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INDEX CONSERVATION ORDER NO. 343
1.) September 9, 1994 BP Exploration Alaska, Inc. Request for Spacing Exception
2.) September 28, 1994 Notice of Public Hearing, Affidavit of Publication
Conservation Order No. 343
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
3001 Porcupine Drive
Anchorage Alaska 99501-3192
Re: THE APPLICATION OF BP Exploration )
(Alaska) Inc. for an order exempting )
the Niakuk oil pool from the requirements )
of 20 AAC 25.280 )
Conservation Order No. 343
Niakuk Field
Niakuk Oil Pool
November 2, 1994
IT APPEARING THAT:
BP Exploration (Alaska) Inc., operator of the Niakuk Field, submitted an application
on September 9, 1994 requesting exemption from the requirements of 20 AAC
25.280(a) and (b) for all wells in the Niakuk oil pool.
2. Notice of public hearing was published in the Anchorage Daily News on September
28, 1994.
3. No protests to the application were filed with the commission.
FINDINGS:
o
Operators must file an Application for Sundry Approvals (Form 10-403) and receive
commission approval prior to performing well workovers (i.e., perforating or
reperforating casing, well stimulation, pulling tubing, altering casing, and repairing
wells). 20 AAC 25.280(a).
2. Current well activity on the North Slope is dominated by the types of workover
operations set forth in 20 AAC 25.280(a).
3. Wells in adjacent pools are drilled and completed similar to those in the Niakuk oil
pool.
4. BP Exploration (Alaska) Inc., as a principle North Slope operator, routinely conducts
well workover operations in wells within and adjacent to the Niakuk oil pool.
5. BPX's procedures for well workovers have become standard and routine for wells
within and adjacent to the Niakuk oil pool (e.g. Prudhoe Bay Field).
o
Information regarding the well condition, well workover program, bottom-hole
pressure and well control program must be submitted with an Application for Sundry
Approval. 20 AAC 25.280(b).
Conservation Order 34j
Page 2
November 2, 1994
.
The operator must submit a Well Completion or Recompletion Report and Log (Form
10-407) within 30 days after completing a well. 20 AAC 25.070. Most of the
information (name, location, condition, downhole equipment, etc.) required with the
Application for Sundry Approvals for workovers also appears on Form 10-407.
.
The operator must maintain records and reports of well workovers for at least five
years. 20 AAC 25.280(c) and 20 AAC 25.070. The operator must submit a complete
well record, with copy of daily reports and tests, after completing well workovers on a
Report of Sundry Well Operations (Form 10-404). 20 AAC 25. 280(d).
9. Conservation Order 329, Rule 8, requires periodic bottom hole pressure surveys in the
Niakuk oil pool.
10. Well workovers under 20 AAC 25.280 on development wells do not prompt additional
requirements beyond the criteria imposed by regulation.
11. The commission has primacy for all Class II injection wells in the state.
12. Well workover operations on injection wells sometime prompt additional requirements
such as mechanical integrity tests.
13. Commission inspectors routinely inspect drilling and well workover operations to
ensure compliance with regulations.
CONCLUSIONS:
.
BP Exploration (Alaska) Inc. is likely to perform well workover operations in Niakuk
oil field wells in much the same manner as it has in adjacent established fields. Those
operations have become standard and routine.
2. BPX's record of performance shows a long history of safe and responsible well
workover operations.
o
Eliminating the requirements of 20 AAC 25.280(a) and (b) for all development wells in
the Niakuk oil pool will reduce filing and result in administrative efficiencies for both
the operator and the AOGCC.
4. Eliminating the requirements of 20 AAC 25.280(a) and (b) for all development wells in
the Niakuk oil pool will not promote waste nor jeopardize correlative fights.
o
In order to administer the Class II UIC program, Form 10-403 must still be required
prior to workovers on all service wells (i.e., gas injection, water injection, waste
injection).
Conservation Order 34~
Page 3
November 2, 1994
6. Subsequent report of workover operations (Form 10-404) must still be filed with the
commission in order to keep well files current.
