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10/6/2005 Orders File Cover Page.doc
A •
Other Index #063
Oooguruk Improper Injection
1. April 23, 2010
Email from Pat Foley to Commissioner Foerster re Notice
of Oooguruk Injection
2.----------------------
Emails re: Oooguruk Glycol Water Injection Issue
3. August 20, 2010
Letter from AOGCC to Pioneer re: Notice of Proposed
Enforcement Action
4. September 2, 2010
Letter from Pioneer to AOGCC re: Notice of Enforcement
Action Improper Class II Injection in ODSK-38
5. September 13, 2010
Letter from Pioneer to AOGCC re: Notice of Mis-
injection ODSK-38i
6. September 13, 2010
Pioneer's Mis-injection Enforcement Payment, check copy
7. September 30, 2010
Letter from Pioneer to AOGCC re: Violation Action
Improper Class II Injection in ODSK-38i
Other Index #063
• •
V F!, SEAN PARNELL, GOVERNOR
AI ASHA OIL AND GAS 333 W. 7th AVENUE, SUITE 100
CONSERVATION COMMISSION ANCHORAGE, ALASKA 99501 -3539
PHONE (907) 279 -1433
FAX (907) 276 -7542
November 19, 2010
Mr. Ken Sheffield
Pioneer Natural Resources Alaska, Inc.
700 G Street, Suite 600
Anchorage, AK 99501
RE: Closeout of ODSK -38 Enforcement Action
Dear Mr. Sheffield:
The Alaska Oil and Gas Conservation Commission issued its final Decision and Order regarding
the improper injection of glycol in well ODSK -38 waste determination on October 22, 2010. As
part of the decision, Pioneer Natural Resources Alaska, Inc (PXD) was ordered to pay a civil
penalty, submit injection operation training protocols, train operating personnel according to the
protocols and submit a list of trained individuals.
PXD has satisfied all obligations as directed under the Commission's Decision and Order. This
enforcement action is considered closed.
Sincerely,
Cathy P./Foerster
Commissioner
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West Seventh Avenue, Suite 100
Anchorage Alaska 99501-3539
Re: Improper Class II Injection in )
Oooguruk Unit ODSK-38; ) AOGCC Order No. 63
Pioneer Natural Resources Alaska, Inc. ) October 22, 2010
DECISION AND ORDER
The Alaska Oil and Gas Conservation Commission (Commission) issued a Notice of
Proposed Enforcement Action (Notice) under 20 AAC 25.535(b) on August 20, 2010 stating
Pioneer Natural Resources Alaska, Inc (PXD) engaged in improper fluid injection in Oooguruk
Unit enhanced recovery well ODSK-38 (Oooguruk ODSK-38). The Commission proposed
specific corrective actions and a $10,000 civil penalty under AS 31.05.150(a).
In reply to the notice of enforcement, PXD:
(1) provided a letter on September 2, 2010 not contesting the proposed enforcement
action, requesting information regarding payment of the fine and seeking
clarification regarding corrective training protocols.
(2) delivered a check in the amount of $10,000 on September 13, 2010 to the
Commission office in payment of the civil fine.
(3) delivered copies on September 30, 2010 of an implementation letter and two
training documents; "AOGCC Area Injection Order -- Overview Training" and
"Pioneer Management of Change -- Overview Training".
AOGCC Order #63 • • October 22, 2010
Page 2 of 6
A. Summary of Proposed Enforcement Action
In its Notice, the Commission identified violations by PXD of Rule 3 of Area Injection
Order No. 33 (AIO 33), specifically that on two occasions, PXD injected glycol -water mixtures
which were not approved injection fluids authorized by Rule 3 or any subsequent Administrative
Approvals. The Commission proposed the following corrective actions:
(1) within 30 days from the effective date of the enforcement order, PXD shall
submit for Commission review and approval new protocols established to
ensure that all responsible PXD personnel are aware of the fluids approved for
ER injection and the protocol necessary to request authorization of additional
fluids as provided in AIO 33;
(2) upon approval by the Commission, PXD shall train all personnel responsible for
injection fluid management consistent with the new protocols; and
(3) within 30 days of approval of the new injection fluid management protocols,
PXD shall provide the Commission the list of trained individuals and date of
completing the training.
In addition, the Commission proposed payment by PXD of a civil penalty under
AS 31.05.150(a) in the amount of $10,000 ($5,000 per violation).
AOGCC Order #63 • • October 22, 2010
Page 3 of 6
stated:
B. Misinjection of Glycol -Water Mixtures
Rule 3 of AIO 33 authorized 4 specific fluids for enhanced recovery injection and further
"The injection of any other fluids, or mixtures of the above fluids, shall be approved by
separate administrative action. "
Two administrative approvals were issued under AIO 33 regarding enhanced recovery
injection,' but did not authorize glycol -water mixtures for such purposes.
C. Violation
Two separate improper injections of glycol -water mixtures were admitted by PXD in its
April 23, 2010 letter to the Commission. Both occurred in the second quarter of 2009 while
PXD commissioned the Oooguruk pipelines used to supply water for enhanced recovery
injection. The letter detailed the circumstances of the improper injection and included a
description of the steps taken to insure additional improper injection would not occur.
D. Mitigating Circumstances
Mitigating factors considered by the Commission include (1) PXD's admission of the
improper injection; (2) lack of injury to the public as demonstrated by the mechanical integrity of
Oooguruk ODSK-38; (3) geologic confinement of all fluids injected into Oooguruk ODSK-38;
and (4) compatibility of glycol -water mixtures with the Kuparuk formation in nearby fields such
as Kuparuk River and Prudhoe Bay where such mixtures have been approved for injection as
part of enhanced recovery.
AOGCC Order #63
Page 4 of 6
• October 22, 2010
PXD attributed this improper injection to operating personnel experienced in other North
Slope enhanced recovery operations where glycol -water mixtures are authorized for injection.
Reliance by these personnel on a waste handling reference document utilized by other North
Slope operators was a causal factor.2
AIO 33 concluded there are no underground sources of drinking water in the affected
area of Oooguruk-Kuparuk formation enhanced recovery injection. Coupled with the confirmed
mechanical integrity of Oooguruk ODSK-38 and the geologic confinement of injected fluids to
the Oooguruk-Kuparuk formation, the lack of underground sources of drinking water mitigates
the concerns about harm to the surface and subsurface environments.
The Commission also considered mitigation provided by PXD's acceptance of
responsibility and its efforts to develop the training protocols outlined in the September 20, 2010
correspondence. The training protocols, which address injection order requirements and
management of change, are applicable to PXD employees and Oooguruk contract personnel.
E. Findings and Conclusions
For the reasons stated above, the Commission finds that PXD violated rules governing
authorized fluids for enhanced recovery injection when it twice improperly injected glycol -water
mixtures into Oooguruk ODSK-38. PXD did not contest the Commission's proposed
enforcement action, paid the civil fine, and established and implemented training protocols for
employees and contractors at Oooguruk governing injection operations and management of
' AIO 33.001 authorizes injection of biocide -treated and oxygen -scavenged (BT-OS) seawater extracted from
Harrison Bay and BT-OS water from shallow source wells; AIO 33.002 authorizes injection of BT-OS effluent from
the ODS reverse osmosis unit and a mixed stream of the fluids authorized by AIO 33.001 and AIO 33.002.
2 Alaska Waste Disposal and Reuse Guide, Revision 8; December 2008; document jointly prepared by BP
Exploration (Alaska) Inc. and ConocoPhillips Alaska Inc. for use by staff and contract personnel at all BPXA and
CPAI facilities in Alaska.
