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HomeMy WebLinkAboutCO 505 A e e Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable ~. direct inspection of the file. G 0 S05 À Order File Identifier Organizing (done) ~wo-sided 11111111I1111111111 o Rescan Needed 11\ 11111111\\ 111111 RESCAN ~olor Items: o Greyscale Items: DIGITAL DATA OVERSIZED (Scannable) o Maps: D Other Items Scannable by a Large Scanner o Diskettes, No. D Other, NolType: D Poor Quality Originals: OVERSIZED (Non-Scannable) o Other: o Logs of various kinds: NOTES: Date 6 /Jj00 I Date: 6" / ~/ Oh f I o Other:: Scanning Preparation BY: + = TOTAL PAGES (Count does not include cover sheet) 151 01£ J~IIIIIIIIIIIIIIIII(t1 e $~ BY: ~ 151 Project Proofing BY: ~ Production Scanning ""111111111111111 Stage 1 Page Count from Scanned File: 53 (Count does include cover sheet) Page Count Matches Number in Scan~ing ¡reparation: BY ~ DateE 1~/oÞ Stage 1 If NO in stage 1, page(s) discrepancies were found: JL:::. YES NO YES 151 W1 f NO BY: Maria Date: 151 1111111111111111111 Scanning is complete at this point unless rescanning is required. ReScanned 1111111111111111111 BY: Maria Date: 151 Comments about this file: Quality Checked 11111111I1111111111 10/6/2005 Orders File Cover Page. doc INDEX Conservation Order N0.505A Orion Pool, Prudhoe Bay Field 1. February 23, 2006 Request for modifications to AIO 026 and CO 505 with Exhibit attachments I-1, II-1, III-3, IV-1, through IV-8 and V-1, except IV-4 held Confidential 2. March 1, 2006 Advertising Order AO-02614029 3. March 29, 2006 E-mail re: hearing vacated 4. March 30, 2006 Exhibit IV-4 Confidentiality request 5. August 31, 2006 E-mail to operator re: reporting times 6. August 31, 2006 Prudhoe Bay Filed -Annual Surveillance Reporting requirements to AOGCC 7. August 21, 2008 BPXA request to allow for the injection of miscible injectant into multiple completion injection wells (COSOSA-001) Conservation Order N0.505A e e STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: THE APPLICATION OF BP EXPLORATION (ALASKA) INC. for modification of Conservation Order 505 to authorize underground injection of enriched hydrocarbon gas for enhanced oil recovery in Orion Oil Pool, Prudhoe Bay Field, North Slope, Alaska ) Conservation Order No. 505A ) Prudhoe Bay Field ) Schrader Bluff Oil Pool ) Orion Development Area ) ) April 28, 2006 ) IT APPEARING THAT: 1. By application dated February 23, 2006 BP Exploration (Alaska) Inc. ("BPXA"), Operator of the Prudhoe Bay Unit ("PBU"), requested an order from the Alaska Oil and Gas Conservation Commission ("Commission") modifying Area Injection Order 26 ("AIO 26") and Conservation Order 505 to authorize the injection of enriched hydrocarbon gas for enhanced oil recovery purposes in the Orion Oil Pool within the PBU. 2. The Commission published notice of opportunity for a public hearing on BPXA's application in the Anchorage Daily News on March 2, 2006. 3. The Commission received no requests for a public hearing. 4 The Commission received no protests or comments. 5. No hearing was held. FINDINGS: 1. Description of Operation BPXA requested authorization for an enhanced oil recovery ("EOR") project using enriched gas from the Prudhoe Bay Central Gas Facility. The project involves the cyclical injection of water alternating with injection of hydrocarbon gas enriched with intermediate hydrocarbons, principally ethane and propane. Implementation of the Orion EOR project will involve connection of Orion injection wells to existing or new miscible gas injection distribution systems on L, V, and Z Pads. Enriched hydrocarbon gas injection is expected to begin in 2nd quarter 2006. Conservation Order 505A April 28, 2006 e e Page 2 2. CO 505, Rule 7: CO 505 and AIO 26 approved and required the use of water injection. AIO 26A sets out rules for injection of enriched hydrocarbon gas for the purposes of enhanced oil recovery. Rule 7 of CO 505 should be updated to include enriched hydrocarbon gas injection as an approved depletion plan option for the Orion Development Area of the Schrader Bluff Oil Pool. 3. CO 505, Rule 9: BPXA plans to monitor the composition of produced gas within offset producing wells to determine the breakthrough volumes of enriched gas. This surveillance is needed for evaluation of the effectiveness of the enriched gas flood. Rule 9 currently includes a requirement that a surveillance report be submitted by April 1 of each year and that a technical meeting with the Commission be conducted by June 1 of each year. BPXA has requested that the due date of the surveillance report be revised to September 15, with a technical meeting soon after. The surveillance report will cover information for the period of July 1 of the prior calendar year through June 30 of the current calendar year. 4. Consolidation of Orders: CO 505 was approved on January 5, 2004. Since that time several new orders have been issued which affect the Orion Oil Pool. These include the following: CO 492 added rules concerning the regulation of annulus pressures of development wells; CO 547 provided rules for use of multiphase meters for well testing in Prudhoe Bay Unit Fields, including the Orion Oil Pool; and CO 556 added rules for waiver of "Application for Sundry Approvals" for workover operations. CONCLUSIONS: 1. Enriched gas injection will significantly improve recovery, and CO 505 should be updated to allow for such injection. 2. Changing the due date for the Annual Reservoir Report from April 1 to September 15 will not affect the Commission's ability to evaluate reservoir performance or ensure that future development plans promote greater ultimate recovery. 3. It is appropriate to consolidate Rules affecting the Orion Development Area of the Schrader Bluff Oil Pool into one order. NOW, THEREFORE, IT IS ORDERED THAT: In addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), the following rules apply to the Schrader Bluff Oil Pool within the following affected area, referred to herein as the Orion Development Area, and supersede and replace the rules adopted in Conservation Order 505: Conservation Order 505A April 28, 2006 e e Page 3 Umiat Meridian Township Lease Sections Range, UM TI2N-RlOE ADL 025637 13 and 24 N/2 T12N-RIIE ADL 047446 17, 18, 19, and 20 ADL 047447 16 S/2 and NW/4 and S/2 NE/4, 21, and 22 ADL 028238 25 SW/4, 26, 35, and 36 ADL 028239 27, 28, 33 E/2 and N/2 NW/4, and 34 ADL 047449 29 N/2 and SE/4, and 30 N/2 NE/4 TIIN-RIIE ADL 028240 1,2, 11 E/2 and E/2 NW/4, and 12 ADL 028241 3 N/2 and N/2 S/2, and 4 NE/4 N/2 SE/4 ADL 028245 13 N/2 and SE/4, 14 E/2 NE/4, and 24 E/2 NE/4 TIIN-R12E ADL 047450 7, and 8 S/2 and NW/4 ADL 028263 16 SW/4 and S/2 NW/4, and 21 SW/4 and S/2 NW/4 and NW/4 NW/4 and W/2 SE/4 ADL 028262 17, 18, 19 N/2 and SE/4 and N/2 SW 14, and 20 ADL 047452 28 W/2 and W/2 E/2 ADL 047453 29 N/2 and N/2 SE/4 Rule 1: Well Spacing (CO 505) Spacing units shall be a minimum of 10 acres. The Schrader Bluff Oil Pool shall not be opened in any well closer than 500' to an external boundary where ownership changes. Rule 2: Casing and Cementing Practices (CO 505) a. In addition to the requirements of 20 AAC 25.030, conductor casing must be set at least 75' below surface. b. In addition to the requirements of 20 AAC 25.030, surface casing must be set at least 500' TVD below the base of permafrost. Rule 3: Automatic Shut-in Equipment (CO 505) a. All wells must be equipped with a fail-safe automatic surface safety valve system capable of preventing an uncontrolled flow. b. All wells must be equipped with landing nipple at a depth below permafrost, which is suitable for the future installation of a downhole flow control device. The Commission may require such installation by administrative action. Conservation Order 505A April 28, 2006 e e Page 4 c. Operation and performance tests must be conducted at intervals and times as prescribed by the Commission to confirm that the safety valve systems are in proper working condition. Rule 4: Common Production Facilities and Surface Commingling (CO 505) a. Production from the Schrader Bluff Oil Pool within the Orion Development Area may be commingled with production from Prudhoe Bay Oil Pool, and other oil pools located in the Prudhoe Bay Unit in surface facilities prior to custody transfer. b. The Prudhoe Bay Unit Western Operating Metering Plan, described by letter from BPXA dated April 23, 2002 and detailed within the PBU Western Satellite Production Metering Plan - Policies and Procedures Document" dated August 1, 2002 is approved for allocation of production from Schrader Bluff Oil Pool wells within the Orion Development Area. c. All Schrader Bluff Oil Pool wells must use the Gathering Center 2 well allocation factor for oil, gas, and water. d. All wells must be tested a minimum of once per month. All new wells must be tested a minimum of two times per month during the first three months of production. The Commission may require more frequent or longer tests if the allocation quality deteriorates. e. Technical process review meetings shall be held at least annually. f. The operator shall submit a monthly report and file(s) containing daily allocation data and daily test data for agency surveillance and evaluation. Rule 5: Reservoir Pressure Monitoring (CO 505) a. Prior to regular production or injection, an initial pressure survey must be taken in each well. b. A minimum of one bottom-hole pressure survey per producing governmental section shall be run annually. The surveys in part (a) of this rule may be used to fulfill the minimum requirements. c. The reservoir pressure datum will be 4400' TVDss. d. Pressure surveys may be stabilized static pressure measurements at bottom-hole or extrapolated from surface (single phase fluid conditions), pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e. Data and results from pressure surveys shall be submitted with the annual reservoir surveillance report. All data necessary for analysis of each survey need not be submitted with the report but must be available to the Commission upon request. f. Results and data from special reservoir pressure monitoring tests shall also be submitted in accordance with part (e) of this rule. Conservation Order 505A April 28, 2006 e e Page 5 Rule 6: Gas-Oil Ratio Exemption (CO 505) Wells producing from the Schrader Bluff Oil Pool within the Orion Development Area are exempt from the gas-oil-ratio limits of 20 AAC 25.240 (a) so long as requirements of 20 AAC 25.240 (b) are met. Rule 7: Enhanced Oil Recovery or Reservoir Pressure Maintenance Operations (Amended this order - CO 505A) Waterflood is required and enriched gas injection is approved for purposes of pressure maintenance and enhanced oil recovery in the Orion Development Area of the Schrader Bluff Oil Pool. Production and injection operations must ensure the average reservoir pressure is maintained above the bubble point. Rule 8: Multiple Completion of Water Injection Wells (CO 505) a. Water injectors may be completed to allow for simultaneous injection in multiple pools within the same well bore so long as mechanical isolation between pools is demonstrated and approved by the Commission. b. Prior to initiation of co-mingled injection, the Commission must approve methods for allocation of injection to separate pools. c. Results of logs or surveys used for determining the allocation of water injection between pools, if applicable, must be supplied in the annual reservoir surveillance report. d. An approved injection order is required prior to commencement of injection in each pool. Rule 9: Annual Reservoir Review (Amended this Order - CO 505A) An annual report must be filed by September 15 of each year. The report must include future development plans, reservoir depletion plans, and surveillance information for the period July 1 of the prior calendar year through June 30 of the current calendar year (except the report due on September 15, 2006 must cover the period from January 2005 through June 30, 2006), and must include: a. voidage balance by month of produced and injected fluids, and cumulative status; b. reservoir pressure map at datum, summary and analysis of reservoir pressure surveys within the pool; c. results and, where appropriate, analysis of production and injection surveys, tracer surveys, observation well surveys, and any other special monitoring; d. review of pool production allocation factors and issues over the prior year; e. progress of enhanced recovery project implementation and reservoir management summary including results of reservoir simulation studies; f. progress of plans and tests to expand the productive limits of the pool, including any work within the Prince Creek formation; and g. results of monitoring to determine enriched gas injectant breakthrough to offset producers. Conservation Order 505A April 28, 2006 e e Page 6 The Operator shall schedule and conduct a yearly technical review meeting with the Commission to discuss the report contents and to review items that may require Commission action during the coming year. The Commission may conduct audits of technical data and analyses used in support of surveillance conclusions and reservoir depletion plans. Rule 10: Waiver of "Application for Sundry Approvals" Requirement for Workover Operations (CO 556) a. Except as provided in (d) and (e) of this rule, the requirement to submit an Application for Sundry Approvals (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 Commission document entitled "Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules," dated July 15, 2005 (referred to below as "Sundry Matrix"). This waiver and modification does not affect the Operator's responsibility to submit a Report of Sundry Well Operations (Form 10-404) within 30 days following the completion of a workover operation. b. Except as provided in (d) and (e) of this rule, the requirement to submit an Application for Sundry Approvals (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 Sundry Matrix. This modification does not affect the Operator's responsibility to submit a Report of Sundry Well Operations (Form 10-404) within 30 days following the completion of a workover operation. c. The Sundry Matrix 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. d. The waivers provided under (a) of this rule do not apply to wells that are required to be reported to the Commission under the provisions of Rule 11. e. The Commission reserves the discretion to require an operator to submit an Application for Sundry Approvals for a particular well or for a particular operation on any well. f. Each week the Operator shall provide the Commission with a report of workover operations performed the previous week that did not require submission of a Form 10-403. (These operations are listed in Column 2 of the Sundry Matrix.) The report must include the date, well, permit to drill number, nominal operation completed, and a brief description of that operation including depths of perforations, reperforations, and stimulated zones. g. Nothing in this rule precludes an Operator from filing an Application for Sundry Approvals (Form 10-403) in advance of any well work or from including Sundry authorized operations (listed in column 3 of the Sundry Matrix) in the weekly report required by (£) of this rule. h. Unless notice and public hearing are otherwise required, the Commission may administratively waive the requirements of any provision of this rule or Conservation Order 505A April 28, 2006 e e Page 7 administratively amend any provision including the Sundry Matrix, 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. Rule 11: Annular Pressures (CO 505, CO 492) a. At the time of installation or replacement the Operator shall conduct and document a pressure test of tubulars and completion equipment in each development well that is sufficient to demonstrate that planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. b. The Operator shall monitor each development well daily to check for sustained pressure, except if prevented by extreme weather conditions, emergency situations, or similar unavoidable circumstances. Monitoring results shall be made available for Commission inspection. c. The Operator shall notify the Commission within three working days after the Operator identifies a well as having (a) sustained inner annulus pressure that exceeds 2500 psig for wells processed through the Lisburne Processing Center and 2000 psig for all other development wells, or (b) sustained outer annulus pressure that exceeds 1000 psig. d. The Commission may require the Operator to submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action or increased surveillance for any development well having sustained pressure that exceeds a limit set out in paragraph 3 of this rule. The Commission may approve the Operator's proposal or may require other corrective action or surveillance. The Commission may require that corrective action be verified by mechanical integrity testing or other Commission approved diagnostic tests. The Operator shall give the Commission sufficient notice of the testing schedule to allow the Commission to witness the tests. e. If the Operator identifies sustained pressure in the inner annulus of a development well that exceeds 45% of the burst pressure rating of the well's production casing for inner annulus pressure, or sustained pressure in the outer annulus that exceeds 45% of the burst pressure rating of the well's surface casing for outer annulus pressure, the Operator shall notify the Commission within three working days and take corrective action. Unless well conditions require the Operator to take emergency corrective action before Commission approval can be obtained, the Operator shall submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action. The Commission may approve the Operator's proposal or may require other corrective action. The Commission may also require that corrective action be verified by mechanical integrity testing or other Commission approved diagnostic tests. The Operator shall give the Commission sufficient notice of the testing schedule to allow Commission to witness the tests. Conservation Order 505A April 28, 2006 e e Page 8 f. Except as otherwise approved by the Commission under (d) or (e) of this rule, before a shut-in well is placed in service, any annulus pressure must be relieved to a sufficient degree (1) that the inner annulus pressure at operating temperature will be below 2000 psig, and (2) that the outer annulus pressure at operating temperature will be below 1000 psig. However, a well that is subject to (c) but not (e) of this rule may reach an annulus pressure at operating temperature that is described in the Operator's notification to the Commission under (c) of this rule, unless the Commission prescribes a different limit. g. F or purposes of this rule, "inner annulus" means the space in a well between tubing and production casing; "outer annulus" means the space in a well between production casing and surface casing; and "sustained pressure" means pressure that (a) is measurable at the casing head of an annulus, (b) is not caused solely by temperature fluctuations, and (c) is not pressure that has been applied intentionally. Rule 12: Use of Multiphase Flowmeters in Well Testing (CO 547) For purposes of satisfying well test measurement requirements of 20 AAC 25.230, the use of multiphase meters will be approved only in accordance with the provisions of the Commission's document, "Guidelines for Qualification of Multiphase Meters for Well Testing" dated November 30, 2004. The Commission may administratively waive a requirement of these Guidelines or administratively amend the Guidelines as long as the change does not promote waste or jeopardize correlative rights, and is based on sound engineering and geoscience principles. This rule expires on January 1,2008. Conservation Order 505A April 28, 2006 e e Page 9 Rule 13: Administrative Action 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 April 28, 200 ~ t ~ \0 \i;~. '\!~I')Í' <¡, 'i .... . '"~ '. .....,"'.. Daniel T. Seamount, Jr., Commissioner Alaska Oil and Gas Conservation Commission Cathy P. oerster, Commissioner Alaska Oil and Gas Conservation Commission AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 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 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, to appeal the decision to Superior Court. Where a request for rehearing is denied by non-action of the Commission, the 30-day period for appeal to Superior Court runs tram the date on which the request is deemed denied (i.e., loth day after the application for rehearing was filed). CO 505A and AIO 26A e e Subject: CO 505A and AIO 26A From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Tue, 02 May 2006 10:32:42 -0800 To: undisclosed-recipients:; BCC: Robert E Mintz <robert_mintz@law.state.ak.us>, Christine Hansen <c.hansen@iogcc.state.okus>, Terrie Hubble <hubblet1@bp.com>, Sondra Stewman <StewmaSD@BP.com>, stanekj <stan cal.com>, eco1aw <ecolaw@trustees.org>, trmjrl <trmjr l@aol.com>, shaneg <shaneg s.com>, jdarlington <jdarlington@forestoil.com>, nelson <knelson@petroleumnews.com>, c <cboddy@usibelli.com>, Mark Dalton <mark.dalton@hdrinc.com>, Shannon Donnelly <sh . onnelly@conocophillips.com>, "Mark P. Worcester" <markp. worcester@conocophillips.com>, <bob@inletkeeper.org>, wdv <wdv@dnr.state.ak.us>, tjr dnr.state.ak.us>, bbritch <bbritch@alaska.net>, mjnelson <mjnelson ingertz.com>, Charles O'Donnell <charles.o'donnell@veco.com>, "Randy L. Skillern" <SkilleRL "Deborah J. Jones" <JonesD6@BP.com>, "Steven R. Rossberg" <RossbeRS@BP. >, Lois <lois@inletke org>, Dan Bross <kuacnews@kuac.org>, Gordon Pospisil <PospisG@BP.com>, "Francis S. S "<SommerFS@BP.com>, Mikel Schultz <Mikel.Schultz@BP.com>, "Nick W. GI verNW@BP.com>, "Daryl J. Kleppin" <KleppiDE@BP.com>, "Janet D. Platt" P.com>, "Rosanne M. Jacobsen" <JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, mckay <mckay@gci.net>, Barbara F Fullmer <barbara.f.fullmer@conocophillips.com>, Charles Barker <barker@usgs.gov>, doug_schultze <doug_sch energy. com>, Hank Alford <hank.alford@exxonmobil.com>, Mark Kovac <yesnol@gc spfoff <gspfoff@aurorapower.com>, Gregg Nady <gregg.nady@shell.com>, Fred Steece <fred.steece@state.sd.us>, rcrotty <rcrotty@ch2m.com>, j ej ones <j ej ones@aurorapower.com>, dapa <dapa@alaska.net>, jroderick <jroderick@gci.net>, eyancy <eyancy@seal-tite.net>, "James M. Ruud" <james.m.ruu conocophillips.com>, Brit Lively <mapalaska@ak.net>,jah <jah@dnr.state.ak.us , uonoje <buonoje@bp.com>, Mark Hanley <mark_hanley@anadarko.com>, loren_IeIIl,an <loren_Ieman@gov.state.akus>, 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@aog Brian Havelock <beh@dnr.state.ak.us>, bpopp <bpopp@borough.kenai.ak.us>, Jim White <jimwhi tx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobil.com>, marty <marty@rkindustnal.com>, ghammons <ghammons@aol.com>, rmclean <rmclean@pobox.alaska.net>, mkm7200 <mkm7200@aoLcom>, Brian' . <ifbmg@uaa.alaska.edu>, David L Boelens <dboelens@aurorapower.com>, Todd Dur URKEE@KMG.com>, Gary Schultz ultz@dnr.state.ak.us>, Wayne Rancier <RANCIER@petro-canada.ca>, Brandon Gagnon nalaw.com>, Paul Winslow <pmwinslo forestoil.com>, Sharmaine Copeland .com>, Kristin Dirks <kristin_dirks@dnr e.ak.us>, Kaynell Zeman . athonoil.com>, John Tower <John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fo adarko.COM>, Scott Cranswick <scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP.com>, Steve Lambe <lambes@unocal.com>,jack newell <jacknewell@acsalaska.net>, James Scherr <james.scherr@mms.gov>, n1617@conocophillips.com, Tim Lawlor <Tim_Lawlor@ak.blm.gov>, Lynnda Kahn <Lynnda_Kahn@fws.gov>, Jerry Dethlefs <Jerry.C.Dethlef: ocophillips.com>, crockett@aoga.org, Tamera Sheffield <sheffield@aoga.org>, Jon Goltz·<Jon. z@conocophillips.co ger Belman <roger.belman@conocophillips.com>, Mindy Lewis <mlewis@brenalaw.com> riarty <moriarty@aoga.org>, Patty Alfaro <palfaro@yahoo.com>, Jeff <smet al.com>, Todd Kratz <ToddKratz@chevron.com>, Gary Rogers <gary_rogers@revenue.state.ak hur Copoulos <Arthur_Copoulos@dnr.state.ak.us>, Ken <ken@secorp-inc.com>, Steve Lambe bert@unocal.com>, Joe Nicks <news@radiokenai.com>, Jerry McCutcheon <susitnahydronow@yahoo.com>, Paul Todd <paulto@acsalaska.net>, Bill Walker 10f2 5/2/2006 10:36 AM CO 505A and AIO 26A e e <bill-wwa@ak.net>, Iris Matthews <Iris_Matthews@legis.state.ak.us>, Paul Decker <paul_decker@dnr.state.ak.us>, Rob Dragnich <ro agnich@exxonmobi1.com>, Aleutians East Boro admin@aleutianseast.org arquerite kr <marguerite_kremer@dnr.state.ak.us>, Robert Brelsobert.Bre1sford@arg iagroup.com> 'cia Konsor <alicia_konsor@dnr.state.ak.us>, Mike <mike@kbbi.org>, d Robinson <gb ·nson@marathonoi1.com>, Cammy Taylor <Cami law.state.ak.us 'nton GAubert n_aubert@admin.state.ak.us>, Thomas E de _maunder@admin. te.ak.us>, Stephen F Davies <steve_davies@admin.state.ak.us>, Kei Wiles <kwiles@marathonoi1.com>, Cynthia B Mciver <bren_mciver@admin.state.ak.us> ontent- Type: application/pdf ontent-Encoding: base64 I r Content-Type: application/pdf ¡AI026A.pdf Content-Encoding: base64 I 20f2 5/2/200610:36 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 Ànchorage, 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 e 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 e 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 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, W A 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 e 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 e 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 ~~ 0 d a a SARAH PALIN, GOVERNOR lZi~[>•-7~ OIIl ~ GAS 333 W. 7th AVENUE, SUITE 100 C01~5ERQA7'IO1~T COMhIIS5I01'1T ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 ADMINISTRATIVE APPROVAL CO SOSA.001 (ORION OIL POOL) ADMINISTRATIVE APPROVAL AIO 26A.002 (ORION OIL POOL) ADMINISTRATIVE APPROVAL CO 471.007 (BOREALIS OIL POOL) Mr. Frank Paskvan GPB Western Region Resource Manager BP Exploration (Alaska) Inc. P.O. Box 196612 Anchorage, AK 99519-66612 RE: Application for Modification of Conservation Order SOSA and Area Injection Order 26A, Orion Oil Pool and Commission Motion to Amend Conservation Order 471, Borealis Oil Pool to Authorize Commingled Miscible Injectant (MI) Injection and Approve a Method for Allocating MI Injection Between the two Pools Dear Mr. Paskvan: In accordance with Rule 13 of Conservation Order (CO) SOSA, Rule 10 of CO 471, and Rule 11 of Area Injection Order (AIO) 26A, the Alaska Oil and Gas Conservation Commission (Commission) administrative approves the commingled injection of miscible injectant (MI) in the Prudhoe Bay Unit (PBU) L-103 and PBU V-105 wells in the Orion and Borealis Oil Pools. By letter dated August 21, 2008, and received by the Commission on August 22, 2008, BP Exploration (Alaska) Inc. (BPXA) requested that the Commission amend CO SOSA and AIO 26A to allow commingled injection of MI in some wells that are approved for the commingled injection of water. Because the application involves commingled injection within two oil pools, it should also have addressed CO 471. Therefore, the Commission, on its own motion, is considering BPXA's application as an application to amend CO 471, as well. Rule 3 of AIO 26A and Rule 2 of AIO 24B authorize the injection of MI into the Orion and Borealis Oil Pools, respectively. Rule 8 of CO SOSA, Rule 6 of AIO 26A, and Rule 8 of CO 471 authorize the commingled injection of water in these pools. BPXA requests the elimination of the reference to water in Rule 8 of CO SOSA, Rule 6 of AIO 26A, and Rule 8 of CO 471 so that other approved fluids can be injected in the commingled injectors. BPXA specifically requests authorization to inject MI into two commingled injectors: the PBU L-103 and P$U V-105 wells. Both wells are classified as water alternating gas injection wells and, as such, have been approved for MI injection. The wells have also been approved for use as commingled water injection wells. Both wells have been used for commingled water injection and are being used for MI injection into the Borealis Oil Pool; the Orion Oil Pool was CO SOSA.001; AIO 26A.002,;'CO 471.007 November 10, 2008 Page 2 of 2 shut-off in these wells. Therefore, the wells appear to have the necessary mechanical integrity to be used as commingled MI injection wells. BPXA also requests approval of a method of allocating MI injection volumes between the two pools by means of a downhole regulator valve that shows a very distinct correlation between injection pressure and. MI flow rate. BPXA also proposes to conduct injection profiles in these wells on a routine basis to ensure that the correlation between the injection pressure and MI flow rate remains valid. The proposed allocation methodology described by BPXA in the August 21, 2008, application will provide adequate results. Accordingly, with the conditions below, Rule 8 of CO 471, Rule 8 of CO SOSA, and Rule 6 of AIO 26A are amended to remove the word "water": these amendments do not promote waste or jeopardize correlative rights, are based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. Conditions: 1) Commingled MI injection is authorized for the PBU L-103 and PBU V-105 wells only. The Commission will consider approving commingled MI injection for other wells by administrative action upon application by the operator. 2) MI injection in the wells must be allocated to the subject pools in accordance with t~- i~~t. method BPXA proposed in its August 21, 2008 application. ~~,=-°"~`~~~ . All other terms and conditions of the affected orders remain unchanged. ` t '` ' f~ ~ ~ a ' ~ f. ~' `~` ~ _ ENTERED at Anchorage, Alaska, and dated November 10, ~ ~' , .o w 1 ~a '~~,,a ,o . s.., .. M,..•^° Daniel T. Seamount, Jr. Cathy . Foerster n ~. Norman Chair Com issioner Comm'~ner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the Commission grants for good cause shown, a person affected by it may file with the Commission an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The Commission shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the Commission denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the Commission grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the Commission, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision on reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited to the questions presented to the Commission by the application for reconsideration." In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday Mary Jones David McCaleb Cindi Walker XTO Energy, Inc. IHS Energy Group Tesoro Refining and Marketing Co. Cartography GEPS Supply & Distribution 810 Houston Street, Ste 2000 5333 Westheimer, Ste 100 300 Concord Plaza Drive Ft. Worth, TX 76102-6298 Houston, TX 77056 San Antonio, TX 78216 George Vaught, Jr. Jerry Hodgden Richard Neahring PO Box 13557 Hodgden Oil Company NRG Associates Denver, CO 80201-3557 408 18th Street President Golden, CO 80401-2433 PO Box 1655 Colorado Springs, CO 80901 Mark Wedman Schlumberger Ciri Halliburton Drilling and Measurements Land Department 6900 Arctic Blvd. 2525 Gambell Street #400 PO Box 93330 Anchorage, AK 99502 Anchorage, AK 99503 Anchorage, AK 99503 Baker Oil Tools Ivan Gillian Jill Schneider 4730 Business Park Blvd., #44 9649 Musket Bell Cr.#5 US Geological Survey Anchorage, AK 99503 Anchorage, AK 99507 4200 University Dr. Anchorage, AK 99508 Gordon Severson Jack Hakkila Darwin Waldsmith 3201 Westmar Cr. PO Box 190083 PO Box 39309 Anchorage, AK 99508-4336 Anchorage, AK 99519 Ninilchick, AK 99639 James Gibbs Kenai National Wildlife Refuge Penny Vadla PO Box 1597 Refuge Manager 399 West Riverview Avenue Soldotna, AK 99669 PO Box 2139 Soldotna, AK 99669-7714 Soldotna, AK 99669-2139 Richard Wagner Cliff Burglin Bernie Karl PO Box 60868 PO Box 70131 K&K Recycling Inc. Fairbanks, AK 99706 Fairbanks, AK 99707 PO Box 58055 Fairbanks, AK 99711 North Slope Borough PO Box 69 Barrow. AK 99723 ~~~/d i~~i2~P • ~ Page 1 of 1 Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Wednesday, November 12, 2008 10:33 AM Subject: co505A-001 (Orion) aio26A-002 (Orion) co471-007 (Borealis) erio3-001 (West McArthur River) Attachments: erio3-001.pdf; co505A-001 A1026A-002 CO 341-007.pdf BCC:'Aaron Gluzman'; caunderwood@marathonoil.com; 'Dale Hoffman'; Fridiric Grenier; 'Joe Longo'; 'Lamont Frazer'; Marc Kuck; 'Mary Aschoff; Maurizio Grandi; P Bates; Richard Garrard; 'Sandra Lemke'; 'Scott Nash'; 'Steve Virant'; Tom Gennings; 'Willem Vollenbrock'; 'William Van Dyke'; Woolf, Wendy C (DNR); 'Aleutians East Borough'; 'Anna Raff; 'Barbara F Fullmer'; 'bbritch'; 'Bill Walker'; 'Brad McKim'; 'Brandon Gagnon'; 'Brian Gillespie'; 'Brian Havelock'; 'Brit Lively'; 'Bruce Webb'; 'buonoje'; 'Cammy Taylor'; 'Cande.Brandow'; 'carol smyth'; 'Cary Carrigan'; 'Charles O'Donnell'; 'Chris Gay'; 'Cliff Posey'; 'Dan Bross'; 'dapa'; 'Daryl J. Kleppin'; 'David Brown'; 'David Hall'; David House; 'David L Boelens'; 'David Steingreaber'; 'ddonkel'; 'Deborah J. Jones'; 'doug_schultze'; 'Eric Lidj i '; 'Evan Harness'; 'eyancy'; 'foms2@mtaonline.net'; 'Francis S. Sommer'; 'Fred Steece'; 'Garland Robinson'; 'Gary Laughlin'; 'Gary Rogers'; 'Gary Schultz'; 'ghammons'; 'Gordon Pospisil'; 'Gregg Nady'; 'gregory micailef; 'gspfoff; 'Hank Alford'; 'Harry Engel'; 'jah'; 'James Scherr'; 'Janet D. Platt'; 'jejones'; 'Jerry McCutcheon'; 'Jim Arlington'; 'Jim White'; 'Jim Winegarner'; 'Joe Nicks'; 'John Garing'; 'John S. Haworth'; 'John Spain'; 'John Tower'; 'John W Katz'; johnny.aiken@north-slope.org; 'Jon Goltz'; 'Julie Houle'; 'Kari Moriarty'; 'Kaynell Zeman'; 'Keith Wiles'; knelson@petroleumnews.com; 'Krissell Crandall'; 'Kristin Dirks'; 'Laura Silliphant'; 'Lois'; 'Lynnda Kahn'; 'mail=akpratts@acsalaska.net'; 'mail=fours@mtaonline.net'; 'Marilyn Crockett'; 'Mark Dalton'; 'Mark Hanley'; 'Mark Kovac'; 'Mark P. Worcester'; 'Marquerite kremer'; 'Matt Rader'; Melanie Brown; 'Mike Bill'; 'Mike Mason'; 'Mikel Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; 'Nick W. Glover'; NSK Problem Well Supv; NSU, ADW Well Integrity Engineer; 'Patty Alfaro'; 'Paul Decker'; 'Paul Winslow'; Pierce, Sandra M (DNR); 'Randall Kanady'; 'Randy L. Skillern'; 'rcrotty'; Rice, Cody J (DNR); 'rmclean'; 'Rob McWhorter '; rob.g.dragnich@exxonmobil.com; 'Robert Campbell'; 'Robert Fowler'; 'Robert Province'; 'Roger Belman'; 'Rudy Brueggeman'; 'Scott Cranswick'; 'Shannon Donnelly'; 'Sharmaine Copeland'; 'Sondra Stewman'; 'Sonja Frankllin'; 'Stan Porhola'; 'stanekj'; 'Steve Lambert'; 'Steve Moothart'; 'Steven R. Rossberg'; 'tablerk'; 'Tamera Sheffield'; 'Temple Davidson'; 'Terrie Hubble'; 'Tim Lawlor'; 'Todd Durkee'; Tony Hopfinger; 'trmjrl'; 'Walter Featherly'; 'Walter Quay'; 'Wayne Rancier'; Birnbaum, Alan J (LAW); Crisp, John H (DOA); Davies, Stephen F (DOA); Fleckenstein, Robert J (DOA); Foerster, Catherine P (DOA); Grimaldi, Louis R (DOA); Johnson, Elaine M (DOA); Jones, Jeffery B (DOA); Laasch, Linda K (DOA); Mahnken, Christine R (DOA); Maunder, Thomas E (DOA); McIver, C (DOA); McMains, Stephen E (DOA); Noble, Robert C (DOA); Norman, John K (DOA); Okland, Howard D (DOA); Paladijczuk, Tracie L (DOA); Pasqual, Maria (DOA); Regg, James B (DOA); Roby, David S (DOA); Saltmarsh, Arthur C (DOA); Scheve, Charles M (DOA); Seamount, Dan T (DOA); Smith, Chasity R (DOA); Williamson, Mary J (DOA) Attachments:erio3-OO1.pdf;co505A-001 AI026A-002 CO 341-007.pdf; Jody J. Colombie Special Assistant to the Commission Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 (907) 793-1221 Direct Line (907) 276-7542 Fax 11/12/2008 ~7 by BP Exploration (Alaska) Inc. 900 East Benson Boulevard P. 0. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 1l ..` August 21, 2008 Daniel T. Seamount, Jr. Chairman Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 BUG ~ ~ zC~ Alaska Oii & Gas Cn~s. ~.`~mmssior Anchor! RE: Application for Modification of Conservation Order 505A and Area Injection Order 26A, Orion Oil Pool Application for Commission Approval on Method of MI Commingled Injection Allocation Dear Chairman Seamount: BP Exploration (Alaska), Inc. (BPXA), operator of the Prudhoe Bay Unit (PBU), on behalf of itself and the other the PBU Working Interest Owners, requests modification of Conservation Order No. 505A (CO 505A) and Area Injection Order No. 26A (A1O 26A) to allow for the injection of miscible injectant (MI) into multiple completion injection wells (commingled Borealis/Orion injectors) to enhance recovery from the Orion Oil Pool. A1O 26A and CO 505A allow for injection of enriched hydrocarbon gas into the Orion Oil Pool, but current language limits Orion Oil Pool injection into "commingled" injection wells to water only. These commingled wells have provided important Orion reservoir support while injecting water, but recently have been shut-in to the Orion interval while the Borealis interval is on the MI portion of its WAG cycle. Modification of these orders to allow for Orion MI injection into "multiple completion" injectors will greatly improve their utility in supporting the Orion reservoir. BPXA's January 23, 2006 request to allow MI injection into the Orion Oil Pool inadvertently overlooked the commingled well language limiting injection to water only. Use of these wells in a WAG injection capacity is part of our depletion plan to maximize Orion Oil Pool recovery. BPXA proposes modifications to A1O 26A Rule 6 and CO 505A Rule 8 by removing the limiter "water" from the references to "water injectors". The title of these rules and subsection (a) would be amended to read as follows: • • Multiple Completion of Infection Wells a. Injectors may be completed to allow for injection in multiple pools within the same wellbore so long as mechanical isolation between pools is demonstrated and approved by the Commission. In addition, BPXA seeks Commission approval of a method for allocating MI injection fluids as required by A10 26A Rule 6(b) and CO 505A Rule 8(b). A detailed description of equipment testing to accurately regulate MI injection between Pools, and an allocation method proposal are enclosed. Although the Commission has approved the one-quarter mile mechanical condition of the commingled injectors, attached is a new area-of-review that revisits the prior analysis and includes recent penetrations. At this time, commingled injection is requested in two injectors, L-103 and V-105, so the review focuses on these wells. Should you have any questions regarding this request, please contact me at 564- 5749 or Taylor West at 564-4647. Thank you for your timely consideration of this request. Sincerely, ~~~~~ r rr~n GPB Western Region Resource Manager Enclosures CC: Sonny Rix (ExxonMobil) Dan Kruse (CPAI) Glenn Frederick (Chevron) Paul Winslow (Forest Oil) Claire Sullivan (BPXA) Sherri Gould (BPXA) David Lenig (BPXA) Taylor West (BPXA) • • Discussion: Commingled Infector Background: The Commission determined in A10 26 Finding 9 that five Borealis wells were mechanically competent to be used for commingled injection into the Borealis Oil Pool and the mechanically-straddled Orion Oil Pool: L-103, L-111, L-115, L-117, and V-105. In 2003, BPXA demonstrated a method to mechanically split water injection between zones using a Schlumberger downhole waterflood regulating valve (WFR) installed adjacent to the straddled Orion interval. The WFR regulates water injection volume to a high degree of accuracy across a broad range of injection pressure. The Commission subsequently approved the injection allocation method in accordance with A10 26, Rule 7(b), and CO 505 Rule 8(b), after which commingled water injection began in three commingled injectors: L-103, L-117, and V-105. In the last year, these injectors, which are permitted for WAG injection, have begun miscible injectant (MI) injection into the Borealis Pool, which required the shut-off of the Orion interval. Approval of MI injection into the Orion interval in these wells is needed in order to maintain proper reservoir voidage and injection support. MI regulating valve qualification: A test was run in the summer of 2007 on a different style of replaceable downhole regulator valve designed for gas injection applications. The valve, supplied by Schlumberger under the name "NOVA", is a highly engineered venturi that produces a linear injection rate profile across a wide range of injection pressures. The valve has no moving parts, and would be installed in aside-pocket mandrel adjacent to the Orion straddled interval. The valve's behavior is well understood by the manufacturer under dry gas applications, but not in a MI application due to the unique properties of enriched hydrocarbon gas. To determine this, a NOVA valve was installed in Orion injector L-2131, which at the time was on MI injection, and then a number of step-rate injection tests were performed to characterize the regulating behavior on MI injection. Data from the injection test is shown in Figures 1 and 2. The step-rate tests confirmed that the valve controlled the injection rate in a linear fashion across the range of injection pressures expected in the commingled injectors. A simple pressure vs. rate correlation was derived, and if applied to the average daily wellhead injection pressure on a commingled injector, would yield an accurate allocation split between the Orion and Borealis intervals. BPXA proposes to install a NOVA valve in the straddled Orion interval of a commingled MI injector, thereby accurately regulating the flow of MI gas to the lower-pressured Orion interval. At month-end, the BP pad engineer will allocate injection between the pools using the simple rate/pressure algorithm. • Figure 3 shows a hypothetical example of this calculation using historical MI injection data from commingled injector L-103. Currently, only a single NOVA valve size has been characterized, but it is expected to cover the desired injection rates, and therefore no qualifications of other valve sizes are planned. Periodic injection profile logs are also proposed in order to confirm the ongoing performance of the NOVA valve. 1) In wells approved for commingled MI injection, BP will use a NOVA valve to regulate MI flow into the Orion Pool. 2) Daily allocation of injectant volumes between Pools will be calculated as a function of average daily wellhead injection pressure. 3) BP will verify calculated injection splits by obtaining an injection profile within three months of the start of MI commingled injection, and then approximately every 6 months thereafter as long as commingled MI injection continues. L-213 MI NOVA Valve Test - 8/64 orifice 3500 3000 2500 N a d 7 2000 tl! v ~ 1500 0 1000 500 0 ~-- 6/29/07 12:00 • inj pressure ^ MI flow 6/30/07 6/30/07 7/1/07 7/1/07 7/2/07 7/2/07 0:00 12:00 0:00 12:00 0:00 12:00 Tim e 2.5 2 0 a LL N 1.5 ~ d 3 0 1 ~ -' 0.5 7/3/07 0:00 Figure 1 - L-213 NOVA Valve Step-Rate Test Data L-213 MI NOVA Valve Test - 8/64 Orifice 3 --.. - ------- - - l I 2.5 a ~ ~~`~ v =-M . _ _ . w 2 ~, ..- - ~ ~ ~ ~. d is 1.5 ~ ~ - _ _ _ _ _ _ _ _ - c ° MI injection rate = 0.0005 x injection pressure + 0.7589 ~~ m 1, 'c ~ i III 0.5 i-- -- -I 01 I 1000 1500 2000 2500 3000 3500 Injection pressure psi Figure 2 -NOVA Rate Algorithm Orion L-103 L-103 Gas Inj Vol Metered Wellhead Pres (via Nova) MSCFPD PSI MSCFPD 2,168 2,361 1954 2,110 2,317 1932 4,652 2,376 1962 2,830 2,342 1945 3,182 2,336 1942 3,290 2,322 1935 2,978 2,315 1931 3,888 2,329 1938 8,128 2,669 2108 13,036 2,705 2126 11,838 2,722 2135 10,862 2,725 2136 10,834 2,727 2137 11,114 2,757 2152 9,890 2,724 2136 9,142 2,734 2141 9,544 2,741 2144 9,832 2,761 2154 Orion injection volume = 0.5 x injection pressure + 759 Borealis Orion Gas Fraction MSCFPD 214 90% 178 92% 2,690 42% 885 69% 1,240 61 1,355 59% 1,047 65% 1,950 50% 6,020 26% 10,910 16% 9,703 18% 8,726 20% 8,697 20% 8,962 19% 7,754 22% 7,001 23% 7,400 22% 7,678 22% Borealis injection volume =total well metered volume metered -Orion gas Figure 3: Hypothetical Calculation Using Historic Pressure and Rate Data • • Infector mechanical isolation area of review C~ n BP proposes MI injection into the Orion interval of V-1051 and L-1031. Both wells were found to be in compliance with 20 AAC 25.030 per Area Injection Order 26, Finding 9. All wells show good mechanical isolation at the Orion interval. Zonal isolation status of wellbores within one-quarter mile of V-105i is summarized below (see Figure 4): Well Date Drilled Distance from in'ector TOC TOC Determination Method Top Pool (Na sand) Top Injection Sand (OA) Coverage/ Comments V-105 8-02 0 4600' and Cement l0 5204' and 5993' and 600' and above ool V-106a 10-04 526 4496' and Calculated, w/30% excess 5275' and 5495' and 779' and above pool V-07 12-07 730 3120' and Cement l0 5075' and 5266' and >1900' and above the ool V-222i 6-07 857 3720' and Cement l0 4543' and 4722' and 823' and above ool V-202 5-03 1244 NA NA NA NA Offset Orion Producer V-204 7-04 1034 NA NA NA NA Offset Orion Producer Note: V-105 was cemented in two stages, with the base of good Schrader cement at 5803' md, 156' below the lowermost injection sand (OBd). Zonal isolation status of wellbores within one-quarter mile of L-103i is summarized below (see Figure 5): Well Date Distance TOC TOC Top Pool Top Injection Coverage/ Comments Drilled from Determination (Na sand) Sand (OA) in'ector Method L-103i 7-02 0 4460 Cement l0 5636' and 5892' and 1176' and above ool L-120 2-02 239' 5099 Calc w/30% 5675' and 5961' and 576' and above pool excess L-201 3-04 918' NA NA NA NA Offset Orion Producer Orion V Pad Area Well V-105 114 Mile Radius Map Structure on Top OA sand V-222 Well within 114 mile of V-105 at Schrader Pool level. Figure 4 - V-105i'/a mile radius map • • • Top Na Sand (Top Schrader Bluff Pool) Well V-105 • Top OA Sand 1/4 Mile • Base OBf Sand (Base Schrader Bluff Pooh Radius ClfCle Qrion L Pad Area • Top Na Sand (Top Schrader Bluff Pool) • Top OA Sand ~ Base OBf Sand (Base Schrader Bluff Pool) Well L-103 1/4 Mile Radius Circle L-120 Well within 114 mile of L-103 at Schrader Pool level. Figure 5 - L-103 '/a mile radius map ~ • Well L-103 1 /4 Mile Radius Map Structure on Top OA sand ·~6 Prudhoe Bay Field - Annual Surveillance Reporting Requirements to AOGCC Group 1 IPA Group 2 GPMA Group 3 Satellites - -~---~..,.__..,...._--------_... --------- t-------- - --- Annual Surveillance Report 15-Mar 15-Jun 15-Sep 1------- --------.