7. A current schedule of upcoming workover operations is necessary for the commission
to exercise its compliance responsibilities.
NOW, THEREFORE IT IS ORDERED THAT'
Rule 1
The requirements of 20 AAC 25.280(a) are hereby waived for all producible wells (i.e.,
development wells) in the Niakuk oil pool.
Rule 2
The operator of Niakuk oil pool shall provide the commission with a schedule of planned
workover operations including the well and intended operation on a weekly basis.
DONE at Anchorage,
David W. ({ohnston, Cha~rna~ -
Alaska Oil ~,~s Conse~ation Commission
Russell A. Douglass,
Alaska Oil and Gas Conservation Commission
Thckerman Babcock, Commissioner
Alaska Oil and Gas Conservation Commission
AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the
Commission an application for rehearing. A request for rehearing must be received by 4:30 p.m. on the 23rd day following the date of the
order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application in whole or in
part within 10 days. The Commission can refuse an application by not acting on it within the 10-day period. An affected person has 30
days from the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing, both being the final
order of the Commission, to appeal the decision to Superior Court. Where a request for rehearing is denied by nonaction of the
Commission, the 30 day period for appeal to Superior Court runs from the date on which the request is deemed denied (i.e., 10th day after
the application for rehearing was filed).
9608
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AFFIDAVIT OF PUBLICATION
STATE OF ALASKA )
THLRD JUDICIAL DISTRICT )
SS.
Eva M Kaufmann being first duly
sworn on oath deposes and says
that she is the Advertising
Representative of the Anchorage
Daily News, a daily newspaper.
That said newspaper has been
approved by the Third Judicial
Court, Anchorage, Alaska, and it
now and has been published in the
English language continually as a
daily newspaper in Anchorage,
Alaska, and it is now and during all
said time was printed in an office
maintained at the aforesaid place of
publication of said newspaper.
That the annexed is a copy of an
advertisement as it was published
in regular issues (and not in
supplemental form) of said
newspaper on:
September 28
,1994
and that such newspaper was
regularly distributed to its
subscribers during all of said
period. That the full amount of the
fee charged for the foregoing
publication is not in excess of the
rate charged private individuals.
signed~-G-~%~~''
Eva M. Kaufmann kD
Classified Advertising Rep.
257-4296
Subscribed and swom to
before me this ..~r~... day of
the State of Alaska.
Third Division
Anchorage, Alaska
MY COMMISSION EXPIRES:
My Commission Expires:
.......... 2,~t.?. r. j.4: .?Z ....... 19 ......
- Notice o! 'F;ublic Nearing
STATE OF ALASKA
Alaska Oil and Gas,
Conservation CommissiOn
:'Re: 'The application of ,BP
"Exploration (Alaska). inc. for
:xception to 20 AAC 25.280 for
7the. Niakuk unit/Prudhoe~' Bay
,Field, Nlak0k oll pool'.--
?.BP'Exploraton (Alaska) i
' Inc. has requested an excep-
tl0n to the provisions .of 20i
;AAC 25.280' (a) and (b). The l
exception .would eliminate the[
. ~rne.q,.,ulrementi.'f0r filing a form
.1',,-.~403 '(APPlication for Sundry
Approvals). prior.tO Initiating
, ;~iffaltt WOrKoyer operations on
Wells In the. NlakUk oll..poo"of
the Nlakuk"Unlt/Prudboe Bay
.Fleld~. '~ i' ":~ ....
. '.'A 'person'who ma~ be 'harm-
;.ed if .the 'requested.:~.order is
'isSued :may.file' a'. wrlffen pro.
..test. prlor'.:'to 4~00..'PNt"O:ctober
'. 13';; ]994 'w th: th~'. Alaska. O
.'and'~ :.Gas. i;C;on'serv'atiOn ~¢om-
',,m:lsslon~ 3~1 'P~rc'jpl-.e Drive
.'Afichor~ge. Alaska 9~$fl e""
..r~queSt' a 'ear qp, or '.~o
i tar.. If .the. '.pro~est'. m. t me~y
' f$1ed, arid .: ra'iseg a '~Ub'Stantia
]'.'"a~d ...mite'riga .~lss~e,'~': cr~u~la!,','t'd
I 'tti~ 'c0'mmls$10n's"d~mrmma.
