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10/6/2005 Orders File Cover Page. doc
.
.
Index Conservation Order 351A
Cook Inlet Field
1.
2.
3.
4.
June 16,2004
June 30, 2004
November 22, 2004
November 23, 2004
5.
6.
7.
8.
January 4, 2005
January 4, 2005
January 4, 2005
December 13, 2005
AOGA/AOGCC Work group
AOGAA/AOGCC Work group
Notice of Hearing and Affidavit of Publication
Proposal Regarding Rules Waiving Sundry Approval
Requirements
Workgroup Determination
Hearing Sign In Sheet
Transcript
AOGCC Letter re: errata to Sundry Waiver Rules
Conservation Order 351A
.
.
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 W. 7th Avenue, Suite 100
Anchorage Alaska 99501-3192
Re: Proposed amendment of rules waiving )
certain requirements of20 AAC 25.280 )
concerning Applications for Sundry Approvals )
for workover operations )
)
)
)
)
Conservation Order No. 351A
Listed Unocal Operated
Cook Inlet Fields
January 24, 2006
IT APPEARING THAT:
1. Conservation Order No. 351 ("CO 351"), issued December 29, 1994, waived the
requirements of 20 AAC 25.280(a) for certain wells in the following identified pools
in certain specified Unocal operated Cook Inlet Fields:
FIELD CO POOL
McArthur River 80A Hemlock Oil Pool
(Trading Bay Unit) Middle Kenai G Oil Pool
West Foreland Oil Pool
228 Middle Kenai Gas Pool
Swanson River 123 HemlockOil Pool
Undefined Oil Pool
Middle Ground Shoal 44 and 54 MGS-A Oil Pool
MGS B, C, D Oil Pool
MGS E, F, G Oil Pool
Granite Point 76 and 76.32 Middle Kenai Oil Pool
Hemlock Oil Pool
Trading Bay 250 Undefined Oil Pool
(Monpod Platform) 93A Hemlock Oil Pool
Middle Kenai - B Oil Pool
Middle Kenai - C Oil Pool
Middle Kenai - D Oil Pool
Middle Kenai - E Oil Pool
Ivan River Undefined Gas Pool
Lewis River Undefined Gas Pool
Conservation Order 351
Page 2
.
January 24, 2006
CO 351 further required the operator to provide the Alaska Oil and Gas Conservation
Commission ("Commission") with a listing of planned workover operations including
the well and intended operation on a weekly basis.
2. One additional gas pool has been defined and the Undefined Oil Pool in Swanson
River Field has been incorporated into the Hemlock pool since CO 351 was adopted.
McArthur River Field
Swanson River Field
Middle Kenai Gas Pool
Hemlock Oil Pool
CO 228
CO 123 A
3. Effective June 2004, Unocal halted operations on Middle Ground Shoal ("MGS")
platforms Baker and Dillon. Unocal is neither producing or injecting in MGS Pools
A, B, C, D, E, F or G.
4. On its own motion, the Commission proposed to amend the waiver for the listed
pools in the specified Unocal operated Cook Inlet Fields.
5. Notice of public hearing was published in the Anchorage Daily News on November
22, 2004.
6. No protests to the proposal were filed with the Commission and no public request for
a hearing was made.
7. One comment letter in support of the Commission's proposed action was received.
8. The Commission held the hearing as noticed.
FINDINGS:
1. 20 AAC 25.280(a) (1 - 5) requires all operators to file an Application for Sundry
Approval (Form 10-403) and receive Commission approval prior to performing well
workovers (Le., perforating or reperforating casing, stimulation, pulling tubing,
altering casing, and repairing wells) on any well subject to the Commission's
jurisdiction.
2. 20 AAC 25.280(d) requires an operator to file a Report of Sundry Well Operations
(Form 10-404), including supporting documentation, within 30 days after completing
workover operations.
3. In addition to relieving the operator of the sundry approval requirement for certain
wells in the specified Unocal operated Cook Inlet Fields for the type of operations in
20 AAC 25.280(a) (1 - 5), CO 351 required the operator, on a weekly basis, to supply
the Commission with a listing of the planned operations for which the requirement to
submit a sundry approval application had been waived.
Conservation Order 35'
Page 3
.
January 24, 2006
4. CO 351 is ambiguous as to the categories of wells that are covered by the waiver.
5. Most work within the physical confines of the production casing/liner or the
production tubing has become standard and routine for development and service wells
in the pools that have been defined in the specified Unocal operated Cook Inlet Fields.
Work within service wells, while routinely performed, requires additional regulatory
scrutiny due to the requirements of the Underground Injection Control ("UIC")
Program as delegated to the Commission by the United States Environmental
Protection Agency. Regardless of the well type, it is still important to the
Commission's surveillance and regulatory functions for the Commission to receive
timely reports of such workover operations.
6. While the general operations have become standard and routine, Unocal does not
continuously conduct well workovers utilizing platform rigs or coiled tubing units
("CTU") in their offshore fields.
7. Alteration of casing which provides a physical barrier between the wellbore and the
subsurface formations in development and service wells is not standard or routine so
as to warrant waiving the requirement of advance approval by the Commission.
8. Well workovers as described in 20 AAC 25.280(a), (1), (2), (3) and (5) on
development wells in the pools that have been defined in the specified Unocal
operated Cook Inlet Fields generally do not call for additional requirements beyond
the criteria imposed by regulation.
9. Well workover operations on injection wells may frequently call for additional
requirements such as but not limited to mechanical integrity tests and cement quality
logs.
10. Commission inspectors routinely inspect drilling and well workover operations to
ensure compliance with regulations.
11. Production and injection operations were halted in June 2004 on Unocal operated
Baker and Dillon Platforms in Middle Ground Shoal Field.
12. The attached document titled "Well Work Operations and Sundry Notice/Reporting
Requirements for Pools Subject to Sundry Waiver Rules," dated July 15, 2005, sets
out with more specificity than the Commission's regulations the sundry application
and reporting requirements that apply to various types of workover operations, as
modified consistent with the above findings.
CONCLUSIONS:
1. Waiving the requirements of 20 AAC 25.280(a) (1), (2), and (3) and modifying
the requirements of20 AAC 25.280(a) (5) for development wells in the pools that
Conservation Order 35'
Page 4
.
January 24, 2006
have been defined in the specified Unocal operated Cook Inlet Fields and where
operations have not been halted will result in administrative efficiencies for both
the operator and the Commission.
2. Waiving the requirements of 20 AAC 25.280(a) (1), (2), and (3) and modifying
the requirements of 20 AAC 25.280(a) (5) for development wells in the pools that
have been defined in the specified Unocal operated Cook Inlet Fields and where
operations have not been halted will not promote waste, jeopardize correlative
rights, or result in an increased risk of fluid movement into freshwater.
3. Modifying the requirements of20 AAC 25.280(a) (1) and (5) for service wells in
the pools that have been defined in the specified Unocal operated Cook Inlet
Fields and where operations have not been halted will result in administrative
efficiencies for both the operator and the Commission.
4. Modifying the requirements of20 AAC 25.280(a) (1) and (5) for service wells in
the pools that have been defined in the specified Unocal operated Cook Inlet
Fields and where operations have not been halted will not promote waste,
jeopardize correlative rights, or result in an increased risk of fluid movement into
freshwater.
5. Modifying the requirements of20 AAC 25.280(a) (1) and (5) for service wells in
the pools that have been defined in the specified Unocal operated Cook Inlet
Fields and where operations have not been halted will not compromise the
administration of the Class II UIC program.
6. Increased regulatory scrutiny for work to repair casing (20 AAC 25.280(a) (4)) is
appropriate.
7. Maintaining the requirement to submit a Sundry Notice for workovers in fields
where operations have been halted is appropriate.
8. Maintaining the requirement to submit a Sundry Notice for the initial rig or CTU
workover on an offshore platform will help maintain Commission oversight on
such work.
9. The operator's submission of a list of workover operations actually performed in
the preceding week is expected to aid the Commission with its surveillance and
regulatory responsibilities.
10. The attached document titled "Well Work Operations and Sundry
Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules" dated
July 15, 2005 sets out the appropriate sundry approval and reporting requirements
for frequently performed well operations in the pools that have been defined in the
specified Unocal operated Cook Inlet Fields and where operations have not been
halted.
Conservation Order 35'
Page 5
.
January 24, 2006
NOW, THEREFORE IT IS ORDERED THAT:
The following rules, in addition to statewide requirements under 20 AAC 25, to the
extent not superseded by these rules, apply to the affected areas established in
Conservation Order No. 80A (McArthur River Field, Trading Bay Unit Oil Pools),
Conservation Order No. 228 (McArthur River Field, Trading Bay Unit Middle Kenai Gas
Pool), Conservation Order No. 123A (Swanson River Field Oil Pools), Conservation
Order No. 44 and 54 (Middle Ground Shoal Oil Pools, Baker and Dillon Platforms),
Conservation Order No. 76 and 76.32 (Granite Point Oil Pools), Conservation Order No.
93A (Trading Bay Field Oil Pools, Monopod Platform), Ivan River Unit Undefined Gas
Pool and Lewis River Unit Undefined Gas Pool. These rules supersede the rules adopted
in Conservation Order No. 351.
Rule 1
Except as provided in Rules 4,5, and 8, the requirement to submit a sundry notice (Form
10-403) and supporting documentation for workover activities described in 20 AAC
25.280(a) (1), (2), (3) and (5) is waived or modified for development wells as provided in
the attached document entitled "Well Work Operations and Sundry Notice/Reporting
Requirements for Pools Subject to Sundry Waiver Rules," dated July 15,2005.
Rule 2
Except as provided in Rules 4,5, and 8, the requirement to submit a sundry notice (Form
10-403) and supporting documentation for workover activities described in 20 AAC
25.280(a) (1) and (5) is modified for service wells as provided in the attached document
described in Rule 1.
Rule 3
Except as provided in Rule 8, the attached document described in Rule 1 summarizes the
sundry approval and reporting requirements that apply to various categories of operations
in the specific well types under Commission regulations as modified by these rules.
Rule 4
The requirement to submit a sundry notice (Form 10-403) and supporting documentation
for workover activities described in 20 AAC 25.280(a) (2), (3) and (5) for development
wells and 20 AAC 25.280(a) (5) for service wells is retained when a platform rig is
started up or CTU is initially deployed to a platform.
Rule 5
The Commission reserves the discretion to require that an operator submit an Application
for Sundry Approvals for a particular well or for a particular operation on any well.
Rule 6
On a weekly basis, the operator shall provide the Commission with a report of workover
operations performed during the prior week, including the date, well, nominal operation
Conservation Order 35'
Page 6
.
January 24, 2006
completed, and a brief description of that operation including depths of perforations,
repreforations, and stimulated zones.
Rule 7
Nothing in this order precludes an operator from filing an Application for Sundry
Approvals in advance of any well work.
Rule 8
Rules I, 2, and 3 are not effective as to an offshore platform on which production
operations have been halted.
Rule 9
Unless notice and public hearing are otherwise required, the Commission may
administratively waive the requirements of any rule stated above or administratively
amend any rule 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 an
increased risk of fluid movement into freshwater.
DONE at Anchorage, Alaska and dated January 24, 2006.
@~
Daniel T. Seamount, Jr., Commissioner
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\ ... 11';":' tý I,,~"¡:~·;,~"~.III: I ::-) days after receipt of written notice of the entry of an order, a person affected by it may file with
1'~ \ '::11111 ".', ... .li'ï!l:.iI','" ~'''I ·~hearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the
date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the
application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10-day
period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an
order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for
rehearing is denied by nonaction of the Commission, the 30-day period for appeal to Superior Court runs from the date on which the
request is deemed denied (i.e., 10th day after the application for rehearing was filed).
Well Work Operations and Sundry NoticelReporting Requirements for Pools Subject to Sundry Waiver Rules
July 29, 2005
No Forms Required
-10-403 Not Required
-10-404 Not Required
Thru-tubing Operations (D)
e
· Fill tag
· Set & pull retrievable plugs
· Change GL V's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
· Pump changes.
· Packoff GLM (POGLM)
.
DEVELOPMENT [PRODUCTION] WELLS
1 Form Required
-10-403 Not Required
-10-404/407 or other form Reauired
Thru-tubing Operations (D)
· Permanent cement or mechanical plugs that
do not completely abandon a zone. (D)
· Cutting off tailpipes. (D)
· Perforate new intervals within a pool (D)
· Patches (D)
2 Forms Required
-10-403 Required
-10-404/407 or other form Required
Thru-tubing Operations (D)
. Perforate a new pool (D)
SPECIAL (D)
On a case-by-case basis, a 10-403 will be
required for a particular well or operation
if the Commission requests it.
If a well is operating under a sundry
approval, a 10-403 may be required to
perform work. The operator should
consult with the AOGCC to determine if
a 10-403 is needed.
Attachment
Incorporated by reference into Conservation Orders 261 A, 297 A, 341 D Rule 14,347 A, 351 A and 556
Page 1 of5
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 29, 2005
DEVELOPMENT [PRODUCTION] WELLS
No Forms Required
-10-403 Not Required
-10-404 Not Required
Pumping Operations, including using coil.(D
1 Form Required
-10-403 Not Required
-10-404/407 or other form Required
Pumping Operations, including using coil.
2 Forms Required
-10-403 Required
-10-404/407 or other form Required
Pumping Operations, including using coil
e · Tubing scale removal · Stimulations (frac or acid) (D) . Remedial cementing operations
· Sludge removal · Remedial cementing operations (including but not limited to)
· Freeze protection 0 Conductor Fill (D) 0 Casing shoes (outer annulus) (D)
· Ice plug removal · Squeezes/plugs to control fluid . Repair casing
· Inhibitor squeezes movement in zone (D) (including but not limited to)
· Hot Oil 0 mechanical repairs (D)
· Tubing acid jobs 0 "pumping" repairs (cement or
· Fill clean out gel squeezes) (D)
Other Operations (D)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
Other Operations
· Seal welding on bradenheads (D)
.
Rig/Coil Operations
· Alteration of mechanical completion
(including but not limited to)
o Pulling tubing, milling packers (D)
o Install velocity strings (D)
Other Operations
· Convert producer (D) to injector
· Major welding repairs on wellheads
(D)
· Conductor "cutaways" and surface
casing welding repairs (D)
· Annular disposal (D)
(Reported on form 10-423)
Rig/Coil Operations
· Repair Casing
(including but not limited to)
o Mechanical repairs (D)
(scab liners, tiebacks, etc)
Attachment
Incorporated by reference into Conservation Orders 261 A, 297 A, 341 D Rule 14,347 A, 351 A and 556
Page 2 of5
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 29, 2005
No Forms Required
-10-403 Not Required
-10-404 Not Required
Thru-tubing Operations (S)
SERVICE [INJECTION] WELLS
1 Form Required
-10-403 Not Required
-10-404/407 or other form Required
Thru-tubing Operations (S)
· Fill tag . Perforate new interval within a pool (S)
· Set & pull retrievable plugs
· Change GL V's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
.
.
If operatìonsìnthis column are planned on a A 10-403 should be submitted for any
disposal well, the ?pe~ator should.contact the perforating (new or repert) operations on a
AOGCC to determme if a 10-4031Sneeded. Class II disposal well.
2 Forms Required
-10-403 Required
-10-404/407 or other form Required
Thru-tubing Operations (S)
· Perforate a new pool. (S)
· Permanent cement or mechanical
plugs that do not completely abandon
a zone (S)
· Patches (S)
· Cutting off tailpipes. (S)
SPECIAL (S)
On a case-by-case basis, a 10-403 will be
required for a particular well or operation
if the Commission requests it.
If a well is operating under a sundry
approval, a 10-403 may be required to
perform work. The operator should
consult with the AOGCC to determine if
a 10-403 is needed.
Please note that authorization from EPA
Region 10 may be necessary to perform an)
work on a Class ldisposal well.
Attachment
Incorporated by reference into Conservation Orders 261 A, 297 A, 341 D Rule 14,347 A, 351 A and 556
Page 3 of 5
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 29, 2005
No Forms Required
SERVICE [INJECTION] WELLS
1 Form Required
-10-403 Not Required -10-403 Not Required
-10-404 Not Required -10-404/407 or other form Required
Pumping Operations, including using coil.(S) Pumping Operations, including using coil.
.
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal
· High pressure breakdown or inhibitor
squeezes, excluding frac or acid jobs
· Hot Oil
· Tubing acid jobs
· Fill clean out
Other Operations (S)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
.
· Remedial cementing operations
o Conductor Fill (S)
· Squeezes/plugs to control fluid
movement in zone (S)
Other Operations
· Injection well MIT (on MIT form) (S)
· Initial conversion from water injector
to WAG injector (S)
· Convert from injector to producer if for
more than 30 days. (S)
· Seal welding on bradenheads (S)
2 Forms Required
-10-403 Required
-10-404/407 or other form Required
Pumping Operations, including using coil.
· Stimulations (frac or acid) (S)
· Remedial cementing operations
(including but not limited to)
o Casing shoes (outer annulus) (S)
· Repair casing
(including but not limited to)
o mechanical repairs (S)
o "pumping" repairs (cement or
gel squeezes) (S)
Other Operations
· Major welding repairs on wellheads (S
· Conductor "cutaways" and surface
casing welding repairs (S)
· Annular disposal (S)
(Reported on form 10-423)
Attachment
Incorporated by reference into Conservation Orders 261 A, 297 A, 341 D Rule 14,347 A, 351 A and 556
Page 4 of 5
ulV ,
Rig/Coil Operations
. Alteration of mechanical completion
(including but not limited to)
o Pulling tubing ,milling packers (S)
. Repair Casing
(including but not limited to)
0 Mechanical repairs (S)
(scab liners, tiebacks, etc)
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
J I 29 2005
.
.
Attachment
Incorporated by reference into Conservation Orders 261 A, 297 A, 341 D Rule 14,347 A, 351 A and 556
Page 5 of5
C0351A Cook Inlet Fields
.
.
Subject: C0351A Cook Inlet Fields
From: Jody Colombie <jody _colombie@admin.state.ak.us>
Date: 26 Jan 200609:30: 17 ·0900
BCC: Robert E Mintz <robert_mintz@law.state.ak.us>, Christine Hansen
<c.hansen@iogcc.state.okus>, Terrie Hubble <hubbletl@bp.com>, Sondra Stewman
<StewmaSD@BP.com>, Scott & Cammy Taylor <staylor@alaska.net>, stanekj <stanekj@unocal.com>,
ecolaw <ecolaw@trustees.org>, trmjr 1 <trmjr 1 @aol.com>, jbriddle <jbriddle@marathonoil.com>,
shaneg <shaneg@evergreengas.com>, jdarlington <jdarlington@forestoil.com>, nelson
<knelson@petroleumnews.com>, cboddy <cboddy@usibelli.com>, Mark Dalton
<mark.dalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips.com>,
Worcester" <mark. p. worcester@conocophillips.com>, Bob <bob@inletkeeper .org>~wdv
<wdv@dnr.state.ak.us>, tjr <tjr@dnr.state.ak.us>, bbritch <bbritch@alaska.net>, mjnelson
<mjnelson@purvingertz.com>, Charles O'Donnell <charles.o'donnell@veco.com>, "Randy L.
<SkilleRL@BP.com>, "Deborah J. Jones" <JonesD6@BP.com>, "Steven R. Rossberg"
<RossbeRS@BP.com>, Lois <lois@inletkeeper.org>, Dan Bross <kuacnews@kuac.org>, Gordon
Pospisil <PospisG@BP.com>, "Francis S. Sommer" <SommerFS@BP.com>, Mikel Schultz
<Mikel.Schultz@BP.com>, "Nick W. Glover" <GloverNW@BP.com>, "Daryl J. Kleppin"
<KleppiDE@BP.com>, "Janet D. Platt" <PlattJD@BP.com>, "Rosanne M. Jacobsen"
<JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, mckay <mckay@gci.net>, Barbara F Fullmer
<barbara.f.fullmer@conocophillips.com>, bocastwf <bocastwf@bp.com>, Charles Barker
<barker@usgs.gov> , doug_schultze <doug_ schultze@xtoenergy.com>, Hank Alford
<hank.alford@exxonmobil.com>, Mark Kovac <yesno 1 @gci.net>, 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>, eyancy <eyancy@seal-tite.net>, "James M. Ruuq'.t
<james.m.ruud@conocophillips.com>, Brit Lively <mapalaska@ak.net>, jah <jah@dnr.state.ak.us>,
buonoje <buonoje@bp.com>, Mark Hanley <mark_hanley@anadarko.com>, loren_leman
<loren_leman@gov.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@unocal.com>, Brady
<brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us>, bpopp <bpopp@borough.kenai.ak.us>, Jim
White <jimwhite@satx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobil.com>, marty
<marty@rkindustria1.com>, ghammons <ghammons@aol.com>, rmclean <rmclean@pobox.alaska.net>,
mkm7200 <mkm7200@aol.com>, Brian Gillespie <ifbmg@uaa.alaska.edu>, David L Boelens
<dboelens@aurorapower.com>, Todd Durkee <TDURKEE@KMG.com>, Gary Schultz
<gary_schultz@dnr.state.akus>, Wayne Rancier <RANCIER@petro-canada.ca>, Brandon Gagnon
<bgagnon@brenalaw.com>, Paul Winslow <pmwinslow@forestoil.com>, GarryC.atl'on
<catrongr@bp.com>, Sharmaine Copeland <copelasv@bp.com>, Kristin Dirks
<kristin_dirks@dnr.state.akus>, Kaynell Zeman <kjzeman@marathonoil.com>, John Tower
<John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fowler@anadarko.COM>, Scott Cranswick
<scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP.com>, Steve Lambe
<lambes@unocal.com>,jacknewell <jacknewell@acsalaska.net>, James Scherr
<james.scherr@mms.gov>, david roby <David.Roby@mms.gov>, Tim Lawlor
<Tim_Lawlor@ak.blm.gov>, Lynnda Kahn <Lynnda_Kahn@fws.gov>, Jerry Dethlefs
<Jerry.C.Dethlefs@conocophillips.com>, crockett@aoga.org, Tamera Sheffield <sheffield@aoga.org>,
Jon Goltz <Jon.Goltz@conocophillips.com>, Roger Belman <roger.belman@conocophillips.com>,
Mindy Lewis <mlewis@brenalaw.com>, Kari Moriarty <moriarty@aoga.org>, Patty Alfaro
<palfaro@yahoo.com>, Jeff <smetankaj@unoca1.com>, Todd Kratz <ToddKratz@chevron.com>, Gary
lof2
1/26/2006 9:30 AM
C035lA Cook Inlet Fields
.
.
Rogers <gary _rogers@revenue.state.ak.us>, Arthur Copoulos <Arthur _ Copoulos@dnr.state.ak.us>, K.en
<ken@secorp-inc.com>, Steve Lambert <salambert@unocal.com>, Joe Nicks <news@radiokenai.com>,
Jerry McCutcheon <susitnahydronow@yahoo.com>, Paul Todd <paulto@acsalaska.net>, Bill Walker
<bill-wwa@ak.net>, Iris Matthews <Iris_Matthews@legis.state.ak.us>, Paul Decker
<paul_decker@dnr.state.ak.us>, Rob Dragnich <rob.g.dragnich@exxonmobil.com>, Aleutians East
Borough <admin@aleutianseast.org>, Cynthia B Mciver <bren_mciver@admin.state.ak.us>
Content-Type: application/pdf
co351a.pdf .
Content-Encodmg: base64
Content-Type: application/msword
Sundry Matrix FINAL.doc
Content-Encoding: base64
20f2
1/26/20069:30 AM
.
Mary Jones
XTO Energy, Inc.
Cartography
810 Houston Street, Ste 2000
Ft. Worth, TX 76102-6298
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
Ciri
Land Department
PO Box 93330
Anchorage, AK 99503
Jill Schneider
US Geological Survey
4200 University Dr.
Anchorage, AK 99508
Darwin Waldsmith
PO Box 39309
Ninilchick, AK 99639
Penny Vadla
399 West Riverview Avenue
Soldotna, AK 99669-7714
Bernie Karl
K&K Recycling Inc.
PO Box 58055
Fairbanks, AK 99711
David McCaleb
IHS Energy Group
GEPS
5333 Westheimer, Ste 100
Houston, TX 77056
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
Mark Wedman
Halliburton
6900 Arctic Blvd.
Anchorage, AK 99502
Baker Oil Tools
4730 Business Park Blvd., #44
Anchorage, AK 99503
Gordon Severson
3201 Westmar Cr.
Anchorage, AK 99508-4336
James Gibbs
PO Box 1597
Soldotna, AK 99669
Richard Wagner
PO Box 60868
Fairbanks, AK 99706
North Slope Borough
PO Box 69
Barrow, AK 99723
.
Mona Dickens
Tesoro Refining and Marketing Co.