AOGCC Order #63
Page 5 of 6
• October 22, 2010
change. The Commission finds PXD's new training protocols to be satisfactory effort to help
prevent further occurrence of improper fluid injection at Oooguruk.
NOW THEREFORE IT IS ORDERED THAT:
PXD shall:
1. Comply with the Commission's regulations, orders, approved administrative actions, and
approval conditions relating to injection for enhanced recovery purposes at Oooguruk.
2. Implement and update as necessary the training protocols governing injection operations
and management of change outlined in PXD's September 30, 2010. PXD shall maintain
and make available for Commission inspection records to substantiate completed training
for Oooguruk personnel.
Done at Anchorage, Alaska this 22th day of October, 2010.
Daniel T. Seamou t, Jr., Chair, Commissioner
Alasle-Oil and/MConservation Commission
Alaska Oi1Gas Conservation Commission
gaty P oerster, Commi sioner
Alaska Oil and Gas Conservation Commission
AOGCC Order #63
Page 6 of 6
RECONSIDERATION AND APPEAL NOTICE
0 October 22, 2010
As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the
Commission grants for good cause shown, a person affected by it may file with the Commission an application for reconsideration of
the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration
must set out the respect in which the order or decision is believed to be erroneous.
The Commission shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to
act on it within 10-days is a denial of reconsideration. If the Commission denies reconsideration, upon denial, this order or decision
and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after
the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision denying
reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which
the application for reconsideration was filed.
If the Commission grants an application for reconsideration, this order or decision does not become final. Rather, the order or
decision on reconsideration will be the FINAL order or decision of the Commission, and it may be appealed to superior court. That
appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise
distributes, the order or decision on reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited
to the questions presented to the Commission by the application for reconsideration."
In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in
the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00
p.m. on the next day that does not fall on a weekend or state holiday.
Colombie, Jody J (DOA)
From: Hart, David [David. Hart@pxd.com]
Sent: Wednesday, November 17, 2010 1:36 PM
To: Hart, David; Seamount, Dan T (DOA)
Cc: Foerster, Catherine P (DOA); Norman, John K (DOA); Colombie, Jody J (DOA); Foley, Pat; Sheffield,
Ken; Smith, Bonnie; Sturtevant, Craig
Subject: Pioneer Oooguruk Area Injection Order Training, AOGCC Order No. 63
Attachments: 2010 HSE Training Matrix, MOC and AIO update, 11- 16- 10.pdf; K38i Improper Injection AOGCC
Order 63.pdf
Dear Commissioner Seamount,
Pursuant to AOGCC Order No. 63, issued to Pioneer on October 22, 2010, Pioneer submits the attached "2010 HSE Training
Matrix, MOC and AIO Update, 11- 16 -10" to demonstrate compliance with items (2) and (3) on page 2, and item 2 on page 5 of
Order No. 63.
Specifically, Pioneer trained all operations personnel responsible for Class 2 FOR injection fluid management including
Anchorage -based engineering, supervisory and management staff, as well as field -based operations and supervisory staff. This
training consisted of two modules, as approved by the AOGCC: "AOGCC Area Injection Orders Overview Training" and
"Management of Change Overview Training ".
This HSE Training Matrix lists all operations staff by name, title and date of training for each of these two modules. We have
retained the associated training rosters as inspection records in the event the AOGCC requests further review of these records.
i
I believe this training completes all outstanding Pioneer obligations related to AOGCC Order No. 63. Please contact me with any
questions on this matter at 343 -2125.
Regards, David Hart
David Hart
Operations Manager
Pioneer Natural Resources Alaska
700 G Street, ATO 600
Anchorage, AK 99501
A
V , : 907.343 -2125 :907.244-1722 l.: 907.343 -2192 I 'Z: david.hartaC2pxd.com
Statement of Confidentiality:
This message may contain information that is privileged or confidential. If you receive this transmission in error, please
notify the sender by reply e -mail and delete the message and any attachments.
i
2010 Regulatory Matr
i Y
f y
l
O1 I w
Y
1
MOM •
Auditable Position Noted in Orange 17 + 18
Positional Category 1 Last Name ! First Name 1 yr 1 yr
Manager Cutting Dan 09130/10 10105110
Manager Hart Dave 09130/10 09/30110
Operati Superintende Gdroy� Jim 10118110 09130110
Operations Supervisor R auchenstein _ — R — ock t ! 10118/10 10/18/10
y _ Operations Supervisor Clark James / 10 /18 /10 1010
P Engineer Williams Theresal 09130110 0913_0
Facilities Engineer Kay Ouyen 11101 10 127/1 0
O Analyst Conner Marlene 10_127110 10
ASRC Craft Ferrell Tim 07/05110 1
MST Aikey Dave 10/18110 10118/10
MST Augustine Ev erett 07 /06110 10 /05110
MST Campanella Michael 10118/10 10/05110
p .. �11I7
MST Christo he Bdl 10119/10: _
MST Curphey Ian 10 /18/10 10118110
MS T Danjin Wayne 07106/10 10118/10
MST DeMoss Roger _1011_8 j 10105110
MST Diselrodl Joel 101 18110 10 /18/10
MST _ Drake Matt _07 10/0511
MST Garvin _ Greg 10118/10 1011_811_0
M ST Gilroy David, 07107110 10
MST Hall Aaron.. 10119/10 10 118/10
MST Hollenberg Shaun 10/ 18110 10105110
MST Hulien Dave 0712 8110 10/05110
MST Messer _ Lloyd 10118110 10111110
MST Moran Pa 10118110 10118110
MST Stagner Was 10/1811 10118110
MST Tredway Tom 07106/10 10105/10
g 7
PIONEER
NATURAL RESOURCES ALASKA
J. Patrick Foley
Manager of Land and External Affairs
Pioneer Natural Resources Alaska, Inc.
700 G Street, Suite 600
Anchorage, Alaska 99501
Voice (907) 343-2110 - Fax (907) 343-2190
Commissioner Daniel T. Seamount, Jr. September 30, 2010
Alaska Oil and Gas Commission
333 W. 7th Avenue, Suite 100
Anchorage, AK 99501-3539
Re: Violation Action
Improper Class H Injection in ODSK -38i
Dear Commissioner Seamount:
I am writing today to provide the follow-up documentation requested by the Commission in its
letter of August 20, 2010 which sets forth the proposed action regarding the ODSK-38i and
future educational requirements and procedures to better ensure Pioneer's complete compliance
with all aspects of the AOGCC's regulatory authorizations that relate to injection practices.
In specific response to the request to submit "new protocols established to ensure that all
responsible PXD personnel are aware of the fluids approved for enhanced recovery injection and
the protocol necessary to request authorization of additional fluids as provided is AIO 33", we
submit the following:
1. AIO 33 and AIO 34 Training Protocol — September 22, 2010
2. AOGCC Area Injection Orders Overview Training PowerPoint Presentation
3. Management of Change Overview Training PowerPoint Presentation
If you have questions on this material or should you have suggestions for improvement we
would be please to meet with you or your staff to discuss this training program in more detail.
The August 20, 2010 letter requires that Pioneer provide the Commission with a list of trained
individuals within 30 days of the date the Commission approves the new protocols. Please let us
know if this material satisfactorily addresses the concern and is approved by the Commission.
I would appreciate if you would please direct follow-up questions and communications regarding
this matter to my attention.
Sincerely,
J. Patrick Foley
cc: Hawk Consultants
0
Area Injection Order 33 and 34 Training Protocol — September 22, 2010
The following protocol will be used to ensure Pioneer injects only authorized fluids into Oooguruk's
Class 2 FOR injection wells, pursuant to our AOGCC Area Injection Orders (AIO) 33 (Kuparuk) and 34
(Nuigsut).
