. Whether flaring during a VRU failure and turbine outage performed to prevent freeze-up, protect personnel, and maintain facility integrity constitutes “waste” under AS 31.05 or 20 AAC 25.235. 2. Whether CIE acted in good faith and minimized flaring to the extent technically and operationally possible. 3. Whether AOGCC improperly included de minimis venting, and sub-one-hour flaring in NOV volume calculations. 4. Whether AOGCC did not follow the (90) day review requirement by using Form 10-422 data from October 2024-January 2025. 5. Whether the Commission’s use of an inflated and incorrect gas valuation is permissible. 6. Whether the Commission applied regulatory standards consistently across North Slope operators. IV. STATEMENT OF FACTS A. VRU Failure Overview 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 6 of 17 • On October 9, 2024, the 3rd-stage VRU compressor at the Badami facility failed catastrophically. • Vendor diagnostics, teardown inspections, and repair orders confirm severe internal mechanical damage. • Part availability was constrained for 8–10 weeks, based on vendor communications. • Winter conditions (−35°F ambient, strong winds, limited daylight) restricted logistics, heavy lift and service access. • Repairing the VRU was the fastest and most effective engineering path to eliminate flaring, and CIE acted immediately to procure parts, mobilize vendors, and execute repairs despite running into long lead times and severe winter constraints; no alternative engineering solution (like installation of a new VRU or vacuum pump) could have reduced separator gas load or mitigated freeze-up risk. B. Turbine Outage Compounded Repair Limitations • From January 26–February 18, 2025, the site experienced a turbine failure that reduced available power. • Backup diesel generators were used, but facility, heat tracing, and circulation systems operated with reduced capacity. • The turbine outage resulted in a full shutdown of Badami production. To minimize operational impact and maintain heat and fluid stability, CIE requested temporary authorization to operate and flare from the B1-33A exploration well; an approach consistent with pre-approved flaring granted to other operators under 20 AAC 25.235(d)(6) for exploration wells in production testing phase. The well was transitioning to gas lift from the bottom-most mandrel from free flow after being brought online September 13, 2024.The Commission did not grant this request, leaving no viable alternative operational pathway during the outage. The turbine outage directly increased freeze up vulnerability. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 7 of 17 C. Freeze-Up Evidence during Turbine Outage CIE documented • The 2nd Stage Separator froze within 4 days of the turbine outage due to the lack of warm fluids from Badami’s highest producing well (B1-33) • Temperature readings below hydrate formation thresholds • Frost accumulation on lines • Flow conditions in pipeline requiring continuous management due to Badami leak detection systems being offline This confirms operating the turbine during the VRU outage was justified to mitigate freezing and safety concerns. D. Flaring Volumes Accurately Reported CIE submitted monthly Form 10-422 reports before the 20th of each month, showing: • All flaring volumes • VRU downtime logs • Continuous monitoring AOGCC staff did not object or notify of said volumes as waste within the 90-day period stated in 20 AAC 25.235(d)(5) for October 2024, November 2024, December 2024, or January 2025 filings. E. Royalty Treatment and Production Accounting of Flared Gas Because Badami requires the higher quality gas produced by Badami wells for power generation and to manage hydrogen sulfide limitations regulated under the Title V Air Operating Permit, the gas that ultimately got routed to the flare was fully allocated to Endicott purchase gas under established production accounting practices. Under Alaska’s production accounting framework, due to huge volumes of gas circulating in a lease that involves gas lift, injection, separation, and production operations, an operator may internally attribute gas from different sources for metering and allocation purposes so long as gas disposition rules are followed and the effective volume leaving the site are accounted for royalty and tax purposes. Accordingly: 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 8 of 17 • CIE purchased this gas at approximately $2.60 per MCF, and • The State received full royalty revenue on the associated volumes. Thus, even though flaring was unavoidable during the VRU outage, the underlying gas volumes were fully compensated, and the State incurred no financial loss. V. TECHNICAL BACKGROUND A. How the Badami Gas System Works The Badami facility relies on: • A 3-stage Vapor Recovery Unit • Two-phase and three-phase separators • A turbine generator for power and heat stabilization The VRU captures all flash gas removed from low pressure separator liquids. When the VRU is offline, this gas must be flared to prevent: • Safety hazards to personnel • Separator shut down and freeze up • Hydrate formation • Pressure excursions From VRU Flaring with Varying Wells: • Flash gas liberated at the separator is determined by pressure and thermodynamic phase behavior. • VRU inlet gas load remains driven by separator thermodynamics. • Shutting in wells reduces liquid flow and heat input, thereby increasing freeze up risk. B. HYSYS Modeling Conclusions (VRU Flaring with Varying Wells) CIE-run HYSYS simulations is establishing that: • Flash gas liberated at the separator is not significantly affected by shutting in individual wells, even high-GOR wells. • Gas-in-liquid remains nearly constant across well configurations. • VRU inlet load is dominated by process fluid properties, not well count. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 9 of 17 • Therefore, flaring volumes would have been materially the same even if wells were shut in. Results and Observations: • High-GOR wells have minimal incremental impact on separator gas. • Shut-in scenarios reduce heat load in the tubing in the permafrost region, increasing hydrate risk. No modeled scenario showed a meaningful flaring reduction from shutting in wells. C. Why Flaring Was Necessary • Protected personnel safety by keeping power generation stable • Prevented freeze up by preventing shut down of equipment exposed to environment • Protected facility integrity • Prevented facility shutdown and loss of ultimate recovery from new exploration well (B1-33) • Prevented use of emergency diesel generators with limited power, limited onsite diesel storage, and reduced reliability • Prevented over pressure of the system Regulation 20 AAC 25.235(d)(A)-(C) allows flaring under these exact circumstances. VI. REGULATORY FRAMEWORK 20 AAC 25.235(d)(1)–(4) explicitly authorize: • Sub-one-hour flaring • Pilot gas • Purge gas • De minimis venting AOGCC improperly counted: • Sub-one-hour flaring • De minimis venting All are expressly allowed. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 10 of 17 AOGCC included these in the NOV volume. 20 AAC 25.235(d)(5) further authorizes flaring: “…for repairs, emergencies, or normal facility operations necessary to prevent harm.” The VRU failure, turbine outage, freeze-up risk, and Arctic operational constraints fall within this provision. A. 90-Day Review Requirement AOGCC must review Form 10-422 filings within 90 days. NOV was issued May 27, 2025 based on: • October 2024 (filed on November 20, 2024) • November 2024 (filed on December 18, 2024) • December 2024 (filed on January 20, 2025) • January 2025 (filed on February 19, 2025) These months were time barred by May 27, 2025. These were all beyond 90 days. Correct review-eligible volume: 9,126 MCF After deducting Endicott gas: 7,985 MCF VII. ARGUMENT A. The flaring was permissible under 20 AAC 25.235(d)(5) The regulation explicitly permits flaring required for safety, repairs, or to protect environmental or facility integrity. CIE’s evidence shows the flaring occurred due to: 1. A catastrophic VRU compressor failure 2. A multi-week turbine outage 3. Documented freeze-up 4. Severe Arctic weather conditions 5. Vendor delays and supply-chain constraints 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 11 of 17 CIE acted appropriately and in a safety first manner and executed the fastest solution to correct the deficiency. B. The NOV volume is legally invalid under the 90-day rule NOV volume: 51,015 MCF Valid review period: Feb–Mar 2025 Correct volume: 9,126 MCF After subtracting Endicott gas: 7,985 MCF AOGCC exceeded the statutory period by ~120 days. C. The NOV includes categories of flaring that are not violations AOGCC improperly included: • Sub-1-hr flaring • De minimis venting All are explicitly allowed. D. AOGCC overstated the gas valuation by 35% AOGCC valuation: ~$3.50/MCF Actual cost paid: ~$2.60/MCF Penalty was inflated before doubling. E. Comparative enforcement shows inconsistency Operators flaring more than CIE: Operator Volume Enforcement Great Bear Pantheon 146,044 MCF (authorized) None Finnex 101,431+ MCF (ongoing) None Prudhoe Bay 304,992 MCF None – same NOV period Kuparuk 11,188 MCF None – same NOV period Point Thomson 12,998 MCF None – same NOV period Northstar 58,753 MCF None – same NOV period Badami (CIE) 51,015 MCF NOV + $357,905 CIE was penalized despite having low volumes. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 12 of 17 CIE also conducted a detailed review of the AOGCC 10-422 database as part of its post-hearing submission. The purpose was to respond to Commissioner Wilson’s request for more context behind comparative flaring and to provide specific examples of how the Commission has historically applied discretion to flaring events. The analysis summarized shows that multiple operators have experienced VRU, compressor, flash-gas, or power-related failures resulting in significant flaring volumes, often with durations exceeding several months, with zero enforcement actions. The Commission treated these cases as “safety” or “lease-use” events and did not classify them as waste, even when: • Flaring volumes were orders of magnitude larger than Badami • The events lasted months or years • Operators did not take corrective action to minimize volumes • The causal mechanism (compressor outage, equipment failure) was identical to Badami • These examples represent only a limited subset of the comparative data. In its formal presentation, CIE provided a detailed, multi-year analysis of flaring volumes by operator and by field on the North Slope, including but not limited to the period covered by the NOV. That analysis demonstrates that Badami has historically and continues to flare among the smallest volumes on the North Slope, even during periods affected by VRU and turbine failures. Facility Start Date End Date Duration (Days) Flaring Volume (MCF) Cause AOGCC Action King Salmon 02/01/2022 06/17/2023 501 103,756 Compressor restart delayed No Corrective Action – Classified as Safety 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 13 of 17 Point Thomson 11/25/2022 12/12/2022 13 24,661 Flash gas compressor shutdown No Corrective Action – Classified as Safety Dolly Varden 09/15/2021 10/30/2021 45 12,765 Compressor outage Normal Operations – No NOV North Star 11/01/2020 01/13/2021 73 254,962 LP compressor outage No Corrective Action – No NOV These examples demonstrate the following: 1. Badami’s flaring volumes were minimal in comparison. Badami: 51,015 MCF (raw) King Salmon: 103,756 MCF North Star: 254,962 MCF Point Thomson: 24,661 MCF in 13 days Great Bear Pantheon (Order 194): 146,044 MCF in 97 days Badami received the only enforcement action across the North Slope and Cook Inlet. 2. AOGCC formally deemed larger volumes as “safety” or “lease-use.” Badami’s flaring was similarly caused by equipment malfunction and safety risk, not discretionary operation. 3. Other operators kept wells online during compressor outages without NOVs. This is identical to the condition AOGCC questioned at Badami. 4. AOGCC has not issued NOVs for numerous high volume events. None of the events listed above resulted in an NOV or penalty. 5. AOGCC has not consistently applied 20 AAC 25.235(c). Badami was penalized despite: • Safety justification 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 14 of 17 • Lower volumes • Shorter duration • Greater documentation • Purchased gas (royalty-paid) AOGCC’s enforcement against CIE is inconsistent with: • Its own precedent, • Industry wide practice, and • The requirement for consistent application of 20 AAC 25.235(c). F. AOGCC’s claim that CIE could have shut in wells is technically incorrect HYSYS results and CIE’s over-a-decade experience operating Badami facility demonstrate: • Shut-in does not significantly reduce separator gas • Shut-in increases freeze-up risk • Physical evidence shows freeze-up was already occurring AOGCC’s theory is contradicted by engineering. G. CIE acted in full good faith CIE did: • Report all volumes • Maintain excellent communication regularly with AOGCC • CIE emphasized over multiple communications that the most effective method to minimize flaring was an expedited repair to the VRU. Installing a new VRU would take about 1-2 years, which exceeded the repair timeline. • Minimized volumes of flared assist gas using best engineering practices to be in compliance with VE observation limits • Submit repair updates • Purchase and royalty-pay all gas • Invest > $500,000 in VRU repairs and system improvements H. Rebuttal to AOGCC’s Presentation 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 15 of 17 AOGCC’s hearing day arguments were raised with <24-hour notice and materially mischaracterized both law and engineering. 1. “Relative flaring vs production volumes” is not supported by regulation AOGCC claimed Badami’s flaring was significant “relative” to its oil production and cited Northstar as an example. Regulations define waste in absolute terms only. • AS 31.05 and 20 AAC 25.235 regulate volumes, not ratios. • No statutory basis exists for “flaring per barrel” or “relative flaring.” • This theory has never been applied to another operator. 2. Numerous operators flare large volumes under the same conditions without NOVs Many compressor outages and flash-gas events similar to Badami were treated as: • “Safety” • “Lease use” • “Normal operations” Badami is the only operator penalized in such circumstances. 3. AOGCC’s claim that wells should have been shut in is technically incorrect HYSYS simulations and separator-gas modeling show: • Shut-in does not reduce separator gas • Shut-in increases freeze-up risk • Facility logs document freeze-up already occurring This argument is refuted by engineering evidence. 4. AOGCC minimized the turbine outage’s impact Freeze up occurred regardless of outage duration. The hazard itself, not the length, is the safety driver. 5. AOGCC did not account for all gas being purchased and royalty-paid Penalty theory based on “economic loss to the State” is inapplicable. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 16 of 17 VIII. RELIEF REQUESTED CIE respectfully requests that the Commission: A. Withdraw the Notice of Violation Because it is based on ineligible volumes, includes authorized flaring categories, and is inconsistent with Rule 25.235. • Based on time barred months • Based on volumes expressly permitted under regulation • Based on technically incorrect claims • Inconsistent with enforcement precedent • Without regulatory support for “relative” flaring theory • Unsupported by the factual and engineering record B. Eliminate the proposed $357,905 penalty Because: • Operation of the turbine was justified for safety and facility integrity. Flared gas was necessary and not wasteful. • Gas valuation was inflated • NOV-eligible volume is significantly overstated • All gas was purchased and royalty-paid • CIE invested over $500,000 in corrective action • Enforcement is inconsistent and inequitable IX. CONCLUSION The evidence clearly demonstrates: • Flaring was necessary for safety and facility integrity, • CIE acted in good faith, • Reporting was complete and timely, • Engineering constraints were real and severe, • Regulatory requirements were followed, • Flared gas volumes were minimal compared to other operators, 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Page 17 of 17 • Enforcement is inconsistent with Commission practice. The record supports withdrawal of the NOV and elimination of the penalty. CIE operated safely, transparently, in good faith, and in compliance with the law. The VRU failure, turbine outage, and freeze-up hazards justified the limited flaring that occurred. The Commission’s late filed arguments were rebutted by engineering evidence, modeling, and factual data. For these reasons, CIE respectfully requests that the Commission withdraw the NOV and eliminate the proposed penalty in full. Exhibits 1. VRU Failure and Repair Timeline 2. VRU Internal Efforts before failure: VRU Maintenance Work Orders 2020-2025 3. VRU Internal Efforts after failure 4. VRU Spend Details 5. Freeze up issues during diesel use 6. Process Flow Diagram – Gas Disposition 7. Material Balance – Gas Disposition 8. Fair Market Value of Gas at Badami 9. Formal Hearing Presentation a. Depicting flaring from other sites, operations of several magnitudes b. Comparative Enforcement Research Exhibit 1: VRU Failure and Repair Timeline Timeline Summary Event #1 10/6/2024 VRU Compressor catastrophic failure event, caused by 3rd Stage Cylinder discharge valve breaking and entering the cylinder while in service 10/15/2024 – 10/17/2024 Siemen’s mechanics onsite for compressor condition assessment inspection 10/17/2024 – 1/6/2025 Repair parts procurement and equipment repairs 1/8/2025 – 1/23/2025 Compressor mechanics onsite for re-alignment and full compressor rebuild 1/23/2025 – 2/24/2025 Sourcing and mobilizing new crankshaft 2/26/2025 – 3/7/2025 New Crankshaft installation 3/8/2025 VRU Compressor back online Event #2 4/14/2025 – 5/09/2025 VRU taken oDline to investigate abnormal noise. Cylinder damage found 5/09/2025 – 6/26/2025 Cylinder Shipment and repair at Bender CCP in Vernon, CA 7/02/2025 VRU Compressor back online Event #3 7/17/2025 – 7/22/2025 VRU taken oDline. Filter debris found and cleaned out from valves and cages. Piston and Piston Rings damaged and need rebuilt or replaced 7/23/2025 – 8/19/2025 Piston and Rings sent to Dukowitz for piston rebuild and new piston ring fabrication 8/21/2025 VRU Compressor stage rebuilt and VRU back online Work Order Number Work Order Description Tag ID Date Time From Date Time To Work Order Status Work Order Priority Work Order Type Work Order Source 2020-00080 2020 January IG A/B and VRU monthly oil sample PM K-0002A K-0002B K-0001 1/1/20 1/31/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00083 January Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/1/20 1/31/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00142 January Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/15/20 2/14/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00198 2020 February IG A/B and VRU monthly oil sample PM K-0002A K-0002B K-0001 2/1/20 3/2/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00203 February Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/1/20 3/2/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00260 February Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/15/20 3/16/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00297 2020 March IG A/B and VRU monthly oil sample PM K-0002A K-0002B K-0001 3/1/20 3/31/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00299 March Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/1/20 3/31/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00336 March Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/15/20 4/14/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00386 2020 April IG A/B and VRU monthly oil sample PM K-0002A K-0002B K-0001 4/1/20 5/1/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00391 April Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/1/20 5/1/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00450 April Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/15/20 5/15/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00491 May Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/1/20 5/31/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-00502 May Week 2 Rollover PM for IG-A, IG-B, and the VRU K-0002A K-0002B K-0001 5/4/20 5/11/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00525 May Week 3 Rollover PM for IG-A, IG-B, and the VRU K-0002A K-0002B K-0001 5/11/20 5/18/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00534 May Week 4 Rollover PM for IG-A, IG-B, and the VRU K-0002A K-0002B K-0001 5/18/20 5/25/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00622 2020 Annual Fin Fan Bearing Bearing Greasing EAC-0001 K-0001 K-0002A 6/16/20 6/16/21 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00657 July 2020 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 7/1/20 7/31/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00917 October 2020 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 10/1/20 10/31/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-00973 October Week 4 Rollover PM for IG-A, IG-B, and the VRU K-0002A K-0002B K-0001 10/19/20 10/26/20 Closed 3. Regular PM PM / Scheduled Maintenance 2020-01003 November Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/1/20 12/1/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-01039 November Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/15/20 12/15/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-01080 December Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/1/20 12/31/20 Closed 2. Important PM PM / Scheduled Maintenance 2020-01119 December Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/15/20 1/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00079 January 2021 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 1/1/21 1/31/21 Closed 3. Regular PM PM / Scheduled Maintenance 2021-00083 January Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/1/21 1/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00131 January Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/15/21 2/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00199 February Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/1/21 3/3/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00240 February Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/15/21 3/17/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00288 March Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/1/21 3/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00324 March Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A 3/15/21 4/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00369 April 2021 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 4/1/21 5/1/21 Closed 3. Regular PM PM / Scheduled Maintenance 2021-00375 April Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/1/21 5/1/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00414 April Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/15/21 5/15/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00455 May Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/1/21 5/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00498 May Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/15/21 6/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00534 2021 VRU Biennial inspection K-0001 FL-0001 6/1/21 7/1/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00544 June Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/1/21 7/1/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00600 June Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/15/21 7/15/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00604 2021 Annual Fin Fan Bearing Bearing Greasing EAC-0001 K-0001 K-0002A 6/16/21 6/16/22 Closed 3. Regular PM PM / Scheduled Maintenance 2021-00650 July 2021 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 7/1/21 7/31/21 Closed 3. Regular PM PM / Scheduled Maintenance 2021-00655 July Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/1/21 7/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00720 July Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/15/21 8/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00761 August Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/1/21 8/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00806 August Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/15/21 9/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00851 September Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/1/21 10/1/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00879 September Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/15/21 10/15/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00937 October 2021 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 10/1/21 10/31/21 Closed 3. Regular PM PM / Scheduled Maintenance 2021-00947 October Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/1/21 10/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-00988 October Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/15/21 11/14/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-01055 November Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/1/21 12/1/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-01089 November Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/15/21 12/15/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-01138 December Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/1/21 12/31/21 Closed 2. Important PM PM / Scheduled Maintenance 2021-01181 December Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/15/21 1/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00079 January 2022 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 1/1/22 1/31/22 Closed 3. Regular PM PM / Scheduled Maintenance 2022-00083 January Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/1/22 1/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00160 January Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/15/22 2/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00222 February Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/1/22 3/3/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00270 February Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/15/22 3/17/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00315 March Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/1/22 3/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00360 March Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/15/22 4/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00418 April 2022 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 4/1/22 5/1/22 Closed 3. Regular PM PM / Scheduled Maintenance 2022-00425 April Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/1/22 5/1/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00490 April Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/15/22 5/15/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00533 May Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/1/22 5/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00587 May Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/15/22 6/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00652 June Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/1/22 7/1/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00702 June Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/15/22 7/15/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00708 2022 Annual Fin Fan Bearing Bearing Greasing EAC-0001 K-0001 K-0002A 6/16/22 6/16/23 Closed 3. Regular PM PM / Scheduled Maintenance 2022-00755 July 2022 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 7/1/22 7/31/22 Closed 3. Regular PM PM / Scheduled Maintenance 2022-00760 July Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/1/22 7/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00823 July Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/15/22 8/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00885 August Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/1/22 8/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00941 August Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/15/22 9/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-00991 September Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/1/22 10/1/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01048 September Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/15/22 10/15/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01104 October 2022 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 10/1/22 10/31/22 Closed 3. Regular PM PM / Scheduled Maintenance 2022-01114 October Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/1/22 10/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01174 October Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/15/22 11/14/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01234 November Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/1/22 12/1/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01288 November Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/15/22 12/15/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01333 December Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/1/22 12/31/22 Closed 2. Important PM PM / Scheduled Maintenance 2022-01387 December Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A 12/15/22 1/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00079 January 2023 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 1/1/23 1/31/23 Closed 3. Regular PM PM / Scheduled Maintenance 2023-00083 January Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/1/23 1/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00156 January Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/15/23 2/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00238 February Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/1/23 3/3/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00296 February Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/15/23 3/17/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00337 March Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/1/23 3/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00396 March Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/15/23 4/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00461 April 2023 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 4/1/23 5/1/23 Closed 3. Regular PM PM / Scheduled Maintenance 2023-00469 April Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/1/23 5/1/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00530 April Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/15/23 5/15/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00602 May Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/1/23 5/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00660 May Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/15/23 6/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00729 2023 VRU Biennial inspection K-0001 FL-0001 6/1/23 7/1/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00739 June Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/1/23 7/1/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00795 June Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/15/23 7/15/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00801 2023 Annual Fin Fan Bearing Bearing Greasing EAC-0001 K-0001 K-0002A 6/16/23 6/15/24 Closed 3. Regular PM PM / Scheduled Maintenance 2023-00853 July 2023 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 7/1/23 7/31/23 Closed 3. Regular PM PM / Scheduled Maintenance 2023-00858 July Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/1/23 7/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-00925 July Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/15/23 8/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01012 August Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/1/23 8/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01063 August Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/15/23 9/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01117 September Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/1/23 10/1/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01179 September Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/15/23 10/15/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01239 October 2023 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 10/1/23 10/31/23 Closed 3. Regular PM PM / Scheduled Maintenance 2023-01248 October Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/1/23 10/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01315 October Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/15/23 11/14/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01379 November Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/1/23 12/1/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01430 November Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/15/23 12/15/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01476 December Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/1/23 12/31/23 Closed 2. Important PM PM / Scheduled Maintenance 2023-01544 December Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/15/23 1/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00080 January 2024 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 1/1/24 1/31/24 Closed 3. Regular PM PM / Scheduled Maintenance 2024-00086 January Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/1/24 1/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00162 January Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/15/24 2/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00233 February Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/1/24 3/2/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00297 February Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/15/24 3/16/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00340 March Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/1/24 3/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00407 March Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/15/24 4/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00465 April 2024 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 4/1/24 5/1/24 Closed 3. Regular PM PM / Scheduled Maintenance 2024-00474 April Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/1/24 5/1/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00547 April Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/15/24 5/15/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00615 May Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/1/24 5/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00674 May Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/15/24 6/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00746 June Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/1/24 7/1/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00808 June Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/15/24 7/15/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00814 2024 Annual Fin Fan Inspection and Bearing Bearing Greasing EAC-0001 K-0001 K-0002A 6/16/24 6/16/25 Closed 3. Regular PM PM / Scheduled Maintenance 2024-00863 2024 Annual Compressor Lube Oil No Go switch battery replacement. K-0002A K-0002B K-0001 6/1/24 6/1/25 Closed 2. Important PM PM / Scheduled Maintenance 2024-00877 July 2024 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 7/1/24 7/31/24 Closed 3. Regular PM PM / Scheduled Maintenance 2024-00885 July Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/1/24 7/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-00912 July 2024 VRU 6 month oil change K-0001 7/1/24 7/31/24 Closed 3. Regular PM PM / Scheduled Maintenance 2024-00962 July Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/15/24 8/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01054 August Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/1/24 8/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01114 August Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/15/24 9/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01173 September Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/1/24 10/1/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01243 September Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/15/24 10/15/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01315 October 2024 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 10/1/24 10/31/24 Closed 3. Regular PM PM / Scheduled Maintenance 2024-01323 October Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/1/24 10/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01395 October Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/15/24 11/14/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01469 November Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/1/24 12/1/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01546 November Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 11/15/24 12/15/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01601 December Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/1/24 12/31/24 Closed 2. Important PM PM / Scheduled Maintenance 2024-01658 December Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 12/15/24 1/14/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00078 January 2025 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 1/1/25 1/31/25 Closed 3. Regular PM PM / Scheduled Maintenance 2025-00081 January Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/1/25 1/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00105 January 2025 VRU 6 month oil change K-0001 1/1/25 1/31/25 Closed 3. Regular PM PM / Scheduled Maintenance 2025-00184 January Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 1/15/25 2/14/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00269 February Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/1/25 3/3/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00351 February Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 2/15/25 3/17/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00411 March Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/1/25 3/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00480 March Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 3/15/25 4/14/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00574 April 2025 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 4/1/25 5/1/25 Closed 3. Regular PM PM / Scheduled Maintenance 2025-00579 April Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/1/25 5/1/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00630 ERRONEOUSLY GENERATED - 2025 VRU Bi-Annual inspection K-0001 FL-0001 2/15/25 3/17/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00656 April Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 4/15/25 5/15/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00716 May Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/1/25 5/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00731 May 2025 Compressor VVCP pocket greasing. K-0001 K-0002A K-0002B 5/1/25 5/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00785 May Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 5/15/25 6/14/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00848 June Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/1/25 7/1/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00905 June Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 6/15/25 7/15/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-00984 July 2025 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B K-0001 7/1/25 7/31/25 Closed 3. Regular PM PM / Scheduled Maintenance 2025-00988 July Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/1/25 7/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01013 July 2025 VRU 6 month oil change K-0001 7/1/25 7/31/25 Closed 3. Regular PM PM / Scheduled Maintenance 2025-01071 July Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 7/15/25 8/14/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01145 August Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/1/25 8/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01226 August Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 8/15/25 9/14/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01301 September Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/1/25 10/1/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01323 September 2025 Compressor VVCP pocket greasing. K-0001 K-0002A K-0002B 9/1/25 10/1/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01375 September Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 9/15/25 10/15/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01450 October 2025 IG A/B and VRU Quarterly oil sample PM K-0002A K-0002B 10/1/25 10/31/25 Closed 3. Regular PM PM / Scheduled Maintenance 2025-01457 October Compressor Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/1/25 10/31/25 Closed 2. Important PM PM / Scheduled Maintenance 2025-01516 October Monthly Compressor Crank Case and Bi-Monthly Cylinder Lube Filter Change K-0001 K-0002A K-0002B 10/15/25 11/14/25 Closed 2. Important PM PM / Scheduled Maintenance Date Position Timesheet Description ST OT Hours 10/06/2024 Maintenance Planner K-0001/3 VRU COMPR 3rd STAGE discharge vale diag and parts pull. 0.0 2.0 2.0 10/07/2024 Maintenance Planner VRU COMPR 3rd STAGE discharge vale and oil system consulting. 1.0 0.0 1.0 10/07/2024 Multi Skilled Plant Operator Safe in VRU 0.0 3.5 3.5 10/07/2024 Plant Mechanic K-0001/3 VRU COMPR 3rd STAGE discharge 2 valve. Removed, cleaned, and replaced VRU S3D2 valve, no noted additional damage found. Lowered VRU crankcase oil by roughly 5", appeared that the crank was smacking the oil due to the fluid height. Packaged old valve, and readied it for shipping. 4.0 0.0 4.0 10/08/2024 Instrument Tech M-300: Troubleshooting K-0001 VRU compressor’s FSLL-2204 cylinder lube oil low flow shutdown switch not working. I found and repaired the problem by straightening the bent magnetic sensor housing for the Oil Divider Valve. The low flow shutdown switch is now working correctly. This work order Task is finished. 