Supply & Distribution
300 Concord Plaza Drive
San Antonio, TX 78216
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
Schlumberger
Drilling and Measurements
2525 Gambell Street #400
Anchorage, AK 99503
Ivan Gillian
9649 Musket Bell Cr.#5
Anchorage, AK 99507
Jack Hakkila
PO Box 190083
Anchorage, AK 99519
Kenai National Wildlife Refuge
Refuge Manager
PO Box 2139
Soldotna, AK 99669-2139
Cliff Burglin
PO Box 70131
Fairbanks, AK 99707
Williams Thomas
Arctic Slope Regional Corporation
Land Department
PO Box 129
Barrow, AK 99723
,~ \~lP
í0~' \\g..'JJ \
#8
·
'~-'-
FRANK H. MURKOWSKI, GOVERNOR
AlASKA OIL AlÐ) GAS
CONSERVATION COltlMISSION
333 W. 7'H AVENUE. SUITE 100
ANCHORAGE. ALASKA 99501-3539
PHONE (907) 279-1433
FAX (907) 276-7542
December 13,2005
Terry Lucht
CPAI Drilling Team Leader
ConocoPhillips Alaska, Inc.
P.O. Box 100360
Anchorage, Alaska 99510-0360
Harry Engel
Staff Engineer
BP Exploration Alaska, Inc.
PO Box 196612
Anchorage, Alaska 99519
Re: 20 AAC 25.280 Workover Operations
CO 347 A
CO 297 A
CO 556
CO 261A
Dear Mr. Lucht and Mr. Engel:
In late July 2005, several conservation orders were issued regarding
certain operations generally known as workovers described at 20 AAC
25.280. The intent of the new orders was to include new oil pools
identified since the original orders were adopted and to help clarify the
permitting and reporting requirements for the myriad tasks that
collectively are known as workovers. As part of that project, a tabular
listing ("matrix")of well work tasks was developed and incorporated as an
integral part of the orders.
We understand that as Mr. Engel was preparing internal training
documents for BP, he noted a discrepancy between the date shown on
the matrix and the references to the matrix contained within the actual
orders. I have researched the information regarding the date differences
and the Commission's legal counsel has asked me to send this letter
regarding the date discrepancies.
The correct date for the matrix and the references within the
conservation orders is July 15, 2005. The orders were adopted on July
29, 2005, and when the orders and matrix were posted to the
Commission web site, the date shown on the matrix was mistakenlv
changed from July 15 to July 29. This was a clerical error. Thanks to
Mr. Engel's observant eye, this error has now been corrected.
Mr. Lucht and Mr. Engel
December 6, 2005
Page2of2
.
.
You should now find that the date on the copy of the matrix posted on
the web site correctly reads July 15, 2005. Enclosed is your copy of the
matrix with the corrected date. As mentioned above, the conservation
orders themselves referenced the correct date, so no change is needed to
the orders.
Please feel free to contact me at 907 -793-1250 with any other questions.
Sincerely,
Jà-~11~~7
Thomas E. Maunder, PE
Sr. Petroleum Engineer
Enclosure
cc: Mr. Jerome Eggemeyer, CPAI
Mr. Mike Mooney, CPAI
Mr. Jerry Dethlefs, CPAI
Ms. Sharon Alsup-Drake, CPAI
Mr. John Peirce, CPAI
Ms. Terrie Hubble, BPXA
Ms. Sondra Stewman, BPXA
Ms. Sharmaine Vestel, BPXA
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 15,2005
No Forms Required
-10-403 Not Required
-10-404 Not Req uired
Thru-tubing Operations (D)
· Fill tag ·
· Set & pull retrievable plugs
· Change GL V's ·
· Dummy & gauge ring runs ·
· Pull & rerun SSSV's ·
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
· Pump changes.
· Packoff GLM (POGLM)
DEVELOPMENT [PRODUCTION) WELLS
1 Form Required
-10-403 Not Required
-10-404/407 or other form Required
Thru-tubing Operations (D)
Permanent cement or mechanical plugs that
do not completely abandon a zone. (D)
Cutting otItailpipes. (D)
Perforate new intervals within a pool (D)
Patches (D)
Incorporated in Conservation Orders 261 A, 297 A, 341 0 Rule 14,347 A, 351 A and 556
2 Forms Required
-10-403 Required
-10-404/407 or other form Required
Thru-tubing Operations (D)
. Perforate a new pool (D)
.
SPECIAL (D)
On a case-by-case basis, a 10-403 will be
required for a particular well or operation
if the Commission requests it.
If a well is operating under a sundry
approval, a 10-403 may be required to
perform work. The operator should
consult with the AOGCC to determine if
a 10-403 is needed.
.
Page 1 of 4
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 15,2005
No Forms Required
DEVELOPMENT [PRODUCTION] WELLS
1 Form Required
-10-403 Not Required -10-403 Not Required
-10-404 Not Required -10-404/407 or other form Required
Pumping Operations, including using coil.(D Pumping Operations, including using coil.
· Tubing scale removal · Stimulations (frac or acid) (D)
· Sludge removal · Remedial cementing operations
· Freeze protection 0 Conductor Fill (D)
· lee plug removal · Squeezes/plugs to control t1uid
· Inhibitor squeezes movement in zone (D)
· I-lot Oil
· Tubing acid jobs
· Fill clean out
Other Operations (D)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
------
Other Operations
· Seal welding on bradenheads (D)
Rig/Coil Operations
· Alteration of mechanical completion
(including but not limited to)
o Pulling tubing, milling packers (D)
o Install velocity strings (D)
Incorporated in Conservation Orders 261 A, 297 A, 341 D Rule 14, 347 A, 351 A and 556
2 Forms Required
-10-403 Required
-10-404/407 or other form Required
Pumping Operations, including using coil
· Remedial cementing operations
(including but not limited to) .
o Casing shoes (outer annulus) (D)
. Repair casing
(including but not limited to)
o mechanical repairs (D)
o "pumping" repairs (cement or
gel squeezes) (D)
Other Operations
· Convert producer (D) to injector
· Major welding repairs on wellheads
(D)
· Conductor "cutaways" and surface
casing welding repairs (D)
· Annular disposal (D)
(Reported on form 10-423)
Rig/Coil Operations
· Repair Casing
(including but not limited to)
o Mechanical repairs (D)
(scab liners, tiebacks, etc)
.
Page 2 of4
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 15,2005
No Forms Required
-10-403 Not Required
-10-404 Not Required
Thru-tubing Operations (S)
SERVICE [INJECTION] WELLS
1 Form Required
-10-403 Not Required
-10-404/407 or other form Required
Thru-tubing Operations (S)
· Fill tag . Perforate new interval within a pool (S)
· Set & pull retrievable plugs
· Change GL V's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
l~ operations in this column are planned on a A 10-403 should be submitted for any
disposal well, the operator should contact the perforating (new or repert) operations on a
AOGCC to detennine if a 10-403 is needed. Class II disposal well.
.---
2 F onns Required
-10-403 Req uired
-10-404/407 or other form Required
Thru-tubing Operations (S)
· Perforate a new pool. (S)
· Permanent cement or mechanical
plugs that do not completely abandon
a zone (S)
· Patches (S)
· Cutting otItailpipes. (S)
.
SPECIAL (S)
On a case-by-case basis, a 10-403 will be
required for a particular well or operation
if the Commission requests it.
If a well is operating under a sundry
approval, a 10-403 may be required to
perform work. The operator should
consult with the AOGCC to detennine if
a 10-403 is needed.
.
Please note that authorization from EP A
Region 10 may be necessary to perform an)
work on a Class I disposal well.
Incorporated in Conservation Orders 261 A, 297 A, 341 D Rule 14, 347 A, 351 A and 556
Page 3 of4
Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules
July 15,2005
No Forms Required
-10-403 Not Required
-10-404 Not Required
Pumping Operations, including using coil.(S)
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal
· High pressure breakdown or inhibitor
squeezes, excluding frac or acid jobs
· Hot Oil
· Tubing acid jobs
· Fill clean out
~-
Other Operations (S)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
SERVICE [INJECTION) WELLS
1 Form Required
-10-403 Not Required
-10-404/407 or other form Required
Pumping Operations, including using coil.
. Remedial cementing operations
o Conductor Fill (S)
. Squeezes/plugs to control fluid
movement in zone (S)
Other Operations
· Injection well MIT (on MIT form) (S)
· Initial conversion from water injector
to WAG injector (S)
· Convert from injector to producer if for
more than 30 days. (S)
· Seal welding on bradenheads (S)
2 Forms Required
-10-403 Req uired
-10-404/407 or other form Required
Pumping Operations, including using coil.
· Stimulations (frac or acid) (S)
· Remedial cementing operations
(including but not limited to)
o Casing shoes (outer annulus) (S)
· Repair casing
(including but not limited to)
o mechanical repairs (S)
o "pumping" repairs (cement or
gel squeezes) (S)
Other Operations
· Major welding repairs on wellheads (S
· Conductor "cutaways" and surface
casing welding repairs (S)
· Annular disposal (S)
(Reported on form 10-423)
.
Rig/Coil Operations
· Alteration of mechanical completion
(including but not limited to)
o Pulling tubing ,milling packers (S)
· Repair Casing
(including but not limited to)
o Mechanical repairs (S)
(scab liners, tiebacks, etc)
.
Incorporated in Conservation Orders 261 A, 297 A, 341 D Rule 14,347 A, 351 A and 556
Page 4 of 4
#7
.
.
1
ALASKA OIL AND GAS CONSERVATION COMMISSION
2
PUBLIC HEARING
3 In Re:
Changes in Certain Fields'
4 Exemptions from Requirements of
20 AAC 25.280 Relating to Sundry
5 Approvals for Workover Operations
E10
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,25;
6
i_n__
'~_~..'. . i~..' '. Q¡,,,,,,,,,,,,,,
(r,~~~ "(ff¡;¡"IJ~
7
TRANSCRIPT OF PROCEEDINGS
8
Anchorage, Alaska
January 4, 2005
9:00 o'clock a.m.
9
10
11
COMMISSIONERS:
12
13
JOHN NORMAN, Chairperson
DAN SEAMOUNT
14
15
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20
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METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
~RI~jN~
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TABLE OF CONTENTS
2
OPENING REMARKS BY CHAIRPERSON NORMAN .
Page 3
Page 4
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Page 13
. Page 22
3
TESTIMONY OF TOM MAUNDER .
4
TESTIMONY OF HAROLD ENGEL .
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DISCUSSION .
END OF PROCEEDINGS
*
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METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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PRO C E E DIN G S
2
(On record - 9:02 a.m.)
3
COMMISSIONER NORMAN:
This is a hearing this morning
4 before the Alaska Oil and Gas Conservation Commission. The
5 date is January 4th, and the time is approximately 9:00
6 o'clock a.m.
7 The purpose of the hearing is to consider amendments
8 to certain conservation orders issued by the Alaska Oil and
9 Gas Conservation Commission pertaining to waivers and also to
10 clarify and standardize provisions within those conservation
11
orders.
The Staff has done preliminary work on this matter
12 and has received comments and suggestions from the regulated
13 industry, and this morning we're ready to formally consider
14 the proposal for these various conservation orders.
15
The hearing is being transcribed.
Our court reporter
16 is Meredith Downing, who is with R & R Court Reporters, Inc.
17 Any persons desiring to receive a copy of the transcript of
18 this hearing may do so by contacting Jody Colombie, special
19 assistant for the Commission.
20 Notice of this hearing was duly published In the
21 Anchorage Daily News, and any persons desiring to receive a
22 copy of the notice of publication may also obtain one by
23 contacting the Commission's special assistant. We'll address
24 comments received in response to the notice in the course of
25 these proceedings.
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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We will hear from persons wishing to testify.
If you
2 do testify, I'd ask that you approach the microphone and state
3 your name.
We will not be swearlng witnesses in this
4 particular proceeding, but we would like you to state your
5 name, who you are, who you represent.
6 This endeavor was begun earlier this year in an effort
7 by the Commission to review the various reports required by
8 the Commission to determine those reports that are necessary
9 and to also determine if there are any reports or paperwork
10 required to be filed with the Commission that is not -- is no
11
longer useful to the Commission.
Our objective was that if
12 there was paperwork that had become obsolete or n longer
13 useful, then we would see if we could eliminate it, to work
14 toward a more efficient operation.
15 Toward that end, Mr. Tom Maunder of the Commission
16 Staff took the lead for Staff in working on this. And,
17 Mr. Maunder, I'd appreciate if you could come forward, please,
18 and give us a little bit of background leading up to today.
19 TESTIMONY OF TOM MAUNDER
20
MR. MAUNDER: Thank you, Commissioner Norman.
21 Marilyn, do I need to put the microphone on, or.....
22
COURT REPORTER: No, you're fine.
23
MR. MAUNDER: Okay. My name is Tom Maunder.
I'm the
24 senior petroleum engineer with the Commission, and as
25 Commissioner Norman indicated, I was one of two staff members
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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of the Commission that worked on this effort in cooperation
with members of the regulated community.
As Commissioner Norman mention, the intent of the
endeavor was to update and revise orders that had been issued
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by the Commissioner pertaining to operations generally known
as workqvers.
Section 280 in the Commission's regulation
provides for the process to obtain approval prior to
performing certain work known as workovers. And workovers is
a term that is generally a catchall.
It can describe anything
as far as a major entry into a well bore or minor other
activities that could be likened to changing the oil or
checking the oil in an automobile.
The original orders that waived some of the
requirements of Section 280 were initially issued in
beginning in 1990, and through 1992 and on into 1994.
Since
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that time, there have been a number of additional pools in the
fields on the North Slope, and some in Cook Inlet that have
been recognized by the Commission, and there's been no
extension of the -- or considering -- consideration of
extending the provisions of the original orders to those
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pools.
That was part of this work as well.
What has resulted, there was a task group formed with
members of the regulated community represented through the
Alaska Oil and Gas Association. And we met several times
25
through 2004 I believe, beginning in April and again through
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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matrix, which looked at, as near as we could to try and
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3 characterize the operations that an operator might perform on
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4 II a well, and to provide a road map to what tasks an operator
5 11 should still seek approval from the Commission prior to
6 II performing, what -- identify those. Also identify tasks that
jlpj¡D~Bl be considered routine, and that prior approval would not
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,I be necessary from the Commission, and then even to identify
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9 II the tasks that I've likened to like checking the oil in the
10 II car where it's so routine that the requirement for doing
11 II paperwork both in approval sense and then in the subsequent
12 II reporting 1S -- you know, would be burdensome to both the
'1,'1
13 operator and the Commission.
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14 [I We did develop these two task matrices as they're
15 il called, and one is applicable to production wells, the other
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16! isle to injection wells which covers the two general
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types of wells that will operate in the State. And by
incorporating this task matrix, or putting this task matrix
out there, to be used by the operator, it literally puts
everybody on the same page as to the requirements of what
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need to seek approval on, and then how the
follow-up reports are necessary.
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It may result in some increased paperwork on the
operators side, but it will, as I've said, have everybody on
the same page and allow a consistent approach across the major
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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developed fields within the State.
One other point that has been amended or will change
in the orders is the -- in the prior orders the operators were
required to provide a listing of the work that they would plan
to do, the so-called workovers in the coming week, and the
6 II operator have been sending this work plan in to the Commission
7 lion a weekly basis. The difficulty that has happened in trying
8 I to use that work plan is that the Commission is not able to
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may have been done or what work simply has disappeared from
the schedule due to reprioritization. The proposal in the
orders is that we would get a report from the operators on a
weekly basis of the work that they have completed in the past
week. And with such a record, we would then be able to use
that in a compliance assurance effort to follow up and assure
that we are getting the follow-up reports for the work that
has been identified.
That concludes my comments, Commissioner Norman.
COMMISSIONER NORMAN: Thank you very much,
Mr. Maunder.
I think that was a good clear statement.
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Commissioner Seamount, questions?
COMMISSIONER SEAMOUNT: Yes. Mr. Maunder, could you
describe what the potential increased paperwork for industry
would be?
MR. MAUNDER: There will some -- there will be some --
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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1 the actual type of paperwork will be the same. It will just
2 be on given wells there may be some additional reports that
3 hadn't been previously filed.
4
COMMISSIONER SEAMOUNT: Have you received -- you've
5 worked in this task force with industry. Did they have any
6 comments about this increased paperwork?
7
MR. MAUNDER: In one of our meetings it was mentioned
8 there would be some increase. You know, there wasn't any
9 specific comment other than that. We do have representatives
10 here today from the group on the industry side that may be
11 able to address that.
12
COMMISSIONER SEAMOUNT: The.....
13
MR. MAUNDER: The goal was -- if I may comment, you
14 know, was to make sure that we were getting the reports that
15 were required, and to, you know, grant the relief on the
16 additional fields as I'd mentioned earlier.
17 COMMISSIONER SEAMOUNT: The fact that they don't have
18 to turn in the plan, does that their plans, does that
19 decrease some of the paperwork?
20
MR. MAUNDER: That will decrease some of it, the
21 actual extent of volume of some of the reports that were
22 included in the plan.
23
COMMISSIONER SEAMOUNT: Now, the report of what was
24 done, is that -- that's on a weekly basis, correct?
25
MR. MAUNDER: Yes, sir.
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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COMMISSIONER SEAMOUNT: And what would that consist
2 of?
3
MR. MAUNDER: The examples I've seen thus far, and BP
4 has been, you know, working with us on setting up a format, it
5 would identify the well that the work was performed on, what
6 the work was, if a 403 approval, a sundry approval was
7 required, and then identify the subsequent report that will be
8 coming.
9
COMMISSIONER SEAMOUNT: Now, the regulations require a
10 407 or 403 on some of these -- some of this work within, is it
11 a month or a quarter?
12
MR. MAUNDER: The 403, where there is a sundry notice
13 required or sundry request required, that would be submitted
14 in advance of the work, and then I'm not sure the -- of the
15 regulation, but the reporting requirement is then within 30
16 days.....
17
COMMISSIONER SEAMOUNT: Within 30 days the 40.....
18
MR. MAUNDER:
.. .. .of completing the operation either
19 a 407 or a 404.
20
COMMISSIONER SEAMOUNT: I meant 404, not 403. Okay.
21 That's the only questions I have. Thank you.
22
MR. MAUNDER: Yes, sir.
23
COMMISSIONER NORMAN: And, Mr. Maunder, this will
24 involve then, if the Commission approves this, these
25 recommendations, this will involve amending the various
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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1 referenced conservation orders, and I'm assuming that would
2 include attaching the work matrix to the orders. The matrix
3 is used as an interpretive matrix, is that.....
4
MR. MAUNDER: Yes, sir.
5
COMMISSIONER NORMAN:
.... .is that correct?
6
MR. MAUNDER:
It would be -- I would call it a
7 guideline.
It's, as I've indicated, the best effort on the
8 that the work group was able to come to of identifying the
9 tasks and categorizing them.
10
COMMISSIONER NORMAN: And I have before me the
11 November printout on the proposed matrix that was part of the
12 official publication package. Have there been any changes to
13 that matrix?
14
MR. MAUNDER: I have been working on it in the
15 interim, and I do have a copy dated today that I can provide
16 you, to both of you actually. The matrix that was provided in
17 the notice was specific to development of production wells,
18 and my colleagues from AOGA will probab -- will indicate later
19 that one of the -- production wells are about half of the
20 wells that exist in the state. The others are injectors. And
21 we had concentrated on defining the matrix for the production
22 wells, and by default you define one for injection wells. And
23 one of the suggestions through their comments had been to
24 provide both matrices to eliminate any possible confusion, and
25 that would be the proposal that we would move forward when and
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
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if the orders are -- the amendments are approved would be to
include matrices for both types of wells.
COMMISSIONER NORMAN: One last questionl are there any
other changes that have been made I any material changes I to
the proposed amendments and the proposed -- or the proposed
uniform rules that deviate from what was published and
distributed to the public?
MR. MAUNDER: NOI sir. That -- like I saYI the
expansion to the dual matrix has been the only substantive
change.
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COMMISSIONER NORMAN: Okay.
Commissioner Seamount any
other questions for Mr. Maunder?
COMMISSIONER SEAMOUNT: NOI
that/s fine.
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COMMISSIONER NORMAN: Mr. Maunderl weld appreciate it
if you would -- we thank you for your testimony I weld
appreciate it if you would remain throughout the hearing so
that if we would need to recall youl we could do so.
MR. MAUNDER: Yes I sir.
COMMISSIONER NORMAN: Are there any other persons
present here today who wish to offer any testimony?
Mr. Engel I please.
TESTIMONY OF HAROLD ENGEL
MR. ENGEL: Good morning I Commissioners Norman and
Seamount. My name is Harold Engel.
11m a staff engineer at
BPI and this morning 11m representing the Alaska Oil and Gas
METRO COURT REPORTING, INC.
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1 Association as a member of the task group that worked this
2 effort with the Commission.
3 I'll start off by saying that the task group at AOGA
4 appreciates the opportunity to work with the Commission on
5 this effort, because we do feel that it's an effort that's
6 going to streamline some processes and also identify some
7 issues that were kind of cloudy prior to this effort, so we do
8 applaud the effort by the Commission and the Staff that we
9 work with.
It was a very productive and collaborative effort.
10
AOGA sent comments to the Commission dated December
11 16th, 2004.
I believe you have those comments. They were
12 submitted by way of fax on the 16th of December. And the --
13 in summary, the comments by AOGA are around supporting the
14 effort and the changes made -- recommended by the Commission.
15 And, again, we do support the effort and development of the
16 matrices that Tom Maunder just described previously.
17
COMMISSIONER NORMAN: Excuse me just one moment. And
18 you're referring to the December 16 letter sent to the
19 Commission, and I'm gOlng to hand a copy of this right now to
20 the reporter and ask that it be -- it be placed in the
21 transcript. Why don't we just mark that as Exhibit A to the
22 transcript for identification purposes so that it's clear to
23 anyone later reading the transcript what Mr. Engel's been
24 referring to.
25 (Exhibit A marked)
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COMMISSIONER NORMAN:
Please continue, Mr. Engel.
2
MR. ENGEL: As the comments mention, Commissioner
3 Norman, we do support the effort, and we do wish to continue
4 working with the Commission as we develop and finalize the
5 language for the proposed amendment.
6 There was talk earlier about comments related to the
7 potential increased reporting requirements from industry, and
8 we did acknowledge that during the process. At this point in
9 time, it's tough for us to actually quantify those increases,
10 because it's just -- it's hard to predict at this point in
11
time.
So we recommend that we continue with the process, and
12 then suggest that we let the process work for a while and
13 evaluate any increases that may in fact be a result of the
14 effort, and then re-initiate a discussion and dialogue about
15 the benefit, pros and cons of any increases at this point in
16 time.
17 So in summary, Commissioners, we -- it was a good
18 effort we worked with the Staff on. We thought it was very
19 productive.
We met several times as a group, and it was a
20 collaborative effort, and again we support the effort and the
21 way it's moving forward.
22
COMMISSIONER NORMAN:
Thank you very much, Mr. Engel,
23 for appearing here on behalf of the Alaska Oil and Gas
24 Association.
25 Commissioner Seamount, any questions?
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COMMISSIONER SEAMOUNT: Yes. When this project was
kicked off, it was kicked off by the fact that we were
receiving reports of plans of what industry intended to do
before it was done, and it turned out a lot of -- the plan
changed, of course, as it always does. We -- the Commission
recognized that, and consequently no one even looked at those
reports, so we decided that is a burden on industry, that it
has no beneficial effect, so we were trying to figure out how
to get rid of that burden.
This -- while looking at that, it was noticed or we
became aware that the 404's and the 407's in a number of cases
were not being submitted on time for reasons -- I'm not sure
exactly what the reasons were.
It was explained to me that it
could be that each operating unit would put their reports
together, you know, all together at one time at certain
intervals. And that led to some reports being, you know,
months late, beyond the 30-day limit.
So that was another problem that was addressed, and it
looks like the task force went beyond that, came with this
matrix. A commendable result.
What I would -- the question I would have is, do you
see any solution to reports not getting in in a 30-day time
because of this or is that a separate issue at this time?
24
MR. ENGEL: Well, Commissioner Seamount, over the
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years the requirement for submitting reports were understood
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1 between the Commission Staff at the time they were in place
2 here at the Commission, and some things may have been
3
understood amongst operators, and not very clear.
So as time
4 went on, this process just evolved.
So that could have been
5 the reason why some reports weren't filed on some activities.
6 So this effort I think is very good in clarifying what
7 activities need reports to be filed, and it reiterates the
8
timeliness of those reports.
So I think it may be separate
9 issues, but they work together to improve the reporting in a
10 timely fashion, and also clarifying what activities need to be
11 reported on.
12
COMMISSIONER SEAMOUNT:
Some of these -- well, I would
13 think that quite a few of the well work that's done -- I mean,
14 it seems like getting them in within a 30-day time or not
15 getting them in, on a lot of that stuff probably doesn't
16 matter.
Okay. Now, if you are to comply with the 30-day
17 rule, is that going to add any burden to industry as opposed
18 to what's been done In the past where I guess you were saying
19 there's this unwritten agreement to where you could be no
20 compliant with that regulation and get them in, you know, when
21 it's convenient to you?
22
MR. ENGEL: Right. Right. At this time,
23 Commissioner, it's tough for me to actually quantify any
24 potential increases in effort on industry's part.