Pioneer has created two training programs which presented in combination will ensure AIO's 33 and 34
are followed. These training programs will be provided to all Pioneer and ASRC Multi -Skilled Technicians
(MST's), field supervisory staff and field engineering staff. These training programs are:
1) AOGCC Area Injection Orders -Overview Training
This training will explain the purpose of the 10 Rules within each AIO 33 and 34, and
specifically focus on the authorized injection fluids allowed for enhanced recovery per Rule
3.
2) Pioneer Management of Change - Overview Training
This training will explain the purpose of OSHA's Process Safety Management program, with
specific focus on the Management of Change (MOC) element 10. MOC requires engineering
and management approval to modify any process, material or equipment through the use of
written procedures, analysis, training and documentation. Pioneer's MOC procedure and
MOC approval form are reviewed with the expectation that all employees must understand
and follow the instructions provided.
Formalized and documented education of the field operations, supervisory and engineering staff
regarding the specific intention and content of the Oooguruk Area Injection Orders 33 and 34 will ensure
only authorized fluids are injected into the Oooguruk Kuparuk and Nuiqsut FOR wells. MOC training will
reinforce that no exceptions to the AIO's can occur without formal engineering and management
approval. Engineering and management will be responsible for coordinating any amendments to AIO 33
and 34.
The training roster documentation will be filed in the Pioneer Alaska training tracking system managed
by Pioneer's HSE Department to ensure additional oversight of this training compliance.
The Management.of Change training was implemented starting in July 2010, and the Area Injection
Order training will be implemented beginning in October 2010.
b
David Hart
Alaska Operations Manager
Pioneer Natural Resources
CC Area Injection
Overview Training
9
11
PIONEER
■ Began in 1958, charged with protecting correlative rights and ensuring
Alaska's petroleum industry:
— Operates safely
— Avoids waste
— Achieves greater ultimate recovery of valuable hydrocarbon resources
— Protects underground freshwater sources
■ AOGCC review plans for all injection wells to ensure that:
d
— Fluids are injection into proper underground zones
— Fluids don't seep to other underground strata or the surface
■ Area Injection Orders (AIOs)
— Describe, evaluate, and approve subsurface injection on an area wide basis for
enhanced oil recovery
— First AIO issued in 1986
1
0
■ Enhanced Oil Recovery (EOR) {
— Injection or rein] ection of water and gas through injection {
wells from the surface to reinforce natural pressure in an oil
reservoir F
Production well
Water reinjection A Gas reinjection
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■ Orders approved April 11, 2008
■ Rule 1- Authorized Injection Strata for Enhanced
Recovery
— Authorized fluids may be injection for purpose of pressure
maintenance and enhanced oil recovery in approved Kuparuk and
Nuigsut formations
vIN1.�L{
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■ Rule 3 - Authorized Fluids for Enhanced Recovery
■ Amended March 131h/201h, 2009 and May 171h/19th, 2010
b
Injection water provided by the Kuparuk Field
c
I Produced water from the Kuparuk and Nuiqsut ail Pools
d
Tracer survey liquid to monitor reservoir performance
e
Biocide -treated and oxygen -scavenged sea water extracted from Harrison Bay, adjacent to the ODS
f
Biocide -treated and oxygen -scavenged water from the ODS shallow water source wells
I g
0
' Biocide -treated and oxygen -scavenged effluent from the ODS reverse osmosis unit
h
..:.Mixtures of the fluids described in ( , f}e} i, and ig} above
i
Non -hazardous Tyco!
Natural gas provided by'KRU CPF-3
and water mixtures
Glycol and water mixtures (until December 31, 2010, if quarterly
injectivity plots are submitted to AGGCC— separate application for
permanent approval may be submitted after October 31, 2010)
■ Rule 4 — Authorized Injection Pressure for Enhanced
Recovery
— Injection pressures must be maintained such that the injected fluids do
no fracture the confining zones or migrate out of the approved injection,
stratum
■ Rule 5 — Monitoring Tubing -Casing Annulus
— Tubing and casing annuli pressures of each injection well must be
monitored daily
• Except if prevented by extreme weather conditions, emergency
situations, or similar unavoidable circumstances
— Monitoring results shall be documented and made available for
AOGCC inspection
7
■ Rule 6 -Demonstration of Thbing/Casing Annulas
Mechanical Integrity
— Mechanical integrity must be demonstrated before injection begins and
before returning to service following a workover
— AOGCC-witnessed MIT must be performed after injection is
commenced for the first time in a well
• To be scheduled when conditions have stabilized (temp, pressure,
rate, etc.)
• 24-hour notice to AOGCC
— Subsequent tests must be preformed at least once every four years
— Unless alternate means are approved, tubing/casing annulus pressure
test using:
• Surface pressure of 1,500 psi or 0.25 psi/foot X vertical depth of
the packer, whichever is greater
• Pressure that shows stabilization with <10 % change during 30
minutes
■ Rule 7 -Well Integrity and Confinement
— Notify the AOGCC by next business day and submit a plan
* of corrective action for approval (Form 10-403) IF:
• Injection rate, operating pressure observations, test,
survey, log, or other evidence indicates pressure
communication, leakage, or lack of in ection zone
isolation
-- Immediately shut in well if continued operation would be
unsafe or threaten contamination of freshwater
— Submit a monthly report of daily tubing and casing annuli
pressures and injection rates for all wells indicating well
integrity failure or lack of injection zone isolation
■ Rule 8 — Notification of Improper Class II Inj ectoon
— Improper injection is any fluids other than those listed in Rule 4
(without prior authorization)
` — Immediately notify AOGCC upon discovery of improper injection
• Provide details of the operation
• Propose actions to prevent recurrence
— Immediately shut in well if fluids are found to be fracturing the
confining zone or migrating out the approved area
9
10
■ Rule 9 -Other Conditions
— AOGCC may suspend, revoke, or modify AIOs if injection
fluids fail to be confined within designated injection strata
■ Rule 10 -Administrative Action
— AOGCC may waive requirements of any rule or amend the
AIOs as long as the change:
• Does not promote waste or jeopardize correlative rights
• Is based on sound engineering and geoscience principles
• Will not results in an 'increased risk of fluid movement
into freshwater
11
*'I ■ Overview and Review of PSM
■ Definition and Purpose of MOC
■ Flixborough Case Study
■ Definition of Change
■ Regulatory Requirements
■ Procedure
■ Example
1
0
■ Process Safety Management (PSM) and Risk
Management Program (RMP)
Prevention or minimization of the consequences of
catastrophic releases of toxic, reactive, flammable,
or explosive chemicals
• RMP is regulated by the Environmental Protection
Agency (EPA)
— Intended to protect the public
PSM is regulated by the Occupational Safety and
Health Administration (OSHA)
Intended to protect employees
The 14 Elements of Process Safety Management
1. Employee Participation
2. Process Safety Information
3. Process Hazard Analysis
4. Operating Procedures
S. Training
6. Contractors
7. Pre -startup Safety Review
g. Mechanical Integrity
9. Hot Work Permit
10. Management of Change
11. Incident Investigation
12. Emergency Planning Response
13. Compliance Audits
14. Trade Secrets
Process Safety Management is part of OSHA requirements which are
for facilities and operations that contain hazardous or flammable
chemicals
3
Fj
Definition
■ A management system for ensuring that changes to
