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Home My WebLink AboutO 036 Ima' Project Order File cove'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. () n :3 0 Order File Identifier Organizing (done) 1111111111111111111 D Two-sided RESCAN DIGITAL DATA D Color Items: D Greyscale Items: D Diskettes, No. D Other, No/Type: D Poor Quality Originals: D Other: NOTES: BY: ~ Date 1/1 3/ Ð fo Date II 13/00 Project Proofing BY: ~~ fc..:::-··- ~ Scanning Preparation BY: ~ (~Vldlld ,/ , x 30 = + Date II I?J lfJ0 Production Scanning Stage 1 4-~ (Count does include cover sheet) V YES Page Count from Scanned File: Page Count Matches Number in sca¡nning Preparation: ~ Date I '3Ioft; Stage 1 If NO in stage 1 page(s) discrepancies were found: BY: BY: Maria Date: Scanning is complete at this point unless rescanning is required. ReScanned BY: Maria Date: Comments about this file: D Rescan Needed 11111111I1111111111 OVERSIZED (Scannable) D Maps: o Other Items Scannable by a Large Scanner OVERSIZED (Non-Scannable) o Logs of various kinds: o Other:: r1f /5/ 111111111111111111I /5/ rY1P = TOTAL PAGES ILl (Count does not i~~~ude cover ;{¡et) n1 f 11111111111111 II III /5/ NO vwf YES NO /5/ 11111111111I11 1111I 1111111111111111111 /5/ Quality Checked 1IIIIIII11111111111 10/6/2005 Orders File Cover Page. doc e 1. September 6, 2005 2. September 21,2005 3. September 23,2005 4. October 14,2005 5. October 14, 2005 6. November 23, 2005 7. December 15,2005 e Other Order 36 Colville River Unit AOGCC Notice to ConocoPhillips (Alaska), Inc of Proposed Enforcement action for failure to perform required MIT's on CRU CDI-19A CP A request for a informal review AOGCC letter scheduling Informal Review Sign In Sheet Background Information AOGCC's Proposed Decision and Order CP A response to Decision Other Order 36 . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501-3539 Re: ConocoPhillips Alaska, Inc., as Operator of the Colville River Unit; Alpine Field; Well CRU CD1-19A Enforcement Action ) ) ) AOGCC Order No. 36 December 22, 2005 DECISION AND ORDER On September 6,2005 the Alaska Oil and Gas Conservation Commission issued a Notice of Proposed Enforcement Action under 20 AAC 25.535(b), stating that it considered that ConocoPhillips Alaska, Inc. ("CP AI") may have violated provisions of Area Injection Order No. 18B in connection with operating well Colville River Unit ("CRU") CD1-19A. The Commission proposed specific corrective actions under AS 31.05.150(a). The Proposed Decision and Order was sent to CP AI on November 23, 2005 (received by CP AI on November 29, 2005). CP AI did not file a written request for a hearing, instead providing written response to the terms and conditions detailed in the Commission's proposed Decision and Order. A. Summary of Proposed Enforcement Action In its Notice of Proposed Enforcement Action, the Commission identified an apparent violation by CP AI of Rule 6 of Area Injection Order No. 18B ("AIO 18B") by failing to perform . required mechanical integrity tests ("MIT"). The well was approved for disposal service in , accordance with Commission regulations and the Underground Injection Control ("UIC") & requirements. As a Class II disposal well, and as further described by CP AI as a slurry injector, . the well was required to be tested for mechanical integrity every 2 years. The Commission proposed to order the following corrective actions by CP AI: Decision and Order 36 Page 2 of6 . . December 22, 2005 (1) that within 30 days after the effective date of the enforcement order, CP AI must correct deficiencies in or develop a tracking capability to ensure the completion of an MIT within the time interval as required by regulation, order or other Commission directive; and (2) report on a monthly basis well pressure data (tubing, inner annulus, and outer annulus) for Well CDI-19A. (3) The Commission proposed no civil penalty under AS 31.05.150(a). B. Surveillance and Reporting Requirements for Injectors Commission requirements for demonstrating and monitoring mechanical integrity of injection wells in the CRU are documented in 20 AAC 25.252 and AIO 18B. Included are requirements for monitoring well pressures on a weekly basis. An annual performance report is required for CRU slurry injection wells. Injector surveillance data, including pressures, are required in an annual report. Commission records include copies of Annual Performance Reports for 2002, 2003, 2004 and 2005. Summaries of tubing and inner annulus pressure data for Well CDI-19A are presented in the Annual Performance Reports. CPAI notified the Commission by electronic mail dated August 30, 2005 that Well CD 1- 19A had not been tested as required for mechanical integrity. Included with that notification were 8 months of well pressure data (tubing, inner annulus, outer annulus) for Well CDI-19A. Well data provided by CP AI clearly indicate there is no pressure communication within the well. On September 4, 2005 CPAI conducted an MIT of Well CDI-19A that was witnessed by a Commission inspector. An acceptable level of well integrity was demonstrated by passing this MIT. Decision and Order 36 Page 3 of6 . . December 22, 2005 C. Informal Meeting In response to the Commission's Notice of Proposed Enforcement Action, CPAI requested an informal review as provided in 20 AAC 25.535(c). CPAI met with the Commission on October 14, 2005. Discussion during this informal meeting concentrated on two areas of mechanical integrity demonstrations CP AI identified as being specific to the CD 1-19 A decision: test cycle for mechanical integrity demonstrations and definition of a slurry well. MIT Cycle. AOGCC establishes the MIT cycle for disposal wells in 20 AAC 25.252. Supplementing the regulation is AIO l8B, providing additional obligations for wells injecting solid waste slurries. Specifically, AIO 18B, Rule 6 requires an MIT to be performed every 2 years in wells injecting solid waste streams. The Commission relies on the well completion report (new completion) or subsequent report of sundry operations (conversion of an existing completion to injection) to determine what test cycle is required for the MIT. In the well completion report for CDl-19A dated September 5, 2000 CPAI clearly identifies the well as a "cuttings disposal well" (i.e., slurry injector). The Commission subsequently established a 2- year test cycle for CD 1-19 A. The timing of an MIT was also discussed during the informal meeting. CP AI indicated that historical precedent allows a MIT to be performed any time during the year it is due, noting the flexibility in timing allows for MITs to be preferentially done during the summer months. While the Commission agrees the preference from a human safety and efficiency standpoint is to do MITs during the more temperate summer months, there is no guidance to suggest anything other than the literal interpretation of 4 years in setting the due date for subsequent tests. A 4- year MIT means the test must be performed on or before the 4-year anniversary of the most recent test unless the Commission has approved an alternate test schedule. Decision and Order 36 Page 4 of6 . . December 22, 2005 Definition of Slurry Injector. Regarding CDl-19A, CPAI argued the point that declaring a well as a slurry injector should be reserved for full time solid slurry injection such as done at the Prudhoe Bay field Grind and Inject facility. Their argument is that many disposal wells will accept some solids through the routine practice of waste injection. They further noted that that the absence of a specific definition in Commission regulations for "slurry" suggests the reliance on industry use of the term, which would exclude intermittent use such as done at CDl-19A. CP AI did not provide the Commission with a specific reference to an industry practice or definition that supports this position. The Commission disagrees with CPAI' s interpretation. More frequent testing of slurry injectors is based on the potential for erosion of the well's primary barrier (injection tubing), increasing the potential for a well integrity failure. Commission rules do not distinguish between intermittent or continuous slurry injection. The Commission also recognizes that it would be impractical to adjust the test cycle (oscillating between 4 years and 2 years) to reflect intermittent slurry injection and to be consistent with the intent of AID 18B, Rule 6. To do so would create confusion that could easily have the unintended consequence of misleading the operator into noncompliance with Commission requirements. Wells injecting slurry (regardless of the slurry injection frequency) must be tested for mechanical integrity every 2 years. D. Corrective Actions The Commission is not assessing monetary penalties in light of several mitigating factors that appear in the present situation. First, the Commission acknowledges the good faith of CP AI. Particularly noteworthy was the voluntary self-disclosure that CD 1-19 A had not been tested for mechanical integrity since 2001. The Commission also acknowledges that pressure data for Decision and