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INDEX CONSERVATION ORDER NO. 482
SWANSON RIVER FIELD
SRU 213-10
1. August 7, 2002
Unocal's request for Tubingless Completions
SRU 213-10
2. August 17, 2002
Notice of hearing, Affidavit of publication, bulk mailing
list for the Anchorage Daily News
3. September 16, 2002 E-mail from Jim re: Unocal
4. September 19, 2002 Sign in Sheet
o
September 25, 2002 Unocal's letter to CC's regarding non-participating in the
hearing.
6. September 19, 2002 Transcript
o
December 20, 2002 Letter from CC's to Unocal Denying Request due to
unresponsiveness from Operator Unocal
Conservation Order 482
Title 43
NATURAL RESOURCES
Part XIX. Office of Conservation' General Operations
Subpart 11. Statewide Order No. 29-J
Chapter 27. Tubingless Completions
§2701. Scope
This Order provides rules and regulations governing
unprotested applications in the use of tubingless completions
in the state of Louisiana.
AUTHORITY NOTE: Promulgated in accordance with
R.S.30:4 et seq.
HISTORICAL NOTE: Adopted by the Department of
Conservation, March 1, 1961, amended May 1, 1963, amended and
promulgated by the Department of Natural Resources, Office of
Conservation, LR 19:777 (June 1993).
§2703. Definitions
Unless the context otherwise requires, the words defined
in this Section shall have the following meanings when
found in this Order.
District Manager, the head of any one of the districts of
the state of Louisiana under the Office of Conservation, and,
as used, refers specifically to the manager within whose
district the field or fields are located.
Office. the Office of Conservation of the state of
Louisiana.
Tubingless Completion' the completion of any well so
as to permit the passage of production fi.om one separate
underground source through one production casing set in the
well.
AUTHORITY NOTE: Promulgated in accordance with
R.S.30:4 et seq.
HISTORICAL NOTE: Adopted by the Department of
Conservation, March 1, 1961, amended May 1, 1963, amended and
promulgated by the Department of Natural Resources, Office of
Conservation, LR 19:777 (June 1993).
§2705. Order
A. From and after the effective date hereof, permission to
complete and produce wells without the use of tubing may
be obtained fi.om the district manager without the necessity
of a public hearing in the absence of protests, and upon strict
compliance with the procedure set forth herein.
g. No permission to complete and produce wells without
the use of tubing will be granted without a public hearing
unless and until the data and information required by the
district manager shall have been filed in his office; said
filings to be made in duplicate and to include the following
information:
APPLICATION FOR TUBINGLESS COMPLETION
IN THE FIELD.
Date: Serial No.:
Field Name: Parish: Dept. Dist:
Operator: Lease: Well No.:
1. This application is for:a. A proposed well
b. A well now being drilled
c. A well now drilled to total depth
2. The following facts are submitted:
a. Name of reservoir:
b. Approximate top of pay section:
c. Approximate bottom of pay section:
d. Approximate perforations:
e. Type of production (oil or gas):
f. Reservoir pressure: ~ psig at
feet subsea.
g. Reservoir pressure gradient: psi per foot
(from above).
h. Anticipated method of production following initial
completion (flowing or artificial lift):
1. Electric Log does not indicate any commercial
productive sand above proposed top of cement.
3. The following are attached:
a. Diagrammatic sketch of proposed tubingless completion
installation.
b. Plat showing location of well.
4. Has the district manager of the Office of Conservation granted tubiagless
completion in this field prior to this application? __
5. Does all geological and engineering data now available indicate that this
well and/or pool contains limited reserves to the extent that a normal
completion is not feasible from the standpoint of economics?
6. List all other operators in the field where this well is located together
with correct mailing address of each and evidence that each such
operator has approved the tubingless completion applied for:
7. Is the fluid to be produced conducive to corrosion to the extent that any
resulting corrosion will destroy the effective seal of the production casing
during the producing life of this well'?
71 Louisiana Administrative Code September 1999
NATURAL RESOURCES
8. If the answer to Item 7 above is Yes, what steps are proposed to combat
or circumvent this corrosion problem?
Date Approved: __
By
Operator
District Manager
CERTIFICATE
This is to certify that, to the best of my knowledge and belief, the
information contained in this application is true and correct.
Signed
Title
Representing
Form-T.C.-1
C. If an applicant for a tubingless completion installation
is unable to obtain the approval of all of the other operators
in the field then such an applicant must apply for a public
hearing following the usual 10-day advertisement period
after furnishing a list of all known parties, including
operators and royalty owners, affected by the application, all
in accordance with Title 30 of the Louisiana Revised
Statutes of 1950, as amended.
D. All approved applications shall be subject to the
applicant's conforming with the following requirements:
1. Conductor Pipe. The use and removal of conductor
pipe during the drilling of any oil or gas well shall be at the
option of the operator. Conductor pipe is that pipe ordinarily
used for the purpose of supporting unconsolidated surface
deposits.
2. Surface and Intermediate Casing. All fresh water
sands shall be cased off by the surface or first intermediate
casing in accordance with provisions of Part XIX, Subpart 1.