: tlon, a hearing on the matter
,will be held at the above ad-
'1 dress at 9:00 am on November
· 2, ~994 in conformance with 20
AAC 25.540. If a hearing is to
be held, interested parties may
I confirm this by calling the
Commission's office (907)
I 2794433 after 'O<~tobe~ ~13, ~994
· If 'no protest' Is filed, the Com-
mission will consider 'the Issu-
ance of the order without a
hearing.
/s/Russell A. Douglass,
Commissloner, Alaska Oil
and Gas Conservation
· Commission
I
~ Pub: September 28, 1994
Notice of Public Hearing
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re:
The application of B P Exploration (Alaska) Inc. for exception to
20 AAC 25.280 for the Niakuk Unit/Prudhoe Bay Field, Niakuk oil pool.
B P Exploration (Alaska) Inc. has requested an exception, to the provisions
of 20 AAC 25.280 (a) and (b). The exception would eliminate the requirement for
filing a form 10-403 (Application for Sundry Approvals) prior to initiating certain
workover operations on wells in the Niakuk oil pool of the Niakuk Unit/Prudhoe
Bay Field.
A person who may be harmed if the requested order is issued may file a
written, protest prior to 4:00 pm October 13, 1994 with the Alaska Oil and Gas
Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska 99501., and
request a hearing on the matter. If the protest is timely filed and raises a
substantial and material issue crucial to the Commission's determination, a hearing
on the matter will. be hel. d at the above address at 9:00 am on November 2, 1994 in
conformance with. 20 AAC 25.540. If a hearing is to be held, interested parties
may confirm this by calling the commission's office, (907) 279-1.433 after
October 1.3, 1994. If no protest is filed, the Commission will consider the issuance
of the order without a hearing.
Russell A. Douglass ~'
Commissioner
Alaska Oil and Gas Conservation Commission
Published September 28, 1994
BP EXPLORATION
ARCO Alaska, Inc.
David W. Johnston, Chairman
Alaska Oil and Gas Conservation Commission
3001 Porcupine Drive
Anchorage, Alaska 99501-3192
Re: Application for Exception to 20 AAC 25.280(a) and (b)
Dear Mr. Johnston,
BP Exploration (Alaska) Inc., operator of the Niakuk Unit, request an exemption
of 20 AAC 25.280(a) and (b) for all wells in the Niakuk Pool lying within the
Prudhoe Bay Field/Niakuk Oil Pool.
20 AAC 25.280(a) requires the operators to file an Application for Sundry
Approvals (Form 10-403) and receive Commission approval prior to performing
well workovers. 20 AAC 25.280(b) stipulates what information must be
submitted on or with Form 10-403. The workover operations covered by this
regulation include: 1) perforating or reperforating casing; 2) stimulations; 3)
pulling tubing; 4) altering casing; and 5) repairing the well. These workover
operations have been performed many times and have become routine and
standardized. The information required for the Application for the Sundry
Approval has become repetitive.
It is the intent of BP Exploration to continue reporting the results of well
workover operations by filing a Report of Sundry Well Operations (Form 10-404)
as required by 20 AAC 25.280(d). It is also our intent to keep all records and
reports of well workover and repair operations in conformance with 20 AAC
25.280(c).
Sincerely,
Steve Horton
Prudhoe Bay Drilling Manager
BP Exploration (Alaska)Inc.
Post Office Box 196612
Anchorage, Alaska 99519-6612
Telephone (907) 561-5111
Co-Operators, Prudhoe Bay Unit
Gas Cons. Commissi0~
Anchorage
ARCO Alaska, Inc.
Post Office Box 100360
Anchorage, Alaska 99510-0360
Telephone (907) 276-1215