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10/6/2005 Orders File Cover Page.doc
• •
INDEX AREA INJECTION ORDER NO . 22E
Prudhoe Bay Unit
Aurora Oil Pool
North Slope, Alaska
1. March 30, 2011 BPXA's request for down-hole commingling
2. April 8, 2011 Notice of Public Hearing; affidavits of publication, email
distribution, and mailings
3. April 30, 2012 BPXA's request for standardization of authorized fluids for
FOR and pressure maintenance
4. May 14, 2013 BPXA's request for Administrative Approval to introduce
radioactive tracer into the Gathering Center 2 (GC2)
production facility for the purpose of oil production,plant
operations, and plant/piping integrity(AIO 22E.002)
5. Emails
6. June 6, 2013 Letter from BPXA to AOGCC regarding clarification
regarding the RCRA status of the radioactive tracers to be
used in the upcoming study at GC2
INDEX AREA INJECTION ORDER NO . 22E
Prudhoe Bay Unit
Aurora Oil Pool
North Slope, Alaska
• •
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7th Avenue, Suite 100
Anchorage Alaska 99501
Re: THE APPLICATION OF BP Exploration (Alaska), ) Docket Number: AIO -11 -05
Inc. for an order authorizing downhole ) Area Injection Order No. 22E
commingling of injection within the wellbore of
Prudhoe Bay Unit S -09, in conformance with 20 ) Prudhoe Bay Unit
AAC 25.215 (c). ) Aurora Oil Pool
North Slope Borough, Alaska
) August 22, 2011
)
NOTICE CLOSING DOCKET
BY THE COMMISSION:
The Commission has the closed the Docket in the above captioned matter.
ENTERED AND EFFECTIVE at Anchorage, Alaska and this 22nd day of August, 2011.
BY DIRECTION OF THE COMMISSION
+I
U '
o t J. Colombie
S . - al Assistant to the Commission
. •
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7th Avenue, Suite 100
Anchorage Alaska 99501
Re: THE APPLICATION OF BP Exploration ) Docket Number: AIO -11 -05
(Alaska), Inc. for an order authorizing ) Area Injection Order No. 22E
downhole commingling of injection within )
the wellbore of Prudhoe Bay Unit S -09, in ) Prudhoe Bay Unit
conformance with 20 AAC 25.215 (c). ) Aurora Oil Pool
North Slope Borough, Alaska
August 22, 2011
IT APPEARING THAT:
1. By letter dated March 30, 2011, BP Exploration (Alaska), Inc. (BPXA), the Prudhoe Bay
Unit (PBU) operator, applied to the Alaska Oil and Gas Conservation Commission
(AOGCC) for authorization to commingle injection within well PBU S -09, in
conformance with 20 AAC 25.215(c).
2. On April 17, 2011, pursuant to 20 AAC 25.540, the AOGCC published in the Alaska
Journal of Commerce notice of opportunity for public hearing on May 26, 2011.
3. The AOGCC received no protest to the application, no public comment, and no request
for hearing.
4. Based upon the information provided by BPXA, the AOGCC has sufficient information
upon which to resolve the request.
5. The public hearing was vacated on May 6, 2011.
FINDINGS:
1. BPXA operates the PBU and the PBU S -09 well, which are located in the North Slope
Borough, Alaska.
2. Well PBU S -09 penetrates hydrocarbon reserves within the Prudhoe Oil Pool (POP) and
Aurora Oil Pool (AOP).
3. Well PBU S -09 is an active water alternating gas (WAG) injection well that penetrates
the POP in an area where offset producers have low production rates due to high water
cuts. The well PBU S -09 currently injects approximately 1,500 barrels of water per day
(BWPD).
4. Well PBU S -09 penetrates the AOP in a compartmentalized area containing a single
producer, well PBU S -118, which is currently shut in due to lack of reservoir support.
The reserves in the portion of the AOP drained by well PBU S -118 do not justify the
drilling of a new well to provide injection support.
5. It is projected that well PBU S -09 could inject approximately 1,000 BWPD in the AOP,
bringing the total injection volume for the well to approximately 2,500 BWPD. Future
Area Injection Order 22E • •
August 22, 2011
Page 2 of 5
injection service for the well may include miscible injectant from the Prudhoe Bay
Miscible Gas Project.
6. Injection logs can be used to determine the allocation of injection volumes between the
two pools.
7. Pressure from the individual pools can be determined by means of tubing plugs and
downhole pressure gauges.
8. Injection into either pool can be blocked as necessary.
CONCLUSIONS:
1. Allowing commingled injection in well PBU S -09 should increase ultimate recovery from
this portion of the field by allowing the PBU S -118 to be returned to production with
support from well PBU S -09, while continuing to provide support for POP oil production.
2. An injection logging plan can be designed to accurately allocate injection volumes
between the two pools.
3. Provided the injection pressure and fluid type requirements of the Area Injection Orders
that pertain to the AOP and POP are followed the pools will not be damaged due to
incompatible fluids or injection pressures that allow for fracture propagation through the
confining intervals.
NOW THEREFORE IT IS ORDERED:
In addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these
rules), the following rules govern Class II injection operations in the affected area described
below and supersede and replace the rules adopted in Area Injection Order No. 22D dated
January 30, 2008, as amended:
AFFECTED AREA
Township Sections
Range, UM
TI1N -R12E Sec 2: W1 /2
Sec 3: All
Sec 4: E 1/2, NW 1/4, E 1/2 SW 1/4
Sec 5: E 1/21/2NE1/4
Sec. 9: NE1 /4, N1 /2SEI /4
Sec 10: NW1 /4SW1 /4, Wl /2NWI /4
TI2N -RI2E Sec 15: Sl /2SE1 /4, SW1 /4
Sec 16: NW1 /4, SI /2
Sec 17: S1 /2, NE1 /4
Sec 18: SE1 /4
Sec 19: Nl /2 NE1 /4
Sec 20: E1/2, N1 /2NW1 /4
Sec 21: All
Sec 22: All
Sec 23: S1/2, S1/2NW1 /4,S1/2NE1 /4
Sec 25; S1/2, S1 /2NW1 /4
Sec 26; All
Sec 27: All
Sec 28: All
Sec 29: E1 /2NE1 /4, SE1 /4
Sec 32: E1 /2
Sec 33: All
Sec 34: All
Sec 35: All
Sec 36: All
Area Injection Order 22E •
•
August 22, 2011
Page 3 of 5
Rule 1. Authorized Injection Strata for Enhanced Recovery (Source: AIO 22)
Injection is permitted into the accumulation of hydrocarbons that is common to, and correlates
with, the interval between 6765'- 7765' measured depth ( "MD ") in the Mobil Oil Corporation
Mobil- Phillips North Kuparuk State No. 26 -12 -12 well.
Rule 2 Injection Pressures (Source: AIO 22B)
The injection operations shall not allow fractures to propagate into the confining intervals.
Surface wellhead injection pressures shall be limited to 2800 psi for water and 3800 psi for gas.
Rule 3. Fluid Injection Wells (Source: MO 22C)
a. The underground injection of fluids must be through a well permitted for drilling as a
service well for injection in conformance with 20 AAC 25.005, or through a well
approved for conversion to a service well for injection in conformance with 20 AAC
25.280.
b. An application to drill or convert a well for injection must be accompanied by the
information required by 20 AAC 25.402(c), and must include cementing records, cement
quality log or formation integrity test records.
Rule 4. Monitoring the Tubing - Casing Annulus Pressure Variations (Source: AIO 22D)
The tubing by casing annulus pressure and injection rate of each injection well must be checked
at least weekly to confirm continued mechanical integrity.
Rule 5. Demonstration of Tubing- Casing Annulus Mechanical Integrity (Source: AIO
22D)
The mechanical integrity of an injection well must be demonstrated before injection begins, and
before returning a well to service following a workover affecting mechanical integrity. An
AOGCC - witnessed mechanical integrity test must be performed after injection is commenced for
the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate,
etc.) have stabilized. Subsequent tests must be performed at least once every four years
thereafter (except at least once every two years in the case of a slurry injection well). The
AOGCC must be notified at least 24 hours in advance to enable a representative to witness
mechanical integrity tests. Unless an alternate means is approved by the AOGCC, mechanical
integrity must be demonstrated by a tubing by casing annulus pressure test using a surface
pressure of 1500 psi or 0.25 psi /ft multiplied by the vertical depth of the packer, whichever is
greater, that shows stabilizing pressure and does not change more than 10 percent during a 30-
minute period. Results of mechanical integrity tests must be readily available for AOGCC
inspection.
Rule 6. Well Integrity Failure (Source: AIO 22D)
Whenever any pressure communication, leakage or lack of injection zone isolation is indicated
Area Injection Order 22E • •
August 22, 2011
Page 4 of 5
by injection rate, operating pressure observation, test, survey, log, or other evidence, the
Operator shall notify the AOGCC by the next business day and submit a plan of corrective action
on a Form 10 -403 for AOGCC approval. The Operator shall immediately shut in the well if
continued operation would be unsafe or would threaten contamination of freshwater, or if so
directed by the AOGCC. A monthly report of daily tubing and casing annuli pressures and
injection rates must be provided to the AOGCC for all injection wells indicating well integrity
failure or lack of injection zone isolation.
Rule 7. Notification of Improper Class II Injection (Source: AIO 22C)
The operator shall notify the AOGCC if it learns of any improper injection of fluids into a Class
II well. Additionally, compliance with the notification requirements of any other State or Federal
agency remains the operator's responsibility.
Rule 8. Other conditions (Source: AIO 22D)
a. It is a condition of the authorization granted by this Order that the operator shall
comply with all applicable AOGCC regulations.
b. The AOGCC may immediately suspend, revoke, or modify this authorization if injected
fluids fail to be confined within the designated injection strata.
Rule 9. Administrative Action (Source: MO 22B)
Unless notice and public hearing are otherwise required, the AOGCC may administratively
waive the requirements of any rule herein or administratively amend any rule as long as the
change does not promote waste or jeopardize correlative rights, is based on sound engineering
and geoscience principles, and will not result in an increased risk of fluid movement into
freshwater.
Rule 10. Authorized Fluids for Enhanced Recovery (Source: AIO 22B)
The fluids authorized by this Order for injection and conditions of the authorization are as
follows:
a. produced water from the AOP or Prudhoe Bay Unit processing facilities;
b. source water from the Prince Creek formation provided that the water is shown to be
compatible with the AOP formation and administrative approval to inject is obtained
from the AOGCC;
c. enriched hydrocarbon gas processed within the Prudhoe Bay Unit processing facilities,
with the following conditions:
1. reservoir pressure must be maintained to ensure miscibility of the injectant, and
2. expansion of injection outside of the North of Crest and West Blocks must be
administratively approved prior to long -term injection;
d. immiscible hydrocarbon gas from the AOP or Prudhoe Bay Unit processing facilities
provided that AOGCC approval of the associated depletion strategy and surveillance
plans is obtained prior to start of injection;
e. tracer survey fluid to monitor reservoir performance; and
Area Injection Order 22E •
•
August 22, 2011
Page 5 of 5
f. non - hazardous filtered water collected from AOP well house cellars and well pads.
Rule 11. Wells Authorized for Downhole Commingled Injection with the Prudhoe Oil
Pool (Source: MO 22C.002 and New This Order)
Injection into the AOP and POP within the same wellbore is authorized for wells PBU S -09 and
S -31A, subject to the following conditions.
a. An approved Application for Sundry Approval (Form 10 -403) is required for each well
prior to commencement of commingled injection.
b. Within 60 days of commencement of commingled injection in a well, or switching from
one injection fluid to the other, BPXA must conduct an injection survey to determine the
proper allocation of injected fluids. Additional injection surveys shall be conducted on
each well at least once per year thereafter as long as the well continues commingled
injection.
c. Annual and total cumulative volumes injected by pool and results of logs or surveys used
for determining the allocation of injected fluids between pools must be supplied in the
Annual Surveillance Report for the AOP.
DONE at Anchorage, Alaska and dat- d A , gus ' 22, 2011. 0 '
- s ..,/ I , , 4
n iel T. Seams unt, Jr. O, T Cathy /P. Foerster co, AND Chair o is 'oner Commissioner y,�
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
� `' � • 2O
Commission grants for good cause shown, a person affected by it may file with the Commission an application for reconsiderati, o `; „
the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsidera "I I ■ ;'
must set out the respect in which the order or decision is believed to be erroneous. ` - G
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.