processes are properly analyzed, documented, and
communicated to affected personnel
Purpose
• Provide a strategy for ensuring that changes
• produce their intended benefits without any
adverse effects
■ The chemical plant was designed to produce 70,000
tons per year of caprolactam, a raw material used for
the production of nylon
■ The process i n , which the accident occurred consisted
of six reactors in series
■
Each reactor contained approximately 20 tons of
cyclohexane
Cause of the Disaster
One of the six reactors in series began leaking
The leaking reactor was bypassed in order to continue
operating
20" pipe was used to bypass the reactor instead of the 28"
specified
The change was temporary and never properly reviewed
The piping was inadequately supported causing flexing in the
pipe
The failure is thought to have been due to fatigue failure of a
Bellows (B4) --
M
0
L r
Aftermath of the Incident
The accident happened two
months after the temporary
change was implemented
40 tons of cyclohexane at
300 degrees F was released
to the atmosphere
■ The vapor cloud found an
ignition source 45 seconds
later destroying the plant
a The fuel air mixture was
estimated at the equivalent
of 15 tons of TNT
f 28 people killed in the
incident
Flixborough Case Study
Lessons Learned from Flixborough
R
.j
■ The incident may have been prevented if the process
change was reviewed by the appropriate personnel
The temporary change needed an expiration date so
that it could have been reviewed ( to replace the
temporary piping with the appropriate piping)
•l A system for tracking and managing change is now
required
11
I
� Change - any process addition,
deletion., alteration,
rearrangement, or replacement
item that is not in kind
■ Replacement in Kind - any item
� that meets the design specionficati
of the item it is replacing
9
Changes
Replacement In Kind
• Installing new pumps, heat
Replacing equipment that meets
exchangers, piping, or other
the same design specifications
equipment or chemical where
Replacing vessels, piping, and
none existed before
equipment with the same size,
• Changing from carbon steel to
metallurgy, wall thickness, and
stainless steel
design pressures and
temperatures
• Changing from schedule 40 to
Replacing a valve that is in all
schedule 80 pipe
aspects identical
Replacing a rising stem valve
Changing a controller set point
with one that is a quarter turn
within the design and operating
Changing an alarm or shutdown
limitations
set point
Routine filter element change
Change type of chemical used in
the process (i.e. corrosion
inhibitor, amine solvent,
hydrate inhibitor)
10
9 1 • Written Procedures
■ Considerations Addressed Prior to
Changes
• Inform and Train Employees
• # • Update Process Safety Information
■ Update Procedures
11
� Establish and implement written
procedures to manage changes to
process chemicals, technology,
equipment, and procedures; and,
changes to facilities that affect a
• covered process
12
The procedure must assure that the following
0 considerations are addressed an prior to change
P Y g
— The technical basis for any proposed change
-- The impact of the change on safety and health
The modifications to operating procedures
-- The necessary time period for the change
9—The authorization requirements for the proposed
13
a
■ Updating the process safety information is required
40 for all covered changes and may include the following
MSDS's
PEU D's
Process Technology
— Relief System Design
9—Material and Energy Balances
— Materials of Construction
14
Changes to all applicable operating procedures must
be considered and updated before a change is
implemented
All affected personnel must be informed of any
changes and instructed in new operating procedures
before .the change is implemented
•
i5
• a PSM is a performance standard
Each facility must determine how to comply
Each PSM facility will develop policies and written
procedures that complies with each element of
PSM
— Compliance is then based on whether or not the
facility is implementing and following its own
9 policies
A facility that is not following its written policies
is out of compliance even if the facility is still
within OSHA compliance
16
r-�
u
Simplified MOC Procedure
I Identify a Change I
Determine if the change is
temporary or
ress
Technical Basis impact on Health
and Safety
anent
Changes in Operating Authorization
Procedures Requirements
Obtain Approval
Update Process
Safetv Information
Update Operating Procedures
Inform and Train Affected Personnel
Implement Change
17
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� PIONIER
NATURAL RESOURCES ALASKA
Commissioner Daniel T. Seamount, Jr.
Alaska Oil and Gas Commission
333 W. 7th Avenue, Suite 100
Anchorage, AK 99501-3539
Re: Mis-injection Enforcement Payment
ODSK -38i
Dear Commissioner:
J. Patrick Foley
Manager of Land and External Affairs
Pioneer Natural Resources Alaska, Inc.
700 G Street, Suite 600
Anchorage, Alaska 99501
Voice (907) 343-2110 - Fax (907) 343-2190
September 13, 2010
Enclosed you will find Pioneer check number 976901 in the amount of $10,000 which is
delivered in payment of the Commission's enforcement action that results from a mis-injection
into the ODSK-38i. This payment is intended to satisfy fully the civil penalty assessed under
this enforcement action.
Pioneer will deliver to the Commission the requested documents that establish new protocols and
procedures to better ensure future compliance with AOGCC authorizations relative to its
injection practices in the very near future.
Sincerely,
"19(5D -
J. Patrick Foley
CF;1
SEP 1 3 2010
Pioneer Natural Resources USA, Inc.
976901
ALASKA OIL & GAS CONSERVATION COM 9/7/2010
Enforcement Action ODSK-381 i Well 10,000.00
PNR USA, Inc Op V#175598 10,000.00
Pioneer Natural Resources USA, Inc. 976901
ALASKA OIL & GAS CONSERVATION COM 9/7/2010
Enforcement Action ODSK-381 i Well 10,000.00
PNR USA, Inc Op V#175598 10,000.00
45
� PIONEER
NATURAL RESOURCES ALASKA
Commissioner Daniel T. Seamount, Jr.
Alaska Oil and Gas Commission
333 W. 7th Avenue, Suite 100
Anchorage, AK 99501-3539
Re: Notice of Mis-injection
ODSK -38i
Dear Commissioner:
J. Patrick Foley
Manager of Land and External Affairs
Pioneer Natural Resources Alaska, Inc.
700 G Street, Suite 600
Anchorage, Alaska 99501
Voice (907) 343-2110 - Fax (907) 343-2190
September 13, 2010
FC-E1V1=D
S E P I <<) 20110
I am writing on behalf of Pioneer Natural Resources Alaska, Inc. (Pioneer) to self -report a past
instance of mis-injection into Oooguruk Drill Site Kuparuk Well 38 (ODSK-38i). This mis-
injection occurred in April and May of 2009 and involved a mixture of seawater and shallow
well water injected for enhanced oil recovery (EOR) purposes. Although seawater and shallow
well water are approved for FOR injection, as explained below, the injection was not in
compliance with applicable conditions established in Rule 3 ("Authorized Fluids for Enhanced
Recovery") of the Alaska Oil and Gas Conservation Commission's (AOGCC's) Area Injection
Order (AIO) 33.
I. REPORT OF MIS -INJECTION AND EXPLANATION
During the initial start-up of Oooguruk waterflood operations using ODSK-38i, the anticipated
water supply from the Kuparuk River Unit (KRU) Seawater Treatment Plant (STP) was not
available from ConocoPhillips due to repairs and related constraints at the STP and associated
seawater supply pipelines. This supply shortage was not anticipated by Pioneer. Pioneer
responded by seeking authorization from the AOGCC to use additional fluid sources for FOR
purposes. Pioneer's request resulted in Administrative Approval AID 33.001, issued by the
AOGCC on March 13, 2009. As relevant here, AIO 33.001 amended Rule 3 of AIO 33 to
authorize use of, among other things, "sea water extracted from Harrison Bay, adjacent to the
Oooguruk Drill Site (ODS)" and "ODS shallow water source wells" as approved FOR injection
fluids, provided that such fluids were "biocide treated and oxygen -scavenged."
