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CO 191
Conservation Order Cover Pag~ 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 plotter/scanner) [] Maps: [] Other items OVERSIZED (Not suitable for plotter/scanner, may work with 'log' scanner) [] Logs of various kinds [] Other ' BY: F~OBIN MARIA Scanning Preparation Production Scanning Stage I PAGE COUNT FROM SCANNED DOCUMENT: PAGE COUNT MATCHES NUMBER IN SCANNING pREpArATION: Y" YES NO BY: Stage 2 IF NO IN STAGE 1, PAGE(S) DISCREPANCIES WERE FOUND: ~ YES NO C"l''iARIA DATE: (.~-/~-~,,~ 'S' (SCANNING IS COMPL'E.T.E.4~[_T.~I.~OINT UNLESS SPECIAL ATTENTION IS REQUIRED ON AN INDIVIDUAL PAGE BASIS DUE TO QUALITY, GRAYSOALE OR COLOR IMAGES) I II I II I General Notes or Comments about this Document: 5/21/03 ConservOrdCvrPg.wpd • Index Conservation Order 191 Prudhoe Bay Field 1) August 25, 1983 Letter from Arco Alaska Inc. West Sak Sands Pilot Project 2) September 9, 1983 Notice of Public Hearing, Affidavit of Publication 3) October 24, 1983 Letter from Arco Alaska Inc. to Commission 4) January 25, 1984 Letter from AOGCC 5) Apri124, 1984 Arco Alaska's Inc. request for an administrative approval 6) June 6,1984 Letter from Governor re: Bi11680 7) June 29, 1984 Letter Re: Administrative Approval 8) July 11, 1984 Letter from Arco Alaska Inc. re: Flare permit for West Sak Pilot -Startup 9) November 19, 1984 Letter from Arco Alaska Inc. re: Flare permit for West Sak Pilot -Startup 10 ) Apri123, 1985 Letter Re: Administrative Approval for purpose of flaring gas Conservation Order 191 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage, Alaska 99501 Re: THE APPLICATION OF ARCO ) ALASKA, INC. for an order ) permitting a project for ) the West Sak Sands in the ) Kuparuk River Field to ) determine the optimum tech- ) niques for development of ) the reservoir and to gather ) information for a pool rules) hearing at a future date. ) Conservation Order No. 191 Kuparuk River Field West Sak Sands Section 35 Project September 26, 1983 IT APPEARING THAT: ARCO Alaska, Inc., by letter dated August 25, 1983, requested the Alaska Oil and Gas Conservation Commis- sion to issue an order to permit conducting a project in the oil-bearing West Sak Sands to determine the optimum techniques for development of the reservoir and to provide vital information for establishing reasonable pool rules. · Notice of public hearing was published in the Anchorage Times on September 9, 1983. 3. There were no protests filed to the application. FINDINGS: I · A hydrocarbon accumulation occurs in a series of sands that have been called the West Sak Sands and extends over a large area of the Kuparuk River Field. e The oil from the West Sak Sands is viscous at reservoir temperature which materially retards unassisted flow. · The evidence indicates that in Section 35, TllN, R10E, UM. the West Sak Sands are oil-bearing and of sufficient thickness to conduct an evaluation project. 4, Conventional depletion methods appear to be impractical. Therefore injection of hot, high pressure water or other fluids into the reservoir may provide an adequate oil producing rate. Conservation Ord=~ No. 191 Page 2 September 26, 1983 · The pattern of producing and injection wells should be closely spaced in order to obtain data within a reason- able time frame. · The project contemplates the drilling of less than 20 wells but performance of the project may require the drilling of additional wells to achieve definitive results. · The project is within the area covered by the Kuparuk River Unit and Unit Operating Agreements thus insuring a mechanism for protection of correlative rights. · This project provides the opportunity to evaluate various drilling, completion and production methods but methods not now envisioned may become appropriate. · A safety flare is an operational necessity for the project. 10. The operator will install production, injection, testing, hydrocarbon measuring and shipping facilities for the project. 11. It appears that casing cemented at 80 feet below the surface will provide adequate anchorage for installation of flow diverter equipment. 12. Drilling experience in the Kuparuk River Unit area demonstrates that adequate well control can be main- tained using a flow diverter system while drilling to the bottom of the West Sak Sands. 13. Correlation of formation test data shows a normal pressure gradient through the West Sak Sands and comming- ling in the wellbore will not cause waste. 14. Completion of wells drilled to the base of the West Sak Sands with a single string of casing to the surface is appropriate. 15. The evaluation of the project may take up to five ye ar s. NOW, THEREFORE, IT IS ORDERED THAT the rules hereinafter set forth apply to the following described area: Section 35, TllN, R10E, U.M. £ Conservation Orde[~ No. 191 Page 3 September 26, 1983 Rule 1; Project Defined. The project shall be known as the West Sak Sands Section 35 Project and shall be confined to the accumulation of oil that correlates with the accumulation found in the ARCO Alaska, Inc. West Sak River State No. 1 well between the depths of 3744 and 4040 feet. Rule 2. Well Spacing. There will be no spacing requirements for wells in the project area but no more than 30 wells may be drilled. Rule 3. Casing and Cementing Requirements. (a) For proper anchorage and to protect the ice-rich portion of the permafrost, casing shall be set at least 80 feet below the surface and sufficient cement shall be used to fill the annulus to the surface. (b) Should an intermediate string be utilized -- it shall be cemented to the surface. (c) Production casing may be set immediately above or through the oil reservoir and sufficient cement shall be used to fill the annulus at least 500 feet above the top of the oil accumulation. A non-freezable fluid shall be left in the annular area from 100 feet below the base of the permafrost to the surface unless it is demonstrated to the Commission's satisfaction that the casing to be installed will withstand freezeback forces. Rule 4. Blowout Prevention Equipment. (a) On all wellS a flow diverter system shall be installed on the first string of casing for use in drilling until the next string of casing is set (as required by 20 AAC 25.035(b)). (b) Should an intermediate casing string be utilized, a 3000 psi blowout prevention stack shall be installed as set forth in 20 AAC 25.035(c). (c) A 3000 psi blowout prevention stack, as set forth in 20 AAC 25.035(c), shall be installed on the production casing and used during subsequent drilling or completion operations. RUle 5' Commingling. The production from all oil-bearing sands, as defined by Rule No. 1, may be commingled in the wellbore. Conservation Orde~ No. 191 Page 4 September 26, 1983 Rule'6. 