2.5 0.0 2.5 10/08/2024 Multi Skilled Plant Operator VRU trouble shooting 0.0 1.0 1.0 10/08/2024 Plant Mechanic K-0001: VRU Low Lube shutdown. Spent time troubleshooting the mechanical side of this issue, and ended up replacing a burst disc and both lubricator pumps on the VRU. This did not solve the issue, so Zack and I removed the FALL 4022 and found a bent magnetic piston. Zack bent it back, we put it back together, started the unit, and that solved the issue of the low low flow alarm that was shutting the VRU down. 7.0 0.5 7.5 10/08/2024 Plant Mechanic K-1000 S3D2 after repairing cylinder lube alarm, stage 3 discharge 2 valve overheated after start up. Waiting for safe out and walk down, but I went and visually looked things over, and started making a game plan to tear down stage 3 in the morning.1.0 3.5 4.5 10/09/2024 Maintenance Planner * Walked down the 3rd stage cylinder damage with the mechanic. Cylinder is damaged. Piston is damaged, 1 discharge and the intake valve are both bad. It looks like the VVCP section is ok. * Contacted Zack: -- Need to get a Dresser support tech here. -- Need to pull the cylinder and get it prepped for repair/replacement. * Verified we have all parts needed to rebuild the 3rd stage once we get a the cylinder repaired or replacement. * Zack asked me to call Seimens tomorrow. He emailed Roteq with request for help. 1.5 2.0 3.5 10/09/2024 Multi Skilled Plant Operator Safe out VRU 1.0 1.5 2.5 10/09/2024 Plant Mechanic K-0001 VRU SD2 It appears that the lock nut holding the reman valve together came off the stud, allowing the valve to experience an unscheduled rapid disassembly, which sent shrapnel into the cylinder. Tore down Stage 3 to bare cylinder. Found extensive damage from the Discharge 2 valve coming apart. Damage to the cylinder walls, piston, rings, piston shaft, etc. There is concern that there could be damage/deformed bearings in the crank case due to the amount of stress potential on them. Larry Johnson spoke with Zack Hundrup, and the current plan is to remove the entire Stage 3 cylinder, pulsation bottle, and possibly cross head. We will then inspect what we can in the crank case and associated piping. A plan is being formulated for sending the cylinder out to be re-machined for an oversized piston and rings, or replaced, depending on the extent of the damage. 7.0 0.0 7.0 10/10/2024 Maintenance Planner Contacted Northern Solutions: They do not do cylinder heads. Contacted Siemens: Emailed pics of the damage. Got a quote for an FRS to come up to look at the VRU Damage. -- $51,000 ---- Emailed quote and texted Zack for further instructions. Contacted Roteq following up on Zack's email. -- They might be able to work on the cylinder but we need to get it down to them. I sent them pictures of the cylinder and they will call me tomorrow to discuss it more. * Contacted Alaska Air Transit to see if they can carry the 1300 pound cylinder on the Pilatus. Awaiting call back. 3.5 4.0 7.5 10/10/2024 Plant Mechanic K-0001: Unbolted and removed pulsation bottle with overhead crane and sat on jack stands. Removed all lubrication lines and fittings. Removed distance box to cylinder adapter bolts. Removed cylinder to bottom pulsation bolts. Rigged cylinder with lifting eyes and removed cylinder from base. Flew cylinder to South end of M300 and strapped to a pallet for shipping. Removed crank case cover bolts and split RTV. Used overhead crane to lift and remove crank case cover for crank case inspection. Cleaned work area, organized parts and tools, inspection of pulsation bottles and cylinder. 5.0 4.0 9.0 Badami Work Order WO 2024-01357 10/11/2024 Maintenance Planner * Working on getting FSR approved to come to Badami. -- Approved by David. -- Siemens required a PO so I had to create a CID for the FSR, MTR, MR, and PO. * Palletized the cylinder for shipment. * Created new CID for the cylinder. * Created R&R and PO for the repair. * Contacted AAT about shipment of the cylinder. * Contacted Roteq about doing the repair. They had questions about the material composition of the cylinder. -- I need to get pics of Cylinder 2's data plates. -- I asked Sam (Siemens) to find out what material it is made of. * Contacted GLM's machine shop (Rob) to see if they can do the repair: They can. -- Rob believes that we can keep using the cylinder with a minimum of repairs (temporary until we get the new cylinder) but if we want to send it down, they can do the repair. -- Rob also recommended Dukowitz to do the repair. 5.5 4.0 9.5 10/11/2024 Plant Mechanic K-0001: Strip all removable weight off of cylinder (studs, distance box adapter), clean up. Inspect VRU for any additional damage. 1.0 2.0 3.0 10/15/2024 Maintenance Planner Working with Dukowitz on cylinder damage solutions. -- They may send a tech up to assist with repair? -- They can do the cylinder and get the correct rings. Working with Charles from Siemens, who is here now, on options. -- It looks like the machine is in rough shape. Will send out pics tomorrow. 1.5 1.5 3.0 10/15/2024 Plant Mechanic K-0001: repaired, closing task. 0.0 0.0 0.0 10/15/2024 Plant Mechanic K-0001 VRU: Worked with Siemens rep to further disassemble VRU Stage 3. Found damaged connecting rod bearings on crosshead and crank end. Siemens rep recommended sending connecting rod out for further inspection (mag particle and dye pen along with checking straightness). He also recommended we have our precision tools calibrated for reassembly. 4.0 4.0 8.0 10/16/2024 Maintenance Planner * Meeting with Zack discussing damage. -- Need complete tear down of the unit. -- Send out the Cylinder and rod to Dukowitz to repair. ---- Add sleeve to the pallet with the rod. -- Bring up Siemens crew for rebuild. * Talked with Joe from Dukowitz -- He's ready for the cylinder and the rod. -- He will send up a tech to retorq any valves that Dukowitz has rebuilt replacing all used nuts with new and locktite. * Repalletized the cylinder: Weight is 1127 pounds. * Palletized the rod and sleeve: 85 Pounds. Set up AAT delivery from Badami to Deadhorse. ICE Services will haul the pallets to Lynden. 70N will use their forklift to unload the Pilatus. Katy will set up delivery from Deadhorse to Dukowitz. * Contacted Sam Frasier (Siemens) for a quote for 1 lead tech and 1 mechanic to help with reassembly and training. -- Will try to have both mechanics on site for training and the rebuild experience. -- There is also a school for these compressors offered by Siemens. 5.0 3.5 8.5 10/16/2024 Plant Mechanic K-0001 VRU: Worked with Siemens; Removed Cylinder 3 connecting rod, took photos of bearings and crank journal. Moved con-rod, crosshead and pin, and valves to warehouse for shipping. Pulled new parts for eventual reassembly and placed on pallet in warehouse. Sat in on meeting discussing photos of damage and working on the path forward. Disassembled Cyl 1 and 2 con-rod caps to assess any further crank damage. Both appear to not have any severe damage, from what I could tell without removing the connecting rod altogether. Gathered all precision tools that need to be calibrated, with Cody Williams, and brought them to the warehouse to be shipped out. 7.0 4.0 11.0 10/17/2024 Maintenance Planner Working with venders on materials and upcoming work: -- Siemens is going to get a quote together for parts as soon as we have a list to them with ETA and price. Sam is also going to quote the 2 person crew that will be sent do Badami to help with the rebuild. -- Dukowitz is ready for the cylinder and connecting rod. He has asked for assistance in getting the bushings for the cross rods as fast as possible. -- GLM is going to complete the test equipment calibrations as fast as they can and hopefully get the materials back in 1 week after they receive the tools. ---- Cody will hand carry the torqwrenches and other tools down with him on Tuesday. -- Alaska Air Transit was unable to carry the cylinder and connecting rod to Deadhorse due to weather. I have set up to do a dedicated flight for the VRU parts on Monday, directly to Kenai. Josie set up for us to use another carrier's forklift for the unloading process. I need to contact Adam Nath to make sure he will be available to haul the pallets to Dukowitz. -- Wright Air has a Caravan that can carry the materials if we choose to. They MAY be able to carry the crank if we have to send it out, but their door is only 48" wide so the pallet would need to be as narrrow as possible. -- ICE Services was lined up to pick up and deliver the parts to Lynden, but as the flight was canceled, they are on hold for that as well. 3.5 4.0 7.5 10/17/2024 Plant Mechanic K-1000: Bagged/tagged/labeled all stage 3 hardware. Performed further inspection with Charles (Siemens rep), noted that the oil pump system needs to be replaced/rebuilt and is fairly worn out and out of spec. Spent time writing notes, and having in person change out with Brenton and Charles along with walking the job down in M300. 6.0 0.0 6.0 10/18/2024 Maintenance Planner * Talked with Joe (Dukowitz) about the crank shaft. He recommend (as well as GLM) that we contact Washington Ironworks to have them do the crankshaft work, if needed. * Talked with Cory at Washington Ironworks and they can do the crank shaft onsite. He would like some more pictures. -- Dan and I took some pictures that I will download and email to Cory tomorrow. 0.0 3.5 3.5 10/18/2024 Plant Mechanic removed vvcp head from the first and second stage and pulled both pistons. i was able to get the connection rod and cross head out of the 2nd stage and staged on bench. 0.0 11.0 11.0 10/19/2024 Plant Mechanic removed first stage connecting rod and cross head. pulled all the block tie rods and started removing the main caps to expose crank for inspection and polishing 0.0 11.0 11.0 10/20/2024 Plant Mechanic pulled main caps and 4th stage connecting rod and cross head weight. labeled the parts to the correct stage so that we can send them off for new bushings and inspection. 0.0 11.0 11.0 10/21/2024 Maintenance Planner * Sam asked for a materials list for anything that needs to be replaced so he can try to get it expedited. -- I gave same an RFQ for 3 Cross Heads, 6 Cross Head pin Bushings, and 4 Conn Rod pin bushings. -- Earlier I had given Sam an RFQ for lock nuts. He said he’s working on it. * Emailed Charlier and Sam pics of the Cross Heads that Brenton pulled out and they recommend replacing them all due to the damage they see, which is similar to the damage seen on the one that Charlie was here to look at in person. * Repair materials were all sent out on AAT. Flight was late getting to Kenai, so materials will be stored for us at Peninsula Aero and Adam will deliver them to Dukowitz on 22 Oct. 3.5 0.0 3.5 10/21/2024 Plant Mechanic did some clean up in the vru area 1.0 4.0 5.0 10/22/2024 Maintenance Planner Reading emails and notes, understanding the plan for repair and where we are now. 2.0 0.0 2.0 10/23/2024 Maintenance Planner Talking to Dukowitz for crosshead measurements and photos. need to identify what weight cross head came from which cylinder. and if it is out of spec needing to be replaced. Same for the Conn rods. Worked with Sam and Charlie on next steps for parts list, need to measure cylinders, Frame Extensions and cross head to determine if replacement is needed. 7.0 0.0 7.0 10/23/2024 Plant Mechanic did alot of vendor contacting and working with larry T on what parts and how far we are planning on going with this teardown. found spec sheet for cylinder and crosshead wear and when we get the tools back from calibration we will mic cylinders 1&2 to see if they are within spec still. got a game plan together with Jonny on how we are going to hook up and flush the VRU oil cooler with the hot oil truck 7.0 4.0 11.0 10/24/2024 HSE & Pipeline Compliance Specialist Serviced the SHOT in prep for using to flush VRU cooler and various lines. 0.0 2.0 2.0 10/24/2024 Plant Mechanic waled down with jonny and found the fittings we need to flush the cooler and block out with hot diesel. removed the main caps and placed on bench. started the removal of the motor coupler. found that the motor gear box is also starting to leak out of then bottom gasket.4.0 4.0 8.0 10/25/2024 HSE & Pipeline Compliance Specialist Broke down flush connections to make adaptors to connect SHOT to process. Rigged up adapters on shot and staged the resst of the adaptors for job when ready. 6.0 0.0 6.0 10/25/2024 Plant Mechanic removed the motor coupler and worked all day trying to find/build and puller to remove the flywheel. I cannot find the proper bolts to drive the wedge coupler off the shaft. will try again tomorrow if I cannot get the fly wheel off I will have to pull the crank with it on and remove it in the shop.7.0 4.0 11.0 10/26/2024 HSE & Pipeline Compliance Specialist Got crank support made, crack along with flywheel lifted brought to shop and then seperated the componets 0.0 8.0 8.0 10/26/2024 Plant Mechanic unbolted front cover and rigged up crank to crane removed and brought to shop where we had to weld nuts onto the flywheel and use our own jacking bolts to remove from crank. 0.0 9.0 9.0 10/27/2024 HSE & Pipeline Compliance Specialist Perfomred flush of cooler and crack case utilizing the SHOT, circulated approoximatelt 8BBL of 160° diesel. Demob shot, greased and put away in cold storage. 0.0 11.0 11.0 10/27/2024 Multi Skilled Plant Operator assist with vru hot oil flush. Added lock and tag to safe out breaker 35 for VRU heater. readlined safeout packet. 0.0 2.0 2.0 10/27/2024 Plant Mechanic hooked up oil cooler to hot oil truck and flushed with hot diesel. set up table in 300 to start storing cleaned parts on so we are ready for reassembly when the time comes. 0.0 11.0 11.0 10/28/2024 Maintenance Planner VRU Compressor rebuild meetings, planning, vender contacts and parts. 7.0 0.0 7.0 10/28/2024 Plant Mechanic built a complete parts list to send off to siemens for quote and cleaned began clean up of gaskets and covers. 7.0 4.0 11.0 10/29/2024 HSE & Pipeline Compliance Specialist Assist with clean up in VRU area, relocated cleaned parts back to mod for storage until reassembly. 4.0 1.0 5.0 10/29/2024 Maintenance Planner More parts research and parts list created and sent for quotes. measurements and vender setup. 4.0 4.5 8.5 10/29/2024 Plant Mechanic cleaning in mod 300 around VRU and under the grates around the VRU. bagged and tagged some bolts and cleaned some parts and started moving over to staged table by south roll up door. moved crank back out to mod for staging until the crank turning people show up.7.0 4.0 11.0 10/30/2024 Plant Mechanic continued work on VRU 7.0 4.0 11.0 10/31/2024 Maintenance Planner Parts and quote follow-up, micrometer shipping and tracking back to Badami. 5.0 0.0 5.0 10/31/2024 Plant Mechanic continued vru work 4.0 4.0 8.0 11/01/2024 Maintenance Planner Worked with Dukowitz on measurements and repair plan. They will clean crossheads, Conn Rods and bushings (All serviceable parts). Ship them back to us and package the #3 cylinder for shipping to Washington Ironworks for repair. 0.0 3.5 3.5 11/04/2024 Maintenance Planner Meeting and vender contact. Cylinder 3 is approved to ship to Washington Iron works. Zack is working with Lynden to air freight it.4.0 0.0 4.0 11/05/2024 Maintenance Planner Got cylinder 3 SS# and information for W. Ironworks to work on parts request. Verified Air freight shipping readiness with Dukowitz. Contacted Siemens on outstanding parts quote and repair plan. 2.0 0.5 2.5 11/11/2024 Maintenance Planner The cylinder was delivered to Washington Ironworks today. 0.0 1.0 1.0 11/13/2024 Maintenance Planner Discussed with Zack about the repairs for the VRU crossheads. Washington Ironworks has said they can repair them rather than having to replace them. -- Zack picked up 2 crossheads and the counterweight from AAT and delivered to TGI Freight. -- I packed up the 3rd crosshead and got it ready for shipment on tomorrows flight. 0.0 1.0 1.0 11/17/2024 Maintenance Planner Compared VRU quote to existing stock. Larry had done this on the original list, but I double checked and added stock levels. Gave Dan a copy of the list. We have about 60% of the parts onhand. 0.0 2.5 2.5 11/18/2024 Maintenance Planner * Discussed the VRU materials and parts out for repair. The Cylinder is completed and ready to ship back to Badami. The Conn Rods are at AAT ready to come to Badami. The Crossheads and the crosshead counterweight are at TGI Freight and going to be shipped to Washington Ironworks for resurfacing even though they are still in tolerance. There is scouring and about a thousandth deviation on them from spec. * Emailed Zack and Katy a list of all materials needed and. -- Numerous discussion via text and phone calls for confusing or missed information. 1.0 1.0 2.0 11/20/2024 Maintenance Planner Parts research and updating the expedited parts list. Looking for a new crank as the grinding process is 3x the cost of new. 1.0 2.0 3.0 11/22/2024 Maintenance Planner Ordered Crank and piston rings from Washington Ironworks. Must send old crank back in shipping crate when it arrives. Much cheaper option then grinding. Reviewed expedited parts list and requested quote, availability and lead time on oil pump, sprockets and chain system from Washington Ironworks.4.0 0.0 4.0 12/03/2024 Maintenance Planner Talked with Iron Works to get crosshead repairs started, crank sprocket may not be installed, will order fastest rout. Re-inventory parts and assess what is needed to put VRU back together. 0.0 4.5 4.5 12/04/2024 Maintenance Planner Crossheads at Iron works Spec is .489 to .491 Our cross heads are worn the same on all of them .4975 to .490, tapered. The taper is an issue. Repaired will be in spec at .490 with no taper. 2.0 0.0 2.0 12/11/2024 Maintenance Planner Started pulling and staging parts for the rebuild. List is about 70% gone through with about 50% on site. Will finish it tomorrow. 2.0 3.0 5.0 12/13/2024 Maintenance Planner Boxed up the crosshead bushings for shipment to Washington Ironworks. 0.0 1.0 1.0 12/27/2024 Maintenance Planner VRU Parts inventory check. 3.0 0.0 3.0 12/31/2024 Maintenance Planner Crank and crossheads shipped today. ETA Arrival 7 Jan. Crew from Washington Ironworks set to come to Badami 8 Jan.1.0 0.0 1.0 01/08/2025 Maintenance Planner Washington Ironworks crew arrived. Lynden Freight is stuck in Coldfoot until Atigan pass opens. Hopefully, the crank and cross heads should arrive tomorrow or Friday. -- Afternoon notice is that the truck is at the pass in the que to go over the pass. Should be to Deadhorse tonight, 8 Jan. Contacted ICE Services to ask them for help loading the freight at 70N. 1.0 2.0 3.0 01/08/2025 Plant Mechanic Helped orientate mechanics, get them setup with safety gear, helped get supplies and clean up VRU crank case more. Got a plan together for tomorrow, and more calipers have been ordered as well. 2.0 4.0 6.0 01/09/2025 Maintenance Planner Setting up delivery from Deadhorse to Badami. Prepping pallets in the warehouse for delivery to M300. Located the missing 3rd stage cylinder oring. 2.0 0.0 2.0 01/09/2025 Plant Mechanic VRU: worked with crew to further clean, inspect, and measure VRU components. 7.0 4.0 11.0 01/10/2025 Maintenance Planner Coordinating shipment of tools from Washington Ironworks. Ordered 3 cases of brake cleaner (warehouse stock). 0.0 3.0 3.0 01/10/2025 Plant Mechanic assisted Washington Iron works with rebuild 7.0 4.0 11.0 01/10/2025 Plant Mechanic Assist with VRU rebuild 7.0 4.0 11.0 01/11/2025 Plant Mechanic assisted with iron works rebuild 0.0 10.0 10.0 01/11/2025 Plant Mechanic Assist with VRU overhaul 0.0 11.0 11.0 01/12/2025 Plant Mechanic Assisted with VRU overhaul. 0.0 11.0 11.0 01/13/2025 Maintenance Planner Loaded up the VRU Crank and shipped it out on AAT. TGI notified to ship it via Lynden. Cort Tate notified that it was headed out. 0.0 1.5 1.5 01/13/2025 Plant Mechanic assisted iron works with leveling the VRU frame to bring back into tolerance. 7.0 4.0 11.0 01/13/2025 Plant Mechanic Assisted with VRU overhaul and cleanup. 7.0 4.0 11.0 01/14/2025 Plant Mechanic assisted iron works with aligning the VRU block and bringing it back into tolerance 7.0 4.0 11.0 01/15/2025 Maintenance Planner Job monitoring, parts and assistance as needed. 0.0 3.5 3.5 01/15/2025 Plant Mechanic assisted iron works with the VRU crank reassembly 7.0 4.0 11.0 01/16/2025 Maintenance Planner Photos, materials and planning. Hot parts order. 1.0 2.0 3.0 01/16/2025 Plant Mechanic assisted iron works with connecting rods and crosshead installation 7.0 4.0 11.0 01/17/2025 Maintenance Planner Assist, parts and repair research and planning. search for options to rectify issues with broken bolts, wrong bushings and crank. 0.0 4.5 4.5 01/17/2025 Plant Mechanic assisted with piston and cylinder installation. on this day we found out the crank was the wrong stroke and must be removed and replaced with a 5 inch stroke crank. 7.0 4.0 11.0 01/18/2025 Maintenance Planner Parts and email research. Wrong crank, bolt shipment 0.0 3.0 3.0 01/18/2025 Plant Mechanic began removing the crank and flywheel 0.0 11.0 11.0 01/19/2025 Maintenance Planner VRU Support and parts 0.0 3.0 3.0 01/19/2025 Plant Mechanic removing crank from vru 0.0 11.0 11.0 01/20/2025 Maintenance Planner Worked with Cory on replacement hub, crank and shipping. Requested a replacement stub shaft for blank cylinder. sending Hub measurements from Brenton. 3.0 0.0 3.0 01/20/2025 Plant Mechanic when trying to remove the taper lock wedge from crank and flywheel it broke the casting on the flange do to being installed incorrectly and over torqued i believe. had to remove the crank and flywheel in one shot just like last time. when we got it into the shop we were able to weld some jacking stud nuts to the flywheel and heat the fly wheel while pressing and hammering. packed parts back onto pallet and brought them back out to the north door in M-300 7.0 4.0 11.0 01/21/2025 Plant Mechanic NOTES FOR FRAME ALIGNMENT: when we got the new crank set inside the frame and started torquing main caps down we found that when tightening #3 main the crank seized. when loosened the crank spins free, Washington Iron Works shipped up a wireline kits and checked alignment of mains. They found that the #3 main bearing saddle was .008 out on the horizontal. After seeing that we were not aligned we loosened all the frame mounting feet and fixed the loose foot on the frame unit first, after this we started un bolting and shimming each cylinder and frame extension trying to get the #3 main back in line with the others. we ended up needing to shove the second stage cylinder to the east a bit to get it closer so we had to INSTALL DOUBLE FLANGE GASKETS ON BOTH SIDES OF THE HARD PIPE FROM SECOND STAGE SUCTION SCRUBBER TO THE PULSATION BOTTLE, THESE CAN NOT BE REMOVED OR WE WILL LOOSE ALIGNMENT. This brought us in .005 and left us only .003 out of alignment. when we got to the third stage we had to INSTALL DOUBLE GASKET ON ONE SIDE OF THE HARD PIPE GOING FROM THIRD STAGE PULSATION BOTTLE TO THIRD STAGE SUCTION SCRUBBER, THESE ALSO CANNOT BE REMOVED. this brought us in to .0015. we torqued all the bolts and re checked to verify nothing moved. 1.0 0.0 1.0 01/21/2025 Plant Mechanic NOTES ON CRANK INTALLATION: Washington Iron works tightened all the main bearing caps and honed the journals .002 so they had more clearance and were still in spec. After that we cleaned the block back out and installed the crank. Crank turned with not issues after torqued down. we installed rods and crossheads and mic out all clearances and tolerances along the way. we installed all the seal packings and pistons and set the piston to crank clearance, while installing stage one piston head we found that the piston comes in contact with head. Troy with Washington Iron Works called his boss and found that they had sent us a 6 inch stroke crank instead of a 5 inch. We halted the project and sent the Iron works crew home until we figure out when we can get a new correct crank. 1.0 0.0 1.0 01/21/2025 Plant Mechanic NOTES ON CRANK REMOVAL: I decided to remove the incorrect crank so that when we get the new one we will be ready to install it. first i tried to remove the flywheel in the mod so that we do not have to bring complete assembly into the shop. i made some Jacking bolts to remove wedge lock from flywheel. while tightening bolts the wedge flange broke off leaving me nothing to press against while in the mod. Removed connecting rods and main caps and unbolted rear cover so we can bring the entire assembly into the shop. lifted the crank out and brought to weld bay, had Bilejo weld some nuts on the flywheel so we could press harder on the wedge. After much heating and hammering and pressing we got the flywheel off. after inspection we found that the wedge had been severely over torqued and installed were the jacking bolts hit to closely to the split in the wedge lock so we pressed hard it snapped at the weak spot. WHEN INSTALLING NEW WEDGE MAKE SURE THAT THE JACKING BOLTS DO NOT HIT NEAR THE SPLIT IN WEDGE brought parts back out to the north roll up door of M-300 until we get new parts for repair. 2.0 0.0 2.0 01/21/2025 Plant Mechanic cleaned up the parts that were removed and gathered measurements for the Washington Iron Works crew to get us a new flange and fly wheel maybe. i number stamped the rods and tie bars so we can easily identify them next time around 3.0 4.0 7.0 01/28/2025 Maintenance Planner Meeting with Iron Works. Old and new Cranks are side by side for comparison. Will ship new 5" stroke crank on 1/29 to Badami. Also include oil pump bushings, flywheel hub and stub shaft for blank crosshead. 2.0 0.0 2.0 01/29/2025 Maintenance Planner Gathered measurements and photos for recreation of the stub shaft for the blank cylinder. Coordinated shipping of the new crank, flywheel collar, bushings and shaft.4.0 0.0 4.0 01/30/2025 Maintenance Planner Getting freight quotes for land and air. Arraigning shipping and payment for crank. 3.0 0.0 3.0 02/24/2025 Maintenance Planner Meeting with Siemens for the upcoming repairs Wednesday. Crank has arrived at AAT.1.0 0.0 1.0 02/27/2025 Plant Mechanic VRU rebuild support. Cleaned new/used crank shaft and moved to M300. Work crew found the piston rod threads had been pulled through the new packings, so we are going to open the packings up and check the scrapers. Installed crank shaft and con-rods after re-measuring the main caps/bearings and con-rod caps/bearings, installed cross bolts into crank case. Found that the crank to motor coupler is the wrong unit. LT will look into finding the correct one as soon as he is able. 2.0 4.0 6.0 02/28/2025 Maintenance Planner Materials and crew coordinating, Parts research and repairs at Deadhorse machine shop. 6.0 0.0 6.0 02/28/2025 Plant Mechanic VRU rebuild support. Installed new cylinder packings/scrapers, finished installing connecting rods, installed piston and piston rods onto crossheads, installed VVCP's. Had to remove Stage 2 Suction pulsation bottle to install the piston lubricator tubing inside of the cylinder. Reinstalled bottle with new gaskets. Installed new lubricator check valve. Found gasket material to make a new drive side end plate gasket. 5.0 4.0 9.0 03/01/2025 Maintenance Planner assistance on crossheads (too big), machine shop in Deadhorse may fix, Hub cut down and measuring tools. 0.0 4.0 4.0 03/01/2025 Plant Mechanic VRU rebuilt support. Continued installation of components, found that the crossheads had been sprayed too thick. They are now removed and being prepped to be shipped out for machining. 0.0 9.0 9.0 03/02/2025 Maintenance Planner Working materials issues, Cross heads don't fit. measurements look to be in spec and block extensions spec good too. Pulled cross heads and prepped to send to machine shop. 0.0 5.0 5.0 03/02/2025 Plant Mechanic VRU rebuild support. More measuring and research on crosshead to guide clearances. Dresser Rand has determined that the top of the guides can be hand clearanced with emory cloth. More disassembly to do that work, including removing VVCP's again to pull pistons and rods back far enough to remove the packing housings.0.0 7.0 7.0 03/03/2025 Maintenance Planner VRU support, parts and repair plan. 3.0 0.0 3.0 03/03/2025 Plant Mechanic VRU rebuild support. Siemens gave the go ahead to file down the crossheads to fit within spec. They now fit in tolerance. Measurements were ran on rod runout, piston runout, rod lift, crosshead clearance. All cylinder heads were installed along with VVCP's and related gaskets. We installed new frame mounted inline filters. We began installing lubricator tubing. Coupler hardware was cleaned up, and new 5/8 fine thread nyloc nuts were ordered from Brooks Range. Bernie, the Siemens lead, called and got coupler and hub installation instructions. I spent a decent amount of time searching our books for the correct information but could not find it in the books in our office, the documentation room, or in the filing cabinets in the doc room. We will be installing the coupler and flywheel tomorrow, along with aligning the motor to the compressor. Then we will get the compressor ready for air runs/break in. 4.0 4.0 8.0 03/04/2025 Instrument Tech 8:06am Call out at Home for K-0001 VRU Compressor is being re-assembled. Working with Cody Williams (Instrument Tech), and Richard Renke (Control Room Operator) by cellphone. _Siemens (3 people) are still working on the VRU, but will soon be requiring to get the magnetic center measurement of the drive motor coupling (need to run the motor by its self). After that to do a Air Run/Break-In, to run the compressor with all the valves removed to break in the new bearings. _Cody Williams helped me get remote connected to BADAMI-PCN2 server using TeamViewer. _Researching drawings for the drive motor controls, and programmable logic controller bypasses. _Texted Cody a list of drawing to print out. _Siemens will be ready for magnetic center measurement tomorrow morning. Work ongoing. 8.0 4.0 12.0 03/04/2025 Journeyman Electrician Meeting on starting VRU motor for finding mag center. 1.5 0.0 1.5 03/04/2025 Maintenance Planner VRU Support, materials and planning. 0.0 4.5 4.5 03/04/2025 Instrument Tech Replacing broken conduit on VRU for lube oil heater, replacing lube oil float switch that got broken off, work with Zac on PLC items for mag center test and air run of the VRU. 2.0 4.0 6.0 03/04/2025 Plant Mechanic VRU Rebuild Support. General cleaning of parts and installed cylinder and crank case lubrication tubing and associated fittings. Installed the cylinder lubricator pump and tubing. We found that several bypasses need to be added to the PLC for Siemens to be able to run the VRU motor to do air runs. Zack Donnely has been contacted and is working on programming to assist with bypasses. Reinstalled distance piece doors, flywheel, and coupler. We searched for new coupler shims, to no avail. This may be something we should consider stocking for future coupler removal/installation. Once coupler is installed, we will be aligning the motor to the compressor. It has been recommended that we flush the oiling system with fresh oil and then drain/refill afterwards before the air runs. We also swapped from IGA to IGB in preparation for rebuild on IGA. 7.0 4.0 11.0 03/05/2025 Instrument Tech 8:02am Call out at Home for K-0001 VRU Compressor is being re-assembled. Working with Cody Williams (Instrument Tech), and Richard Renke (Control Room Operator) by cellphone. I called Cody Williams. He was in the control room. They gathered up Patrick Rowe (Mechanic) and Ray Williams (Electrician) to go over the plan to run the VRU motor and get the magnetic center for the coupling. _At 9:48am I forced PLC-1 O:157/4 output to start the drive motor (YS_0001 K-0001 VRU MCC START/STOP). Magnetic center measurement was taken. At 9:50am removed the force and stopped the motor. _Siemens and Patrick Rowe (Plant Mechanic) have more work to do on the drive coupling and the motor / compressor alignment. _I continued researching the programmable logic controller bypasses to do the Air Run/Break-In. Work ongoing. 8.0 4.0 12.0 03/05/2025 Journeyman Electrician On standby at the disconnect during motor run. 1.0 0.0 1.0 03/05/2025 Maintenance Planner Parts handling and support, packing up the crank for backhaul. 5.0 0.0 5.0 03/05/2025 Instrument Tech VRU finish conduit repair on lube oil heater, Motor run test for mag center, had safety meeting for concerns, finished wiring the float switch on the lube oil, had to replace the switch and replace all the wiring including the MI cable. will function test tomorrow, helped with getting alignment tool mounted for the VRU.7.5 1.0 8.5 03/05/2025 Plant Mechanic VRU Rebuild Support. Installed oil pump chain, replaced crank case filter cartridges, ran motor to check for magnetic center (Zack Donnely was able to bypass), filled crank case with fresh oil to flush contaminates. We worked on alignment but ran into issues. One of the issues being that the hub needs to move towards the motor. The motor is at the end of its forward travel. The crew is trying to get approval to neck down the motor clamp down bolt shoulders, so that they can get ~.0050. While trying to remove the flywheel, the crew discovered that Washington Ironworks galled the jacking bolts threads badly. We are looking at possibly getting a 1-1/8th by 8tpi tap. 7.0 4.0 11.0 03/06/2025 Instrument Tech -Call out at Home for K-0001 VRU Compressor is being re-assembled. Working with Cody Williams (Instrument Tech), and Richard Renke (Control Room Operator) by cellphone. I finished up the bypasses in the VRU programmable logic controller for the Air Run/Break In. I found a way to simplify it down to one bypass in Ladder File 15, Rung 16: Added AFI (Always False Input) to prevent the compressor from going in to “Unit Ready To Load” B3:3/13. _This keeps the Compressor Crankcase oil level and low oil pressure below 25psi shutdowns armed. _After 120 seconds of run – arms shutdowns for FSLL-2204 “Compressor Cylinder Lube Oil No-Flow”, VT-0137 Drive Motor Vibration, and VT-0138 Compressor Vibration. _This also disables Low Low gas pressure shutdowns for 1st Stage, and keeps the all 3 stages PID valves in recycle. _14:43:33 1 min First Air Run/Break In. _14:55:31 5 min 2nd Air Run/Break In. _16:02:30 15 min 3rd Air Run/Break In. _16:32:53 33 min 4th Air Run/Break In. Four runs completed today. Work ongoing. 8.0 4.0 12.0 03/06/2025 Journeyman Electrician Opening and closing breaker for the VRU. Had to troubleshoot the prelube pump and found the starter chattering. Starter was replaced and pump ran without problems. 6.0 0.0 6.0 03/06/2025 Maintenance Planner VRU support 3.0 0.0 3.0 03/06/2025 Instrument Tech Function Test LSLL-2201 and tested trip points and refill points from the sight glass on the VRU lube oil, remounted and verified vt-0138, helped refill lube oil and start up pumps. assisted with the first couple of air starts from the control room 8.0 2.0 10.0 03/06/2025 Plant Mechanic VRU Rebuild Support. Drained crank case oil, refilled oil, reinstalled coupler, aligned machine, prepared for air runs. 6.0 0.0 6.0 03/07/2025 Instrument Tech -Call out at Home for K-0001 VRU Compressor is being re-assembled. Working with Cody Williams (Instrument Tech), and Richard Renke (Control Room Operator) by cellphone. _06:21:17 59 min 5th Air Run/Break In _07:38:39 1 hour 59 min 6th Air Run/Break In _09:53:48 5 seconds 7th Air Run/Break In _10:16:44 4 hour 8th Air Run/Break In Four more runs completed today. All done. _18:30pm Per Richard Renke I removed the bypasses from the VRU programmable logic controller. They are going to put the cylinder valves back in the VRU compressor and safe it back in. Work ongoing. 6.0 0.0 6.0 03/07/2025 Plant Mechanic air runs on the vru and gathering data. 7.0 4.0 11.0 03/08/2025 Instrument Tech -Call out at Home for K-0001 VRU Compressor: Working with Cody Williams by phone to troubleshoot and calibrate the LIT-0601 Level Transmitter not working on the VRU compressor 1st Stg Blowcase. The level reading was staying at 61%. _Found It did not have proper liquid fill in the sensing tubing. Refilled all the sensing lines with glycol 60/40 water, Mono Ethylene Glycol (MEG) and with the blowcase empty now = 0% on the transmitter. With the VRU running the Blowcase is controlling the level between 30% and 40%. 0.0 4.0 4.0 03/08/2025 Instrument Tech VRU start start up, had to troubleshoot the Blowcase LIT-0601, transmitter was reading 72% full. i was able to drain it to 61% but no more, reading through old WO's it appears that this transmitter is tubed differently. High side of DP transmitter runs to low vessel tap and Low side of DP transmitter runs to high tap on the vessel. both sensing lines need to be completely filled all the way to the needle valve at the vessel tap's with MEG, i purged all the sensing lines with 60/40 MEG and returned the transmitter to normal operation, verified 0% on the HMI since the blowcase was empty, started VRU, about 3-4 hours in a level started build level in the blowcase and it is correctly controlling level between 30 and 40%. 0.0 6.0 6.0 03/09/2025 Maintenance Planner Materials audit, restock and handling. 0.0 4.5 4.5 03/09/2025 Instrument Tech 3rd Stage suction scrubber dump valve (lv-0641) was not working. Tested valve and Level controller. valve was plugged, took gas from first stage IGB suction scrubber and blew out LV-0641. Adjusted LC-0641 (fisher level controller) after adjustment the dump valve closes at the bottom of the sight glass and opens when it builds 2-3 inches. 0.0 7.0 7.0 10/09/2025 Maintenance Planner Started making VRU parts inventory list and checking locations. 2.0 2.0 4.0 10/10/2025 Maintenance Planner VRU parts inventory and research. 4.0 2.0 6.0 10/18/2025 Maintenance Planner Parts handling and receiving valves from Dukowitz. 0.0 2.0 2.0 Date Position Timesheet Description ST OT Hours 04/15/2025 Multi Skilled Plant Operator finished Safe out and walkdown with superintendent. 1.0 0.0 1.0 04/15/2025 Plant Mechanic removed discharge valve 2 because it was overheating and found a lot of grey black material on every surface. looking into cylinder i noticed that the new plating on the cylinder was coming off and during further inspection i noticed that the rider band on the rear of the piston was gone and there was scoring on the side of the piston itself. removed the head and piston and found the piston was destroyed and the new cylinder was very chewed up with tons of scoring and heavy pitting. cleaned up area and am waiting on further instruction. 7.0 0.0 7.0 05/02/2025 Plant Mechanic started parts list for repairs 0.0 2.0 2.0 05/06/2025 Plant Mechanic removed the third stage cylinder for shipping out for repair. 2.0 4.0 6.0 05/07/2025 Plant Mechanic cleaned up tooling and put nuts and bolts in bags for easy access and assembly. 3.0 0.0 3.0 05/09/2025 Maintenance Planner Completed PO and BOL for shipping the cylinder out to Bender CCP. PO BAD2025-00332 1.0 0.0 1.0 06/27/2025 Plant Mechanic Parts research and pulled parts for VRU stage 3 reassembly. Training Storm on Savant and warehouse. 0.0 4.0 4.0 06/27/2025 Plant Mechanic Researched repair procedures and gathered materials 0.0 4.0 4.0 06/29/2025 Maintenance Planner Off load cylinder from 70 North. 0.0 1.0 1.0 06/29/2025 Plant Mechanic Staged parts, and organized tools for work. Helped receive cylinder into module. Prepped cylinder and work area. Installed cylinder with new spiral would gaskets, put discharge pulsation bottle into place. Installed packing into distance piece. Research on pulsation bottle spool piece gaskets and spacer to remove doubled up spiral wound gaskets. Cleaned up area.0.0 7.0 7.0 06/29/2025 Plant Mechanic Staged parts, and organized tools for work. Helped receive cylinder into module. Prepped cylinder and work area. Installed cylinder with new spiral would gaskets, put discharge pulsation bottle into place. Installed packing into distance piece. Research on pulsation bottle spool piece gaskets and spacer to remove doubled up spiral wound gaskets. Cleaned up area.0.0 7.0 7.0 06/30/2025 Multi Skilled Plant Operator Safed in, ready for walk down. main breaker needs closed by electrician 0.0 1.5 1.5 06/30/2025 Plant Mechanic Finished packer install and torque, oil supply and drain lines. Installed piston with new rings and rod and set clearances. Torqued rod nut and set screws. Installed distance piece access door. Installed stage 3 suction scrubber to pulsation bottle spool piece WITH ONE GASKET ON EACH SIDE due to physical alignment. Having removed the bottle and cylinder, the distances between the spool piece and scrubber and bottle changed. Walked down with Dan Clark and Johnny to verify and conversed with Rich as well. We all agreed to run as is, without the double stacked gaskets. Torqued all hardware and installed VVCP. 7.0 4.0 11.0 06/30/2025 Plant Mechanic Finished packer install and torque, oil supply and drain lines. Installed piston with new rings and rod and set clearances. Torqued rod nut and set screws. Installed distance piece access door. Installed stage 3 suction scrubber to pulsation bottle spool piece WITH ONE GASKET ON EACH SIDE due to physical alignment. Having removed the bottle and cylinder, the distances between the spool piece and scrubber and bottle changed. Walked down with Dan Clark and Johnny to verify and conversed with Rich as well. We all agreed to run as is, without the double stacked gaskets. Torqued all hardware and installed VVCP. 7.0 4.0 11.0 07/02/2025 Control Room Operator M300: K-0001; VRU back online. Cooler bay was frozen on 2nd startup and thawed with URH to cooler bay. VRU motor start failed on first startup. 0.0 0.0 0.0 07/02/2025 Plant Mechanic Primed drippers and started lube oil pump. Brought VRU online after troubleshooting high discharge pressure on cylinder 2. Suspected ice in cooler blocking flow. Waited for it to warm up and was able to get the VRU started. Monitored valve temps, noises, and vibrations for any indications of problems. Unit is operating as designed currently. Performed multiple temp and sound checks throughout the day.4.0 2.0 6.0 07/02/2025 Plant Mechanic Start up of VRU- Adjusted lube rates, monitored temps and pressures, inspected for leaks or issues. 3.0 2.0 5.0 07/23/2025 Maintenance Planner Investigate possible cause, damage, inspect piston / rod and cylinder. Build shipping create for piston assembly and ship to Dukowitz. shipped both assemblies in hopes one usable assembly can be sent back CID 394085. Requested quote from Siemens for pistons rod assembly and separate components. 7.0 0.0 7.0 08/23/2025 Plant Mechanic Complete 0.0 0.0 0.0 09/03/2025 Maintenance Planner Verified all work is completed. 0.5 0.0 0.5 Badami Work Order WO 2024-00663 Date Position Timesheet Description ST OT Hours 07/20/2025 Plant Mechanic Disassembled stage 3 distance piece access panel and both discharge valves for inspection. Checked piston clearances, piston rod nut for movement, valve condition, cylinder liner condition, ring condition, and yoke condition. All looked good and clearances were in spec. Had Larry Thompson also look at unit and verify my findings. Reassembled unit and cleaned up work area.0.0 4.0 4.0 07/21/2025 Maintenance Planner Assist and inspect as needed. 4.0 0.0 4.0 07/21/2025 Plant Mechanic After the initial inspection, and reassembly, unit was brought back online. The rattling noise and vibration persisted. The decision was made to shut down and safe out unit to inspect further. After tear down, some small metal/tin pieces along with some thread protector material (plastic/rubber mesh) was found in Suction 2. Upon further inspection Larry found Suction 1 cage to be deformed. I found foreign material in Suction 1 valve, along with a very small washout on the shoulder of where the valve meets the seat. The decision was made to replace all 3 valves, seats, and o rings, then safe it back in and see if the problem was solved. 