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Home My WebLink AboutCO 252Conservation 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 plotter/scanner) ~"Maps: [] Other items OVERSIZED (Not suitable for plotter/scanner, may work with 1~3.--"~ Logs of various kinds [] Other BY: MARIA Scanning Preparation DATE :~).~Z~ ....(~_~ /S/ TOTAL PAGES 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 (SCANNING IS COMPLETE AT THIS POINT UNLESS SPECIAL A'I-FENTION IS REQUIRED ON AN INDIVIDUAL PAGE BASIS DUE TO QUALIT'Y, GRAYSCALE OR COLOR IMAGES) General Notes or Comments about this Document: 5/21/03 ConservOrdCvrPg.wpd STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Re: THE APPLICATION OF UNION ) Oil Company of California ) to establish spacing rules ) and commingling of product-) ion of oil bearing sands ) below the Hemlock oil pool ) in Trading Bay Field with ) other pools in the field. ) Conservation Order No. 252 Trading Bay Field Undefined zone below the Hemlock oil pool May 7, 1990 IT APPEARING THAT: 1. Union Oil Company of California (Unocal) submitted an appli- cation dated March 21, 1990 requesting rules governing well spacing and commingling of production of oil bearing sands underlying the Hemlock oil pool in the Trading Bay Field with production from other pools in the field. 2. A notice of public hearing was published in the Anchorage Daily News on March 23, 1990. 3. A public hearing on the matter was held April 23, 1990 in the offices of the. Alaska Oil and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska. Testimony was presented in support of the petition. FINDINGS: 1. Oil bearing sands underlie the Hemlock oil pool in strata that appears to correlate with the West Forelands Formation. 2. Insufficient information is available to delineate these oil bearing sands as a separate pool. 3. The areal extent of the oil bearing sands appears to be approximately 160 acres. 4. More than one well will be required to drain the accumulation because of the high clay content of the reservoir sands. 5. Wellbore commingling of produced fluids from these sands with production from overlying pools will promote the prudent development of the sands. 6. Conservation Order 93A concluded that allocation of produced fluids to their respective pools in Trading Bay Field is no longer of any benefit to reservoir management, ultimate recovery, or the prevention of waste. Conservation Order No. 252 Page 2 May 7, 1990 CONCLUSIONS: 1. Unlimited well spacing in the oil bearing sands underlying the Hemlock oil pool will benefit reservoir management, improve ultimate recovery and prevent waste. 2. Wellbore commingling of produced fluids from the oil bearing sands underlying the Hemlock oil pool with production from other oil producing intervals within the field will enhance ultimate recovery and prevent waste. 3. Correlative rights will be protected if the wellbore is not open to production within 500 feet of a lease boundary marking a change in ownership. NOW, THEREFORE, IT IS ORDERED: 1. Conservation Order 93 is amended by adding a new rule to read: Rule 13. Spacing rules for oil bearing sands below Hemlock Oil Pool. Unlimited well spacing is allowed for wells drilled to oil bearing sands underlying the Hemlock oil pool, except that no well may be open to produce these sands closer than 500 feet to a lease boundary marking a change in ownership. 2. Rule 3 of Conservation Order 93 (as amended by C.O. 93A) is further amended to read: Commingling in the wellbore of produced fluids from the Trading Bay Middle Kenai B, C, D, E, and Hemlock oil pools, and those oil bearing sands which overlie the Middle Kenai 'B' oil pool and those oil bearing sands which underlie the Hemlock oil pool is permitted. Total well production need not be allocated to each pool and productive sand. Done at Anchorage ~~~~ C'.' V. Chatterton, Chairman d Gas Conservation Commission David ]~. ~Joh~ioner ~~ Fl~~~~~.~a~~~~rvati°n C°mmis si°n L~ie C. Smi~~ommissioner Alaska Oil and' Gas Conservation Co~ission l0 12 14 16 17 20 2! 22 23 24 25 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: UNOCAL application to ) commingle production of those ) oil bearing sands which ) underlie the Trading Bay ) Field, Hemlock Oil Pool. ) ) APPEARANCES: FOR THE COMMISSION: ALSO PRESENT: PUBLIC HEARING MR. CHAT CHATTERTON, CHAIRMAN MR. LONNIE SMITH, MEMBER MR. DAVID JOHNSTON, MEMBER MR. ROBERT PROVINCE, UNOCAL MR. DUANE GRUBERT, UNOCAL MR. ROBERT WARTHEN, UNOCAL MR. RON KIES, UNOCAL MR. RUSS DOUGLASS, AOGCC MR. ROBERT CRANDALL, AOGCC April 23, 1990 2:00 p.m. Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska R & R COURT REPORTERS 810 n STREET, SUITE 1OI 509W. 3RDAVENUe 277-O572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 12 14 16 17 20 22 23 24 25 PROOEED I NG S MR. CHATTERTON: Sood afternoon. For the record I am Chat Chatterton, Chairman of the Oil and Gas Conservation Commission, and we are at $001 Porcupine Drive, Anchorage, in the conference room of the Alaska Oil and Gas Conservation Commission. We are here in response to a request by Union Oil Company for an exception to some commingling regulations that now exist. And the time I believe is about 2:05, the afternoon of -- what date? MR. SMITH: 23rd. MR. CHATTERTON: The 23rd of April, 1990. Lonnie, would you -- oh, before we go, why, let me introduce the people at the head table here. To my right, your left, is Commissioner David Johnston, and to my immediate left is Commissioner Lonnie Smith, and at my far left is Meredith Downing with the R & R Court Reporters, who will be recording the proceedings at this session. Without further adieu, why, we'll read into the record the notice of this meeting. Lonnie? MR. SMITH: Yes. The notice of the public hearing was published in the Anchorage Daily News on March the 23rd, 1990. "State of Alaska, Alaska Oil and Gas Conservation Commission. Reference: The UNOCAL application to commingle production of those oil bearing sands which underlie the Trading R & R COURT rEPORTERS 810 N STREEt, SUITE 101 509 W. 3rd AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-75 ! 