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Home My WebLink AboutSIO 001 . . INDEX STORAGE INJECTION ORDER NO. 1 1. December 13, 1990 2. December 14, 1990 3. September 27,2004 BP Request for Storage Injection Order for Point McIntyre Notice of Public Hearing Proposals to amend underground injection orders to incorporate consistent language addressing the mechanical integrity of wells Storage Injection Order No.1 It . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive JUlchorage AJaska 99501-3192 Re: THE APPLICATION OF BP ) EXPLORATION (ALASKA), ) INC. for an order authorizing) the underground storage of ) liquid hydrocarbons by in- ) jection into the undefined ) Kuparuk reservoir in the ) Point McIntyre #6 well. ) Storage Injection Order No. 1 Point McIntyre # 6 January 15, 1991 IT APPEARING THAT: 1. BP Exploration (Alaska) Inc. submitted an application dated December 13, 1990 requesting an order authorizing the underground storage of liquid hydrocarbons by injecting limited volumes of crude oil from the testing of Pt. McIntyre #9 well into the Kuparuk Formation of the Pt. McIntyre #6 well 2. Notice of Public Hearing on the application was published in the Anchorage Daily News and the Anchorage Times on December 14, 1990 in accordance with 20AAC25. 540 3. No protests to the application were filed with the Commission. FINDINGS: 1. The underground injection of hydrocarbons for purposes of storage is permissible under Alaska's Underground Injection Control Program. 2. Criteria for casing, cementing and tubing an injection well are outlined under 20 ACC 25.412 3. Pt. McIntyre #6 was completed on March 28, 1990, it meets the casing, cementing and tubing criteria of 20 ACC 25.412. Storage Injection eder January 15, 1991 Page 2 No.1 . 4. Cement bond logs from the Pt. McIntyre #6 indicate isolation between the injection strata and the remainder of the wellbore. 5. The mechanical integrity of Pt. McIntyre #6 shall be demonstrated prior to injection per 20 ACC 20.252 (d). 6. The Kuparuk Formation is the same zone from which the test fluids from Pt. McIntyre #9 originate. 7. The proposed injection will not initiate or propagate fractures through the confining zones. CONCLUSIONS: The injection of crude oil into the Pt. McIntyre #6 well for the purpose of storage will not promote waste, will not jeopardize correlative rights and will not endanger underground sources of drinking water. NOW, THEREFORE IT IS ORDERED: The Commission hereby approves the injection for storage, of limited volumes of crude oil from the testing of the Pt. McIntyre #9 well into the Pt. McIntyre #6 well. DONE at Anchorage, Alaska and dated January 15, 1991. Commission C. Smith Co issioner Oil and Gas Conservation Commission /2..~J'-<lU /l ~ Russell A. Douglass, Co ISSlOner Alaska Oil and Gas Conservation Commission #3 . . lflb J ~ 1 ~ UL::::. FRANK H. MURKOWSKI, GOVERNOR A"(A~1iA. OIL A5D 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 Integritv 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, U gnu, 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 l8A - 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 I - 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 DIO 16 - West McArthur 2 3 5 River Unit; WMRU 4D DIO 17 - North Cook Inlet 2 3 6 Unit; NCill A-12 DIO 19 - Granite Point 6 Field; W. Granite Point State 3 4 17587 #3 DIO 20 - Pioneer Unit; Well 3 4 6 1702-l5DA WDW DIO 21 - Flaxman Island; 3 4 7 Alaska State A-2 DIO 22 - Redoubt Unit; RU 3 No rule 6 D1 DIO 23 - Ivan River Unit; No rule No rule 6 IRU 14-31 DIO 24 - Nicolai Creek Order expired Unit; NCU #5 DIO 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 In.iection Orders Era 1 - Prudhoe Bay Unit; No rule 8 Prudhoe Bay Field, Schrader No rule Bluff Formation Well V-105 . . Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Integrity" Confmement" EIO 2 - Redoubt Unit; RU-6 5 8 9 · . ,) I 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AOFR1\1 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 AGENCY CONTACT DATE OF A.O. AOGCC 333 West ih Avenue, Suite 100 o Anchorage, AK 99501 [\If 907-793-1221 R T o Journal of Commerce 301 Arctic Slope Ave #350 Anchorage, A.K. 