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Home My WebLink AboutAIO 004 B 0 • Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable b direct inspection of the file. - 1-0 Order File Identifier Organizing (done) ❑ Two -sided III !I 11111 111 ❑ Rescan Needed 1 1 111 1111 RES N DIGITAL DATA OVERSIZED (Scannable) Color Items: ❑ Diskettes, No. ❑ Maps: ❑ Greyscale Items: ❑ Other, No/Type: ❑ Other Items Scannable by a Large Scanner ❑ Poor Quality Originals: OVERSIZED (Non - Scannable) ❑ Other: ❑ Logs of various kinds: NOTES: ❑ Other:: BY: Date: ! / /s/ ry Project Proofing 11111111 1111 BY: Maria ` Date: /s/ Scanning Preparation x 30 = + = TOTAL PAGES 33 (Count does not include cover sheet) ' A BY: Date: /s/ Production Scanning I 11111 IIII Stage 1 Page Count from Scanned File: 54' , (Count does include cover sheet) Page Count Matches Number in Scanning reparation: , I7YES NO BY: - Date: 1/7 11 is! /11,1) Sta 1 If NO in stage 1, page(s) discrepancies were found: YES NO BY: Maria Date: /s/ Scanning is complete at this point unless rescanning is required. I 1111111 II I ReScanned I IIIII I BY: Maria Date: /s/ Comments about this file: Quality Checked II 11111 ! 10/6/2005 Orders File Cover Page.doc 11° • Area Injection Order 4B PRUDHOE BAY 1) October 24, 1997 Letter regarding Reserve Pit Close Out Operations 2) November 3, 1997 Ltr from ARCO to AOGCC: PBU AIO 4A Reserve Pit Close Out Operations 3) November 14, 1997 Notice of Hearing, Affidavit of Publication, mailing list 4) November 12, 1998 AOGCC Year end report 5) December 1, 1998 Lre from BPXA to AOGCC re: request for approval disposal of wastes derived from coil- tubing operations in a Class II Disposal well BPXA 6) December 22, 1998 Ltr from AOGCC to BPXA Re: Request for Approval for Disposal of Wastes derived from Coil Tubing Operations in a Class II Disposal Well 7) May 17, 1999 Ltr from AOGCC to BPXA Re: Surface Freeze Protect Fluids as Class II Fluids Area Injection Order 4B All Annual reports are located in the Field Files 0 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage Alaska 99501 -3192 Re: The application of ARCO Alaska, Inc. ) Area Injection Order No. 4B ( "AAI ") to dispose of Class II fluids via ) slurry injection into three wells located in ) ARCO Alaska, Inc. the Prudhoe Bay Field. ) Eastern Operating Area ) Prudhoe Bay Unit and ) Pt. McIntyre Field April 13, 1998 IT APPEARING THAT: 1. By correspondence dated October 24, 1997, AAI requested authorization from the Alaska Oil and Gas Conservation Commission ( "Commission ") to inject Class II waste fluids into three Prudhoe Bay wells located at the Surfcote pad as part of a continuing Grind and Inject (G &I) waste disposal project. 2. The Commission published notice of opportunity for public hearing in the Anchorage Daily News on November 14, 1997. 3. The Commission did not receive protest or a request for a public hearing. FINDINGS: 1. The Commission has issued the following Area Injection Orders and approvals for the Eastern Operating Area of the Prudhoe Bay Unit: Area Injection Order 4 on July 11, 1986, Administrative Approval 4.1 on October 28, 1996, Area Injection Order 4A on August 12, 1993, revised October 4, 1993, and a letter approval on July 5, 1994. 2. The hearing records and administrative files for the above listed Area Injection Orders and approvals remain valid for the Eastern Operating Area of the Prudhoe Bay Field, and are incorporated by reference into this order. 3. AAI proposes the Surfcote disposal injection project as a replacement for disposal injection in the Drill Site 4 -19 well. The DS 4 -19 well is no longer approved for disposal injection under Commission letter dated April 15, 1997. 4. AAI is the operator of the Eastern Operating Area of the Prudhoe Bay Unit. There are no other operators within a one - quarter mile radius of the proposed Surfcote disposal injection project. 5. The State of Alaska is the only surface owner within one mile of the proposed Surfcote disposal injection project. Area Injection Order #40 • Page 2 April 13, 1998 6. AAI proposes to complete the Surfcote wells with 20" conductor casing, 13 3/8" surface casing set at about 3900' TVD and cemented to surface, 9 5/8" injection casing set at about 7000' TVD and cemented to within 50 feet of the surface casing shoe, and 7" tubing and packer set at about 4000' TVD. 7. Material intended for slurry injection will consist of Class II wastes as follows: 1) excavated material from existing reserve pits in the Prudhoe, Kuparuk, and Lisburne fields, commingled with seawater from the Seawater Treatment plant, treated produced water from Flow Station 2, or water produced from the Tertiary/Cretaceous formations in the Drill Site 4vicinity; 2) waste drilling muds and cuttings from development and exploratory drilling operations on the North Slope; 3) other Class II solid wastes, including but not limited to materials as oily solid waste removed from oil processing and treating facilities; and 4) other Class II fluids, such as reserve pit water from snowmelt, workover fluids, contaminated crude, produced water, diesel, gel, and glycol associated with well production operations. 8. The maximum G &I Plant injection capacity is approximately 40,000 barrels per day, with a target slurry density between 9.5 and 11 pounds per gallon. 9. Estimated average surface injection pressure for slurry disposal will be between 1,300 and 2,000 psi, depending on the density of the fluid and the injection rate. 10. AAI proposes to operate the Surfcote wells concurrently or on a revolving schedule to evenly distribute the volume of waste being injected into the three wells. 