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Home My WebLink AboutAIO 026 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 by direct inspection of the file. Alo O;¡(p A Order File Identifier Organizing (done) ~o-sided 11111111111" 111111 R~CAN vzr Color Items: o Greyscale Items: DIGITAL DATA o Diskettes, No. D Other, No/Type: o Poor Quality Originals: o Other: NOTES: Date: ~ J 3 J 00 I I oateÓ/3/ob I I BY: C Maria~ Project Proofing BY: CMaria~ Scanning Preparation BY: Date: Production Scanning o Rescan Needed 1111111111111111111 OVERSIZED (Scannable) o Maps: o Other Items Scannable by a Large Scanner OVERSIZED (Non-Scannable) o Logs of various kinds: o Other:: 151 V11P 1111111111111111111 151 mp + = TOTAL PAGES~ (Count does not include cover sheet) P 151 1111111111111111111 Stage 1 Page Count from Scanned File: ~ (Count does include cover sheet) Page Count Matches Number in Scanning Preparation: ~ YES NO BY: ~ Date:S!a/o(P Isl W1f Stage 1 If NO in stage 1 page(s) discrepancies were found: YES NO BY: Maria Date: Scanning is complete at this pOint unless rescanning is required. Isl 1111111111111111111 ReScanned BY: Maria Date: 151 Comments about this file: III 11111111111 "III Quality Checked 111111111I111111111 10/6/2005 Orders File Cover Page. doc u INDEX Area Injection Order N0.026A Orion Pool, Prudhoe Bay Field 1. September 27, 2004 Advertising Order AO-02514016 2. October 28, 2004 Internal e-mail comments for Nov. 4 hearing 3. 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 4. March 1, 2006 Advertising Order AO-02614029 5. March 29, 2006 E-mail re: hearing vacated 6. March 30, 2006 Exhibit IV-4 Confidentiality request 7. June 20, 2007 BPXA Request hydro testing for the PBU 207 Pipeline Replacement Project 8. August 21, 2008 BPXA request to allow for the injection of miscible injectant into multiple completion injection wells (AI026A-002) Area Injection Order No. 26A e e STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: THE APPLICA nON OF BP EXPLORA nON (ALASKA) INC. for modification of Area Injection Order 26 to authorize underground injection of enriched hydrocarbon gas for enhanced oil recovery in Orion Oil Pool, Prudhoe Bay Field, North Slope, Alaska; and THE PROPOSAL initiated by the Commission to amend underground injection orders to incorporate consistent language addressing mechanical integrity of wells. IT APPEARING THAT: ) ) ) ) ) ) ) Area Injection Order No. 26A Prudhoe Bay Field Schrader Bluff Oil Pool Orion Development Area May 1,2006 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 ("EOR") purposes in the Orion Oil Pool within the PBU. 2. The Commission published notice of opportunity for 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 On its own motion, the Commission proposed to amend the rules addressing well mechanical integrity in all existing orders authorizing underground injection. The Commission published notice of opportunity for public hearing on the proposal in the Anchorage Daily News on October 3,2004. 6 Bye-mail dated October 15, 2004 BPXA suggested edits to the Commission's proposed language addressing the mechanical integrity of injection wells. 7. The Commission received no requests for a public hearing. 8. The Commission received no protests or comments. Area Injection Order 26A May 1, 2006 e e Page 2 9. No hearing was held. FINDINGS: 1. Operator BPXA is Operator of the Orion Development Area of the Schrader Bluff Oil Pool in the Prudhoe Bay Field, North Slope, Alaska. 2. Formations Authorized for Enhanced Recovery Enhanced recovery injection for the Orion Development Area is proposed within the Schrader Bluff Oil Pool. The target injection zones are correlative to Prudhoe Bay Unit well V-201 between the measured depths ("MD") of 4,549 feet and 5,106 feet (Schrader Bluff formation). 3. Proposed Iniection Area BPXA requested authorization to Inject fluids for the purpose of enhanced recovery operations on lands within Umiat Meridian TI2N-RI0E, TI2N-RIIE, TIIN-RIIE, and TIIN-RI2E in the Prudhoe Bay Unit. 4. Operators/Surface Owners Notification BPXA provided operators and surface owners within one-quarter mile of the proposed area with a copy of the application for injection. The only affected operator is BPXA, operator of Prudhoe Bay Unit and the Milne Point Unit. The State of Alaska, Department of Natural Resources is the only affected surface owner. 5. Description of Operation The contemplated operation is an 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. 6. Hydrocarbon Recovery The Schrader Bluff Oil Pool is estimated to contain 1,070 - 1,785 million stock tank barrels ("STB") of original oil in place ("OOIP") within the Orion Development Area, based on exploratory drilling and seismic mapping. Computer simulation indicates primary recovery within the major sands of the development area is expected to be 5% - 10% of the OOIP, and waterflood may increase recovery to 20% - 25% of the OOIP where implemented. Preliminary evaluations suggest that the EOR project could yield an incremental recovery to waterflood of up to 6% where implemented. These recovery estimates were obtained using an Equation of State ("EOS") developed for the nearby Polaris Oil Pool, a close analog of e e Page 3 Area Injection Order 26A May 1, 2006 the Orion Development Area. Oil from the Polaris Oil Pool has essentially identical composition and quality as that of the Orion accumulation and both accumulations have similar reservoir temperature, pressure and depth. Laboratory swell, multiple contact, and slimtube experiments were conducted using Polaris oil from W -203 and the PBU enriched gas and were used to develop a new Polaris EOS. Fully compositional, mechanistic type pattern model simulations were conducted using the Polaris EOS for a W Pad reservoir description. In part of the project area where the reservoir oil has sufficient concentration of C7 - C 13, the enriched gas forms a miscible bank with the reservoir oil through exchange of hydrocarbon components, and displaces nearly all of the contacted oil. In areas where the oil lacks sufficient concentration of C7 - C 13 components to be miscible with the Prudhoe enriched gas at reservoir conditions, miscibility may not occur. Rather, a multiple contact condensing/vaporizing mass transfer mechanism between reservoir oil and the C02 and C2 - C4 in the Prudhoe enriched gas causes a significant reduction in reservoir oil viscosity. BPXA states that the magnitude of tertiary oil recovery by this "viscosity reducing, immiscible enriched gas flood" is very close to that with miscible gas injection. A fifty-fold reduction in viscosity of a 40 cp Polaris oil was found by contacting the PBU enriched gas in a single cell multiple-contact laboratory experiment conducted at reservoir conditions. Gross utilization of Prudhoe enriched gas was estimated to be around 5.3 thousand cubic feet ("MCF") of enriched gas injected for every barrel of EOR oil. This is similar to the efficiency at other satellite Prudhoe projects and compares to an efficiency of about 15 - 20 MCF/barrel for enriched gas injection in the mature IPA EOR project area, which justifies the preferential injection of Prudhoe enriched gas into the Orion accumulation. Approval was granted for enriched gas injection within the Polaris Oil Pool on November 28, 2005. 7. Geologic Information a. Stratigraphy: The Schrader Bluff Oil Pool encompasses reservoirs assigned to the Late Cretaceous-aged Schrader Bluff formation ("Schrader Bluff'). The Schrader Bluff is divided into two stratigraphic intervals that are designated, from deepest to shallowest, the "0 sands" and the "N sands." The 0 and N sand intervals were deposited in marine shoreface and shallow shelf environments. The Schrader Bluff 0 sands are divided into seven separate reservoir intervals that are named, from deepest to shallowest, OBf, OBe, Obd, OBc, OBb, OBa, and OA. Each of these intervals coarsens upward from non-reservoir, laminated muddy siltstone at the base to reservoir-quality sandstone at the top. The lower portion of the Schrader BluffN sands is dominated by mudstone and siltstone. However, the sediments coarsen upward, and fine- to medium-grained sandstone is prevalent in the upper part of the N sands. Three reservoir intervals are recognized within the N sands. They are, from oldest to youngest, Nc, Nb, and Na. b. Structure Overview: The structural dip ranges from 1 to 4 degrees to the east and northeast, and is broken by three sets of normal faults from Northwest to Southeast, Area Injection Order 26A May 1, 2006 e e Page 4 North to South, and East to West. The Northwest to Southeast fault trend has throws up to 200 feet. The North to South striking faults, downthrown to the west and east, have throws of up to 100 feet. East to West faults are less common, and form the reservoir trap on the southwestern side of the Orion Development Area. c. Confining Intervals: The upper contact between the N Sands and the overlying Prince Creek formation is generally an abrupt transition from sandstone to mudstone forming the upper confinement. The Lower Prince Creek formation (Ma-Mc sands) typically contains over 30 feet of laterally continuous shales and mudstones. Mudstones and muddy siltstones up to 1000 feet thick provide the basal confinement of the Schrader sandstones. 8. Well Logs The logs of existing injection wells are on file with the Commission. 9. Mechanical Integrity of Wells The Commission has approved injection operations for all currently drilled Orion injectors. Mechanical integrity has been established for all injectors and wells within one-quarter mile of the Orion injectors. Cement tops are at an adequate height above the injection zone to prevent fluid from migrating out of the Orion injection zone. 10. Type of Fluid / Source Fluids requested for injection are: a. enriched gas from Prudhoe Bay Unit processing facilities; b. produced water from Prudhoe Bay Unit production facilities for the purposes of pressure maintenance and enhanced recovery; c. source water from the Prince Creek formation (also known as the Ugnu formation); d. tracer survey fluid to monitor reservoir performance; e. fluids injected for purposes of stimulation per 20 AAC 25.280(a)(2); f. source water from the Seawater Treatment Plant; and g. non-hazardous water collected from well-house cellars and standing ponds. 