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 he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2004, and thereafter for _ consecutive days, the last publication appearing on the _ day of . 2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2004. Notary public for state of My commission expires Public Notices . . Subject: Public Notices From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 29 Sep2004 13:01 :04 -0800 10f2 9/29/2004 1:10PM Public Notices . . 20f2 9/29/2004 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 Content- Type: applicationlmsword Mechanical Integrity of Wells Notice.doc Content-Encoding: base64 Content- Type: applicationlmsword Ad Order form. doc Content-Encoding: base64 I of I 9/29/2004 I: 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 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 SOldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 /lJal'kd (tí/;d-t; David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 . [Fwd: Re: Consistent Wording for Injection.s - Well Integrity ... . Subject: [Fwd: Re:.Consistent WotgiIfg;for lrlJectioIl Ordér.s -Wen1r1t¢gri~y{~evis~4)] F~()m: John Nonnan<john=norman@agmin.state.ak.us> Date: Fri, 01 Oct 200411:09:26;..0800 more -------- Original Message -------- Subject:Re: Consistent Wording for Injection Orders - Well Integrity {Revised) Date:Wed, 25 Aug 2004 16:49:40 -0800 From:Rob Mintz <robert mintz@3law.state.ak.us> To:jim regg@3admin.state.ak.us CC:dan seamount@3admin.state.ak.us, john nonnan@3admin.state.ak.us Jim, looks good, but I still think maybe it would be good to include the following sentence or something like it in the well integrity and confinement rule: "The operator shall shut in the well if so directed by the Commission." My thinking is that otherwise, an operator might argue that the Commission can only require the well to be shut in by going through an enforcement action, issuing an order after notice and opportunity for hearing, or meeting the strict requirements for an emergency order under the regulations. The proposed language makes clear that it is a condition of the authorization to inject, that the operator must shut in the well if directed by the Commission after a notification of loss of integrity, etc. »> James Regg <iim regg(a¿,admin.state.ak.us> 8/25/20043:15:06 PM »> Rob - Thanks for the review; here's a redraft after considering your comments. I have accepted most of the suggested edits; also attached is response to questions you pose (responses are embedded in the comments, using brackets [JBR - ...] to set apart from your questions). Jim Regg Rob Mintz wrote: Jim, I have some questions about the draft language, which are shown as comments on the first document attached. Based on my current guesses about what the answers will be to my questions, I also have some suggested edits, which are shown as redlines on the second document attached. »> James Regg <jim regg@;admin.state.ak.us> 8/17/2004 4:33:52 PM »> Please delete previous version (email sent 8/9/04); I found another inconsistency in the injection orders regarding well integrity that I have integrated into the proposed fix. Attached is a proposal for consistent language in our injection orders addressing 3 rules related to well integrity: - "Demonstration of Tubing/Casing Annulus Mechanical Integrity" - "Well Integrity Failure" - "Administrative Actions". This proposal includes input from all Sr. staff (except Jack). If you agree with the approach, I'll work with Jody to prepare the public notice. Main points - Demonstration of Tubing/Casing Annulus Mechanical Integrity - standardizes the wording used for mechanical integrity demonstrations, and establishes abililty to grant alternate methods (e.g., temp survey, logging, pressure monitoring in lieu of pressure testing lof2 1012120044:07 PM [Fwd: Re: Consistent