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Home My WebLink AboutCO 406 A ) ) Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable by direct inspection of the file, Go 40ft:, 1\ Order File Identifier Organizing (done) D Two-sided 1111111111111111111 ~scan Needed 1111111111111111111 R¡SCAN ¢ Color Items: o Greyscale Items: DIGITAL DATA OVERSIZED (Scannable) D Maps: D Other Items Scannable by a Large Scanner D Diskettes, No. D Other, No/Type: o Poor Quality Originals: OVERSIZED (Non-Scannable) o Other: o Logs of various kinds: NOTES: Scanning Preparation BY: Helen ~ x 30 = + D Other:: , Date<t: +/CJ~III¡I/IIII~ Date:~ if e;Ò- Isl Y'Vf¡iJ I = nOTI¡\L PAGES Q If (CoUl]...<joes ?O', include cover sh/et) (II A n DateK t...;., 0 5 /5/ r V fLf/ ,f'. 1111111111111111111 BY: Helen ~ Project Proofing BY: Helen ~ Production Scanning Stage 1 Page Count from Scanned File: Of Ö (Count does include cover sheet) Page Count Matches Number in Scanning Preparation: V YES NO HelenS Date:~, l¡./()6 Isl yvtD If NO in stage 1, page(s) discrepancies were found: YES1 NO BY: Stage 1 BY: Helen Maria Date: /51 Scanning is complete at this point unless rescanning is required. 1111I111I11111I11I1 ReScanned 1111111111111111111 BY: Helen Maria Date: /5/ Comments about this file: Quality Checked 1111III1I1111111111 8/24/2004 Orders File Cover Page.doc ) ') INDEX CONSERVATION ORDER NO. 406A 1) 2) August 8, 2002 August 12, 2002 3) August 16, 2002 4) September 5, 2002 5) September 8, 2002 6) September 25, 2002 7) October 1, 2002 8) February 6, 2003 9) February 28, 2003 10) March 3, 2003 11 ) ----------------- 12) May 22, 2003 13) August 2, 2005 Draft Letter from Phillips requesting Float-Float Adoption Request Formal request for Modifications to Kuparuk River AOGCC Unit Conservation Orders Pertaining to Methods Of Allocation of Production Among Kuparuk River Unit Oil Pools Notice of Hearing, affidavit of Publication, bulk mailing List Internal e-mail Production Allocation Conservation Order Internal e-mail i.e.: vacate hearing Internal e-mail between senior staff Internal e-mail between senior staff Requested Modifications to Kuparuk River AOGCC Unit CO and AIO Internal e-mail Sign In sheet Kuparuk Order Review Various Letters Letter from CPA Cookson re: Automatic Shut-in Equipment Request from Keitha Kolvig, Faulkner Banfield for copy of entire file. Agency created a CD on 8/4/05. Conservation Order 406A ) , ) STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501 Re: THE APPLICATION OF Phillips ) Alaska, Inc" the predecessor company of ) ConocoPhillips Alaska, Inc. ("CP AI") for ) changes to Rules 6, 7, 8, and 11, Conser- ) vation Order 406, which affect the West ) Sak Oil Pool, I(uparuk River Unit, North ) Slope, Alaska. ) Conservation Order No. 406A Kuparuk River Unit West Sak Oil Pool August 27,2003 IT APPEARING THAT: 1) ConocoPhillips Alaska, Inc. ("CP AI"), by letter dated August 12, 2002, requested changes to Rule 7 Conservation Order 406 pertaining to Common Production Facilities and Surface Commingling allocation methods affecting the West Sak Oil Pool producing within the Kuparuk River Unit ("KRU"). 2) The Commission published notice of opportunity for public hearing in the Anchorage Daily News on August 16, 2002, pursuant to 20 AAC 25.540. A tentative hearing date was set for September 18, 2002. 3) No requests for public hearing or protests to the application were received. The hearing date was vacated on September 8,2002. 4) During discussions with AOGCC staff and in correspondence dated September 5, 2002, September 25, 2002, October 1, 2002, February 6, 2003, April 14, 2003, and May 22, 2003, CP AI requested administrative changes to Rules 6, 8, and 11 of Conservation Order ("CO") 406 be made coincident with the production allocation issue noticed under item 1. 5) The Commission delayed action on the Production Allocation Rule application until CP AI finalized their request and subsequent personnel changes were complete. FINDINGS: 1) The Operator of the KRU has nominally changed through corporate acquisitions and corporate mergers. ARCO Alaska, Inc., the original Operator, was acquired by Phillips Petroleum, which has since merged with Conoco, Inc, The Operator is currently doing business in Alaska as ConocoPhillips Alaska, Inc, ) ) ) 2) Satellite pools have been discovered and developed utilizing the infrastructure built to develop the Kuparuk River Oil Pool ("KROP") within the KRU. 3) Production allocation procedures for satellite pools have evolved since initially established for the West Sak Oil Pool in CO 406, dated October 16, 1997. 4) Satellite pool allocation procedures were proposed to eliminate duplicate facilities needed to produce separate reservoirs into unitized surface facilities in the KRU. 5) Satellite pool allocation requires a minimum of two well tests per month, point-to- point interpolation between tests, and uses the following month initial test to allocate month-end production to eliminate wedge effects. 6) Well test-based allocation is a method for dividing production among owners, calculating royalty, managing reservoirs and calculating severance tax prior to final processing at Central Processing Facilities ("CPF") that were initially built for the KROP. The allocation procedure compares the summation of theoretical production from all wells into one facility (including KROP and satellite pools) to its Lease Automatic Custody Transfer ("LACT") meter total. The ratio of the two determines an allocation factor ("AF") that is applied to the theoretical well production so that the volumes are forced to agree. 7) The initial procedure applied at KRU fixed the satellite pool AF to 1.0 (called the "fixed-float" method). The satellite AF was fixed while the I(ROP AF floated according to the ratio of the theoretical volume to the total LACT volume less the satellites volume. The floating AF was used to correct KROP volumes. 8) In November 2001, the Operator agreed to test a methodology, advocated by the DOR, that allowed the satellite pools AF to float up to a limit of 1.02. The method involved the same procedures except the AF was based on the ratio of total facility volume compared to total facility theoretical volume. If AF exceeded 1.02, the satellite AF is "capped" and the I<ROP AF is allowed to float. The method is called the "capped float-float" method. 9) Department of Natural Resources Division of Oil & Gas ("DOG") specified the capped float-float methodology for the Greater Kuparuk Area for a twelve-month trial in their August 29, 2001 "Decision and Findings for the Seventh Expansion of the Kuparuk River Unit and Formation of the Meltwater Participating Area." 10) CP AI initiated the capped float-float method in January 2002 for all satellite pools including the West Sak Oil Pool in the KRU. Representatives of the AOGCC, DOG and DOR reviewed the first six months of allocation data under the new method on July 30, 2002. All parties agreed that the transition to capped float-float was smooth and without notable affect on any of the separate pools. 11) The agencies and CP AI agreed the capped float-float allocation technique would be appropriate for production allocation at the KRU satellite pools on a permanent basis. 12) CP AI requested administrative changes to specific rules in CO 406 to standardize the rules and timing of required reports for annual surveillance, annual pressure measurements and automatic shut-in equipment for the West Sak Oil Pool within the KRU. Conservation Order No. 406A Page 2 of 8 Effective August 27, 2003 ) j ) 13) The requested changes will make compliance with Conservation Orders and field operation of the pools more consistent and efficient, as CP AI will be administering similar rules with consistent requirements and deadlines for all pools within the KRU operating area, 14) Annual surveillance reporting requirements are documented in CO 406, Rule 11 for the West Sak Oil Pool. 15) CP AI requested the annual surveillance reporting requirements be changed such that the report for each pool for a calendar year is due by April 1 of the following year. 16) Automatic Shut-In Equipment rules are documented in CO 406, Rule 6 for the West Sak Oil Pool. 17) CP AI requested additional wording to distinguish between safety valve requirements for water and gas injectors, and requiring that gas and miscible gas injectors be equipped with a landing nipple for installation of a down hole flow control device. 18) Reservoir pressure monitoring rules are documented in CO 406, Rule 8 for the West Sak Oil Pool. 19) CP AI requested flexibility to determine the appropriate number of pressure surveys each year in the pools, and to provide a plan each year as part of the Annual Reservoir Surveillance Report. CONCLUSIONS: 1) DOR, AOGCC and DOG, the State of Alaska agencies affected by the capped float- float production allocation procedure, have agreed that this method is appropriate for allocation of production amongst pools producing within the KRU. 2) Well test-based production allocation methods applied consistently to all pools producing to a common facility have been approved by the affected State agencies, DOR, DOG and AOGCC, based on technical review of data developed from January to July of 2002. 3) Commingling of West Sak Oil Pool fluids at the surface with produced fluids from the other KRU Pools is appropriate provided there are adequate well tests to assure accurate production allocation. 4) Wording changes to rules affecting automatic shut-in equipment will make planning completions and workovers consistent and less complicated. 5) Wording changes to rules affecting reservoir pressure monitoring will allow the Operator to plan surveillance to meet reservoir management requirements. 6) Wording and timing changes to rules affecting annual surveillance reports will enhance efficiency of the Operator regulatory responsibilities, 7) The changes to these rules will not cause waste, harm correlative rights or adversely impact ultimate recovery from the affected pool. Conservation Order No, 406A Page 3 of 8 Effective August 27, 2003 ) t ) NOW, THEREFORE, IT IS ORDERED: 1) Conservation Order 406 is amended to provide changes to Rules 6, 7, 8, and 11. 2) Conservation Order 406A supersedes Conservation Order 406 dated October 16, 1997. 3) The findings, conclusions and administrative record for Conservation Order 406 are adopted by reference and incorporated in this decision. 4) The following rules, in addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), apply to the following affected area. Umiat Meridian Township Range Sections T8N R 7E Sections 1-18 T9N RIlE Sections 5-8, 17-20, 29-32 T9N RI0E All T9N R9E All T9N R8E All T9N R 7E All TI0N RIlE Sections 3-10, 15-22,29-32 TI0N RI0E All TI0N R9E All TI0N R8E All TI0N R7E All TIIN RIlE Sections 5-8, 16-22, 27-34 TIIN RI0E All TIIN R9E All TIIN R8E All TIIN R7E All T12N RI0E Sections 3-10, 14-23,25-36 Conservation Order No, 406A Page 4 of 8 Effective August 27, 2003 J J ) T12N R9E All T12N R8E All T12N R7E All T13N R9E SW/4 Section 2, W/2& SE/4 Section 11, Sections 3- 10, 15-22, 25-36 T13N R8E Sections 1-3, 10-12, 13-15, 19-36 T14N R9E Sections 19, 30, 31 T14N R8E Sections 24, 25, 36 Rule 1 Field and Pool Name The field is the I(uparuk River Field. Hydrocarbons underlying the affected area and within the herein defined interval of the Schrader Bluff Formation constitute a single oil and gas reservoir called the West Sak Oil Pool. Rule 2 Pool Definition The West Sak Oil Pool is defined as the accumulation of hydrocarbons common to and correlating with the interval between the measured depths of 3742 feet and 4156 feet in the West Sak No.1 well. Rule 3 Spacing Units Nominal spacing units within the pool will be 10 acres. The pool shall not be opened in any well closer than 300 feet to an external boundary where ownership changes. Rule 4 Casing and Cementing Practices a) Conductor casing will be set at least 75 feet below ground level and cemented to surface. b) Where required for annular disposal, surface casing will be set at least 500 feet measured depth below the permafrost and be cemented to surface, c) Combination surface-production casing will be set where applicable through the producing or injection intervals and be cemented to surface. Rule 5 Injection Well Completion Injection wells may be completed with tapered casing provided a seal bore, packer, or other isolation device is positioned not over 200 feet above the top of the producing or perforated interval. Conservation Order No. 406A Page 5 of 8 Effective August 27, 2003 ) J ') Rule 6 Automatic Shut-in Equipment a) All producing wells will be equipped with a fail-safe automatic surface safety valve. b) Water injection wells will be equipped with a double check valve arrangement or a single check valve plus a fail-safe automatic surface safety valve. c) Gas or miscible gas ("MI") injection wells will be equipped with a failsafe automatic surface safety valve and a single check valve. d) Gas or MI injection wells must be equipped with a landing nipple at a depth which is suitable for the future installation of a down hole flow control device to control subsurface flow. e) Surface safety valve systems must be maintained in good working order at all times and must be tested at six-month intervals or on a schedule prescribed by the Commission. Rule 7 Common Production Facilities and Surface Commingling a) Production from the West Sak Oil Pool may be commingled with production from the Tarn, Tabasco, Meltwater, and I(uparuk River oil pools in surface facilities prior to custody transfer. b) The allocation factor for the West Sak Oil Pool produced fluids will be based on West Sak well tests. The allocation factor will be calculated on a monthly basis utilizing the Satellite Allocation Technique detailed on Exhibit 18 of the written testimony dated April 26, 2001 ("Testimony for Meltwater Oil Pool Rules - Revision 1") and will be capped at 1.02000. c) Each producing well must be tested a minimum of twice per month. d) The Commission may require more frequent or longer tests if the allocation quality deteriorates. e) The operator shall submit a monthly report and electronic file(s) containing daily allocation data and daily test data for agency surveillance and evaluation. £) The operator shall provide the Commission with a well test and allocation review report in conjunction with an annual reservoir surveillance report. Rule 8 Reservoir Pressure Monitoring a) A bottom-hole pressure survey shall be taken on each well prior to initial sustained production or injection, b) The Operator shall obtain pressure surveys as needed to effectively manage hydrocarbon recovery processes subject to an annual plan outlined in e) of this rule. c) The reservoir pressure datum will be 3500 feet subsea. Conservation Order No. 406A Page 6 of 8 Effective August 27, 2003 ) j ') d) Pressure surveys may consist of stabilized static pressure measurements at bottomhole or extrapolated from surface under single-phase conditions, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests, e) Data from the surveys required in this rule shall be filed with the Commission by April 1 of the subsequent year in which the surveys are conducted. Along with the survey submittal, the operator will provide a proposed survey plan for the upcoming year. The proposed plan shall be deemed accepted if the operator has not received written correspondence from the Commission within 45 days. Reservoir Pressure Report, Form 10-412 shall be utilized for all surveys with attachments for complete additional data. Data submitted shall include, but are not limited to rate, pressure, depth, fluid gradient, temperature, and other well conditions necessary for complete analysis of each survey being conducted. f) Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part ( e) of this rule. Rule 9 Gas-Oil Ratio Exemption Wells producing from the West Sak Pool are exempt from the gas-oil-ratio limits of 20 AAC 25.240(b) so long as the provisions of20 AAC 25.240(c) apply. Rule 10 Pressure Maintenance Proj ect A pressure maintenance waterflood must be initiated within six l110nths after the start of regular production from the West Sak Pool. Rule 11 Reservoir Surveillance Report The Unit Operator shall submit an Annual Reservoir Surveillance Report by April 1 of each year documenting operations for the previous calendar year. The report shall include but is not limited to the following: a) Reservoir management summary including a description of progress of enhanced recovery project implementation and results of reservoir simulation techniques; b) Voidage balance by month of produced fluids and injected fluids on a standard and reservoir volume basis with yearly and cumulative volumes; c) Summary and analysis of reservoir pressure surveys within the pool; d) Results and, where appropriate, analysis of production and injection log surveys, tracer