I would
25 suggest we let it go its course and let us work with it and
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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1 submit the reports as required, and then evaluate any
2
increases and review the burden.
If there anything that's
3 maybe redundant or unnecessary, we can discuss those at a
4 future date. But I don't think that at this time I can really
5 quantify any potential increases.
6 Again, I think that one of the positive -- there are
7 many positive things in this effort.
One is that we worked
8 together as a team, which was very productive, but also by
9 having dialogue between the operators and the Commission
10 Staff, we're able to identify what activities that in the past
11 were grey or ambiguous, and now it's pretty clear as to what
12 activities need to have reports filed and the appropriate
13 timeliness of those reports.
14
COMMISSIONER SEAMOUNT: Yes, I think the task force
15 has done a very good job.
I'd like to comment everybody that
16 was involved in it.
I would request that if there's any
17 tweaking that needs to be done in the future that you make us
18 aware of it.
19
MR. ENGEL: Yes. And we do understand that this
20 process will allow us to address other issues that may crop up
21 in the future by going through a public forum to work those
22 out and -- for the benefit of industry and the Commission,
23 meet both needs.
24 And I would like to again note that this was a great
25 process to work with the Staff on, and it's perhaps a model
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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1 for future activities that would requlre industry input into
2 activities'that would allow us to make improvements in a
3 public forum that would improve our process and efficiencies.
4
COMMISSIONER SEAMOUNT:
Okay.
Thank you, Mr. Engel.
5 I have no other questions or comments.
6
COMMISSIONER NORMAN:
I'd like to join with
7 Commissioner Seamount in thanking all who worked on this and
8 provided input.
9 The focus of the number of different pools that will
10
be affected is fairly broad.
My question for you is, is
11 there anything in the proposed amendments that unnecessarily
12 increases the reporting or paperwork burden on industry that
13 is unnecessary as to these specific amendments? In other
14 words, as a result of this effort, have we created any
15 additional paper -- unnecessary paperwork for industry?
16
MR. ENGEL: There may be some more paperwork required
17 for activities that we do in the field. Again, it's tough for
18 me to quantify those right now, Commissioner Norman. My gut
19 is that it won't be significant at this point in time.
20
COMMISSIONER NORMAN:
It will not?
21
MR. ENGEL:
It will not be significant at this point
22
In time.
But it may require us to submit reports on
23 activities we had not done in the past. And I would suggest
24 that we continue on with the amendment and evaluate any
25 increases that we would see, and then perhaps discuss those at
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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1 a later date.
2
COMMISSIONER NORMAN:
Okay. Very good. Well, I thank
3 you again, and through you we thank the Alaska Oil and Gas
4
Conservation Commission for this effort.
I think by working
5 together and getting the comments of the regulated industry,
6 it's helped us get to the bottom line much more quickly than
7 if the Commission had done it alone.
8
I think we can excuse you.
I would ask that you
9 remain for the conclusion of the hearing in case we would need
10 to recall you.
11
MR. ENGEL: Thank you, Commissioner.
12
COMMISSIONER NORMAN:
Mr. Maunder, could you return,
13 please? I have one more question here for you.
14
MR. MAUNDER: Yes, Commissioner Norman.
15
COMMISSIONER NORMAN:
This could -- this question
16 addressed all of the proposed amendments, the new rules and
17
the matrix.
It's a very general question, but is there
18 anything that will be done by adoption of these amendments
19 that lessens safety, or protection against waste, or in any
20 way lessens the Commission's vigilance over the traditional
21 conservation issues that are the -- within the purview of the
22 Commission? I've read them myself, but I'm just more -- I'm
23 interested in your opinion. Are we weakening or losing
24 anything by way of our regulatory oversight?
25
MR. MAUNDER: No, sir, I don't believe we are. As I
METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
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had mentioned earlier, in -- the development of the matrices
allowed the tasks that are normally performed to be
identified, and then categorized as to being routine, being
nonroutine.
One of the changes that I didn't mention earlier was
removing one of the workover tasks identified in 280 that
where waivers had been allowed before, and that had to do with
the repair of casing. And in looking at events that have
happened in the last couple of years where casings have been
compromised, that was one area from a professional point of
view and regulatory point of view where the isolation of the
well bore from the downhole or the earth environment could be
compromised, that that has been included to be covered under a
sundry now whether it's an injection well or whether it's a
production well. So that, you know, could potentially
increase the burden on the industry, although I think the
events where that happens are not great, so -- but the fact
that they're not great also is reason for the Commission to be
vigilant on them. But the.....
COMMISSIONER NORMAN: But that represents a tightening
up if you will of.....
MR. MAUNDER: Yes, sir.
COMMISSIONER NORMAN:
. . . . .our regulatory oversight?
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MR. MAUNDER: Yes, sir.
COMMISSIONER NORMAN: Yes.
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MR. MAUNDER: But having worked with my industry
2 colleagues and other Commission colleagues on this, I think
3 we've looked at it and evaluated it, and where there is no
4 intent to, you know, deviate from acceptable standards or to
5 provide any weakening in the purview of the Commission with
6 regard to prevention of waste and protection of fresh water.
7 And I don't believe in our discussions that anything was
8
identified in that regard.
If it had been, it would have been
9 -- it would have been thoroughly discussed and accommodations
10 made or assurances done that there would be no compromise in
11 that effort.
12
COMMISSIONER NORMAN: Good. Thank you very much.
13 Anything more for Mr. Maunder?
14
COMMISSIONER SEAMOUNT: No, Mr. Chairman.
15
COMMISSIONER NORMAN: And, Mr. Maunder, we can excuse
16 you.
17
MR. MAUNDER: Thank you, sir.
18
COMMISSIONER NORMAN: We will
because this is a
19 public process, we will leave the record open for an
20 additional two weeks from today. Let me in fact see what that
21 would -- let's take a look here so we have a specific date.
22 So we will leave the record open until the 19th of January for
23 any additional comments from either regulated industry,
24 members of the public, governmental agencies. We want to be
25 sure that we have the benefit of all comments before the
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Commission acts on this matter.
I anticipate that then
following the close of the record, then the Commission will
act upon the proposal fairly expeditiously, and will give
notice to all parties.
I do note that this -- both of the persons testifying,
Mr. Maunder for the Staff, Mr. Engel for AOGA, have indicated
that this may be something that we need to revisit again in
some months, perhaps later this year, and the Commission is
willing to do that.
In the meantime, however, once these are adopted, then
the Commission will expect full compliance.
If, for any
reason full compliance proves to be impractical, then we will
expect you to contact the Commission immediately, and we do
have authority then to look at it. But once adopted, these
will control and the Commission will expect compliance in
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Also, it has been an objective of Commissioner
Seamount and myself to watch for any paperwork th3t is not
necessary to the work of the Commission, and any time we can
eliminate such paperwork, not only are we willing to do so,
but that is our desire, not only for the benefit of industry,
but to allow the Commission to focus its Staff where needed.
So I would appreciate it if you could keep that In mind, and
perhaps if we revisit this again toward the end of the year,
and you have any suggestions along that line, they'd be
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3 II that wish to testify, either orally or offer any comments in
4 II " ? k
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5!1 persons have requested to testify, and the record should
II
6 II reflect the comment from AOGA in the December 16th letter.
II
81Y If we have nothing further, then these proceedings are
!I adjourned at 9:35 a.m.
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May I ask are there any other persons present today
The record should reflect that no other
(Off record)
* * * END OF PROCEEDINGS * * *
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1
C E R T I FIe ATE
2
SUPERIOR COURT
)
) ss.
)
3
STATE OF ALASKA
4
5 I, Jerri Young, Notary Public in and for the State of
Alaska, do hereby certify:
6
THAT the annexed and foregoing pages numbered 2
7 through 22 contain a full, true and correct transcript of the
Public Hearing before the Alaska Oil and Gas Conservation
8 Commission, taken by Meredith Downing and transcribed by
Meredith Downing:
9
THAT the Transcript has been prepared at the request of
10 the Alaska Oil and Gas Conservation Commission, 333 West
Seventh Avenue, Anchorage, Alaska,
11
DATED at Anchorage, Alaska this 25th day of January,
12 2005.
13
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745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276-3876
· Alaska Oil and Gas !sociation
--........-........
: 'ACOOa
121 W. Fireweed Lane, Suite 207
Anchorage, Alaska 99503-2035
Phone: (907)272-1481 Fax: (907)279-8114
Judith M. Brady, Executive Director
, December 16; 2004
VIA F ACSIMILE#276-7542
Commissioner John K. Norman
'Chairman
Alaska Oil and Gas Conservation Commission
,333 West. 7th Avenue, Suite 100
, Anchorage, AK 99501
CommissionerDaníel T. Seamount, Jr.
Alaska Oil and Gas Conservation Comm.
333 West 7th Avenue, Suite 100
Anchorage, AK 99501
" Re: Changes in certain fields' exemptions from requirements of 20 MC 25.280 related to
sundry approvals for workover operations
, ' Dear Commissioners Norman and Seamount:
. Th~ Alaska Oil & Gas Association (AOGA) appreciates the opportunity to provide comments to the
. Ala~ka Oil and Gas COr'lservation Commission (AOGCC) on AOGCC's proposal to amend existing
, rutEis for certain fields that waive requirements of 20 MC 25.280 relating to submission of an
Application for Sundry Approval (Form 10-403) for routine workover operations.
We first want to thank the Commíssion for inviting AOGA to participate in a working group with
AOGCC staff members to review AOGCC reporting requirements. We applaud the Commission's
effort$ to work jointly with industry to identify and eliminate redundant or unnecessary reporting, and
to modify and clarify the required reporting for various wor1<over operations.
AOOA supportS the proposed changes recommer'lded by the AOGCC and wishes to continue
, working with the Commission in 'drafting the final language ìmplementing these changes. One of our
initial :comments would be to have two separate matrices; one for development wells and one for
service wells. Members of AOGA's AOGCC Task Group will follow-up with AOGCC staff on this
dunng the drafting of the final language.
. Thank you again for this opportunity to work with the Commission in this effort. If you or. your
colleagues have any questions, please feel free to call.
Sincerely,
,,---~
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JtJDITH M. BRADY
/Executive Director
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#6
.
.
STATE OF ALASKA
OIL AND GAS CONSERV A TION COMMISSION
Changes in certain fields exemptions from requirements of 20 AAC 25.280
related to sundry approvals for workover operations
January 4, 2005 9:00 AM
NAtVlE - AFFILIATION
ADDRESS/PHONE NUMBER
TESTIFY (Yes or No)
(PLEASE PRINT)
.,
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Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination
Summary of Well Work Sundry Requirements
20 AAC 25.280(a) prescribes that Operators will seek approval to perform any workover operations as described in the regulation. In
recognition of "routine" operations and in order to reduce the burden for the Operator and Commission, a series of Conservation Orders
were enacted relieving many Operators from the requirement for notice and approval prior to performing the workover operations in
specific pools. These orders were recently [January 2005] amended. Sundry waivers are presently authorized in the following fields:
Prudhoe Bay Field
Endicott Field
Kuparuk River Field
Milne Point Field
Several Cook Inlet area oil and gas fields operated by Unocal
.
In the following tables, various well work operations and approval/reporting requirements have been identified. The operations
identified in the table are not meant to be an all-inclusive listing of the possible well work operations that could be performed on a well.
It is an attempt to identify the most common operations and categorize them according to determined reporting requirements.
The approval and reporting requirements are different depending on whether the work planned is on a DEVELOPMENT
[PRODUCTION] WELL or a SERVICE [INJECTION] well. The approval and reporting requirement is dependant on what the well is
prior to performing the proposed work. Special attention also needs to be given to any work planned on disposal wells, especially the
few Class I disposal wells in the state. Such wells are operated under EP A permits and they may need to be notified prior to attempting
any well work.
PLEASE NOTE:
.
1. With the exception of column 1 (No Forms Required) an exemption to the requirement to file a sundry notice to perform well
work can only be granted via a Conservation Order.
2. For any SERVICE [INJECTION] well, an Injection Order must be in place before any fluids may be injected.
Attachment to Conservation Order
Page 1 of5
January 4, 2005
Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination
No Forms Required
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing Operations (D)
· Fill tag
· Set & pull retrievable plugs
· Change GLV's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
· Pump changes.
· Packoff GLM (POGLM)
Attachment to Conservation Order
DEVELOPMENT [PRODUCTION] WELLS
1 Form Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing Operations (D)
·
Permanent cement or mechanical plugs that
do not completely abandon a zone. (D)
Cutting off tailpipes. (D)
Perforate new intervals (D)
within a pool
Patches (D)
·
·
·
2 Forms Required
-10-403 Required
-10-404 / 407 or other form Re uired
SPECIAL (D)
In all cases where there is an unusual event,
a sundry will be required if the Commissio
requests it.
If a well is operating under a sundry
approval, a 403 may be required to perform
work. The Operators' engineer should
consult with the AOGCC to determine if a
sundry notice if needed.
Page 20[5
January 4, 2005
No Fonns Required
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing pumping Operations, including
using coil. (D)
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal
· Inhibitor squeezes
· Hot Oil
· Tubing acid jobs
· Fill clean out
Other Operations (D)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
Attachment to Conservation Order
Well Work Operations and Notice/Reporting Requirements
AOGCC/ AOGA Workgroup Determination
DEVELOPMENT [PRODUCTION] WELLS
1 Fonn Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations, including
using coil.
· Stimulations (frac or acid) (D)
· Remedial cementing operations
o Conductor Fill (D)
· Squeezes/plugs to control f1uid
movement in zone (D)
Other Operations
· Seal welding on bradenheads (D)
Rig/Coil Operations
· Alteration of mechanical completion
(including but not limited to)
o Pulling tubing, milling packers (D
o Install velocity strings (D)
2 Forms Required
-10-403 Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations,
including using coil.
. Remedial cementing operations
(including but not limited to)
o Casing shoes (outer annulus)
(D)
. Repair casing
(including but not limited to)
o mechanical repairs
o "pumping" repairs (gel or cement
squeezes) (D)
Other Operations
· Convert producer to injection (D)
· Major welding repairs on wellheads
(D)
· Conductor "cutaways" and surface
casing welding repairs (D)
· Annular disposal (D)
(Reported on form 10-423)
Rig/Coil Operations
· Repair Casing
(including but not limited to)
o Mechanical repairs (D)
(scab liners, tiebacks, etc)
Page 3 of5
January 4,2005
Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination
No Forms Required
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing Operations (S)
SERVICE [INJECTION] WELLS
1 Form Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing Operations (S)
· Fill tag . Perforate new interval within a pool
· Set & pull retrievable plugs
· Change GLV's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
· Pump changes.
· PackoffGLM (POGLM)
If"non-routine" Cölumn 1 operations are
plannedonadisposalwell, the Operators'
engineer shoµldcontactthe AOGCC to
detennineifasundry application is needed.
Attachment to Conservation Order
A sundry should be submitted for any
perforating (new or reperf) operations on a
Class IldisposalweIl.
2 Forms Required
-10-403 Required
-10-404/407 or other form Re uired
Thru-tubing Operations (S)
. Permanent cement or mechanical plugs
that do not completely abandon a zone.
. Cutting off tailpipes.
SPECIAL (S)
In all cases where there is an unusual event,
a sundry will be required if the Commissio
requests it.
If a well is operating under a sundry
approval, a 403 may be required to perform
work. The Operators' engineer should
consult with the AOGCC to determine if a
sundry notice if needed.
Please note that authorization ttomEP A
Region lOmayhe necessary to perfortIl an
work on a Class I disposaLweIl'
Page 4 of5
January 4,2005
Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination
No Forms Re uired
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing pumping Operations, including
using coil. (S)
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal
· Inhibitor squeezes
· Hot Oil
· Tubing acid jobs
· Fill clean out
Other Operations (S)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
Attachment to Conservation Order
SERVICE [INJECTION] WELLS
1 Form Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations, including
using coil.
· Remedial cementing operations
o Conductor Fill (S)
· Squeezes/plugs to control fluid
movement in zone (S)
Other Operations
· Injection well MIT (on MIT form) (S)
· Initial conversion from water injector
to WAG injector (S)
· Convert from injector to producer if for
more than 30 days. (S)
· Seal welding on bradenheads (S)
2 Forms Required
-10-403 Required
-10-404/407 or other form Re uired
Thru-tubing pumping Operations,
including using coil.
· Stimulations (frac or acid) (S)
· Remedial cementing operations
(including but not limited to)
o Casing shoes (outer annulus) (S)
· Repair casing
(including but not limited to)
o mechanical repairs (S)
o "pumping" repairs (gel or cement
squeezes) (S)
Other Operations
· Major welding repairs on wellheads
(S)
· Conductor "cutaways" and surface
casing welding repairs (S)
· Annular disposal (S)
(Reported on form 10-423)
Rig/Coil Operations
· Alteration of mechanical completion
(including but not limited to)
o Pulling tubing ,milling packers (S)
· Repair Casing
(including but not limited to)
o Mechanical repairs (S)
(scab liners, tiebacks, etc)
Page 5 of5
January 4,2005
Summary of Development Well Work Sundry Requirements for Pools Subject to Sundry Waiver Rules
-10-403 Not Required -10-403 Not Required -10-403 Required
-10-404 Not Required -10-404/407 or other form Required -10-404/407 or other form Required
Thru-tubing Operations Thru-tubing Operations Thru-tubing Operations
· Fill tag
· Set & pull retrievable plugs · Permanent cement or mechanical plugs that
· Change GL V's do not completely abandon a zone.
· Dummy & gauge ring runs · Cutting off tailpipes SPECIAL
· Pull & rerun SSSV's · Perforate new intervals
· Pressure surveys - unless required by within a pool In all cases where there is an unusual event,
some specific approval · Patches a sundry will be required if the Commissio
· Temperature surveys - unless required by requests it.
some specific approval If a well is operating under a sundry
· Caliper surveys approval, a 403 may be required to perform
· Reperforating existing intervals work. The Operator should consult with th
· Bottom hole samples AOGCC to determine if a sundry notice if
· Spinner surveys needed.
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some Please note that authorization from EP A
specific approval Region 10 may be necessary to perform
· Pump changes. work on any of the Class I wells on the
· Packoff GLM (POGLM) slope.
No Forms Required
1 Form Required
2 Forms Required
11123/2004
Page 1 of 2
Summary of Development Well Work Sundry Requirements for Pools Subject to Sundry Waiver Rules
No Forms Required
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing pumping Operations, including
using coil.
1 Form Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations, including
using coil.
· Tubing scale removal · Stimulations (tfac or acid)
· Sludge removal · Remedial cementing operations,
· Freeze protection including but not limited to
· Ice plug removal 0 Conductor Fill
· Inhibitor squeezes · Squeezes/plugs to control fluid
· Hot Oil movement in zone
· Tubing acid jobs
· Fill clean out
Other Operations
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
Other Operations
· Seal welding on bradenheads
Rig/Coil Operations
· Alteration of mechanical completion,
including but not limited to
o Pulling tubing, milling packers
o Install velocity strings
2 Forms Required
-10-403 Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations,
including using coil.
. Remedial cementing operations,
including but not limited to
o Casing shoes (outer annulus)
. Repair casing,
including but not limited to
o mechanical repairs
o "pumping" repairs (gel or cement
squeezes)
Other Operations
· Convert producer to injection
· Major welding repairs on wellheads
· Conductor "cutaways" and surface
casing welding repairs
· Annular disposal
(Reported on form 10-423)
Rig/Coil Operations
· Repair Casing,
including but not limited to
o Mechanical repairs
(scab liners, tiebacks, etc)
11/2312004
Page 2 of 2
#4
.
.
Proposal Re2ardin2 Rules Waivin2 Sundry Approval Reauirements
The Alaska Oil and Gas Conservation Commission (AOGCC) has published notice of
proposed changes to a series of Conservation Orders (COs) regulating the need to obtain
prior approval via Sundry Approval (Form 403) before performing certain well work,
commonly referred to as workovers, as well as the reporting requirements for work
accomplished. This document provides information regarding the proposed actions, lists
the existing rules presently in force, and sets out the proposed uniform rules that will
replace them.
The regulations applicable to workovers are at 20 AAC 25.280. During the early and mid
1990s, a series of COs were issued at the Operators' request that waived the requirements
to file a sundry for the operations listed in 25.280 (a) (1) - (5).
The proposed action will:
1. add recognized existing pools to the appropriate field orders and extend the
sundry waiver to development well workover operations conducted in those
pools;
2. make several changes in the content of the existing rules including
a. remove repair of casing [25.280 (a) (4)] from the list of workover
operations where no sundry is required
b. require that operators submit, weekly, a list of workover operations
completed in the past week rather than a planned workover list for the
coming week
c. clarify that post-work filings are required notwithstanding a waiver of
pre-work approval
3. provide for uniform rule language for all affected fields; and;
4. recognize and approve for use a document titled "Summary of Development
Well Work Sundry Requirements for Pools Subject to Sundry Waiver Rules" .
This document was developed to provide a common reference for the notice
and reporting requirements for frequently conducted well operations on
development wells in pools subject to sundry waiver rules.
Please reference the hearing notice for information regarding the comment period for this
action and the tentatively scheduled hearing date.
AOGCC Proposal Re2ardin2 Rules Waivin2 Sundry Approval Reauirements
11/23/2004 Page 1 of 6
.
.
EXISTING RULES PROPOSED TO BE AMENDED OR REPLACED
CO 261
Kuparuk
Rule I
The requirements of20 AAC 25.280(a) are hereby waived for those wells in the KRU
Kuparuk River Oil Pool of the Kuparuk River Field.
Rule 2
The operator shall provide the Commission with a listing of planned workover operations
including the well and intended operation on a weekly basis.
CO 297
Endicott
Rule I
The requirements of20 AAC 25.280(a) are hereby waived for all development wells in
the Duck Island Unit, Endicott Field, Endicott Oil Pool.
Rule 2
The operator shall provide the Commission with a schedule of planned workover
operations including the well and intended operation on a weekly basis.
CO 341D, Rule 14 Prudhoe Oil Pool
Rule 14 Waiver of "Application for Sundry Approval" Requirement for Workover
Operations (ref. c.o. 258)
The requirements of20 AAC 25.280(a) are waived for development wells in the Prudhoe
Oil Pool of the Prudhoe Bay Field. (Source: C.O. 258)
CO 347
Milne Point
Rule 1 The requirements of20 AAC 25.280(a) are hereby waived for all producible wells
(i.e., development wells) in the Milne Point Unit, Kuparuk River Field, Kuparuk River oil
pool and Schrader Bluff oil pool.
Rule 2 The operator of Milne Point Unit, Kuparuk River Field, Kuparuk River oil pool
and Schrader Bluff oil pool, shall provide the commission with a schedule of planned
workover operations including the well and intended operation on a weekly basis.
AOGCC Proposal Re1!ardin1! Rules Waivin1! Sundry Approval ReQuirements
11/23/2004 Page 2 of 6
.
.
CO 342
Lisburne & Greater Point McIntyre Area
Rule 1 The requirements of20 AAC 25.280(a) are hereby waived for all producible wells
(i.e., development wells) in the Greater Point McIntyre/Prudhoe Bay Field, Pt McIntyre,
Stump Island and Lisburne oil pools.
Rule 2 The operator of Greater Point McIntyre/Prudhoe Bay Field, Pt McIntyre, Stump
Island and Lisburne oil pools shall provide the commission with a schedule of planned
workover operations including the well and intended operation on a weekly basis.
CO 343
Niakuk
Rule 1 The requirements of20 AAC 25.280(a) are hereby waived for all producible wells
(i.e., development wells) in the Niakuk oil pool.
Rule 2 The operator ofNiakuk oil pool shall provide the commission with a schedule of
planned workover operations including the well and intended operation on a weekly
basis.
CO 351
l\'cArthur River, Swanson River, Middle Ground Shoal, Granite
Point, Trading Bay, Ivan River, Lewis River
Rule 1 The requirements of20 AAC 25.280(a) are hereby waived for all producible wells
(i.e., development wells) in the following Unocal operated fields/pools in the Cook Inlet
area:
Rule 2 The operator of the aforementioned fields and pools, shall provide the
Commission with a schedule of planned workover operations including the well and
intended operation on a weekly basis.
AOGCC Proposal Ree:ardine: Rules Waivine: Sundry Approval Requirements
11/23/2004 Page 3 of 6
.
.
PROPOSED UNIFORM NEW RULES FOR AFFECTED POOLS:
Rule 1
Except as provided in Rules 2 and 3, the requirements to submit a sundry notice (Form
10-403) and supporting documentation for workover activities described in 20 AAC
25.280(a) (1), (2), (3) and (5) and (b) are waived for development (i.e., production)
wells. The attached "Summary of Development Well Work Sundry Requirements for
Pools Subject to Sundry Waiver Rules" summarizes the application and reporting
requirements that apply to development wells under Commission regulations as modified
by this rule.
Rule 2
The waiver provided under Rule 1 does not apply to a well that is required to be reported
to the Commission under the provisions of an applicable Sustained Casing Pressure Rule.
Rule 3
The Commission reserves the discretion to require that an operator submit an Application
for Sundry Approvals for a particular well or for a particular operation on any well.