11. Enriched Gas Composition and Compatibility with Formation The enriched gas proposed for injection is a hydrocarbon with similar composition to reservoir fluids in the Orion Oil Pool and therefore no compatibility issues are anticipated. The compatibility of the injection waters was addressed in AIO 26 dated February 3, 2003. 12. Iniection Rates and Pressures Maximum miscible gas injection requirements are about 60,000 MSCFD. Maximum water injection is projected at 125,000 bwpd. The average manifold injection pressure for the enriched gas will be 3000 psi, with a maximum of about 3300 psi. The average surface Area Injection Order 26A May 1, 2006 e e Page 5 water injection pressure will be about 1100 psi, with a maximum of about 2000 psi. This will result in a maximum bottom hole pressure of about 4000 psi. 13. Fracture Information The Commission originally ordered that injection pressures be maintained below 0.67 psi/ft to ensure that Orion injected water does not fracture or migrate out of zone, and based its decision upon BPXA's estimate of a 0.66 - 0.67 psi/ft fracture pressure for the confining mudstone using data from stress tests and dipole sonic log. Several tests conducted with the Commission's approval support BPXA's conclusion that increased injection pressures will not result in migration out of zone. A zonal isolation test was completed in Orion well L-210 in April 2005. Sand-face pressure gauges were installed adjacent to discrete zones both above and below an isolated injection interval in order to record pressure response and reveal whether injection was breaching the confining barriers. The two perforated zones were separated by around 28 feet TVD of unperforated OA interval comprised of silty mudstone. Injection rates of up to 4200 BWPD with an injection gradient of up to 0.82 psi/ft were achieved while injecting into the lower zone. No pressure response in the adjacent zone was seen; hence, the water did not breach out of zone. Additional step rate and pulse tests in Polaris and Milne Point Schrader formations showed similar results. On December 13, 2005 the Commission administratively approved elimination of the injection pressure limitation. However, injection pressure must be maintained such that injected fluids do not fracture the confining zones or migrate out of the approved injection stratum. BPXA will monitor each injection well and if any significant change in injectivity indicates injection out of zone, surveillance will be conducted to determine the cause of the injection anomaly. 14. Freshwater exemption Aquifer Exemption Order # 1, dated July 11, 1986 exempts all portions of aquifers beneath the Western Operating Area of the Prudhoe Bay Unit, including the area designated for the proposed waterflood pilot project. 15. Mechanical Condition of Adjacent Wells All wells within one-quarter mile of existing proposed water-alternating-gas injectors have been reviewed for mechanical isolation. The records of cement jobs and cement bond logs were reviewed. All wells appear to have mechanical isolation between the Schrader Bluff and all other intervals. 16. Amendments to Rules The Commission proposed amendments to Rules 4 and 5 and the addition of Rule 7 in order to incorporate consistent language addressing the mechanical integrity of injection wells. Various wording used in different rules creates confusion and inconsistent implementation of well integrity requirements for injection wells. Area Injection Order 26A May 1, 2006 e e Page 6 CONCLUSIONS: 1. The application requirements of20 AAC 25.402 have been met. 2. Enriched gas injection will significantly improve recovery. 3. The proposed injection operations will be conducted in permeable strata, which can reasonably be expected to accept injected fluids at pressures less than the fracture pressure of the confining strata. 4. Injected fluids will be confined within the appropriate receiving intervals by impermeable lithology, cement isolation of the wellbore and appropriate operating conditions. 5. Reservoir and well surveillance, coupled with regularly scheduled mechanical integrity tests will demonstrate appropriate performance of the enhanced oil recovery project or disclose possible abnormalities. 6. Amendments to Rules 4 and 5 and the addition of Rule 7 will provide for consistent implementation of well integrity requirements for injection wells. 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 govern the underground injection of fluids for enhanced oil recovery in the Schrader Bluff Oil Pool within the affected area described below, referred to herein as the Orion Development Area, and supersede and replace the rules adopted in AIO 26 dated January 5,2004 and AIO 26.001 dated December 13,2005. Umiat Meridian Township Lease Sections Range, UM TI2N-RI0E ADL 025637 13 and 24 N/2 TI2N-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 Area Injection Order 26A May 1, 2006 e e Page 7 ADL 028241 3 NI2 and N/2 S/2, and 4 NE/4 NI2 SE/4 ADL 028245 13 N/2 and SE/4, 14 E/2 NE/4, and 24 E/2 NE/4 TIIN-RI2E ADL 047450 7, and 8 S/2 and NW/4 Rule 1: Authorized Injection Strata for Enhanced Recovery (AIO 26) Fluids appropriate for enhanced oil recovery may be injected for purposes of pressure maintenance and enhanced recovery within the Orion Development Area into strata that are common to, and correlate with, the interval between measured depths 4,549 feet MD and 5,106 feet MD in the PBU V-201 well and between the measured depths of 4,174 feet and 4,800 feet in Milne Point Unit well A-1. Rule 2: Fluid Injection Wells (AIO 26) The underground injection of fluids must be through a well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005, or through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280 and 20 AAC 25.412 (e). Rule 3: Authorized Fluids for Enhanced Recovery (Revised by this Order AIO 26A) Fluids authorized for injection include: a. enriched gas from the Prudhoe Bay Unit processing facilities; b. produced water from Prudhoe Bay Unit production facilities for the purposes of pressure maintenance and enhanced recovery; c. . tracer survey fluid to monitor reservoir performance; d. source water from a sea water treatment plant; e. source water from the Prince Creek (Ugnu) formation; and f. non-hazardous filtered water collected from Schrader Bluff Oil Pool well house cellars and well pads in the Orion Development Area. Rule 4: Monitoring Tubing-Casing Annulus Pressure (Revised by this Order AIO 26A) The tubing and casing annuli pressures of each injection well must be monitored at least daily, except if prevented by extreme weather condition, emergency situations, or similar unavoidable circumstances. Monitoring results shall be documented and made available for Commission inspection. Rule 5: Demonstration of Tubing/Casing Annulus Mechanical Integrity (Revised by this Order AIO 26A) The mechanical integrity of an injection well must be demonstrated before injection begins, and before returning a well to service following a workover affecting mechanical integrity. A Commission-witnessed mechanical integrity test must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, Area Injection Order 26A May 1, 2006 e e Page 8 pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter. The Commission must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Unless an alternate means is approved by the Commission, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1,500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 minute period. Results of mechanical integrity tests must be readily available for Commission inspection. Rule 6: Multiple Completion of Water Injection Wells (AIO 26) a. Water 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. b. Prior to initiation of commingled injection, the Commission must approve methods for allocation of injection to the 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 7: Well Integrity Failure and Confinement (Added this Order AI026A) Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall notify the Commission by the next business day and submit a plan of corrective action on a Form 10-403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule 8: Notification of Improper Class II Injection (AIO 26) Injection of fluids other than those listed in Rule 3 without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately notify the Commission, provide details of the operation, and propose actions to prevent recurrence. Additionally, notification requirements of any other State or Federal agency remain the operator's responsibility. Rule 9: Plugging and Abandonment of Fluid Injection Wells (AIO 26) An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission in accordance with 20 AAC 25. Rule 10: Other conditions (AIO 26) Area Injection Order 26A May 1, 2006 e e Page 9 It is a condition of this authorization that the operator complies with all applicable Commission regulations. The Commission may suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection strata. Rule 11: Administrative Actions (AIO 26) Unless notice and public hearing is otherwise required, the Commission may administratively waive the requirements of any rule stated above or administratively amend any rule as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. DONE at Anchorage, Alaska and dated an, Cha Alaska Oil and Gas Con ~ Daniel T. Seamount, Jr., Commissioner Alaska Oil and Gas Conservation Commission oerster, Commissioner il 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 23'd day following the date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10-day period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for rehearing is denied by nonaction of the Commission, the 30 day period for appeal to Superior Court runs from the date on which the request is deemed denied (i.e., lOth day after the application for rehearing was filed). 