surveys, observation well surveys, and any other special monitoring; e) Review of pool production allocation factors and issues over the prior year; and Conservation Order No, 406A Page 7 of 8 Effective August 27, 2003 ) J ) f) Updated future development plans including an estimated development schedule, progress report and basis of timeline for the complete pool development; Rule 12 Production Anomalies In the event of oil production capacity proration at or from the Kuparuk facilities, all commingled reservoirs produced through the Kuparuk facilities will be prorated by an equivalent percentage of oil production, unless this will result in surface or subsurface equipment damage. Rule 13 Administrative Action Upon proper application, the Commission may administratively waive the requirements of any rule stated above or administratively amend this order as long as the change does not promote waste, jeopardize correlative rights, and is based on sound engineering and geoscience principles. Rule 14 Statewide Requirements Except where a rule stated above substitutes for a statewide requirement, statewide re- quirements under 20 AAC 25 apply in addition to the above rules. DONE at Anchorage, Alaska and dated August 27,2003. Jþ Sar Par, Chair ~/ Al sk il and Gas Conshation Commission ~ Daniel T. SeaÌnount, Jr., Commissioner Alaska Oil and Gas Conservation Commission ~ ~-c,.. R~~y---;~h, Commissioner Alaska Oil and Gas Conservation Commission AS 3 1.05.080 provides that within 20 days after receipt of written notice of the cntty of an order, a person affected by it may 1ile with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rù 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 pati 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 tì'om 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 COuti. Where a request for rehearing is denied by non-action of the Commission, the 30-day period for appeal to Superior COUli runs from the date on which the request is deemed denied (i.e., lOth day after the application for rehearing was tiled). Conservation Order No, 406A Page 8 of 8 Effective August 27, 2003 SO Dept of Env & Natural Resources Oil and Gas Program 2050 West Main, Ste 1 Rapid City, SD 57702 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 Kenai Peninsula Borough Economic Development Distr 14896 Kenai Spur Hwy #103A Kenai, AK 99611-7000 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 ) , Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 W. Allen Huckabay ConocoPhillips Petroleum Company Offshore West Africa Exploration 600 North Dairy Ashford Houston, TX 77079-1175 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise, 10 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr, Anchorage, AK 99508 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Penny Vadla Box 467 Ninilchik, AK 99639 Richard Wagner PO Box 60868 Fairbanks, AK 99706 ') Mary Jones XTO Energy, Inc, Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Trustees for Alaska 1026 West 4th Ave., Ste 201 Anchorage, AK 99501-1980 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Kevin Tabler Unocal PO Box 196247 Anchorage, AK 99519-6247 James Gibbs PO Box 1597 Soldotna, AK 99669 Cliff Burglin PO Box 131 Fairbanks, AK 99707 Bernie Karl K&K Recycling Inc, PO Box 58055 Fairbanks, AK 99711 I) ) ) North Slope Borough PO Box 69 Barrow, AK 99723 ) Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 Conservation Orders ) ) ) Subject: Conservation Orders Date: Wed, 27 Aug 2003 15:52:18 -0800 From: Jody Colombie <jody _ colombie@admin.state.ak.us> Organization: Alaska Oil and Gas Conservation Commission BCC: Robert E Mintz <robert_mintz@law.state.ak.us>, Christine Hansen <c.hansen@iogcc.state.ok.us>, John Tanigawa <JohnT@EvergreenGas.com>, Terrie Hubble <hubbletl@bp.com>, Sondra Stewman <StewmaSD@BP.com>, Scott & Cammy Taylor <staylor@alaska.net>, stanekj <stanekj@unocal.com>, ecolaw <ecolaw@trustees.org>, roseragsdale <roseragsdale@gci.net>, tnnjrl <tnnjrl@aol.com>, jbriddle <jbriddle@marathonoil.com>, rockhill <rockhi11@aoga.org>, shaneg <shaneg@evergreengas.com>, rosew <rosew@evergreengas.com>, jdarlington <jdarlington@forestoil.com>, nelson <nelson@gci.net>, cboddy <cboddy@usibelli.com>, "markdalton" <markdalton@hdrinc.com>, "shannon.donnelly" <shannon.donnelly@conocophillips.com>, "mark p. worcester" <mark p. worcester@conocophillips.com>, "j erry.c.dethlefs" <j erry.c.dethlefs@conocophi11ips.com>, arlenehm <arlenehm@gci.net>, bob <bob@inletkeeper.org>, wdv <wdv@dnr.state.akus>, tjr <tjr@dnr.state.ak.us>, bbritch <bbritch@alaska.net>, mjnelson <mjnelson@purvingertz.com>, burgin _ d <burgin _ d@niediak.com>, "charles.o 'donne 11 " <charles.o'donnell@veco.com>, "Skillern, Randy L" <SkilleRL@BP.com>, "Dickey, Jeanne H" <DickeyJH@BP.com>, "Jones, Deborah J" <JonesD6@BP.com>, "Hyatt, Paul G" <hyattpg@BP.com>, "Rossberg, R Steven" <RossbeRS@BP.com>, "Shaw, Anne L (BP Alaska)" <ShawAL@BP.com>, "Kirchner, Joseph F" <KirchnJF@BP.com>, "Pospisil, Gordon" <PospisG@BP.com>, "Sommer, Francis S" <SommerFS@BP.com>, "Schultz, Mikel" <Mikel.Schultz@BP.com>, "Jenkins, David P" <JenkinDP@BP.com>, "Glover, Nick W" <GloverNW@BP.com>, "Kleppin, Daryl J" <KleppiDE@BP.com>, "Platt, Janet D" <PlattJD@BP.com>, "Wuestenfeld, I(aren S" <WuesteKS@BP.com>, "J acobsen, Rosanne M" <J acobsRM@BP .com>, ddonkel <ddonkel@cfl.rr.com>, collins_mount <collins_mount@revenue.state.akus>, mckay <mckay@gci.net>, "barbara. f. fullmer" <barb ara. f. fullmer@conocophillips.com>, eyancy <eyancy@seal-tite.net>, bocastwf <bocastwf@bp.com>, cowo <cowo@chevrontexaco.com>, ajiii88 <ajiii88@hotmail.com>, doug_schultze <doug_ schultze@xtoenergy.com>, "hankalford" <hankalford@exxonmobil.com>, yesno 1 <yesno 1 @gci.net>, "john. w.hanes" <john. w.hanes@exxonmobil.com>, gspfoff <gspfoff@aurorapower.com>, "gregg.nady" <gregg.nady@shell.com>, "fred. steece" <fred. steece@state.sd.us>, rcrotty <rcrotty@ch2m.com>, jejones <jejones@aurorapower.com>, dapa <dapa@alaska.net>, jroderick <jroderick@gci.net>, eyancey <eyancey@seal-tite.net>, "james.m.ruud" <j ames.m.ruud@conocophillips.com>, Brit Lively <mapalaska@ak.net>, jah <jah@dnr.state.ak.us>, Kurt E Olson <kurt_olson@legis.state.ak.us>, buonoje <buonoje@bp.com>, "Emeka. C.Ezeaku" <Emeka. C.Ezeaku@spdc.shell.com>, mark _ hanley <mark _ hanley@anadarko.com>, lof2 8/27/20033:52 PM Conservation Orders ) J ) loren _leman <loren _leman@gov.state.ak.us>, Harry R Bader <harry_bader@dnr.state.ak.us>, julie_houle <julie_houle@dnr.state.ak.us>, John W Katz <jwkatz@sso.org>, Suzan J Hill <suzan_hill@dec.state.ak.us>, tablerk <tablerk@unoca1.com>, brady <brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us> Attached is the AOGCC's most recent amended Conservation Orders. CO 406A CO 430A CO 435A CO 456A ¡----_. ! Name: C0435A.doc i IIco435A.doc Type: WINWORD File (application/msword) Encoding: base64 );;':';'X'·¡;¡:';';^';'X':·»·';··'»»/X¡;;~;:¡;~:V'ì;'¡;':N¡:';""X;'¡¡¡:¡¡:': "."""."".'';''.:'':''''-'';'»:';''';'';';';':';'';':;'-¡:'»¡:'¡¡¡:':¡:;¡¡~'.'."""'.""""""'';''.'';''':.'';':'"'·;"·'·:·:·'·"·:"·'·:·'·;';':·:·»:';'¡;":·;;0:·;'¡¡ì';¡¡¡;;¡¡:~;. ............,.,......,......,.,."",,,..,,,.,,,,,,,.,.,.,.,,,.A ,..-_................~~"."_......_........-- . . ."'""~..,,",,.....".""""...................... IIC0456A.doc Name: C0456A.doc Type: WINWORD File (application/msword) base64 ! .. .. ··---....·········1---- ..................__... ..-..."...........---. . ¡ ¡ Name: C0430A.doc' i...~.~~~~.~~·~:k~5J;];;~~:~~~=s=~r~)1 -......-. ·.....··--......-·------1- ......... ..... ---..-----.. ..................-... ....... ......-.....--......- -..- .....---...-.-...... ....... ....... ........ ........ ....... ¡ Name: C0406A.doc II C0406A.doc· Type: WINWORD File (application/msword) L'~'~"""""="M" "'".""~........~n~.~.~~~~.:. b~.:~()~...."'.M'...MÚ...M.U."...,=."'..^,.^......~~__..,...'.,."W',ú,.","... . ............-..~~..~~..._~..~.___._..__."~~~,~~.."...~.._~.. ~".m .._~~_..~_ Jody Colombie <jody colombie(iÙadmin.state.ak.us> 20f2 8/27/20033:52 PM ) i'"fl~D [t fï1\ ~. fÃ\ ,I I I 1,_. ! -\ l-J r lr11 --J J Ù ') c 0 ~o ~ A (. lJ j.}f.I.7 " l ~\ L_ \.~ FRANK H. MURKOWSKI, GOVERNOR AI¡A.SIiA OIL AlU) GAS CONSERVATION COMMISSION 333 W. pH AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 406A.Ol Mr. Randy Thomas GKA Drilling Team Leader ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510-0360 Re: Spacing Exception for Kuparuk River Unit 1 E-123Ll Well Dear Mr. Thomas: On May 17, 2004, the Alaska Oil and Gas Conservation Commission ("Commission") received your correspondence dated May 15, 2004 requesting a waiver of spacing requirements for drilling and operation of the Kuparuk River Unit ("KRU") lE-123Ll oil production well. This well will lie entirely within state leases ADL 025651 and ADL 025648, and more than 300 feet from any property lines where ownership changes. The productive interval of KRU lE-123Ll will lie within the West Sak "D" sand, and will approach within 310 feet of existing well KRU IB-IOIL1, which is also open to the West Sak D sand. Conservation Order 406A ("CO 406A") governs the West Sak Oil Pool within the Kuparuk River Unit. Rule 3 of CO 406A states: "Nominal spacing units within the pool will be 10 acres. The pool shall not be opened in any well closer than 300 feet to an external boundary where ownership changes." An exception to the spacing requirements of Rule 3 is required as KRU lE-123Ll will open the pool in the same 10-acre spacing unit as existing well KRU IB-IOILl. Rule 13 of CO 406A states: "Upon proper application, the Commission may administratively waive the requirements of any rule stated above or administratively amend this order as long as the change does not promote waste, jeopardize correlative rights, and is based on sound engineering and geoscience principles." Administrative approval is appropriate for a waiver of well spacing requirements specified in CO 406A. Notice and public hearing are not required for this spacing exception application as KRU lE-123Ll will lie entirely within unitized State leases ADL 025651 and ADL 025648, which are committed to the West Sak Participating Area, and will be located more than 300 feet from any property lines. Correlative rights will not be jeopardized. (i.~ ,," {. b\~::~J~.-I' n T,f',TI "" (! 200 n Úì\."'&-t: '\j il 'ö t:L ~~ th'¡j .L lrI "r ') ) Mr, R. Thomas May 20, 2004 Page 2 of2 The Commission has detennined drilling and operation of the KRU lE-123Ll well is based on sound engineering and geoscience principles, will enhance recovery, will not promote waste or jeopardize correlative rights, and will not result in an increased risk of fluid movement into freshwater. The Commission hereby approves the drilling and operation of the Kuparuk River Unit lE-123Ll well as proposed. DONE at Anchorage, Alaska and dated May 20,2004. (7 ;;Zka Oil and Gas Conservation commiSSion~~~ Johr K~rrnW ~~ount, Jr. ~~ ~missioner Commissioner 5p.oJotí .g..'~/Op~ SC/ìNK\!E[J JUN 1 () 2Dû4 . .~ ·li ConocoPhillips Alaska ') Post Office Box 100360 Anchorage, Alaska 99510-0360 Randy Thomas Phone (907) 265-6830 Email: Randy.L.Thomas@conocophillips.com May 15, 2004 Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Suite 100 Anchorage, Alaska 99501 Re: Application for Spacing Exception, We1l1E-123 L1 Dear Commissioners: ConocoPhillips Alaska, Inc. hereby applies for a spacing exception for the well bore to be designated 1E- 123L1, under the terms of 20 MC 25.055. At total depth, the 1E-123L1 well bore is expected to be 304 feet from the nearest point of "D" sand production in we1l1B-101L1 (this point being the top of the liner in wellbore lS-101L1), a West Sak production well in the West Sak Oil Pool of the Kuparuk River Unit. This distance will be less than that mandated by Conservation Order 406A, Rule 3, which states, "Nominal spacing within the pool will be 10 acres." Details of the distances between the two wells are depicted on the attached illustration, entitled "Spacing between 1E-123 & 1B-101 and 1E-123L1 & 1B-101L1". ConocoPhillips requests this exception to maximize production of the reserves in the West Sak Pool. All properties and lands within 1000' of 1E-123L1 are owned and operated by the same entities, with all those entities having the same percentages of ownership and / or authority to operate across those properties within 1000 feet of 1E-123L1. In addtion to the spacing illustration, please find attached for the review of the Commission the information required by 20 MC 25.055 (d): · A copy of the notice sent to all owners, landowners, and operators of all properties within 1,000 feet of 1E-123L1, notifying them of this application. · A list of those owners, and the addresses to which the above notice was sent, and the date the notice was mailed to those owners · A plat showing the proposed bottom hole location of 1E-123L1, all other completed and drilling wells on the property, and all adjointing properties and wells. · An affidavit verifying that all facts are true, and that the plat correctly portrays the pertinent and required data. Please contact Steve McKeever at 265-6826 if more information is needed to grant this spacing exception. Sincerely, ~.~~ Randy ~~ GKA Drilling Team Leader ~l~t~~D Alaska Oil & ~as Cons~ Commì$sioll A\a~ka Oil ,~~~~~ Con¡¡jil~~\' Anchorage SCANNED JUN 1. S 20D4 ') ) 1 E-123 L 1: P:OPOSed toe ~ .( 356 ft. :...........~.....................~........._....._.................... .................. ..................~..................................... ~ 660 ft. /' 66b ft. ~ i I I i ¡ I i ¡ ¡ {330 ft. / 330 ft. { ¡ ¡ Ii! :.. .: ¡. I I! _·~·_'i·_·_·_·i·_·_·_·_·_·_·_·_·_·_·_·_·i·_·_·_·_·_·_j-. ¡ ~ ~! ! ~ ~! i I I ¡ I. .: ¡ ~ ~! ¡ I I ¡ L.......n.~.n.n......_.._n....~.........n..............._n._....._..n..............n...............~...................................j EJø o__tiiªw..-º_ªR1C1Lo.Q.. 1 0 a crª_~Raci ng . . I 1 B-1 01 L 1 top of '''D'' Sand Liner: / southern most ~oint of production in D sand. ~ I I I . . I I ~ ~ 18-101 7-518" ~Sing shoo, ~ ~ southern most point of I production in "B" sand, , I /-- 304 ft.-----, I I I , I j 1 E-123: proposed toe J / : I I . . I Vertical Sectibn View I -.-----..-...-...-- ....··r-·..-·.....--·T-·----....·-·..·- ...--..... , I . . I I :..····-····~-·-··..·..·-..····..·r····--···..··········..·....·....... ........... .........................[....................... ......... "'1 l' 66~ ft. / 66~ ft. ,( ! ¡I! ¡ j 330 ft. /' 330 ft. j ! : .: ¡ I I ¡ ¡ i i ¡ _.l._~._._._.~._._._._._._._._._._._._.i._._._._._.-I-. CD CD 710ft. I I I , I I ..........~..... .................¡--... .................. .............-. ............... ....-... ..........·ï·..·..·..·....·..·..···..··....·.... P I a.[L.~iewJ:>-ª-R ictinQ..J.Q.._ª.crª-..sP"ª,Çing Conoc~hillips Alaska Spacing between 1 E-123 & 1 B- 101 and 1 E-123L 1 & 1 B-1 01 L 1 Sheet 1 of 2 prepared by Steve McKeever 1E-123 - 18-101 Spacing diagram. vsd 5/16/2004 SçJ\NNEeJ ,JUN 1. 6 20D4 ') ') MD TVD TVD SS X, NAD 27 Y, NAD 27 1a..10tp.·.TQP 6,848.Q $;955.9 $,566;9 554,764·.1 t5,~€iø ,95304 1B..101 D Window 6,847.0 3,655.3 3,566,3 554,764. 1 5,969,952.5 1 B..1 01 L1 1st Screen 6,939,0 3,670,5 3,581,5 554,764.2 5,970,043.0 1B-101 B Top 7,315.0 3,726.0 3,637.3 554,739.8 5,970,411.7 1B-101 Casing Shoe 7,387,0 3,730.2 3,641.2 554,724.8 5,970,482.0 1 B-101 1st screen 7,480.0 3,734.4 3,645.4 554,709.3 5,970,573.6 1E-123 Toe 13,345.9 3,742.0 3,643.0 554,810.0 5,969,777.0 MD TVD TVD SS X, NAD 27 Y, NAD 27 1E-123L1 Toe to 1B·401. p<'tpp 1E-123L 1 Toe t61B-101Dwindow 305 1 E-123 Toe to 1B-101 B Top 1E-123 Toe to 1 B-101 Casing 1E-123 Toe to 18-101 1st Screen 639 304 710 1E~123L1Toeto 1B·4011stScreen 803 1E-123L1: proposed toe \ /--304 ft.---, 1 B-1 01 L 1 top of "D" Sand Liner: / southern most point of production in / D sand. 1E-123: proposed toe J / 710ft. J , t 1B-101 7-5/8" casing shoe, southern most point of production in "B" sand. ~e.rti~ªLSecti_QJ1_Ylew SCt\NNEC JUN 1 S 200~ y ConocoPhillips Alaska Spacing between 1 E-123 & 1 B- 101 and 1E-123L1 & 1B-101L1 Sheet 2 of 2 prepared by Steve McKeever 1E-123 - 18-101 Spacing diagram. vsd 5/16/2004 ') J. P. Williams, Jr. ExxonMobil Alaska Production Inc. 3301 "C" Street, Suite 400 Anchorage, Alaska, 99503 D. Nicolson BP Exploration (Alaska) Inc. 900 E. Benson Boulevard Anchorage, Alaska 99508 G. M. Forsthoff Chevron U.S.A. Inc. 11111 So. Wilcrest Dr. Houston, Texas 77099 J. MacArthur Union Oil Company of California 909 West 9th Avenue Anchorage, Alaska, 99501 KUPARUK RIVER UNIT WORKING INTEREST OWNERS ) SCj~~~~\jEC JUN 1 Û 2004 _ES 0 .2 .4 .6 .8 1.0 STA TUTE MILES 1F-~5-08 / 1&11 1&10 r 1A-03 / o 1A-20 ---------- ~14 1A-04A ~~/ ~~ o 182 \11 ;EET 0 t;7\ \:.:.J 1 F-19 ¿ --. @ --Jif ) ) -----------.-..----- 1C-07 . 1'1.18 cc 0) 1G1C'4PB1 GT-------- "t "t - ~ ~ ~ \ 1C- 1 , ~-/ "C\I + 1')"0 e.cS ~-I" <::( q; ~ 1~ <.0' r--...:tC-03.- ~ ¡ <.0 <.0 .....- _1:1 "" "t . r- :1:S 1ro~ 1C-.}.72 1C-t 7 ".<::( ~0-.112 1C- 25 -f . + 1~100 U .