3. Producing Oil String
a. Producing or oil string is that casing used for the
purpose of segregating the horizon from which production is
obtained and affording a means of communication between
such horizon and the surface.
b. The producing string of casing shall consist of
new or reconditioned casing tested at mill tent pressure or at
1.25 times the maximum anticipated bottomhole pressure,
whichever is greater. The producing string of casing shall be
set at a sufficient depth to cut off all gas formations above
the oil-saturated horizon in which the well is to be
completed. The position of the oil horizon shall be
determined by coring, testing or electrical logging, or other
satisfactory method, and the producing string of casing shall
be bottomed and cemented at a point below the gas/oil
contact, if determinable and practicable. The producing
string of casing shall be of sufficient size and completed
with the proper amount of tension so as to allow the running
of conventional bottomhole pressure bombs, temperature
survey units and all instruments of similar nature to the
depth of the producing horizon.
c. Cement shall be by the pump and plug method,
or another method approved by the office. Sufficient cement
shall be used to fill the calculated annular space behind the
casing to such a point as, in the opinion of the district
manager, local conditions require to protect the producing
formations and all other oil and gas formations occurring
above, but in every case, no less cement shall be used than
the calculated amount necessary to fill the annular space to a
point 500 feet above the top producing zone. The calculated
amount of cement required shall be determined by a hole
caliper survey or 1.5 times the theoretical volume required to
fill this annular area.
d. The amount of cement to be left remaining in the
casing, until the requirements of §2705.D.3.e below have
been met, shall be not less than 20 feet. This shall be
accomplished through the use of a float collar or other
approved or practicable means, unless a full-hole cementer,
or its equivalent, is used.
e. Cement shall be allowed to stand a minimum of
12 hours under pressure and a minimum total of 24 hours
before initiating test or drilling plug in the producing or oil
string. Under pressure is complied with if one or more float
valves are employed and are shown to be holding the cement
in place, or when other means of holding pressure are used.
When an operator elects to perforate and squeeze or to
cement around the shoe, he may proceed with such work
after 12 hours have elapsed after placing the first cement.
fi Before drilling the plug in the producing string of
casing in wells drilled to 3,000 feet or less, the casing shall
be tested with a pressure equivalent to 1,500 psi surface
pressure applied with water in the casing, and in wells
drilled deeper than 3,000 feet, the casing shall be tested with
a pressure equivalent to 3,000 psi surface pressure applied
with water in the casing. If, at the end of 30 minutes, the
pressure gauge shows a drop of 10 percent of the test
pressure or more, the operator shall be required to take such
corrective measures as will insure that the producing string
of casing is so set and cemented that it will hold said
pressure for 30 minutes without a drop of more than 10
percent of the test pressure on the gauge.
g. If the commissioner's agent is not present at the
time designated by the operator for inspection of the casing
tests of the producing string, the operator shall have such
tests witnessed, preferably by an offset operator. An affidavit
of the test, on the form prescribed by the Office of
Conservation, signed by the operator and witness, shall be
furnished to the district office of the Office of Conservation
shown that the test conformed satisfactorily to the above
mentioned regulations before proceeding with the
completion. If test is satisfactory, normal operations may be
resumed immediately.
h. If the test is unsatisfactory, the operator shall not
proceed with the completion of the well until a satisfactory
test has been obtained.
i. A temperature survey shall be run in the
producing string prior to perforating if returns were lost
Louisiana Administrative Code September 1999 72
Title 43, Part XIX
during cementing or unusual circumstances were noted
during the primary cementing operation to assure all
interested parties that the cement has been displaced a
sufficient height outside the producing casing.
j. If a kill string is recommended by the district
manager for the prevention of underground waste and the
operator does not concur, such requirement pertaining to the
installation of a kill string shall be resolved by the
conservation commissioner and his staff after due
consideration and review. The conservation commissioner
and his staff shall also determine the minimum setting depth,
size, and quality of the kill string, if required.
k. No permit to make a tubingless completion in a
corrosive or extreme pressure (gradient in excess of .5 psi
per foot of depth or surface tubing pressure in excess of
4,500 psig) field shall be granted unless preventive measures
for the corrosion or extreme pressure problems have been
resolved and approved by the district manager.
E. This Order shall be cumulative of and in addition to
all Statewide Orders, rules and regulations affecting the
drilling and production of gas and/or liquid hydrocarbons
heretofore promulgated, and when anything in this Order is
in conflict therewith, then the provisions of this Order shall
govern. In case of conflict between this Order and any
special orders issued on specific fields, said special orders
on specific fields shall govern.
AUTHORITY NOTE: Promulgated in accordance with
R.S.30:4 et seq.
HISTORICAL NOTE: Adopted by the Department of
Conservation March 1, 1961, amended May 1, 1963, amended and
promulgated by the Department of Natural Resources, Office of
Conservation, LR 19:777 (June 1993).
73 Louisiana Administrative Code September 1999
ALASKA OIL AND GAS
CONSERVATION COHHISSION
FRANK H. MURKOWSKI, GOVERNOR
333 W. 7TM AVENUE, SUITE 100
ANCHORAGE, ALASKA 99501-3539
PHONE (907) 279-1433
FAX (907) 276-7542
Jim Mosley
Unocal Alaska
Union Oil Company of Califomia
P.O. Box 196247
Anchorage, AK 99519-6247
December 20, 2002
Re:
Application for Conservation Order allowing tubingless
and packerless well completions in the Swanson River Field
Dear Mr. Mosley:
By letter dated August 7, 2002, unocal Alaska, as operator of the Swanson River Field,
requested authorization to complete newly drilled wells without a tubing and packer as
required by 20 AAC 25.200(d). On September 16, 2002, the Alaska Oil and Gas Conser-
vation Commission ("Commission") requested additional information from Unocal'
Alaska in support of the application. Unocal did not appear at the hearing on September
19, 2002, and never responded to the Commission's request for additional information.