------------~ I-------------_._-~~ - - -----------~ _.._--._._-~-_._._--_."--~-_.._,---_.._-_._--- -----------~----- 1---------------------- Annual Overview Presentation 22-Mar 22-Jun 22-Sep ------------------~ .---- -- ----.,---.'--.- ---------- .--- - --- Production Period to be Covered Jan 1-Dec 31 Apr 1-Mar 31 Jul 1-Jun 30 Amends Order/Rule Group 1 - IPA OilJ:»_()~I~_________ ~...~--,--"._--,._--~-_.- Prudhoe Oil Pool C0341 D Rule 11 ----, , _..___,...________.,._._._______._______~_ __ ~__~,_,_~.._._.,_. .________ o'·__n.'_...'·__ Put River Oil Pool C0559 ºr()IJ.e.2:-ºPIVI~_OiL~~()ls__________ _ Order Date 11/30/2001 11/22/2005 . Comment Note C0341 E (modified Pool Definition to include a portion of Put River Sandstone) Corrected 2/14/2006 ---._~-'----~---'--- -,._,--------~--_._--_.- ----------_.-. __~o rule on Su~eillance repo!!s Lisburne C0207, 207 A _.._.__._---------,----~ - -_.__.._._--------_.~-_._------_.. --- Niakuk C0329A Rule 9 .--.-------..... ...__.'. --.. . -". ---~----"'-''"'-,---~.-._~- --.....--.--- . _~_____________~.Jorth_~ædho~ Bay C0345 Rule 8 __________?t. ~clntyre ____-º0317B Rule 15 Raven Oil Pool C0570 Rule 10 - -.----.- ..._~..----_.~--------~--_._~._.~----_.__..._-~_._.~-.~.~ West Beach Oil Pool C0311 BRule 13 ._---~-----_._- 6/4/1996 12/16/1994 4/19/2000 8/9/2006 ~._._-_. 8/1/2000 4~=-~-=-=- - . ---- . º~~IJP _ ~__-_J:»!udh~!..ª-~telli!~ O~~~ool!S_ _____________~_____ _______~____~_________________________ .... _,6.lJ!ora__-ºº~57B .B.uJ~ª______~_?125/200.±________.J..corrected 8/9/2004) Boreallis C0471 Rule 4 5/29/2002 ._.._.,____.___'.._.._.___.n'.._.__."._'''______ ~~___._____..____.____.".__.~.___._ ___~_.~~_ ._._~lci.~i9_~!.ªIJ.!'~_ C0452 Rule 11 ____m____ 11/15/2000 Orion C0505A Rule 9 4/28/2006 __.._____.__~_.. ___.___~_ _ __________ ____..._..__..,__.___________.__ ____._~________._._.m___~_ Polaris C0484A Rule 9 11/3/2005 _....._--_...__._--~---_._-----~----,,---.__._~---_......._._-~--.- __ +__m_______ ____ ____ ~___....__________L_____.. _ ____._._..__ .. ..__.__________________~,_.___ I l.... ,. ...... l.... ., -- ~~_. ............. _....~_£.._- ..-t''''.... --"'-""jJ . . Subject: [Fwd: [Fwd: Re: surveillance report dates]] From: Jane Williamson <jane _ williamson@admin.state.ak.us> Date: Fri, 20 Apr 2007 13:03:59 -0800 To: Jody J Colombie <jody_colombie@admin.state.ak.us>, Dave Roby <dave_roby@admin.state.ak.us>, Cathy P Foerster <cathy _ foerster@admin.state.ak.us>, Alan J Birnbaum <alan _ birnbaum@law.state.ak.us> cc: Stephen E Mcmains <steve_mcmains@admin.state.ak.us>, art Saltmarsh <art_saltmarsh@admin.state.ak.us>, Thomas E Maunder <toID_maunder@admin.state.ak.us> There is something I didn't get around to before I left and that was to administratively amend the cas for PBU to include reporting dates agreed to verbally with BP (and DNR). Really, only pt. McIntyre and Borealis have the wrong dates in the eo's. The others are either ok, or not explicit. Attached are the COs affected. I'm not sure how you want to handle. Jody. Please put this in the following CO files along with the attachment. Group I - IP A Oil Pools Prudhoe Oil Pool C0341D Put River Oil Pool C0559 Group 2 ~ GPMA Oil Pools Lisburne C0207, 207 A Niakuk C0329A Rule 9 North Prudhoe Bay C0345 Pt. McIntyre C0317B Raven Oil Pool C0570 West Beach Oil Pool C0311B Group 3 - Prudhoe Satellite Oil Pools Aurora C0457B Boreallis C0471 Midnight Sun C0452 Orion C0505A Polaris C0484A -------- Original Message -------- Subject:Re: surveillance report dates Date:Thu, 31 Aug 2006 17:27:45 -0800 From:Jane Williamson <iane williamson(a!admin.state.ak.us> Organization:State of Alaska To:Lenig, David C <David.Lenig(Cl?bp.com> References:<CBF4D8E92B5A 70479F64416582F6A 17CB81 AEO(a!bp 1 ancex005.bp 1.ad.bp.com> Oops Lenig, David C wrote: Hi Jane, 100 4/23/2007 9:50 AM LA ..-. LA ,..... .."-....~.............. . ""'-'-""-....--..... ..-t'.......-'-... -.........uJJ . . didn't get the attachrnent David From: Jane Williamson Sent: Thursday, August 31, 2006 5: 14 PM To: Lenig, David C Subject: Re: surveillance report dates E-mail is fine. Attached is a list of the pools and orders/rules that will be amended with the Admin approval. Take a look and see if this looks right to you. (Note, I'm only listing the rules that are affected by the new dates - there may be additional amendments unrelated to the surveillance requirements that I've not listed.) I'm flexible on the date for the Overview presentation. I'd be fine with specifying it to be within one or two months of the report date rather than the POD overview that you've noted. What would you prefer? Lenig, David C wrote: Jane, Here is a table showing the dates for the various Reports and Presentations. I've added the production period as well. The IPA review date remains problematic due to the proximity to spring break but we seem to work around it each year. Would you prefer that I put this in a letter requesting the changes? I know we talked about this a little while ago I just haven't found the time. Thanks, David Plan of Development Production Period Jull-Jun30 IPA GPMA March 15 June 15 September 15 March 22 June 22 September 22 March 30 June 30 September 30 Janl-Dec31 Aprl-Mar31 Satellites Annual Surveillance Report Annual Overview Presentation -----Original Message----- From: Jane Williamson [mailto:jane williamson@ad~in.state.ak.us] Sent: Thursday, August 31, 2006 2:30 PM To: Lenig, David C Subject: surveillance report dates Hi David. When you get a second, could you please send back an e-mail that lists all the surveillance report dates that we've agreed to for all PBU pools (including GPMA)? Also, do you have dates for surveillance reviews? I'll go through the list and make sure the Conservation orders are correctly worded, then put out administrative amendments as necessary. I checked with Cammy and she said an e-mail is fine for starting the 20f3 4/23/2007 9:50 AM l' ..-. L"'- ........ -"-~_......-... ............-.....-.... ~-r.......... --..-.....JJ . administrative action process. . Thanks. Jane "\JVi Hian1S0Rl" <i ane ,,;.villiaD.lsorl(~adT(liTl. state. alc. us> Senior Reservoir Engineer (907) 793-1226 Alaska Oil and Gas Conservation Commission Content-Type: application/vnd.ms-excel surveillance report.xls Content-Encoding: base64 3 on 4/23/2007 9:50 AM *5 [Fwd: Re: Request Surveillance reporting peri.arificatiOn] . ! Subject: [Fwd: Re: Request Surveillance reporting period clarification] From: Jane Williamson <jane _ williamson@admin.state.ak.us> Date: Thu, 31 Aug 2006 13:37:23 -0800 To: Jody J Colombie <jody_colombie@admin.state.ak.us> CC: Cathy P Foerster <cathy_foerster@admin.state.ak.us>, Camille <cammy _ taylor@law.state.ak.us> Please put this e-mail in the CQ 505a and C0484A files. -------- Original Message -------- Subject:Re: Request Surveillance reporting period clarification Date:Thu, 31 Aug 200613:33:53 -0800 From:Jane Williamson <jane williamson(a!admin.state.ak.us> Organization:State of Alaska To:West, Taylor <Taylor.West(a!bp.com> CC:Sullivan, Claire (Claire.Sullivan(a!BP.com) <Claire.Sullivan(2~bp.com>, Bajsarowicz, Caroline J <Caroline.Bajsarowicz(a!bp.com>, Holloway, Emberley L <Emberley.Holloway(a!bp.com>, Lenig, David C <David.Lenig(a!bp.com> References:<C I1D74A5F 1 DF 194DB3A9ADF 4DBC4EDEOC9B99D(a!bp lancex005.bp l.ad.bp.com> Taylor, Yes, both reports will be due on September 15 each year, and both reports for this year should cover July 1, 2005-June 30, 2006. The requirement to report on the period from January 2005-June 2006 was in error as you had provided that information in last years report. Thanks so much for bringing this to my attention. Jane West, Taylor wrote: 10f2 8/31/20062:03 PM [Fwd: Re: Request Surveillance reporting peri.arificatiOn] . . I Jane: " Per our phone conversation today, I would like Commission clarification on two annual surveillance report requirements: 1. Orion (CO 505A) Rule 9 states: "An annual report must be filed by September 15... .must include... surveillance information for the period July 1 of the prior calendar year through June 30 of the current calendar year (except the report due on September 15.2006 must cover the period from January 2005 through June 30. 2006)" The last Orion Surveillance report submitted to the Commission on September 15, 2005 covered the period September 1, 2004 through July 31, 2005. Would it be acceptable for the current report to cover the period July 1. 2005 through June 30. 2006? This will keep Orion aligned with the other satellite assets, and will actually provide a one month (July 2005) overlap with last year's report. It's not clear to me if there is value in restating the Jan 2005 through June 2005 data in the current report. 2. Polaris (CO 484A) Rule 9 contains the historic reporting language: "The report (covers)... the prior calendar year". Please confirm that the current report should cover the period July 1. 2005 through June 30. 2006 per prior conversations, and in keeping all satellite assets aligned. As with Orion, the current report will overlap last year's report by one month. Thanks Taylor West Production Engineer BP Exploration (Alaska), Inc. Greater Prudhoe Bay - Polaris I Orion Viscous Oil 907.564.4647 907.632.0111 cell 907.564.5016 (fax) WestTL~bp.com Jane Williamson, PE <jane wilIiamson(a!admin.state.ak.us> Senior Reservoir Engineer (907) 793-1226 Alaska Oil and Gas Conservation Commission 20f2 8/31/20062:03 PM #4 RE: Hearing vacated . . Subject: RE: Hearing vacated From: "Paskvan, Frank A" <Frank.Paskvan@bp.com> Date: Thu, 30 Mar 2006 15:25:45 -0900 lliamson <j illiamson illi >, "SuI " <Gary. ould@bp.co CC: J J Colombie <bob _ crandall@admin. Jane, Thank you very much for the update i.e. Orion AIO mod hearing vacated. If any outstanding questions arise, please let us know. RE item IV-4 confidentiality, 2 years is sufficient. As an FYI, you probably already know this, but we're in the process of GC-2 production restart. You may notice in well production that actually already a couple of Kuparuk sats wells alreadly are being flowed now. These are to slowly warmup production pipelines prior to full restart. Their production is routed into GC-l, not GC-2, for processing. MI and Water injection has been continued at GC-2 although at a lower than typical levels since we don't have GC-2 produced water to inject. Injection water comes from GC-1 via waterwheel. We're warming up the gas lift system by bullheading gas into an Orion and Polaris producer. We might see GC-2 itself processing oil as early as Sunday, but expect it will be some time before full capacity is restored. . . Regards, Frank Paskvan -----Original Message----- From: Jane Williamson [mailto:jane williamson@admin.state.ak.us] Sent: Wednesday, March 29, 2006 11:41 AM To: Paskvan, Frank A¡ Williams, Jonathan 0 Cc: Jody J Colombie¡ Robert P Crandall Subject: Hearing vacated Frank and Jonathon, The hearing on Orion is vacated. One item we need for our records. How long are you requesting IV-4 to be held confidential? Jane 1 of 1 3/30/20063:37 PM #3 Hearing vacated ~ . Subject: Hearing vacated From: Jane Williamson <jane _ williamson@admin.state.akus> Date: Wed, 29 Mar 2006 11 :41:00 -0900 FrankA" <Pask Frank and Jonathon, The hearing on Orion is vacated. One item we need for our records. How long are you requesting IV-4 to be held confidential? Jane Jane Williamson, PE <iane williamson(Q}admin.state.ak.us> Reservoir Engineer Alaska Oil and Gas Conservation Commission 1 of 1 3/29/20061:15 PM #2 ---------..---- STATE OF ALASKA . NOTICE TO PUBLISHER . ADVERTISING ORDER NO. ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING AOVERTISING ORDER NO., CERTIFIED AO-02614029 AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE SEE BOTTOM FORINYOICEADDRESS ·c F AOGCC AGENCY CONTACT DATE OF A.O. R 333 W 7th Ave, Ste 100 Jodv Colombie March 1, 2006 0 Anchorage, AK 99501 PHONE PCN M - (907) 791 -1221 DATES ADVERTISEMENT REQUIRED: T Anchorage Daily News March 2, 2006 0 PO box 149001 Anchorage, AK 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 legal~ 0 Display Classified DOther (Specify) SEE ATTACHED SENDIN\1()I~l:l~T~F'l..lp~TEI AOGCC, 333 W. 7th Ave., Suite 100 I TOTAL OF ¡I PAGE 1 OF ALL PAGES$ TO .c c· < c· cc..· Anchora!!e_ AK 99';01 2 PAGES REF TYPE NUMBER AMOUNT DATE COMMENTS 1 YEN 2 ARD 02910 3 4 ¡::IN 4MnllNT c:v f".f". D~M If". 4f".f".T ¡::v NMR DIST UQ 1 05 02140100 73451 2 3 4 ,~ i/' / I~ I REQUISITI~~~Ã__ ( (tJËJw\ / "'. DIVISION APPROVAL: i ) '- ! \/ . . Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Prudhoe Bay Field Orion Oil Pool Application to amend Area Injection Order 26 and Conservation Order 505 By application dated February 23, 2006, BP Exploration (Alaska) Inc. as Unit Operator of the Prudhoe Bay Unit requested the Commission to amend Area Injection Order 26 and Conservation Order 505 to authorize underground injection of enriched gas into the Orion Oil Pool. The Orion Oil Pool of the Prudhoe Bay Field lies within Tl2N-RIOE, Tl2N-RllE, TllN- RIlE, Tl1N-RI2E, Umiat Meridian. The Commission has tentatively scheduled a public hearing on this application for April 6, 2006 at 9:00 am at the offices of the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentatively scheduled hearing be held by filing a written request with the Commission no later than 4:30 pm on March 17,2006. If a request for a hearing is not timely filed, the Commission may consider the issuance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221 after March 24, 2006. In addition, a person may submit a written protest or written comments regarding this application and proposal to the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Protests and comments must be received no later than 4:30 pm on April 3, 2006 except that if the Commission decides. to hold a public hearing, protests or comments must be received no later than the conclusion of the April 6, 2006 hearing. ho may need special accommodations in order to e contact the Commission's Special Assistant Jody Published Date: March 2, 2006 AO # 02614029 . Anchorage Daily News Affidavit of Publication . 1001 Northway Drive. Anchorage, AK 99508 PRICE OTHER OTHER OTHER OTHER OTHER ~ AD# DATE PO ACCOUNT PElt DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 735823 03/02/2006 02614029 STOF0330 $186.44 $186.44 $0.00 $0.00 $0.00 $0.00 $0.00 $186.44 . Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Prudhoe Bay Field Orion Oil Pool Application to amend Area I niectian Order 26 and Conservation Order 505 By application dated February 23, 2006, BP Explo- ration (Alaska) Inc. as Unit Operator of the Prud- hoe Bay Unit requested the Commission to amend Area Iniection Order 26 and Conservation Order 505 toauthori.¡;e underground iniectionof enriched gaS into the Orion Oil Pool. The Orion Oil Pool of the Prudhoe Bay Field lies within Tl2N·Rl0E, Tl2N-RllE, TlIN-RllE, TllN-RI2E, Umiat Merid- ian. STATE OF ALASKA THIRD JUDICIAL DISTRICT Christine Clark, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing u ication is not in excess of the rate charged private individua m(U /~ ~, Joo!t The Commission has tentativelysèheduled a pub- lic hearing on this applicatløn' and the Commission ~f~h~s~II~~k:g~11 a6~J~tsa:::~~é~~t~b~~( %r;rs~ sion at 333 West 7th Avenue, Suite 100, Ancharage, "'Ioska 99501. A person mov request that the tel1to- tivelv scheduled hearing be held by fllin ¡ èt wrlt- .ten request with the Commission no loter than 4::30 pm on Morch 17, 2006. If 0 request for a hearing is not timelv filed, the 'Commission may consider the issuonce of anor- der without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221 af- ter March 24, 2006. In addition, a person mav submit a written protest or written comments regarding this application and Proposal to the Alaska Oil and Gas Conserva· tion Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Protests and comments must be received no later than 4:30 pm on April 3, 2006 except that if the Commission decides to hold a public hearing, protests or comments must be received no later than the conclusion of the April 6, 2006 hearing. If vou are a person with a disabi¡itvwtK/J.may need special accommodations in ordef-to, comment or to attend the public hearing, pleaáec'òntact the Commission'.s Special Assistant"J!1dy,Calombie at 793-1221. " Is/: John K. Norman Chairman Si Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska AO #02614029 Published Date: March 2, 2006 Re: Public Notice . . Subject: Re: Public Notice From: "Ads, Legal" <legalads@adn.com> Date: Wed, 01 Mar 2006 15:16:08 -0900 To: Jody Colombie <jody_colombie@admin.state.ak.us> Hello Jody: Following is the confirmation information on your legal notice. Please review and let me know if you have any questions or need additional information. Account Number: STOF 0330 Legal Ad Number: 735823 Publication Date(s): March 2, 2006 Your Reference or PO#: 02614029 Cost of Legal Notice: $186.44 Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 On 3/1/06 9:38 AM, "Jody Colombie" <jody colombie@admin.state.ak.us> wrote: Please publish tomorrow. Jody Colombie Special Staff Assistant 1 of 1 3/1/2006 3 :31 PM 02-902 (Rev. 3/94) Publisherl riginal Copies: Department Fiscal, Departme , eceiving AO.FRM STATE OF ALASKA ADVERTISING ORDER $EEBOTTOM FOR]NVOICEADDRESS NOTICE TO PUBLISHER ADVERTISING ORDER NO. INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF AOVERTISEMENT MUST BE SUBMITTED WITH INVOICE AO-02614029 F R o M AOGCC 333 West ih Avenue. Suite 100 Anr.hnr::tup A K QQ~Ol 907-793-1221 AGENCY CONTACT .Indv ~ . PHONE (907) 791 -1221 DATES ADVERTISEMENT REQUIRED: DATE OF A.O. I M::tTrh 1 2006 PCN T o Anchorage Daily News PO box 149001 Anchorage, AK 99514 March 2, 2006 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Account # STOF0330 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 helshe 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 2005, and thereafter for _ consecutive days, the last publication appearing on the _ day of . 2005, 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 2005, Notary public for state of My commission expires 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, ID 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 M /\1 \v1o U ì ( )11 I Public Notice Prudhoe Bay Field Orion Oil PO'- . Subject: Public Notice Prudhoe Bay Field Orion Oil Pool From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 01 Mar 200609:39:57 -0900 To: undisclosed-recipients:; BCC: Cynthia B Mciver <br _ er@admin;stá in <robert mintz ak.us>, Christine Hansen .hansen@iogcc.state. s>,Te <hub ewman <StewmaSD@BP.com>;Scott & Cammy Tay ekj@unocal.com>, ecolaw <ecolaw@trustees.o shaneg evergree etto m>,cb n Donnell .us>, >, Mindy Lewis @yahoo.com>, ogers lof2 3/1/200610:21 AM Public Notice Prudhoe Bay Field Orion Oil po,- . .us>, Ken adiokenai.com> , I Walker leutians East te.ak.us>, Robert nr.state.ak.us>, i : Content- ce.pdfi i Content- '''/' ~ 20f2 3/1/200610:21 AM Public Notice . . Subject: Public Notice From: Jody Colombie <jody _ colombie@admin.state.ak.us> Date: Wed, 01 Mar 200609:38:11 -0900 To: Legal Ads AnchørâgeDai1y Please publish tomorrow. Jody Colombie Special Staff Assistant Content-Type: application/msword Order form.doc Content-Encoding: base64 Content-Type: application/msword Orion Public Notice.doc Content-Encoding: base64 1 of 1 3/1/2006 10:21 AM #1 r BP Exploration (Alaska), I. 900 East Benson Boulevard Post Office Box 196612 Anchorage, Alaska 99519-6612 Telephone (907) 561-5111 . ObP February 23, 2006 REceiVED FEB 2 7 2.006 Alaska Oil & Gas Cons. Commission Anchorage Commissioners Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 RE: Modifications to Conservation Order 505 and Area Injection Order 26 Orion Oil Pool - Prudhoe Bay Field Dear Commissioners: BP Exploration (Alaska) Inc. (BPXA) , operator of the Prudhoe Bay Unit (PBU), on behalf of itself and the other the PBU Working Interest Owners, requests modification of Conservation Order No. 505 (CO 505) and Area Injection Order No. 26 (AIO 26) to allow for the injection of miscible injectant necessary to enhance recovery from the Orion Oil Pool. Attached is a detailed description of the proposed CO 505 and AIO 26 modifications. BPXA also requests that all exhibits labeled "Confidential" be treated as confidential in accordance with the provisions of AS 31.05.035(d) and 20 AAC 25.537. Should you have any questions regarding this request, please contact Jonathan Williams at 564-5854. Sincerely, /~ <4L fJ~-- F~~~kvan ! GPB WEST Manager Attachments CC: Sonny Rix, ExxonMobil Dan Kruse, CPAI Paul Winslow, Forest Oil Gary Forsthoff, Chevron Jonathan Williams, BPXA Taylor West, BPXA Gary Gustafson, BPXA David Lenig, BPXA Jane Williamson, AOGCC Art Copoulos, DNR Application for orion. Injection Order Modification . 2/23/2006 Modification of Area Injection Order 26 Orion Oil Pool February 23, 2006 Area Injection Operations............. ................................. ..................................................... 2 Plat of Project Area......................................................................................................... 2 Operators/Surface Owners .............................................................................................. 2 Description of Operation......................................................................... ........................ 2 Geologic Information.......................................................................................... ............ 3 Mechanical Integrity of Injection Wells ......................................................................... 3 Injection Fluids.................... ....................................... .................................................... 4 Type of Fluid/Source...................... .......... .................................................................. 4 Composition and Compatibility with Formation and Confming Zones ..................... 4 Maximum Injected Rate........ .......................... ............................................................ 4 Injection Pressures.......................................................................................................... 4 Fracture Information........................................................................ ............................... 5 Formation Water Quality ................................................................................................ 5 Fresh Water Strata................................................................ ........ ............................... 5 Hydrocarbon Recovery ......................... ........... ....................................... ........................ 6 Surveillance Plan ................................................... ..................................................... 9 Mechanical Condition of Wells Within a One-quarter Mile Radius of Injectors........... 9 List of Exhibits.................................. ................................................................................ 