Order 36 Page 5 of6 . . December 22, 2005 CD 1-19A demonstrates there is no pressure communication. In considering the lack of injury to the public or environment resulting from the violation, the Commission is convinced (based on actual well data and a passing MIT on September 4, 2005) that the risks during the 4+ years of operation were minimal. Because of the well design (multiple casing strings with pressure ratings exceeding injection pressure available to contain pressure communication or leakage), there was never any danger of annulus overpressure and no misinjection of fluids occurred. The Commission also recognizes that CP AI took timely action to perform a MIT after discovering the deficiency, and to correct the test frequency in its MIT database. E. Findings and Conclusions CPAI acknowledged that CRU CDI-19A was not tested for mechanical integrity as required between March 31, 2001 and September 4, 2005. The mechanical integrity of CDl- 19A has been confirmed by historical pressure data; however, the only Commission-approved demonstration of integrity for this injection well is a formal MIT every 2 years. The applicable regulatory requirements for demonstrating ongoing well integrity of an injection well were violated, and CP AI does not dispute that fact. In the Commission's September 6, 2005 notice, monthly reporting of well pressures in CDI-19A was proposed as part of the corrective actions. The Commission has decided that this action is not necessary given the extent of reporting already required under AIO 18B, and the lack of well integrity concerns to date. However, the Commission believes it is appropriate to require CP AI to take specific corrective measures to prevent future violations of the sort that occurred in this case. Decision and Order 36 Page 6 of6 . . December 22, 2005 For the reasons stated above, the Commission finds that CP AI violated AIO 18B, Rule 6, and regulation 20 AAC 25.252(d). NOW THEREFORE IT IS ORDERED THAT: 1. Within 30 days from the date of this Decision and Order, CP AI shall submit to the Commission in writing a proposed program that provides for adequate tracking of MIT requirements for injection wells that handle slurry, regardless of injection frequency, to ensure the completion of an MIT within the time interval required by regulation, order or other Commission directive; and 2. Within 30 days from the date the Commission approves (or requires modifications to) CPAI's proposed program, CP AI shall provide the Commission with documentation that the program as approved or modified has been implemented. ----._..-..._._.--...._..._~--_._--~_.~.__.- UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid ~ USPS (;) Permit No. G-10 .¡;; a .~ lJ.) Sg~der:i>lease print your name, address, and ZIP+4 in this box · '- <::::> ,3 _, 52 _.. ''-' ~ C!J ~~ E ~l f)óGCC ßI /¡ li gj ~ ~ 33 3 bJ 717-- /J¿;e fflO() i mvLfJ(flç:7û) líïl¡Y / h05)~~~cL)ji9Iq..' SENDER: COMPLETE THIS SECTION · 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: WíJ7Ct? jc/clì-f )/1::; Opfl Ié1-/;OI)5 r;o/ícCoGff, 7t,~/;? !/fJhcifJ~.' q{j/j/O 2. Article Number (Transfer from service lal COMPLETE THIS SECTION ON DELIVERY A. Signature I X /f J'k~ B. Received by (Printed Name) I C¡ oat, e of Delivery ,; 1. Sr1J1;{i/..I J L ~ 2-3 -ó) D. Is delivery address different from item 1?~ If YES, enter delivery address below: .~ M-.4nt ~~~ressee 3.~ Type l: ~~rt.ified Mail 0 Express Mail o Registered ~n Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) DYes PS Form 3811, August 2001 700~ 1160 0001 5753 7123 102595-02-M-0835 -.-...--"........., Domestic Re\urn Receipt U.S. Postal ServiceTM ~ CERTIFIED MAILM RECEIPT ,...:¡ (Domestic Mail Only; No Insurance Coverage Provided) I"- _. ...__ For delivery Information visit our webslte at www.usps.com.. ~ I .' .. . .. ". .. ". '" "', . . . '.. ~ ". 'f :. ,~ . I :.'. I"- U1 UNIT H!":qt:"l~_ /A:~~'?.'.'~~'Î'<~' --;1/"'- . c9. /Ó~ POs1m~J 'ß, ¡Qf H~.. ,0 ~.~\ '. ~~~r"" ~ ~1tS::~""_¡~f1L ! U1 TO~S $ (~, 65 1~"'Z:.·"':(YS ~ ':;8;~z-·-~ç,?f:t~---,-¿¡¿Ç2&~.......--------· orPO Box No. ~I. . ëitÿ. -šiãië; Z¡p:¡:;'¡ - --- - - - _n .... - - - -... -. - ------------- -. - n - - - -. - - - --------- -. - -- --. Postage $ ,...:¡ t:J t:J t:J Retum ReceIpt Fee (Endorsement Required) t:J Restricted Delivery Fee ..n (Endorsement Required) ,...:¡ ,...:¡ Certified Fee -." IJI!!II!IrI! -~,,!!!!! ,~ .... VII!JIJ /.3(\ 1.75 I "",~_..,,~~_ .>....~~---, I !II! ' #7 ) ) Terrance S. Lucht Acting Vice President North Slope Operations & Development, Alaska ConocciP'hillips Alaska, Inc. ATO 2100 700 G Street P 0 Box 1 00360 Anchorage, AK 99510 Ph: (907) 263-4585 December 15,2005 RECEIVED DEC 1 9 2005 Alaska Oil & Gas Cons. Commission Anchorage Mr. John Norman, Chairman State of Alaska Alaska Oil & Gas COlnmission 333 West ih Avenue, Suite 100 Anchorage, AK 99501 Re: Well CRU CDl-19A Enforcement Action, AOGCC Order No. 36 Dear Mr. Norman: This letter is being sublTIitted to satisfy the tem1S and conditions detailed in AOGCC Order No. 36 sent to ConocoPhillips Alaska, Inc. (CPAI) dated November 23, 2005. The order regards corrective actions to be implemented for tracking Mechanical Integrity Tests (MIT) as required in Area Injection Order No. 18B, Rule 6, for injection wells. The corrective action contains two requirements. The first is a submission in writing of program description to accurately track MIT requirements and test frequency for injection wells. The second is·to provide documentation to the Commission within 30-days that the program has been implemented. Responses to these requiren1ents are as follows: Item 1: Description of tracking program An MIT tracking program has been used by CPA, or its predecessor companies, since field startup over twenty years ago. The CP AI Wells Group has the responsibility for managing and coordinating all aspects of Well Integrity, including the MIT program, for all CP AI assets. The Well Integrity Supervisor coordinates diagnostic work and data management to ensure that operation of wells is compliant with both regulatory and COlTIpany requirements. A copy of CPA Well Integrity program documents was provided to the AOGCC several years ago which includes requirements for MIT management. A key component of the Well Integrity program is tracking and maintenance of pertinent data via the Annular Communication Database (ACDB). Implemented approximately two years ago, the ACDB is an Access database platform that is designed to present and store data on a per-well basis. Major areas of the database include known well integrity problems, planned action items to address those problems, and an event history for operations that have taken place. There is a section for each well regarding MIT information including the most recent test date, the most recent test date witnessed by an AOGCC Inspector, the test pressure, and test frequency (months). Based on the test frequency a new "due date" is calculated so that future test dates are readily known. ) ') Mr. John Norman, Chairman Alaska Oil & Gas Conservation Commission December 15,2005, Page 2 The ACDB has several options for report generation, one of which is the "MIT Injector Test Report." The report can be generated at any time, and lists all injectors in ascending order by the due date for the next MIT (excerpt in Attachment A). The key item is the test frequency input field for the listing to function properly; it must be known for each well if the test frequency is 4- years, 2-years, or some other value. If the well is to be classified as a "slurry injector" and is subject to 2-year testing frequency, that must be known for accurate tracking. The report is reviewed frequently so that upcoming tests can be coordinated and performed in a timely fashion. The current version of the ACDB has proven to be reliable, functional and accurate. The database resides on a server and is backed-up daily for security and data recovery purposes. No improvements or alterations were made to the program as an outcome of this enforcement action. Item 2: Implementation of tracking program The most practical way to provide verification the program has been implemented is to demonstrate the database capabilities in person; CP AI would be willing to provide this demonstration. For the purposes of this enforcement action there are two attachments: Attachment B is a snapshot of the ACDB MIT data cells for CD 1-19 A, and Attachn1ent C isa list of MIT tests due during the first six months of 2006. If you have any questions about these attachments additional information can be provided. CP AI takes regulatory compliance very seriously and has systems and personnel in place dedicated for that purpose. With over 500 injection wells to n10nitor and n1anage in Alaska, it is not a sn1all task. The company will continue to look for ways to improve data management and regulatory oversight when beneficial opportunities are identified. Terrance S. Lucht Acting Vice President North Slope Operations & Development, Alaska Attachments TSL:MBM By fax (907-276-7542) & confirmation mail copy/ . ~ I, . ,. . " , } . '. . ¡'.J. .. ,,- 'j! ".. .' .. -J'"1 .. ~~,:",: .