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 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 ~P\~~OV 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: undis recipients:; BCC: Ro intz <robert_mintz@law.state.ak.us>, Christine Hansen <c.hanse .state.okus>, Terrie Hubble <hubbletl@bp.com>, Sondra Stewman <StewmaS P.com>, stanekj <stanekj@unoca1.com>, ecolaw <ecolaw@trustees.org>, tnnjrl <tnnjr 1 @ao1.com>, shaneg <shaneg@evergreengas.com>, jdarlington <jdarlington@forestoi1.com>, nelson <kÍ1elson@petroleumnews.com>, cboddy <cboddy@usibellLcom>, Mark Dalton <markdalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips.com>, "Mark P. Worcester" <markp.worcester@conocophillips.com> b <bob@inletkeeper.org>, wdv <wdv .state.ak.us>, tjr <tjr@d <bbritch@alaska.net>, mjnelson <mjne purvingertz.com>, Ch es.o'donnell@veco.com>, "Randy L. Skillern" <Skille @BP.c >, "Deborah J. esD6@BP.com>, "Steven R. Rossb " <RossbeRS@BP is <lois@inl er.org>, Dan Bross <kuacnews@kua >, Gordon Pospisil <Posp'P >, "Fran er" <SommerFS@BP.com>, Mikel Schultz <Mikel. Schult om>, "Nick W. Glover" <GloverNW@BP.com>, "Daryl J. Kleppin" <KleppiD om>, "Janet D. Platt" <PlattJD@BP.com>, "Rosanne M. Jacobsen" <Jacobs P.com>, ddonkel <ddonkel@cfl.rr.com>, mckay <mckay@gci.net>, Barbara F Fullmer <barbara. er@conocophillips.com>, Charles Barker <barker@usgs.gov>, doug_schultze <doug_sc e@xtoenergy.com>, Hank Alford <hank.alfor xonmobi1.com>, Mark Kovac <yesnol@gci. off <gspfoff@aurorapower.com>, Gregg Nady <gregg.nady@shell.com>, Fred Steece <fred. ate.sd.us>, rcrotty <rcrotty@ch2m.com>,jejones <jejones@aurorapower.com>, dapa <dap a.net>,jroderick <jroderick@gci.net>, eyancy <eyancy@seal-tite.net>, "James M. Ruud" <j .ruud@conocophillips.com>, Brit Lively <mapalaska@ak.net>, jah <jah@dnr.sta .ak.us>, buonoje <buonoje@bp. >, Mark Hanley <mark_hanley@anadarko.com>, loren_Ie <loren_Ieman@gov.state. Houle <julie_houle@dnr.state.ak.us>, John W Katz <jwkat sso.org>, Suzan J Hill <s c.state.ak.us>, tablerk <tablerk@unoca1.com>, Brady <brady@aoga.or Brian Havelock < e @dnr.state.ak.us>, bpopp <bpopp@borough.kenai.ak.us>, Jim White <jimwhi tx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobi1.com>, marty <marty@~ki om>, ghammons <ghammons@ao1.com>, nnc1ean <nnc1ean@pobox.alaska.net>, mkm7200 7200@ao1.com>, Brian Gillespie <ifbmg@uaa.alaska.edu>, David L Boelens <dboele orapower.com>, Todd Durkee <TDU KMG.com>, Gary Schultz <gary _s z@dnr.state.ak.us>, Wayne Rancier <RANCI @petro-canada.ca>, Brandon Gagnon < n renalaw.com>, Paul Winslow <pmwinslow@forestoi1.com>, Sharmaine Copeland <capel @bp.com>, Kristin Dirks <kristin_dirks@dnr.state.ak.us>, Kaynell Zeman <kjzeman@m noi1.com>, John Tower <John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fowler 0 M>, Sc wick <scott.cranswick@mms.gov>, Brad McKim <mckimbs S L < bes@unoca1.com>, jack newell <jacknewell@acsalaska.net>, James Sc . cherr@mms.gov>, nI617@conocophillips.com, Tim Lawlor <Tim_La .blm.gov>, Lynnda Kahn <Lynnda_Kahn@fws.gov>, Jerry Dethlefs <Jerry.C. fs@conocophillips.com>, crockett@aoga.org, Tamera Sheffield <sheffield@aoga.org>, J 0 <Jon.Goltz@conocophillips.com>, Roger Belman <roger.belman@conocophillips.com>, is <mlewis@brenalaw.com>, Kari Moriarty <moriarty@aoga.org>, Patty Alfaro <paID yahoo ff <smetank' unoca1.com>, Todd Kratz <ToddKratz@chevron.com>, Gary Rogers <gary_ r ue.state. , Arthur Copoulos <Arthur_Copoulos@dnr.state.ak.us>, Ken <ken@seéorp-i >, Steve Lambert <salambert@unoca1.com>, Joe Nicks <news@radiokenai.com>, Jerry McCutcheon sitnahydronow@yahoo.com>, Paul Todd <paulto@acsalaska.net>, Bill Walker 10f2 5/2/2006 10:36 AM CO 505A and AIO 26A e e <bill- ak.net>, Iris Matthews <Iris_Matthews@legis.state.ak.us>, Paul Decker <paul er@dnr.state.ak.us>, Ro gnich <rob.g.dragnich@exxonmobi1.com>, Aleutians East Bora dmin@aleutianseast.o arq ite kremer <marguerite_kremer@dnr.state.ak.us>, Robert BreIs Robert.Brelsford@argu .com>, Alicia Konsor <alicia_konsor@dnr.state.ak.us>, Mike Mason <mike@kbbi.org>, Garland Robinson <gbrobinson@marathonoi1.com>, Cammy Taylor <Camille~Taylor .ak.us>, Winton GAubert <winton_aubert@admin.state.ak.us>, Thomas E Maunder <tom dmin.state.ak.us>, Stephen F Davies <steve_davies@admin.state.ak.us>, Keith Wiles < arathonoi1.com>, Cynthia B Mciver <bren_mciver@admin.state.ak.us> 20f2 Id I Content-Type: application/pdf :C0505A.pdf . i Content-Encodmg: base64 I Content-Type: application/pdf AI026A.pdf . Content-Encodmg: base64 5/2/2006 10:36 AM . ~1r~1ræ rnJ~ ~~~~[{~ . AI,ASIiA. OIL A1Q) GAS CONSERVATION COMMISSION SARAH PALIN, GOVERNOR 333 W. 7th AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 ADMINISTRATIVE APPROVAL NO. AIO 3.018 ADMINISTRATIVE APPROVAL NO. AIO 4E.023 ADMINISTRATIVE APPROVAL NO. AIO 20.001 ADMINISTRATIVE APPROVAL NO. AIO 24A.00l ADMINISTRATIVE APPROVAL NO. AIO 25A.00l ADMINISTRATIVE APPROVAL NO. AIO 26A.00l Ms. Colleen Burgh Waste Technical Authority BP Exploration (Alaska), Inc. P.O. Box 196612 Anchorage, AK 99519-6612 RE: Request for Administrative Approval to Inject Hydrotest Water Prudhoe Bay Unit Oil Pools Dear Ms. Burgh: BP Exploration (Alaska), Inc. ("BPXA") has notified the Commission of ongoing and planned construction of replacement oil transit pipeline segments throughout the Prudhoe Bay Unit fields. The pipeline segments must undergo pressure testing (referred to as "hydrotesting") to verify integrity. Filtered lake water that is chemically treated with a corrosion inhibitor and an oxygen scavenger will be used for hydrotesting the pipeline segments. The Commission has previously approved the injection of filtered and treated lake water used to hydrotest a pipeline segment between Lisburne Ll production pad and the Lisburne Production Center ("LPC"), part of the Greater Point McIntyre development area. Administrative approval under Area Injection Order ("Ala") 4E authorized, as an enhanced recovery injection fluid, hydrotest water consisting of treated and filtered lake water stored for fire fighting purposes (refer to Ala 4E.22). The Commission approves BPXA's June 20, 2007 written request for authorization to inject hydrotest water as an enhanced recovery fluid. The composition of hydrotest water referred to in BPXA's current request appears to be no different than that used to test the Lisburne replacement pipeline segment. BPXA has demonstrated to the satisfaction of the Commission that the hydrotest water, as described in the June 20, 2007 request, is consistent and compatible with fluids used in routine enhanced recovery operations in the Prudhoe Bay Unit oil pools and will not adversely impact the reservoir or production equipment. EaR Injection of HYdrot'Water June 21, 2007 Page 2 of2 . The following AIO rules governing injection operations in Prudhoe Bay Unit oil pools are amended to include filtered and chemically treated lake water used for hydrotesting replacement pipeline segments to the list of fluids authorized for enhanced oil recovery injection: AIO 3 (Prudhoe Oil Pool), Rule 1 Ala 4E (Prudhoe Oil Pool), Rule 1 Ala 20 (Midnight Sun Oil Pool), Rule 1 Ala 24A (Borealis Oil Pool), Rule 2 Ala 25A (Polaris Oil Pool), Rule 3 Ala 26A (Orion Oil Pool), Rule 3 Any change in the composition of the hydrotest water that has the potential to affect its compatibility with formation fluid or the normal enhanced recovery injection fluid will require additional review by the Commission before injection occurs. Similarly, any change in treating chemical use that results in the hydrotest fluid exhibiting hazardous characteristics will require additional review. As provided in AS 31.05.080, within 20 days after written notice of this 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 rehearing. A request for rehearing is considered timely if it is received by 4:30 PM on the 23rd day following the date of this letter, or the next working day if the 23rd day falls on a holiday or weekend. A person may not appeal a Commission decision to Superior Court unless rehearing has been requested. DONE at Anchorag , Alaska and dated June 21, 2007. ¿ 2 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 Baker Oil Tools 4730 Business Park Blvd., #44 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 . . 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 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Schlumberger Drilling and Measurements 2525 Gambell Street #400 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 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 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Ciri Land Department PO Box 93330 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 Public Notice Lone Creek #4 and Admin APP.l'S PBU . Subject: Public Notice Lone Creek #4 and Admin Approval's PBU From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Thu, 21 Jun 2007 14:55:49 -0800 To: undi -recipients:; BCC: C B Mciver <bren r@admin.state.ak.us>, C <c.hansen@iogcc.state.ok.us>, Te Hubble <hubbletl@bp.com>, So <StewmaSD@BP.com>, stanekj < ekj@unocal.com>, trmjrl <trmjrl@aol.co darlington <jdarlington@forestoil.com>, nelson <knelson@petroleumnews.com>, Mark Dalton <mark.dalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips.com>, "Mark P. Worcester" <mark.p.worcester@conocophillips.com>, Bob <bob@inletkeeper.org>, Dave Roby <dave Joby@admin.state.ak.us>, bbritch <bbritch@alaska.net>, mjnelson <mjnelson@purvingertz.com>, Charles O'Donnell <charles.o'donnell@veco.com>, "Randy L. Skillern" <SkilleRL@BP.com>, "Deborah J. Jones" <JonesD6@BP.com>, "Steven R. Rossberg" <RossbeRS@BP.com>, Lois <lois@inletkeeper.org>, Dan Bross <k ws@kuac.org>, Gordon Pospisil <PospisG@BP.com>, "Francis S. Sommer" <SommerFS@B m>, . el Schultz <Mikel.Schultz@BP.com>, "Nick W ver" <GloverNW@BP.co Dary leppin" <KleppiDE@BP.com>, "Janet D. PIa lattJD@BP.com>, "Ros . Jacobsen" <JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, mckay <mckay@gci.net>, Barbara F Fullmer <barbara.f.fullmer@conocophillips.com>, doug_schultze <doug_ schultze@xtoenergy.com>, Hank Alford <hank.alford@exxonmobil.com>, Mark Kovac <yesno 1 @gci.net>, gspfoff <gspfoff@aurorapower.com>, Gregg Nady <gregg.nady@shell.c , Fred Steece <fred.steece@state.sd.us>, rcrotty <rcrotty@ch2m.com>,jejones <j es@aurorapower.com>, dapa <dapa@alaska.net>, eyancy <eyancy@seal-tite.net>, "J . Ruud" <james.m @conocophilli com>, Brit Lively <bl@ ka.com>, jah <jah@dnr.state.ak.us>, buonoje uonoje@bp.com>, anley <mark_hanley@anadarko.com>, Julie Houle <julie_houle@dnr.state.ak.us>, Jo Katz <jwkatz@alaskadc.org>, tablerk <tablerk@unocal.com>, Brady <brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us>, Jim