7.0 4.0 11.0 07/22/2025 Maintenance Planner assist, planning and parts research. reviewed past W/Os 4.0 0.0 4.0 07/22/2025 Plant Mechanic Inspected VRU and listened to noises. Seems as though the noise and vibration persists albeit substantially quieter. Spoke with LT, he is going to check on it as well, then we will talk about our next move. Packaged old valves and piston/rod assembly into crates, labelled, and readied for shipping to Dukowitz. The rod looks salvageable, but the piston halves definitely need to be replaced. Finished issuing materials to work order and verifying all replaced components are accounted for. Went through VRU inventory and did CID on hand counts. Corrected the app to reflect actual on hand stock. Sent email to planner to have auto reorder turned selected for a few that were not on auto reorder. Rebuilt VRU rod packer with new packing. Cleaned all cups, inspected cups, and reassembled with all new packing. 7.0 0.0 7.0 07/23/2025 HSE & Pipeline Compliance Specialist opened up the 3rd stage suction scrubber and found that the filters has all degraded and there was a tremendous amount of debris inside, we are confident that this is the same debris found in the valves and inside the compressor as well. Vaced out what we could, cleaning will continue. 4.0 0.0 4.0 07/23/2025 Maintenance Planner Call out for compressor shut down on LL 1st stage suction pressure. 0.0 4.0 4.0 07/24/2025 HSE & Pipeline Compliance Specialist contineud with scrubber inspections on VRU, 2nd stage looked good, 1st stage was full of schmoo and filters were in bad condition. both 2nd stage and 3rd stage have been buttoned up and torqued to spec. 4.0 0.0 4.0 07/24/2025 Multi Skilled Plant Operator bolted up and Torqued 2nd stg suction scrubber top flange to spec (368#'s). Bolted up and torqued 3rd stage suction scrubber top flange to spec (535#'s) 1.5 3.0 4.5 07/24/2025 Plant Mechanic Spent time looking for part numbers to replace 3rd Stage suction scrubber elements. Tomorrow I will take some measurements and get with Cody to see if a company he knows of can replace them for us. 0.0 2.0 2.0 07/26/2025 HSE & Pipeline Compliance Specialist contiued working on filter removal on suction scrubber. 2.0 0.0 2.0 07/27/2025 HSE & Pipeline Compliance Specialist finally able to remove the remaining filters from 1st stage suction scrubber. 2.0 0.0 2.0 07/28/2025 HSE & Pipeline Compliance Specialist opened up blowcase and found it full of the same liquid as in 1st stage, pulled sample and vaced out and then buttoned up all flange connections that we had opened up. 2.0 0.0 2.0 07/31/2025 Plant Mechanic Went through notes and checked over unit. Inspected for any other indicators of root cause for initial failure. Brought removed packer back to shop for rebuild. 4.0 0.0 4.0 08/01/2025 Plant Mechanic Inspected old removed packer, pulled parts and began rebuild 2.0 0.0 2.0 08/10/2025 Plant Mechanic Completed rebuild of 3rd stage packer. Assigned pulled materials to WO# for replacements. 0.0 2.0 2.0 08/19/2025 Plant Mechanic Received piston and rod assembly. Took assembly and rebuilt packer out to M300. Installed packer, installed lube lines, installed piston and rod assembly and ran the initial clearances. Cleaned up area. 0.0 3.0 3.0 08/20/2025 Plant Mechanic Finished setting piston clearances (Crank end .061, head end .093). Note: clearance between piston halves: one side is .033, the other side is .17 and is not even all the way around. PISTON AND ROD ASSEMBLY WAS REMAN'D BY DUKOWITZ AND HAS OVERSIZED RING LANDS, THIS MEANS STANDARD RINGS WILL NOT WORK ON THIS PISTON, THEY MUST BE .958 WIDE FOR THIS SPECIFIC PISTON ONLY. I triple checked the crosshead clearance, and it is .009 at this time. Reassembled cylinder with new valves, o rings, seats, and gaskets. Torqued valve cover studs, and VVCP to cylinder studs, to 220lb/ft. Put away tools, returned used valves to warehouse, cleaned up work area. 7.0 1.0 8.0 08/21/2025 Plant Mechanic Started VRU, waited for oil to come up to temp and operations to load unit. Spent time inspecting, listening, and watching unit run, looking for any potential issues. As of right now, the unit is running as it should, temps are where they should be, and everything sounds and feels normal.2.0 0.0 2.0 7.0 1.0 8.0 Badami Work Order WO 2024-01087 07/23/2025 Plant Mechanic Disassembled 3rd Stage cylinder. Removed piston/rod assembly for inspection along with rod packer. Measured gap between piston halves and found one side to have .838mm of clearance, while the other side has .457mm of clearance. LT and I determined it needs to go to Dukowitz for further inspection and repairs. There were also signs of chatter and abnormal wear in the rod packing. Date Note Power 2/1/25 2nd stage separator parachuted with 2 heaters on it to thaw Diesel Back Up Generators 2/2/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/3/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/4/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/5/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/6/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/7/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/8/25 Two Heaters on the 2nd Stage Separator, 3 Heaters on the Drilling Rig warming up Tires and moving system and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/9/25 Three Heaters on the 2nd Stage Separator, 1 Heater on M-500 Generator windings to dry out, 1 Heater in M-700 and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed Diesel Back Up Generators 2/10/25 Two Heaters on the 2nd Stage Separator, 1 Heater on M-500 Generator windings to dry out, 1 Heater in M-700 and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed and 1 - Heater went with the Subbase, Once Rig is back in Doyon Yard Cruz will haul it back to their yard Diesel Back Up Generators 2/11/25 Two Heaters on the 2nd Stage Separator, 1 Heater on M-500 Generator windings to dry out, 1 Heater in M-700 and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed and 1 - Heater went with the Subbase, Once Rig is back in Doyon Yard Cruz will haul it back to their yard Diesel Back Up Generators 2/12/25 Cruz rental Heaters: Two Heaters on the 2nd Stage Separator, 1 Heater on M-500 Generator windings to dry out, 1 Heater in M-700 and 1 Heater in the Big Tent keeping Water Truck, etc. warm / thawed and 1 - Heater went with the Subbase, Once Rig is back in Doyon Yard Cruz will haul it back to their yard Diesel Back Up Generators 2/13/25 Cruz rental Heaters: Two Heaters on the 2nd Stage Separator, 1 Heater on M-300, 1 Heater in M-700, 1 – on Rental Transformers thawing ice around power lines and 1 - Heater went with Rig 19 Subbase, Once Rig is back in Doyon Yard Cruz will haul it back to their yard Diesel Back Up Generators 2/14/25 Cruz rental Heaters: Two Heaters on the 2nd Stage Separator, 1 Heater on M-300, 1 Heater in M-700, 1 – on Rental Transformers thawing ice around power lines and 1 - Heater went with Rig 19 Subbase, Once Rig is back in Doyon Yard Cruz will haul it back to their yard Diesel Back Up Generators 2/15/25 Cruz rental Heaters: Two Heaters on the 2nd Stage Separator, 1 Heater on M-300, 1 Heater in M-700, 1 – on Rental Transformers thawing ice around power lines Diesel Back Up Generators 2/16/25 Cruz rental Heaters: Two Heaters on the 2nd Stage Separator, 1 Heater on M-300, 1 Heater in M-700, 1 – on Rental Transformers thawing ice around power lines Turbine 2/17/25 Cruz rental heaters: Two heaters on the 2nd Stage Separator, 1 heater on M-300, 1 heater in M-700, 1 – on rental transformers thawing ice around power lines Turbine 2/18/25 Cruz rental heaters: Two heaters on the 2nd Stage Separator, 1 heater on M-300, 1 heater in M-700, 1 – on rental transformers thawing ice around power lines. We will be making a plan today, to demob heaters Turbine 2/19/25 Cruz rental heaters: Two heaters on the 2nd Stage Separator, 1 heater on M-300, 1 heater in M-700, 1 – on rental transformers thawing ice around power lines. Still using heaters and will demob asap Turbine 2/20/25 Cruz rental heaters all removed from service and staged for pickup. Cruz notified and will come at to get them as soon as they are able Turbine Cook Inlet Energy, LLC/Glacier Oil and Gas Corp. Formal Hearing Presentation AOGCC Docket No: OTH-25-031 Badami VRU Flaring Event October 30, 2025 1 Background and Timeline 2 Root Cause and Conditions •The compressor failure was mechanical, not operational negligence •Preventative maintenance was in full effect prior to incident • Discharge valve failure debris went inside the cylinder, damaged the cylinder and piston •Damage was discovered between the piston, through the crosshead and into the crankshaft •Repair parts required specialized fabrication; shipping delayed by winter weather and vendor backlog •Additional damage to the new cylinder lining after replacement (37) days of operation after initial repair •New HVOF repair was made to the cylinder, and the VRU •Arctic temperatures and remote logistics prevented safe shutdown for extended maintenance •Flaring was the only safe option to maintain power, system pressure balance and protect personnel, infrastructure, operations and pipelines Summary 3 Operational Context •Badami Unit’s VRU captures low pressure produced gas (< 75psi) for recycling into the system •VRU accounts for <2% of total gas volume handled by Badami facility •When the VRU failed; •Badami facility couldn’t utilize the low pressure gas and used the eductor system to collect and flare gas safely •Controlled flaring ensured safe operations while preserving overall system integrity •Kept power generation unaffected at Badami facility •Prevented potential freeze-up of separation, production systems and flow lines at facility •Kept Nutaaq pipeline operational •Production continuity maintained power stability for the not only for the Badami Facility but also for the Nutaaq Pipeline, preventing regional shipping impacts. VRU Failure 4 Regulatory Framework and Compliance •Our actions were fully within this provision 20 AAC 25.235(d)(5) – allows flaring for •Facility repairs or emergencies •It was necessary for facility operations and repairs •Prevention of equipment damage and safety hazards •It was a response to an emergency that threatened life and property, particularly in arctic conditions •Continuation of essential facility operations •And it was necessary to prevent loss of ultimate recovery, especially from the Exploration well B1-33A well that had just come online •All flaring volumes reported on Form 10-422 monthly •Continuous communication maintained with AOGCC staff via phone calls, email correspondence and in-person meeting •CIE acted transparently, within the regulatory framework, and without concealment •Gas flared was purchased from Endicott and State already received royalties on this gas “Gas may be flared as required for facility repairs, emergencies, and facility operations necessary to prevent injury or loss of ultimate recovery.” – 20 AAC 25.235(d)(5) 5 Regulatory Framework and Compliance North Slope Flaring Statistics by Unit 2023 Data from AOGCC Form 10-422 filings 6 Regulatory Framework and Compliance North Slope Flaring Statistics by Unit 2024 Data from AOGCC Form 10-422 filings 7 Regulatory Framework and Compliance North Slope Flaring Statistics by Unit 2025YTD Data from AOGCC Form 10-422 filings 8 Regulatory Framework and Compliance North Slope Flaring Statistics PBU 2022-2025YTD Data from AOGCC Form 10-422 filings 9 Regulatory Framework and Compliance North Slope Flaring Statistics 2022 - 2025 YTD by Operator Conoco Hilcorp (-PBU)CIE (Badami) Hilcorp (PBU)Data from AOGCC Form 10-422 filings 10 Regulatory Framework and Compliance North Slope Flaring Summary - Fine Period Comparison Data from AOGCC Form 10-422 filings (Oct 2024 – Mar 2025)11 Regulatory Framework and Compliance North Slope Flaring >1hr for NOV Period (Oct 24 - Mar 25) Operator Gas Flared During NOV Period (MCF)Relative to Badami Proportional Fine AOGCC Enforcement Action Hilcorp (PBU)384,126 7.53x $ 2,694,260 None Hilcorp (excluding PBU)85,405 1.67x $ 599,031 None ConocoPhillips 49,283 0.96x $ 345,671 None Badami 51,015 $ 357,905 NOV + $357,905 fine “Active flaring spanned approximately 150 days (mid-October to early March) within the 182-day regulatory window covered by the NOV.” “Despite multiple operators flaring greater total volumes during the same six-month period — none received NOVs or fines. Only Badami, flaring the smallest amount, did.” 12 Mitigating Factors •Gas flared was purchased from Endicott •Gas was priced at $2.50 to $2.73 per MCF for Endicott gas compared to state estimate of $3.503 to $3.516 (x2) •The State already received royalties on this gas through production accounting •Badami produced gas is used on lease and there is no access to market for sale. •Therefore, no financial or resource loss occurred to the State of Alaska •Badami production supported Nutaaq pipeline throughput (also carrying Point Thomson oil) •State royalties and transportation revenue continued uninterrupted •Badami produced 510,530 barrels between October and March •The State earned $4.76 million in royalty from Badami alone (Actuals) •Point Thomson, which ships through our Nutaaq pipeline, produced 787,944 barrels in that same period •The State earned $6.96 million in royalty from Point Thompson (Estimated at the 12.5% Royalty @ $70.65) Economic & Conservation Context “CIE’s operations not only generated royalties from its own production, but also ensured continuous transport and royalties from Point Thomson oil, amplifying the State’s fiscal benefit during the flaring event.”13 Comparative Analysis during VRU failure Flaring vs Emergency Diesel generators Flaring Diesel Generators Keeps the existing turbines operational at Badami facility Shuts down turbine power completely at Badami facility and initiates start of diesel generators Keeps operating power at facility at 9MW Reduces power from 9MW to 3MW Facility is under normal operation Critical infrastructure can only be powered - Camps, HMI, and pipeline for short durations. Severe impacts to facility and support operations including airport, communication, heat , portable water, camps, injection, sewage etc. Reliable and eliminates life and safety issues in dead of winter Unreliable and initiates secondary emergency protocols to evacuate personnel incase of generator failure Keeps production from Badami and Point Thompson sustained Shuts down Badami production and unreliable support for Point Thompson’s production transport through Nutaaq pipeline Less polluting. Complete combustion of flare gas achieved More polluting due to combustion of aromatics and sulfur compounds Economically feasible power at 3c/KWh Uneconomical power at 35c/KWh. Emergency tariff modifications to the RCA pipeline tariff required No reliability issues on natural gas source for power Unrealiable due to limited diesel storage and challenging logistics to move fuel without gravel road system Reliability ensures Nutaaq pipeline remains operational Nutaaq/Point Thompson pipeline could go offline causing freezing and spills similar to the Harvest pipeline spill in 2024. Similar consequences to Badami facility housing flow lines, seperators and tankage 14 Environmental Impact Analysis during VRU failure Flaring vs Emergency Diesel generators Parameter / Emission Natural Gas Combustion Diesel Combustion Main Fuel Composition Primarily methane (CH₄) with small ethane/propane fractions Hydrocarbon mixture (approx. C₁₂H₂₃) with sulfur and aromatics Stoichiometric Reaction (ideal)CH₄ + 2O₂ → CO₂ + 2H₂O C₁₂H₂₃ + 17.75O₂ → 12CO₂ + 11.5H₂O CO₂ Concentration (vol%)8–10%12–14% Water Vapor (vol%)10–12%10–12% Excess Oxygen (vol%)2–4% typical 2–4% typical Nitrogen (N₂)74–78%70–75% NOₓ (ppm)10–50 ppm 50–500 ppm CO (ppm)<10 ppm (clean burn)50–300 ppm (higher under load) SO₂ (ppm)~0 (no sulfur in fuel)50–300 ppm (depends on sulfur content) Particulate Matter (PM)Negligible 0.01–0.5 g/m³ (visible soot possible) Unburned Hydrocarbons (VOCs)<10 ppm 10–100 ppm Odor/Smoke None Noticeable at load or poor combustion CO₂ Emission Factor (kg/MMBtu)~117 ~161 Thermal Efficiency Very high, clean flame High but with soot and higher losses Maintenance Impact Minimal fouling; clean exhaust Requires soot blowers, filters, or DPF/SCR systems Regulatory Effects Meets most modern air-quality standards without after- treatment Requires emission controls to meet standards 15 Key Takeaways What would have happened if we did not flare OPTION A - Run Emergency Diesel Generators OPTION B- Shut Down Facility Badami Unit production would be shut down Badami Unit production would be shut down Nutaaq pipeline initiated for scheduled shut down Nutaaq pipeline would be shut down Coordination with Point Thompson Unit for scheduled shut down while on emergency diesel generators Point Thompson Unit will be forced to shut down Increasing HSE issues for both units and pipelines HSE issues for both units and pipelines Likelyhood of spills and weather related injuries to personnel due to urgency Likelyhood of spills and weather related injuries to personnel due to urgency Increased costs to turnaround the facility for restart Low oil prices would have postponed restart for Badmai Unit and Nutaaq pipeline Other operators who were actively depending on CIE would have been severely impacted potentially compromising their operations Other operators who were actively depending on CIE would have been severely impacted potentially compromising their operations State would have lost $4.76 MM of royalties from Badami and potential $6.96MM Point Thompson excluding additional revenue from production taxes State would have lost $11.72 MM of royalties from Badami and Point Thompson excluding additional revenue from production taxes OPTION A ends up being a precursor to OPTION B 16 Financial Impact and Corrective Investment VRU Failures, Repairs, and Investments (2024–2025) Event Date(s)Description / Cause & Repair Repair Cost (USD) Cylinder, Piston & Discharge Valve Failure Oct 9, 2024 – Mar 8, 2025 Discharge valve disintegrated inside cylinder, damaging piston, crosshead, and crankshaft. Major rebuild and component replacement. $450,000 Cylinder Lining Damage Apr 14 – Jul 2, 2025 Inadequate repair from prior vendor; reworked at Bender CCP with new HVOF coating and liner replacement.$20,000 Piston & Ring Failure Jul 23 – Aug 21, 2025 Piston damage without cylinder failure; replaced piston and ring assembly. Sustained VRU operation since repair. $30,000 (est.) Total Investment to Date —Comprehensive repairs, freight, vendor delays, engineering support.$500,000 “CIE Invested over $500,000 in corrective and reliability improvements — exceeding the proposed $357,905 fine.”17 Technical Improvements Implemented •Completed Corrective Actions •Replaced 3rd-stage compressor cylinder, piston, and discharge valve assembly (March 2025) •Repaired crosshead and crankshaft alignment; rebalanced drive system •Implemented new High Velocity Oxygen Fuel (HVOF) coating to extend cylinder life (July 2025) •Installed new piston and ring set with improved metallurgy for durability (August 2025) •Verified integrity and reinstalled VRU compressor under improved QA/QC procedures •Reliability Enhancements (In Progress / Planned): •Vacuum Pump Retrofit: Evaluating installation in place of eductor — expected to reduce potential flaring by 0.12–0.17 MMSCFD during outages. •Redundant VRU Project: Pre-IFA design underway with K-Corp; engineering completion targeted for Q1 2026. •Critical Spares Program: Stocking key VRU components and shortening Siemens’ lead times for expedited repair cycles •Instrumentation Upgrade (2026 M300 Campaign): To address historic instrument trips that previously caused downtime These actions collectively ensure greater reliability, minimize future flaring risk, and directly address AOGCC’s conservation and operational reliability expectations. 18 Key Takeaways •Flaring was safety-driven and necessary, not wasteful •Conducted fully within 20 AAC 25.235(d)(5) allowances •Prevented HSE and operational issues especially with the Point Thompson pipeline •Prevented Badami facility shutdown and mandatory turnover •Prevented massive impact on royalties payments paid to state both from Badami Unit and Point Thompson Unit •Gas was purchased and royalty-paid; no loss to State •Prevented pollution from diesel consumption •Prevented emergency tariff increases to the Nutaaq pipeline •Over $445,000 spent in repairs and other engineering solutions in the way •CIE maintained continuous communication and transparency with AOGCC •Prevented damage to newly drilled exploration well B1-33 and retained investor confidence on huge capital spend 19 Requests to the Commission •We respectfully request to drop the Notice of Violation (NOV) and allow us to utilize regulations made for this very situation •Acknowledge safety, compliance, and ensure fair treatment consistent with other North Slope operators • We respectfully request to eliminate the $357,905 penalty •Company already invested more than the penalty amount •Gas was purchased and royalty-paid •We paid $2.50 to $2.73 per MCF for Endicott gas, not the $3.5+ x (2) the state has used •Recognition of transparency, open communication, corrective actions and future safeguards 20 Closing Message •Cook Inlet Energy remains committed to •Safe and responsible operations •Transparent engagement with regulators •Continuous improvement in facility reliability and conservation •We respectfully request that the Commission •Drop the Notice of Violation, recognizing that this was a safety-driven event conducted under 20 AAC 25.235(d)(5); and •Eliminate the $357,905 penalty, acknowledging that the gas was purchased, royalty-paid, and that Cook Inlet Energy has already spent more than that amount in corrective and reliability improvements. 21 8 AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 ALASKA OIL AND GAS CONSERVATION COMMISSION In the Matter of the Application of ) Cook Inlet Energy, LLC for Hearing ) Regarding Other Order 221, Badami Unit ) Vapor Recovery Unit Flaring Event. ) __________________________________________) Docket No.: OTH-25-031 PUBLIC HEARING October 30, 2025 10:00 o'clock a.m. BEFORE: Jessie Chmielowski, Commissioner Greg Wilson, Commissioner AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 2 1 TABLE OF CONTENTS 2 Opening remarks by Commissioner Wilson 03 3 Testimony by Mr. Boman 07 4 Testimony by Mr. Ratcliff 29 5 Testimony by Mr Pascal 36 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 3 1 P R O C E E D I N G S 2 (On record - 10:03 a.m.) 3 COMMISSIONER WILSON: So good morning, I will 4 call this hearing to order. It is approximately 10:03 5 on Thursday, October 30th, 2025. This is public 6 hearing on docket number OTH-25-031. By letter 7 received on August 22nd, 2025, Cook Inlet Energy, LLC 8 filed a request for hearing with the Alaska Oil and Gas 9 Conservation Commission regarding other order 221, 10 Badami Unit, Vapor Recovery Unit flaring event. I am 11 Commissioner Greg Wilson and with me is Commissioner 12 Jessie Chmielowski. Today's hearing is being held in 13 person and via Microsoft Teams. The in person location 14 is the Alaska Oil and Gas Conservation Commission 15 office at 333 West 7th Avenue, Anchorage, Alaska. For 16 those on Teams please be mindful of any background 17 noise and make sure you're muted when you're not 18 testifying or addressing the AOGCC. 19 If you require any special accommodation please 20 see Samantha Coldiron. She can be reached at 907-793- 21 1223 or send her a message through the Microsoft Teams 22 chat icon and she will do her best to accommodate you. 23 Samantha Coldiron will be recording the 24 hearing, Computer Matrix will be preparing the 25 transcript. Upon completion and preparation of the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 4 1 transcript anyone desiring a copy will be able to 2 obtain it by contacting Computer Matrix. 3 This hearing is being held in accordance with 4 Alaska statute 44.62 and 20 AAC 25.540 of the Alaska 5 Administrative Code. 6 The notice of hearing was published on the 7 state of Alaska online notices website as well as the 8 AOGCC's website and was sent through the AOGCC's email 9 list serve on September 2nd, 2025. The AOGCC also 10 published the notice in the Anchorage Daily News on 11 September 7th, 2025. To date the AOGCC has received 12 one comment on this matter. 13 As background on August 22nd, 2025 Cook Inlet 14 Energy, LLC filed a request for public hearing with the 15 AOGCC regarding other order 221, Badami Unit VRU 16 flaring event. Other order 221 was issued to Cook 17 Inlet Energy, LLC on August 14th, 2025 following a 18 notice of proposed enforcement action issued May 27th, 19 2025 and an informal review held between AOGCC and Cook 20 Inlet Energy on June 17th, 2025. Other order 221 was 21 issued for flaring of 51,015 MCF of gas at the Badami 22 processing plant across six months from October, 2024 23 to March, 2025 and imposed a penalty for the flared gas 24 of $357,905 per Alaska 31.05.150(d). The gas flared 25 was produced gas which normally would be gathered by AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 5 1 Badami's vapor recovery unit which was offline across 2 the six months specified previously. 3 The Commissioners will ask questions during 4 testimony, we may also take a recess to consult with 5 Staff to determine whether additional information or 6 clarifying questions are needed. 7 Before we get to the presentation from Cook 8 Inlet Energy we think it may be helpful to describe the 9 iterative process and timeline that this issue has 10 followed to date. To do so we would like to invite 11 Wade Boman, Petroleum Engineer for the AOGCC, to recap 12 that event. Mr. Boman is the lead engineer regarding 13 this matter. 14 15 Mr. Boman, are you prepared? 16 MR. BOMAN: Yes. 17 COMMISSIONER WILSON: We'll swear you in. 18 Please raise your right hand and respond. 19 (Oath administered) 20 MR. BOMAN: I do, yes. 21 COMMISSIONER WILSON: Let the record reflect 22 the witness responded in the affirmative. 23 Do you wish to be recognized as an expert 24 witness? 25 MR. BOMAN: Yes. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 6 1 COMMISSIONER WILSON: Please identify your 2 field of expertise and your credentials. 3 MR. BOMAN: I've got a bachelor of science in 4 petroleum engineering from the University of Alaska 5 Fairbanks. Sorry. First of all my name's Wade Boman 6 for the -- for the record. This is slide -- slide two 7 of the presentation. I'm a petroleum engineer here at 8 the Alaska Oil and Gas Conservation Commission. I work 9 at both drilling and reservoir engineering where I've 10 been for the last two and a half years. I hold a 11 bachelor of science degree from the University of 12 Alaska Fairbanks from 2013. I have a background in 13 North Slope heavy equipment, logistics and engineering. 14 Prior to the AOGCC I served as drilling materials 15 specialist for ConocoPhillips Alpine field, before that 16 I was a production and reservoir engineer with BPXA for 17 seven years, much of that time responsible for 18 production, interventions and reservoir engineering for 19 GC3's A, B and X pads. I was also a BP company expert 20 in multiphase flow systems modeling, focusing on 21 optimizing Prudhoe Bay production and solving large 22 capital expenditure project development questions. 23 COMMISSIONER WILSON: Commissioner Chmielowski, 24 are you satisfied with the expertise and credentials as 25 presented? AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 7 1 COMMISSIONER CHMIELOWSKI: Yes, I have no 2 objections. 3 COMMISSIONER WILSON: You will be recognized as 4 an expert in the field you identified. So just please 5 remember to speak into the microphone, also reference 6 your slides by number or title so that someone reading 7 the public record can follow along. So you can 8 proceed. 9 WADE BOMAN 10 having been first duly sworn under oath, called as a 11 witness on behalf of the AOGCC, testified as follows 12 on: 13 DIRECT EXAMINATION 14 MR. BOMAN: Thank you, Commissioner Wilson. 15 This is still at slide number 2, the intro slide for 16 me. I wanted to mention that here at the Commission 17 one primary focus area of my work is produced gas 18 disposition which includes analyzing flared gas volumes 19 from oil and gas facilities in the state mainly on the 20 North Slope and in Cook Inlet. The state cares about 21 the volumes of gasses vented or flared away for 22 excessive venting or flaring is a waste of gas 23 resources that could otherwise be used to increase 24 ultimate recovery by injection into a reservoir or for 25 potential future gas sales. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 8 1 Here we'll change slides to slide three. This 2 is only an example. A lot of people in my experience, 3 other than people in this room perhaps, but a lot of 4 people in general don't know a lot about flaring. This 5 is not of Badami, I just wanted to give a photo for 6 people that don't know, it's for anyone not familiar 7 with gas flaring and the volumes involved. This is a 8 facility in Prudhoe Bay, on the right is a -- is a 9 flare nozzle at flare and the left is a flare nozzle 10 with its pilot lit. During normal operations flare 11 tips only have the pilot burning. Pilot purge gas is 12 used to keep the pilot perpetually lit for safety 13 reasons and assist gas is used to add to the flare 14 stream to ensure good -- good flare combustion. And 15 flare gas which is what we're discussing today, flare 16 gas is a gas that a facility cannot handle that is 17 intentionally -- intentionally released and burned. 18 Again this is not Badami, this is just for intuitive 19 understanding for somebody not familiar with flaring. 20 Okay. This hearing concerns gas flaring that 21 occurred at Badami due to Badami's facility's vapor 22 recovery unit or VRU from now on being offline and all 23 gas normally collected by it being flared over multiple 24 months. The pink part of this slide shows the time 25 period and gas volumes flared that are being focused on AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 9 1 today. Even though flaring due to VRU issues continued 2 for another five months after the VRU was rebuilt shown 3 in yellow below on the slide. And you'll see these 4 same volumes and timelines in further slides. 5 COMMISSIONER WILSON: Mr. Boman, I have a 6 question. 7 MR. BOMAN: Sure. 8 COMMISSIONER WILSON: For the record could you 9 define what an MCF is? 10 MR. BOMAN: Oh, yes. That's 1,000 standard 11 cubic feet of gas. 12 COMMISSIONER WILSON: And so the total measure 13 that you've circled would be? 14 MR. BOMAN: It would be 51 million. Just add 15 three zeros to the right of that -- of that number or 16 rather multiply it by 1,000, you could do that as well. 17 COMMISSIONER WILSON: Thank you. 18 MR. BOMAN: We are on slide five for the 19 record. The beginning of the flared event. This goes 20 back about a year ago. On October 9th, 2024 Cook Inlet 21 Energy notified the AOGCC that Badami's VRU experienced 22 catastrophic damage to its third stage compressor due 23 to a discharge valve failure. Cook Inlet Energy 24 requested for AOGCC approval to vent for flared gas at 25 the Badami unit for over one hour. Emphasis was made AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 10 1 that maintaining facility operations was critical to 2 the continued operation of the Nutok pipeline which 3 carries both Point Thomson and Donnie production. 4 Right here I'd like to say that when all Badami 5 wells were later offline in January and February the 6 Point Thomson pipeline or production was not affected. 7 That's something to keep in mind at this point. That 8 didn't happen until later, but anyway I'll go on. 9 AOGCC responded by email that same day 10 explaining that per regulation preapproval of flaring 11 outside of well testing prior to production is not 12 allowed. The Commission can only -- basically the 13 Commission can only allow or approve flaring for well 14 testing production -- well testing prior to production. 15 AOGCC asked Cook Inlet Energy what steps were being 16 taken to reduce the flared volume of gas. Cook Inlet 17 Energy responded by email the same day stating the only 18 way Savant would be able to reduce the volume of 19 flaring is to repair the VRU and get it back online. 20 I want to note here that it was -- it was 21 interesting that shutting in producing wells was not 22 mentioned as an option nor was shutting in even a 23 single well or a handful of wells. 24 A couple weeks later on October 16th, 2024 Cook 25 Inlet Energy emailed the AOGCC informing that its AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 11 1 technician had assessed the VRU and identified repairs 2 and that they were sourcing parts to the unit to be 3 back online as soon as possible. Cook Inlet Energy 4 emailed the AOGCC informing that a complete tear down 5 of the VRU was necessary and that parts had been 6 shipped out for reworking. 7 This isn't on the slide, but at this point 8 email communication fell silent. In general the online 9 producing well count remained at 10 as it had been in 10 September prior to the VRU failure. October production 11 which we actually saw on a previous slide was greater 12 than in September despite the plant running a flare 13 every day of the month. Online well count never 14 reduced all through the many months of flaring. 15 I will now go to slide six for the record. To 16 show this visually note the pot on -- on this slide. 17 The black triangles represent the 10 wells online both 18 before and after the VRU failure. Red bars represent 19 gas flared in MCF and green box --green boxes show that 20 the online wells flowed for full months, 30 to 31 days 21 per month, up until the power turbine failure later on 22 in January. As in -- as in one of the previous slides 23 the pink portion of this table shows the time period 24 and gas flare that is being focused on even though 25 flaring due to the VRU iss -- VRU issues continued for AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 12 1 another five months after the VRU was rebuilt. 2 We're on slide seven for the record. The table 3 on slide seven shows the same online wellstock, days 4 online as well as oil and gas produced and gas flared. 5 As can be seen Badami remained at full production 6 despite the nonfunctioning VRU. As in the previous 7 slides the pink portion of the table shows the time 8 period and the gas flare that's being focused on today. 9 Basically we show the same information in a different 10 -- different form. 11 This is slide eight for the record. On January 12 6th, this is the fourth month of the flaring event. On 13 July 6, 2025 the -- this -- January of this year, the 14 fourth month of the event I reached out to Cook Inlet 15 Energy by email for an update on the flaring and plant 16 situation. Cook Inlet Energy replied with a thorough 17 emails, giving details of the VRU components and an 18 estimated rebuild time of the VRU of about one week. 19 And that work would begin soon. It would be one week 20 to repair once work began to make that clear. 21 On January 29th, a couple weeks later Cook 22 Inlet Energy emailed the AOGCC and requested approval 23 to flare gas from Badami well B133 for a period of 30 24 days. This was due to a catastrophic failure of 25 Badami's only functioning power generation turbine GTB AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 13 1 leaving the facility without power as the other power 2 generation turbine GTA was offline undergoing 3 controller system upgrades. The next day I emailed the 4 CIE, Cook Inlet Energy explaining -- again explaining 5 that the Commission is only authorized to preapprove an 6 inter-flaring of gas for the purposes of testing a well 7 before being put online for regular production. In the 8 same email I asked Cook Inlet Energy a list of 9 questions and they promptly answered the next day. 10 This is -- for the record this is slide nine. 11 This is things we've seen before, but I want to just 12 mention so at this point Badami shut in all production, 13 went to emergency diesel power for about three weeks 14 and pursued the controller upgrade of a GTA power 15 turbine. It was the only time flaring was minimized or 16 stopped shown here by February's lower flaring rate. 17 It doesn't show it clearly on here, but at one point 18 the plant was -- was shut down, all wells were offline 19 and so the overall flaring amount for February is very 20 low. The diesel generators provided power to the camp 21 and power to the safety systems of the Nutok pipeline 22 and Point Thomson flow rate continued unabated. 23 Here I'd like to point out that later we were 24 informed by Hilcorp the actual flow rate for Badami's 25 wells is not required to ensure production assurance AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 14 1 from Point Thomson as Hilcorp adds glycol injection 2 into the line from Point Thomson so freezing of the 3 line does not occur. What is needed from Badami is 4 electricity to power up the Point Thomson pipeline 5 system at Badami including communication, leak 6 detection and pipeline valves. So it is notable to 7 question why at least some of the wells at Badami were 8 not shut in during this month long flaring event. 9 Eventually in mid February the controller upgrade to 10 the GTA power turbine was completed, all 10 wells were 11 popped and flaring commenced exactly as it had before 12 the power outage. Hence the flaring volumes for 13 February being 6,587 MCF despite only 11 days of 14 production. When it came back online all wells were -- 15 all 10 wells were put back online. 16 On March 9th the Commission was informed by 17 Cook Inlet Energy that the VRU was back online as of 18 2:10 p.m., March 8th. Hence the relatively low flaring 19 volumes for March. Following that VRU troubles 20 continued and associated flaring continued as well for 21 the next five months. That means that overall from 22 October 24th through August 25th, 2025, sorry, Badami 23 was -- flared the VRU issues across 11 months and 24 nearly a full year. 25 For the record we're going to slide 10. Slide AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 15 1 10 shows this as well with flaring occurring through 2 last summer shown in yellow. Note that flaring only 3 reduces in the first time span because all wells were 4 shut in for three weeks during January and February. 5 On March 9th -- oh, sorry, that -- this is a 6 repeat. We'll go to slide 11. Through much 7 consideration of the Badami -- of the Badami VRU gas 8 flaring event the Commission issued a notice of 9 proposed enforcement action to Cook Inlet Energy on May 10 27th, 2025. And considering the findings careful 11 consideration was given to two things. Number 1, the 12 unusually prolonged time period of the flaring and 13 number 2, the seeming lack of effort to minimize the 14 flaring volumes. Per statute 20 AAC 25.235(c) quote, 15 the operator shall take -- shall take action in 16 accordance with good oil field engineering practices 17 and conservation purposes to minimize the volume of gas 18 released, burned or permitted to escape into the air. 19 Quoting the notice of proposed enforcement 20 action quote, upon review of the incident details, 21 including Badami's production data throughout the time 22 frame involved the Commission concludes that no effort 23 was made to minimize the volume of gas flared that the 24 VRU at Badami would normally capture. This is 25 evidenced by the same number of producing wells being AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 16 1 kept online while the VRU is down as were online before 2 the VRU failure, 10 during and 10 before. Furthermore 3 average monthly oil and gas production amounts after 4 the VRU failure are greater than those of the month of 5 September prior to the VRU failure. October, November, 6 December averages of 100,000 barrels -- 100,113 barrels 7 of oil and 48,755 MCF of gas versus 77,000 barrels of 8 oil and 38,404 MCF of gas for September. The same is 9 true of well B133's production is not taken into 10 account. 11 AS 31.05.1050(d) [sic], the penalty for gas 12 determined to be waste is twice the fair market value 13 for every 1,000 SCFs or standard cubic feet of gas 14 wasted. Gas fair market value is be -- is being 15 referenced from the Alaska Department of Revenue's 16 website. Badami's VRU flare event was ongoing across 17 six months and two yearly quarters with the prevailing 18 market value fluctuating across them. Thus monthly 19 flare volumes have been multiplied by the fair market 20 value for the appropriate quarter. Proposed action is 21 for Cook Inlet Energy to pay -- to pay the penalty -- 22 penalty totaling $357,905. Now it's all quoted from 23 the noticed of proposed enforcement action. This is 24 slide 11, we'll go to slide 12. 25 Cook Inlet Energy requested a informal review AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 17 1 after being issued the notice of proposed enforcement 2 action. The review was held on June 17th, 2025. 3 Following the review Cook Inlet Energy sent a letter of 4 response following the informal hearing. Many of the 5 points made in the letter of response were addressed in 6 the Commission's other order 221 issued to Cook Inlet 7 Energy on August 14th, 2025. 8 For the record I'm going to slide 13. From 9 other order 221, these are the findings. Cook Inlet 10 Energy acknowledged the flaring occurred and was 11 reported as required by 20 AAC 25.235. Cook Inlet 12 Energy stated that the flaring was not waste, but a 13 safety trip in response to equipment failure during 14 arctic winter conditions. The AOGCC agrees that the 15 flaring was duly reported on facility reports of 16 produced gas disposition, form 10-422. The AOGCC 17 defines this flaring as waste and does not agree with 18 Cook Inlet Energy's response that Cook Inlet Energy's 19 response was purely safety driven as all wells that 20 were producing before the VRU failure were kept online 21 after the failure for several months until the VRU was 22 back online. 23 Another point made, Cook Inlet -- by Cook Inlet 24 Energy is Cook Inlet Energy pointed out that regulatory 25 compliance was maintained as all events were reported AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 18 1 via form 10-422, facility reports of produced gas 2 disposition along with supplemental reporting and that 3 direct communications were maintained with the 4 Commission. Response on the enforcement action is the 5 Commission agrees that Cook Inlet Energy reported 6 flaring volumes via form 10-422 per regulation, that 7 the AOGCC points out that all operators are required to 8 report gas disposition in this manner per production 9 facility regardless of the nature of the production 10 facility's operations be they normal or otherwise. 11 Failure to report was, it is not in question. The 12 Commission agrees that supplemental reporting by email 13 and direct telephone communication did take place. 14 This being said as the VRU troubles rolled into power 15 turbine issues initial communications from Cook Inlet 16 -- Cook Inlet Energy did not make it clear that a 17 separate issue had developed. Additionally 20 AAC 18 25.235(b) and (c) require an operator to describe 19 actions taken to minimize the volume of gas flared. 20 Forms 10-422 for the period in question do not detail 21 actions taken to minimize volume, only repeating the 22 description of the flared events and I also believe 23 they refer to the VRU being repaired. 