~.~..:~::- - . ; . ¡ " ~ , . ' . .-'-~-.. - ~_..'._..._......._....... ---'-'-'--....- ---"--.--- ,.. , ., ,I '. L I _....._._.......!..... ........_._. "oR ."'-0. ~,_.".,,, "-___ , 'I' - , D3./3D/IJ1: Initial r>.o1ITIA Passed @ 1 S<Ú'G psi (State v.'itnessed} U9/G4/US: State witnessed 2 year MITIA - passed. ) ) ) ') ConocoPhillips Alaska, Inc. 2006 Required MIT List First Six Months LAST MIT LAST WITNESSED TEST FREQ TEST DUE TEST WELL TYPE DATE DATE (Months) DATE PRESSURE P/F COMMENTS 1C-111 INJ 1/10/2002 01/10/02 48 01/10/06 1650 P 1C-121 INJ 1/10/2002 01/10/02 48 01/10/06 1750 P 1 C-125 INJ 1/10/2002 01/10/02 48 01/10/06 1750 P 1C-131 INJ 1/10/2002 01/10/02 48 01/10/06 2500 P 2N-302 INJ 1/10/2002 01/10/02 48 01/10/06 3083 P 2N-348 INJ 1/10/2002 01/10/02 48 01/10/06 1519 P 3H-09 INJ 1/13/2004 06/27/02 24 01/13/06 1800 P MITIA 2-Year test, Sundry 2U-07 A INJ 1/14/2004 01/14/04 24 01/14/06 3000 P CMIT T x IA w / TTP, Sundry 3A-06 INJ 1/19/2004 01/19/04 24 01/19/06 3000 P MITIA fails, CMIT w/TTP, Sundry 1 H-07 INJ 1/28/2004 01/28/04 24 01/28/06 2500 P MITIA fails, CMIT w/TTP, Sundry 2C-07 INJ 2/27/2004 02/27/04 24 02/27/06 2420 P CMIT T x IA @ BP set 6165', Sundry CD2-15 INJ 3/9/2002 03/09/02 48 03/09/06 2000 P CD2-17A INJ 3/9/2002 03/09/02 48 03/09/06 1875 P CD2-26 INJ 3/9/2002 03/09/02 48 03/09/06 1875 P CD2-49 INJ 3/31/2002 03/31/02 48 03/31/06 2000 P 1C-119 INJ 4/25/2002 04/25/02 48 04/25/06 1950 P 2N-309 INJ 4/25/2002 04/25/02 48 04/25/06 2960 P 2N-326 INJ 4/25/2002 04/25/02 48 04/25/06 2955 P 2N-335 INJ 4/25/2002 04/25/02 48 04/25/06 2940 P 1 C-06 INJ 4/29/2005 08/12/97 12 04/29/06 3000 P CD2-32 INJ 5/11/2002 05/11/02 48 05/11/06 2000 P 2G-03 INJ 5/16/2004 11 /16/96 24 05/16/06 3000 P T x IA Sundry WD-02 DISP 5/27/2005 OS/27/05 12 OS/27/06 3500 P Alpine Class I inj (EPA witness) 3N-13 INJ 6/2/2005 11/09/99 12 06/02/06 3000 P 1 B-02 INJ 6/16/2002 06/16/02 48 06/16/06 1980 P 1 B-05 INJ 6/16/2002 06/16/02 48 06/16/06 2000 P 1 B-07 INJ 6/16/2002 06/16/02 48 06/16/06 1950 P 1 B-08A INJ 6/16/2002 06/16/02 48 06/16/06 2050 P 1B-12 INJ 6/16/2002 06/16/02 48 06/16/06 2100 P 1 C-05 INJ 6/16/2002 06/16/02 48 06/16/06 2050 P 1 C-1 0 INJ 6/16/2002 06/16/02 48 06/16/06 2025 P 1 A-09 INJ 6/27/2004 06/27/04 24 06/27/06 3000 P MITT 2-Year test, Sundry 1 F-08 INJ 6/27/2004 06/27/04 24 06/27/06 3090 P MITT, 2-year required, Sundry 3H-02 INJ 6/27/2002 06/27/02 48 06/27/06 1810 P 3H-06 INJ 6/27/2002 06/27/02 48 06/27/06 1750 P 3H-07 INJ 6/27/2002 06/27/02 48 06/27/06 1750 P 3H-15 I NJ 6/27/2002 06/27/02 48 06/27/06 1900 P ---_._-~,,-- 3H-17 INJ 6/27/2002 06/27/02 48 06/27/06 1850 P 3H-22 INJ 6/27/2002 06/27/02 48 06/27/06 1940 P 3H-24 INJ 6/27/2002 06/27/02 48 06/27/06 1775 P 3H-31 INJ 6/27/2002 06/27/02 48 06/27/06 1800 P 2M-23 DISP 6/28/2004 12/04/95 24 06/28/06 1800 P Class II Disposal well requirements: Area In. Order 2B Classified as slurry injection well by AOGCC, 2-year MIT 2V-08A INJ 6/28/2004 08/24/96 24 06/28/06 2980 P Waivered for OA x conductor leak 30-05 INJ 6/28/2002 06/28/02 48 06/28/06 2040 P 30-06 INJ 6/28/2002 06/28/02 48 06/28/06 3050 P 30-07 INJ 6/28/2002 06/28/02 48 06/28/06 2000 P 30-16A INJ 6/28/2002 06/28/02 48 06/28/06 1700 P 30-17 INJ 6/28/2002 06/28/02 48 06/28/06 3000 P Attachment C CPAIINJ/DISP MIT REPORT 12/1/2005 WELL TYPE MIT _DATE WITNESSED FREQ (man) DT _DUE PRESS P/F COMMENTS WD-02 DISP 5/27/2005 5/27/2005 12 OS/27/06 3500 P Alpine Class I inj (EPA witness) 2M-23 DISP 6/28/2004 12/4/1995 24 06/28/06 1800 P Class II Disposal well requirements: Area In. Order 28 Classified as slurry injection well by AOGCC, 2-year MIT CD1-19A DISP 9/4/2005 9/4/2005 24 09/04/07 2170 P Classified as slurry injection well by AOGCC, 2-year MIT 1 R-18 DISP 11/6/2005 11/6/2005 24 11/06/07 1820 P Class II Disposal well requirements: Area In. Order 28 Classified as slurry injection well by AOGCC, 2-year MIT 3R-11 D DISP 11/6/2005 11/6/2005 24 11/06/07 1840 P Class II Disposal well requirements: Area In. Order 28 Classified as slurry injection well by AOGCC, 2-year MIT .- ConocoPhillips Alaska, Inc. Attachment A #6 ) ) ST ATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501-3539 Re: ConocoPhillips Alaska, Inc., as Operator of the Colville River Unit; Alpine Field; Well CRU CDl-19A Enforcement Action ) ) ) AOGCC Order No. 36 November 23,2005 PROPOSED DECISION AND ORDER On September 6, 2005 the Alaska Oil and Gas Conservation Commission issued a Notice of Proposed Enforcement Action under 20 AAC 25.535(b), stating that it considered that ConocoPhillips Alaska, Inc. ("CP AI") may have violated provisions of Area Injection Order No. 18B in connection with operating well Colville River Unit ("CRU") CDl-19A. The Commission proposed specific corrective actions under AS 31.05.150(a). A. Summary of Proposed Enforcement Action In its Notice of Proposed Enforcement Action, the Commission identified an apparent violation by CP AI of Rule 6 of Area Injection Order No. 18B ("AIO 18B") by failing to perform requir~d mechanical integrity tests ("MIT"). The well was approved for disposal service in accordance with Commission regulations and the Underground Injection Control ("UIC") » requirements. As a Class II disposal well, and as further described by CP AI as a slurry injector, the well was required to be tested for mechanical integrity every 2 years. Proposed Decision and Order Page 2 of7 ) '.) November 23, 2005 The Commission proposed to order the following corrective actions by CP AI: (1) that within 30 days after the effective date of the enforcement order, CP AI correct deficiencies in or develop a tracking capability to ensure the completion of an MIT within the time interval as required by regulation, order or other Commission directive; and (2) report on a monthly basis well pressure data (tubing, inner annulus, and outer annulus) for Well CDl-19A. The Commission proposed no civil penalty under AS 31.05.150(a). B. Surveillance and Reporting Requirements for Injectors Commission requirements for demonstrating and monitoring mechanical integrity of injection wells in the CRU are documented in 20 AAC 25.252 and AIO 18B. Included are requirements for monitoring well pressures on a weekly basis. An annual performance report is required for CRU slurry injection wells. Injector surveillance data, including pressures, are required in an annual report. Commission records include copies of Annual Performance Reports for 2002, 2003, 2004 and 2005. Summaries of tubing and inner annulus pressure data for Well CDl-19A are presented in the Annual Performance Reports. CPAI notified the Commission by electronic mail dated August 30,2005 that Well CDI- 19A had not been tested as required for mechanical integrity. Included with that notification were 8 months of well pressure data (tubing, inner annulus, outer annulus) for Well CDI-19A. Well data provided by CP AI clearly indicate there is no pressure communication within the well. On September 4, 2005 CPAI conducted an MIT of Well CDI-19A that was witnessed by a Proposed Decision and Order Page 3 of7 ) ) November 23, 2005 Commission inspector. An acceptable level of well integrity was demonstrated by passing this MIT. C. Informal Meeting In response to the Commission's Notice of Proposed Enforcement Action, CP AI requested an informal review as provided in 20 AAC 25.535(c). CPAI met with the Commission on October 14, 2005. Discussion during this informal meeting concentrated on two areas of mechanical integrity demonstrations CP AI identified as being specific to the CD 1-19 A decision: test cycle for mechanical integrity demonstrations and definition of a slurry well. MIT Cycle. AOGCC establishes the MIT cycle for disposal wells in 20 AAC 25.252. Supplementing the regulation is AIO 18B, providing additional obligations for wells injecting solid waste slurries. Specifically, AIO 18B, Rule 6 requires an MIT to be performed every 2 years in wells injecting solid waste streams. The Commission relies on the well completion report (new completion) or subsequent report of sundry operations (conversion of an existing completion to injection) to determine what test cycle is required for the MIT. In the well completion report for CD 1-19A dated September 5, 2000 CP AI clearly identifies the well as a "cuttings disposal well" (i.e., slurry injector). The Commission subsequently established a 2- year test cycle for CD 1-19 A. The timing of an MIT was also discussed during the informal meeting. CP AI indicated that historical precedent allows a MIT to be performed any time during the year it is due, noting the flexibility in timing allows for MITs to be preferentially done during the summer months. While the Commission agrees the preference from a human safety and efficiency standpoint is to Proposed Decision and Order Page 4 of7 ) ) November 23,2005 do MITs during the more temperate summer months, there is no guidance to suggest anything other than the literal interpretation of 4 years in setting the due date for subsequent tests. A 4- year MIT means the test must be