White <jimwhite@satx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobil.com>, marty <marty@rkindustrial.com>, ghammons <ghammons@aol.com>, rmclean <rmclean@pobox.alaska.net>, mkm7200 <mkm7200@aol.com>, Brian Gillespie <ifbmg@uaa.alaska.edu>, David L Boelens <dboelens@aurorapower.com>, Todd Durkee <todd.durkee@anadarko.com>, Gary Schultz <gary_schultz@dnr.state.ak.us>, Wayne Rancier <RANCIER@petro-canada.ca>, Brandon Gagnon <bgagnon@brenalaw.com>, Paul Winslow <pmwinslow@forestoil.com>, Sharmaine Copeland <copelasv@bp.com>, Kristin Dirks <kristin_dirks@dnr.state.ak.us>, K ell Zeman <kjzeman@marathonoil.com>, John Tower <John.Tower@eia.doe.gov>, Bill F ler <Bill_Fowler@anadarko M>, Scott Cranswick <scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP.com es Scherr <james.scherr mms.gov>, Tim Lawlor <Tim_Lawlor@ak.blm.gov>, Lynnda Kahn <Lynnda_ fw v>, Jerry Dethlefs <Jerry.C.Dethlefs@conocophillips.com>, crockett@aoga.org, Tamera S ld <s eld@aoga.org>, Jon Goltz <Jo ltz@conocophillips.com>, Roger Belman <roger.bel onocophillips.com>, Mindy Le < is@brenalaw.com>, Kari Moriarty <moriarty@aoga.org>, Patty Alfaro <pa oo.com>, Gary s <gary_rogers@revenue.state.ak.us>, los <Arthur_Co s@dnr.state.ak.us>, Ken <klyons@otsintl.com>, Steve Lamb rt@unocal.com>, Jo icks <news@radiokenai.com>, Jerry McCutcheon <susitnahydrono oo.com>, Bill Walker <bill-wwa@ak.net>, Paul Decker <paul_decker@dnr.state.ak.us>, Aleutians East Borough <admin@aleutianseast.org>, Marquerite kremer <marguerite_kremer@dnr.state.ak.us>, Mike Mason <mike@kbbi.org>, Garland Robinson <gbrobinson@marathonoil.com>, Cammy Taylor <cammy _taylor@dnr.state.ak.us>, Thomas E Maunder <tom _ maunder@admin.state.ak.us>, Stephen F Davies <steve _ davies@admin.state.ak.us>, ] of2 6/21/20072:56 PM Public Notice Lone Creek #4 and Admin APP.l'S PBU . Keith Wiles <kwiles@marathonoil.com>, Deanna Gamble <dgamble@kakivik.com>, James B Regg <jim_regg@admin.state.ak.us>, Cath' Foerster <cathy_foerster@admin.state.ak.us>, gregory micallef <micallef@clearwire.net>, La iphant <laura _ silliphant@dnr.state.ak.us>, David Stein ber <da' .steingreaber@exxonmobil.co pratts@a ska.net, Robert Campbell <Robe pbe euters.com>, Steve Moothart moothart .state.ak.us>, Anna Raff <anna.raff@dowjones.com>, Posey <cliff@posey.org>, Meghan Powell <Meghan.Powell@asrcenergy.com>, Temple Davidson <temple_davidson@dnr.state.ak.us>, Walter Featherly <WFeatherly@PattonBoggs.com>, Tricia Waggoner <twaggoner@nrginc.com>, John Spain <jps@stateside.com>, Cody Rice <Cody _ Rice@legis.state.ak. hn Garing <garingJD@bp.com>, Harry Engel <engelhr@bp.com>, Jim Winegamer <jimwineg brooksrangepetro.com>, Matt Rader <matt_rader@dnr.state.ak.us>, carol smyth <carol.smyth ell.com>, Arthur C Saltmarsh <art _ saltmarsh@admin.state.ak.us>, Chris Gay <cdgay@marathonoil.com>, foms@mtaonline.net, Rudy Brueggeman <rudy.brueggemann@international.gc.ca>, Cary Carrigan <cary@kfqd.com>, Sonja Frankllin <sfranklin6@bloomberg.net>, Mike Bill <Michael.Bill@bp.com>, Walter Quay <WQuay@chevron.com>, "Alan Birnbaum <\"\"Alan J Birnbaum \">" <alan_birnbaum\"@law.state.ak.us>, Randall Kanady <Randall.B.Kanady@conocophillips.com>, MJ Loveland <N1878@conocophillips.com>, Christian Gou-Leonhardt <Christian _ Gou- Leonhardt@legis.state.ak.us> Jody Colombie <iody colombie(cl}admin.state.ak.us> Special Staff Assistant Alaska Oil and Gas Conservation Commission Department of Administration ... Content-Type: application/pdf varIOUS admlß approvals AIO.pdf C E . b 64 ontent- ncodlßg: ase Content- Type: applica . Lone Creek Content-Encoding: base64 20f2 6/21/20072:56 PM i • ~a~~~ ~~~rl~, ~~u~~~, 333 W. 7ihAVE1~U=, SUITE 100 ."-,ftC4-llC3iACsE,.,`LASKSi 99'50`-3539 t~S-rv^Mt (907) 279-133 RX (907) 27G-7542 AI)1'~II1~1IS'TRA'I'IVE APPR®VAI, C® SOSA.®O1 (®RI®1®1 ®II. P®®I.) ADIVIII~IIS'I'RA'I'IV1E APPR®VAI. AI® 26A.002 (®RI®1®I ®II. P®®I.) AI)1VIIlaIIS'I'RA'I'IVE APPR®VAI. C® 471.007 (>l3®REAI,IS ®II. P®®IJ) 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) [nc. (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 SflSA, 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 A10 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 PBU V-105 wells. Both wells are classified as water alternating gas injection .:'elks aP,d, as Suvh, ha`v'e beep, 'appro'ved ,vr Aii `ii,~ectoi,. Th£ lveiiS ,la'v'e aiSv bGeii apprvY~d fvl" 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.oal; Alo 26A.oo2-•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 welts. BPXA also requests approval of a method of allocating MI injection volumes between the hvo 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 Ml 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 ~~ •Z~, t)it ~ method BPXA proposed in its August 21, 2008 application. , ~~;~-- `~ ,~, ,~" ~ ~~ :, 1 r All other terms and conditions of the affected orders remain unchanged. ~ ~ ~ ~`~"~,~, , p~~~. ENTERED at Anchorage, Alaska, and dated November 10, ~ ~, '~ ,~ ~ #~'"" ; ~~ tom} : .~ , ~a c r .:.~ ~ ~ a- ~: -~+~ ~~:.~ Daniel T. Seamount, Jr. Cathy . Foerster n .Norman Chair Comrl'iissioner 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 IO days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. [f 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 [he 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 tiled 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 3L05.080(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 afer 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 x:00 p.m. on the next day that does not fall on a weekend or state holiday. • 3lnary Jones i3avid 11llcCaleb XTO Energy, t.nc. IHS Energy Group Car#ography CEPS 810 Houston Street, Ste 2000 5333 Westheime:r, Ste 100 Ft. Worth, TX 76102-6298 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 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 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden. CO 80401-2433 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 Richard Wagner Cliff Burglin PO Box 60868 PO Box 70131 Fairbanks, AK 99706 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 Cindi 9Nalke~ Tesoro Refiring and 1Ularketing Cn. Supply & Distributiom 300 Concord Plaza Drive San Antonio., 1'X 78216 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 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 /~i.L ////2~~ • Page 1 of 1 Colombie, Jody J (®®A) 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 SCC:'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 Lidji '; '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 micallef; '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 (DO_A);_No_rman, 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 ~$ • QPExploration (Alaska) Inc. °00 Easi{3enson Boulevard P. O. Box 196612 Anchorage, Alaska 99519~'oG12 (907) 56 i-5111 ,~ m~ ~ _` ~ I ~ .~~ August 21, 2008 ~~ Z[lt)t Daniel T. Seamount, Jr. la~l~~ Oil Gas lanri!s. ~r~rrmissi~~ Chairman Ar~char~•~± Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 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 (AIO 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. AIO 26A and CO 505A allow for injection of enriched hydrocarbon gas in#o 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 Ml 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 A10 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: • • IVlultiple C®mpleti®n ®f Ini!ecti®n 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 A1O 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 rrk' l~askvan 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) ~~ ®iscussi®na C®rnrr'ingled ln~ect®r Backgr®~a~d: The Commission determined in A1O 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 AIO 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. RAI 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-213i, which at the time was on Mt injection, and then a number of step-rate injection tests were performed to characterize the regulating behavior on MI injection. ®ata 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 aNocation split between the Orion and Borealis intervals. BPXA proposes to install a NOVA valve in the s#raddled Orion interval of a commingled Ml injector, thereby accurately regulating the #low of Ml gas to the lower-pressured Orion interval. At month-end, the BR 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. Summary Proposal for Commingled Miscible Iniectant Allocation: 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 -____ _._ __ __. _ .. ___--- -------__ __..... _..-.. __. _ . _... _ .--- -- -----_ _ __._ . ~ 2.5 i _ - .. - - 3000 i - _ __ _ _ _ _ pis ~+~+~~ ~r:- ._~ 2 2500 ~ - --- - ~~ - - -- - _ - Mid. _ _ ___ 1 0 ,~ :a rt-::~ ,-. ~, .,, x I a ~ H 2000 N~MM MM+ ~'`~ ~ - ! N ~ w I 1.5 d ~ _ 1500 _ _ . _ __ __ !!~~ _ - - -- -. - _ o I 3 V O '~ - 1000 i ___ __ - - _ _ _ __~__----_ _ ~ - -.-,.»...._~_,._ - 1 ~ • inj pressure 500 ' ------------ ----------..~----.-.._-...-------Y._._---- ^ MI flow - --- 0 0 5 . 6/29/07 6/30/07 6/30/07 7/1/07 7/1/07 7/2/07 7/2/07 7/3/07 12:00 0:00 12:00 0:00 12:00 0:00 12:00 0:00 Tim e Figure 1 - L-213 NOVA Valve Step-Rate Test Data L-213 RAI B~®VA Valve Test - 8/fib ®rifice o` 1000 1500 2000 2500 3000 3500 Injection pressure psi Figure 2 -NOVA Rate Algorithm Orion L-103 L-'003 Gas Borealis Orion Inj Vol Metered Wellhead Pres (via Nova) Gas Fraction MSCFPD PS! MSCFPD MSCFPD 2,168 2,361 1954 214 90% 2,110 2,317 1932 178 92% 4,652 2,376 1962 2,690 42% 2,830 2,342 1945 885 69% 3,182 2,336 1942 1,240 61 3,290 2,322 1935 1,355 59% 2,978 2,315 1931 1,047 65% 3,888 2,329 1938 1,950 50% 8,128 2,669 2108 6,020 26% 13,036 2,705 2126 10,910 16% 11,838 2,722 2135 9,703 18% 10,862 2,725 2136 8,726 20% 10,834 2,727 2137 8,697 20% 11,114 2, 757 2152 8,962 19% 9,890 2,724 2136 7,754 22% 9,142 2,734 2141 7,001 23% 9,544 2,741 2144 7,400 22% 9,832 2,761 2154 7,678 22% ®iri®n injection volume = 0.5 x 1l$®rea-a~ injection volume =total well injection pressure + 759 metered volume metered -Orion gas Figure 3: Hypothetical Calculation Using Historic Pressure and Rate Data Infector mechanical isolation area of review • BP proposes nlll injection into the Orion interval of V-105i and L-103i. 