Based on the absence of information before the Commission, Unocal's August 7, 2002
request is denied, If Unocal chooses to renew this request in the future, please provide
the additional information requested by the Commission's September 16, 2002 letter.
Sincerely,
,
Cammy Oechsli Taylor
Chair
#6
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STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7th Avenue, Suite 100
Anchorage, Alaska 99501
PUBLIC HEARING
In Re: )
)
Unocal's application for an order )
allowing completion of newly drilled )
wells without a tubing and packer for )
those wells in the Swanson River Field. )
)
RECEIVED
Alaska O~l & G~s Co~$, C~~
Ar~ora:je
TRANSCRIPT OF PROCEEDINGS
Anchorage, Alaska
September 19, 2002
9:05 o'clock a.m.
COMMISSIONERS:
MS. CAMMY O. TAYLOR, CHAIR
MR. DANIEL T. SEAMOUNT
METRO COURT REPORTING,INC.
745 West 4th Avenue, Suite 425
Anchorage, Alaska 995021
(907) 276-3876
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P R O C E E D I N G S
(On record)
COMMISSIONER TAYLOR: Today is Thursday, September
19th, 2002. The time is approximately 9:05. We're at the
offices of the Alaska Oil and Gas Conservation Commission, at
333 West Seventh Avenue. The subject of today's hearing is
Unocal's application for an order allowing completion of newly
drilled wells without a tubing and packer for those wells in
the Swanson River Field. My name is Cammy Taylor, and to my
right is Commissioner Dan Seamount. From Metro Court Reporting
is Desiree Disotell. Did I pronounce that correctly?
COURT REPORTER: That's correct.
COMMISSIONER TAYLOR: These proceedings are being
recorded and transcribed. And if anybody in the audience would
like a copy of the transcript, they can make that request
directly of Metro Court Reporting. However, since I'm looking
out at the audience, neither the applicant or any other parties
outside of the Oil and Gas Conservation Commission are present.
There is an e-mail in the record provided to us by Jim
Rigg (ph), who contacted the applicant, Jim Mosley, with some
additional written questions for this hearing. And when he
contacted him he was advised that Mr. Mosley would be on
vacation. Unocal has not sent anybody else in his place, and
Jim Rigg reflects that they need some additional time to
respond to these questions.
METRO COURT REPORTING, INC.
745 West 4th Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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So, my recommendation is that we leave the record open
for 30 days to allow Unocal to respond to these questions, and
then we can issue a written decision if all the answers are
provided in writing by Unocal.
Do you have any preference or concerns about doing
that, leaving it open for 30 days?
COMMISSIONER SEAMOUNT: Sounds fine with me. And I
will hold any of my questions until I see Unocal's response in
the next few weeks.
COMMISSIONER TAYLOR: With that, we'll leave the record
open for Unocal to respond to the written questions from the
Commission for 30 days from today. And we'll close the hearing
record -- close the hearing today.
(Off record)
END OF PROCEEDINGS
METRO COURT REPORTING, INC.
745 West 4th Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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C E R T I F I C A T E
UNITED STATES OF AMERICA )
) SS.
STATE OF ALASKA )
I, Cari Ann Ketterling, Notary Public in and for the
State of Alaska, and Reporter for Metro Court Reporting, do
hereby certify:
That the foregoing Alaska Oil & Gas Conservation
Commission Public Hearing was taken before Desiree Disotell on
the 19th day of September 2002, commencing at the hour of 9:05
o'clock a.m., at the offices of the Alaska Oil & Gas
Conservation Commission, 333 West Seventh Avenue, Suite 100,
Anchorage, Alaska;
That the meeting was transcribed by me to the best of
my knowledge and ability.
IN WITNESS WHEREOF, I have hereto set my hand and
affixed my seal this 3rd day of October, 2002.
Cari Ann Kette ~s///ka
Notary Public in and for
.My commission expires: 07/19/04
METRO COURT REPORTING, INC.