performed on or before the 4-year anniversary of the most recent test unless the Commission has approved an alternate test schedule. Definition of Slurry Injector. Regarding CD 1-19A, CP AI argued the point that declaring a well as a slurry injector should be reserved for full time solid slurry injection such as done at the Prudhoe Bay field Grind and Inject facility. Their argument is that many disposal wells will accept some solids through the routine practice of waste injection. They further noted that that the absence of a specific definition in Commission regulations for "slurry" suggests the reliance on industry use of the term, which would exclude intermittent use such as done at CD 1-19 A. CP AI did not provide the Commission with a specific reference to an industry practice or definition that supports this position. The Commission disagrees with CPAI' s interpretation. More frequent testing of slurry injectors is based on the potential for erosion of the well's primary barrier (injection tubing), increasing the potential for a well integrity failure. Commission rules do not distinguish between intermittent or continuous slurry injection. The Commission also recognizes that it would be impractical to adjust the test cycle (oscillating between 4 years and 2 years) to reflect intermittent slurry injection and to be consistent with the intent of AIO 18B, Rule 6. To do so would create confusion that could easily have the unintended consequence of misleading the operator into noncompliance with Commission requirements. Wells injecting slurry (regardless of the slurry injection frequency) must be tested for mechanical integrity every 2 years. Proposed Decision and Order Page 5 of7 ) ) November 23,2005 D. Corrective Actions The Commission has not proposed assessIng monetary penalties, in light of several mitigating factors that appear in the present situation. First, the Commission acknowledges the good faith of CP AI. Particularly noteworthy was the voluntary self-disclosure that CD 1-19A had not been tested for mechanical integrity since 200 I. The Commission also acknowledges that pressure data for CD 1-1 9 A demonstrates there is no pressure communication. In considering the lack of injury to the public or environment resulting from the violation, the Commission is convinced (based on actual well data and a passing MIT on September 4, 2005) that the risks during the 4+ years of operation were minimal. Because of the well design (multiple casing strings with pressure ratings exceeding injection pressure available to contain pressure communication or leakage), there was never any danger of annulus overpressure and no misinjection of fluids occurred. The Commission also recognizes that CP AI took timely action to perform a MIT after discovering the deficiency, and to correct the test frequency in its MIT database. E. Findings and Conclusions CP AI acknowledged that CRU CD 1-19A was not tested for mechanical integrity as required between March 31, 2001 and September 4, 2005. The mechanical integrity of CD 1- 19A has been confirmed by historical pressure data; however, the only Commission-approved demonstration of integrity for this injection well is a formal MIT every 2 years. The applicable regulatory requirements for demonstrating ongoing well integrity of an injection well were violated, and CP AI does not dispute that fact. Proposed Decision and Order Page 6 of7 ') ) November 23,2005 In the Commission's September 6, 2005 notice, monthly reporting of well pressures in CDl-19A was proposed as part of the corrective actions. The Commission has decided that this action is not necessary given the extent of reporting already required under AIO 18B, and the lack of well integrity concerns to date. However, the Commission believes it is appropriate to require CP AI to take specific corrective measures to prevent future violations of the sort that occurred in this case. For the reasons stated above, the Commission finds that CP AI violated AIO 18B, Rule 6, and regulation 20 AAC 25.252(d) and should be required to take the corrective actions described below. NOW THEREFORE IT IS ORDERED THAT: 1. CP AI shall comply with the following corrective actions:: a. Within 30 days from the date this Decision and Order becomes final, CP AI shall submit to the Commission in writing a proposed program that provides for adequate tracking of MIT requirements for injection wells that handle slurry, regardless of injection frequency, to ensure the completion of an MIT within the time interval required by regulation, order or other Commission directive; and b. Within 30 days from the date the Commission approves (or reqUIres modifications to) CP AI's proposed program, CP AI shall provide the Commission with documentation that the program as approved or modified has been implemented. Proposed Decision and Order Page 7 of7 ) ) November 23,2005 2. This Decision and Order becomes final on the 11 th day after the date of its issuance shown below, unless within 10 days after the date of issuance CP AI files a written request for a hearing under 20 AAC 25.535(d). If CP AI timely files a writt n request for a hearing this \ I Decision and Order will be of no effect. ~ c~rt~~ ;".-.- ) '. T---·-·---..··--..·--.. .....----....- .....'.-..-...-------, UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 · Sendeir": Please print your name, address, 'and ZIP+4 in this box. AOGCC 333 W 7th Ave, Ste 100 Anchorage, AK 99501 7 {t¡) / ~_. /94 ['0134, 11,1,,1, L III J } ,11t1 ,,\\11 II II II 111 J \ J II Ii 1'1 \ I'" , I , I , II I' ,1\ :Î:.\~~:,~~r,....·""·· ".. --, .",...~-~.", ,. .._~....,...."",.....-.__._-,...._.-. SENDER: COMPLS¡!E THIS SECTION \ · 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 mallplece, or on the front if space permits. 1. Article Addressed to: X B. ~~" ~~ bY~.~te¡r1.._ Name) C. Pìte of Delivery Iff (' .-/â( d-O I j 20 () s/ D. Is delivery address different from Item 1? 0 Yes If YES, enter delivery address below: )iil$Jo ~o~ W\'ì\-\ G"'e~ V'P ~IC?p.- 'f>o ~:;/ \ Cö 3\.90 'PY\L'v- 'f-\ \C- Ü\Ü\~\O 3. ~~e Type ~ertlfled Mall· 0 Express Mail o Registered "'B:Retum Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 'Yes 2. Article Number (fransfer from servIce fabeQ PS Form 3811. February 2004 7004 1160 0001 3621 1694 Return Reclept ree (Endorsement Required) o Restricted Delivery Fee ...D (Endorsement Required) M 1 M Total Postage & Fees $ U.s. Postal ServiceTM ' CERTIFIED MAILTM RECEIPT 1.,,- u¿·., '1" ", - . ";.".. I"' Domestic Return Receipt 102595-02-M-1540 Certified Fee g -;:~:---JojUl_----Ú/..b./.¿r2.á_e-c:l.¿m_ ~ .~~~'¿~~~·~~--------CR&_________________________________________. City, State, ZIP+4 }"'''~I'-'I;I'I'Jl'tJII'I:r.I.IlI}·_'1'r.I:lol'.I.'¡II-'1=11[;J11r.m.mt¡I~ #5 (1'/ tJ J ôù C~1O b~(;,~ £ept-~~ ( -fVrvA 10-40 1) ¡, sts ~~Cl Og it C¿df..''j~ dlSfOýJ vve_ll '1 -- lAJO~kove- Z-IZb{t4*~ ptu,,(emkß IvlC}( I t!I f tt--h())~ Vtctve ,-- Lov~s+ \Jòl<Alk:--s I V''''reckd cUt (. M¿,'.J-t~ s ,.:g, 'c",vi a<; sL~ I1\JeD4-z~ 6 Ian-03 0 3 6 I 5 6 o 3 ru - Iul-02 ^.... , ~' ^ 1,462 3 ¡ Iun-02 0 1,884 3 r May-02 0 '.m 13 ~ ¡ ...... , Apr-02 0 5,2~5 5 r Mar-02 0 16,738 13 ì' ,...... ... ^ ¡ ~~ 0 6 ¡----~hn-02 0 1,546 4 ~.,....~:'·:.=~~~~~~1~.~..m~:-~1·-~...--....-~...--...~=~=~~~.~,·+±=~.~=~s.~Hö.~~·~.~·.:~.J.~. :',':~~.',~.~:,:'~~'.:~:='::~'~=~.J ¡ Oct·OI ¡ 0 10,145; 12 ~ r-.--.'....-.....--..............---...¡----....'.......-...--.-.. ---j...---..............................(.--...--...........-......--..-- ¡ Sep-Ol .. 0 12,169 ¡ 15 ¡ f·~~·}0:~~;~~n~~f~i~~~~~;: ·.r··· -..J~J l -=~1: -~F:·+~:+~:!~~f¡~~· :r-~ ·*::=1¡nitial MIT 3/30/01 ....,..........._..........._........_........;...................._................_.........-....-'___.....__.................... .............. .-, . ...... .. . ..........................._-...J Feb-Ol i 0 ¡ 1,164 : 4 ¡ }.~~ ........~...._""_.....__.-...._......._.¡.....,~._......._.__.,_....~-,.._...._....._~...._.......~_........._...~. ·......·.........r ....... ..".-......_....._-_....._...-...._..~ ¡ Ian-Ol i 0 ¡ 1,010 ¡ 5 ¡ l==~-=~8;~~...=-¡.._--~~~__~~~~~-=:_.t~....=:·=~._..;==_...J i Oct-OO : 0 ¡ 3,641 I 16 ! [·~~~~~iJf~~==[~..... ~1~=--~l-~~.__~fE~~=-..~~~~_·_:-..=_~~}==] pre-inj MIT 6/1/00 f V5 .--< .J B CI- "" ~ 25 20 12 18 21 22 I 6 4 9 13 3 5 4 6 7 7 4 8 13 8 o o o o o o o o o o o o o o o o o o o r J ~ 2,095 ... ~~771 829 132 2,663 1,745 28,237 27,53? '--' -~ ~'.