'Finid"in~'e&ti6n'~ The injection of fluids into the West Sak Sands interval is hereby permitted. Rule 7. Automatic Shut-in Equipment. A fail-safe automatic surface safety valve (SSV), approved by the Commission, shall be installed on each producing well. A representative of the Commission will witness operational and performance tests at intervals of time perscribed by the Commission to confirm proper working condition. Rule 8. Logging Requirements. One well on each drilling pad that penetrates the entire reservoir will be logged from the shoe of the conductor casing to total depth. The remaining wells, whether produc- tion or injection wells, need only to be logged over the hydrocarbon bearing portion of the hole. Rule 9. Flaring of Gas. The flaring of gas produced from the project is prohibited except that a maximum of 200 MCF per day may be used to maintain a pilot flare to provide for safe conditions in case of an operational upset. Rule 10. Casing Pressure Tests. Ail casing and tubing strings shall be periodically pressure tested and the results reported as prescribed by the Commission. A representative of the Commission may witness these tests at intervals and times as prescribed by the Commission. Rule 11. Reports. In addition to the reports required by Title 20, Chapter 25 of the Alaska Administrative Code, a report recapitulating the facts and progress of the project will be submitted every three months by the 20th day of the month following the reporting period. Rule 12. Administrative Relief. Upon request, the Commission may administratively amend any rule stated above as long as the operator demonstrates to the Commission's satisfaction that sound engineering practices are maintained and waste will not occur. Conservation Ord~~_~'' No. 191 Page 5 September 26, 1983 Rule 13. Conformance. The project and project operations shall be approved and conducted in conformance with the requirements of the Kuparuk River Unit Agreement and Unit Operating Agreement. DONE at Anchorage, Alaska and dated September 26, 1983. . V. Chiton_, ~hairman . Alaska Oil and ~as Conservation Commission Harry W./Kugler ,/Commissioner Alaska Oil and Gas Conservation Commission ~n~ie C. Sm~h,-Commissioner Alaska Oil a~d'~ Gas Conservation Commission May 28, 1986 A D M I N I ~' T R AT I V E A P P R O V A L NO. 191.6 Re: ',The application of ARCO Alaska, Inc. to flare gas produced R'-.~t the West Sak' Sands Section 35 Project between June 1, 19.86 and May 31, 1987. Mr. J. D. Weeks Manager, West Sak Pilot ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Weeks: We have received your application, dated May 27, 1986, requesting permission to flare excess gas resulting from the production from the West Sak Sands Section 35 Project. This application is for the period from June 1, 1986 to May 31, 1987. The Commission has studied the available data and is still in agreement with the fact's set forth in Administrative .Approval No. 191.4 which waived Rule 9 of Conservation Order No. 191 and approved the flaring of all gas until May 31, 1985. .Therefore, by this letter, the Alaska Oil and Gas Conservation Commission approves the flaring of gas at the West Sak Sands Section 35 Project from June 1, 1986 until May 31, 1987. This action is taken pursuant to Rule 12 of Conservation Order . '~,~,~,,o. 191. '~,~ .... Yours ver~ Commissioner BY ORDER OF THE COMMISSION be:3.AA191 May 21, 1985 A D M I N I S T R A T I V E A P P R 0 V A'L NO. 191.5 Re: The application of ARCO Alaska, Inc. to flare gas produced at the West Sak Sands Section 35 Project between June 1, 1985 and May 31, ]986. Mr. Landon B. Kelly Manager, West Sak Pilot ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Kelly We have received your application, dated April 23, 1985, request- ing permission to flare excess gas resulting from the production from the West Sak Sands Section 35 Project. This application is for the period from June 1, 1985 to May 31, 1986. The Co~nission has studied the available data and is still in agreement with the facts set forth in Administrative Approval No. 191.4 which waived Rule 9 of Conservation Order No. ].91 and approved the flaring of all gas until May 31' 1985. Therefore, by this letter, the Alaska Oil and Gas Conservation Commission approves the flaring of gas at the West Sak Sands Section 35 Project from June 1, 1985 until May 3!, 1986. This action is taken pursuant to Rule 12 of Conservation Order No. 191. Yours very truly, Harry W. Kugle~r Commissioner BY ORDER OF THE COM}~ISSION be: 3.AA191 NoVember 20, 1984 ADMINISTRATIVE APPROVAL NO. 191.4 The application of ARCO Alaska, Inc. requesting administrative relief from the requirement of Rule 9 of Conservation Order .~191 for the purpose of flaring gas produced by Section 35 Project from November 21, 1984 through May 31, 1985. Mr. L. B. Kelly, Manager Section 35 Project ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510 Dear Landon: Please refer to your November 19, 1984 subject letter requesting administrative relief from Rule 9 of Conservation Order #191 which prohibits the flaring of associated gas in excess of the 200 MCFD allowed for a safetY pilot flare. Upon review of your application and subsequent 'discussions of the application with you, the Commission finds: That upon production startup and during the sixty day commissioning period for Section 35 Project facilities and walls, the.daily production rate of associated gas exceeds the volUme of gas necessary for a safety pilot fl.are and that is in a usable condition for beneficial use in meeting energy requirements of Project facility. That within the Section 35 Project productive interval, a reservoir material balance is being accomplished with the injection of hot 'water The ormg_nal reservoir pressure will thus be maintained. ~ That injection of gas into the Section 35 Oil Project productive interval at.this time will materially Interfere with evaluat~on of a hot Waterflood and thereby jeopardize the very thrust of the project, which is ~¢ develop a prudent means for exploiting the resource. ,. 4. That curtailment of the ~ate of crude oil production from the project area as a meah~ for reduczng the rate Administrative Approval No. 191.4 Page 2 November 20, 1984 of associated gas production defeats the purpose of the Section 35 Project. · That there is not a prudently viable means for the beneficial disposal of gas produced in excess of project facility needs. · That the public good is served by undertaking all reasonable steps to promote the success of the Section 35 Project Therefore, by this letter the Alaska Oil and Gas Conservation Commission waives Rule 9 of Conservation Order ~191 by approving the escape of associated gas which is produced by the Section 35 Project during the period of time commencing November 21, 1984 and extending through May 31, 1985, providing that for safety purposes the gas is flared. Sinc~.rel.y, ~I j C7. V2 Chatterton Chairman BY ORDER OF THE CO}~ISSION lc July 16, 1984 A D M I N I S T R A T I V E A P P R O V A L NO. 191.3 Re: The application of ARCO Alaska, Inc. to flare gas during the start-up and commissioning of the facilities and wells at the West Sak Sands