745 West 4th Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
#5
Unocal Alaska
Union Oil Company of California
P.O. Box 196247
Anchorage, AK 99519-6247
Telephone (907) 276-7600
UNOCAL )
" Alaska
James R. Harrison
Drilling Manager
September 25, 2002
Alaska Oil and Gas Conservation Commission
333 West 7th Avenue
Anchorage, Alaska 99501
Attn: Commissioner CammyTaylor
Re:
Swanson River and Soldotna River Unit
Tubingless Packer Waiver Hearing
Commissioner Taylor:
Union Oil Company of California, dba Unocal would like to thank the AOGCC for its
cooperation in the review of tubingless and packerless completions for the Swanson
River Field and apologize for any miscommunications on our part. Jim Mosley, the
Unocal drilling engineer assigned to this project and Jim Harrison the Unocal Drilling
Manager are currently out of the country and scheduled to return the first week of
October. Upon their return Unocal will address the request for additional information
made by Jim Rigg and if necessary reschedule the Public hearing that was originally
scheduled for September 19, 2002,
If there are any questions, please contact Leo Phelps at 263-7948. We appreciate your
help and consideration on this matter
(...-" Jim Harris6n
Drilling Manager
Cc: Jim Harrison
Jim Mosley
SEP
#4
STATE OF ALASKA
OIL AND GAS CONSERVATION COMMISSION
SWANSON RIVER UNIT AND SOLDOTNA CREEK UNIT
TUBINGLESS COMPLETIONS
September 19, 2002 at 9:00 am
NAME - AFFILIATION
(PLEASE~~~PRI~
ADDRESS/PHONE NUMBER
TESTIFY (Yes or No)
#3
Unocal Request for CO - Tubingless Completions at Swanson River Field
Subject: Unocal Rvque4t for CO - Tubingless Completions at swanson River Field
Date: M0n, 16 Sep/2fl02 13:06:47-0800
From: Jin~,~mLregg~admin. state.ak.us~
Organization: AOGCE-
To: Cammy Taylor <cammy_taylor~admin. state.ak.us>,
Dan Seamount <dan_seamount~admin. state.ak.us>,
Tom Maunder <tom_maunder~admin. state.ak.us>
CC: Winton G Aubert <winton_aubert~admin. state.ak.us>
I spoke with Jim Mosely (Unocal) today in regards to their request.
Recall from our meeting last week that we had identified additional
information needed by the Commission. I sent the attached letter to Mr.
Mosely via email today; we briefly discussed the info request. Mr.
Mosely indicated that he would be out of town for the next 2 weeks and
would prefer to wait until he returns to provide a complete response to
our questions. Here's the brief response he gave:
1. Oil or Gas wells? Unocal purposely did not specify since they are
hoping for both; immediate interest is gas (and they would limit their
focus there as a starting point); also indicated that for Swanson River
Field, oil wells would require artificial lift that would likely render
oil well tubingless completions impractical
2. Design life - short (whatever that means)
3. Alternate means of assuring long term casing integity (since do not
have an annular space for monitoring) - he referred to surface casing as
barrier; I tried to focus him toward the lower section of the well where
there is a single barrier to the formation; sounds like he is thinking
the cement is a barrier (I mentioned the requirements to confine fluids
to the wellbore and to prevent fluid migration from one stratum to the
next); no comment on testing, etc.
4. Historical evidence of long term integrity in existing wells - said
there may be a few wells with annular communication but in general
fluids are no problems; fluids are noncorrosive
5. Expected pressures - said they are low since shallow objectives
(again, whatever low means).
We will need to wait for a formal response to our questions; that will
be 2-3 weeks. Do we postpone the hearing tentatively set for Thursday,
9/197
Jim Regg
~tbgless_swanson_co info reqst.doc
Name: tbgless_swanson co info_reqst.doc
Type: WINWORD File (application/msword)
Encoding: base64
Jim Regg <jim_regg~admin.state.ak.us>
Petroleum Engineer
AOGCC
Administration
1 of 2 9/19/2002 8:15 AM
Mr. Jim Mosely
Unocal Corporation
P.O. Box 196247
Anchorage, AK 99501
Dear Mr. Mosely:
Your letter dated August 7, 2002, requests the issuance of a Conservation Order for the Swanson
River and Soldotna Creek Units (collectively, the Swanson River Field) addressing tubingless
completions. A waiver of 20 AAC 25.200(d) would be the basis to be addressed in a CO as
requested.
The AOGCC continues to review your request, and a hearing has tentatively been scheduled for
September 19, 2002, to provide the public with the opportunity to comment regarding your
request. A decision whether to hold the hearing has not been made. The following additional
information is necessary for our review:
1. Is the request directed at both oil and gas, or just gas wells?
2. What is the expected design life of Swanson River Field wells that would be tubingless
completions?
3. Alternate means of assuring barrier integrity throughout the life of the well are necessary
for tubingless completions. What tests would be performed by Unocal to confirm there is
pressure integrity subsequent to commencing operation? (Our understanding is that there
would be a single barrier between the production flow path and the earth below any
surface casing). What would be the testing frequency?
4. Provide historical evidence of long-term tubing and casing integrity in existing Swanson
River Field wells. That information should conclusively determine that tubingless
completions in the Swanson River Field can be designed and operated at an equivalent
leVel of safety and protection to the enviroment as a well designed in accordance with
,
20 AAC 25.200. Information could include workover history, any annular :
communication that exists in Swanson River Field wells; we recognize from your August
7 .le~er that there is "very little or no H2S or CO2 so the risk of internal corrosion will be
low." Differences attributable to the well producing oil or gas should be identified.
5. Production pressures for the wells expected to be tubingless completions.
Your earliest response would be appreciated.
#2
STATE OF ALASKA ! NOTICE TO PUBLISHER N~ ADVERTISING ORDER NO.
ADVERTISING ,Nvo, ~ ,.~UST BE ,, TR,PL,0ATE S.OW,.G ^DVERT,S,.G ORDER .. ~RT,F,EDan n~nn 4009
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SEE BOTTOMFORI;IN~OICE ~DRESSl;',,
, .....
F AC)C~C AGENCY CONTACT DATE OF A.O.