\ .. r.) ~. ~ ..0 MIT 9/4/05 Alpine CD1-19A (PTD 2000400) Injection History 10/14/2005 ) ') ) ) subject: Alpine CD1-19A (PTD 200-040) From: NSK Problem well Supv <n1617@conocophillips.com> Date: Tue, 30 Aug 2005 16:46:43 -0800 To: James Regg <jim_regg@admin.state.ak.us>, Thomas Maunder <tom_maunder@admin.state.ak.us> CC: "Alonzo, chris" <chris.Alonzo@conocophillips.com>, "Erwin, Michael D" <Michael.D.Erwin@conocophillips.com>, "Elmer, Matt J." <Matt.J.Elmer@conocophillips.com>, ALP ops Maint supv <alp1167@conocophillips.com>, Alpine Lead operators <alp1006@conoc0p'hillips.com>, "Hanson, Kelli L" <Kell i . L. Hanson@conocophi 11 i ps. com>, 'Mooney, M" <M. Mooney@conocophi 11 i ps. com>, NSK problem well supv <n1617@conocophillips.com> Jim/Tom, CD1-19A is a class II disposal well located on the Alpine CD1 drill site. The well is used for disposal of drilling and wellwork fluids in the sadlerochit formation. CD1-19A has been used for slurry injection intermittently since initial injection in August 2000. under Area Injection order No. 188, Rule 6, a MIT is required every 2 years for slurry injectlon wells. The initial CD1-19A MIT was conducted on 3/30/01; however, the next required MIT was not completed in 2003. This was an inadvertent omission as the completion report identifies this well as a waste disposal well and was believed to only require a 4 year MIT similar to other North slope class II disposal wells. A recent review of Area Injection order 188 was conducted during preparations for normal 4 year injection well MIT'.s and revealed this error. As a result of this oversight, the MIT frequency has been corrected in our MIT database and we will pursue a MIT at the earliest possible opportunity. Though the 2003 MIT was not performed, the following describes regular monitoring and reporting activities that have occurred in accordance with AIO 188 and prudent operations practices: cD1-19A Injection History: 2005-0830-Alpine_CD1-19A_missing_MITs.txt August 2000 - June 2001 July 2001 - November 2002 December 2002 - May 2003 June 2003 - october 2004 November 2004 - August 2005 slurry disposal Liquid disposal only slurry disposal Liquid disposal only slurry disposal CD1-19A Monitoring and Reporting practices: Tubing, IA and OA Pressures monitored daily Tubing, IA and OA Pressures and pumped volumes recorded every 15 minutes during injection operations Annual performance Reports submitted on 3/27/02, 4/15/03, 3/17/04 and 3/23/05 Current and historical data indicates the tubing-casing annulus has full mechanical integrity. See the attached plot below for Tubing and IA pressures for the last 6 months. Microsoft Excel chart A MIT on CD1-19A is tentatively scheduled for saturday September 5th, contingent on State Inspector availability. please let me know if you have any questions regarding this well. page 1 ) ) 2005-0830-Alpine_CDl-19A_missing_MITs.txt MJ Loveland conocophillips problem well supervisor 659-7224 page 2 ( STATE OF ALASKA ( ALASKA OIL AND GAS CONSERVATION COMMISSION WELL COMPLETION OR RECOMPLETION REPORT AND LOG 1. status of well 011 0 Gas 0 2. Name of Operator Phillips Alaska, Inc. 3. Addl8ss P. O. Box 100360, Anchorage, AK 99510-0360 4. Location of weD at surface rëo~pï::T~t 351' FNL, 2447 FWL, Sec. 5, T11 N, R5E, UM (ASP: 385873, 5975778) ,"or:TE '\.', i At Top Producing Interval ~ ..k..:. "7 ~ ~ 972' FSL, 69' FEL, Sec. 29, T12N, R5E, UM (ASP: 388714, 5982339) , vË;i=¡eO . ¡ At Total Depth ,/lb. i 1736' FNL,3325' FEL, Sec. 33, T12N, R5E, UM (ASP: 390706, 5979599)' '.' -~- 5. Elevation In feet (Indicate KB, DF, etc.) 6. Lease Designation and Serial No. RKB 36 feet ADL 25558. 25557 & 25558 12. Date Spudded 13. Date T.D. Reached 14. Date 9'~'.. S,rp. Or Aband. AprilS, 2000 April 17, 2000 ~OOOi'b 17. Total Depth (MD + TVD) 18. Plug Back Depth (MD + TVD) 19. Directional Survey 11956' MD /9595" TVD 11860' MD /9502' TVD YES 0 No D 22. l)pe Electric or Other Logs Run GR/ResJNeutlDens. GAlCCL, USIT 23. Suspended D Abandoned 0 Service 0 CASING SIZE WT. PER FT. 16" 62.5# 9.625" 36# 7" 26# CASING, LINER AND CEMENTING RECORD SETTING DEPTH MD TOP BOTTOM Surface 114' Surface 2825' Surface 11947' GRADE H-40 J-S5 L-SO HOLE SIZE 24" 12.2S" 8.S" 24. Perforations open to Production (MD + TVD of Top and Bottom and Interval, size and number) 8750'-8760' MD 6692'-6699' TVD 4 spf 8990'-9000' MD 6868'-6876' TVD 4 spf 11463'·11483' MD 9116'·9136' TVD 6 spf 11750'·11769' MD 939S'-9408' TVD 6 apt 11504'-11520' MD 9156'-9172' TVD 6 spf 11768'-11776' MD 9412'-9420' TVD 6 spf 11780'-11794' MD 9424'-9438' TVD 6 spt 11800'-11813' MD 9443'-9456' TVD 6 spt. 27. Date Fist Production 25. SIZE Classification of Service Well Cuttings Disposal Well 7. Permit Number 200-040 1300-128 /300-111 8. API Number S0-103-20294-01 ..lOCA TiöNS' 9. Unit or lease Name . V!ISfØ)~~ Colville River Unit .~ ,~ 10. Well Nurmer 11.,( .' .' .. CD1-19A ..:.:.... ".: .. 11. Field and Pool Colville River Field Alpine Oil Pool 15. Water Dept~, If offshol8 N/A feet MSL 20. Depth where SSSV set N/A feet MD 16. No. of Completions 1 21. Thickness of Pennafrost 896' CEMENTING RECORD 10 cu yds Portland Type 3 860 ex AS III lW, 230 $X Class G 566 ex Class G AMOUNT PULLED 3.S" lUBING RECORD DEPTH SET (MD) 10792' PACKER SET (MD) 8671', 10716' ACID, FRACTURE, CEMENT SQUEEZE, ETC. DEPTH INTERVAL (MD) AMOUNT & KIND OF MATERIAL USED N/A 26. Date atTest PRODUCTION TEST Method of Operation (Flowing, gas 11ft, etc.) N/A Oll-BBl Hours Tested Production for Test Period> Calculated 24-Hour Rate> GAS-MCF Flow Tubing Casing Pressure Oll-BBl GAS-MCF WATER-BBl CHOKE SIZE GAS-Oil RATIO WATER-BBL Oil GRAVITY· API (corr) 28. CORE DATA Brief description of lithology, porosity, fractUI8S, apparent d~ and præsence of 01, gas or water. Submit core chips. NIA Fonn 1D-407 Rev. 7-1-80 CONTINUED ON REVERSE SIDE REC'EIVED SEP 0 7 2000 Al88k8 Oši & Gas Cons. Commission Anchoråge Submit In duplicate 29, (' GEOLOGIC MARKERS 30. ( FORMATION TESTS NAME MEAS,DEPTH TRUE VERT. DEPTH Include Interval tested, pressure data, all fluids recovered and gravity, GOR, and time of ead! phase. Alpine D 10350' 6835' Base Alpine 10407' 6852' N/A 31. LIST OF AlTACHMENTS Summary of Daily Operations, Directional Survey 32. I hervby certify that the foUowlng Is true and correct to the best of my knowledge. Questions? Call Brian Robertson 265-6034 Signed ft:':.¿, ()(..,( G. C. Alvord 11tle Alpine Drilling Team l~der Date , t)1 1)0 Prspared by Shsron AIJ8up-DraJcø INSTRUCTIONS General: This form is designed for submitting a complete and correct well completion report and log on all types of lands and leases In Alaska. Item 1: Classification of Service wells: Gas Injection, water Injection, steam injection, air injection, salt water disposal, water supply for injection, observation, injection for in-situ combustion. Item 5: Indicate which elevation is used as reference (where not otherwise shown) for depth measurements given in other spaces on this form and in any attachments. Item 16 and 24: If this well is completed for separate production from more tha.n one interval (mu~iple completion), so state in item 16, and in item 24 show the producing intervals for the interval reported in item 27. Submit a separate form for each additional interval to be separately produced, showing the data pertinent to such interval. Item 21: Indicate whether from ground level (GL) or other elevation (DF, KB, etc.). Item 23: Attached supplemental records for this well should show the details of any mu~iple stage cementing and the location of the cementing tool. Item 27: Method of Operation: Flowing, Gas Lift, Rod Pump, Hydraulic Pump, Submersible, Water Injection, Gas Injection, Shut-in, Other-explain. Item 28: If no cores taken, indicate -none-, RECEIVED Form 1 D-407 SEP 07 2000 Alaska o§ & Gas Cons. Commission A__L _._.,. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Mechanical Integrity Test Email to: Tom_Maunder@admin.state.ak.us; Bob_Fleckenstein@admin.state.ak.us; Jim_Regg@admin.state.ak.us OPERATOR: ConocoPhillips Alaska Inc. FIELD I UNIT / PAD: Alpine/ CRU/ CD1 DATE: 09/04/05 OPERATOR REP: Arend/Greenwood AOGCC REP: Chuck Scheve Packer Depth Pretest Initial 15 Min. 30 Min. wellCD1-01 I Type Inj. G TVD I 6,885' Tubing 790 790 790 790 Interval 4 P.T.D. 1990460 Type test P Test psi 1721.25 Casing 850 2,130 2,110 2,110 P/F P Notes: OA 400 450 450 450 welllcD1-02 I Type Inj. I S TVD I 6,823' Tubing 1,100 1,100 1,100 1,100 Interval 4 P.T.D. 2001720 Type test P Test psi 1705.75 Casing 400 2,150 2,120 2,110 P/F P Notes: OA 650 675 675 675 wellCD1-03 Type Inj. S TVD I 6,881' Tubing 1,335 1,335 1,335 1,335 Interval 4 P.T.D. 1991200 Type test P Test psi 1720.25 Casing 550 2,110 2,100 2,100 P/F P Notes: OA 650 750 750 750 welllcD1-05 Type Inj. S TVD I 6,684' Tubing 735 735 735 735 Interval 4 P.T.D. 1991280 Type test P Test psi 1671 Casing 1 ,490 2,380 2,210 2,200 P/F P Notes: OA 400 450 430 430 welllcD1-06 Type Inj. G TVD I 6,622' Tubing 2,320 2,320 2,320 2,320 Interval 4 P.T.D. 2000830 Type test P Test psi 1655.5 Casing 1,100 2,130 2,130 2,130 P/F P Notes: OA 450 475 475 475 welllcD1-13 Type Inj. G TVD I 6,781' Tubing 3,150 3,150 3,150 3,150 Interval 4 P.T.D. 1990520 Type test P Test psi 1695.25 Casing 750 2,140 2,140 2,140 P/F P Notes: OA 400 400 400 400 welllcD1-14 Type Inj. S TVD I 6,666' Tubing 1,270 1,270 1,270 1,270 Interval 4 P.T.D. 2010380 Type test P T est psi 1666.5 Casing 150 2,120 2,100 2,090 P/F P Notes: OA 600 650 650 650 welllcD1-16 Type Inj. G TVD I 6,733' Tubing 3,390 3,390 3,390 3,390 Interval 4 P.T.D. 1990940 Type test P Test psi 1683.25 Casing 950 2,170 2,170 2,170 P/F P Notes: OA 750 750 775 775 welllcD1-19A I Type Inj. I I TVD I 6,633' Tubing 850 850 850 850 Interval 0 P.T.D. 2000400 Type test P Test psi 1658.25 Casing 