11. Fracture propagation within the disposal interval is an integral part of the process of placing waste slurries into the disposal interval. Fractures will be created as disposal zone porosity and permeability is occluded by the deposition of solids in pore spaces. Fractures provide pathways to transport waste fluids to unfilled areas within the disposal zone. 12. Fracture propagation caused by large -scale injection of solids in loosely consolidated formations is not fully understood at this time. 13. AAI will run cement quality logs within the surface casing and long string of each Surfcote well to determine the adequacy of the cement to isolate disposal intervals. 14. AAI will test tubing and casing integrity according to 20 AAC 25.412 prior to initiation of slurry injection operations and every two years thereafter 15. A fluid broach occurred in March 1997 at the DS4 -19 well. Data collected confirmed the existence of thaw bulbs around wellbores on the pad. 16. AIO #4 approved disposal injection into strata that correlates with strata found in the ARCO Sag River State Well No. 1 between the measured depths of 1900 feet and 6750 feet. 17. AIO #4A found this interval to be overlain with Tertiary shale and mudstone beds, between 10 and 50 feet thick, and approximately 1,800 feet of permafrost, which isolates the disposal interval from surface waters. Area Injection r r 4 Ode #� Page 3 April 13, 1998 18. No Class II injection has occurred in an interval shallower than 4500 feet in the Eastern Operating Area of the Prudhoe Bay Unit and the Pt. McIntyre field. 19. A layer of confining shale lithology, which correlates with the interval between 3505 feet and 3607 feet measured depth in the ARCO Sag River No. 1 well, exists throughout the Eastern Operating Area of the Prudhoe Bay Unit and Pt. McIntyre field. 20. Periodic surveillance of slurry injection operations will ensure waste fluids are contained within the disposal interval. Surveillance methods include temperature surveys, pressure transient tests, step rate tests, thermal decay time logs, disposal rate and pressure monitoring, mechanical integrity tests and tagging effective depth to determine fill buildup. 21. Reservoir surveillance techniques will also be used for tracking near wellbore fluid movement, estimating dimensions of disposal fracture or disposal storage volume and detecting changes in disposal zone characteristics in slurry injection wells. 22. AAI will evaluate operational performance and reservoir surveillance to aid in preventing fracturing of the confining zones. CONCLUSIONS: 1. The requirements of 20 AAC 25.252 have been met for the AAI proposed Surfcote pad disposal injection project. 2. It is reasonable to issue a revised area injection order for the Eastern Operating Area of the Prudhoe Bay Unit and Pt. McIntyre fields to include the Surfcote disposal injection project. The record for this order should include the hearing record and administrative files from AIO #4, AIO #4A, AA4.1 and approval letter dated July 5, 1994. 3. Permafrost is not an appropriate barrier to fluid flow after thaw bulbs develop around producing wells. 4. It is reasonable to redefine the approved interval for disposal injection in the Eastern Operating Area of the Prudhoe Bay Unit and Pt. McIntyre field to an interval overlain by confining shale, and not rely in any manner on the presence of permafrost to confine disposed fluids. 5. No underground sources of drinking water are known to exist in the Eastern Operating Area of the Prudhoe Bay Unit and the Pt. McIntyre oil field. 6. Waste fluids authorized for disposal under this order will consist exclusively of Class II waste generated from drilling, completion, workover, production and reserve pit closure operations. 7. Permeable strata which reasonably can be expected to contain the total volume of disposal fluid anticipated for this project are present in the West Sak, Ugnu and Sagavanirktok formations. 8. Movement of waste fluids will be confined within the appropriate receiving intervals by confining lithology, cement isolation of the wellbore and appropriate operating conditions. Area Injection Order #41 Page 4 April 13, 1998 9. It is reasonable to require a deeper injection zone for grind and inject operations because of the reliance on fracturing to place waste slurry into the disposal zone 10. Surveillance of disposal material movement, monitoring of operating parameters and demonstration of mechanical integrity every two years will ensure the slurry disposal materials are contained within the disposal interval. Changes from initial conditions may be an indication that fluid is escaping beyond the designated confining zone. 11. Prudhoe Bay Unit disposal wells will be constructed and demonstrate mechanical integrity in accordance with the requirements of 20 AAC 25.412. 