5 Bay Field, Hemlock Oil Pool. "UNOCAL in correspondence dated March the 21st of 1990 has applied for an order allowing commingled production of those oil bearing sands which underlie the Trading Bay Field, Hemlock 0il Pool with production from other defined oil pools in the field. "A hearing on the matter will be held at the Anchorage -- Alaska Oil and Gas Conservation Commis- -- Commission, 3001 Porcupine Drive, Anchorage, Alaska, 99501, at 2:00 p.m. on April the 2$rd, 1990, in conformance with AS 31.05.100(a). Lonnie Smith, Commissioner." MR. CHATTERTON: Thank you, Lonnie. Bob, how many -- who do you have planning to testify? MR. WARTHEN: Mr. Commissioner, we have -- Mr. Chairman, we have two expert witnesses to testify today. We have Mr. Duane Grubert, who's a petroleum reservoir engineer with Union Oil Company, and'we have Mr. Ron Kies, a petroleum geologist also with Union Oil Company. Both of the -- both of these individuals have testified previously and have been designated as expert witnesses, s'o perhaps you might want to swear them in and we can begin? MR. CHATTERTON: Bob, with all -- all due respect, why, they have not been sworn in or qualified as expert witnesses to testify in -- in this hearing, and so we will ask you to go through that song and dance again for us -- our R & R COURT REPORTERS 810 N STREET, SUITE 10! 509 W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-7515 l0 16 17 20 22 23 24 consideration. But ..... MR. WARTHEN: Very good. MR. CHATTERTON: ..... without any further adieu, Lonnie, would you like to swear the two witnesses in, please? MR. SMITH: Would you stand, please? RON KIES DUANE SRUBERT having first been duly sworn, testified as follows: MR. SMITH: Thank you. MR. CHATTERTON: Thank you. Thank you, Lonnie. All right. You may proceed, and you may state your qualifications as -- at the beginning of your testimony if you like. MR. KIES: My name is Ron Kies. I work for UNOCAL Oil Corporation. I've been a petroleum geologist for the past eight years. The last two years I've been involved with Cook Inlet development work, primarily the Trading Bay Field, the Monopod Platform. Prior to this time I was involved with exploration work both on the North Slope in the Beaufort and Bering Seas. And prior to working for UNOCAL I graduated with a masters from San Diego State University. MR, 8RUBERT: My name is Duane Srubert, ..... MR. CHATTERTON: Thank you. Just a moment. Any objections? MR. JOHNSTON: I have no objection. R & R COURT REPORTERS 81ON STREET, SUite 101 509W. 3RDAVeNUe 277-O572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 l0 ]2 13 16 17 20 2! 23 24 MR. SMITH: No. MR. CHATTERTON; All right. Very good. Ron, we'll -- we'll sure recognize you as an expert witness in the matters before us at this hearing. Thank you. MR. GRUBERT: My name is Duane Grubert. I'm a petroleum engineer for Union 0il Company. I've been working for the company for seven years, working exclusively on the Cook Inlet for about two and a half years. Prior to that my work involved the oil fields of California involving primarily gravel pack, sand control completions. My education in the petroleum discipline was at Stanford University. I received my bachelor of science degree there in 1983. MR. CHATTERTON: Thank very much. And we will accept you as an expert witness in the matters before us. You may proceed. MR. KIES: Recently with the drilling of Trading Bay State number A-28 redrill from the Monopod Platform UNOCAL drilling the Hemlock oil pool and set casing. And at that time, because we had encountered the Hemlock oil pool in an up dip position in the thrust -- subthrust fault block to the northeast of the platform, it was decided to go ahead and extend the well and examine and test the West Foreland Formation below the Hemlock. The West Foreland is unconformally -- rests on the R & R COURT REPORTERS 810 N STREET, SUITE 1OI 509 W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-7515 14 16 17 19 20 2! 22 23 24 25 duracic (ph) Talkeetna Formation and is disconformally overlain by the Hemlock Formation. It's an interval in the ..... Exhibit Four is the type log from Trading Bay State A-28 redrill which shows the West Foreland Formation from 9079 to 9857 measured depth in the Trading Bay State A-28 redrill well. This oil pool prior to this time has not been encountered in any of the wells in Trading Bay Field either in the subthrust block in which this well is located, or in the main producing portion of the field called the two-A fault block. It's ..... Our purpose here today is to define this as an oil pool for the purposes of commingling with the Hemlock Formation so that we could take advantage of this newly discovered resource. I'll just review quickly a little bit of the geology. Exhibit One is a structure map of the subthrust block of the Trading Bay Field. It's a compressional fault block between the Trading Bay fault to the east -- excuse me, to the west, and the Texaco fault to the east. This compressional block is very steeply dipping. It has dips from 30 to 65 degrees, and locally the beds are overturned where they're in contact with -- with the Trading Bay fault. So it's a very steep dipping fault block. Our well, which I'll point out, was the first well to come significantly up dip within the subthrust fault block. For this reason, we decided to again extend into the West Foreland and what we encountered was a section of West Foreland which R & r COURT REPORTERS 81on STREET, SUITE 101 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 9950! ! 007 W. 3RD AVENUE 272-7515 10 12 14 16 17 20 22 23 24 25 looked prospective for oil production. Exhibit Two is a cross section, A-A-prime through the well, showing the general structural configuration. And as you can see, it's a very steep easterly dip to this portion of the -- of the subthrust reservoir. Exhibit Three is a stratigraphic cross section which ties the A-28 redrill well to the TS four well to the north. I'll point out the TS four. TS four is the well that indicated that there was a number of sands below the Hemlock Formation which could be productive if they were encountered far enough up dip. From this information again it was decided that we should penetrate the -- the Hemlock and -- and look for some Nest Foreland reservoirs. And that's A-28 to the left. Because of reservoir quality concerns and the somewhat subjective call on if it was productive or not, we, of course, put the well on test. And Duane can review a little bit about those test results and describe the -- the production characteristics that we have so far on the -- on the Nest Foreland. MR. GRUBERT: This well is very important to us in that it is exploiting the West Foreland at Trading Bay Field for the first time. And in terms of our desire to commingle the zone with other zones, I think this is a classic example of where commingling serves to allow greater production from the field. After really an exhaustive effort to make the West R & R COURT REPORTERS 81ON STREET, SUITE IO1 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 ~ 2 l0 12 13 14 16 17 19 20 2! 