VIII
• •
Fisher, Samantha J (DOA)
From: Fisher, Samantha J (DOA)
Sent: Tuesday, August 23, 2011 9:18 AM
To: '( michael .j.nelson @conocophillips.com); '(Von.L .Hutchins @conocophillips.com)';
'AKDCWeIIIntegrityCoordinator; 'Alan Dennis'; 'alaska @petrocalc.com'; 'Anna Raff; 'Barbara
F Fullmer; 'bbritch'; 'Becky Bohrer; 'Bill Penrose'; 'Bill Walker; 'Bowen Roberts'; 'Brady, Jerry
L'; 'Brandon Gagnon'; 'Brandow, Cande (ASRC Energy Services)'; 'Brian Havelock'; 'Bruce
Webb'; 'caunderwood'; 'Chris Gay'; 'Cliff Posey'; 'Crandall, Krissell'; 'D Lawrence'; 'dapa';
'Daryl J. Kleppin'; 'Dave Harbour; 'Dave Matthews'; 'David Boelens'; 'David House'; 'David
Scott'; 'David Steingreaber'; 'ddonkel @cfl.rr.com; 'Dennis Steffy'; 'Elizabeth Bluemink'; 'Elowe,
Kristin'; 'Erika Denman'; 'eyancy'; 'Francis S. Sommer; 'Fred Steece'; 'Garland Robinson';
'Gary Laugh lin'; 'Gary Schultz (gary.schultz @alaska.gov)'; 'ghammons'; 'Gordon Pospisil';
'Gorney, David L.'; 'Greg Duggin'; 'Gregg Nady'; 'gspfoff; 'Harry Engel'; 'Jdarlington
(jarlington @gmail.com); 'Jeanne McPherren'; 'Jeff Jones'; 'Jeffery B. Jones
(jeff.jones @alaska.gov)'; 'Jerry McCutcheon'; 'Jill Womack'; 'Jim White'; 'Jim Winegarner
'Joe Nicks'; 'John Garing'; 'John Katz (john.katz @alaska.gov)'; 'John S. Haworth'; 'John
Spain'; 'John Tower'; 'Jon Gott'; Jones, Jeff (GOV sponsored); 'Judy Stanek'; 'Julie Houle';
'Kari Moriarty'; 'Kaynell Zeman'; 'Keith Wiles'; 'Kelly Sperback'; 'Kim Cunningham'; 'Larry
Ostrovsky'; 'Laura Silliphant (laura.gregersen @alaska.gov); 'Marc Kovak'; 'Marilyn Crockett
'Mark Dalton'; 'Mark Hanley (mark.hanley @anadarko.com)'; 'Mark P. Worcester; 'Marguerite
kremer (meg.kremer @alaska.gov)'; 'Michael Dammeyer; 'Michael Jacobs'; 'Mike Bill'; 'Mike
Mason'; 'Mike) Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; 'nelson'; 'Nick W.
Glover; 'NSK Problem Well Supv'; 'Patty Alfaro'; 'Paul Decker (paul.decker @alaska.gov)';
'Paul Figel'; 'PORHOLA, STAN T'; 'Randall Kanady'; 'Randy L. Skillern'; 'Rena Delbridge';
'Renan Yanish'; ' rob.g.dragnich @exxonmobil.com'; 'Robert Brelsford'; 'Robert Campbell';
'Rudy Brueggeman'; 'Ryan Tunseth'; 'Scott Cranswick'; 'Scott Griffith'; 'Shannon Donnelly';
'Sharmaine Copeland'; Shellenbaum, Diane P (DNR); Slemons, Jonne D (DNR); 'Sondra
Stewman'; 'Steve Lambert'; 'Steve Moothart (steve.moothart @alaska.gov)'; 'Steven R.
Rossberg'; 'Suzanne Gibson'; 'tablerk'; 'Tamera Sheffield'; Taylor, Cammy 0 (DNR); 'Temple
Davidson'; 'Teresa Imm; 'Terrie Hubble'; 'Thor Cutler; 'Tina Grovier'; 'Todd Durkee'; 'Tony
Hopfinger'; 'trmjrl'; 'Vicki Irwin'; 'Walter Featherly'; 'Will Chinn'; Williamson, Mary J (DNR);
'Yereth Rosen'; 'Aaron Gluzman'; 'Ben Greene'; Bruno, Jeff J (PCO); 'Casey Sullivan'; 'Dale
Hoffman'; 'David Lenig'; 'Donna Vukich'; 'Eric Lidji'; 'Gary Orr; Heusser, Heather A (DNR);
'Jason Bergerson'; 'Joe Longo'; King, Kathleen J (DNR); 'Lars Coates'; 'Lois Epstein'; 'Marc
Kuck'; 'Marie Steele'; 'Mary Aschoff; 'Matt Gill'; 'Maurizio Grandi'; Ostrovsky, Larry Z (DNR);
'Patricia Bettis'; 'Peter Contreras'; 'Richard Garrard'; 'Ryan Daniel'; 'Sandra Lemke'; 'Talib
Syed'; 'Ted Rockwell'; 'Wayne Wooster'; 'Wendy Wollf; 'William Van Dyke'; 'Aubert, Winton G
(DOA) (winton.aubert @alaska.gov)'; Ballantine, Tab A (LAW); Bender, Makana K (DOA);
'Brooks, Phoebe L (DOA) (phoebe.brooks @alaska.gov)'; 'Colombie, Jody J (DOA)
(jody.colombie @alaska.gov)'; 'Crisp, John H (DOA) (john.crisp @alaska.gov)'; 'Davies,
Stephen F (DOA) (steve.davies @alaska.gov)'; 'Foerster, Catherine P (DOA)
(cathy.foerster @alaska.gov); 'Grimaldi, Louis R (DOA) (lou.grimaldi @alaska.gov)'; Herrera,
Matt F (DOA); 'Johnson, Elaine M (DOA) (elaine.johnson @alaska.gov)'; 'Laasch, Linda K
(DOA) (Iinda.laasch @alaska.gov); 'Maunder, Thomas E (DOA) (tom. maunder @alaska.gov)';
'McIver, Bren (DOA) (bren.mciver @alaska.gov)'; 'McMains, Stephen E (DOA)
(steve.mcmains @alaska.gov)'; Mumm, Joseph (DOA sponsored); 'Noble, Robert C (DOA)
(bob.noble @alaska.gov)'; 'Norman, John K (DOA) (john.norman @alaska.gov)'; 'Okland,
Howard D (DOA) (howard.okland @alaska.gov)'; 'Paladijczuk, Tracie L (DOA)
( tracie .paladijczuk @alaska.gov)'; 'Pasqual, Maria (DOA) (maria.pasqual @alaska.gov)'; 'Regg,
James B (DOA) (jim.regg @alaska.gov)'; 'Roby, David S (DOA) (dave.roby @alaska.gov);
'Saltmarsh, Arthur C (DOA) (art.saltmarsh @alaska.gov); 'Scheve, Charles M (DOA)
(chuck.scheve @alaska.gov)'; 'Schwartz, Guy L (DOA) (guy.schwartz @alaska.gov)
'Seamount, Dan T (DOA) (dan.seamount @alaska.gov)'
Subject: aio22e Prudhoe Bay Unit
Attachments: aio22e.pdf
Samantha Fisher, Executive Secretary II
Alaska Oil and Gas Conservation Commission
(907)793 -1223
1
• •
Mary Jones David McCaleb
XTO Energy, Inc. IHS Energy Group George Vaught, Jr.
Cartography GEPS P.O. Box 13557
810 Houston Street, Ste 200 5333 Westheimer, Suite 100 Denver, CO 80201 -3557
Ft. Worth, TX 76102 -6298 Houston, TX 77056
Jerry Hodgden Richard Neahring Mark Wedman
Hodgden Oil Company NRG Associates Halliburton
President
408 18 Street 6900 Arctic Blvd.
Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502
Colorado Springs, CO 80901
Bernie Karl CIRI Baker Oil Tools
K &K Recycling Inc. Land Department 795 E. 94 Ct.
P.O. Box 58055 P.O. Box 93330 Anchorage, AK 99515 -4295
Fairbanks, AK 99711 Anchorage, AK 99503
North Slope Borough Richard Wagner Gordon Severson
Planning Department P.O. Box 60868 3201 Westmar Circle
P.O. Box 69 Fairbanks, AK 99706 Anchorage, AK 99508 -4336
Barrow, AK 99723
Jack Hakkila Darwin Waldsmith James Gibbs
P.O. Box 190083 P.O. Box 39309 P.O. Box 1597
Anchorage, AK 99519 Ninilchick, AK 99639 Soldotna, AK 99669
Penny Vadla Cliff Burglin
399 West Riverview Avenue 319 Charles Street
Soldotna, AK 99669 -7714 Fairbanks, AK 99701
D)■,\ ( 5\ \\
SO)
• •
IR C_a e� a a A SEAN PARNELL, GOVERNOR
O
ALASKA 0114 AND GAS 333 W. 7th AVENUE, SUITE 100
CONSERVATION COMMISSION ANCHORAGE, ALASKA 99501 -3539
PHONE (907) 279 -1433
FAX (907) 276 -7542
ADMINISTRATIVE APPROVAL
AREA INJECTION ORDER NO. 22E.001
Ms. Allison Cooke
UIC Compliance Advisor
BP Exploration (Alaska) Inc.
P.O. Box 196612
Anchorage, AK 99519 -6612
RE: Authorized Fluids for EOR and Pressure Maintenance for the Aurora Oil Pool
Dear Ms. Cooke:
By letter dated April 30, 2012, BP Exploration (Alaska) Inc. (BPXA) requested that the Alaska
Oil and Gas Conservation Commission (AOGCC) administratively amend the following Area
Injection Orders (AIO): 3A, 4E, 14A, 20, 22E, 24B, 25A, 26B and 31. BPXA requested the
amendments in an effort to standardize the fluids authorized for injection for enhanced recovery
and pressure maintenance for the oil pools in the Prudhoe Bay Field. BPXA requested the
standardization due to the complexity of managing injection operations for multiple pools, with
different lists of authorized fluids, which are served by common production facilities. In
accordance with terms set forth below, BPXA's request is APPROVED, with a minor change
to the wording proposed by BPXA.
BPXA proposes that AIO No. 22E be modified to approve the following for EOR and pressure
maintenance injection.
- Produced water and gas;
- Enriched hydrocarbon gas;
- Non - hazardous water and water based fluids — (includes seawater, source water,
freshwater, domestic wastewater, equipment washwater, sump fluids, hydrotest fluids,
firewater, and water with trace chemicals, and other water based fluids with a pH greater
than or equal to 2 or less than or equal to 12.5 and flashpoint greater than 10 degrees F);
- Fluids introduced to production facilities for the purpose of oil production, plant
operations, plant/piping integrity or well maintenance that become entrained in the
produced water stream after oil, gas, and water separation in the facility. Includes but not
limited to:
o Freeze protection fluids;
o Fluids in mixtures of oil sent for hydrocarbon recycle;
o Corrosion/scale inhibitor fluids;
o Anti - foams /emulsion breakers;
AIO 22E.001 • •
September 4, 2012
Page 2 of 3
o Glycols
- Non - hazardous glycols and glycol mixtures;
- Fluids that are used for their intended purpose within the oil production process.
Includes:
o Scavengers;
o Biocides
- Fluids to monitor or enhance reservoir performance. Includes:
o Tracer survey fluids;
o Well stimulation fluids;
o Reservoir profile modification fluids.
As shown above, the list of fluids for which BPXA seeks approval uses the terms "includes" and
"includes but not limited to. Words such as "includes" and includin along with phrases such
g g p
" inappropriately to BPXA the authority "includes but is not limited to inappropriately delegate y to determine
what additional fluids are approved. Therefore, this approval modifies BPXA's proposal to
delete the use of any such language as set forth below.
In support of its application, BPXA submitted a fluid compatibility review based on previous
orders and laboratory testing. This review showed that the proper handling and treating,
including the use of scale inhibitors, of the injection fluids as well as the proper operation and
maintenance, including the pumping of scale remover and acid treatments, of the injection wells
will prevent or counteract incompatibility effects. Thus there are no operational risks associated
with injection of the proposed fluids in this pool.