Initial injection of FOR fluids approved for use in AID 33.001 began on March 21, 2009. The
fluids injected from March 21st through April 23rd were a mixture of seawater, shallow well
water and Reverse Osmosis Unit (RO) effluent (also an approved FOR fluid). The seawater and
well water were biocide treated and oxygen scavenged as required by Rule 3. However, for as
many as twenty-two (22) days, from April 2, 2009 and through April 23, 2009, the seawater and
shallow well water mixture may not have been oxygen scavenged and/or biocide treated as
required. Specifically, no oxygen scavenger may have been used during this entire period and,
ODSK-38i Mis-Injection Notice
September 13, 2010
during the first thirteen (13) days of this period, no biocide may have been used.' The total
volume of FOR fluids (RO effluent+seawater+well water) injected into ODSK-38i during this
twenty-two day period was 62,510 bbls.
On April 24, 2009, seawater from the KRU STP became available again and Pioneer
discontinued use of alternative water sources. However, on May 4, 2009 and continuing for an
eighteen (18) day period through May 21, 2009, Pioneer supplemented seawater from the KRU
with a mixture of seawater extracted at Oooguruk and shallow well water. The Oooguruk
seawater and shallow well water was biocide treated, but was not oxygen scavenged. The total
volume of FOR fluid (KRU seawater+Oooguruk fluids) injected during this eighteen day period
was 39,310 bbls. From May 22, 2009 forward to the present, Pioneer has only injected seawater
supplied by ConocoPhillips from the KRU STP.
II. ENFORCEMENT FACTORS
The following additional information is provided with respect to the factors identified in AS
31.05.150(g):
A. The extent to which the actions were taken in good faith
This mis-injection involved the same Pioneer personnel, occurred during the same April/May
2009 time frame and arose from the same basic circumstances and errors that led to Pioneer's
previously reported glycol/water mixture mis-injection into the same well. Accordingly,
although this notice is later in time than Pioneer's notice regarding the glycol/water mis-
injection, the events being reported here were contemporaneous with the glycol mis-injection.
As with the glycol events, the fundamental cause of this mis-injection was a combination of
inadequate communication and training regarding the requirements of AIO-33 and, in particular,
Rule 3. These events reflect honest and good faith errors in training, communication and
judgment.
It should be noted that this mis-injection is not a circumstance identified by Mr. Kelley in his
ADS document or in any other communications. Rather the facts were openly identified by the
Oooguruk Operations Supervisor in materials requested by and voluntarily provided to Hawk
Consultants as part of its investigation of Mr. Kelley's allegations. This disclosure resulted in
further inquiry by Hawk Consultants and investigation by Pioneer, leading to identification of the
mis-injection and, ultimately, this notice.
B. The extent to which violations were willful or knowing in manner
For the reasons described above, the mis-injection reported here was neither willful nor knowing.
C. The extent and seriousness of the violation and the actual or potential threat
to the public health or the environment
'The documentation associated with the events reported in this notice are operator
notices reflecting block periods of time, rather than daily or even weekly conditions. Pioneer has
reported the maximum period during which there may have been non-compliance.
ODSK-38i Mis-Injection Notice
September 13, 2010
0
The mis-injection in this instance never presented an actual or potential threat to either the public
health or to the environment. Untreated seawater and well water injected in the Kuparuk are
directed only into the subsurface. Subsurface fluids are not a public health concern or hazard at
Oooguruk or on the North Slope. Moreover, neither seawater nor well water are hazardous
substances or present public health concerns in the context of FOR injection.
D. The injury to the public resulting from the violation
The public did not suffer any detectable injury or consequence. Pioneer appreciates that every
regulatory infraction is a form of injury to the public. In this instance, we respectfully believe
that the injury, if any, was very slight.
E. The benefits derived from committing the violation
Pioneer did not derive any benefits from the mis-injection events.
F. The need to deter similar behavior by others
Pioneer is not aware of circumstances indicating that there is an incentive for others to make a
similar mistake, or that other operators have, in fact, done so.
G. The efforts made to correct and prevent further similar unauthorized actions
There are sound operational reasons to biocide treat and oxygen scavenge the seawater and water
well sources involved in this matter. However, in this instance, the period of mis-injection was
relatively short and the volumes involved were relatively small. Consistent with these
circumstances, no damage to the reservoir or increased corrosion has been detected. Pioneer's
production from the Kuparuk reservoir is well -documented and has been reviewed by Hawk
Consultants and the AOGCC. It is known to the full extent practicable that there have been no
detectable adverse consequences to the reservoir. There are no prudent different or additional
actions or monitoring to conduct with respect to reservoir function. With respect to corrosion, it
would not be possible to distinguish between the effects of the identified events and the effects of
ordinary use. However, it is possible to determine whether the involved equipment and pipelines
have, by whatever causes, experienced unusual corrosion. Pioneer routinely performs external
ultrasonic testing (UT) of the relevant equipment/facilities in the ordinary course and has done so
on several occasions since these reported events. The involved equipment/pipelines remain
within expected and safe tolerances, and do not exhibit unusual or unexpected corrosion. This
testing is the most practicable and prudent physical remedial action to take under the
circumstances.
With respect to the basic underlying cause of this mis-injection, pursuant to the AOGCC's recent
enforcement action concerning the glycol/water mis-injection, in which Pioneer has fully
concurred, Pioneer is required to develop "new protocols" on an established schedule with
AOGCC oversight "to ensure that all responsible Pioneer personnel are aware of the fluids
approved for enhanced recovery injection[.]" Because the currently reported mis-injection
resulted from the same underlying cause, Pioneer is already taking the appropriate corrective
action under the formal auspices of an AOGCC enforcement action.
ODSK-38i Mis-Injection Notice*
September 13, 2010
is
Finally, Pioneer observes that its senior operations staff at Oooguruk are in a transition to new
managers. Subsequent to the events described in this notice, David Hart became the Oooguruk
Operations Manager. Mr. Hart has been intimately involved in investigating and implementing
changes responsive to Mr. Kelley's concerns and in leading Pioneer's efforts to cooperate to the
fullest extent possible with the investigation being conducted by the AOGCC through Hawk
Consultants. Pioneer believes that Mr. Hart brings to this senior operations position a keen
understanding of and appreciation for the identified mis-injection issues, as well as the other
issues addressed by Hawk Consultants, and we encourage the AOGCC to obtain Hawk
Consultants' perspective and judgment on this key leadership change. In addition, Pioneer is in
the process of hiring a new Oooguruk Operations Superintendant and has created a new position
for an on -site Facilities Engineer. These actions ensure that necessary changes are being
embraced and implemented from a fresh perspective by Pioneer managers at the Oooguruk
facility without reason to feel defensive.
I would appreciate if you would please direct follow-up questions and communications regarding
this matter to my attention.
Sincerely,
J. Patrick Foley
cc: Hawk Consultants
0 PIONEERS
NATURAL RESOURCES ALASKA
Commissioner Daniel T. Seamount, Jr.
Alaska Oil and Gas Commission
333 W. 7th Avenue, Suite 100
Anchorage, AK 99501-3539
Kenneth H Sheffield, Jr.
President
Pioneer Natural Resources Alaska, Inc.
700 G Street, Suite 600
Anchorage, Alaska 99501
Voice (907) 343-2112 - Fax (907) 343-2190
September 2, 2010
F!