~ + 15-07 ~ -J Q <::( <t: 0)' 00' <.0 <010-113 "t "'t + ~ ~ -J -J <:( q; 1E-20 5000 FEET 15-18 Scale: 1" = 2,640 feet G= Section Numbers in T11N, R10E, Umiat Meridian (,:.... '""" Jt;:¡,~E' \ P EM ~)C!-\N~~ =L ,,)un 1 G 200L) ~ ConocoPhillips Alaska Well 1 E-123L 1 Bottom Hole Location with Nearby Wells & Properties Sheet 1 of 1 1 E-123L1 Spacing Plat. vsd prepared by Steve McKeever Friday, May 14, 2004 ) ) AFFIDA VIT TO THE ALASKA OIL AND GAS CONSERVATION COMMISSION AFFIDAVIT OF STEPHEN O. MCKEEVER STATE OF ALASKA THIRD JUDICIAL DISTRICT I, Stephen o. McKeever, declare and affirm as follows: 1. My name is Stephen o. McKeever. I am over 19 years old and have personal knowledge of the matters set forth herein. 2. I am a Drilling Engineer for the operator, ConocoPhillips Alaska, Inc. 3. I am acquainted with the facts associated with the drilling of the lE-123Ll well. 4. I have reviewed the application submitted for the exception to the spacing requirements of Conservation Order 406A and affirm that all facts therein are true. 5. I have reviewed the plat attached to the application and it correctly portrays pertinent and required data. /~ß day of May, 2004. DATED at Anchorage, Alaska this SM~ StePhe~~eever SUBSCRIBED AND AFFIRMED before me at Anchorage, Alaska this \ t7*' 2004. day of May, NOTARYPUB~~~~~~ATEOFALASKA My commission expires ~''(~ \1..9 \ 'Lü)1 11.;,' ,("' i'; I", ~ i.I.. y ~- ';-', II Ilj!ì:. \1 ,¡; lit ? 0 [1 1 ,,:r¡I.Ú-\il\!r\!lC.:..J ", Ii.. :i\1 ~ 10\ ,_ _f'., CHECKL -)T - SPACING EXCEPTION # __)PLICATION ConocoPhillips Alaska PROPERTY ID/ LEASE Inc Kuparuk River / West Sak Oil Pool 1E-123L1 S: ADL 25648 OPERATOR FIELD/POOL WELL NAME PI/BH: ADL 25648 VERTICAL DEVIATED x EXPLORATORY DELINEATION DEVELOPMENT GAS OIL x x SURFACE LOCATION PRODUCTIVE INTERVALS (Top and Bottom) BOTTOM HOLE 933' FSL, 630' FEL, Section 16, T11 N, R10E, UM 924' FNL, 1169' FEL, Section 15, T11 N, R10E, UM 528' FNL, 909' FEL, Section 10, T11 N, R10E, UM 528' FNL, 909' FEL, Section 10, T11 N, R10E, UM Check applicable reason(s) for spacing exception per 20 AAC 25.055(a): X To drill with spacing closer than the nominal 10 acres spacing mandated by Conservation Order 406A. (1) to drill a well for oil within 500 feet of a property line where ownership or landownership changes, (2) to drill a well for gas within 1500 feet of a property line where ownership or landownershi p changes, (3) to drill and complete more than one oil well in a governmental quarter section; or to drill and complete an oil well closer than 1000' to any well drilling to or capable of producing from the same pool, (4) to drill and complete more than one gas well in a governmental section; or or to drill and complete a gas well closer than 3000' to any well drilling to or capable of producing from the same pool. Does the application contain: X A brief explanation for why the operator has chosen to drill the specified location, A plat drawn to a scale of one inch equaling 2,640 feet or larger, showing the location of the well or portion of the well for which the exception is sought, all other completed and drilling wells on the property, and all adjoining properties and wells within 1,000 feet of a well or portion of the well requiring the spacing exception that is drilling for oil or within 3,000 feet of a well or portion of the well requiring the spacing exception that is drilling for gas. The names of all owners, landowners, and operators of all properties within 1,000 feet of a well or portion of the well requiring the spacing exception that is drilling for oil or within 3,000 feet of a well or portion of the well requiring the spacing exception that is drilling for gas, A copy of the notice sent by certified mail to the owners, landowners and operators described above, the date of mailing, and the addresses to which the notice was sent. An affidavit by a person acquainted with the facts verifying that all facts are true and that the plat correctly portrays pertinent and required data. If the operator requests a variance from the notice requirements of 20AAC25.055(d), sufficient information to demonstrate that it is not feasible to comply with the notice requirements because of the complexity of ownership within the notice area. X X X x 8(ÇP~~NEC' JUN J. 6 20D4- prmlCTØI INC. 0.3 )()JJ~m .~~.. ~ ;. PRDDLcTmN INCa B.m=~IL tUSK" Pmo~TÎÌJI~ 'JNc..~t.: EXXCH4amL-'WÞ OJ1X t£VAØ4 utA) t.1tX. '. CfoIEVRii\US4 It«: a.1t1X -" .' ~>;'" ¡ - Ct£\IRDH usA Øf; O.uX ' , r Dr CÂI...JftI1NIA .¡ ~ OIL ClI4P y'iijF ClLlrDRtGA 4.~UNJtW mL"- ctW"r.artCAUFrRMIA 4.!. . '. uNIoN Wl cn~NV EF CALm: lASJCA) 1ft«; 3928% P E)lpUliAtmÞ4 (~SIC'Ã) 1Nt 39.m . ~ EJìPL.tRltTJDN f.cwW It4C 3RaX".- JP EXPLDAATEtI( (It.A¡1(A).1J4C .illICIt. It-c. n.nx tDJ~wps LAI¡(A. IH:. :SS29X ,t[ll].C?J'Hn.unALf'_~ 1~ ".~ ~DtŒÐPHu..L~PS M.A.;', INC._ " . . f )W.est Sak PA. I -..... ; AI¥. $2ë ~ f'tt KRU , ~ t ..... ',- . . . --m ~ "'i.._ st iII...,... 'I,. = IIoi~D1It ,\', ·q~O ~ tW, rr '~. ~pI 'HIU , . -g- . t \IlL Og25151 ~. -~, JìdI~~ '.0.:13 ~c'Ro,.Ltý.. ,?øo I N.t Prom .!acp~' HIU ~ ~~- . "u .... --au, DE 'dt4:Jln.. M.ASKA PADDUCTl , 0.3'" - E\IR~ USA INt (lUX [f:1>4 an.. CCÞFA"Y OF' ~ .95'(. . ÐCPLORA TIDN <IILÂSf(Ã) .28% IIŒCPHn..tJPS "'-It.A. _ ,1- " ...- ' '"J' -. . , ~ -'. -\W. - > \i '{( L oœ:JG52 .It Il&Ukr. .13 "'R ('b' :. 'iJIT"r,.,.o t \ .. ~ n.L." ....... DC rJ' ~..2-"" ~JU:TIlJN ax ~ CALtF"ORNfA ~ ITis*cA) JNC ç- -=. ¿ iKA ltC, c :z L~ ç, f""o..) CJ 52· ConocÓPhUIi ps Alaska ) Post Office Box 100360 Anchorage, Alaska 99510-0360 May 17, 2004 D. Nicolson BP Exploration (Alaska) Inc. 900 E. Benson Boulevard Anchorage, Alaska 99508 Re: Application for Spacing Exception, West Sak Oil Pool Well lE-123 Ll To Whom it May Concerm: ConocoPhillips Alaska, Inc. has applied, on May 17, 2004, to the Alaska Oil and Gas Conservation Commission for a spacing exception for the wellbore to be designated lE-123Ll, under the terms of 20 MC 25.055. At total depth, the lE-123Ll well bore is expected to be 304 feet from the nearest point of "D" sand production in welllB-l01Ll (this point being the top of the liner in wellborelB-l01Ll), a West " Sak production well in the West Sak Oil Pool of the Kuparuk River Unit. This distanc:e.will be less than that mandated by Conservation Order 406A, Rule 3, which states, "Nominal spacing: within the pool will be 10 acres." The total depth location of lE-123 Ll is expected to be 528' FNL, 909' FEL, of Section 10, TllN, Rl0E, Umiat Meridian. This is in ADL 25648, wholly within the Kuparuk River Unit. Please contact Steve McKeever at (907) 265-6826, or email steve.mckeever@conocophillips.comif more information is needed regarding the spacing exception. Sincerely, Ç;l~v^- Jf!;ï/ -7)~ei Sharon Allsup-Drake Engineering Aide ,y ConocoPhillips Alaska , Post Office Box 100360 Anchorage, Alaska 99510-0360 May 17, 2004 J. P. Williams, Jr. ExxonMobil Alaska Production Inc. 3301 "c" Street, Suite 400 Anchorage, Alaska, 99503 Re: Application for Spacing Exception, West Sak Oil Pool WelllE-123 Ll To Whom it May Concerm: ConocoPhillips Alaska, Inc. has applied, on May 17, 2004, to the Alaska Oil and Gas Conservation Commission for a spacing exception for the wellbore to be designated lE-123Ll, under the terms of 20 MC 25.055. At total depth, the lE-123Ll well bore is expected to be 304 feet from the nearest point of "0" sand production in welllB-l01Ll (this point being the top of the liner in wellbore lB-l01Ll), a West Sak production well in the West Sak Oil Pool of the Kuparuk River Unit. This distance will bé less than . that mandated by Conservation Order 406A, Rule 3, which states, "Nominal spacing within:the pool will be 10 acres." .. The total depth location of lE-123 Ll is expected to be 528' FNL, 909' FEL, of Section 10, TllN, Rl0E, Umiat Meridian. This is in ADL 25648, wholly within the Kuparuk River Unit. Please contact Steve McKeever at (907) 265-6826, or email steve.mckeever@conocophillips.comif more information is needed regarding the spacing exception. Sincerely, . / Ç;(tf-/\- ~I/~? ~L~ Sharon Allsup-Drake ( Engineering Aide sCt,h!HEr' .nn~ r ?nnl - ConoC6~hinips Alaska ') Post Office Box 100360 Anchorage, Alaska 99510-0360 May 17, 2004 G. M. Forsthoff Chevron U.S.A. Inc. 11111 So. Wilcrest Dr. Houston, Texas 77099 Re: Application for Spacing Exception, West Sak Oil Pool WelllE-123 Ll To Whom it May Concerm: ConocoPhillips Alaska, Inc. has applied, on May 17, 2004, to the Alaska Oil and Gas Conservation Commission for a spacing exception for the wellbore to be designated lE-123Ll, under the terms of 20 MC 25.055. At total depth, the lE-123Ll well bore is expected to be 304 feet from the nearest point of "D" sand production in welllB-l01Ll (this point being the top of the liner in wellbore lB-l01Ll), a West Sak production well in the West Sak Oil Pool of the Kuparuk River Unit. This distance will be less than that mandated by Conservation Order 406A, Rule 3, which states, "Nominal spacing within the pool will be 10 acres." The total depth location of lE-123 Ll is expected to be 528' FNL, 909' FEL, of Section 10, TllN, Rl0E, Umiat Meridian. This is in ADL 25648, wholly within the Kuparuk River Unit. Please contact Steve McKeever at (907) 265-6826, or email steve.mckeever@conocophillips.comif more information is needed regarding the spacing exception. sinc~~7 ' çtu~~, 4;- ()4L Sharon Allsup-Drake Engineering Aide ~L:' ,""/" \.Y liit:-T' µ¡ ~Ii'~ .., R,i 200 ~ ðtAl"~1,~\J~\h.::L". d~)!\: J \:> _ ,t{ Conoc6Phillips Alaska ) Post Office Box 100360 Anchorage, Alaska 99510-0360 May 17, 2004 J. MacArthur Union Oil Company of California 909 West 9th Avenue Anchorage, Alaska, 99501 Re: Application for Spacing Exception, West Sak Oil Pool Well lE-123 Ll To Whom it May Concerm: ConocoPhillips Alaska, Inc. has applied, on May 17, 2004, to the Alaska Oil and Gas Conservation Commission for a spacing exception for the wellbore to be designated lE-123Ll, under the terms of 20 AAC 25.055. At total depth, the lE-123Ll well bore is expected to be 304 feet from the nearest point of "D" sand production in welllB-l01Ll (this point being the top of the liner in wellbore lB-l01Ll), a West Sak production well in the West Sak Oil Pool of the Kuparuk River Unit. This distance will be less than that mandated by Conservation Order 406A, Rule 3, which states, "Nominal spacing within the pool will be 10 acres." The total depth location of lE-123 Ll is expected to be 528' FNL, 909' FEL, of Section 10, TllN, Rl0E, Umiat Meridian. This is in ADL 25648, wholly within the Kuparuk River Unit. Please contact Steve McKeever at (907) 265-6826, or email steve.mckeever@conocophillips.comif more information is needed regarding the spacing exception. SincereIYV., . SJU/3'- Sharon Allsup-Drake Engineering Aide JIt-¡_'~'í L SCJ\'!N\\\EC H.!N ":: :1': ?n'ld #13 RE: Conservation orders ) ) Subject: RE: Conservation orders From: Keitha Kolvig. <kkolvig@faulknerbanfield.com> Date: Wed, 03 Aug 200507:33:25 -0800 To:. Helen·Warmah.<~èl~h;.:.,^,årman@adrn.in.stcltè.åk;(J.s::> Wo iJrø looking for 406, 406A and 406B. Th~~ attorney roquesting thøso said that not all 01 tt1ørn had høiJrlngs, but thoy rnigtlt 11i.\Ve accopto(j writtøn t~)stirnony and cornrnøntary. Thanks lor your tl~)lp. Keitha J. Kolvig Faulkner Banfield, P.C. One Sealaska Plaza, Suite 202 Juneau, AK 99801-1245 907.523.6134 Confidentiality Notice: This message is a confidential and privileged communication, intended only for the use of the individual or entity to whom it is addressed, and should not be read or used by anyone else. If you receive this message in error, please immediately notify us by return email or by collect call at (907) 586-2210, and delete the message from your system, retaining no hard copies. -"-'Origlnal Message----- From: Helen Warman [mallto:helen_warman@admin.state.ak.us] Sent: Tuesday, August 02,20059:09 AM To: Keitha Kolvig Subject: Re: Conservation orders We have the hard copy originals here. did you have an order number or any other information so I can research it? Keitha Kolvig wrote: I did look there. What I guess I'm looking for is the actual file that shows the "work-product" that lead up to the order. It's sort of like the work file that contains any notes, drafts. etc. Is that something you have there or on microfiche? Keitha J. Kolvig Faulkner Banfield, P.C. One Sealaska Plaza, Suite 202 Juneau, AK 99801-1245 907.523.6134 Confidentiality Notice: This message is a confidential and privileged communication, intended only for the use of the individual or entity to whom it is addressed, and should not be read or used by anyone else. If you receive this message in error, please immediately notify us by return email or by collect call at (907) 586-2210, and delete the message from your system, retaining no hard copies. -····Orlginal Message----- From: Helen Warman [mailto:helen warrnan@admln.state.ak.us] Sent: Tuesday, August 02, 20058:59 AM To: Keitha Kolvlg Subject: Re: Conservation orders Yes, we have the Conservation Orders here. Do you have the number(s) of the orders you need? Have you checked out website www.aoQcc.alaska.Qov yet? It also may be of some assistance to you. Please let me know exactly what you need and I will be happy to assist. Helen Keitha Kolvig wrote: My name is Keitha, and I work for the law firm of Faulkner Banfield, in Juneau. One of the attorneys I work with has requested I obtain copies of the public record on certain conservation orders. I contacted you in the hopes that you could point me in the right direction. Thanks for any help. Keitha J. Kolvig Faulkner Banfield, P.C. One Sealaska Plaza, Suite 202 Juneau, AK 99801-1245 907.523.6134 I Confidentiality Notice: This message is a confidential and privileged communication, intended only for the use of the individual or entity to whom it is addressed, and should not be read or used by anyone else. If you receive this message in error, please immediately notify us by return email or by collect call at (907) 586-2210, and delete the message from your system, retaining no hard copies. (!o I/o t;; L/O(P ft £tQ {ç f; ~~ ~ ~~ 1 of 1 ~/ 8/4/2005 8: 14 AM #12 .) -..,... ConocriP'hillips ) -.. John Cookson GKA Development Advisor Post Office Box 1 00360 Anchorage, Alaska 99510 ATO-1200 phone 907,265.6547 john.cookson@conocophillips.com May 22,2003 RECEIVED MAY 2 3 2003 Ms. Sarah H. Palin, Chair Alaska Oil and Gas Conservation Commission 333 W. ih Ave #100 Anchorage, Alaska 99501-3539 Alaska Oil & Gas Cons. Commission Anchorage RE: Requested Modifications to Kuparuk River AOGCC Unit Conservation Orders Pertaining to Automatic Shut-In Equipment. Dear Ms. Palin, In a letter dated February 6, 2003, ConocoPhillips Alaska, Inc. requested modifications to the subject AOGCC rules as they apply to Kuparuk River Unit Satellites. In a follow up meeting on March 3,2003, AOGCC staff requested that CP AI provide the specific language desired in the conservation orders. The proposed language is shown in Attachment 1. CP AI requests that this language replace the existing language shown in Attachment 2. We request that this change be made administratively. If you should have further questions or suggestions, feel free to contact me at any time. Sincerely, jJ~C~ (j John Cookson -.) .) Attachment 1 - Requested Language a, All wells capable of unassisted flow of hydrocarbons will be equipped with a fail-safe automatic surface safety valve, b, Water injection wells will be equipped with a double check valve arrangement or a single check valve plus a fail-safe automatic surface safety valve. c. Gas or MI injection wells will be equipped with a fail-safe automatic surface safety valve and a single check valve. d. Gas or MI injection wells must be equipped with a landing nipple at a depth which is suitable for the future installation of a down hole flow control device to control subsurface flow. Upon application by the operator, the Commission in its discretion may administratively approve exceptions to this rule. e. Surface safety valve systems must be maintained in good working order at all times and must be tested at six-month intervals or on a schedule prescribed by the Commission. RECEIVED MAY 2 3 2003 Alaska Oil & Gas Cons. Commission Anchorage ) -. ) ., Attachment 2 - Current Language TARN - C0430 Rule 6 Automatic Shut-in Equipment a. All wells capable of unassisted flow of hydrocarbons will be equipped with a fail- safe automatic surface safety valve, b. Injection wells will be equipped with a double check valve arrangement. c. Surface safety valves will be tested at six-month intervals. Tabasco -CO 435 Rule 6 Automatic Shut-in Equipment a. All wells capable of unassisted flow of hydrocarbons will be equipped with a fail- safe automatic surface safety valve. b. Injection wells will be equipped with a double check valve arrangement. c. Surface safety valves will be tested at six-month intervals. Meltwater -CO 456 Rule 5 Automatic Shut-in Equipment a. All wells must be equipped with a fail-safe automatic surface safety valve system capable of detecting and preventing an uncontrolled flow. b. The wells must be equipped with a landing nipple at a depth, which is suitable for the future installation of a downhole flow control device to control subsurface flow. c. Surface safety valve systems must be maintained in good working order at all times and must be tested at six-month intervals or on a schedule prescribed by the Commission. West Sak -CO 406 Rule 6 Automatic Shut-in Equipment (a) All wells capable of unassisted flow of hydrocarbons will be equipped with a fail-safe automatic surface safety valve. (b) Injection wells will be equipped with a double check valve arrangement. (c) Surface safety valves will be tested at six-month intervals. ....) ~ Co no co Phil lips Ii.