23 24 8 Foreland productive, we've ended up with a 50-barrel per day producer, which given the cost of drilling the well is not at all economic to justify future development. However, in concert with the Hemlock production that we anticipate is producible from this same well bore, we can leave that 50 barrels per day on and allow it to be produced. The way we have to look at it at this point, since we have limited data on the West Foreland producibility, is that we cannot drill wells for the West Foreland alone; however, there should be no reservoir problem with keeping these perforations open when we go and take our Hemlock completion. So this has been a relatively recent event for us, and again we have about a 50-barrel oil per day producer here, and anticipate to get significantly higher rates from the Hemlock. But we are requesting to leave these perforations open to commingle the two and we want to set this precedent for the record to allow commingling of the West Foreland with the Hemlock or with the other zones. MR. CHATTERTON: What would be the areal extent roughly between the -- of this accumulation between the Trading Bay Fault and Texas -- Texaco Fault? MR. KIES: Approximately, if you could look for scales here, this is 250 feet, so the entire width of that block is only 2,000 feet at its widest. MR. CHATTERTON: And the areal extent of the R & r cOUrt REPORTERS 810 n STREET, SUITe IO1 509W. 3RDAVeNUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 ! 007 W. 3RD AVENUE 272-7515 l0 12 14 16 17 19 20 2! 22 23 24 indicated pool limits? MR. GRUBERT: The green. The green. MR. CHATTERTON: That's the green -- the green line? MR. KIES: Yes. Right. The indicated -- the pool limits that we have delineated here are indicated in dark green on the map. MR. CHATTERTON: And -- and roughly how many acres? MR. KIES: Roughly 27- -- excuse me. The acreage on that is roughly -- have to -, I have to refer ..... MR. GRUBERT: Maybe the oil in place number would be more relevant. We -- we're figuring with the limited data we have about ..... MR. CHATTERTON: No, I'd say ..... MR. KIES: He -- he needs f ..... MR. CHATTERTON: ..... not right now, ..... MR. GRUBERT: Okay. MR. CHATTERTON: ..... that isn't more ..... MR. KIES: I just need the ..... MR. CHATTERTON: ..... relevant. I'll get to that. MR. GRUBERT: Okay. MR. CHATTERTON: Don't try and guess how my brain works. R & R COURT REPORTERS 8i0 n STREET, SUITE 101 509 W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 l0 12 13 14 16 17 19 20 2! 22 23 24 25 10 MR. GRUBERT: No, no. MR. KIES: Jesus. What was that areal extent? That's only the ..... MR. SRUBERT: You can back it out. MR. KIES: Yeah, I can ..... MR. OHATTERTON: Well, ..... MR. KIES: ..... 40 acres? MR. CHATTERTON: What's the size ..... UNIDENTIFIED: (Indiscernible) MR. KIES: No, it's ..... MR. CHATTERTON: ..... of the section ..... MR. KIES: ..... bigger than that. MR. CHATTERTON: ..... there? We can -- we can guess if -- if you show me the outline of the section, ..... MR. KIES: Let me show you the outline there. MR. CHATTERTON: ..... or the quarter section, I can pretty well guess myself. MR. KIES: This is one section, so it's about ..... MR. CHATTERTON: Oh, it's one section. Okay. MR. KIES: ..... it's about a quarter section. MR. CHATTERTON: You're about 160 acres, yeah. MR. KIES: Right. MR. CHATTERTON: Okay. Fine. Is the -- about the areal extent of this indicated pool. All right. Very, very R & R COURT REPORTERS 810N STREET, SUITE 101 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-75 ! 5 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 good. MR. KIES: Yeah. MR. CHATTERTON: And under current ..... MR. KIES: We ..... MR. CHATTERTON: ..... Am I right, under current regulations, why, you -- that would permit you to drill one well to this pool, is that correct? 160-acre spacing for an oil -- ? or is there something else that ..... ? MR. WARTHEN: That's -- that's correct. MR. KIES: That is correct, ..... MR. CHATTERTON: That is ..... MR. KIES: ..... under the -- under ..... MR. CHATTERTON: ..... correct, right. MR. KIES: ..... the present pool rules. MR. CHATTERTON: And you do not believe one well will adequately drain this accumulation, is that right? MR. KIES: That is correct. We feel given the reservoir quality of the rocks, it will require a tighter spacing than 160 acres to come -- come anywhere near draining ..... MR. CHATTERTON: Right. MR. KIES: ..... the oil in place within this block. MR. CHATTERTON: Have you made an estimate of that spacing? Of that density? MR. KIE$: No, we haven't. And I think it has a R & R COURT REPORTERS 810 N STREET, SUITE I O I 509 W. 3Rd AveN U e 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-75 ! 5 l0 12 [4 17 20 21 22 23 24 lot to do with how you want to -- we have not made an estimate of that ..... MR. CHATTERTON: Okay. MR. KIES: ..... spacing, no. MR. CHATTERTON: Have you made an estimate of the acre feet? MR. KIES: Yes, we have. MR. CHATTERTON: Well, if -- if Duane's going to touch on these, ..... MR. KIES: Um-hm. MR. CHATTERTON: ..... well, we can wait for that later on. Okay. Bob? MR. KIES: That's ..... MR. WARTHEN: I think, Mr. Commissioner, that we felt at the time that when we made this here discovery in the West Foreland, that since this is a long narrow band so to speak between the Monopod and platforms further to the northeast, it would appear that two wells could drain this accumulation. I don't know at this juncture whether we could drill those two wells -- or one additional well from the Monopod or if we could use the spur in a drilling capacity, since that platform has no drilling capabilities right now. So we still are investigating that possibility. MR. CHATTERTON: Okay. MR. WARTHEN: I think though initially we feel R & R COURT REPORTERS 810 N STREET, SUITE 10 ! 