R 333 W 7thAve, Ste 100 Jod¥Colombie August 16,2002
o Anchorage, AK 99501 ~.O~E ~CN
~ - (907~ 793 --1221
I~ATE~ ADVERTISEMENT REQUIRED:
T Anchorage Daily News August 17, 2002
o
P O Box 149001
TIlE MATERIAL BETWEEN TItE DOUBLE LINES MUST BE PRINTED IN ITS
Anchorage, AK 99514 EN~'I~n' O~*UE D^~ES SUOWm.
SPECIAL INSTRUCTIONS:
Account #STOF0330
Advertisement to be published was e-mailed
Type of Advertisement X Legal E] Display E] Classified E~Other (Specify)
SEE ATTACHED PUBLIC HEARING
i.. I It°Tal°F I ALL I
SEND INVOICE__IN TRIPLICATE AOGCC, 333 W. 7th Ave., Suite 100 PAGE 1 Of PAGES$'
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02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM
Notice of Public Hearing
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re~
Swanson River Field and Soldotna Creek Unit
Unocal Corporation
Unocal Corporation by letter dated August 7, 2002, has requested authorization to
allow completion of newly drilled gas wells without a tubing and packer as required
under 20 AAC 25.200(d) for the Swanson Rover Field which includes the Swanson River
Unit and Soldotna Creek Unit.
The Commission has tentatively set a public hearing on this application for
September 19, 2002 at 9:00 am at the Alaska Oil and Gas Conservation Commission at
333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that
the tentatively scheduled hearing be held by filing a written request with the Commission
no later than 4:30 pm on September 3, 2002.
If a request for a hearing is not timely filed, the Commission will consider the
issuance of an order without a hearing. To learn if the Commission will hold the public
hearing, please call 793-1221.
In addition, a person may submit written comments regarding this application to
a 1 e a th
the Alask Oi and Gas Cons rv tion Commission at 333 West 7' Avenue, Suite 100,
Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on
September 17, 2002 except that if the Commission decides to hold a public hearing,
written comments must be received no later than 9:00 am on September 19, 2002.
If you are a person with a disability who may need a special modification in order
to comment or to attend the public hearing, please contact Jody Colombie at 793-1221
before September 12, 2002.
Cammy O'~chsli Taylor ~
Chair
Published Date: August 17, 2002
ADN AO# 02314009
Anchorage Daily News
Affidavit of Publication
1001 Noxthway Drive, Anchorage, AK 99508
$/19/2oo2
AD # DATE PO ACCOUNT
532651 08/17/2002 02314009 STOF0330
PRICE OTHER OTHER
PER DAY CHARGES CHARGES
$131.52
$131.52 $0.00 $0.00
OTHER
CHARGES #3
OTHER
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OTHER
CHARGES
GRAND
TOTA~
$0.00 $0.00 $0.00 $131.52
STATE OF ALASKA
THIRD JUDICIAL DISTRICT
Lorene Solivan, being first duly sworn on oath deposes and says that
she is an 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 the above dates 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 foregoingpublication is not in excess of the rate charged
private individuals.
Signed ~
Subscribed and sworn to me before this date:
Notary Public in and for the State of Alaska.
Third Division. Anchorage, Alaska
MY COMMIS EXPIRES:
,,,,,6~t t {./t_ttq'rr.
---
Notice of Public Hearing
STATE OF ALASKA '
Alaska Oil and Gas ConServation COmmission
Re: Swanson River Fieid"and Soldotna. Creek Unit
Unocal Corporation '
Unocal corporation by letter dated August 7, 2002,
has requested out, horizOtion to allow completion of
newly drilled gas wells, without a tubi,ng and
packet'as.required under 20 AAC 251200(d) for the
Swanson Rover Field which includes the Swanson
River Unit and Soldotna creek Unlt,~
The Commission has tentatively set a public hear-
ing On this 'appli'ca,tion for.~.,Sentember 19,: 20.02 at
9 00 am at the. Alaska O' and'Gas Conservation
,Commission at 333 West 7th .Avenu'e; Suite 100, An-
. chorage, Ala.'.kt. ;~.'.':'. /. r'e-~:.r' "~c;-.-'r3:lue~t that
the tentati.ve,,' .~c,": :'.J :.'.: n:,:':- r.:' c.." re d:by~fJ'!ing
a' written re~: :.' ..'..; .. '", ",c ','::,.r't' ~;:',:-'.,'. no later
than'4:3.0.pm :i:' ~::: :..'"',:::- ':'
I:f a. rec~ue'st;f~r a hearing.is not ~imelY"filed, the'
commission will consider the JssucJrlce of an order
Without'a,..h'earing.. To learn' if the' ~emmiss.lOn will
h01d the publia,hearing; please call 793~'.122i.' '..
In''addition, a Per. s°n ma~ subm'It'W~itten.corm':
'ments regarding.this/aPplicatiOn .to t'be Ala'ska Oil
. and Gas Conservation .Commisslon. at;333 .West ..7th
Avenue, Suite 100, AnChorage,.Alaska 99501.. Writ-
ten comments must be received no later than 4':~30
pm On September 17,'.2002 except that'.if the Cor-
m ss 'On decides to had a public, hearing, written
comments must be.received no later than 9:0O .am
on September 19,2002. ...'...' '
If you a?e a person with a 'di~abi'litv'who may need
a'sPeCjal modification Jn order to oomment or:to
attend the,public hearing, Please. contact .Jody Co-
Iombie~at 7934221 before September 12,.2002'.' '..
cammy Oechsli Taylor . ' . '
'Chair.