Wording for Injectioeers - Well Integrity .., . - specific to AIO 2C for Kuparuk, there is wording that is more appropriately included in Well Integrity Failure (i.e., more frequent MITs when communication demonstrated) - establishes more frequent MIT schedule for sluny injection wells (every 2 yrs) which is consistent with our current practice (but not addressed in regulations) Well Integrity Failure - retitles to "Well Integrity Failure and Confinement"; inserted language regarding injection zone integrity (see DIO 25 and 26) - consistent language regardless of type of injection (disposal, EOR, storage); - eliminates requirement for immediate shut in and secure; allows continued injection until Commission requires shut in if there is no threat to freshwater; - eliminates delay in notifYing Commission after detect leakage or communication ("i.e., "immediately notifY"); - removes language about notifYing "other state and federal" agencies; - requires submittal of corrective action plan via 10-403; - requires monthly report of daily injection rate and pressures (tubing and all casing annuli); this is a requirement we currently impose when notified of leak or pressure communication; - notice and action not restricted to leaks above casing shoe as stated in several DIOs Administrative Actions - adopts "Administrative Actions" title (earlier rules used "Administrative Relief"); - consistent language regardless of type of injection (disposal, EOR, storage); - uses "administratively waive or amend" in lieu of terms like "revise", "reissue", etc.; - adds geoscience to "sound engineering principles"; - language is more generic regarding fluid movement out of zone; existing versions mention varying combinations of protecting "freshwater", "aquifers", "USDWs"; "risk of fluid movement"; "fluid escape from disposal zone" Jim Regg John K. Norman <John Norman(â}admin.state.us> Commissioner Alaska Oil & Gas Conservation Commission 20f2 10/2/20044:07 PM JFwd: Re: Consistent Wording for Injection.s - Well Integrity... . Subject: [Fwd: Re:Consistent Wording for Injection Oni,ers ". WêIIIntêgrity (Revised)] From: John Norman <john_nqrman@admin.state.ak.µs> Date: Fri, 01 Oct 2004 11 :08:55 -0800 please print all and put in file for me to review just prior to hearing on these amendments. thanx -------- Original Message -------- Subject:Re: Consistent Wording for Injection Orders - Well Integrity (Revised) Date:Thu, 19 Aug 200415:46:31 -0800 From:Rob Mintz <robert mintz@¿law.state.ak.us> To:dan seamount@¿admin.state.ak.us, ¡im regg@¿admin.state.ak.us, john norman@¿admin.state.ak.us Jim, I have some questions about the draft language, which are shown as comments on the first document attached. Based on my current guesses about what the answers will be to my questions, I also have some suggested edits, which are shown as redlines on the second document attached. »> James Regg <iim regg@!admin.state.ak.us> 8/17/20044:33:52 PM »> Please delete previous version (email sent 8/9/04); I found another inconsistency in the injection orders regarding well integrity that I have integrated into the proposed fix. Attached is a proposal for consistent language in our injection orders addressing 3 rules related to well integrity: - "Demonstration of Tubing/Casing Annulus Mechanical Integrity" - "Well Integrity Failure" - "Administrative Actions". This proposal includes input from all Sr. staff (except Jack). If you agree with the approach, I'll work with Jody to prepare the public notice. Main points - Demonstration of Tubing/Casing Annulus Mechanical Integrity - standardizes the wording used for mechanical integrity demonstrations, and establishes abililty to grant alternate methods (e.g., temp survey, logging, pressure monitoring in lieu of pressure testing - specific to AIO 2C for Kuparuk, there is wording that is more appropriately included in Well Integrity Failure (i.e., more frequent MITs when communication demonstrated) - establishes more frequent MIT schedule for slurry injection wells (every 