509 W. 3R D AVENUe 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 13 14 16 17 19 20 2! 22 23 24 25 13 that two wells could drain this -- this feature in the West Foreland. MR. CHATTERTON: Now, I presume that in no way could you develop this accumulation with two wells drilled solely and completed in the -- in the -- this -- these oil -- these oil bearing horizons, is that right? MR. WARTHEN: That's correct. Not for this entity by itself. MR. CHATTERTON: So it's got to piggy-back on an existing or yet to exist wells? MR. WARTHEN: That's correct. MR. CHATTERTON: Thank you. Any other questions? MR. SMITH: Not now. MR. CHATTERTON: Okay. proceed, Duane, if you like? MR. SRUBERT: Okay. the most important thing here. Not right now. Thank you. You may I think we've hit on really This feature herein the subthrust block will never be fully or properly exploited, because it is as unproductive as -- it -- it is as small as it is and as unproductive as it is. And as you pointed out, the only way you're going to see West Foreland production here will be in conjunction with, for example, a Hemlock well where we just deepen and take the West Foreland with it in a commingled completion. We've been bouncing around an oil in place estimate of r & R COURT REPORTERS 810N STREET, SUITE IO1 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 10 11 12 13 14 15 16 ¸17 18 19 20 21 22 23 24 25 14 about 30 million for the West Foreland, so it is a significant accumulation in that respect. The areal extent is rather limited compared to the other reservoirs in the other over-lying sands. However, we would like to be able to develop as much of this as we can. We know the resource is there, and unless commingling is allowed, we would never drill a well to this asset. And unless commingling is allowed, none of that oil will be produced. MR. SMITH: And what was the oil number again? The in-place? recover? MR. GRUBERT: MR. SMITH: Thirty million barrels. Thirty million? MR. GRUBERT: As a preliminary number. MR. SMITH: And how much would you expect to MR. GRUBERT: It would really depend on the Hemlock development, and it's too early to get a good feel for that. The quality of the rock here is poor, and perhaps a 5~ recovery estimate wouldn't be unreasonably low, if you were going to try just to get this horizon developed. However, economically you would never do that. For this particular portion of the field, I foresee maybe two, possibly three eventual Hemlock wells that could also exploit the West Foreland. And based on the rates we've seen, we're talking in the neighborhood, unless we see something better, of about 150,000 barrels of West Foreland oil per well. R & R cOUrt REPORTERS 81ON STREET, SUITE 10~ 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 9950! 1007 W. 3RD AVENUE 272-75 I 5 l0 16 17 19 20 2! 22 23 24 25 15 So on the order of half a million barrels of oil is -- is really the issue that will be exploited if we can commingle, and it will just be left behind if we cannot. MR. SMITH: Okay. And would you propose to.do any testing between the zones here at all on such a well? MR. GRUBERT: On the well that we've already drilled to this zone, we have a good figure for production from the West Foreland alone, and on this particular well, I don't see foresee that we would do a lot of diagnostic testing in the first, let's say, year of production. But if a well in the future was to be produced with the original intent of having both zones completed, again it would be as the other commingled wells are, prudent on our part to production log the well on about an annual basis, just to clarify where the production really is coming from. The other thing that is particularly convenient with a West Foreland commingled completion is that we foresee this will be the bottom set of perforations in any well. There's nothing below us here, and in the event that the West Foreland does water out or does create any problems, it is easy to abandon those perforations just by spotting sand or cement; whereas in a different set of commingled perforations, for example, a D/West Foreland, the upper set of perforations are often difficult and expensive to eliminate. Here the West Foreland is really a convenient set of perforations to be able to exclude in the R & R COURT REPORTERS 810N STREET, SUITE 104 509W. 3RD AVENUe 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-75 i 5 l0 12 13 16 17 19 20 21 22 23 24 25 16 future if you have to. reservoir rock? MR. SMITH: Okay. MR. CHATTERTON: Dave? MR. JOHNSTON: Could you briefly describe the MR. KIES: In -- the -- the West Foreland is a poorly sorted, volcanic wacky at -- at this location, which is kind of in keeping with the -- the general reservoir quality that was seen throughout the Cook Inlet. It's large -- the large amount of clay matrix material is responsible for the -- the low porosity which we see in this well, and a number of wells in the immediate area. MR. JOHNSTON: You said -- in -- earlier you said this was steeply dipping and in some places overturned? MR. KIES: Yes. When we looked at the dip meter data, actually the FMS data on the A-28, we discovered that there's a small amount of over-turning locally on the down-thrown side of the Trading Bay Fault. It -- we weren't able to see this over-turning on the -- the Hemlock or the West Foreland, but we've seen it on the shallower zones, the D and the E zones above the Hemlock. This is because we pierced the Trading Bay Fault, and we went from the -- the up-thrown side down into the -- the D and E zones, and it's just below this that -- it's just below the Trading Bay Fault that we see the over-turning. It's just -- again it stresses the -- the high degree and R & R COURT REPORTERS 81ON STREET, SUITE IO1 509W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1OO7 W. 3RD AVENUE 272-7515 l0 ll !2 !3 !4 !6 !7 !9 20 2! 