24 Go to slide 14 for the record. Cook Inlet 25 Energy pointed out that the primary cause of the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 19 1 flaring was the failure of the VRU unit that had no 2 backup unit to provide redundancy and that VRU failure 3 was unexpected. CIE further pointed out that power 4 turbine outages compounded the situation leaving only 5 diesel power. VRU flaring was essential to avoid 6 freeze up and loss of life or infrastructure. The 7 Division response was AOGCC agrees that the primary 8 cause of the flaring was the failed VRU, however 9 justifying flaring due to turbine outages and the 10 reliance on diesel generators is misleading as this 11 combination of events was only over a two to three week 12 period of the six calendar months that the VRU 13 associated flaring commenced. Additionally this 14 argument is baseless due to the fact that while both -- 15 that while both power generating turbines were offline 16 all production wells were shut in leaving no facility 17 gas to flare. 18 Another point made by Cook Inlet Energy is that 19 the flaring was justified under 20 AAC 25.235(d)(5) due 20 to the flaring being required for repairs and facility 21 operations, emergency response to negative 40 22 fahrenheit conditions and the ultimate recovery from 23 well -- from new well B133A. The Commission points out 24 that allowance is detailed in 25.235 for flare or 25 venting of gas for a period exceeding one hour or by AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 20 1 the Commission's discretion per 25.235(d)(5) and 2 considering authorized flaring for facility operations, 3 emergencies or ultimate recovery many things are 4 considered, not least of all the time span of such 5 flaring. Cook -- Cook Inlet Energy's flaring at Badami 6 extended across two yearly quarters and six different 7 months making careful consideration of waste trim 8 necessary. Moreover even if flaring could be justified 9 under the criteria listed in 25.235(d)(5), if there is 10 no action to minimize the flaring as required the AOGCC 11 may classify the flaring as waste pursuant to 12 25.235(d). 13 We're onto slide 15 for the record. So yeah, 14 CIE referenced other order 194 as the precedent 15 previously set by the Commission for the allowed 16 flaring volumes. Our response was other order 194 17 authorized the flare of gas from a new production well 18 on a lone drill site lacking permanent production 19 facilities. Applying for the authorization for flaring 20 for purposes of testing a well before the regular 21 production is within the rights of any operator. Upon 22 application the Commission in its discretion may 23 authorize such flaring pursuant to 25.235(d)(6). 24 Authorization, past or present, for flaring of gas for 25 well testing prior to regular production is not AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 21 1 precedent for the same or another operator's flaring of 2 gas from regular production due to processing facility 3 operation -- operations. 4 Another point made by Cook Inlet Energy is that 5 the state received 4.76 million in royalties from 6 Badami production during the VRU flaring event. Cook 7 Inlet Energy also pointed out that during the same time 8 period 787,944 barrels of oil flowed down the Nutok 9 pipeline from Point Thomson. CIE claims that shutting 10 in Badami production would have halted all production. 11 The Commission's response is other than considering 12 whether flaring is necessary to prevent loss of 13 ultimate recovery pursuant to 25.235(d)(5)(C), the 14 Commission does not take royalties or other economic 15 factors into account when enforcing Alaska oil and gas 16 statutes. Badami experienced a loss of power turbine 17 generating capacity and all production wells were shut 18 in. The emergency diesel generators were enough to 19 keep the Nutok pipeline operating. Also this argument 20 proposes a false dilemma as shutting in some production 21 wells was an option that was not pursued as across all 22 six months except for the two to three weeks during the 23 power turbine outage the same production wells were 24 kept online. 25 We'll go to the next slide, slide 16 for the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 22 1 record. And I'm almost done here. Cook Inlet Energy, 2 another point they made after the informal review was 3 that the -- they made the point that the flaring -- 4 that flaring gas does not equate to lost royalties of 5 the state or to the state. Accord -- adding that the 6 gas is for on site use only and has no market value or 7 export path. The Commission's response is resource 8 conservation including that of reducing or eliminating 9 gas flare volumes is of utmost importance to the state 10 of Alaska with lack of a current export path or current 11 unrealized royalties being immaterial. 12 A final point that Cook Inlet made was that the 13 gas valuation used to determine the overall value of 14 the gas flared is overstated, that the only viable 15 benchmark is Cook Inlet Energy's cost of gas when 16 purchasing gas from Endicott for use at Badami. The 17 Commission's response is Alaska statute 31.05.105(d) 18 [sic] mandates that a waste penalty should be -- shall 19 be twice the fair market value of the natural gas at 20 the point of waste. In determining the fair market 21 value for waste determination the Commission has 22 consistently utilized the prevailing value of North 23 Slope gas published by the Alaska Department of Revenue 24 at their website. The Department of Revenue's 25 publication states that quote, this prevailing value is AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 23 1 the weighted average sales price of gas to publicly 2 regulated utilities in the North Slope area. The 3 Commission concludes that this publication is an 4 accurate method of calculating the fair market value of 5 the flared gas. 6 For the record we'll go to slide 17. In the 7 order the Commission fined Cook Inlet Energy $357,905 8 with the caveat that any upgrades to or replacement of 9 both Badami's VRU and eductor system within the next 10 year can be credited against the penalty amount. 11 I have one slide I've added this morning. We 12 can look at it later if we would like. It is a 13 comparison of North Star versus Badami. You can see 14 that -- you can see that the oil production between 15 North Star and Badami -- first of all I just chose 16 North Star relatively arbitrarily, there's many 17 facilities you could compare on the Slope. North Star 18 and Badami make roughly the same amount of barrels of 19 oil, about 70, 73,000 barrels a month. The lower rows 20 are averages. North Star produces 485 times at least 21 in these five months -- these are the five months after 22 the VRU was repaired at Badami, North Star produced 485 23 times the amount of gas that Badami did and they only 24 flared over an hour three times the amount of gas that 25 Badami flared. Again this is not -- this is an example AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 24 1 that I believe in the presentation we're about to see 2 there will be many slides comparing facilities. I 3 wanted to point this one comparison out. Again roughly 4 the same oil production, North Star produced and 5 handled 485 times the gas that Badami did while only 6 flaring three times as much. Over the same period 7 after Badami's VRU was rebuilt, Badami still flared 8 one-third the gas that North Star did. 9 And that's all I have. Thank you. 10 COMMISSIONER WILSON: Cook Inlet 11 representatives, are you prepared or did you have 12 to..... 13 MR. PASCAL: I have some clarification 14 questions. 15 MR. RATCLIFF: Let's -- why don't we come back 16 to that. 17 MR. PASCAL: No, I wanted to see how the 18 process works. 19 MR. RATCLIFF: Okay. 20 MR. PASCAL: So you would like the presentation 21 from us before jumping on and answering Mr. Boman's 22 questions or comments. I wanted to kind of see what 23 the procedural talks about it because we were required 24 to submit our presentation on or before October 27 and 25 we did receive your presentation end of business AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 25 1 yesterday. So we are willing to address his 2 presentation, but we also want to reserve the right to 3 be able to come back and submit comments to the AOGCC 4 in a timely manner. 5 COMMISSIONER CHMIELOWSKI: We could consider 6 keeping the record open for you to submit. As much 7 time as you need would be fine. Would that -- would 8 that work for you? 9 MR. PASCAL: We appreciate it..... 10 COMMISSIONER CHMIELOWSKI: Okay. 11 MR. PASCAL: .....yes. 12 COMMISSIONER WILSON: You are prepared with 13 your computer setup though to do the presentation? 14 MR. RATCLIFF: We're not prepared on the 15 computer..... 16 COMMISSIONER WILSON: You're not. Okay. 17 MR. RATCLIFF: .....so we just need..... 18 COMMISSIONER WILSON: Yes. 19 MR. RATCLIFF: .....to be able to work in. 20 COMMISSIONER WILSON: We'll give you a second 21 there to hook your computer up, yeah. 22 (Pause) 23 COMMISSIONER WILSON: So I understand there 24 will be three from Cook Inlet Energy testifying? 25 (No audible response) AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 26 1 COMMISSIONER WILSON: Okay. Thank you. 2 MR. RATCLIFF: While we're getting set up I'm 3 going to give an opening statement, David's going to 4 give a presentation and then Zack's got a couple things 5 prepared. Do you want us all to give our names, 6 titles..... 7 COMMISSIONER WILSON: What -- yeah. I was 8 going to -- once you were prepared to present I was 9 going to swear in the witnesses and then if you want to 10 be..... 11 MR. RATCLIFF: .....and then we'll go into 12 opening comments themselves. 13 COMMISSIONER WILSON: Yeah, we'll hold for the 14 moment. 15 MR. RATCLIFF: Okay. Thank you. 16 (Pause) 17 COMMISSIONER WILSON: Are you ready to make 18 your presentation? 19 MR. RATCLIFF: We are. 20 COMMISSIONER WILSON: All right. We'll swear 21 in the witnesses then. So will all of you please raise 22 your right hand and respond. 23 (Oath administered) 24 IN UNISON: Yes. 25 COMMISSIONER WILSON: Let the record reflect AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 27 1 the witnesses all responded in the affirmative. 2 Do any of you presenting today wish to be 3 recognized as expert witnesses? 4 MR. RATCLIFF: All three of us do. 5 COMMISSIONER WILSON: Okay. So one by one 6 please identify your field of expertise and your 7 credentials. 8 MR. RATCLIFF: I'll go ahead and start first. 9 So Stephen Ratcliff, president and CEO for Glacier Oil 10 and Gas. Glacier Oil and Gas is the owner of Cook 11 Inlet Energy who's the operator of the Badami unit. 12 I've got a petroleum engineering degree from Texas A&M, 13 25 years of experience in this industry, I of course 14 run Glacier Oil and Gas as well. I would say fourth 15 generation in this industry in oil and gas as well as 16 second industry to work here in Alaska in the industry 17 as well. 18 David. 19 MR. PASCAL: David Pascal. (Indiscernible - 20 away from microphone). 21 COMMISSIONER WILSON: David, could you -- yeah, 22 lean forward just a bit. Yeah. 23 MR. PASCAL: All right. I'll restart. My name 24 is David Pascal, chief operating officer for Glacier 25 Oil and Gas which also includes Cook Inlet Energy, AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 28 1 entities we're talking about today. I have over 27 2 years of experience in chemical, petrochemical and 3 industries involved in oil and gas. 4 With respect to Badami I was part of the team 5 which actually evaluated the assets and bought Badami. 6 I served in Badami as a production superintendent, 7 production manager, vice president of operations and 8 now the chief operating officer. 9 (Off record comments - microphone) 10 MR. PASCAL: So I do know the ins and outs of 11 Badami not only from the operations point of view, but 12 also from the regulatory point of view. My background 13 is in chemical engineering. I've studied -- a 14 bachelor's in chemical engineering from University of 15 Mumbai and master's in petroleum engineering from 16 University of Alaska Fairbanks. In fact Wade and I 17 crossed paths, I used to be his teaching assistant for 18 a few courses. So small world. 19 MR. HUNDRUP: I'm Zack Hundrup, I'm the 20 production and facilities manager for Glacier Oil and 21 Gas. I've got a bachelor of science in mechanical 22 engineering from the University of Idaho in 2009 and 23 then I started up at Badami in 2012 as the facilities 24 engineer, I did about a year of two and two shift work 25 up there. And then when Glacier bought the company I AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 29 1 became a Glacier employee and in 2020 I became the 2 production and facilities manager for Glacier so I've 3 been working the Badami field for about 13 years now. 4 COMMISSIONER WILSON: Commissioner Chmielowski, 5 are you satisfied with the expertise and credentials as 6 presented? 7 COMMISSIONER CHMIELOWSKI: Yes, I have no 8 objection. Thank you. 9 COMMISSIONER WILSON: You all will be 10 recognized as experts in the field you identified. 11 So again for those testifying please remember 12 to speak into the microphone, also reference your 13 slides by number or title so that someone reading the 14 public record can follow along. State your names and 15 job titles clearly for the record and please begin. 16 STEPHEN RATCLIFF 17 having been first duly sworn under oath, called as a 18 witness on behalf of Glacier Oil and Gas, testified as 19 follows on: 20 DIRECT EXAMINATION 21 MR. RATCLIFF: Well, good morning, 22 Commissioners. I just want to say first thank you for 23 the opportunity to be here today to present on our 24 behalf. Also thank you to Staff and the others that 25 have joined us today. So I'm going to go through some AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 30 1 opening remarks and then I'm going to pass this over to 2 David. David has a presentation prepared which I 3 believe you guys received last Monday that we will also 4 go through as well. 5 So we're very passionate about the assets we 6 own and operate in the state of Alaska as well as our 7 commitment to regulatory compliance, safety and our 8 good stewardship on the resources that we own and 9 operate and are responsible for. We respect the -- we 10 respect and appreciate the AOGCC's role in ensuring 11 resource conservation, environmental protection and 12 fair oversight of Alaska's oil and gas operators. 13 We're here today regarding the Badami vapor 14 recovery unit flaring event. We acknowledge the 15 flaring occurred as we effectively communicated details 16 around the event, repair mitigation as well as 17 reporting every volume accurately to the Commission in 18 real time both for transparency and in good faith. 19 It's also my position that statements in the AOGCC 20 hearing presentation provided by the Commission 21 yesterday and also here recently by Mr. Boman 22 mischaracterize and omit communications from our office 23 to the Commission and do not accurately apply current 24 regulations in place. I ask today that this event be 25 evaluated on its full operational and regulatory AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 31 1 context with fairness and consistency in how 2 enforcement actions are applied throughout all 3 operators on the North Slope. 4 So our position rests on five key points. 5 First safety and facility and pipeline integrity; 6 number 2, good faith compliance; number 3, fairness and 7 consistency; number 4, mitigation and economic factors; 8 and number 5, forward commitment and investment. So on 9 position one, safety and facility, pipeline integrity, 10 the flaring..... 11 COMMISSIONER WILSON: I'm sorry, Mr. Ratcliff, 12 before you go into that I was asked can we take just a 13 short break, we think one of the microphones is dying. 14 MR. RATCLIFF: Okay. 15 MS. COLDIRON: I'm so sorry. 16 MR. RATCLIFF: No, that's okay. No problem. 17 (Off record) 18 (On record) 19 COMMISSIONER WILSON: We apologize. So, Mr. 20 Ratcliff, you may proceed. 21 MR. RATCLIFF: Okay. Thank you, Commissioner. 22 So I'm going to start on our position number 1 around 23 safety and facility, pipeline integrity. 24 The flaring event resulted from the vapor 25 recovery unit compressor failure at Badami of which the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 32 1 VRU was both on and off online multiple times during 2 the 182 days that have been referenced while working on 3 repairs replacement components and mitigation measures, 4 much of which was during arctic winter conditions. 5 Although replacement parts were built repairs were 6 further intensified by limited vendor availability and 7 prolonged supply chain delays for specialized 8 replacement components and repairs of which included 9 manufacturing of new parts for equipment that was built 10 circa 1990s. Immediate priority was on protecting our 11 personnel, the properties, facilities, preventing 12 freeze up of our facilities, wells and pipelines and 13 maintaining safe operations for our team. 14 We believe the event was managed responsibly, 15 all volumes were fully reported to the AOGCC Staff, 16 both by email as well as phone calls and in person 17 meetings. In other words collaboration between our 18 office to yours was of high importance to us to make 19 sure that you all were in the loop as to what was going 20 on. We believe we were very transparent throughout 21 this entire process to keep you fully up to speed on 22 not only the progress, but also when repair efforts 23 were negated with faulty manufactured replacement 24 parts. 25 On topic number 2, good faith compliance. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 33 1 Every flaring event was reported via form 10-422 with 2 ongoing direct updates to the Commission. Our actions 3 were consistent with regulation 20 AAC 25.235, section 4 (d), number (5), which permits flaring as required for 5 repairs, safety and facility operations. We operated 6 transparency -- transparently, excuse me, within the 7 regulatory framework and took immediate corrective 8 actions to restore full compliance. 9 On topic number 3, fairness and consistency. 10 Upon reviewing the AOGCC's own flaring and venting 11 database it is clear that other North Slope operators 12 including large unit fields such as Prudhoe Bay, 13 Colville River, Milne Point, North Star as was 14 referenced and Point Thomson routinely flare and vent 15 volumes that are several orders of magnitude greater 16 than the 51,000 MCF that was flared over the 182 days 17 at Badami. Many of these operators reporting flared 18 volumes occurred both within and outside of the same 19 time frame for which Cook Inlet Energy is being fined, 20 yet no NOVs or penalties were issued for comparable or 21 greater volumes. From January 1st of this year through 22 September 30th the AOGCC report -- reporting showed 23 over 657,000 MCF, over half a billion, from North Slope 24 assets operated by Hilcorp, roughly 13 times the amount 25 flared from Badami or nine times the volume when AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 34 1 looking at the same period of time that Badami flared. 2 During my time on the Slope during the month of August 3 there was an ongoing flare at North Star. It was 4 referenced in the slide that over 60,000 MCF was flared 5 at North Star. That's a volume greater in one month 6 than our entire event. This raises a issue of 7 equitable enforcement since the data demonstrates that 8 Badami's flaring was minimal, safety driven and 9 substantially less compared to regional averages. 10 On topic number 4, mitigating and economic 11 factors. The gas that was flared was purchased gas 12 meaning it was not free gas, but already paid for and 13 subject to state royalties. The state of Alaska did 14 not incur a financial loss as royalties were paid on 15 every molecule. Meanwhile we kept the Nutok pipeline 16 fully operational, supporting throughput from Point 17 Thomson and preserving regional oil deliverability. 18 Legitimate concerns around total loss and freeze up of 19 the pipeline were feared. Given the four months of 20 pipeline freeze up with Harvest operated Point Thomson 21 pipeline in 2024 we believe that these were validated 22 concerns. 23 On item 5, forward commitment and investment. 24 Cook Inlet Energy is already invested well beyond the 25 proposed $357,000 penalty in repairs and system AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 35 1 upgrades to the VRU and eductor system. Additional 2 permanent engineering, improvements are underway to 3 ensure this issue does not reoccur, directly addressing 4 the Commission's conservation objectives. 5 With this context in mind our specific request 6 to the Commission is as follows. First, to remove the 7 notice of violation, recognizing this was a safety 8 driven, non-waste event conducted under good faith and 9 in compliance with AOGCC regulations and second, to 10 eliminate the proposed penalty as the state already 11 received royalties on the flared gas and Cook Inlet 12 Energy has spent substantially more on repairs and long 13 term solutions than the penalty amount itself. 14 In closing we believe the record will show that 15 Cook Inlet Energy acted responsibly, transparently and 16 justifiably and operated within the framework of the 17 regulations. Our reporting and data we've provided, 18 both operational and regulatory, support this 19 enforcement action as inconsistent without comparable 20 cases that have been handled across the North Slope. 21 We respectfully request that the Commission 22 acknowledges these mitigating circumstances. The 23 presentation of the new information we have submitted 24 and our corrective actions by removing the NOV and 25 waiving the fine. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 36 1 I will now hand off the meeting to David to 2 walk through our presentation that we've prepared for 3 the Commission. I appreciate the time and the 4 opportunity to present today. 5 DAVID PASCAL 6 having been first duly sworn under oath, called as a 7 witness on behalf of Glacier Oil and Gas, testified as 8 follows on: 9 DIRECT EXAMINATION 10 MR. PASCAL: Thank you, Stephen. I hope you 11 can hear me this time or should I speak up? 12 COMMISSIONER WILSON: And then lean in as close 13 as you can and just within a few inches of the 14 microphone. 15 MR. PASCAL: I'll apologize a little bit, I've 16 been having a little throat infection for the last few 17 days. So but anyway I'm going to do my best. 18 Well, thank you, Stephen, for handing it off. 19 And I'll be going through the slides called the Badami 20 VRU flaring event. Formal hearing representation, 21 AOGCC docket number OTH-25-031. So right now we're on 22 slide number 1 which is the title slide. 23 So good morning, Commissioners, the AOGCC Staff 24 and also the members of the public here today. Like I 25 said before my name is David Pascal, I'm the chief AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 37 1 operating officer of Glacier Oil and Gas which includes 2 Cook Inlet Energy which is the operator of the Badami 3 unit on record. On behalf of our team I really 4 appreciate this opportunity to present our position 5 regarding the VRU flaring event. Once again like 6 Stephen mentioned before we fully respect the 7 Commission's mission to save Alaska's resources through 8 conservation, safety and responsible oil and gas 9 operation. And hopefully after this meeting we can 10 clear some things up. 11 So a quick note before I jump into the slides 12 about the Badami unit for context. So GLA acquired -- 13 when I say GLA it's Glacier Oil and Gas, the parent 14 company, we acquired Savant around 2014. In fact 15 Stephen and I were part of the evaluation team looking 16 at Badami. And at the time Badami was on the verge of 17 shut down because the production was below 800 barrels 18 per day and was not able to pass leak detection limits 19 and it was on a downward spiral to it being abandoned. 20 So we took over the unit and we transformed Badami 21 quite a bit. So Stephen and I personally along with 22 Zack have operated the Badami unit for over 10 years 23 now with great success. We generated over 4 million 24 barrels of royalty payments, 4 million barrels 25 amounting to almost about $30 million of royalty AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 38 1 payments to the state of Alaska and another $11 and a 2 half million of production taxes. So something to keep 3 in mind. 4 We also invested a lot of money in Badami, our 5 capital investment that exceeded over $150 million 6 since we bought it and we also were able to discover 7 more potential at Badami which has transformed the east 8 side in terms of resource development. Not to mention 9 that we also support a lot of companies in that area 10 who depend upon us for critical operations. Like for 11 example (indiscernible) which during the time we were 12 flaring gas was actually receiving power from Badami to 13 the DC2 camp and we were housing personnel to construct 14 an ice road. So their operations were dependent upon 15 our operations. 16 We'll jump into the slides. So this is slide 17 number 2, background and timeline. So I won't spend 18 too much time on this because Mr. Boman talked about 19 this. What I want to say is that the period I know you 20 considered was the 180 days and the VRU was offline for 21 only 150 days out of that -- out of those days. So 22 something to keep in mind. 23 So the problem we had is -- this is not -- this 24 is the first time it happened in my 10 plus years of 25 operating Badami, we had a catastrophic failure of the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 39 1 compressor, VRU compressor and it was not operator 2 error for sure. And like Stephen mentioned it took a 3 lot of time to source parts and find services, calling 4 people from the lower 48. Post covid we have seen a 5 lot of people exit Alaska. There is lack of vendors, 6 services and support. In fact one of the vendors who 7 performed the first repairs, they said they'd never 8 work in Alaska after working at Badami. Not because 9 they didn't like us, it was because it was so difficult 10 for them to organize stuff. We had to fly them on 11 first class tickets, we had to pay them overtime for 12 flying and all kinds of things. In spite of that it 13 was really difficult. So we did our best and we also 14 ran into secondary problems which we'll talk about a 15 little bit, but we did the best we could and got the 16 VRU up and running. And then like we mentioned before 17 in the dead of winter especially in the coldest months 18 we actually even lost the turbines. Normally you have 19 two turbines and one of the turbines collect power, 9 20 megawatts, but we were having a control system upgrade 21 so one turbine was completely offline and once again we 22 had a catastrophic damage in one of the turbines. I've 23 been dealing with turbines for over 20 years and this 24 is something I've never seen before. So odds were 25 stacked against us and we were left without anything at AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 40 1 Badami for normal power generation. So we struggled in 2 Jan and Feb, but we definitely got the VRU restored and 3 operational after that. 4 COMMISSIONER CHMIELOWSKI: Thank you, Mr. 5 Pascal. Is the VRU -- you say it was restored and 6 operational March 8th, but it looks like there was 7 flaring after that. Was that related to the VRU, is it 8 operational today? 9 MR. PASCAL: It was a combination of both. And 10 we'll discuss a little bit more into detail. Like we 11 said we tried to get the VRU up and running as soon as 12 we could. We ran into secondary issues and we had a 13 second VRU failure 37 days after repairing it and we 14 had to rebuild the VRU again. 15 COMMISSIONER CHMIELOWSKI: Is it operational 16 now? 17 MR. PASCAL: It is completely operational now. 18 COMMISSIONER CHMIELOWSKI: Today? 19 MR. PASCAL: That's correct. Yes. So before I 20 jump in you can see like the total flaring period, five 21 months, 182 days. 150 days was aggregated to the VRU 22 compressor being offline. And I want to kind of talk 23 about this 51,000 MCF which kind of translates to the 24 notice of proposed enforcement action. So the volume 25 was calculated on total flared volumes, this is less AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 41 1 than one hour and over one hour from October 24 to 2 March 25. And this is clearly stated in AOGCC's notice 3 of enforcement action dated May 27, 2025. The fine was 4 determined by taking all the 51,000 MCF of gas flared 5 at fair market value which was $3.50, we'll talk about 6 why we disagree with that, and then doubling the figure 7 to arrive at the penalty amount. The calculation did 8 not account for the fact that the gas we purchased was 9 approximately at an average cost of $1 to 2.60 per MCF 10 which is still -- 40 percent more is what we've been 11 attributed with. There is already royalty paid which 12 means the state incurred no fiscal losses. Badami gas 13 is entirely consumed on site and no -- has no avenue to 14 be transported or sold to market. So this is something 15 we want everybody to understand. Even if you had 16 excess Badami gas there's no way we can sell it to 17 anyone or transport it, it has to be used on lease. 18 In addition the total includes volumes that 19 fall under authorized categories of 20 AAC 25.235, 20 subsection (b)(1), (2) and (4). For example flaring 21 below one hour as a result of an emergency, of an 22 operational upset, planned lease operations, unplanned 23 lease operations and de minimis venting. It's in the 24 regulations. So there's no effort made to kind of 25 subtract those volumes of gas. Furthermore according AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 42 1 to 20 AAC 25.235, subsection (d) and (5), it clearly 2 states that when the gas disposition report is sent in, 3 the 10-422, AOGCC has a 90 day window to respond back 4 to determine if this gas was considered to be a waste 5 or not. So we submitted gas disposition reports before 6 20th of every month and the notice of enforcement was 7 issued on May 27th. So if you look at the 90 day 8 window it goes back to Feb 27. So if the regulations 9 are taken straight as of this, you know, the AOGCC 10 cannot go back in time and they can only consider 11 reports, the 10-422 reports starting in March and 12 April. So if you look at the amount a month AOGCC has 13 used in their calculation for fines, more than 80 14 percent of it will fall outside that 90 day window. 15 So summarize that 51,000 MCF, it's our belief 16 that the flaring volume and penalty calculation are 17 overstated and very procedurally inconsistent with 20 18 AAC 25.235. 19 COMMISSIONER CHMIELOWSKI: Mr. Pascal, you 20 state on this slide that all gas volumes were paid for. 21 So you're state that all the gas flared was Endicott 22 gas? 23 MR. PASCAL: That is how we allocate that gas 24 in our production accounting system. 25 COMMISSIONER CHMIELOWSKI: So -- so no AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 43 1 subsurface gas ever go -- could go to the flare? 2 MR. PASCAL: Well, the answer is that it's 3 impossible to trace every molecule of gas because at 4 Badami there is more than 20 -- the compressor rate of 5 over 21 million, but I think at anytime there's 15 6 million of gas circulating in the system which includes 7 gas lift, injection, gas for heating, production, 8 burners, gas for heating camps, also gas for the 9 turbines. And also the gas passes paths back and forth 10 and the way we try to run our operations is that we 11 want to use Badami gas for fuel consumption, the 12 approximately fuel consumption is anywhere between 1.6 13 to 1.8 MCF per day for just the turbines. And the 14 turbines from EPA regulations and DEC regulations need 15 to run in SoLoNOx which means that I cannot use 16 Endicott gas which has higher H2S limits in it. And we 17 had a similar situation back -- a couple of years back 18 as the Commission remembers, that our B107 well was 19 offline, we were forced to buy more gas from Endicott 20 and we were crossing our H2S limits because our H2S 21 limits are 250 parts per million according to permit 22 and Endicott has an advantage of having higher H2S 23 limits, they can go up to two to 3,000 which is 24 inconsistent and unfair, but it's a whole different 25 story. So when we were using Endicott's gas to keep AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 44 1 Badami basically running and during this time there's 2 no flaring by the way, we were threatened with criminal 3 action actually. And luckily thanks to the AOGCC we 4 were able to get B107 online because we went through 5 another hearing like this in which the AOGCC authorized 6 us to use the Thunderbird rig in the month of April. 7 So we appreciate the Commission's haste -- haste action 8 on this. It prevented us from shutting Badami and the 9 Nutok pipeline. 10 COMMISSIONER CHMIELOWSKI: Could you -- oh, 11 sorry. Could you just -- and this is not a correct 12 absolutely remember, approximately what percentage of 13 gas handling is native or subsurface gas versus 14 Endicott gas? 15 MR. PASCAL: That's a very good question. So 16 we'll talk with the VRU gas person, the slides and I'll 17 kind of give a distribution of what gas it is in the 18 forthcoming slide. 19 COMMISSIONER WILSON: One further question on 20 that topic. Just for the avoidance of doubt, does the 21 native gas mix with the Endicott gas? 22 MR. PASCAL: Yes, that is correct. So to 23 answer the question, Commissioners, it would be the 24 next slide which is slide number 4, but I want to 25 quickly touch on slide number 3. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 45 1 So I want to make it clear that the compressor 2 failure is mechanical and it was not operational 3 negligence. And like I said these type of failures 4 happen seldom and in the 10 years we've been operating 5 Badami this is the first time it happened for not only 6 the compressor, but also the turbine. It was just our 7 bad luck for lack of better words. And we can show 8 multiple records that our PM program was in full swing 9 so we were up to date on all the compressor maintenance 10 on it. And the root cause of what happened is a 11 discharge valve failed, the debris entered into the 12 system and it ended up damaging the cylinder and piston 13 completely. So we literally had to rebuild the VRU 14 third stage. And like Stephen mentioned and Zack will 15 attest to it, repair parts required special 16 fabrication, it was delayed by vendor logistics and it 17 -- it's a highly balanced system because any sort of 18 vibrations will take the system offline and cause more 19 damages. And we had to do a lot of changes to make it 20 work. In fact, one of the cylinders we got for 21 replacement had a two millimeter difference in a throw, 22 just two millimeters. Two millimeters is not even 23 noticeable by the naked eye. And we couldn't use it 24 and we had to go back to the drawing board and do 25 something else. And when we got the right cylinder to AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 46 1 use which is plus two millimeters of throw, that also 2 failed in 37 days. We had to go back and figure out 3 how to make it more robust and once again had to go 4 back to the drawing board to get the VRU operational. 5 It was a very tough process for sure. 6 So and it was really difficult because in a -- 7 in a major window where these repairs were happening we 8 had arctic temperatures and it was really difficult to 9 do any kind of work or shut down the facility because 10 when we shut down the facility like we know we need 11 time to properly plan, evacuate bezzles, evacuate 12 pipelines, remove moisture so that we can shut things 13 down. So we really required the turbine power which is 14 9 megawatts and not the diesel power which is 1.5 15 megawatts each. And those are backup generators and 16 not regular generators there. So flaring was the only 17 safe option for us to keep power. And like I 18 mentioned, you're also providing power to the DC2 camp 19 which house (indiscernible) personnel and also the 20 Nutok pipeline. We'll talk about diesel generators and 21 Nutok pipeline and some of the false assumptions about 22 it in the forthcoming slides. So flaring was the only 23 safe option. 24 So I'll move on to slide number 4 now which is 25 the operational context in which I will kind of talk AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 47 1 about some of the Commissioner's questions there. 2 So let's go back to the original design for 3 Badami's production facility. They have two main 4 compressors and one compressor runs at all time and we 5 have a backup. There's no backup to the VRU compressor 6 and it's for a very good reason because when BP 7 designed this facility they looked at the volumes and 8 said that the VRU is only handling 2 percent of the gas 9 which is circling the whole system. And it's actually 10 2 percent because we are only using one compressor. If 11 you had both the compressors because you have more 12 volume, more production, then that 2 percent is 13 probably going to go down to like half a percent. So 14 for 2 percent BP made a conscious decision that -- an 15 engineering decision saying that a second VRU is not 16 needed. And even if today we decide we want to put a 17 second VRU it's not going to happen in 10 days, it's 18 not going to happen in 20 days, it's going to take at 19 least a year to two to do an FID, find the right 20 people, make modifications to the system pressure, run 21 a lot of modeling, expand the units, put in foreign gas 22 system. So Rome is not going to build -- be built in a 23 day, we can start with the foundation. So I wanted the 24 Commission to kind of understand that. 25 So our option was to just get the VRU back AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 48 1 online. So when the VRU failed they're having all this 2 low pressure gas, what are we going to do with this low 3 pressure gas. We just can't vent it into a module 4 because it's not safe. So we use an eductor system 5 that basically captures all the gas going to the VRU 6 and safely routes it to the flare system. So by doing 7 that, you know, we were able to keep the turbines 8 operational. So Badami was getting full power during 9 winter which means that no issues of freeze up of 10 production systems and flow lines at Badami. So we 11 also kept Nutok pipeline operational. We'll talk about 12 Nutok pipeline and diesel in forthcoming slides. And 13 the production continued at Badami, we needed the power 14 stability for that. There's no question about that. 15 And if someone who has been operating the Badami unit 16 for long enough they can understand how important those 17 turbines are to keep Badami powered. And it also 18 prevented regional shipping impacts with Point Thomson. 19 Like my colleague, Stephen, mentioned here, you know, 20 Point Thomson had a spill, in fact, we helped them -- 21 we helped haulers with the spill gear, the first 22 responders because it was so cold that no one could get 23 there, it was arctic conditions, phase two, phase three 24 conditions. And their pipeline froze up pretty quick 25 after that. They were not able to get online until the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 49 1 weather improved. And Point Thomson makes a lot of 2 water compared to Badami and water also enters into the 3 Nutok pipeline because we can't avoid it. So if we had 4 some sort of emergency shut down of the pipeline in the 5 dead of winter and it was not properly planned needless 6 to say we would have had the same problem that Point 7 Thomson pipeline had with the Nutok pipeline. No 8 question about it. 9 COMMISSIONER CHMIELOWSKI: Mr. Pascal, you say 10 that the VRU accounts for less than 2 percent of total 11 gas when operational, but when it's down the eductor 12 system feeds quite a bit of gas. So when it's down 13 what percentage of gas does that account for for 14 flaring? 15 MR. PASCAL: Oh, normally what enters the VRU 16 is about 150 to 200 MCF of gas per day. And how the 17 eductor system works is it like a (indiscernible) 18 system. So you're using high pressure gas coming from 19 your compressors and you pass this high pressure gas 20 coming from your compressors and you pass this high 21 pressure gas through (indiscernible). Due to the 22 potential difference in pressure there's a vacuum 23 created in your Thorb (ph) system which will safely 24 suck out the low pressure gas. And it is all routed to 25 our flare system which the gas is 100 percent AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 50 1 completely combusted. So by the virtue of adding high 2 pressure gas to recover the low pressure gas you're 3 adding another 200 MCF on top of it, 150 to 200 MCF on 4 that. But you're right, there's a little bit of extra 5 gas being used by the eductor system, but in the 6 condition that was the best engineering decision for us 7 to do. You just can't have gas in the module free, we 8 have to send it somewhere. And the only way we can 9 send it was a eductor system. So we looked at 10 everything and we'll also address if you could shut the 11 wells down and everything in just a second, but that 12 was the only safe way for us to collect and flare the 13 gas. 14 COMMISSIONER CHMIELOWSKI: Just for the record 15 I've heard a rule of thumb about 10 times the gas is 16 needed to be fed through the eductor system to get the 17 VRU gas out? 18 MR. PASCAL: That is not in our case. 19 COMMISSIONER CHMIELOWSKI: What is it then? 20 Okay. 21 MR. PASCAL: So I said like -- like I said it's 22 about 150 go 200 MCF of gas on an average going to the 23 VRU. And when we had this problem we were flaring 24 anywhere within -- 350 I think was the average for the 25 six months. So the delta is actually the gas which was AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 51 1 used to power the eductor system. 2 COMMISSIONER CHMIELOWSKI: So it doubles. Is 3 that what you're saying? 4 MR. PASCAL: Almost, but not -- not entirely 5 double. 6 COMMISSIONER CHMIELOWSKI: Okay. 7 MR. PASCAL: All right. Moving on to slide 8 number 5. I want to kind of address the regulatory 9 framework a little bit over here. So I'll kind of read 10 out 20 AAC 25.235(d)(5), you know, gas may be flared as 11 required especially to repair emergency and facility 12 operations necessary to prevent injury, loss or -- or 13 loss of ultimate recovery. You know, we believe our 14 actions were fully in line with this very regulation 15 and we also asked AOGCC for guidance on it which we 16 would -- we did not get any guidance on it. And my 17 point is if you can't use the regulations then what is 18 the point of having regulations in the first place. 