10 Exhibits 1 of 10 . . Application for Orion Area Injection Order Modification 2/23/2006 Area Injection Operations This application, prepared in accordance with 20 AAC 25.402 (Enhanced Recovery Operations) and 20 AAC 25.460 (Area Injection Orders), requests modification of Area Injection Order No. 26 at Orion to encompass injection of Prudhoe Bay Miscible Injectant (PBU MI) for enhanced recovery operations (EOR). Plat of Project Area 20 AAC 25.402(c)(1) ~xhibit 1-1 shows the general location of the Orion Oil Pool (OOP) and Injection Area and includes all existing injection wells, production wells, abandoned wells, dry holes, and any other wells within the OOP as of February 1,2006. Specific approvals for any new injection wells or existing wells to be converted to injection service will be obtained pursuant to 20 AAC 25.005, 25.280 and 25.507, or any applicable successor regulation. Operators/Surface Owners 20 AAC 25.402(c)(2) and 20 AAC 25.402(c)(3) BP Exploration (Alaska) Inc. is the designated operator of the Orion Participating Area. Exhibit II-I is an affidavit showing that all the Operators and Surface Owners within a one-quarter mile radius of the injectors within the Orion Participating Area have been provided a copy of this application. Description of Operation 20 AAC 25.402(c)(4) The development plans for the OOP are described in Section II of the OOP application, dated October 1, 2003, and are updated annually with reports to the commission. The contemplated operation addressed in this application is a tertiary recovery project using the enhanced oil recovery (EOR) techniques of miscible gas flooding and viscosity reducing immiscible enriched gas flooding to increase recoverable oil. The project i~vo1ves the cyclical injection of water alternating with injection of enriched hydrocarbon gas into the oil column of the Schrader Bluff sandstone fonnation of the OOP. The gas to be used in the project ("Miscible Injectant" or "MI") will be comprised of hydrocarbon gas, enriched with intennediate hydrocarbons, 2 of 10 Application for orion. Injection Order Modification . 2/23/2006 principally ethane and propane. In a part of the project area where the reservoir oil has sufficient concentration of C7-CI3, the MI forms a miscible bank with the reservoir oil through the exchange of hydrocarbon components, and effectively displaces nearly all of the contacted oil, resulting in residual oil saturations significantly lower than with watertlood alone. The oil develops miscibility with MI at reserVoir conditions by the condensing-vaporizing multiple contact miscibility mechanism. In areas of the reservoir (project area) where the biodegradation of oil is high, the oil lacks sufficient concentration of C7 -C 13 components to be miscible with the PBU MI at reservoir conditioJ.ls. In this project area, although the injected PBU MI does not develop miscibility with the reservoir oil in all zones, the multiple-contact condensing/vaporizing mass transfer mechanism between the CO2 and C2-C4 rich PBU MI and the reservoir oil causes a significant reduction in the reservoir oil viscosity. The magnitude of tertiary oil recovery by this ''viscosity reducing, immiscible enriched gas flood" mechanism is in fact very close to the tertiary oil recovery in the project area with the "miscible gas flood" mechanism. Injected water helps maintain reservoir pressure, retards gravity segregation of the miscible injectant, and controls gas channeling. Orion wells are drilled from the existing Prudhoe Bay Initial Participating Area (IPA) L-Pad, V- Pad and Z-Pad. Installing a new I-Pad to access the northwest portion of Orion is under evaluation. MI is currently being delivered to the Orion area through the IP A MI and Borealis MI pipeline systems. Implementation of the Orion EOR project will involve connection of Orion injection wells to existing, expanded or new MI trunk and lateral distribution systems on I-Pad, L-Pad, V-Pad and Z-Pad. First injection ofMI into the OOP is expected to occur in 2Q of2006. Geologic Information 20 AAC 25.402(c)(6) The Geology of the OOP is described in Section I of the Pool Rules application. Mechanical Integrity of Injection Wells 20AAC 25.402 (C) (8) All Orion wells drilled for injection service have been completed in accordance with 20 AAC 3 of 10 . . 2/23/20b6 Application for Orion Area Injection Order Modification 25.412, thus satisfying the mechanical integrity requirements as required by 20 AAC 25.402. The casing program for each well was permitted and completed in accordance with 20 AAC 25.030. Each injector has been on water injection prior to this application, with full commission witnessed testing prior to being placed on water injection. Prior to startup of MI injection, or as directed by the commission, current injectors will have a commission witnessed pressure test to demonstrate the mechanical integrity wellbore and tubular. Exhibit III-l lists the wells currently utilized for water injection at Orion that will be used for MI injection service. All drilling and production operations will follow approved operating practices regarding the presence ofH2S in accordance with 20 AAC 25.065. Actual casing programs are included with the "Application to Drill" for each. API injection casing specifications are included on each drilling permit application. Injection Fluids 20 AAC 25.402(c)(9) Type of Fluid/Source The Orion EOR project will utilize Miscible Injectant from the Prudhoe Bay Central Gas Facility. Composition and Compatibility with Formation and Confining Zones The composition of Miscible Injectant planned for injection was shown in Exhibit VI-3 of the original Polaris AIO application. Miscible gas is a hydrocarbon with similar composition to reservoir fluids in the OOP therefore no compatibility issues are anticipated with the formation or confining zones. The composition of GC-2 produced water and compatibility issues were addressed in the Polaris AIO application. Maximum Injected Rate Maximum miscible gas injection requirements at OOP are estimated at 60,000 MSCFD. Water injection requirements at OOP are estimated at 100,000 to 125,000 bwpd maximum. Injection Pressures 20 AAC 25.402(c)(lO) The average manifold surface miscible gas injection pressure for the project is estimated to be approximately 3000 psi. The maximum surface injection pressure available for the Orion EOR 4 of 10 Application for orion" Injection Order Modification . 2/23/2006 project is estimated to be approximately 3300 psi. The resulting bottom-hole pressure will be limited by hydraulic pressure losses in the well tubing, with a maximum expected bottom hole pressure of approximately 4000 psi. Normal injection pressures will be controlled by choking the MI from the available manifold pressure to control injection rate into the Schrader Bluff wells. Fracture Information 20 AAC 25.402(c)(11) BPXA previously supplied fracture propagation information in the application for Area Injection Order for the OOP, and in an Application for Amendment to Area Injection Order No. 26 dated December 8, 2005. Miscible gas and water injection operations at the OOP are expected to be above the Schrader Bluff Formation parting pressure to enhance injectivity and improve recovery of oil. Fracture propagation models and fracturing operations for stimulating wells in the OOP have involved injecting highly viscous fluids at high rates, 10-20 barrels per minute (bpm). During both actual and simulated cases, the operations have not created net pressures sufficient to exceed the integrity of the confining layers. Conditions for planned injection will be at lower rates, less than 10 bpm, and utilize lower viscosity fluids. Miscible gas and water injection operations will result in lower net pressures, and will not cause fracturing to occur through the confming layer. To ensure injection conformance, injection performance will be monitored for each injection well. Any significant change in injectivity that would indicate injection out of zone will be followed up with surveillance. The surveillance could include spinner/temperature logs and if necessary, a tracer survey to determine the location of the injection anomaly. Formation Water Quality 20 AAC 25.402(c)(12) The compositions of injection water from GC-2 and OOP connate water were provided in Exhibit Vl-2 of the original OOP Ala application. The composition of Orion produced water will be a mixture of connate water and injection water. Fresh Water Strata 20 AAC 25.402(c)(13) 5 of 10 . . Application for Orion Area Injection Order Modification 2/23/2006 Under 20 MC 25.440, Aquifer Exemption Order No. I exempts those portions of freshwater aquifers lying directly below the Western Operating and K Pad Areas of the Prudhoe Bay Unit, including the entire OOP. Hydrocarbon Recovery 20 MC 25.402(c)(14) Estimates for original oil in place ("OOIP") for the Orion accumulation reflect current well control, stratigraphic and structural interpretation, and rock and fluid properties. The OOP current estimate of OOIP ranges between 1070 and 1785 MMSTB. The extent of the range of estimates is due primarily to uncertainty in the OOP structural definition, oil-water contact and reservoir net pay interval estimates. Estimated associated formation gas in place ranges from 210 to 345 BSCF. Primary and waterflood recovery is estimated at 5-25% of OOIP based on field performance reservoir modeling and varies based on rock and crude quality. A three-dimensional geologic and dynamic flow model of the Orion accumulation has been constructed based on detailed stratigraphic and structural interpretation. This model provides the bulk reservoir volume, porosity distribution and recovery estimates for the OOP. The model area encompasses the known extent of the Orion accumulation. The model has 200 feet by 200 feet (1 acre) cells and is defined vertically with layers 2 feet thick. Faults and structural juxtapositions are honored in the model through the use of comer point geometry and non-local grid connections. Water saturations in the reservoir model were established by capillary pressure equilibrium. Oil water contacts were varied across the pool based on available log data; Exhibit IV-I shows forecast OOP production and injection. This forecast includes improved recovery due to water injection and miscible gas injection. Preliminary evaluations indicate that EOR could yield a net recovery of up to 6% of OOIP where implemented. The MI source is the PBU MI. The EOR recovery estimates were obtained using an Equation-of-State (EOS) developed for reservoir fluid from the neighboring Polaris Oil Pool (POP), an analog to the OOP. Polaris is an excellent analog for Orion as they produce oil of essentially identical composition and quality from horizontal multi-lateral wells in the same Schrader Bluff formation at similar conditions of reservoir temperature, pressure, and depth. A composite surface sample from well W -203 was acquired. The sample was analyzed for 6 of 10 Application for orion. Injection Order Modification . 