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-1051 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 I_-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 I_-201 3-04 918' NA NA NA NA Offset Orion Producer i • V-222 1lVelt within 1/4 mile of V-105 at Schrader Pool lave[. figure 4 - \/-305i'/~ rXti[e radius gap -_ _ • Top Na Sand (Top Schrader Bluff Pool) 1Nei[ ~ 105 •~. • Top OA Sand '~/4 ~ige • Base OBf Sand (Base Schrader Bluff Pooh ~~ Radius Circle A C~ Orion L Pad Area Well L-103 1/4 Mile Radius Map Structure on Top OA sand '~~ ~ `~ t ~' L-1 1 E3 -202 ~~ \,\ ~~ ~ , \ 6~E 1 ~~ ~ 9 • \\ \ ~J \, \ \ ~ Top Na Sand (Top Schrader Bluff Pool) Well L-103 • Top OA Sand 1/4 Mile • Base OBf Sand (Base Schrader Bluff Pool) ~ Radius Circle L-120 Well within 1/4 mile of L-103 at Schrader Pool level. -441 1 ~•, i Figure 5 - L-103 '/a mile radius map *7 bp . . , June 20, 2007 BP Exploration (Alaska) Inc. PO. Box 196612 900 East Benson Boulevard Anchorage, AK 99519-6612 o Mr. John Norman, Chairman Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 RECEIVED .JUN 2 1 2007 Subject: Hydrotest Water: PBU 2007 Pipeline Replacement ProjeAlaska Oil & Gas Cons. Commission Administrative Approval Request: Anchorage Prudhoe Oil Pool, Area Injection Orders 3 and 4E Midnight sun Oil Pool, Area Injection Order 20 Borealis Oil Pool, Area Injection Order 24A Polaris Oil Pool, Area Injection Order 25A Orion Oil Pool, Area Injection Order 26A Dear Mr. Norman: BP Exploration (Alaska) Inc. (BPXA) requests approval under Area Injection Order (AIO) 4E Rule 9, AIO 3 Rule 9, AIO 20 Rule 9, AIO 24A Rule 8, AIO 25A Rule 13, and AIO 26A, Rule 11 to utilize water from pressure testing (also known as hydrotesting) replacement oil transit pipeline segments as an enhanced oil recovery (EOR) fluid in the various Greater Prudhoe Bay pools listed above. This water will temporarily augment ongoing water injection in the pool by providing additional water volume. During injection, the Class II disposal wells at FS-3 and GC-l will be shut in to ensure all of the hydrotest water will be utilized for EOR. FS-l to Skid 50 Oil Transit Line Segment Approximately 26,500 feet of 18" pipeline is under construction to replace a section of oil transit pipeline. This line will carry production from the FS-l to Skid 50 and is scheduled for pressure testing before the end of June. Approximately 7700 barrels of treated lake water will be used to pressure test the line. After the pressure test is complete, the hydrotest water will be displaced into a tank and then into pipeline to FS-3, mixing with produced fluids. At FS-3 the water will be separated in the process trains and injected in EOR wells at DS 13 and 14. In this way, the hydrotest water will augment the current water injection in the Prudhoe Oil Pool. The total volume of produced water injection is about 150,000 bpd, and the dilution of the hydrotest water with produced water will minimize any potential water compatibility issues. GC-2 to GC-l Oil Transit Line Segment Approximately 16,200 feet of 20" pipeline is under construction to replace a section of oil transit pipeline. This line will carry production from GC-2 to GC-l and is scheduled for pressure testing in late June or early July. Approximately 5900 barrels of treated lake Mr. John Norman, Ch!an June 20, 2007 Page 2 . water will be used to pressure test the line. After the pressure test is complete, the hydrotest water will be displaced into a tank and then into pipeline near GC-1, mixing with produced fluids. Depending on the process configuration at the time, the GC-1 water may also be routed to GC-3 then to FS-3. Given the configuration uncertainty, some hydrotest water could be injected in the following pools: Prudhoe, Midnight Sun, Borealis, Polaris, or Orion, at pads E, L, R, U, V, W, Z or DS 13 and 14. In this way, the hydrotest water will augment the current water injection. The total volume of produced water at GC-1 is about 100,000 bpd and the dilution of the hydrotest water with produced water will minimize any potential water compatibility issues In both cases, the lake water will be filtered and treated with a corrosion inhibitor and an oxygen scavenger. At the specified chemical concentrations, the treated lake water will be considered non-hazardous. Alternatives to proposed beneficial use of the hydrotest water include surface discharge after filtration under a NPDES permit, or trucking the water to a suitable disposal site. The difficulty in removing very small particles limits the effectiveness of filtration treatment to meet NPDES effluent limits for turbidity and color. The option of trucking the hydrotest water to Pad 3 would require multiple loads increasing the complexity of the job and the possibility of a spill. We believe the best option for handling the hydrotest water from this replacement pipeline is to use it to augment the GPB waterfloodÆOR project. Additional pipeline replacement projects are in progress or are planned elsewhere in the Greater Prudhoe Bay area, so BPXA may have additional requests to beneficially reuse pipeline hydrotest water at other field locations in the future. Please call me at 564-5229 if you have any questions. Sincerely, ~~I- Colleen Burgh Waste Technical Authority cc: James Regg, AOGCC #6 RE: Hearing vacated . . Subject: RE: Hearing vacated From: "Paskvan, Frank A" <Frank.Paskvan@bp.com> Date: Thu, 30 Mar 2006 15 :25 :45 -0900 To: Jane Williamson e_williamson@admin.state.ak.us>, <Jonathan.Williams@bp.c Claire" (Ala " <Gary. Gustafson <Sherri.Gould@bp.c , "West, Taylor" CC: J OlO11).b I <bob l@admin.state. 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-1, 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 D 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 4/3/2006 12:01 PM #5 Hearing vacated . . Subject: Hearing vacated From: Jane Williamson <jane_williamson@admin.state.ak.us> Date: Wed, 29 Mar 2006 11 :41 :00 -0900 To: "Paskvan, F aFA@BP.com>, Will' CC: J Colo y_colombie@admin.state.ak.u <bob crandall te.ak.us> P.com ,Robert PC 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~admin.state.ak.us> Reservoir Engineer Alaska Oil and Gas Conservation Commission 1 of 1 3/29/2006 12:29 PM #4 STATE OF ALASKA . NOTICE TO PUBLISHER . ADVERTISING ORDER NO. ADVERTISING ORDER INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE AO-02614029 F AOGCC AGENCY CONTACT DATE OF A.O. R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M lad Colombie PHONE March 1 2006 PCN DATES ADVERTISEMENT REQUIRED: ~ Anchorage Daily News PO box 149001 Anchorage, AK 99514 March 2, 2006 THE MATERIAL BElWEEN 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 LegallZ! D Display Classified DOther (Specify) SEE ATTACHED AOGCC, 333 W. 7th Ave., Suite 100 Anchor:u>e_ AK 99-;01 AMOUNT DATE 2 ARD 3 4 02910 :"IN 4MnllNT ~v f'.f'. Pf::M If'. 4f'.f'.T :"v NMR DIST LlQ 1 2 3 4 REQUISITI 05 02140100 73451 DIVISION APPROVAL: . . 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-RI0E, Tl2N-RllE, TlIN- RIlE, TlIN-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 ih Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentatively scheduled hearing be held by filing a written request with the Commission no later than 4:30 pm on 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 GRAND AD# DATE PO ACCOUNT PER 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 Si Noti¿e of Publiè Hearing . STATE OF ALASKA Alaska Oil and Gas Conservation Co,!,mission Re: Prudhoe Bav Field . Orion Oil Pool. . Application to .omend Area rniectiòn . Order 26. and Conservation Order 505 ruarv'23¡·2006, BP Explo- ~~~t ¿>:~~r~;ig~ }~ea~eUndd 6 and Corn;ervation Order 'ound injection of enriched 001. The Orion Oil Pool of ,d lW~_~\~~,n uT~ra~-ß¡~~i~: 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 pu1Jlished 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 pu ication is not in excess of the rate charged private md¡,"d~ '.;>:";n',',' :'~("-:~_-.---_-:.;' -,_..._-"'-"':,'/"..-.,-,,'.:-:':."".;'. :,"', '. -."" ""-.,,. - ":.' "'-""-, ',::- ":-",',:,,><-.,..;,,,-,>, ng 'fs not timelv filed', ·the der the 'issuance òf an or- To learn if the Commission ing, ,please call 79,3'1221 af- mCU!I~ ~, JOO& V submit a written protest egarding' t·his application Oll'and Gas Conserva- , 7th Avenue, Suite 100, Anclio rotestS and comments' must be· received no-'Iater than 4:30_pm on Aprií 3, 2006except-thatilthe Commisšion deèides tÕhold o public hearing, protests or comments'must be received no later than' fhe conclusion of the April 6, 2006 hear;ng. ' ' If vou are a person 'with .. spetJalaccommodatiorlsOi atte'nd the public heor Commission's Special A 79,3-122l. Is/: John K. Norman Chairman Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska MY CO MISSION EXPIRES: 09 // J-Þ067 -I I). .,{/'.(. i I " 1 t < JJ '" ~ ~ ~,:.\ \~~,t~",:t AO #02614029, Published Date: March 2,2006 Public Notice '. . Subject: Public Notice From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 01 Mar 200609:38:11 -0900 To: Legal AdsZ\.tlgrnôrågêDailY News <legalads@adn.com> Please publish tomorrow. Jody Colombie Special Staff Assistant i lAd Order form.doc Content-Type: application/msword i Content-Encoding: base64 i Content-Type: application/msword Orion Public Notice.doc Content-Encoding: base64 1 of 1 311/2006 10:21 AM Re: Public Notice . . Subject: Re: Public Notice From: "Ads, Legal" <legalads@adn.com> Date: Wed, 01 Mar 2006 15:16:08 -0900 To: Jody 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 loft 311/20063:40 PM 02-902 (Rev. 3/94) Publisher riginal Copies: Department Fiscal, Department, Receiving AO.FRM STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER ADVERTISING ORDER NO. F INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AO 02614029 AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH AlTACHED COPY OF - ADVERTISEMENT MUST BE SUBMllTED WITH INVOICE R o M AOGCC 333 West 7th Avenue. Suite 100 Anrhnr::luP A K QQ~Ol 907-793-1221 AGENCY CONTACT DATE OF A.O. 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, 10 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 North Slope Borough PO Box 69 Barrow, AK 99723 . Mona Dickens Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 Ivan Gillian 9649 Musket Bell Cr.