2 yrs) which is consistent with our current practice (but not addressed in regulations) Well Integrity Failure - retitles to "Well Integrity Failure and Confinement"; inserted language regarding i~ection zone integrity (see DIO 25 and 26) - consistent language regardless of type of injection (disposal, EOR, storage); - eliminates requirement for immediate shut in and secure; allows continued injection until Commission requires shut in if there is no threat to freshwater; - eliminates delay in notifYing Commission after detect leakage or communication ("i.e., "immediately notifY"); - removes language about notifYing "other state and federal" agencies; - requires submittal of corrective action plan via 10-403; - requires monthly report of daily i~ection rate and pressures (tubing and all casing annuli); this is a requirement we currently impose when notified of leak or pressure communication; - notice and action not restricted to leaks above casing shoe as stated in several DIOs Administrative Actions lof2 10/2/2004 4:07 PM [Fwd: Re: Consistent Wording for Injectioeers - Well Integrity ... . - adopts "Administrative Actions" title (earlier rules used "Administrative Relief'); - consistent language regardless of type of injection (disposal, EOR, storage); - uses "administratively waive or amend" in lieu of terms like "revise", "reissue", etc.; - adds geoscience to "sound engineering principles"; - language is more generic regarding fluid movement out of zone; existing versions mention varying combinations of protecting "freshwater", "aquifers", "USDW s"; "risk of fluid movement"; "fluid escape from disposal zone" Jim Regg John K. Norman <John Norman(â¿adrnin.state.us> Commissioner Alaska Oil & Gas Conservation Commission Content-Type: applicationlmsword Injection Order language - questions.doc Content-Encoding: base64 Injection Orders language Content-Type: applicationlmsword Content-Encoding: base64 20f2 10/212004 4:07 PM . . Standardized Language for Injection Orders Date: August 17, 2004 Author: Jim Regg Demonstration of Tubing/Casing Annulus Mechanical Integrity The mechanical integrity of an injection well must be demonstrated before injection begins, after a workover affecting mechanical integrity, and at least once every 4 years while actively injecting. For slurry injection wells, the tubing/casing annulus must be tested for mechanical integrity every 2 years. The MIT surface pressure must be 1500 psi or 0.25 psi/ft multiplied by the vertical depth, whichever is greater, must show stabilizing pressure and may not change more than 10% during a 30 minute period. Any alternate means of demonstrating mechanical integrity must be approved by the Commission. The Commission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. Well Integrity Failure and Confinement The tubing, casing and packer of an injection well must demonstrate integrity during operation. The operator must immediately notify the Commission and submit a plan of corrective action on Form 10-403 for Commission approval whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, or log. If there is no threat to freshwater, injection may continue until the Commission requires the well to be shut in or secured. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating pressure communication or leakage. 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. . . Standardized Language for Injection Orders Date: August 17, 2004 Author: Jim Regg Demonstration of Tubing/Casing Annulus 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 aftef a workover affecting mechanical integrity, ~md at løœ;t once every '1 years while actively injecting. For slurry injection 'NeIls, the tubing/casing ar..nulus must be tested for mechanical integrity e','ery 2 years. Unless an alternate means is approved bv the Commission. mechanical integrity must be demonstrated by a tubing pressure test using a:::¡::fie MI+-surface pressure of must be 1500 psi or 0.25 psi/ft multiplied by the vertical depth, whichever is greater, that