Re: Notice of Enforcement Action '3 Ell 2 `I
Improper Class II Injection in ODSK -38kL t,A'ri+stiSS�c;,
Dear Commission Seamount:
On behalf of Pioneer Natural Resources Alaska, Inc. ("Pioneer"), this letter responds to the
Alaska Oil and Gas Conservation Commission's ("AOGCC's") Notice of Proposed Enforcement
Action dated August 20, 2010 ("Notice").
As addressed in the Notice, Pioneer self -reported the mis-injection of a 50150 glycol/water
mixture into ODSK-38 in late April 2010. The details associated with this occurrence were
provided to the AOGCC in Pioneer's letter of May 24, 2010 and the associated attachments.
Pioneer concurs in the AOGCC's proposed action for this noncompliance, which consists of a
three -stage corrective action plan and payment of a $10,000 civil penalty.
In addition, Pioneer respectfully requests the following of the AOGCC in connection with this
matter:
1. That the AOGCC meet with Pioneer as soon as may be practicable to clarify and
to discuss the "new protocols" Pioneer is required to submit to the AOGCC
within 30 days of the effective date of the enforcement order;
2. That, for good cause, the AOGCC set the effective date of the enforcement order
as the date the clarification meeting between the AOGCC and Pioneer occurs; and
3. That the AOGCC provide Pioneer with the necessary information pursuant to
which Pioneer may pay the assessed $10,000 civil penalty.
Your consideration of these matters is sincerely appreciated. Please do not hesitate to call me if
you, or your staff, have any questions or concerns regarding this matter.
Sincerely,
enneth H Sheffield, Jr.
*3
r
17, A U'L70F 0 F� A I A 2 9 A SEAN PARNELL, GOVERNOR
ALASKA OIL AND GAS 333 W. 7thAVENUE, SUITE 100
CONSERVATION COAII USSION ANCHORAGE, ALASKA 99501-3539
PHONE (907) 279-1433
FAX (907)276-7542
August 20, 2010
Certified Mail Return Receipt Requested
7009 2250 0004 3911 4412
Mr. Ken Sheffield
President
Pioneer Natural Resources Alaska, Inc.
700 G Street, Suite 600
Anchorage, AK 99501
Re: Notice of Proposed Enforcement Action
Improper Class Il Injection in ODSK-38
Dear Mr. Sheffield:
Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (Commission)
hereby notifies Pioneer Natural Resources Alaska, Inc. (PXD) of a proposed enforcement action.
Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1
The Commission considers that PXD has violated the provisions of Area Injection Order No. 33
(AIO 33), Rule 3 ("Authorized Fluids for Enhanced Recovery") in connection with operating
Oooguruk Drill Site Kuparuk Well 38 (ODSK-38).
Basis for Findine the Violation or Noncompliance (20 AAC 25.535(b)(2
PXD apparently violated Rule 3 of AIO 33, by injecting a glycol -water mixture as an enhanced
recovery fluid prior to receiving Commission authorization to do so. Eight specific fluids have
been authorized for enhanced recovery in the Oooguruk-Kuparuk Oil Pool. Rule 3 of AIO 33
states in relevant part:
The injection of any other fluids, or mixtures of the above fluids, shall be approved by
separate administrative action.
Additional fluids were authorized for injection in Administrative Approvals AIO 33.001 and
33.002; glycol -water mixtures were not included in the list of approved fluids.
PXD's letter dated April 23, 2010 notified the Commission of two unauthorized injections of
glycol -water mixtures in the Oooguruk-Kuparuk Oil Pool during the second quarter of 2009. The
injections were part of commissioning the Oooguruk injection water pipeline. According to
S. Postal Service,,,,
ERTIFIED
MAIL,.,
RECEIPT
mestic Mail Only;
No Insurance
Coverage
Provided)
L
delivery information
visit our
website at
www.usps.com,;FFICIAL
USE
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Fee
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C3 Restdcted Delivery Fee
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sen'7 Pioneer Natural Res. Alaska
C3 or PO 700 G. Street, Suite 600
r �; Anchorage, AK 99501
■ Complete'items 1, 2, and 3. Also complete
Item 4 if Restricted Delivery is desired.
■ Print your name -and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front If space permits.
1. Article Addressed to:
Agent
y T*lted Alsme) C. Data of Delivery
D. is delivery address diffbrard rrom item 1? D Yes
If YES, enter delivW address below: ❑ No
Pioneer Natural Res. Alaska
700 G. Street, Suite 600 11
Anchorage, AK 99501 s. Service TYPQoExpress f
a Registered o Return Receipt for Mera,arialse
❑ hrsured Mail 0 C.O.D.
4. Restricted Delivery? Pft Fee) 13 Yes
2. Article_Numbeir
MWxlsrftMservicehbel) 7009 2250 0004 3911 4412
Ps Form 3811, February 20% Domestic Return Receipt 10-nt-into
Ken Sheffield
August 20, 2010
Page 2 of 4
PXD-provided information, 35,331 gallons of a glycol -water mixture was injected when the sea
water supply line was commissioned in May 2009 and an additional 9,596 gallons of glycol water
mixture was injected on May 28, 2009. In response to a request to provide an exact date of
pipeline commissioning, PXD responded that the water injection pipeline was first put in service
April 24, 2009.
PXD's April 23, 2010 letter also requested the Commission authorize future injection of glycol -
water mixtures for enhanced recovery and approve "after -the -fact" the glycol -water injections of
April - May 2009. In a separate action, the Commission approved the future injection of glycol
water mixtures into the Oooguruk-Kuparuk Oil Pool by Administrative Approval AIO 33.003
dated May 17, 2010.
This proposed enforcement action deals with the glycol -water injections of April - May 2009.
Although future injection of glycol -water mixtures has now been authorized, that specific action
is not germane to the unauthorized injections.
Proposed Action (20 AAC 25.535(b)(3).
Possible mitigating circumstances of this apparent violation include:
(1) evidence suggests all fluids injected into ODSK-38 are confined to the
Oooguruk-Kuparuk reservoir as intended;
(2) fresh water was not impacted nor does there appear to be any damage to the
reservoir; and
(3) PXD included details for revisions to its employee training protocols regarding
proper management of injection operations at Oooguruk..
However, it is evident that PXD was familiar with the Commission's regulatory requirements and
process based on applications for administrative approval requesting additional fluids/mixtures of
fluids for enhanced oil recovery injection. AIO 33.001 and 33.002 were both approved prior to
the apparent injection of unapproved glycol -water mixtures into the Oooguruk-Kuparuk Oil Pool.
The Commission proposes to order the following corrective actions by PXD:
(1) within 30 days from the effective date of the enforcement order, PXD
shall submit for Commission review and approval new protocols established to
ensure that all responsible PXD personnel are aware of the fluids approved for
enhanced recovery injection and the protocol necessary to request authorization
of additional fluids as provided in AIO 33;
(2) upon approval by the Commission, PXD shall train all PXD personnel
responsible for injection fluid management consistent with the new protocols;
and
(3) within 30 days of approval of the new injection fluid management protocols,
PXD shall provide the Commission with the list of trained individuals and date
of completing the training.
Ken Sheffield
August 20, 2010
Page 3 of 4
For violating AIO 33, Rule 3, the Commission additionally proposes to impose civil penalties on
PXD under AS 31.05.150 (a) as follows:
- $5,000 for each misinjection occurrence (2 events);
The total proposed civil penalty is $10,000.
Rights and Liabilities (20 AAC 25.535(b)(4)).