0 2,170 2,140 2,140 P/F P Notes: 2 Year MIT cycle per AIO OA 350 375 375 375 Test Details: TYPE INJ Codes D :::: Drilling Waist G:::: Gas I = Industrial Waistewater N = Not Injecting W = Water TYPE TEST Codes M = Annulus Monitoring P = standard Pressure Test R = Internal Radioactive Tracer Survey A = Temperature Anomaly Survey D = Differential Temperature Test INTERVAL Codes I = Initial Test 4 = Four Year Cycle V = Required by Variance T = Test during Workover o = Other (describe in notes) MIT Report Form Revised: 06/19/02 2005-0904_M IT _ CRU_ CD1-19A_ CS. xis Area Injection Order No. 18B October 7, 2004 Page 6 Rule 2 Authorized Iniection Strata for Disposal (Restated from AID 1SA) Within the affected area, Class II fluids may be injected for purposes of disposal into strata that are com- mon to and correlate with the interval between the measured depths of 8,432 and 9,540 feet in the Sohio Alaska Petroleum Company Nechelik No. 1 well. Rule 3 Fluid Iniection Wells (Restated from AID 1SA) The underground injection of fluids must be through a well permitted for drilling as a service well for in- jection in conformance with 20 AAC 25.005 or through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280. Rule 4 Monitorin2; the Tubin2;-Casin2; Annulus Pressure Variations (Restated from AID 1SA) The tubing-casing annulus pressure and injection rate of each injection well must be checked at least weekly to ensure there is no leakage and that it does not exceed a pressure that will subj ect the casing to a hoop stress greater than 70% of the casing's minimum yield strength. Rule 5 Reportin2; the Tubin2;-Casin2; Annulus Pressure Variations (Restated from AID 1SA) Tubing-casing annulus pressure variations between consecutive observations need not be reported to the Commission unless well integrity failure is indicated as in Rule 7 below. Rule 6 Demonstration of Tubin2;/Casin2; Annulus Mechanical Inte2;ritv The mechanical integrity of an injection well must be demonstrated before injection begins, after a work- over affecting mechanical integrity, and at least once every 4 years while actively injecting. For slurry injection wells, the tubing/casing annulus must be tested for mechanical integrity every 2 years. The MIT surface pressure must be 1500 psi or 0.25 psi/ft multiplied by the vertical depth, whichever is greater, must show stabilizing pressure and may not change more than 10% during a 30 minute period. Anyal- ternate means of demonstrating mechanical integrity must be approved by the Commission. The Com- mission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. Rule 7 Well Inte2ritv Failure and Confinement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injec- tion rate, operating pressure observation, test, survey, log, or other evidence, the operator shall immedi- ately notify the Commission and submit a plan of corrective action on a Form 10-403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule S Plu2;2;in2; and Abandonment of Iniection Wells (Restated from AID 1SA) An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission in accordance with 20 AAC 25.105. #4 . . ALASKA OIL AND GAS CONSERVATION COMMISSION Date: to...4--OS- Time W:CðA."'-- MEETING - Subject C DI- l'ì4 ~~ }.,\~ NAME - AFFILIATION TELEPHONE (pLEASE PRINT) ~1 "'D ~ I ~ r--.~19 ('~ Fo€l3W M ¡ ¡¿,{. JIf. í'VI/-I"'-/ M,,~<_ l;Nw,~ \P~\ ~b,^~ ~S""""' -ýrN .Lvchf V ¿\j'/ 5' ed ÞlOù~ 1- Artx;cc... V '193-12.3 ç.., 7(12..- ) 2-2-) ~(P3 --45 74- 2(,S""'\LJ.1R -z' 3 - '-'I <¿(2.'- Zfð3- '-I59-5 7PJ3 - {2.. L1 CPAJ WA1 CPA I CfIT Z /VGC-C- #3 . ~\ 7""'""""9 .,-;, ,'= ~.;==o;< .1 '1;,."j '=j 'ì' f' ", ", "'"! r " .F" ~ \. 'I! ,.'~ ì ';,1 '\. "~! 'I' 'I 1J ~ '11,i:;J n'~', 1, I. " '1 ,i 1 l \..1,1 1, iI ,!"\ '1 ,1" "~' W:W ;~~ ~ .f'? jþ U /7'\ ~n, ,,7'~, I "1 i j ;;.~\;, 'w ..fh'~ ¡ ¡ /1'\\ \\ I......' Lb ,,,...,j,., " ij/'11M: Jj--'~\r1}'1 J.J w, ,!.,.¡ w'~ ~ f ¡\ 1 ,ftH ¡UI in, \ ::-J:..,a AI,ASIiA. OIL AlQ) GAS CONSERVATION COltDllSSION September 23,2005 Terrance S. Lucht Acting Vice-President North Slope Operations & Development, Alaska ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510-0360 Re: Scheduled Informal Review Well CDI-19A Dear Mr. Lucht: . FRANK H. MURKOWSKI, GOVERNOR 333 W. 7'" AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 The Alaska Oil and Gas Conservation Commission ("Commission") is in receipt of your September 21,2005 letter requesting Informal Review of the Commission's proposed en- forcement action for Well CD 1-19 A. The Informal Review you have requested has been scheduled for October 14, 2005 at 10:00 am at the Commission offices, 333 West ih Avenue Ste 100, Anchorage, Alaska. If you have any additional documentary material you wish the Commission to consider please file it with us by the close of business 0 onday October 10, 2005 so we will have time to fully consider it prior to our meet' g. cc: Daniel T. Seamount, Commissioner Cathy Foerster, Commissioner #2 . ConoccrPhillips . Terrance S. Lucht Acting Vice President North Slope Operations & Development, Alaska ATO 2100 700 G Street POBox 100360 Anchorage, AK 99510 Ph: (907) 263-4585 September 21, 2005 Mr. John K. Nonnan, Chainnan Alaska Oil and Gas Conservation Commission State of Alaska 333 \V. 7th Avenue, Suite 100 Anchorage, Alaska 99501-3539 Re: Notice of Proposed Enforcement Action, Well CRU CDI-19A Dear Mr. Nonnan: I received your September 9, 2005, letter regarding a proposed enforcement action against ConocoPhillips Alaska, Inc. ("CP AI") in connection with Colville River Unit ("CRU") well CDI-19A. I believe it would be of value to both CPAI and the Alaska Oil and Gas Conservation Commission to have further discussion of the circumstances involved, so I hereby request an infonnal review as offered in your letter and described in 20 AAC 25.535(c). Hopefully, a time can be scheduled for the infonnal review that is mutually convenient, allowing participation by those most knowledgeable about the relevant circumstances. I ask your staff to contact Michael Mooney at 263-4574 to schedule a time for the infonnal review. Of course, you may also contact me if I can be of any assistance. Sincerely, ~~ Terrance S. Lucht Acting Vice President North Slope Operations & Development, Alaska TSL:MBM By fax (907-276-7542) & confirmation mail copy / #1 e e o JI t70stage Ul o o ,Return Reclept Fee o (Endorsement Required) o Restricted Delivery Fee Ul (Endorsement Required) .-'=I fT1 Certified Fee 2.30 1.75 Postmark Here Total Postage & Fees $ t..f. dJ;)/;. g -~~~:-~~--___jQb_n____Wh_:Lfu_b_e_a_d__oo__ ~ -;t~?:f;;~?::~5---.1{)::J mto_O______oo______________ CIty. State, ZIP+4 º m¡~¡fI~Î nT', ". '. '.". ,~11\f:ÀalfJ!1l~~:ø èlFC,::: 8<65JH. H (~V7f1) 09/08/05 ~ UNITED STI1TES IJà po~mL SERViCE; ***** WELCOME TO ***** 5TH AVENUE POSTAL STORE ANCHORAGE, AK 99501-2351 09/08/05 02:15PM Store USPS Trans 43 Wkstn sys5002 Cashier KGS3HH Cas~ier's Name DENISE Stock Unit Id WINDENISE PO Phone Number 800-275-8777 USPS # 0203150535 1. Fi rst Class Destination: Weight: Postage Type: Affix. Post.: Total Cost: Base Rate: SERVICES Ce rt i f i ed Ma i 1 70023150000535211560 Rtn Recpt (Green Card) Subtotal Total 0.00 99510 0.70 oz. Affixed -4.42 4.42 0.37 2.30 1. 75 0.00 0.00 Number of Items Sold: We here at the Postal Store appreciate You as our customer and wish you a Happy Holiday and a Safe New Year ~. ~-:::tOð'~ c.-:::J[' -I: :.J ..~ :1 '. I 12.._ r\J ., ".:.:1 . an -e: fA\ - IÄ\ (0"(( fð\ III J f If\\ "Uti \l1),\\ Ir1\ ALASIiA. OIL AND GAS CONSERVATION COMMISSION September 6, 2005 . / I ¡ l I i I Î I FRANK H. MURKOWSKI, GOVERNOR 333 W. 7m AVENUE. SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 Certified Mail Return Receipt Requested 70023150000535211560 John Whitehead Vice-President ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510-0360 Re: Notice of proposed enforcement action Failure to perform required MITs on CRU CDI-19A Dear Mr. Whitehead: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission ("Commission") hereby notifies ConocoPhillips Alaska, Inc. ("CP AI") of a proposed enforcement action. The Commission considers that CP AI may have violated provisions of Area Injection Order 18B, Rule 6 (Demonstration of Tubing/Casing Annulus Mechanical Integrity) in connection with operating Colville River Unit ("CRU") well CDI-19A. Specifically, it appears that CP AI violated Rule 6 of Area Injection Order No. 18B ("AIO 18B") by failing to perform required mechanical integrity tests ("MIT"). Rule 6 of AIO 18B provides: "The mechanical integrity of an injection well must be demonstrated be- fore injection begins, after a workover affecting mechanical integrity, and at least once every 4 years while actively injecting. For slurry injection wells, the tub- inglcasing annulus must be tested for mechanical integrity every 2 years. The MIT surface pressure must be 1500 psi or 0.25 psVft multiplied by the vertical depth, whichever is greater, must show stabilizing pressure and may not change more than 10% during a 30 minute period. Any alternate means of demonstrat- ing mechanical integrity must be