Section 35 Project. Mr. L. B. Kelly Manager, West Sak Pilot ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Kelly: The Alaska Oil and Cas Conservation Commission has received your letter of July 11, 1984 requesting the flaring of gas during the start-up and commissioning of the facilities and wells at the West Sak Sands Section 35 Project. The letter states that a maximum volume of 60 MMSCF may be flared and the flaring will occur over a 60 day period beginning as early as August 15, 1984. The Commission has visited the facilities and examined the data avail'able and believes the flaring of gas is an operational necessity to effect the start-up of the Project. Therefore, by this letter the Alaska Oil and Gas Conservation Commission waives the stipulations of Rule 9 of Conservation Order No. 191 and authorized the flaring of a maximum volume of 60 MMSCF during the start-up and commissioning of the facil- ities and the wells in the West Sak Sands Section 35 project. The flaring may' take place over a 60 day time period beginning on or about August 15, 1984. This waiver and authorization is done pursuant to Rule 12, Conservation Order No. 191. All gas flared under this permit shall be metered and the volume of gas over that which is permitted for ssfety is subject' to AS 43.55.020(e). Mr. L. B. Kell/ July 16, 1984 Page 2 Within 30 days after the completion of the referenced activities, ARCO Alaska, Inc. will file a report with the Commission recapitulating the history of the activities and the resulting flared volumes. Yours very truly, Harry W, Kugler Commissioner BY ORDER OF THE COMMISSION be',l June 29, !984 ADMINISTRATIVE APPROVAL NO. 191.2 Re: The application of ARCO, Alaska, Inc. requesting that Conservation Order No. 191 be amended so that the production reports from the West Sak Sand Section 35 Project be kept confidential, Mr. L. B. Kelly Manager, West Sak Pilot ARCO Alaska,. Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Kelly: The referenced application was received on June 28, 1984 requesting that Conservation Order No. 191 be amended so that production data from the pilot project be kept confidential. ~e application stated that AS 31.05.170 was recently amended to define "regular production" and exclude pilot production activities which have been approved by an order by the Commission. The Commission considers this project to be an experimental pilot production activity and it appears the definition of the project should be amended to reflect this consideration. Therefore Rule 1 of Conservation Order No. '191 is amended as follows: _R_ule !- ProJect Define~?~. The project shall be known as the ~est Sak Sands Section 35 Project and shall be confined to the accumulation of oil that correlates with the accumulation found in the ARCO Alaska, Inc. West Sak River State No. 1 well between the depths,.of 3744 and 4040 feet. The project is designated an ~ experimental pilot production activity. Mr. L. B. Keli.~. June 29, 1984 Page 2 This amendment is made pursuant to Rule 12 of Conservation Order No. 191 and is effective July 1, 1984. Yours very truly, ,/ / ?"~ '~. V. Chat'ret'ton Chairman BY ORDER OF THE COMMISSION be:l October 26, 1983 A D M I M I S T R A T I V E A P P R O V A L ~'~O. 191.1. Res %"se application of ARCO Alaska, Inc. r~questing that Rule 7 of Con8ervation Order !.Io. 191 be amended so that a fail-safe automatic surface safety valve (SSV) is not required on producing wells in the West Sak Sands Section 35 Project. Mr. Landon B. Kelly, Manager West Sak Sands Section 35 Project ARCO Alaska., Inc. P. O. Box. 100360 Anchorage, Alaska 99510 Dear Mr. Kelly: The referenced application was received on October 25, 1983 and stated that Rule 7 of Conservation Order 1'~o. 1.91 ~hould be amended so that producing wells in the project are not required to have a SS¥. %%e application fur'ther stated that the West Sak Reservoir has been proven incapable of unassisted .flow to the surface, that the project will be continuously manned, by experienced operators .for waste-free operation, that three manually-operated s. hutdown valves will be on. the line to each producing well and that there is a need to d.e~onstrate safe, reliable, and different surface and downhole techniques for this 'less- than-prolific reservoir. The Alaska ()il and Gas Conservation Comn~ission has studied the. evidence available and hereby rescinds Rule 7 of Cons~rvation Order I~o. 191 pursuant to Rule 12 of the same Conservation Order. BY ORDER OF TIlE COb}fISSION b~ ARCO Alaska, Inc. '~ Post Office R}c. ~00360 Anchorage, Alaska 99510 Telephone 907 276 1215 Landon B. Kelly, Manager West Sak Pilot April 23, 1985 C.V. Chatterton Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501-3192 RE: Application of ARCO Alaska, Inc., Requesting Administrative Relief From Requirement Rule 9 of Conservation Order No. 191 and Extension of Administrative Rule 191.4 for Purpose of Flar- ing Gas Produced by Section 35 Project From May 31, 1985, to May 31, 1986 Dear Commissioner Chatterton: On November 20, 1984, the Alaska Oil and Gas Con- servation Commission approved Administrative Approv- al. No. 1.91.4. That approval extended the period by which ARCO Alaska, Inc., as operator of the Sec- tion 35 Project, was allowed to flare gas through May 31, 1985. This approval allowed ARCO to flare certain volumes above the safety flare volume stipu- lated in Rule 9 of Conservation Order No. 191. ARCO respectfully requests the Commission extend the application of Order No. 191.4 through and including May 31, 1986. This extension will allow ARCO to continue the Section 35 Project and gather RECEIVED reservoir and production data from the West Sak Reservoir. AoX:l, ,., ... !'r,,~,.~ ]g~ Flaring these additional volumes will . not jeop- ardize original reservoir pressure. Within Sec- ~aska 0i~ & Gas Cons. ¢0mmissi0~ion 35, material balance is being accomplished AIlch0ra§e through the injection of hot water. The injection of gas into the West Sak Reservoir at this time could materially interfere with the evaluation of the water flood and jeopardize the data gathering to determine the most efficient and prudent means for exploiting the West Sak Reservoir. Gas injec- tion would also mean the curtailment of rate of oil ARCO Alaska, Inc. is a Subsidiary of AHanticRichfieldCompany Commissioner Chatterton April 23, 1985 Page 2 production from the Section 35 Project area. At present, there is not a prudently viable means for beneficial disposal of the gas in excess of the project facility means. ARCO, therefore, requests an extension of Conservation Order No. 191.4 to allow flared volumes above the safety flare set forth in Rule 9 of Conservation Order 191. Reports of volumes of gas flared will be submit- ted to the Commission on the Producer's Report of Gas Disposition (Form 10-422) in accordance with 20AAC25.230. If the commission has any questions regarding this, or if we can provide further information, please advise