Rule 4
On a weekly basis, the operator shall provide the Commission with a report of workover
operations performed during the prior week, including the date, well, nominal operation
completed, and a brief description of that operation including depths of perforations,
repreforations, and stimulated zones.
Rule 5
Nothing in this order precludes an operator from filing an Application for Sundry
Approvals in advance of any well work.
Rule 6
Unless notice and public hearing is otherwise required, the Commission may
administratively waive the requirements of any rule stated above or administratively
amend any rule 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 an
increased risk of fluid movement into freshwater.
AOGCC Proposal Re2ardin2 Rules Waivin2 Sundry Approval Requirements
11/23/2004 Page 4 of 6
.
.
APPLICABILITY OF NEW RULES:
In addition to the pools currently covered by sundry waiver rules, several pools
not currently covered are also proposed to covered by the new rules, and two
conservation orders covering portions of the Prudhoe Bay Unit are proposed to be
replaced with a single order, as follows:
Affected Order Field/Unit Pools
CO 261 Kuparuk River Field Kuparuk River Oil Pool
(Kuparuk River Unit) [Add 4 defined pools]
West Sak Pool,
Tarn Pool,
Tabasco Pool
Meltwater Pools
CO 297 Endicott Field Endicott Oil Pool
Duck Island Unit [Add 3 defined pools]
Sag Delta North Pool
I Alapah Pool
Eider Pool
CO 341D Prudhoe Bay Field Prudhoe Oil Pool
Rule 14 Prudhoe Bay Unit
Rescind: CO 342 Greater Point McIntyre Pt. McIntyre Pool,
Area Stump Island Pool,
Prudhoe Bay Unit Lisburne Oil Pool.
Rescind: CO 343 Prudhoe Bay Unit Niakuk Oil Pool.
CO 347 Milne Point Unit, Kuparuk River Oil Pool,
Schrader Bluff Oil Pool,
[Add 1 defined pool:]
Sag River Pool
AOGCC Proposal Re2ardin2 Rules Waivin2 Sundry Approval ReQuirements
11/2312004 Page 5 of 6
.
.
CO 351 McArthur River Field McArthur River Hemlock Pool,
Middle Kenai - G Pool,
West Foreland Pool.
Swanson River Field Hemlock Undefined Pool.
Middle Ground Shoal Middle Ground Shoal - A Pool,
Field Middle Ground Shoal - B, C, D
Pool,
Middle Ground Shoal - E, F, G
Pool,
Granite Point Field Middle Kenai Pool,
Hemlock Pool,
Trading Bay Field Hemlock Undefined Pool,
Middle Kenai - B Pool,
Middle Kenai - C Pool,
Middle Kenai - D Pool,
Middle Kenai - E Pool.
Ivan River Field Undefined Pool.
Lewis River Field Undefined Pool.
New CO Prudhoe Bay Field Consolidate 4 pools -
Prudhoe Bay Unit Pt. McIntyre Pool,
Stump Island Pool,
Lisburne Pool,
Niakuk Pool,
[Add 7 defined pools:]
Aurora Pool,
Borealis Pool,
Polaris Pool,
Orion Pool,
Midnight Sun Pool,
North Prudhoe Bay Pool,
West Beach Pool.
AOGCC Proposal Re2ardim! Rules Waivin2 Sundry Approval Requirements
11/2312004 Page 6 of 6
#3
~- - - ----
ADVERTISING It .ST BE IN TRIPLICATE SHOWING ADVERTISING ORC .TIFIED AO-02514023
ORDER A. F PUBLICATION (PART 2 OF THIS FORM) WITH ATi.~. PY OF
ADVERTISEMENT MUST BE SUBMIITED WITH INVOICE
SEE BOlTOM FOR INVOICE ADDRESS ,
"
F AOGCC AGENCY CONTACT DATE OF A.O.
R 333 W 7th Ave, Ste 100 Jodv Colombie November 18.2004
0 Anchorage,AJ( 99501 PHONE PCN
M - (907) 793 -1221
DATES ADVERTISEMENT REQUIRED:
T Anchorage Daily News November 22, 2004
0
PO Box 149001
Anchorage, AJ( 99514 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS
ENTIRETY ON THE DATES SHOWN.
SPECIAL INSTRUCTIONS:
Advertisement to be published was e-mailed
Type of Advertisement X Legal D Display D Classified DOther (Specify)
SEE ATTACHED
: SEND INVOICE IN TRIPLICATE ,:OGCC, 333 W. 7t~ Ave., Suite 100 I PAGE 1 OF TOTAL OF ,I
",', ""TO m . ,',', " Anchorage, AK 99)01 2 PAGES ALL PAGES$
REF TYPE NUMBER AMOUNT DATE COMMENTS
1 VEN
2 ARD 02910
3
4
FIN AMOUNT SY CC PGM LC ACCT FY NMR
Dlst LID
1 05 02140100 73451
2
3
4
REQUISITIONED BY: -=~~~\~( cí.Cf~ ^ A(l DIVISION APPROVAL:
-"" ,-----
(^ ì
i
._,//
.
Notice of Public Hearing
.
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re: Changes in certain fields' exemptions from requirements of20 AAC 25.280
relating to sundry approvals for workover operations.
The Alaska Oil and Gas Conservation Commission ("Commission"), on its own motion,
proposes to amend existing rules for certain fields that waive requirements of 20 AAC
25.280 relating to submission of an Application for Sundry Approval (Form 10-403) for
routine workover operations. In doing so, the Commission proposes to amend rules and
add new defined pools to Conservation Order ("CO") 261, CO 297, and CO 347; amend
Rule 14 CO 341D, amend CO 351, rescind CO 342 and CO 343, and create a new CO
consolidating and adding defined pools in the Prudhoe Bay Unit. The affected fields are:
Kuparuk River, Endicott, Prudhoe Bay (including Greater Point McIntyre Area), Milne
Point, McArthur River, Swanson River, Middle Ground Shoal, Granite Point, Trading
Bay, Ivan River, and Lewis River.
The proposed rule changes may be inspected at the Commissions offices or on its website
at:
http:í íwww.state.ak.usílocalíakpagesíADMINíogcíhomeogc.htm.
The Commission has tentatively set a consolidated public hearing on these
proposed actions for January 4,2005 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 the scheduled tentative hearing be held by filing a written request with the
Commission no later than 4:30 pm on December 8, 2004.
If a request for a hearing is not timely filed, the Commission will consider the issuance of
orders 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 these proposed actions to
the Alaska Oil and Gas Conservation Commission at 333 West ih Avenue, Suite 100,
Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on
December 23, 2004, except that if the Commission decides to hold a public hearing,
written comments must be received no later than 9:00 am on January 4,2005.
If you are a person with a disability who may need special accommodations in order to
comment or to attend the public hearing, øæOdY Col m ie at 793-122 t.
Danie T. Seamount, Jr.
Commissioner
Published Date: November 22,2004
ADN AO# 02514023
.chorage Daily News
Idavit of Publication
.
1001 Northway Drive. Anchorage. AK 99508
PRICE OTHER OTHER OTHER OTHER OTHER GRAND
AD# DATE PO ACCOUNT PER DAY CHARGES CHARGES iI2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL
348946 11/22/2004 02514023 STOF0330 $192.72
$192.72 $0.00 $0.00 $0.00 $0.00 $0.00 $192.72
Notice òf, Public Hearing
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re:: CnangeS.iri.':çert_oIn f:ièld~/, _ei.:e.:mPti~ns fr'¿'n,
r~quirem~nts Of20,AAC25.2S0 relating to
sùndry oppr'ovals for worl(over~operations.
T~~~ AJbs~~ :¡¡-á·'~Ú-'6:a-:; C~-i'S~Äl:l;iêfn C:Jmmission
C"Corr'T'lission", ·:>n it-:. 0·:'" ¡j"'=O~I'::", ::,.-opòsesto,
a~Emdexis:¡n:j ""J1es ¡';Jr cenn"·' ·¡~·CS, ~hat waive
re=lu:rl?r'rlC'!"'t.:' ;>f 20 ~:..: 25.2~:J rS'la""ng to submis-
s":Jr1 af 'J" ~co I::ot;:m fo" Su"·::ry .~ppr:)val (F·orm
1'; -1'13:' for r::wtir'e .'o"k:Jler oo-a"'a~lOns In doing
50. tr:.e Comm"ssi:J"1 ;J1"''JDose:; to r,¡mend, rules and
add :l~~·...._d~~:'i"'eu po::>I,s r:) C{H'3~"yo~ion:Orde'r
i: .':,.: '.: ::¡ ", .:.:~g"d~~da~~lçd43¡~
.. . . .... : Iling and addin!;íde-
, . .' ,: - ,'" ~,~,' Unit. The offeèted
fields· are: Kuparuk Rivêr; Endicott, PrudhoêBav
(includlng'Great~r Point Mcintyre Area), Milne
point; McArthur River,Syvanson River, Middle
Ground Shoal, Granite:;po.inl, Trading Bav', Ivon
River, and--Lewi's:River.'" , '~
STATE OF ALASKA
THIRD JUDICIAL DISTRICT
Teresita Peralta, 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
Anchora~e, Alaska, and it is now and durin~ 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.
:; ,;-
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Signed
5fuif/aJ
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":0(,:. :.
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,'. .' ,'" I ': ',~ " . -. .": . .:. ~ .. "
. ,':.","" " :
later than 4:30 pmon December S, 2004.
If a reqye,stfÓr a hearing is not timely filed, the
C:Jmrr-i:;sion :¡¡II· ::on~:der the issuO.,c-:- of orde,rs
·"¡Ith~ut :J heor;:19. To lear', ,t ti"'!:' CCM:"issi'onwíl'l
r10ld t~e DUD!i:: "€laring, olccsl~ :::'1 793-;221:
Notary Public in and for the State of Alaska.
Third Division. Anchorage, Alaska
rI! ! '1 J.ìf- /'¡ 7
MY COMMISSION EXPIRES: 1//1 I /./,j;C.C. /
'J I , / /'
I ,I :J ,I' ./ r ~ / ¡. ·1 / \ "p ~ :~"'; ~~;
{i! i/ /1 .\~,~~.r_...,
XI / ,: ¡ J / ; ./ r ~\.\', ~7:~ .,~. . ,. ~ ,
// ~'I -/'!/l..',l"}")'~'././I J:¿t'/ ,/"-J..',/j ,(,.;,' f -1.; li~ ,~~.-., ~\~ "H'~~'~ "
I~ ,', .',' ,-, "" ;;;:;.""- ,t , '."r'.,"", ,_ ¡...... "', '.
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ftf'~/
~r. 6ddftibii,"'0' "P'!-"-sonmc:y subl'n;twrLttenc:_om~
rnen·; ~egardinq tt'1ese prO:3Os'!:'c! acJi.ons\ to the
~iask~ Oi· and Gas :O'1Sf.&r"'J':J'lon C,~mm,ission at
3J3 'Nes· 7~h Ave'1oJe, Sui!'e :00. .1.r.cnorage, AI,aska:
995Gi ·"Jrõtten com",ents mu;:¡r b~ received no
¡o~e~ ~hor .t:30 pm on DE"cer~'oe" 23, 2004, except
that if,the'Commissiondecldes tohold a public
he-aring, written comments must be received no
later than 9:00 am on Januarv 4, 2005.
If vou are 0 person with a, disabilitv wha mav need
speciol accommodations in order to comment or to
àttend the ¡>ublicheariog, please contact Jodv Co-
lombie a1793-1221. '
,::_,-:-_,,"_--,:';: ß'-',
Dan'Iel, T: Seàmount;'J r.
COrT!m'issioner ...
Subscribed and sworn to me before this date:
f), L J
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From: legalads < @adn.com>
Date: Thu, 18 Nov 200416:54:48 -0900
To: Jody Colombie <jody _ colombie@admin.state.ak.us>
Hi Jody:
Following is the confirmation information on your legal notice. Please let me know if you have any questions or
need additional information.
Account Number: STOF 0330
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Kim Kirby
Anchorage Daily News
Legal Classified Representative
E-Mail: legalads@adn.com
Phone: (907) 257-4296
Fax: (907) 279-8170
----------
From: Jody Colombie
Sent: Thursday, November 18, 2004 1 :54 PM
To: legalads
Subject: Public Notice
«File: Consolidated notice.doc»«File: Ad Order form.doc»
Please publish on 11/22/04.
1 ofl
11/19/20047:10 Al\1
-~ - ---~ - -r-'" ...........
.~~~. . .us
i~V,tKl'v1
STATE OF ALASKA
ADVERTISING
ORDER
SEE BOTTOM FOR INVOICE ADDRESS
.. ..
INVO!UST 8E I~~~~~T~ S~~I:~~~~:~~:ER .ERTIFIED
AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COpy OF
ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE
ADVERTISING ORDER NO.
AO-02514023
F
AGENCY CONTACT
Toclv ~ I I'
PHONE
{c}()7ì 7c}~ -1 ?? 1
DATES ADVERTISEMENT REQUIRED:
DATE OF A.O.
AOGCC
333 West 7th Avenue, Suite 100
Anchorage,AJ( 99501
M 907-793-1221
R
o
...~
1>< 2004
PCN
T
o
Anchorage Daily News
PO Box 149001
Anchorage, AJ( 99514
November 22,2004
THE il<lA TERIAL BETWEEN THE DOUBLE LINES MtiST BE PRINTED IN ITS
ENTIRETY ON THE DATES SHOWN.
SPECIAL INSTRUCTIONS:
United states of America
AFFIDAVIT OF PUBLICATION
REMINDER
State of
ss
INVOICE MUST BE IN TRIPLICATE AND MUST
REFERENCE THE ADVERTISING ORDER NUMBER.
A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION
MUST BE SUBMITTED WITH THE INVOICE.
ATTACH PROOF OF PUBLICATION HERE.
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
and
state of
and that the advertisement, of which the annexed
is a true copy, was published in said publication on the
day of
2004, and thereafter for _ consecutive days, the last
publication appearing on the _ day of
, 2004, 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
2004,
Notary public for state of
My commission expires
02-901 (Rev. 3/94)
AO.FR.t\1
Citgo Petroleum Corporation
PO Box 3758
Tulsa, OK 74136
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
Mark Wedman
Halliburton
6900 Arctic Blvd.
Anchorage, AK 99502
Baker Oil Tools
4730 Business Park Blvd., #44
Anchorage, AK 99503
Gordon Severson
3201 Westmar Cr.
Anchorage, AK 99508-4336
James Gibbs
PO Box 1597
SOldotna, AK 99669
Richard Wagner
PO Box 60868
Fairbanks, AK 99706
Williams Thomas
Arctic Slope Regional Corporation
Land Department
PO Box 129
Barrow, AK 99723
.
Mary Jones
XTO Energy, Inc.
Cartography
810 Houston Street, Ste 2000
Ft. Worth, TX 76102-6298
.
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
Schlumberger
Drilling and Measurements
2525 Gambell Street #400
Anchorage, AK 99503
Ciri
Land Department
PO Box 93330
Anchorage, AK 99503
Jack Hakkila
PO Box 190083
Anchorage, AK 99519
Kenai National Wildlife Refuge
Refuge Manager
PO Box 2139
Soldotna, AK 99669-2139
Cliff Burglin
PO Box 70131
Fairbanks, AK 99707
North Slope Borough
PO Box 69
Barrow, AK 99723
David McCaleb
IHS Energy Group
GEPS
5333 Westheimer, Ste 100
Houston, TX 77056
George Vaught, Jr.
PO Box 13557
Denver, CO 80201-3557
John Levorsen
200 North 3rd Street, #1202
Boise, ID 83702
Michael Parks
Marple's Business Newsletter
117 West Mercer St, Ste 200
Seattle, WA 98119-3960
David Cusato
200 West 34th PMB 411
Anchorage, AK 99503
Jill Schneider
US Geological Survey
4200 University Dr.
Anchorage, AK 99508
Darwin Waldsmith
PO Box 39309
Ninilchick, AK 99639
Penny Vadla
399 West Riverview Avenue
Soldotna, AK 99669-7714
Bernie Karl
K&K Recycling Inc.
PO Box 58055
Fairbanks, AK 99711
III a I /¿? cA-
!~Ø9)i/
of2
11/
Robert E Ylintz <robert mintz(~law.state.ak.us>, Christine Hansen
- '-
<c.hansen@iogcc.stat~.ok.us>, Terrie Hubble <hubbletl@bp.com>, Son.dra Stewman
<StewmaSD@BP.com>, Scott & Cammy Taylor <stayJor@alaska.net>, stanekj
<stanekj@unocal.com.>, ccolaw <ecolaw@trustees.org>, roseragsdale <roseragsdale@gci.ncl>, tnnjr
<tnnjrl@ao1.com>,jbriddle <jbriddle@marathonoil.com>, rockhill <rockhill@aoga.org>, shaneg
<shaneg@cvergreengas.com>, jdarlington <jdart ington@f:orestoil.com>, nelson
<knclson@petroleumncws.com>, cboddy <cboddy@usibelli.com>, Mark Dalton
<mark.dalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips.com>, "Mark P.
Worcester" <mark.p.worcester@conocophillips.com>, "Jerry C. Dethle[ç;"
<jerry.c.dethlcfs@conocophiUips.com>, Bob <bob@inletkeepcr.org>, wdv <wdv@dnr.state.ak.us>,
~jr <tjr@dnr.state.ak.us>, bbritch <:bbritch@alaska.net>. mjnelson <mjnelson@purvingertz.com>,
Charles O'Donnell <charles.o'donnell@vcco.com>, "Randy L. Skillern" <SkillcRL@BP.com>,
"Deborah J. Jones" <JonesD6@BP.com>, "Paul G. Hyatt" <hyattpg@BP.com>, "Steven R. Rossberg"
<RossbeRS@BP.com>, Lois <lois@inletkeeper.org>, Dan Bross <kuacnews@kuac.org>, Gordon
Pospisil <PospisG@BP.com>, "Francis S. Sommt:r" <SommcrFS@BP.com>, Mikel Schultz
<:vlikel.Sehultz@BP.com>, "~ick W. Glover" <Glover!\W@BP.com>, "Daryl J. Kleppin"
<KleppiDE@BP.com>. "Janet D. Platt" <PlattJD@BP.com>. "Rosanne M. Jacobsen"
<JacobsR\tl@BP.com>. ddonkel <ddonkel@d1.rr.com>, CaBins Mount
<collins__mount@revenue.state.ak.us>, mckay <mckay@gci.n~t>, Barbara F Fullmer
<barbara.f fullmer@conocophillips.com>, bocastwf <bocastwf@bp.com>, Charles Barker
··.:::barkcr@usgs.gov>, doug_.schultzc <doug_schultze@xtocnergy.com>, Hank Altord
<hank.alt(xd@exxonmobil.com>, Mark Kovac <yesnoJ (ffgci.ner;...., gspfotI
<gspfoft@aurorapowçr.com>, Gregg Nady <gregg.nady@shell.com>, Fred Steece
<fred.steecc@state.sd.us>, rcrotty <rcrotty@ch2m.com>,jejoncs <jejoncs@aurorapower.com>, dapa
<dapa@alaska.nct>, jroderick <'-jroderick@gci.nct>, eyancy <eyancy@seaJ-titc.nct>, "James M.
Ruud" '<james.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>,
Mark Hanley <markJlanley@anadarko.com>, 10ren_Ieman <lorcn_leman@gov.state.ak.us>, Julie
Houle <julie_houle@dnr.state.ak.us>, John W Katz <jwkatz@sso.org>, Suzan J Hill
<suzan_hill@dcc.state.ak.us>, tablcrk <tablcrk@unocal.com>, Brady <brady@aoga.org>, Brian
Havelock <beh(0dnr.state.ak.us>, bpopp <bpopp@borough.kenai.ak.us>, Jim \\inite
(jimwhite@satx.rr.com>, "John S. Haworth" <john.s.haworth@cx.xonmobil.com>, marty
<marty@rkindustrial.com>, ghammons <ghan1D1ons@aol.com>, rmc1ean
<nnclean@pobox.alaska.net>, mkm7200 <mkmï200@aol.com>, Brian Gillespie
<ifbmg@uaa.alaska.edu>, David L Boelcns <dbocJens@aurorapowcr.com>, Todd Durkee
<TDLRKEE@K~1G.com>, Gary Schultz <gary_schultz@dnr.statc.ak.us>, Wayne Rancier
<RA:\'CIER@petro-canada.ca>, Bill Miller <BiH.__Miller@xtoalaska.com>, Brandon Gagnon
<bgagnon@brenalaw.com>, Paul Winslow <pmwinslow@f()rcstoil.com>, Garry Catron
Kcatrongr@bp.com>, Sbarmaine Copeland <copelasv@bp.com>, Kristin Dirks
<kristin_dirks@dnr.state.ak.us>, KayllCll Zcman <kjzcman@marathonoil.com>, John Tower
<John.Tower@eia.doe.gov>, Bill Fowler <Bill_ Fowter@anadarko.COM> , Vaughn Swartz
<vaughn.swartz@rbccm.com>, Scott Cranswick <scott.cranswick@mms.gov>, Brad McKim
<mckimbs@BP.com>, Steve Lambe <lambes@unoca1.com>, jack newell
8/2004
55 PM
Date
To: undisclosed-recip
BCC
Subject: Public Notice
From: J ody Colombie <jody _ colombie@admin.state.ak.us>
Thu, 18 \iO\' 2004 13:55:27 -0900
ients
.
.
20f2
¡Consolidated _ notice. doc
Content-Type: applicationlmsword
Content-Encoding: base64
11/18/2004
:55 PM
<jack.newell@acsalaska.n
<David.Roby@mms.gov>
&es Scherr <James.Scherr@mms.b
.avid roby
Subject: Public Notice
From: Jody Colombie <jody_colombie@admin.state.ak.us>
Date: Thu, 18 Nov 2004 13:54:50 -0900
To: Legal Ads Anchorage Daily News <legalads@adn.com>
.
.
Please publish, on1:i[22/04.
Content-Type: applicationlmsword '
Consolidated notice. doc
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Content-Type: applicationlmsword
Ad Order form.doc
Content-Encoding: base64
1 of 1
11/18/20041:55 PM
~ullJed: Public Notice
F'~oln:Joçly Co lQmbie <jody_ colombie@admin.state..ak.us>
.Qat~:'J?hu.,,18Nov 2Q04,13:?4:03-0900
T o:undisc1osed~recipients:;
BCC: Cynthia BMciŸer <bren mciver@admin.state.ak.us>, Angela Webb
<angie _ webb@admin.statê.ak.~s>
.
.
Please add to website.
Content-Type: applicationlmsword
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1 of!
11118/2004 1:55 PM
#2
ConocoPhillips
BPXA
Marathon
XTO
AOGCC
AOGA
.
.
ANTICIPATED ATTENDEES
AOGAJAOGCC WORKING GROUP MEETING
ON REPORTING REQUIREMENTS
1:30 p.m., Wednesday, June 30, 2004
AOGA Conference Room
Jerome Eggemeyer
Jerry Dethlefs (via teleconference)
Bob Christensen (via teleconference)
Harry Engel
-,lmi.-s'T\I ,,~,,' " , .
~~
Bill Miller
Tom Maunder
~
Jack Hartz
Theresa Rockhill
Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination June, 2004
Summary of Well Work Sundry Requirements
20 AAC 25.280(a) prescribes that Operators will seek approval to perform any workover operations as described in the regulation. In
recognition of "routine" operations and in order to reduce the burden for the Operator and Commission, a series of Conservation Orders
were enacted relieving many Operators from the requirement for notice and approval prior to performing the workover operations in
specific pools. The specific pools presently authorized a sundry waiver are:
Prudhoe Bay Oil Pool (CO 341D) - Lisburne and Pt. McIntyre Oil Pools (CO 342)
Niakuk Oil Pool (CO 343) - Endicott Oil Pool (CO 297)
Kuparuk River Oil Pool (CO 261) - Milne Point and Schrader Bluff Oil Pools (CO 347)
Listed pools within Cook Inlet area oil and gas fields operated by Unocal (CO 351)
.
The requirement to report work accomplished as required by 25.280(d) was not removed. A further requirement of the waiver orders
was for the Operator to supply the Commission a weekly listing of planned well work operations. Review of some Commission well
files has indicated that no well work has been reported for a number of years on some wells. It has been the Commission's experience
that the listing of intended or planned work has not provided much benefit. The intent of this effort is to cooperatively establish the
notification, approval and reporting requirements for various "workover" operations performed in the fields and change the weekly
reporting requirement to what work has actually been done. The outcomes of this effort should be consistent requirements for the
Operators and reasonably accurate well files for the Commission.
In the following table, various well work operations and approval/reporting requirements have been identified. The operations
identified in the table are not meant to be an all-inclusive listing of the possible well work operations that could be performed on a well.
It is an attempt to identify the most common operations and categorize them according to determined reporting requirements. Please
note that with the exce tion of column 1 No Forms Re uired an exem tion to the re uirement to file a sundr notice t
perform well work can on Iv be eranted via a Conservation Order.