19 So point number 1 was facility repairs, yes. 20 It was necessary for facility repairs. It would not be 21 in this condition if we were not performing a repair on 22 the VRU. It was an emergency because we're remote, we 23 do not have access to the road system and we just can't 24 shut down Badami facility in a -- in a heartbeat. It 25 takes months to plan and all -- months all -- and weeks AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 52 1 to execute safely. We wanted to prevent equipment 2 damage and not create any safety hazards because it was 3 arctic conditions, we just can't evacuate people from 4 Badami. And backup generators are meant to be backup, 5 they don't provide full power and power has to be 6 selectively used in your modules. So it comes -- when 7 -- when it comes to that you have to choose on what 8 sections you need to power off. So if Badami's 9 completely operational and you don't have any sections 10 that he can safely power off you cannot be relying on 11 diesel generators, it's a big problem. 12 And also continue the essential facility 13 operations. It was necessary to prevent loss of 14 ultimate recovery especially B -- well B133A which had 15 just come online. So for record B133A was our 16 exploration well in the Killian. Glacier spent a lot 17 of money on that well, over $65 million, got the well 18 online in late September because we had a really bad 19 ice road season and (indiscernible) both affected, we 20 had to go into the barging season and this well 21 basically was the well which would increase the 22 production in -- at Badami unit. Because the well was 23 brought on in the end of September and we were well 24 testing it and the well free flowed for a bit and then 25 in December, mid December to end of December, we AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 53 1 started gas lift operations in it. And gas lift 2 operations are all trial and error. You start off from 3 the poor gas lift mantle and work your way to the 4 bottom gas lift mantle. They were actively working on 5 this well, it was a new well, we were doing it. 6 And when we approached the AOGCC in Feb because 7 we had lost all production from Badami and we asked 8 AOGCC to exclusively produce only B133 well because the 9 production rates are higher from B133 and also the 10 amount of gas coming from B133 is lower compared to 11 other wells which have IGRs for the sake of keeping a 12 new well online and we were flatly refused in writing 13 saying that they cannot approve flaring for the B133 14 well even though this well was new. And like I 15 mentioned in my informal hearing (indiscernible) was 16 given approval to flare and the word used in other 17 order 194 was for economic justification, not well 18 testing. Well testing was included, but also economic 19 justification which means they got a blanket nine month 20 extension to flare. And they flared more gas, almost 21 two times more gas than what Badami did in six months 22 in two months. I think it was 57 days or something 23 like that. So the point I'm trying to make is we were 24 also refused when we had to use the regulations for 25 well testing purposes for the B133 exploration well. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 54 1 So we had to sadly shut down the well and we did see 2 reservoir damage to the well because of that. The 3 (indiscernible) of the well was impacted after we 4 brought it back online. 5 And then like Stephen mentioned 10-422 monthly 6 forms we submitted and yes, that -- that's the duty for 7 every operator to submit it so we're not asking for 8 special consideration submitting this form, but I also 9 want to say that once a 10-422 form is submitted 90 10 days a decision has to be made whether any gas flaring 11 over one hour is considered to be waste and excessive. 12 And the decision was not made in our case. It was made 13 very, very late, it crossed the 90 day window. So the 14 only two months the Commission can go back and say it 15 fell within the 90 day window is for the month of Feb 16 and March. So which means 80 percent of the gas volume 17 of that 51,000 mentioned has to be removed from the 18 volume stated. 19 We remained in constant communication with the 20 AOGCC. I think in every scenario we over communicated 21 with the AOGCC. Sometimes you don't get responses 22 back, it's fine, but we make our intentions known, we 23 talk, we come down in person, we over communicate we 24 try to make an effort to give all data possible to the 25 Staff of the AOGCC so they make the best decision. So AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 55 1 communication was not a problem, we acted really 2 transparently and we gave pages and pages of timelines 3 and what is happening and issues of vendors and parts 4 and services. It was not hidden from the AOGCC. They 5 exactly knew what was happening with us. 6 And once again, you know, the gas flared was 7 purchased from Endicott and we only buy gas from 8 Endicott when we need it because we don't want to pay 9 for gas we don't need or can produce on site. And 10 Endicott gas is not a really good gas, it has like 70 11 percent methane. Badami gas is the best gas on the 12 east side, over 99 percent methane, very low amount of 13 H2S, high calorific value, our turbines like it. And 14 in order to be SoLoNOx compliant I need to use Badami 15 gas. So I don't want to use Endicott gas if I don't 16 have to. So the gas which we bought was because we had 17 to make up and keep the turbines running because we did 18 not have enough fuel gas for Badami. So all of Badami 19 gas is used for fuel. 20 COMMISSIONER WILSON: Before we leave that 21 slide just a question for clarity. When you said you 22 were refused on B133 was it that you were refused or 23 were you told that the AOGCC cannot preapprove to 24 authorize flaring of gas in any case except for an 25 exploration well? AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 56 1 MR. PASCAL: I don't remember the exact words, 2 it goes along the lines like will not allow flaring 3 from the B133 well. It was an email towards the end of 4 Jan which we can produce, yeah. 5 COMMISSIONER CHMIELOWSKI: Mr. Pascal, you're 6 making a case here for why the facility should have 7 remained online during the VRU failure. What specific 8 actions did Glacier take to minimize the volume of gas 9 flared? 10 MR. PASCAL: Very good question, Commissioner. 11 So in order to minimize the amount of gas flaring we 12 looked at all our wells, we ran HYSYS modeling to see 13 how exactly this would reduce the amount of gas and we 14 found out that if we shut in wells the impact which it 15 would have on the amount of gas flared would be very 16 minimum. And like I already previously mentioned when 17 you're looking at the volumes of gas at Badami this is 18 like two -- less than 2 percent of the gas associated 19 with the VRU. It's really, really impossible to make 20 changes which really make impact on this 2 percent gas. 21 COMMISSIONER CHMIELOWSKI: So you mentioned a 22 HYSYS model. Were -- was at anytime a well shut in to 23 see if the gas flared would go down? 24 MR. PASCAL: Yeah, we did. So -- so normally 25 what happens is wells that were routinely shut down in AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 57 1 Badami because we have to do waterline work in order to 2 remove paraffin. The wells are shut in anywhere from a 3 few hours to maybe sometimes even a day or two if 4 there's some pending work on it. And the gas volumes 5 remain consistent, the flared volumes. 6 COMMISSIONER CHMIELOWSKI: So that's a general 7 statement, but I asked specifically what actions did 8 you take. So specifically which well or wells did you 9 shut in to verify that? 10 MR. PASCAL: So like I mentioned it's really 11 hard for us to shut down wells because I cannot 12 increase the H2S limits by shutting down any well 13 because I need the Badami gas too in order to comply 14 with the EPA regulations. 15 COMMISSIONER CHMIELOWSKI: Okay. So you can't 16 shut them in, but you do, you..... 17 MR. PASCAL: I mean, any well can be shut down, 18 but..... 19 COMMISSIONER CHMIELOWSKI: Right. 20 MR. PASCAL: .....the point is I have to run 21 the facility in an agency compliant manner. And the 22 way I can only run it is to make sure that my feedstock 23 for the turbines have the most amount of Badami gas 24 possible. 25 COMMISSIONER CHMIELOWSKI: Okay. Thank you. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 58 1 And a question about the HYSYS modeling. At the time 2 of the informal review in June it was AOGCC's 3 understanding that the HYSYS model had not been run 4 yet, but that that was ran after the informal review, 5 is that correct? 6 MR. PASCAL: Yes. 7 COMMISSIONER CHMIELOWSKI: So how could you 8 have used that information back in October? 9 MR. PASCAL: Because we do know when we shut 10 down the wells what impacts it does to the system. We 11 don't have models to prove it, but we know what exactly 12 it does..... 13 COMMISSIONER CHMIELOWSKI: Okay. So..... 14 MR. PASCAL: .....from experience. 15 COMMISSIONER CHMIELOWSKI: .....you're using 16 general knowledge, but there's not specific..... 17 MR. PASCAL: Yes. Because the..... 18 COMMISSIONER CHMIELOWSKI: .....information you 19 can provide that demonstrates that? 20 MR. PASCAL:.....because the numbers are so 21 small that -- and not impactful that we had to use a 22 HYSYS model to quantify those low numbers. But we have 23 historicals, we do. And the last time we shut down a 24 well like I mentioned, B107, we were threatened with 25 criminal action because we could not keep up with our AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 59 1 Sox limits, SOx and NOx limits. 2 COMMISSIONER WILSON: Are you referring to the 3 EPA? 4 MR. PASCAL: This is the DEC which operates -- 5 Title V which operates on behalf of EPA. 6 All right. Let's go to slide number 6. So 7 what I basically tried to do on slide number 6 is I 8 started off in 2023 because in 2023 we did not have any 9 problems with the VRU. And to Stephen's point in his 10 introductory comments over there, you know, Badami 11 probably flares the least amount of gas on the Slope 12 compared to other North Slope operators. And you guys 13 can go back in records and you can check and all those 14 data is from the AOGCC website, the 10-422 forms pulled 15 through a (indiscernible) database. 16 So if you look in 2023, this is when the VRU is 17 completely operational, Badami -- this is -- this is a 18 normal thing for Badami, in a whole year, you know, 19 Badami for less than one hour flared about 808 (ph) MCF 20 of gas and for greater than one hour about 760 MCF of 21 gas. If you add it it's about 1. -- 1,568 MCF of gas 22 for the whole year. And in comparison if you look at 23 other units, I won't go into all the units, but I'll 24 just take Colville River unit for example, they flared 25 95,303 greater than one hour and 67,362 less than one AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 60 1 hour amounting 162,000 MCF of gas. several orders of 2 magnitude. And I know Mr. Boman was talking about the 3 gas produced versus the gas being flared on a 4 comparative ratio, but end of the day when you look at 5 causation it does not matter, it does not matter what 6 the company's producing, flaring is flaring. If waste 7 is considered to be gas flared, every molecule of gas 8 needs to be counted, not the related molecules of gas 9 with respect to what is being produced. So 162 versus 10 1,568, huge magnitudes of difference. And it goes 11 across the board for every operator. And this is from 12 the data that's submitted. 13 Moving on to 2024, the next slide where we 14 started having problems with the VRU, and this has 15 happened like I said for the first time we operated the 16 Badami unit, our numbers increased a little bit, I 17 agree with that, because we were trying to get this VRU 18 repaired. If you look at it it bumped up to a total 19 flared volume of 33,564 or one hour was only 33,308. 20 And please keep in mind we were flaring because we also 21 -- Badami also had production upsets in which the main 22 compressors go down and on. And in those cases we have 23 to flare gas in order to relieve the system pressure. 24 But in comparison you go back and once again I'll hit 25 Colville River unit, 162,000. That is 4.5 times more AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 61 1 than Badami if you look at it. And same goes across 2 the board, North Star -- Stephen mentioned North Star 3 and North Star flared actually more gas in one month 4 than Badami flared in an entire six months as part of 5 normal operation. 6 COMMISSIONER CHMIELOWSKI: Mr. Pascal, as we go 7 through these comparisons do you have information about 8 -- for each of these and they're cumulative, many 9 events sum -- summarized into these charts, the reasons 10 for the events, the duration of the events or the 11 mitigations that were taken to minimize flaring? 12 MR. PASCAL: Well, I've looked at the comments 13 provided on the 10-422 forms. For example in the 14 Colville River unit most of the events were associated 15 with upsets for the compressors, trying to get the 16 facility back online and everything, but the point 17 we're trying to make is I don't the background among 18 all the details on flaring. If the AOGCC's considering 19 flaring greater than one hour to be a problem it needs 20 to be the same all across the board, you need to be 21 treated the same. And we -- if -- if there was a 22 specific reason why they were doing it and the AOGCC 23 authorized it, I couldn't find anything on the 24 authorization except for the ones associated with Great 25 Bear and FedEx. I don't even think the FedEx one is AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 62 1 still there, but we -- if they initiated a process with 2 the AOGCC and got permission, we also initiated a 3 process with the AOGCC, but we were shut down. The 4 conversations do not go forward, there's no 5 (indiscernible) is happening and we did not get the 6 same level of understanding and discussion which other 7 units got to be able to do the same. 8 COMMISSIONER CHMIELOWSKI: Question about, you 9 know, how facilities should be treated the same. Have 10 you been physically present for example like near GC1 11 during an emergency shut down? 12 MR. PASCAL: No. 13 COMMISSIONER CHMIELOWSKI: Because there's a 14 huge amount of gas flared as the facility slams to a 15 halt basically. Is it your position that that's the 16 same as flaring due to the VRU for over six months? 17 MR. PASCAL: Well, the rules are done in such a 18 way that every molecule of gas which is flared, it 19 doesn't say in the regulations about the related amount 20 of gas flared compared to the gas produced. It talks 21 about just flaring in general and just flaring of 22 natural gas over one hour to be considered to be waste. 23 So I'm just going back to those points. If there was a 24 ruling said that we will consider related amounts of 25 gas produced versus flared then the argument is going AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 63 1 to be completely different. And we have to go into 2 seeing why this flaring's happened and how exactly it 3 supported their operation. 4 Once again it's not my intention to point out 5 and say AOGCC needs to fine other companies, my 6 intention is only to say that we need to be treated 7 fairly because end of the day we need production, we 8 need loyalties and a lot of things happening which we 9 don't get privy to, the Commission gets privy to. So I 10 -- there -- I'm pretty sure there's a valid reason for 11 all this flaring and I may not be privy to that 12 information, but I'm trying to focus on volumes of gas 13 for other fields greater than one hour compared to 14 Badami. That's my only comparison here. 15 COMMISSIONER WILSON: Would you agree on the 16 bar charts that we should compare single events to 17 single events and -- and actions taken to mitigate too 18 in each of those events then? 19 MR. PASCAL: Yes, but if you have a constant 20 history of having a facility go offline for multiple 21 reasons, that is the same thing over and over again, 22 then there has to be some sort of a -- I'm not saying 23 enforcement, but some sort of interference in which it 24 would be like well, guys, you are -- your facility's 25 going offline so many times during a year causing you AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 64 1 guys to flare gas, huge amounts of gas, and something 2 needs to be done about it. In our case our flaring was 3 caused due to the VRU, but in other operators' case it 4 could be that the flaring was caused due to the 5 facility going down due to -- maybe due to alarms or 6 something happening, but there had to be a conversation 7 with them saying hey, enough is enough, you guys need 8 to do something to reduce the amount -- the number of 9 times your unit is going offline and causing this 10 flaring. If it just happened for one month I 11 understand that, but it's been happening for years, 12 it's been happening in numerous amounts and all I'm 13 asking is to be -- to have Badami be treated the same 14 and to understand why it was happening for Badami and 15 kind of give us some grace. 16 COMMISSIONER CHMIELOWSKI: Mr. Pascal, you talk 17 about AOGCC following its regulations. If the AOGCC is 18 only specifically allowed to preapprove flaring for 19 exploration wells, how would you expect AOGCC to 20 preapprove flaring for your facility repair? 21 MR. PASCAL: So like we went back to the 22 regular same work, we talked about a specific component 23 in the gas disposition rules and with regulations that 24 were done to -- I'll go back to the slide once again, 25 that is slide number 5. So it says there, last gas may AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 65 1 be flared as required for facility repairs, which we 2 were doing facility repairs, emergencies, we were in an 3 emergency, and facility operations necessary to prevent 4 injury or loss of ultimate recovery. There is a 5 regulation and we ask for the regulation to be applied 6 for us. 7 COMMISSIONER CHMIELOWSKI: I'm talking about 8 your statement about preapproval. 9 COMMISSIONER WILSON: Yeah, I was going to say 10 that's not preapproving, but it's allowed circumstances 11 on the gas disposition report. 12 MR. PASCAL: Yes, I completely understand. And 13 we did ask for flaring of the B133 well and we firmly 14 believe that B133 well was a new well and we were doing 15 the production testing phase and we were also denied 16 that request. 17 COMMISSIONER CHMIELOWSKI: Are you familiar 18 with the difference between exploration wells and 19 development wells? 20 MR. PASCAL: I am. 21 COMMISSIONER CHMIELOWSKI: Okay. Thank you. 22 MR. PASCAL: And B133A is classified as an 23 exploration well for our submissions to the AOGCC. 24 All right. This is the last slide and I won't 25 go into too much, but what I'm trying to say is this AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 66 1 slide number 10, look at the operators. This slide 2 just basically couples these operators and the scales 3 for Conoco, Hilcorp and CIE are all the same, you can 4 look at it. The upper scale is about 300,000 and the 5 bore (indiscernible) kind of represent 23 to 25 6 flarings. And you can see Badami normally 20, 23 and 7 before doesn't flare, we had problems, we flared, but 8 if you look at the other operators cumulative, you 9 know, they're several magnitudes over and the whole 10 reason why Hilcorp PBU has put on other slide because 11 you can't yet put it to the same scale because the 12 amount of flaring which happens there is insane. I 13 mean, in 2023 if you look at it, you know, it -- it 14 reached 1.27 BCF just for Prudhoe Bay unit. And then 15 in 2024 it was .75 BCF and then in 2025 came down to 16 360. So I don't know what is happening there which 17 required them to flare so much. 18 And this is the same slide in a different way. 19 During the time we were given fines these are the 20 flaring volumes from every single facility there. And 21 you can notice a trend, there's some units flaring 22 month after month regularly. And I don't know what is 23 going on and yet we have been treated differently. And 24 once again the PBU is on the right side, the scale is 25 completely different if you look at it. I can't even AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 67 1 compare myself to PBU. 2 So I'll get off this topic, you know, on us 3 versus others. Once again I want to be extremely clear 4 it's not my intention to ask AOGCC to go after other 5 operators, no. We -- we have a good working 6 relationship, we work as a team, we all want to do good 7 for the state of Alaska. All we're asking is AOGCC 8 treat us fairly. And if you looked at all the flaring 9 which happened over several units during the same time 10 we were fined, Badami was 51,000, we talked about it; 11 Conoco 49,85384 [sic]. You can see the regular units 12 of gas more than Badami. Conoco is just a little bit 13 lower than us and Hilcorp was seven and a half times 14 more than us. So if everyone was treated the same the 15 proportional fines are kind of indicated there and 16 we're the only people that got a NOV and a -- and a 17 fine. So this is slide number 12. 18 So we'll kind of move on to slide number 13. 19 So some mitigation factors. I know Mr. Boman said that 20 AOGCC kind of looks at it in a closed system. They 21 only look at the amount of gas being flared and they 22 don't want gas to be flared. But what I would like to 23 talk in these set of slides is the reasons behind and 24 what would happen if you're not given a little bit of 25 leeway in applying some of the regulations which are AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 68 1 already there for this very purpose, to provide more 2 economic losses and agency related issues to operators. 3 So we talked about the gas pricing, that is our 4 gas pricing, we have completed a (indiscernible) with 5 that. And when the -- when -- when you talk about the 6 state estimate of three and a half there's a wording 7 there saying that is the gas being purchased by the 8 borough or the -- something related to the borough, 9 North Slope Borough being able to use the gas. And 10 like I said Badami's remote, we don't have any access 11 to market. So I think it's unfair to kind of compare 12 what is the price of gas at Badami versus price of gas 13 at Prudhoe. And the best benchmark we have is if you 14 physically stand at the Badami pad and wanted to buy 15 gas you get it from Endicott and that is the price, 40 16 percent lower than what AOGCC used. And through our 17 production accounting we can clearly show that the 18 state received royalties on this gas because all Badami 19 gas is used on lease so we don't have to pay royalties 20 on it and gas from Endicott is -- is -- we pay 21 royalties on it. 22 So technically speaking there is no financial 23 or resource loss of the state of Alaska. In fact you 24 were able to help with ultimate recovery by keeping the 25 facility online and keeping Badami wells online and AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 69 1 Point Thomson wells online. So we were able to support 2 the Nutok pipeline without any issues which carries 3 Point Thomson oil and state royalties and 4 transportation revenue remained uninterrupted when we 5 had these problems. And once again these problems 6 happened once in a decade. 7 We have shown that the state received, these 8 are actual numbers, 476 million in royalty payments 9 during the time we kept Badami running. And keep in 10 mind we also had a really tough time finding investment 11 for B133A. We just got a (indiscernible) online and to 12 just go in and shut off the well, right, especially 13 when we had delays in drilling, would have been really, 14 really bad for Glacier as an organization. And Point 15 Thomson pipeline carried 787 at a 12 and a half percent 16 royalty rate average one price. These are my 17 calculations by the way. At 7165 it is 6.96 million in 18 state royalties which we were able to reliably ensure 19 that money not only went to the state, but to the 20 people of Alaska. So in a sense on this slide what I 21 want to say, CIE's operations not only generated 22 royalties for its own production, but also ensured 23 continuous transport and royalties from Point Thomson 24 oil, amplifying the state's fiscal benefit during the 25 flaring event. So if the state said na, shut down AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 70 1 Badami, we don't want -- we want zero flaring even when 2 you're trying to use the regulation already in place 3 what would have happened is all this thing would have 4 been done and then it would have been really hard to 5 get Badami back online because once you shut Badami 6 down it takes a full turnover to get Badami on. It 7 happened during covid as you guys know. And not to 8 mention issues with shutting down a pipeline in the 9 middle of winter. Point Thomson pipeline would have 10 froze, they have low spots in the pipeline with water, 11 the same thing would have happened to even Badami. And 12 we could have had more agency issues. 13 COMMISSIONER CHMIELOWSKI: Mr. Pascal, thank 14 you for clarifying that the B133 is an exploration 15 well. What I meant to say was that I guess what -- 16 what's the difference is when a well's considered to be 17 in quote, unquote, regular production. 18 MR. PASCAL: That is right. 19 COMMISSIONER CHMIELOWSKI: Thank you. A 20 question about the Point Thomson pipeline. I 21 understand that after they had that freeze up event 22 they made changes to their operations adding more 23 glycol. So I'm having conflicting information that 24 they do or do not need Badami online? 25 MR. PASCAL: They do have low spots in the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 71 1 pipeline, that is where the water accumulates. And -- 2 and that could be a really bad problem and cause a lot 3 of issues with their pipeline. I'm not saying there 4 would be a guaranteed breach in the pipeline, but the 5 probable, especially given the history -- I can go off 6 of facts that happened before and yes, they've done a 7 few things to ensure reliability of the pipeline, but 8 there's always that nagging feeling it could happen 9 again. 10 COMMISSIONER CHMIELOWSKI: Is there any 11 communication from Hilcorp on this matter related to 12 keeping Badami online..... 13 MR. PASCAL: We..... 14 COMMISSIONER CHMIELOWSKI: .....for Point 15 Thomson? 16 MR. PASCAL: .....we closely work with Hilcorp. 17 Hilcorp was aware of what was happening at Badami 18 because we -- we manage the Nutok pipeline, we also 19 have to look at their operating pressures of their 20 pipeline to ensure safe operations. We have 21 (indiscernible) detection systems not only on their 22 pipeline, our pipeline, Endicott pipeline. We are a 23 midstream company transporting oil to pump station one 24 and we all work in close conjunction to communicate 25 operational deficiency and we also are the only people AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 72 1 who can receive thanks for the Point Thomson pipeline. 2 Any sort of (indiscernible) operations, pipeline 3 operations, have to be coordinated within both teams. 4 COMMISSIONER CHMIELOWSKI: Yet is it correct 5 that when the facility went down was January, correct, 6 for two weeks, there was no impact to Point Thomson? 7 MR. PASCAL: That is correct. 8 COMMISSIONER CHMIELOWSKI: Okay. 9 MR. PASCAL: And I'll tell you why. 10 COMMISSIONER WILSON: I was just going to ask, 11 yeah. 12 MR. PASCAL: (Indiscernible - simultaneous 13 speech), yes. 14 COMMISSIONER WILSON: Okay. 15 MR. PASCAL: So actually this is the right 16 slide to kind of talk about it, you know, so let's go 17 into flaring versus emergency diesel generators. Mr. 18 Boman kind of said that we should have gone on diesel 19 generators. And I'll tell you what would have happened 20 if we'd gone on diesel generators. They're not 21 reliable. You know, when you flare you can keep the 22 turbines running at Badami operational, but when you go 23 back to diesel generators -- it's our backup, it's an 24 emergency backup, you use it as a last resort. And the 25 power falls from 9 megawatts to 3 megawatts because the AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 73 1 diesel generators are 1.2 -- 1.5 megawatts each. So we 2 have to run both. When BP used to run the diesel 3 generators they ran only one because they did not have 4 a Nutok pipeline to run at the time, but we have a 5 Nutok pipeline to run. On top of it I also mentioned 6 we were powering the DC2 camp, (indiscernible) people 7 were housed over there. And we could not sacrifice 8 power, it was really, really difficult because then we 9 have to make really urgent decisions on the fly on what 10 modules and what things we need to shut down. And 11 we'll obviously keep the camp operational, but that 12 will impact each of my systems. If you go on diesel 13 generators and we have problem with one of the 14 generators, we will have to shut down the Nutok 15 pipeline ASAP and we won't have enough time to react to 16 evacuate the pipeline. 17 So by using -- by flaring we were able to keep 18 the facility online at full 9 megawatt, it was very 19 reliable, it eliminated life safety issues in the dead 20 of winter, it kept production with Badami and Point 21 Thomson the sustained and we'll talk about flaring 22 versus diesel in terms of normal impacts. And one 23 thing to remember is cost of power. Cost of power is 3 24 cents per kilowatt hour using the turbine and diesel 25 power is 10 times more than that, 35 cents per kilowatt AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 74 1 hour which means that we cannot effectively operate the 2 Nutok pipeline under RCA regulation. We have to apply 3 for emergency authority. 4 And we also don't have enough diesel storage at 5 Badami. When we run out of diesel storage it takes -- 6 it requires a tremendous amount of work to get diesel 7 in the winter because we get all our diesel on a barge. 8 Barging season was closed so we may have to either use 9 tundra travel which takes a lot of -- lot of time to be 10 up for. Normally you get six inches of snow which is 11 the minimum for tundra travel past December. These 12 problems are in October. So no barging, nothing. So 13 how can I get my diesel to Badami. And we use that 14 only to have enough diesel stored and if you have a 15 problem at Badami to safely shut down the Badami 16 facility. So we can't -- cannot run diesel generators 17 forever. And they're not designed to be run forever. 18 And we ran them during covid for a few months, they 19 completely disrupted the diesel jets (ph), you had to 20 do a lot of maintenance on them. And right now Zack 21 leaving a test that we have to completely go because 22 the -- the engines are like completely torn apart right 23 now, running for 17 days -- it was 41 days, I'm sorry, 24 in January when we had our issue with the turbine. So 25 we cannot run those generators again, we have to do a AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 75 1 lot of maintenance on it. 2 And to my point before when BP had to run the 3 emergency generators they never operated the pipeline, 4 Point Thomson was never in production. Point Thomson 5 cam in production after we bought out Savant and we did 6 our best of course to keep the pipeline operational so 7 we could even protect their asset. 8 COMMISSIONER WILSON: I think I missed it as 9 you went by, but for what would you need RCA approval? 10 MR. PASCAL: Because we operated the pipeline, 11 we operated Nutok pipeline, it's a midstream company 12 which is under the Glacier umbrella and every year we 13 submit cost to the RCA and with -- there's an 14 understanding that for per barrel which runs through 15 the 26 months of the pipeline, there's a cost 16 associated with it. And we cannot exceed those cost 17 unless there is some sort of emergency. So if we get 18 into using diesel like I said 10 times more the cost, 19 impacts the pipeline cost and then we'll have to make 20 an emergency tariff. And we did make an emergency 21 tariff when Point Thomson pipeline was down. Point 22 Thomson's pipeline tariff for them ranges from $15 per 23 barrel to transport to Badami to 25. They made a 24 emergency tariff and ours went from I think it was 2.55 25 to north -- north of -- north of $4, $5, but that AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 76 1 happened before and it's not sustainable. At some 2 point in time, you know, we have to make an economic 3 decision, not a regular decision to kind of shut down 4 operation. 5 COMMISSIONER WILSON: Okay. Thank you for the 6 clarification. 7 MR. PASCAL: Let me go quickly to the next 8 slide. I won't spend too much time on this. I have a 9 background in chemical engineering and this is like 10 very basic -- it's talk about reactions, it's talking 11 about what is good for the moment, flaring versus 12 burning diesel. And everybody in this room is 13 engineers and people working in compliance know that 14 burning diesel is bad for the environment versus 15 burning natural gas. 16 I want to focus a little bit on the fuel 17 emission. Fuel emissions is really big right now. A 18 lot of companies are going after energy policy, 19 specifically insurance companies, they want you to 20 decrease your emission and Glacier does a lot of future 21 damage and monitoring, already these damages are almost 22 negligible and plan for a normal operation. So if we 23 ran on diesel generators we would have produced a lot 24 of (indiscernible), a lot of NOx, not of SOx, compared 25 to natural gas and also increase emissions in terms of AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 77 1 CO2. And I know this for a fact because I lived in 2 Fairbanks, so did Mr. Wade, and in Fairbanks every 3 winter, the air quality in Fairbanks has been 4 classified as the worst in America by the American Lung 5 Association. Why, because people are burning diesel 6 and also biomass to supplement diesel. So it was a 7 huge breath of fresh air for me when I started working 8 in Anchorage because you all use natural gas for 9 heating. So if I was given a choice I would always use 10 natural gas as my first option. 11 So back to the next slide. You know, let's say 12 we were faced with an option saying that, you know, 13 let's say flaring was not even an option for us and we 14 couldn't keep our generators running, what would be the 15 two options for Badami. One is to run emergency diesel 16 generators, the second thing is you shut down the 17 facility. And like I said shutting down the facility 18 is not a thing you do in a week, it takes weeks of 19 planning, sometimes months to properly secure it. When 20 we do it we do it in the summer, we don't do it in the 21 winter. So if you ran Badami generators, like I said 22 power reduces from 9 megawatts to 3 megawatts, Badami's 23 production is gone out of the window which means the 4 24 and a half million royalty payments are going to begin 25 with. So and you're doing this to save about 50,000 AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 78 1 MCF of gas and it also takes ultimate recovery from 2 Badami. And the Nutok pipeline will be on notice to be 3 shut down at any given point of time because you don't 4 have any backup to the backup emergency generators. 5 Running on backup diesel generators for lack of better 6 ways to kind of explain it is like your car has a flat 7 tire, you put on your -- you put on your spare, you 8 can't run at full speed, you can't run extended periods 9 of time. This is not only having a flat, but having an 10 engine failure so you're literally trailering -- 11 trailering your car from point A to point B with a 12 disaster waiting to happen because if one of the 13 generators went of, we were running two generators, 14 consuming about 120 gallons of diesel fuel every hour 15 and if one of the generators went off we would be in a 16 crisis which means that we'll have to evacuate people 17 and we won't have enough time to shut down Badami or 18 even a facility pipeline. 19 So in other sense option A ends up being a 20 precursor to option B. If we had a situation in which 21 we had to shut down Badami and go on diesel generators 22 we are simultaneously making plans to shut down Badami 23 and evacuate people in order to make sure that we can 24 fully protect the facility. And to the Commissioner's 25 point can you run the Nutok pipeline on diesel AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 79 1 generators, absolutely you can, but there's no 2 reliability on it. And the whole reason was because we 3 had a timeline in sight which said that we are working 4 on control system upgrades for the turbine. And we 5 knew when the turbine was going to come offline with a 6 high degree of certainty so we took that risk because 7 we didn't want to shut down things and have people 8 scrambling. So we did our best and we were able to 9 kind of do that. And even that 21 days of shut down 10 caused a lot of issues with generators. So just want 11 to be transparent on that. 12 So moving forward to slide number 17, you know, 13 we talked about -- you know, we spent over $500,000 on 14 it and some of the cost -- you can provide the invoices 15 and everything, going back and making plans and trying 16 to get the fastest solution for us to get the existing 17 VRU online because putting a new VRU or vacuum pump 18 system is not going to happen in a single week, it 19 takes months and months of planning, engineering, you 20 have to shut down the facility, make changes to 21 pipeline, do hazmat analysis, foreign gas systems, 22 there's a lot of work in involved in it. So with our 23 current team, with our best possible solution was to 24 get the VRU online which is what we did. So I'm not 25 saying that CIE will stop here, they're in fact more AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 80 1 kind of a hold campaign to see what we can do 2 additionally to make sure that we can prevent things 3 like this in the future. 4 And so moving on to the next slide which is 5 slide number 18 we'll talk about some of the corrective 6 actions we're doing. And keep in mind that BP 7 overdesigned stuff, they did things way beyond what was 8 required according to regulations when they initially 9 came in. They made a conscious decision not to have a 10 second VRU and they did not need a second VRU until now 11 because we were able to tackle every single problem 12 within the confines of CIE's expertise there. And this 13 is a one time thing and unfortunately it happened, 14 we've completed the corrective actions and what we're 15 doing for the future is yes, we repaired it, going 16 forward we talked about eductor system, we use our best 17 possible engineering decision at the time to safely 18 collect the VRU gas. I did not have anything on site 19 or something designed from an engineering point of 20 view, could not use the eductor system. So I cannot 21 just throw in a vacuum pump there because you don't 22 have a vacuum pump that was designed for that place. 23 So we're going to work on designing a vacuum pump and 24 like the Commissioner stated that will definitely 25 reduce the amount of flared gas, but it's not going to AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 81 1 happen today, we have to do a lot of engineering. So 2 we have embarked on that mission. And we're also 3 looking at getting a second VRU. It may not make 4 economic sense because it could probably take 8 or $10 5 million dollars to get a whole new VRU system 6 retrofitted to Badami. And given the reserves 7 associated with Badami, the PDP right now, operating 8 expenses, oil prices which have fallen 15 percent since 9 the start of 2025, it may not make economic sense or 10 engineering sense for that matter to do that. So yet 11 to come, I'm not saying they're not going to do it, 12 they're investigating it and it'll go on until QR 2026 13 before we get in more information. 14 We are working on the critical stress program, 15 we have good critical stress because if you look at 16 history of 2023 and before we have been running okay 17 with one VRU unit. If you look at our amount of 18 flaring below one hour and over one hour they have been 19 very reasonable, very reasonable compared to other 20 operators, almost minimis. So if we were able to keep 21 one VRU functioning because we had a great PM program 22 and a great critical stress program, but we've gone 23 back to Siemens and we are working with them and we 24 are seeing what else we can do to improve that 25 reliability, what else critical stress can we get to AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 82 1 make sure that we can adhere to any sort of issues with 2 the VRU before we find a permanent solution over there. 3 Some of our engineers have gone one step forward and 4 they're going to evaluate all the instrumentation 5 systems on the VRU and make sure that none of the 6 instruments will take the VRU offline for any reason. 7 So we're going to -- we have the campaign schedule for 8 2026, it's a N300 module campaign. 9 So this is what CIE's going to do irrespective 10 of whether or not a fine is going to be put or not to 11 us because we are responsible and this is what we'll go 12 through. 13 COMMISSIONER CHMIELOWSKI: Mr. Pascal, on slide 14 -- I'm not sure which it is, the one with the financial 15 impact. Yes, that one. 16 MR. PASCAL: It's 17, please. 17 COMMISSIONER CHMIELOWSKI: Yeah. Thank you. 18 So I know you gave this example of a -- you know, some 19 other operator who has a compressor that keeps failing 20 and maybe something should be done about that. You 21 know, it seems to me when I look at this that maybe the 22 VRU keep failing. So how are these repairs adequate to 23 fix the problem? 24 MR. PASCAL: Well, the VRU has not failed since 25 we got everything online. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 83 1 COMMISSIONER CHMIELOWSKI: When? 2 MR. PASCAL: That was -- so that was August 3 21st, 2025. 4 COMMISSIONER CHMIELOWSKI: Okay. 5 MR. PASCAL: So we got the VRU placed in March 6 like I said, but then since we rushed this project we 7 had a failure after 37 days of having the VRU online. 8 So we went back, redid the engineering and got back 9 with a different solution for it, the HVOF. And now 10 the VRU has been running smoothly. And keep in mind we 11 are running as we are -- I've been running as we are 12 for 10 years and not having repeated problems with the 13 VRU, if not AOGCC's approached us and -- and -- and 14 given us an enforcement action, saying hey, do 15 something with the VRU. Because we're able to handle 16 all the VRU problems within an hour if something 17 happened, we also have a good PM schedule. 