#5 Anchorage, AK 99507 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 ~0~Hou Public Notice Prudhoe Bay Field Orion Oil p. . e Hubble .IT.com>, twf ka.net> , lof2 3/1/2006 10:21 AM Public Notice Prudhoe Bay Field Orion Oil PiIÞ . Ken kenai.com>, 11 Walker s East s>, Robert ate.ak.us>, 20f2 3/1/200610:21 AM #3 . , BP Exploration (AlaSka.. 900 East Benson Boulevard Post Office Box 196612 Anchorage, Alaska 99519-6612 Telephone (907) 561-5111 . ObP February 23, 2006 RECEIVED FEB 2 7 2006 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 MC 25.537. Should you have any questions regarding this request, please contact Jonathan Williams at 564-5854. Sincerely, F~n fJ..- 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 ~ ~.Lìa 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 Confining 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)(I) Exhibit 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 involves the cyclical injection of water alternating with injection of enriched hydrocarbon gas into the oil column of the Schrader Bluff sandstone formation of the OOP. The gas to be used in the project ("Miscible Injectant" or "MI") will be comprised of hydrocarbon gas, enriched with intermediate hydrocarbons, 2 of 10 Application for Orion. .....ìa 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-C13, 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 waterflood 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 conditions. 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 (IP A) 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 Application for Orion Area Injection Order Modification 2/23/2006 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 111-1 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 of H2S 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)(10) 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. .)ea 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. Nonnal 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 infonnation 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 Fonnation 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 confining layer. To ensure injection confonnance, injection perfonnance 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 detennine 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 VI-2 of the original OOP AIO 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 AAC 25.440, Aquifer Exemption Order No.1 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 AAC 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 fonnation gas in place ranges from 210 to 345 BSCF. Primary and waterflood recovery is estimated at 5-25% of OOIP based on field perfonnance 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 -1 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 sotlfce 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 fonnation 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. _Yea 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 PBV 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 IV -8, for an immiscible displacement of high viscosity oils by PBV MI, there is a significant reduction in the oil viscosity by the multiple-contact condensing/vaporizing mass transfer mechanism by the enriched PBV 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 from 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 from 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 PBD MI ranges from 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 -C 13 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 from most favorable to unfavorable, the EOR recovery was estimated to range from 2-10% with average around 6%. Gross utilization ofPBV MI to achieve this EOR recovery was estimated to be around 5.3 MCF of MI/barrel 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. .)ea 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 ofPBU MI into the Orion EOR project area over IPA. 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 1-1 Orion Pool Rules and AIO Area II-I Affidavit III-I 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 Multiple Contact Experiment IV-3 Density of Polaris W-203 Oil by Prudhoe Bay MI in a Multiple Contact Experiment IV-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 -C 13 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 -1 Orion Injection Area Wells Within ~ mile of Injectors 10 of 10 ¡...Hi.ift:ll! Production Well High Angle £'..$$5,,_ Production Well 25 Injection Well $......,... 36 :n Overlay on Top OA Structure. C.I. == 20' £"#'1$,,.þi: 5 5 ~hj1i,,:W 12 'ì S 5"W...'- 13 18 17 16 5..Mg,,~ E hi it 1-1 : II rl I Inj cti n n r $OOffte B."d.if~ ~,.u 21 IS 20 21 22 23 25 51! 29 28 27 26 5mt~-I\IIjØ 5imdU!fj: !í.!MhtifiS: !'iss..@¡¡:,e 'j'JfiMiI:i!ti: tìjJ$,Mii8 flf§.iiIü -,- -s~m".m: 5$51'-808 iI'.Hi,MØ a rion Pool/l "ection Area . . Exhibit 11-1 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 F.J.. ;2. 7- Zoc~ 6 , 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 of the proposed injection area: Operators: BP EXPLORATION (ALASKA), INC. GREATER PRUDHOE BAY PERFORMANCE UNIT ATTENTION: MAUREEN JOHNSON P.O. BOX 196612 ANCHORAGE, AI( 99519-6612 Surface Owners: STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DNISION OF MINING, LAND AND WATER ATTENTION: DICKMYLIUS 550 WEST 7TH AVENUE, SUITE 1070 ANCHORAGE, AI( 99501-3510 Dated: F~?-7- I ~lot> fo . Declared and affirmed before me this ~ day of ~P~. F A. Paskvan ~,~ ~~~~~~ Notary Public in and r Alaska My commission expires~\. )"\~ n~ Well Name L-117 V-201 L-103 V -105 L-210 L-211 L-216 V-213 V-216 V-21O 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 WaterInjector Vertical Water Injector Exhibit IV-1- 0 P Production and Recove ater nd Miscibl Oil Production 45000 40000 35000 ~ 30000 :g !. 25000 i a:: 20000 Õ 15000 10000 5000 Year Gas I a:: '" '" c¡. Year Profiles with Gas Injectio _._.._~. .._----_.._~---~._~-------- Water 120000 100000 ~ ~ i 60000 a:: Ai ~ 40000 20000 Year ~___MM_~'~____ Oil Recovery, field Pressure e :::I ::I l .. 1950 I î </1- '" 1900 ~ 1850& I! 1800 i 1750 Exhibit IV-2: Viscosity Reduction of W...203 il by Prudhoe Bay MI in ultiple Contact Experiment 100 EOS ~ 10 ..... 1;; o u t) :> 800 "" ....... 1 .~ L-_~~ 0.0 2.0 M! ¡bit IV-3: D nsi of in Multiple Oil by rudhoe Bay ontact Experiment I W 203 PBMGP Gas Multiple Contact 1 0.75 0.5 0.25 o 0.00 0.50 1 1 2.00 2.50 3.00 Cum Moles . . Exhibit IV -4 held Confidential ¡bit IV-5: 1 0.9 N . >ot .... ~ 0.8 o u CD O! 0.6 2000 I at it Slimtube Experiment with PBU rvoir mperatu W203 Slim Tube Recovery versus Pressure 4500 5000 -,~..~,_..~"'-,~.~.~ -- -^- - ----- 1.10 1.00 0.90 N 0.80 . "f"'" ¡bit IV-6: Minimum with Oil ibility P u Va oncentrati n -~~--~------_._-~.."-~.._~~--^------------- on _.___.~.,,__.~._______.__~~___._._'m_..~~"_.~__~.~_.._~~.__~~~_~^__~~ Viscous Oil MMP 13 MMP 3200 .. W205 OA (High Viscosity) .---------- W200 OBcd Viscosi u 0.70 (I ~ 0.60 0.50 0.40 1500 2000 3500 4000 · ¡bit IV-?: Inc mental il for Sch r luff il with M Prudhoe Bay MI Injection iurn to High Viscosi Rang Inere ntal ry ~ CD > o Co) 10 ~ 1 + 1 100 CÞ tn m 1 .c a.. tn m ø 0.1 0.01 I : Ph Viscosity I Inj . Ion r O. il Vi During 1 Displacement 10 · . y í6 xhi it V-1 III Inj cti ells ¡thin % ¡I f Inj ct II rl n n r rs III sœ~øe mt.Ü ...,... S'lSfjU: ....... rion Pool/Injection $,iS1h.lÞ" \!hfUIS,ü$! Area Injection ell Location ap 5~Ultitü.e- i~$Si!lta.ê Production Well High Angle "ì.kttlSJUe $,$ß.~hM¡¡¡ Production Wen 25 Injection Well 1/4 Mile Radius Circle $~Mi$fW- S"Utt.IIfIß around existing Orion Injection wells 35 :31 5,I'1fhSU $,B1fhem¡\ 6 5 $..aUdiSt $*.11,. 12 7 8 ¡,&f!!'.hUS S,iI'ß5.tØJØ 13 18 17 16 5,-iHhhUS $,$U,saa 19 21 '5~-&-55t$Ø j'k¡ß5,¡-i!iiU\ 2" 2>1 22 23 25 30 29 28 21 26 !h"53,US ~!!i5¡h$$$ -,- ~~~ j'fh¡¡,.ft1i}0 """.... ....... 5$."1*__ ~.$Ø£ #2 [Fwd: Re: [F"Y"d: ÁOGCC Proposed WI Lan. for Injectors]] . Sul)iect: [Fwd: Re: [Fwd: AOGCCProposed WI Langµage for Injectors]] From: Winton Aubert <wintöh_auþert@admm.state.ak.µs> Ðªte:Thu,28 Oct 200409:48' 1-08QO This is part of the record for the Nov. 4 hearing. WGA -------- Original Message -------- Subject: Re: [Fwd: AOGCC Proposed WI Language for Injectors] Date: Thu, 28 Oct 2004 09:41:55 -0800 From: James Regg <jim regg@admin.state.ak.us> Organization: State of Alaska To: Winton Aubert <winton aubert@admin.state.ak.us> References: <41812422.8080604@admin.state.ak.us> These should be provided to Jody as part of public review record Jim Winton Aubert wrote: FYI. -------- Original Message -------- AOGCC Proposed WI Language for Tue, 19 Oct 2004 13:49:33 -0800 Engel, Harry R <EngeIHR@BP.com> winton aubert@admin.state.ak.us Injectors Subject: Date: From: To: Winton... Here are the comments we discussed. Harry *From: * NSU, ADW Well Integrity Engineer *Sent: * Friday, October 15, 2004 10:43 PM *To: * Rossberg, R Steven¡ Engel, Harry R¡ Cismoski, Doug A¡ NSU, ADW Well Operations Supervisor *Cc: * Mielke, Robert L.