2/23/2006 extended compositional distribution. Laboratory swell, multiple-contact, and slimtube experiments were conducted using this sample and the PBU MI. The laboratory data were used to develop a new Polaris EOS. Exhibit IV -2 shows a fifteen-fold reduction in viscosity of a 40 cp Schrader Bluff oil by contacting with PBU MI in a single cell multiple-contact laboratory experiment conducted at reservoir conditions. Exhibits IV-3 and IV-4 show the density and k- values in the same experiment and Exhibit IV -5 shows recovery at 1.2 PV in a slimtube experiment with PBU MI. The Exhibits IV -2 through IV -5 also demonstrate a good match of the laboratory data with the EOS model. Bottom-hole samples from sands OA, OBa, OBc, and OBd for well W -205 and a composite OBc-d sample from well W -200 were collected and analyzed for extended compositional distribution. The compositional analysis illustrated that the W-Pad oil quality was different in different sands, varying from highly bio-degraded, high viscosity (> 1 00 cp) oil with lower C7- C 13 concentrations in the OA sands to moderate viscosity (<40cp) oil with higher C7 -C 13 concentrations in the OBc sand. The newly developed Polaris EOS was next used to calculate the minimum miscibility pressure (MMP) for oil from these sands with PBU MI. The PBU MI was found to be miscible with the oil from the W200 OBc-d sand at reservoir conditions (MMP 2250 psia). However, the calculated MMP was about 1000 psia higher than the reservoir pressure for other sands with lower concentrations of the C7 -C 13 components (Exhibit IV -6). Fully compositional, mechanistic Type Pattern Model (TPM) Simulations were conducted using the Polaris EOS for a W-Pad reservoir description, and varying oil quality (from miscible OBc sand oil to high viscosity, below MMP OA sand oil) and 30% HPV slug injection of PBU MI at WAG ratio of 1. These simulations showed that the incremental oil recovery (WAG - Waterflood recovery) for the below miscible, but very efficient viscosity reducing WAG flood in the OA sand was very close to the incremental oil recovery for the miscible WAG flood for the OBc sand (Exhibit IV -7). Single-contact PVT experiments and one-dimensional, displacement simulations of varying quality Schrader Bluff oils with PBU MI explain why the incremental recovery for immiscible, high viscosity oils is of the same magnitude as the incremental recovery for miscible moderate viscosity oils. Single-cell, multiple-contact laboratory PVT experiments with a 40 cp Schrader Bluff W -203 oil and PBU MI (Exhibit IV -2) show that there is a significant reduction of oil 7 of 10 . . Application for Orion Area Injection Order Modification 2/23/2006 viscosity by PBU MI at reservoir conditions (2100 psia) even if the MMP is much higher (3400 psia). The reduction in oil viscosity by the condensing/vaporizing mass transfer process in a one dimensional slimtube displacement is illustrated by examining the oil and gas properties after a half pore volume of MI injection for two different oils. As shown in Exhibit N -8, for an immiscible displacement of high viscosity oils by PBU MI, there is a significant reduction in the oil viscosity by the multiple-contact condensing/vaporizing mass transfer mechanism by the enriched PBU MI carrying a high concentration of C02 and C2-C4 components. This multiple contact, condensing/vaporizing mechanism is essentially the same as the condensing/vaporizing mechanism in miscible moderate viscosity oils. In both these displacements, the reduction in oil viscosity by the condensing rich components ftom the gas phase is of the same magnitude. The only difference is that in the miscible displacement case, the gas phase richness by vaporization mechanism brings the oil and gas composition close to critical point (K-values becomes 1.0), further reducing interfacial tension between the gas and oil phase. In these viscous oil displacement processes, through rich gas injection, the most significant part of the enhanced recovery results ftom the viscosity reduction and displacement of less viscous oil by water to the producing well. Further enrichment of the injected gas will achieve miscibility, i.e. the gas and oil compositions get closer to the critical point and the interfacial tension between the gas and oil phase is reduced. However, the additional recovery by the miscibility mechanism may not be as significant in the highly viscous oil displacements. In summary, displacement mechanism for Orion and Polaris reservoir fluid with PBU MI ranges ftom multiple-contact miscible for oils with high concentration of C7 -C 13 components to a very efficient viscosity reducing immiscible (VRI) displacement for oils with lower concentration of C7-C13 concentration. The EOR recovery estimate for the whole range of varying Polaris oil compositions is quite close. Assuming a 67% areal sweep, 3D incremental EOR recovery for this W-Pad description is 10%. To account for a range of reservoir description ftom most favorable to unfavorable, the EOR recovery was estimated to range ftom 2-10% with average around 6%. Gross utilization of PBU MI to achieve this EOR recovery was estimated to be around 5.3 MCF of MIlbarrel of EOR oil. This MI efficiency is similar to MI efficiency at other GPB new EOR projects (e.g. Aurora and Borealis). The MI efficiency of these new EOR projects is 8 of 10 Application for orion" Injection Order Modification . 2/23/2006 significantly better than the marginal MI efficiency around 15-20 MCF/barrel of EOR oil for continued injection of MI into the mature IP A EOR project area, thus justifying the preferential injection of PBU MI into the Orion EOR project area over IP A. Surveillance Plan To ensure the efficient allocation ofMI for the Orion EOR project, rate and pressure response to injection will be monitored. Production fluid compositional samples will be taken at least annually to assess pattern efficiency based on the returned MI (RMI) ratio. Offset producers of injectors currently on MI can be sampled on a more frequent basis to help determine break through times and flood efficiency. Water injection surveillance will continue using pressure falloffs and other monitoring methods as required by patterns. Injection of water and miscible gas into patterns will be evaluated on a regular basis to address pattern performance and optimum injection rates to maximize recovery. Mechanical Condition of Wells within a One-quarter Mile Radius of Injectors 20 AAC 25.402(c)(15) A map showing all penetrations through the OOP, and wells within a one-quarter-mile radius of the injection wells are shown on Exhibit V-I. Mechanical integrity has been established for the subject wells based on calculated cement tops being at an adequate height above the injection zone to prevent fluid that is injected into the OOP from flowing into other zones or to the surface. All existing Orion injection wells have been certified as Service Wells allowing water injection. Dates for recertification are on file with the AOGCC. Prior to any enhanced injection on wells without prior certification, wells will be certified through established approved testing procedures, with a requested State Inspector present, to confirm mechanical integrity as required by 20 AAC 25.402 (e). Although injection pressure will exceed average OOP reservoir pressure, reservoir modeling indicates rapid reservoir pressure falloff away from the injector during water and MI injection. Reservoir modeling indicates a radius of pressure influence less than 1000 feet from the injector at the end of the MI cycle. 9 of 10 . . Application for Orion Area Injection Order Modification 2/23/2006 List of Exhibits I-I Orion Pool Rilles and AIO Area II-I Affidavit III-1 Orion Injection Wells IV-lOOP Production and Recovery Profiles with Water and Miscible Gas Injection IV-2 Viscosity Reduction ofW-203 Oil by Prudhoe Bay MI in a Milltip1e Contact Experiment IV-3 Density of Polaris W-203 Oil by Prudhoe Bay MI in a Multiple Contact Experiment N-4 K-values of Polaris W-203 Oil by Prudhoe Bay MI in a Multiple Contact Experiment IV-5 W-203 Oil Slimtube Experiment with PBU MI at Reservoir Temperature IV-6 Minimum Miscibility Pressure Variation with Oil C7-CI3 Concentrations IV -7 Incremental Oil with Prudhoe Bay MI Injection for Polaris Oil with Medium to High Viscosity Range IV -8 Phase Viscosity after 0.5 HPV MI Injection V-I Orion Injection Area Wells Within 14 mile of Injectors 10 of 10 i~"',.~ 1hW~:aü Well High Angle 5"US$1M S-~j&$fÜS Production Well 25 Well .$"élW...~ $,48&.640 36 31 on Top OA == 5~*'1S..aM ¡~.ø'15..lh} 8 5 5f'-á1......tOO: 5:.á'«ktWi 12 7 8 ¡¡;"tlW...tø S. .$5. $.ìli! !3 18 17 16 5~騧~" '!hjf!i!Mtiili xhi n it 1-1 II I I Inj cti n n III II! $OO...~ !..m..~ 2'1 18 20 21 22 23 5..9!Ç5~.aoo 25 30 29 26 27 26 ~¡'dl~Hb.J!I0Ø: $!JihØ0.0 5æ'ha0ø ti7ffdHI0 5.15.3$¡¡¡ $OO~.ø@1J¡ 585~ iU!ø 5$.tUJft- 5S5.W$B mw.øi.!I ßi5:.$j!$- lîH'hU8 tU5.1Um nihan r $.$æ.w Orion Pool/Injection Area S.:tSS.lilh :$. as..." . . Exhibit II-I AFFIDA VIT STATE OF ALASKA THIRD JUDICIAL DISTRICT I, Frank A. Paskvan, declare and affirm as follows: 1. I am the Greater Prudhoe Bay West Manager for BP Exploration (Alaska) Inc., the designated operator of the proposed Orion Participating Area, and as such have responsibility for Orion operations. 2. On h-J. ).1- Z:>c t, , I caused copies of the Orion Area Injection Order Amendment Application to be provided to the following surface owners and operators of all land within a quarter mile radius ofthe proposed injection area: Operators: BP EXPLORATION (ALASKA), INC. GREATER PRUDHOE BAY PERFORMANCE UNIT ATTENTION: MAUREEN JOHNSON P.O. BOX 196612 ANCHORAGE, AK 99519-6612 Surface Owners: STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF MINING, LAND AND WATER ATTENTION: DICK MYLIUS 550 WEST 7TH AVENUE, SUITE 1070 ANCHORAGE, AK 99501-3510 F;.J.. ~.~ 7- J 'ZC:it) b . Dated: Declared and affirmed before me this ~ day of ~. p~L- Fr A. Paskvan ~ ~ ~' . """'.H ""'~'" ~ Notary Public in and, r Alaska My commission expires~\.. )~D ~ Well Name L-117 V-201 L-103 V-105 L-210 L-211 L-216 V-213 V-216 V-210 V-211 V-221 L-212 L-214 L-218 L-215 V-212 . Exhibit 111-1 Orion Injection Wells . Orion Area Injection Wells in Service, by Spud Date API No. 500292303900 500292305400 500292310100 500292309700 500292318700 500292319700 500292320600 500292321300 500292321600 500292323100 500292323200 500292324600 500292325200 500292325800 500292327200 500292327400 500292327900 Spud Date 9/13/2001 12/25/2001 7/26/2002 8/27/2002 12/31/2003 2/24/2004 5/2/2004 7/12/2004 9/2/2004 10/31/2004 11/12/2004 2/22/2005 3/23/2005 5/16/2005 8/24/2005 9/08/2005 12/2/2005 Well Type Commingled Vertical Water Injector Vertical Water Injector Commingled Vertical Water Injector Commingled Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector Vertical Water Injector I -1- ~ ." - ------_._-~._- --~--~~-~._~_._,----~-~._.~-- Oil ~ ~ .!!! '" a:: Õ 111105 111110 111115 111/20 111125 1/1/30 111135 Year ------~~~~_._-- "-_.._.~-~----~.,_. Gas r ---_._~.-.-~-_._,- 120000 100000 ~ 80000 !. i 60000 a:: (¡; ~ 40000 20000 o 1/1100 111105 111110 1/1115 1/1120 111125 1/1/30 1/1135 Year ---~-.._..~..._.._- ~""~---"--~'~'--~-----'----------~~----~-"--~"-- 011 flElld Pressure 'i ß: Year 1 1 1 B _____·_·_________.__.·m'_~._.,__.___.._.__~_.._ iI I r~ . -~----~-_.~.~.. 1 œ . ~---------~-~.- I -~--~~--~---~_._~-~--~--~._~-_."-_._-------~~_..._._-----~ --~~..- - 1 1 . . Exhibit IV -4 held Confidential 1 I -~-_..~-"-~--~~... ø 9 m I il . Ir .~~--~~ ~~..._-----~~ -.. ----_.__.~-- -- -- -~~ ~,-~,-,---------- 1,1 1. ""'" I · I r I i I I I r i I "~"-~~"~""'---'-"--'------~-~~"---'-'~~~---'----..._---~--~~.-~_..-.--~_."._'- 1 I I 1 1 1 , #l eI", xhi it -1 : III rl n Inj cti II ¡thin mil n 5~USfU~ í1tsfU:3 S2a~..a !hU5tOäe 5,.á$4hiÞS- ß~¡lI~hilWê: 25 s:,JðS.fm 35 91 5di1S"tlas 6 5 S.S-·U)~.IUi 12 ? 8 fhiI!~hftS 13 !7 16 18 s..&I!!$:~.aá! 2'1 19 20 21 22 23 s:..s55f8M1 5.S55.832 25 30 29 28 27 26 !'h$;m.lai! -,- ....... 5Jß.ØI§ß 5"15:.~ waø.~ ....... '5...<IQ.~ M'hJ}fJ!~ 5. .;I5Ð ~.@Wø tfti.'H!0 f Inj ct rs rian Pool/Injection Area In tion Location ell ap Production Well High Angle Production Well Injection Wen Mile