In the table, you will see D and S following individual operations or categories. The approval and reporting requirements are different
depending on the classification of a well as development (production wells) (D) or service (injection wells) (S). Exploration and
stratigraphic wells are excluded. Service wells are subject to additional regulations due to the Underground Injection Control Program
(UIC). Underground injection is closely regulated by EP A and the Class II portion of the program has been delegated to AOGCe. Due
to the UIe requirements, the information needs are greater for service wells than development wells. Please also note that an Injection
Order must be in place before any fluids may be injected.
Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination June, 2004
No Forms Required
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing Operations (D and S)
· Fill tag
· Set & pull retrievable plugs
· Change GLV's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
· Caliper surveys
· Reperforating existing intervals
· Bottom hole samples
· Spinner surveys
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
· Patches
· Pump changes.
· Packoff GLM (POGLM)
If "non-routine" Column 1 operations are I
planned on a disposal well, the Operators' i
engirieer should contact the, AOGCC to I
__~~te~!ne ~[~~~!ldry_~ppE~~)j~)~.E~_~~~~.. _
1 Form Required
2 Forms Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing Operations
-10-403 Required
-10-404 / 407 or other form Re uired
Thru-tubing Operations (S)
· Permanent cement or mechanical plugs that .
do not completely abandon a zone. (D)
· Cutting off tailpipes. (D)
· Perforate new intervals
within a poo 1
Permanent cement or mechanical plugs
that do not completely abandon a zone.
. Cutting off tailpipes.
(D and S)
SPECIAL
(D and S)
In all cases where there is an unusual event,
a sundry will be required if the Commissio
requests it.
If a well is operating under a sundry
approval, a 403 may be required to perform
work. The Operators' engineer should
consult with the AOGCC to determine if a
sundry notice if needed.
Please note that authorization from EP A
Region 10 may be necessary to perform
work on any of the Class I wells on the
slope.
Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination June, 2004
No Forms Required
-10-403 Not Required
-10-404 Not Re uired
Thru-tubing pumping Operations, including
using coil. (D and S)
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal
· Inhibitor squeezes
· Hot Oil
· Tubing acid jobs
· Fill clean out
Other Operations (D and S)
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
1 Form Required
-10-403 Not Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations, including
using coil.
·
Stimulations (frac or acid)
Remedial cementing operations
o Conductor Fill
Squeezes/plugs to control fluid
movement in zone
(D and S) .
(D) .
·
(D and S)
·
Other Operations
· Injection well MIT (on MIT form) (S)
· Initial conversion from water injector
to WAG injector (S)
· Convert from injector to producer if for
more than 30 days. (S)
· Seal welding on bradenheads (D and S)
Rig/Coil Operations
· Alteration of mechanical completion
o Pulling tubing, milling packers (D
o Install velocity strings (D)
2 Forms Required
-10-403 Required
-10-404 / 407 or other form Re uired
Thru-tubing pumping Operations,
including using coil.
.
Stimulations (frac or acid) (S)
Remedial cementing operations
o Casing shoes (outer annulus)
(D and S)
Repair casing
o "pumping" repairs (gel or cement
squeezes) (D and S)
Other Operations
· Convert producer to injection (D)
· Alteration of mechanical completion
o Pulling tubing, milling packers (S)
· Major welding repairs on wellheads
(D and S)
· Conductor "cutaways" and surface
casing welding repairs
(D and S)
· Annular disposal (D and S)
(Reported on form 10-423)
Rig/Coil Operations
· Alteration of mechanical completion
o Pulling tubing ,milling packers (S)
· Repair Casing
o Mechanical repairs (D and S)
(scab liners, tiebacks, etc)
.
.
Notice of Public Hearing
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re: Waiver of Requirements for filing Sundry Notice (Form 403) for Workover
Operations as contained in the following Orders:
Conservation Order 261 :
Conservation Order 297:
Conservation Order 341D:
Conservation Order 342:
Conservation Order 343:
Conservation Order 347:
Conservation Order 351:
Kuparuk River Oil Pool
Endicott Oil Pool
Prudhoe Bay Oil Pool
Greater Point McIntyre Area/Prudhoe Bay Field, Pt.
McIntyre Stump Island and Lisburne Oil Pools
Niakuk Oil Pool
Milne Point and Schrader Bluff Oil Pools
Various Cook Inlet Oil and Gas fields operated by
Unocal
The Alaska Oil and Gas Conservation Commission ("Commission"), on its own
motion, proposes to amend rules waiving the requirement at 20 AAC 25.280 (a) to submit
a sundry notice (Form 403) seeking approval to perform workover operations as
contained in the listed Conservation Orders (CO) for the specified pools. The
Commission also proposes to add additional productive pools to CO 261 (Kuparuk) and
CO 341D (Prudhoe Bay). The proposed rules may be inspected at the Commissions
offices or on its website at
htip ://www.state.ak.us/locaUakpages/ADMIN/ogc/homeogc.htm.
The Commission has tentatively set a consolidated public hearing on these
proposed actions for [DATE and TIME] at the Alaska Oil and Gas Conservation
Commission at 333 West ih 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 [DATE)..
If a request for a hearing is not timely filed, the Commission will consider the
issuance of orders 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 these proposed
actions to the Alaska Oil and Gas Conservation Commission at 333 West ih A venue,
Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than
.
.
4:30 pm on [DATE], except that if the Commission decides to hold a public hearing,
written comments must be received no later than 9:00 am on [DATE].
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 [DATE]..
John Norman
Chair
Published Date: [DATE]
ADN AO# [XXXXXXX]
~
----,/
.
.
STATE OF ALASKA
ALASKA OIL AND GAS CONSERV A TION COMMISSION
3001 Porcupine Drive
Anchorage Alaska 99501-3192
Re: THE MOTION OF THE ALASKA
OIL AND GAS CONSERVATION
COMMISSION to ammend Conservation
Order No. [342] exempting development wells
in the [Point McIntyre, Stump Island and
Lisburne] oil pools from the requirements of 20
AAC 25.280 and to change the name of the
Operator
IT APPEARING THAT:
) Conservation Order No. [342A]
)
) [Greater Point McIntyre Area]
) [Point McIntyre Oil Pool]
) [Stump Island Oil Pool]
) [Lisburne Oil Pool]
)
[DATE]
1. [ARCO Alaska, Inc., operator of the Greater Point McIntyre Area/Prudhoe Bay
Field, submitted an application on September 9, 1994 requesting exemption from
the requirements of 20 AAC 25.280(a) and (b) for all wells in the Pt McIntyre,
Stump Island and Lisburne oil pools.
2. Conservation Order No. 342 was issued November 2, 1994 waiving the need to
file Sundry Approvals (Form 403) for all "producible wells (i.e., development
wells)" in the subject pools.
3. The Operator of the Greater Point McIntyre Area has nominally changed
through corporate acquisitions and corporate mergers. ARCO Alaska, Inc., the
original Operator, was acquired by Phillips Petroleum Company (PPCo) which
has since merged with Conoco and operates in Alaska as ConocoPhillips Alaska,
Inc. (CP AI). BP Exploration Alaska, Inc (BPXA) has succeeded ARCO and its
successors as operator for the Greater Point McIntyre Area.]
4. Notice of public hearing was published in the Anchorage Daily News on [DATE].
5. No protests to the application were filed with the commission.
FINDINGS:
1. 20 AAC 25.280(a) requires all operators to file an Application for Sundry
Approvals (Form 10-403) and receive commission approval prior to performing
well workovers (i.e., perforating or reperforating casing, well stimulation, pulling
tubing, altering casing, and repairing wells).
Conservation Order .J42A
Page 2 .
.
[DATE, 2004]
a. Information regarding the well condition, well workover program, bottom-hole
pressure and well control program must be submitted with an Application for
Sundry Approval. 20 AAC 25.280(b).
b. The operator must submit a Well Completion or Recompletion Report and Log
(Form 10-407) within 30 days after completing a well. 20 AAC 25.070.
c. The operator must maintain records and reports of well workovers for at least five
years, per 20 AAC 25.280(c) and 20 AAC 25.070. The operator must submit a
complete well record, with copy of daily reports and tests, after completing well
workovers on a Report of Sundry Well Operations (Form 10-404) per 20 AAC 25.
280( d).
2. The Commission approved Conservation Order No. [342 November 2, 1994]
relieving the operator of the sundry approval requirement on production wells for the
type of operations in 20 AAC 25.280(a) 1 - 5.
3. Granting relief from the requirements of 20 AAC 25 .280( a) and (b) for all production
(development) wells in the Point McIntyre, Stump Island and Lisburne oil pools can
result in administrative efficiencies for both the operator and the AOGCC.
4. Sustained Casing Pressure Rules have been or are being enacted governing the
operation of all production wells statewide.
5. Work within the physical confines of the production casing/liner or the production
tubing may be considered standard and routine for wells in the subject pools.
6. Alteration of casing, which provides a physical barrier between the wellbore and the
subsurface formations, in development and service wells is not considered standard or
routine.
7. Alteration of casing, which provides a physical barrier between the wellbore and the
subsurface formations, in development and service wells is not considered standard or
routine.
8. Well workovers as described in 20 AAC 25.280 (a), (1), (2), (3) and (5) on
development wells do not prompt additional requirements beyond the criteria imposed
by regulation.
9. The commission has primacy for all Class II injection wells in the state.
10. Well workover operations on injection wells may prompt additional requirements
such as mechanical integrity tests and cement quality logs.
11. Commission inspectors routinely inspect drilling and well workover operations to
ensure compliance with regulations.
Conservation Order 342A
Page 3 .
.
[DATE, 2004]
12. Weekly reports of planned or anticipated operations have been filed with the
commission since the order was adopted. The reports do not specify if the work is to
be performed.
CONCLUSIONS:
1. The Operator is likely to perform well workover operations in these oil pools. Some
operations have become standard and routine, however operations to effect repairs to
casing should not be considered routine.
2. Eliminating the requirements of 20 AAC 25.280(a) (1), (2), (3) and (5) and (b) for
some production (development) wells in these oil pools will result in administrative
efficiencies for both the operator and the AOGCC.
3. Eliminating the requirements of 20 AAC 25.280(a) (1), (2), (3) and (5) and (b) for
some production wells in the will not promote waste or jeopardize correlative rights.
4. Increased regulatory scrutiny for those wells reported to the Commission in
compliance with the Sustained Casing Pressure Rules [CO 492 for Lisburne and
CO 503 for Point McIntyre and Stump Island] is appropriate.
5. Increased regulatory scrutiny for wells with compromised ability to contain pressure
is appropriate.
6. Increased regulatory scrutiny for work to repair casing (20 AAC 25.280 (a)(4)) is
appropriate.
7. Administration of the Class II UIC program requires approval and reporting of
workovers on all service wells (i.e., gas and gas storage injection, water injection,
waste injection wells) as outlined in 20 AAC 25.280.
8. A Subsequent Report of Sundry Well Operations (Form 10-404) done on Class II UIC
wells must be filed with the commission to comply with 20 AAC 25.280(d).
9. Providing a schedule of upcoming or planned workover operations has not aided the
commission with its compliance responsibilities.
10. A list of work performed in the preceeding week will assist the commission with its
compliance responsibilities.
NOW, THEREFORE IT IS ORDERED THAT:
This Conservation Order supersedes [CO 342 dated November 2, 1994] The findings,
conclusions and administrative record for [CO 342] are adopted by reference and
Conservation Order 1~
Page 4 .
.
[DATE, 2004]
incorporated in this decision. The following rules, in addition to statewide requirements
under 20 AAC 25, to the extent not superseded by these rules, apply to the [Pt.
McIntyre, Stump Island and Lisburne] Oil Pools.
Rule 1
Except as noted in Rules 2 and 3, the requirement to submit a sundry notice (Form 403)
for workover activities described in 20 AAC 25.280(a) (1), (2), (3) and (5) is hereby
waived for all production (development) wells in the CPt McIntyre, Stump Island and
Lisburne] oil pools.
Rule 2
If a production well has been reported to the Commission in compliance with the
Sustained Casing Pressure Rules [CO 492 for Lisburne and CO 503 for Point
McIntyre and Stump Island], then the provisions of 20 AAC 25.280 apply and an
Application for Sundry Approval (Form 403) is required
Rule 3
The Commission, at its' own discretion, may request that an Operator provide a sundry
notice prior to performing work on any well.
Rule 4
The Operator shall provide the Commission with a report of workover operations
performed on a weekly basis noting the date, well and nominal operation completed.
Rule 5
Nothing in this order precludes an Operator from filing a sundry notice in advance of well
work.
Rule 6
Unless notice and public hearing is otherwise required, the Commission may
administratively waive the requirements of any rule stated above or administratively
amend any rule 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 an
increased risk of fluid movement into freshwater.
DONE at Anchorage, Alaska and dated [DATE, 2004].
John K. Norman, Chairman
Conservation Order
Page 5
-.
.
[DATE, 2004]
Alaska Oil and Gas Conservation Commission
Daniel T. Seamount, Jr., Commissioner
Alaska Oil and Gas Conservation Commission
AS 31,0'.080 provides that within 20 days after receipt ofwrÎuen notice arUte entry oran order, a person affected by it may file wit:h the Commission m application for rehearing. ,A, request for rehearÎng must be
received by 4:30 PM on the 2Jrd day following the date arme order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application ín whole or in pan wíthin
10 days. The Commission can refuse an application by not aCling on it within the IO-day period. An affected person has 30 d¡tys tram the date the Commission refuses the application or mails (or otherwise
distributes) an order upon rehearing. both being the final order of the Commission. 10 appeal the decision to Superior Court. Where a request for rehearing is denied by RCDaction of the CommissÎon. the 30 day
period for appeal to SuperÎor Coun runs trom the date on which !.he request is deemed denied (i.e., 10th day after !.he application for rehearing was filed).
Alaska t.&~~.._LOnSe~~_:~~~ 4fmmission
Forms Notice
June 16, 2004
All Alaska Operators and AOGA
RE: Current Commission Forms Over the past year, the Alaska Oil and Gas Conservation
Commission (AOGCC) has revised the permit and reporting forms required by the Commission's
regulations. Copies of the revised forms are available in electronic versions (pdf and Excel) on the
AOGCC web site (www.aogcc.alaska.gov).Printed copies of the forms may be obtained by calling
the Commission's offices at (907) 793-1221.
The AOGCC's electronic data system is based on the current set of forms. In the future, the AOGCC will
be offering operators the option of submitting reports and permit information electronically. To insure
we can accept the information submitted it is imperative that operators use only the current set of
forms and follow the instructions provided.
The Commission expresses appreciation to the operators in the state that are already using the new
forms. Those who have not yet done so should visit the AOGCC web site to obtain the newest
versions,
effeçtiY~~Se.Rtemºer L 2ºº~,_ªPRli.çªtign§ªJ1d reports .s.!JÞmltt~don fQrms with revisio.n dCiJe.spriQrJo
$ePtemÞer~ºQ3_w.W riot l;>eaÇceptecl.
If you or your colleagues have any questions, please contact Steve McMains at (907) 793-1242 or
steve _mcmains@admin.state.ak.us.
John K. Norman
Chair
Daniel T. Seamount, Jr.
Commissioner
.' .-, ...,.-'.".,...."..~,...........
Forms Index
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· AOGCC/AOGA WORKING GROU!'
ON AOGCC REPORTING REQUIREMENTS
ALASKA OIL AND GAS ASSOCIATION
AOGA Conference Room
121 W. Fireweed Lane
Suite 207
Anchorage, Alaska
2:00 p.m.
Wednesday
June 16, 2004
AGENDA
1. Review/recommendations on AOGCC matrix outlinina Routine Sundry
Activities that ReQuire Follow-Up Reports
2. Discussion reaardina other AOGCC reQuired reports
3. Other Business
4. Next Meetina
5. Adiournment
c:06.16.04agenda
.
.
ANTICIPATED ATTENDEES
AOGA/AOGCC WORKING GROUP MEETING
ON REPORTING REQillREMENTS
2:00 p.m., Wednesday, June 16, 2004
AOGA Conference Room
ConocoPhillips
Barbara Fullmer
Jerome Eggemeyer
BPXA
Harry Engel 'J-, i~i
Garry Catron ~ j'c/, I æ (AA.,J!!f'-
J --) 1-~k4J
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Marathon
Gary Laughlin
XTO
Bill Miller
AOGCC
Tom Maunder
Steve McMains
Jack Hartz
AOGA
Theresa Rockhill
aft
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Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination June, 2004
Well Work or Sundry Operations
20 AAC 25.280(a) prescribes that Operators wiU seek approval to perform any workover operations as described in the regulation. In
recognition of "routine" operations and in order to reduce the burden for the Operator and Commission, a ~~s oLÇgE~ryation ºrd~~ It L
were enacted relieving many Operators from the requirement for notice prior to performing the workover operations in specific pools<
The requirement to report work accomplished as required by 25.280(d) was not removed. Review of some Commission well files has t)
indicated that no well work has been reported for a number of years on some wells. The intent of this effort is to cooperatively establ5a ¿
the notification and reporting requirements for various "workover" operations performed in the fields. The outcomes of this effUW'
should be consistent requirements for the Operators and reasonably accurate well files for the Commission.
In the following table, various well work operations and proposed approval/reporting requirements have been identified. The operations
identified in the table are not meant to be an all-inclusive listing of the possible well work operations that could be performed on a well.
It is an attempt to identify the most common operations and categorize them according to determined reporting requirements. Please
note that, with the exception of column 1 (No Forms Required) an exemption to the requirement to file a sundry notice to perform well
work can only be granted via a Conservation Order.
In the table, you will see D and S following individual operations or categories. The approval and reporting requirements are different
depending on the classification of a well as development (D) or service (S). Exploration and stratigraphic wells are excluded. Service
wells are subject to additional regulations due to the Underground Injection Control Program (UIC). Underground injection is closely
regulated by EPA and the Class II portion of the program has been delegated to AOGCC. Due to the UIC requirements, the information
needs are greater for service wells than production wells.
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Well Work Operations and Notice/Reporting Requirements
AOGCC/AOGA Workgroup Determination June, 2004
~íø.áÅ¡., (D and S) External to casing
Spinner surveys . Stimulations (frac or acid)
· Pressure & Temperature surveys - unless . Perforate new intervals
required by some specific approval with-in pool
· Reperforating existing intervals
· Logs - CNL, TDT, CO, CCL, CBL and
Other Types - Unless required by some
specific approval
, y910-403 Not Required
(6 v -10-404 Not Re uired
Wireline¡Üperations (D and S)
· Fill tag
· Set & pull retrievable plugs
· Change GL V's
· Dummy & gauge ring runs
· Pull & rerun SSSV's
· Pressure surveys - unless required by
some specific approval
· Temperature surveys - unless required by
some specific approval
/
/
/
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I Form Required
-10-403 Not Required
-10-404 or 407 Re uired
Wire line Operations (D)
· Permanent cement or mechanical plugs
that do not completely abandon a zone.
Electric Line Operations (D)
· Permanent cement or mechanical plugs
that do not completely abandon a zone.
· Cutting off tailpipes. (D)~d (5)
(D)
(D and S)
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2 Forms Required
-10-403 Required
-10-404 or 407 Re uired
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SPECIAL
(D and S)
In all cases where there is an unusual event a
,
sundry will be required if the Commission
requests it.
If a well is operating under a sundry approval
a 403 may be required to perform work. The
Operators' engineer should consult with the
AOGCC to determine if a sundry notice if
needed.
.
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Well Work Operations and Notice/Reporting Requirements ~
AOGCC/AOGA Workgroup Determination June, 2004 J~
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*
No Forms Required
~
-1-0-403 Not Required
-10-404 Not Re uired
Other - Inside tubing, casing (D and S)
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal
· Inhibitor squeezes
· Hot Oil
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
Rig/Coil Tubing Operations (D and S)
· Fill clean out
· Scale milling
· Tubing acid jobs
f) / rf'"
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· ~ Rfl"
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1 Form Required
-10-403 Not Required ( '"
-10-404 or 407 Re uiredA7
Internal to casing & tubing
· Injection well MIT (S) JL,~
*-. Convert from water to MI.....f'd"'\'(S)
· Convert from injector to (S)
producer
,f.. ?~t6'~~ (p)
Rig/CoillPumping Operations
· Alteration of mechanical completion
o Squeezes/plugs to control fluid
movement in zone (D and S)
· Remedial cementing operations
o Casing shoes (outer annulus)
o Conductor Fill
· Pulling tubing, milling packers (D!/
.......~
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2 Forms Required
-10-403 Required
-10-404 or 407 Re uired
g--- -¥:
· Convert producer to injection (S) .
· Repair casing (D and S)
o ~his in~ludes both ~echanical repairs 1 t ¡,~t'~¿g¡'
(mstallmg scabs or tiebacks) and ( ,,' ,
"pumping" repairs (gel or cement )
squeezes)
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Rig/Coil/Pumping Operations
. Alteration of mechanical completion
o _.2uUiag-tumft.g,.milling.pJ!£,kers (S)
· b Welding on wellheads (D and S
~r;=;,,;1\ w/[p, (ai~~?; ·
Cðt{f;J §tf~k.~ I ~-c:,¡
¿ç-;
t5Î,t'/ , ~
Theresa Rockhill
.
.
From:
Sent:
To:
Cc:
Subject:
Eggemeyer, Jerome C. [Jerome.C.Eggemeyer@conocophillips.com]
Friday, May 21 ,20049:54 AM
Tom Maunder (E-mail)
rockhill@aoga.org
AOGCC - Forms vs Activities.xls
{J
AQGCC . Forms vs
Activities.xl... Tom,
In our AOGA meeting this week I promised to send a draft format of reports versus
activities that we could use to facilitate dialogue regarding spirit of intent for
reporting of various activities. obviously this is a partial list of activities.
Thanks,
Jerome Eggemeyer
«AOGCC - Forms vs Activities.xls»
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number of ·S {! ~ :,g ~ ~ ~ :,g,!:, Þ1 Ib' ~ ~ 0 0 <f õ' 0 9: Q. ~ ~ tf ~ 8i if .f:! P
, ~ ~ ~ Þ1 ~ ~ ~ & ~ ð 6 ~ ~ ! ~ ~ ~ ~ ~ ! ~ III III ~ Þ1 , !
form Form Name f , ¡ ¡ £ I , , i M I ø 0 ~ 6 Ii a , !o I 6 & ~ ~ .~ ~ ~ i
10-401 Permit to Drill (10-401\ I
10-402A Surety Bond (10-402A) .
10-402B Personal Bond (10-402B)
1 0-403 Application for Sundrv Approvals (10-403)
10-403AD Annular Disposal Application /10-403AD\
10-404 Report of Sundrv Well Operations /10-404)
10-405 Monthlv Production Report /10·405)
10-406 Monthlv Iníection ReDor! /10-406)
10-407 407)
10-409
Well Status Report and Gas-Oil Ratio Tests /10-409)
10-411 DesiQnation of Operator /10-411)
10-413 Report of Iniection Proiect /10-413)
10-412 Reservoir Pressure Reoort /10-412)
10-417 Notice of Chance of Ownership /10-417)
10-421
Gas Well Open Flow Potential Tests Report /10-421)
10-422
Facility Report of Produced Gas Disposition /10-422)
10-423 Report of Annular Disposal /10-423)
y~ yes
N:; no
S == Sometimes
.
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Conservation Order Variances for 25.280(a) V
Routine Sundry Activities that require Follow-up Reports
~- NoN G tfD :;;
10-403 Not Required -10-404 Report Not Routine Sundry Operations - No 403 ; Sundry Operations -403 and
Required 10-404 or 407 Report Required ' 10-404 or 407 Report Required
Wireline Operations Wireline Operations
· F ill tag · Permanent cement or mechanical
· Set & pull retrievable plugs plugs that do not completely abandon
· Change GL V's a zone.
· Dummy & gauge ring runs
· Pull & rerun SSSV's Electric Line Operations
· Pressure surveys - unless required by · Permanent cement or mechanical
some specific approval plugs that do not completely abandon
· Temperature surveys - unless required a zone. \
Cutting off tailpipes, , c1 r" I{ "
by some specific approval · ,{l,{ (. (f'" '\ <l\~~
---
Electric Line Operations External to casing - Matrix Operations SPECIAL
· Spinner surveys · Fracture jobs
· Pressure & Temperature surveys - · Perforate new intervals In all cases where there is an unusual
unless required by some specific event, a sundry will be required if the
approval Commission requests it.
· Reperforating existing intervals
· Logs - CNL, TDT, CO, CCL, and
CBL? Others? - Unless required by
some specific approval
/fr;:
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Other - Inside tubing, casing
· Tubing scale removal
· Sludge removal
· Freeze protection
· Ice plug removal,
· Xmas tree & valve replacement
· Diagnostic & pressure testing - unless
required by some specific approval
Rig and Coil Tubing Operations
· Fill clean out
· Scale milling
· Tubing acid jobs
5cGh _'ItA. t~_&-,,)w·t...
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Internal to casing & tubing
· Injection well MIT .