The change proposed by BPXA will result in increased production, is based on sound
engineering and geotechnical reasons, does not promote waste or jeopardize correlative rights,
and will not result in increased risk of fluid movement into freshwater. Correlative rights are
protected because all lands subject to these orders have been unitized. Freshwater is protected by
the proper design and completion of the wells, ongoing /periodic mechanical integrity evaluation
required for all injection wells and review of the offset wells to ensure that they won't act as
conduits to fluid movement.
NOW THEREFORE IT IS ORDERED THAT:
Rule 10 of AIO 22E is repealed and replaced by the following:
Rule 10. Authorized Fluids for Enhanced Recovery
The fluids authorized by this Order for injection are as follows:
a) Produced water and gas from Prudhoe Bay Unit processing facilities;
b) Enriched hydrocarbon gas;
c) Non - hazardous water and water based fluids — (specifically seawater, source
water, freshwater, domestic wastewater, equipment washwater, sump fluids,
hydrotest fluids, firewater, and water with trace chemicals, and other water based
AIO 22E.001 • •
September 4, 2012
Page 3 of 3
fluids with a pH greater than or equal to 2 or less than or equal to 12.5 and
flashpoint greater than 10 degrees F);
d) Fluids introduced to production facilities for the purpose of oil production, plant
operations, plant/piping integrity or well maintenance that become entrained in
the produced water stream after oil, gas, and water separation in the facility.
Specifically:
i. Freeze protection fluids;
ii. Fluids in mixtures of oil sent for hydrocarbon recycle;
iii. Corrosion/scale inhibitor fluids;
iv. Anti -foams /emulsion breakers;
v. Glycols
e) Non - hazardous glycols and glycol mixtures;
f) Fluids that are used for their intended purpose within the oil production process.
Specifically:
i. Scavengers;
ii. Biocides
g) Fluids to monitor or enhance reservoir performance. Specifically:
i. Tracer survey fluids;
ii. Well stimulation fluids;
iii. Reservoir profile modification fluids. g s`i' OIL avo
DONE at Anchorage, Alaska and dated September 4, 2012.
� O P�4�� 4i) cin
Daniel T. eamount, Jr. J inrk. 1 orman 4 1ioN C
Commissioner Commissioner
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 AOGCC
grants for good cause shown, a person affected by it may file with the AOGCC 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 AOGCC 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 l0 -days is a denial of reconsideration. If the AOGCC 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
AOGCC mails, OR 30 days if the AOGCC 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 AOGCC 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 AOGCC, and it may be appealed to superior court. That appeal MUST be filed
within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on
Y
reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited to the questions presented to the AOGCC 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.
•
Fisher, Samantha J (DOA)
From: Fisher, Samantha J (DOA)
Sent: Thursday, September 06, 2012 1:42 PM
To: '( michael .j.nelson @conocophillips.com)'; '(Von.L .Hutchins @conocophillips.com)';
'AKDCWelllntegrityCoordinator; 'alaska @petrocalc.com'; 'Anna Raff; 'Barbara F Fullmer';
'bbritch'; 'Becky Bohrer'; 'Bill Penrose'; 'Bill Walker'; 'Bowen Roberts'; 'Bruce Webb';
'caunderwood'; 'Claire Caldes'; 'Cliff Posey'; 'Crandall, Krissell'; 'D Lawrence'; 'dapa'; 'Daryl J.
Kleppin'; 'Dave Harbour'; 'Dave Matthews'; 'David Boelens'; 'David House'; 'David Scott';
'David Steingreaber'; 'ddonkel @cfl.rr.com'; 'Dennis Steffy'; 'Elowe, Kristin'; 'Erika Denman';
'Francis S. Sommer'; 'Gary Laughlin'; 'Gary Schultz (gary.schultz @alaska.gov)'; 'ghammons';
'Gordon Pospisil'; 'Gorney, David L.'; 'Greg Duggin'; 'Gregg Nady'; 'Gregory Geddes'; 'gspfoff;
'Jdarlington (jarlington @gmail.com)'; 'Jeanne McPherren'; 'Jeff Jones'; 'Jeffery B. Jones
(jeff.jones @alaska.gov)'; 'Jerry McCutcheon'; 'Jill Womack'; 'Jim White'; 'Jim Winegarner';
'Joe Lastufka'; 'Joe Nicks'; 'John Easton'; 'John Garing'; 'John S. Haworth'; 'John Spain'; 'Jon
Goltz'; Jones, Jeffrey L (GOV); 'Judy Stanek'; 'Julie Houle'; 'Julie Little'; 'Kari Moriarty'; 'Kaynell
Zeman'; 'Keith Wiles'; 'Kelly Sperback'; 'Laura Silliphant (Iaura.gregersen @alaska.gov)'; 'Luke
Keller'; 'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley @anadarko.com)'; 'Mark P.
Worcester'; 'Marguerite kremer (meg.kremer @alaska.gov)'; 'Michael Jacobs'; 'Mike Bill'; 'Mike
Mason'; 'Mike Morgan'; 'Mikel Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200';
'nelson'; 'Nick W. Glover'; 'NSK Problem Well Supv'; 'Patty Alfaro'; 'Paul Decker
(paul.decker @alaska.gov)'; 'Paul Figel'; 'Paul Mazzolini'; 'Randall Kanady'; 'Randy L. Skillern';
'Rena Delbridge'; 'Renan Yanish'; 'Robert Brelsford'; 'Robert Campbell'; 'Ryan Tunseth'; 'Scott
Cranswick'; 'Scott Griffith'; 'Shannon Donnelly'; 'Sharmaine Copeland'; Shellenbaum, Diane P
(DNR); Slemons, Jonne D (DNR); 'Sondra Stewman'; 'Stephanie Klemmer'; 'Steve Moothart
(steve.moothart@alaska.gov)'; 'Steven R. Rossberg'; 'Suzanne Gibson'; 'Tamera Sheffield';
Taylor, Cammy 0 (DNR); 'Temple Davidson'; 'Teresa Imm'; 'Terrie Hubble'; 'Thor Cutler'; 'Tim
Mayers'; 'Tina Grovier'; 'Todd Durkee'; 'Tony Hopfinger'; 'trmjrl'; 'Vicki Irwin'; 'Walter
Featherly'; Williamson, Mary J (DNR); 'Yereth Rosen'; 'Aaron Gluzman'; 'Aaron Sorrell'; 'Bruce
Williams'; Bruno, Jeff J (DNR); 'Casey Sullivan'; 'Dale Hoffman'; 'David Lenig'; 'Donna Vukich';
'Eric Lidji'; 'Erik Opstad'; Franger, James M (DNR); 'Gary Orr'; 'Graham Smith'; 'Greg Mattson';
Heusser, Heather A (DNR); 'Jason Bergerson'; 'Jennifer Starck'; 'Jill McLeod'; 'Joe Longo';
King, Kathleen J (DNR); 'Lars Coates'; 'Lois Epstein'; 'Marc Kuck'; 'Marie Steele'; 'Mary
Aschoff; 'Matt Gill'; 'Maurizio Grandi'; OilGas, Division (DNR sponsored); 'Patricia Bettis';
Perrin, Don J (DNR); 'Peter Contreras'; Pexton, Scott R (DNR); 'Richard Garrard'; 'Ryan
Daniel'; 'Sandra Lemke'; 'Talib Syed'; 'Wayne Wooster'; 'Wendy Wollf; 'William Hutto';
'William Van Dyke'; Ballantine, Tab A (LAW); Bender, Makana K (DOA); 'Brooks, Phoebe L
(DOA) (phoebe.brooks @alaska.gov)'; 'Colombie, Jody J ( DOA) (jody.colombie @alaska.gov)';
'Crisp, John H (DOA) (john.crisp @alaska.gov)'; 'Davies, Stephen F (DOA)
(steve.davies @alaska.gov)'; Ferguson, Victoria L (DOA); 'Foerster, Catherine P (DOA)
(cathy.foerster @alaska.gov)'; 'Grimaldi, Louis R (DOA) (lou.grimaldi @aiaska.gov)'; 'Johnson,
Elaine M (DOA) (elaine.johnson @alaska.gov)'; 'Laasch, Linda K (DOA)
(linda.laasch @alaska.gov)'; 'McIver, Bren (DOA) (bren.mciver @alaska.gov)'; 'McMains,
Stephen E (DOA) (steve.mcmains @alaska.gov)'; Mumm, Joseph (DOA sponsored); 'Noble,
Robert C (DOA) (bob.noble @alaska.gov)'; 'Norman, John K (DOA)
(john.norman @alaska.gov)'; 'Okland, Howard D (DOA) (howard.okland @alaska.gov)';
'Paladijczuk, Tracie L (DOA) ( tracie .paladijczuk @alaska.gov)'; 'Pasqua!, Maria (DOA)
(maria.pasqual @alaska.gov)'; 'Regg, James B (DOA) (jim.regg @alaska.gov)'; 'Roby, David S
(DOA) (dave.roby @alaska.gov)'; 'Scheve, Charles M (DOA) (chuck.scheve @alaska.gov)';
'Schwartz, Guy L (DOA) (guy.schwartz @alaska.gov)'; 'Seamount, Dan T (DOA)
(dan.seamount @alaska.gov)'; Wallace, Chris D (DOA)
Subject: aio22e -001 Aurora Oil Pool
Attachments: aio22e -001. pdf
3
• •
Mary Jones David McCaleb
XTO Energy, Inc. IHS Energy Group George Vaught, Jr.
Cartography GEPS P.O. Box 13557
810 Houston Street, Ste 200 5333 Westheimer, Suite 100 Denver, CO 80201 -3557
Ft. Worth, TX 76102 -6298 Houston, TX 77056
Jerry Hodgden Richard Neahring Mark Wedman
Hodgden Oil Company NRG Associates Halliburton
408 18 Street President 6900 Arctic Blvd.
Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502
Colorado Springs, CO 80901
Bernie Karl CIRI Baker Oil Tools
K &K Recycling Inc. Land Department 795 E. 94 Ct.
P.O. Box 58055 P.O. Box 93330 Anchorage, AK 99515 -4295
Fairbanks, AK 99711 Anchorage, AK 99503
North Slope Borough Richard Wagner Gordon Severson
Planning Department P.O. Box 60868 3201 Westmar Circle
P.O. Box 69 Fairbanks, AK 99706 Anchorage, AK 99508 -4336
Barrow, AK 99723
Jack Hakkila Darwin Waldsmith James Gibbs
P.O. Box 190083 P.O. Box 39309 P.O. Box 1597
Anchorage, AK 99519 Ninilchick, AK 99639 Soldotna, AK 99669
Penny Vadia
399 West Riverview Avenue
Soldotna, AK 99669 -7714
• 1 cb
ID •
w \�I 7 s ∎ THE STATE Alaska Oil and Gas
� �'� ° fALASKA Conservation Commission
u ,\T GOVERNOR SEAN PARNELL 333 West Seventh Avenue
OF Q. Anchorage, Alaska 99501 -3572
ALAS Main: 907.279.1433
Fax: 907.276.7542
ADMINISTRATIVE APPROVAL
AREA INJECTION ORDER NO. 22E.001 AMENDED
Ms. Alison Cooke
UIC Compliance Advisor
BP Exploration (Alaska) Inc.
P.O. Box 196612
Anchorage, AK 99519 -6612
RE: Authorized Fluids for EOR and Pressure Maintenance for the Aurora Oil Pool
Dear Ms. Cooke:
The Alaska Oil and Gas Conservation Commission has amended the Administrative Approval to
correct an error in the description of non - hazardous water based fluids. The correction occurs in
two locations and is shown in underlined text below.
By letter dated April 30, 2012, BP Exploration (Alaska) Inc. (BPXA) requested that the Alaska
Oil and Gas Conservation Commission (AOGCC) administratively amend the following Area
Injection Orders (AIO): 3A, 4E, 14A, 20, 22E, 24B, 25A, 26B and 31. BPXA requested the
amendments in an effort to standardize the fluids authorized for injection for enhanced recovery
and pressure maintenance for the oil pools in the Prudhoe Bay Field. BPXA requested the
standardization due to the complexity of managing injection operations for multiple pools, with
different lists of authorized fluids, which are served by common production facilities. In
accordance with terms set forth below, BPXA's request is APPROVED, with a minor change
to the wording proposed by BPXA.