-i) ,.. John Cookson GKA Development Advisor Post Office Box 1 00360 Anchorage, Alaska 99510 ATO-1200 phone 907,265,6547 john.cookson@conocophillips.com May 22, 2003 RECEIVED MAY 2 3 2003 Ms. Sarah H. Palin, Chair Alaska Oil and Gas Conservation Commission 333 W. ih Ave #100 Anchorage, Alaska 99501-3539 Alaska Oil & Gas Cons. Commission Anchorage RE: Requested Modifications to Kuparuk River Unit AOGCC Conservation Orders Pertaining to Annual Pressure Measurements. Dear Ms. Palin, In a letter dated February 6, 2003, ConocoPhillips Alaska, Inc. requested modifications to the subject AOGCC rules as they apply to the Kuparuk River Unit Satellites. In a follow up meeting on March 3, 2003, AOGCC staff requested that CP AI provide the specific language desired in the conservation orders. CP AI suggests language similar to that of the Kuparuk Participating Area (CO 432, Rule 8) as it provides the flexibility to obtain the proper and necessary data. This suggested language is shown in Attachment 1. The current language to be replaced is shown in Attachment 2. We request that this change be made administratively. If you should have further questions or suggestions, feel free to contact me at any time. Sincerely, (Jr í) {/¡/~~;; ~¡fCCOOkson ) -.. .,) Attachment 1 - Suggested Language (a) A bottom-hole pressure survey shall be taken on each well prior to initial sustained production. (b) The operator shall obtain pressure surveys as needed to effectively manage hydrocarbon recovery processes subject to an annual plan outlined in (d) of this rule. (c) Pressure surveys may consist of stabilized static pressure masurements at bottom-hole or extrapolated from surface, pressure fall- off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. (d) Data from the surveys required in this rule shall be filed with the Commission by April 1 of the subsequent year in which the surveys are conducted. Along with the survey submittal, the operator will provide a proposed survey plan for the upcoming year. Reservoir Pressure Report, Form 10-412, shall be utilized for all surveys with attachments for complete additional data. Data submitted shall include, but are not limited to, rate, pressure, time, depths, fluid gradient, temperature, and other well conditions necessary for complete analysis of each survey being conducted. The pool pressure datum plane shall be feet subsea. (e) Results and data from any special reservoir pressure monitoring techniques, tests, or surveys shall also be submitted as prescribed in (d) of this rule. (f) Upon application by the operator, the Commission in its discretion may administratively approve exceptions to this rule. Note: i) ii) For each satellite, the datum plane listed in (d) should reference the same datun1 as currently prescribed. The above language is identical to Kuparuk CO 432, Rule 8 except for part ( c) which is taken fron1 Tarn CO 430, Rule 8 RECEIVED MAY 2 3 2003 Alaska Oil & Gas Cons. Commission Anchorage ') -., ,,) Attachment 2 - Current Language TARN - C0430 Rule 8 Reservoir Pressure Monitorinq a. Prior to regular production or injection an initial pressure survey shall be taken in each well. b. A minimum of one bottom-hole pressure survey per producing or injecting governmental section shall be measured annually. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. c. The reservoir pressure datum will be 5200 feet subsea. d. Pressure surveys may consist of stabilized static pressure measurements at bottom-hole or extrapolated from surlace, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e. Data and results from pressure surveys shall be reported quarterly on Form 10- 412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412 but must be available to the Commission upon request. f. Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part (e) of this rule. Tabasco -CO 435 Rule 8 Reservoir Pressure Monitorinq a, Prior to regular production or injection an initial pressure survey shall be taken in each well. b. A minimum of one bottom-hole pressure survey per producing or injecting governmental section shall be measured annually. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. c. The reservoir pressure datum will be 3000 feet subsea. d. Pressure surveys may consist of stabilized static pressure measurements at bottom-hole or extrapolated from surlace, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e. Data and results from pressure surveys shall be reported quarterly on Form 10- 412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412 but must be available to the Commission upon request. f. Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part (e) of this rule, ~ J Attachment 2 (Continued) - Current Language Meltwater -CO 456 Rule 7 Reservoir Pressure Monitorinq a) Prior to regular production or injection, an initial pressure survey must be taken in each well. b) The minimum number of bottom-hole pressure surveys acquired each year will equal the number of governmental sections within the MOP that contain active wells. A minimum of four surveys will be required each year in representative areas of the MOP. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. c) The reservoir pressure datum will be 5,400 feet TVDss. d) Pressure surveys may be stabilized static pressure measurements at bottom-hole or extrapolated from surface (single phase fluid conditions), pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e) Data and results from all relevant reservoir pressure surveys must be reported quarterly on Form 10-412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412, but must be available to the Commission upon request. f) Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with paragraph (e) of this rule. West Sak -CO 406 Rule 8 Reservoir Pressure Monitorinq (a) Prior to regular production or injection an initial pressure survey shall be taken in each well except those equipped with a subsurface pump. (b) A minimum of one bottom-hole pressure survey per producing or injecting governmental section shall be measured annually. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. (c) The reservoir pressure datum will be 3500 feet subsea. (d) Pressure surveys may consist of stabilized static pressure measurements at bottom- hole or extrapolated from surface, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. (e) Data and results from pressure surveys shall be reported quarterly on Form 10-412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412 but must be available to the Commission upon request. (f) Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part (e) of this rule, .. . ... \.,) y ConocoPhiiii ps . ') -., John Cookson GKA Development Advisor Post Office Box 1 00360 Anchorage, Alaska 99510 ATO-1200 phone 907,265,6547 john.cookson@conocophillips.com May 22, 2003 Ms. Sarah H. Palin, Chair Alaska Oil and Gas Conservation Commission 333 W. ih Ave #100 Anchorage, Alaska 99501-3539 RE: Requested Modifications to Kuparuk River Unit AOGCC Conservation Orders Pertaining to Annual Reservoir Surveillance Reports. Dear Ms. Palin, In a letter dated February 6, 2003, ConocoPhillips Alaska, Inc. requested modifications to the subject AOGCC rules as they apply to the Kuparuk Participating Area and the other Kuparuk River Unit Satellites. In a follow up meeting on March 3, 2003, AOGCC staff requested that CPAI provide the specific language desired in the conservation orders. After further review, CP AI now requests that only the due date be changed in these rules. CP AI requests a common due date of April i which is consistent with the due date for the Kuparuk Field report. A common due date will ease the burden of writing and reviewing the annual reports for all involved. The suggested language is shown in Attachment 1. The current language is shown in Attachment 2. We request that this change be made administratively. If you should have further questions or suggestions, feel free to contact me at any time. Sincerely, () ~ord ~) .,) Attachment 1 - Suggested Language The Unit Operator will submit an Annual Surveillance Report by April 1 of each year. Data contained in the report will cover operations for the previous calendar year. The report will include but not be limited to the following information: (Existing list of information prescribed for each participating area) ..,) ) " Attachment 2 - Current Language TARN - C0430 Rule 11 Reservoir Surveillance Report A surveillance report will be required after one year of regular production and annually thereafter. The report shall include but is not limited to the following: Tabasco -CO 435 Rule 11 Reservoir Surveillance Report A surveillance report will be required after one year of regular production and annually thereafter. The report shall include but is not limited to the following: Meltwater -CO 456 Rule 10 Reservoir Surveillance Report An annual reservoir surveillance report for the prior calendar year will be required after one year of regular production and annually thereafter. The report shall include, but is not limited to, the following: West Sak -CO 406 Rule 11 Reservoir Surveillance Report A surveillance report will be required after one year of regular production and annually thereafter. The report shall include but is not limited to the following: ,ENDER: COMPLETE THIS SECTION I Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired, I Print your name and address on the reverse so that we can return the card to you, I Attach this card to the back of the mailpiece, or on the front if space permits, , Article Addressed to: rh· G. 11. ç=o"s~uff de"~OVl v. S. A. k. , t \\ t SO. lù~ t~>{~S+ Dr. +\ou S.\vVl I \ ljtt5 110'11 :, Art~ Number (Transfer from service label) 'S Form 3811 , August 2001 I mJ LIP~~,:::,ressee B. R~ed ::ìl"1"~ ":'"'ame) c. ~~ of Delive<y t'/ -r k \ L-e -lit ¡". / ~ 1---'1 D. Is delivery address different from item 1? D Ves If VES, enter delivery address below: D No 3~ice Type ~ertified Mail 0 Express Mail o Registered ~turn Receipt for Merchandise o Insured Mail D C,O,D. . 4, Restricted Delivery? (Extra Fee) Dyes · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: J1 {. '1. Jt ac A('flv( Ù\<\ ¡ 00\ D;! Co ....Fa....: I (4It. 101 tD. 1~ A~v~ Ät).c,kovð-9!-, Ælastt:L \J C(qçol 3,... ~ice Type ;:t9-Certified Mail _ Oppress Mail o Registered ~eturn Receipt for Merchandise o Insured Mail D C,O.D, 4, Restricted Delivery? (Extra Fee) Dves 2. Article Number 7 0 0 1 2 5 1 0 0 0 0 2 9 5 8 8 5 6 0 7 (Transfer from service labeO 102595-02-M-1540 . PS Form 3811 J August 2001 Domestic Return Receipt I l 7001 2510 OOO~ 9588 5591 Domestic Return Receipt ENDER: COMPLETE THIS SECTION I Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. I Print your name and address on the reverse so that we can return the card to you, I Attach this card to the back of the mailpiece, or on the front if space permits. . Article Addressed to: K'(.l). N ,'CO SOV\ -v"P 6T(OV"~lH" Mo.sÞ- ~OO £. ~~ B\vcl A...c1oVA~1 A-t 1'tÇQ8 , Article Number (Transfer from service label) '8 Form 3811, August 2001 7001 2510 Domestic Return Receipt '::':'"::?2i.:_~::~,~; ~~~.- c --c·_~~,---b·~,c";::~::;,,.~~'i ~,~~~ 102595-02-M-154 . IVery addr 1, Article Addressed to: ,..-.- ES, enter ~ 'J. P lJ;llio.t«.t ) JV-. < .;'\~ b)(OVl Mol7l( A[ltSk¡. ~ ~(k -hen.- 3. ~~i' 'e" sl-y~* S""~t~ ~rtìfìed Mail D Express Mail I A"...." D Registered XReturn Receipt for MerchandisE ( ( t ~ D Insured Mail 0 C,O.D, A\,\.c\A.ov'"-(f' Ma. <; IlL 't'i5D34. Restricted Deliveoy? (Extra Fee) 0 Yes 2, Article Number 70 0 1 2 5 1 0 0 0 0 2 9 S 8 8 5 6 1 4 (Transfer from service IOOeO 102595-02-M-1540 j PS Form 3811, August 2001 I ~-~-~~..~ A. Signature ~ l 'OAgent I X D Addressee I ___.... 1 B. "Kd bï!~r;:r7 ~t~; r;r I D. Is delivery address different from item 1?~ D vis ( I If YES, enter delivery address below: D No I I 3. Service Type ~ertified Mail D Express Mail - D Registered ~eturn Receipt for Merchandise D Insured Mail D C,O,D, 4. Restricted Delivery? (Extra Fee) Dves 0002 9588 5584 ~.. ! .~~~.Z~~-~~X~?--· - J","~.:"q,,,'1"~"''''''''~,_.._'''''--' COMPLETE THIS SECTION ON DELIVERY · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you, · Attach this card to the back of the mail piece, or on the front if space permits. A~i9 ~ X . 0 Agent D Addressee 8, Received by ( Printed Name) C. Date of Delive!) DYes D No 3"X>t Domestic Return Receipt 102595-D2-M-154 ~- ... c.. :- · sen~Please print your name, address, and ZIP+4 in this box· o ~ ~~a:01t¡\¡r5 Âlaste<.1w-. ~ rð100 ê¡ sV~t ~ ~ ;;:¡ A-",-clol{~ Ælas~ 1'[ çö) · I: 0 A-~~~: ~"O^ A[ ,$vr-1kA ~ po J>C"') ~ ~ n CA :::rC") ~ 0 Q) ~ cc c.. ctI . » First-Ctass Mai1 Postage & Fees Paid USPS Permit No. G-10 UNITED STATES POSTAL SERVICE ~~-~"':~~'õ:::-'_-_::"'~~"7~ ,.T~..l._ Er f! t '! I I ¡ I . i I ! ,I I 'J" I I I It II ¡ i' ddnlïli!d¡ 11 !1I!id IIIInlllll! It dulln" !II !!lIt ~..: :..-..--: .-..--: .. .. "".... -.... .. ""- ....:.. : ._....~._. .-. UNITED STATES POSTAL SERVIC~l'::5' " ; " - , ',' ..~. - Fìr:.st.:c1á5S~~ t ~ .- . POS~ge &1Fees Raid ¡"~ '. USP5r';I~ F-=- " ~ ....: , ~ , " ~ 'ff"'~!!l~J~;Y~1"'./ ' ;... ~. ~ . .' J.' _..J. -3.¡-<~L1I1t ,- v jl ie.... » "-' 'ìL I4A \ ' " - ' ~~--:;~,. , ~sender: ~ase prin - *áhì¿~dre55. and' ZIP:¡:'¡ in fhi~ ~~ . I. }--1 -. '-- IT C, T\ ( ~ c . · ~ ~ ; ci \A.oc-o (I I rs 1:\11,(. [~ I>:> IT! 1 00 ~ S.{¡~t ~:::I N < co ; ~ m it¡'{c~O(()..?f I Ar-- c¡-qçol I: 0 A+'(-~: ~v-o" A! ,çur-þvA;Itz. J II I I I I III II II I I II I 1 II II I II llduh ilih illuH!dlnHiïl!!lulhh !ill¡!!HH! ¡!!II - - ',,I- )Jr' " ,I-'I( "'.- -" ~-é'- ~ ~ · Sender: PleaSe..,Q!inl~/ru1r·name, addrèss-,-árrd-ZTP~~~ C~ ;tJ -.::.>"'... ~ 2 m G~a:.o "Fi.;{l;r A-Itts.b., lxc Þ::¡) :z () 1 /' ,~( ~;, ~ m OD L=::¡ Srrr-ee '\ -__~ ~ <: "Vtvko~ A let S k~ qC( ç~ I :JC)m rr , I. -f>o 0 M4t\; Otl. At (s'"'r-1)va-,u. õ' ::J First'-ClassMail Postage & Fees Paid USPS Pennit No.G-1 0 \. UNITED STATES POSTAL SÊRviêe ' --C"=-"_~-~ -' .,.-~c~..,,.c~- II I I I I I" I II , "' I 'I II II II, IIII ' I ' : , 'I' : I,' II : :: III ' I .¡ 'I ' . ·1 11'1 It II' : " : I ,II II: '1'1 . ! : t : I ; I ... ............ ....... .. ...... ...... ... .......... . , . ...~ » Q;III en ~ · sen~ Please print your name, address, and ZIP+4 in this box· ~ ~ COIAa-oß;[\;r5 .Jtlad~~k. ~ IT! 1CO ~ Wee-.(- ~ ~;;:¡ A-~JO{~ I M(ld~t(( 'rlS:ÇI I: 0 M-~t\: ~t.avc~ A[t~vrÞvoLlu- o ::J ~ ~ J>G) ~ Q. ('") "" :::TC") ~ 01 Q) == co ~ C'D . ~Mai Postage & Fee:s Paid ~ USPS Permit No. G-10 UNITED STATES POSTAL SERVICE #11 L:nm Li:lJ1~uagt: lor \..,v lVlooS J ~ Subject: Draft Language for CO Mods Date: Mon; 14 Apr 2003 17:43:37 -0800 From: "John Cookson" <John.Cookson@conocophillips.com> To: Tom_Maunder@admin.state.ak.us, jack_hartz@admin.state.ak.us, steve _ davies@admin.state.ak.us Tom, Jack, Steve Here's the drafts. Send me your comments/suggestions. Thanks, (See attached file: Kuparuk _ ASR Letter.doc) (See attached file: Kuparuk _ Pressure Surveys Letter.doc) (See attached file: Kuparuk Safety Valves Letter.doc) - ~ .". -, " _, '.IV, ... ~ , ·..··....w···..v·....· . . ...,,·"·..··T..··'·.....,...m....~.... ..... ................ ···10'··1'......·· ....~ ¡ Name: Kuparuk _ ASR Letter.doc I ~Kuparuk ASR Letter.docl Type: WlNWORD File (application/msword)1 ¡ Encoding: base64 ¡ ............Wo'''..". ........\0'.."'10'............,..........".............................. ....................11I................., .... ....·....·..·..·...···__......1....·.. ......... .. .. .............1'...\\10'......... o'.....t!!mlll\IV···"'·.....·'I!IIm~···...'..."'...t!I"!....."'I....\4!ly\lJ4II\"ltv.II:·····..·..!...It'I'\ltW·...'II~U'·....'III\Ltlln:...·"·w"I"LII'IIIIII\·IY......·~III'¡..··.. 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Name: Kuparuk _ Pressure Surveys Letter.doc i I ~Kuparuk Pressure Surveys Letter.doc Type: WlNWORD File (application/msword)¡ I ¡ Encoding: base64 ! ..,.."""""....,,,,"'.,,.........,,,,"',,,,,,"'.....,,,...,,,,,.,,,,"'....,,.,,,,,..,,,,,,"'........".,,,,,,,,,,"'......,...,"'.......,,,,..."',,,,,"'...".,,,,....,,,...,..."J.....""'""......".....",,,,,,,,,,,,"'...,.....,,,,,,,,"'.....,,"',..,.,,,,,,'"............."""'''''''....'''''..,...''''."...''.''''''........."..'''...............".."