· Convert from water to MI
· Convert from injector to producer
Rig and Coil Tubing Operations
· Alteration of mechanical completion
o Add perforations
o Squeezes or plugs to control
inflow
· Remedial cementing operations
o Casing shoes (outer annulus)
o Fill conductor
e kÚ.AA(é¡ Q lOt1~ß(f ~i~LitS \
t~7;J
----_."'~--~ !=,~~:~)
Internal to casing & tubing
· Convert producer to injection ~;tttT (" ¿;~l,
· Repair casing
:t.'ifad- ",Vi.
Rig and Coil Tubing Operations
· Alteration of mechanical
completion
o Squeezes or plugs to control
injection
· Remedial cementing operations
o Casing integrity repairs
(y r¿rJÄ r) li1<S'I, ",
o \/ &Jl,t)
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ConocoPhillips
BPXA
Marathon
Unocal
XTO
AOGCC
AOGA
.
.
ANTICIPATED ATTENDEES
AOGA/AOGCC WORKING GROUP MEETING
ON REPORTING REQUIREMENTS
1:30 p.m., Wednesday, May 19,2004
AOGA Conference Room
Barbara Fullmer
Jerome Eggemeyer
Harry Engel
Gary Laughlin
Steve Lambe
Bill M.iller
T om Maunder
Steve McMains
Jack Hartz
Theresa Rockhill
Sundry Waiver Summary
Listed below are the Conservation Orders that pertain to waiving the requirements of 20 AAC 25.280 to submit a sundry
application for workover operations. . ;. ,.
Order Effective Date Pool(s)
341 D (258) 9/12/90 Prudhoe Oil Pool
261 10/23/90 Kuparuk Oil Pool
297 7/27/92 Endicott Oil Pool
342 11/2/94 pt. Mcintyre, Lisburne, Stump Island
343 11/2/94 Niakuk Oil Pool
347 11/17/94 Schrader Bluff, Kuparuk Oil Pool
351 11/29/94 Unocal Operated Cook Inlet Fields
408 1/15/98 Marathon Operated Cook Inlet Fields--DENIED
.
The waivers are pool specific and the orders DO Not contain an administrative rule.
.
~
...
Change pro gram?
-+
Yes
404 Within 30 days
403 to resume
Valid for 1 year
Complete Well
1
Pmc1lJ(~er?
Injector?
MIT & CBL required
~
407
Within 30 days
Ongoing Requirements:
Monthly fluids report
6 month SV test (except WI)
Recurring MIT for inj ectors
SCP monitoring for all wells
5 year report for suspended
Waivered injector monthly report
Suspended
or Inj ector?
" P&A, Alter CasiI1g~SCJ?', ',"
6~~~~~ti:d~!~J;~~~~, ..
','" Ç?ariging, çompletioh4J.terya.J ,.
..,", ,," or·,'..,:,: ,
. . , . ., .' ..'
'...' :UNUSUAiEVENT?" ,
-.
~1
~Ir
403
T
Sundry
waIver III
p lace*
-.
CfJ
~
..~~~:~~?~~~:
404 or 407
within 30 days
04
4
within 30 days If well is not
abandoned
. 1
.... ~
Version III-May 7, 2004
*Certain pools within the state have been exempted rrom the requirement to submit a sundry in advance of work over
operations as defined in 20 AAC 25.080(a).
.
.
AOGCC Permitting Forms
10-401: Application for Permit to Drill for new drilling, redrilling, reentry, and lateral operations.
Requires Form 10-407 to close.
10-403: Application for Sundry Approval for all well operations not covered by Form 10-401.
Requires Form 10-404 or Form 10-407 to close, except for certain variances.
10-404: Report of Sundry Well Operations for workovers, operation shutdowns, stimulations,
etc. Closes Form 10-403 when completion interval is unchanged.
10-407: Well Completion or Recompletion Report and Log to close Form 10-401 when well is
completed or recompleted, and to close Form 10-403 when completion interval is
changed or well is suspended or plugged and abandoned.
Application for Permit to Drill
Form 10-401
Application for Sundry Approval
Form 10-403
Change Program
After Spud
Change Program
Before Spud
UIC V3rianee kLD.;".
Form 10-404
No Form Required
Form 10-403 to restart
Form 10-407
Note: All incoming forms (401 ,403,404,407) should be processed promptly.
.
.
20 AAC 25.280
WORKOVER OPERATIONS.
(a) An Applicatio"n for Sundry Approvals (Form 10-403) must be submitted to and
approved by the commission in order to enter a well and conduct one or more of the
following types of well workover operations:
(1) the perforation or reperforation of casing;
(2) stimulation;
(3) the pulling of tubing;
(4) alteration of the casing;
(5) repairs to the well. _
(b) The Application for Sundry Approvals must set out
(1) the current condition of the well;
(2) a copy of the proposed program for well work;
(3) unless already on file with the commission, a diagram and description
of the well control equipment to be used, including if applicable a list of the
blowout prevention equipment (BOPE) with specifications;
(4) a description of any wellbore fluid to be used for primary well control;
and
(5) the current bottom-hole pressure, or, if data setting out the actual
pressure are not available, an estimate of the current bottom-hole pressure.
, (c) The operator shall keep records and reports of well workover operations,
including BOPE test results, in confonnance with the requirements of 20 AAC 25.070
(1).
(d) The operator shall file with the commission, within 30 days after completion of
workover operations, on a Report of Sundry Well Operations (Form 10-404), a complete
record of the work performed and the tests conducted, and a summary of daily well
operations as described in 20 AAC 25.070 (3). Upon request, the operator shall file with
the commission a copy of the daily record required by 20 AAC 25.070(1).
(e) Upon application, the commission will, in its discretion, waive the
requirements of this section for wells in a pool for which pool rules have been prescribed
under 20 AAC 25.520.
History: Eff. 4/2/86, Register 97; am 11/7/99, Register 152
Authority: AS 31.05.030
Subject: Re: Sundry Waivers, Pótent.ork Schedule and Sundry Expiration .
From: John Hartz<jack_hartZ:@admin.state.ak.us>
Date: Mon, 22 Mar 2004 10:43:28 ~0900
Tj}: Dan Seamount <dan~seam.Ount@admin.state.ak.us> ',', ,', ",'," '," , " , "
çe: Thomas Maunder <tom ..,:maµnder@admiIi.state.ak.us>; Steve, Davies <steve:..:dilvies@admin.state.ak.us>, Bob' CrandaU
<bob ~cråndalI@admi,n,state~ak.us> ,Jane',Williamson <jane _wiHiamson@admin'.state.ablS>, Jim Regg
<jim Jegg@admin.stå:te.åk~us>; ;Winton,GAµbert<WÌriton _aubert@admin.state.ak.us>, John K Norman
<john _nonnan@adm.irdtatê~*ll?,~()GCCNorth Slope Office '<aogcc yrudftoe_ bay@admin.state.ak.us>, Bob' Fleckenstein
<bob _ fleckensteiri@adIDm.stäte.akuS>,SteveMcMäins <:Steve _mcmains@admin.state.ak.uS>, Howard Okland '
<howard _ okland@admiri.state.ak.us>; RobMiIitz <Robert _ Mintz@law.state.ak.w;>, '
In addition to the comments of 3/17 and 3/18 on the issue of Conservation Orders that provide for variances to Applications for
Sundry approvals (20AAC 25.280) --
I. The expamples that Tom probably showed of "anticipated work list" are not very helpful at all and never have been
because we never know if some, any or all of the anticipated work is actually done.
2. The first variance orders were issued to PBV in Sept. 1990 and Kuparuk River Field (MPV and KRV) in Nov. 1994.
3. There is currentlv no way to know if we get the information about work done within 30 days of completion.
4. Followup reports of Sundry work that has been done results in one of the following:
a.) it is reported on 10-404 within 30 days
b.) it is reported on a 10-404 within _? months or _? years
c.) a 10-404 is never submitted.
d.) ... none of the above
e.) there is not a good way to ensure compliance with the 10-404 reporting of non-permitted work that is
done
4. Changing the CO's, which provide variances from 20 AAC 25.280 permitting regs, to require a list of "routine well
work accomplished during the reporting period" will provide the following advantages:
a.) The AOGCC and Inspectors will have an accurate reference of field work done with and without rig
involvement.
b.) There will be a way to check compliance with the 10-404 report requirements.
c.) The accuracy of AOGCC well files should improve by documenting in a timely manner the changes
that have occurred to well configurations - mechanical completion, perforations, packers set, new
jewelry, tubing or casing patches and the other sundry items covered in 20 AAC 25.280.
d.) The operators will not waste time compiling lists of work they might do or anticipated activity.
In summary, there is no good reason to keep recieving lists of "anticipated work". There are a number of very good reasons to
change the practice to report a list of work done in the recent past. The current practice wastes the AOGCC's time and the operators
time. Changing the CO's to require a listing of "field work done" will provide a useful compliance tool, ensure timely information
flow and improve accuracy of AOGCC well files all of which will soon be available to the general public over the web. A new
hindcast listing requirement should reduce the operators efforts by not requiring reporting potential events that may never take
place.
Recommendation:
Modify all CO's providing variances from Sundry Application requirement to require a routine filing offield work finished during a
prior period and recind the requirement to report anticipated work. Should we stay with the current requirements, then AOGCC
will need to draft an appropriate disclaimer to ensure the public is aware of the shortcomings of the information available in our
well files.
Jack
»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»»
Dan Seamount wrote:
"and whether we need to change to a summary of work done I 5 days after completion or just wait for the report after 30 days."
Simply put: Regarding the "anticipated work list", all I requested was to find out if anyone can think of a reason to continue to
receive it since it appears that no one looks at it and we get the information about work done within 30 days of completion
anyway.
dan
of2
5119/2004 I :06 PM
.
.
Thomas Maunder wrote:
All,
In the Wednesday public meetings of March 3 and March 17 the subject of sundry waivers has been discussed. It appears that
the Commissioners are in favor of moving forward with modifications with regard to the operations waived, the weekly
"anticipated work list" that BP and CPAI provide and how long an approved sundry should be valid (sundry expiration). Your
comments with regard to these issues are requested. It is planned to be in a position to present a proposal to the
Commissioners at the public meeting on March 31.
I have attached the two most recent documents I have on these issues. As is noted in the attachments, there are a number of
COs that contain the waiver. They are pool specific and not all pools in a given field/unit are covered. None of the orders has
an administrative clause. If we are going to do a change, each order will have to be changed. However, since the wording in
most cases is similar Rob feels that the issue can be handled with a consolidated notice and hearing.
Please provide comments on any and all issues. I will consolidate and then distribute for finalization.
Comments I am aware of with regard to the issues are:
1. Operations waived. In all the "Waiver COs", a sundry notice has been waived for the 5 listed operations in 25.280(a).
Following are various discussion points that I am aware of with regard to this issue.
It has been recommend the (a)(4) "alteration of the casing" not be waived.
Jack feels that if perforating is planned "out of pool" (eg Aurora or Polaris where Kuparuk/Ivishak/Schrader Bluff/Ugnu may
exist in the same well bore), then a sundry would should be required.
Jim feels that if a workover is planned in a well with a packer that a sundry should be required.
I feel that any well that has been reported to the Commission in accordance with the Sustained Casing Pressure COs should
also require a sundry.
Is it appropriate to consider extending the "limited waiver list" to other pools?? As an example Prudhoe Pool has the
exemption, but Midnight Sun, Polaris, Aurora and Orion don't. Kuparuk Pool has the exemption, but West Sak, Tam,
Tobasco and Meltwater don't. Alpine doesn't have a waiver. Northstar doesn't have a waiver and given its location
(offshore/isolated), I would not recommend a waiver be given. Maybe Alpine shouldn't get a waiver for the same reason.
2. Weekly "anticipated work list". We get weekly lists from CPAI and BP. Of the two, my opinion is that BP's is the best
since it gives only the work that might be done in a given week. BP's list is in contrast to CP AI's that includes the "universe"
of all potential jobs they have on their schedule. In the latest discussion in the public meeting Dan questioned if 404's would
be received on the operations when performed (yes) and if that was the case was any notice (planned or done) worthwhile?
I hope Bob and Steve contribute to this portion of the discussion as I understand one of your "complaints" has been that you
have no way of knowing what work has been done to know what reports to expect. Are the reports we presently get,
regardless of format, of any use?? Would a report of "what work was completed" (in the last week) be of any use??
3. Sundry Expiration: The regulations provide for the expiration of a drilling permit 2 years after it was issued. There is no
similar time limit on sundries. The attached document proposes a new section in the regulations applying the same 2 year
time limit.
Is 2 years too long?? I would tend to think that a I year period might be more appropriate.
Thanks,
Tom
2 of2
5119/2004 I :06 PM
Subject: Re:040604-SUndry_ar .
From: Rob Mintz <robert_mintz@law.state.ak.us>
Date: Thu, 08 Apr 200416:51 :48 -0800
To: t~11l_maunder@a(.hnllLstate;ak.us ,
CC:dan _ seamount@admiIl.state.ak.us, jack ~ hartz@admin.state~ak. us,
john_Jionrian@admin.state.ak. us~ steve _ davies@admin.state.ak.us",
Tom, here is the letter with my suggested revisions.
»> Thomas Maunder <tom_maunder@admin.state.ak.us> 4/7/2004 4:13:55 PM »>
If(a)(5) is designed to be the catch-all, then you are correct that (d) is limited just to the 5 "tasks" listed in (a). Trying to list
every repair/remediation task that could be considered a workover would be a difficult task. The 5 enumerated in the reg are
both specific and general, (a)(5) is particularly general.
Nearly all the conservation orders specifically mention that reports (404s) must be submitted. The exemptions were for (a)
and in some cases (b), but no where have I seen (d) exempted.
Jack, Steve and I have done some editing on the letter I provided yesterday, a copy is enclosed. I also have been working on
editing CO 342 with what I believe the new rules should be. It is still a work in progress, but I am including a copy as well
as a potential notice.
Tom
Rob Mintz wrote:
I think I understand better now why there might be confusion on the part of operators as to their obligation to file a
Form 10-404 after workover operations in pools that have an exemption ITom 20 AAC 25.280(a). The latter subsection
requires a Form 10-403 before conducting one of five enumerated "types of well workover operations." Subsection (d),
on the other hand, simply says that an operator shall file a Form I OA04 "within 30 days after completion of work over
operations" - it is not expressly limited to the five types enumerated in subs~ction (a).
Presumably subsection (d) doesn't really require a Form 10-404 after each and every workover operation, but only after
one of the types listed in subsection (a). (Or am I wrong about this?) If that's the case, then it is not a very long leap ITom
inferring that subsection (d) only applies to items listed in subsection (a), to inferring that the requirement of subsection
(d) is only triggered after subsection (a) is triggered. And subsection (a) is not triggered when the pool has an exemption
in its pool rules.
Maybe sometime subsec. (d) should be amended to clarify its application.
»> Thomas Maunder ::':~º..æ.._!p.<runli~!:r,qi<l.~:JJ;:t?jl}.?!':l.!::::_ª1.<..:~!§..::: 4/6/2004 4:46:32 PM »>
All,
Enclosed is a proposed draft of a letter with regard to the sundry
waiver. The basis of the letter is a document that Jim mostly authored
in January. At this time a letter provides the "quickest" option with
regard to notifying the operators of this issue. According to my
review, all the applicable Conservation Orders do not have
administrative clauses so a notice and possible hearing are needed to
effect the changes. I am sending this message and document to allow
examination of the document prior to the "public meeting".
There are multiple reasons to make these proposes changes. There are
different requirements out there for the waivers and it appears that
beginning in 1994 the need for keeping sundries for injection wells was
noted and all orders since then have been consistent in that regard.
The "recent" orders have also required the submission of reports and the
"planned work list". To varying degrees, the operators have complied
with the requirements although compliance varies.
There is a need to change the orders due to the development of the
sustained casing pressure rules. Exempting workover operations that
lof2
5119/2004 I :06 PM
"alter the casing" should not be ""..
It is possible that waivers could be "offered" to other pools (West Sak,
Tam, Tobasco, Aurora, Borealis, etc). Sort of a carrot and stick. It
is also possible that the waiver for Unocal should be revoked since one
of the reasons for granting it in the first place was "numerous similar"
operations and they presently are not doing much work.
If it is determined that sending this letter is not the desired way
forward, I will move to timely draft the notices for the Order changes.
Tom Maunder
.
Content-Type: applicationlmsword
040604-sundry _letter rem. doc
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20f2
5/19/20041:06 PM
Snbject: 040507-rcport flOW' III. doc ·
From: Thomas Maunâer <tom ~maunder@admin.state.ak. us>
Date: Fri, 07 ]\t[ay200411:08:52 -0800, " "
To: Steve McMains<:steve_JI:l:cmaîns@admin.state.ak.us>, Jim~egg <jiÏnJegg@adrrrinstate~ak.us>,
Winton G Aubert-<winton _aubert@admin.state.ak, us>, John D Hartz· "
<jack _hartz@ádmin.statè~,ak:. tis>, BohFleckenstein <bob _ fleckenstein@admin.state.ak:. us>
Attached is a "report flow" form/chart I have put together for permitting and
reporting well operations. It incorporates some of the information Winton had
prepared a while back. A meeting with AOGA had been set for yesterday, but was
canceled.
In the sundry side of the process, I show a block that lists out what operations
would require a sundry. This is what I proposes for pools that have the sundry
exemption conservation order. As the exemption is presently structured, the 5
workover activities listed in 25.080(a) do not require sundries. Under the current
situation, we would only see sundries on P&As and conversions to injectors. I am
proposing that be changed to include alteration of casing, wells reported under the
SCP orders, wells operating under a sundry approval (failed ESPs operating under
gas lift) and "Unusual Events". In the case of an unusual event (eg A-22), any
exemption order would have a rule that the Commission could require a sundry at
their discretion.
Further down in that flow, I have a box that requiring weekly reporting of what has
been done. This is the change of the present situation where the anticipated work
list is provided.
With regard to the pools that have sundry exemptions. I would propose that several
pools be added to the exemption list or that we change the orders to make them
field specific. Exemptions would be for development producers only. Milne's order
covers the multiple pools in that field, while the Kuparuk order is only for the
Kuparuk Pool. I would propose that the remaining pools at Kuparuk be included
under the exemption with maybe the exception of Meltwater. I would propose that
the western pools at Prudhoe also be exempted from the sundry requirement. I would
not propose to exempt North Star. It is possible that CPAI would want to exempt
Alpine, but we will have to see about that. Alpine differs from North Star in that
they do have a rig out there and likely other intervention equipment. In short,
they can do work in a timely manner, while for North Star it could be a major
logistics operation just to get the proper equipment out there. Also, one of the
basis for granting the sundry exemption is that the operations are routinely
performed. I don't think that North Star qualifies in that regard. This also
brings up Unocal's exemption in Cook Inlet. I don't think the term routine applies
here either and I would propose that their exemption be revoked.
I look forward to your thoughts.
Tom
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~~~
Suspended
or Injector?
P&A, Alter Casing, SCP,
Conversion to Injector,
Operating under a waiver,
Changing completion interval
or
UNUSUAL EVENT?
-~1
403
Yes
404 Within 30 days
403 to resume
Valid for 1 year
T
Sundry
waiver III
place*
~
Complete Well
1
~
~
Procillcer?
Injector?
MIT & CBL required
Weekly report of
operations completed.
404 or 407
within 30 days
~
r
407
Within 30 days
within 30 days If well is not
abandoned
... 1
~ ,
~
404
Ongoing Requirements:
Monthly fluids report
6 month SV test (except WI)
Recurring MIT for inj ectors
SCP monitoring for all wells
5 year report for suspended
Waivered injector monthly report
Version III-May 7,2004
*Certain pools within the state have been exempted from the requirement to submit a sundry in advance of work over
operations as defined in 20 AAC 25.080(a).
01' ~D GAS CONSERVATION COM".ION
. 3001 Porcupine Drive
Anchorage, Alaska 99501-3192
Re:AOGCC motion to amend Conservation Order 341B,
revoking rule 10 relating to facility gas flaring
from the Prudhoe Oil Pool.
Conservation Order No. 341C
Prudhoe Bay Field
Prudhoe Oil Pool
June 12, 1997
:T APPEARING THAT:
1. By its own motion, the Alaska Oil and Gas Conservation Commission issued public notice of its intention
to amend Conservation Order 341 B by revoking Rule 10, Facility Gas Flaring. The Commission considers
this action necessary because new gas disposition regulations became effective on January 1, 1995 and
functionally revoked all previously issued conservation orders relating to facility flaring. Subsequent
revisions to Conservation Order 341 inadvertently retained an out-of-date rule describing approved flare
volumes for Prudhoe Bay facilities.
2. Notice of opportunity for public hearing was published March 29, 1997. No protest were received.
Findings:
1. Previously issued conservation orders for the Prudhoe Bay Field describing facility flaring are:
a. Conservation Order 145A which established reporting requirements for flaring events as well as
procedures to be taken to minimize waste. The rule also limited flaring during a single event to a
twelve hour period before Commission approval must be obtained.
b. Conservation Order 197 which prohibited the flaring or venting of gas except as authorized by the
Commission in cases of emergency or operational necessity. This rule also allowed operators the
chance to apply for Commission approval to permit well testing in areas of the pool where access to
pool gas gathering facilities was not prudent.
c. Conservation Order 219, Rule 1 which established daily flaring rates for specific facilities to maintain
safety flares and allow purging of gas handling equipment.
2. The Commission consolidated the aforementioned rules relating to facility flaring, along with other rules
previously approved for the Prudhoe Oil Pool, in Conservation Orders 341 (consolidated), dated October
2,1994. Rule 10, Facility Gas Flaring, of Conservation Order 341 was carried forward unchanged as Rule
10 of Conservation Order 341A (amended Oct. 2, 1995) and as Rule 10 of Conservation Order 341 B
(amended Nov. 17, 1995).
3. The Commission established new gas disposition regulations, 11 AAC 25.235, effective January 1, 1995
to cover flaring events at oil and gas production facilities statewide. The gas disposition regulations
functionally revoked all previously issued flaring rules detailed in conservation orders issued prior to
January 1, 1995.
Conclusions:
1. Rules dealing with facility gas flaring under Conservation Orders 145A, 197, and 219 were revoked by 11
MC 25.235 on January 1, 1995, as was Rule 10 of Conservation Order 341.
2. Incorporating Rule 10 of Conservation Order 341 in subsequent amendments to that order (i.e. CO 341 A
and CO 341 B) was in error.
3. Revoking Rule 10 of Conservation Order 341 B will not promote waste, harm ultimate recovery nor
inted for Theresa Rockhill <rockhil(â)Dobox.alaska.net>
5/18/0
IVL....,
r. 12N., R.
11 E..
. .
1S, 16, 17, 18, 19,20,21,22, 2S, 26, 27, 28, 29,
30, 32, 33, 34, 3S, 36
r. 12N., R.
12E.,
23,24,25,26,27,28,29,30,31,32,33,34,35,
36
r. 12N., R.
13E.,
19,20,21,22,23,26,27,28,29,30,31,32,33,
34,3S,36
T. 12N., R.
14E.,
2S,26, 27, 28,29,31, 32,33,34, 3S, 36
T. 12N., R.
1SE.,
2S,26,27,28,29, 30,31,32.33,34,35,36
Source: C. O. 145, page 7, expansions/contractions of initial participating area based on November 20, 1987
!tter, Wade and Nelson to Eason, Re: Prudhoe Bay Unit Exhibits, Exhibit C, Part I Oil Rim Participating Area
nd Part 'I Gas Cap Participating Area.)
ule ,1' Pool Oefin ition and Chang ing the Affected Area( ref. C. O. 145)
I) The Prudhoe Oil Pool is defined as the accumulations of oil that are common to and which correlate with the
~cumulations found in the Atlantic Richfield - Humble Prudhoe Bay State No. 1 well between the depths of
.110 feet and 8,680 feet.
)ource: C.O. 145, Rule 1)
I) The Commission may adjust the description of the affected area to conform to future changes in the initial
~rticipating area by administrative approval.
¡ource: C. O. 145, Rule 12)
ule 2 Well Spacing (ref. C.O. 145, 174)
1ere shall be no restrictions as to well spacing except that no pay shall be opened in a well closer than SOO
et to the boundary of the affected area.
·ource: C.O. 174, Rule 2)
Jle 3 Casing and Cementing Requirements (ref. C.O. 14S, 238)
) Conductor casing shall be set at least 75 feet below the surface and sufficient cement shall be used to fill tho
nulus behind the pipe to the surface. Rigid high density polyurethane foam may be used as an alternate to
ment, upon approval by the Commission. The Commission may also administratively åpprove other sealing
~terials upon application and presentation of data which show the alternate is appropriate based on accepted
gineering principles. (Source: C.O. 238, Rule 3a)
ntprl fnr Tnprp<;:~ Ro('khil1 <ro('khilrmnnncw ::.h<::k::. npt>
';;/1 R/r,
,_ . _, ~-t"-~''''' ..... 1"'.... ."', "" '=r ""lvVIILI UII<;;U IIUVV uy ;:)IIUlLlIIY VII IIVW ê::Illf It::: wellneaa ana snuITlng aown any
artificial lift system where an over· .ure of equipment may occur. .