BPXA proposes that AIO No. 22E be modified to approve the following for EOR and pressure
maintenance injection.
- Produced water and gas;
- Enriched hydrocarbon gas;
- Non - hazardous water and water based fluids — (includes seawater, source water,
freshwater, domestic wastewater, equipment washwater, sump fluids, hydrotest fluids,
firewater, and water with trace chemicals, and other water based fluids with a pH greater
than 2 and less than 12.5 and flashpoint greater than 140 degrees F);
- Fluids introduced to production facilities for the purpose of oil production, plant
operations, plant/piping integrity or well maintenance that become entrained in the
produced water stream after oil, gas, and water separation in the facility. Includes but not
limited to:
• •
AIO 22E.001 Amended
October 9, 2012
Page 2 of 3
o Freeze protection fluids;
o Fluids in mixtures of oil sent for hydrocarbon recycle;
o Corrosion/scale inhibitor fluids;
o Anti -foams /emulsion breakers;
o Glycols
- Non - hazardous glycols and glycol mixtures;
- Fluids that are used for their intended purpose within the oil production process.
Includes:
o Scavengers;
o Biocides
- Fluids to monitor or enhance reservoir performance. Includes:
o Tracer survey fluids;
o Well stimulation fluids;
o Reservoir profile modification fluids.
As shown above, the list of fluids for which BPXA seeks approval uses the terms "includes" and
"includes but not limited to." Words such as "includes" and "including" along with phrases such
as "includes but is not limited to" inappropriately delegate to BPXA the authority to determine
what additional fluids are approved. Therefore, this approval modifies BPXA's proposal to
delete the use of any such language as set forth below.
In support of its application, BPXA submitted a fluid compatibility review based on previous
orders and laboratory testing. This review showed that the proper handling and treating,
including the use of scale inhibitors, of the injection fluids as well as the proper operation and
maintenance, including the pumping of scale remover and acid treatments, of the injection wells
will prevent or counteract incompatibility effects. Thus there are no operational risks associated
with injection of the proposed fluids in this pool.
The change proposed by BPXA will result in increased production, is based on sound
engineering and geotechnical reasons, does not promote waste or jeopardize correlative rights,
and will not result in increased risk of fluid movement into freshwater. Correlative rights are
protected because all lands subject to these orders have been unitized. Freshwater is protected by
the proper design and completion of the wells, ongoing /periodic mechanical integrity evaluation
required for all injection wells and review of the offset wells to ensure that they won't act as
conduits to fluid movement.
NOW THEREFORE IT IS ORDERED THAT:
Rule 10 of AIO 22E is repealed and replaced by the following:
Rule 10. Authorized Fluids for Enhanced Recovery
The fluids authorized by this Order for injection are as follows:
a) Produced water and gas from Prudhoe Bay Unit processing facilities;
b) Enriched hydrocarbon gas;
• •
AIO 22E.001 Amended
October 9, 2012
Page 3 of 3
c) Non - hazardous water and water based fluids — (specifically seawater, source
water, freshwater, domestic wastewater, equipment washwater, sump fluids,
hydrotest fluids, firewater, and water with trace chemicals, and other water based
fluids with a pH greater than 2 and less than 12.5 and flashpoint greater than 140
degrees F);
d) Fluids introduced to production facilities for the purpose of oil production, plant
operations, plant /piping integrity or well maintenance that become entrained in
the produced water stream after oil, gas, and water separation in the facility.
Specifically:
i. Freeze protection fluids;
ii. Fluids in mixtures of oil sent for hydrocarbon recycle;
iii. Corrosion/scale inhibitor fluids;
iv. Anti -foams /emulsion breakers;
v. Glycols
e) Non - hazardous glycols and glycol mixtures;
f) Fluids that are used for their intended purpose within the oil production process.
Specifically:
i. Scavengers;
ii. Biocides
g) Fluids to monitor or enhance reservoir performance. Specifically:
i. Tracer survey fluids;
ii. Well stimulation fluids;
iii. Reservoir profile modification fluids. st ,OMLAN )
NUNC PRO TUNC September 4, 2012
DONE at Anchorage, Alaska and dated October 9, 201. `.y
,; z
Daniel T. Seamount, Jr. , T ' orman t�ION cod
Commissioner Commissioner
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 AOGCC
grants for good cause shown, a person affected by it may file with the AOGCC 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 AOGCC 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 AOGCC 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
AOGCC mails, OR 30 days if the AOGCC 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 AOGCC 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 AOGCC, and it may be appealed to superior court. That appeal MUST be filed
within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC 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 AOGCC by
the application for reconsideration."
In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period;
the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day
that does not fall on a weekend or state holiday.
•
Mary Jones David McCaleb
XTO Energy, Inc. IHS Energy Group George Vaught, Jr.
Cartography GEPS P.O. Box 13557
810 Houston St., Ste. 200 5333 Westheimer, Ste. 100 Denver, CO 80201 -3557
Ft. Worth, TX 76102 -6298 Houston, TX 77056
Jerry Hodgden Richard Neahring Mark Wedman
Hodgden Oil Company NRG Associates Halliburton
` St Presid
40818 6900 Arctic Blvd.
Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502
Colorado Springs, CO 80901
Bernie Karl CIRI
K &K Recycling Inc. Land Department Baker Oil Tools
P.O. Box 58055 P.O. Box 93330 795 E. 94 Ct.
Anchorage, AK 99515-4295
Fairbanks, AK 99711 Anchorage, AK 99503
North Slope Borough Richard Wagner Gordon Severson
Planning Department P.O. Box 60868 3201 Westmar Cir.
P.O. Box 69 Fairbanks, AK 99706 Anchorage, AK 99508 -4336
Barrow, AK 99723
Jack Hakkila Darwin Waldsmith James Gibbs
P.O. Box 190083 P.O. Box 39309 P.O. Box 1597
Anchorage, AK 99519 Ninilchik, AK 99639 Soldotna, AK 99669
Penny Vadia
399 W. Riverview Ave.
Soldotna, AK 99669 -7714
\ C " ) ( \C '( 1 -e) ` 2
CC
• •
Fisher, Samantha J (DOA)
From: Fisher, Samantha J (DOA)
Sent: Tuesday, October 09, 2012 3:40 PM
To: 'Aaron Gluzman'; 'Aaron Sorrell'; 'Bruce Williams'; Bruno, Jeff J (DNR); 'CA Underwood';
'Casey Sullivan; 'Dale Hoffman'; 'David Lenig'; 'Donna Vukich'; 'Eric Lidji'; 'Erik Opstad';
Franger, James M (DNR); 'Gary Orr; 'Graham Smith'; 'Greg Mattson'; Heusser, Heather A
(DNR); 'James Rodgers'; 'Jason Bergerson'; 'Jennifer Starck; 'Jill McLeod'; 'Joe Longo'; King,
Kathleen J (DNR); 'Zara Coates'; 'Lois Epstein'; 'Marc Kuck'; 'Marie Steele'; 'Matt Gill
'Ostrovsky, Larry Z (DNR)'; 'Patricia Bettis'; Perrin, Don J (DNR); 'Peter Contreras'; Pexton,
Scott R (DNR); 'Richard Garrard'; 'Ryan Daniel'; 'Sandra Lemke'; 'Talib Syed'; 'Wayne
Wooster; 'Wendy WoIIf'; 'William Hutto'; 'William Van Dyke';
'(michael.j. nelson @conocophillips.com)'; '(Von.L .Hutchins @conocophillips.com);
`AKDCWelllntegrityCoordinator; 'alaska @petrocalc.com; 'Anna Raff; 'Barbara F Fullmer;
'bbritch'; 'Becky Bohrer; 'Bill Penrose'; 'Bill Walker; 'Bowen Roberts'; 'Bruce Webb'; 'Claire
Caldes'; 'Cliff Posey'; 'Crandall, Krissell'; 'D Lawrence'; 'dapa'; 'Daryl J. Kleppin'; 'Dave
Harbour; 'Dave Matthews'; 'David Boelens'; 'David Duffy'; 'David House'; 'David Scott; 'David
Steingreaber; 'Davide Simeone'; 'ddonkel @cfl.rr.com; 'Dennis Steffy'; 'Elowe, Kristin'; 'Francis
S. Sommer'; 'Gary Laugh lin'; 'Gary Schultz (gary.schultz @alaska.gov); 'ghammons'; 'Gordon
Pospisil'; 'Gorney, David L.'; 'Greg Duggin'; 'Gregg Nady'; 'Gregory Geddes'; 'gspfoff;
'Jdarlington (jarlington @gmail.com)'; 'Jeanne McPherren'; 'Jeffery B. Jones
(jeff.jones @alaska.gov)'; 'Jerry McCutcheon'; 'Jill Womack'; 'Jim White'; 'Jim Winegarner;
'Joe Lastufka'; 'Joe Nicks'; 'John Easton; 'John Garing'; 'John Spain'; 'Jon Goltz'; Jones,
Jeffrey L (GOV); 'Judy Stanek'; 'Julie Houle'; 'Julie Litt le'; 'Kari Moriarty'; 'Kaynell Zeman';
'Keith Wiles'; 'Kelly Sperback'; 'Laura Silliphant (laura.gregersen @alaska.gov); 'Luke Keller;
'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley @anadarko.com)'; 'Mark P.
Worcester'; 'Marguerite kremer (meg.kremer @alaska.gov)'; 'Michael Jacobs'; 'Mike Bill; 'Mike
Mason'; 'Mike Morgan`; `Mike) Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200';
'nelson'; 'Nick W. Glover; 'NSK Problem Well Supv'; 'Patty Alfaro'; 'Paul Decker
(paul.decker @alaska.gov)'; 'Paul Figel'; 'Paul Mazzolini'; 'Randall Kanady'; 'Randy L. Skillern';
'Rena Delbridge'; 'Renan Yanish'; 'Robert Brelsford'; 'Robert Campbell'; 'Ryan Tunseth'; 'Scott
Cranswick'; 'Scott Griffith'; 'Shannon Donnelly'; 'Sharmaine Copeland'; Shellenbaum, Diane P
(DNR); Slemons, Jonne D (DNR); 'Sondra Stewman'; 'Stephanie Klemmer; 'Steve Moothart
(steve.moothart@alaska.gov)'; 'Steven R. Rossberg'; 'Suzanne Gibson'; 'Tamera Sheffield';
Taylor, Cammy 0 (DNR); 'Temple Davidson'; 'Teresa Imm; 'Thor Cutler'; 'Tim Mayers'; 'Tina
Grovier; 'Todd Durkee'; 'Tony Hopfinger; 'trmjrl'; 'Vicki Irwin'; 'Walter Featherly'; 'Yereth
Rosen'; Ballantine, Tab A (LAW); Bender, Makana K (DOA); 'Brooks, Phoebe L (DOA)
(phoebe. brooks @alaska.gov)'; 'Colombie, Jody J ( DOA) (jody.colombie @alaska.gov)'; 'Crisp,
John H (DOA) (john.crisp @alaska.gov); 'Davies, Stephen F (DOA)
(steve.davies @alaska.gov)'; Ferguson, Victoria L (DOA); 'Foerster, Catherine P (DOA)
(cathy.foerster @alaska.gov)'; 'Grimaldi, Louis R (DOA) (lou.grimaldi @alaska.gov)'; 'Johnson,
Elaine M (DOA) (elaine.johnson @alaska.gov)'; 'Laasch, Linda K (DOA)
(Iinda.Iaasch @alaska.gov)'; 'McIver, Bren (DOA) (bren.mciver @alaska.gov)'; 'McMains,
Stephen E (DOA) (steve.mcmains @alaska.gov)'; Mumm, Joseph (DOA sponsored); 'Noble,
Robert C (DOA) (bob.noble @alaska.gov)'; 'Norman, John K (DOA)
(john.norman @alaska.gov)'; 'Okland, Howard D (DOA) (howard.okland @alaska.gov)';
'Paladijczuk, Tracie L (DOA) ( tracie.paladijczuk @alaska.gov); 'Pasqual, Maria (DOA)
(maria.pasqual @alaska.gov)'; 'Regg, James B (DOA) (jim.regg @alaska.gov); 'Roby, David S
(DOA) (dave.roby @alaska.gov); 'Scheve, Charles M (DOA) (chuck.scheve @alaska.gov)';
'Schwartz, Guy L (DOA) (guy.schwartz @alaska.gov)'; 'Seamount, Dan T (DOA)
(dan.seamount @alaska.gov)'; Singh, Angela K (DOA); Wallace, Chris D (DOA)
Subject: aio22e -001 amended
Attachments: aio22e -001 amended.pdf
1
i •
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7th Avenue, Suite 100
Anchorage Alaska 99501
Re: THE APPLICATION OF BP ) Docket Number: AIO-13-10
EXPLORATION (ALASKA) INC. for ) Area Injection Order No. 22E.002
Administrative Approval to inject )
radioactive tracers used for surface facility ) Prudhoe Bay Unit
optimization in enhanced oil recovery ) Aurora Oil Pool
injection wells. North Slope, Alaska
June 20, 2013
By letter dated May 14, 2013, BP Exploration (Alaska) Inc. (BPXA) requested administrative
approval to introduce radioactive tracers into the Gathering Center 2 (GC2) production facility
for the purpose of facility optimization. After passing through the production facility the
radioactive tracers would be entrained in the produced water injection system and injected in
enhanced oil recovery and disposal wells.