Publish: AuguSt' 17, 2002 . AO# 02314009
STATE OF ALASKA (r NOTICE TO PUBLISHER ( ^[~V[mTlSl~C DRIVER ~O.
ADVERTISING ~NVOIC¥ MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDERN~., ,.,ERTIFIED
AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF AO'0231 4009
ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE
:.~ SEE BOTTOM F, OR IN~()ICE :,~DRE~SS. '
~ i~ i':,~ ~, ~. ~ ~"; i ~, i,. ¥ ~::'.~" ! ~q~ ~ !:?-~i~?~:i?!~:,' !¢,' !:~ ~:" ? ? i'i:!~, ~ .~ :' i'~
F AOGCC AGENCY CONTACT DATE OF A.O.
R 333 West 7th Avenue, Suite 100 Jodv Colombie Auto, st 1(5_ 2002
o Anchorage, AK 99501 PHOI~E PCI~ '
M
- (907~ 793 - 1221
6ATE~ ADW. RT]SEMENT m~OUI~D:
T Anchorage Daily News August 17, 2002
o
P O Box 149001
Anchorage, AK 99514 . TUE ~TEmA,. SE~VEEN T.E DOUS,.E ~.I~ES M~ST ~ ~m~TED l~ ITS
ENTIRETY ON THE DATES SHOWN.
I SPECIAL INSTRUCTIONS:
Account #STOF0330
AFFIDAVIT OF PUBLICATION
United states of America REMINDER
State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE
THE ADVERTISING ORDER NUMBER.
division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION
MUST BE SUBMITTED WITH THE INVOICE.
Before me, the undersigned, a notary public this day personally appeared
ATTACH PROOF OF PUBLICATION HERE.
who, being first duly sworn, according to law, says that
he/she is the of
Published at in said division and
state of and that the advertisement, of which the annexed
is a true copy, was published in said publication on the day of
2002, and thereafter for __ consecutive days, the last
publication appearing on the ~ day of ,2002, and that
the rate charged thereon is not in excess of the rate charged private
individuals.
Subscribed and sworn to before me
This ~ day of 2002,
Notary public for state of
My commission expires
02-901 (Rev. 3/94) AO.FRM
Page 2 PUBLISHER
John Katz
State of Alaska
Alaska Governor's Office
444 North Capitol St., NW, Ste 336
Washington, DC 20001
Daniel Donkel
2121 North Bayshore Drive Ste 1219
Miami, FL 33137
SD Dept of Env & Natural Resources
Oil and Gas Program
2050'West Main, Ste #1
Rapid City, SD 57702
Alfred James
107 North Market Street, Ste 1000
Wichita, KS 67202-1822
Christine Hansen
Interstate Oil & Gas Compact Comm
Excutive Director
PO Box 53127
Oklahoma City, OK 73152
Citgo Petroleum Corporation
PO Box 3758
Tulsa, OK 74136
Conoco Inc.
PO Box 1267
Ponca City, OK 74602-1267
Mir Yousufuddin
US Department of Energy
Energy Information Administration
1999 Bryan St., Ste 1110
Dallas, TX 75201-6801
Mary Jones
XTO Energy, Inc.
Cartography
810 Houston St., Ste 2000
Ft. Worth, TX 76102-6298
Gregg Nady
Shell E&P Company
Onshore Exploration & Development
PO Box 576
Houston, TX 77001-0576
Michael Nelson
Purvin Gertz, Inc.
Library
600 Travis, Ste 2150
Houston, TX 77002
Paul Walker
Chevron
1301 McKinney Rm 1750
Houston, TX 77010
G. Scott Pfoff
Aurora Gas, LLC
10333 Richmond Ave, Ste 710
Houston, TX 77042
G. Havran
Gaffney, Cline & Associations
Library
1360 Post Oak Blvd., Ste 2500
Houston, TX 77056
David McCaleb
IHS Energy Group
GEPS
5333 Westheimer, Ste 100
Houston, TX 77056
William Holton, Jr.
Marathon Oil Company
Law Department
5555 San Fecipe St.
Houston, TX 77056-2799
T.E. Alford
ExxonMobil Exploration Company
PO Box 4778
Houston, TX 77210-4778
Texico Exploration & Production
PO Box 36366
Houston, TX 77236
Chevron USA
Alaska Division
PO Box 1635
Houston, TX 77251
W. Allen Huckabay
Phillips Petroleum Company
Exploration Department
PO Box 1967
Houston, TX 77251
Donna Williams
World Oil
Statistics Editor
PO Box 2608
Houston, TX 77252
Chevron Chemical Company
Library
PO Box 2100
Houston, TX 77252-9987
Shawn Sutherland
Unocal
Revenue Accounting
14141 Southwest Freeway
Sugar Land, TX 77478
Kelly Valadez
Tesoro Refining and Marketing Co.
Supply & Distribution
300 Concord Plaza Drive
San Antonio, TX 78216
James White
Intrepid Prod. Co./Alaskan Crude
4614 Bohill
SanAntonio, TX 78217
Doug Schultze
XTO Energy Inc.