approved by the Commission. The Commission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. " John Whitehead September 6, 2005 . Page 2 of2 . . In an electronic mail ("E-mail") message dated August 30, 2005, CP AI acknowledged that Well CDI-19A had not been tested for mechanical integrity since March 30, 2001. Data provided with the message confirms the use of the well as an intermittent slurry in- jector. There is also no record that CP AI obtained Commission approval of an alternate means of demonstrating mechanical integrity as provided for in Rule 6 of AID 18B. Fur- ther, the Commission is unaware of any effort by CP AI to obtain administrative relief (AID 18B, Rule 11) from well integrity demonstration requirements. The Commission proposes to order the following corrective actions by CP AI: (1) Within 30 days from the effective date of the enforcement order, CP AI shall sub- mit for Commission review and approval a complete description of an MIT track- ing procedure (i.e., test pressures, test intervals, results) for all injection wells that corrects deficiencies in its existing process and assures the completion of MITs within the required time interval and otherwise assures compliance with Commis- sion requirements (including 20 AAC 25.310); (2) Upon approval by the Commission, CP AI shall fully implement the MIT tracking procedure for all injection wells operated by CP AI in Alaska; and (3) CP AI shall report on a monthly basis well pressure data (tubing, inner annulus, and outer annulus) for Well CDI-19A to confirm ongoing mechanical integrity. Pressure data provided by CP AI for 2005 (January I - August 30) indicates there is no pressure communication between the tubing and inner annuls of this disposal injector. Therefore, the Commission proposes no civil penalty under AS 31.05.150(a) since, among other reasons, the well has retained integrity (no leakage, no pressure communica- tion) throughout its operating life as demonstrated by Annual Performance Reports for 2002-2005. As provided by 20 AAC 25.535(c), within 15 days after receipt of this notification CPAI may file with the Commission a written response that concurs in whole or in part with the proposed action described here, requests informal review, or requests a hearing under 20 AAC 25.540. If informal review is requested and CPAI disagrees with the Commission's proposed decision or order after that review, CP AI may then request a hearing within 10 days after the proposed decision or order is issued. If CP AI does not file a timely written response to this notification, the Commission will consider CP AI to have accepted by default the pro sed action described above. If CP AI requires more than 15 days to respond, you m for good cause shown request an exten- sion of the 15-day response ~ II Sle-ety, hn ~rman Chairman . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Mechanical Integrity Test Email to: Tom_Maunder@admin.state.ak.us; Bob_Fleckenstein@admin.state.ak.us; Jim_Regg@admin.state.ak.us OPERATOR: ConocoPhillips Alaska Inc. FIELD I UNIT I PAD: Alpinel CRUI CD1 DATE: 09104105 OPERATOR REP: Arend/Greenwood AOGCC REP: Chuck Scheve Packer Depth Pretest Initial 15 Min. 30 Min. wellCD1-01 I Type Inj. I G TVD I 6,885' Tubing 790 790 790 790 Interval/ 4 P.T.D. 1990460 Type test P Test psi 1721.25 Casing 850 2,130 2,110 2,110 P/F P Notes: OA 400 450 450 450 wellCD1-02 I Type Inj. I S TVD I 6,823' Tubing 1,100 1,100 1,100 1,100 Interval/ 4 P.T.D. 2001720 Type test P Test psi 1705.75 Casing 400 2,150 2,120 2,110 PIF P Notes: OA 650 675 675 675 wellCD1-03 Type Inj. S TVD I 6,881' Tubing 1,335 1,335 1,335 1,335 I nterval 4 P.T.D. 1991200 Type test P Test psi 1720.25 Casing 550 2,110 2,100 2,100 P/F P Notes: OA 650 750 750 750 wellCD1-05 Type Inj. S TVD I 6,684' Tubing 735 735 735 735 I nterval 4 P.T.D. 1991280 Type test P Test psi 1671 Casing 1,490 2,380 2,210 2,200 P/F P Notes: OA 400 450 430 430 wellCD1-06 Type Inj. G TVD I 6,622' Tubing 2,320 2,320 2,320 2,320 Interval 4 P.T.D. 2000830 Type test P Test psi 1655.5 Casing 1,100 2,130 2,130 2,130 P/F P Notes: OA 450 475 475 475 wellCD1-13 Type Inj. G TVD I 6,781 ' Tubing 3,150 3,150 3,150 3,150 Interval/ 4 P.T.D. 1990520 Type test P Test psi 1695.25 Casing 750 2,140 2,140 2,140 PIF P Notes: OA 400 400 400 400 welllcD1-14 Type Inj./ S TVD 6,666' Tubing 1,270 1,270 1,270 1,270 Interval/ 4 P.T.D. 2010380 Type test P Test psi 1666.5 Casing 150 2,120 2,100 2,090 P/F P Notes: OA 600 650 650 650 wellCD1-16 Type Inj. G TVD / 6,733' Tubing 3,390 3,390 3,390 3,390 I nterval 4 P.T.D. 1990940 Type test P Test psi 1683.25 Casing 950 2,170 2,170 2,170 P/F P Notes: OA 750 750 775 775 -?> wellCD1-19A Type Inj. I I TVD 6,633' Tubing 850 850 850 850 Interval/ 0 P.T.D. 2000400 Type test P Test psi 1658.25 Casing 0 2,170 2,140 2,140 P/F P Notes: 2 Year MIT cycle per AIO OA 350 375 375 375 Test Details: TYPE INJ Codes D = Drilling Waist G = Gas I = Industrial Waistewater N = Not Injecting W = Water TYPE TEST Codes M = Annulus Monitoring P = Standard Pressure Test R = Internal Radioactive Tracer Survey A = Temperature Anomaly Survey D = Differential Temperature Test INTERVAL Codes I = Initial Test 4 = Four Year Cycle V = Required by Variance T = Test during Workover o = Other (describe in notes) MIT Report Form Revised: 06/19/02 MIT CRU CD1 09-04-05.xls [Fwd: Alpine CDl-19A (PTD 200-040)] . . SlIb.iect: [F\....d: Alpinc CDI-19A (PID 200-(40)] J'"rom: James Regg <jim_.regg@admin.statc.ak.lIs> Date: Wed, 31 AlIg 2005 15:47:49 -0800 To: Tom Maunder <tom maundcr,.'i:ìadmin.state.ak.lIs>. Robert E Mintz - .- '~,..,.I' ~ <robcrt_plintL:Ø!law .statc.ak .lIS> I think we have to address this as an enforcement action, particularly given the fact that we have to report noncompliance to EP A as part of our quarterly UIC performance report (EP A form 7520-4, Part IV is required with each quarterly report to document exceptions - noncompliance - during the past quarter). Draft notice of proposed enforcement is attached for your review. Our new procedure of sending a letter advising of investigation and soliciting information does not seem to be necessary in this case. My recommendation is to require very simple corrective action (which they have done or can do simply); I do not see any value in a monetary penalty. Suggested corrective action is to require CPA to address in writing their corrective actions, require monthly reporting of tubing/inner annulus/outer annulus pressures, and completion ofMIT (scheduled for 9/5/05). They get off easy (no monetary penalty) because ofthe self reporting and fact that well has not lost integrity, and we accomplish our responsibilities as primary UIC Class 2 enforcement agency. Jim -------- Original Message -------- Subject:Alpine CD1-19A (PTD 200-040) Date:Tue, 30 Aug 2005 16:46:43 -0800 From:NSK Problem Well Supv <n1617(à]conocophillips.com> To:James Regg <:Jim regg(a~admin.state.ak.us>, Thomas Maunder <tom maunder@?admin.statc.ak.us> CC:A10nzo, Chris <Chris.Alol1zo(a)conocophillips.com>, Erwin, Michael D <Michae1.D.Erwin(â}conocophillips.com>, Elmer, Matt 1. <Matt.J.Elmer(c~conocophillips.com>, ALP Ops Maint Supv <alpI167@}conocophillips.com>, Alpine Lead Operators <alp1006~conocophillips.com>, Hanson, Kelli L <Kclli.I."JIanson@!,conocophillips.com>, Mooney, M <M.Mooney(a)conocophillips.com>, NSK Problem Well Supv <11 1617 (Cl?conocophillips.com> Jim/Tom, CD1-19A is a Class II disposal well located on the Alpine CD1 drill site. The well is used for disposal of drilling and wellwork fluids in the Sadlerochit formation. CD1-19A has been used for slurry injection intermittently since initial injection in August 2000. Under Area Injection Order No. 188, Rule 6, a MIT is required every 2 years for slurry injection wells. The initial CD1-19A MIT was conducted on 3/30/01; however, the next required MIT was not completed in 2003. This was an inadvertent omission as the completion report identifies this well as a waste disposal well and was believed to only require a 4 year MIT similar to other North Slope Class II disposal wells. A recent review of Area Injection Order 188 was conducted during preparations for normal 4 year injection well MIT's and revealed this error. As a result of this oversight, the MIT frequency has been corrected in our MIT database and we will pursue a MIT at the earliest possible opportunity. 10f3 8/31/20053:52 PM [Fwd: Alpine CDl-l9A (PTD 200-040)] . . Though the 2003 MIT was not performed, the following describes regular monitoring and reporting activities that have occurred in accordance with Ala 188 and prudent operations practices: CD1-19A Injection History: August 2000 - June 2001 July 2001 - November 2002 December 2002 - May 2003 June 2003 - October 2004 November 2004 - August 2005 Slurry disposal Liquid disposal only Slurry disposal Liquid disposal only Slurry disposal CD1-19A Monitoring and Reporting Practices: Tubing, IA and OA Pressures monitored daily Tubing, IA and OA Pressures and pumped volumes recorded every 15 minutes during injection operations Annual Performance Reports submitted on 3/27/02, 4/15/03,3/17/04 and 3/23/05 Current and historical data indicates the tubing-casing annulus has full mechanical integrity. See the attached plot below for Tubing and IA pressures for the last 6 months. CD1-19A T/I 4000 3500 3000 2500 II) 2000 c. 1500 1000 500 o .. l.C) l.C) l.C) l.C) l.C) l.C) l.C) l.C) L.