Radioactive tracers are not regulated by the Resource Conservation and Recovery Act (RCRA).
The volume of radioactive tracer material will be exceedingly small in proportion to the millions
of gallons of produced water that GC2 handles on a daily basis. The half-life of the proposed
tracers is less than two days.
The exceedingly small volume and low concentration of the radioactive tracer material in the
produced water stream will have no impact on its performance as an enhanced oil recovery
injectant, and will not result in any formation or reservoir fluid compatibility issues. Therefore,
amending the list of approved fluids to include radioactive tracer fluids introduced to production
facilities is appropriate.
NOW THEREFORE IT IS ORDERED THAT:
Rule 10 of AIO 22E is repealed and replaced by the following:
Rule 10. Authorized Fluids for Enhanced Recovery
The fluids authorized by this Order for injection are as follows:
a) Produced water and gas from Prudhoe Bay Unit processing facilities;
b) Enriched hydrocarbon gas;
c) Non-hazardous water and water based fluids — (specifically seawater, source
water, freshwater, domestic wastewater, equipment washwater, sump fluids,
hydrotest fluids, firewater, and water with trace chemicals, and other water based
•
AIO 22E-002
June 20,2013
Page 2 of 2
fluids with a pH greater than 2 and less than 12.5 and flashpoint greater than 140
degrees F);
d) Fluids introduced to production facilities for the purpose of oil production, plant
operations, plant/piping integrity or well maintenance that become entrained in
the produced water stream after oil, gas, and water separation in the facility.
Specifically:
i. Freeze protection fluids;
ii. Fluids in mixtures of oil sent for hydrocarbon recycle;
iii. Corrosion/scale inhibitor fluids;
iv. Anti-foams/emulsion breakers;
v. Glycols;
vi. Radioactive tracer survey fluids
e) Non-hazardous glycols and glycol mixtures;
f) Fluids that are used for their intended purpose within the oil production process.
Specifically:
i. Scavengers;
ii. Biocides
g) Fluids to monitor or enhance reservoir performance. Specifically:
i. Tracer survey fluids;
ii. Well stimulation fluids;
iii. Reservoir profile modification fluids. .;io1:Tij
DONE at Anchorage, Alaska and dates un- , 2 r'
313. J "_
yy J ` Cffr
Daniel T. Seam'''.
eaount, Jr. Jo . orman _
m' f .44
- �
Commissioner Commissioner ill
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
AOGCC grants for good cause shown,a person affected by it may file with the AOGCC 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 AOGCC 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 AOGCC 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 AOGCC mails, OR 30 days if the AOGCC 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 AOGCC 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 AOGCC,and it may be appealed to superior court. That appeal MUST be
filed within 33 days after the date on which the AOGCC mails,OR 30 days if the AOGCC 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
AOGCC 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.
•
Singh, Angela K (DOA)
From: Fisher, Samantha J (DOA)
Sent: Thursday,June 20, 2013 1:20 PM
To: (michaei j.nelson @conocophillips.com);AKDCWellIntegrityCoordinator;
alaska @petrocalc.com;Alexander Bridge;Andrew VanderJack;Anna Raff; Barbara F
Fullmer; bbritch; bbohrer @ap.org; Bill Penrose; Bill Walker; Bowen Roberts; Brian
Havelock;caunderwood @marathonoil.com;Cliff Posey;Crandall, Krissell; D Lawrence;
Dave Harbour; Dave Matthews; David Boelens; David Duffy; David House; David Scott;
David Steingreaber; Davide Simeone; ddonkel @cfl.rr.com; Donna Ambruz; Dowdy,Alicia
G (DNR); Dudley Platt; Elowe, Kristin; Francis S. Sommer; Gary Laughlin; schultz, gary
(DNR sponsored);ghammons;Gordon Pospisil;Gorney, David L; Greg Duggin;Gregg
Nady; Gregory Geddes;gspfoff;Jdarlington (jarlington @gmail.com);Jeanne McPherren;
Jones,Jeffery B (DOA);Jerry McCutcheon;Jim White;Jim Winegarner;Joe Lastufka;
news @radiokenai.com; Burdick,John D (DNR); Easton,John R(DNR);John Evans;John
Garing;Jon Goltz;Jones,Jeffrey L(GOV);Juanita Lovett;Judy Stanek; Houle,Julie(DNR);
Julie Little; Kari Moriarty; Kaynell Zeman; Keith Wiles; Kelly Sperback; Gregersen, Laura S
(DNR); Luke Keller; Marc Kovak; Dalton, Mark(DOT sponsored); Mark Hanley
(mark.hanley @anadarko.com); Mark P.Worcester; Kremer, Marguerite C (DNR); Michael
Jacobs; Mike Bill; mike @kbbi.org; Mike! Schultz; Mindy Lewis; MJ Loveland; mjnelson;
mkm7200; knelson @petroleumnews.com; Nick W.Glover; Nikki Martin; NSK Problem
Well Supv; Patty Alfaro; Decker, Paul L(DNR); Paul Mazzolini; Pike, Kevin W(DNR);
Pioneer; Randall Kanady; Randy L. Skillern; Randy Redmond; Rena De!bridge; Renan
Vanish; Robert Brelsford; Robert Campbell; Ryan Tunseth;Sara Leverette; Scott
Cranswick; Scott Griffith; Shannon Donnelly; Sharmaine Copeland;Sharon Yarawsky;
Shellenbaum, Diane P(DNR); Slemons,Jonne D (DNR); Smith, Kyle S (DNR); Sondra
Stewman; Stephanie Klemmer; Moothart, Steve R(DNR); Steven R. Rossberg; Suzanne
Gibson; sheffield @aoga.org;Tania Ramos;Ted Kramer; Davidson,Temple (DNR);Teresa
Imm;Thor Cutler;Tim Mayers;Tina Grovier;Todd Durkee;Tony Hopfinger;trmjrl;Vicki
Irwin;Walter Featherly;yjrosen @ak.net;Aaron Gluzman;Aaron Sorrell; Bruce Williams;
Bruno,Jeff J (DNR);Casey Sullivan; David Lenig; Donna Vukich; Eric Lidji; Erik Opstad;
Franger,James M (DNR);Gary Orr; Smith, Graham 0 (PCO);Greg Mattson; Heusser,
Heather A(DNR);James Rodgers;Jason Bergerson;Jennifer Starck;
jill.a.mcleod @conocophillips.com;Jim Magill;Joe Longo;Jolie Pollet; King, Kathleen J
(DNR); Laney Vasquez; Lois Epstein; Louisiana Cutler; Marc Kuck;Steele, Marie C (DNR);
Matt Gill; Ostrovsky, Larry(DNR sponsored); Bettis, Patricia K(DOA); Perrin, Don J (DNR);
Peter Contreras; Pexton, Scott R(DNR); Pollard, Susan R(LAW); Richard Garrard; Ryan
Daniel; Sandra Lemke;Talib Syed;Wayne Wooster;Woolf,Wendy C (DNR);William
Hutto;William Van Dyke; Ballantine,Tab A(LAW); Bender, Makana K(DOA); Bettis,
Patricia K(DOA); Brooks, Phoebe L(DOA); Colombie,Jody J (DOA);Crisp,John H (DOA);
Davies, Stephen F (DOA); Ferguson,Victoria L(DOA); Fisher, Samantha J (DOA); Foerster,
Catherine P (DOA); Grimaldi, Louis R(DOA); Hunt,Jennifer L(DOA);Johnson, Elaine M
(DOA); Laasch, Linda K(DOA); Mumm,Joseph (DOA sponsored); Noble, Robert C(DOA);
Norman,John K(DOA); Okland, Howard D (DOA); Paladijczuk,Tracie L(DOA); Pasqual,
Maria (DOA); Regg,James B (DOA); Roby, David S (DOA); Scheve, Charles M (DOA);
Schwartz, Guy L(DOA); Seamount, Dan T (DOA); Singh,Angela K(DOA);Turkington,Jeff
A (DOA);Wallace, Chris D (DOA)
Subject: AIO 3A.002,AIO 26B.002,AIO 25A.016,AIO 24B.004,AIO 22E.002 (Prudhoe Bay Unit)
Attachments: aio3a-002.pdf;aio26b-002.pdf;aio25a-016.pdf;aio24b-004.pdf;aio22e-002.pdf
1
•
Samantha Fisher
Executive Secretary II
Alaska Oil and Gas Conservation Commission
333 West 7th Avenue, Suite 100
Anchorage, AK 99501
(907) 793-1223 (phone)
(907) 276-7542 (fax)
2
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Alison Cooke
UIC Compliance Advisor
BP Exploration(Alaska)Inc.
Post Office Box 196612
Anchorage,AK 99519-6612
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David McCaleb
Penny Vadla IHS Energy Group George Vaught,Jr.
399 W.Riverview Ave. GEPS Post Office Box 13557
Soldotna,AK 99669-7714 5333 Westheimer,Ste.100 Denver,CO 80201-3557
Houston,TX 77056
Richard Neahring Mark Wedman
Jerry Hodgden NRG Associates
Hodgden Oil Company Halliburton
40818`h St. President 6900 Arctic Blvd.
Golden,CO 80401-2433 Post Office Box 1655 Anchorage,AK 99502
Colorado Springs,CO 80901
Bernie Karl CIRI Baker Oil Tools
K&K Recycling Inc. land Department 795 E.94`h Ct.
Post Office Box 58055 Post Office Box 93330 Anchorage,AK 99515-4295
Fairbanks,AK 99711 Anchorage,AK 99503
North Slope Borough Richard Wagner Gordon Severson
Planning Department Post Office Box 60868 3201 Westmar Cir.
Post Office Box 69 Fairbanks,AK 99706 Anchorage,AK 99508-4336
Barrow,AK 99723
Jack Hakkila Darwin Waldsmith James Gibbs
Post Office Box 190083 Post Office Box 39309 Post Office Box 1597
Anchorage,AK 99519 Ninilchik,AK 99639 Soldotna,AK 99669
( a11.sz1/-czc3
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-46
I p
BP Exploration(Alaska)Inc.
900 E.Benson Blvd
P 0.Box 196612
Anchorage,AK 99519-6612
USA
Main 907 561 5111
Fax 907 564 5020
June 6, 2013
Alaska Oil and Gas Conservation Commission
333 W. 7th Avenue
Suite 100
Anchorage, AK 99501
Attention Mr. David Roby
li
Dear Mr. Roby:
Thank you for your request for clarification regarding the RCRA status of the
radioactive tracers to be used in the upcoming study at GC2. The GC2 Capacity
Study involves the injection of low level radioactive tracers upstream of the slug
catchers in GC2 to study the separation efficiency of various vessels. Once injected
into the vessels, the tracer will be commingled with production fluids at the
gathering center, follow the normal separation process, and be routed to the Class I I
well system for either enhanced oil recovery or injection. The project is scheduled-
to start June 20, 2013. Here are responses to your questions:
1. Evidence and legal authority in support of BP's assertion that
radioactive tracer wastes are not regulated under RCRA;
RCRA regulates hazardous solid wastes. Therefore, the threshold question when
determining the RCRA status of a material is whether it is a "solid waste." In order
to be a solid waste, a material must be "discarded." RCRA section 1004(27).1
Therefore, products being used for their intended purposes are not wastes because
they are not being discarded. In this case, the facility will be injecting low level
radioactive tracers upstream of the slug catchers in GC2 to study the separation
efficiency of various vessels. The purpose of this injection is not to discard or
dispose of the tracers, but to utilize them for their intended, useful purpose
(conducting the separation efficiency study). RCRA does not regulate this activity
because the purpose of the injection is not to discard the tracers.