12. Disposal injection operations in the Prudhoe Bay Unit will not cause waste, jeopardize correlative rights, or impair ultimate recovery. NOW, THEREFORE, IT IS ORDERED that Area Injection Order #4A is repealed and reissued as Area Injection Order #4B with the following rules to govern Class II injection operations in the affected area described below: UMIAT MERIDIAN T12N R14E Sections 3, 4, 9, 10, 13, 14, 15, 16, Section 17: NE 1/4, N '/Z SE 1/4, E '' /z E '/Z NW 1/4, E '/Z NE 1/4 SW 1/4, Section 21: N 1/4 NE 1/4, Sections 22, 23, 24, 25, 26, 35, and 36. T12N R15E Sections 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, and 36. T12N R16E Sections 28, 29, 30, 31, 32, 33, and Section 34: W 1/4 NW 1/4, SW 1/4, SW 1/4 SE 1/4 T11N R14E Sections 1, 2, 9, 10, 11, 12, 13, 14, 15, 16, 21, 22, 23, 24, 25, 26, 27, 28, 33, 34, 35, and 36. T11N R15E Entire Township. T11N R16E Section 2: SW 1/4 NW 1/4, SW 1/4, S '/z SE 1/4, Sections 3, 4, 5, 6, 7, 8, 9, 10, 11, > > > > 4 E 4 SE 4 /4 Section 12: NW 1/4, /,S /,SW Sections 13, 14, 15, 16, 17, 18, 19, 20, 21, 28, 29, 30, 31, 32, and 33. T1ON R14E Sections 1, 2, 3, 4, 9, 10, 11, 12, 13, 14, 15, 16, 21, 22, 23, 24, 25, 26, 27, 28, and 36. • Area Injection Order #4D Page 5 April 13, 1998 T 1 ON RISE Entire Township. T1ON R16E Sections 4, 5, 6, 7, 8, 9, 16, 17, 18, 19, 20, 29, 30, and 31. Those Lands in Block 605 lying northerly of the north boundary of Section 3, T12N, R14E, UM AK (identical with line 4 -5 on block 605) and lying easterly of the west boundary of sections 2 and 11, T12N, R14E, UM, AK (identical with line 5 -6 on Block 605) and lying northerly of the south boundary of Section 11 and 12, T12N, R14E, UM, AK, and lying northerly of the south boundary of Section 7, T12N, R15E, UM, AK (identical with line 6 -7 on block 605), within the offshore three -mile arc lines listed as State Area on the "Supplemental Official O.C.S. Block Diagram," approved 12/9/79, containing 1457.32 hectares. Rule 1 Authorized Injection Strata for Enhanced Recovery Within the affected area, Class II fluids may be injected for purposes of pressure maintenance and enhanced recovery into strata defined as those which correlate with and are common to the formations found in the ARCO Prudhoe Bay State No. 1 well between the measured depths of 8,110 -8,680 feet for the Prudhoe oil pool and between the measured depths of 8,790 - 10,440 feet for the Lisburne oil pool and in the Pt. McIntyre No. 11 well between the measured depths of 9,908- 10,665 feet for the Pt. McIntyre oil pool. Rule 2 Authorized Injection Strata for Disposal Within the affected area, Class II waste fluids may be disposed by injection into strata defined as those which correlate with and are common to the strata found in the ARCO Sag River State No. 1 well between the measured depths of 3,607 -6,750 feet. Class II slurry injection from the Grind and Inject processes may be disposed into strata defined as those which correlate with and are common to the strata found in the ARCO Sag River State No. 1 well between the measured depths of 4,270 -6,750 feet. Rule 3 Fluid Injection Wells The injection of fluids must be conducted: 1) through a new well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005; 2) through an existing well that has been approved for conversion to a service well for injection in conformance with 20 AAC 25.280; or 3) through a well that existed as a service well for injection purposes on the date of this order. Rule 4 Monitoring the Tubing - Casing Annulus Pressure Variations The tubing - casing annulus pressure of each injection well must be checked at least weekly to ensure there is no leakage and that it does not exceed a pressure that will subject the casing to a hoop stress greater than 70% of the casing's minimum yield strength. Area Injection Order #4. • Page 6 April 13, 1998 Rule 5 Reporting the Tubing - Casing Annulus Pressure Variations Tubing- casing annulus pressure variations between consecutive observations need not be reported to the Commission. Rule 6 Demonstration of Tubing/Casing Annulus Mechanical Integrity A schedule must be developed and coordinated with the Commission that ensures that the tubing - casing annulus for each injection well is pressure tested prior to initiating injection, following well workovers affecting mechanical integrity, and at least once every four years thereafter. For slurry injection wells, the tubing/casing annulus must be tested every two years for mechanical integrity. A test surface pressure of 1500 psi or 0.25 psi /ft. multiplied by the vertical depth of the packer, whichever is greater, but not to exceed a hoop stress greater than 70% of the casing's minimum yield strength must be held for at least a 30 minute period with decline no more than or equal to 10% of test pressure. The Commission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. Rule 7 Well Integrity Failure Whenever disposal rates and/or operating pressure observations or pressure tests indicate pressure communication or leakage of any casing, tubing or packer, the operator must notify the Commission on the first working day following the observation, obtain Commission approval to continue injection and submit a plan of corrective action on Form 10 -403 for Commission approval. Rule 8 Plugging and Abandonment of Injection Wells An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission in accordance with 20 AAC 25.105. Rule 9 Administrative Action Upon proper application, the Commission may administratively waive the requirements of any rule stated above or administratively amend this order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering principles, and will not result in an increased risk of fluid movement into an USDW. Rule 10 Surveillance For slurry injection wells, a baseline temperature survey from surface to total depth, initial step rate test to pressures equal or exceeding maximum injection pressure and pressure falloff are required prior to sustained disposal injection. Regular fill depth tags are required at least once annually or as warranted following consultation with the Commission. Operating parameters including disposal Area Injection Order #4b Page 7 April 13, 1998 rate, disposal pressure, annuli pressures and volume of slurry pumped must be monitored and reported according to the requirements of 20 AAC 25.432. Also for slurry injection wells, an annual performance report will be required including rate and pressure performance, surveillance logging, fill depth, survey results, and volumetric analysis of the disposal storage volume, estimate of fracture growth, if any, and updates of operational plans. Report submission must be on or before July 1. DONE at Anchorage, Alaska and dated April 13, 1998. —411114%..