me. VerV truly yours, L.B. Ketly LBK:v DI.18.5 ARCO Alaska, Post Offic~ ,.,ox 100360 Anchorage, Alaska 99510 Telephone 907 276 1215 Landon B. Kelly, Manager West Sak Pilot November 19, 1984 C(]NFIDENTInL C. V. Chatterton, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 RE: West Sak Sands, Section 35 Project Conservation Order No. 191 Administrative Relief from Rule 9 Flare Permit for West Sak Pilot Dear Chairman Chatterton, Pursuant to Conservation Order No. 191 and 20 AAC 25.235, ARCO Alaska, Inc. (ARCO) as operator of the West Sak Sands Pilot Project requests administrative relief from the flaring requirements as stated in Rule 9 of Conservation Order No. 191. ARCO requests a permit to flare up to 50 million standard cubic feet (MMSCF) of gas above the safety flare volume stipulated in Rule 9 during the continued evaluation of waterflood performance. To conduct this evaluation without controlling producing rates to minimize the flare volume to 200 MCFD, ARCO requests approval to flare a maximum of 500 MCFD through May 31, 1985. This flare permit would commence November 21, 1984. The original facility design for the West Sak Pilot production facilities utilizes the associated gas with the oil production as fuel gas for the fired heaters and supplemented with a portion of ARCO's share of gas from the Kuparuk River Unit, Kuparuk Participating Area lift gas system. Water injection at the West Sak Pilot commenced September 22 and initial injection rates have averaged 300-500 BWPD per well. Injection rates have been held at this level to evaluate waterflood response by injecting below formation parting pressure. The Sadlerochit source water temperature is higher than expected and in combination with the low injection volume, the fuel gas demand has been low. With production having stabilized at approximately 950 BOPD, the daily flare volume is averaging 250-350 MCFD, or more than the safety flare volume of 200 MCFD authorized in Rule 9 of Conservation Order No. 191. RECEIVED ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany T ov 9 tgl AlasKa 0il & Gas Cons. oommissi0r] Anchorage C. V. Chatterton Page 2 November 19, 1984 The unique nature of the West Sak Sands Section 35 Project has been recognized by the Commission. The data gathered from this Project will enable the Commission to establish pool rules, and provide valuable information for future development and drilling techniques. An integral part of the Project is to determine the waterflood response of the reservoir in this Section 35 area. With the present flaring prohibition set forth in Rule 9 of Conservation Order 191, this data may never be gathered. In order to meet the requirements set forth in Rule 9, productive wells must be shut in to avoid a potential violation. That is why ARCO is requesting interim relief at this time to flare up to 50 MMSCF through May 31, 1985. The maximum daily flare will not exceed 500 MCFD commencing November 21, 1984. Granting this request will allow ARCO to continue to waterflood a portion of the reservoir and gather valuable test and response data. It will also provide time to review options for compression and determine the optimum gas handling system for this Project. ARCO will file quarterly reports to the Commission commencing with December 20, 1984, discussing the history of activities on the Project to date, and providing the volumes flared to date. The quarterly report will also discuss the options and alternatives pursued by ARCO to solve the gas handling problem. If you have any questions please call me at 263-4525. Your consideration of our request is appreciated. Very truly yours, L. B. K.~lly Manager, West Sak LB K /TW /kjc/0005 / AOGC C RECE!VFD NOV 9 9tl4 Alasl~a 0il & Gas Cons. {;on, mission Anchorage Mr. L. B. Kelk/ July 16, 1984 Page 2 Within 30 days after the completion of the referenced activities, ARCO Alaska, Inc, will file a report with the Commission recapitulating the history of the activities and the resulting flared volumes. Yours very truly, Harry W. Eu$1er. Commissioner BY ORDER OF THE COMMISSION be:l ARCO Alaska, Inc. '{' Post OfficeB'(.,,, 100360 Anchorage, Alaska 99510 Telephone 907 276 1215 Landon B. Kelly, Manager West Sak Pilot July 11, 1984 C. V. Chatterton, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive A. nchorage, AK 99510 Re: West Sak Sands, Section 35 Project Conservation Order No. 191 Administrative Relief from Rule 9 Flare Permit for West Sak Pilot - Startup Dear Chairman Chatterton, Pursuant to Conservation Order No. 191 and 20 AAC 25.235, ARCO Alaska, Inc. (ARCO) as operator of the West Sak Sands Pilot Project requests administrative relief from the flaring requirements as stated in Rule 9 of Conservation Order No. 191. ARCO requests a permit to flare up to 60 million standard cubic feet (MMSCF) of gas during startup activities related to commissioning the Pilot facilities and wells. The commissioning activities of the facility and wells are anticipated to encompass a 60-day period and will begin after pre-startup testing of the producers are complete. This well testing could be completed as early as August 15, 1984. The original facility design for the West Sak Pilot production facilities utilizes the associated gas with the oil production as fuel gas for the fired heaters and supplemented with a portion of ARCO's share of gas from the Kuparuk River Unit, Kuparuk Participating Area lift gas system. The initial commissioning plan for the West Sak Pilot waterflood is to start water injection into the five injection wells at Iow injection rates until water breakthrough is obtained in the offset producing wells. Recent injectivity tests performed suggest that initial injection rates could be 300-500 BWPD per well, thus limiting the fuel gas demand for the heaters. During this period of time the production rate will be controlled to balance the pattern. Several workovers are anticipated during the same period. The result of these activities is that the fuel gas demand for the heaters will initially be much lower than design and will fluctuate during the 60-day Pilot startup commissioning period with the excess gas production being flared. RECEIVED ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany .";~ska 0il & Gas Cons. C0mmissiol Anchorage C. V. Chatterton July 11, 1984 Page 2 In order to safely and prudently commission the facility and the Pilot waterflood, ARCO requests, pursuant to 20 AAC 25.235 and Conservation Order No. 191, approval to flare up to 60 MMSCF of gas during the 60-day startup commissioning period. Because the startup date is not known at this time, ARCO will notify the Commission prior to any flaring under this request, if approved. If you have any questions please call me at 263-4525. Your consider- ation of our request is appreciated. L. B. Kelly Manager, West Sak LBK/kjc RECEIVED JUL 1 19 4 Alaska 0il & Gas Cons. Commission ^ncho,rage June 29, 1984 Mr. Landon B. Kelly, Manager West Sak Pilot ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 9'9510-0360 Re.. Administrative. Approval No. 191.2. Dear Mr. Kelly: Please refer to your June 28, 1984 letter requesting the amendment of Conservation Order No. 191. Administrative Approval No. 191.2, attached, amends Rule 1 of Conservation Order No. 191 to effect, by order of the Commission, the West Sak Sands Section 35 Project as an experimental ~ pilot production activity. In conformance with Section 3 Chapter 91 SLA 84 .effective June 7, 1984, the Commission shall hold confidential all Section 35 individual well production reports. Accordingly, please proceed to comply with Rule 11 of Conservation Orde.r No. 191 by filing Form 10-405, 'Monthly Production and Injection Reports for the Section 35 project. Please ensure that the Form 10-405 is stampled "Confidential" before sUbmittal. Sincerely, C. V.. Chatterton Chairman be:l.C.191 Mr. L. B. Kelk,~. June 29, 1984 Page 2 This amendment is made pursuant to Rule 12 of Conservation Order No. 191 and is effective July 1, 1984. Yours very truly, Chairman BY ORDER OF THE COMMISSION be:l ARCO Alaska, Inc."{' Post Office B5x 100360 Anchorage, Alaska 99510 Telephone 907 276 1215 Landon B. Kelly, Manager West Sak Pilot June 28, 1984 C. V. Chatterton Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 ; ~ ?.-r~,,~-_ ........ RE: Petition to Alaska Oil and Gas Conservation ~ ..... ~.. TFC' '- Commission to Amend Conservation Order No. 191-, and Keep and Maintain Confidential the West Sak f FI[.F: ........... Pilot Production Data Acquired Pursuant to Operations Approved Under Conservation Order No. 191 Dear Chairman Chatterton, Pursuant to AS 31.05.035, ARCO Alaska, Inc. (ARCO) hereby petitions the Alaska Oil and Gas Conservation Commission (AOGCC) to amend Conservation Order No. 191, and keep and maintain confidential the production reports submitted by ARCO from the West Sak Sands Pilot Project approved by Conservation Order No. 191. Earlier this year, a dispute arose between the AOGCC and ARCO related to the filing of certain production reports from the West Sak Sands Pilot Project on Form 10-405. ARCO contended that West Sak Sands Pilot production reports on Form 10-405 were not requir- ed since "regular production" had not occurred. On January 25, 1984, the AOGCC ordered ARCO to file the production reports on Form 10-405. ARCO requested reconsideration of that Order, and a settlemen agreed to between ARCO and the AOGCC. On the '~asi~.~'~ - , of that settlement, ARCO continues to file conf~e~'~!~!. production reports until Julv 1' 1984' or · . -- · . · .~% i~ '~ ", '~' "" ~ .... of the West Sak Pzlot production faczl~ .~..wh.zche~er is earlier. ~ ~?ii. ~ ' ~,.'' ..'"'~., ': Since this settlement, AS 31.05.170 was e s ature to ae ne "regular ,, This amendment was included in HB No. 680,"whiCh was recently signed by ~overnor Sheffield. A copy of 680 (Chapter 91, SLA 1984), which is effectiv~ imme~£i~:. lately, is attached hereto and made a part of tb~'"~ Petition. AS 31 05 170(14) states- "Re'ular prod%c . . . g _ tion means continuing production of oil or gas/from a well into production facilities and to market, but does not include short-term test~; .......................... ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany C. V. Chatterton June 28, 1984 Page Two evaluation, or experimental pilot production activities that have been approved by permit or order of the Commission. (Emphasis added) The term "regular production" is also found in AS 31.05.035(c). That section indicates that production data must be filed with the Commission, and that production data, as used in that section, means volume, gravity, and gas/oil ratio of all production of oil or gas after the well begins "regular production." The amendment to AS 31.05.170(14) now defines "regular production" to exclude experimental pilot production activities which have been approved by Order of the Commission. The West Sak Sands Pilot Project, approved by Conservation Order No. 191, is an experimental pilot production activity. Therefore, the production reports pursuant to Conservation Order No. 191 should be kept and maintained confidential by the AOGCC. Based on AS 31.05.170(14) and AS 31.05.035(c), ARCO hereby respectfully requests the Commission, pursuant to Rule 12 of Conservation Order No. 191, to amend Conservation Order No. 191 to keep and maintain confidential the production reports submitted by ARCO for the West Sak Sands Pilot Project, including pro- duction reports previously filed under the settlement noted above. ARCO requests that the Order adopted by the Commission amend the previous settlement agreement referred to herein. ARCO will continue to file monthly confidential production reports with the AOGCC in the same manner as those filed in previous months. ARCO representatives are available to discuss matters with the Commission at any time. Respectfully submitted this ~ day of ~3~, 1984. ARCO Alaska, Inc. %%.~..~ ManaGer West Sak Pilot Projecg-- LAWS OF ALASKA 1984 Source Chapter No. CSH~ 68O (U&C) 91 AN ACT Relating to ~the recovery and production of oil and natural gas; and providing for an effective date. BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF ALASKA:' THE ACT: FoLLows ON PAC--E'i, LI~IE, 10 Approved by the Governor: June 6, 1984 Actual Effective Date: June 7, 1984 10 11 ' read: 12 13 i--14 15 16 17 18 19 2O 21 23 24 25 26 27 28 Chapter 91 29 AN ACT : Relating t° the recovery and production of oil and natural gaS; -and providing for an effective date. . . . * Section 1. "AS 31 05.030 'is amended by adding a new subsection to . · . .. , '(h) The commission may take all actions necessary to allow the state to acquire primary. 'enforcement respOnsibility under 42 U.S.C. 300h24 (Safe Drinking Water Act of 1974, as amended, 42 U.S.C. 300f - 300j), for the control 'of .undergroUnd injection related to the re- covery and production of oiI 'and natural gas. · * Sec. 2.. AS 31.05..035'is amended y'adding a new subsection to read: (e) Notwithstanding (c) of this section, claims of confidential- _ - . ity will be denied for information disClosed to the commission under _ As 31.05.030(h) that is required to be disclosed under 42 U.S C. . : 300h-4. . :': ' "':' · * Sec. 3. .AS 31.'05.~70 ±s amended by add£ng a ne~ paragraph to read= (14) "regular production" means continuing production of oil . or gas frOm a well int° production facilities and transportation to market, but does not inClude short term testing, evaluation, or exper- imental pilot production activities that have been approved by permit or order of the commission. * Sec. 4. AS 46.03.100 is amended by adding a new subsection to read: (d) This sectiOn does not apply to injection.projects permitted .--1-- CSHB 680(L&C) :- 10 11 15; 16 17 lg .19 2O 21 :22 23 24. 26 27 28 Chapter 91 under AS 31.05. 030(h). * Sec. 5. This Act takes effect immediately in accordance with AS 01.- ! 