3000 North Garfield, Ste 175
Midland, TX 79705
Robert Gravely
7681 South Kit Carson Drive
Littleton, CO 80122
George Vaught, Jr.
PO Box 13557
Denver, CO 80201-3557
Scott Webb
Ocean Energy Resources, Inc.
1670 Broadway, Ste 2800
Denver, CO 80202-4826
Jerry Hodgden
Hodgden Oil Company
408 18th St.
Golden, CO 80401-2433
John Levorsen
200 North 3rd St., #1202
Boise, ID 83702
Kay Munger
Munger Oil Information Service, Inc
PO Box 45738
Los Angeles, CA 90045-0738
John F. Bergquist
Babson and Sheppard
PO Box 8279
Long Beach, CA 90808-0279
Samuel Van Vactor
Economic Insight Inc.
3004 SW First Ave.
Portland, OR 97201
Thor Cutler OW-137
US EPA egion 10
1200 Sixth Ave.
Seattle, WA 98101
Michael Parks
Marple's Business Newsletter
117 West Mercer St, Ste 200
Seattle, WA 98119-3960
Duane Vaagen
Fairweather
715 L St., Ste 7
Anchorage, AK
99501
Julie Houle
State of Alaskan DNR
Div of Oil & Gas, Resource Eval.
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Williams VanDyke
State of Alaska
Department of Natural Resources
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Steve E. Mulder
Dorsey & Whitney
1031 West 4th Ave., Ste 600
Anchorage, AK 99501
Richard Mount
State of Alaska
Department of Revenue
500 West 7th Ave., Ste 500
Anchorage, AK 99501
Cammy Taylor
1333 West 11th Ave.
Anchorage, AK 99501
Robert Mintz
State of Alaska
Department of Law
1031 West 4th Ave., Ste 200
Anchorage, AK 99501
Susan Hill
State of Alaska, ADEC
EH
555 Cordova St.
Anchorage, AK 99501
Ed Jones
Aurora Gas, LLC
Vice President
1029 West 3rd Ave., Ste 220
Anchorage, AK 99501
Tim Ryherd
State of Alaska
Department of Natural Resources
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Jim Arlington
Forest Oil
310 K St., Ste 700
Anchorage, AK 99501
Trustees for Alaska
1026 West 4th Ave., Ste 201
Anchorage, AK 99501-1980
Mark Wedman
Halliburton
6900 Arctic Blvd.
Anchorage, AK 99502
Mark Dalton
HDR Alaska
2525 C St., Ste 305
Anchorage, AK 99503
Schlumberger
Drilling and Measurements
3940 Arctic Blvd., Ste 300
Anchorage, AK 99503
John Harris
NI Energy Development
Tubular
3301 C St., Ste 208
Anchorage, AK 99503
Ciri
Land Department
PO Box 93330
Anchorage, AK 99503
Mark Hanley
Anadarko
3201 C St, Ste 603
Anchorage, AK 99503
Baker Oil Tools
4730 Business Park Blvd., ~44
Anchorage, AK 99503
Judy Brady
Alaska Oil & Gas Associates
121 West Fireweed Lane, Ste 207
Anchorage, AK 99503-2035
Aden Ehm
2420 Foxhall Dr.
Anchorage, AK
99504-3342
Greg Noble
Bureau of Land Management
Energy and Minerals
6881 Abbott Loop Rd
Anchorage, AK 99507
Jeff Walker
US Minerals Management Service
Regional Supervisor
949 East 36th Ave., Ste 308
Anchorage, AK 99508
Jill Schneider
US Geological Survey
4200 University Dr.
Anchorage, AK 99508
Rose Ragsdale
Rose Ragsdale & Associates
3320 E. 41st Ave
Anchorage, AK 99508
Jim Scherr
US Minerals Management Service
Resource Evaluation
949 East 36th Ave., Ste 308
Anchorage, AK 99508
Thomas R. Marshall, Jr.
1569 Birchwood Street
Anchorage, AK 99508
Chuck O'Donnell
Veco Alaska,Inc.
949 East 36th Ave., Ste 500
Anchorage, AK 99508
Richard Prentki
US Minerals Management Service
949 East 36th Ave., 3rd Floor
Anchorage, AK 99508
Paul L. Craig
Trading Bay Energy Corp
5432 East Northern Lights, Ste 610
Anchorage, AK 99508
Gordon Severson
3201 Westmar Cr.
Anchorage, AK 99508-4336
Jim Ruud
Phillips Alaska, Inc.
Land Department
PO Box 100360
Anchorage, AK 99510
Kristen Nelson
IHS Energy
PO Box 102278
Anchorage, AK
99510-2278
Perry Markley
Alyeska Pipeline Service Company
Oil Movements Department
1835 So. Bragaw - MS 575
Anchorage, AK 99515
Jordan Jacobsen
Alyeska Pipeline Service Company
Law Department
1835 So. Bragaw
Anchorage, AK 99515
Robert Britch, PE
Northern Consulting Group
2454 Telequana Dr.
Anchorage, AK 99517
Jeanne Dickey
BP Exploration (Alaska), Inc.