22 23 24 25 17 -- of steep dips and structural complexity which characterize this block, to make it difficult to -- it's very important that we use very few well bores as -- as few well bores as possible to deplete the block, because it is so narrow and elongated. MR. JOHNSTON: The -- the fault that cuts the accumulation at a 45 degree angle about mid way up through it, what kind of throw do you have on that? MR. KIES: We are missing about 450 feet of section, so we interpret that to have around 400 feet of -- of throw. It could be slightly greater, be- -- along the course of its trajectory, but we feel it's a -- it's a reasonable -- a reasonable estimate. Because of the steep nature of the dips in the subthrust block, we rely entirely on dip meter data, the old well data, to -- as a guide. Geophysical information is of limited use. So it's -- it's difficult to delineate it other than where we have fault -- or well control. MR. JOHNSTON: And the accumulation extends across that fault so it's not sealing? MR. KIES: We at the present time feel it is not a sealing fault. UNIDENTIFIED: MR. JOHNSTON: MR. CHATTERTON: That's right. I have no further questions. Not quite two years ago in a -- in a matter of commingling, downhole commingling, the Commission R & R COURT REPORTERS 81ON STREET, SUITe 101 509W. 3rD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 l0 12 13 16 17 19 20 2! 22 23 24 18 concluded from the testimony that was given at that hearing, that the allocation of produced fluids to their respective pools is no longer of any benefit to reservoir management, ultimate recovery, or the prevention of waste. And, of course, this was referring to the Trading Bay Field, and -- and at that time it was not -- did not have the -- the sands below the Hemlock in mind. Would -- would you say that that statement still is valid even after we've seen this -- these sands below the Hemlock? MR. GRUBERT: Yes, this really hasn't changed anything, and that comment is very important, that as we saw at the previous hearing today regarding the A zone, when our discussion there started ..... MR. CHATTERTON: Regarding what? MR. GRUBERT: Remember the A zone ..... ? MR. CHATTERTON: No, I don't know anything about MR. GRUBERT: the A zone. different direction. Okay. I'll -- I'll take this In discussion of the pools in the past two or three years, the re-interpretation of geologic data and the acquisition of new geophysical data has gotten the picture clearer that we do have extensive faulting, and that the pools are not as relevant to reservoir management as we had previously thought. We continue to in-house think of the reservoir in terms of pools. However, the actual end recovery from the field will not be r & r COURT REPORTERS 8!O N STREET, SUITE 1OI 509 W. 3RD AVENUE 277-0572 - 277-0573 277~8543 aNChORAGE, ALASKa 9950! 1007 W. 3RD AVENUE 272-75 ! 5 14 l? 24 19 changed by regarding them as pools or not. It's more of an accounting process now than it is a reservoir management tool in that the pools have become very unimportant. MR. CHATTERTON: Yeah. Is that because of different ownerships in the pools or ..... ? MR. GRUBERT: No, the ownerships are consistent throughout ..... MR. CHATTERTON: All the same? MR. GRUBERT: ..... the whole field. MR. CHATTERTON: Okay. MR. GRUBERT: Luckily. And it's more a matter that we are now recognizing that there is juxtaposition of some sands of a given pool against sands in a different pool, and that basically the pressures throughout the field move in concert in their decline. MR. CHATTERTON: Right. We -- we heard -- we've heard in -- in another matter, why, we've heard testimony given, it was not -- it was not -- it was not under oath, but that within the Hemlock zone, for example, why, cross flow between beds could occur. I presume you're going to have a different pressure existing in some of these sands from say what the over- lying Hemlock or middle Kenai. Do you expect that if a well were shut in, for example, or didn't have a high draw-down, that you would have cross flow? MR. GRUBERT: At the Trading Bay Field, that's a R & R COURT REPORTERS 81ON STREET, SUITE 10! 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 l0 17 2O 2! 22 23 24 2O relatively minimal consideration, because we do not have a very efficient water-flood system in that the water going into a given sand communicates to many different sands. And in a situation such as you're describing, if you truly do have segregation of a sand from another sand, that would be a significant problem in some cases. But here, since everything is basically at -- in the same system in that pressures can affect different sands, even though they were intended for one sand only, basically the whole field moves in -- in a pressurewise (sic) it moves together, and that we would not expect significant cross flow here. MR. GHATTERTON: If cross flow did occur, would you expect it to minimize the ultimate recovery? MR. GRUBERT: The only way that cross flow could really significantly reduce recovery would be if you had a very active emphasis on water flooding a given sand, and then subsequently started to develop some other sand, so that one body could be mainly water saturated due to your injection, and then you're exposing the oil to that water. That would be a negative situation. However, at the Trading Bay Field, we've worked, especially in the last three years, to concurrently develop all of the zones for this reason, and that the entire field zonewise should die together rather than complete development of a given zone and then begin another horizon. And that's a large factor R & R COURT REPORTERS 81ON STREET, SUITe 101 509W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, aLASKa 9950! 007 W. 3RD AVENUE 272-7515 10 14 16 17 !9 2O 2! 23 24 25 21 in that is to avoid that situation. MR. CHATTERTON: So actually, why, opening these sands below the Hemlock to production, why, probably is a good move, because you let it ..... MR. GRUBERT: That's true. MR. CHATTERTON: ..... pressures decline more uniformly. MR. GRUBERT: That's true. IF you were to complete just the Hemlock here and then ten years down the road open the West Foreland, which it then at that point should have a higher pressure, you might run into reservoir trouble with cross flow. MR. CHATTERTON: Thank you. Your application mentioned something about establishing pool rules for what I guess you were going to define as the West Forelands Pool, and -- and you -- for -- and you wanted those established for basically I guess to accomplish commingling. What about -- it's probably here, but I don't see it -- what -- what -- did you need also pool rules to establish spacing to ..... ? MR. GRUBERT: We would prefer to see pool rules allow unlimited spacing in the West Foreland right away, even though we do not have any current development going on, with the exception of this one well. So the -- the critical problem for us right now in terms R & R COURT REPORTERS 81ON STREET, SUITE 101 509W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANChORaGE, ALASKA 99501 007 W. 3RD AVENUE 272-7515 10 16 17 2O 2! 