íJ L.íJ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 C:! C:! C! C:! C:! C:! C:! C:! C:! C! ..-- l.C) en ("\ UJ ("\ UJ ~ ('Y') ~ -- ..-- C! ..-- C! ..-- C:! C:! ..-- ........ -- -- """ l.C) ..-- ("\ ("\ ('Y') ('r') """ Date l.C) o o C:! ..-- C:! l.C) l.C) o o C:! ~ to l.C) o o C:! ro ..-- ""'- UJ L.íJ o o C:! C! r-... l.C) o o C:! UJ ..-- ""'- r-... l.C) o o C:! o (Q r-... -+- Tubing ----IA I A MIT on CD1-19A is tentatively scheduled for Saturday September 5th, contingent on State Inspector availability. Please let me know if you have any questions regarding this well. 20f3 8/31/20053:52 PM [Fwd: ~lpine CDl-19A (PTD 200-040)] MJ Loveland ConocoPhillips Problem Well Supervisor 659-7224 e Alpine CDl-19A Enf Act Letter 30f3 . Content-Type: application/msword Content-Encoding: base64 8/31/20053:52 PM . . Alpine CD1-19A (PTD 2000400) Injection History 8/31/2005 ¡initial MIT 3/30101 pre-inj MIT 6/1/00 \re\\ Injection Order No. 18B )ctober 7, 2004 'age 5 ) . ) . A{pJÆe 9. Class I industrial waste disposal injection is, and will continue to be, in accord with EPA VIC Area Permit AK-1I003-A. 10. No wells may be drilled into or below the arresting zone (lower Kingak) within the 'l.4 mile radius area of review of well WD-02 under EPA permit AK-1I003-A. 11. Well mechanical integrity is demonstrated in accordance with 20 MC 25,4 12 prior to initiation of injection or disposal operations. 12. The mechanical integrity of each injection well will be tested at least every four years after an ini- tial test. Wells used for grind and inject purposes must be tested every two years. 13. Tubing-casing annulus pressure and injection rates are monitored at least weekly for surveillance of operational conditions. 14. An amendment to Area Injection Order 18A to expand the project area will not cause waste nor jeopardize correlative rights. ~ow, THEREFORE, IT IS ORDERED that: fhis Area Injection Order supersedes AIO 18A dated April 18, 2000, and AIO 18 dated January Z4, 2000. The findings, conclusions and administrative record for AIO's 18 and 18A are adopted JY reference and incorporated in this decision so far as they do not conflict with the findings of this )rder. The following rules, in addition to statewide requirements under 20 AAC 25, to the extent Jot superseded by these rules, apply to the Alpine Oil Pool within the following affected area: UMIAT MERIDIAN flIN R4E Section 1,2,3,4,5, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16,21,22,23,24,25,26,27. f11N R5E Sections 1,2,3,4,5,6,7,8,9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19,20,21,22,23,24, 29, and 30. fl2N R3E Sections 25, 36. fl2N R4E Sections 20,21,22,23,24,25,26,27,28,29,30,31,32,33,34,35 and 36. fl2N R5E Sections 13, 14, IS, 19,20,21,22,23,24,25,26,27,28,29,30,31,32,33,34,35 and 36. Rule 1 Authorized Injection Strata for Enhanced Recoverv (Restated from AIO 1SA) Within the affected area, fluids may be injected for purposes of pressure maintenance and enhanced re- covery into strata that are common to and correlate with the interval between the measured depths of 6,876 and 6,976 feet in the Bergschrund No.1 well. \rea Injection Order No. 18B )ct~ber 7, 2004 'age 6 ) . ) . ~ule 2 Authorized Injection Strata for Disposal (Restated from AIO 1SA) iVithin the affected area, Class II fluids may be injected for purposes of disposal into strata that are com- non to and correlate with the interval between the measured depths of 8,432 and 9,540 feet in the Sohio \.laska Petroleum Company Nechelik No.1 well. ~ule 3 Fluid Injection Wells (Restated from AIO 18A) rhe underground injection of fluids must be through a well permitted for drilling as a service well for in- ection in conformance with 20 AAC 25.005 or through a well approved for conversion to a service well or injection in conformance with 20 AAC 25.280. ~ule 4 Monitorine; the Tubine;-Casine; Annulus Pressure Variations (Restated from AIO 1SA) [he tubing-casing annulus pressure and injection rate of each injection well must be checked at least iVeekly to ensure there is no leakage and that it does not exceed a pressure that will subject the casing to a lOOp stress greater than 70% of the casing's minimum yield strength. lule 5 Reportine; the Tubine;-Casine; Annulus Pressure Variations (Restated from AIO 1SA) rubing-casing annulus pressure variations between consecutive observations need not be reported to the :::ommission unless well integrity failure is indicated as in Rule 7 below. Rule 6 Demonstration of Tubin2lCasine; Annulus Mechanical Intee:rit~ fhe mechanical integrity of an injection well must be demonstrated before injection begins, after a work- )ver affecting mechanical integrity, and at least once every 4 years while actively injecting. For slurry .1\Ìection wells, the tubing/casing annulus must be tested for mechanical integrity every 2 years. The MIT mrface pressure must be 1500 psi or 0.25 psi/ft multiplied by the vertical depth, whichever is greater, Dust show stabilizing pressure and may not change more than 10% during a 30 minute period. Any al- :emate means of demonstrating mechanical integrity must be approved by the Commission. The Com- :nission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. Rule 7 Well Inte2;ritv Failure and Confmement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injec- tion rate, operating pressure observation, test, survey, log, or other evidence, the operator shall immedi- ately notify the Commission and submit a plan of corrective action on a Form 10-403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule 8 Plue;e:ine: and Abandonment of Injection Wells (Restated from AIO 1SA) An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission in accordance with 20 MC 25.105. A.rea Injection Order No. 18B October 7, 2004 Page 7 ) . ) . Rule 9 Surveillance (Modified from AIO ISA) For grind and inject slurry injection wells, a baseline temperature survey from surface to total depth, ini- tial step rate test to pressure equal or exceeding maximum injection pressure and pressure falloff are re- quired prior to sustained disposal injection. Regular fill depth tags are required at least once annually or as warranted following consultation with the Commission. Operating parameters including disposal rate, pressure, annuli pressures and volume of slurry pumped must be monitored and reported according to the requirements of20 AAC 25.432. For slurry injection wells, an annual performance report will be required including rate and pressure per- formance, surveillance logging, fill depth, survey results, and volumetric analysis of the disposal storage volume, estimate of fracture growth, if any, and updates of operational plans. Report submission must be on or before April I, in conjunction with the Alpine Pool Annual Reservoir Report. Rule 10 Notification (Restated from AIO ISA) The operator must notify the Commission if it learns of any improper Class II injection. Additionally, notification requirements of any other State or Federal agency remain the operators' responsibility. Rule 11 Administrative Actions Unless notice and public hearing is otherwise required, the Commission may administratively waive or amend any rule stated above as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in fluid movement outside of the authorized injection zone. DO...NE. at.A~. ~Alaska.an. doc~obe , 04. Æ~b.OU: 1~"· ~ ~~ '~'~~t~ W /~ \ . \ ¡ Il,~>~:-:~.\ ~. /' Þ' .... 0 ../ '\~) \ Jo K.~an, Chai <In . --- .. ;~'.' _ ...; ~~;.-::~~~~'Ir.~"::'.\1 as ~l an as onservatton ComnnSSlOn a _-J:¡I~.I. ··"'t·!.·,I'...h...·'/I·, ~J ~ t' .¡.:. '" t~~ ""'\1 ~i""'~ ~ I..... 1'1 ~^?; f,;f ~ ;<'7,{t: ':" I~ t ~ "'. (. " J l \ì ~'~":'I 'W -,.il ß . 'A ,..t , ~····Ij.. .. f,' ^' \....:-:' ·"IJ~t~~~;.:\"f::':'. 'j/ .~/ Dan T. Seamo Jr., Commissioner \~~. ¡, ·;~.I-¡~X~·i\~~rà;.~~~-;:,.. ;.~9.,,!' Alaska Oil and Gas Conservation Commission ;' ,t... ·".J,.:~..·!!t~i: -,!"; ,I: '/""L':>;t . . /t. .',. .,.~- ,., ";»~i'JOl'; :¿c~~A~::'" . ~....",.'", ...l':'j,:f"IO AS 31.05.080 provides thäí within 20 days after receipt of written notice of the entry of an order. a person affected by it may file with the Commis- sion an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order. or next work- ing day if a holiday or weekend. to be timely filed. The Commission shall grant or refuse the application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10-day period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing. both being the final order of the Comn¡ission. to appeal the deci- sion to Superior Court. Where a request for rehearing is denied by nonaction of the Commission. the 30-day period for appeal to Superior Court runs from the datc on which the request is decmed denied (i.e.. 10th day after the application for rehearing was filed).