18 So this was something which was way out of our control, 19 it was a very big problem which happens with VRU. 20 So I'll jump to slide number 19 which are the 21 key takeaways. Before key takeaways, you know, we kind 22 of mentioned order number 194 and something about 23 (indiscernible). I want to kind of do this pretty 24 quick. So in order 194 the Commission granted Pantheon 25 permission to flare for nine months in three month AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 84 1 increments with -- with the (indiscernible). So they 2 also authorized them to flare between 150 to 400 MCF a 3 day where gas could not be used, sold or reinjected due 4 to limited infrastructure. So I'll get to -- if you 5 look at the AOGCC update, it's 97 days it ran, 146,000 6 MCF of gas flared, almost three times the amount of 7 Badami's gas flared. And they got it because they do 8 not have a compression system, it was a new well. So I 9 want to make it clear, but I'm just saying in our case 10 we did not have a VRU compressor operational and we 11 asked that the AOGCC apply the specific guideline used 12 professionally in reverse in our case. And also, you 13 know, FedEx has been flaring according to their order 14 since December, 2024. So far it has crossed over 15 101,000 MCF. And once again at some point of time, you 16 know, you -- you could use -- you could use well 17 testing, but, you know, it has been a very long time. 18 In our case all we're asking is to get a little bit of 19 grace while we are performing repairs on AOGCC. 20 Nothing against Great Bear and nothing against FedEx, 21 they've been great people to work with. And just want 22 to kind of talk about the guys' (indiscernible). 23 COMMISSIONER WILSON: Yeah, and for clarity I 24 -- I would state that in the Great Bear case that is 25 something where we are authorized to preapprove. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 85 1 MR. PASCAL: And there are economic reasons to 2 cite it and we had strong economic reasons, we had what 3 is happening in our case. 4 Key takeaways. I won't go into much detail on 5 this point. Safety events, not wasteful in our 6 opinion. We are asking for 20 ACC 235(d)(5) 7 allowances. It clearly states we are hitting all those 8 requirements in that. We are asking to use the 9 regulation it says in the gas disposition rules, not. 10 Not -- we're not asking the AOGCC to create a new 11 regulation. We provided agency and operational issues, 12 that was always Glacier's intention. We wanted to do 13 everything in the best practice possible to prevent any 14 agency issues. We prevented a Badami facility shut 15 down and possibly even a Point Thomson facility shut 16 down. We kept the royalty payments running to the 17 state. Once again on the gas purchases royalty was 18 paid so no loss to the state on that. We did not burn 19 diesel during the six months, prevented pollution, 20 impacts from diesel consumption, no tars increases the 21 pipeline, we're able to responsibly run the Nutok 22 pipeline. We already spent way over the fine amount 23 just on repairs and more to come on upgrades. We 24 talked all the time with the AOGCC and we were able to 25 prevent serious damage to the new B133 well. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 86 1 Unfortunately when we shut it down for 21 days we did 2 see PI changes to that well, but for the majority of 3 time during the time that we were -- we were able to 4 keep that well running. So which means the investments 5 we made from the extended drilling campaign we had and 6 also getting new investors in we were able to prevent 7 huge conflict of interest over the..... 8 So moving on to the final two slides, I'll 9 repeat the ask which Stephen made. Respectfully 10 requesting to drop the notice of violation and allow us 11 to utilize the regulation made for this very situation 12 and the gas disposition rules. We also respectfully 13 request you eliminate the 357,000 penalty based on the 14 fact that, you know, we invested more than the penalty 15 amount, the gas was purchased and royalty paid and also 16 there have been price variation of gas on the Badami 17 field. And also recognition of transparency, open 18 communication, corrective actions, future safeguards 19 and also to be treated fairly as other North Slope 20 operators. 21 I would pause here and see how do we want to 22 proceed because we do want to talk about Mr. Wade's 23 presentation. So if you guys want to take a break and 24 have us present and do some argument against that or do 25 it right now. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 87 1 COMMISSIONER WILSON: I would say they proceed. 2 MR. PASCAL: Okay. Do you think we can pull up 3 his presentation again? 4 COMMISSIONER WILSON: Before we go to that I 5 have a question. 6 MR. PASCAL: Sure. 7 COMMISSIONER WILSON: If, you know, incremental 8 to order 221 there's information on the Endicott gas 9 and its, you know, component in what was being flared 10 and everything. So if we set the Endicott gas aside, 11 knowing that the two mix and everything, but you are 12 reinjecting gas into the field, et cetera, would you be 13 able to show from a material balance standpoint that 14 the -- the native gas flared is de minimis? 15 MR. PASCAL: So what I can show you is -- I can 16 send a note and I think I may have some status stats 17 right here, I can tell you what the total gas is 18 circulating in the system. So it's about 15 million 19 which is circulating a single day in Badami. I'll give 20 the right numbers after I work with my engineers. Out 21 of the 15 million cubic feet of gas circulating in the 22 system, the gas going to the VRU is less than 2 23 percent, it's about 200 MCF. We flared on average 350 24 MCF out of that 15 million. We utilized around -- 25 somewhere around 1.6 to 1.8 million cubic feet of gas AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 88 1 for fuel consumption. About 11 million cubic feet of 2 gas are used for gas lift, this gas circulates in the 3 system. We have really minimum injection and retrieval 4 of gas because Badami gas like I said is all being used 5 for power generation. And we are only buying extra gas 6 we need. So there's no excess gas for us to -- to be 7 utilized. 8 The only reason a portion of this gas was 9 flared when the VRU was down was because the VRU 10 collects really low pressure gas from the gas pool 11 primary, secondary. When the VRU is down there's no 12 way to collect gas which is less than 75 PSI. It 13 ranges -- because the VRU takes the gas from almost at 14 (indiscernible) which is 14 PSI, not absolute, but 15 about 14 PSI, jumps to about 27 PSI and then kind of 16 goes on to jump to 75 PSI. Then when the VRU has 17 enough. the way it pressurizes that gas, you're able to 18 put it in the high compressor system and be able to 19 utilize this gas. So the problem we were having is 20 when the VRU went down we couldn't take this gas and 21 increase the pressure of this gas to be saved, the only 22 option was to safely flare this gas. 23 So the content was 2 percent, then 1.6 to 1.8 24 and also the produced gas from Badami is roughly around 25 the same order of magnitude, 1.5 to 1.7 depending upon AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 89 1 which wells are running and what is happening. 2 COMMISSIONER WILSON: Okay. Thank you. 3 MR. PASCAL: So once again we did not get 4 enough time to fully review the contents of this 5 presentation so we will come back with a formal 6 response in writing very soon. 7 So going to the first slide, you know, Mr. Wade 8 is in charge of gas disposition. So it will be really 9 interesting to kind of know how other fields and 10 operators are being handled for flaring over one hour. 11 I'm not hoping to get that answer right now, but you -- 12 I mean, I should kind of get an understanding to see 13 how it applies to Badami, are we doing something 14 different, are we on the same page, you know, what are 15 they doing which is reasonable to the AOGCC that we are 16 not able to do. And if they're applying and getting 17 certain provisions, you know, because we also applied, 18 are we doing it the wrong way, just need a little bit 19 more help on that matter. 20 No comments on this slide, it's slide number 3 21 and we are slide number 4. And in slide number 4 they 22 show some flaring volumes here and like I've shown in 23 my presentation before, prior to 2023 you would not see 24 these volumes. So we're not saying these numbers are 25 wrong, we're saying it was caused by having VRU issues. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 90 1 We worked on getting the VRU back online as quick as we 2 can, we ran into secondary issues, but ever since we 3 got the VRU restored we're not having any problems, you 4 can see it in our recent flaring reports. I also want 5 to bring the fact that, you know, some of the months 6 being shown here fall outside that 90 day window. So 7 it's up to the Commission to go back and kind of look 8 at that. And this 51,000 also included a lot more 9 things, flaring less than one hour and it did not 10 subtract the days in which the VRU was actually online 11 because like I said you're looking on a month to month 12 basis. So if you took 180 days and the VRU was running 13 for 150 days, so 180 minus 150 days, that is not 14 associated with the VRU so that should be treated a 15 different way. And also the facility upsets, gas 16 flared for operational issues, planned maintenance and 17 things like that and that should not be included in the 18 51,000 in my opinion. 19 So this is some of the, you know, communication 20 between CIE and AOGCC. I don't think AOGCC contends 21 the fact that CIE did not communicate with them in a 22 timely manner. I'm not going to go into much more 23 detail, but it kind of talks about what exactly 24 sequence of events. And I feel like every operator 25 sitting in this room can sympathize with what we went AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 91 1 through. For example when Point Thomson came online 2 they were having problems with the compressors, even 3 though they're required by the state to flow 10,000 4 barrels of oil put in the pipeline, they couldn't do it 5 for years because it was a high pressure system, the 6 compressors were specially designed and they're having 7 numerous problems with it and it took them a lot of 8 time to get back to the production and -- and ensure 9 reliability. So we sympathize with their problems and 10 other operators sitting here can look at us and 11 sympathize with our problems too knowing that it -- 12 it's a tough place to run compressors and also get 13 service, parts and support for it. 14 So one of the comments which Mr. Wade made was, 15 you know, well, the wells were offline in Jan, Feb, yet 16 the Point Thomson pipeline wasn't affect -- wasn't 17 affected. That is correct because we went out of our 18 way to make sure the Point Thomson pipeline was 19 operational because the Nutok pipeline was operational. 20 If we do not have Point Thomson's production there was 21 no reason for me to run the Nutok pipeline. I mean, 22 why would I run the Nutok pipeline if I don't have 23 Badami's production going to it. You know, but we did 24 our best, we ran the pipeline. And the reason why we 25 were able to run the pipeline is because we had a clear AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 92 1 date on when our turbine was going to be online. Not 2 only the one we were working on control system 3 upgrades, but Solar Turbines were able to put us -- 4 they were very apologetic, they knew that this problem 5 with our main compressor which added catastrophic 6 failure. Once again in my 10 plus years with Glacier 7 I've never seen any issues with turbines like this, 8 both from Cook Inlet side and the North Slope side. 9 Turbines they just time out, they don't fail like this. 10 So when something happened they put us to the front of 11 the line and we actually got the other turbine replaced 12 within record time. So we knew when the end was in 13 sight and that is why we took a risk in running the 14 Nutok pipeline. 15 So to make a statement saying that yes, you can 16 run your Nutok pipeline on the diesel generators is not 17 an entirely true statement, there's a lot of gray area 18 in it, it's like a ticking time bomb, you know, and we 19 cannot do that not only from operational reasons, but 20 also from what we talked about cost reasons. 21 Then they said shutting in producing wells was 22 not an option. And we looked at shutting producing 23 wells and we have done that before and when we had 24 wells offline we run into other compliance issues. You 25 know, Mr. Wade is -- he said he was an expert in these AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 93 1 matters, but there's more to just knowing how wells are 2 going to operate because when you look at a facility 3 the other permits associated with it, the other nuances 4 from the facility and you may not be aware of all the 5 intricacies involved with the Badami unit. So you 6 probably did not realize that if I shut down wells, one 7 is it does -- it makes a very negligible difference in 8 the amount of volume flared, we also modeled and gave 9 those results. And also it puts Glacier in additional 10 compliance issues. You can only run so much diesel in 11 a year, only so much PPM of H2S we can exceed. 12 So we just cannot shut down wells and like I 13 said our gas for running the turbines is about 1.6 to 14 1.8 and the Badami produced gas is almost the same 15 amount. So if I start cutting on wells from Badami, I 16 have to buy gas of poor quality that's 70 percent 17 methane, 20 percent CO2, H2O is at 450 parts per 18 million from Endicott to supplement it. So my 19 feedstock going to the turbine becomes worse and worse 20 and then I run into additional compliance issues. So 21 that point was not taken into consideration because -- 22 there's no fault at him because he doesn't know the 23 intricacies of other permits. 24 And going over to the next slide, once again 25 trying to make a point saying that hey, you guys had a AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 94 1 power failure and still, you know, you guys were able 2 to run the Point Thomson pipeline. We already hit it, 3 I'm not going to go back again. And he's also showing 4 gas volumes having issues after that. And we talked 5 about, you know, the VRU having a problem for 37 days, 6 we resolve it, it's fixed, and we are back to what we 7 were in 2023. So I think we need to take the full 8 picture into consideration in this case. 9 Once again more status stats on this, on Badami 10 production. And he's talking about the VRU compressor 11 rebuild, but 37 days after that we had a failure and we 12 went back and had to fix it. So gas volumes flared was 13 a little bit higher than normal operations. So once 14 you guys start seeing newer data kind of come in you 15 guys will see that we have gone back to where we were 16 before. This is slide number 7 by the way. 17 And this is more communication over here. I 18 mean, we tried to communicate in several different ways 19 and talk about -- even in an informal hearing we talked 20 about our permits with the DEC and the EPA, bought some 21 Endicott gas, we already transferred and clear about 22 that, we also submitted written responses to the -- our 23 informal hearing and then all this data. And on 24 January 29th, you know, we literally asked permission 25 to flare an exploration well which was recently brought AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 95 1 online in the same time frame which other companies 2 like Great Bear and FedEx enjoyed or took advantage of 3 and yet for B133 we were denied. We didn't ask to 4 flare from any other well, it was just B133, it was not 5 B107 even though B107 is an exploration well, it was 6 B133 because B133 was a well which was recently brought 7 online. We were -- it free flowed from September to 8 December and in December we started the process of gas 9 lift operation. So we start gas lift operation, we 10 start from the first mandril and work our way down and 11 every time we do that we have a balance gas see the 12 well performance. So we were actively going through 13 gas lift manipulation, they're trying to get to the 14 bottom most mandril. Yet we were not allowed to flare 15 from this well. And the whole reason we asked to flare 16 from this well is because it compounds the issues, the 17 turbines went down and now we have zero source of good 18 quality gas at Badami. And we have zero revenue coming 19 from Badami and we had to offset in some way, it was 35 20 cent per kilowatt hour being run by diesel. This is 21 one of our solutions to get the biggest well online, 22 keep some revenue flowing so we can support the Nutok 23 pipeline and also be able to get some good quality gas 24 in the Badami system. 25 So I don't have any comments on the rest of AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 96 1 this slide, it's just correspondence which we have with 2 the AOGCC. It kind of shows that we were fully engaged 3 with the AOGCC. 4 This is the same thing as before, just showing 5 volume, oil produced and everything. And we kept our 6 wells online, no question about that except for that 21 7 days in which we couldn't run the turbine. You can't 8 run the turbines, you can't run our wells. We can't 9 run our wells on diesel generators. 10 Once again more information on what is kind of 11 happening and unfortunately on slide 10 all these 12 volumes are associated with the VRU failure and nothing 13 else. Once (indiscernible) issue and some of these 14 volumes also include volumes which were preauthorized 15 (indiscernible) regulations for safety purposes. 16 Then you go back to some findings on slide 17 number 11 that said you have to use good oil field 18 engineering practices. And I'll tell you like if I 19 brought any other engineer from any other company in 20 any capacity in Badami at the time in which our VRU 21 went online and told him or her like look at the whole 22 Badami system and use your best engineering practices 23 to make sure that we flare the less and also safely run 24 the facility, they would have done the same thing. You 25 can't pull a vacuum pump (indiscernible) out of thin AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 97 1 air. The only thing we had was use efficiently. We 2 looked at taking wells down, we looked at the 3 compliance issues which we can run into and what I can 4 say at this point of time is that we did the best we 5 could applying not only engineering practices, also 6 (indiscernible) and also compliance issues to minimize 7 the volume of gas released, burned or permitted to 8 escape in the air. 9 And we talked about the fair market value of 10 gas. Once again if you look at it it had reference to 11 North Slope Borough, we don't have access to the North 12 Slope Borough through gas pipeline. We only have 13 access to the Endicott facility with a gas pipeline. 14 So our gas cannot be transferred back and forth from 15 Prudhoe Bay. So the value of gas anywhere else being 16 applied to Badami on site is it's on two different 17 levels. So and we've been charged 40 percent more than 18 what the fair value of gas is at Badami. 19 And then these are some more dates -- I mean, 20 these are faxes, there's nothing to contest about these 21 things. 22 And back to slide number 13 on findings. The 23 AOGCC is calling this as waste and we're not calling 24 this as waste. It was a response in order to keep the 25 facility, pipeline and personnel safe. And we did AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 98 1 everything we could to minimize this waste and 2 especially given the fact that other North Slope 3 operators are flaring several orders of magnitude from 4 a long, long time ago to the time we were flaring and 5 continue to flare and is not being considered waste is 6 something we need to consider when the statement is 7 being made by AOGCC. 8 So point number 2 we kind of talked about, you 9 know, our turbines going down. I mean we communicated 10 with the AOGCC when it happened, we asked to get B133 11 well online, we also talked about an informal meeting, 12 emails were sent about it. So I don't know how we 13 could have made it even more clear that it's separate 14 issues (indiscernible) up. And we did everything to 15 minimize the volume of gas flared. We reported the 16 volumes on form 10-422 according to regulations. So, I 17 mean, if things were not clear we would come back a 18 second, third, fourth time and explain things. But I 19 think we communicated enough to kind of talk to them 20 about the issue we're raising with the VRU and the 21 component issues we're facing with the turbine for 22 those 21 days. I think we clearly communicated on 23 that. 24 COMMISSIONER WILSON: Mr. Pascal, excuse me, at 25 what point in the timeline did you request to have B133 AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 99 1 remain online? 2 MR. PASCAL: As soon as it went offline, as the 3 turbines went offline sometime at the end of January. 4 I think it was January 29th if memory serves. 5 Next in findings, order 221. So the order 221 6 was issued on August 14th and I think this order was 7 associated with FedEx, am I right, 221? Oh, this is 8 actually in person, I'm sorry. I kind of got confused. 9 UNIDENTIFIED VOICE: (Indiscernible - away from 10 microphone). 11 MR. PASCAL: Well, thank you for the 12 clarification because before the other order was issued 13 I think the first notice of enforcement was in May. So 14 -- so a statement was made by the AOGCC saying that a 15 flaring due to turbine outages and reliance on diesel 16 generators is misleading, but like I told about diesel 17 generators are supposed to be a backup and we don't 18 have any backup to the backup. They're supposed to be 19 used in an emergency. And when we have an issue which 20 we know is going to take a bit of time to fix, having 21 reliable diesel generators is not an option because if 22 I ran diesel generators starting in October, the clock 23 would have started and maybe by November, December in 24 the dead of winter you would have had a generator 25 failure and we had to shut down Badami and Point AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 100 1 Thomson. And also when we had the diesel generators in 2 place we started working on emergency measures in case 3 we lose the diesel generators in order to safely shut 4 down Badami. So I think we were kind of clear about 5 it, diesel versus flaring and why we are trying to use 6 our -- our turbines in this case. 7 Okay. Then back to order number 194. AOGCC's 8 authorized in this case, I think it was Great Bear or 9 Pantheon, they were able to flare because they did not 10 have any sort of production equipment and was given 11 over nine months and was not only given for the sake of 12 well testing, it was also given for economic reasons as 13 far as I understand to give Pantheon a chance to kind 14 of understand if they can produce enough quantities to 15 make it economically justifiable to put a production 16 plant. So we have kind of crossed from the realm of 17 testing a well which is preapproved by the AOGCC as per 18 regulations to now testing for economic reasons which 19 is not covered on the regulations. So if the AOGCC 20 wanted to give permission to a specific company in 21 order to evaluate for economic reasons, I feel like 22 given our situation and the amount of agency issues we 23 could have had, the AOGCC could have given us a little 24 bit more leniency in flaring gas while we were working 25 on getting the VRU. I'm not asking for something AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 101 1 indefinite, while we were working getting the VRU 2 operational because it did impact economically, it did 3 impact the region economically. So 221 order -- I'm 4 sorry, 194 order is not pertaining to only well testing 5 reasons, it went beyond that from reading -- from my 6 understanding of order 194. 7 Then once again number 6. We are kind of going 8 into a black and white statement saying that hey, when 9 you guys flare we don't care about what happens, you 10 should stop flaring completely. But the gray reason -- 11 the area is if you stop flaring completely there's so 12 many things that are going to happen that will impact 13 the state in different ways. We can't just put on our 14 blinders and look at the issue in a very narrow 15 approach, we have to go beyond this and see how is it 16 affecting other companies, how is it affecting revenue 17 from the state. If we shut down Badami for example, it 18 would have been really hard for us to come back online 19 in this current dollar prices because it takes a lot of 20 investment and money to get Badami back and running. 21 We would have been still shut in waiting for better oil 22 price (indiscernible). And when we make things like 23 this we take the agency competent into consideration 24 and also, you know, also taking into consideration 25 economic impacts not only to us, but also to the state AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 102 1 and other operators too. So for a statement to be made 2 that is very black and white and it does not consider 3 things beyond that. That is my only comment on that. 4 And once again we cannot rely upon keeping the 5 pipeline operating only on diesel generators. I want 6 to be extremely clear on that. 7 So point number 16 or slide number 16, point 8 number 7. So once again we don't have an explored pot 9 so it's claiming that any sort of unrealized royalties 10 is being -- is immaterial, but in this case it was 11 material because the state did get royalties on the gas 12 we flared. So I think the comment is not reflective of 13 the intention. We want to make sure that the state 14 doesn't have any loss in anyway so we'll do everything 15 possible, whether it's paying royalties, production 16 taxes, property taxes, insurance -- not insurance, 17 property taxes or anything else, we'll make every 18 effort to make sure that the state is also benefiting 19 apart from Glacier. 20 So last number is gas valuation to determine 21 value of gas is overstated and once again it states -- 22 I'm not disagreeing that the penalty should be twice 23 the amount of fair market value, we are kind of 24 questioning the fair market value on this. And at the 25 prevailing value of North Slope gas and it also talks AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 103 1 about to publicly regulated utilities in the North 2 Slope area. We don't have an avenue to send our gas to 3 public regulated utilities at Badami. So having the 4 same benchmark being applied to Badami I think is not 5 correct and our benchmark -- the realistic benchmark is 6 gas prices coming from either Point Thomson or from 7 Endicott. 8 And this is slide number 17 finally. They're 9 talking about the eductor system and we talked a little 10 bit about the eductor system, but in the avenue and in 11 the situation we were presented it was the best 12 possible way for CIE to safely collect all the gas and 13 flare it. We did not have anything apart from the 14 eductor system. It's not that we designed the eductor 15 system, it was done after careful design, engineering 16 and consideration by BP and we kept that system alive 17 all this time. So one of the things we're doing which 18 we talked in our future commitments is we're going to 19 be looking at the eductor system and see if we can 20 completely replace that with a vacuum pump. And it's 21 not going to happen in days, it's going to take some 22 time. 23 So I think this brings us to the end of the 24 presentation and like I said we would like to have some 25 more time to review this and provide written comments AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 104 1 to it. And one thing I did not notice in this 2 presentation is when we gave our presentation on Monday 3 we reference a lot of North Slope operators and there 4 was no justification given as to why AOGCC was allowing 5 other North Slope operators to flare huge amounts of 6 gas, several orders of magnitude, compared to CIE. And 7 if there's a reason those reasons were not given to us 8 and we are not given even guidance or avenues to kind 9 of explore to see what reasons would fall in our 10 specific circumstance in order to help us for a few 11 months. So those things were not covered. 12 So that's all I had for now and we are more 13 than happy to take questions. And thank you, 14 Commissioners, for your time. And I know it kind of 15 went over a long time, but in closing we remain 16 committed to safe, reliable and transparent operation. 17 Ongoing cooperation with AOGCC, a long term investment, 18 that both protect production and Alaska's natural 19 resources. End of the day all we want to do is we want 20 to safely operate assets, we want to make money not 21 only for us, but for the state of Alaska and we want to 22 be treated the same as other operators. 23 Thank you. Thank you for this opportunity. 24 COMMISSIONER WILSON: I have no additional 25 questions at this time. Commissioner Chmielowski. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 105 1 COMMISSIONER CHMIELOWSKI: No, I don't. 2 COMMISSIONER WILSON: What we will do at this 3 point is take a 30 minute break, confer with Staff and 4 then we return there may be additional questions and 5 there will be an opportunity for anyone from the public 6 that wishes to testify to have an opportunity at that 7 time. 8 COMMISSIONER CHMIELOWSKI: So we'll reconvene 9 at 1:00 o'clock sharp you say? 10 COMMISSIONER WILSON: Yeah, 1:00 is fine. 1:00 11 sharp. 12 COMMISSIONER CHMIELOWSKI: Thank you. 13 (Off record) 14 (On record) 15 COMMISSIONER WILSON: So I just have one 16 additional question from us, it's maybe multifaceted, 17 but trying to get a better handle on how the purchased 18 gas is distributed in the system. And so since the 19 record is remaining open and we'll have to determine 20 how long we want to leave the record open, but with the 21 record open if you could provide for us a diagram of 22 the system, including the subsurface, that shows how 23 the gas is distributed in the system, if any purchased 24 gas in the mix is being reinjected into the reservoir 25 and then the volumes associated with each part of that AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 106 1 system so essentially is any of the purchased gas 2 taking the place of native gas in the process. And the 3 volumes of each that are being flared. 4 COMMISSIONER CHMIELOWSKI: We may want to touch 5 base after the hearing with Staff to make sure we -- 6 we're communicating it clearly, but what we're talking 7 about is like first all question any gas going into the 8 reservoir and staying in the reservoir, not like gas 9 lift. And then I have -- I'm just going to hold this 10 up, it's not in the record, but it's like a little 11 process flow diagram, you know, that shows where gas 12 goes. And at the end it shows Endicott fuel gas mixing 13 with Badami fuel gas and it goes -- and then I think it 14 comes back over here as just fuel gas. Anyway I would 15 like to see when you mix Badami fuel gas with Endicott 16 fuel gas you have some mixture, where does that mixture 17 go and what part of it goes to the flare and what part 18 of it goes to the eductor. Does that make sense? 19 MR. RATCLIFF: It does. 20 COMMISSIONER CHMIELOWSKI: And we can talk 21 about that later or we can move past, yes. 22 MR. RATCLIFF: No, we understand the process. 23 Thank you. 24 COMMISSIONER CHMIELOWSKI: Yes. 25 COMMISSIONER WILSON: And then there were a AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 107 1 number of slides with the bar chart comparisons to 2 other operators and you did qualify that with that was 3 the information that you had available. I would say 4 not maybe entirely fair to the other operators given 5 that everything, all the gas over that time period was 6 lumped into one bar on the chart as one event basically 7 and would be compared to Badami as one event. But you 8 can on the 10-422s, the PDFs that are available, that 9 does have the incremental information and if it was an 10 approved issue of safety, conservation of resource, et 11 cetera and how many events would go into each of those 12 volumes on the bar chart. Not anything to address 13 here, but it is incremental information that you can 14 get from the PDF version of the 422s available. 15 MR. RATCLIFF: Thank you. 16 COMMISSIONER CHMIELOWSKI: And I forgot to add, 17 you know, as part of that request on sort of the gas 18 flow and if you could provide, you know, on a monthly 19 basis, you know, how much gas was purchased from 20 Endicott and how much gas was reservoir gas and then, 21 you know, your flare volume would be great on a monthly 22 basis. And you could do maybe starting January, 2024 23 until your latest volumes would be great. so before and 24 after the VRU failure. Okay. 25 MR. RATCLIFF: Okay. We can do that. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 108 1 MR. PASCAL: One quick note. For the month of 2 September we submitted our 10-422 and the gas we flared 3 for less than one house was report at 390 MCF for the 4 whole month and the gas over one hour was 67 MCF. 5 Because you were asking if we are back to where we were 6 because we -- we are. 7 COMMISSIONER WILSON: Okay. Thank you. 8 Commissioner Chmielowski, any additional questions? 9 COMMISSIONER CHMIELOWSKI: No, not at this 10 time. Thank you. 11 COMMISSIONER WILSON: So at this time I would 12 like to offer to any member of the public the 13 opportunity to testify or provide comments. And I'll 14 remind everyone that we did receive one written comment 15 on the matter, it's in the record. 16 Samantha, do we have anyone online that's 17 wishing to comment? 18 (No audible response) 19 COMMISSIONER WILSON: Is there anybody in the 20 room that was wishing to comment on the matter? 21 (No comments) 22 COMMISSIONER CHMIELOWSKI: Commissioner Wilson, 23 it sounds like we have one participant online who has 24 stated that he or she does not wish to testify. So I 25 think we would be okay to skip that. AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 109 1 COMMISSIONER WILSON: Okay. I'll skip the 2 instructions on how to comment if you're online then 3 and waiting a full 60 seconds for the same result. 4 Okay. And with that I guess we need to decide 5 what's appropriate in leaving the record open for the 6 request that we made. Do you have a suggestion on 7 about how much time you'll need to get that together? 8 MR. RATCLIFF: We'd suggest 30 days to leave 9 the record open. 10 COMMISSIONER WILSON: Commissioner Chmielowski, 11 is that fair to you? 12 COMMISSIONER CHMIELOWSKI: I have no objection. 13 So sounds like 30 -- the 30 days -- the 30th of 14 November is a Sunday so we could either do it Friday, 15 November 28th or Monday, December 1st. Do you have a 16 preference? 17 MS. COLDIRON: Thanksgiving. 18 COMMISSIONER CHMIELOWSKI: Oh, that's 19 Thanksgiving week. How about Monday, December 1st, 20 would that be appropriate, 5:00 p.m.? 21 MR. RATCLIFF: That would be fair. 22 COMMISSIONER CHMIELOWSKI: Okay. 23 COMMISSIONER WILSON: With that and no others 24 wishing to comment, hearing no other business, better 25 check my phone, the time is 1:06 and this hearing is AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 Page 110 1 now adjourned. 2 (Hearing adjourned) 3 (END OF REQUESTED PORTION) 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 AOGCC 10/30/2025 ITMO: APPLICATION OF COOK INLET ENERGY, LLC... Docket No. OTH-25-031 329 F Street, Ste. 222., Anch. AK 99501 Fax: 907-243-1473 Email: sahile@gci.net Computer Matrix, LLC Phone: 907-227-5312 1 TRANSCRIBER'S CERTIFICATE 2 I, Salena A. Hile, hereby certify that the 3 foregoing pages numbered 02 through 111 are a true, 4 accurate, and complete transcript of proceedings in 5 Docket No.: OTH-25-031, transcribed under my direction 6 from a copy of an electronic sound recording to the 7 best of our knowledge and ability. 8 9 _______________ _______________________________ 10 DATE SALENA A. HILE, (Transcriber) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Alaska Oil and Gas Conservation Commission Badami Unit VRU Flaring Event 2024-2025 Docket OTH-25-031 Hearing Presentation - October 30, 2025 Wade Boman, Petroleum Engineer, AOGCC 1 2 Wade Boman Bachelor of Science in Petroleum Engineering from University of Alaska, Fairbanks - 2013 BP Production & Reservoir Engineer – 7 years - GC3 well pads – production, interventions, reservoir engineering – GC3 A, B, C, X pads - Expert well systems modeling engineer – Prudhoe Integrated Systems Model (PrISM) Drilling Materials Specialist at ConocoPhillips’ Alpine Field AOGCC Petroleum Engineer – 2-1/2 years - Drilling and Reservoir Engineering - Gas Disposition – analyze volumes of produced gas flared or vented - excess venting/flaring is a waste of state resources Alaska Oil and Gas Conservation Commission Photo courtesy of BPXA Pilot / purge gas - ensures flare stays lit - sustains forward flow inside piping Assist gas - ensures good flare combustion Flared gas - any gas unable to be processed by a facility, routed out of that facility and burned. NOTE: The above photo is not of Badami’s processing facility. Pilot Flare 3 Alaska Oil and Gas Conservation Commission 4 Alaska Oil and Gas Conservation Commission October 2024 flaring: 9398 MCF November 2024 flaring: 11149 MCF December 2024 flaring: 11459 MCF January 2025 flaring: 9470 MCF February 2025 flaring: 6587 MCF March 2025 flaring: 2952 MCF 51,015 MCF 03/09 – VRU rebuild completed April 2025 flaring: 5450 MCF May 2025 flaring: 8792 MCF June 2025 flaring: 8085 MCF July 2025 flaring: 2849 MCF August 2025 flaring: 5201 MCF 30377 MCF Vapor Recovery Unit issues Vapor Recovery Unit issues Waste determination Power offline 3 weeks - all wells shut-in 5 October 9, 2024 •CIE notified the AOGCC that Badami’s VRU experienced catastrophic damage to its third stage compressor due to a discharge valve failure. •CIE requested for AOGCC approval to vent or flare gas at the Badami Unit for over one hour. Emphasis was made that maintaining facility operations was critical to the continued operation of the Nutaaq Pipeline which carries both Pt Thomson and Badami production. - Noteably, when all Badami wells were later offline in January/February, the Pt Thomson production was not affected. •AOGCC responded by email that day, explaining that per regulation, pre-approval of flaring outside of well testing prior to production is not allowed. •AOGCC asked CIE what steps were being taken to reduce the flared volume of gas. CIE responded via email the same day, stating “…the only way Savant would be able to reduce the volume of flaring is to repair the VRU and get it BOL.” - Noteably, shutting in producing wells was not mentioned as an option, nor was shutting in even a single well. October 2024 October 16, 2024 •CIE emailed the AOGCC, informing that a technician had assessed the VRU and identified repairs, and that they were sourcing parts for the unit to be BOL as soon as possible. •CIE emailed the AOGCC, informing that a complete teardown of the VRU was necessary and that parts had been shipped out for reworking. Alaska Oil and Gas Conservation Commission Online wells flowed for complete months despite VRU being offline 10 wells online each month even when the VRU was offlineVRU failure Power turbine failure VRU Compressor Rebuild MonthsMCF flraredAlaska Oil and Gas Conservation Commission 6 Month Wells online Days online Oil prod (bbls) Gas prod (MCF) Sept 2024 10 30 77,011 38,404 Oct 2024 10 31 118,085 54,603 Nov 2024 10 30 97,696 41,027 Dec 2024 10 31 84,558 50,635 Jan 2025 10 25 72,600 48,193 Feb 2025 10 11 41,530 18,258 Mar 2025 10 31 96,061 42,458 Apr 2025 10 30 81,310 42,774 May 2025 10 31 75,102 40,291 Jun 2025 10 30 66,515 24,912 July 2025 10 31 67,070 36,046 Aug 2025 10 31 62,799 27,338 7 Alaska Oil and Gas Conservation Commission Badami production Gas flared 9398 MCF 2952 MCF 11149 MCF 11459 MCF 9470 MCF 6587 MCF 5450 MCF 8792 MCF 8085 MCF 2849 MCF 5201 MCF VRU offline VRU Compressor Rebuild 8 Alaska Oil and Gas Conservation Commission January 29, 2025 •CIE requested approval to flare gas from Badami well B1-33 for a period of 30 days. •Catastrophic failure of Badami’s power generation turbine, GT-B. •GT-A, the other power turbine, was offline and undergoing controller system upgrades, leaving the facility without power. January 2025 January 6, 2025 •4th month of the flaring event, I reached out to CIE for an update. •CIE replied with a detailed email, giving an estimated time for the rebuild to be a week, once the work would soon begin. January 30, 2025 •I emailed CIE - authorization for pre-approval can only be given for the purposes of testing a well prior to regular production. - asked them a list of questions. January 31, 2025 •CIE promptly responded, answering my questions. Month Wells online Days online Oil prod (bbls) Gas prod (MCF) Sept 2024 10 30 77,011 38,404 Oct 2024 10 31 118,085 54,603 Nov 2024 10 30 97,696 41,027 Dec 2024 10 31 84,558 50,635 Jan 2025 10 25 72,600 48,193 Feb 2025 10 11 41,530 18,258 Mar 2025 10 31 96,061 42,458 Apr 2025 10 30 81,310 42,774 May 2025 10 31 75,102 40,291 Jun 2025 10 30 66,515 24,912 July 2025 10 31 67,070 36,046 Aug 2025 10 31 62,799 27,338 9 Alaska Oil and Gas Conservation Commission Badami production Power turbine failure 9398 MCF 2952 MCF 11149 MCF 11459 MCF 9470 MCF 6587 MCF Gas flared 2952 MCF 5450 MCF 8792 MCF 8085 MCF 2849 MCF 5201 MCF VRU Compressor Rebuild VRU offline MCFPilot/Purge ~400 MCF/mo Oct~9400 ~11000 ~11500 ~9500 ~6500 VRU Compressor Rebuild Complete – 3-9-2025~8800 ~8000 ~5500 ~2800 Across 6 months Oct 9, 2024 – March 9, 2025 51,015 MCF NovDecMarFebJanJuneMayAprJuly~2800 ~30,000 MCF Aug~5200 5 months April, 2025 - August, 2025 10Sept 11 Alaska Oil and Gas Conservation Commission Notice of Proposed Enforcement Action – issued May 27, 2025 •20 AAC 25.235(c): The operator shall take action in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. •“Upon review of the incident details, including Badami’s production data throughout the timeframe involved, the AOGCC concludes that no effort was made to minimize the volume of gas flared that the VRU at Badami would normally capture. This is evidenced by the same number of producing wells being kept online while the VRU was down as were online before the VRU failure (10 during and 10 before). Furthermore, average monthly oil and gas production amounts after the VRU failure are greater than those of the month (September) prior to the VRU failure: October, November, December averages of 100,113 bbls oil and 48,755 MSCF gas vs 77,011 bbls oil and 38,404 MSCF gas for September. The same is true if well B1-33’s (which was put online mid-September) production is not taken into account: October, November, December averages of 25,531 bbls oil and 39,957 MSCF gas vs 24,553 bbls oil and 31,254 MSCF gas for September.” •“Per AS 31.05.150(d), the penalty for gas determined to be waste is twice the fair market value for every 1,000 SCF of gas wasted. Gas fair market value is being referenced from the Alaska Department of Revenue’s website at https://tax.alaska.gov/programs/oil/prevailing/index.aspx. Badami’s VRU flaring event was ongoing across 6 months and 2 yearly quarters, with the prevailing market value fluctuating across them. Thus, monthly flare volumes have been multiplied by the fair market value for the appropriate quarter (see table below). The proposed action is for CIE to pay the penalty, totaling $357,905.” Findings May 2025 12 Alaska Oil and Gas Conservation Commission June 17, 2025 - Informal Review June 18, 2025 - CIE’s Response Following Informal Hearing June 2025 August 14, 2025 - Other Order 221 issued August 2025 13 Alaska Oil and Gas Conservation Commission Other Order 221 – issued August 14, 2025 1)“CIE acknowledged that the flaring occurred and was reported as required per 20 AAC 25.235. CIE stated that the flaring was not waste but a safety- driven response to equipment failure during arctic winter conditions.” “The AOGCC agrees that the flaring was duly reported on Facility Reports of Produced Gas Disposition (Form 10-422). The AOGCC defines this flaring as waste and does not agree that CIE’s response was purely safety driven, as all wells that were producing before the VRU failure were kept online after the failure for several months until the VRU was back online.” 