1 42 U.S.C. § 6903(27).
•
Once used, the radioactive tracers are not regulated under RCRA because they are
specifically excluded from the definition of "solid waste" under 40 CFR 261.4(a)(4).
Radioactive tracers are instead regulated under the Atomic Energy Act. As you
note in your letter, radioactive tracer waste is not E&P exempt because such waste
is not uniquely associated with oil and gas; many other industries use radioactive
tracers.
2. Evidence to support a determination whether radioactive tracer waste is
hazardous or whether it exhibits hazardous characteristics under 40 CFR
Part 261
As noted above, radioactive waste is excluded from the definition of "solid
waste" under RCRA. Therefore, such waste is not a "hazardous solid
waste" regulated under the statute.
3. Evidence and legal authority to support a claim that radioactive tracer
waste may otherwise fall under a RCRA exemption.
Disposal of the mixture comprised of produced water and the radioactive tracers is
covered under the RCRA Mixture Rule, which allows non-hazardous, non- E&P
exempt waste (e.g., used radioactive tracers) to be commingled with E&P exempt
waste (produced water), with the resulting mixture retaining the E&P
exemption.(See page 17 of the EPA RCRA E&P Guidance Document you cited in
your May 31, 2013 email.) Note that this result is consistent with how produced
water exposed to radioactive tracers injected during well logging is regulated as E&P
exempt waste.
We hope that this explanation satisfies your request for clarification. As noted
above, the study is scheduled to begin June 20, 2013. Please contact as soon as
possible if you have additional questions or want to discuss further at 907-564-5501
or contact Alison Cooke at 564-4838.
eik";
Janet D Platt
Director, Regulatory Compliance and Environment, Alaska
Cc: Alison Cooke, BP
Cc Cathy Foerster, AOGCC
Cc: Jim Regg, AOGCC
•
Colombie, Jody J (DOA)
From: Roby, David S (DOA)
Sent: Friday, May 31, 2013 12:45 PM
To: Cooke, Alison D
Cc: Regg, James B (DOA); Wallace, Chris D (DOA); Lau, Glenn L; Crandall, Krissell
Subject: RE: BPXA Request for Administrative Approval
Alison,
BP's assertion that"Radioactive tracers are not regulated under the Resource Conservation and Recovery Act (RCRA)
so the fluids would not be designated hazardous or non-hazardous.Therefore,the diluted radioactive tracer which BP
proposes to use at GC2 would not be categorized as hazardous or non-hazardous under RCRA ..." cannot be reconciled
with a RCRA Guidance document which lists "radioactive tracer wastes" as a Non-Exempt Waste. See,
http://www.epa.gov/osw/nonhaz/industrial/special/oil/oil-gas.pdf at page 13 of 40. As a result, the AOGCC requests BP
provide the following:
1. Evidence and legal authority in support of BP's assertion that radioactive tracer wastes are not regulated under
RCRA;
2. Evidence to support a determination whether radioactive tracer waste is hazardous or whether it exhibits
hazardous characteristics under 40 CFR Part 261.
3. Evidence and legal authority to support a claim that radioactive tracer waste may otherwise fall under a RCRA
exemption.
Regards,
Dave Roby
(907) 793-1232
From: Cooke, Alison D [mailto:Alison.Cooke @bp.com]
Sent: Tuesday, May 14, 2013 11:38 AM
To: Foerster, Catherine P (DOA)
Cc: Roby, David S (DOA); Regg, James B (DOA); Wallace, Chris D (DOA); Lau, Glenn L; Crandall, Krissell
Subject: BPXA Request for Administrative Approval
Ms. Foerster:
Attached is a request from BPXA for administrative approval to inject dilute volumes of radioactive tracer that
has been used for the purposes of studying vessel inefficiencies in Gathering Center 2 in the Prudhoe Bay Field
in either FOR wells or Class II disposal wells. A hard copy of the letter is also being sent to you by certified
mail.
BPXA had a teleconference with your staff on April 25,2013 to discuss this project and our request. We would
appreciate the Commission's timely review of this request. If possible we would appreciate a response by
May 31.
<<BPXA to AOGCC GC2 Tracer.pdf>>
If you or your staff have any questions please contact me at 440-8167 or alison.cooke @bp.com.
1
•
P'Bards,
Alison
Alison D. Cooke
907-564-4838 tel.
907-440-8167 cell
907-564-5020 fax.
cookeadna,bp.com
2
r
4
b p '-
MAY 1 5 'tow
AOOCC
BP Exploration(Alaska)Inc.
P.0.Box 196612
CERTIFIED MAIL: 7011 2970 0001 9241 2635 900 E.Benson Boulevard
Anchorage,AK 99519-6612
USA
May 14, 2013
Ms. Cathy Foerster, Chair
Alaska Oil and Gas Conservation Commission
333 West 7th Avenue
Anchorage, Alaska 99501
Subject: Radioactive Tracer Injection: PBU 2013 GC2 Optimization
Administrative Approval Request:
Prudhoe Oil Pool, Area Injection Order 3A
Aurora Oil Pool, Area Injection Order 22E
Borealis Oil Pool, Area Injection Order 24B
Polaris Oil Pool, Area Injection Order 25A
Orion Oil Pool, Area Injection Order 26B
Dear Ms. Foerster:
BP Exploration (Alaska) Inc. (BPXA) requests approval under Area Injection Order
(AIO) 3A Rule 1, AIO 22E Rule 10, AIO 24B Rule 2, AIO 25A Rule 3, and AIO 26B
Rule 3 to introduce radioactive tracer into the Gathering Center 2 (GC2)
production facility for the purpose of oil production, plant operations, and
plant/piping integrity. Radioactive tracers are not regulated under the Resource
Conservation and Recovery Act (RCRA) so the fluids would not be designated
hazardous or non-hazardous. Therefore, the diluted radioactive tracer which BP
proposes to use at GC2 would not be categorized as hazardous or non-hazardous
under RCRA.
The tracer will comingle with produced fluids and be diluted prior to enhanced oil
recovery (EOR) reservoir injection. Mixing the radioactive tracer with produced
fluids meets the criteria of fluids suitable for Class II disposal well injection. The
tracer has been deemed to have no negative impact on the reservoir. Alyeska
Pipeline Service Company has been informed of the test and noted no concerns
with handling the diluted tracer.
In order to keep standardized and consistent language referencing the fluids
authorized for injection for enhanced recovery and pressure maintenance for all
Prudhoe Bay Field (PBF) AlOs, BPXA also requests that radioactive tracer fluids
MINIM
1110
Ms. Cathy Foerster
May 14, 2013
Page 2
be specifically included as fluids introduced to production facilities for the
purpose of oil production, plant operations, and plant/piping integrity in A1O 4E
Rule 1, AIO 14A Rule 1, AIO 20 Rule 1, and A1O 31 Rule 3.
GC2 Optimization
The West End Developments program consists of several projects to
debottleneck base production and increase future GC2 production. As part of the
program, the optimization of GC2 and its separation capabilities will be reviewed.
The current separation and sand handling capabilities will be evaluated in the
study and changes will likely be recommended to process future production
streams.
Capacity Study
The study will determine current vessel inefficiencies and propose upgrades to
the facility. Radioactive tracer is needed to calculate the residence time of the oil
and water phases in the slugcatchers and the water residence time in the skim
tanks. For this determination, a total of 300 mL of radioactive tracer (lanthanum
nitrate hexahydrate) will be injected upstream of the GC2 slugcatchers and skim
tanks to trace the water phase. It is expected that minor amounts of the 200 mL
bromoanthracene oil tracer will be carried into the produced water system.
The half-lives of each tracer used in this study will be less than 2 days. Reservoir
tracers typically used include cobalt-57, cobalt 60, carbon-14, or tritium which
have half-lives of 270 days, 5.26 years, 5730 years, and 12.32 years,
respectively. The shorter half-life in conjunction with the smaller injection sizes
proposed exposes the reservoir to minimal radioactivity for a short duration (see
table and chart Appendix 1).
Alternatives to radioactive tracer have been considered. The main benefit of a
tracer is the ability to detect concentration as a function of time, which
correlates to vessel residence time and can characterize inefficiencies of
internals. A non-radioactive tracer would require frequent sampling, and there is
a possibility the tracer would pass through the system between samples,
yielding no data. The ability to characterize vessel inefficiencies would be
compromised with a non-radioactive tracer.
Correct assessment of the separation capabilities of GC2 is necessary to
determine appropriate upgrades to the facility for increased separation capacity.
The most effective way to evaluate the separation capability of the facility is to
use a radioactive tracer. To summarize, BPXA requests Commission approval to
Ms. Cathy Foerster
May 14, 2013
Page 3
inject dilute volumes of radioactive tracer (that have been used in production
facilities for diagnostic purposes) in all PBF AlOs and in Class II disposal wells.
Should you have any questions, or require additional information, please contact
me at 564-4838 or alison.cooke @bp.com.
Sincerely,
Alison Cooke
UIC Compliance Advisor
Attachment: Appendix 1 —Tracerco Information
cc: James Regg, AOGCC
Dave Roby, AOGCC
Chris Wallace, AOGCC
• •
Ms. Cathy Foerster
May 14, 2013
Page 5
Appendix 1 — Tracerco Information
Tracerco Tracers Reservoir Tracers
B-82 La-140 Co-57 Co-60 C-14 Tritium
Injection Size (mCi) 120* 160* 200** 500** 2000** 10000**
Half Life 35 hrs 40 hrs 270 days 5.26 yrs 5730 yrs 12.32 yrs
* Proposed Amount to be Used for Study
** Typical Amounts Used for Reservoir Studies
The following decay chart assumes starting activities of 200 mCi for comparison.
Actual activities are shown in the chart above.
Decay Chart -Tracerco Tracers vs. Other Reservoir Tracers
250
200
150 -- —
- -Br-82(Tracerco)
E -�-La-140(Tracerco)
-,1r-C-14
e� cif-•H-3
100 -?k-Co-60
-11-Co-57
50 ---- -- -- _
0 Ffiii-# 1111 • 1111• ■i ■ • • fe
0 5 10 15 20 25 30 35
+II Time(Days)
3
•
b •
0 p
BP Exploration (Alaska) Inc.
B 0. Box 196612
900 E. Benson Boulevard
Anchorage, AK 99519 -6612
USA
CERTIFIED MAIL # 7011 2970 0003 5821 9955 E
CEI VEt7
April 30, 2012 MAY 0 2 2012
Kathy Foerster, Commissioner G
Alaska Oil & Gas Conservation Commission
333 West 7th Avenue, Suite 100
Anchorage, AK 99501
Re: Prudhoe Bay Field Area Injection Orders, Standardization of Authorized Fluids for EOR and
Pressure Maintenance
Dear Ms. Foerster,
This letter is to request a change to Prudhoe Bay Field (PBF) Area Injection Orders (AIO) to
standardize the language in the rule referencing the fluids authorized for injection for enhanced
recovery and pressure maintenance. BP Exploration (Alaska) Inc. (BPXA) is requesting this
change in order to address the complexity of field operations with multiple pools serviced by
common facilities and potential confusion that results from the differing language in the various
orders. This proposed change is intended to clarify and document the fluids that are authorized
for enhanced oil recovery (EOR) and pressure maintenance injection within the PBF and
provide greater compliance assurance for our field operations.