...."...",,,..............,,,,,,,,,,,,,,. t 1Y....·.........Àlllmll"I:.......-.v.v......·.....~\II~·""'\Y..·~IILlLHLIII:·.....·".....· . ..·..............I.....w....·...........,.......'-.:.............\oI...\oI......·Wlty,'...'ltl~......1¥LIII\IIII.....\(IIIIIIII' ............... v.....· ....II'+'( ....... ·1\01...\01"'1/1Io'oI1\11I111I)1...·\01....'..11I1111'....' ......11I...·"'11\11111·11I1\11I1..·\1'11I11I11)1....111 ... ........ )0' )1...."1. IlL:'" y'" ¡ Name: Kuparuk _ Safety Valves Letter.doc 1 ~Kuparuk Safety Valves Letter.dOC! Type: WINWORD File (application/msword)] l,,"'.... ....."",......."....,,,,,. ..........."",,,,,.,,.....,,,...,,,,,,,,,,,,,,,,,,.....,.,,....,,,.........,.,......,,,.",.."........"...,."""""",,,,,,J ,~.~..':~,~!.~~,~''',:?~.~~,?.~.."''''',....".."''"...,,.,'''''''''...,,,,,,,,,,..,,,,,,"",,..... ..""....."............."..,..""....""",,,i ~ ConocóP'hillips ~JOhn Cookson GKA Development Advisor Post Office Box 100360 Anchorage, Alaska 99510 ATO-1200 phone 907.265,6547 john.cookson@conocophillips,com April 11, 2003 Ms. Sarah H. Palin, Chair Alaska Oil and Gas Conservation Commission 333 W. ih Ave #100 Anchorage, Alaska 99501-3539 RE: Requested Modifications to Kuparuk River AOGCC Unit Conservation Orders Pertaining to Injection Well Surface Automatic Shut-In Equipment. Dear Ms. Palin, In a letter dated February 6, 2003, ConocoPhillips Alaska, Inc. requested modifications to the subject AOGCC rules as they apply to Kuparuk River Unit Satellites. In a follow up meeting on March 3, 2003, AOGCC staff requested that CP AI provide the specific language desired in the conservation orders. The desired specific language is shown in Attachment 1. CP AI requests that this language replace the existing language shown in Attachment 2. We request that this change be made administratively. If you should have further questions or suggestions, feel free to contact me at any time. Sincerely, John Cookson ~ ) . Attachment 1 - Requested Language a. All wells capable of unassisted flow of hydrocarbons will be equipped with a fail-safe automatic surface safety valve, b. Injection wells will be equipped with a double check valve arrangement or a single check valve plus a fail-safe automatic surface safety valve. c. Surface safety valve systems must be maintained in good working order at all times and must be tested at six-month intervals or on a schedule prescribed by the Commission. ) . ~ Attachment 2 - Current Language TA,RN - C0430 Rule 6 Automatic Shut-in Equipment a. All wells capable of unassisted flow of hydrocarbons will be equipped with a fail- safe automatic surface safety valve. b. Injection wells will be equipped with a double check valve arrangement. c. Surface safety valves will be tested at six-month intervals, Tabasco -CO 435 Rule 6 Automatic Shut-in Equipment a, All wells capable of unassisted flow of hydrocarbons will be equipped with a fail- safe automatic surface safety valve. b. Injection wells will be equipped with a double check valve arrangement. c. Surface safety valves will be tested at six-month intervals. Meltwater -CO 456 Rule 5 Automatic Shut-in Equipment a. All wells must be equipped with a fail-safe automatic surface safety valve system capable of detecting and preventing an uncontrolled flow. b. The wells must be equipped with a landing nipple at a depth, which is suitable for the future installation of a downhole flow control device to control subsurface flow. c. Surface safety valve systems must be maintained in good working order at all times and must be tested at six-month intervals or on a schedule prescribed by the Commission. West Sak -CO 406 Rule 6 Automatic Shut-in Equipment (a) All wells capable of unassisted flow of hydrocarbons will be equipped with a fail-safe automatic surface safety valve. (b) Injection wells will be equipped with a double check valve arrangement. (c) Surface safety valves will be tested at six-month intervals. ~ ConocóP'hiIIi ps " John Cookson GKA Development Advisor Post Office Box 100360 Anchorage, Alaska 99510 ATO-1200 phone 907.265,6547 john.cookson@conocophillips,com April 11, 2003 Ms. Sarah H. Palin, Chair Alaska Oil and Gas Conservation Commission 333 W. ih Ave #100 Anchorage, Alaska 99501-3539 RE: Requested Modifications to Kuparuk River Unit AOGCC Conservation Orders Pertaining to Annual Reservoir Surveillance Reports. Dear Ms. Palin, In a letter dated February 6, 2003, ConocoPhillips Alaska, Inc. requested modifications to the subject AOGCC rules as they apply to the Kuparuk Participating Area and the other Kuparuk River Unit Satellites. In a follow up meeting on March 3, 2003, AOGCC staff requested that CP AI provide the specific language desired in the conservation orders. After further review, CP AI now requests that only the due date be changed in these rules. CP AI requests a common due date of April 1 of each year. A common due date will ease the burden of writing and reviewing the annual reports for all involved. The suggested language is shown in Attachment 1. The current language is shown in Attachment 2. We request that this change be made administratively. If you should have further questions or suggestions, feel free to contact me at any time. Sincerely, John Cookson .,; ) . Attachment 1 - Suggested 'Language The Unit Operator will submit an Annual Surveillance Report by April 1 of each year. Data contained in the report will cover operations for the previous calendar year. The report will include but not be limited to the following infonnation: (Existing list of information prescribed for each participating area) ) . ) . Attachment 2 - Current Language TA.RN - C0430 Rule 11 Reservoir Surveillance Report A surveillance report will be required after one year of regular production and annually thereafter. The report shall include but is not limited to the following: Tabasco -CO 435 Rule 11 Reservoir Surveillance Report A surveillance report will be required after one year ot'regular production and annually thereafter. The report shall include but is not limited to the following: Meltwater -CO 456 Rule 10 Reservoir Surveillance Report An annual reservoir surveillance report for the prior calendar year will be required after one year of regular production and annually thereafter. The report shall include, but is not limited to, the following: West Sak -CO 406 Rule 11 Reservoir Surveillance Report A surveillance report will be required after one year of regular production and annually thereafter. The report shall include but is not limited to the following: Kuparuk - CO 1988 Rule 3, Kuparuk River Unit Reservoir Surveillance ProQram The Unit Operator will submit an annual report to the Commission on the Kuparuk River Unit oil pool development and enhanced recovery operations, The report will be submitted by April 1 of each year for the period ending December 31 and will include but not be linúted to the following information: .) . ConocóPhillips ) . John Cookson GKA Development Advisor Post Office Box 100360 Anchorage, Alaska 99510 ATO-1200 phone 907,265.6547 john,cookson@conocophillips,com April 11, 2003 Ms. Sarah H. Palin, Chair Alaska Oil and Gas Conservation Commission 333 W. 7th Ave #100 Anchorage, Alaska 99501-3539 RE: Requested Modifications to Kuparuk River Unit AOGCC Conservation Orders Pertaining to Annual Pressure Measurements. Dear Ms. Palin, In a letter dated February 6,2003, ConocoPhillips Alaska, Inc. requested modifications to the subject AOGCC rules as they apply to the Kuparuk River Unit Satellites. In a follow up meeting on March 3, 2003, AOGCC staff requested that CP AI provide the specific language desired in the conservation orders. CP AI suggests language similar to that of the Kuparuk Participating Area (CO 432, Rule 8) as it provides the flexibility to obtain the proper and necessary data. This suggested language is shown in Attachment 1. The current language to be replaced is shown in Attachment 2. We request that this change be made administratively. If you should have further questions or suggestions, feel free to contact me at any time. Sincerely, John Cookson ) . ) . Attachment 1. - Suggest.ed 'Language (a) A bottom-hole pressure survey shall be taken on each well prior to initial sustained production. (b) The operator shall obtain pressure surveys as needed to effectively manage hydrocarbon recovery processes subject to an annual plan outlined in (d) of this rule. (c) Pressure surveys may consist of stabilized static pressure masurements at bottom-hole or extrapolated from surface, pressure fall- off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. (d) Data from the surveys required in this rule shall be filed with the Commission by April 1 of the subsequent year in which the surveys are conducted. Along with the survey submittal, the operator will provide a proposed survey plan for the upcoming year. Reservoir Pressure Report, Form 10-412, shall be utilized for all surveys with attachments for complete additional data. Data submitted shall include, but are not limited to, rate, pressure, time, depths, fluid gradient, temperature, and other well conditions necessary for complete analysis of each survey being conducted. The pool pressure datum plane shall be feet subsea. (e) Results and data frqm any special reservoir pressure monitoring techniques, tests, or surveys shall also be submitted as prescribed in (d) of this rule. (f) Upon application by the operator, the Commission in its discretion may administratively approve exceptions to this rule. Note: i) ii) For each satellite, the datum plane lžsted in (d) should reference the same datum as currently prescribed. The above language is identical to Kuparuk CO 432, Rule 8 exceptfor part (c) which žs taken from Tarn CO 430, Rule 8 .,) ~ Attachment 2 - Current Language T.ARN - C0430 Rule 8 Reservoir Pressure Monitoring a. Prior to regular production or injection an initial pressure survey shall be taken in each well. b. A minimum of one bottom-hole pressure survey per producing or injecting governmental section shall be measured annually. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. c. The reservoir pressure datum will be 5200 feet subsea. d. Pressure surveys may consist of stabilized static pressure measurements at bottom-hole or extrapolated from surface, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e. Data and results from pressure surveys shall be reported quarterly on Form 10- 412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412 but must be available to the Commission upon request. f. Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part (e) of this rule. Tabasco -co 435 Rule 8 Reservoir Pressure Monitorinq a. Prior to regular production or injection an initial pressure survey shall be taken in each well. b. A minimum of one bottom-hole pressure survey per producing or injecting governmental section shall be measured annually. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. c. The reservoir pressure datum will be 3000 feet subsea. d. Pressure surveys may consist of stabilized static pressure measurements at bottom-hole or extrapolated from surface, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests, e. Data and results from pressure surveys shall be reported quarterly on Form 10- 412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412 but must be available to the Commission upon request. f. Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part (e) of this rule. .,) ~ Attachment 2 (Continued) - Current 'Language Meltwater -CO 456 Rule 7 Reservoir Pressure MonitorinQ a) Prior to regular production or injection, an initial pressure survey must be taken in each well. b) The minimum number of bottom-hole pressure surveys acquired each year will equal the number of governmental sections within the MOP that contain active wells. A minimum of four surveys will be required each year in representative areas of the MOP. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. c) The reservoir pressure datum will be 5,400 feet TVDss. d) Pressure surveys may be stabilized static pressure measurements at bottom-hole or extrapolated from surface (single phase fluid conditions), pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e) Data and results from all relevant reservoir pressure surveys must be reported quarterly on Form 10-412, Reservoir Pressure Report. All data necessary for analysis of each survey need not be submitted with the Form 10-412, but must be available to the Commission upon request. f) Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with paragraph (e) of this rule. West Sak -CO 406 Rule 8 Reservoir Pressure Monitoring (a) Prior to regular production or injection an initial pressure survey shall be taken in each well except those equipped with a subsurface pump. (b) A minimum of one bottom-hole pressure survey per producing or injecting governmental section shall be measured annually. Bottom-hole surveys in paragraph (a) may fulfill the minimum requirement. (c) The reservoir pressure datum will be 3500 feet subsea. (d) Pressure surveys may consist of stabilized static pressure measurements at bottom- hole or extrapolated from surface, pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. (e) Data and results from pressure surveys shall be reported quarterly on Form 10-412, Reservoir Pressure Report, All data necessary for analysis of each survey need not be submitted with the Form 10-412 but must be available to the Commission upon request. (f) Results and data from special reservoir pressure monitoring tests or surveys shall also be submitted in accordance with part (e) of this rule, #10 ... -- ALASKA OIL AND GAS CONSERVATION COMMISSION Date: \J\.c)...~" ~ \ e;,.",,()êJ ~ Time \ ~ 0 () MEETING-Subject 'L.'-")~Ñ~ ()~,,, ~~\<L~ NAME - AFFILIATION TELEPHONE (pLEASE PRINT) \Ð \\,",,\-\.c..~ Q \-~". /j&vf~ÎÍi ~~v\ C~ð k~ l G\tYQ \ S QŸ\~ \\". ". ¡ ~ÌI\~" lIÛ; l t ('4.~ <;CJv¡ ~G~L AC!r--cJ ~c.l:." C.PA-.t- cpA-T AD (1-C-( 1t ~ ""S - \ è>-.s-è) ,::::;;-. ~ -' J 023 C1 1<7 3 - ( 2- 3 :2- 1 (, 5"-" S'--{ T :l0Ç-(øL[-Lt 713 - / ?-2Ç;" #9 Kupa;r.uk .'1iver Unit Order Updates and Approvals ~ ) -- .) Subject: Kuparuk River Unit Order Updates and Approvals Date: Fri, 28 Feb 2003 11 :21: 16 -0900 From: Robert Crandall <Bob _ Crandall@admin.state.ak.us> Organization: DOA-AOGCC To: "Hartz, John" <jack_hartz@admin.state.ak.us>, "Maunder, Thomas" <tom _ maunder@admin.state.ak. us>, "Williamson, Mary" <jane_ williamson@admin.state.ak.us> CC: "Seamount, Dan" <dan_seamount@admin.state.ak.us> ~ Tom and Jack; On monday March 3 @ 11:00 John Cookson and crew will be coming over here to discuss requested modifications to a number of KRU orders. Your invited. Here are the key points I took away from a discussion with Tom and Jack yesterday; Much of this falls into the realm of housekeeping and general cleaning up. Some of the items are major enough so that the orders should be changed/ such as the Tarn AIO. Since a new notice will be required anyway (Jane has already noticed the production allocation) / we should include all the items in the new notice/ except production allocation. Operator Name- Standardizing the Annual Reservoir Surveillance Reports- we should be prepared to discuss what each report should include and dates for submittal. Annual Pressure Measurements-operator wants more flexibility/ to make pressure measurements fit for purpose in each pool Injection well Surface Automatic Shut-in Equipment- standardize for all pools production Allocation-Jane has done the technical work on this already. Tarn Vertical Pool Defintion-Will need an explanation/ ie intervals not . 'oiì/IA,}Searing in the pool area. J~~p,Recovery process- description of water interaction with the reservoir/ current testimony indicates reservoir is water sensitive.-confining zone thickness/ reservoir and confining zone fracture gradients-injection pressures/-recovery factors. uT§~2sco~revised pool area(current pool area includes a large eXPloratory}. area) - reservoir maps (structure / "net sand iso.) -recovery processes and, efficiency-future plans. . t>ff rJ6{~~...... ..-.-'-.'. /,) --. / I~,V~¡ 2" P /1ßrJ Òú--Jt.. ~, 1 ~.0 ()Je.ø? :55 V - Dðt~-e.e· Ct...$e. k~ Wt~' ~ - r~'I-r 55V(~ Øk a¡,'J'M..''j ø I ~l.l rf~ / v "-I ß ~~-~~",-_!£--~~-~~-~_:. ...... :;fJ', y 5fi.:.. ~ t ,/ .f"" ~,....,----~. A¿¡, ~..... Vç6 ò~ / ¿~J' C·o Jf'32- "B ~.- IVL ~ß0~ A P LA / ~. ~~0_.. _.- ...........