2)“CIE pointed out that regulatory compliance was maintained, as all events were reported via Form 10-422, Facility Reports of Produced Gas Disposition, along with supplemental reporting, and that direct communications were maintained with the AOGCC.” “The AOGCC agrees that CIE reported flaring volumes via Form 10-422 per 20 AAC 25.235. The AOGCC points out that all operators are required to report gas disposition in this manner per production facility, regardless the nature of a production facility’s operations, be they “normal” or otherwise. Failure to report was and is not in question. The AOGCC agrees that supplemental reporting via email and direct telephone communication did take place. This being said, as the VRU troubles “rolled into” power turbine issues, initial communication from CIE did not make it clear that a separate issue had developed. Additionally, 20 AAC 25.235(b) and (c) require an operator to describe actions taken to minimize the volume of gas flared. CIE’s Form 10-422s for the period in question do not detail actions taken to minimize volume, only repeating the description of the flaring events.” Findings 14 Alaska Oil and Gas Conservation Commission Other Order 221 – issued August 14, 2025 3)“CIE pointed out that the primary cause of the flaring was the failure of the VRU unit that had no backup unit to provide redundancy, and that the VRU failure was unexpected. CIE further pointed out that power turbine outages compounded the situation, leaving only diesel power, arguing that flaring was essential to avoid freeze-up and loss of life or infrastructure.” “The AOGCC agrees that the primary cause of the flaring was the failed VRU. However, justifying flaring due to turbine outages and the reliance on diesel generators is misleading, as this combination of events was only over a 2-week period of the 6 calendar months that the VRU associated flaring commenced. Additionally, this argument is baseless due to the fact that while both power generating turbines were offline, all production wells were shut-in, leaving no facility gas to flare.” 4)“CIE argued that the flaring was justified under 20 AAC 25.235(d)(5), due to the flaring being required for repairs and facility operations, emergency response to -40F conditions, and the ultimate recovery from new well B1-33A.” “The AOGCC points out that allowances detailed in 20 AAC 25.235 for flaring or venting of gas for a period exceeding 1 hour are by the AOGCC’s discretion (20 AAC 25.235 (d)(5)). When considering authorizing flaring for facility operations, emergencies, or for ultimate recovery, many things are considered, not least of all the time span of such flaring. CIE’s flaring at Badami extended across 2 yearly quarters and 6 different months, making careful consideration of a waste determination necessary. Moreover, even if flaring could be justified under the criteria listed in 20 AAC 25.235(d)(5), if there is no evidence of actions to minimize the flaring as required under 20 AAC 25.235(c), the AOGCC may classify the flaring as waste pursuant to 20 AAC 25.235(e).” Findings 15 Alaska Oil and Gas Conservation Commission Other Order 221 – issued August 14, 2025 5)“CIE referenced Other Order 194 as a precedent previously set by the AOGCC for the allowed flaring volumes.” “Other Order 194 authorized the flaring of gas from a new production well on a lone drillsite lacking permanent production facilities. Applying for the authorization for flaring for purposes of testing a well before regular production is within rights of any operator. Upon application, the AOGCC, in its discretion, may authorize such flaring pursuant 20 AAC 25.235(d)(6). Authorization, past or present, for flaring of gas for well testing prior to regular production is not precedent for the same or another operator’s flaring of gas from regular production due to processing facility operations.” 6)“CIE pointed out that the State received $4.76 million in royalties from Badami production during the VRU flaring event. CIE also pointed out that during the same time period 787,944 barrels of oil flowed down the Nutaaq Pipeline from Point Thomson. CIE claimed that shutting in Badami production would have halted all production.” “Other than considering whether flaring is necessary to prevent loss of ultimate recovery pursuant to 20 AAC 25.235(d)(5)(c), the AOGCC does not take royalties or other economic factors into account when enforcing Alaska Oil & Gas statutes. When Badami experienced the loss of power turbine generating capacity, and all production wells were shut-in, the emergency diesel generators were enough to supply power to keep the Nutaaq Pipeline operating. Also, this argument proposes a false dilemma, as shutting in some production wells was an option that was not pursued, as across all 6 months (minus the 2 weeks during the power turbine outage) the same production wells were kept online.” Findings 16 Alaska Oil and Gas Conservation Commission Other Order 221 – issued August 14, 2025 7)“CIE made the point that flaring gas does not equate to lost royalties of the state, adding that the gas is for onsite use only and has no market value or export path.” “Resource conservation, including that of reducing or eliminating gas flare volumes, is of utmost importance to the State of Alaska, with lack of a current export path or current unrealized royalties being immaterial.” 8)“CIE argued that the gas valuation used to determine the overall value of the gas flared is overstated; that the only viable benchmark is CIE’s cost of gas when purchasing gas from Endicott for use at Badami.” “AS 31.05.150(d) mandates that a waste “penalty shall be twice the fair market value of the natural gas at the point of waste.” When determining the fair market value for waste determinations, the AOGCC has consistently utilized the prevailing value of North Slope gas published by the Alaska Department of Revenue, at https://tax.alaska.gov/programs/oil/prevailing/northold.aspx. The Department of Revenue’s publication states that “[t]his prevailing value is the weighted average sales price of gas to publicly regulated utilities in the north slope area.” The AOGCC concludes that this publication is an accurate method of calculating the fair market value of the flared gas.” Findings 17 Alaska Oil and Gas Conservation Commission Other Order 221 – issued August 14, 2025 “The AOGCC finds that CIE committed the violation as initially alleged in the Notice and that the proposed $357,905 penalty represents “twice the fair market value of the natural gas” flared as required by AS 31.05.150(d). However, the AOGCC recognizes that CIE is having repeated issues with the Badami VRU, and that CIE has identified a significant inefficiency in the plant’s eductor system, causing much more gas to go to flare when the VRU is down than the VRU normally captures. Accordingly, the AOGCC will give CIE one year from the date of this Order to complete the upgrade/replacement of both the VRU and eductor system that will prevent future failures, with expenditures within the year being credited against the $357,905 penalty. Costs for repairs to either will not be credited against the penalty amount.” Findings 18 Alaska Oil and Gas Conservation Commission Thank you. By Samantha Coldiron at 8:16 am, Oct 28, 2025 7 Mustang Holding LLC 310 K Street, Suite 309 Anchorage, AK 99501 MustangHolding 10/30/2025 Alaska Oil and Gas Conservation Commission 333 W 7th Ave Anchorage, AK 99501-3539 Subject: Comments Regarding Other Order 221 Dear Commissioners, My name is Josh Tempel, and I am submitting these comments regarding Other Order 221 in my capacity as Head of Operations for Mustang Holding LLC, operator of the Southern Miluveach Unit (SMU). As a small independent operator on Alaska’s North Slope, Mustang is directly affected by the outcomes and precedents established through this hearing. There are few small independent operators on the North Slope, and those that exist typically work in remote, isolated, and economically challenging conditions. Compared to larger operators, small independents are more severely impacted by the circumstances that necessitate flaring, the resources required to respond to violations, and the consequences of receiving violation notices— particularly with respect to their ability to raise capital. Given that the State’s concerns about flaring are rooted in an economic interest in maximizing value from Alaska’s natural resources, it seems reasonable to also consider the economic impacts on small independents and how restricted access to capital may ultimately reduce a reservoir’s total recovery. Mustang strongly believes that small independent operators play an essential role in maximizing value from Alaska’s North Slope assets. Without these operators willing to risk private capital, many reserves—such as those at Badami or the Southern Miluveach Unit—might have remained undeveloped for many years, or possibly never be developed at all. While I do not have full details regarding the circumstances of Cook Inlet Energy’s violation notice, the record suggests that Badami has historically purchased gas and would therefore place significant value on any available gas. From that perspective, it appears likely that CIE had strong reasons for flaring. Mustang Holding LLC understands these challenges firsthand. We are currently flaring gas related to pre-regular production well testing and are engaged in discussions with the State on how to best maximize resource value through gas injection strategies. We believe these discussions will meaningfully affect the ultimate recovery and long-term value of the Southern Miluveach Unit for the State. By way of context regarding Mustang Holding’s concerns about the outcome of this hearing: the owners of Mustang Holding LLC were the only parties to actively pursue ownership when the State offered its interest in the Southern Miluveach Unit to the market. This limited interest underscores the difficulty of attracting investment in Alaska’s smaller fields. For nearly fifteen years, this field remained undeveloped. Since the current owners acquired the unit, the SMU has had significant investment, enabling first-phase production facilities to be near completion. Looking ahead, continued investment will be critical to optimally develop the field. If Alaska’s investment climate limits available capital—or if the State does not consider how the economics of flaring influence ultimate By Samantha Coldiron at 9:55 am, Oct 30, 2025 2 recovery—then small independents like Mustang will face even greater financial strain. In such a scenario, the State risks losing more value in unproduced oil than is ever lost through flared gas. Mustang Holding LLC respectfully urges the Commission to work collaboratively with small independent operators to ensure that regulatory frameworks both protect the State’s interests and support the continued flow of private capital into Alaska’s petroleum sector. By encouraging further investment, the Commission can help ensure that maximum long-term value is realized from Alaska’s natural resources. The North Slope remains an exceptional petroleum basin with many projects worthy of continued development. We sincerely appreciate your time and consideration of these comments as you deliberate on Other Order 221. Sincerely, Josh Tempel Head of Operations Mustang Holding LLC 6 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: OTH-25-031 Other Order 221 Cook Inlet Energy, LLC (CIE) requested a hearing regarding Other Order 221, Docket Number OTH-25-031. The Alaska Oil and Gas Conservation Commission (AOGCC) grants the request. A public hearing on the matter has been scheduled for October 30, 2025, at 10:00 a.m. The hearing, which may be changed to full virtual if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907)202-7104 Conference ID: 211 286 67#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. In addition, written comments regarding this matter may be submitted to the AOGCC at 333 West 7th Avenue, Anchorage, AK 99501, or samantha.coldiron@alaska.gov. Comments must be received no later than the conclusion of the October 30, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron at (907) 793-1223 no later than October 22, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.02 16:09:57 -08'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.02 16:20:18 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notice (CIE) Date:Tuesday, September 2, 2025 4:23:19 PM Attachments:OTH-25-031 Public Hearing Notice, CIE request for hearing Badami VRU flaring event .pdf Docket Number: OTH-25-031 Other Order 221 Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 09/07/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0054913 Cost: $209.87 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: OTH-25-031 Other Order 221 Cook Inlet Energy, LLC (CIE) requested a hearing regarding Other Order 221, Docket Number OTH-25-031. The Alaska Oil and Gas Conservation Commission (AOGCC) grants the request. A public hearing on the matter has been scheduled for October 30, 2025, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 211 286 67#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. In addition, written comments regarding this matter may be submitted to the AOGCC at 333 West 7th Avenue, Anchorage, AK 99501, or samantha.coldiron@alaska.gov. Comments must be received no later than the conclusion of the October 30, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron at (907) 793-1223 no later than October 22, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Pub: Sept. 7, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-09-08 2029-01-23 Document Ref: MBXEM-UCVL6-GLAA6-OATNY Page 3 of 34 5 "(( %"! ))%!# )!' ##$&'$% )!' ##$&'#% ''%&5..75.,.1 ///5%&5( &5( ' !$75%5441,- %%%) %%""!'% %&% ("$( #!%*% % %+ 8 !!5 &5 $*75 75 !"$&!$5 !5 &5 5 &75 $%"&'*5 %'&%5 &%5 )$&& 5 $#'%&5 !$5 5 !$5 $ 5 "'$%' &5 &!5 .,5 5 .161/1<=5 5 .,5 5 .1610,5$$ 5&$5$$5..-75!&5 !65;.1;,/-75%%'5''%&5-075.,.16 5$5$#'%& 55!$5$ 5)& 5&5-,;*5&$5"$!(5' $5&5 $'&! %65%5$#'%&5%55&!5"$%$(5!'$5$&%5 5&!5!)5!!5 &5 $*5&!5"$% &5&%&! *75( 75 5$' &5! $ 5&5 %5 5 $* ! '%! %5! & 5 5&$5$$5..-75 ' 5'&5 !&5&5&!8 : 5$&$+&! 5!5&55 5$ 5( &5%5>?5' $5.,5 5.16./1 : 5&$ &! 5!5" &*5'&! %5' $55/-6,16-1,<=95 : ! %$&! 5!5&& 5!"$&! 5 5%&*5&!$%5'$ 5&5 5 !'&6 5$#'%&5&&5&5!%%! 5!5&%5%! 5 5* 5" 5&%5 $ 75! %%& &5)&5.,55.161/1<=6 %5! $5$"&5!5&%5$#'%&5 5(%5! 5&5&5 5%' 5!5&5 $ 6 !'5 5$55&5"%A$!6! 5&5<4,2=50//;/3..6 %"&'*7 5"$& 5$ $55 5%5!$"6 ! 55!5!!5 &5 $*75 By Samantha Coldiron at 2:43 pm, Aug 22, 2025 4 By Samantha Coldiron at 7:15 am, Jun 23, 2025 AOGCC INFORMAL HEARING Docket No. OTH-25-031 I Badami VRU Flaring Event Presented by: David Pascal i June 2025 1. Acknowledgment of Flaring Flaring occurred and was reportable under 20 AAC 25.235. It was not waste, but a safety -driven response during Arctic winter. 2. Regulatory Compliance All events reported via Form 10-422. Supplemental reporting and direct communications maintained with AOGCC. 3. Primary Cause: VRU Failure No backup VRU; failure was unexpected. Turbine outages compounded the situation, leaving only diesel power. Flaring was essential to avoid freeze-up and loss of life/infrastructure. 4. Justified Under 20 AAC 25.235(d)(5) ✓ Required for repairs and facility operations ✓ Emergency response to -40OF conditions ✓ Necessary to preserve ultimate recovery from new well B1-33A 5. Commission Precedent — Order 194 Great Bear flared 150-500 MCFD for 9 months. Savant/CIE flared less, for shorter duration, to preserve active production and royalty flows. 6. Royalty and Production Impact Badami: 510,530 barrels (Oct —Mar) --> $4.76M State royalties. Point Thomson: 787,944 barrels flowed via Nutaaq pipeline. Shut-in would have halted all production. 7. No Royalty Lost from Flared Gas Onsite-only use; no market value or export path. State gained additional royalties from makeup gas purchased from Endicott. 8. Gas Valuation Overstated Endicott gas cost $2.50—$2.73/MCF (only viable benchmark). Penalty calculation uses unrealistically high value for Badami gas. p' 4o �e vSRd 9. Facility Design and Power Constraints Gas turbines: —10 MW I Diesel gens: 1.5 MW each Diesel = 8x cost, environmentally limited, not tariff -compatible Diesel was used solely to prevent disaster, not as a cost saving measure 10. Investor Confidence & State Policy Penalizing flaring under these emergency conditions sends wrong signal. Glacier and its partner invested in Badami and Grey Owl based on "Alaska is open for business" 11. Closing Request Flaring was emergency -driven, reported, and justified. We request that the proposed fine be waived 2024/2025 Badami VRU Rebuild Timeline Summary 10/9/2024 VRU discharge valve failure and compressor damage event 10/15/2024 – 10/17/2024 Siemens Compressor Mechanic onsite for VRU condition assessment. •Cylinder & Piston Inspection o Cylinder requires replacement or rebuild o Piston and rings require replacement •Connecting Rod Inspection o Rod Bushing recommended further inspection by outside source or replacement •Crosshead Inspection o Crossheads inspection recommended finite measurements and buildup of material if measurements not within specified tolerances or purchase of new crossheads. o Crosshead Bushing Inspection – Recommended further inspection or replacement •Crankshaft Inspection – Recommended onsite polishing repair or replacement 10/17/2024 – 1/6/2025 •Specification, selection and procurement of new VRU components (crankshaft, piston rings, oil pump, sprocket, discharge valves, bushings, o-rings, etc.) •Repair of damaged components (cylinder and crossheads) o Cylinder and crosshead components sent to Texas for metal buildup and machining to bring tolerances to within specification 1/8/2025 – 1/23/2025 Washington Ironworks Contractors onsite performing VRU rebuild. •Frame alignment need discovered during rebuild – mobilized the tools required and compressor alignment completed. •At the final completion of the rebuild, it was discovered that the new crankshaft was not compatible with the Badami VRU pistons and needed to be replaced. 1/23/2025 – 2/24/2025 New Crankshaft sourcing and shipment to site. Crankshaft shipped from Texas on 2/13/2025 and arrived in Anchorage on 2/24/2025. 2/26/2025 Siemens Compressor Mechanics travel to Badami for new crankshaft installation and final rebuild. Rebuild was completed and the VRU was back online on 3/8/2025. 3 By Samantha Coldiron at 11:39 am, Jun 02, 2025 2 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 May 27, 2025 CERTIFIED MAIL RETURN RECEIPT REQUESTED 7018 0680 0002 2052 9891 Zack Hundrup Production & Facilities Manager Cook Inlet Energy 188 W. Northern Lights Blvd. Ste 510 Anchorage, AK 99503 Re: Docket Number: OTH-25-031 Notice of Proposed Enforcement Action Badami VRU Flaring Event Badami Unit Dear Mr. Hundrup: The Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Cook Inlet Energy (CIE) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)) CIE violated AS 31.05.095, 20 AAC 25.235(c), and 20 AAC 25.235(d) and by flaring produced gas which was unable to be recovered in Badami’s production system due to a non-functioning vapor recovery unit (VRU). Flaring of said gas occurred from October 2024 to March 2025, with a total flared volume of 51,015 MCF, according to Cook Inlet Energy’s submitted Forms 10-422 Facility Report of Produced Gas Disposition. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)) Per email correspondence and telephone conversations with CIE from October 2024 through March 2025, the AOGCC gathered the below details. On October 9, 2024, Badami’s VRU experienced catastrophic damage to its third stage compressor due to a discharge valve failure. A request was made for AOGCC approval to vent or flare gas at the Badami Unit for over one hour. The email included an estimate that 300 MSCF/day of gas would be flared while the VRU was offline, and emphasis was made that maintaining facility operations was critical to the continued operation of the Nutaaq pipeline which carries both Point Thompson and Badami production (incidentally, it was discovered later in January and February of 2025 that the Nutaaq pipeline operation was not impacted for the approximate 2 weeks that all Badami production was shut-in). The same day, the AOGCC responded by email, explaining that Docket Number: OTH-25-031 May 27, 2025 Page 2 of 4 per regulation, pre-approval of flaring or venting outside of well testing prior to production is not allowed and asking CIE what steps were being taken to reduce the flared volume of gas. CIE responded via email the same day, stating the only way to reduce the volume of flared gas was to repair the VRU and get it back online as soon as possible. Repairs on the VRU compressor took multiple weeks and months, due to increasing complexities of repair needs and parts sourcing. Notably, during the flaring event, CIE chose to keep all production wells online until a catastrophic failure of Badami’s one functional power generating turbine. At that time, CIE again requested AOGCC pre-approval for flaring all production gas from Badami well B1-33, and the AOGCC again explained its inability to pre-approve flaring or venting outside of well testing prior to production. All production wells were then shut-in, and Badami went on emergency diesel generators for power until one of Badami’s two power generating turbines could be brought back online. Once turbine power was restored, all production wells were brought back online, even though the VRU was still non-functional. Full production continued, along with the associated flaring of production gas that would normally be captured by the VRU. Per email on March 9, 2025, CIE informed the AOGCC that the VRU at Badami was back online as of 2:10 PM the day prior. Hence, the VRU was offline from October 9, 2024 to March 8, 2025, with associated flaring occurring that entire time, except for the 2+ weeks where the Badami facility was offline due to both turbine generators being offline and Badami running on backup diesel generator power. Per email on March 10, 2025, the AOGCC requested CIE provide a final written report be submitted, summing up the event and the details of the repair process. Per email on March 19, 2025, CIE provided the AOGCC with a document outlining the VRU repair timeline. CIE’s submitted Form 10-422 Facility Reports of Produced Gas Disposition from October 2024 through March 2025 list a total flared gas volume of 51,015 MCF. Per 20 AAC 25.235(c), “The operator shall take action in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air.” Upon review of the incident details, including Badami’s production data throughout the timeframe involved, the AOGCC concludes that no effort was made to minimize the volume of gas flared that the VRU at Badami would normally capture. This is evidenced by the same number of producing wells being kept online while the VRU was down as were online before the VRU failure (10 during and 10 before). Furthermore, average monthly oil and gas production amounts after the VRU failure are greater than those of the month (September) prior to the VRU failure: October through December averages of 100,113 bbls oil and 48,755 MSCF gas vs 77,011 bbls oil and 38,404 MSCF gas for September. The same is true if well B1-33’s (which was put online mid-September) production is not taken into account: October through December averages of 25,531 bbls oil and 39,957 MSCF gas vs 24,553 bbls oil and 31,254 MSCF gas for September. Docket Number: OTH-25-031 May 27, 2025 Page 3 of 4 Per AAC 25.235(d), the total gas flared due to the Badami VRU being offline, 51,015 MSCF, is considered waste and subject a civil penalty pursuant to AS 31.05.150(d), which states: “In addition to the penalties in (a)—(c) and (e) of this section, the commission may impose a civil penalty for each 1000 cubic feet of natural gas flared, vented, or otherwise determined to be waste as defined in AS 31.05.170. The penalty shall be twice the fair market value of the natural gas at the point of waste.” Proposed Action (20 AAC 25.535(b)(3)) Per AS 31.05.150(d), the penalty for gas determined to be waste is twice the fair market value for every 1,000 SCF of gas wasted. Gas fair market value is being referenced from the Alaska Department of Revenue’s website at https://tax.alaska.gov/programs/oil/prevailing/index.aspx. Badami’s VRU flaring event was ongoing across 6 months and 2 yearly quarters, with the prevailing market value fluctuating across them. Thus, monthly flare volumes have been multiplied by the fair market value for the appropriate quarter (see table below). The proposed action is for CIE to pay the penalty, totaling $357,905. Quarter, yr Month Total waste gas (MCF) Fair market value, $/MCF Total ($) x2 ($) Qtr 4, 2024 October 9,398 3.503 32,921 65,842 Qtr 4, 2024 November 11,149 3.503 39,055 78,110 Qtr 4, 2024 December 11,459 3.503 40,141 80,282 Qtr 1, 2025 January 9,470 3.516 33,297 66,593 Qtr 1, 2025 February 6,587 3.516 23,160 46,320 Qtr 1, 2025 March 2,952 3.516 10,379 20,758 51,015 TOTAL: 357,905 Rights and Liabilities (20 AAC 25.535(b)(4)) Within 15 days after receipt of this notification – unless the AOGCC, in its discretion, grants an extension for good cause shown – CIE may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide CIE an opportunity to submit documentary material and make a written or oral statement. If CIE disagrees with the AOGCC’s proposed decision or order after that review, it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10-day period, the proposed decision or order will become final on the 11th day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. If CIE does not concur in the proposed action described herein, and the AOGCC finds that CIE violated a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action; (ii) suspension or revocation of a permit or other approval; and (iii) imposition of penalties under AS 31.05.150. In taking action after an informal review or Docket Number: OTH-25-031 May 27, 2025 Page 4 of 4 hearing, the AOGCC is not limited to ordering the proposed action described herein, as long as CIE received reasonable notice and opportunity to be heard with respect to the AOGCC’s action. Any action described herein or taken after an informal review or hearing does not limit the action the AOGCC may take under AS 31.05.160. Sincerely, Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.05.27 09:41:26 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.05.27 12:14:21 -08'00' 1 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:Zack Hundrup To:Boman, Wade C (OGC) Cc:Lynnette Peluso Subject:RE: Badami VRU Outage Date:Thursday, August 21, 2025 10:10:53 AM Attachments:image001.png Wade, We received the repaired pistons and rider bands 2 days ago on our Tuesday flight, and the VRU is back online as of this morning. I also flew up on Tuesday and was able to look at the VRU and the cylinder itself, which still looks to be in good shape. Flaring will be back to normal levels starting this morning. Please reach out with any questions. Thanks Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Tuesday, August 5, 2025 11:24 AM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: Lynnette Peluso <lpeluso@glacieroil.com> Subject: Badami VRU Outage Hi Wade, We’ve had another VRU outage at Badami that we are experiencing. This time it’s not the cylinder itself, rather, the piston has developed a slight “tilt” between the piston halves and was causing elevated noise and vibrations in the compressor. The piston has been sent out for repair and we are looking at a 2 week turnaround (from this week) to get new, oversized rider bands and the piston repaired. Currently we are targeting the week of August 18th for the VRU to be back online. I’ll reach out to let you know if anything on that timeline changes, and please reach out with any questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com 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:Zack Hundrup To:Boman, Wade C (OGC) Cc:Lynnette Peluso Subject:RE: Badami VRU Compressor Date:Wednesday, July 2, 2025 2:43:17 PM Attachments:image002.png Wade, This is notification that the Badami VRU has been repaired and is back online as of this morning. You will see the corresponding reduction of flared gas on the flare reports beginning today (7.2.2025). Please feel free to reach out with any questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Tuesday, June 10, 2025 2:24 PM To: 'Boman, Wade C (OGC)' <wade.boman@alaska.gov> Cc: Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami VRU Compressor Wade, VRU update here. We opted for repair through Bender CCP and were able to ship the cylinder down to California for repair. They received the cylinder 2 weeks ago at the end of May and I just got a call today that it’s ready for pickup and shipment back to Badami. We are arranging that now, and expected delivery time to Anchorage is around 6/20/2025 (next Friday). Ideally we will put that on our Tuesday (6/24) flight to Badami, and will begin the re-assembly process that last full week of June. Let me know if you have any questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Monday, May 5, 2025 10:26 AM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami VRU Compressor Hi Wade, Still working on a path forward. One cylinder found is for a 6” stroke machine, but we have a 5” stroke machine and Siemens Engineering is reviewing whether or not we can make that work. I’m also waiting on a response from Bender CCP on repair options for the existing cylinder. Their expert for that process was out last week, but will be back in their office tomorrow and I plan to follow up with him. Please reach out with any questions. Thanks Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Tuesday, April 29, 2025 3:25 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: Lynnette Peluso <lpeluso@glacieroil.com> Subject: Badami VRU Compressor Hi Wade, I wanted to reach out to let you know that we are having another round of VRU problems. Our repaired cylinder has not held up to continued operation, and upon further inspection is wearing internally such that it is damaging the piston and rings. So you’ll see some more flaring on this April monthly log as we try and source a new cylinder. I do have a lead on a new/used cylinder out of California and am working with the vendor to validate it is the correct size and type and that it will fit with our engine. A brand new cylinder from Siemens has a 21 week lead time, so I am not pursing that option at the moment. My third option is to get the existing cylinder inspected and possibly repaired again, but given that the last repair has failed, I’d prefer we get a new or rebuild cylinder instead. I’ll plan to give you an update here at the end of the week so you can have an idea of progress. Please let me know if you have any questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com 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:Zack Hundrup To:Boman, Wade C (OGC); Roby, David S (OGC); Regg, James B (OGC) Cc:David Pascal; Lynnette Peluso Subject:Badami VRU Flaring Event - Informal Hearing Follow-Up Date:Friday, June 27, 2025 2:53:37 PM Attachments:image001.png image003.png Badami Simplified VRU Gas Network.pdf Hi Wade, During our informal hearing of the Badami flaring a question was asked about what flare volume reduction would be observed if “high GOR” wells were shut in. At the time, I was not able to provide any quantifiable answers, but generally answered that shutting down individual wells would have minimal impact to the total flaring quantity. The email below, along with the attached diagram should do a better job of explaining my verbal answer. Through thermodynamic modeling (HYSYS) we have run a couple of scenarios with the VRU offline to quantify the reduction in flare gas for each scenario: Scenario #1 – Normal Production (all wells flowing and normal operations) Scenario #2 – Shut in B1-15 well Scenario #3 – Shut in B1-15 and B1-28 wells As you can see from the table below, approximately 99.43% of the produced gas and recycled gas lift is captured in the 1st Stage Separator. The remaining off gassing that occurs from all wells in the 2nd Stage Separator and Gas boot equates to about 0.567% of the total produced gas + gas lift volumes. If we were to shut in B1-15 and B1-28 we see a reduction in flare volume by about 1.0 MSCFD while losing approximately 54 BOPD. The VRU has 5 total sources of gas (reference attached schematic): 1st Stage VRU Inlet – Operating Pressure <1 psig TEG Reboiled Vapors TEG Regeneration Stripping Gas Slop Tank (TK-0002) blanket gasses 2nd Stage VRU Inlet – Operating Pressure ~ 15 psig Gas Boot Offgas 3rd Stage VRU Inlet – Operating Pressure ~ 50 psig 2nd Stage Separator Offgas Out of the total flared volume at Badami, according to the modeling, only about 70 MSCFD is being contributed by the 2nd Stage Separator and Gas Boot. The remaining flared gas comes from the VRU 1st Stage contributors, however, when the VRU is down, the TEG reboiled vapors, Regenerative Stripping Gas and Slop Tank vapors do not have enough pressure on their own to get into the flare system. Badami utilizes an eductor jet pump system which utilizes Badami Produced Gas as drive gas to sweep the low pressure gas into the flare header. The secondary piece to this event, that I mentioned in our meeting, is that we have to consider the impact of reduced Badami fuel gas if we chose to shut in any of our producing wells. Currently we are buying an average of 1.3 MMSCFD from Endicott with an H2S concentration of 300ppmv. Badami’s air permit has a limit of 250 ppmv so we have to dilute the Endicott Gas with Badami gas in order to achieve a mixture rate within our H2S limits. We have natural swings in produced gas volumes as we clean out wells on an every other day basis, so we can’t be too close to that 250 ppmv limit, otherwise we risk being out of compliance during a facility swing where instantaneous Badami Produced Gas rates are low. In conclusion, shutting down wells at Badami with the VRU offline has a greater air impact based on our title V permit while having minimal impact to reduced flare volumes. Glacier Oil’s action “in accordance with good oil field engineering practices” was to repair the VRU compressor in order to minimize the volume of gas flared. Let me know if you need clarification or have more questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From:Zack Hundrup To:Boman, Wade C (OGC) Cc:David Pascal; Roby, David S (OGC); Lynnette Peluso Subject:RE: Badami Emergency Flaring Event Date:Tuesday, April 1, 2025 12:19:13 PM Attachments:image002.png Wade, Thanks for the phone call today and I’m seeing why there’s some confusion here now, and will do my best to explain clearly. David’s 30 day flaring request sent on 1/29/2025 at 2:52PM for flaring gas from the B1-33 Production Well is unrelated to the VRU compressor repairs. The power generation outage at Badami was the reason for the 30 day flaring request, and also impacted the VRU repair work, but was ultimately an unrelated request. After Turbine Generator GT-B failed, and we were faced with 2 weeks of no production while we completed the controls retrofit on Turbine Generator GT-A, we were trying to get creative with ideas for minimizing the financial impact of being productionless for 2 weeks. One avenue we explored is allowing Production Well B1-33 to produce through the facility (no gas lift available) utilizing the well’s existing stored energy, however, being on backup generators would have required us to flare all of the Produced Gas from that Well’s production. We did not end up producing any wells during our power/production outage and did not flare any gas per David’s flaring request. So in summary, the VRU repair/rebuild was completely separate from the turbine outage and flaring request. Any time a production well was producing, our injection gas compressors were online (omitting gas compressor shutdown/blowdown events) and recovering the produced gas to be used as fuel gas or lift gas. Any other residual gas that would have been recovered by the VRU was being sent to flare until the VRU compressor repair was completed at the end of February. Please feel free to call or email with any other questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Boman, Wade C (OGC) <wade.boman@alaska.gov> Sent: Friday, March 21, 2025 12:58 PM To: Zack Hundrup <ZHundrup@glacieroil.com> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Zack thank you for the summary of turbine GT-B’s repairs. It’s great to hear things are running smoothly. However, events include turbine GT-A being offline in the first place for its controller upgrade work, and the summary doesn’t mention that. My understanding is that the months long flaring was necessary because both turbines were down, from GT-B suffering its catastrophic 3rd stage failure while GT-A was already down for its controller upgrade. In your summary, could you please add/intersperse info on turbine GT-A? A line or two about losing all power and having to go to backup diesel generators would be good as well. It would also be good to see a total of all gas flared, which well was left online, why it was chosen, etc. With such an extended flaring event, any info you can include in the summary will help validate how the flaring gets categorized. Thanks. -Wade Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 From: Zack Hundrup <ZHundrup@glacieroil.com> Sent: Wednesday, March 19, 2025 4:57 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Wade, Attached is a summary for the VRU repair timeline and sequence of inspection/procurement/repair activities that took place. Please let me know if you have any follow up questions. As of today, the VRU is still running smoothly! Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Boman, Wade C (OGC) <wade.boman@alaska.gov> Sent: Monday, March 10, 2025 9:52 AM To: Zack Hundrup <ZHundrup@glacieroil.com> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Thanks for the update, Zack. And as we discussed on the phone, a final written report (submitted in a week or so) will be very helpful so sum up the event, the details, and the tribulations of the repair process. Thanks for you time on the phone. -Wade Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 From: Zack Hundrup <ZHundrup@glacieroil.com> Sent: Sunday, March 9, 2025 4:08 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, Sending a final update on the Badami VRU status. The compressor rebuild has been completed and the VRU at Badami is back online as of 2:10PM yesterday March 8. Flaring levels at Badami have returned to normal. Please reach out with any questions and I’ll be happy to answer them. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Thursday, January 23, 2025 2:35 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, Sending another status update. The compressor has been successfully realigned, cylinders, pistons and accessories reassembled and piping bolted up, but we rant into another problem that requires us to source another crankshaft. Currently, we have one in route to our service vendor in Texas for measurement and inspection prior to shipment to site. I expect we will have visibility on the crankshaft’s fitness for service by mid next week. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Monday, January 13, 2025 1:50 PM To: 'Boman, Wade C (OGC)' <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; 'Roby, David S (OGC)' <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, I wanted to give you a status update for the ongoing VRU repair work at Badami. Last week (Thursday/Friday) when attempting to install the new crankshaft, it was discovered that the compressor frame needs a realignment. This required the mobilization of additional alignment tools from Texas which we have expedited and will be delivered to site at the end of today. We are still at risk for “additional discoveries” as they realign the compressor and continue with the reassembly process, but I’ll be sure to give you impact updates as I receive them. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Monday, January 6, 2025 3:28 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, Yes the VRU repair unfortunately took longer than we had hoped, mainly due to repair parts availability through Siemens and other aftermarket channels. To quickly summarize our status, however, we have the remaining parts scheduled to be delivered in Deadhorse tomorrow, and the Compressor Mechanics arriving to site on Wednesday (Jan 8) to begin the reassembly process. Estimated time for rebuild is about 1 week. The major components needing repair on the VRU were Cylinder #3, all crossheads, and the crankshaft. Many minor components were also needed to complete the repair (lists attached). Below is the list of major components and the lead time we were getting from Siemens: New 11” Cylinder – 19 Working Weeks New Crossheads – 31 Working Weeks New Crankshaft – 22 Working Weeks Fortunately we were able to explore other options for each of these components. The Cylinder and crossheads were all sent down to Washington Iron Works (Texas…not Washington) to receive a metal spray buildup and re-boring procedure. They were also able to find a refurbished crankshaft in stock, so we were able to improve the lead time of those components by exploring other repair options. For the minor components like bushings, specialty seals and locknuts, oil pump, sprocket, etc, we saw lead times ranging from 4 weeks to 56 weeks. From there, we were able to refine the list into an “expedited needs” list in order to speed up the repair. This required us to go through and prioritize individual components to determine what can be reused temporarily vs required immediate components. See attached Siemens Quote 20409594 for the complete minor items list as compared to the Purchase Order 2024-00716 which reflects the “expedited needs” list. From there we continued to work with Siemens to improve those lead times as best we could. As stated at the beginning, we have procured the parts needed (almost to Deadhorse anyway) and are on track for the reassembly process to begin later this week. Please reach out with any other questions, otherwise I hope to have an updated VRU and flaring status beginning around January 15th. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Boman, Wade C (OGC) <wade.boman@alaska.gov> Sent: Monday, January 6, 2025 2:29 PM To: Zack Hundrup <ZHundrup@glacieroil.com> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Zack, CIE’s 10-422 gas disposition reports for all of October and all of November show gas being flared due to Badami’s VRU shutdown. This is a long time period for such flaring. Please provide the AOGCC an update on this matter, detailing the repairs, the reasons for the delayed repairs, and the current status of the VRU and the flaring. Thank you. Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 16, 2024 4:04 PM To: Zack Hundrup <ZHundrup@glacieroil.com>; Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Zack, Thanks for this update. No further questions at this time. Regards, Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Zack Hundrup <ZHundrup@glacieroil.com> Sent: Wednesday, October 16, 2024 4:00 PM To: Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Dave, I wanted to write and provide a little more information and context to the inspections yesterday and today. The Siemens Rotating Equipment Mechanic showed up on Tuesday afternoon (yesterday) and started going through the machine. As Lynnette stated, we have identified parts associated with the 3rd stage of this compressor that need to go out for repair, but he has also recommended that we proceed with a complete teardown and inspection to ensure that the failure hasn’t been translated into the crankshaft or other compressor stages. Tomorrow we will be flying the 3rd stage parts (cylinder, crosshead, connecting rod, etc) to Deadhorse and shipping them Lynden down to Dukowitz on the Peninsula. Meanwhile we will continue with the compressor teardown. My hope is that the expanded inspections will not identify more compromised components, and that the repaired components from Dukowitz will be completed by next week, about the same time we finish up with the remaining inspection. At that time we will schedule a Siemens team to return to Badami for the re-installation and balancing of the compressor. My best guess at this point is that we are a couple weeks away from a repaired compressor. The major variable that we can’t account for yet is the possibility of finding more damage as the inspection scope grows. Thank you and let me know if you have any other questions. Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 16, 2024 11:22 AM To: Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Lynette, Do you have an idea as to when the repairs will be completed, or is it too early to tell at this point? Please keep us up to date on the repair schedule. Thanks, Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Lynnette Peluso <lpeluso@glacieroil.com> Sent: Wednesday, October 16, 2024 9:44 AM To: Roby, David S (OGC) <dave.roby@alaska.gov>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Good morning, Mr. Roby, Savant Alaska had a cylinder technician come to site and assess the VRU. He has identified the required repairs and we are sourcing parts required to get the unit repaired and back online as soon as possible. Please let us know if you have any questions. Respectfully Lynnette Peluso Regulatory and Compliance Manager (907) 433-3829 - Office (801) 391-8971 - Cell Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd., Suite 510 Anchorage, AK 99503 From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 9, 2024 4:30 PM To: Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Thank you. Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Lynnette Peluso <lpeluso@glacieroil.com> Sent: Wednesday, October 9, 2024 4:22 PM To: Roby, David S (OGC) <dave.roby@alaska.gov>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Mr. Roby, Thank you for your email. To your question, the only way Savant would be able to reduce the volume of flaring is to repair the VRU and get it back online. We are and have been taking these steps by assessing the VRU for repair and sourcing new parts as quickly as we can. Respectfully Lynnette Peluso Regulatory and Compliance Manager (907) 433-3829 - Office (801) 391-8971 - Cell Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd., Suite 510 Anchorage, AK 99503 From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 9, 2024 3:53 PM To: Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event External Sender: Proceed with Caution Hi Lynette, The AOGCC can only pre-approve flaring/venting when associated with well testing prior to regular production. We will evaluate this incident in the course of our normal review of the gas disposition reports. Has CIE/Savant taken any steps to reduce the flared volume, and if so what are those steps? Regards, 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. You don't often get email from lpeluso@glacieroil.com. Learn why this is important Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Lynnette Peluso <lpeluso@glacieroil.com> Sent: Wednesday, October 9, 2024 3:18 PM To: Roby, David S (OGC) <dave.roby@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: Badami Emergency Flaring Event Good afternoon, Mr. Roby, Savant Alaska is requesting approval from the AOGCC to vent/flare gas at the Badami Unit for over one hour, in accordance with regulation 20 AAC 25.235. Earlier today, the Vapor Recovery Unit (VRU) at Badami suffered catastrophic damage to its 3rd stage due to a discharge valve failure. Savant is currently assessing the situation and working with vendors to source the necessary components to restore the VRU to operational status as soon as possible. However, the timeline for repairs is still uncertain. We will keep the Commission updated on the progress. It is estimated that approximately 300 MCFD of gas will be flared while the VRU remains offline. Maintaining facility operations is critical, as both the Badami Unit and the Point Thomson Unit rely on the Badami facility for the continued operation of the Nutaaq pipeline. Savant will document this event on the Gas Disposition Forms as required. We appreciate your assistance in this matter. For further information, please feel free to contact me at (801) 391-8971. Respectfully Lynnette Peluso Regulatory and Compliance Manager (907) 433-3829 - Office (801) 391-8971 - Cell Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd., Suite 510 Anchorage, AK 99503 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:David Pascal To:Boman, Wade C (OGC) Cc:Roby, David S (OGC); Regg, James B (OGC); Chmielowski, Jessie L C (OGC); Wilson, Greg C (OGC); Lau, Jack J (OGC); McLellan, Bryan J (OGC); Sherry, Patrick F (LAW); Coldiron, Samantha J (OGC); Zack Hundrup; Stan Porhola; Stephen Ratcliff Subject:Re: Response for approval request to flare/vent gas from Badami well B1-33 Date:Friday, January 31, 2025 9:13:26 AM Wade, Thank you for the prompt response and I appreciate it. Please see the answers below to your questions. Happy to answer additional questions and will be available via phone. I am heading to Houston over the weekend to meet with the board, but can have Zack Hundrup meet you in person as needed Regards David Pascal Chief Operating Officer | Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd. Suite 510 907-433-3822 (Direct)| 907-903-4164 (Mobile) 907-334-6745 (Main) | 907-334-6735 (Fax) Email:dpascal@glacieroil.com From: "Boman, Wade C (OGC)" <wade.boman@alaska.gov> Date: Thursday, January 30, 2025 at 3:24ථPM To: David Pascal <dpascal@glacieroil.com> Cc: "Roby, David S (OGC)" <dave.roby@alaska.gov>, "Regg, James B (OGC)" <jim.regg@alaska.gov>, "Chmielowski, Jessie L C (OGC)" <jessie.chmielowski@alaska.gov>, "Wilson, Greg C (OGC)" <greg.wilson@alaska.gov>, "Lau, Jack J (OGC)" <jack.lau@alaska.gov>, "McLellan, Bryan J (OGC)" <bryan.mclellan@alaska.gov>, "Sherry, Patrick F (LAW)" <patrick.sherry@alaska.gov>, "Coldiron, Samantha J (OGC)" <samantha.coldiron@alaska.gov>, Zack Hundrup <ZHundrup@glacieroil.com> Subject: Response for approval request to flare/vent gas from Badami well B1-33 External Sender: Proceed with Caution David, thank you for contacting us via email yesterday. The information is appreciated, as is the request for flaring/venting gas from producer B1- 33. However, the AOGCC cannot grant approval, as we are only authorized to pre-approve venting or flaring of gas for purposes of testing a well before being put online for regular production, as per 20 AAC 25.235(d)(6). The flaring/venting will be considered during our normal review of Badami’s monthly gas disposition reports. On that note, we appreciate Zack’s efforts in providing details of the ongoing VRU / compressor repairs. At this time we do have some additional questions: 1. What is the estimated timeline to replace (repair??) the compressor that recently suffered the catastrophic internal failure? We have two turbines at Badami, GT-A and GT-B, with one turbine always running while the other remains on standby for redundancy. In January, we initiated a control system upgrade on GT-A, which is currently in progress and scheduled for completion by the end of February. Unfortunately, while GT-A was undergoing work, GT-B suffered a catastrophic failure in the third-stage compressor of the engine package, leaving Badami without a functional turbine. GT-B will require a full core swap, a process expected to take several months. Given these circumstances, we have prioritized expediting the GT-A upgrade to bring it back online as soon as possible. Our turbines are among the oldest Solar Turbine packages in Alaska, making control system upgrades particularly complex due to their age. At this time, we anticipate completing the GT-A work by late February. 2. Why is it necessary to keep B1-33 on production? At present, there is no production or revenue from the Badami Unit due to the lack of turbine power, placing significant financial strain on Glacier. Turbine A is undergoing a scheduled control systems upgrade with upgrades scheduled to conclude late February. We confirmed that Turbine B has suffered a catastrophic failure in the third-stage compressor. The required replacement of the entire compressor/engine package will take up to several months. B1-33 is the highest-producing well at Badami, recently brought online last September, and bringing it back online is critical to ensuring that CIE can sustain operations at the Badami Unit during this period. a. If it is necessary to keep it online, does it need to be kept at full production, or can it be choked back (or flowed with minimal lift) to minimize flaring/venting of the produced gas? We will take all reasonable measures to minimize flaring/venting from B1-33. However, nitrogen lift is less effective than gas lift, which relies on compressor-powered turbines. As a result, production rates will naturally be lower under nitrogen lift coupled with the low GOR of the well 3. What are your plans for the other producers? Given their lower production rates, it is not cost-effective to utilize nitrogen for artificial lift on the other wells. Therefore, they will remain shut-in. 4. You state that diesel power generation is limited, how does this compare to the power that is normally generated by the turbine(s)? Each turbine generates approximately 9.5 MW of power, whereas the emergency diesel generators produce about 1.5 MW each. The emergency generators provide just enough power to sustain critical control systems, essential facility and camp components, and the Nutaaq pipeline, which also serves as a common carrier for Point Thomson’s production. 5. Our regulations require an operator to have the ability to shut off artificial lift to a well, as per 20 AAC 25.265(e). Do you have a plan on how you’re going to accomplish this when you switch to nitrogen for the lift gas? B1-33 has a fully operational SVS (Surface Safety System), which will remain in service during production. The existing gas lift supply lines will be connected to a nitrogen pumping unit equipped with a shut-off capability to ensure compliance with regulatory requirements in the event of an emergency. For reference and clarity, I included your initial email request to Jim Regg below, as I was not included in that email chain. Thank you. -Wade Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 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: David Pascal <dpascal@glacieroil.com> Sent: Wednesday, January 29, 2025 2:52 PM To: Regg, James B (OGC) <jim.regg@alaska.gov> Subject: Request for Approval to Flare/Vent Gas – Well Badami B1-33 Dear Jim, Cook Inlet Energy, LLC (CIE), as the operator of the Badami Unit, is requesting approval from the Commission to flare/vent gas from Well Badami B1-33 for a period of 30 days. Currently, both turbines at the Badami facility are offline. One turbine is undergoing major maintenance for control system upgrades, while the other has suffered sudden catastrophic internal failure leaving the unit with no power. The control system upgrades are expected to take approximately four weeks to complete and the facility is currently running on diesel power generators with limited capacity To ensure continued production from the unit from highest-producing well, B1-33, CIE proposes utilizing nitrogen gas for lift instead of regular gas and requests approval to vent/flare the associated gas during this period. The well’s gas-oil ratio (GOR) is approximately 275–300 scf/STB, and, depending on the lift efficiency, the estimated gas volume to be vented/flared ranges between 300–500 MCFD. CIE will document this event accordingly in the Gas Disposition Reports. We appreciate your consideration and assistance in this matter. Respectfully, David Pascal Chief Operating Officer | Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd. Suite 510 907-433-3822 (Direct)| 907-903-4164 (Mobile) 907-334-6745 (Main) | 907-334-6735 (Fax) Email:dpascal@glacieroil.com From:Zack Hundrup To:Boman, Wade C (OGC) Cc:David Pascal; Roby, David S (OGC); Lynnette Peluso Subject:RE: Badami Emergency Flaring Event Date:Tuesday, April 1, 2025 12:19:12 PM Attachments:image002.png Wade, Thanks for the phone call today and I’m seeing why there’s some confusion here now, and will do my best to explain clearly. David’s 30 day flaring request sent on 1/29/2025 at 2:52PM for flaring gas from the B1-33 Production Well is unrelated to the VRU compressor repairs. The power generation outage at Badami was the reason for the 30 day flaring request, and also impacted the VRU repair work, but was ultimately an unrelated request. After Turbine Generator GT-B failed, and we were faced with 2 weeks of no production while we completed the controls retrofit on Turbine Generator GT-A, we were trying to get creative with ideas for minimizing the financial impact of being productionless for 2 weeks. One avenue we explored is allowing Production Well B1-33 to produce through the facility (no gas lift available) utilizing the well’s existing stored energy, however, being on backup generators would have required us to flare all of the Produced Gas from that Well’s production. We did not end up producing any wells during our power/production outage and did not flare any gas per David’s flaring request. So in summary, the VRU repair/rebuild was completely separate from the turbine outage and flaring request. Any time a production well was producing, our injection gas compressors were online (omitting gas compressor shutdown/blowdown events) and recovering the produced gas to be used as fuel gas or lift gas. Any other residual gas that would have been recovered by the VRU was being sent to flare until the VRU compressor repair was completed at the end of February. Please feel free to call or email with any other questions. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Boman, Wade C (OGC) <wade.boman@alaska.gov> Sent: Friday, March 21, 2025 12:58 PM To: Zack Hundrup <ZHundrup@glacieroil.com> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Zack thank you for the summary of turbine GT-B’s repairs. It’s great to hear things are running smoothly. However, events include turbine GT-A being offline in the first place for its controller upgrade work, and the summary doesn’t mention that. My understanding is that the months long flaring was necessary because both turbines were down, from GT-B suffering its catastrophic 3rd stage failure while GT-A was already down for its controller upgrade. In your summary, could you please add/intersperse info on turbine GT-A? A line or two about losing all power and having to go to backup diesel generators would be good as well. It would also be good to see a total of all gas flared, which well was left online, why it was chosen, etc. With such an extended flaring event, any info you can include in the summary will help validate how the flaring gets categorized. Thanks. -Wade Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 From: Zack Hundrup <ZHundrup@glacieroil.com> Sent: Wednesday, March 19, 2025 4:57 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Wade, Attached is a summary for the VRU repair timeline and sequence of inspection/procurement/repair activities that took place. Please let me know if you have any follow up questions. As of today, the VRU is still running smoothly! Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Boman, Wade C (OGC) <wade.boman@alaska.gov> Sent: Monday, March 10, 2025 9:52 AM To: Zack Hundrup <ZHundrup@glacieroil.com> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Thanks for the update, Zack. And as we discussed on the phone, a final written report (submitted in a week or so) will be very helpful so sum up the event, the details, and the tribulations of the repair process. Thanks for you time on the phone. -Wade Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 From: Zack Hundrup <ZHundrup@glacieroil.com> Sent: Sunday, March 9, 2025 4:08 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, Sending a final update on the Badami VRU status. The compressor rebuild has been completed and the VRU at Badami is back online as of 2:10PM yesterday March 8. Flaring levels at Badami have returned to normal. Please reach out with any questions and I’ll be happy to answer them. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Thursday, January 23, 2025 2:35 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, Sending another status update. The compressor has been successfully realigned, cylinders, pistons and accessories reassembled and piping bolted up, but we rant into another problem that requires us to source another crankshaft. Currently, we have one in route to our service vendor in Texas for measurement and inspection prior to shipment to site. I expect we will have visibility on the crankshaft’s fitness for service by mid next week. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Monday, January 13, 2025 1:50 PM To: 'Boman, Wade C (OGC)' <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; 'Roby, David S (OGC)' <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, I wanted to give you a status update for the ongoing VRU repair work at Badami. Last week (Thursday/Friday) when attempting to install the new crankshaft, it was discovered that the compressor frame needs a realignment. This required the mobilization of additional alignment tools from Texas which we have expedited and will be delivered to site at the end of today. We are still at risk for “additional discoveries” as they realign the compressor and continue with the reassembly process, but I’ll be sure to give you impact updates as I receive them. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Zack Hundrup Sent: Monday, January 6, 2025 3:28 PM To: Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Wade, Yes the VRU repair unfortunately took longer than we had hoped, mainly due to repair parts availability through Siemens and other aftermarket channels. To quickly summarize our status, however, we have the remaining parts scheduled to be delivered in Deadhorse tomorrow, and the Compressor Mechanics arriving to site on Wednesday (Jan 8) to begin the reassembly process. Estimated time for rebuild is about 1 week. The major components needing repair on the VRU were Cylinder #3, all crossheads, and the crankshaft. Many minor components were also needed to complete the repair (lists attached). Below is the list of major components and the lead time we were getting from Siemens: New 11” Cylinder – 19 Working Weeks New Crossheads – 31 Working Weeks New Crankshaft – 22 Working Weeks Fortunately we were able to explore other options for each of these components. The Cylinder and crossheads were all sent down to Washington Iron Works (Texas…not Washington) to receive a metal spray buildup and re-boring procedure. They were also able to find a refurbished crankshaft in stock, so we were able to improve the lead time of those components by exploring other repair options. For the minor components like bushings, specialty seals and locknuts, oil pump, sprocket, etc, we saw lead times ranging from 4 weeks to 56 weeks. From there, we were able to refine the list into an “expedited needs” list in order to speed up the repair. This required us to go through and prioritize individual components to determine what can be reused temporarily vs required immediate components. See attached Siemens Quote 20409594 for the complete minor items list as compared to the Purchase Order 2024-00716 which reflects the “expedited needs” list. From there we continued to work with Siemens to improve those lead times as best we could. As stated at the beginning, we have procured the parts needed (almost to Deadhorse anyway) and are on track for the reassembly process to begin later this week. Please reach out with any other questions, otherwise I hope to have an updated VRU and flaring status beginning around January 15th. Thank you Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Boman, Wade C (OGC) <wade.boman@alaska.gov> Sent: Monday, January 6, 2025 2:29 PM To: Zack Hundrup <ZHundrup@glacieroil.com> Cc: David Pascal <dpascal@glacieroil.com>; Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Zack, CIE’s 10-422 gas disposition reports for all of October and all of November show gas being flared due to Badami’s VRU shutdown. This is a long time period for such flaring. Please provide the AOGCC an update on this matter, detailing the repairs, the reasons for the delayed repairs, and the current status of the VRU and the flaring. Thank you. Wade Boman Petroleum Engineer Alaska Oil & Gas Conservation Commission 333 W 7th Ave, Anchorage, AK 99501 wade.boman@alaska.gov office: 907-793-1238 cell: 907-687-4468 From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 16, 2024 4:04 PM To: Zack Hundrup <ZHundrup@glacieroil.com>; Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Zack, Thanks for this update. No further questions at this time. Regards, Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Zack Hundrup <ZHundrup@glacieroil.com> Sent: Wednesday, October 16, 2024 4:00 PM To: Roby, David S (OGC) <dave.roby@alaska.gov>; Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Dave, I wanted to write and provide a little more information and context to the inspections yesterday and today. The Siemens Rotating Equipment Mechanic showed up on Tuesday afternoon (yesterday) and started going through the machine. As Lynnette stated, we have identified parts associated with the 3rd stage of this compressor that need to go out for repair, but he has also recommended that we proceed with a complete teardown and inspection to ensure that the failure hasn’t been translated into the crankshaft or other compressor stages. Tomorrow we will be flying the 3rd stage parts (cylinder, crosshead, connecting rod, etc) to Deadhorse and shipping them Lynden down to Dukowitz on the Peninsula. Meanwhile we will continue with the compressor teardown. My hope is that the expanded inspections will not identify more compromised components, and that the repaired components from Dukowitz will be completed by next week, about the same time we finish up with the remaining inspection. At that time we will schedule a Siemens team to return to Badami for the re- installation and balancing of the compressor. My best guess at this point is that we are a couple weeks away from a repaired compressor. The major variable that we can’t account for yet is the possibility of finding more damage as the inspection scope grows. Thank you and let me know if you have any other questions. Zack Hundrup Production & Facilities Manager Glacier Oil & Gas 188 W. Northern Lights Blvd. Suite 510 Anchorage, AK 99503 Office: 907-433-3819 Cell: 907-830-2655 zhundrup@glacieroil.com From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 16, 2024 11:22 AM To: Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Lynette, Do you have an idea as to when the repairs will be completed, or is it too early to tell at this point? Please keep us up to date on the repair schedule. Thanks, Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Lynnette Peluso <lpeluso@glacieroil.com> Sent: Wednesday, October 16, 2024 9:44 AM To: Roby, David S (OGC) <dave.roby@alaska.gov>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Good morning, Mr. Roby, Savant Alaska had a cylinder technician come to site and assess the VRU. He has identified the required repairs and we are sourcing parts required to get the unit repaired and back online as soon as possible. Please let us know if you have any questions. Respectfully Lynnette Peluso Regulatory and Compliance Manager (907) 433-3829 - Office (801) 391-8971 - Cell Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd., Suite 510 Anchorage, AK 99503 From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 9, 2024 4:30 PM To: Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Thank you. Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Lynnette Peluso <lpeluso@glacieroil.com> Sent: Wednesday, October 9, 2024 4:22 PM To: Roby, David S (OGC) <dave.roby@alaska.gov>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event Hi Mr. Roby, Thank you for your email. To your question, the only way Savant would be able to reduce the volume of flaring is to repair the VRU and get it back online. We are and have been taking these steps by assessing the VRU for repair and sourcing new parts as quickly as we can. Respectfully Lynnette Peluso Regulatory and Compliance Manager (907) 433-3829 - Office (801) 391-8971 - Cell Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd., Suite 510 Anchorage, AK 99503 From: Roby, David S (OGC) <dave.roby@alaska.gov> Sent: Wednesday, October 9, 2024 3:53 PM To: Lynnette Peluso <lpeluso@glacieroil.com>; Boman, Wade C (OGC) <wade.boman@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: RE: Badami Emergency Flaring Event External Sender: Proceed with Caution Hi Lynette, The AOGCC can only pre-approve flaring/venting when associated with well testing prior to regular production. We will evaluate this incident in the course of our normal review of the gas disposition reports. Has CIE/Savant taken any steps to reduce the flared volume, and if so what are those 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. You don't often get email from lpeluso@glacieroil.com. Learn why this is important steps? Regards, Dave Roby Senior Reservoir Engineer Alaska Oil and Gas Conservation Commission 907-793-1232 From: Lynnette Peluso <lpeluso@glacieroil.com> Sent: Wednesday, October 9, 2024 3:18 PM To: Roby, David S (OGC) <dave.roby@alaska.gov> Cc: David Pascal <dpascal@glacieroil.com>; Zack Hundrup <ZHundrup@glacieroil.com> Subject: Badami Emergency Flaring Event Good afternoon, Mr. Roby, Savant Alaska is requesting approval from the AOGCC to vent/flare gas at the Badami Unit for over one hour, in accordance with regulation 20 AAC 25.235. Earlier today, the Vapor Recovery Unit (VRU) at Badami suffered catastrophic damage to its 3rd stage due to a discharge valve failure. Savant is currently assessing the situation and working with vendors to source the necessary components to restore the VRU to operational status as soon as possible. However, the timeline for repairs is still uncertain. We will keep the Commission updated on the progress. It is estimated that approximately 300 MCFD of gas will be flared while the VRU remains offline. Maintaining facility operations is critical, as both the Badami Unit and the Point Thomson Unit rely on the Badami facility for the continued operation of the Nutaaq pipeline. Savant will document this event on the Gas Disposition Forms as required. We appreciate your assistance in this matter. For further information, please feel free to contact me at (801) 391-8971. Respectfully Lynnette Peluso Regulatory and Compliance Manager (907) 433-3829 - Office (801) 391-8971 - Cell Glacier Oil and Gas Corporation 188 W. Northern Lights Blvd., Suite 510 Anchorage, AK 99503 Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 10/2024 0 3,050 21 9,377 403 40,284 53,135 19,113 Purchased gas is from Endicott Pipeline. Badami 60100 95.43 Badami, Oil Undefined 60150 4.57 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2024.11.20 09:41:59 -09'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume13667010/1/2024 116525 0290000019 10/6/2024 15:54 00:00 10/7/2024 P 121 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/7/2024 00:00 00:00 10/8/2024 P 359 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/8/2024 00:00 00:00 10/9/2024 P 368 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/9/2024 00:00 00:00 10/10/2024 P 352 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/10/2024 00:00 00:00 10/11/2024 P 348 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/11/2024 00:00 00:00 10/12/2024 P 371 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/12/2024 00:00 00:00 10/13/2024 P 353 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/13/2024 00:00 00:00 10/14/2024 P 351 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/14/2024 00:00 00:00 10/15/2024 P 376 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/15/2024 00:00 00:00 10/16/2024 P 394 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/16/2024 00:00 00:00 10/17/2024 P 372 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/17/2024 00:00 00:00 10/18/2024 P 382 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/18/2024 00:00 00:00 10/19/2024 P 387 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/19/2024 00:00 00:00 10/20/2024 P 414 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/20/2024 00:00 00:00 10/21/2024 P 363 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/21/2024 00:00 00:00 10/22/2024 P 339 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/22/2024 00:00 00:00 10/23/2024 P 329 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/23/2024 00:00 00:00 10/24/2024 P 346 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/24/2024 00:00 00:00 10/25/2024 P 360 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/25/2024 00:00 00:00 10/26/2024 P 352 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/26/2024 00:00 00:00 10/27/2024 P 350 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/27/2024 00:00 00:00 10/28/2024 P 358 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/28/2024 00:00 17:42 10/28/2024 P 327 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/28/2024 18:48 00:00 10/29/2024 P 98 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/29/2024 00:00 00:00 10/30/2024 P 429 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/30/2024 00:00 00:00 10/31/2024 P 413 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 10/1/2024 116525 0290000019 10/31/2024 00:00 00:00 11/1/2024 P 365 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 11/2024 0 536 10 11,139 390 27,896 39,971 24,785 Purchased gas is from Endicott Pipeline. Badami 60100 95.70 Badami, Oil Undefined 60150 4.30 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2024.12.18 08:22:30 -09'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume13667011/1/2024 116525 0290000019 11/1/2024 0:00 0:00 11/2/2024 P 383 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/2/2024 0:00 0:00 11/3/2024 P 366 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/3/2024 0:00 0:00 11/4/2024 P 367 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/4/2024 0:00 0:00 11/5/2024 P 362 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/5/2024 0:00 0:00 11/6/2024 P 336 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/6/2024 0:00 0:00 11/7/2024 P 364 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/7/2024 0:00 0:00 11/8/2024 P 336 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/8/2024 0:00 0:00 11/9/2024 P 370 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/9/2024 0:00 0:00 11/10/2024 P 375 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/10/2024 0:00 0:00 11/11/2024 P 345 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/11/2024 0:00 0:00 11/12/2024 P 529 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/12/2024 0:00 0:00 11/13/2024 P 380 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/13/2024 0:00 0:00 11/14/2024 P 358 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/14/2024 0:00 0:00 11/15/2024 P 366 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/15/2024 0:00 0:00 11/16/2024 P 383 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/16/2024 0:00 0:00 11/17/2024 P 392 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/17/2024 0:00 7:18 11/17/2024 P 120 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/17/2024 8:12 0:00 11/18/2024 P 271 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/18/2024 0:00 0:00 11/19/2024 P 438 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/19/2024 0:00 0:00 11/20/2024 P 435 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/20/2024 0:00 0:00 11/21/2024 P 26 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/21/2024 0:00 0:00 11/22/2024 P 360 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/22/2024 0:00 0:00 11/23/2024 P 353 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/23/2024 0:00 0:00 11/24/2024 P 369 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/24/2024 0:00 0:00 11/25/2024 P 352 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/25/2024 0:00 0:00 11/26/2024 P 369 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/26/2024 0:00 0:00 11/27/2024 P 434 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/27/2024 0:00 0:00 11/28/2024 P 411 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/28/2024 0:00 0:00 11/29/2024 P 437 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/29/2024 0:00 0:00 11/30/2024 P 372 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 11/1/2024 116525 0290000019 11/30/2024 0:00 00:00 12/1/2024 P 380 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 12/2024 0 450 0 11,459 403 37,121 49,433 29,950 Purchased gas is from Endicott Pipeline. Badami 60100 94.55 Badami, Oil Undefined 60150 5.45 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.01.20 10:05:21 -09'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume13667012/1/2024 116525 0290000019 12/1/2024 0:00 0:00 12/31/2024 P 11459 VRU shutdown for maintenance, cuasing vapor gas to be flared Continue with maintenance until VRU is back online GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 01/2025 0 304 15 9,455 403 36,680 46,857 22,951 Purchased gas is from Endicott Pipeline. Badami 60100 94.90 Badami, Oil Undefined 60150 5.10 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.02.18 10:53:07 -09'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366701/1/2025 116525 0290000019 01/01/25 00:00 08:30 01/12/2025 P 4898 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/12/2025 08:36 00:00 01/12/2025 P 11 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/13/2025 00:00 06:18 01/13/2025 P 4 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/13/2025 06:24 18:06 01/13/2025 P 7 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/13/2025 18:30 00:00 01/14/2025 P 4 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/14/2025 00:00 07:30 01/14/2025 P 105 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/14/2025 08:00 09:42 01/14/2025 P 25 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/14/2025 09:48 12:18 01/14/2025 P 36 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/14/2025 13:12 00:00 01/15/2025 P 166 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 1/15/2025 0:00 0:36 1/26/2025 P 3426 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 1/26/2025 09:24 00:00 1/30/2025 U 617 Plant BESD Continue maintenance to bring facility back online. 1/1/2025 116525 0290000019 01/30/2025 00:00 01:54 01/30/2025 P 59 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 1/1/2025 116525 0290000019 01/30/2025 02:30 00:00 2/1/2025 P 97 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 02/2025 0 745 0 6,587 364 5,047 12,743 20,345 Purchased gas is from Endicott Pipeline. Badami 60100 96.36 Badami, Oil Undefined 60150 3.64 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.03.18 12:07:21 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366702/1/2025 116525 0290000019 02/01/25 00:00 00:00 02/28/2025 P 6587 VRU shutdown for maintenance, causing vapor gas to be flared.VRU shutdown for maintenance, causing vapor gas to be flared. GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 03/2025 0 1,332 168 2,784 403 36,546 41,233 21,344 Purchased gas is from Endicott Pipeline. Badami 60100 96.47 Badami, Oil Undefined 60150 3.53 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.04.16 14:31:29 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366703/1/2025 116525 0290000019 3/1/2025 0:00 14:24 3/8/2025 P 2539 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 3/1/2025 116525 0290000019 03/12/2025 14:54 17:18 03/12/2025 P 45 Shut VRU because blow case wasnt draining Shut down VRU 3/1/2025 116525 0290000019 03/23/2025 05:30 08:12 03/23/2025 U 27 Compressor shutdown causing gas to be flared.Bring offline compressor online. 3/1/2025 116525 0290000019 03/25/2025 16:18 18:42 03/25/2025 U 13 Gas compressor shut down, vented gas to flare.Bring compressor back online. 3/1/2025 116525 0290000019 03/28/2025 15:54 18:30 03/28/2025 U 160 BESD Restart plant GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 04/2025 0 536 3 5,447 390 36,101 42,477 21,380 Purchased gas is from Endicott Pipeline. Badami 60100 96.31 Badami, Oil Undefined 60150 3.69 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.05.19 15:02:26 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366704/1/2025 116525 0290000019 04/14/2025 19:00 00:00 4/30/2025 U 5447 VRU shutdown for maintenance, causing vapor gas to be flared.Troubleshoot and repair ongoing GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 05/2025 0 526 0 8,792 403 26,929 36,650 41,003 Purchased gas is from Endicott Pipeline. Badami 60100 96.44 Badami, Oil Undefined 60150 3.56 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.06.18 10:42:13 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366705/1/2025 116525 0290000019 5/1/2025 00:00 00:00 5/31/2025 P 8792 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20.For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety:MCF 13. Other (see instructions) Lease Use:MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation:MCF 15. NGL Gas Equivalent Waste:MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 06/2025 0 58,077 4 8,081 390 12,172 78,723 37,709 Purchased gas is from Endicott Pipeline. Badami 60100 95.83 Badami, Oil Undefined 60150 4.17 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.07.20 13:53:23 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume136670 6/1/2025 116525 0290000019 6/1/2025 00:00 11:36 06/05/2025 P 1369.7 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 6/1/2025 116525 0290000019 06/05/2025 18:00 00:00 6/28/2025 P 6421.8 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. 6/1/2025 116525 0290000019 06/28/2025 00:00 08:06 06/28/2025 U 109 Plant BESD M700 fire detection Inspected M700. No fire. Restarted facility 6/1/2025 116525 0290000019 06/28/2025 15:12 00:00 6/29/2025 U 61 Plant BESD M700 fire detection Inspected M700. No fire. Restarted facility 6/1/2025 116525 0290000019 6/29/2025 00:00 00:00 7/1/2025 P 119 VRU shutdown for maintenance, causing vapor gas to be flared.Continue with maintenance on VRU until back online. GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 07/2025 0 1,169 122 2,727 403 29,815 34,236 22,769 Purchased gas is from Endicott Pipeline. Badami 60100 94.57 Badami, Oil Undefined 60150 5.43 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.08.14 11:48:05 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366707/1/2025 116525 0290000019 07/01/2025 00:00 00:00 07/02/2025 P 337 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 7/1/2025 116525 0290000019 07/02/2025 00:00 09:54 07/02/2025 P 82 VRU shutdown for maintenance, causing vapor gas to be flared. Continue with maintenance on VRU until back online. 7/1/2025 116525 0290000019 07/18/2025 10:12 20:24 07/18/2025 P 2 Shut down VRU for inspection on 3rd stage and repair Complete inspection and restart VRU 7/1/2025 116525 0290000019 07/19/2025 16:54 17:24 07/20/2025 U 219 VRU shut down for repairs VRU repairs ongoing. 7/1/2025 116525 0290000019 07/21/2025 09:30 19:18 07/21/2025 U 84 VRU shut down for repairs VRU repairs completed and restart compressor. 7/1/2025 116525 0290000019 07/22/2025 18:30 00:00 07/23/2025 U 49 VRU shut down for maintenance, casuing vapor gas to be flared Continue with maintenance on VRU until back online. 7/1/2025 116525 0290000019 07/23/2025 00:00 00:00 08/01/2025 U 1954 the vapor recovery unit compressor was down for maintenance restarted the compressor after maintenance was completed GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR Percent Comm.Comm. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume.6. Sold Pool Name Pool Code 7. Reinjected 8. Flared or vented 1 hour or less 12. Fuel gas used in lease operations AOGCC Use Only Authorization >1 hr: 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 11. Assist Gas Safety: MCF 13. Other (see instructions) Lease Use: MCF 14. TOTAL VOLUME (ITEMS 6-13) Conservation: MCF 15. NGL Gas Equivalent Waste: MCF 16. Purchased gas 1. Facility Number 2. Facility Name 3. Field 4. Operator 5. Month/Year of Disposition Reviewed by: COMMISSIONER Authorized Name and Digital Signature with date: I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Phone: Contact Email: Note: All volumes must be corrected to pressure of 14.65 psia and to a temperature of 60° F. Authority 20 AAC 25.235. Revision? Date of Revision:Title: 19. Remarks: 17. Transferred from: 18. Transferred to: (Express as a negative #) Form10Ͳ422Revised10/2021 20AAC25.235 SubmitinPDFformatto aogcc.reporting@alaska.gov 290000019 B1 Badami Cook Inlet Energy 08/2025 0 1,053 77 5,124 403 17,691 24,348 29,785 Purchased gas is from Endicott Pipeline. Badami 60100 95.35 Badami, Oil Undefined 60150 4.65 Chief Operating Officer (907) 334-6745 dpascal@glacieroil.comDavid Pascal Digitally signed by David Pascal Date: 2025.09.17 08:24:58 -08'00' RptDate OpNo FacilityNo Date Flared Start Time Ending Time End Date Planned MCF Description of Flaring Event Action Taken to Minimize Volume1366708/1/2025 116525 0290000019 8/1/2025 00:00 10:30 08/21/2025 P 5124 the vapor recovery unit compressor was down for maintenance restart the compressor after maintenance is completed GAS DISPOSITION IMPORT FORM FOR FLARING EVENTS GREATER THAN 1 HOUR