¡ Reeves, Donald F¡ Dube, Anna T¡ NSU, ADW Well Integrity Engineer *Subject: * AOGCC Proposed WI Language for Injectors Hi Guys. John McMullen sent this to us, it's an order proposed by the AOGCC to replace the well integrity related language in the current Area Injection Orders. Listed below are comments, not sure who is coordinating getting these in front of Winton/Jim. Overall, looks okay from an Operations perspective. We do have a few comments, but could live with the current proposed language. Note the proposed public hearing date is November 4. The following language does not reflect what the slope AOGCC inspectors are currently requiring us to do: "The mechanical integrity of an injection well must be demonstrated before injection begins, at least once every four years thereafter (except at least once every two years in the case of a slurry injection well), and * before* ** 100 10/28/2004 11:09 AM [Fwd: Re: [FWd: ÀOGCC Proposed WI Lanee for Injectors]] . return.:tng a well to service following a workover affecting mechanical integrity." After a workover, the slope AOGCC inspectors want the well warmed up and on stable injection, then we conduct the AOGCC witnessed MITIA. This language requires the AOGCC witnessed MITIA before starting injection, which we are doing on the rig after the tubing is run. Just trying to keep language consistent with the field practice. If "after" was substituted for "before", it would reflect current AOGCC practices. It would be helpful if the following language required reporting by the "next working day" rather than "immediately", due to weekends, holidays, etc. We like to confer with the APE and get a plan finalized, this may prevent us from doing all the investigating we like to do before talking with the AOGCC. "Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall * immediately*_** notify the Commission" This section could use some helpjwordsmithing: "A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation." Report content requirements are clear, but it's a little unclear what triggers a well to be included on this monthly report. Is it wells that have been reported to the AOGCC, are currently on-line and are going through the Administrative Action process? A proposed re-write would be: "All active injection wells with well integrity failure or lack of injection zone isolation shall have the following information reported monthly to the Commission: daily tubing and casing annuli pressures, daily injection rates." Requirements for the period between when a well failure is reported and when an administrative action is approved are unclear. This document states "the operator shall immediately notify the Commission and submit a plan of corrective action on a Form 10-403". If we don't plan to do any corrective action, but to pursue an AA, does a 10-403 need to be submitted? The AOGCC has stated they don't consider an AA as "corrective action". Let me know if you have any questions. Joe -----Original Message----- From: Kleppin, Daryl J Sent: Wednesday, September 29, 2004 1:37 PM To: Townsend, Monte A; Digert, Scott A; Denis, John R (ANC); Miller, Mike E; McMullen, John C Subject: FW: Public Notices FYI -----Original Message----- From: Jody Colombie [ mailto:jody colombie@admin.state.ak.us Sent: Wednesday, September 29, 2004 1:01 PM Subject: Public Notices Please find the attached Notice and Attachment for the proposed amendment of underground injection orders and the Public Notice Happy Valley #10. Jody Colombie «Mechanical Integrity proposal. ZIP» «Mechanical Integrity of Wells Notice.doc» 2 of3 10/28/2004 11:09 AM [Fwd: Re: [Fvij: ÁOGCC Proposed WI Lan.e for Injectors)] . 30f3 10/28/2004 11 :09 AM #1 STATE OF ALASKA . NOTICE TO PUBLISHER . ADVERTISING ORDER NO. ADVERTISING ORDER INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO, CERTIFIED AFFIDAVIT OF PUBLICATION (PART2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE AO-02514016 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M AGENCY CONTACT DATE OF A.O. Jod Colombie PHONE Se tember 27 2004 PCN T Journal of Commerce o 301 Arctic Slope Ave #350 Anchorage, AK 99518 October 3, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal o Display Advertisement to be published was e-mailed o Classified DOther (Specify) SEE A TT ACHED DATE 2 ARD 02910 3 4 FIN AMOUNT SY CC PGM LC ACCT FY NMR DIST LIQ 05 02140100 73451 2 3 4 REQUISITIONED BY: " ¡ \vvL/ ' DIVISION APPROVAL: · . I 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FlUvl STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER ADVERTISING ORDER NO. INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO, CERTIFIED AO-02514016 AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE F AOGCC 333 West ih Avenue, Suite 100 Anchorage,AJ( 99501 907-793-1221 AGENCY CO NT ACT DATE OF A.O. R o M DATES ADVERTISEMENT REQUIRED: T o Journal of Commerce 301 Arctic Slope Ave #350 Anchorage, AJ( 99518 October 3, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that 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 2004, and thereafter for _ consecutive days, the last publication appearing on the _ day of . 2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2004, Notary public for state of My commission expires . . Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Amendment of underground injection orders to incorporate consistent language addressing the mechanical integrity of wells The Alaska Oil and Gas Conservation Commission ("Commission"), on its own motion, proposes to amend the rules addressing mechanical integrity of wells in all existing area injection orders, storage injection orders, enhanced recovery injection orders, and disposal injection orders. The proposed amendments will replace numerous variations in the wording of these rules with uniform, consistent language, in order to avoid confusion and inconsistent implementation of well integrity requirements for injection wells when pressure communication or leakage is indicated. The proposed amendments may be reviewed at the offices of the Commission, 333 West 7th Avenue, Suite 100, Anchorage, Alaska, or on the Commission's website at http://www.aogcc.alaska.gov, or a copy may be obtained by phoning the Commission at (907) 793-1221. The proposed amendments affect the following orders and fields or wells: AIO 1- Duck Island Unit AIO 2B - Kuparuk River AIO 3 - Prudhoe Bay Unit; AIO 4C - Prudhoe Bay Unit; Unit; Kuparuk River, Tabasco, Western Operating Area Eastern Operating Area U gnu, West Sak Fields AIO 5 - Trading Bay Unit; AIO 6 - Granite Point Field; AIO 7 - Middle Ground McArthur River Field Northern Portion Shoal; Northern Portion AIO 8 - Middle Ground AIO 9 - Middle Ground AIO lOB - Milne Point Unit; Shoal; Southern Portion Shoal; Central Portion Schrader Bluff, Sag River, Kuparuk River Pools AIO 11 - Granite Point Field; AIO 12 - Trading Bay Field; Ala 13A - Swanson River Southern Portion Southern Portion Unit AIO 14A - Prudhoe Bay Unit; AIO 15 - West McArthur AIO 16 - Kuparuk River Unit; Niakuk Oil Pool River Unit Tam Oil Pool AIO 17 - Badami Unit AIO 18A - Colville River AIO 19 - Duck Island Unit; Unit; Alpine Oil Pool Eider Oil Pool AIO 20 - Prudhoe Bay Unit; AIO 21 - Kuparuk River Unit; Ala 22C - Prudhoe Bay Unit; Midnight Sun Oil Pool Meltwater Oil Pool Aurora Oil Pool AIO 23 - Northstar Unit AIO 24 - Prudhoe Bay Unit; AIO 25 - Prudhoe Bay Unit; Borealis Oil Pool Polaris Oil Pool AIO 26 - Prudhoe Bay Unit; DIO 1 - Kenai Unit; KU WD- DIO 2 - Kenai Unit; KU 14-4 Orion Oil Pool 1 DIO 3 - Beluga River Gas DIO 4 - Beaver Creek Unit; DIO 5 - Barrow Gas Field; Field; BR WD-l BC-2 South Barrow #5 . . DIO 6 - Lewis River Gas DIO 7 - West McArthur River DIO 8 - Beaver Creek Unit; Field; WD-l Unit; WMRU D-l BC-3 DIO 9 - Kenai Unit; KU 11- DID 10 - Granite Point Field; DIO 11 - Kenai Unit; KU 24- 17 GP 44-11 7 DIO 12 - Badami Unit; WD- DIO 13 - North Trading Bay DIO 14 - Houston Gas Field; 1, WD-2 Unit; S-4 Well #3 DIO 15 - North Trading Bay DIO 16 - West McArthur DIO 17 - North Cook Inlet Unit; S-5 River Unit; WMRU 4D Unit; NCIU A-12 DIO 19 - Granite Point Field; DIO 20 -Pioneer Unit; Well DIO 21 - Flaxman Island; W. Granite Point State 17587 1702-15DA WDW Alaska S tate A - 2 #3 DIO 22 - Redoubt Unit; RU DIO 23 - Ivan River Unit; DIO 24 - Nicolai Creek Unit; Dl IRU 14-31 NCU #5 DIO 25 - Sterling Unit; SU DIO 26 - Kustatan Field; KFl SIO 1 - Prudhoe Bay Unit, 43-9 Point McIntyre Field #6 SIO 2A- Swanson River Unit; SIO 3 - Swanson River Unit; EIO 1 - Prudhoe Bay Unit; KGSF #1 KGSF #2 Prudhoe Bay Field, Schrader Bluff Formation Well V-I05 EIO 2 - Redoubt Unit; RU-6 The Commission has tentatively set a consolidated public hearing on the amendments for November 4, 2004 at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West ih Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentatively scheduled hearing be held by filing a written request with the Commission no later than 4:30 pm on October 20, 2004. If a request for a hearing is not timely filed, the Commission may consider the issuance of orders on the subject of the proposals without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written protests or written comments regarding these proposals to the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written protests or comments must be received no later than 4:30 pm on November 3, 2004 except that if the Commission decides to hold a public hearing, written protests or comments must be received no later than the conclusion of the November 4, 2004 hearing. Published Date: October 3,2004 AO# 02514016 . . FRANK H. MURKOWSKI, GOVERNOR AItASIiA OIL AND GAS CONSERVATION COMMISSION 333 W. 7'" AVENUE, SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 September 27, 2004 Proposals to Amend Underground Injection Orders to Incorporate Consistent Language Addressing the Mechanical Integrity of Wells The Alaska Oil and Gas Conservation Commission ("Commission"), on its own motion, proposes to amend the rules addressing mechanical integrity of wells in all existing area injection orders, storage injection orders, enhanced recovery injection orders, and disposal injection orders. There are numerous different versions of wording used for each of the rules that create confusion and inconsistent implementation of well integrity requirements for injection wells when pressure communication or leakage is indicated. In several injection orders, there are no rules addressing requirements for notification and well disposition when a well integrity failure is identified. Wording used for the administrative approval rule in injection orders is similarly inconsistent. The Commission proposes these three rules as replacements in all injection orders: Demonstration of Mechanical Integrity The mechanical integrity of an injection well must be demonstrated before injection begins, at least once every four years thereafter (except at least once every two years in the case of a slurry injection well), and before returning a well to service following a workover affecting mechanical integrity. Unless an alternate means is approved by the Commission, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 minute period. The Commission must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Well Integrity Failure and Confinement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall immediately notify the Commission and submit a plan of corrective action on a Form 10-403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. . . Administrative Actions Unless notice and public hearing is otherwise required, the Commission may administratively waive or amend any rule stated above as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in fluid movement outside of the authorized injection zone. The following table identifies the specific rules affected by the rewrite. Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Integrity" Confinement" Area Injection Orders AIO 1 - Duck Island Unit 6 7 9 AIO 2B - Kuparuk River Unit; Kuparuk River, 6 7 9 Tabasco, Ugnu, West Sak Fields AIO 3 - Prudhoe Bay Unit; 6 7 9 Western Operating Area AIO 4C - Prudhoe Bay Unit; 6 7 9 Eastern Operating Area AIO 5 - Trading Bay Unit; 6 6 9 McArthur River Field AIO 6 - Granite Point Field; 6 7 9 Northern Portion AIO 7 - Middle Ground 6 7 9 Shoal; Northern Portion AIO 8 - Middle Ground 6 7 9 Shoal; Southern Portion AIO 9 - Middle Ground 6 7 9 Shoal; Central Portion AIO lOB - Milne Point Unit; Schrader Bluff, Sag River, 4 5 8 Kuparuk River Pools AIO 11 - Granite Point 5 6 8 Field; Southern Portion AIO 12 - Trading Bay Field; 5 6 8 Southern Portion AIO 13A - Swanson River 6 7 9 Unit AIO 14A - Prudhoe Bay 4 5 8 Unit; Niakuk Oil Pool AIO 15 - West McArthur 5 6 9 . . Affected Rules "Demonstration of "Well Integrity "Administrative Injection Order Mechanical Failure and Action" Integrity" Confinement" River Unit AIO 16 - Kuparuk River 6 7 10 Unit; Tarn Oil Pool 6 8 AIO 17 Badami Unit 5 AIO 18A - Colville River 6 7 11 Unit; Alpine Oil Pool AIO 19 - Duck Island Unit; 5 6 9 Eider Oil Pool AIO 20 - Prudhoe Bay Unit; 5 6 9 Midnight Sun Oil Pool AIO 21 - Kuparuk River 4 No rule 6 Unit; Meltwater Oil Pool AIO 22C - Prudhoe Bay 5 No rule 8 Unit; Aurora Oil Pool 6 9 AIO 23 Northstar Unit 5 AIO 24 - Prudhoe Bay Unit; 5 No rule 9 Borealis Oil Pool AIO 25 - Prudhoe Bay Unit; 6 8 13 Polaris Oil Pool AIO 26 - Prudhoe Bay Unit; 6 No rule 13 Orion Oil Pool Disposal In.iection Orders DIO 1 - Kenai Unit; KU No rule No rule No rule WD-l DIO 2 - Kenai Unit; KU 14- No rule No rule No rule 4 DIO 3 - Beluga River Gas No rule No rule No rule Field; BR WD-l DIO 4 - Beaver Creek Unit; No rule No rule No rule BC-2 DIO 5 - Barrow Gas Field; No rule No rule No rule South Barrow #5 DIO 6 - Lewis River Gas No rule No rule 3 Field; WD-l DIO 7 - West McArthur 2 3 5 River Unit; WMRU D-l DIO 8 - Beaver Creek Unit; 2 3 5 BC-3 DIO 9 - Kenai Unit; KU 11- 2 3 4 17 DIO 10 - Granite Point 2 3 5 Field; GP 44-11 . . Affected Rules "Demonstration of "Well Integrity "Administrative Injection Order Mechanical Failure and Action" Integrity" Confinement" DIO 11 - Kenai Unit; KU 2 3 4 24-7 DIO 12 - Badami Unit; WD- 2 3 5 1, WD- 2 DIO 13 - North Trading Bay 2 3 6 Unit; S-4 DIO 14 - Houston Gas 2 3 5 Field; Well #3 DIO 15 - North Trading Bay 2 3 Rule not numbered Unit; S-5 DIG 16 - West McArthur 2 3 5 River Unit; WMRU 4D DIO 17 - North Cook Inlet 2 3 6 Unit; NCIU A-12 DIO 19 - Granite Point 4 6 Field; W. Granite Point State 3 17587 #3 DIG 20 - Pioneer Unit; Well 3 4 6 1702-15DA WDW DIO 21 - Flaxman Island; 3 4 7 Alaska State A - 2 DIO 22 - Redoubt Unit; RU 3 No rule 6 Dl DIO 23 - Ivan River Unit; No rule No rule 6 IRU 14-31 DIO 24 - Nicolai Creek Order expired Unit; NCU #5 DIG 25 - Sterling Unit; SU 3 4 7 43-9 DIO 26 - Kustatan Field; 3 4 7 KFl Storage Injection Orders SIO 1 - Prudhoe Bay Unit, No rule No rule No rule Point McIntyre Field #6 SIO 2A- Swanson River 2 No rule 6 Unit; KGSF #1 SIO 3 - Swanson River Unit; 2 No rule 7 KGSF #2 Enhanced Recovery Injection Orders EIO 1 - Prudhoe Bay Unit; No rule 8 Prudhoe Bay Field, Schrader No rule Bluff Formation Well V-I05 . . Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Integrity" Confinement" EIO 2 - Redoubt Unit; RU-6 5 8 9 Public Notices . . Subject: Public Notices From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 29 Sep 2004 13:01 :04 -0800 10f2 9/29/2004 1: 10 PM Public Notices . . 20f2 9/2912004 1: 10 PM Public Notice . . Subject: Public Notice From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 29 Sep 2004 12:55:26 -0800 Please publish the attached Notice on October 3, 2004. Thank you. Jody Colombie Mechanical Integrity of Wells Content-Type: application/msword Content-Encoding: base64 Content- Type: application/msword Content-Encoding: base64 1 of 1 9/29/2004 1: 10 PM Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage. AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna. AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 . Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 · l1Ja/kd /(J/fd'l David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Robert Gravely 7681 South Kit Carson Drive Littleton. CO 80122 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 SOldotna, AK 99669-2139 Penny Vadla 399 West Riverview Avenue SOldotna, AK 99669-7714 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks. AK 99711 North Slope Borough PO Box 69 Barrow, AK 99723 . . OF COMMERCE 301 Arctic Slope Avenue, Suite 350, Anchorage, AK 99518· (907) 561-4772 AFFIDAVIT OF PUBLICATION . .. UNITED STATES OF AMERICA ) ) STATE OF ALASKA ss ) THIRD JUDICIAL DIVISION ) BEFORE ME, the undersigned, a Notary Public, this day personally appeared '3",-.c;" 'To",'-.~ who, being first duly sworn, according to law, says that he/she is the \)~b \~Ù....a...r of the Alaska Journal of Commerce published at Anchorage in said Division and State of Alaska, and that the advertisement, of which the annexed is a true copy, was published in said publication on Oc..+o\a.t........ 3. '2..øo~ ........................... .\........... ................................ ........................................................................ ........................................................................ ........................................................................ and that the rate charged thereon is not in excess of the rale c("'ffie pnvale individuals. Subs crib a~worn before me this 20 +1: day of o~ '9o-r "'Z....'DO Lf Notmy Pl . J My Commission Expires YVONNE L. WILLIAMS NOTARY PUBLIC STATE OF ALASKA My Camm. Exp. 12·1-~··2C') . . Public Notice Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Amendment of underground injection orders to incorporate consistent language addressing the mechanical integrity of wells The Alaska Oil and Gas Conservation Commission ("Commission"), on its own motion, proposes to amend the rules addressing mechanical integrity of wells in all existing area injection orders, storage injection orders. enhanced recovery injection orders, and disposal injection orders. The proposed amendments will replace numerous variations in the wording of these rules with uniform, consistent language, in order to avoid confusion and inconsistent implementation of well integrity requirements for injection wells when pressure communication or leakage is indicated. The proposed amendments may be reviewed at the offices of the Commission, 333 West 7th Avenue. Suite 100, Anchorage, Alaska, or on the Commission's website at http://www.aogcc.alaska.gov, or a copy may be obtained by phoning the Commission at (907) 793-1221. The proposed amendments affect the following orders and fields or wells: AIO 1 - Duck Island Unit AIO 2B - Kuparuk River AIO 3 - Prudhoe Bay Unit; AIO 4C - Prudhoe Bay Unit; Unit; Kuparuk River, Tabasco, Western Operating Area Eastern Operating Area U gnu, West Sak Fields AIO 5 - Trading Bay Unit; AIO 6 - Granite Point Field; AIO 7 - Middle Ground McArthur River Field Northern Portion Shoal; Northern Portion AIO 8 - Middle Ground AIO 9 - Middle Ground AIO lOB - Milne Point Unit; Shoal; Southern Portion Shoal; Central Portion Schrader Bluff, Sag River, Kunaruk River Pools AIO 11 - Granite Point Field; AIO 12 - Trading Bay Field; AIO 13A - Swanson River Southern Portion Southern Portion Unit AIO 14A - Prudhoe Bay Unit; AIO 15 - West McArthur AIO 16 - Kuparuk River Unit; Niakuk Oil Pool River Unit Tarn Oil Pool AIO 17 - Badami Unit AIO 18A - Colville River AIO 19 - Duck Island Unit; Unit; Alnine Oil Pool Eider Oil Pool AIO 20 - Prudhoe Bay Unit; AIO 21 - Kuparuk River Unit; AIO 22C - Prudhoe Bay Unit; Midnight Sun Oil Pool Meltwater Oil Pool Aurora Oil Pool AIO 23 - Northstar Unit AIO 24 - Prudhoe Bay Unit; AIO 25 - Prudhoe Bay Unit; Borealis Oil Pool Polaris Oil Pool AIO 26 - Prudhoe Bay Unit; DIO 1 - Kenai Unit; KU WD- DIO 2 - Kenai Unit; KU 14-4 Orion Oil Pool 1 DIO 3 - Beluga River Gas DIO 4 - Beaver Creek Unit; DID 5 - Barrow Gas Field; Field; BR WD-1 BC-2 South Barrow #5 DIO 6 - Lewis River Gas DIO 7 - West McArthur River DIO 8 - Beaver Creek Unit; Field; WD-1 Unit; WMRU D-1 BC-3 DIO 9 - Kenai Unit; KU 11- DIO 10 - Granite Point FIeld; DIO 11 - Kenai Unit; KU 24- 17 GP 44-11 7 DlO 12 - Badami Unit; WD- DIO 13 - North Trading Bay DIO 14 - Houston Gas Field; 1, WD-2 Unit; S-4 Well #3 DlO 15 - North Tradinl!' Bav DlO 16 - West McArthur DIO 17 - North Cook Inlet Unit; S-5 River Unit; WMRU 4D Unit;NCnu A-12 DlO 19 - Granite Point Field; DIO 20 - Pioneer Unit; Well DlO 21 - Flaxman Island; W. Granite Point State 17587 1702-15DA WDW Alaska State A-2 #3 DlO 22 - Redoubt Unit; RU DIO 23 - Ivan River Unit; DlO 24 - Nicolai Creek Unit; D1 IRU 14-31 NCU #5 DlO 25 - Sterling Unit; SU DlO 26 - Kustatan Field; KF1 SIO 1 - Prudhoe Bay Unit, 43-9 Point McIntyre Field #6 SIO 2A- Swanson River Unit; SIO 3 - Swanson River Unit; EIO 1 - Prudhoe Bay Unit; KGSF #1 KGSF #2 Prudhoe Bay Field, Schrader Bluff Formation Well V-105 EIO 2 - Redoubt Unit; RU-6 The Commission has tentatively set a consolidated public hearing on the amendments for November 4, 2004 at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West 7tlt 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 October 20, 2004. If a request for a hearing is not timely filed, the Commission may consider the issuance of orders on the subject of the proposals without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written protests or written comments regarding these proposals to the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100,. Anchorage, Alaska 99501. Written protests or comments must be received no later than 4:30 pm on November 3, 2004 except that if the Commission decides to hold a public hearing, written protests or comments must be received no later than the conclusion of the November 4, 2004 hearing. If you are a person with a disability who may need special accommodations in order to comment or to attend the public hearing, please contact Jody Colombie at 793-1221. John K. Norman, Chairman Published Date: October 3, 2004 AO# 02514016 -