(b) The safety valve system (SVS) shall not be deactivated except during repairs, while engaged in active well
Nork, or if the pad is manned. If the SVS cannot be returned to service within 24 hours, the well must be shut ir
:It the well head and at the manifold building.
1. Wells with a deactivated SVS shall be identified by a sign on the wellhead stating that the SVS has
been deactivated and the date it was deactivated.
2. A list of wells with the SVS deactivated, the dates and reasons for deactivating, and the estimated re-
activation dates must be maintained current and available for Commission inspection on request.
c) A representative of the Commission will witness operation and performance tests at intervals and times as
Irescribed by the Commission to confirm that the SVS is in proper working condition.
j) The SVSSafety valve systems must be maintained in working condition at all times unless the well is shut in
nd secured, or the well is being operated in conformance with other sections of this rule.
~) Upon proper application or its own motion, the Commission may administratively waive or amend the
:!quirements of this rule as long as the change does not promote waste, jeopardize correlative rights or
ompromise ultimate recovery, and is based on sound engineering principles.
) Nothing in this rule precludes the installation of a SSSV in wells designated by the operator. If a SSSV is
Istalled, it must be maintained in working order and is subject to performance testing as part of the SVS.
ule 6 Pressure Surveys (ref. C.O. 145, 165,192,208,213,220, AA 220.1,3418)
I) Prior to regular production, a static bottom hole or transient pressure survey shall be taken on at least one ir
ree wells drilled from a common drilling site.
;ource: C.O. 220, RuJe 1, C.O. 3418)
) An annual pressure surveillance plan shall be submitted to the Commission in conjunction with the Annual
-udhoe Pool Reservoir Surveillance Report by April 1, each year. The plan will contain the number of pressure
Irveys anticipated for the next calendar year and be subject to approval by the Commission by May 1. These
Irveys are needed to effectively monitor reservoir pressure in the Prudhoe Oil Pool. The surveys required in
) of this rule may be used to fulfill the minimum requirements.
ource: C.O. 220, Rule 6, C.O. 3418)
) Data from the surveys required in (a) and (b) of this rule shall be filed with the Commission by the last day 01
9 month following the month in which each survey is taken. Form 10-412. Reservoir Pressure Report, shall be
ed to report the data from these surveys. Data submitted shall include rate, pressure, time, depths,
nperature and any well condition necessary for the complete analysis of each survey. The datum for the
9ssure surveys is 8800 feet subsea. Transient pressure surveys obtained by a shut in buildup test, an
ection well pressure fall-off test, a multi-rate test or an interference test are acceptable. Other quantitative
~thods may be administratively approved by the Commission.
:)Urce: C.O. 220, Rule 7)
Results and data from any special reservoir pressure monitoring techniques, tests, or surveys shall also be
:>mitted as prescribed in (c) of this rule
)urce: C.O. 220, Rule 8)
By administrative approval the Commission may grant time extensions and waive requirements of this rule,
~tPrl for Thprf"<;:~ RoC'k-hill <r"C'k-hilrmn"hoy ~1~<;:k-~ nf"t>
,,/1 RIO
... _ ... ...,.__, '-"-..'.'w _.._ __........_.._.. _. - ._.~- ~....... ........,....... 1-"1-'.....11....., ..,,-, Q'lIlUa, aV....,CI~C VIIlC:U\,C Idlt:: IUI Yd:S :sna
be determined by dividing the total ~me of gas produced in the caler' .. year by the number of days
remaining in the year following init.~livery to the large gas sales pip~. .
Rule 10 Facility Gas Flaring revoked(ref. C. O. 341 C)
Rule 11 Annual Surveillance Reporting (ref. C.O. 165, 186, 195, 208,223, 224,279, AA 279.1)
(a) An annual Prudhoe Oil Pool surveillance report will be required by April 1 of each year. The report shall
include but is not limited to the following:
1. Progress of enhanced recovery project(s) implementation and reservoir management summary
including engineering and geotechnical parameters.
2. Voidage balance by month of produced fluids, oil, water and gas, and injected fluids, gas, water, low
molecular weight hydrocarbons, and any other injected substances (which can be filed in lieu of monthly
Forms 10-413 for each EOR project). (Source C.O. 279, Rule 7 and AA 279.1 excerpt from paragraph 3)
3. Analysis of reservoir pressure surveys within the field.
4. Results and where appropriate, analysis of production logging surveys, tracer surveys and observation
well surveys.
5.Results of gas movement and gas-oil contact surveillance efforts including a summary of wells surveyec
and analysis of gas movement within the reservoir. The analysis shall include map(s) and/or tables
showing the locations of various documented gas movement mechanisms as appropriate.
(Source: C.O. 279, Rule 7)
J) Upon its own motion or upon written request, the Commission may administratively amend this rule so long
s the change does not promote waste nor jeopardize correlative rights and is based on sound engineering
rinciples.
)ource: C.O. 279, Rule 8)
.ute 12 Prudhoe Bay Miscible Gas Project (PBMGP) (ref. C.O. 195,290)
I) Expansion of the PBMGP and infill expansion of miscible gas injection in the NWFB is approved for the
3,740 acre portion of the Prudhoe Oil Pool defined in the record. (Source: C.O. 290, Rule 1, AA 290.1)
I) An annual report must be submitted to the Commission detailing performance of the PBMGP and outlining
)mpositionat information for the current miscible injectant (MI) necessary to maintain miscib'ïlity under
lticipated reservoir conditions. (Source: C.O. 290, Rule 2)
) The operator will maintain a pressure differential of at least 250 psi between the minimum miscibility
'essure (MMP) of the MI and the prevailing reservoir pressure at the time of injection. This differential is based
1 a projected prevailing reservoir pressure decline of no more than 30 psi/year over the life of the project.
tource: C.O. 290, Rule 4)
) The operators are directed to continue investigating options to mitigate pressure decline and to provide an
Inual progress report to the Commission.
ource: C.O. 290, Rule 5)
) Upon its own motion or upon written request, the Commission may amend this rule by administrative action
:he change does not promote waste, violate correlative rights, nor jeopardize ultimate recovery, and is based
intf"n fm Tni"ri"<:::! R()('khil1 <rnr.k-hl1((])nonm( ¡¡h"k-~ npt> S/1 RIO
.
". .....,_."..~._....
J UQ':)~ ~Il (.X \Jcß LUIl~eIVallOn ,-,OmnllSSIOn
.
FORMS CATALOG
The AOGCC has revised the following forms, and made them available on this web site. As other
forms are revised, they will be posted here, If you do not see the form you need, please contact the
AOGCC directly at
333 W 7th Ave, Ste. 100
Anchorage, AK 99501
(907) 279-1433
Please be aware of the following updates:
1. All forms are available in pdf format and are intended for printing -- NOT FOR ELECTRONIC
SUBMISSION. Select forms are also available in Excel format.
2. API numbers should be completed as a 14-digit number (Ex: 50-123-12345-00-00),
3. Be aware that some information locations have changed.
4. Instructions are available on the last page of selected forms.
5. Certain forms may no longer be required in multiple submittals. Please look in the lower right
hand corner to determine the current number of submittals required
6. Submit a well schematic diagram with each 10-407 well completion report and 10-404 well sundry
report when the downhole well design is changed
7. Forms with a revision date prior to January 1 2003 will not be accepted.
For best results, use a recent version of Adobe Acrobat or Reader to view these files.
Need help viewing pdf files? Click Here.
Form Name and Number
Permit to Drill (10-401 )
Surety Bond (1 0-402A)
Personal Bond (10-402B)
Application for Sundry Approvals (10-403)'
Annular Disposal Application (10-403AD)/
Report of Sundry Well Operations (10-404)/
Monthly Production Report (10-405)
Monthly I njection Report (10-406)
Well Completion or Recompletion Report and Log (10-407)-
Well Status Report and Gas-Oil Ratio Tests (10-409)
Designation of Operator (10-411)
Reservoir Pressure Report (10-412)
Report of I njection Project (10-413)
Notice of Change of Ownership (10-417)
Gas Well Open Flow Potential Tests Report (10-421)
Facility Report of Produced Gas Disposition (10-422)
Facility Codes for 10-422
Report of Annular Disposal (10-423) /
Format
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
PDF Excel
No. of Pages
1
2
2
1
2
1
2
2
2
2
1
2
1
1
2
2
2
Revised
12/2003
10/2003
10/2003
12/2003
9/2003
04/2004
12/2003
12/2003
12/2003
12/2003
10/2003
9/2003
12/2003
10/2003
1/2004
4/2004
4/2004
2/2004
Thank you to ConocoPhillips and Marathon for kindly donating Excel versions for some of these forms.
'.r...·...__...._.....__"'__..·~_.~~·"..·_.._,···,,__·_~
If you have any suggestions regarding this page and the forms linked to it, please contact the Webmaster
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._..,_.~-"',._--....-..""-..",'..,.'".. ..~_..,
,tpn for The:re:~H Rockhill <rockhil((i)nohox.alaska.net>
5/4/0
ALASKA OIL AND GAS CONSERVATION COMMISSION
. PERMIT TO DRILL .
20 AAC 25.005
1a. Type of Work: Drill o Redrill U ; b. Current Well Class: Exploratory 0 Development Oil 0 Multiple Zone 0
Re-entry 0 Stratigraphic Test 0 Service 0 Development Gas 0 Single Zone 0
2. Operator Name: 5. Bond: Blanket U Single Well 0 11. Well Name and Number:
Bond No.
3. Address: 6. Proposed Depth: 12. Field/Pool(s):
MD: TVD:
4a. Location of Well (Governmental Section): 7. Property Designation:
Surface:
Top of Productive Horizon: 8. Land Use Permit: 13. Approximate Spud Date:
Total Depth: 9, Acres in Property: 14. Distance to Nearest
Property:
4b. Location of Well (State Base Plane Coordinates): 10. KB Elevation 15. Distance to Nearest Well
Surface:x- y- Zone- (Height above GL): feet Within Pool:
16. Deviated wells: Kickoff depth: feet 17. Maximum Anticipated Pressures in psig (see 20 AAC 25.035)
Maximum Hole Angle: degrees Downhole: Surface:
18. Casing Program: Specifications Setting Depth Quantity of Cement
Size Top Bottom c.f. or sacks
Hole Casing Weight Grade Coupling Length MD TVD MD TVD (including stage data)
19. PRESENT WELL CONDITION SUMMARY (To be completed for Redrill and Re-Entry Operations)
Total Depth MD (ft): Total Depth TVD (ft): Plugs (measured): Effect. Depth MD (ft): Effect. Depth TVD (ft): Junk (measured):
Casing Length Size Cement Volume MD TVD
Structural
Conductor
Surface
Interm~diate
Production
Liner
Perforation Depth MD (ft): Perforation Depth TVD (ft):
20. Attachments: Filing Fee U BOP Sketch U Drilling Program U Time v. Depth Plot U Shallow Hazard Analysis U
Property Plat 0 Diverter Sketch 0 Seabed Report 0 Drilling Fluid Program 0 20 AAC 25.050 requirements 0
21. Verbal Approval: Commission Representative: Date
22. I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact
Printed Name Title
Signature Phone Date
Commission Use Only
Permit to Drill API Number: Permit Approval I ~ee cover letter for other
Number: 50- Date: requirements.
Conditions of approval :
Samples required Yes 0 No 0 Mud log required Yes 0 No 0
Hydrogen sulfide measures Yes 0 No 0 Directional survey required Yes 0 No 0
Other:
BY ORDER OF
Approved by: THE COMMISSION Date:
Form 10-401 Revised 12/2003
Submit inDuplicate
.
STATE OF ALASKA
ALASKA OIL AND GAS CONSER V A nON CO.MMISSION
SURETY BOND
BOND NUMBER
PENAL SUM $
KNOW ALL PERSONS BY THESE PRESENTS,
That we,
of the City of State of
as principal, and
of ,as surety, an authorized insurer under AS 21. 09
whose certificate of authority is in good standing, are held firmly bound unto the Alaska Oil and Gas
Conservation Commission in the penal sum as indicated above, lawful money of the United States of
America, for which payment, well and truly to be made, we bind ourselves and each of us, and each
of our heirs, executors, administrators, successors, and assigns, jointly and severally, firmly by these
presents.
WHEREAS the above bounden principal proposes to engage in the drilling or operating of a well or
wells subject to regulation by the Alaska Oil and Gas Conservation Commission at a location
described as follows:
o
SINGLE WELL BOND
- minimum penal sum $100,000 (except as otherwise
allowed by the Commission under 20 AAC 25.025(b))
Unit or Lease Name
Well Number
Area of State
Surface Well Location - Sec., Twp., Rng. and Mer.
Surface Well Location - Alaska State Plane Coordinate System coordinates
o BLANKET BOND
- minimum penal sum $200,000
Any and all wells drilled or operated by the principal in the State of Alaska.
NOW, THEREFORE, the above bounden principal shall comply with all of the provisions of the
laws of the State of Alaska and the regulations, rules, and orders of the Alaska Oil and Gas
Conservation Commission in the drilling, operation, maintenance, repair, and abandonment of each
well and the clearance of each location, and shall file with the Alaska Oil and Gas Conservation
Commission all notices and records required by said Commission.
Form 10-402A Rev. 10/2003
Page 1 of2
Submit in Duplicate
.
BOND NUMBER
(continued) PENAL SUM $
This obligation shall remain in full force and effect until released by the Alaska Oil and Gas
Conservation Commission at the request of principal or surety.
Witness our hand and seal this
day of
Principal
By:
Signature
Printed name and title
Witness our hand and seal this
day of
Surety
By:
Signature
Printed name and title
Countersigned
(Resident Agent if necessary)
Official Use Only Below Line
ALASKA OIL AND GAS CONSERV A nON COMMISSION
Approved:
Commissioner
Date
Approved:
Commissioner
Date
Approved:
Commissioner
Date
(Requires approval by two Commissioners)
Form 10-402A Rev. 10/2003
Page 2 of 2
Submit in Duplicate
STATE OF ALASKA
ALAS.. eL AND GAS CONSER VA nON <:.- eISSION
PERSONAL BOND
BOND NUMBER
PENAL SUM $
KNOW ALL PERSONS BY THESE PRESENTS,
That we,
of the City of State of
as operator, is held firmly bound unto the Alaska Oil and Gas Conservation Commission in the penal
sum as indicated above, lawful money of the United States of America, for which payment, well and
truly to be made, the operator binds itself and its heirs, executors, administrators, successors, and
assigns, firmly by these presents. The operator's performance under this bond is guaranteed by the
following security, the disposition of which shall be solely determined by the Alaska Oil and Gas
Conservation Commission until released by said Commission.
D The attached Certificate of Deposit No.
Alaska Oil and Gas Conservation Commission by
a bank authorized to do business in the State of Alaska.
issued in sole favor of the
L! The attached Irrevocable Letter of Credit issued in sole favor of the Alaska Oil and Gas
Conservation Commission , a bank authorized to do
business in the State of Alaska.
D [Description of other approved security:]
WHEREAS the above bounden principal proposes to engage in the drilling or operating of a well or
wells subject to regulation by the Alaska Oil and Gas Conservation Commission at a location
described as follows:
D
SINGLE WELL BOND
- minimum penal sum $100,000 (except as otherwise
allowed by the Commission under 20 AAC 25.025(b))
Unit or Lease Name
Well Number
Area of State
.
Surface Well Location - Sec., Twp., Rng. and Mer.
Surface Well Location - Alaska State Plane Coordinate System coordinates
D BLANKET BOND
- minimum penal sum $200,000
Any and all wells drilled or operated by the principal in the State of Alaska.
BOND NUMBER
.
(continued) PENAL. $
NOW, TIffiREFORE, the above bounden operator shall comply with all of the provisions of the
laws of the State of Alaska and the regulations, rules, and orders of the Alaska Oil and Gas
Conservation Commission in the drilling, operation, maintenance, repair, and abandonment of
each well and the clearance of each location, and shall file with the Alaska Oil and Gas
Conservation Commission all notices and records required by said Commission.
This obligation shall remain in full force and effect until released by the Alaska Oil and Gas
Conservation Commission at the request of the operator.
Witness our hand and seal this
day of
Operator
By:
Signature
Printed name and title
ACKNOWLEDGEMENT
State of
Judicial District (or County of )
The foregoing instrument was acknowledged before me on this
, by (name)
(operator), on behalf of
day of
(title) of
(operator).
Notary Public in and for
My commission expires:
I Official Use Only Below Line I
ALASKA OIL AND GAS CONSER VA nON COMIvfISSION
Approved:
Commissioner
Date
Approved:
Commissioner
Date
Approved:
Commissioner
Date
(Requires approval by two Commissioners)
Form 10-4028 Rev. 10/2003
Page 2 of 2
Submit in Duplicate
ALASKA OIL AND GAS CONSERVATION COMMISSION
Af e::A TION FOR SUNDRY AF eV AL
20 MC 25.280
1. Type of Request Abandon U Suspend U Operational shutdown U Perforate U Waiver U Annular Dispos. U
Alter casing 0 Repair well 0 Plug Perforations 0 Stimulate 0 Time Extension 0 Other 0
Change approved program 0 Pull Tubing 0 Perforate New Pool 0 Re-enter Suspended Well 0
2. Operator Name: 4. Current Well Class: 5. Pennit to Drill Number:
Development 0 Exploratory 0
3. Address: Stratigraphic 0 Service 0 6. API Number:
7. KB Elevation (ft): 9. Well Name and Number:
8. Property Designation: 10. Field/Pools(s):
11. PRESENT WELL CONDITION SUMMARY
Total Depth MD (ft): /Total Depth TVD (ft): ¡Effective Depth MD (ft): Effective Depth TVD (ft): Plugs (measured): Junk (measured):
Casing Length Size MD TVD Burst Collapse
Structural
Conductor
Surface
Intermediate
Production
Liner
Perforation Depth MD (ft): I Perforation Depth NO (ft): Tubing Size: Tubing Grade: Tubing MD (ft):
Packers and SSSV Type: Packers and SSSV MD (ft):
12. Attachments: Description Summary of Proposal U 13. Well Class after proposed work:
Detailed Operations Program 0 BOP Sketch 0 Exploratory 0 Development 0 Service 0
14. Estimated Date for 15. Well Status after proposed work:
Commencing Operations: Oil 0 Gas 0 Plugged 0 Abandoned 0
16. Verbal Approval: Date: WAG 0 GINJ 0 WINJ 0 WDSPL 0
Commission Representative:
17. I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact
Printed Name Title
Signature Phone Date
COMMISSION USE ONLY
Conditions of approval: Notify Commission so that a representative may witness I Sundry Number:
Plug Integrity 0 BOP Test 0 Mechanical Integrity Test 0 Location Clearance 0
Other:
Subsequent Form Required:
BY ORDER OF
Approved by: COMMISSIONER THE COMMISSION Date:
Form 10-403 Revised 12/2003
INSTRUCTIONS ON REVERSE
Submit in Duplicate
ALASKA OIL AND GAS CONSERVATION COMMISSION
AULAR DISPOSAL APPLlC eN
. - 20 MC 25.080
1. Operator Name: 3. Permit to Drill No:
4. API Number: 50-
2. Address: 5. Well Name:
6. Field:
7. Publicly recorded wells 8. Stratigraphic description:
a) Interval exposed to
a) All wells within one- open annulus:
quarter mile:
b) Waste receiving
zone:
b) water wells within
one mile: c) Confinement
9. Depth to base of 10, Hydrocarbon zones
permafrost: above waste receiving
zone:
11. Previous volume disposed in annulus and date: 12. Estimated slurry density: 1 3, Maximum anticipated pressure at shoe:
14. Estimated volume to be disposed with this request: 15. Fluids to be disposed:
16. Estimated start date:
17. Attachments:
Well Schematic (Include MD and TVD) 0 Cement Bond Log (if required) fi FIT Records wI LOT Graph n
LJ
Surf. Casing Cementing Data 0 Other 0
18. I hereby certify that the foregoing is true and correct to the best of my knowledge.
Signature: Title:
Printed Phone
Name: Number: Date:
Commission Use Only
Conditions of approval:
LOT review and approval:
Subsequent form Approval
required: number:
Approved BY ORDER OF THE
by: COMMISSIONER COMMISSION Date:
Form 10-403AD Rev.9/2003
INSTRUCTIONS ON REVERSE
Submit in Duplicate
Block No:
1 - 6
7-8
10
¡ructions to complete fonn 10403AD' .
Self-explanatory
When an additional annular disposal request is submitted for the same field, list only the information that was not
referenced in a previous disposal request.
List MVD & TVD of any Hydrocarbon Zones above waste receiving zone.
Form 10-403AD Rev.9/2003
Submit in Duplicate
ALASKA Oil AND GAS CONSERVATION COMMISSION
RE' .r OF SUNDRY WELL OPE eONS
1. Operations Abandon U Repair Well U Plug Perforations U Stimulate U Other U
Performed: Alter Casing 0 Pull Tubing 0 Perforate New Pool 0 Waiver 0 Time Extension 0
Change Approved Program 0 Operat. Shutdown 0 Perforate 0 Re-enter Suspended Well 0
2. Operator 4. Current Well Class: 5. Permit to Drill Number:
Name: Development 0 Exploratory 0
3. Address: Stratigraphic 0 Service D 6. API Number:
7. KB Elevation (ft): 9, Well Name and Number:
8. Property Designation: 1 Q. Field/Pool(s):
11. Present Well Condition Summary:
Total Depth measured feet Plugs (measured)
true vertical feet Junk (measured)
Effective Depth measured feet
true vertica I feet
Casing Length Size MD TVD Burst Collapse
Structural
Conductor
Surface
Intermediate
Production
Liner
Perforation depth: Measured depth:
True Vertical depth:
-
Tubing: (size, grade. and measured depth)
Packers and SSSV (type and measured depth)
12. Stimulation or cement squeeze summary:
Intervals treated (measured):
Treatment descriptions including volumes used and final pressure:
13. Representative Daily Average Production or Injection Data
Oil-Bbl Gas-Mcf Water-Bbl Casing Pressure Tubing Pressure
Prior to well operation:
Subsequent to operation:
14. Attachments: 15. Well Class after proposed work:
Copies of Logs and Surveys Run Exploratory D Development D Service D
Daily Report of Well Operations 16. Well Status after proposed work:
oilD Gas D WAG D GINJ D WINJ D WDSPL 0
17. I hereby certify that the foregoing is true and correct to the best of my knowledge. SUndry NumberorN/A ifC.O. Exempt:
Contact
Printed Name Title
Signature Phone Date
Form 10-404 Revised 04/2004
Submit Original Only
Name of Operator: Field and Pool: Month and Year:
1. Well No. 2. API No. 3. Type 4. Field & 5. Method 6. Days in Oper. 7. Tubing PSIG DAILY AVG. PRODUCTION TOTAL MONTHLY PRODUCTION
50-XXX-XXXXX-XX-XX (see Pool Code (see 8. OIL 9. WATER 10. GAS 11. OIL 12. WATER 13. GA
instruct.) instruct.) (BBL) (BBL) (MCF) (BBL) (BBL) (MCF)
.
.
I hereby certify that the foregoing is true and correct to the best of my knowledge, 14.
Printed Name: Title:
Signature: Date: TOTAL
STATE OF ALASKA
ALASKA Oil AND GAS CONSERVATION COMMISSION
MONTHLY PRODUCTION REPORT
20 MC 25.230
Form 10-405 Rev, 12/2003
INSTRUCTIONS ON REVERSE SIDE
Submit in Duplicate
INSTRUCTIONS FOR FORM 10-405:
1. Report due by the 20th of the month following reporting period.
2. Property totals should be shown for each defined pool or defined commingling group. Inclusion of more than one property in a pool on the
page is permissible.
3. Codes used in column 3, Type of well are:
1 -Oil producer
2 -Gas producer
3 -Plant products
4. Codes used in column 4, Field and Pool Code, are as assigned by the Alaska Oil and Gas Conservation Commission.
5. Codes used in column 5, Method, are:
1 -Flowing
2 -Gas lift
3 -Rod pump
4 -Hydraulic pump
5 -Electric sumbmersible
8 -Shut-in or standing
9 -Plant products
6. Well!;> with no production that are not abandoned should be shown with zero production and as code 8 in column 5 (Method).
7. In column 6, Days in Operation, report any portion of a day as a full day.
8. Daily Average Production must equal Total Monthly Production divided by Days in Operation.
9. Block 14 total must equal total amount in the column.
Form 10-405 Rev. 12/2003
.
.
Submit in Duplicate
Name of Operator: Field and Pool: Month and Year:
1. Well No. 2. API No. 3. Type 4. Field & 5. Method 6. Days TUBING PRESS. CASING PRESS. DAIL Y AVG. INJ. TOTAL MONTHLY IN.
50-XXX-XXXXX-XX-XX (see Pool Code (see in Oper. 7. MAX 8. AVG 9. MAX 10. AVG 11. LIQUID 12. GAS 13. LIQUID 14. GA
instruct. ) instruct. ) PSIG PSIG PSIG PSIG (MCF) (BBL) (BBL) (MCF)
.
.
.
I hereby certify that the foregoing is true and correct to the best of my knowledge. 15.