--,... #8 ~ . Ryan Stramp Meltwater Coordinator Kuparuk Development Group y ConocoPhillips Alaska, Inc. 700 G Street, A TO-950 P,O, Box 100360 Anchorage, AK 99510-0360 Phone: (907)265-6806 Ryan.stramp@conocophillips,com February 6, 2003 i'·' ~ rr:' I: \!"" ~." v., Ms. Cammy Oechsli Taylor, Chair Alaska Oil and Gas Conservation Commission 333 W. 7th Ave #100 Anchorage, Alaska, 99501-3539 ('¡ 7' '2(')O,~< _, .. ,J Alast<a Oil & Gas Cons, Anchorage Re: Requested Modifications to Kuparuk River AOGCC Unit Conservation Orders and Area Injection Orders Dear Ms. Oechsli Taylor: On August 12, 2002, the Kuparuk River Unit Operator requested modifications to the West Sak, Tarn, Tabasco, and Meltwater Pool Rules to update the stipulated production allocation methodology for all the pools. On August 16, 2002, the AOGCC published public notice of a possible hearing on this topic to be held on September 18, 2002. We understand that no requests for a hearing were received, and that the AOGCC is considering taking administrative action to make the necessary changes to adopt the new production allocation methodology. ConocoPhillips Alaska staff and AOGCC staff have discussed additional changes to the various Pool Rules that may be efficient to make at the same time the production allocation changes are implemented. Follwing is a listing ConocoPhillips' suggested changes to be considered at this time: For All Pools (Kuparuk, West Sak, Tarn, Tabasco, and Meltwater) 1) Update the Operator name to: "ConocoPhillips Alaska, Inc." 2) Standardize the content and timing of the Annual Reservoir Surveillance Reports. 3) Standardize the requirements for number and location of annual pressure measurements. 4) Standardize requirements for surface automatic shut-in equipment for injection wells. 5) Update the production allocation methodology as requested in the August 12 memo. For the Tarn Pool Only 1) Adjust the vertical pool definition to eliminate the C-30, Arete, and Iceberg intervals. 2) Reflect that MW AG is now the predominant recovery mechanism. Following is a brief discussion of each of the requested changes. Operator Name ConocoPhillips Alaska, Inc. is the current operator for all Pools in the Kuparuk River Unit. Annual Reservoir Surveillance Reports Each of the satellite pools in the Kuparuk River Unit have requirements for annual reservoir surveillance reports in the Area Injection orders and/or Pool Rules, however, they are worded slightly differently, and have different numbers of requirements listed. The required timing of each is stated as ".. ..after one year of regular production and annually thereafter." Requested Modifications to Kuparuk i. AOGCC Unit ConselVation Orders and Area Iniecti_rders February 6, 2002 Page 2 of 3 ConocoPhillips Alaska would like for the AOGCC to draft a single set of requirements that will apply to all the Kuparuk River Unit satellite reservoirs, and set a common due-date for all the reports. ConocoPhillips suggests reports covering each calendar year be submitted by the first of April of the subsequent year. Annual Pressure Measurements Three different standards exist across the Unit. The West Sak and Tarn Pool Rules require one pressure measurement per year per developed section. The Meltwater Pool Rules require a number of measurements equal to the number of developed sections, however there is flexibility in the actual locations from which the pressures are measured. The intent is to still provide a representative distribution of data. The Kuparuk Pool Rules do not specify numbers or locations for the pressure measurements; however, they require that the Operator submit an annual proposal for pressure data gathering to the AOGCC. ConocoPhillips would like to see a single standard similar to the Kuparuk rule put in place for all the Pools. This version of the rule allows the Operator, in conjunction with the AOGCC, to develop a fit-for-purpose plan for each reservoir each year. Injection Well Surface Automatic Shut-In Equipment The requirements for surface automatic shut-in equipment for injectors are not currently consistent across the Kuparuk River Unit satellites. ConocoPhillips recommends that the rules pertaining to surface automatic shut-in equipment for injectors be modified to stipulate installations include either double check valves, or a single check valve plus a fail-safe automatic surface safety valve. Production Allocation Methodology See the attached memo dated August 12, 2002. Tarn Vertical Pool Definition At the time of the Tarn Pool Rules hearing, hydrocarbons had been confirmed in the Bermuda and Cairn intervals in the Tarn area, and the C30, Arete, and Iceberg intervals were all viewed to be prospective. The AOGCC includes all five geologic intervals in the vertical definition of the Tarn Oil Pool. Drilling results to date have failed to confirm developable hydrocarbons in the C30, Arete, or Iceberg intervals. If the AOGCC wishes to adjust the vertical definition of the Tarn Pool at this time to include only the Bermuda and Cairn intervals, the definition would need to be adjusted to reference the following depths from the Bermuda #1 well: "Bermuda" Interval "Cairn" Interval 5608' to 5542' MD 5452' to 5316' MD Tarn Recovery Process At the time of the Tarn Pool Rules and Area Injection Order hearings, the recovery process proposed for Tarn was MI (Miscible Injectant) injection only. Consideration had been given to utilizing a Miscible Water-Alternating-Gas (MWAG) process, however MWAG was not initially proposed due to concerns about water injection resulting in formation damage. Subsequent to the start-up of the Tarn field, small-scale field testing of water injection was undertaken. The field tests suggested that water could be successfully injected into the reservoir without loss of water or MI injectivity. Water was injected into the Tarn reservoir in a larger scale tests during the summers of 1999 and 2000, further confirming the ability to inject water into the Bermuda reservoir. Tarn has operated using MWAG continuously since the summer of 2001. The field continues to produce at high oil rates and low GORs under the MW AG process. ~ Requested Modifications to Kuparuk . AOGCC Unft ConselVStlon Orders and Area Inj~rders February 6, 2002 \ Page 3 of 3 ConocoPhillips now would like to request that the Tarn Pool Rules and Area Injection Order be modified to reflect that an MW AG process will be used and will result in further increased recoveries as compared to MI injection alone. ConocoPhillips staff would be happy to discuss changes to the Kuparuk River Unit Pool Rules and Area Injection orders with the AOGCC at your convenience. As I have recently moved to a new assignment within ConocoPhillips Alaska, please contact John Cookson at 265-6547 with any questions or to schedule further discussions about these topics. 7~ L ~~. Ryan L. Stramp Meltwater Project Coordinator Kuparuk Development Group ConocoPhillips Alaska Cc: John Cookson - ConocoPhillips Alaska Jeff Spencer - ConocoPhillips Alaska Jane Williamson - AOGCC #7 R"t: GKA PoOol Rules ~ Subject: Re: GKA Pool Rules Date: Tue, 01 Oct 200211 :00:53 -0800 From: Jane Williamson <Jane_ Williamson@admin.state.ak.us> To: Robert E Mintz <robert_mintz@law.state.ak.us>, John D Hartz <jack_hartz@admin.state.ak.us>, Robert P Crandall <bob_crandall@admin.state.ak.us> ~ One other thing in addition to changes noted They are requesting that the pool definition Arete, and Iceberg intervals. Jane below: be amended to delete the "C-30", Does this require public notice and chance for hearing. Jane williamson wrote: > Rob and Jack, > I am finalizing allocation technique changes for the Kuparuk Satellites, Tarn, > Meltwater, West Sak. In addition, I want to update the orders, which Kuparuk > appears to agree with. I have a couple of procedural questions that I want to > double-check with you. > > The changes (in addi tion to going to float-float technique for allocation) are > outlined below per Ryan's note to me. > > 1. Name change to Conoco Phillips Alaska, Inc. > 2. Reservoir Surveillance reports due at the same time > 3. Standardize distance from lease line to 500' per statewide regs (West > Sak had 300'). > 4. Standardize requirements for automatic SI equipment (note, I have a call > into Ryan on this one. I would prefer to go with most recent verbage requiring > a landing nipple, with installation of a downhole flow control device in MI > wells. > > Can we make these changes administratively, or do we need a formal application > or notice from the Commission (with a 30 day wait) . > > Jane > > Ryan L Stramp wrote: > > > Jane - > > > > Just a note to let you know that I have not forgotten this effort. I found > > our old mark-ups for the Tarn rule changes and I have talked to folks about > > West Sak and Tabasco. Here is a summary of the general changes I have > > identified: > > > > For All Pools > > Update operator name to Conoco Phillips Alaska, Inc > > Update Allocation Methodology > > Make all the Reservoir Surveillance reports due at the same time (much > > easier for us to remember and execute) > > Delete references to OOIP and estimated recovery (Tarn has gone > > up/Meltwater has gone down, but all will continue to change with time) > > Automatic Shut-in equipment - for injection wells allow for double > > check valves OR A FAIL-SAFE AUTOMATIC SURFACE SAFETY VALVE > > Standardize standoff from lease line with ownership change if the > > Commission feels this is necessary. > > > > Tarn Only > > Adjust vertical pool definition to delete the "C-30", Arete, and lir8: qKv\."p()ol Rules ~ .J > > Iceberg intervals. > > Change recovery mechanism to full MWAG (initially envisioned as MI > > injection only due to concerns wi water damage) > > Change required pressure measurements to a number equal to 1 annual > > measurement per section with a representative spread of the data points > > (Getting exactly one measurement per section is problematic in > > some cases when there is only one well in the section) > > > > How do we go about this process from here? Can you just administratively > > make these changes? Do you need a formal letter from us requesting the > > changes (beyond the allocation issues that have already been addressed)? > > > > Let me know how you would like to proceed. > > > > Ryan L. Stramp > > Meltwater Coordinator > > ATO-1150 > > 907-265-6806 ~~l:GKA }'sol Rules .,) Subject: Re: GKA Pool Rules Date: Tue, 01 Oct 2002 10:53:39 -0800 From: Jane Williamson <Jane_ Williamson@admin.state.ak.us> To: Robert E Mintz <robert_mintz@law.state.ak.us>, John D Hartz <jack_hartz@admin.state.ak.us> ) . Rob and Jack, I am finalizing allocation technique changes for the Kuparuk Satellites, Tarn, Meltwater, West Sak. In addition, I want to update the orders, which Kuparuk appears to agree with. I have a couple of procedural questions that I want to double-check with you. The changes (in addition to going to float-float technique for allocation) are outlined below per Ryan's note to me. 1. Name change to Conoco Phillips Alaska, Inc. 2. Reservoir Surveillance reports due at the same time 3. Standardize distance from lease line to 500' per statewide regs (West Sak had 300'). 4. Standardize requirements for automatic SI equipment (note, I have a call into Ryan on this one. I would prefer to go with most recent verbage requiring a landing nipple, with installation of a downhole flow control device in MI wells. Can we make these changes administratively, or do we need a formal application or notice from the Commission (with a 30 day wait) . Jane Ryan L Stramp wrote: > Jane - > > Just a note to let you know that I have not forgotten this effort. I found > our old mark-ups for the Tarn rule changes and I have talked to folks about > West Sak and Tabasco. Here is a summary of the general changes I have > identified: > > For All Pools > Update operator name to Conoco Phillips Alaska, Inc > Update Allocation Methodology > Make all the Reservoir Surveillance reports due at the same time (much > easier for us to remember and execute) > Delete references to OOIP and estimated recovery (Tarn has gone > up/Meltwater has gone down, but all will continue to change with time) > Automatic Shut-in equipment - for injection wells allow for double > check valves OR A FAIL-SAFE AUTOMATIC SURFACE SAFETY VALVE > Standardize standoff from lease line with ownership change if the > Commission feels this is necessary. > > Tarn Only > Adjust vertical pool definition to delete the "C-30", Arete, and > Iceberg intervals. > Change recovery mechanism to full MWAG (initially envisioned as MI > injection only due to concerns w/ water damage) > Change required pressure measurements to a number equal to 1 annual > measurement per section with a representative spread of the data points > (Getting exactly one measurement per section is problematic in > some cases when there is only one well in the section) > > How do we go about this process from here? Can you just administratively Ill!: GKA ;1'\>01 Rules > make these changes? > changes (beyond the D~OU need a formal letter from u~equesting the allocation issues that have already been addressed)? > > Let me know how you would like to proceed. > > Ryan L. Stramp > Meltwater Coordinator > ATO-1150 > 907-265-6806 #6 !..1:'ò,Vd:U.K,.A.POOI KUleSJ ~ Subject: [Fwd: GKA Pool Rules] Date: Wed, 25 Sep 2002 11 :29: 13 -0800 From: Jane Williamson <Jane_ Williamson@admin.state.ak.us> To: John D Hartz <jack_hartz@admin.state.ak.us> ~ Jack, Can we talk about this? Jane I.·,,,"·.··., ........~W'..............._ Subject: GKA Pool Rules Date: Wed, 25 Sep 2002 08:03:53 -0800 From: "Ryan L Stramp" <rstramp@ppco.com> To: Jane Williamson <Jane_ Williamson@admin.state.ak:.us> Jane - Just a note to let you know that I have not forgotten this effort. I found our old mark-ups for the Tarn rule changes and I have talked to folks about West Sak and Tabasco. Here is a summary of the general changes I have identified: For All Pools Update operator name to Conoco Phillips Alaska, Inc Update Allocation Methodology Make all the Reservoir Surveillance reports due at the same time (much easier for us to remember and execute) Delete references to OOIP and estimated recovery (Tarn has gone up/Meltwater has gone down, but all will continue to change with time) Automatic Shut-in equipment - for injection wells allow for double check valves OR A FAIL-SAFE AUTOMATIC SURFACE SAFETY VALVE Standardize standoff from lease line with ownership change if the Commission feels this is necessary. Tarn Only Adjust vertical pool definition to delete the "C-30", Arete, and Iceberg intervals. Change recovery mechanism to full MWAG (initially envisioned as MI injection only due to concerns w/ water damage) Change required pressure measurements to a number equal to 1 annual measurement per section with a representative spread of the data points (Getting exactly one measurement per section is problematic in some cases when there is only one well in the section) How do we go about this process from here? Can you just administratively make these changes? Do you need a formal letter from us requesting the changes (beyond the allocation issues that have already been addressed)? Let me know how you would like to proceed. Ryan L. Stramp Meltwater Coordinator ATO-1150 907-265-6806 #5 [F wd: Production Allocation Conservation Order (" J Kuparuk Satellites] \ J Subject: [Fwd: Production Allocation Conservation Order Change - Kuparuk Satellites] Date: Sun, 08 Sep 2002 11 :40: 19 -0800 From: Cammy Oechsli Taylor <Cammy_Taylor@admin.state.ak.us> Organization: DOA-AOGCC To: Jody Colombie <jody _ colombie@admin.state.ak.us> CC: Dan Seamount <dan:.-seamount@admin.state.ak.us> Jody, OK to vacate hearing Jane Williamson wrote: > > Canuny and Dan, > Phillips applied for modification to Pool rules governing allocation of > production by letter dated August 12, 2002. Their application was > noticed wi th a comment period ending Sep.. 2, 2002. There have been no > requests for a hearing and no comments. I believe we have sufficient > information upon which to make a ruling, and unless you see a need for a > hearing, I recommend vacating the hearing which had been set for > September 18. > > The specific orders which PAI requests revision to include: > West Sak Conservation Order 406 Rule 7 > Tarn Conservation Order 430 Rule 7 > Tabasco Conservation Order 435 Rule 7 > Meltwater Conservation Order 456 Rule 6 > > The change in rules would set the allocation of production among the > Satellites and Kuparuk River Oil Pool to a "float-float" system. What > that means is if there is a difference in the total "theoretical" > production calculated from well tests vs. LACT sales volumes, a > modification, or allocation factor is determined and applied equally > among all pools, and each wells theoretical production by well tests > would be modif~ed by that factor. The first 3 orders (CO 406, 430 and > 435) called for interim allocation factor of 1.0 for the satellites > (called the "fixed-float" method), meaning the Kuparuk River Oil Pool > took all the adjustment, there was no adjustment made to the well > production values from the Satellites. Last year there were > negotiations between DOR and PAI to change the allocation factor to > "float-float" upper limit of 1.02 for the satellites' allocation factor > was set tin the Meltwater documents, and was specified by the DNR for > the Greater Kuparuk area in their November 7, 2001 Advance Meltwater ELF > Ruling. The AOGCC approved this same methodology for a trial period for > Meltwater for 1 year in Rule 6 of CO 456, and stated that a hearing > would be held on September 12, 2002 to review the allocation quality > under the float-float methodology with the 1.02 cap. > > PAI shifted to the float-float methodology in January 2002. > Representatives of the AOGCC, DNR and DOR reviewed the first six months > of > allocation data under this method on July 30. The transition to capped > float-float was smooth and nearly invisible, and had very little > apparent effect on any property. The allocation factor has been running > very close to 1.0 (.975). No one voiced objection to going to this > allocation technique as a permanent method. The float-float methodology > is consistent with the recent Borealis decision, and methodology > approved for Greater Point McIntyre and Milne Point Unit. > > Both Jack and I think, however, the the cap of 1.02 is arbitrary and > unfounded. But, the allocation factor has not run that high in a few > years, and I anticipate it will be a rare occasion for it to go above 1 of2 9/8/2002 12:53 PM [Fwd: Production Allocanon Conservanon OrderC'J Kuparuk Satellites] \. ~ > 1. 