22 23 24 22 of timing is the commingling issue, and we definitely want to have that incorporated into any rule about the West Foreland. The spacing issue, it would be to our advantage to handle that now rather than to have to pursue it later. MR. CHATTERTON: Okay. MR. SRUBERT: We would like that to occur. MR. CHATTERTON: If the spacing, well spacing and commingling can be satisfactorily addressed by a means other than establishing pool rules, do you still need the designation of West Forelands Pool? MR. SRUBERT: No. We would continue to use that designation in our shop, ..... MR. CHATTERTON: All right. MR. SRUBERT: ..... but we would not need it. MR. CHATTERTON: All right. The sands beneath the Hemlock zone in the Trading Bay field appear to be equivalent to -- to those sands in the McArthur River field known as the -- and defined as the West Foreland sands, is that correct? MR. SRUBERT: Yes. MR. WARTHEN: Correct. MR. CHATTERTON: If we were to issue an order here that provided for the commingling of production from bearing sands occurring in the Trading Bay field beneath the Hemlock zone, and the only spacing requirement would be to stay at least 500 feet from the boundary of the unit, does that satisfy all of R & R COURT REPORTERS 810N STREET, SUITE IOI 509W. 3RD AVENUE 277-0572 - 277-0573 277-8543 aNChORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-7515 l0 12 13 14 16 17 20 2! 22 23 24 25 23 your needs? MR. KIES: Yes, it would. Yeah, it does. MR. WARTHEN: Mr. Chairman, was that 500 feet from the unit or 500 feet and/or 500 feet from different ownership? Well, regardless, we're -- that would be okay. That would be acceptable. MR. CHATTERTON: No, I think the unit -- the unit agreement governs pretty much -- I don't know whether you'll have to establish a participating area for this or ..... MR. WARTHEN: Well, we have no established unit here, so ..... MR. CHATTERTON: Oh, you don't have ..... MR. WARTHEN: No. MR. CHATTERTON: ..... an established ..... ? MR. WARTHEN: Not at Trading Bay field. But ..... MR. CHATTERTON: Then you'd ..... MR. WARTHEN: ..... there is ..... MR. CHATTERTON: ..... better not let ..... MR. WARTHEN: ..... a unit ..... MR. CHATTERTON: ..... me get away with your boundary. You'd better say property. MR. WARTHEN: Well, I was assuming the unit boundary to be the unit at North Trading Bay unit to the east. I thought perhaps that was what you were referencing to. And r & R COURT rEPorTers 810 N STREET, SUiTe I0! 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-7515 14 l? 19 2! 24 24 property ownership is owned by the same two parties well outside of this here accumulation. MR. CHATTERTON: Oh, I -- I know. Yeah. Well, from the lease boundary? MR. WARTHEN: That would be acceptable. MR. CHATTERTON: Would the same -- if I used that word singular, "lease," does that do it, or -- or do you need "leases"? I think you do, don't you? MR. WARTHEN: I think we ..... MR. GRUBERT: Leases, we ..... MR. WARTHEN: ..... need "leases". MR. GRUBERT: ..... need "leases". Yeah. MR. CHATTERTON: Yeah. Right. MR. GRUBERT: We need "leases". MR. WARTHEN: Right. MR. CHATTERTON: Okay. We can figure some way around that, can't we? MR. SMITH: I think so. MR. CHATTERTON: It's not Germane to this hearing, but this is an approach that was proposed on another matter this morning which seemed to meet with your approval. MR. WARTHEN: That's correct, sir. MR. CHATTERTON: Okay. Anything else? Anybody Got any more questions? MR. SMITH: No. r 8:r COURT reporters 81ON STREET, SUITE lO! 509W. 3RDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 9950! IOOTW. 3RD AVENUE 272-7515 14 17 2O 2! 24 25 25 MR. CHATTERTON: Anybody got any more to offer? MR. WARTHEN: For the record, Mr. Chairman, we do have a report here with the appropriate exhibits that were on display during the hearing today, and a text as well as a cover letter for your perusal. And I will provide those to Mr. Douglass. MR. CHATTERTON: Thank you, Bob, very much. Appreciate it. MR. WARTHEN: We have no further testimony, sir. MR. KIES: No further testimony. MR. CHATTERTON: Anyone from the staff have -- have any comments? MR. CRANDALL: The thing that's interesting to me about this is that over at North Trading Bay Unit, the -- the West Foreland over there is pretty fairly over-pressured. You don't see anything like that over in here now? MR. KIES: We thought we did initially, because we had so much trouble drilling through the West Foreland. It turns out that there's a fracture system immediately above the West Foreland in those clays before you get into the ..... MR. CRANDALL: Right. MR. KIES: ..... the Hemlock, so ..... MR. CRANDALL: Are (ph) you washed out from that? MR. KIES: Well, our drilling problems were primarily related to the -- the intense fracturing that occurred R & R COURT REPOrTErS 8~0 N STREET, SUITE TO! 509 W. 3RD AVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 1007 W. 3RD AVENUE 272-75 I 5 l0 14 16 17 19 2O 2! 22 23 24 26 in that clay stones. MR. CRANDALL: That's tough. MR. KIES: So we don't seem to have the same over-pressuring that we did at North Trading Bay field. MR. CRANDALL: This would be a good unit to drill a horizontal well, or at least a well parallel to the bedding plane then? MR. WARTHEN: They can ..... MR. CRANDALL: It's a good -- it's a good heavy crack (ph) in West Foreland. MR. KIES: That's -- that's why as -- as we go into this now that we know it's there, and we can tie it with the Hemlock production, we can design well pores that have a tail end that -- that if anything would be having a down the bedding plane orientation to accommodate that kind of completion. MR. CRANDALL: But you were able to establish that the -- the gradient in the West Forelands is something around .45 ..... MR. GRUBERT: Yes. MR. CRANDALL: MR. GRUBERT: ..... (indiscernible)? Um-hm. MR. KIES: Yes. MR. CHATTERTON: If there's nothing else to come before us, why thank you, gentlemen, very, very much, and we'll ad3ourn this hearing on -- at approximately 2:45 p.m. Thanks a R & R COURT REPORTERS 810 N STREET, SUITE 10! 