Printed Name: Title:
Signature: Date: TOTAL
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
MONTHLY INJECTION REPORT
20 MC 25.432
Form 10-406 Rev. 12/2003
INSTRUCTIONS ON REVERSE SIDE
Submit in Duplicate
ALA~KA OIL AND GAS CONSERVATION COMMISSION
WELL COMPLE1 OR RECOMPLETION ~ RT AND LOG
1a. Well Status: OilU Gas[J Plugge Abandoned U Suspended 0 WAG 1b. Well Class:
20MC 25,105 20MC 25.110 Development 0 ExploratoryD
GINJD WINJD WDSPL 0 No. of Completions Other Service 0 Stratigraphic Test 0
2. Operator Name: 5. Date Comp., Susp., or 12. Permit to Drill Number:
Aband.:
3. Address: 6. Date Spudded: 13. API Number:
4a. Location of Well (Governmental Section): 7. Date TD Reached: 14. Well Name and Number:
Surface:
Top of Productive Horizon: 8. KB Elevation (ft): 15. Field/Pool(s):
Total Depth: 9. Plug Back Depth(MD+ TVD):
4b. Location of Well (State Base Plane Coordinates): 10, Total Depth (MD + TVD): 16. Property Designation:
Surface: x- y- Zone-
TPI: x- y- Zone- 11. Depth Where SSSV Set: 17. Land Use Permit:
Total Depth: x- y~ Zone-
18. Directional Survey: Yes o No U 19. Water Depth, if Offshore: 20. Thickness of Permafrost:
feet MSL
21 . Logs Run:
22. CASING, LINER AND CEMENTING RECORD
'NT. PER SETTING DEPTH MD SETTING DEPTH TVD AMOUNT
CASING FT. GRADE TOP BOTTOM TOP BOTTOM HOLE SIZE CEMENTING RECORD PULLED
"
23. Perforations open to Production (MD + TVD of Top and Bottom 24. TUBING RECORD
Interval, Size and Number; if none, state "none"): SIZE DEPTH SET (MD) PACKER SET (MD)
25. ACID, FRACTURE, CEMENT SQUEEZE, ETC.
DEPTH INTERVAL (MD) AMOUNT AND KIND OF MATERIAL USED
26. PRODUCTION TEST
Date First Production: Method of Operation (Flowing, gas lift, etc.):
Date of Test: Hours Tested: Production for Oi/-Bbl: Gas-MCF: Water-Bbl: Choke Size: /GaS-Oil Ratio:
Test Period .
Flow Tubing Casing Press: Calculated Oi/-Bbl: Gas-MCF: Water-Bbl: Oil Gravity - API (carr):
Press. 24-Hour Rate ..
27. CORE DATA
Brief description of lithology, porosity, fractures, apparent dips and presence of oil, gas or water (attach separate sheet, if necessary).
Submit core chips; if none, state "none".
Form 10-407 Revised 12/2003
CONTINUED ON REVERSE
·.. '..'--' IVIL.J IVU Include and briefly summarize test results. List intervals tested, and attach
. detailed supportir .s necessary. If no tests were conducted, state
"None",
30. List of Attachments:
31, I hereby certify that the foregoing is true and correct to the best of my knowledge. Contact:
Printed Name: Title:
Signature: Phone: Date:
INSTRUCTIONS
Generai: This form is designed for submitting a complete and correct well completion report and log on all types of lands and leases in Alaska. Submit
a well schematic diagram with each 10-407 well completion report and 10-404 well sundry report when the downhole well design is changed.
Item 1a: Classification of Service wells: Gas Injection, Water Injection, Water-Altemating-Gas Injection, Salt Water Disposal, Water Supply for
Injection, Observation, or Other. Multiple completion is defined as a well producing from more than one pool with production from each pool
completely segregated. Each segregated pool is a completion.
Item 4b: TPI (Top of Producing Interval).
Item 8: The Kelly Bushing elevation in feet above mean low low water. Use same as reference for depth measurements given in other spaces on this
form and in any attachments.
Item 13: The API number reported to AOGCC must be 14 digits (ex: 50-029-20123-00-00),
Item 20: True vertical thickness.
Item 22: Attached supplemental records for this well should show the details of any multiple stage cementing and the location of the cementing tool.
Item 23: If this well is completed for separate production from more than one interval (multiple completion). so state in item 1, and in item 23 show the
producing intervals for only the interval reported in item 26. (Submit a separate form for each additional interval to be separately produced,
showing the data pertinent to such interval).
Item 26: Method of Operation: Flowing. Gas Lift, Rod Pump, Hydraulic Pump, Submersible, Water Injection, Gas Injection, Shut-in, or Other (explain),
Item 27: If no cores taken, indicate "none".
Item 29: List all test information. If none, state "None".
Form 10-407 Revised 12/2003
Operator: Field and Pool: Unit or Lease Name:
Address: Reporting Period:
Well Name and No. API Number Date of Method Choke Pressures Length of Separator Production During Test Gas-I
50-XXX-XXXXX-XX-XX Test Size Tubing Casing Separator Test Temp, of Water Gravity Oil Bbls. Gravity Gas MCF Ratio I
Bbls. Oil Gas Ft./BI
-
-=
-
,
t'
All tests reported herein were made in accordance with the applicable rules, regulations and instructions of the Alaska Oil and Gas Conservation Commission.
I hereby certify that the foregoing is true and correct to the best of my knowledge.
Printed Name: Title:
Signature: Date:
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
WEll STATUS REPORT AND GAS-Oil RATIO TESTS
20 MC 25.270
Form 10-409 Rev. 12/2003
INSTRUCTIONS ON REVERSE SIDE
INSTRUCTIONS TO COMPLETE FORM 10-409:
Use a separate sheet for each pool.
Show all data requested for each well separately, and determine the gas-oil ratio according to the following procedure:
(1) General:
All well data and gas oil ratio tests submitted to the Commission on this form shall be made by a person qualified by training or experience
to make such tests. Methods of gas measurement used shall be in accordance with API standards. All API numbers reported to AOGCC
must consist of 14 digits (ex: 50-029-20123-00-00).
(2) Gas Volumes:
The volume of gas used in computing the gas-oil ratio and reported as being produced during the test (except tests on gas lift wells) shall
be the total volume of gas produced from the well in the test period. This total volume of gas shall include all gas withdrawn from the .
casing as well as that produced through the tubing.
(3) Flowing Wells:
The oil flow shall be stabilized during the 24-hour period immediately preceding the test. Adjustments in the rate of flow should be made
during the first 12 hours of the stabilization period and no adjustment shall be made during the last 12 hours or during the time in which the
well is being tested.
(4) Gas Lift:
In submitting gas-oil ratio tests for gas lift wells, the total input and the total output gas volumes shall be recorded separately. These
volumes shall be properly identified and determined by continuous measurement during the test. The volume of gas used in determining
the operating gas-oil ratio hereunder shall be the volume remaining after the total input gas has been deducted from the total output
volume; this net volume is to be reported on this form.
(5) Pumping Wells:
In computing the operating gas-oil ratio, the total volume of gas and the total barrels of oil produced during the test period must be used
regardless of the pumping time in the test period.
(6) Method of Operation:
Under "Method of Operation" use the following code: 1-Flowing, 2-Gas Lift, 3-Rod Pump, 4-Hydraulic Pump, 5-Submersible Pump, 8-
Standing or Shut-In, 9-0ther.
.
(7) Pressures:
Show the stabilized working pressure on the tubing, casing, and separator, while the well is being tested.
(8) Gas Production:
The Gas Production listed shall be the total volume of gas produced during the test, expressed in thousands of cubic feet (MCF) at a
standard pressure of 14.65 pounds per square inch, absolute, and a standard temperature of 60 degrees Fahrenheit; volume corrections
are to be made in accordance with chapter 14.3 of the API Manual of Measurement Standards (adopted A.GA Report No.3).
Fonn 10-409 Rev. 12/2003
ALASKA Oil AND GAS CONSERVATION COMMISSION
aÐESIGNA TION OF OPERA' .
.- 20 MC 25.020
1. Name and Address of Owner:
2. Notice is hereby given of a designation of operatorship for the oil and gas property described below:
Legal description of property:
Property Plat Attached: 0
3. Name and Address of Designated Operator:
4. Effective Date of Designation:
5. Acceptance of operatorship for the above described property within all attendant responsibilities and obligations is hereby acknowledged:
Signature Date
Printed Name Title
6. The Owner hereby certifies that the foregoing is true and correct:
Signature Date
Printed Name Title
7.
Approved:
Commissioner Date
Approved:
Commissioner Date
Approved:
Commissioner Date
(Requires approval by two Commissioners)
Form 10411 Rev.1012003
Submit in duplicate
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
RESERVOIR PRESSURE REPORT
1. Operator: 12. Address:
3. Unit or Lease Name: 4. Field and Pool: 5. Datum Reference: 6. Oil Gravity: 7. Gas Gravity:
8. Welt Name and 9. API Number 10. Oil (0) 11. AOGCC 12. Final Test 13. Shut-In 14. Press. 15. B.H. 16. Depth Tool 17. Final 18. Datum TVDss 19. Pressure 20.
Number: 50-XXX-XXXXX-XX-XX or Gas (G) Pool Code Date Time, Hours Surv. Type Temp. TVDss Observed (input) Gradient, Pressure
(see Pressure at psi/ft. Datum (e
instructions for Tool Depth
codes)
-
-
-=
21. All tests reported herein were made in accordance with the applicable rules, regulations and instructions of the Alaska Oil and Gas Conservation Commission,
I hereby certify that the foregoing is true and correct to the best of my knowledge.
Signature Title
Printed Name Date
Form 10-412 Rev. 9/2003
INSTRUCTIONS ON REVERSE SIDE
Submit in Duplicate
GENERAL NOTES AND INSTRUCTIONS FOR REPORTING RESERVOIR PRESSURES FORM 10-412:
This report shall be submitted. in duplicate. not later than the last day of the month immediately following the month in which tests were made. All bottom hole pressure tests reported herein shall
made by a person qualified by both training and experience to make such tests.
Calibration: The subsurface bomb-type pressure tool shall be calibrated against a U.S. Bureau of Standards certified dead weight tester both prior and subsequent to the dates at which all tests
reported hereon are made, and in no case shall this time exceed a period of one month. The prior and subsequent calibrations shall not disagree by more than one percent (1%).
If the subsurface pressure tool is a quartz crystal pressure gauge or electronic gauge its calibration is subject to inspection by the AOGCC,
Block No:
5 Datum Reference: Shall be in feet above or below sea level, per conservation order I area injection order, if applicable.
7
Gas Gravity: Shall be determined from an analysis of the casinghead gas.
.
9
All API numbers reported to AOGCC must consist of 14 digits (ex: 50-029-20123-00-00).
12 Date Tested: Enter in this column the month and day on which the bottom hole pressure test was made.
13 Shut-in Time: Shall be reported accurately to the nearest hour. The well tested shall have produced its normal daily rate of production or allowable within the 24-hour period immediate
preceding the time at which it was shut-in. (Any, deviations shall be certified on this report and shall be approved by the AOGCC.)
14 Pressure Survey Type Codes:
DST - drill stem test
EXRT1 - extrapolate - single phase
MRT - multi-rate tests, 4 point, isochronal, AOF, etc.
PBU - pressure build up
PFO - pressure fall off
RFT - formation tester
SBHP - static bottom hole pressure
OTHER - please explain at bottom of form
15
Bottom Hole Temperature: Shall be reported in degrees Fahrenheit as determined at test depth by either a recording or maximum reading thermometer.
.
16 Tool Depth: Shall be reported in feet as measured depth at the point to which the pressure tool was stationed.
17 Final Observed Pressure at Tool Depth: Shall be reported as the pressure in pounds per square inch gauge observed at test depth before any necessary depth and temperature
corrections have been made.
19 Pressure Gradient: Shall be in pounds per square inch per foot based on check points from the pressure tool.
20 Pressure at Datum: The datum pressure shall be representative of the near well reservoir pressure. Only one pressure shall be reported per well unless there are separate discreet
reservoir tests being documented.
(a) In the case of pressure tool measurements, this pressure shall be the observed pressure after the corrections for reservoir temperature and for the difference between test depth
and datum reference have been made. It shall be reported in pounds per square inch gauge.
(b) In the case of sonic measurements this pressure shall be determined from the weight of the fluid column plus the weight of any gas present above the fluid column plus casingheac
pressure after proper corrections are made for temperature.
Form 10-412 Rev. 9/2003
Submit in Duplicate
, ,o-,rUJ'V'""\ VIl... 1"'\1 'tU \"JIM,", ,",UI"':>c:.~ V M I UI~ vUMMI~~IUN
AN~"~ REPORT OF INJECTION "'..,ECT
. FOR THE YEAR: .
20 AAC 25.432 (2)
Name of Operator Address
Unit or Lease Name Field and Pool
Type of Injection Project Name of Injection Project Number of Inj.lConservation Order Authorizing
Project
1. WATER INJECTION DATA
As of Jan. 1, active water ¡nj. Water inj. wells added or As of Dec. 31, active water inj. Annual volume water inj. Cumulative water inj. to date
wells subtracted Wells
+ -
2. GAS INJECTION DATA
As of Jan. 1, active gas inj. wells Gas inj. wells added or As of Dec. 31, active gas inj. Annual volume gas inj. Cumulative gas inj. to date
subtracted Wells
+ -
3. LPG INJECTION DATA
As of Jan. 1, active LPG inj, LPG inj. wells added or As of Dec. 31, Active LPG ¡nj. Annual volume LPG inj. Cumulative LPG inj. to date
wells subtracted wells
+ -
4. PRODUCTION DATA
As of Jan. 1, Total oil wells Oil wells added or subtracted As of Dec. 31, Total oil wells Annual volume oil and/or Cumulative oil and/or
condensate produced condensate to date
+ -
As of Jan. 1, Total gas wells Gas wells added or subtracted As of Dec. 31, Total gas wells Annual volume gas produced Cumulative gas to date
+ -
5. INJECTION VOLUMES (Resevoir Barrels)
Annual Volume Cumulative since oroiect start
Water (surface bbls.=reservoir bbls.) (A)
LPG (Surface bbls.=reservoir bbls.) Indicate type of LPG, Butane. Propane or othe (B)
( Standard CF X volume factor v, where v= )
Gas Z (Compressibrltv factor) X Tr (rese",oir temperature 'F absolute) X 14,65
5,615 cflbbL X Pr, (reselVo;r pressure, psia) X 520 (absoiute equivalent at60'F (C)
TOTAL FLUIDS INJECTED (reservoir bbfs.) (A)+(B)+(C) 0 0
6. PRODUCED VOLUMES (Resevoir Barrels)
Oil (Stock tank Bbls. X formation volume factor) (0)
Free ( Total gas produced in standard cubic feet less solution gas )
Gas produced (Stock tank bbls, Oil produced X solution gas oil (E)
ratio) X volume factor II calculated for croducedaas
Water (surface bbls.=reservoir bbls.) (F)
TOTAL PRODUCED VOLUMES (reservoir barrels) (D)+(E)+(F)
NET INJECTED (+) OR PRODUCED (-) VOLUMES (5.)-(6.) 0 0
Year end reservoir pressure Datum feet
psia Subsea
I herebv certify that the foreaoina is true and correct to the best of my knowledae.
Signature: Date:
Printed Name: Title:
Form 10-413 Rev. 12/2003
Submit Original and One Copy
I"'\I.J'\,;;)/V'\ UIL f-\NU ~A;:) ~UN~t::KVA nON COMMISSION
r ~E OF CHANGE OF OWNr .IP
. 20 AAC 25.022
1. Operator Name:
2. Address:
3. Notice is hereby given that the owner U . landowner
assigned or transferred interest in the property indicated below:
LJ
, of record for the oil and gas property described below has
Property Designation:
Legal description of property:
Field or Unit:
Property plat attached n
4. Effective date of assignment or transfer:
5, Percentage interest assigned or transferred:
6. Assignee or Transferee:
Address:
7. Assignor or Transferor:
Address:
8. I hereby certify that the foregoing is true and correct to the best of my knowledge,
Signature:
Date:
Printed Name:
Title:
Form 10-417 Rev. 10/2003
ALASKA OIL AND GAS CONSERVATION COMMISSION
GAS WEL. EN FLOW POTENTIAL T REPORT
1a. Test: U Initial U Annual U cial 11 b, Type Test: U Stabilized U Non Stabilized U Multipoint
o Constant Time o Isochronal o Other
2. Operator Name: 5. Date Completed: 11. Permit to Drill Number:
3. Address: 6. Date TO Reached: 12. API Number:
50-
4a. Location of Well (Governmental Section): 7. KB Elevation (ft): 13. Well Name and Number:
Surface:
Top of Productive Horizon: 8. Plug Back Depth(MD+ NO): 14. Field/Pool(s):
Total Depth: 9. Total Depth (MD + TVD):
4b. Location of Well (State Base Plane Coordinates): 10. Land Use Permit: 15. Property Designation:
Surface: x- y- Zone-
TPI: x- y- Zone- 16. Type of Completion (Describe):
Total Depth: x- y- Zone-
17. Casing Size Weight per foot, lb. 1.0. in inches Set at ft. 19. Perforations: From To
18. Tubing Size Weight per foot, lb. 1.0. in inches Set at ft.
20. Packer set at ft: 21. GaR cf/bbl: 22. API Liquid Hydrocardbons: 23. Specific Gravity Flowing Fluid (G):
24a. Producing through: 24b. ReseNoir Temp: 24c. ReseNoir Pressure: 24d. Barometric Pressure (Pa):
o Tubing 0 Casing Fe psia @ Datum TVDSS psi a
25. Length of Flow Channel (L): Vertical Depth (H): Gg: I % CO2: % N2: %H2S: Prover: I Meter Run: I Taps:
26. FLOW DATA TUBING DATA CASING DATA
Prover Choke Pressure Diff. Temp. Pressure Temp. Pressure Temp. Duration of Flow
No. Line X Orifice
Size (in.) Size (in.) psig Hw Fe psig Fe psig Fe Hr.
1. X
2. X
3. X
4. X
5. X
Basic Coefficient Pressure Flow Temp. Gravity Factor Super Compo Rate of Flow
No. (24-Hour) -J hwPm Pm Factor Fg Factor Q1 Mcfd
Fb or Fp Ft Fpv
1.
2.
3.
4.
5.
Temperature for Separator for Flowíng
No. Pr Tr z Gas Fluid
T Gg G
1.
2.
3. Critical Pressure
4. Critical Temperature
5.
Form 10-421 Revised 1/2004
CONTINUED ON REVERSE SIDE
Submit in Duplicate
¡-c; pc· Pf PF
No. P! pe Pc2 _Pt2 Pw pvl Pc' Ps PS2 PF _PS2
1.
2.
3.
4.
5.
25.
AOF (Mcfd) n
Remarks:
I hereby certify that the foregoing is true and correct to the best of my knowledge.
Signed
Title
Date
DEFINITIONS OF SYMBOLS
AOF Absolute Open Flow Potential. Rate of Flow that would be obtained if the bottom hole
pressure opposite the producing face were reduced to zero psia
Fb Basic orifice factor Mcfdl ~ hwPm
Fp Basic critical flow prover or positive choke factor Mcfd/psia
Fg Specific gravity factor, dimensionless
Fpv Super compressibility factor= -I1ïZ dimensionless
Ft Flowing temperature factor, dimensionless
G Specific gravity of flowing fluid (air=1.000), dimensionless
Gg Specific gravity of separator gas (air=1.00), dimensionless
GOR Gas-oil ratio, cu. ft. of gas (14.65 psia and 60 degrees F) per barrel oil (60 degrees F)
hw Meter differential pressure, inches of water
H Vertical depth corresponding to L, feet (TVD)
L Length of flow channel, feet (MD)
n Exponent (slope) of back-pressure equation, dimensionless
Pa Field barometric pressure, psia
Pc Shut-in wellhead pressure, psia
Pf Shut-in pressure at vertical depth H, psia
Pm Static pressure at point of gas measurement, psia
Pr Reduced pressure, dimensionless
Ps Flowing pressure at vertical depth H, psia
Pt Flowing wellhead pressure, psia
Pw Static column wellhead pressure corresponding to Pt, psia
Q Rate of flow, Mcfd (14.65 psia and 60 degrees F)
Tr Reduced temperature, dimensionless
T Absolute temperature, degrees Rankin
Z Compressibility factor, dimensionless
Recommended procedures for tests and calculations may be found in the Manual of
Back- Pressure Testing of Gas Wells, Interstate Oil Compact Commission, Oklahoma
City, Oklahoma.
Form 10-421 Revised 1/2004
Side 2
.
Facility Codes
.
Code Facility Name
0290000019 Badami
0230000001 Barrow
1330000011 Beaver Creek
2830000001 Beluga River
1030000017 Colville River Unit
0290000002 DIU Endicott
1330000031 Falls Creek
1330000032 G Oskolkoff
1330000005 GP Anna Platform
1330000007 GP Bruce Platform
1330000006 GP GP Platform
1330000008 GP TF Anna/Bruce
1330000009 GP TF Gran Pt Prod Fac (Plat)
1330000010 GP TF LEX Plant
2830000002 Ivan River
1330000012 Kenai
1330000013 Kenai Cannery Loop
0290000021 KRU CPF 1
0290000022 KRU CPF 2
0290000023 KRU CPF 3
2830000003 Lewis River
2830000008 Lone Creek
1330000014 MGS A Platform
1330000015 MGS Baker Platform
1330000016 MGS C Platform
1330000017 MGS Dillon Platform -SMGS
0290000024 Milne Point Central
2830000009 Moquawkie
2830000005 Nicolai Creek
2830000004 North Cook Inlet
0290000025 Northstar
0290000000 PBU CCP/FFGU
0290000008 PBU CGF B
0290000028 PBU FS 1
0290000029 PBU FS 2
0290000030 PBU FS 3
0290000031 PBU GC 1
0290000032 PBU GC 2
0290000033 PBU GC 3
0290000009 PBU Lisburne Prod (GrPtMcArea)
0090000001 Pioneer
2830000006 Pretty Creek
1330000029 RS Kustatan
1330000033 S Dionne
1330000002 SR Swanson River LEX
1330000018 Sterling
ntpr! f('\r Thprp<;:~ R('\l'·1-h;l1 <rnC'1-h;Ifí1)r\nhnv ~bdr~ npot>
"/4/0
1330000000 TB Onshore Facility MRF
80000020 TBF Monopod .
~0000019 TBF North NonUnit 800 Spurr
1330000021 TBU Dolly Varden Platform
1330000022 TBU Grayling Platform
1330000023 TBU King Salmon Platform
1330000024 TBU North 800 Spark
1330000025 TBU Steelhead Platform
1330000035 TBU-MRF Monopod
1330000026 W Foreland
1330000027 W McArthur River
0230000003 Walakpa
1330000030 Wolf Lake
Forms Index
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5/4/0
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
REPORT OF ANNULAR DISPOSAL
1. Operator: 4a. Well Class: Stratigraphic LJ Service U 6. Permit to Drill Number:
Development 0 Exploratory 0 7. Well Name:
2. Address: 4b. Well Status: Oil 0 Gas 0 WAG 0 6. API Number:
GINJ 0 WINJ 0 WDSPL 0 50-
3. (Check one box only) 5a. Sundry Number: 5b. Sundry approval date: 9. Field:
Initial Disposal 0 Continuation 0 Final 0
10 (h)(1) drilling mud, drilling (h)(2) drill rig wash fluids (h)(3) other Commission Volume (bbls): Number of Disposal Disposal Source Wells:
cuttings, reserve pit fluids and drill rig domestic waste approved substances (include days Beginning Dates: Ending .
cement-contaminated drilling water descriptions In block 12) disposal Dates:
mud, completion fluids, occurred:
formation ftuids and any
necessary water added.
Previous
totals
(bbls):
YYYY/Q#
YYYY/Q#
YYYY/Q#
YYYY/Q#
Total Report is due on the 20th .-
Ending
Volume of the month following the final month of the quarter. Ex:
(bbls): April 20 for the first quarter, July 20 for the second quarter,
11. Attach: Disposal Performance Data: Pressure vs. Time o Step Rate Test 0 October 20 for the third quarter, and January 20 for the
Other (Explain) 0 fourth quarter.
12. Remarks and Approved Substances
Description(s):
I hereby certify that the foregoing is true and correctto the best of my knowledge.
Signature: Date:
Printed Title: Phone
Name: Number:
Form 10-423 Rev. 2/2004
INSTRUCTIONS ON REVERSE SIDE
Submit in Duplicate
Block No:
Instructions to complete form 10-423:
The report will be submitted each quarter, even with zero volumes, until the application expires.
3 Check the appropriate box. Check "Final" if disposal operations have been completed.
10 A description of "Other Commission Approved Substances" is required and should be included in block 12. "Remarks".
11
Disposal performance data is required. Examples include:
Step Rate Pressure Test
Pressure VS. Time
Temperature Survey
Some other type that the operator is using to ensure waste is going to stay where intended.
Form 10-423 Rev. 2/2004
.
.
Submit in Duplicate