Legal Department
PO Box 196612
Anchorage, AK 99518
David Cusato
600 West 76th Ave., #508
Anchorage, AK 99518
Tesoro Alaska Company
PO Box 196272
Anchorage, AK 99519
J. Brock Riddle
Marathon Oil Company
Land Department
PO Box 196168
Anchorage, AK 99519-6168
Kevin Tabler
Unocal
PO Box 196247
Anchorage, AK 99519-6247
Sue Miller
BP Exploration(Alaska),lnc.
PO Box 196612
Anchorage, AK 99519-6612
BP Exploration (Alaska), Inc.
Land Manager
PO Box 196612
Anchorage, AK 99519-6612
Dudley Platt
D.A. Platt & Associates
9852 Little Diomede Cr.
Eagle River, AK 99577
Bob Shavelson
Cooklnlet Keeper
PO Box 3269
Homer, AK 99603
Shannon Donnelly
Phillips Alaska, Inc.
HEST-Enviromental
PO Box 66
Kenai, AK 99611
Kenai Peninsula Borough
Economic Development Distr
PO Box 3029
Kenai, AK 99611
James Gibbs
PO Box 1597
Soldotna, AK
99669
Penny Vadla
Box 467
Ninilchik, AK
99669
Claire Caldes
US Fish & Wildlife Service
Kenai Refuge
PO Box 2139
Soldotna, AK 99669
Kenai National Wildlife Refuge
Refuge Manager
PO Box 2139
Soldotna, AK 99669-2139
John Tanigawa
Evergreen Well Service Company
PO Box 871845
Wasilla, AK 99687
Richard Wagner
PO Box 60868
Fairbanks, AK 99706
Cliff Burglin
PO Box 131
Fairbanks, AK
99707
Harry Bader
State of Alaska
Department of Natural Resources
3700 Airport Way
Fairbanks, AK 99709
North Slope Borough
PO Box 69
Barrow, AK 99723
Bernie Karl
K&K Recycling Inc.
PO Box 58055
Fairbanks, AK 99711
Senator Loren Leman
State Capitol Rm 113
Juneau, AK 99801-1182
Williams Thomas
Arctic Slope Regional Corporation
Land Department
PO Box 129
Barrow, AK 99723
#1
Unocal Corporation
P.O. Box 196247
Anchorage, AK 99501
Telephone (907) 263-7805
UNOCAL
' Alaska
August 7, 2002
Commissioner Cammy Taylor
Alaska Oil and Gas Conservation Commission
333 W. 7th Ave., Suite 100
Anchorage, AK 99501-3539
RE:
Swanson River Unit
Conservation Order Application
Tubingless Completions
Dear Commissioner Taylor:
As operator of the Swanson River Field, Unocal respectfully requests the Alaska Oil and
Gas Commission to issue a Conservation Order for the Swanson River Field, to include
Swanson river Unit (SRU) and Soldotna Creek Unit (SCU), allowing completion of newly
drilled wells without a tubing and packer as required under 20 AAC 25.200(d).
The reason for this request is to provide a wider array of options for developing reserves
within the Swanson River Field. A waiver to the tubing and packer requirement will allow
Unocal to use, where appropriate, slim hole drilling techniques and small diameter
casings. The slim hole drilling and completion technique significantly lowers well costs,
thereby allowing Unocal to increase ultimate recovery by drilling and producing reserves
that would not be economical to develop with conventional drilling and completion
practices.
Based upon prior drilling in the area, targeted reserves would have very little or no H2S
or CO2, so the risk of internal corrosion will be Iow. To maintain producibility and
mechanical integrity of the new tubingless Wells, Unocal proposes to bring the cement
top to the surface as was done on the recent SRU 213-10 well. For wells that do not
succeed in having cement return to the surface, Unocal will run a CBL log to
demonstrate the cement top is sufficiently inside the surface casing. Unocal proposes to
include an "X" nipple in each of the tubingless completions placed above the highest
potential perforation interval. The "X" nipple will be used to set a plug so that Unocal can
demonstrate mechanical integrity via negative pressure testing on an annual basis.
Unocal will monitor annulus pressure daily on wells that do not have cement circulated to
the surface and will report results to the Commission annually or as requested. If any
pressure readings indicate a failure of mechanical integrity, Unocal will implement
corrective action to the satisfaction of the Commission.
August7,2002
Swanson River Unit-Conse~ation Order Application
Page 2
Anticipated well construction plans would be similar to the recently completed SRU 213-
10 well, as follows: The SRU 213-10 well set 133/8 inch conductor casing driven to about
80 feet, 7 inch L-80 surface casing was run to about 1800 feet TVD and cemented to
surface, and a 3¼ inch L-80 production casing was run to TD and cemented to the
surface. The 3~ inch production casing was cemented with a lead and a tail cement job
consisting of a Iow weight lead slurry and a conventional tail slurry designed to prevent
migration of fluids. The 7 inch surface casing was set below the maximum depth of fresh
water and just above the targeted hydrocarbon bearing shallow production zones.
Future tubingless wells will be designed similarly with surface casing set below the
required minimum depth, and production casing set and cemented with the planned top
of cement high enough in the surface casing so as to effect a seal in the production
casing by surface casing annulus.
If you have any questions concerning this request, please contact me at 263-7679.
Cc:
Jim Harrison
John Zager
File
Sincerely
Jim Mosley
Sr. Adv. Drilling Engineer