509 W. 3RD aVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD AVENUe 272-7515 i0 l! 12 16 17 i9 20 2! 23 24 lot. MR. WARTHEN: Thank you. GRUBERT: Thank you. (END OF PROCEEDINGS) R & R COURT REPORTERS 810 N STREET, SUITE IO1 509 W. 3RD AVENUE 277-0572 - 277~O573 277-8543 ANCHORAGE, ALASKA 99501 007 W. 3RD aVENUE 272-7515 l0 12 14 15 16 17 18 20 2! 22 23 24 25 28 C E R T I F I C A T E UNITED STATES OF AMERICA ) ) ss STATE OF ALASKA ) I, Meredith L. Downing, Notary Public in and for the State of Alaska, residing at Anchorage, Alaska, and Electronic Reporter for R & R Court Reporters, Inc., do hereby certify: THAT the annexed and foregoing Public Hearing before the Alaska Oil and Gas Conservation Commission was taken before me on the 23rd day of April, 1990, commencing at the hour of 2:00 o'clock p.m., at the offices of the Alaska Oil and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska, pursuant to Notice. THAT the witnesses, before examination, were duly sworn to testify to the truth, the whole truth, and nothing but the truth; THAT this Transcript of Public Hearing, as heretofore annexed, is a true and correct transcription of the testimony given at said Public Hearing, taken by me and thereafter transcribed by me; THAT the original of the transcript has been lodged, as required, with the Alaska Oil and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska. THAT I am not a relative, employee or attorney of any of the parties, nor am I financially interested in this action. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal this 15th day of May, 1990. Not~ ~ubiic in an~--f~aska My Commission Expires: .. 5/3/9.4 SEAL R & R COURT REPORTERS 810 n STREET, SUITE IO! 509W. 3rDAVENUE 277-0572 - 277-0573 277-8543 ANCHORAGE, aLASKA 99501 1 O07 W. 3RD AVENUE 272-75 ! 5 ... Unocal Oil & Ga~( sion Unocal Corporatioh P.O. Box 190247 Anchorage, Alaska 99519-0247 Telephone (907) 276-7600 UNO I L April 23, 1990 Robert T. Anderson Manager, Lands Alaska Region Mr. Chat Chatterton Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 TRADING BAY FIELD State of Alaska Application for Commingling Order for the West Foreland Pool Dear Mr. Chatterton: Union Oil Company of California (Unocal), as Operator of the Trading Bay Unit, and on behalf of the Working Interest Owners, requests an order to establish the commingling of production of those oil bearing sands which underlie the Trading Bay Field; Hemlock Oil Pool with production from other defined oil pools in the Field. The West Foreland Pool Definition' From 9079' to 9857' (drilled depth) Please find attached an engineering and geologic report that provides supporting information for the commingling of the West Foreland Pool with other zones in the Trading Bay Field. It is requested that the attachments hereto be held confidential. Personnel from Unocal and Marathon, as Operator and sub-Operator respectively in the Trading Bay Unit, are available to meet with you concerning any questions you may have or additional data you may require. Pursuant to the aforementioned commingling of the West Foreland Pool with other zones, we respectfully request administrative approval to commingle this pool as defined. RAP:rms Attachment Very truly yo~qrs, ,:;;','''' Robert A. Province Landman R"ECEI'VED EXHIBIT A GEOLOGIC AND ENGINEERING REPORT The stratigraphy of the Trading Bay Field area is comprised of several hundred feet of Recent and Quaternary fluvio-glacial gravels and clays that are underlain by 7000'-10,000' of nonmarine Tertiary sediments. These Tertiary sediments, which belong to the Kenai Group and West Foreland Formation are comprised of often regionally discontinuous units of sandstone, conglomerate, coal, siltstone, and claystone. Unconformably, underlying the Tertiary sediments, is an unknown thickness of Lower Ourassic Talkeetna Formation volcanics and volcaniclastics. The West Foreland 0il Pool of the West Foreland Formation, Eocene in age, occurs unconformably below the Hemlock Oil Pool. The West Foreland Oil Pool is composed of clayey and silty sands, pebbly sands, and conglomerate, interbedded with siltstone and minor coals. This unit is characteristically tuffaceous. The sands vary in continuity through the structure due to changing lithology and pinchout. Exhibit IV, the type log, and Exhibit III, a stratigraphic section, show the lithologic variability throughout the unit. The structure of the Trading Bay Field area is characterized by east-west compression, north-south extension, and right lateral strike-slip faulting. Two major near-vertical strike-slip faults cross the mapped area from south-southwest to north-northeast. The most documented of these is the Trading Bay Fault, although it is difficult to determine the extent of lateral movement. The sense of movement ls belleved to be rlght lateral, largely based on theoretical rock mechanics, considering the maxlmum compressional direction appears to be east-west. Also, correlations across the Tradlng Bay Fault from Trading Bay Field to the Northwest Feature of McArthur Rlver Field to the south are often better than correlations straight across the fault. This also supports right lateral movement. In the Trading Bay Field there is a high-angle reverse component of motion to the Trading Bay Fault that is probably more apparent movement than actual and is due to juxtaposition of the Trading Bay anticline next to a structural low on the east side of the fault. Consequently, the fault has often been referred to as a thrust fault. To the north near the Spurr Platform, the reverse sense of movement diminishes to nearly zero, and actually changes to normal throw in the upper part of the section. To the south on the Northwest Feature of McArthur River Field the throw is about half that seen in the Trading Bay Field area. The Trading