— �,,__ ►r Date _ . 'rman 0i[ Alaska II ' - ►. d Gas Conservation Commission A 4r A Ike" I I I it/ 416 r % z .` Robert N. Ti: r nson, Commissioner N Alaska Oil and Gas Conservation Commission 4 , .1ON CO C ai 04-e/Le-L Camille Oechsli, Commissioner Alaska Oil and Gas Conservation Commission AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10 -day period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for rehearing is denied by nonaction of the Commission, the 30-day period for appeal to Superior Court runs from the date on which the request is deemed denied (i.e., 10th day after the application for rehearing was filed). .�7 11, :I " TONY KNOWLES, GOVERNOR ALASKA OIL AND GAS 3001PORCUPINE DRIVE ALASKA CONSERVATION COMMISSION PHONE (907) (907) 279 -1433 99501 -3192 FAX (907) 276 -7542 May 17,1999 1M` 0 Mr. Jerry Bixby ` — \O 2 Well Operations Supervisor \ BPXA — Western North Slope P.O. Box 196612 Anchorage, Alaska 99519 -6612 Re: Surface Freeze Protect Fluids as Class II Fluids Dear Mr. Bixby: In your April 15 letter to me, you requested that the rationale contained in Commissioner Johnston's December 22, 1998 letter to Janet Platt "Re: Request for Approval for Disposal of Wastes derived from Coil Tubing Operations in a Class II Disposal Well" be applied to "Well Work Operations." We have considered your request and consider it appropriate. Therefore, in Commissioner Johnston's December 22 letter you can insert the words "well work operations" where the letter says, "coil tubing operations ". Jerry, if you have any questions, please call me at 279 -1433 ext. 226. Sincerely, I . f),17 �� Blair E. Wondze gr.E. UIC Program Manager File:UIC2 \I- w- o- flds.doc 14 6 a ) ' a J In TONY KNOWLES, GOVERNOR �y ALASKA OIL AND GAS 3001 PORCUPINE DRIVE ANCHOAGE, ALASKA CONSERVATION COMMISSION PHONE: 279 -1433 99501 -3192 FAX: (907) 276 -7542 December 22, 1998 Janet Platt Supervisor, Environment, HSE Alaska ( \O '-- BP Exploration (Alaska) Inc. PO Box 196612 �� ` \-5 Anchorage, AK 99519-6612 Re: Request for Approval for Disposal of Wastes derived from Coil Tubing Operations in a Class II Disposal Well Dear Ms. Platt: The Commission has reviewed your December 1, 1998 request for approval to allow Class II disposal of fluids generated during coil tubing operations. BPXA staff also fully described the wastes derived from the coil tubing operations during a teleconference with Wendy Mahan of our staff and Jonathan Williams of EPA Region 10 on November 18, 1998. According to your letter, freeze protect fluids in surfacc lines consist mainly of diesel or a 50/50 methanol /water mix. These fluids become commingled with fluids produced to the surface during well workovcr operations and are subsequently circulated to a portable surfacc storage tank. Segregation of the fluids prior to entry into the tank without introducing a spill risk is impossible because the produced fluids are pressurized. The entire system connected to the well and surface tanks must also be pressure tested with freeze protcct fluids. If a leak occurs, the freeze protect fluid must be drained. The fluids can not be reused because thcy may have been contaminated with produced fluids. It is impossible to tell the extent of contamination at the wellsite. Commingling freeze protcct fluids with produccd fluids during coil tubing operations is both unavoidable and necessary to ensure protection of surface equipment. As long as extraneous wastes are not introduced in order to circumvent legitimate disposal, the combined waste stream of freeze protect and produccd fluids may be disposed of in a Class II well. 1111 0411 10 David W. Johnston Commissioner cc: Jonathan Williams, EPA Region 10 `' iTV 411 • BP BP EXPLORATION BP Exploration (Alaska) Inc. PECEWFD 900 East Benson Boulevard PO. Box 196612 Anchorage, Alaska 99519 -6612 Ec 1 1998 (907) 561 -5111 December 1, 1998 Alaska Oil & Gas Cons. Commission Anchorage Wendy Mahan, Natural Resource Officer bi4,-0 Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 \OTS Request for Approval Disposal of Wastes derived from Coil Tubing Operations in a Class II Disposal Well BP Exploration, Alaska North Slope Operations Dear Ms. Mahan: Thank you for taking the time on November 18 to meet with me and staff from BP Exploration (BPXA) North Slope Operations and discuss via teleconference with Jonathan Williams, EPA, issues surrounding waste handling generated from coil tubing operations. BPXA seeks approval from the Alaska Oil and Gas Conservation Commission (AOGCC) to dispose of fluids generated during coil tubing operations in permitted Class II disposal wells. Coil Tubing Units (CTU) are now used on the North Slope to conduct many well workover operations. The CTU has a truck - mounted steel coiled tube for which different tools can be attached. The tubing enters the well through the top of the `tree' on the well head. Once the tubing and attached tool are placed at the appropriate depth in the well, workover fluids are fed into the tubing. Fluids can then be reversed out of the well through surface lines that are connected to