ffH::l5f-show~ stabilizing pressure that doesand may not change more than 1 ~ percent during a 30 minute period. --Âfly alternate means of demonstrating mechanical integrity must be approved by the Commission. The Commission must be notified at least 24 hours in ádvance to enable a representative to witness pressure tests. Well Integrity Failure and Confinement Except as otherwise provided in this rule, +the tubing, casing and packer of an injection well must demonstrate maintain integrity during operation. \Vhencver any pressure communication. leakage or lack of iniection zone isolation is indicated by iniection rate. operating pressure observation, test, survey. log. or other evidence. t+he operator ffH±St-shall immediately notify the Commission and submit a plan of corrective action on a Form 10-403 for Commission approval, ..vhenever an\' pressure communication. leakage or lack of injection zone isolation is indicated bv J _ ' _ J injection rate. operating pressure observation, te~;t, sUf\'ey. or log. The operator shall shut in the well if so directed by the Commission. The operator shall shut in the well \vithout awaitin.g a response from the Commission if continued operation would be unsafe or would threaten contamination of freshwaterIf there is no threat to freshv..·ater, injection may continue until the Commission requires the '.vell to be shut in or secured. Until corrective action is successfully completed, Aª monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating pressure communication or leakage. 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. ·[F:d: Re: [Fwd: AOGCC Proposed WI Lan. for Injectors]] . S.t:lI:~Ject: [Fwd: Re: [Fwd: AOGCC Proposed WI Language for Injectors]] ~1"()m:Wifitofi Aubert <winto~aubert@adInin.state.ak. us> Ðat~: Thu, 28 Oct 200499:48:53 -0800 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 <EngelHR@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* ** loO 10/28/2004 11:09 AM [Fwd: Re: [Fwd: AOGCC Proposed WI La&e for Injectors]] . return~_ng 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 help/wordsmithing: "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 Ai Digert, Scott Ai Denis, John R (ANC) i Miller, Mike Ei 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 00 1 0/28/2004 11 :09 AM ~2 e . Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: The application of BP Exploration (Alaska) Inc. (BPX) for an order authorizing the underground storage of liquid hydrocarbons by injection into the undefined Kuparuk reservoir in the Point McIntyre No. 6 well. The Alaska Oil and Gas Conservation Commission has been requested by letter from BPX dated December 13, 1990 to issue an order authorizing the underground storage of liquid hydrocarbons by returning limited volumes of crude oil from the testing of Pt. McIntyre #9 well to the Kuparuk formation by injection into the Point McIntyre No. 6 well. A person who may be harmed if the requested order is issued may file a written protest prior to 4: 00 pm December 31, 1990 with the Alaska Oil and Gas Conservation Commission, 3001 Porcu- pine Drive, Anchorage, Alaska 99501, and request a hearing on the matter. If the protest is timely filed, and raises a substantial and material issue crucial to the Commission's determination, a hearing on the matter will be held at the above address at 9: 00 am on January 16, 1991 in conformance with 20 AAC 25.540. If a hearing is to be held, interested parties may confirm this by calling the Commission's office, (907) 279-1433, after December 31, 1991. If no proper protest is filed, the Commission will consider the issuance of the order without a hearing. ~' / -) . I - / L/ " \,,' ,-, It... J~ ~~,~ (... Lonnie C. Smith Commissioner Published December 14, 1990 :#1 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 17;7;'~;?';·"~'^'-_ Anchorage, Alaska 99519-6612. '.;~'.~."../~_".;'.'~_ ~" -_..../ (907) 561-5111 I (;;,;;/i --:- ! I t'ÖF,1 ;;.-- lr5< -.1 ;:.. ~ , " , ¡ . ~ ,-~ r : : j -...