Bay Subthrust Block is a wedge-shaped, proven-productive fault block situated beneath and east of the Trading Bay Fault and on the upthrown (west) side of the near-vertical Texaco Fault (Exhibits I and II). Both the Trading Bay and Texaco Faults are high-angle, up to the west reverse faults, with approximately 1000'-2400' of vertical uplift of the Trading Bay Fault and 200'-800' of vertical uplift on the Texaco Fault. The boundaries of the Subthrust Fault Block are controlled by fault plane maps of the Trading Bay and Texaco Faults. Numerous cross faults exist in the block. . Dips in the Trading Bay Subthrust Fault Block range from 30 to 65 degrees to the east and southeast, as interpreted from dipmeter dips, Formation Microscanner (FNS), and structural mapping. This steep easterly to southeasterly dip forms the south boundary of the Subthrust Block oil accumulations. The A-28RD well was the first well to establish oil production in the Nest Foreland in Trading Bay Field. The overall producing interval in the Nest Foreland in this well is 9392' MD to 9668' MD. ENGINEERING The West Foreland Zone at the Trading Bay Field has been put on production in A-28RD. This is the first time the formation has been produced in the field with the exception of DSTs performed during early development. This initial completion will most likely yield additional West Foreland development. The zone has never been defined in the Trading Bay Field, It is requested that no limitation be placed on well spacing for this zone, and that commingling with any other productive zone be allowed in order to maximize oil recovery and prolong the productive life of the field. Although little data exists relative to long term performance of the Nest Foreland, it is clear that the zone is not overpressured, and that no adversely high gas ratios exist in the A-28RD wellbore. Thus, no problems with commingling should be experienced. It is proposed to allow the A and West Foreland Zones to be commingled with oil production from any other zone on the Monopod at Trading Bay Field. This circumstance is already in effect for the B, C, D, E and Hemlock Zones at Trading Bay Field. Given that: 1. Trading Bay Field is in a late stage of development. 2. All zones still have development potential. Flexibility of well completions must be afforded to maximize longterm well utility. 4. Investment must be minimized to continue development of the Trading Bay Field Monopod Platform. Ownership of produced oil and gas in all pools on all subject acreage will not be affected by commingling production. It appears that commingled oil production would increase ultimate field recovery. 1. Commingled production extends expected life and usefulness of producers by: e a. eliminating the risk of losing one production string for mechanical reasons in a dual string noncommingled completion; b. allowing through-tubing profile modifications and stimulation of all zones completed with a single string; c. allowing for coiled tubing cleanouts of all intervals completed with a single string; d. gaining these benefits without being forced to drill two single string producers; and e. eliminating abandonment of productive sands during well recompletions when shifting emphasis to a new zone. 2. A single string completion allows for wireline production profiles to be run across all zones: a. estimates of production volume breakdowns for individual sands in multiple zones is no less accurate in a commingled producer than would be similar estimates for a single string zone producer. Gas lifting a single tubing string vs. two strings should increase production rates by allowing optimization of gas lift valve settings. Summary of Benefits With single string commingled zone completions: - No compromise would be made as to data on individual sand production. Well life and thus ultimate field recovery would be increased by eliminating potential for future mechanical problems. Existing productive intervals would not have to be permanently abandoned when new zones are added. Remedial well work is afforded to all subject intervals, thus increasing well life and ultimate recovery. Lowered investment allows marginal projects to be implemented and the recovery of otherwise excluded reserves. Increased well life and recovery extends the viable life of the Monopod, increasing the chance for new development to take place. Ownership interests for the subject property will not be affected in any case by commingling. 5 /-'r =~ ~-7'- /I Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: UNOCAL application to commingle production of those oil bearing sands which underlie the Trading Bay Field, Hemlock Oil Pool. UNOCAL in correspondence dated March 21, 1990 has applied for an order allowing commingled production of those oil bearing sands whi.ch underlie the Trading Bay Field, Hemlock Oil Pool with production from other defined oil pools in the field. A hearing on the matter will be held at the Alaska Oil and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska 99501, at 2:00 pm on April 23, 1990 in conformance with AS 31.05.100(a). Lonnie C. Smith Commi s s ioner Alaska Oil & Gas Conservation Commission Published March 23, 1990 Robert T. Anderson Manager, Lands Alaska Region Unocal 011 & Ga~ ,sion Unocal Corporatior,' P.O. Box 190247 Anchorage, Alaska 99519-0247 Telephone (907) 276-7600 UNOCAL March 21, 1990 Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Attn: Chat Chatterton Dea.r Mr..Chatterton: ~ ,, ~,:~ ', TRADING BAY FIELD State of Alaska Application for the Establishment of Pool Rules and Commingling Order for the West Foreland Pool Union Oil Company of California hereby makes application for the establishment of pool rules and spacing order for the West Foreland Pool, Trading Bay Field. An order for the commingling of the West Foreland Pool with other zones in the Trading Bay Field will increase ultimate recovery rates, thereby extending the economic unit of the Field without sacrificing data quality, operational safety or environmental goals. Your favorable consideration of this application is respectfully requested. Union will submit its recommendation for pool rules in the near future prior to the Public Hearing. Very truly yours, Robert A. Province Landman RAP:rms