the wellhead and circulated to a portable surface storage tank. The attached diagram illustrates the CTU setup. Coil tubing operations occur year round. Much of the year, operations occur during freezing temperatures. After pumping fluids into the well for a period of time (duration is variable depending on the specific well operation), pumping is shut down and fluids become static in surface lines. The surface lines must be freeze protected with methanol (50/50 methanol /water mix) or diesel to prevent fluids from freezing in these lines. As pumping starts up again, fluids are then reversed out of the well to surface tanks under pressure. The downhole fluids become combined with freeze protection fluids in surface lines in the process of conducting the coil tubing job. The resultant waste stream is predominately fluids from downhole (up to 1000 bbls), mixed with a small amount of freeze protectant fluids (30 gallons to 1 bbl). TYPICAL COILED TUBING PROCESS DIAGRAM yi Methanol Workover Bulk Returns Tank Fluids 0 2 - Inch Hardline elk 2 - Inch Hardline Ma nifold , Soft ine Hoses ch 2 ("nch ar hne 2 - Inc Hardline Coiled q. Coiled Pump Tubing Tubing Reel etk Unit Coiled Tubing • Well ead III Down -Hole Formation December 1, 1998 1111 Since the downhole fluids are under pressure when circulated out of the well, it is not possible to segregate the freeze protection fluids prior to entering the tank without introducing the risk of release via a spill. BPXA currently handles the wastes in the tank at a Class 1 disposal well or must attempt to segregate the freeze protection fluids from the downhole fluids once in the tank. BPXA seeks approval from AOGCC to dispose of these coil tubing operations wastes in a Class II disposal well. BPXA believes this is analogous to other Agency approvals allowing wastes generated in processes where fluids come in contact with wastes from downhole to go to Class II wells in order to facilitate disposal of those downhole fluids; such as wastes from pigging of surface lines containing sand and crude oil deposits from downhole. BPXA does not introduce unused workover fluids or unused freeze protection fluids into the coil tubing operations waste tank for disposal. These unused fluids are used on another job. The contents of the tank are returned fluids from downhole and a small volume of freeze protection fluids displaced from surface lines in the process of reversing fluids out of the well. In addition to the wastes generated during the coil tubing operation process, the entire system, piping, manifolds and pumps connected to the well and surface tanks, must be pressure tested with freeze protection fluids. If a leak is detected in a valve, hose or fitting during the test, freeze protection fluids must be drained off the system. These fluids cannot be reused in the event cross contamination has occurred and changes the freeze protection fluids properties. BPXA also seeks guidance from AOGCC to handle these fluids in a Class II well for disposal as well. BPXA appreciated your consideration and review of this process. If you require more information, please contact me at (907) 564 -5501. Sincerely, Ps q79 / ar .T PZR 7' Janet D. 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Url r? ? &n . �1 GUALRY LITHO PRIMtNtE. ANCHORAGE, AK (90t) 5634743 .. 159_SBB1 *3 7 1111 • • • Notice of Public Hearing STATE OF ALASKA Oil and Gas Conservation Commission Re: The application of ARCO Alaska, Inc. for an order allowing the underground disposal of Class II fluids by injection into three wells in the eastern operating area of the Prudhoe Bay field. The Commission proposes an administrative approval to Area Injection Order #4A in order to allow the underground disposal of Class II fluids in these wells. An administrative approval is necessary to incorporate new Commission requirements for grind and inject projects. A person who may be harmed if the requested order is issued may file a written protest prior to 4:00 PM December 1, 1997 with the Alaska Oil 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 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 December 16, 1997 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 1, 1997. If no protest is filed, the Commission will consider issuance of the order without a hearing. If you are a person with a disability who may need a special modification in order to comment or to attend the public hearing, please contact Diana Fleck at 279 -1433 no later than December 10, 1997. q u it " _ II , David W. Johnston Chairman Published November 14, 1997 ADN AO 02814012 #7672 1 3TOF0330 AO- 02814012 AFFIDAVIT OF PUBLICATION $65.49 STATE OF ALASKA, ) Not of Public Hearias THIRD JUDICIAL DISTRICT. ) srarEoP. caste Ataska'Ottapd �� rq KatzfMann ationtp�tf ion Canseit Eva . . Re,: The ` apphcafion .af AReO being first duly sworn on oath Alaskartnd far anorder g Y allowing 'tie deposes and says that he /she is disposal :of C1as it fluids 'by` injection into three wells in the an advertising representative of eastern operating area of the the Anchorage Daily News, a Prudhoe Bay field. The C ommission pro pn adminis approva to daily newspaper. That said Area Miect,on Order #4A in er news a has been approved order to allow the underground newspaper p p disposal of Class 11 fluids in by the Third Judicial Court, these wells, 'An administrative approval is necessary to Anchorage, Alaska, and it now incorporate new Commission? requirements for ,grind :ondl and has been published in the inject projects. A person who requested be English language continually as