10.070(c). CSHB 68©(L&C) · · -2- AUTHENTICATION The following officers of the Legislature certify that the attached enrolled bill, CS FOR HOUSE BILL I~.O' 680 (L&C) . . , consisting of. pages, was Passed in confomity with the requirements of the constitution and laws of the State 'of Alaska and the Uniform _ Rules of the Legislature. ' . Passed by the House March 30, 1984 . ATTEST: - · ~Chie'f ~'1~ . _ . . . - Passed by the Senate MaY 18 ATTEST: 1984 .~e' nate ACTION BY GOVERNOR Approved by the Governor Governor of Alaska . · ! LAWS OF ALASKA 1984 SOuKe Chapter No. CSHB 680(L&C) 91 AN ACT Relating to the recovery and production of oil and natural gas; and providing for an effective date. BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF ALASKA: THE ACT FOLLOWS ON PAgE 1, LINE 10 Approved by the Governor: June 6, 1984 Actual Effective Date: June 7, 1984 mde~, AN ACT Relating to the recovery and production of oil and natural gas; and providing for an effective date. Chapter 91 * Section 1. AS 31.05.030 is amended by adding a new subsection to read: (h) The commission may take all actions necessary to allow the state to acquire primary enforcement responsibility under 42 U.S.C. 300h-4 (Safe Drinking Water Act of 1974, as amended, 42 U.S.C. 300f - 300j), for the control of underground injection related to the re- covery and production of oil and natural gas. * Sec. 2. AS 31.05.035 is amended by adding a new subsection to read: (e) Notwithstanding (c) of this section, claims of confidential- ity will be denied for information disclosed to the commission under AS 31.05.030(h) that is required to be disclosed under 42 U.S.C. 300h-4. * Sec. 3. AS 31.05.170 is amended by adding a new paragraph to read: (14) "regular production" means continuing production of oil or gas from a well into production facilities and transportation to market, but does not include short term testing, evaluation, or exper- imental pilot production activities that have been approved by permit or order of the commission. * Sec. 4. AS 46.03.100 is amended by adding a new sub~ection toread: (d) This section does not apply to injection projects permitted -1- CSHB 680(L&C) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Chapter 91 under AS 31.05.030(h). * Sec. 5. This Act takes effect immediately in accordance with AS 01.- 10.070(c). CSHB 680(L&C) -2- =~lLk ~ H E:I='FI E:LO June 6, 1984 The Honorable Jalmar Kerttula President of the Senate Alaska State Senate Pouch V Juneau, AK 99811 Dear Senator Kerttula: I have signed the following bill and am transmitting the engrossed and enrolled copies to the Lieutenant Governor's Office for permanent filing: COMMITTEE SUBSTITUTE FOR HOUSE BILL 680 (L&C) (An Act relating to the recovery and production of oil and natural gas; and providing for effective date.) Chai~ter 91, SLA 1984 Sincerely, Bill Sheffie~ Governor RECEIVED J U N £ 8 Alaska 0/I & Gas Cons. Commission Anchorage ARCO Alaska, Ir~" Post Offi6. _,ox 100360 Anchorage, Alaska 99510 Telephone 907 276 1215 Landon B. Kelly, Manager West Sak Pilot April 24, 1984 C. V. Chatterton, Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99510 RE' West Sak Sands Section 35 Project, Conservation Order No. 191 Administrative Relief from Rule 9 Flare Permit for West Sak Pilot - 13 Test Dear Chairman Chatterton, ARCO Alaska, Inc. requests administrative relief from flaring restrictions as stated in Rule 9 of Conservation Order No. 191. We request a permit to flare up to a total of 30 million standard cubic feet (MMSCF) of gas from West Sak Pilot - 13 (WSP-13) during testing operations. After completion of the subject well, excess gas production caused testing difficulties. A thin sand stringer is the expected source. We believe that this thin layer of sand is isolated and is not a significant accumulation. Producing this well safely and accurately metering all produced fluids requires the use of a test separator with appropriate oil and gas meters. Flaring the gas off the test separator will substan- tially reduce the gas that is vented and provide a safe and stable production test. If conditions permit while testing WSP-13 we will obtain separator gas samples for compositional analyses. Likewise, surface and downhole pressure data will be collected for safe and prudent monitoring of well performance. At all times oil and gas rates will be metered, with the understanding that not more than a cumulative of 30 MMSCF gas will be flared. In order to safely and prudently test WSP-13, ARCO Alaska, Inc. requests your administrative relief of Rule 9 of Conservation Order No. 191 to flare up to 30 MMSCF gas. Based on the test rates we will inform the Commission prior to reaching this cumulative flare amount. Further, we will advise the Commission as to the performance of this well once the thin gas layer appears to be depleted. 'If you have any questions please call me at 263-4525. consideration of our request is appreciated. L. B. Kelly Manager, West Sak LBK/kjc Your ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ALASKA OIL AND CAS CONSERVATION COMMISSION January 25, 1984 Bill Sheffield, Governor 3001 PORCUPINE DRIVE ANCHORAGE,ALASKA 99501'-31'92 TELEPHONE (907) 279.'-1433 Mr. Landon B. Kelly ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510 Dear Mr. Kelly We have received your letter of January 18, 19.84 concerning the request for confidentiality of individual well production for wells in the West Sak Sands Section 35 Project. The Alaska Oil and Gas Conservation Commission has spent a great deal of time in consideration of your request and the applic- ability of the statutes and the regulations to it. The Commis- sion has reached the decision that the production from the individual wells in the referenced project should be reported as required by the regulations and made available to the public. Since the Commission has taken some time in reaching this decision, it feels that the December, 1983 production data should be submitted on our Form 10-405 but with a grace period of 21 days so that the Form 10-405 will be due in our office on February 10, 1984. C. V. Chatterton// v Chairman ~ BY ORDER OF THE COMMISSION be ARCO Alaska, Inc.