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HomeMy WebLinkAboutAIO 046AIO 46 Southern Miluveach Unit Kuparuk River Oil Pool North Slope Borough, Alaska 1. June 3, 2024 Mustang Application for Area Injection Order for the Kuparuk Oil Pool 2. July 12, 2024 AOGCC Notice of Public Hearing and Affidavit 3. September 25, 2025 Mustang Request for Verbal Approval STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF Mustang Holding, LLC to gain authorization to inject fluids for pressure maintenance and enhanced recovery of hydrocarbons in the Southern Miluveach Unit, Kuparuk River Oil Pool ) ) ) ) ) ) ) Area Injection Order 46 Kuparuk River Oil Pool Southern Miluveach Unit North Slope Borough, Alaska February 11, 2026 ERRATA NOTICE The Alaska Oil and Gas Conservation Commission (AOGCC) notes that Area Injection Order 46 (AIO 46) had an error in one rule. Namely, the second paragraph of Rule 2, which states: In lieu of the packer depth requirements under 20 AAC 25.412(b), the packer/isolation equipment for injection wells may be located above 200 feet measured depth (MD) from above the top of the perforations/open interval but must be located below the base of the confining zone and shall have outer casing cement volume sufficient to place a minimum of 300 feet MD above the planned packer depth. Mustang Holding LLC had requested that the packer could be located above 200 feet measured depth from the top of the perforated/open interval where injection occurs but that it must be located below the top of the confining zone, but AIO 46 inadvertently stated the packer had to be located below the base of the confining zone. The rule that Mustang proposed is a common rule in injection orders issued by the AOGCC with the setting depth requirement being below the top of the confining zone. As such the order will be corrected and this correction will be reflected in a revised AIO 46 to be issued by the AOGCC. DONE at Anchorage, Alaska and dated February 11, 2026. Jessie L. Chmielowski Gregory C. Wilson Thomas W. McKay Commissioner Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2026.02.11 08:31:10 -09'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2026.02.11 08:38:57 -09'00' Thomas W. McKay Digitally signed by Thomas W. McKay Date: 2026.02.11 13:01:36 -09'00' STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF Mustang Holding LLC to gain authorization to inject fluids for pressure maintenance and enhanced recovery of hydrocarbons in the Southern Miluveach Unit, Kuparuk River Oil Pool ) ) ) ) ) ) ) ) ) Area Injection Order 46 Corrected Docket Number: AIO-24-018 Southern Miluveach Unit Kuparuk River Oil Pool North Slope Borough, Alaska February 11, 2026 Nunc pro tunc September 25, 2025 IT APPEARING THAT: 1. By application dated June 3, 2024 (Application), Mustang Holding LLC (MHLLC), in its capacity of operator of the Southern Miluveach Unit (SMU), requested an Area Injection Order (AIO) authorizing injection of fluids for pressure maintenance and enhanced recovery of hydrocarbons from the Kuparuk River Oil Pool (KROP) within the SMU (the portion of the KROP within the SMU and the Affected Area of this order are referred to as the SMU-KROP). 2. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) tentatively scheduled a public hearing for August 27, 2024. On July 12, 2024, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website and electronically transmitted the notice to all persons on the AOGCC’s email distribution list. On July 17, 2024, the notice was published in the ANCHORAGE DAILY NEWS. 3. The AOGCC received no comments or requests to hold the proposed hearing. The hearing was vacated. 4. MHLLC submitted updated information mid-September 2025, concerning fracture gradients and injection pressures, that was taken into consideration as an accessory to the Application. 5. MHLLC’s application, supplemental information, and AOGCC’s public records provide sufficient information to make an informed decision. FINDINGS: 1. Order History Area Injection Order 42 (AIO 42), issued June 12, 2019, defined rules governing the injection of fluids for pressure maintenance and enhanced recovery of hydrocarbons for the SMU- KROP, with Brooks Range Petroleum Corporation (BRPC) as the designated operator. On December 4, 2020, MHLLC succeeded BRPC as operator of the SMU. In accordance with 20 AAC 25.402(i) AIO 42 automatically expired on June 12, 2021, due to injection not starting prior to that date. AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 2 of 11 2. Affected Area The Affected Area lies onshore within the SMU, North Slope Borough, Alaska, about 45 miles west-southwest of Prudhoe Bay. The SMU-KROP is being developed from the SMU Mustang drill site, a gravel pad located in Section 2, Township (T) 10N, Range (R) 7E, Umiat Meridian (UM). 3. Owners and Landowners Mustang Holding, LLC is the operator of the SMU. Working interest owners are Mustang Holding, LLC, Mustang Operations Center 1, LLC, Mustang Investment Holdings, LLC, and Alaska Venture Capital Group, LLC. The State of Alaska, Department of Natural Resources is the surface and subsurface landowner of the Affected Area. 4. Exploration, Delineation, and Production History During January 2012, BRPC drilled the discovery well—North Tarn 1A (Permit to Drill No. 211-174)—into the Kuparuk Formation (Kuparuk) in Section 2, T10N, R7E, UM, and encountered oil indicators. This discovery was confirmed by the Mustang 1 exploratory well (Permit to Drill No. 212-174) in February 2012. To date, five wells have been logged across the Kuparuk reservoir within the SMU. Three-dimensional seismic survey and well log data have been used to determine the geologic structure and reservoir distribution for the SMU-KROP. Well log, well test, and Operator- supplied information were used to establish reservoir and fluid properties for the pool. 5. Pool Identification The KROP, defined in Conservation Order 432F (CO 432F), is the accumulation of oil that is common to and correlates with the accumulation found in the Atlantic Richfield Company West Sak River State No. 1 well between the depths of 6,474- and 6,880-feet MD (Permit to Drill No. 171-003). Along with the SMU, portions of this expansive oil pool also lie within the adjoining Kuparuk River Unit (KRU) and the nearby Milne Point Unit (MPU). 6. Geology a. Structure: The Colville Anticline is the regional structural trap for the SMU-KROP. The SMU lies on a portion of that anticline. Within the SMU, the SMU-KROP ranges in depth from about -5,800 to -6,400 feet TVDSS.1 b. Stratigraphy: Within the SMU, Cretaceous-aged reservoir sandstones within the Kuparuk Formation are informally divided into two intervals, the Kuparuk C-Sands (C-Sand) and the underlying Kuparuk A-Sands (A-Sand). The C-Sand consists of bioturbated and burrowed glauconitic sandstones, shaley sandstones, siltstones, and shales. These sediments were most likely deposited in an offshore marine-shelf setting. The thickness of the C-Sand interval varies from 0 to 25 feet within the SMU, and this variation is believed to have been influenced by syndepositional fault activity. 1 To avoid confusion, when depths presented represent true vertical depth below sea level (subsea), the footage will be preceded by a minus sign and followed by the acronym TVDSS (e.g., 5,800 feet true vertical subsea is depicted as -5,800 feet TVDSS). AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 3 of 11 The regional Lower Cretaceous Unconformity (LCU) separates the C-Sand from the underlying A-Sands, and it progressively truncates the A-Sand intervals from southeast to northwest across the SMU. Within the SMU, the A-Sands consist of two upward-coarsening intervals that were deposited in an offshore marine setting. Here, the A-Sands are subdivided into intervals informally named “A4” and “A3”, in descending order. The thickness of A4 varies from 0 to 36 feet from northwest to southeast across the SMU. Interval A3 varies from 2 to 40 feet in thickness from northwest to southeast within the SMU. The thickness trends of the A-Sands do not appear to be influenced by faulting or the present-day structure. c. Rock Properties: The C-Sand comprises fine- to coarse-grained quartzose sandstone that contains up to 40 percent glauconite and is commonly cemented with secondary siderite. Porosity averages 22 percent. Permeability ranges from 50 to several hundred millidarcies (md), averaging 70 md. Water saturation with the C-Sand can be as low as 20 percent. The underlying A-Sand consists of very fine- to fined-grained sandstone interbedded with siltstone and mudstone. Porosity averages 22 percent. Permeability ranges from less than 10 to 100 md, averaging 30 md. Water saturation in the A-Sand can be as high as 40 percent. d. Faults: Two sets of faults cut the Colville Anticline within the SMU; one set trends north-northeast, and the other set trends west-northwest. The vertical displacement of faults cutting the proposed SMU-KROP ranges up to 85 feet but is generally less than 30 feet. Because of the relatively thin-bedded nature of reservoir sands within the proposed pool, some faults may act as localized flow barriers and may result in reservoir compartments. e. Trap Configuration and Seals: Well log and seismic information indicate that structural dip controls the hydrocarbon accumulation within the SMU-KROP. The overlying Kalubik and HRZ Shales form the top seal for the oil accumulation within the proposed pool. 7. Reservoir Continuity Many faults cut the KROP within the Affected Area. As mapped using 3D seismic, these faults have vertical displacements that are generally less than 30 feet. However, some compartmentalization of the pool is expected due to the thin nature of the reservoir strata, especially in the western portion of the Affected Area. 8. Reservoir Fluid Contacts To date, no hydrocarbon contacts have been encountered in the Kuparuk reservoirs within the Affected Area. 9. Reservoir Fluid Properties In the SMU-KROP area, the initial producing gas oil ratio (GOR) is estimated to be about 600 standard cubic feet per stock tank barrel (scf/stb). The API gravity of oil recovered from the proposed pool measured about 24° in the North Tarn 1A well. Due to injection activities in AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 4 of 11 the KROP within the adjoining KRU, pressure in the SMU-KROP measured as high as 3,850 psi. Bubble-point pressure is estimated to be 1,930 psi. The oil formation volume factor is estimated at 1.2 reservoir barrels per stock tank barrel of oil. 10. In-Place and Recoverable Volume Estimates (based on reservoir modeling predictions) 11. Future Development Plans MHLLC has plans to develop the pool from the existing SMU “Mustang” drill site, through multiple phases. Development includes reinstallation of production facilities, reconnecting the Mustang Pipeline to the Alpine Pipeline for access to the Trans-Alaska Pipeline System (TAPS), re-entering existing wells, and drilling additional wells. Well stock will involve up to 11 horizontal or vertical development (production) wells and up to 10 horizontal or vertical service (injection) wells, with most production wells trending north-south, parallel to the direction of the major fault patterns that cut the pool. Some producers will produce from both the C-Sand and the A-Sand. Injection wells may be placed to create alternating rows of producer-injector pairs for line drive flood patterns. The length of the horizontal sections of wells are planned to range up to 6000 feet. Depending upon reservoir quality, some producers or injectors may be hydraulically fractured to enhance productivity and to enhance vertical injection sweep. 12. Confining Layers for Injection Approximately 260 feet of Kalubik and HRZ shales overlie the SMU-KROP. Several hundred feet of shales assigned to the Miluveach and Kingak Formations underlie the SMU-KROP. 13. Fracture Propagation and Confinement Kuparuk Formation fracture closure pressure was found via pressure decline analysis to be 0.67 psi/ft * 6,100’ TVD = 4,087 psi. Via history match of a frac in an offset well, it was found that an increase of 1,000 psi above the Kuparuk closure pressure of 4,087 psi was needed before excessive fracture height develops into confining shales: 4,087 psi + 1,000 psi = 5,087 psi. The confining shale fracture gradient is therefore 5,087 psi / 6,100’ = 0.834 psi/ft. A fracture propagation model showed that, at the planned estimated maximum injection pressures for miscible water alternating gas (MWAG) or immiscible water alternating gas (IWAG) service, fractures would form in the injection interval but would not initiate into or 2 The acronym MMSTB signifies millions of stock tank barrels. Hydrocarbon Resource Estimated Volume2 Original Oil in Place (OOIP) 70 MMSTB Primary Recovery (10-15% OOIP) 7-10.5 MMSTB Primary + Water Injection (10-25% OOIP incremental) 7-17.5 MMSTB Incremental Primary + Water and Lean Gas Injection (1-5% OOIP incremental) 0.7-3.5 MMSTB Incremental Primary + Water and Enriched Gas Injection (3-15% OOIP incremental) 2.1-10.5 MMSTB Incremental AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 5 of 11 propagate through confining strata. For fractures to propagate into the confining layers, surface pressures during injection would have to exceed 2,391 psi with water and 4,477 psi with gas. 14. Injection Pressures 3 Maximum injection pressures at the wellhead, for both water and gas, will be below the confining zone fracture gradient of 0.834 psi/ft. For water, a maximum of 2,300 psi will be well below the 2,391 psi that corresponds to the confining zone frac gradient. For gas, a maximum of 4,400 psi will be well below the 4,477 psi that corresponds to the confining zone frac gradient. Average injection pressure on water is expected to be ~1,400 psi, very near the surface water injection pressure of 1,391 psi that corresponds to the Kuparuk fracture gradient of 0.67 psi/ft. 15. Injection Rates The anticipated peak daily injection rate for individual wells within the SMU-KROP is 6,000 barrels of water per day (BWPD) and 6 million standard cubic feet of gas per day (MMSCFD). 16. Freshwater Strata No porosity logs have been recorded across the shallow geologic section within the SMU. The former operator, BPRC, commissioned a formation water salinity determination using logs from well West Sak 25590-15, which is located about 3 miles east of the SMU development gravel pad. Well log calculations suggest that aquifers shallower than a depth of about 2,300 feet MD (-2,140 feet TVDSS) within the SMU may contain native formation waters that have total dissolved solids concentrations of less than 10,000 mg/l. However, MHLLC will isolate these aquifers by setting the surface casing at -2,500 feet TVDSS and cementing it to surface. 17. Aquifer Exemption Order MHLLC’s Application contends that the US Environmental Protection Agency’s (EPA) Aquifer Exemption for the Kuparuk River Unit (KRU), defined in 1984 by 40 CFR 147.102(b)(3), still applies to the current area of the SMU. The exact boundary of that Aquifer Exemption is currently under review by the EPA. CONCLUSIONS: 1. An Area Injection Order is appropriate to authorize the injection of fluids for enhanced oil recovery purposes in the SMU-KROP within the SMU. 2. The Aquifer Exemption for the KRU—as described in Federal Regulation 40 CFR147.102(b)(3)—currently applies to the SMU-KROP. However, if subsequent EPA review determines that the SMU-KROP falls outside of the affected area for the KRU Aquifer Exemption, MHLLC must apply for a new Aquifer Exemption. 3. Reservoir simulation modeling shows water and water-alternating-gas injection (both immiscible water alternating gas (IWAG) and miscible water alternating gas (MWAG)) into 3 For fracture gradient calculations, 0.442 psi/ft was used for water, 0.1 psi/ft for gas, and -6,100’ TVDSS for depth. AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 6 of 11 the SMU-KROP will provide a substantial EOR benefit over primary recovery alone, maximize ultimate recovery from the SMU-KROP, and prevent waste. 4. The maximum wellhead injection pressures of 2,300 psig during water injection and 4,400 psi during gas injection are well below the pressures needed to initiate fractures in the confining intervals. As such, the confining intervals will ensure that injected fluids remain in the SMU- KROP. NOW THEREFORE IT IS ORDERED: The underground injection of fluids for pressure maintenance and enhanced recovery is authorized in the following area, subject to the following rules and 20 AAC 25, to the extent not superseded by these rules: Affected Area (Revised this order): Umiat Meridian Township/Range Sections 10N-7E 1-4, 9-12 11N-7E 24-26, 34-36 Table 1. Legal Description of Affected Area AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 7 of 11 Figure 1. Extent of Affected Area (Source: Mustang Holding LLC) AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 8 of 11 Rule 1: Authorized Injection Strata for Enhanced Recovery Within the Affected Area, Class II fluids may be injected for the purposes of pressure maintenance and enhanced recovery into strata defined as those which correlate with, and are common to, the formation found in the North Tarn 1Awell (Permit to Drill No. 211-051) between measured depths of 6,130 feet and 6,212 feet (see Figure 2, below). Figure 2. North Tarn 1A, Reference Log for the SMU Kuparuk River Oil Pool Kuparuk River Oil Pool C-Sand A4-Sand A3-Sand Lower Cretaceous Unconformity AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 9 of 11 Rule 2: Fluid Injection Wells and Well Construction The injection of fluids must be conducted through a new well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005, or through an existing well that AOGCC has approved for conversion to a service well for injection in conformance with 20 AAC 25.280. In lieu of the packer depth requirements under 20 AAC 25.412(b), the packer/isolation equipment for injection wells may be located above 200 feet measured depth (MD) from above the top of the perforations/open interval but must be located below the top of the confining zone and shall have outer casing cement volume sufficient to place a minimum of 300 feet MD above the planned packer depth. Rule 3: Authorized Fluids for Injection for Enhanced Recovery Fluids authorized for injection are: a. Source water from the KRU seawater treatment plant; b. Produced water from the SMU-KROP, produced water from other as yet undefined oil pools in the SMU if authorized administratively after showing they will be compatible with the SMU-KROP formation and fluids; c. Enriched hydrocarbon gas (MI): a blend of KRU lean gas with indigenous and/or imported natural gas liquids; d. Lean hydrocarbon gas; e. Fluids used during hydraulic stimulation; f. Tracer survey fluids to monitor reservoir performance (e.g., chemical, radioactive, etc.); g. Fluids used to improve near wellbore injectivity (e.g., acid washes, scale inhibition treatments, etc.); h. Fluids used to seal wellbore intervals which negatively impact recovery efficiency (e.g., cement, resin, etc.); i. Fluids associated with freeze protection (diesel, glycol, methanol, etc.); and j. Standard oilfield chemicals (corrosion inhibitor, scale inhibitor, etc.). Rule 4: Authorized Injection Pressure for Enhanced Recovery Maximum injection pressures shall be well below the confining zone fracture gradient of 0.834 psi/ft, to ensure containment of injected fluids within the defined injection interval of the defined Affected Area. Maximum wellhead injection pressures shall be 2,300 psig during water injection and 4,400 psig during gas injection. AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 10 of 11 Rule 5: Monitoring Tubing-Casing Annulus Pressure Inner annulus, outer annulus, and tubing pressures shall be monitored and recorded at least daily, except if prevented by extreme weather condition, emergency situation, or similar unavoidable circumstances for all injection and production wells. The outer annulus pressures of all wells that are not cemented across the SMU-KROP and are located within a one-quarter mile radius of a SMU-KROP injector shall be monitored daily. All monitoring results shall be documented and available for AOGCC inspection. Rule 6: Demonstration of Tubing/Casing Annulus Mechanical Integrity The mechanical integrity of each injection well must be demonstrated before injection begins and before returning a well to service following any workover affecting mechanical integrity. An AOGCC-witnessed mechanical integrity test (MIT) must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter. The AOGCC must be notified at least 24 hours in advance to enable a representative to witness an MIT. Unless an alternate means is approved by the AOGCC, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure equivalent to the maximum injection pressure, or 1,500 psi, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30-minute period. Results of MITs must be readily available for AOGCC inspection. Rule 7: Well Integrity and Confinement Whenever an indication of pressure communication, leakage, or lack of zone isolation occurs, the operator must notify the AOGCC by the next business day. Such indication may arise from information including but not limited to injection rate change, operating pressure change, test, survey, log, or outer annulus pressure monitoring in wells within a one-quarter mile radius of where the SMU-KROP is not cemented. The operator shall notify the AOGCC by the next business day and submit a plan of corrective action on an Application for Sundry Approvals Form 10-403 for AOGCC approval. The operator must shut-in any well for which: (a) continued operation would be unsafe, (b) continued operation would threaten communication of freshwater, or (c) the AOGCC directs the operator to shut-in the well. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC for all injection wells that: (a) are subject to administrative approval (AA) to operate, or (b) lack injection zone isolation. Rule 8: Notification of Improper Class II Injection Injection of fluids other than those listed in Rule 3 without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. This requirement is in addition to, and does not relieve the operator of, any other obligations under the notification requirements of any other State or Federal agency, regulation or law. AIO 46 Corrected February 11, 2026 Nunc pro tunc September 25, 2025 Page 11 of 11 Rule 9: Other Conditions If fluids are found to be fracturing the confining zone or migrating out of the approved injection stratum, the operator must immediately shut in the injection wells and immediately notify the AOGCC. Injection must not be restarted unless approved by the AOGCC. DONE at Anchorage, Alaska and dated February 11, 2026, nunc pro tunc September 25, 2025. Jessie L. Chmielowski Gregory C. Wilson Thomas W. McKay Commissioner Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2026.02.11 08:33:22 -09'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2026.02.11 08:39:53 -09'00' Thomas W. McKay Digitally signed by Thomas W. McKay Date: 2026.02.11 10:58:58 -09'00' STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF Mustang Holding LLC to gain authorization to inject fluids for pressure maintenance and enhanced recovery of hydrocarbons in the Southern Miluveach Unit, Kuparuk River Oil Pool ) ) ) ) ) ) ) ) Docket Number: AIO-24-018 Area Injection Order 46 Southern Miluveach Unit Kuparuk River Oil Pool North Slope Borough, Alaska September 25, 2025 IT APPEARING THAT: 1. By application dated June 3, 2024 (Application), Mustang Holding LLC (MHLLC), in its capacity of operator of the Southern Miluveach Unit (SMU), requested an Area Injection Order (AIO) authorizing injection of fluids for pressure maintenance and enhanced recovery of hydrocarbons from the Kuparuk River Oil Pool (KROP) within the SMU (the portion of the KROP within the SMU and the Affected Area of this order are referred to as the SMU-KROP). 2. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) tentatively scheduled a public hearing for August 27, 2024. On July 12, 2024, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website, electronically transmitted the notice to all persons on the AOGCC’s email distribution list, and mailed printed copies of the Notice of Public Hearing to all persons on the AOGCC’s mailing distribution list. On July 17, 2024, the notice was published in the ANCHORAGE DAILY NEWS. 3. The AOGCC received no comments or requests to hold the proposed hearing. The hearing was vacated. 4. MHLLC submitted updated information mid-September 2025, concerning fracture gradients and injection pressures, that was taken into consideration as an accessory to the Application. 5. MHLLC’s application, supplemental information, and AOGCC’s public records provide sufficient information to make an informed decision. FINDINGS: 1. Order History Area Injection Order 42 (AIO 42), issued June 12, 2019, defined rules governing the injection of fluids for pressure maintenance and enhanced recovery of hydrocarbons for the SMU- KROP, with Brooks Range Petroleum Corporation (BRPC) as the designated operator. On December 4, 2020, MHLLC succeeded BRPC as operator of the SMU. In accordance with 20 AAC 25.402(i) AIO 42 automatically expired on June 12, 2021, due to injection not starting prior to that date. AIO 46 September 25, 2025 Page 2 of 11 2. Affected Area The Affected Area lies onshore within the SMU, North Slope Borough, Alaska, about 45 miles west-southwest of Prudhoe Bay. The SMU-KROP is being developed from the SMU Mustang drill site, a gravel pad located in Section 2, Township (T) 10N, Range (R) 7E, Umiat Meridian (UM). 3. Owners and Landowners Mustang Holding, LLC is the operator of the SMU. Working interest owners are Mustang Holding, LLC, Mustang Operations Center 1, LLC, Mustang Investment Holdings, LLC, and Alaska Venture Capital Group, LLC. The State of Alaska, Department of Natural Resources is the surface and subsurface landowner of the Affected Area. 4. Exploration, Delineation, and Production History During January 2012, BRPC drilled the discovery well—North Tarn 1A (Permit to Drill No. 211-174)—into the Kuparuk Formation (Kuparuk) in Section 2, T10N, R7E, UM, and encountered oil indicators. This discovery was confirmed by the Mustang 1 exploratory well (Permit to Drill No. 212-174) in February 2012. To date, five wells have been logged across the Kuparuk reservoir within the SMU. Three-dimensional seismic survey and well log data have been used to determine the geologic structure and reservoir distribution for the SMU-KROP. Well log, well test, and Operator- supplied information were used to establish reservoir and fluid properties for the pool. 5. Pool Identification The KROP, defined in Conservation Order 432F (CO 432F), is the accumulation of oil that is common to and correlates with the accumulation found in the Atlantic Richfield Company West Sak River State No. 1 well between the depths of 6,474- and 6,880-feet MD (Permit to Drill No. 171-003). Along with the SMU, portions of this expansive oil pool also lie within the adjoining Kuparuk River Unit (KRU) and the nearby Milne Point Unit (MPU). 6. Geology a. Structure: The Colville Anticline is the regional structural trap for the SMU-KROP. The SMU lies on a portion of that anticline. Within the SMU, the SMU-KROP ranges in depth from about -5,800 to -6,400 feet TVDSS.1 b. Stratigraphy: Within the SMU, Cretaceous-aged reservoir sandstones within the Kuparuk Formation are informally divided into two intervals, the Kuparuk C-Sands (C-Sand) and the underlying Kuparuk A-Sands (A-Sand). The C-Sand consists of bioturbated and burrowed glauconitic sandstones, shaley sandstones, siltstones, and shales. These sediments were most likely deposited in an offshore marine-shelf setting. The thickness of the C-Sand interval varies from 0 to 25 feet within the SMU, and this variation is believed to have been influenced by syndepositional fault activity. 1 To avoid confusion, when depths presented represent true vertical depth below sea level (subsea), the footage will be preceded by a minus sign and followed by the acronym TVDSS (e.g., 5,800 feet true vertical subsea is depicted as -5,800 feet TVDSS). AIO 46 September 25, 2025 Page 3 of 11 The regional Lower Cretaceous Unconformity (LCU) separates the C-Sand from the underlying A-Sands, and it progressively truncates the A-Sand intervals from southeast to northwest across the SMU. Within the SMU, the A-Sands consist of two upward-coarsening intervals that were deposited in an offshore marine setting. Here, the A-Sands are subdivided into intervals informally named “A4” and “A3”, in descending order. The thickness of A4 varies from 0 to 36 feet from northwest to southeast across the SMU. Interval A3 varies from 2 to 40 feet in thickness from northwest to southeast within the SMU. The thickness trends of the A-Sands do not appear to be influenced by faulting or the present-day structure. c. Rock Properties: The C-Sand comprises fine- to coarse-grained quartzose sandstone that contains up to 40 percent glauconite and is commonly cemented with secondary siderite. Porosity averages 22 percent. Permeability ranges from 50 to several hundred millidarcies (md), averaging 70 md. Water saturation with the C-Sand can be as low as 20 percent. The underlying A-Sand consists of very fine- to fined-grained sandstone interbedded with siltstone and mudstone. Porosity averages 22 percent. Permeability ranges from less than 10 to 100 md, averaging 30 md. Water saturation in the A-Sand can be as high as 40 percent. d. Faults: Two sets of faults cut the Colville Anticline within the SMU; one set trends north-northeast, and the other set trends west-northwest. The vertical displacement of faults cutting the proposed SMU-KROP ranges up to 85 feet but is generally less than 30 feet. Because of the relatively thin-bedded nature of reservoir sands within the proposed pool, some faults may act as localized flow barriers and may result in reservoir compartments. e. Trap Configuration and Seals: Well log and seismic information indicate that structural dip controls the hydrocarbon accumulation within the SMU-KROP. The overlying Kalubik and HRZ Shales form the top seal for the oil accumulation within the proposed pool. 7. Reservoir Continuity Many faults cut the KROP within the Affected Area. As mapped using 3D seismic, these faults have vertical displacements that are generally less than 30 feet. However, some compartmentalization of the pool is expected due to the thin nature of the reservoir strata, especially in the western portion of the Affected Area. 8. Reservoir Fluid Contacts To date, no hydrocarbon contacts have been encountered in the Kuparuk reservoirs within the Affected Area. 9. Reservoir Fluid Properties In the SMU-KROP area, the initial producing gas oil ratio (GOR) is estimated to be about 600 standard cubic feet per stock tank barrel (scf/stb). The API gravity of oil recovered from the proposed pool measured about 24° in the North Tarn 1A well. Due to injection activities in the KROP within the adjoining KRU, pressure in the SMU-KROP measured as high as 3,850 AIO 46 September 25, 2025 Page 4 of 11 psi. Bubble-point pressure is estimated to be 1,930 psi. The oil formation volume factor is estimated at 1.2 reservoir barrels per stock tank barrel of oil. 10. In-Place and Recoverable Volume Estimates (based on reservoir modeling predictions) 11. Future Development Plans MHLLC has plans to develop the pool from the existing SMU “Mustang” drill site, through multiple phases. Development includes reinstallation of production facilities, reconnecting the Mustang Pipeline to the Alpine Pipeline for access to the Trans-Alaska Pipeline System (TAPS), re-entering existing wells, and drilling additional wells. Well stock will involve up to 11 horizontal or vertical development (production) wells and up to 10 horizontal or vertical service (injection) wells, with most production wells trending north-south, parallel to the direction of the major fault patterns that cut the pool. Some producers will produce from both the C-Sand and the A-Sand. Injection wells may be placed to create alternating rows of producer-injector pairs for line drive flood patterns. The length of the horizontal sections of wells are planned to range up to 6000 feet. Depending upon reservoir quality, some producers or injectors may be hydraulically fractured to enhance productivity and to enhance vertical injection sweep. 12. Confining Layers for Injection Approximately 260 feet of Kalubik and HRZ shales overlie the SMU-KROP. Several hundred feet of shales assigned to the Miluveach and Kingak Formations underlie the SMU-KROP. 13. Fracture Propagation and Confinement Kuparuk Formation fracture closure pressure was found via pressure decline analysis to be 0.67 psi/ft * 6,100’ TVD = 4,087 psi. Via history match of a frac in an offset well, it was found that an increase of 1,000 psi above the Kuparuk closure pressure of 4,087 psi was needed before excessive fracture height develops into confining shales: 4,087 psi + 1,000 psi = 5,087 psi. The confining shale fracture gradient is therefore 5,087 psi / 6,100’ = 0.834 psi/ft. A fracture propagation model showed that, at the planned estimated maximum injection pressures for miscible water alternating gas (MWAG) or immiscible water alternating gas (IWAG) service, fractures would form in the injection interval but would not initiate into or propagate through confining strata. For fractures to propagate into the confining layers, 2 The acronym MMSTB signifies millions of stock tank barrels. Hydrocarbon Resource Estimated Volume2 Original Oil in Place (OOIP) 70 MMSTB Primary Recovery (10-15% OOIP) 7-10.5 MMSTB Primary + Water Injection (10-25% OOIP incremental) 7-17.5 MMSTB Incremental Primary + Water and Lean Gas Injection (1-5% OOIP incremental) 0.7-3.5 MMSTB Incremental Primary + Water and Enriched Gas Injection (3-15% OOIP incremental) 2.1-10.5 MMSTB Incremental AIO 46 September 25, 2025 Page 5 of 11 surface pressures during injection would have to exceed 2,391 psi with water and 4,477 psi with gas. 14. Injection Pressures 3 Maximum injection pressures at the wellhead, for both water and gas, will be below the confining zone fracture gradient of 0.834 psi/ft. For water, a maximum of 2,300 psi will be well below the 2,391 psi that corresponds to the confining zone frac gradient. For gas, a maximum of 4,400 psi will be well below the 4,477 psi that corresponds to the confining zone frac gradient. Average injection pressure on water is expected to be ~1,400 psi, very near the surface water injection pressure of 1,391 psi that corresponds to the Kuparuk fracture gradient of 0.67 psi/ft. 15. Injection Rates The anticipated peak daily injection rate for individual wells within the SMU-KROP is 6,000 barrels of water per day (BWPD) and 6 million standard cubic feet of gas per day (MMSCFD). 16. Freshwater Strata No porosity logs have been recorded across the shallow geologic section within the SMU. The former operator, BPRC, commissioned a formation water salinity determination using logs from well West Sak 25590-15, which is located about 3 miles east of the SMU development gravel pad. Well log calculations suggest that aquifers shallower than a depth of about 2,300 feet MD (-2,140 feet TVDSS) within the SMU may contain native formation waters that have total dissolved solids concentrations of less than 10,000 mg/l. However, MHLLC will isolate these aquifers by setting the surface casing at -2,500 feet TVDSS and cementing it to surface. 17. Aquifer Exemption Order MHLLC’s Application contends that the US Environmental Protection Agency’s (EPA) Aquifer Exemption for the Kuparuk River Unit (KRU), defined in 1984 by 40 CFR 147.102(b)(3), still applies to the current area of the SMU. The exact boundary of that Aquifer Exemption is currently under review by the EPA. CONCLUSIONS: 1. An Area Injection Order is appropriate to authorize the injection of fluids for enhanced oil recovery purposes in the SMU-KROP within the SMU. 2. The Aquifer Exemption for the KRU—as described in Federal Regulation 40 CFR147.102(b)(3)—currently applies to the SMU-KROP. However, if subsequent EPA review determines that the SMU-KROP falls outside of the affected area for the KRU Aquifer Exemption, MHLLC must apply for a new Aquifer Exemption. 3. Reservoir simulation modeling shows water and water-alternating-gas injection (both immiscible water alternating gas (IWAG) and miscible water alternating gas (MWAG)) into 3 For fracture gradient calculations, 0.442 psi/ft was used for water, 0.1 psi/ft for gas, and -6,100’ TVDSS for depth. AIO 46 September 25, 2025 Page 6 of 11 the SMU-KROP will provide a substantial EOR benefit over primary recovery alone, maximize ultimate recovery from the SMU-KROP, and prevent waste. 4. The maximum wellhead injection pressures of 2,300 psig during water injection and 4,400 psi during gas injection are well below the pressures needed to initiate fractures in the confining intervals. As such, the confining intervals will ensure that injected fluids remain in the SMU-KROP. NOW THEREFORE IT IS ORDERED: The underground injection of fluids for pressure maintenance and enhanced recovery is authorized in the following area, subject to the following rules and 20 AAC 25, to the extent not superseded by these rules: Affected Area (Revised this order): Umiat Meridian Township/Range Sections 10N-7E 1-4, 9-12 11N-7E 24-26, 34-36 Table 1. Legal Description of Affected Area AIO 46 September 25, 2025 Page 7 of 11 Figure 1. Extent of Affected Area (Source: Mustang Holding LLC) AIO 46 September 25, 2025 Page 8 of 11 Rule 1: Authorized Injection Strata for Enhanced Recovery Within the Affected Area, Class II fluids may be injected for the purposes of pressure maintenance and enhanced recovery into strata defined as those which correlate with, and are common to, the formation found in the North Tarn 1Awell (Permit to Drill No. 211-051) between measured depths of 6,130 feet and 6,212 feet (see Figure 2, below). Figure 2. North Tarn 1A, Reference Log for the SMU Kuparuk River Oil Pool Kuparuk River Oil Pool C-Sand A4-Sand A3-Sand Lower Cretaceous Unconformity AIO 46 September 25, 2025 Page 9 of 11 Rule 2: Fluid Injection Wells and Well Construction The injection of fluids must be conducted through a new well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005, or through an existing well that AOGCC has approved for conversion to a service well for injection in conformance with 20 AAC 25.280. In lieu of the packer depth requirements under 20 AAC 25.412(b), the packer/isolation equipment for injection wells may be located above 200 feet measured depth (MD) from above the top of the perforations/open interval but must be located below the base of the confining zone and shall have outer casing cement volume sufficient to place a minimum of 300 feet MD above the planned packer depth. Rule 3: Authorized Fluids for Injection for Enhanced Recovery Fluids authorized for injection are: a. Source water from the KRU seawater treatment plant; b. Produced water from the SMU-KROP, produced water from other as yet undefined oil pools in the SMU if authorized administratively after showing they will be compatible with the SMU-KROP formation and fluids; c. Enriched hydrocarbon gas (MI): a blend of KRU lean gas with indigenous and/or imported natural gas liquids; d. Lean hydrocarbon gas; e. Fluids used during hydraulic stimulation; f. Tracer survey fluids to monitor reservoir performance (e.g., chemical, radioactive, etc.); g. Fluids used to improve near wellbore injectivity (e.g., acid washes, scale inhibition treatments, etc.); h. Fluids used to seal wellbore intervals which negatively impact recovery efficiency (e.g., cement, resin, etc.); i. Fluids associated with freeze protection (diesel, glycol, methanol, etc.); and j. Standard oilfield chemicals (corrosion inhibitor, scale inhibitor, etc.). Rule 4: Authorized Injection Pressure for Enhanced Recovery Maximum injection pressures shall be well below the confining zone fracture gradient of 0.834 psi/ft, to ensure containment of injected fluids within the defined injection interval of the defined Affected Area. Maximum wellhead injection pressures shall be 2,300 psig during water injection and 4,400 psig during gas injection. Rule 5: Monitoring Tubing-Casing Annulus Pressure Inner annulus, outer annulus, and tubing pressures shall be monitored and recorded at least daily, except if prevented by extreme weather condition, emergency situation, or similar unavoidable circumstances for all injection and production wells. The outer annulus pressures of all wells that AIO 46 September 25, 2025 Page 10 of 11 are not cemented across the SMU-KROP and are located within a one-quarter mile radius of a SMU-KROP injector shall be monitored daily. All monitoring results shall be documented and available for AOGCC inspection. Rule 6: Demonstration of Tubing/Casing Annulus Mechanical Integrity The mechanical integrity of each injection well must be demonstrated before injection begins and before returning a well to service following any workover affecting mechanical integrity. An AOGCC-witnessed mechanical integrity test (MIT) must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter. The AOGCC must be notified at least 24 hours in advance to enable a representative to witness an MIT. Unless an alternate means is approved by the AOGCC, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure equivalent to the maximum injection pressure, or 1,500 psi, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30-minute period. Results of MITs must be readily available for AOGCC inspection. Rule 7: Well Integrity and Confinement Whenever an indication of pressure communication, leakage, or lack of zone isolation occurs, the operator must notify the AOGCC by the next business day. Such indication may arise from information including but not limited to injection rate change, operating pressure change, test, survey, log, or outer annulus pressure monitoring in wells within a one-quarter mile radius of where the SMU-KROP is not cemented. The operator shall notify the AOGCC by the next business day and submit a plan of corrective action on an Application for Sundry Approvals Form 10-403 for AOGCC approval. The operator must shut-in any well for which: (a) continued operation would be unsafe, (b) continued operation would threaten communication of freshwater, or (c) the AOGCC directs the operator to shut-in the well. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC for all injection wells that: (a) are subject to administrative approval (AA) to operate, or (b) lack injection zone isolation. Rule 8: Notification of Improper Class II Injection Injection of fluids other than those listed in Rule 3 without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. This requirement is in addition to, and does not relieve the operator of, any other obligations under the notification requirements of any other State or Federal agency, regulation or law. Rule 9: Other Conditions If fluids are found to be fracturing the confining zone or migrating out of the approved injection stratum, the operator must immediately shut in the injection wells and immediately notify the AOGCC. Injection must not be restarted unless approved by the AOGCC. AIO 46 September 25, 2025 Page 11 of 11 DONE at Anchorage, Alaska and dated September 25, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.25 16:39:54 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.25 16:51:26 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 46 (Mustang) Date:Thursday, September 25, 2025 4:55:24 PM Attachments:AIO46.pdf Authorization to inject fluids for pressure maintenance and enhanced recovery of hydrocarbons in the Southern Miluveach Unit, Kuparuk River Oil Pool Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v 3 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:Josh Tempel To:AOGCC Permitting (CED sponsored) Cc:David Wages; Gabriela Keeton Subject:Mustang AIO: Request for Verbal Approval Date:Thursday, September 25, 2025 10:17:45 AM Attachments:image001.png Hello Chris, We will be commissioning our gas compressors this morning, and it is strongly preferable from both an engineering and wells operations standpoint to start by injecting gas into WAG injector M-02 prior to initiating gas lift. AIO 42 was submitted June 3, 2024, and I understand it is in final review, but may still be a few days away. To initiate gas injection on M-02, Mustang requests verbal approval to inject under the Brooks Range AIO issued 6/12/2019. Within a verbal approval, we propose Mustang adhere to the pressure limitations found in the old Brooks Range AIO until final approval is given for the new AIO: RULE 4: Injection pressures shall not exceed the maximum injection gradient of 0.67 psi/ft to ensure containment of injected fluids within the defined Affected Area and injection interval. This project has come a long way in the last year, and today’s commissioning will be a big milestone for Mustang and the State leases. We appreciate all the effort AOGCC has put into working with us to get to this point. Best regards, Josh Josh Tempel Head of Operations, Mustang Holding LLC Phone: (907)-891-5930 310 K Street, Ste 309 Anchorage, AK 99501 2 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: AIO-24-018 By application dated June 3, 2024, Mustang Holding LLC (Mustang), as the operator of the Southern Miluveach Unit (SMU), requests that the Alaska Oil and Gas Conservation Commission (AOGCC) approve an Area Injection Order (AIO) to allow enhanced oil recovery (EOR) injection activities in the portion of the Kuparuk River Oil Pool (KROP) located in the SMU. The AOGCC approves injection orders for several purposes, including EOR, storage, and disposal either on an individual well or area wide basis in Alaska. EOR injection orders establish rules for conducting operations that are intended to increase the amount of oil or gas that could be recovered from a pool by one or more of the following mechanisms, maintain reservoir energy, sweeping oil through the reservoir to a production well, or modifying the properties of the oil to make it more mobile. This is consistent with the portion of the AOGCC’s mission that seeks to promote greater ultimate recovery. This notice does not contain all the information filed by Mustang. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or Samantha.Coldiron@alaska.gov. A public hearing on the matter has been tentatively scheduled for August 27, 2024, 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: 912 691 777#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on July 31, 2024. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after August 2, 2024. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on August 22, 2024, except that, if a hearing is held, comments must be received no later than the conclusion of the August 27, 2024, 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 August 20, 2024. Jessie L. Chmielowski Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.07.12 13:40:33 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notices Date:Friday, July 12, 2024 2:42:06 PM Attachments:CO-24-010 public hearing notice expansion of S-BGP in BRU.pdf CO-24-009 and AIO-24-019 public hearing notice establishing pool rules and an AIO for the COP in KRU.pdf AIO-24-018 public hearing notice establishing an AIO for the KROP in SMU.pdf Docket Number: AIO-24-018 By application dated June 3, 2024, Mustang Holding LLC (Mustang), as the operator of the Southern Miluveach Unit (SMU), requests that the Alaska Oil and Gas Conservation Commission (AOGCC) approve an Area Injection Order (AIO) to allow enhanced oil recovery (EOR) injection activities in the portion of the Kuparuk River Oil Pool (KROP) located in the SMU. Docket Numbers: CO-24-009 and AIO-24-019 By application dated June 20, 2024, ConocoPhillips Alaska, Inc. (CPAI), as the operator of the Kuparuk River Unit (KRU), requests that the Alaska Oil and Gas Conservation Commission (AOGCC) approve Pool Rules establish rules for the development of the Coyote Oil Pool (COP) in the KRU and an Area Injection Order (AIO) to allow enhanced oil recovery (EOR) injection activities in the COP. Docket Number: CO-24-010 By applications dated June 27, 2024, Hilcorp Alaska, LLC (Hilcorp), as the operator of the Beluga River Unit (BRU), requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the vertical extent of the Sterling-Beluga Gas Pool (S-BGP), as currently defined by Rule 2 of Conservation Order No. 802 (CO 802) in the BRU. 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 ______________________________________ 07/17/2024 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 #: W0047006 Cost: $335.69 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Numbers: AIO-24-018 By application dated June 3, 2024, Mustang Holding LLC (Mustang), as the operator of the Southern Miluveach Unit (SMU), requests that the Alaska Oil and Gas Conservation Commission (AOGCC) approve an Area Injection Order (AIO) to allow enhanced oil recovery (EOR) injection activities in the portion of the Kuparuk River Oil Pool (KROP) located in the SMU. The AOGCC approves injection orders for several purposes, including EOR, storage, and disposal either on an individual well or area wide basis in Alaska. EOR injection orders establish rules for conducting operations that are intended to increase the amount of oil or gas that could be recovered from a pool by one or more of the following mechanisms, maintain reservoir energy, sweeping oil through the reservoir to a production well, or modifying the properties of the oil to make it more mobile. This is consistent with the portion of the AOGCC’s mission that seeks to promote greater ultimate recovery. This notice does not contain all the information filed by Mustang. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or Samantha.Coldiron@alaska. gov. A public hearing on the matter has been tentatively scheduled for August 27, 2024, 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: 912 691 777#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on July 31, 2024. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after August 2, 2024. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on August 22, 2024, except that, if a hearing is held, comments must be received no later than the conclusion of the August 27, 2024, 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 August 20, 2024. Jessie L. Chmielowski Commissioner Pub: July 17, 2024 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2024-07-19 2028-07-14 Document Ref: DT9YN-EWAGQ-ZQCBO-S2GHR Page 8 of 23 1 pg. 1 June 3, 2024 Jessie Chmielowski, Chair Alaska Oil and Gas Conservation Commission 333 W. 7th Ave #100 Anchorage, Alaska, 99501-3539 RE: Application for Area Injection Order for the Kuparuk Oil Pool Southern Miluveach Unit, North Slope, Alaska Dear Commissioner Chmielowski: In accordance with 20 ACC 25.402 (Enhanced Recovery Operations) and 20 AAC 25.460 (Area Injection Orders), Mustang Holding LLC (“MHLLC”)as operator of the Southern Miluveach Unit ("SMU") and on behalf of the Working Interest Owners, requests that the Alaska Oil and Gas Conservation Commission ("Commission") approve MHLLC's application for an Area Injection Order ("AIO") for the Kuparuk Oil Pool, as defined by the Commission and within the SMU as defined in the SMU Agreement by and between the Alaska Department of Natural Resources. First injection into the Kuparuk Oil Pool in the Southern Miluveach Unit is expected to occur as early as the 4th quarter of 2024. MHLLC requests that the hearing date for this application be scheduled as soon as possible after the 30-day notice period has concluded. A limited number of maps have been marked confidential to retain proprietary reservoir and subsurface interpreted information. Please contact Harry Bockmeulen (907-865-5808) if you have questions or require additional information. Best Regards, Gordon Pospisil PE President & CEO Mustang Holding LLC By Samantha Coldiron at 4:54 pm, Jun 03, 2024 pg. 2 Mustang Holding LLC Application for Area Injection Order in the Kuparuk Oil Pool Southern Miluveach Unit May 31, 2024 Section A- Introduction Section B- Plot of Project Area 20 AAC 25.402(c)(1) Section C- Operator & Surface Owners 20 AAC 25.402(c)(2) Section D- Affidavit 20 AAC 25.402(c)(3) Section E- Description of Proposed Operation 20 AAC 25.402(c)(4) Section F- Pool Description 20 AAC 25.402(c)(5) Section G- Formation Geology 20 AAC 25.402(c)(6) Section H- Logs of Injection Wells 20 AAC 25.402(c)(7) Section I- Mechanical Integrity of Injection Wells 20 AAC 25.402(c)(8) Section J- Injection Fluids 20 AAC 25.402(c)(9) Section K- Injection Pressures 20 AAC 25.402(c)(10) Section L- Fracture Information 20 AAC 25.402(c)(11) Section M- Formation Water Quality 20 AAC 25.402(c)(12) Section N- Aquifer Exemption 20 AAC 25.402(c)(13) Section O- Hydrocarbon Recovery 20 AAC 25.402(c)(14) Section P- Confinement in Offset Wells 20 AAC 25.402(c)(15) Section Q- Proposed Area Injection Order Rules 20 AAC 25.402(c)(16) pg. 3 List of Figures/Exhibits B-1: Plot of the SMU Kuparuk Oil Pool Area and all Existing Wells D-1: Affidavit F-1: Outline of AIO and Pool Area highlighting leases outside of the SMU F-2: Defining Well, North Tarn 1A, highlighting Pool interval with respect to the upper and lower confining intervals G-1: West to East Schematic Stratigraphic Cross Section Across Area of Interest G-2: Kuparuk “C” Reservoir Isochore G-3: Kuparuk “A4” Reservoir Isochore G-4: Kuparuk “A3” Reservoir Isochore G-5: West to East Well Cross Section across the AIO Area G-6: Lower Cretaceous Unconformity (LCU)/Kuparuk “C” Structure Grid I-1: Generic Kuparuk Injector Well Design J-1: Kuparuk Seawater Treatment Plant Water Composition J-2: Kuparuk Gas Injectant Composition J-3: Kuparuk Pool Produced Water Composition K-1: Southern Miluveach Unit, Kuparuk Oil Pool Injection Pressure Summary L-1: Well log from 2S-13PB1 used in GOHFER fracture analysis L-2: Model of single point Injection into the Kuparuk “C” L-3: Injection pressure modeled at 3000 BOPD L-4: Fracture geometry, exhibiting containment within the Kuparuk formation at 3000 BOPD L-5: Injection pressure modeled at 6000 BOPD L-6: Water Injection Without Propped Fracture At 6,000 BPD M-1: SMU Kuparuk Pool Water Sample Analysis from North Tarn 1A Well Test M-2: SMU Kuparuk Pool Gas Sample Analysis from North Tarn 1A Well Test M-3: SMU Kuparuk Pool Crude Oil Sample Analysis from North Tarn 1A Well Test O-1: Map of Proposed SMU Kuparuk Development Wells pg. 4 Section A – Introduction Document Scope This document is an application for an Area Injection Order ("AIO") submitted to the Alaska Oil and Gas Conservation Commission ("Commission") in accordance with 20 AAC 25.460 (Area Injection Orders). The purpose of this document is to gain authorization from the Commission to inject fluids for pressure maintenance and enhanced recovery of hydrocarbons in the Southern Miluveach Unit, Kuparuk Oil Pool pursuant to 20 ACC 25.402. Mustang Holding LLC ("MHLLC"), in its capacity as Operator of the Southern Miluveach Unit (SMU), submits this document to the Commission. This application has been prepared in accordance with 20 ACC 25.402 (Enhanced Recovery Operations) and 20 ACC 25.460 (Area Injection Orders). MHLLC is operating the SMU Kuparuk Reservoir under the Current Kuparuk Pool Rules that govern the development of the Kuparuk Pool. Introduction The Kuparuk Oil Pool within the SMU is a continuation of the deposit of Kuparuk “C” and Kuparuk “A” Sands adjacent to the southwest portion of the Kuparuk River Unit. It is comprised of sandstones, siltstones, and shales at depths between -5800 ft. true vertical depth sub-sea ("TVDSS") and -6400 ft. TVDSS within the SMU. Development of the Kuparuk Oil Pool in the SMU will be completed in multiple phases to mitigate risk and improve recovery. The reservoir targets will be accessed from the SMU “Mustang” drill site. Current plans are to develop the field with up to 11 horizontal or vertical producers and up to 10 horizontal or vertical injectors. Some of the producers and injectors may be hydraulically fractured to enhance production and ultimate recovery. For Phase I, MHLLC will reinstall production facilities, re-enter existing wells, reconnect the Mustang Pipeline, and return the field to production from up to four production and injection wells by year end 2024. Mustang full field development is underway with production ramping up in 4Q 2024 through a series of project phases. In Phase I, a 6,000 bopd Early Production Facility (EPF) will be installed to process oil produced from the initial wells completed in the central and SE corner of the Unit. The EPF will have the capability to produce sales quality crude oil along with gas and produced water handling. Gas will be separated from the oil and utilized for power generation and process heat with any excess injected into the reservoir. Produced water will initially be trucked to an off-site disposal facility. In Phase II, additional wells will be drilled to keep field production in the targeted range of 4 mbopd and expand waterflood operations. During Phase II, the EPF will be expanded to include a Produced Water Injection pump system to inject water into designated wells and the existing seawater line will be connected to the Colville Seawater pipeline to provide supplemental waterflood volumes. Additional wells will be drilled in subsequent phases (to be permitted at a later date) with the ultimate well count as high as 21 wells, dependent on earlier phase results. The Early Production Facility will be debottlenecked or replaced by additional facilities modules as warranted by longer term production results, reservoir performance, and potential third party or multi-horizon Mustang field development. Produced oil will be delivered to the market through a tie-in at the common carrier Alpine Pipeline which crosses through the SMU and connects to the Trans-Alaska Pipeline System. pg. 5 Section B – Plot of Project Area 20 AAC 25.402(c)(1) 20 AAC 25.402(c)(1) -An application for injection must include a plat showing the location of each proposed injection well, abandoned or other unused well, production well, dry hole, and other well within one-quarter mile of each proposed injection well. Figure B-1 shows all existing injection wells, production wells, abandoned wells, dry holes and any other wells within the requested Southern Miluveach Unit, Kuparuk Oil Pool as of March, 2024. Specific approvals for any new injection wells or existing wells to be converted to injection service will be obtained pursuant to 20 AAC 25.005, 25.280, and 25.507, or any applicable successor regulation. pg. 6 Section C – Operator & Surface Owners 20 AAC 25.402(c)(2) 20 AAC 25.402(c)(2)- An application for injection must include a list of all operators and surface owners within a one-quarter mile radius of each proposed injection well. MHLLC is the designated operator of the SMU, which includes the Mustang drill site from which the Kuparuk development wells will be drilled. The surface owners and operators within one-quarter mile radius of the proposed injection area are listed below. Surface Owners Operators State of Alaska ConocoPhillips Department of Natural Resources 700 G Street Division of Oil and Gas Anchorage, Alaska 99501 Attention: James Beckham, Director 550 West Seventh Avenue, Suite 1100 Oil Search (Alaska), LLC a subsidiary of Santos Limited Anchorage, AK 99501-355 900 E. Benson Blvd. Anchorage, Alaska 99508 Repsol 3800 Centerpoint Dr. Anchorage, Alaska, 99503 pg. 7 Section D – AFFIDAVIT 20 AAC 25.402(c)(3) 20 AAC 25.402(c)(3) -An application for injection must include an affidavit showing that the operators and surface owners within a one-quarter mile radius have been provided a copy of the application for injection. Exhibit D-1 is an affidavit showing that the operators and surface owners within a one-quarter mile radius of the proposed injection area have been provided a copy of this application. pg. 8 Section E- Description of Proposed Operation 20 AAC 25.402(c)(4) 20 AAC 25.402(c)(4) -An application for injection must include a full description of the particular operation for which approval is requested. The Kuparuk Oil Pool within the Southern Miluveach Unit will be developed from the existing SMU Mustang drill site and produced through the SMU processing facilities. Current plans call for 11 horizontal or vertical producers and up to 10 horizontal or vertical injection wells. Depending on expected reservoir quality, some of the producers or injectors may be hydraulically fractured to stimulate production and enhance ultimate recovery. As needed, additional wells may be drilled to optimize reservoir performance. Most of the development wells will trend North to South parallel to the direction of the major fault patterns that cut through the reservoir. The length of the horizontal sections of the wells are planned to range in length up to 6000’ within the reservoir. Some of the wells will produce from both the Kuparuk “C” and the Kuparuk “A” reservoirs. In these wells it is expected that hydraulic fracture stimulation may be needed to enhance productivity and improve vertical injection sweep. The wells may be arranged end-to-end to form alternate rows of producers and injectors in a line-drive flood pattern. Initial studies, which include a computer-generated reservoir simulation study, suggest a nominal 1500’-2000’ inter-well spacing will fit within and between the major faults which cut through the Kuparuk reservoir and will most likely cause some interference to a conformable waterflood. Based on well performance, some infill drilling may be needed to optimize reservoir performance and maximize recovery. To evaluate the performance of the Kuparuk Reservoir, a 3-D model, based on the available 3D seismic surveys and well data, was constructed covering the entire development area to assess reservoir performance using a waterflood for enhanced recovery. Additionally, waterflooding may be followed with either lean gas or miscible gas injection to further improve recovery. Production and injection will be managed to maintain reservoir pressure near the original measured pressure. Injection will most likely consist of either produced water or seawater. The seawater injection source water will come from the nearby CPAI operated Alpine seawater pipeline. Gas will be sourced from the SMU processing facilities. Although the future availability of gas for injection purposes cannot be fully ascertained, some form of Immiscible Water Alternating Gas (“IWAG”) flood, Miscible Water Alternating Gas (“MWAG”) or rich gas injection may be implemented on one or more injection patterns to enhance recovery from the reservoir. An economic evaluation of IWAG and MWAG processes will determine the feasibility of utilizing these enhanced oil recovery methods within the SMU. pg. 9 Section F- Pool Description 20 AAC 25.402(c)(5) 20 AAC 25.402(c)(5) -An application for injection must include the names, descriptions, and depths of the pools to be affected. Location As shown on Figure F-1, the affected area proposed for the Southern Miluveach Unit, Kuparuk Oil Pool Area Injection Order is the entire Kuparuk Oil Pool, as proposed, which is within the following land: Location As shown on Figure F-1, the affected area proposed for the SMU Kuparuk Oil Pool Injection Order is the entire SMU Kuparuk Oil Pool including the following land: Umiat Meridian T10N, R7E Sections 1, 2, 3, 4, 9, 10, 11, 12 all T11N, R7E Sections 24, 25, 26, 34, 35, 36 all Pool Definition Injection of fluids for enhanced recovery is proposed for the correlative interval shown in Figure F-2, the North Tarn 1A well, known as the Southern Miluveach Unit (SMU), Kuparuk Oil Pool. Within the requested areal extent, the SMU Kuparuk Pool is defined as the accumulation of hydrocarbons common to and correlating with the interval between the depth of -6006 ft. TVDss and -6090 ft. TVDss as defined in the North Tarn 1A Well. Within the proposed Area Injection Order, the primary Kuparuk reservoirs are the Kuparuk “C” and the Kuparuk “A” intervals. Lower Confining Interval Below the Kuparuk Oil Pool is the Miluveach Shale. The Miluveach is a thick regional shale interval throughout the proposed area of development. The Kuparuk Pool in the area of the SMU The primary reservoirs in the proposed Area Injection Order consist of the shallow marine sandstones of the Kuparuk “A” reservoir and the unconformably overlying transgressive sandstones of the Kuparuk “C” reservoir. The underlying “A” sand is generally a lower permeability reservoir than found in the Kuparuk “C” sand. Upper Confining Interval The Kuparuk “C” reservoir is overlain by the Kalubik Shale interval. The Kalubik Shale is a regionally extensive and thick shale unit which provides a top seal for the reservoir and provides the upper confining layer to waterflood. pg. 10 Section G- Formation Geology 20 AAC 25.402(c)(6) 20 AAC 26.402(c)(6) -An application for injection must include the name, description, depth, and thickness of the formation into which fluids are to be injected, and appropriate geological data on the injection zone and confining zone, including lithologic descriptions and geologic names. Stratigraphy Figure G1 shows the depositional model for the Kuparuk Formation, which consists of the underlying Kuparuk “A” shallow marine sands which are estimated to be thinning westward and truncated in the Western portion of the SMU. The Kuparuk “A” sand is overlain by the Kuparuk “C” which is a transgressive sand deposited on the regional Lower Cretaceous Unconformity. The Kuparuk “C” and underlying Kuparuk “A” members of the Cretaceous age Kuparuk formation consist of very fine to coarse grained sandstones and siltstones. Within the proposed development area, the combined thickness of the two members ranges from 0 to over 80 feet. Figure G-2 shows the expected isochore of the Kuparuk “C”, which is the primary reservoir in the area ranging from 0 to as much as 35 feet thick. Thickness is estimated from well data and seismic signature. Figure G-3 shows the expected isochore of the Kuparuk “A” reservoir, ranging from 0 to as much as 80 feet thick. The Kuparuk A” reservoir thins to the west as it is truncated by the Lower Cretaceous Unconformity. Sedimentology The Kuparuk “C” sandstones are fine to coarse-grained, composed of quartz and up to 40% structural glauconite, and are commonly cemented with secondary siderite (the ubiquitous precipitate in North Slope reservoir sandstones). Porosity averages 22% and permeabilities range from 50 to hundreds of mD in the Kuparuk “C” averaging 70 mD in the Mustang area. The Kuparuk “A” sandstones are very fine to fined grained sandstone interbedded with siltstone and mudstones. Porosity averages 22%, but the permeability is lower than the Kuparuk “C” member ranging from less than 10 mD to 100mD, averaging 30 mD. Structure and Trap The Kuparuk Pool within the SMU ranges in depth from -5800 to -6400’ TVDSS. Oil is trapped within the regional structural trap formed by the Colville Anticline. There is no oil-water contact in the area of the proposed Area Injection Order. The Kuparuk reservoirs in the SMU are well above the known oil-water contact of the Kuparuk Oil Pool, which Range in depth from 6530’ TVDss to 6650’ TVDss in the KRU and are deeper than this to the Northeast in the Milne Point Unit. Defining Net Pay Net pay is generally defined by Gamma Ray, Resistivity and Porosity logs. Water saturation in the Kuparuk “C” can be as low as 20%, while water saturations in the Kuparuk “A” are as high as 40%. Net Pay cutoffs of about 15% porosity and 35% water saturation are assumed for purposes of volumetric calculations and are consistent with petrophysical evaluations in offset producing wells which suggest these cutoffs are good indicators of net pay in the Kuparuk “C” sand. pg. 11 Section H- Logs of Injection Wells 20 AAC 25.402(c)(7) 20 AAC 25.402(c)(7) -An application for injection must Include the logs of the injection wells if not already on file with the commission. To date, two wells within the SMU have been drilled and completed which may ultimately be utilized for injection. The well logs and well histories for these wells, North Tarn #1A and SMU M-02, have been submitted and are on file with the AOGCC. pg. 12 Section I - Logs of Injection Wells 20 AAC 25.402(c)(8) 20 AAC 25.402(c)(B) -An application for injection must include a description of the proposed method for demonstrating mechanical integrity of the casing and tubing under 20 AAC 25.412 and for demonstrating that no fluids will move behind casing beyond the approved injection zone, and a description of (A) the casing of the injection wells if the wells are existing; or (B) the proposed casing program, if the injection wells are new. The well design for the SMU Kuparuk Oil Pool well (Figure1-1) are similar to other Kuparuk Oil Pool wells drilled within the adjacent Kuparuk River Unit with surface casing to be set below the West Sak Interval and cemented to surface. Within the planned development area, the base of permafrost is interpreted to be approximately 1250’ TVDss. Intermediate casing strings will be set and cemented to isolate problematic shales zones and to optimize drilling through these zones. Any significant hydrocarbon bearing zones found in the borehole above the Kuparuk Reservoir will be isolated in accordance with Commission regulations. Top of cement will extend a minimum of 500 feet measured depth above the known hydrocarbon bearing formations in accordance with 20 AAC 25.030(d)(5). The SMU Kuparuk Oil Pool will likely be developed using the following completion methods. The reservoir interval will be completed with cemented and perforated liners or a solid liner including pre-perforated pup joints and/or sliding sleeves. This completion will be utilized where hydraulic fracturing is implemented to enhance well production or injection. Alternatively, completions may utilize uncemented slotted liners where fracture stimulation is not implemented. Tubing sizes will be determined to optimize expected production and injection rates. In lieu of the packer depth requirement under 20 AAC 25.412(b) specifying packer depth within 200 ft. measured depth from above the top of the perforations, MHLLC request the packer/isolation equipment depth may be located above 200 ft. measured depth from above the top of the perforations/open interval, but shall not be located above the confining zone and shall have outer casing cement volume sufficient to place cement a minimum of 300’ measured depth above the planned packer depth. Given some of the Kuparuk Oil Pool injectors may be planned as horizontal wells, stimulation optimization efforts and well work feasibility may be impeded if the packer/isolation equipment depth is required to be within 200 ft. measured depth from above the top of the perforations/open interval. The tubing/casing annulus pressure of each injection well will be tested in accordance with 20 ACC 25.412(c). Drilling and completion operation will be performed in accordance with 20 ACC 25. In accordance with 20 AAC 25.412(d), cement quality logs, or other data approved by the Commission, will be provided for all injection wells to demonstrate isolation of the injected fluids to the approved interval. All SMU Kuparuk Oil Pool injection wells will: x Be cased and cemented above the reservoir interval to prevent leakage and contamination into oil, gas, or freshwater sources. x Be equipped with tubing and a packer or with other equipment that isolates pressure to the injection interval, unless the Commission approves the use of alternate means to ensure that injection of fluid is limited to the injection zone. x Be pressure-tested to demonstrate the mechanical integrity of the tubing and packer (or with other equipment that isolates pressure to the injection interval) and of the casing immediately surrounding the injection tubing string. x Have a cement quality log or other well data approved by the Commission to demonstrate isolation of the injected fluids to the approved interval. pg. 13 Section J - Logs of Injection Wells 20 AAC 25.402(c)(9) 20 AAC 25.402(c)(9) ·An application for injection must include a statement of the type of fluid to be injected, the fluid's composition, the fluid's source, the estimated maximum amounts to be Injected daily, and the fluid's compatibility with the injection zone. Waterflooding will be implemented as the initial enhanced recovery mechanism for the proposed SMU Kuparuk Oil Pool with the use of both produced water and treated seawater. Seawater will be delivered through a pipeline spur off the nearby Alpine water pipeline. Additionally, waterflooding may be followed later with either lean gas or miscible gas injection to further improve recovery. Other fluids may also be injected for reservoir stimulation, reservoir performance, evaluation, freeze protection, or chemical inhibition; however, these fluids are not planned for continuous injection as a means for enhanced recovery. The volumes of these other fluids are expected to be less than 0.1% of the total volume injected and are not expected to hinder the recovery efficiency of the proposed SMU Kuparuk Oil Pool. Types and sources of fluids requested for injection are (compositions included for fluids that may be dedicated injection fluids): x Source water from the Kuparuk seawater treatment plant (composition listed in Figure J-1) x Produced water from all present and yet-to-be defined oil pools within the SMU Kuparuk River Field, including without limitation the Kuparuk Oil Pool. x Enriched hydrocarbon gas (MI): Blend of KRU lean gas with indigenous and/or imported natural gas liquids (composition listed in Figure J-3) x Lean gas (composition listed in Figure J-3) x Fluids used during hydraulic stimulation x Tracer survey fluids to monitor reservoir performance (chemical, radioactive, etc.) x Fluids used to improve near wellbore injectivity (via use of acid or similar treatment) x Fluids used to seal wellbore intervals which negatively impact recovery efficiency (cement, resin, etc.) x Fluids associated with freeze protection (diesel, glycol, methanol, etc.) x Standard oilfield chemicals (corrosion inhibitor, scale inhibitor, etc.) Fluid Compatibility Dispersed clay in the sandstone layers is not prone to swelling when in contact with typical injection water salinities expected to be used in the SMU Kuparuk Oil Pool. Analyses of formation water samples collected from the Kuparuk producers within the KRU indicate the potential for moderate scaling during production and when the formation water mixes with seawater. The specific scale risks are listed below. x Produced Water Injection o BaSO4 and CaCO3 o Scale risks are minimized with the injection water going deeper into formation x Seawater Injection o BaSO4 risk is high from wellbore throughout the mixing zone o CaCO3 risk is minor in reservoir beyond the near wellbore area Scaling mitigation measures include placement of aqueous and solid phase scale inhibitors in fracture treatments, conventional squeeze treatments, and chemical injection in the wells and at the surface. The analyses of the formation water samples listed above indicate that the scale risk is expected to be controlled utilizing these measures. Field injectivity data from analogous reservoirs (The Kuparuk River Field, Kuparuk Pool and Nanuq/Kuparuk in the Colville River Field) suggest limited permeability degradation will occur with properly treated injection fluids. pg. 14 No compatibility issues between injection gas and Kuparuk Reservoir fluids have been identified. Fluids used for hydraulic stimulation are planned to include a mixture of water (freshwater, seawater, or produced water), gelling agents added to make the fluid thicker and slicker, and larger grain ceramic sand to improve and sustain conductivity within the fracture through the life of the well. Hydraulic stimulation operations will be performed in accordance with 20 AAC 25.283. Hydraulic stimulation formulations may be adjusted as new technologies emerge and as the reservoir characterization is further defined. Injection Volumes Estimated maximum injection rate for each injector is estimated at 6,000 barrels of water per day and 6 million standard cubic feet of gas per day; however, injection rates will be confined by injection pressures as to not exceed the overburden pressure gradient and cause fractures to penetrate through the confinement layer. pg. 15 Section K – Injection Pressures 20 AAC 25.402(c)(10) 20 AAC 25.402(c)(10)- An application for injection must include the estimated average and maximum injection pressure. MHLLC proposes to develop the SMU Kuparuk Oil Pool using a waterflood and IWAG flood, with the option to convert to an MWAG or rich gas flood to enhance recovery from the reservoir. Injection rates will be managed to replace production voidage and will be controlled by surface chokes. The upper and lower confining intervals, the Kalubik and Miluveach shales, respectively, have fracture gradients based on the offset well data of 0.80 psi/ft or higher. To ensure containment of injected fluids within the SMU Kuparuk Oil Pool, water injection pressures are designed for a maximum of 4700 psi bottom-hole pressure or (and will not exceed the confining layer fracture gradient. Average water injection pressure gradient is expected to be 0.67. Figure K-1 lists the estimated wellhead pressures and bottom-hole pressures. pg. 16 Section L – Fracture Information 20 AAC 25.402(c)(11) 20 AAC 25.402(c)(11) -An application for injection must include evidence to support a commission finding of that each proposed injection well will not initiate or propagate fractures through the confining zones that might enable the injection fluid or formation fluid to enter freshwater strata. An internal containment assurance analysis, obtained by MHLLC, indicates that the estimated maximum injection pressures for the Kuparuk wells (listed in Section K) in IWAG or MWAG service will not initiate or propagate fractures through the confining strata and therefore, will not allow injection or formation fluid to enter any freshwater strata. The internal containment assurance analysis involved the use of a fracture model built based on the nearby KRU 2S-13pb1 well log data and calibrated by using data from nearby geo-mechanical tests and pressure history matched data from the North Tarn #1 fracture stimulation results. The simulations of the hydraulic fracturing stages and long-term water injection cases were run and indicate that fracture growth is contained within the Kuparuk Oil Pool without risk of breaking through overburden or under-burden containment zones. The frac modelling software used was the Grid Oriented Hydraulic Fracture Extension Replicator (GOHFER), due to its reliability and common use by North Slope operators as well as in the fracturing industry. GOHFER is a planar 3-D geometry fracture simulator developed by Barree & Associates in association with Stim-lab and is commercially available throughout the industry for performing hydraulic fracture simulation work. Modeling the growth of hydraulic fractures induced by water injection into the Kuparuk C zone was conducted using the three-dimensional numerical simulator. Results suggest that hydraulic fractures can be created and extended within the Kuparuk A and C formations if water injection is conducted at surface pressures above 1700- 2000 psi. This modeling also indicated that created fractures would be contained within the Kuparuk interval unless the surface injection pressure rises to more than 2700-3000 psi. Based on the computed and calibrated stress profile, and the model results presented here, it is possible to initiate and propagate fractures with water injection in the Kuparuk formation at surface pressures up to 2000 psi, with all created fractures contained within the sands by the in-situ stress contrast between the sands and bounding silt/shale layers. An increase in fracture treating pressure of more than 1000 psi above the stable fracture extension pressure indicated by the model is required before excessive fracture height growth develops. The calibrated stress and fracture model predict height containment within each reservoir interval. It is not able to accurately predict the lateral extent of the created fractures. Rate of fracture extension (laterally) depends primarily on the balance between injection rate and leakoff rate to the surrounding formation. This can be affected by spatial changes in pore pressure and reservoir quality, and by progressive plugging or damage to the formation sand-face caused by injected suspended solids and contaminants. To study how fractures are initiated during injection in the Kuparuk Reservoir and whether they can be effectively contained within the target interval, the following cases were simulated for a horizontal well penetrating and injecting into a single point within the Kuparuk “C”. Single point injection models the worst-case scenario for the induced pressure on the confining layers. In practice, injecting along the length of the lateral will result in less fracture height growth at each point. Injection at a single point would lead to the most fracture growth in the zone. Increasing the number of injection points in the well will decrease the possibility of fracturing out of zone. 1) Water Injection without propped fracture at 3,000 bpd (Figure L-1,2,3,4,) 2) Water Injection without propped fracture at 6,000 bpd (Figure L-5,6) The above simulations indicate that injection induced fractures will be contained within the Kuparuk Reservoir; no breakthrough of the overburden or under-burden containment zones will occur. pg. 17 Section M – Formation Water Quality 20 AAC 25.402(c)(12) 20 AAC 25.402(c)(12)- An application for injection must include a standard laboratory water analysis, or the results of another method acceptable to the commission, to determine the quality of the water within the formation into which fluid injection is proposed. Laboratory analysis of the Kuparuk Reservoir water sample collected from the North Tarn #1A well test is above the 10,000 mg/l cut off for freshwater. Based on the calculation of the weight percent of the chloride ions (chlorine molecules in the analysis) and sodium ions in the analysis from Kuparuk Lab, the total weight percent would be 1.66 weight percent which translates to 16,600 parts per million. This is consistent with the 15,000 to 20,000 ppm readings that are measured from the Kuparuk Reservoir. In fresh water - official salt concentration limits in drinking water US: 1000 ppm. Salinity of the Kuparuk Reservoir water in nearby Kuparuk River Unit producers found a salinity range from approximately 16,000 to 20,000 mg/l NaCI. Based on this information, the Kuparuk Reservoir is not a source of drinking water. Composition of the North Tarn #1A water, gas and crude oil composition is listed in Figures M-1, 2 and 3. pg. 18 Section N – Aquifer Exemption 20 AAC 25.402(c)(13) 20 AAC 25.402(c)(13)- An application for injection must Include a reference to any applicable freshwater exemption issued under 20 AAC 25.440. Minimum values of formation water salinity in the Southern Miluveach Unit Area, west of the Kuparuk River Unit and continuing into the NPRA through the Colville River Unit determined using standard open hole wellbore geophysical methods which have been calibrated from drill stem and production testing, range from over 3,000 to 18,000 milligrams per liter ("mg/l") total dissolved solids ("TDS"). This evaluation was conducted by qualified petrophysicists contracted from Schlumberger Oil Field Services by Brooks Range Petroleum. Permafrost extends from the surface to approximately 1300’ TVDss in the SMU, although partially frozen zones locally exist to a depth of 1800’ TVDss. As such, no fresh water aquifers exist within the planned development from the surface to this depth. Any potential aquifer sands that could be located below this interval would be considered uneconomic sources of drinking water in this area. No significant permeable zones have been identified in any nearby wells that penetrate the stratigraphy below permafrost and above the first potential hydrocarbon bearing reservoir intervals. The first potential hydrocarbon zone in the SMU could be found at a depth of about 4000’ TVDss, which is stratigraphically equivalent to the shallowest producing horizon in the nearby Tarn oil pool. This zone, stratigraphically equivalent to the Tarn Pool has not yet been proven to be a productive oil pool within the SMU. A petrophysical evaluation of the zone from the base of permafrost to 4000’ TVDss was conducted on the nearby West Sak 25590 15 well which has a complete logging suite suitable for estimating the Total Dissolved Solids content (TDS) and salinity. From this analysis, the TDS/Salinity content of the fluids in these sands is calculated to be more than 3000 ppm. Hence, by definition, there are no drinking water aquifers identified in the vicinity by this analysis. The EPA has adopted an aquifer exemption for the "portions of aquifers on the North Slope described by a mile area beyond and lying directly below the Kuparuk River Unit oil and gas field." 40 CFR147.102(b)(3). The Commission has adopted that exemption by reference 20 AAC 25.440(c). All of the proposed SMU Kuparuk Oil Pool and the area to which the proposed AIO applies is within the ORIGINAL Kuparuk River Unit as approved in 1984 when the Environmental Protection Agency adopted the original aquifer exemption, and in 1986, when the Commission incorporated the KRU aquifer exemption. As such, the original aquifer exemption still applies to the proposed SMU AIO. An aquifer exception should be granted for the SMU based on these factors and analysis. No fresh water aquifers are found within the development area of the SMU. pg. 19 Section O – Hydrocarbon Recovery 20 AAC 25.402(c)(14) 20 AAC 25.402(c)(14) -An application for injection must include the expected incremental increase in ultimate hydrocarbon recovery. The quality of the crude requires adoption of a secondary recovery mechanism to obtain an economic production profile. Water injection has been implemented as the main improved recovery process for the Kuparuk River Field and will also be planned for the SMU Kuparuk Oil Pool. This waterflood technique has been widely used on North Slope with consistent success. The SMU Kuparuk Oil Pool will employ a horizontal well line drive pattern IWAG flood, with the option to convert to an MWAG or rich gas flood, to enhance recovery from the reservoir. Some wells will likely be hydraulically fracture stimulated to enhance productivity and improve vertical injection sweep. Most wells will trend north to south, sub parallel the maximum principal stress direction to improve waterflood performance, and range in length up to 6,000 feet within the reservoir (Figure O-1). Wells will generally be arranged end-to-end to form alternating rows of producers and injectors in a line-drive flood pattern. After taking into account structural constraints, a nominal 1,500 ft. inter-well spacing is expected to deliver adequate secondary response. Initial wells will provide critical performance and injection data for the SMU Kuparuk Pool which may, in combination with additional geologic and engineering studies, change the number of wells, well spacing, well design, and well placement for the remaining SMU Kuparuk Pool development. The primary uncertainties in the development of the SMU Kuparuk Oil Pool are the lateral continuity of the relatively thin sandstones and the effective displaceable pore volumes. The seismic signature of the SMU Kuparuk Pool reservoir is consistent with and supports laterally continuous productive sandstones over the development area with some compartmentalization possible. Hydraulic fracture stimulation will aid in connecting the more poorly developed sandstone intervals. Reservoir modeling predictions indicate that primary recovery will be approximately 10 to15% of the original oil-in- place ("OOIP") and that waterflood recovery will range from 10% to 25% incremental recovery OOIP, yielding a total recovery with waterflood of up to 35%. Gas injection, whether miscible or immiscible, could yield incremental recovery in the SMU Kuparuk Oil Pool. Historical IWAG incremental recovery has been in the range of 1-5% of OOIP, while MWAG incremental recovery has been demonstrated to range from 3-15% of OOIP. Due to uncertainty in natural gas liquid ("NGL") supply, there is uncertainty in the composition of gas that will be available for injection in the Kuparuk Interval. Therefore, it is not possible at this time to predict with certainty whether or not miscibility between the injected gas and the formation oil will is possible. Resource recovery for water and gas floods is primarily dependent on injection throughput, water and gas injection conformance, and displacement efficiency. pg. 20 Section P – Confinement in Offset Wells 20 AAC 25.402(c)(15) 20 AAC 25.402(c)(15)- An application for Injection must include a report on the mechanical condition of each well that has penetrated the injection zone within a one-quarter mile radius of a proposed injection well. At the time of this report, no wells have been drilled within a one-quarter mile radius of each other within the SMU. However, the development may contain additional wells within this offset distance. Specific approvals for any new injection wells or existing wells to be converted to injection service will be obtained pursuant to 20 AAC 25.005, 25.280 and 25.507, or any applicable successor regulation. pg. 21 Section Q – Proposed Area Injection Order Rules 20 AAC 25.402(c)(16) The rules set forth apply to the following area referred to in this order: Umiat Meridian T10N, R7E Sections 1,2,3,4,9,10,11,12 all T11N, R7E Sections 24,25,34,35,36 all Rule 1. Authorized Injection Strata for Enhanced Recovery Fluids authorized under Rule 3, below, may be injected for the purposes of pressure maintenance and enhanced hydrocarbon recovery within the proposed SMU Kuparuk Oil Pool, which is defined as the accumulation of oil and gas common to and correlating with the interval within the North Tarn #1 well between the depths of -6006 ft. TVDSS and -6096 TVDSS respectively). Rule 2. Well Construction In lieu of the packer depth requirement under 20 AAC 25.412(b), the packer/isolation equipment depth may be located above 200 ft. measured depth from above the top of the perforations/open interval; but shall not be located above the confining zone and shall have outer casing cement volume sufficient to place cement a minimum of 300' measured depth above the planned packer depth. Rule 3. Authorized Fluids for Injection for Enhanced Recovery Fluids authorized for injection are: a. Source water from the Kuparuk seawater treatment plant b. Produced water from all present and yet-to-be defined oil pools within the SMU Kuparuk River Pool, including without limitation the Kuparuk Oil Pool. c. Enriched hydrocarbon gas (MI): Blend of KRU lean gas with indigenous and/or imported natural gas liquids d. Lean gas e. Fluids used during hydraulic stimulation f. Tracer survey fluids to monitor reservoir performance (chemical, radioactive, etc.) g. Fluids used to improve near wellbore injectivity (by use of acid or similar treatment) h. Fluids used to seal wellbore intervals which negatively impact recovery efficiency (cement, resin, etc.) i. Fluids associated with freeze protection (diesel, glycol, methanol, etc.) j. Standard oilfield chemicals (corrosion inhibitor, scale inhibitor, etc.) Rule 4. Authorized Injection Pressure for Enhanced Recovery Injection pressures will be managed as to not exceed a maximum injection gradient of 0.77 psi/ft.to ensure containment of injected fluids within the SMU Kuparuk Oil Pool. Rule 5. Administrative Action Upon proper application, the Commission may administratively waive the requirements of any rule stated above or administratively amend the order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering or geoscience principles, and will not result in an increased risk of fluid movement into freshwater. pg. 22 List of Figures/Exhibits B-1: Plot of the SMU Kuparuk Oil Pool Area and all Existing Wells D-1: Affidavit F-1: Outline of AIO and Pool Area highlighting leases outside of the SMU F-2: Defining Well, North Tarn 1A, highlighting Pool interval with respect to the upper and lower confining intervals G-1: West to East Schematic Stratigraphic Cross Section Across Area of Interest G-2: Kuparuk “C” Reservoir Isochore G-3: Kuparuk “A4” Reservoir Isochore G-4: Kuparuk “A3” Reservoir Isochore G-5: West to East Well Cross Section across the AIO Area G-6: Lower Cretaceous Unconformity (LCU)/Kuparuk “C” Structure Grid I-1: Generic Kuparuk Injector Well Design J-1: Kuparuk Seawater Treatment Plant Water Composition J-2: Kuparuk Gas Injectant Composition J-3: Kuparuk Pool Produced Water Composition K-1: Southern Miluveach Unit, Kuparuk Oil Pool Injection Pressure Summary L-1: Well log from 2S-13PB1 used in GOHFER fracture analysis L-2: Model of single point Injection into the Kuparuk “C” L-3: Injection pressure modeled at 3000 BOPD L-4: Fracture geometry, exhibiting containment within the Kuparuk formation at 3000 BOPD L-5: Injection pressure modeled at 6000 BOPD L-6: Water Injection Without Propped Fracture At 6,000 BPD M-1: SMU Kuparuk Pool Water Sample Analysis from North Tarn 1A Well Test M-2: SMU Kuparuk Pool Gas Sample Analysis from North Tarn 1A Well Test M-3: SMU Kuparuk Pool Crude Oil Sample Analysis from North Tarn 1A Well Test O-1: Map of Proposed SMU Kuparuk Development Wells pg. 23 B-1: Plot of the SMU Kuparuk Oil Pool Area and all Existing Wells pg. 24 pg. 25 F-2: Defining Well, North Tarn 1A, highlighting Pool interval with respect to the upper and lower confining intervals Kalubik Shale Upper Confining Miluveach Shale Lower Confining Layer pg. 26 G-1: West to East Schematic Stratigraphic Cross Section Across Area of Interest pg. 32 I-1: Generic SMU Kuparuk Pool Injector 4 String Casing Well Design pg. 33 J-1: Kuparuk Seawater Treatment Plant Water Composition pg. 34 J-1: Kuparuk Seawater Treatment Plant Water Composition (Continued) pg. 35 J-2: Kuparuk Gas Injectant Composition pg. 36 J-3: Kuparuk Pool Produced Water Composition pg. 37 J-3: Kuparuk Pool Produced Water Composition (Continued) pg. 38 Figure K-1: SMU Kuparuk Oil Pool Injection Pressure Summary Injection Type Estimated Wellhead Pressure (PSIA) Estimated Bottom-hole Pressure Average* Maximum** Average* Maximum** Water Injection 1400 2100 4000 4700 Gas Injection 3800 4000 4410 4610 *Based on planned operations at a true vertical depth of 6100 feet ** Maximums vary according to actual interval depth Assumptions: Datum (TVDss) 6100 Average Injection Gradient 0.67 Maximum Injection Gradient 0.77 Confining Zone Fracture Gradient 0.80 CPF-3 Fluid Gradient (Water) 0.442 Gas Gradient (Produced Gas) 0.10 Calculations: Bottom Hole Pressure (BHP)=Datum (TVDss)*Injection Gradient (Water or Gas) Hydrostatic Pressure = Datum (TVDss) * Fluid Gradient Well Head Pressure (WHP)=BHP-Hydrostatic Pressure pg. 39 Figure L-1: Well log from 2S-13PB1 used in GOHFER fracture analysis pg. 40 Figure L-2: Model of single point Injection into the Kuparuk “C” pg. 41 Figure L-3: Injection pressure modeled at 3000 BOPD pg. 42 Figure L-4: Fracture geometry, exhibiting containment within the Kuparuk formation at 3000 BOPD pg. 43 Figure L-5: Injection pressure modeled at 6000 BOPD pg. 44 Figure L-6: Water Injection Without Propped Fracture At 6,000 BPD pg. 45 M-1: Oil/Water Sample Analysis, North Tarn 1A pg. 46 M-2: Gas Sample Analysis, North Tarn 1A (Continued) pg. 47 M-3: SMU Kuparuk Pool Crude Oil Sample Analysis, North Tarn 1A