A review of AIOs for pools in the PBF indicates that some contain very general language and
some are very specific in defining which fluids are authorized for injection. The language
defining fluids that may be injected has changed over time in successive versions of some of
the orders. For instance, AIO 4 language has changed from "non- hazardous fluids ", to "Class II
fluids" to "authorized fluids ". In addition, some fluids have received specific authorization via
administrative approvals. The diversity of language and changes over time has resulted in
confusion over which fluids are actually authorized for injection. The enclosed list (Attachment
A) shows the various PBF pools, AIOs, and a summary of the current rule and /or administrative
approvals that authorize fluids that may be injected for purposes of pressure maintenance and
enhanced recovery. Also included is a summary of findings regarding the compatibility of fluids
authorized for injection.
As discussed with your staff, BPXA proposes to standardize the list of authorized fluids for the
various pools within the PBF. Attachment B is proposed language for this change. In some
pools, additional clarification may be required to capture specific conditions or restrictions
contained in current orders. Attachment C is a list of historical fluids injected for EOR and
pressure maintenance
•
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 2
Should you have any questions, or require additional information, please contact me at 564-
4838.
Sincerely,
ate• arIQJL-
Alison Cooke
UIC Compliance Advisor
Attachments
cc: Jim Regg AOGCC
Dave Roby AOGCC
• •
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 3
Attachment A
Prudhoe Bay Field: fluids specifically authorized for enhanced recovery and pressure maintenance in
Area Injection Orders
AIO Rule Pool Fluids Authorized Compatibility with Formation
3 1 Prudhoe non - hazardous fluids; Area Injection Order Application for PBU WOA
Bay AIO 3.03 rinsate (minus FOR and Fluid Disposal Wells: Section I: 1.
(West) solids) from cleaning aerial Water: Beaufort Sea water and Produced
gas coolers; Sadlerochit water; Compatibility: Water
AIO 3.018 filtered and sensitivity tests on core samples showed no
chemically treated lake significant problems with formation plugging or
water used for hydrotesting clay swelling over the anticipated operating range
replacement pipeline of salinities for produced and Beaufort Sea water;
segments; 2. Miscible Gas from CGF; Compatibility: Full
AIO 3.028 mixtures of glycol compatibility - reinjected into producing zone; 3.
and water Produced Gas from Sadlerochit and Sag River
reservoirs; Compatibility: Full compatibility -
reinjected into producing zone
4E 1 Prudhoe authorized fluids; AIO4D, Finding 12: The main fluid source will be
Bay (East) AIO 4C.02 rinsate (minus source water from the Seawater Treatment Plant.
Put River solids) from cleaning aerial No significant compatibility issues are anticipated
Lisburne gas coolers; between the formation and injected fluid.
Pt. AIO 4E.022 filtered and Analyses of core samples from Put River
McIntyre chemically treated lake Formation sandstone in Prudhoe Bay
West water used for hydrotesting Unit Well 2 -14 demonstrate similar clay mineral
Beach replacement pipeline types and proportions as those in Kuparuk River
Stump segments for Greater Point Formation reservoirs in adjacent North Slope
Island McIntyre; fields. Each of the analog fields has a successful
AIO 4E.023 filtered and history of waterflooding and based on these
chemically treated lake comparisons the
water used for hydrotesting Put River Formation is not anticipated to have
replacement pipeline compatibility issues related to seawater injection.
segments for Prudhoe Bay AIO4C, Finding 20: Seawater is currently injected
Unit fields; in the Pt. McIntyre waterflood. It is possible that
AIO 4E.034 mixtures of produced water will be used later in the project.
glycol and water Both water sources have previously been
approved in Area Injection Order No. 4B
Finding 34: Laboratory testing, core analyses and
geochemical modeling indicate no significant
problems are likely due to clay swelling or in -situ
fluid compatibility problems between WBOP and
Tertiary formation waters.
Finding 35: WBOP waterflood source water from
the Sagavanirktok Formation is expected to have
excess barium ion which could precipitate barium
sulfate scale if mixed with PMOP produced water.
WBOP produced water will be inhibited upstream
of the commingling point with PMOP fluids to
prevent scale precipitation.
• •
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 4
PBU EOA Area Injection Order Application,
Section I Enhanced Recovery type of fluid: A.
source water - treated seawater; Compatibility:
no significant problems with formation plugging or
clay swelling due to fluid incompatibilities are
anticipated; B. produced water from Flow
Stations and LPC; Compatibility: Fluid is returned
to the reservoir from which it was produced, no
compatibility problems anticipated; C. Natural
Gas and NGL; Compatibility: Fluid is returned to
the reservoir from which it was produced, no
compatibility problems anticipated; D. Miscibile
Injectant; Compatibility: Fluid is returned to the
reservoir from which it was produced, no
compatibility problems anticipated.
14A 1 Niakuk produced water from LPC, AIO14A, Finding 7: Injection will utilize either
Beaufort seawater, produced or source water. The wells are currently
trace amounts of scale configured to allow 60,000 Barrels of Water per
inhibitor, corrosion inhibitor, Day ( "BWPD ") total, with a maximum injection of
emulsion breakers, other up to 70,000 BWPD. The produced water will be
products used in production a mix of Pt. McIntyre, West Beach, North
process, stimulation fluids Prudhoe Bay, Lisburne and Niakuk produced
water separated through the Lisburne Production
Center ("LPC"), with the majority coming from Pt.
McIntyre. Seawater has been injected as well.
SEM, XRD and ERD analyses conducted on
Niakuk core indicate very low clay content in
reservoir intervals. As a result no significant
problems with formation plugging or clay swelling
due to fluid incompatibilities is expected.
Produced water may contain trace amounts of
scale inhibitor, corrosion inhibitor, emulsion
breakers, and other products used in the
production process.
20 1 Midnight fluids appropriate for A1020 Finding 21: Geochemical model results
Sun enhanced recovery; indicate that a combined Tertiary water and
AIO 20.001 filtered and connate water is likely to form calcium carbonate
chemically treated lake and barium sulfate scale. Similar scale
water used for hydrotesting precipitation is anticipated for produced water.
replacement pipeline Scale will be controlled with commonly available
segments inhibitors.
• •
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 5
22E 10 Aurora produced water, Prince A1022B, Finding 9: The compositions of injection
Creek source water *, water and AOP connate water were provided in
enriched hydrocarbon gas *, Exhibit IV -4 of the original AIO application. Water
immiscible hydrocarbon analysis from the nearby Milne Point Prince
gas *, tracer survey fluid, Creek Formation was provided in the April 28,
non - hazardous filtered 2003 application for rehearing
water from pads and cellars
*conditions for authorization
are included in the current
order
24B 2 Borealis produced water, non- A1024A, Finding 9: As previously approved by
hazardous filtered water the Commission, produced water from GC -2 is
from pads and cellars, used as the primary water source for Borealis
tracer survey fluid, treated injection. Injection performance, core, log and
seawater, enriched pressure - buildup analyses indicate no significant
hydrocarbon gas *, Prince problems with clay swelling or compatibility with
Creek source water; in -situ fluids. BPXA analysis of cores from the
AIO 24A.001 filtered and BOP wells indicates relatively low clay content.
chemically treated lake Petrographic analysis indicates that clay volumes
water used for hydrotesting in the better quality sand sections ( >20 md) are in
replacement pipeline the range of 3 - 6 %. Clay volumes increase to
segments approximately 6 - 12% in rock with permeabilities
in the range of 10 - 20 md. Below 10 md, clay
volumes increase to a range of 12 - 20 %. Most of
the identified clay is present as intergranular
matrix, having been intermixed with the sand
through burrowing. The overall clay composition
is a mixture of roughly equal amounts of kaolinite,
illite and mixed layer illite /smectite. No chlorite
was reported during petrographic analysis. The
presence of iron - bearing minerals suggests that
*conditions for authorization the use of strong acids should be avoided in
are included in the current breakdown treatments, spacers, etc. Water from
order the seawater treatment plant has been
successfully used for injection within the Kuparuk
of the Pt. McIntyre Oil Pool. Geochemical
modeling indicates that a combination of GC -2
produced water and connate water is likely to
form calcium carbonate and barium sulfate scale
in the production wells and downstream
production equipment. Scale precipitation will be
controlled using scale inhibition methods similar
to those used at Kuparuk River Unit and Milne
Point Unit. Miscible gas is a hydrocarbon with
similar composition to reservoir fluids in the BOP
therefore no compatibility issues are anticipated
with the formation or confining zones. The
composition of injection water from the Prince
Creek aquifer is expected to fall within the range
of Well W-400 and MPF -02 produced water
• •
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 6
compositions, less than 10,000 -ppm total
dissolved solids. Milne Point Unit F -Pad Prince
Creek source water has been injected since 1996
into the Milne Point Kuparuk Reservoir,
lithologically similar to the BOP, with no apparent
formation damage. A single well chemical tracer
test in BOP well L -122 conducted using 640
barrels of Prince Creek Source water did not
detect any formation damage.
25A 3 Polaris produced water, tracer AIO 25A, Finding 11: The enriched gas proposed
survey fluid, enriched for injection is a hydrocarbon with similar
hydrocarbon gas, treated composition to reservoir fluids in the Polaris Oil
seawater, non - hazardous Pool and therefore no compatibility issues are
filtered water from pads and anticipated.
cellars, enriched AIO 25, Finding 12: BPXA provided laboratory
hydrocarbon gas; analysis of the injection and produced waters. No
AIO 25A.001 filtered and significant compatibility problems are evident
chemically treated lake from these analyses. Disposal of PBU produced
water used for hydrotesting water within the Ugnu sands has successfully
replacement pipeline occurred in other parts of the field.
segments
26B 3 Orion enriched gas, produced AIO 26A, Finding 11: The enriched gas proposed
water, tracer survey fluid, for injection is a hydrocarbon with similar
treated seawater, Prince composition to reservoir fluids in the Orion Oil
Creek source water, non- Pool and therefore no compatibility issues are
hazardous filtered water anticipated.
from pads and cellars, non- AIO 26, Finding 11: The composition of produced
hazardous filtered lake water will be a mixture of connate water and
water employed for injection water, and will change over time
hydrotesting pipeline depending on the rate and composition of
segments injection water. Based on analyses of Polaris
water samples, no significant compatibility
problems are expected between connate water
and injection water.
31 3 Raven produced water, tracer AIO 31, Finding 14: Water compatibility problems
survey fluid, stimulation are not expected because of the successful
fluids, source water from history of both sea water and produced water
STP, and non - hazardous injection into the Prudhoe Bay Reservoir. No clay
water collected from well swelling problems have been seen in the Ivishak
house cellars and standing Formation in the Ivishak Participating Area of the
ponds. PBU (IPA) with either source water injection or
produced water injection. When present, scaling
in the Ivishak Formation in the IPA has been
limited to calcium carbonate deposition, which
has been eliminated with acid treatments and
controlled with the use of inhibitors. Minimal
problems with formation plugging or clay swelling
due to fluid incompatibilities are anticipated.
•
• •
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 7
Attachment B
Proposed Standardized List of Fluids Authorized for Injection in Prudhoe Bay Field Pools
Fluids authorized for injection include:
• Produced water and gas;
• Enriched hydrocarbon gas
• Non - Hazardous Water and water based fluids — (includes seawater, source water,
freshwater, domestic wastewater, equipment washwater, sump fluids, hydrotest fluids,
firewater, and water with trace chemicals, and other water based fluids with a pH
greater than or equal to 2 or less than or equal to 12.5 and flashpoint greater than 140
degrees F)
• Fluids introduced to production facilities for the purpose of oil production, plant
operations, plant/piping integrity or well maintenance that become entrained in the
produced water stream after oil, gas and water separation in the facility. Includes but
not limited to:
• Freeze protection fluids;
• Fluids in mixtures of oil sent for hydrocarbon recycle
• Corrosion /Scale inhibitor fluids
• Anti - foams /emulsion breakers
• Glycols
• Non - hazardous glycols and glycol mixtures
• Fluids that are used for their intended purpose within the oil production process.
Includes:
• Scavengers;
• Biocides
• Fluids to monitor or enhance reservoir performance. Includes:
• Tracer survey fluids;
• Well stimulation fluids
• Reservoir profile modification fluids
• •
Alaska Oil and Gas Conservation Commission
April 30, 2012
Page 8
Attachment C
Historical Fluids Injected for FOR and Pressure Maintenance: these fluids were authorized and
injected under the general descriptions of authorized fluids:
AIO 4, 4A, and 4B: Class II fluids; AIO 4C: authorized fluids; AIO 3: non - hazardous fluids
Treated Seawater supplied from PBU STP. Contains small amounts of chemicals: coagulant,
anti -foam, scale inhibitor, biocide, oxygen scavenger and other process chemicals.