{' Post Office 15~ x 1479 Anchorage, Alaska 99510 Telephone 907 277 5637 October 24, 1983 Mr. C. V. Chatterton, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Re: West Sak Sands Section 35 Project Conservation Order No. 191 Amendment of Rule 7 Dear Sir: ARCO Alaska, Inc. requests that Rule 7 of Conservation Order No. 191 be amended pursuant to Rule 12, Adminis- trative Relief, as described below. We request that the wording of Rule 7 be changed such that a fail-safe automatic surface safety valve (SSV) is not required on any producing well. We suggest that this change is appropriate in light of the following facts: · The West Sak reservoir has historically been proven incapable of unassisted flow to surface due to rock permeability and oil viscosity. · The Section 35 Pilot Project will be manned continuously by capable operators, and any leaks which might occur will be observed and stopped immediately. · Three manually operated shutdown valves will be on each line to each producing well. One valve will be located at the wellhead, one valve at the edge of the reserve pit, and the last valve will be located at the entrance to the manifold building. · ARCO Alaska, ~nc. is a subsidiary of AtlanticRichfieldCompany Ail pipelines carrying fluid to or from each producing well will be located on supports in the reserve pit of the drilling pad. Any leaks, should they occur, will be contained within the reserve pit. ~47~ lb.' "~,,. C. V. Chatterton October 24, 1983 Page 2 · In keeping with the nature of the West Sak Sands Section 35 Project, it is important to demonstrate safe, reliable surface and downhole techniques which provide cost effective alternatives to practices most commonly used on more prolific reservoirs. As always, ARCO Alaska, Inc. is interested in safe practices which protect life and the environment based on sound engineering and proper operating techniques. We request that Rule 7 be amended to remove the manda- tory installation of SSV's on all producing wells in the West Sak Sands Section 35 Project based on the five reasons stated above. If you have any questions please call either myself at 263-4525 or John Havard at 265-6369. Your consider- ation of our request is appreciated. Respectfully requested, L. B. Kelly Manager, West Sak Pilot LBK/JCH/kjc xc: R. K. Doughty - ATO 1988 J. C. Havard - ATO 528 J. B. Kewin - ATO 1496 J. R. Knepler - ATO 526 R. A. Ruedrich - ATO 1926 NOTICE OF PUBLIC HEARING STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: The application of ARCO ALASKA, INC., dated August 25, 1983, requesting an order permitting a pilot production project on the West Sak Sands in the Kuparuk River Field to gain infor- mation for development of the West Sak Reservoir. Notice is hereby given that ARCO Alaska, Inc. has requested the Alaska Oil and Gas Conservation Commission, to issue an order permitting the applicant to conduct a pilot project within Section 35, TllN, R10E, UM. The purpose of the project is to gain data on the producibility of the West Sak Sands reservoir using various completion techniques and additional recovery methods on closely-spaced wells and to gain information for presentation at a pool rules hearing if pool-wide development is prudent. Parties who may be aggrieved if the order is issued granting the referenced request are allowed 10 days from the date of this publication in which to file a protest, in writing, stating in detail the nature of their aggrievement and their request for a hearing. The place of filing is the Alaska Oil and Gas Conserva- tion Commission, 3001 Porcupine Drive, Anchorage, Alaska 99501. If such a protest is timely filed, a hearing on the matter will be held at the above address at 9:00 AM on September 23, 1983 at which time protestants and others may be heard. If no such protest is timely filed, the Commission will consider the issu- ance of the order without a hearing. Harry'. Kugl Commis s ioner Alaska Oil and Gas Conservation Commission PROOF OF PuBblCATIOm THE~ ANCHORAGE Ti" P.O. BOX 40 ANCHORAGE, ALASKA 99510-0040 AK OIL m GAS CONSERVATION COMB 3001 PORCUPINE ANCHORAGE, AK 99501 DEBBY M. AUSTIN , BEING DULY SWORN, ACCORDING TO LAw DECLARES: THAT SHE iS THE LEGAL CLERK OF THE ANCHORAGE TIMES, A DAILY' NEWSPAPER PUBLISHED IN THE TO~N OF ANCHORAGE IN THE THIRD jUDICIAL DIVISION, STATE OF ALASKA, AND THAT THE NOTICE OF.......................... AO-08 5526 A COPY OF' WHICH 15 HERETO ATTACHED, WAS PUBLISHED IN.......,..,..,..,,. OF THE ANCHORAGE TIMES. B~GINNING ON.,,.,,,,,,....,,,...... ENDING ON........................,. ISSUES 09/09183 09109/83 THE SIZE OF THiS AD WAS..........,. 65 bINES THE PRICE OF THIS SIGNED.... , . , AD I$,,,,,,,,,,,,, $ 19,50 THE AD NUMBER IS.................... 1619465 NOTICE OF PUBLIC HEARING STATE OF ALASKA AMska OII and Gas Conservation Commission Re: .The aPpllcatlon, of ARCC ALASKA, INC.~ d~fed AU gust 2~, 198~, requesting or order ~ermlfflng Xt':' PilO' broductlon prolect."'on th~ West tek S~nds in the Ku paruk River Field to golr ' Information~ for . develop. =' mont. of .the:iWest.Sok Res ,~ ervolr. , · Notice IS hereby given thai 'ARCO Alaska~ Inc.' has re. quested the Ala'Ska. OII ~nd Ga~ .Conservation CommisSion, to ! Issue an order permlfflng the t apMIcant to coDduCt a'pllot, prol. ~ect within S~ctlon. 35~,r T11N, R10E, UM. The purl~se of the prolect Is to gain data', on. the I:Preduclblllty of .the, West Sak Sands reservoir, uslng"~arlouS completion teChnlque~';ahd addl.. I. tional recovery.~; m~thods on ~closel¥,sPaced wells and to ga n ~'lnformation for presentation, at q poO. I rules hearing. If ..IX~l-wlde ; ae_velopment .Is pruaenT'. · '.Parties wno may .De ag- , g'rJeved, ..if. granting the reterenced re~iuett qr.e allowed 10 days: ;fFo~ ..the · aate of.this publication i, Which fifll, oi.' I!e a ~rotest, In.'wrJtlr)g~"~tat4 'ling ~ln detail the' na¥~e.',0f their: i .aggrlevement and' flielr request for a hearing. Theglace 0f .filing ?iS~the Alaska 011, .and'.Ga~i Con- se~vatlon' commi~sr6~; .Porc. uplne Drive, i Ancho. ro.ge~ .iA.'lasKa 99501. If sucn. a protest Is.' .timely flied, a hearing '~on the. .n!atterwlll be 'held'~at~th~e'.a~ge address at 9:00 AM on. Semem. , .IM, r. 23., 1983 .at Which time pro~. i.!e~stants 'ana othe. rs maybe h6ar.d. If .no. $uch'~:~protest ~qs .timely filed, the CommissiOn Will consider· the Issuance of the larder without ahearlng... '.. Harry W. KU01er ' Com.mlssL0~ex i 'Alaska Conservation Commission , 'Aa-08 5526 . Pub,:,Sept.' % i983 ' ' SUBSCRIBED AND SWORN TO 8~FORE ~,E THIS,...............,., 09 DAY OF SEP,198~ ~""~' ~-,,,, !~,~'" ,,~ :r~f~' ~, ',~/? ,~,,~., ARCO Alaska, Inc( Post Office .~ox 100360 Anchorage, Alaska 99510 Telephone 907 276 1215 August 25, 1983 Mr. C. V. Chatterton, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 RE: West Sak Sands Pilot Project Kuparuk River Field Sec. 35, TllN, R10E, UM CONFER: FtLF: I> Dear Sir: ARCO Alaska, Inc. proposes the implementation of a West Sak sands pilot production project in the Kuparuk River Field. The entire project will be located in Section 35, TllN, R10E, UM. Our purpose is to determine the optimum technique(s) for development of the West Sak reservoir, and to gather information for use in a pool rules hearing once appropriate. We hereby petition for a conservation order allowing ARCO to conduct a pilot test of the West Sak sands in Section 35. The West Sak sands are part of the late Cretaceous deltaic system which underlies the Kuparuk River, Milne Point and Prudhoe Bay Units. The interval in which the West Sak sands occur is shown between 3744 and 4040 feet MD on the Arco West Sak River St. #1 log, Attachment 1. Drilled in 1971, this was the discovery well for'~'~i--i-~-"~e West Sak sands. The West Sak sands consist of very fine-to-fine grained sand with interbedded mudstone and claystone. They are oil-bearing primarily in the Kuparuk and Milne Point Units. This pilot will test recovery techniques useful in producing West Sak oil typically found at the depths and temperatures within these two Units. In the West Sak pilot project ARCO intends to assess the performance of various recovery techniques beyond the primary mode. Because of this, we feel several variances in the statewide oil and gas regulations are appropriate. Our sug- gestions for specific variances follow. Concerning drilling operations, we intend to employ various casing designs in wells. In all cases the conductor will be set at 80'. This depth is well below the deepest interval in which free ice has been encountered within the Kuparuk area. In gravel mining operations, free ice has been found only in Gas Cons. ,iL-l!.i~..