Within 15 days after receipt of this notification —unless the Commission, in its discretion, grants
an extension for good cause shown—PXD may file with the Commission a written response that
concurs in whole or in part with the proposed action described herein, requests informal review,
or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action
will be deemed accepted by default. If informal review is requested, the Commission will
provide PXD an opportunity to submit documentary material and make a written or oral
statement. If PXD disagrees with the Commission's proposed decision or order after that review,
it may file a written request for a hearing within 10 days after the proposed decision or order is
issued. If such a request is not filed within that 10-day period, the proposed decision or order will
become final on the I Ph day after it was issued. If such a request is timely filed, the proposed
decision or order will be of no effect, and the Commission will schedule a hearing.
If PXD does not concur in the proposed action described herein, and the Commission finds that
PXD violated a provision of AS 31.05, 20 AAC 25, or a Commission order, permit or other
approval, then the Commission may order one or more of the following: (i) corrective action or
remedial work; (ii) suspension or revocation of a permit or other approval; (iii) payment under the
bond required by 20 AAC 25.025; and (iv) imposition of penalties under AS 31.05.1.50, In taking
action after an informal review or hearing, the Commission is not limited to ordering the
proposed action described herein, as long as PXD received reasonable notice and opportunity to
be heard with respect to the Commission's action. Any action described herein or taken after an
informal review or hearing does not limit the action the Commission may take under AS
31.05.160.
Sincerely,
Daniel T. Seamount, Jr.
Chair, Commissioner
Ken Sheffield
August 20, 2010
Page 4 of 4
RECONSIDERATION AND APPEAL NOTICE
As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the
Commission grants for good cause shown, a person affected by it may file with the Commission an application for reconsideration of
the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration
must set out the respect in which the order or decision is believed to be erroneous.
The Commission shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to
act on it within 10-days is a denial of reconsideration. If the Commission denies reconsideration, upon denial, this order or decision
and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after
the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision denying
reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be tiled within 40 days after the date on which
the application for reconsideration was filed.
If the Commission grants an application for reconsideration, this order or decision does not become final. Rather, the order or
decision on reconsideration will be the FINAL order or decision of the Commission, and it may be appealed to superior court. That
appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise
distributes, the order or decision on reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited
to the questions presented to the Commission by the application for reconsideration."
In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in
the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00
p.m. on the next day that does not fall on a weekend or state holiday.
Page 1 of 4
0 0
Maunder, Thomas E (DOA)
From: Maunder, Thomas E (DOA)
Sent: Wednesday, August 04, 2010 10:45 AM
To: Foerster, Catherine P (DOA); Regg, James B (DOA)
Subject: FW: Oooguruk Glycol Water Injection Issue
Cathy and Jim,
Here is a message trail regarding the in service date of the Kuparuk to Oooguruk sea water supply line. In the
course of completing the violation/enforcement letter I had asked for Pioneer to identify a specific date. It appears
that initial water movement through the line and the unauthorized injection of the glycol -water mixture would have
occurred on April 24, 2009 rather than "May 2009" as communicated previously. This probably doesn't make
much difference in the whole matter, but I am passing the information on for completeness and accuracy.
Tom
From: Foley, Pat [mailto: Pat. Foley@pxd.com]
Sent: Wednesday, August 04, 2010 10:28 AM
To: Maunder, Thomas E (DOA)
Cc: Hart, David; Kleinman, Mark
Subject: RE: Oooguruk Glycol Water Injection Issue
Tom,
I'm sorry my response has been delayed.
We have reviewed our K38i injection logs and I can report that on April 24, 2009, partial water deliveries from
KRU were injected into the Kuparuk reservoir. We previously reported a general "May 2009" period as the time
when our water supply line was brought into service. The more specific date is April 24.
Please call if you have other questions.
Pat
From: Maunder, Thomas E (DOA) [mailto:tom.maunder@alaska.gov]
Sent: Tuesday, July 27, 2010 4:13 PM
To: Foley, Pat
Subject: RE: Oooguruk Glycol Water Injection Issue
Pat,
I am working on the glycol wltter %jection matter. Here is a message trail we exchanged resolving the actual
volume number.
Enhanced recovery injection at ODS was initially prevented due to CPAI's inability to supply PXD with water and
multiple temporary sources were authorized.
The "normal" sea water supply was made available in May 2009 and that is when the glycol water was first
injected into ODSK-38. Do you have a specific date when sea water first flowed through the subsea pipeline? As
you can see below in my note of May 13, 2010, all I have for the initial event is "May 2009". Thanks in advance
for you assistance here.
Tom Maunder, PE
AOGCC
From: Foley, Pat [mailto:Pat. Foley@pxd.com]
9/10/2010
Page 2 of 4
0 0
Sent: Friday, May 14, 2010 8:11 AM
To: Maunder, Thomas E (DOA)
Cc: Roby, David S (DOA); Davies, Stephen F (DOA); Schwartz, Guy L (DOA); Hart, David; jwleppo@stoel.com;
Kleinman, Mark; Sturtevant, Craig
Subject: Re: Oooguruk AIO Modification Request
Thank you.
Pat
From: Maunder, Thomas E (DOA) <tom.maunder@alaska.gov>
To: Foley, Pat
Cc: Roby, David S (DOA) <dave.roby@alaska.gov>; Davies, Stephen F (DOA) <steve.davies@alaska.gov>;
Schwartz, Guy L (DOA) <guy.schwartz@alaska.gov>; Hart, David; Leppo, Jeffrey W. <JWLEPPO@stoel.com>;
Kleinman, Mark; Sturtevant, Craig
Sent: Fri May 14 11:09:02 2010
Subject: RE: Oooguruk AIO Modification Request
Pat, et al,
Thanks for clarifying the notice dates. Your requests for AIO amendments are being finalized.
We will notify you when they are completed.
Tom Maunder, PE
AOGCC
From: Foley, Pat (mailto: Pat. Foley@pxd.com]
Sent: Friday, May 14, 2010 8:04 AM
To: Maunder, Thomas E (DOA)
Cc: Roby, David S (DOA); Davies, Stephen F (DOA); Schwartz, Guy L (DOA); Hart, David; Leppo, Jeffrey W.;
Kleinman, Mark; Sturtevant, Craig
Subject: RE: Oooguruk AIO Modification Request
Tom,
1 response to your questions:
1. The fluid balance below accurately summarizes what Pioneer believes has occurred with respect to the
glycol/water mixture. As reflected in the original information, some of the figures are measurements in
which we have high confidence, and some of the figures are estimates based upon experience and
conservative judgments.
2. Besides the September 2, 2009 notice from Joey Hall, Pioneer provided AOGCC of notice regarding
injection of glycol at the meeting with Cathy Foerster on April 22, 2010, followed by written notice via
email on April 23, 2010. These are the only notices from Pioneer to AOGCC regarding injection of the
glycol/water mixture of which we are aware.
Again, I am happy to address all of the Commissions questions and concerns. I am hopeful that a formal
response to our AIO expansion request is in the works and will be swiftly forthcoming. Anything you can share
regarding timing and likely outcome will be appreciated.
Thank you for working this issue with priority, as our desire to initiate WAG flood is strong.
9/10/2010
0
Page 3 of 4
Pioneer Natural Resources Alaska, Inc.
Manager of Land and External Affairs
700 G St., Ste 600, Anchorage, AK 99501
Office (907) 343-2110
Mobil (907) 830-0999
Fax (907) 343-2190
Email:
From: Maunder, Thomas E (DOA) [mailto:tom.maunder@alaska.gov]
Sent: Thursday, May 13, 2010 4:29 PM
To: Foley, Pat
Cc: Roby, David S (DOA); Davies, Stephen F (DOA); Schwartz, Guy L (DOA); Hart, David; Leppo, Jeffrey W.;
Kleinman, Mark; Sturtevant, Craig
Subject: RE: Oooguruk AIO Modification Request
Pat, et al,
Thanks for the information. Here is the fluid balance I determine from your document.