Produced water from PB field producing formations. Contains small amounts of entrained
produced oil and gas, and chemicals: scale inhibitor, corrosion inhibitor, emulsion breaker, and
other production process chemicals.
Natural Gas (including natural gas liquids) from PB field producing formations.
Miscible Injectant from PBU Central Gas Facility.
Reserve Pit water from pit dewatering operations. Consists of precipitation and small amounts
of drilling wastes and chemicals (oxygen scavenger and biocide).
Source water from shallow formations. Contains small amount of production chemicals (scale
inhibitor).
N
STATE OF ALASKA NOTICE TO PUBLISHER ADVERTISING ORDER NO.
ADVERTISING INVOI •ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N ., RTIFIED A O_2114032
AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF A
ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE.
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DATES ADVERTISEMENT REQUIRED:
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g ITS ENTIRETY ON THE DATES SHOWN.
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(PBU S - 09 Docket # AIO- 11 -05)
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REQUISITIONED Y: r / DIVISION APPROVAL:
___
, c u .0 0 , At I
02 - 902 (Rev. 3/94) Publisher /Original Copies: Department Fiscal, Department, Receiving AO.FRM
• •
Notice of Public Hearing
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re: Docket # AIO- 11 -05. BP Exploration (Alaska) Inc., by a letter dated March 30,
2011 and received April 6, 2011, requests the Alaska Oil and Gas Conservation
Commission (Commission) issue an order authorizing the commingling of water
alternating gas injection in the same wellbore in accordance with the requirements
of 20 AAC 25.215(c) to allow the Prudhoe Bay Unit S -09 Well to commingle
injection into the Aurora and Prudhoe Oil Pools.
The Commission has tentatively scheduled a public hearing on this application for May 26, 2011
at 9:00 a.m. at the Alaska Oil and Gas Conservation Commission, at 333 West 7 Avenue, Suite
100, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a
written request must be filed by 4:30 p.m. on May 2, 2011.
If a request for a hearing is not timely filed, the Commission may consider the issuance of an
order without a hearing. To learn if the Commission will hold the hearing, call 793 -1221 after
May 3, 2011.
In addition, written comments regarding this application may be submitted to the Alaska Oil and
Gas Conservation Commission, at 333 West 7 Avenue, Suite 100, Anchorage, Alaska 99501.
Comments must be received no later than 4:30 p.m. on May 20, 2011, except that, if a hearing is
held, comments must be received no later than the conclusion of the hearing.
If, because of a disability, special accommodations be needed to comment or attend the
hearing, contact the Commission's Special Assistan , od Colombie, at 793 -1221, no later than
May 20, 2011.
o
C . issioner
STATE OF ALASKA • NOTICE TO PUBLISHER • ADVERTISING ORDER NO.
ADVERTISING INVOICE
AFFIDAVIT MUST OF BE IN TRIPLICATE PUBLICATION (PART SHOWING 2 OF THIS ADVERTISING FORM) WITH ORDER ATTACHED NO., CERTIFIED COPY OF /1 A O_2114032
ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE.
SEE BOTTOM FOR INVOICE ADDRESS
F AOGCC AGENCY CONTACT DATE OF A.O.
R 333 W 7 Avenue. Ste 100 Jody Colorable 4/8/11
° Anchorage, AK 99501 PHONE
M (9071 793 -1221
DATES ADVERTISEMENT REQUIRED:
T Alaska Journal of Commerce
° 4/17/11
301 Arctic Slope Ave., Suite 350
Anchorage, AK 9951 S THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN
g ITS ENTIRETY ON THE DATES SHOWN.
SPECIAL INSTRUCTIONS:
AFFIDAVIT OF PUBLICATION
United states of America REMINDER
State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE
THE ADVERTISING ORDER NUMBER.
division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION
MUST BE SUBMITTED WITH THE INVOICE.
Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE.
who, being first duly sworn, according to law, says that
he /she is the of
Published at in said division and
state of and that the advertisement, of which the annexed
is a true copy, was published in said publication on the day of
19 and thereafter for consecutive days, the last
publication appearing on the day of . 19 , and that
the rate charged thereon is not in excess of the rate charged private
individuals.
Subscribed and sworn to before me
This _ day of 19_,
Notary public for state of
My commission expires
02 -901 (Rev. 3/94) AO.FRM
Page 2 PUBLISH
• •
Mary Jones David McCaleb
XTO Energy, Inc. IHS Energy Group George Vaught, Jr.
Cartography GEPS P.O. Box 13557
810 Houston Street, Ste 200 5333 Westheimer, Suite 100 Denver, CO 80201 -3557
Ft. Worth, TX 76102 -6298 Houston, TX 77056
Jerry Hodgden Richard Neahring Mark Wedman
Hodgden Oil Company NRG Associates Halliburton
President
408 18 Street 6900 Arctic Blvd.
Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502
Colorado Springs, CO 80901
Bernie Karl CIRI Baker Oil Tools
K &K Recycling Inc. Land Department to
P.O. Box 58055 P.O. Box 93330 795 E. 94 C.
Anchorage, AK 99515-4295
Fairbanks, AK 99711 Anchorage, AK 99503
North Slope Borough Richard Wagner Gordon Severson
Planning Department P.O. Box 60868 3201 Westmar Circle 1
P.O. Box 69 Fairbanks, AK 99706 Anchorage, AK 99508 -4336
Barrow, AK 99723
Jack Hakkila Darwin Waldsmith James Gibbs
P.O. Box 190083 P.O. Box 39309 P.O. Box 1597
Anchorage, AK 99519 Ninilchick, AK 99639 Soldotna, AK 99669
Kenai National Wildlife Refuge Penny Vadla Cliff Burglin
Refuge Manager 399 West Riverview Avenue 319 Charles Street
P.O. Box 2139 Soldotna, AK 99669 -7714 Fairbanks, AK 99701
Soldotna, AK 99669 -2139
-\ \
\ .‘ \ \\
• •
Fisher, Samantha J (DOA)
From: Fisher, Samantha J (DOA)
Sent: Friday, April 08, 2011 9:23 AM
To: '(foms2 @mtaonline. net)'; '( michael .j.nelson @conocophillips.com)';
'(Von.L .Hutchins @conocophillips.com)'; 'AKDCWeIIIntegrityCoordinator; 'Alan Dennis';
'alaska @petrocalc.com'; 'Anna Raff; 'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer; 'Bill
Penrose'; 'Bill Walker; 'Bowen Roberts'; 'Brady, Jerry L'; 'Brandow, Cande (ASRC Energy
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Lawrence'; 'dapa'; 'Daryl J. Kleppin'; 'Dave Matthews'; 'David Boelens'; 'David House'; 'David
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Schwartz, Guy L (DOA) (guy.schwartz @alaska.gov); Seamount, Dan T (DOA)
(dan.seamount @alaska.gov); Shartzer, Christine R (DOA)
Subject: Notice of Public Hearing PBU
Attachments: PBU S -09 Commingled Injection.pdf
Sami,cwuthw Rishex
A Lcvdca O i L cuvLdi G cam- Co vts o-w C ,
(907)793 -1223
(907)276 -7542 (fa/Y0
1
r
BP Exploration (Alaska), Inc.
•
• 0
900 East Benson Boulevard
Post Office Box 196612 bp
Anchorage, Alaska 99519 - 6612 y
Telephone (907) 564 581 RECEIVED
E 111E D
APR 0 6 2011
March 30, 2011 Alaska Oil & Gas Cons,
Alaska Oil and Gas Conservation Commission Anchorage
333 West 7 Avenue, Suite 100
Anchorage, AK 99501
Application for Down -hole Commingling of WAG Injection to Aurora and
Prudhoe Pools
In its capacity as Operator of the Aurora Oil Pool (AOP) and the Prudhoe Oil Pool (POP), BP
Exploration (Alaska) Inc. ("BP") hereby requests approval to commingle WAG injection to
the AOP and POP in the same welibore.
Because commingling of injection to the AOP and POP will not cause waste, but rather
should allow for recovery of a greater quantity of oil, and such production can be properly
allocated, BP requests that the Commission issue an order authorizing the commingling of
WAG injection to the AOP and the POP within the same well -bore. Plans are to commence
commingling of WAG injection from AOP and POP in Well S -09 by the 3Q 2011.
The following information is provided to support this application. Please call Mackie
Derrick 564 -5891 or Kirsten Schultz 564 -5105 if you have any questions.
Sincerely,
p l oc ka U . - I
r e - r Emeka Emembolu
Resource Base Management Manager
CC: Gerry Smith (ExxonMobil)
Mark Menghini (CPAI)
• Aurora Prudhoe Commingling • 3/30/2011
Introduction
Commingling of injection within the same well -bore from two pools is permitted under 20
AAC 25.215(amended) if the Commission, after request, notice and opportunity for public
hearing in conformance with 20 AAC 25.540, the commision,
"(1) finds that proposed injection activity will not result in waste or damage to a pool,
and the injection volumes can be proberly allocated; and
(2) issues an order providing for injection into wellbores completed to allow for
simultaneous injection into two or more pools."
Waste Will Not Occur
1. Injection Considerations
Well S -09 penetrates the AOP in an area with a single producer, S -118, that is shut in
because of no reservoir support; and POP in an area where production well rates are low or
shut in for high water cut. Although there is currently no AOP injection from the S -09
wellbore, the expected rate and reserves do not justify drilling a separate standalone well. By
commingling injection to the two pools within the same well -bore, the injection rate and
WAG capability can result in AOP production to returning, increased FOR benefits for both
AOP and POP and allow for recovery of a greater quantity of oil.
2. Hydraulic Impacts on Production
Well S -09 was drilled in 1982 as an injector from the POP, with a fracture stimulation. In
1988 the tubing was changed out. Injection rates from Well S -09 averages 1500 bwpd. This
is considered a normal rate for the existing 5 -1/2" tubing, causing no complications with
increased injection into the AOP pool. It is estimated that Well S -09 will inject about 1000
bwpd making the total injection rate for both pools around 2500 bwpd and will not result in a
significant change in injection pressures.
2/4
Aurora Prudhoe Commingling • 3/30/2011
•
Without the commingled injection of the S -09 wellbore, the S -118 producer would remain a
long term shut in well. With this injector support the annualized daily production is depicted
in Table 2.
Due to the low current AOP production rate, no
Table 1. S - 118 Oil rate per year: additional artificial lift gas would be required to handle
®pu additional liquid from S -118. This selective application
8i1e7SS #'• of commingled injection will result in an increase of
2011 398
2012 170 overall recovery.
2013 104
2014 73
2015 55
2016 43
2017 36
2018 31
2019 28
Appropriate Surveillance and Injection Allocation Will Be Assured
Appropriate surveillance and injection allocation measures will be undertaken to meet
reservoir management objectives and to provide an acceptable allocation methodology.
g objectives P P
1. Injection Allocation
In addition to stand -alone daily injection rates prior to and after commingling, will be
compared with injection logs within the initial 60 days of injection. After one year, injection
logs will be done on an as needed basis for reservoir management.
2. Reservoir Surveillance
Long -term development plans for AOP and POP pools include water -flood and Enhanced Oil
Recovery using "Miscible Injectant" (or "MI ") from the Prudhoe Bay Miscible Gas Project.
Reservoir pressure and hydraulic communication will be determined by comparing initial
pressure and injection from each pool with Injection Profile Surveys. If pressure
maintenance is a concern, static pressures from each pool can be measured with the use of
3/4
Aurora Prudhoe Commingling.
• 3/30/2011
down -hole plugs and pressure gauges. If it is determined that a completion in one pool is
adversely affecting injection to the other pool, that completion can be isolated as necessary to
ensure waste does not occur.
Conclusion
BP requests approval for well -bore commingling of WAG injection for AOP and POP,
commencing with Well S -09. During the first 60 days of injection an injection survey for
purposes of allocation of injection by pool will be taken. Thereafter, it is proposed that
injection surveys be taken on an as needed basis .
4/4