02. PAI does not care to push the issue. > > I am also working with Ryan Stramp to see if there is any clean up of > other rules within these orders that should/could be done (for items > that shouldn't require a notice), and I will poll the staff on this. We > are not planning on attacking consolidation of the Kuparuk River Oil > Pool rules during this go-round, but I can start that discussion as > well. > > Let me know if you have questions. > > Jane Cammy Oechsli Taylor <cammy taylor(ã¿admin.state.ak.us> Commissioner Alaska Oil and Gas Conservation Commisison Department of Administration 20f2 9/8/2002 12:53 PM #4 ro~uction Allocation Conservation Order Change - v '''ruk Satellites 1~., . .. .) .) Subject: Production Allocation Conservation Order Change - Kuparuk Satellites Date: Thu, 05 Sep 2002 10:26:31 -0800 From: Jane Williamson <Jane_ Williamson@admin.state.ak.us> Organization: Alaska Oil & Gas Conservation Commission To: Camille 0 Taylor <cammy_taylor@admin.state.ak.us>, Daniel T Seamount JR <dan_seamount@admin.state.ak.us> CC: John D Hartz <jack_hartz@admin.state.ak.us>, Stephen F Davies <steve_davies@admin.state.ak.us>, Jody J Colombie <jody_colombie@admin.state.ak.us> Cammy and Dan, Phillips applied for modification to Pool rules governing allocation of production by letter dated August 12, 2002. Their application was noticed with a comment period ending Sep.. 2, 2002. There have been no requests for a hearing and no comments. I believe we have sufficient information upon which to make a ruling, and unless you see a need for a hearing, I recommend vacating the hearing which had been set for September 18. The specific orders which PAI requests revision to include: West Sak Conservation Order 406 Rule 7 Tarn Conservation Order 430 Rule 7 Tabasco Conservation Order 435 Rule 7 Meltwater Conservation Order 456 Rule 6 The change in rules would set the allocation of production among the Satellites and Kuparuk River Oil Pool to a "float-float" system. What that means is if there is a difference in the total "theoretical" production calculated from well tests vs. LACT sales volumes, a modification, or allocation factor is determined and applied equally among all pools, and each wells theoretical production by well tests would be modified by that factor. The first 3 orders (CO 406, 430 and 435) called for interim allocation factor of 1.0 for the satellites (called the "fixed-float" method), meaning the Kuparuk River Oil Pool took all the adjustment, there was no adjustment made to the well production values from the Satellites. Last year there were negotiations between DOR and PAI to change the allocation factor to "float-float" upper limit of 1.02 for the satellites' allocation factor was set tin the Meltwater documents, and was specified by the DNR for the Greater Kuparuk area in their November 7 ~01 AdvariceMeltwater ELF ~ling. _ The AOGCC approved this "s~·':.~~.~1~~~~~9.l~~1:§£·~'ã:F~<>~,f.:]?:~.Ei,§2"~,!.~~~,, Meltwater for 1 ÿear--rrr·1~tI'ì·ê-··6-6f CO 456, and stated that a hearing wôüld,,,w:b~-"h;;ìd onšépFèTñbê'Ç"'ï272õõ2''''''to-'i-ëvfew the - afj.'õê'"ã"t'iõñqüã'iity uIÎde":r····"t'iïè··..·t"iõã£ - floaE''"''metî1õd:õ!ògy with the 1.02 cap. ¡ '\PAI shifted to the float-float methodology in January 2002~ Representatives of the AOGCC, DNR and DOR reviewed the first six months !of allocation data under this method on July 30. The transition to capped float-float was smooth and nearly invisible, and had very little apparent effect on any property. The allocation factor has been running very close to 1.0 (.975). No one voiced objection to going to this allocation technique as a permanent method. The float-float methodology is consistent with the recent Borealis decision, and methodology approved for Greater Point McIntyre and Milne Point Unit. Both Jack and I think, however, the the cap of 1.02 is arbitrary and unfounded. But, the allocation factor has not run that high in a few years, and I anticipate it will be a rare occasion for it to go above 1.02. PAI does not care to push the issue. r am also working with Ryan Stramp to see if there is any clean up of \\ OVÅJ4I oit~ (þ(¡.l"" ~ ;f .;~--¡;.... ....----. w...·· ,....... ~..... ~.._.... - }-~ U"_u..~ ~ . other rules within these orders that should/could be done (for items that shouldn't require a notice), and I will poll the staff on this. We are not planning on attacking consolidation of the Kuparuk River oil Pool rules during this go-round, but I can start that discussion as well. Let me know if you have questions. Jane #3 AO,FRM Publisher/Original Copies: Department Fiscal, Department, Receiving 02-902 (Rev, 3/94) r~:~~1r~ ~~!/ 73540 NMR DIST LlO FY ACCT PAGE 1 OF TOTAL OF 2 PAGES ALL PAGES$ COMMENTS 2 3 4 REQUISITIONED BY~ () A n . J i~{ O1·vJ- I 02140100 03 LC CC SY REF TYPE 1 VEN 2 ARD 3 4 FIN AMOUNT PGM 02910 .SEND INVOICE IN TRIPLlCAT.E AOGCC, 333 W. 7th Ave" Suite 100 TO Anchorage, AK 99501 NUMBER AMOUNT DATE SEE ATTACHED PUBLIC HEARING Account #STOF0330 Advertisement to be published was e-mailed D Classified DOther (Specify) THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: (907) 793 ~ 1 ?,?1 DATES ADVERTISEMENT REQUIRED: August 16, 2002 August 15,2002 PCN AGENCY CONTACT lody Colombie PHONE DATE OF A.O, D Display Type of Advertisement X Legal ¿ Anchorage Daily News POBox 149001 Anchorage,AJ( 99514 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AJ( 99501 M \ } NOTICE TO PUBLISHER ~ INVO"'ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER .. cRTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHE COpy OF ADVERTISEMENT MUST BE SUBMITIED WITH INVOICE STATE OF ALASKA ADVERTISING ORDER . SEESOTTOM 'FORINVOIC~ ADDRESS . AO-02314008 ADVERTISING ORDER NO. J ~ Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Modification to Pool Rules Governing Allocation of Production West Sak Conservation Order 406 Rule 7 Tam Conservation Order 430 Rule 7 Tabasco Conservation Order 435 Rule 7 Meltwater Conservation Order 456 Rule 6 Phillips Alaska, Inc. by letter dated August 12, 2002, has applied for a modification to the above referenced Conservation Orders pertaining to methods of allocation of production among Kuparuk River Unit Oil Pools. The Commission has tentatively set a public hearing on this application for September 18, 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 2, 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 the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on September 16, 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 18, 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 5, 2002. ~ ¡[)ukL ~~ Cammy cAchsli Taylor Chair Published Date: August 16, 2002 ADN AO# 02314008 ~nChOrage Daily News Affidavit of Publication ~ 1001 Northway Drive, Anchorage, AK 99508 PRICE OTHER OTHER OTHER OTHER OTHER GRAND AD# DATE PO ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 531105 08/16/2002 023114008 STOF0330 $142.48 $142.48 $0.00 $0.00 $0.00 $0.00 $0.00 $142.48 STATE OF ALASKA THIRD JUDICIAL DISTRICT Noticeöf P ~bl¡ë Hearing' I , , . :'STATE OF ALASKA , AlaSka'Olland Glas Conservation Commission 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 foregoing publication is not in excess of the rate charged private individuals. r~ s:i ~ J , , Re: Modification to Pool Rules Governing AllOCQtion of Production , West Sak Coriservat~on Order 406 Rule 7 Tarn ConservQtion Order 430 Rule '7 Tabasco Conservation, Order 435 Rule7 , MeltI,Voter cons,rvation Order 456 Rule 6 , Phillips Alaska, lric, by letter dated August 12, 20Ô2, has applied for~:a'modlf¡cation to the àbove' referenced Conserv\:1tlon Orders pertaining to methods,'of allocatiQn of production amongKu- paruk River UnlfOIl po~ls, . .1 :1,"', . TheCommiss¡(rh· has tentcitivel~ seta public hearing on this QPpllcation for September 1 B, 2002 at 9:00 am at the Alaska 011 and Gas ConserllQtion Commission at 333 Wést 7th Avenue, Suite 100, An- chorage! Alaska 99501, A person maY request that the tentatlve:IY schec;luled hearing 'be h~ld by filing a written request with the Commission no later thaI'14:30, pm on ~ePtember.~,2092, If a request for a hearing,is not timely filed, the 'Commission will consider the issuance of an order without à hearing. Tòlearn If the Commission wiH hold the public hearing, please call 793-1221. I n addition, a persón ,may submit written com· ments regarding thi~ .qppllcal ion to Ir..," Ala,>ko Oil and Gas Conservat\6n, Commission 01 JJ3 WE''i>' 7th Avehue, Suite 100; Anchora9o: L\loska 99501. INrI!, Yen comme'nts ,rríu~t.be received no later than 4:30. ,pm on Septemb~r ,l~;2p02 e~cept tl1at if the Çom- ',mission dec1des to t)oi!I a pUblic hearing, written comments must be rec;eived no I~ter than 9:,00 am on SeptemberlB, 2~~~,r; ....... '. ....... ..' . Jfvou area personwith.adisablIitYvltho may, need a special modlfication.inor:der tOCOn'll11ent or .to attencjthe publicheari ng,' please cO.l1tact)od~ ÇOlor¡¡,b,lecjt79;3-1221 before September 5, 2002", ., Cammy Oechsll :TaYlor ,(ho iI", Signed Subscribed and :fPF ;;:..fore this date: Notary Public in and for the State of Alaska, Third Division. Anchorage, Ala~:; /! h MY COMMISSION EXPIR S: fj '2f¡ð ---/l . / C!4'if); f-~~/ c \ \ t { ('J!..1J-.lr7~ \,\\,\ ~,,:\~. ~'. 0,;/,;",...... ~ OC:J·· --- " ~:t.,.. ~~:~OTARj;.. ~ ~ . ~ --- ~ ~ : ÞuS\..\C : ê ~..~ __~:£J:::: -.:?t . cv~ ~~:-y.. ··~OF ..'~':\, ~;% . . . . . \#.\"\' "',' ..:bnE'~~ ,\ i' J,"..'.. \'~, Publ ish:. August16i 2002 00#0231.1400B STATE OF ALASKA ADVERTISING ORDER ;,$~E;;B;~:m-~Mi<~Ø;~:;~~"Ø,!¢S;A" . J NOTICE TO PUBLISHER \ J INVOICE MUST BE IN lRlPUCATE SHOWING ADVERTISING ORDER N_TIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COpy OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE F AOGCC 333 West ih Avenue, Suite 100 o J\nchorage,AJ( 99501 M R T o J\nchorage Daily News POBox 149001 J\nchorage,i\J( 99514 ADVERTISING ORDER NO. AO-02314008 AGENCY CONTACT DATE OF A.O. Jody Colombie Au~st 15, ?OO? PHONE pcNr (907) 793 -1 ?? 1 DATES ADVERTISEMENT REQUIRED: August 16, 2002 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Account #STOF0330 AFFIDAVIT OF PUBLICATION REMINDER United states of America State of ss division, Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that he/she is the of Published at in said division 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) Page 2 INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMllTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. and AO,FRM PUBLISHER Re: Advertising Order J .. Subject: Re: Advertising Order Date: 15 Aug 2002 11 :33 :23 -0800 From: Lorene Solivan <lsolivan@adn.com> To: lody Colombie <jody_colombie@admin.state.ak.us> Thank you Jody, all is good to go. Lorene 257-4296 On Thursday, August 15, 2002, Jody Colombie <jody_colombie@admin.state.ak.us> wrote: >Lorene: > >Please publish the attached order Friday August 16, 2002. Confirm with >e-mail. Thank you. Jody > 1 of 1 8/15/2002 2: 19 PM John Katz State of Alaska Alaska Governor's Office 444 North Capitol St., NW, Ste 336 Washington, DC 20001 Alfred James 107 North Market Street, Ste 1000 Wichita, KS 67202-1822 Conoco Inc. PO Box 1267 Ponca City, OK 74602-1267 Gregg Nady Shell E&P Company Onshore Exploration & Development PO Box 576 Houston, TX 77001-0576 G, Scott Pfoff Aurora Gas, LLC 10333 Richmond Ave, Ste 710 Houston, TX 77042 William Holton, Jr, Marathon Oil Company Law Department 5555 San Fecipe St. Houston, TX 77056-2799 Chevron USA Alaska Division PO Box 1635 Houston, TX 77251 Chevron Chemical Company Library PO Box 2100 Houston, TX 77252-9987 James White Intrepid Prod, Co./Alaskan Crude 4614 Bohill SanAntonio, TX 78217 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 J Daniel Donkel 2121 North Bayshore Drive Ste 1219 Miami, FL 33137 Christine Hansen Interstate Oil & Gas Compact Comm Excutive Director PO Box 53127 Oklahoma City, OK 73152 Mir Yousufuddin US Department of Energy Energy Information Administration 1999 Bryan St., Ste 1110 Dallas, TX 75201-6801 Michael Nelson Purvin Gertz, Inc, Library 600 Travis, Ste 2150 Houston, TX 77002 G. Havran Gaffney, Cline & Associations Library 1360 Post Oak Blvd" Ste 2500 Houston, TX 77056 T,E, Alford ExxonMobilExploration Company PO Box 4778 Houston, TX 77210-4778 W. Allen Huckabay Phillips Petroleum Company Exploration Department PO Box 1967 Houston, TX 77251 Shawn Sutherland Unocal Revenue Accounting 14141 Southwest Freeway Sugar Land, TX 77478 Doug Schultze XTO Energy Inc, 3000 North Garfield, Ste 175 Midland, TX 79705 Scott Webb Ocean Energy Resources, Inc. 1670 Broadway, Ste 2800 Denver, CO 80202-4826 .. SD Dept of Env & Natural Resources Oil and Gas Program 2050 West Main, Ste #1 Rapid City, SD 57702 Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Mary Jones XTO Energy, Inc, Cartography 810 Houston St., Ste 2000 Ft. Worth, TX 76102-6298 Paul Walker Chevron 1301 McKinney Rm 1750 Houston, TX 77010 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Texico Exploration & Production PO Box 36366 Houston, TX 77236 Donna Williams World Oil Statistics Editor PO Box 2608 Houston, TX 77252 Kelly Valadez Tesoro Refining and Marketing Co, Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Jerry Hodgden Hodgden Oil Company 408 18th St. Golden, CO 80401-2433 John Levorsen 200 North 3rd St. , #1202 Boise, ID 83702 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Duane Vaagen Fairweather 715 L St., Ste 7 Anchorage, AK 99501 Steve E. Mulder Dorsey & Whitney 1031 West 4th Ave" Ste 600 Anchorage, AK 99501 Robert Mintz State of Alaska Department of Law 1031 West 4th Ave" Ste 200 Anchorage, AK 99501 Tim Ryherd State of Alaska Department of Natural Resources 550 West 7th Ave" Ste 800 Anchorage, AK 99501 Mark Wedman Halliburton 6900 Arctic Blvd, Anchorage, AK 99502 John Harris NI Energy Development Tubular 3301 CSt., Ste 208 Anchorage, AK 99503 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Greg Noble Bureau of Land Management Energy and Minerals 6881 Abbott Loop Rd Anchorage, AK 99507 j Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Thor Cutler OW-137 US EPA egion 10 1200 Sixth Ave. Seattle, WA 98101 Julie Houle State of Alaskan DNR Div of Oil & Gas, Resource Eva!. 550 West 7th Ave., Ste 800 Anchorage, AK 99501 Richard Mount State of Alaska Department of Revenue 500 West 7th Ave., Ste 500 Anchorage, AK 99501 Susan Hill State of Alaska, ADEC EH 555 Cordova St. Anchorage, AK 99501 Jim Arlington Forest Oil 310 K St., Ste 700 Anchorage, AK 99501 Mark Dalton HDR Alaska 2525 CSt., Ste 305 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Judy Brady Alaska Oil & Gas Associates 121 West Fireweed Lane, Ste 207 Anchorage, AK 99503-2035 Jeff Walker US Minerals Management Service Regional Supervisor 949 East 36th Ave" Ste 308 Anchorage, AK 99508 ~ John F, Bergquist Babson and Sheppard PO Box 8279 Long Beach, CA 90808-0279 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Williams VanDyke State of Alaska Department of Natural Resources 550 West 7th Ave" Ste 800 Anchorage, AK 99501 Cammy Taylor 1333 West 11th Ave, Anchorage, AK 99501 Ed Jones Aurora Gas, LLC Vice President 1029 West 3rd Ave" Ste 220 Anchorage, AK 99501 Trustees for Alaska 1026 West 4th Ave" Ste.201 Anchorage, AK 99501-1980 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Mark Hanley Anadarko 3201 CSt, Ste 603 Anchorage, AK 99503 Arlen Ehm 2420 Foxhall Dr. Anchorage, AK 99504-3342 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Rose Ragsdale Rose Ragsdale & Associates 3320 E, 41st Ave Anchorage, AK 99508 Chuck O'Donnell Veco Alaska,lnc. 949 East 36th Ave" Ste 500 Anchorage, AK 99508 Gordon Severson 3201 Westmar Cr, Anchorage, AK 99508-4336 Perry Markley Alyeska Pipeline Service Company Oil Movements Department 1835 So, Bragaw - MS 575 Anchorage, AK 99515 Jeanne Dickey BP Exploration (Alaska), Inc, Legal