Starting glycol/water mix volume: 266, 000 gallons
Transferred to others:
190, 000 gallons
Remainder:
76, 000 gallons
Used for other purposes:
5, 419 gallons
Remainder:
70, 581 gallons
Injected into ODSK-38 (5/2009):
35, 331 gallons
Injected into ODSK-38 (5/28/09):
9,596 gallons
Remainder:
25,654 gallons
Residual removed via gas lift:
4,125 gallons
Remaining in gas line:
4, 125 gallons
Remainder:
17, 404 gallons
Transferred to Pollard:
1, 150 gallons
Remainder:
16, 254 gallons
Final transfer to Price Gregory:
16, 254 gallons
The notification of possible mis-injection of freeze protection fluids was given September 2, 2009. Was there
another notification made to the Commission regarding the glycol/water volumes injected into OSDK-38? I have
not found any such notice in our files.
Thanks in advance,
Tom Maunder, PE
AOGCC
From: Foley, Pat [mailto: Pat. Foley@pxd.com]
Sent: Wednesday, May 12, 2010 10:49 AM
To: Maunder, Thomas E (DOA)
Cc: Roby, David S (DOA); Davies, Stephen F (DOA); Schwartz, Guy L (DOA); Hart, David; Leppo, Jeffrey W.;
Kleinman, Mark; Sturtevant, Craig
Subject: RE: Oooguruk AIO Modification Request
Tom,
9/10/2010
Page 4 of 4
•
Please see the attached document that responds to your questions.
If you have further questions please call me.
Pioneer Natural Resources Alaska, Inc.
Manager of Land and External Affairs
700 G St., Ste 600, Anchorage, AK 99501
Office (907) 343-2110
Mobil (907) 830-0999
Fax (907) 343-2190
Email:
From: Maunder, Thomas E (DOA) [mailto:tom.maunder@alaska.gov]
Sent: Monday, May 10, 2010 4:22 PM
To: Foley, Pat
Cc: Roby, David S (DOA); Davies, Stephen F (DOA); Schwartz, Guy L (DOA)
Subject: FW: Oooguruk AIO Modification Request
Pat,
As I mentioned when we spoke a few moments ago, a few additional questions have developed.
In a 9/2/09 email (copy attached) Joey Hall informed Jim Regg of a possible misinjection of freeze protection
fluids (which included glycol, diesel and crude oil) and that the volume "...could be no more than 120 bbls
(5040 gallons). In the response it was communicated that freeze protection using diesel, crude or glycol was
a routine activity necessary to preserve well integrity. In your latest application to modify the AIOs it is stated
that about 49,000 gallons of a 50/50 glycol/water mixture was injected.
1) Is the originally estimated 5040 gallons included in the 49,000 gallons?
2) Were there multiple separate instances of where about 5040 gallons of glycol/water mixtures was
injected or was the remaining - 44,000 gallons injected at one time?
3) If there were multiple separate injection events, was it for freeze protection?
Thanks in advance,
Tom Maunder, PE
AOGCC
Statement of Confidentiality:
This message may contain information that is privileged or confidential. If you receive this transmission
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9/10/2010
`01
From:
Foley; Pat [Pat.Foley@pxd.comj
Sent:
Friday, April 23, 2010 11:52 AM t�
To:
Foerster, Catherine P (DOA)
Cc:
Hart,. David; Leppo, Jeffrey W.
Subject:
Notice of 0ooguruk Injection
Dear Commissioner Foerster,
I am sending you this email to confirm and document Pioneer Natural Resources' meeting with you yesterday
on April 22, 2010. In particular, this note restates in writing the information Pioneer provided to you regarding
injection of a 50/50 mixture of water and glycol into FOR wells at Pioneer's Oooguruk facility. We also more
generally discussed the results of Pioneer's investigation into the broader range of allegations asserted by Mr.
Kelley; however, this note is not intended to document our discussion of the full range of issues under
investigation. Finally, as we discussed at the meeting, in conjunction with Pioneer's letter addressing the
broader range of issues raised by Mr. Kelley, a more detailed description of the matters addressed in this note
will be provided to the AOGCC, as well as to other regulatory agencies, in the next few weeks.
Pioneer has determined that it injected on the order of 53,000 gallons of a non -hazardous 50/50 mixture of
water and glycol as follows:
- A residual quantity of the water/glycol mixture remained in the Oooguruk 8-inch seawater supply
pipeline following hydrotesting and warming of this pipeline using this fluid.. In May 2009,
approximately 35,300 gallons of this fluid mixture was injected into the Kuparuk formation through an
Oooguruk FOR well when seawater injection was initiated via the 8-inch line.
- A residual quantity¢of this same water/glycol mixture also remained in the Oooguruk 6-inch gas supply
pipeline following hydrotesting and warming. Pioneer estimates this quantity to be approximately 8,250
gallons. We estimate that roughly half of this amount has been stripped from the line along with gas
flow utilized in the Nuiqsut well gas lift operations, and that the remaining amount is still in the gas
supply pipeline.
- In May 2009, during a Shutdown of the 8-inch seawater supply line, an additional volume of the
water/glycol mixture was pumped into the line as a means of beneficially reusing the mixture as an FOR
injection fluid in lieu of injection into Pioneer's Class I disposal well. We estimate that the maximum
volume pumped into the line at this time, and subsequently injected into the Kuparuk formation when
the seawater supply line was brought back into service, is 9,600 gallons.
As we reported to you at our meeting on April 22, 2010, these injections occurred at a time when the applicable
Oooguruk Area Injection Orders issued by the AOGCC did not authorize injection of this water/glycol mixture
for FOR purposes. As we discussed, Pioneer is seeking by separate application an amendment of its Area
Injection Orders from the AOGCC to authorize injection of non -hazardous water/glycol mixtures into the
Kuparuk and Nuiqsut reservoirs. We are seeking this authorization to address both the continuing presence of
this fluid which has already been injected, and injection of the remaining residual glycol in the gas supply line
into the Nuiqsut reservoir.
Finally, we also discussed in our meeting various issues and factors related to the injection of the water/glycol
mixture. Although we will be addressing these matters again in more detail in the coming letter, in brief, this
injection occurred as a result of an innocent misunderstanding of what fluids were authorized for injection by
the Pioneer onsite operations staff. At the time, the operators involved were intent on assuring that the mixture
was non -hazardous and benefic0br use as an FOR fluid. Because non-haitous glycol mixtures have long
been an approved FOR fluid for injection into the Kuparuk and Prudhoe Bay Reservoirs, operations personnel
erroneously assumed that the Oooguruk injection orders also authorized injection of this fluid mixture. There
was no intent to evade or ignore regulatory requirements; nor was there any operational or economic imperative
to do so. There are no adverse environmental or reservoir consequences. Pioneer did not gain any material -
savings or benefit from the injection. Pioneer has taken remedial steps to ensure this mistake is not repeated.
Please do not hesitate to contact me if you have any questions regarding the information provided at yesterday's
meeting, this email or Pioneer's yet to be provided detailed letter.
Sincerely,
Pioneer Natural Resources Alaska, Inc.
Manager of Land and External Affairs
700 G St, Ste 600, Anchorage, AK 99501
Office (907) 343-2110
Mobil (907) 830-0999
Fax (907) 343-2190
Email: patfoley0pxd.com
Statement of Confidentiality:
This message may contain information that is privileged or confidential. If you receive this transmission in
error, please notify the sender by reply e-mail and delete the message and any attachments.
2