~.a.~~, ~-~r. f~ · .r~ ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany Mr. C. ~" 'hatterton, Chairman August 2). 1983 Page 2 the top 17' of overburden. Normally this ice does not extend below the 2' to 3' active layer. To date, the deepest mining operations have been taken is approximately 60'. A separate surface casing string will be set below the permafrost when needed to facilitate special drilling operations; however, the typical design will utilize 7", 23#, BTC surface/production casing. The 7" surface/production casing will be set either above or through the West Sak interval. Our tentative grade selection for this casing string is S-95. Tensile tests made on this pipe in the past month indicate a minimum yield strength of 91,000 psi. With this yield strength, the casing will be able to withstand stresses due to warm or thermally stimulated wellbores and "column-type" loading to a depth of 2000' or more, without any support from the conductor. The 7" casing will not be structurally dependent on the 9 5/8" conductor. Additionally, the 7" surface/production casing will withstand any imposed freeze-back pressures as determined in previous modeling work for surface casing qualifications. Due to the strength of the 7" casing and the high risks and costs inherent in using multiple stage equipment, we may not cement the surface/production casing back to surface. We are currently evaluating cement tops in the range of 1500' to 2000'. Lateral support from the permafrost will probably be sufficient to prevent an undesirable buckling condition. This is currently being studied and exact cement tops with explanations will be provided in the specific well Permit To Drill Applications. The effects of permafrost subsidence on the 7" casing is under investigation. We are currently determining the suitability of this casing through a computer-generated finite element analy- sis to determine post-yield tensional and compressional strains. With the above in mind, a variance is required to allow surface/production casing to be cemented with a "deep" cement top. This will provide for zonal isolation of hydrocarbons and actually reduce stresses in the casing string by allowing the casing to expand when heated. On West Sak wells without surface casing, a flow diverter stack will be used to drill below conductor casing to below the West Sak. This has recently become common practice in western Kuparuk development wells due to the very low potential for flow from both the Ugnu and West Sak formations. We believe that this can be safely extended to the pilot project area. When surface casing is utilized, a RSRRA or RSRA BOP stack will be employed when drilling below surface casing. On all wells, Mr. C. V~ hatterton, Chairman August 25, 1983 Page 3 a 3000 psi (minimum) and RSRA BOP stack will be used during completion. One particular recovery technique we wish to test is a hot waterflood. Ten to twenty thousand barrels of water will be injected per-day (note this is an upper limit depending on reservoir and fluid characteristics in Section 35) to raise reservoir pressure. We therefore request that permission be granted for water injection into the West Sak. Although the water source has not been identified, two good possibilities are the Ugnu water sands above the West Sak and the Sadlerochit formation which underlies the Kuparuk reservoir. Because the pilot is located west of the massive Eileen fault (which defines the western boundary of the Prudhoe Bay field), producing Sadlerochit water for the pilot should not negatively impact reservoir pressure in any Sadlerochit producing area. To obtain timely results, it will be necessary to conduct the hot, high pressure waterflood on close spacing. For section 35 we suggest: (1) No wellbore may be opened in the West Sak closer than 500' to a property line common to another leaseholder. (2) No spacing restrictions apply on the West Sak interval. Because there is a need for flexibility in testing recovery techniques, we suggest that the above be the only spacing stipulations within Section 35 through the west Sak interval. We request that up to 30 wells be allowed in the proposed pilot. In the potentially producible areas of the West Sak, there are typically several oil bearing sands separated by impermeable mudstones and claystones. A recent correlation of wireline formation test data has shown that the pressure gradient through the West Sak is fairly constant. No indication of abnormal gradient between sands has ever been detected. Because we expect a normal production drawdown would greatly exceed any pressure difference between producing intervals, we believe that the West Sak should be commingled using a single completion. Because of the limited areal extent of the Pilot, we propose that one mud log and set of cuttings be required per drillsite. Furthermore, we propose that only one well per drillsite be logged continuously with an electric/radioactive log from conductor to TD. Subsequent wells on the same or adjoining pad may only be logged across hydrocarbon bearing intervals. Mr. C. '~attert0n, Chairman August 2, 1983 Page 4 We believe that there is low potential for natural flow from the West Sak wells. Because of this, sub-surface or surface safety valves will not be used. The pilot will be continuously monitored by operations personnel for both wells and facilities. For safety, an emergency flare system will be installed for relief of critical areas in the production facilities. It therefore will be necessary to maintain a pilot flare that will consume approximately 200 MCFPD continuously. We believe that the pilot project herein proposed will be an important step in understanding the economic potential of the West Sak reservoir. We intend to begin implementation of the project as soon as AOGCC approval is obtained. Please contact either L. B. Kelly at 263-4525 or John Havard at 265-6369 if additional information is needed. Respectfully submitted, L. B. Kelly Manager, West Sak Pilot LBK:CLC:pg cc: J. C. Havard R. K. Doughty J. R. Knepler J. B. Kewin R. A. Ruedrich AT0/528 AT0/1988 ATO/l176 AT0/1496 AT0/1926