---; . ¡ /2 ::__-,TT'¿;PlI IC';;3~T-~ f---- ~r;;.J I '" ... i"-~)';;i,ljh ff/~~¥~1U '''~:....~.-...."._- _A_~__':..____) . . Iii BP EXPLORATION December 13, 1990 Lonnie Smith Commissioner AOGCC Porcupine Drive Anchorage, AK Dear Lonnie: BP Exploration requests permission to reinject produced fluids from the Pt McIntyre No.9 well back into the same reservoir through the Pt Mcintyre NO.6 well bore. Both bottom hole locations are in 100% BP acreage and are within 1 mile of each other and both surface locations are at West Dock 3. Pt McIntyre NO.6 well data necessary to evaluate this request is attached as listed below: 1 . Cement Bond Log (CBT) 2. Wellbore diagram Mechanical integrity tests were performed prior to testing Pt Mcintyre NO.6 and will be performed prior to testing Pt Mcintyre NO.9. Pt Mcintyre No.9 is a tight hole and therefore we request that all conversations and data relating to this well be held confidential. If additional information is required, please do not hesitate to call Bob Janes at 564-4623 or Sandy Macfarlane at 564-4725. Sincerely, .ç Terry J. Obeney Manager NiakuklPt Mcintyre REQEIVED DEC 1 3 1990 Alaska Oil & Gas Cons. Commission Anchorage STATE OF ALASKA ADVERTISING ORDER Ad#-8485 Acct#-STOF0330 AO: 08-5648 AO- 08- 56M3 F R o M Anchorage Daily News P. O. Box 11.9001 Anchor(lge, þJ( 99514-9001 T o p U B L I S H E R AJ.<1ské.1. lli1 & Gas Conservation Caxmi.ssion 3001 Porcupine DriVè Anchorage, AK 99501 ADVERTISING ORDER NO. AGENCY CONTACT Patty Shanðers DATE OF A.a. December 13, 1990 PHONE 779-1433 (907) DATES ADVERTISEMENT REQUIRED: December 14, 1990 SPECIAL INSTRUCTIONS: AFFIDAVIT OF PUBLICATION UNITED STATES OF AMERICA STATE OF Alaska ss third DIVISION. BEFORE ME, THE UNDERSIGNED, A NOTARY PUBLIC THIS DAY PERSONALLY APPEARED Shelly Ryan WHO, BEING FIRST DULY SWORN, ACCORDING TO LAW, SAYS THAT HE/SHE IS THE Legal Ad Rep. OF the Daily News PUBLISHED AT Anchorage IN SAID DIVISION third AND STATE OF Alaska AND THAT THE ADVERTISEMENT, OF WHICH THE ANNEXED IS A TRUE COPY, WAS 14th PUBLISHED IN SAID PUBLICATION ON THE DAY OF December 19~, AND THEREAFTER FOR ~ CONSECUTIVE DAYS, THE LAST PUBLICATION APPEARING ON THE ~~AY OF December 19~, AND THAT THE RATE CHARGED THEREON IS NOT IN EXCESS OF THE RATE /aj'L~ SUBSCRIBED AND SW RN TO BE"RE ME THIS~DAY OF'-t:::.:--L."- ç~~g.s.C) C-·,,\'\., . tà ,., (-.., '-- \.........s;¡.'" '\. & '- -",,'-......<::1 ç . ......_ NOTARY PUBLIC F À STATE OF J~h MY COMMISSION EXPIRES JULY 3, ! 494 02-901 (Rev. 6-85) PUBLISHER REMINDER- 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. ATTAC~ I I I Notice of Public Hearing TION HERE. STATE OF ALASKA . Alaska 011 and Gas Conservation Commission Re: The. application of Bi> Exploration (Alaska) liìê: (B PX) for an order authoriz- ing the underground storage,of liquid hydrocarbons by inlec- tio.n into the undefined Kupa- ruk reservoir in the Point Mc- intyre NO.6 well. The Alaska Oil and Gas Conservation Commission has been requested by letter. from BPX dated December 13, 1990 to issue an order authorizing the underground storage of liquid hydrocarbons by return- Ing limited vOlur,1es - òfcrUde 011 from the testing of Pt- . Mcintyre 119 well to the Kupa-· ruk formation by Inleçtion into the Point Mcintyre No.6 well. A person who may be harmed.1f the requested order Is issued may file a written protest prior to 4:00 pm De- cember 31, 1990 with the Alas- ka 011 and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska 99501, and request a hearing on the matter. If the protest is timely filed, and raises a sub- stantial arid material Issue crucial to the Commission's ~~~e':alt~::i?;íll ~e h:~~na~ t~~ I above address at 9:00 am on January 16. 1991 In confor· mance with 20 AAC 25.540. If a hearing Is to be held, interest- ed parties may confirm thiS by calling the Commission's office, (907) 279-1433, after De- cember 31, 1991. If no proper protest Is filed, the Commis- sion will consider the Issuance of the order without a hearing. Is! Lonnie C. Smith Commissioner p,ub:December ~4, 1990 AO: Oé-5648 .