a harmed if the requested'brder' is issued May file a .written . daily newspaper in Anchorage, protest prior to 4:00 PM Alaska, and it is now and during December 1, 1997 with the Alaska Oil and acs Conserve -' all said time was rinted in an tion Commission, 3001 Porcu p pine Drive, Anchorage, Alaska maintained at the aforesaid 99501, and request a hearing on -the matter. If the protest is place of publication of said timely filed and raises .a sub- stantial, and material issue newspaper. That the annexed is (crucial to the Commission's idetermination, a - hearing on a copy of an advertisement as it the matter will be held at the above address at 9:00 AM on was published in regular issues December 16, 1997 'in confor -, (and not in supplemental form) of hearing v ishto h be A eld 55 interest- said newspaper on leall ng Commissions . this by office, (907) 279 -1433 after t (� (1 December 1, 1997. If no,protest, 199 Nov . 1/I , 7 is filed, the Commission , will ' consider the issuance of an order without a hearing. If you are a person with ,a' disability who may need a special. modification An order to comment o1% to attend the Public hearing, please contact. Diana _Fleck of , 279 -1433 no later than December 10, 1997. /s/David W. Johnston Chairman Pub.: November 14, 1997 and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. signe Subscribed and sworn t, , fore me this /?day of ,47pe 4(ex, 1 7 V Notary Public in and fo the State of Al . Third Division. Anchorage. Alaska MY COMMISSION EXPIRES ....e e ,4,4%.20.4a-2 2 ARCO Alaska, AL. I Post Offk, ox 3 60 Anchorage Alaska 99510 -0360 %COMM i► Telephone 907 276 1215 COMM 0!17,0 COMM David W. Hanson RES ENG • Staff Permit Coordinator SR ENG Prudhoe Bay /GPMA (ATO -1968) NRO 907 - 263 -4745 907 - 263 -4334 (fax) SR GEOL GEOL ASS GE November 3, 1997 STAT TECH 1 STAT TECH_ David W. Johnston Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Road FILE Anchorage, AK 99501 f}Zb RE: Prudhoe Bay Unit, Eastern Operating Area P : °'` Area Injection Order #4A Reserve Pit Close Out Operations Dear Mr. Johnston: r aq X61 On October 24, 1997 a letter detailing changes in the Grind and Inject (G &I) Project was sent to you. This letter was intended as an update to the 1986 Area Injection Order (AIO) for the Eastern Operating Area of the Prudhoe Bay Unit, the 1993 Application for an Amendment to AIO #4, and related correspondence. This letter referenced four attachments that were inadvertently omitted. These four attachments are enclosed with this letter. Our apologies for any inconvenience that this may have caused. If you have any questions, please call me at 265 -4745. Sincerely, jo David W. Hanson Attachments ARCO Alaska, Inc. is a Subsidiary of Atlantic Richfield Company a_ , s L.... - AR3B 6003 - Illkosed Surfcote Wells AC 10.2.1110 er•i. LM' • CC I ? EvAPHOLE • Ir I IC " • I 00 • 0 Base Permafrost +/- 1850 ft I GO pm ow • .... P 1 1 1 (l Ito 0 r. 1 v t 1 V ISM rfX . 1. , — R 1 Confining Zone sv . ,.. , . i • oe. '.... • Arresting Strata '‘D — . S VI ■- '— g V 1 Confining Bed .., , . 1 Surface Casing shoe - ._ g : Conlin' . Bed ' Tvgi t gr • ' SY .... . 'O . o o i - . i .. _ . ..... _ ' I g I ID 1 •• . • • . . • -- C. Po ..., Injection biterval 1 e , . • ' I- . • ___ ... .. , ..___..... __„„ • I 2 . r.... i_ 1 - tc, . _ — 0 _..... %._ .0 , - - I ' -: _ - _ i0 L 3. - ,-. iim 1 Initial Perfs rg 1: g 1 .61 PC .... Pe CPO . 4 - tun: , eif CI 1 ft rwes Reference Log: DS 4-19 [ • 1. ,, 111010 II% , Structure Cross Section PWDW 2-1 L 3 - 8 4-19 L 4 - 1 5 ...,. . ...,. . - -__:— 11 i ' ' I 1 ' ,:!;:.:.■ :,1 ,:.'.i!, • I t;',.!1' , .■ il i ' I :ill ' • Confining Zone i :;•.:::: •.• 1111111 :. : • 111 1 1 11 ••• • ' ' . . , ' • i i i I: i l :••i : i..:i,1 , .•p , Iii1+ ' - i' . .■ ,' I li'' ' ' .... i •P1 -: 1: . l' , ''': .., A .... ' ',II,'■Iiii;'--,-_.,,. ' " ' - ------- , -.,___. ____ Confining Zone kil •,::..,..--,::,.,. ,, ' , ___------ - - -- i ,.. F., ----------.-___,S.■/. -.. - 1111 Arresting Strata .v. I- , #i --------- 1 - 1 -------- . ,-, Confining Bed , I ! 11, [ --------5-- -- ', --------- Immo Arresting Strata , ..._.1 ---S---- , . l i i • ----______ _ S-V.Z ________-________,_ ,,_, Coatioiag--- i II i 1 1 1 1 1 111 ----- --------- 1-1 Vi , 1 ! 41 . , .,ii .. . I. 1 , 1 ,I - IF- ., I —2.... ', UG4 Is ,., __, _ ..,____ i-At 1 --------- 1 Injection .,l' .., 21 • 1 I §' L . .. . Z I 1 • ii ji, ' 1 , ,,,, - , .-. 1 -k Interval : ' te, .- IC I - I . ,.. 31 • I Wil . W S 2 ..1-i. - . ' 1 ---- % .r.. . . - 1 ' 1 - - ).- .., i 1 - 1 II 1 1 k- - t: MI ;... till , • 1 ,s. ..! :. 1 1 1 ' I ..., ir , i'''. I. P;'. ' ' 1 4 Mk, .4 ' ' • .7: I I SCANNED JUN 3 0 2004 Surfcote Map - - + - - SL -BHL Target @ 6500 ft TVD Pad 5,961,000 04 -08 �A -- ... -- 04 -16 . q ammvim E -- -- - 04 17 5,960,00L 0 3 ' #1 3671 ' #2 2518 • 4E:E,, Stepout , Stepout 1 5959000 111 i pffa ., 04-23A s al,' 5,958,000 • . „ r 04 -24 Emu 1. I 04 -25 ' #3 2412 ' 5 957 000 r•• F . 04 26 ,: Stepout a l 04 -28 Q 5,956,000 0433 at I X a la .• , � - �. 1 • .., ), Surfcote --I-- 04 -34A 5,955,000 : ' • Ill '`'``'.`'''`` 04-37 , . 5,954,000 ` : :.m .. - - -- - --- 04 -39 i- 04 -49 _: • £ - L3 -18 5,953,000 � : ^ :.....p: .. ? -1 ■il�.: L3 24 U — L4 03 5,952,000 .,..... ...- - -- El - v - – L4-11 710,000 711,000 712,000 713,000 714,000 715,000 716,000 717,000 718,000 719,000 720,000 721,000 722,000 723,000 - -L4 -15 ASP X ■ 6000' TVD L4 -31 ❑ 6500' TVD . 010 4110 Cr) Proposed Surfcote 9 Well Design .......... ....:...• :::: ,.............• ..„:„.. ........„ ...„ ........:.•::::: ......:.• ::::. ..... .... :::::.