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Home My WebLink AboutO 110OTHER ORDER NO. 110 BP Exploration (Alaska), Inc. Docket No. 0TH -16-002 1. January 11, 2016 BPXA's Request for Administrative Waiver of filing Mechanical Logs ------------------- Email 3. February 17, 2016 Notice of Hearing and Affidavit of Publication 4. March 22, 2016 Transcript (Calendaring Only), sign in sheet and exhibits 5. March 31, 2016 Transcript and sign in sheet OTHER ORDER NO. 110 ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: The application of BP Exploration ) Dockett Number: OTH-16-002 (Alaska) Inc. for Administrative Waiver, ) Other Order 110 Filing of Mechanical Logs Under 20 ) AAC 25.071 ) May 23, 2016 IT APPEARING THAT: 1. By letter dated January 11, 2016, BP Exploration (Alaska) Inc. (BPXA) requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue a waiver from the requirements of 20 AAC 25.071 for the filing of mechanical well logs in any format. 2. Pursuant to 20 AAAC 25.540, the AOGCC tentatively scheduled a public hearing for March 22, 2016. On February 17, 2016, the AOGCC published notice of the opportunity for that hearing on the State of Alaska's Online Public Notice website and on the AOGCC's website, electronically transmitted the notice to all persons on the AOGCC's email distribution list, and mailed printed copies of the notice to all persons on the AOGCC's mailing distribution list. On February 17, 2016, the AOGCC published the notice in the ANCHORAGE DISPATCH NEWS. 3. The hearing commenced at 9:OOAM on March 22, 2016, in the AOGCC's offices located at 333 West 7th Avenue, Anchorage, Alaska. 4. Testimony was received from representatives of BPXA. 5. The record was closed at the end of the hearing. FINDINGS: 1. Representatives of BPXA testified that specific types of Mechanical Logs do not analyze geologic formations in any way and do not provide any additional geologic knowledge. BPXA considers Mechanical Logs to be: o Perforating Records o Jewelry Logs o Inflatable Bridge Plugs o Tubing Patch Setting Records o Chemical Tubing Cut Records o Tubing Puncher Records o Jet Cutter Records o Pack of Gas Lift Mandrel Records o Leak Detection Logs o Caliper Surveys 2. BPXA requested the AOGCC recognize that these Mechanical Logs do not fall under the reporting requirements set out in 20 AAC 25.071. 3. BPXA believes that the initial request for Mechanical Logs under 20 AAC 25.071 and the resulting Administrative Waiver Request from BP are no longer valid. Other Order No. 110 • May 23, 2016 Page 2 of 2 CONCLUSIONS: 1. The AOGCC concurs that current regulation 20 AAC 25.071 does not regulate the types of logs that BP classifies as Mechanical Logs. 2. The Administrative Waiver Request from BP is not valid. 3. No changes to existing reporting requirements are required. �,;,Mrd_ Done at Anchorage, Alaska and dated May 23, 2016. e 7K F Cathy P oerster Daniel T. S ount, Jr. x tuN L�� Chair, Commissioner Commissioner TION 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. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Tuesday, May 24, 2016 9:06 AM To: 'Ballantine, Tab A (LAW) (tab.ballantine@alaska.gov)'; 'Bender, Makana K (DOA) (makana.bender@alaska.gov)'; 'Bettis, Patricia K (DOA) (patricia.bettis@alaska.gov)'; 'Bixby, Brian D (DOA)'; 'Brooks, Phoebe L (DOA) (phoebe.brooks@alaska.gov)'; Carlisle, Samantha J (DOA); 'Colombie, Jody J (DOA) Oody.colombie@alaska.gov)'; 'Cook, Guy D (DOA)'; 'Davies, Stephen F (DOA) (steve.davies@alaska.gov)'; Eaton, Loraine E (DOA); Toerster, Catherine P (DOA) (cathy.foerster@alaska.gov)'; Trystacky, Michal (michal.frystacky@alaska.gov)'; 'Grimaldi, Louis R (DOA) (lou.grimaldi@alaska.gov)'; 'Guhl, Meredith (DOA sponsored) (meredith.guhl@alaska.gov)'; Herrera, Matthew F (DOA); 'Hill, Johnnie W (DOA)'; 'Jones, Jeffery B (DOA) (Jeff jones@alaska.gov)'; Kair, Michael N (DOA); 'Link, Liz M (DOA)'; Loepp, Victoria T (DOA); 'Mumm, Joseph (DOA sponsored) Ooseph.mumm@alaska.gov)'; 'Noble, Robert C (DOA) (bob.noble@alaska.gov)'; 'Paladijczuk, Tracie L (DOA)(tracie.paladijczuk@alaska.gov)'; 'Pasqual, Maria (DOA) (maria.pasqual@alaska.gov)'; 'Quick, Michael (DOA sponsored)'; 'Regg, James B (DOA) Oim.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) (angela.singh@alaska.gov)'; 'Wallace, Chris D (DOA) (chris.wallace@alaska.gov)'; 'AKDCWeIIIntegrityCoordinator'; 'