Department of Commerce, Community, and Economic Development
Alaska Oil and Gas Conservation Commission
Loading...
HomeMy WebLinkAboutCO 117Conservation Order Cover Page
XHVZE
This page is required for administrative purposes in managing the scanning process. It marks
the extent of scanning and identifies certain actions that have been taken. Please insure that it
retains it's current location in this file.
~_/_. ~;~_ Conservation Order Category Identifier
Organizing
RESCAN
[] Color items:
[] Grayscale items:
[] Poor Quality Originals:
[] Other:
NOTES:
DIGITAL DATA
[] Diskettes, No.
[] Other, No/Type
OVERSIZED (Scannable with large
plotte~
[] Other items
OVERSIZED (Not suitable for
plotter/scanner, may work with
'log' scanner)
[] Logs of various kinds
[] Other
BY: /~.¢.~ARIA
Scanning Preparation
Production Scanning '
Stage I PAGE COUNT FROM SCANNED DOCUMENT:
PAGE COUNT MATCHES NUMBER IN SCANNING PREPARATION: ~ YES
NO
BY;
Stage 2
'IF NO IN STAGE 1, PAGE(S) DISCREPANCIES WERE FOUND: ~ YES ~ NO
RIA DATE: '__ /SI
(SCANNING IS COM~OINT UNLESS SPECIAL ATTENTION IS REQUIRED ON AN INDIVIDUAL PAGE BASIS DUE TO QUALITY, GRAYSCALE OR COLOR IMAGES)
General Notes or Comments about this Document:
5/21/03 ConservOrdCvrPg.wpd
STATE OF ALASKA
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF OIL AND GAS
Alaska 011 and GAs Conservation Committee
3001 Porcupine Drive
Anchorage, Alaska 99501
Re: The application of BP Alaska Inc. )
for an exception to Rule 2 of Conserva- )
tion Order No. 98-B for relief from the )
the footage spacing requirements for )
nineteen wells in a specified area. )
Conservation Order 117-A
Prudhoe Bay Field
Prudhoe Oil Pool
September 7, 1973
IT APPEAR I NG THAT:
I. BP Alaska Inc. submitted the referenced application dated July 26, 1973.
2. Notice of the hearing on this request was published in the Anchorage
Daily News on August 3, 1973 pursuant to Title II, Alaska Administrative
Code, Section 2009, and no protest was received.
F INDI NGS:
I. Rule 2 of Conservation Order No. 98-B requires that no pay be opened to
well bore closer then 3000 feet to any pay in the same pool opened to the
wel I bore of another wel I. The appl icant requested that the 3000 foot distance
be changed to 2000 feet.
2. Accurate directional drilling of a well to a precise target is difficult.
3. The pay section of a deviated well may be perforated for production over
a horizonal interval of several hundred feet, thereby limiting the permissible
target areas for future wells.
4. It is prudent to locate wells to permit future development on a 160 acre
pattern if required to increase ultimate recovery of oil.
CONCLUS ION:
The granting of applicant's request wi l not result in waste nor impair corre-
lative rights of affected parties.
NOW, THEREFORE IT IS ORDERED THAT:
Applicant, BP Alaska, Inc. is hereby granted an exception to Rule 2 of
Conservation Order No. 98-B to permit the opening of pay in the well bore
Con se rvat i on 0 rde r NIL I 17-A
Page 2
September 7, 1973
no closer than 2000 feet to any pay in another well in the same pool in each
of the following sections:
Township II N- Range 13E, tJ.M.
Sec. 5, 8, I0, II, 14, 16, 22, 23, 24, 25, 26, 36.
Township II N- Range 14E, IJ.M.
Sec. 6, 7, 18, 30, 31, 32.
Township 12 N - Range 14E, U.M. Sec. 32.
DONE at Anchorage, Alaska and dated September 7, 1973.
Thomas R. Marshall, Jr., Executive Secretary
Alaska Oil and gas Conservation Committee
Concurr Ing:
Homer L. Burrell, Chairman
Alaska 011 and Gas Conservation Committee
Alaska Oil and Gas Conservation Committee
STATE OF ALASKA
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF OIL AND GAS
Alaska 0II and Gas Conservation Committee
3001 Porcup I ne Drl ve
Anchorage, Alaska 99501
Re: THE APPLICATION OF BP ALASKA,
INC. for an exception to Rule 2 of
Conservation Order No. 98-B to
permit the drilling and completion
of two oll wells per governmental
section on selected sectlons In the
Prudhoe 0II Pool.
Conservation Order No. 117
Prudhoe Bay Fleld
Prudhoe Ol I Pool
March 5, 1973
IT APPEARING THAT:
I. BP Alaska, Inc. by letter dated January 16, 1973, requested the referenced
exception for 19 wells to be drilled and completed In the Prudhoe Bay Field,
.Prudhoe 0II Pool.
2. Notlce of publlc hearing was published In the Anchorage Dally News on
February I, 1973, pursuant to Tltle II, Alaska Administrative Code, Section
2009.
3. A public hearlng was held on February 16, 1973, In the City Council
Chambers of the Z.J. Loussac Library, 5th Avenue and F Street, Anchorage,
Alaska, at which time the applicant and affected partles were heard.
FINDINGS:
I. Applicant Is developing leases it operates In the westerly portion of
the Prudhoe Bay Field with one active drilling rig.
2. Forty-one wells capable of producing oll have been drilled and suspended
by applicant, and under Rule 2 of Conservation Order No. 98-B only three
additional Prudhoe 011 Pool locations remain undrllled on the applicant-
operated leases in the westerly portion of the Prudhoe Bay Field.
3. Negotiations on the proposed Prudhoe Bay Unit are continuing, and applicant
Is unwllllng to drlll outside the operating area tentatively assigned to It.
Three of the 19 proposed wells will not be drilled until applicant reaches
agreement with other lessees In Its operating area.
4. Unless the requested exception Is granted, applicant may cease drill lng
operatlons within the referenced pool wlthln a few months.
Conservation Order 117
Page 2
March 5, 1973
5. Delays In approval of the trans-Alaska plpellne will delay the start-
up date; therefore, applicant plans to Increase the field production rate
during the early stages of production.
6. An Increased field production rate necessitates additional producing
wells, Inasmuch as (a) testing of recently drilled wells Indicates a wide
variation In productivity Index, and (b) some wells will occasionally be
shut-in for service and repair.
7. The drilling of the 19 wells would not reduce the ultlmate recovery from
the pool but might result in a greater ultimate recovery by more efflclent
dral nage patterns.
8. There Is no evidence that the drllllng and completion of the proposed
19 wells would result In waste.
9. Correlative rlghts of affected operators can be protected by allowing
them to drill on the same spacing or by restricting production rates of
the 19 wells requested by the applicant and/or other wells In proxlmlty
thereto.
I0. Exxon Company, USA was the sole objector to applicant's request, but
failed to offer any evidence in support of Its objection.
CONCLUSION:
I. The granting of applicant's request will not result In waste nor Impalr
correlative rights of affected parties.
NOW:, THEREFORE, IT IS ORDERED THAT:
Applicant, BP Alaska, Inc. Is hereby granted an exception to Rule 2 of
Conservation Order No. 98-B to permit the drllllng, completion and pro-
duction of two oll wells In each of the following sections in the referenced
pool:
Townshlp lin - Range 13E, U.P.M.
Sec. 5, 8, I0, ii, 14, 16, 22, 23, 24, 25, 26 and 36.
Townshlp liN - Range 14E, U.P.M.
Sec. 6, 7, 18, 30, 31 and 32.
Township 12N - Range 14E, U.P.M.
Sec. 32.
Conservat!on Order 117
Page 3
March 5, 1973
DONE at Anchorage, Alaska and dated March 5, 1~73.
Thomas R. Marshall, Jr., E×ecutlve Secretary
Alaska 0II and Gas Conservation Committee
Concurrence:
Homer L. Burrell, Chalrman =
Alaska 0II and Gas Conservation Committee
O. K. Gl lbreth, Jr.,
Alaska 011 and Gas Conservatlon Committee
BP ALASKA INC.
Mr. Homer L. Burrell, Director
State of Alaska
Department of Natural Resources
Division of Oil & Gas
3001 Porcupine Drive
Anchorage, Alaska 99504
P.O. BOX 4-1379
3111 - C - STREET
ANCHORAGE. ALASKA 99503
TELEPHONE (907) 279-0644
August 7, 1973
1 CT,DE
2 GF. OL
....
DRAFT
SEC
CONFER:
/ ! 7--A-
Dear Mr. Burrell:
Reference a recent telephone conversation with our Mr. A. K.
Howard regarding our application by letter of July 26, 1973
for an exception to Conservation Order 117 as it incorporates
Rule 2 of Conservation Order 98-B to permit a closer well
spacing for the nineteen (19) wells referred to in Conservation
Order 117, we wish to confirm as requested that the information
has been relayed to Exxon Company, U.S.A., and further that
Exxon Company, U.S.A. have indicated verbally that they have
no technical objection to our application for an exception to
drill the aforementioned nineteen (19) wells on a closer well
spacing.
Should you require additional information concerning this matter,
please contact us.
Very truly yours,
D~anager
CGM;vjp;hw
cc: Mr. Judd Miller, Jr., Exxon Company, U.S.A., Los Angeles
Vice President Production & Planning, BP Alaska, New York
Manager Field Development Planning, BP Alaska, New York
File DEV-PB-741/4
,tdJ 9
At~anticRichfie]dCompany
North American ?roducin~t Division
Post Off,c%. ,='ox 360
Anchorage, .A~asks 99510
Telephone 907 277 5637
O. G. Simpson
No~h Alsska D~stdct Msnager
August 2, 1973
~4r. Homer Burrell, Director
Division of Oil and Gas
Department of Natural Resources
State of Alaska
3001 Porcupine Drive
Anchorage, AK 99504
5 ENG I~
· .
2 GEOL
- ,.-.,
3 G'...,t
R.r.-v
DR,AFT-
_.
SEC
CONFER:
Dear Mr. Burrell'
Atlantic Richfield has no objection to granting BP Alaska
Inc. a spacing exception to Conservation Order 117, as it
incorporates Rule 2 of Conservation Order 98-B. Specifi-
cally, we, Atlantic Richfield, have no objection to BP
Alaska Inc. receiving permission to drill any of the nineteen
wells referred to in Conservation Order 117 in such a manner
that the pay open to production be up to, but no closer than,
2000 feet from the pay open to production in an adjacent well.
The maximum distance between wells on a regular 320-acre
spacing pattern is approximately 3700 feet. The 3000
foot spacing rule currently in effect requires that. direc-
tional control be very precise to obtain this regular
spacing and not violate the 3000 foot rule on these '320-acre
spaced wells. Additionally, many of the original BP Alaska
Inc. wells do not conform with a rigorous 320-acre spacing
pattern. In order to effect this pattern for the nineteen
wells covered by Conservation Order 117 and any future 320-
acre locations, exceptions to the 3000 foot spacing rule
are required.
It is Atlantic Richfield's opinion that ultimate recovery
will be improved if future wells are drilled on regular
spacing patterns. Thus we have no objection to this spacing
relief request of BP Alaska Inc.
Very truly yours,
OGS: PBN: j a ~
BP ALASKA INC.
August 2, 1973
Mr. Homer L. Burrell
Director
State of Alaska
Department of Natural Resources
Division of Oil and Gas
3001 Porcupine Drive
Anchorage, Alaska 99504
P.O. BOX 4-1379
3111 - C - STREET
ANCHORAGE. ALASKA 99503
TELEPHONe (907) 279-0644
[ 2 GEOL
t 3 c~oC
I ,~v
.... !'-DRAFT'
t
i
Dear Mr. Burrell:
With reference to our application by letter of July 26, 1973 for an exception
to Conservation Order 117 as it incorporates Rule 2 of Conservation Order 98-B
to permit a closer well spacing for the nineteen (19) wells referred to in
Conservation Order 117 and, further to recent telephone communications with
our Mr. A. K. Howard, we submit the following information for your consideration
to substantiate our application.
The development scheme proposed for the initial phase of field production is
based on the following principles:
(1) The area initially being developed is restricted to the thicker part of
the oil column where there might be a later requirement for production or
injection wells on a .density equivalent to 160-acre spacing.
(2) Problems as to the geological configuration of the margins of the oil
accumulation are not a primary concern in locating wells internally within
this part of the field, and in the thick sand section with' low structural
dips the area can be treated as grossly homogeneous.
(3) The principal concern with well positions in this area then is one of
equally spacing wells for drainage, minimum interference, and possible
efficiency of recovery from injection processes in the future.
(4) The spacing pattern that achieves this is an equilateral triangular (or
hexagonal) pattern. Wells should be 5674 ft. apart for 640-acre spacing,
4012 ft. apart for 320-acre spacing, and 2837 ft. apart for 160-acre
spacing. It is apparent that a 320-acre pattern cannot be infilled
equally to achieve a 160-acre pattern.
Mr. Homer L. Burrell
Director
Division of 0il and Gas
- 2 - August 2, 1973
(5) As we see a possible need for future 160-acre spacing wells in the
middle part of the field, a development location grid has been drawn in
that area' on this basis (i.e.' 2837 ft. between Wells) adjusted as
necessary to compromise existing locations. In practice the plan needs
constant minor revision as each well is drilled and does not exactly
reach target. For the first stage of development we plan to drill
approximately half the locations in this grid and of necesSity ~(4. above)
this does not result in a completelY regular pattern. This is not
considered significant considering the spacing involved, but does imply
that some locations will have to be Programmed' in theory to be 2837 ft.
from~existing wells, which, with practical restrictions as outlined in
our application by letter~ of July 26, 1973, may be a somewhat lesSer
dis tance. '
Should you reqUire additional information concerning this matter' please
contact us.
CGM: vjp
VerY truly yours
BP ~'~K~ INC.
~L:/~--t~i~frict Manager
cc: Vice President, Production and
Planning, ' New York
Manager, Field DevelOpment
Planning, New' York
File DEV-PB- 741/4
STATE OF ALASKA, )
THIRD JUDICIAL DISTRICT, ) ss.
.... ~a~.y..L...S h ak.e ................
being first duly sworn on oath
· sba
deposes and says that ................
is the ...... ..~..e..~..EI..1.....C.]-...e.?l~f the
Anchorage News, a daily news-
paper. That said newspaper has
been approved as a legal news-
paper by the Third Judicial Court,
Anchorage, Alaska, and it is now
and has been published in the
English language continually as
'a daily newspaper in Anchorage,
Alaska, and it is now and during
all of said time was printed in an
office maintained at the aforesaid
place of publication of said news-
paper. That the annexed is a true
copy of a .--Le~-~q.].-.-N-o-t;.:j..oG
as it was published in regular
issues (and not in supplemental
form) of said newspaper for. a
period of .... OZ3~. ....... insertions,
commencing on the ..3. ........ day
of ........ ...7.3, ,nd
ending on the .........3 ........ day of
of ........ .~g.l:l..$.t ........ , 19...7..3,
both dates inclusive, and that
such newspaper was regularly
distributed to its subscribers dur-
ing all of sa,id period. That the
full amount of the fee charged
for the foregoing publication is
the sum of $13.75~ which
amount has been paid in full at
the rate of 25¢ per line; Mini-
mum charge t;7.50.
Subscribed~ sworn to before
me this .3. ...... day of .....
19.?.~..
Nota~ Public in and f~
the State ~ Alaska,
Third Division,
A~horage, Alaska
'~O~I~ION EXPIRES
' /?
........ .....
8029
lie ,PUBLICATION
NOTIOE OF PUBLIC HEARING'
STATE OF ALASKA
.DEPARTM. EN? OF NATURAL EESOL~ECE$
OIVI,~ION OF OIL. AND GAS
AI,asba:?~'Dil ~n,d Gas Conservation
', · .,:; , Committee
: Con'~erv~i,on ,'~Ha rio. $17 A~,'
for,:,ien or~er gra,r~ing on a6di-
· io~!,i exceFtion t~ ~onse~a*lon
,O~der ,Nq;' 98B ~ ,el, i,~ from
· ll,e~'fOo~ege epa,~ing reqUi,remen~
~or ~ '
, a,i~eteen, wel~ls ,in:the
'~Jas~",ln,'O./ ,b~:~',', ,~U~d' 'th,e' Oi, I
','"~ '" ' ' ~ ....... ..... ,L ' "'~%'~' ' , ,
',e~oed ',~e! I~',"':fro~. ~,~,,,:~,~" mini,
mum d~ot~6,oe, ~o~ire~e~, of the
~eferen~..~rden }',,~,~&fion ,'Order.
end prO~u~l,on' ~f~,' ~';,~j~ill, ~el,Is in',
,e~oh,'of?'~lg,sPeo~?~':'S~qns in the'
,'~PrudhoeOJl Pool.~'~'artiej who m~y
,, %grieved':,,.E ~be'f:~eque~eW or6er
~issued ',a~re' el, jo,:ed:' ,l~'~a~S' from ~h,e
,fil,e a ~.'~:D~: c'~ rc:.:st for hear-'
i,n,g. F.o:e of ~...;.~ i~ jO01
pi, ne O~,ive, ,~,oh,~n~ge,, Al,~s~a.::
J~h · ~t',,is,~i, mel,y fi'led~',l
}ng on, ~ matter ,wHI be held' ~
'1,4, '1'9~3~, et,Whi,oh *ime
and ,o~ers may: be ~ea,~d~ If~'jO]:J:g,~h
'~rofO~''i's 'tim~ y :,filed~ ,fha Chum,rte
~ Wil4 :..,o~nS~ider,::',':~he~:'' :.i~U~n~oI ~:~'
, , ,,' ,~ ; . , ,, ,., , ,
,,,. ,, ~,~,~..., '~,~,j,, j~.,,
., EXeO~tiVe ~e~a~, ,
' Cons'e'rv~i,on'
' ', ~i, "P'~rcupinje'. D~ive ,
~, , , ., . ,
NOTICE OF PUBLIC HEAR I~,IP~
STATE OF ALASKA
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF OIL AHF) GAS
Alaska Oil and Gas Conservation Oommittee
Conservation File No. 117 A
Re: The application B P Alaska Inc. for an order granting an additional
exception to Conservation Order Ho. 98B for relief from the footage
spacing requirements for nineteen wells in the Prudhoe Oil Pool
of the Prudhoe Bay Field.
Notice is hereby given that B P Alaska Inc., has requested the Oil
and Gas Conservation Committee to issue an order exempting the referenced
wells from the 3000 - foot minimum distance requirement of the referenced
order. Conservation Order I17 permitted the drilling completion and
production of two oil wells in each of 19 specified sections in the Prud-
hoe Oil Pool. Parties who may be aggrieved if the requested order is
issued are al lowed I0 days from the date of this publication in which to
file a protest and request for hearing. Place of filing is 3001 Porcupine
Drive, Anchorage, Alaska. If such a protest is timely fi led, a hearing on
the matter will be held at the above address at 9:00 AM August 14, 1973,
at which time protestants and others may be heard. If no such protest is
timely fi led, the Committee will consider the issuance of the order
without a hearing.
Thomas R. Marshall, Jr.
Execut i ve Sec reta ry
Alaska 011 and Gas Conservation Committee
3001 Porcupine Drive
Anchorage, Alaska 99501
Publish August 3, 1973
II
BP ALASKA INC.
P.O. BOX 4-1379
3111 - C - STREET
ANCHORAGE. ALASKA 99503
TELEPHONE (907) 279-0644
July 26, 1973
Mr. Homer Burrell, Director
Division of Oil & Gas
Department of Natural Resources
State of Alaska
3001 Porcupine Drive
Anchorage, Alaska 99504
Dear Mr. Burrell:
c.c. //7,4
In our request of January 16, 1973 for a change in the Prudhoe
Bay Oil Pool rules to permit us to drill two wells in selected
sections, and at the subsequent hearing on February 16, 1973,
we did not request a change in the required distance between
wells. Our intention at that time, pending the completion of
unitization negotiations, was not to unnecessarily request
changes in the existing rules unilaterally. It was our expect-
ation that we could continue our drilling program honoring the
3000-ft spacing rule, although that rule is not necessarily
consistent with any proposed ultimate development scheme.
However, two factors in practice and one in principle have
indicated to us that the procedure is too restrictive and we
see considerable advantage and no disadvantage to any party in
relaxing this spacing requirement. The factors are (1) the
difficulty in drilling a well to a precise target and the reli-
ability of directional surveying during drilling; (2) with the
deviations achieved and anticipated, the pay section of a well
could be required to be perforated for production over a hori-
zontal interval of several hundred feet, a factor which restricts
the available distance between wells; and (3) although not proven
to be necessary, it is prudent to locate present wells to allow
in the future for possible regular spacing of wells for production
or pressure maintenance on a grid equivalent to 160 acres.
We appreciate that the 3000-ft spacing rule was initially adopted
to avoid an uneven pattern of development well locations. It
is in an effort to achieve this objective that we now feel that
this spacing requirement should .be amended. Correlative rights
can be protected and ultimate recovery possibly enhanced in this
mmanner or, if the State should feel concern in this regard, it
could invoke a rule based on Finding 9 of Conservation Order 117.
We w~ould therefore request that we be granted an exception to
Conservation Order 117 as it incorporates Rule 2 of Conservation
Order 98-B. Specifically, we require permission to drill any
of the ~
19 wells referred to in Conservation Order 117 ia ~q~ ~ %~ ~
manner that their respective pay zones may be open~~~ ~ ~"
Mr. Homer Burrell
-]- July 26, 1973
completion for production to no closer than 2000 feet to any pay in the same
pool opened to the well bore of another well.
As we anticipate no objection to this request from any affected party with
holdings in the Prudhoe Bay Pool and we have no further 'testimony to offer
beyond that presented on February 16 and the above comments, we would apprec-
iate your ruling as to whether this request could be acted upon immediately,
formally published and ruled on by your Department without a hearing.
hw
cc: VP Production & Planning
.Mgr., Field Development Planning
Very truly yours,
D~'~trl.ct Manager
STATE OF ALASKA
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF OIL AND GAS
Alaska 011 and Gas Conservation Committee
CONSERVATION ORDER NO. 117
Prudhoe Bay Fleld
Prudhoe Ol I Pool
HEAR lNG
February 16, 1973
P R O C E E D I N G S
Mr. Burrell: Good Morning, Ladies and Gentlemen. This is a
hearing of the Alaska Oil and Gas Conservation Committee. My name
Is Homer Burrell, I'm Chairman; to my right, is Mr. Tom Marshall,
member of the Committee and Executive Secretary; to my left is Mr.
O. K..Gllbreth, member of the Committee; and to his left, on the end,
Is Mr. Hoyle Hamilton, a Petroleum Reservoir engineer with the Division
of Oil and Gas. Mr. Hamilton will aSsist us, and probably participate
In questions today.
This is a publlc hearlng, Conservation~Flle # 117 the application
of BP Alaska Inc. for an exception to rule 2 of Conservation Order #98-
B, to permit the drilling an~ completion of two oli wells per governmental
section on selected sections in the Prudhoe Bay Field, Prudhoe Oil Pool.
This was published February ~, 1973 in the Anchorage Daily News. We
will open the Public Hearing on this and ask the applicant to testify.
For your information we will ask anybody who testifies to come up where
they can be picked up by the microphone and anybody who testifies or
wishes to make a written statement at any time, and everybody here will
have the opportunity to do that at the conclusion of the applicant's
testimony and our questions. We may proceed now.
Harlan Fllnt: Mr. Chairman, my name is Harlan Flint. I am Managerof
Services for BP and an attorney. I'm here on behalf of BP Alaska. Wlth
me this morning is Mr. A. K. Howard, who will be our only witness to be
presented. Would you like to have him sworn at this time?
Mr. Burrell: Yes, could I ask you speak a little louder, Nr. Flint?
We are just barely catching you, according to our blinking light on the
tape recorder.
Mr. Flint: Right.
Mr. Burrell: Thank you. Nr. Marshall will swear Mr. Howard in.
Mr. Marshall: Would you please stand? Raise your right hand. In
the matter now at hearing do you swear to tell the truth, the whole truth
and nothing but the truth so help you God?
Mr. Howard: i do.
Mr. Flint: WIll you please state your full name?
Mr. Floward: My name is A. K. Howard.
Mr. FIlnt: And what Is your position with BP Alaska, Mr. Howard?
Mr. Howard: ! am Manager of Operatlons for BP Alaska, inc., In Anchorage.
Mr. Flint: Would you please give the Committee a brief resume of
your education and experience?
Mr. Howard: Yes I received a BS honors degree in electrical engineering
at the University of Nottingham in England In 1956. I am a fellow of
the Institute of Petroleum in London and am currently Chairman of the
Southwest Alaska Section of the Society of Petroleum Engineers of A IME.
I commenced work with the British Petroleum Company Ltd. in 1956. Having
received 15 months training In oll field drill lng, production and reservoir
engineering,..I was transferred to BP Trinidad Ltd. as a assistant Production
Engineer. During my period with BP Trinidad, I was assigned to the production
department as a production engineer for three years, petroleum reservoir
engineer for three years, and production superintendent for two years.
! was transferred to the Middle East in 1966 and became Senior Petroleum
Engineer with the Abu Dhabt Petroleum Company Ltd. in 1967. In 1969
-2-
I was appointed Senior Petroleum Engineer for BP's North Sea operations,
and the following year came to Alaska as Senior Technical Advisor for
BP Alaska. In this capacity my duties Include fleld development planning
of the Prudhoe 0II Pool and responsibility for engineering data collected
from BP Prudhoe wells~ In April 1972, I received my present appointment
in which I carry the responsibllity to BP Alaska's drilling and engineering
activities conducted on the North Slope.
Mr. Flint: Mr. Chairman, Mr. Howard has prepared his testimony
In form of a narrative statement for the Committee's approval. We would
like to have hlm proceed to present that, then answer any questions you
may have following his statement.
Mr. Burrell: That'll be fine, Mr. Flint, I would like the record~ito
reflect that Mr. Howard has previously qualified as a expert witness,
at a previous hearing before this Committee. You have not?
Mr. Howard: No sir.
Mr. Burrell: Dldn't you testify in the Prudhoe Bay hearing?
Mr. Howard: No, I dld not.
Mr. Burrell: 83 or 98?
Mr. Howard: No
Mr. Burrell: The first one or the second one?
Mr. Howard: No sir.
Mr. Burrell: Alright, I thought you had. I'm wrong and want the record
to reflect that you now are a accepted as an expert witness.
Mr. Howard: Thank you, Mr. Chairman.
Mr. Flint: Mr. Howard, will you then proceed wIth your statement?
-3-
Before the record, Mr. Chairman, before we proceed with the testimony
we did file an application with attachments, exhibit type attachments
which are the subject of thls hearing. Am I correct in my understanding
that that would be considered to be a part of the record of this hearing?
Mr. Burrell: Yes, the application for a permit to drill, is that
correct?
Mr. Flint: No, the application letter dated, dated January
1973 and attached Exhibit ~A~'~.
Mr. Burrell: Yes, that will be part of the record. It is in the
file at this t~me. Excuse me, Mr. Flint, I presume that was a request that
you made?
Mr. Flint: Yes, we do prefer that it be made part of the record.
Mr. E~urrelI: Thank you.
Mr. Flint: AIright Mr. Howard, you may now proceed.
Mr~ Howard: Mr. Chairman and members of the Alaska Oil and Gas
Conservation Committee. Since the discovery of the Prudhoe Bay Fietd~
two hearings have been he~d (in November 13-~4, 1969 and February
197~) to establish Pool Ru~es. During the course of this presentation,
t shall refer to testimony presented to you at botl~ of these hearings.
BP Alaska Inc. has requested this hearing to seek an exception to
Rule 2 of Conservation Order No. 98-B which~ If approved, would permit
the completion of two oil wells per governmental section in 19 selected
sections w~thin the BP A~aska operating area. In this context, reference
is made to a ~etter from BP A~aska to the Director of the Division of
-4-
011 and Gas, dated January 16, 1973, and to Exhibit "A" attached thereto
whtch counsel has asked to be included in the record.
As is generally known, BP Alaska is operating In the western part
of the Prudhoe Bay Field. An initial plan for this operating area, showtng
actual and proposed bottom hole well locations, is presented as Exhibit
':A~. The 72 wells shown comprise the first stage development wells
In this portion of the field. I don't know whether you can see this.
Mr. Burrell: I think a man on the iIght switch might help.a little blt.
Mr. Howard: I will briefly Indicate what this map represents and
this Is In fact the western part of the field, which I'm referring to.
The area to the east Is the ARCO operating area, this area is the BP
Alaska operating area. The map indicates a number of pads, drilling
pads, and these are Indicated in red on this map, although they are not
red on your Exhlblt. Thls map in fact was the base map on which the Exhibit
which you have was prepared. The darker dots represent, with the exception
of this one, and one, two, three~ four, five, six wells on there, which
in fact are in green, and I don't know whether you can see them clearly.
The darker dots, the remainder, are in fact wells which have already
been drilled and suspended. The yellow dots are the, represent the bottomhole
locations of the wells that we proposed to drill and to which we are
taking applications today, is that clear, can I give any further explanations
of that?
Mr. Burrell: That's adequate for my purposes. Does anybody have
any questions?
Mr. Flint: For the sake of the record, I might note that Mr. Howard
-5-
has been referring to a slide projected on the wall which corresponds
generally with what has been Identified as ap011cant's E×hiblt "A~'.
Mr. Burrell.' Thank you, Mr. Flint.
Mr. Howard: At the present time, development drilling is proceeding
with one active rig, and 41 scheduled future ~roduction wells have been
drilled and suspended. It is BP Alaska's wish to continue drilling first
stage development wells and the planned sequence for this drilling calls
for a number of so-cai led 320 acre spaced wells. It Is readily apparent
'from the Field Development Map (that's Exhibit '~A") that, having drilled
three more wells, no programmed additional wells could be completed in
the BP A~aska operating area within BP Oil Corporation's lease area under
existing rules.
I wou~d point out that these wells on your Exhibit are wells C-2,
which ls 17-1~-~4.. This well ls currently being drilled. Since Exhibit
~'A'~ was prepared we have in fact moved on to this location. On C-4, which
is 18-11-14 on your map, and another well H-6, which is in Section 20-
Testimony presented in February 1971 indicated that negotiations
were proceeding with the objective of forming a Prudhoe Bay Unit. These
negotiations are continuing and BP Alaska's development plan anticipates
the successful conclusion of the negotiations prior to production. For
this reason, it Is not BP Alaska's wish to drlll wells within BP 0il
Corporation leases situated In the ARCO operating area, which could be
completed under existing pool rules.
That is the area to the west of our demarcation line between the
ARCO and the BP operating area.
-6-
~lr. G i l breth~ To the west or to the east?
Mr. Howard~ Sorry to the east, I beg your ~ardon.
Similarly, until a unit is formed, there are difficulties associated
with drilling wells on other companies' leases~ and the developemnt drilling
program for the immediate future confines the wells to be drilled to
BP Oil Corporation leases in the BP Alaska operating area.
Having disclosed our progress and outlined our immediate future
plans for the development of our operating area~ I will now elaborate
a little on the overall philosophy which has led to our request at this
time for an exception to Conservation Order No. 9F~-B, Rule #2, regarding
Infi II wel
The Committee will be aware that, primarily as a result of delays
~n the issuance of the construction permit for the trans-Alaska plpe~ine,
drllling activity is at a Iow ebb on the North S~ope~ as compared with
the work being conducted at about the time of the 1969 North Slope lease
sale. At that time, in the Prudhoe Bay area alone~ $~veral ~tgs were
actively engaged In development or appraisal drilling and numerous support
services camps were located in the area, providing employment for many
hundreds of people. During the past year~ only one r~g has been continuously
utilized In this area and the support consists mainly of sporadic projects
which provide barely sufficient justification for many service companies
to continue operating, if the rig currently on contract to BP Alaska
and engaged in drilling Prudhoe E~ay development wells were to shut down,
there wou~d be further reductions in employment levels which wou~d not
only affect the drilling contractors, but have serious repercussions
In other companies as wel~.
During the years that BP Alaska Inc. has been engaged In drilling
and evaluating the Prudhoe Bay Field, It has acqulred expertise In dealing
with the problems peculiar to ~he area. Its staff, and those of the
service companles, have become aware, through trainlng and experience, of
acceptable and efficient methods of dealing with such mat~ers as the cold
envlronment, the permafrost, the dellcate ecosystem, and many others. We
belleve that it Is In the interest of our company, the oll Industry In
Alaska, and the State of Alaska, to continue operating and so maintain
these personnel as an effectlve force.
I wlll now make a few remarks concerning the approach BP~'~Alaska Inc.
has adopted for the Initial development of Its operating area for the
Prudhoe Bay Fleld.
,
Your committee was presented with geo~toglc and other Information on
the Prudhoe 011 Pool, at the Fleld Rules Hearing held on February 9, 1971,
whlch gave a general description of the field, Since that hearing BP
Alaska has conducted a number of addltlonal well production tests, the
results of which are now presented as Exhlblt ~'B". (For the sake of com-
pleteness, we have summarized the production test results obtained by BP
Alaska to date In Exhibit "B".)
Hr. Flint: Hr. Howard, are you now referring to.a sllde which wlll
depict the same Information shown on Exhlblt 'B'?
Hr. Howard: Yes, ~ am. This exhlblt summarizes the tests that we
have conducted to date. Th:Is column Indlcates well number, test date,
wellhead flowing pressure, which we have arbltrarlly picked, something
between, I thlnk the lowest wellhead flowlng pressure, was 1095, sorry 1076,
and the highest was 1360, whlch we antlclpate being wlthln the range
of our one one of our oil productlon. The choke sl~e the rate that we
-8-
obtaln from the well, the gas/oll ratlo, and the productivity Index.
I don't think I need say anymore about this. I think the rest of It
shou I d be se I f exp I anatory,
The President of Alyeska Is on public record as having Indicated
the trans-Alaska plpellne Is being designed for an Initial capacity of
600,000 BPD, which capacity may be Increased to an ultimate throughput
of 2,000,000 BPD. We cannot at this time commlt ourselves to a maximum
oll produclng rate for the Prudhoe Oil Pool, partlcularly as unltlzatlon
has not yet been concluded. However, we are confident that the reservolr
will sustain a substantially hlgher rate than the lnltlal pipeline capacity
of 600,000 BPD. It ls not uncommon In reservoirs of thls nature to anticipate
a's a rule of thumb a 25 to 30-year life. The recoverable reserves have
been quoted at 9.6 bllll°n barrels and this leads us to believe the reservoir
could ~ a crude oll production rate of approximately 1,000,000
:
BPD over a 25-year Ilfe. Durlng the early stages of production, It can
be reasonably expected the production level could be slgnlficantly higher
than the average rate. BP Alaska's flrst stage development plan Is predicated
on Its ability to ~ pr. oduce ha'If of the total field offtake during these
early stages of production.
Verbal testimony presented by Mr. Anderson of ARCO at the November
1969 Fleld Rules Hearing (Reference Is made on thls to R.'.& R Court Reporter's
transcrl pt, page 59) I nd I cared that one we I I cou Id adequately dral n
a 640-acre section and, assuming each well were capable of producing
I0,000 BPD, I00 wells could produce 1,000,000 BPD. We support this
testimony, although structural features could lnfluence the drainage
pattern In certaln areas. In pursuing thls matter further and with reference
-9-
to the production test results shown In Exhibit "B", I, Is evident that
not all wells will be capable of sustainlng a production rate of I0,000
BPD, and some allowance mus, be made for we l Is shut In for service and
other reasons.
The Committee wlll note that there Is a wlde varlatlon In productlvl~y
Index and hence we antlclpate a wlde varlatlon In Individual well offtake.
To go from ,he mlnlmum to the maximum we have well A-6, which Is 26-
11-13, which shows us a productlvl~y Index of six, with a complete production
Interval openlng, as compared wlth well 30-11-14 whlch Indicates productlvl~y
Index of 68.
SIm!larly, by assuming a production rate of hlgher than I million
BPD, a need for additional wells obviously arlses. Hence, the 72 wells
programmed should adequately provide the required production from the
BP Alaska operatl ng area.
The Commlt,ee wi II note that the proposed lnfll I wel Is are located
In areas of the fleld where a relatively ,hick oli column can be expected
and not on the flanks of the s,ruc,ure. We belleve that, by locating
,he wel Is here, the maximum producing life can be expected from them
whlle mlnlmizlng overall, well requirements, it may well be necessary
later to locate wells on the flank of the structure; however, at the
present s,age of our knowledge of the field, we have not planned such
W'~I is.
In concludlng~thls testimony, the Comml~,ee wlll be aware that an
exception to Conservation Order 98-8, RUle 2, Is requlred only at the
time of well com-pletlon. The Committee, however, wll I appreclate that
BP Alaska could not commlt funds for drill lng without receiving the assurance
that thls proposal Is acceptable to the State.
-I0-
Gentlemen, I wish to thank you for your attention and ! will be
glad to answer any questions you may have to the best of my ab llil~/.
Mr. Burre l I: Thank you Mr. Howard.
Mr. Fllnt: Mr. Chairman, for the sake of completeness here we should
move the admission of the statement, of the apl lcant's Exhibit "Bt', It
Is not attached to the orlglnal appllcatlon.
Mr. Burrell: Thank you very much. We'll Include that as applicant's
Exhlblt "B" for the record.
Mr. Flint: That then completes our case, Mr. Chairman.
Mr. Burrell: Thank you very much. We'll have a few questions of
Mr. Howard, I'm sure. Mr. Howard, as you know our statutory duties are
limited generally to the prevention of the waste, and the protection
of correlatlve rights. ~, you will no doubt be asked several questions
by the engineers here, partlcularly about the reservoir condltlons, to
justify the necessity for these wells. I'll ask you one about correlative
rights rlght now. I've noticed some of your proDosed wel Is on 320 acre
spaclng are adjacent to leases belong to other operators and there is
no problem If you are unltlzed. ~ you don't .get unitized, It would
of course under correlative rights protectlon necessity, they would have
the right to drill on the same spacing If they so requested.
Mr. Howard: Yes, I:thlnk our company appreciates this, Mr. Chairman.
You will perhaps be aware that the testimony that we presented to you
today has been made avallable to the people that own the leases adjacent
to our area and you will also note that In my testimony I did Indicate
that our development plan Is predicated on there being a unit prior to
our going on productlon.
-11-
Mr. Butte I I: I understand ,hat. I'll ask the other members of
the Commit,aa. as well as Mr. Hamilton. If they have any questlons of
Mr. Howard. Mr. Marshall. do you have any questions at this tlme?
Mr. Marshall: Yes. Mr. Howard your application for excep,lon Is
to Conservation Order 98-B. One of ,he flndlngs In ,ha, order was ,ha,
,he Saddlerochlt forma,lon con,alned very porous fine demeaning grained
well sorted quartz sandstone which are not separa,ed from each other
by Impermeable rock of sufflclen, ,hickness to constl,ute a permeability
barrier. In ,he lnterlm have you found any data which would con,rover,
this finding of the Commlt,ee?
Mr. Hc~ard: In certaln areas ,here could be variations. I Vm referring
here ,o possible faulting. We are no, at thls ,1me sure whether these
faul,s would be a barrier to the migration of fluids across them or whe,her
In fac, ,he flulds are ,ransmlsslble across them. We would not be able
,o ge, a firm handle on this Information untll such tlme as we came upon
production.
Mr. Marshal I: Thank you. Another flndlng of the Comml,,ee in fha,
order 98-B, was that ,he permeabl I I,y and pressure communlcatlon in the
Saddlerochlt forma, lon Is such that a well should draln 540 acres. Perhaps
Mr. Gl Ibre,h ls going ,o commen, on this and I should defer ,ha, question
,o after hls. For ,he ,Ime being then. I will. that wlll flnlsh my questlons.
Mr. Howard: Thank you.
Mr. Burrell: Mr. Gllbre,h.
Hr. Gl Ibre,h: Mr. Howard, you men, loned In your tes,lmony ,ha,
the In field wel Is fha, you are proposing here are located in the thlcker
par, of ,he s,ruc,ure. Can the Comml~-fee assume that the exhlblts presen,ed
-12-
the previous cases, that Is the structure maps and the lsopach maps are
stlll valid In so far as the Iocatlon of each of these locations Is concerned?
Hr. Howard: By and large, and for thls purpose, yes, you can assume
that. We have found minor varlatlons with regard to the structural map
that was presented to you In February 1971, but there is no significant
change to It.
Hr. Gllbreth: To the best of your knowledge there Is no significant
change In so far as any one of the proposed additional wells is concerned?
I~r. Howard: No, could you spell It out for me, please?
~lr. GI Ibreth: Well, we have nothing here to show that these wells
might not be over In the real thln area or something Ilke that, and
~ just wondered If there was any significant changes In the thlckness, that
have occured In the meantime would effect the Interpretation on any of
these wel is that you are proposing?
~lr. Howard: No, It wll I not. The wel Is are in the thickest part
of the oi I column.
Hr. Gl Ibreth: ~ly recollection Is that the testimony at that hearing
Indicated you were going to drlll In the thicker part of the reservoir.
Could you tell us to what extent your plans are here to drill In thick
or thin sections? How thin are you going down to for drilling these
wel Is?
Hr. Howard: It's very difficult to answer that at this tlme. Our
vlew Is that If we find that wetve got an active water drive It would
be quite posslble for us to have wells located down flank and flnd that
within posslbly a short period of tlme, by short period of tlme ! mean
years rather than months, that these wells would be, I think, useless
to us or only useable from the point of view of obtaining reservoir -13-
.
Pressur. e Informatlon. We feel that where we have located the wel Is
we w lll need them there at some stage in the development sooner or later
and for the reasons that I~ve given you we would prefer to drill these
we l Is now rather than ~heno
~lr. Gl Ibreth: You are convinced In your own mind that ultimately,
before the f leld Is abandoned, these wou Id be necessary anyhow for eff i clent
dral nage?
Mr. Howard: I'm, we're certaln of that, yes.
Mr. Gl ibreth: The Committee of course Is charged from a statutory
standpolnt of determining that not too few a number of wells are drilled
or that not too large a number of wells are drilled. Based on the Information
that you have at this time do you foresee that It might be necessary
to even drlll to a more dense pattern than what you proposed here?
Mr. Howard: Thls Is quite possible In the J~ter stages of develop-
ment but I don~t think that a't thls ,lme we should commit ourselves to
any well density. We feel that thls'number of wells wi11 meet the requirements
that we have for the pr°ductlon for the Inltlal, the early stage of
productlon. Hevlng obtained that reservoir data., we shall be feeding
It Into a computer model of sure ~m srue you are aware~ I know we have
one, I understand that you are having one and many other companies who
,,
are connec,ed wlth the Prudhoe Unit also have one or are bul Idlng one.
This Information will be fed Into these computers when we have production
data but that is the time that I feel that we are i'~n a better posltion
to decide how many wells we shall ultimately need. I don't thlnk we
should present anything at this tlme.
-t4-
Hr. Gl lbreth: Well, my question revolves around this, we had the
previous testimony that the 640 acre spaclng pattern could draln the
field, so then It becomes a matter of plain dellverablll~y. Now my next
question would be thls then, do you have any lnformatlon or are you con- ·
vlnced on what you see rlght now, and ! might say the State's study
has not progressed to the extent that we can te,t.I although we have some
Ideas - do you see any danger signals here that the rates that you're
looking at per well would cause damage to the reservoir?
Hr. Howard: No, I don't think so. As was explained In my testimony
we feel a reservolr of this nature could substaln an offtake of sub-
stantlally more than 1,000,000 BPD. It Is In the Interest of my company
as well, as those of the State of Alaska, to seek maximum recovery with-
In the framework of a maximum rate, whlch can be substalned fo~ extended
period of time wlthout wasting reservoir energy. Our normal pr. oceedure,
:.,
which we plan to adopt, Is to feel our way very carefully durlng the
flrst.".phases of production and then to use thls Information to obtaln,
to derive, thls maxlmum rate.
Hr. GI Ibreth: ~ notice on the west side, the area that you have
outlined on Exhibit "A" the hachured area, does not Include the Elleen
Area. Is there any plan afoot right now to do anyth!ng over there? Thls
would be In the BP operating area, would 'It not?
I~r. Howard: Yes, it would and this would be predlcated on our, well
thls would be Investigated thoroughly when we formed the unlto
Mr. Gllbreth: After unltlzatlon.
Mr. Howard: Yes, I thlnk right now we are dealing wlth a first
-15-
phase, a first stage of development, and that thls would be dealt with
at some subsequent stage.
Hr. Gllbreth: I touched on this, I would Ilke to approach It from
a slightly different angle. With the inf.ill wells that you are pro-
poslng here now and the rates that you foresee are ultimately planned
to produce, do you see any danger in, letVs say coning or anythlng Ilke
that, from the number of wells that you propose at thls time?
Hr. Howard: No, Intact I would have thought that by virtue of
havlng additional wells the chances of any conlng problems were reduced.
~. [., If you were, If you had to meet a level of production, you coald
then average the productlon such as to get a iow average production per
well, and hence any chances of conlng would be reduced by vlrtue of
having these additional wells. You will obvlously understand that we
would not spend money on drilling addltlonal wells if we dldnVt feel
that they were worthwhlle. We, like you, would have preferred to have
mlnlmum wells to keep the production comml?ments that we are obliged
to meet.
Hr. Gl lbreth: Based on your best knowledge at this time what, about
what type of a average producing rate do you anticipate from wel Is In
your operating area? Ultlmately, a maximum amount.
,,
Hr. Howard: Yes, okay~ So far relatlvel¥ few wells have been flow-
tested, and as we shown In Exhibit '~B', there's a conslderable varlatlon
In productivity. Wlth such a small sampling It Is difficult to accurately
estimate the average well production rate. However, on the basis of
lnformatlon so far to hand,, the average well.production rate wlll probably
be around i0,000 BPD.
-16-
Mr. Gllbreth: That's all ! have for now.
Mr. Burrell: Mr. Hamilton, do you have a question?
Mr. Hamllton: Mr. Howard, In your Exhibit 'TBS', were these wells
perforated in a manner that would be slml lar to perforatlons when they come
on production?
Mr. Howard: Yes, the majority of them were, but there was one
exceptlon, I think Its 18-11-13, where I believe we had 30' of perfor-
atl OhS open.
Mr. Haml Itoh: But the other wel Is had perforations that would be
equlvalent to say a well you planned to bring on later on?
Mr. Howard: Yes, that Is true. I think I could say that In the
case of the well that was tested last summer where we did penetrate a sub-
stantlal oll column, this ls well 26-11-13. The productlvltY of this
well was dlsappointly Iow so hence It Is really not posslble to predlct
the produc..tlon rate for any given well untll you physical Iy produce It.
There are certain Instances where you could get a better handle from wells
;
whlch perhaps we have cored, but It Is not easy at thls tlme and we do
not feel that we should be testing every well that we have because of the
waste.
Mr, Hamilton: Are you, you mentioned earlier, I believe, that you
ultimately can't tell what spacing you mlght need until you get some
productl on I nformatl on?
Mr. Howard: That Is correct.
Mr. Haml Iron: But In the meantime are you making any s~o'dles at
all Involving density of wells?
Mr. Howard: Well density. Yes, we have conducted some pr~llmlnary
-17-
studies but this was done rather more to get an Idea of what surface
facllitles we would be looking at, where our flow lines would run, how
much area we would need for drilling pads and these matters rather than
It be,lng a firm plan to proceed. At thls time It would be, In our opinion,
unwise to proceed with a further stage of deve~lopment until we have
Information on productlon from the wells that we are proposlng at thls
time.
Mr. Burrell: Mr. Gllbreth.
Mr. Gllbreth: Mr. Howard, just for the sake of the record I believe
you testified that there were 41 wells drilled and suspended, the 41
wells that you testified to are those In what you've outllned as a BP
operatlng area on Exhlblt "A"?
Mr. Howard: Yes they are. Can I make one point on this? You wlll
note that the Exhlblt "A" which was presented to you In January, since
that time well C-2, which Is shown as drill lng on Exhibit "A", has In
fact been drllled and suspended, and that we are now drilling well C-3.
Mr. Gl Ibreth: The point I wanted to make for the record Is that
these wells had been drllled and suspended. Are there any wells within
this area that right now could be opened up and produced?
Mr. Howard: Yes, one well. Well 01-11-12, M-I, does In fact have
tubing, It has a tublng plug In the well, so without putting a rig on
that well we could In fact produce It. Thls Is the only well. The
others have all been In fact been suspended with cement plugs or brldge
plugs, Obvlously these wells are confined to the welts that have been
tested, The remainder of the wells have not been perforated, The
-18-
casing Is simply run and cemented and the well capped.
Hr. Gl Ibreth: You mentloned In response to a question from Hr.
Burrel I regardl ng correlative rlghts that the testimony that you are pre-
sentlng here today had been made avallable to the people, I belleve you
sald offsetting you there, has the testlmony been made available to all
owners In the pool?
Mr. Howard: Yes It has.
Mr. Gl Ibreth: It has?
Mr. Howard: yes.
Mr. Gllbreth: That's all I have.
Mr. Burrell: Mr. Marshall.
Mr. Marshall: Mr. Howard, your application Is silent about any re-
quested change In the distance between wells. Finding #10 of our previous
Order 98-B for this pool reads: a dlstance of 1,000 feet between wells
mlght result In a poor dralnage pattern where not more than one well
ls permll"fed on a governmental section and a well 500 feet from a pro-
perty Ilne where ownership changes might Impair correlatlve rights. Would
you care to comment on thls In view of this clause In thls sentence where
not more than one well Is permitted to a governmental sectlon and you're
app lyl ng now for two,
Mr. Howard: Yes, we're not asking for a change In the rule on the
well spacing. We feel, In some ways, the statute or the rule could be
consldered posslbly unreallstlc in vlew of the shape of the structure.
In other words, If the philosophy of that flndlng was that wells should
be spaced 3,000 feet apart then our request here today would conform wlth
a rule of that nature. Does that answer your question?
-19-
Hr. Harshall: Youtve given me an explana,lon. Thank you.
Hr. Burrel I: Does anybody else In ,he Committee have any questions?
Hr. Howard, ltd like ,o make one comment a, ,his ,Ime. In the even,, !
want everybody to understand and I wan, ,he record ,o ref lec, ,ha, In
,he even, we approve this reques, we're no, only ,he drllllng and com-
ple, lon, we're approving ,he producing of ,hese wells and I tm sure ,ha, Is
what you wan,,
Hr. Howard: Yes s It.
Mr. Burrell: And those people who have adjacen, leases, if they
don~, unl,lze could be adversely affec,ed or If we don~, Impose unl,l-
za,lon could be adveresely affec,ed ,hereby, and ! jus, wan,ed ,he record
to reflect ,ha~.
Hr. Howard: I unders,and, sir.
r~r. Burrell: ^, ,his time I will ask If ,here Is anybody In the
audience who has a ques,lon of Hr, Howard and ,hen al,er ,he questlons
we'll take people who wan, ,o add or' make s,atemen,s-lf ,here ls anybody
who wants to do ,hat. Is there anybody In the audience who has a ques,lon
of Hr. Howard a, ,hls time? If not, I guess you're excused Hr. Howard.
Thank you.
Hr. Howard: Thank you.
Hr. Burrell: Is there anybody in the audience who wlshes ,o make a
statement at this time? Please come up to the microphone and Identify
yourselves. Take ,ha, chalr.
Hr. Harrlson: ~lr. Chairman, members of the 011 and Gas Conservation
Comml,,ee, my name is W. R. Harrlson~ I~m general at,orney for Hobll
011 Corporation and I am appearing In ,his mat,er on behalf of Hobll
-20-
011 Corporatlon. Mobil owns a interest In leases In the western portlon
of the Prudhoe Bay Field. These leases lie adjacent to the area for which
spacing exceptlons have been requested here today by BP Alaska Inc. Mobll
has been furnished a copy of BP~s draft testimony supporting their rec-
ommendatlons for exception to the well spacing rule for the Prudhle Bay
Field, In this testlmony references were made to the objective of forming
a Prudhoe Bay Unit. BP will be the logical operator of the western
portion of the Prudhoe Bay Unit. Mobil supports the objective of forming
a unit and the proposed well spacing exception. We have reviewed BP~s
draft testimony and we support their p~oposal as a necessary step In
the development of a unit. That's the end of my statement. Mr. Chairman,
for the record ltd I lke to enter th ls statement.
..
Mr. Burrell: Thank you very much Mr. Harrison, Is there anybody
else who wishes to make a statement?
Mr. Swetnam: Mr, Chairman, members of the 0II and Gas Conservation
,.
Committee, my ~name Is R. I. Swetnam. I am speaking In represen~ation
of Ph I I I I ps Petroleum Company.
Phl Illps Petroleum Company owns Interests In ol I and gas leases
adjacent to the leases of BP Alaska, Inc. for whlch the exceptions are
sought I n thls hearl'ng.
Phllllps and the other owners of reserves In the Prudhoe 0il Pool
have excuted or ratlfle,~ a letter agreement pertalnlng ~o unitization of
the Prudhoe 0II Pool. in antlclpatlon:of completion of deflnltlve
Unltlzatlon Agreements, we believe that the prOpoSal Is logical and
reasonable as a part of unit development of the Prudhoe 0II Pool and
-21-
according ly recommend approval of the app I Ica?Ion. Thank you.
Mr, Burrel I: Thank you Mr, Swetnam. Is there anybody else who
wishes to make a statemen*?
Hr. Rosen?hal: Hr. Chalrman, members of the Alaska 0II and Gas
Conservation Commll~ee, I am C. H. Rosen?hal, Public Affairs, Exxon
Company, U.S.A. I am appearing before you as a representative for Exxon
Company, U.S.A. to I ntP. oduce Into the record a statement of Exxon~s
posltlon regarding BP~s request for an exception Rule 2, Conservation
Order No. 98-B.
Exxon does not support BPts proposal for selective Infl II develop-
men? on 320-acre spacing. We belleve such development at this time
would be premature, not only In vlew of recent rultngs on the Alyeska
Plpellne permlt, but also wlth respect to the orderiV and efflclent devel-
opment of the field.
We continue to support lnltlal development of Prudhoe Bay on 640
acre spacing as the most prudent and efficient means of deflnlng the
reservoir, Its productive capacity, and the number of wells requlred
for start-up. We support unltlzatlon of the field and believe Inflll
development can be best accomplished under a unitized plan that wi II
prevent economic waste and minlmlze the cost to all opera?ors. Fur, her,
we belleve these activities can be completed In time to allow the drill lng
of any Inflll wells whlch may be needed pr~l:or to production start-up.
Accord Ing ly, we recommend that BPi s request for an exceptlon to Rule 2
of Conservatlon Order 98-B not be approved at thls time.
-22-
Mr. Burrell: Thank you Mr. Rosenthal. Could we ask a question sir,
before you leave the microphone?
Mr. Rosenthal: Yes.
Mr. Burrell: Does Exxon Corporation have any geological or engineering
data to submit In support of their objectlon? We received some from the
appllcant, we have not received any from Exxon.
Mr. Rosenthal: We do not have any data to sub.~lt at this tlme. I of
course do not have a technical background so I cannot comment.
Mr. Burrell: Does Exxon Corporation wlsh to submit some if we hold
the record open for a reasonable .perlod of time?
Mr. Rosenthal: it Is my understanding that we do not.
Mr. Burrell: I see. We are going to be left w~th simply a request for
dlsapproval with no substantlatlng data, is that correct sir?
Mr. Rosenthal: I can't go beyond the statement that I have made.
Mr. Burrell: Thank you, I have no further questions.
Mr. GI Ibreth: Could I ask a questlon, Mr. R°senthal? I understood
you to say you're objecting to the granting of this request at thls time.
Could ! ask you, do you mean because of the tlmlng Or because of the lack
of Informatlon? Could you enlighten us any on that'=or Is It just a objec-
tion to do It righ.t now?
Mr. Rosenthal: I think that the only thing I can do Is to rely on
the statement itself, and It seems to suggest the timing.
Mr. Gl Ibreth: I understand. Thank you.
,:
Mr. Burrel I: Tom, do you have a questl°n?
Mr. Flint: Mr. Chairman, could I just comment?
Mr. Burrell: Yes, excuse me, yes sir.
-23-
Hr. Flint: Thls Is Harlan Flint again, attorney for the applicant, and
I just would comment wlth respect to the Exxon statement, that as ~Ir.
Rosenthal has frankly described it, It Is pretty much a statement of
policy and as you gentlemen have mentioned It should not constitute evidence.
I would suggest further that the statement does not allege that the
granting of thls appllcation would result In waste as that term is defined
In the statute and regulations, nor does It suggest that It would Interfere
wlth the full protection of correlative rlghts. Thus we do feel that
we have substantiated our case with the expert testimony of Mr. Howard
and that the case that has been made entitles us to the teller we requested.
Thank you. I believe that does conclude our presentation.
Mr. Burrell: Thank you Mr. Flint, I'll ask If there Is anybody
else In the audience who wants to make a statement or comment? We have
several operators who we haven't heard from or at least owners of Interests
In nearby leases, including Standard 0II Company of California, Atlantlc
Richfield Company, the Placld group, Amerada and Getty. is there anybody
here who wants to m~ke a statement on behalf of any of those companies?
Apparently not. Anybody else from the Committee, Mr. Haml Iton, have a
questl on?
Mr. Hamilton: No.
Mr. Burrell: In that case we will adjourn this hearing for a 15 minute
br...eak untll ten mlnutes after ten and we'll have another hearing at that
time. Thank you.
-24-
REQUEST FOR EXCEPTION TO RULE 2, CONSERVATION ORDER NO. 98-B ....
STATE OF ALASKA HEARING-PRUDHOE BAY FIELD
February 16, 1973
Testimony Presented by A. K. Howard, BP Alaska Inc.
Mr. Chairman and members of the Alaska Oil and Gas Conservation Committee.
Since the discovery of the Prudhoe Bay Field, two hearings have been held
(November'13-14, 1969 and February 9, 1971) to establish Pool Rules. During
the course of this presentation, I shall refer to testimony presented to you
at both of these hearings.
BP Alaska Inc. has requested this hearing to seek an exception to Rule 2
of Conservation Order No. 98-B which, if approved, would permit the completion
of two oil wells per governmental section in 19 selected sections .within the
BP Alaska operating area. In this context, reference is made to a letter
from BP Alaska Inc. to the Director of the Division of Oil and Gas, dated
January 16, 1973, and to Exhibit "A" attached thereto, which counsel has asked
to be included in the record.
As is generally known, BP Alaska is operating in the western part of the
Prudhoe Bay Field. An initial plan for this operating area, showing actual
and proposed bottom hole well locations, is presented as Exhibit "A". The 72
wells shown comprise the first stage development wells in this portion of the
field.
At the present time, development drilling is proceeding with one active
rig and 41 scheduled future production well~ have been drilled and suspended.
It is BP Alaska's wish to continue drilling first stage development wells and
the planned sequence for this drilling calls for a number of so-called 320
acre spaced wells. It is readily apparent from the Field Development Plan
Map (Exhibit "A") that, having drilled three more wells, no programmed addi-
tional wells could be completed in the BP Alaska operating area within BP Oil
-2-
Corporation's lease area under existing rules.
Testimony presented in February 1971 indicated that negotiations were
proceeding with the objective of forming a Prudhoe Bay Unit. These negot-
iations are continuing and BP Alaska's development plan anticipates .the
successful conclusion of the negotiations prior to production. For this
reason, it is not BP Alaska's wish to drill wells within BP 0il Corporation
leases situated in the ARCO operating area, which could be completed under
existing pool rules. Similarly, until a unit is formed, there are difficulties
associated with drilling wells on other companies' leases, and the development
drilling program for the immediate future confines the wells to be drilled to
BP Oil Corporation leases in the BP Alask~ operating area.
/
Having disclosed our progress and Outlined our immediate future plans for
the development of our operating area, I will now elaborate a little on the
overall philosophy which has led to our request at this time for an exception
to COnservation Order No. 98-B, Rule #2, regarding infill wells.
The Committee will be aware that, primarily as a result of delays in the
issuance of the construction permit for the trans-Alaska pipeline, drilling
activity is at a low ebb on the North Slope, as compared with the work being
conducted, at about the time of the 1969 North Slope lease sale. At that time,
in the Prudhoe Bay area alone, several rigs were actively engaged in develop-
ment or appraisal drilling and numerous suppor~ services camps were located
in the area, providing employment for many hundreds of people. During the past
year, only one rig has been continuously utilized in this area and the support
consists mainly of sporadic projects which provide barely sufficient justifi-
cation for many service companies to continue, operating. If the rig currently
-3-
on contract to BP Alaska and engaged in drilling Prudhoe Bay development wells
were to shut down, there would be further reductions in employment levels
which would not only affect the drilling contractors, but have serious reper-
cussions in other companies as well.
During the years that BP Alaska Inc. has been engaged in drilling and
evaluating the Prudhoe Bay Field, it has acquired expertise in dealing with
the problems peculiar to the area. Its staff, and those of the service
companies, have become aware, through training and experience, of acceptable
and efficient methods of dealing with such matters as the cold environment,
the permafrost, the delicate ecosystem, and many others. We believe that it
is in the interest of our company, the oil industry in Alaska, and the State
of Alaska, to continue operating and so maintain these personnel as an
effective force.
I will now make a few remarks concerning the approach BP Alaska Inc. has
adopted for the initial development of its operating area for the Prudhoe Bay
Field.
Your committee was presented with geologic and other informatiOn on the
Prudhoe Oil Pool, at the Field Rules Hearing held on February 9, 1971, which
gave a general description of the field. Since that hearing BP Alaska has
c,onducted a number of additional well production tests, the results of which
are now presented as Exhibit "B". (For the sake of completeness, we have
summarized the production test results obtained by BP Alaska to date in Ex-
hibit "B". )
The President of Alyeska is on public record as having indicated the trans-
Alaska pipeline is being designed for an initial capacity of 600,000 BPD, which
-4-
capacity may be increased to an ultimate throughput of 2,000,000 BPD. We
cannot commit ourselves to a maximum oil producing rate for the Prudhoe Oil
Pool alt present, particularly as Unitization has not yet been concluded.
However, we' are confident that the reservoir will sustain a substantially
higher rate than the initial pipeline capacity of 600,000 BPD. It is not
uncommon in reservoirs of this nature to anticipate as a rule of thumb a
25/30-year life. The recoverable reserves have been quoted at 9.6 billion
barrels and this leads us to believe the reservoir could average a crude
oil production rate of approximately 1,000,000 BPD over a 25-year life.
During the early stages of production, it can be reasonably expected the
production level could be significantly hi~her than the average rate. BP
Alaska's first stage development plan is predicated on its ability to pro-
duce half of the 'total field offtake during these early stages of production.
Verbal testimony presented ~by Mr. Anderson~'(ARCO)at the "NOvember 1969
Field Rules Hearing (=efer to R & R Court Reporter's transcript, Page 59),
indicated that one well could adequately drain a 640-acre Section and,
assuming each well were capable of producing i0,000 BPD, 100 wells could'
produce 1,000,000 BPD. We support this testimony, although struct'ural.
features could influence the drainage pattern, in certain areas. In pursuing
this matter further and with reference to the production test results shown
in Exhibit. "B", it is evident that not all. wells will be capable of sus-
taining a production rate of 10,000 BPD, and some allowance must be made
for wells shut in for service Or?other reasons. Similarly, by assuming a
,.
production rate higher than 1 million BPD, a need for additional wells?, arises.
/
Hence, the 72 wells programmed should adequately provide the required pro-
duction from the BP Alaska operating area.
-5-
The committee will note that the proposed infill wells are located
in areas of the field where a relatively thick oil column can be ex-
pected and not on the flanks of the structure. We believe that, by loc-
ating the wells here, the maximum producing life can be expected from
them while minimizing overall well requirements. It may well be
necessary later to locate wells on the flank of the structure; however,
at the present stage of our knowledge of the field, we have not planned
such wells.
In concluding this testimony, the Committee will be aware that an
exception to Conservation Order 98-B, Rule 2, is. required only at the
time of well completion. The Committee, however, will appreciate that
BP Alaska could not commit funds for drilling without receiving the
assurance that this proposal is acceptable to the State.
Gentlemen, I wish to thank you for your attention and I will be glad
to answer any questions you may have to the best of my ability.
Statement of Exxon's Position
BP Request for Exception to Rule 2, Conservation Order No. 98'B
State of Alaska Hearing-Prudhoe Bay Field
February 16, 1973
Mr. Cha~, members of the Alaska Oil and Gas Conservation Co~ttee, I
am C. H. Rosenthal, Public Affairs, Exxon Company, U.S.A. I am appearing before
you as the representative for Exxon Company, U.S.A. to introduce into the record a
statement of Exxon' s position regard~ ng BP' s request for an exception to Rule 2,
Conservation Order No. 98-B.~ ~'
Exxon does not support BP's proposal for selective infill develo~x~ent on
320-acre~ spacing. We believe such development at this time would be premature, not
only in view of recent rulings on the Alyeska Pipeline permit, but also with respect
to the orderly and efficient developr~m~t Of the field.
We continue, to support initial development of Prudhoe Bay on 640-acre
spacing as the most prudent and efficient' means of defining the reservoir, its
·
productive. 'capacity, and the number of wells required for starts-up. We support
unitization of the field and believe infill development can be best accomplished
under a unitized plan that' will prevent economic waste and minimize the cost to
all operators. Further, we believe ~these activities can be completed in time to
allow' the drilling of any infill Wells which may be needed prior to production
start-up. Accordingly, we re~d that BP's request for an excepti°n to Rule 2
of Conservation Order. 98-B not be approved at this time.
My name is R.I. Swetnam. I am speaking in representation of Phillips
Petroleum Company.
Phillips Petroleum Company owns interests in oil and gas leases adjacent
to the leases of BP Alaska, Inc. for which the exceptions are sought
in this hearing.
Phillips and the other owners of reserves in the Prudhoe Oil Pool
have executed or ratified a letter agreement pertaining to unitization
of the Prudhoe Oil Pool. In anticipation of completion of definitive
Unitization Agreements, we believe that the proposal is logical and
reasonable as a part of unit development of the Prudhoe Oil Pool and
accordingly recommend approval of the application.
Oil Corporcafion
POST OFFICE POUCH 7-003
ANCHORAGE. ALASKA 99510
ALASKA DIVISION
W. R. HARRISON
GENERAL ATTORNEY
February 15, 1973
RE:
The application of BP Alaska InC.. for an exception to Rule 2 of
Conservation Order No. 98-B to permit the drilling and completion
of two oil wells per governmental section on selected sections in
the Prudhoe Bay Field, Prudhoe Oil Pool.
My name is W. R. Harrison, General Attorney for Mobil Oil Corporation, and
I am appearing in this matter on behalf of Mobil Oil Corporation.
Mobil owns an interest in leases in the western portion of the Prudhoe Bay
Field. These leases lie adjacent to the area for which spacing exceptions
have been requested here today by BP Alaska, Inc.
Mobil has been furnished a copy of BP's draft testimony supporting their
recommendation for exception to the well spacing rule for the Prudhoe Bay
Field. In this testimony, reference is made to the objective of forming a
Prudhoe Bay Unit. BP will be the logical operator of the western portion of
the Prudhoe Bay Unit. Mobil supports the objective of forming a unit and the
proposed well spacing exception.
We have reviewed BP's draft testimony and we support their proposal as a
necessary step in the development of a unit.
/i3c
W. R. Harrison
Well No.
27-11-14
~4-11-13
30-11-14
14-11-13
18-11-13
01-11-12
26-11-13
Test Date
6/30/69, 7/01/69
8/21/70
11/10/70
7/26/71
Productivity of Oil Wells Flow-Tested
in the Prudhoe Bay Field
Sadlerochit Reservoir
WHFP Choke Size
psig 1/64"
Rate
STBPD.
1360 N/A 10,020
1105 86
1265 64
·
1076
15,500
12,000."
'96
19,400
9/27/71 llO0 1.700
1240 :'33
2,500
,
7/12/72
11/02/72
1095 '48
400
~ ·
GOR
Scf/bbl
837
722
741
·
·
' 750
·
· " 730
·
690
·
710
-.
·
·
Exhibit B
Productivity
Index
STBPD/psi
25
37
68
22
STATE OF ALASKA, )
THIRD JUDICIAL DISTRICT, ) ss.
Mary L Shake
being first duly sworn on oath
deposes and says that...~.~?. ......
is the ...... ~.e.~.a..Z.....C..Z..e.?..~.. of the
Anchorage News, a daily news-
paper. That said newspaper has
been approved as a legal news-
paper by ,the Third Judicial Court,
Anchorage, Alaska, and it is now
and has been published in the
English language continually as
a daily newspaper in Anchorage,
Alaska, and it is now and during
all of said time was printed in an
office maintained at the aforesaid
place of publication of said news-
paper. That the annexed Js a true
copy of a .... i~.e.g.a..1....~.!p.~.~..c..e...~]?'l
as it was published in regular
issues (and not in supplemental
form) of said newspaper for. a
period of ....... .9.~.e. .... insertions,
commencing on the ...~ ....... day
of ...~.e. br.a..~,~.~' ..... ,19 ~.., and
ending on the ............3:. ...... day of
of .....~..e. ~.z.;?..a..r...y. ........ , 197.~...,
both dates inclusive, and that
such newspaper was regularly
distributed to its subscribers dur-
ing all of sa,id period. That the
full amount of the fee charged
for the foregoing publication is
the sum of $ 15,00 which
amount has been paid in full at
the rate of 25¢ per line; Mini-
mum charge $7.50.
/ // /
S~scribed'~.nd sworn to before
me this .; .....day of-Eeb~.,
the ,State o~ Alaska,
Third Division,
Anchorage, Alaska
(, COMAAISSION EXPIRES
...... ....... /Z.,,
D EJ~ARTM ENT OFqgATURA~ RESOI~RCES
". DIV!$1:~,-0F .01L'.A~
Alaska Oil .~...'~ ,Cons~atiOn
,~iff~,
,.
;.~-{~ns~tlen Fill Ne.
"~' '~nl~' "~"] '" ",
~ '-" ,,.~: _. . .... ~--
' ge~ '~; ...... ; ....
t~ ~l~n within
"eutU ~"'"' :' "t · :' . .... '
- · .~~~[~:.
qU&St Will be held ~ 9:~ A,M,
· .~t ':~h,leh tlm~
:;L,?:' st~
~ .............. , ,~"~.~ ~::,,":' .~
.
,~ "~ ' "'~: ~ml~ ,' ,
'~i,"~,,~.,,.~.~, ,,~, ,~ '
1, ,.~,: ~ :', ~, "~';,: :': ~; ;'
NOTICE OF PUBLIC HEARING
STATE OF ALASKA
DEPARTHENT OF NATURAL RESOURCES
DIVISION OF OIL AND GAS
Alaska 0II and Gas Conservatlon Committee
Conservation File No. 117
RE: The application of BP Alaska Inc. for an exception to Rule 2 of
Conservation Order No. 98-B to permit the drilling and completion
of two oll wells per governmental section on selected sections in
the Prudhoe Bay Field, Prudhoe 0II Pool.
Notice is hereby given that BP Alaska Inc. has requested an order
granting exception to Rule 2 of Conservation Order No. 98-B which would
permit the operator to drlll and complete 19 wells at a density of 2
wells per governmental section within the BP Alaska Inc. operating
area as outlined on Exhibit "A" submitted wlth the operators application.
No changes are requested in that portion of Rule 2 of Conservation
Order 98-B regarding distances to property I lnes where ownership
changes and minimum distances between completion intervals of adjacent
we l Is In the same pool.
,
Pursuant to Title ii, Alaska Admlnlstratlve Code, Section 2009 a
public hearing to consider this request will be held at 9:00 A.M.
February 16, 1973 in the City Council Chambers of the Z.J. Loussac
Library, 5th Avenue and "F" Street, Anchorage, Alaska at which time the
applicant and affected and interested parties will be heard.
Thomas R. Marshall, Jr.
Executi ve Secretary
Alaska 0II and Gas Conservation Committee
3001 Porcupine Drive
Anchorage, Alaska 99501
Pub I Ish FebrUary I., :197:3
BP ALASKA INC.
P.O. BOX 4-1379
3111 - C - STREET
ANCHORAGE. ALASKA 99503
TELEPHONE (907) 279-0644
January 16, 1973
Mr. Homer Burrell, Director
State of Alaska
Department of Natural Resources
Division of Oil & Gas
3001 Porcupine Drive
Anchorage, Alaska 99504
OAS
ANO~ORAOl~
Dear Mr. Burrell:
Exception to Rule #2 (Well Spacing)
Prudhoe 'Bay Field '- 'Prudhoe 'Oil Pool 'Rules
It is the purpose of this letter to seek exceptions to Rule 2 of Conservation
Order No. 98-B, in order to permit BP Alaska Inc., as operator for BP Oil Corp-
oration, to increase the drilling and completion of oil wells from one to two
per governmental section on selected sections situated in the proposed BP
Alaska Inc. Operating Area in the Prudhoe Bay Field. Appended hereto, and by
this reference made a part hereof, is a field development map identified as
Exhibit "A" depicting the proposed wells. It is not the intention at this time
to request a change in Prudhoe Oil Pool Rules to permit a general change from
one well to two wells per section.
Exhibit "A" shows the approximate locations of 72 wells which comprize the first
stage development plan for the BP Operating Area. Three oil gathering centers
are planned for this area and 24 wells will be connected to each center. In
order to maximize producing well life and minimize overall well requirements,
the wells have been located where gross oil sand thickness is anticipated to be
200 feet or more. Thus, while the plan for certain areas of the pool is for two
wells per governmental section, large areas of the pool are not planned for dev-
elopment drilling at this time.
Of the 53 sections planned for development at this time, there are 19 on which
two wells are planned, and the 1973 schedule of work for the BP Alaska Oper-
ating Area calls for the employment of one drilling rig during the year drilling
certain of these infill wells.
It should be noted that we are not requesting any change of that portion of
Rule 2 of the subject rules regarding distances to property line where ownership
changes, and to the bottom hole locations of other wells in the same pool.
Except for the change in well spacing in nineteen selected sections, it is
proposed that the subject wells be drilled as required by the subject pool rules
and the applicable statutes and regulations of the State of Alaska.
Exception to Rule #2 ..... 2- January 16, 1973
It is our understanding that the request for an exception to Rule ~2 of Con-
servation Order No. 98-B may necessitate a public hearing. If this is the
case, we would appreciate your scheduling the hearing either in the afternoon
of February 15 or the morning of February 16, 1973.
Attachment
Very truly yours,
I EiCEIIVE