•::::: ............ ::::: :::: .......... :.:.:„.....,......„....., — ---- ..--..-..:....i....•:....•:..-.: :•-....i....i....i.....: ............ „......... ...„..-..„,,s. .......... ........: :::: ..... .... ..................... ..„..„:„.........„,:,:::„..„...,.. ::::: ,....... ............„....„„ ..... .... :::::.• ::::: ism :::::.• ,........ ::::.• :::: ........„...• :............., .................„ ..... .... ........... ::::.• :::: ..... .... 20" Conductor Pipe ...... ---- ::::.• .••••:.••":.••••::•••:.••••:,••" ...... ...... ..... ...... ::::.• ........... ..... ...... ...... ---- ...,..... ...... ...... ..... ...... ::::.• ......;..... ::::.• Base Permafrost ..... ...•'..:...'...•'...: .......... T +I 1850 ft II ::::.• .....;;;. .......... ..... ::::.• ::::.• ::::.• ::::.• 1 ...... :::::.• ...... ...... .................. ............ .-- ...... ..... .-..:::...-...-: c ........., .•':':'.-- ..... 1 ...... ............ ----- ...... ...... .................... ..... ..... ......., .-'.•':':'.-'• ...... ...... Confining Zone :::.,:::.• ............ :::::.• ..... ..... ••••• :::::.• ..... ..... •••••• Confining Bed .......-.. ..... ..... SV5 Marker +1 3400 ft TVD I An sting Strata ::::::, ::::::. lig 13 3/8" Surface Casing ...... ---- iiiiii Set below SV3 Marker .......: Confining Bed ............ ---- iiiiiiiiii +1- 3900 ft TVD SV3 Marker +/- 3900 ft TVD7............ AiL ........... Confining Bed ><Iii 7" Tubing SV2 Marker +1- 4100 ft TV]) ka: Packer at +I 4000 ft TVD ...... :::::.• ...... ........., ....... ............ ....... ....... --- ....... :::::: ---- ...... ........ ...... :...-...-...-...-...-..:: :::::: ....... ....... :::::.- .........................,. :::::.• ....... ...... ....... ....... .::::: ....... :::::: ...... ...... ....... ....... ....... :::::.- .......... ::::::::: Injection Inteival ...... ....... ....... ....... . ...... „...„.... ....... ,..... ....... .............. ....... ...„.. ....... ....... ....... ....... ....... ...... ....... .•••••••••••••••.•.: ....... ::::.• ...... ....... :...•....•..-.•,..,- ....... ........... ...... ::::::: ::::.• ...... ....... ::::: ••••••• :::::: ..... ...... ....... ..... ..... ...... „........ ...... ....... -...... ........... „,.,...„ ........, ........ .............: Initial Perf in MI ........., 9 5/8" Injection Casing UgnufW Sak kiail fid .....:, LE Set near base West Sak +I- 6600 ft TVD +1- 7000 ft TVD r" . '''' )7'1 Rt CE / V i: i,) 1)7 f ida;,i,,,,a A & '202, ',, ....■;,,,,.:'..,,,' v ' AnCrani •7;t:,, . , C' ?CT': �� d>AVL, ,oa+IME $0 AA - To Alo 4R To ARCO Alaska, Inc.. I,,,cpePo £M�N75 '► Post Office x 100360 8 �N �J919� ��-rr ,A�o 4A D � ' Anchorage Alaska 99510 -0360 �Su�J= JUE NT�Y co'€'- ��. t � � E H A Telephone 907 276 1215 two " T 5-rat—r Tom Wellman Manager;` cm Prudhoe Bay /GPMA HSET 700 "G" Street 1 9 Anchora e, AK 99517 � ��J phone (907) 263 -4304 v E fax (907) 263-4540 fet 0, , GEOL � $ October 24, 1997 o (cc �� ` °- David W. Johnston Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Road Anchorage, Alaska 99501 Re: Prudhoe Bay Unit, Eastern Operating Area Area Injection Order #4A Reserve Pit Close Out Operations Dear Mr. Johnston: Since early 1995, the Reserve Pit Close Out Demonstration Project has utilized the Grind and Inject (G &I) Plant located at DS 4 with injection into the Tertiary/Upper Cretaceous intervals of disposal well DS 4 -19 to assess the feasibility of using G &I technology. We have completed our evaluation and propose to continue using the G &I Plant at its current location to dispose of reserve pit wastes into three new injection wells to be drilled from the nearby Surfcote pad. These wells will also be completed in the Tertiary /Upper Cretaceous sands and will be manifolded such that one, two or all three wells can inject fluids at any particular time. In addition, we anticipate using this facility and wells to dispose of other Class II solid and fluid wastes. This letter is intended to provide information on this project, to update and supplement the information presented in the 1986 Eastern Operating Area, Area Injection Order Application, the 1993 Application for an Amendment to AIO #4, and related correspondence. The specific items below refer only to the Fluid Disposal references in the applications, and are intended to satisfy the informational requirements of 20 AAC 25.252 and 25.402. Type and Source of Fluid - Slurries of Solid Wastes The following lists the types of wastes, and their sources, which will be injected into the new G &I wells: • Various existing reserve pits in the Prudhoe, Kuparuk and Lisburne fields will be closed out. The material currently in the reserve pits, primarily drilling mud solids and cuttings from past drilling operations, will be excavated and processed through ARCO Alaska, Inc. is a Subsidiary of Atlantic Richfield Company AR3B 6003 - David W. Johnsto. • October 24, 1997 Page 2 the G &I Plant and a slurry of these materials will be injected into the new disposal wells. The G &I Plant process water used to create the slurry will be seawater from the Seawater Treatment Plant, treated produced water from Flow Station 2, or water produced from the Tertiary/Cretaceous formations in the vicinity of DS 4. Analyses of these fluids were included in the AIO Applications referenced above. • Waste drilling muds and cuttings from ongoing drilling operations in the Prudhoe Bay Unit, GPMA, Endicott and other fields as well as from exploratory drilling operations will be processed through the G &I Plant and injected into the new disposal wells. These materials are