Department PO Box 196612 Anchorage, AK 99518 J. Brock Riddle Marathon Oil Company Land Department PO Box 196168 Anchorage, AK 99519-6168 BP Exploration (Alaska), Inc. Land Manager PO Box 196612 Anchorage, AK 99519-6612 Shannon Donnelly Phillips Alaska, Inc, HEST -Enviromental PO Box 66 Kenai, AK 99611 Penny Vadla Box 467 Ninilchik, AK 99669 John Tanigawa Evergreen Well Service Company PO Box 871845 Wasilla, AK 99687 J Jim Scherr US Minerals Management Service Resource Evaluation 949 East 36th Ave" Ste 308 Anchorage, AK 99508 Richard Prentki US Minerals Management Service 949 East 36th Ave., 3rd Floor Anchorage, AK 99508 Jim Ruud Phillips Alaska, Inc, Land Department PO Box 100360 Anchorage, AK 99510 Jordan Jacobsen Alyeska Pipeline Service Company Law Department 1835 So. Bragaw Anchorage, AK 99515 David Cusato 600 West 76th Ave" #508 Anchorage, AK 99518 Kevin Tabler Unocal PO Box 196247 Anchorage, AK 99519-6247 Dudley Platt D,A, Platt & Associates 9852 Little Diomede Cr, Eagle River, AK 99577 Kenai Peninsula Borough Economic Development Distr PO Box 3029 Kenai, AK 99611 Claire Caldes US Fish & Wildlife Service Kenai Refuge PO Box 2139 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 ') " Thomas R. Marshall, Jr, 1569 Birchwood Street Anchorage, AK 99508 Paul L, Craig Trading Bay Energy Corp 5432 East Northern Lights, Ste 610 Anchorage, AK 99508 Kristen Nelson IHS Energy PO Box 102278 Anchorage, AK 99510-2278 Robert Britch, PE Northern Consulting Group 2454 Telequana Dr, Anchorage, AK 99517 Tesoro Alaska Company PO Box 196272 Anchorage, AK 99519 Sue Miller BP Exploration (Alaska), Inc, PO Box 196612 Anchorage, AK 99519-6612 Bob Shavelson Cook Inlet Keeper PO Box 3269 Homer, AK 99603 James Gibbs PO Box 1597 Soldotna, AK 99669 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 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 _J Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Senator Loren Leman State Capitol Rm 113 Juneau, AK 99801-1182 -t Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 #2 ,} ~ PHilliPS Alaska, Inc. A Subsidiary of PHILLIPS PETROLEUM COMPANY August 12, 2002 Ms. Cammy Oechsli Taylor, Chair Alaska Oil and Gas Conservation Commission 333 W. 7th Ave #100 Anchorage, Alaska, 99501-3539 Re: Requested Modifications to Kuparuk River AOGCC Unit Conservation Orders Pertaining to Methods of Allocation of Production Among Kuparuk River Unit Oil Pools Dear Ms. Oeçhsli Taylor: Phillips Alaska, Inc. as Operator of the Kuparuk River Unit, requests the Alaska Oil and Gas Conservation ComlI1ission make modifications to Conservation Orders 406 (West Sak), 430 (Tarn), 435 (Tabasco), and 456 (Meltwater) necessary to adopt the Greater Kuparuk Area interim production allocation methodology described in Order 456. Orders 406, 430, and 435 as originally approved, prescribe a production allocation process that sets the allocation factor for these first three satellites pool (West Sak, Tam, and Tabasco) to a value of 1.0. Adjustments to balance "theoretical" monthly production rates with actual sales volumes are made in the Kuparuk Pool values. This scheme has been referred to as the "fixed- float" method because the satellite production is fixed at theoretical values, and all "float" takes place in the Kuparuk production. A different scheme was proposed prior to Meltwater administrative approvals and development in 2001. This alternative scheme called for the adjustments between the total theoretical production and actual sales volumes take place in satellite production and the Kuparuk production. This general scheme has been referred to as the "float-float" methodology, since both the satellite and Kuparuk production values float to make up the differences between theoretical and actual production. An upper limit of 1.02 for the satellites' allocation factor was set in the Meltwater documents. I will refer to this as the "capped float-float" methodology or scheme. RECFt\/ED t\Ur3 .,! 2 2002 k O·! &·····s {'ons GomrniSS\Or¡ Aias a It \::0.- v ¡ . Anchorage .} .. Requested Modifications to Kuparuk River AOGCC Unit Conservation Orders Pertaining to Methods of Allocation of Production Among Kuparuk River Unit Oil Pools August 12, 2002 Page 2 The capped float-float methodology was specified by the Alaska Department of Revenue for the entire Greater Kuparuk area in their November 7,2001 Advance Meltwater ELF Ruling. The Alaska Department of Natural Resources specified the capped float-float methodology for the GKA for a twelve month trial in their August 29,2001 Decision and Findings document for the Seventh Expansion of the Kuparuk River Unit and formation of the Meltwater Participating Area. The Alaska Oil and Gas Conservation Commission also specified the capped float-float methodology for a trial period of 1 year in Rule 6 of Conservation Order 456 - Kuparuk River Unit Meltwater Pool Rules dated August 1, 2001. Rule 6 also states that a hearing will be held on September 12, 2002 to review allocation quality under the float-float methodology and decide what allocation methodology to use in the future. PAl shifted from the prior fixed-float technique to the new capped float-float technique in January 2002. PAl met with representatives of the Alaska Oil and Gas Commission, Alaska Department of Revenue, and Alaska Department of Revenue on July 30 to review the fist six moths of allocation data under the capped float-float method. Plots of the oil allocation factor across the transition period were reviewed and discussed. The transition to capped float-float was smooth, and nearly invisible. This was as expected based upon the relative volumes of Kuparuk vs. Satellite oil (-75% Kuparuk/25% Satellite) and the fact that the allocation factor is already running very close to 1.0 (-0.975 for the first six months of 2002). Moving to capped float-float as the new permanent allocation method was discussed during the July 30 meeting. No objections or concerns were voiced. Two graphs are attached illustrating the Greater Kuparuk Area allocation factor history including the change from fixed-float to capped float-float. PAl recommends that the Commission act to remove the probationary language in Conservation Order 456 related to the capped float-float methodology and make amendments to the other Greater Kuparuk Area Satellite Pool Rule Orders as necessary to adopt the capped float-float methodology for the entire Greater Kuparuk Area. PAl is also requesting that the Alaska Department of Natural Recourses find that the trial period of the capped float-float methodology is complete and specify it as the permanent methodology for the Greater Kuparuk Area. · Reqnested Modifications to Knparu,,"er AOGCC Unit Conservation Orders ... Pertaining to Methods of Allocation of Production Among Kuparuk River Unit Oil Pools August 12, 2002 Page 3 In summary, based upon the data trends and all agency feedback recei ved to date, PAl recommends the AOGCC and the Department of Natural Resources remove the temporary status of the capped float-float production allocation methodology and designate capped float-float as the allocation methodology to be used on an ongoing basis for the Greater Kuparuk area. Please feel free to contact me by phone (265-6806) or email (rstramp@ppco.com) if there are any questions or comments relating to this request. Very truly yours, ~ G4-~ ~"p.T) l . '-~ ~ .;.. ( Ryan L. Stramp Meltwater Development Coordinator PHTI.1 .IPS Alaska, Inc. Enclosures RLS/rls cc: Mark Myers Division of Oil and Gas Alaska Department of Natural Resources 550 W. 7th Avenue, Suite 800 Anchorage, AK 99501 Dan E. Dickinson Director, Tax Division Alaska Department of Revenue 550 W. 7th Avenue, Suite 500 Anchorage, AK 99501 Jane Williamson - AOGCC Chris Ruff - DNR-DOG Steve Bross - Phillips Alaska, Inc. John Cookson - Phillips Alaska, Inc. Louise Kari - Phillips Alaska, Inc. Jeff Spencer - Phillips Alaska, Inc. 0.9000 I I I I , , , I. '. 1 '.. I' .'. I..,....'.. ,...,....._1................'.....'...........'...'..-.....'...'_.'....'..'.;........'...'...·.,.....,'.>...1,....,."..'.' ".' '...' '. .' '.' I.' I. , .' '. I.. '...' , '. ,. '. ' .1 , .'. '" I'. I , ..'1 , , I'. ' I , , I· , - -. --', - -"--" ---- . ,- - --- - . - . - - - - - - -.- .. --, - -- -- - ,- - - " - - --. ,.....,.....,.....,.....,.....,.....,.....,.....,............,.....,..... ,.....CX)CX)CX)CX)CX)CX)CX)CX)œ.cócoCQO>,Q)O)O)O)(»d>O)CJ)O)O)c:nbObÒOOOo-ooOo...... ......O¡O-........................ r;-.................. 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'..... .'.......'.::s........'..'. Q)...'~.........'..........'....,.,0...........'.....$1>.. ..!....«:$......... ..'.........(1)... ..'.iiI;:.ø... ,~...a..,.......:.«S..... .....::s.......... -, « en ZQ-'U-.-=:: -. ~J '. ··«tJJ\J)ZD~~~>~~~~'l:mp¡)~)Z~lf?I..l;.:~ :';; :~~r.g~,~~~~:~;~~~.;;.~g>~..~~~.I.L-==.......~? ___- Historic Actual Fixed-Float -tI Back-Calculated Float/Float .~ New Actual Float-Float 0 Hypoth Fixed-Float #1 ¡i)t~t:Kuparuk Area Well Testing and Productiqn Allocation ReviewMeeting] ,,) .) Subject: [Fwd: Greater Kuparuk Area Well Testing and Production Allocation Review Meeting] Date: Wed, 07 Aug 2002 17:14:39 -0800 From: Jane Williamson <Jane_ Williamson@admin.state.ak.us> Organization: Alaska Oil & Gas Conservation Commission To: Camille 0 Taylor <cammy_taylor@admin.state.ak.us>, Daniel T Seamount JR <dan_seamount@admin.state.ak.us>, John D Hartz <jack_hartz@admin.state.ak.us> FYI. Please review. I would like to discuss this with you when you are available. Jane ...'.... ~~ Subject: Re: Greater Kuparuk Area Well Testing and Production Allocation Review Meeting Date: Wed,? Aug 2002 10:31 :06 -0800 From: "Ryan L Stramp" <rstramp@ppco.com> To: Jane Williamson <Jane_ Williamson@admin.state.ak.us> Jane- Attached is a draft of a letter to the Commission requesting change to the GKA allocation procedure that we discussed last week. Can you take a look at this and see if you think it will be sufficient to get the ball rolling? I still need to clean it up a little and add the attachments, but I wanted to get a general feel to see if this is along the lines of what you had in mind. Thanks- (See attached file: Float-Float Adoption Request.doc) Ryan L. Stramp Meltwater Coordinator ATO-1150 907-265-6806 L....."......................................"............................................................................".... .... ........"..........".........,.,............................"................. ...............................................".......................................... ................................"............."..,..........m...................................,,,.....................,......', ~~~*'II.¡I'III·.....''''*III',..·~·'WI'''....''''\I'LLII~mullI:·....·..·:I:..·my'\IIo'J..·\It~'·..~lIlIIlm:ItIl¡IIW1IIII\UlIIIIm,'..t"f¡.Ww.."""-nUIItI'r.llIIl~lIlI~·1I!llI!ylNlIl'~""'muml:·..w.....llnl¡.iJlI""*"IIiJ!tIIl"'w....~I1w..../.lx\ltmIlIllIHII~11\!11I1I1o'''I''WT....'JIIY1I;.!IIIIIIIIUlltmtlllll'ftItIiHtlW,W\\lIlllttllIIl.IIIII.IIo'·!!\I~····..·w....·....·~lItllttl1l''''lILm~ : i Name: Float-Float Adoption Request.doc , I )Float-Float Adoption Request.doci Type: WINWORD File (applicationlmsword)! , [Encoding: base64 . ... ....,...."'.. '.'''1 ~.....~..., W' '''''W' "'\)I" ............. :11I111I1: IIlaUlla~..·\u··t: ...·"HI:IIIII 1oI·\W·'I(IIIIIIIIo'I....··.."· -.,.... '\010" " "." '~11I1:mm""·..n1- tillVJII!:" ,,,,,.'t" '"'' "~II:.'U"'." .....".......".... \ .......·..~IItItI'I. _IIIIHItI\tIIIIi~t!1oIoI1'\ ... . ......... ·"1 itllt:( IW' .........~II·I·Io'1 ~'II!'...... \'(¡'>(WIWI:."I!. ...." .'1/""140''(10'.... ·~lIlImlml'iJII. .It·.....,,,· ,,) .,) PHilliPS Alaska, Inc. A Subsidiary of PHilLIPS PETROLEUM COMPANY August 8, 2002 DRAFT Ms. Cammy Oechsli Taylor, Chair Alaska Oil and Gas Conservation Commission 333 W. 7th Ave #100 Anchorage, Alaska, 99501-3539 Re: Requested Modifications to Kuparuk River AOGCC Unit Conservation Orders Pertaining to Methods of Allocation of Production Among Kuparuk River Unit Oil Pools Dear Ms. Oechsli Taylor: Phillips Alaska, Inc. as Operator of the Kuparuk River Unit, requests the Alaska Oil and Gas Conservation Commission make modifications to Conservation Orders 406 (West Sak), 430 (Tam), 435 (Tabasco), and 456 (Meltwater) necessary to adopt the Greater Kuparuk Area production allocation methodology described in Order 456. ' Orders 406, 430, and 435 as originally approved prescribe a production allocation process that sets the allocation factor for these first three satellites pool to a value of 1.0. Adjustments to balance "theoretical" monthly production rates with actual sales volumes are made in the Kuparuk Pool values. This scheme has been referred to as the "fixed-float" method because the satellite production is fixed at theoretical values, and all "floaf' takes place in the Kuparuk production. A different scheme was proposed prior to Meltwater administrative approvals and development in 2001. This alternative scheme calls for the adjustments between the total theoretical production and actual sales volumes take place in satellite production and the Kuparuk production. This general scheme has been referred to as the "float-float" methodology, since both the satellite and Kuparuk production values float to make up the differences between theoretical and actual production. An upper limit of 1.02 for the satellites' allocation factor was set in the Meltwater documents. I will refer to this as the "capped float-float" methodology or scheme. The capped float-float methodology was specified by the Alaska Department of Revenue for the entire Greater Kuparuk area in their November 7,2001 Advance Meltwater ELF Ruling. The Alaska Department of Natural Resources specified the capped float-float methodology for the N , , Requested Modifications to Kupa,Jver AOGCC Unit Conservation Orders .J Pertaining to Methods of Allocation of Production Among Kuparuk River Unit Oil Pools August 8, 2002 Page 2 GKA for a twelve month trial in their August 29,2001 Decision and Findings document for the Seventh Expansion of the Kuparuk River Unit and formation of the Meltwater Participating Area. The Alaska Oil and Gas Conservation Commission also specified the capped float-float methodology for a trial period of 1 year in Rule 6 of Conservation Order 456 - Kuparuk River Unit Meltwater Pool Rules dated August 1, 2001. Rule 6 also states that a hearing will be held on September 12,2002 to review allocation quality under the float-float methodology and decide what allocation methodology to use in the future. PAl shifted from the prior fixed-float technique to the new capped float-float technique in January 2002. P AI met with representatives of the Alaska Oil and Gas Commission, Alaska Department of Revenue, and Alaska Department of Revenue on July 30 to review the fist six moths of allocation data under the capped float-float method. Plots of the oil allocation factor across the transition period were reviewed and discussed. The transition to capped float-float was smooth, and nearly invisible. This was as expected based upon the relative volumes of Kuparuk vs. Satellite oil (°..-75% Kuparuk/25% Satellite) and the fact that the allocation factor is already running very close to 1.0 (-'0.975 for the first six months of2002). Moving to capped float-float as the new permanent allocation method was discussed during the July 30 meeting. No objections or concerns were voiced. Two graphs are attached illustrating the Greater Kuparuk Area allocation. factor history including the change from fixed-float to capped float-float. PAl recommends that the Commission act to remove the probationary language in Conservation Order 456 related to the capped float-float methodology and make amendments to the other Greater Kuparuk Area Satellite Pool Rule Orders as necessary to adopt the capped float-float methodology for the entire Greater Kuparuk Area. PAl is also requesting that the Alaska Department of Natural Recourses find that the trial period of the capped float-float methodology is complete and specify it as the methodology for the Greater Kuparuk Area. Please feel free to contact me by phone (265-6806) or email (rstramp~ppco.com) if there are any questions or comments relating to this request. Very truly yours, ... ., . '. Requested Modifications to Kup~er AOGCC Unit Conservation Orders ... Pertaining to Methods of Allocation of Production Among Kuparuk River Unit Oil Pools . August 8, 2002 Page 3 Ryan L. Stramp Meltwater Development Coordinator PHILLIPS Alaska, Inc. Enclosures RLS/rls cc: Mark Myers Division of Oil and Gas Alaska Department of Natural Resources 550 w. ih Avenue, Suite 800 Anchorage, AK 99501 Dan E. Dickinson Director, Tax Division Alaska Department of Revenue 550 w. ih Avenue, Suite 500 Anchorage, AK 99501 Steve Bross - Phillips Alaska, Inc. John Cookson - Phillips Alaska, Inc. Louise Kari - Phillips Alaska, Inc. Jeff Spencer - Phillips Alaska, Inc.