currently handled at the WOA CC -2A facility. • Other Class 11 solid wastes, including such materials as oily solid waste removed from oil processing and treating facilities, will be processed through the G &I Plant and injected into these disposal wells. • G &I Plant process water will be injected without solids prior to solids injection and during periods of Plant maintenance and upsets. • Other Class 11 fluids referenced in the AIO applications and related correspondence may be periodically injected into these wells. These fluids could include reserve pit water from snow melt, workover fluids, contaminated crude, produced water, diesel gel, and glycol associated with well production operations. Estimated Maximum Amount to be Infected Daily The maximum G &I Plant injection capacity is approximately 40,000 barrels per day. The three new injection wells may be operated concurrently and or on a revolving schedule, so the long term average rate into each well will be significantly less than this amount. The composition and source of the slurry solids will vary, but the target slurry density will be between 9.5 and 11 pounds per gallon (ppg). The source of the injected materials will be one or more of the following, totaling not more than 40,000 barrels per day: • Reserve Pit Solids - The maximum disposal rate is 40,000 barrels per day of slurry containing approximately 4,000 cubic yards (about 3,300 tons) of excavated reserve pit material. • Ongoing Drilling Wastes - The maximum rate is 10,000 barrels per day of slurry. • Other Class 11 Solid Wastes - The maximum disposal rate is 4,000 barrels per day containing 400 cubic yards (approximately 330 tons) of solid. • Other Class 11 Fluids - A maximum rate of 25,000 barrels per day of reserve pit water could be injected for short periods of time. Volumes of other fluid wastes will be less than 1,000 barrels per day. David W. Johnsto • October 24, 1997 Page 3 Infection Pressure • High pressure alarms are currently set at 2,800 psi on the G &I plant discharge. • Estimated average surface injection pressure will be between 1,300 and 2,000 psi depending on the density of the fluid and the injection rate. Geologic Information: Colville Group and Sagavanirktok Formation (also known as the Tertiary/Upper Cretaceous Sands). • A description of this interval is included in both the original Area Injection Order Application and the Application for an Amendment. The Authorized Injection Strata for Disposal is defined as those which correlate with and are common to the strata found in ARCO Sag River State Well No. 1 between the measured depths of 1,900 feet and 6,750 feet. (AIO 4A, Rule 2) • The injection interval for the slurry injection operations at the Surfcote site will be further limited to below the SV2 marker, approximately 4,100 feet SS at the Surfcote site. The confining and arresting strata at this location will then consist of shales and sands from below the permafrost (about 1,800 feet SS) through the SV2 shale (about 4,100 feet SS). The sands and shales between the SV5 (about 3,400 feet SS) and the SV2 in particular are thick, continuous and of good quality in this area. (See attached type log and cross section.) Well Locations and Completions • Three new disposal wells will be directionally drilled from the Surfcote site. The disposal zone locations will be approximately 2,000 feet or greater from any uncemented annuli in existing wells drilled from pads DS 4, L 3, and L 4. Specific details for each well will be included in the Applications to Drill. (See attached map.) • The well designs will conform to all AOGCC regulations. • The wells will be completed with large tubulars: 13 3/8" surface casing, 9 5/8" injection casing and 7" tubing. (See attached schematic.) • The surface casings will be set in a sand below the SV3 marker (about 3,900 feet SS) and cemented to surface. • The injection casing will be cemented to just below the surface casing shoe. Surveillance and Monitoring • Injection rate, injection pressure and the inner and outer annulus pressures will be continuously monitored. Injection volumes and pressures will be reported monthly on Form 10 -406. David W. Johnst • October 24, 1997 Page 4 • Mechanical integrity tests will be performed prior to commencing injection and at least once every two years thereafter. • Downhole Togs, reservoir tests and surveys will be scheduled to provide baseline information, and periodically thereafter on an as- needed basis. The information contained in this letter provides a description of planned operations and, where appropriate, an update to the data included in the referenced applications and related correspondence. The anticipated future rates and pressures listed above are intended to represent maximum expected peak daily rates and pressures. However, in some cases these parameters will be limited by existing facilities and future well performance, so expected average values will be somewhat less. Additional updates will be provided if conditions or plans change significantly in the future, or as requested by the Commission. It is our belief that Area Injection Order #4A provides for the above activities and no change in the order is requested by ARCO at this time. If you wish to discuss these matters further, please contact me or D. W. Hanson (263- 4745) at your convenience. Sincerely, Tom Wellman TW:dcd cc: M. L. Bill ATO 1528 D. W. Bose ATO 1670 R. R. Bowden ATO 1576 W. L. Friar ATO 1828 D. W. Hanson ATO 1968 M. M. Ireland ATO 1570 E. M. Oba ATO 1526 D. G. Rodgers ATO 2002 K. Bell BPX MB 9 -1 M. Barker Exxon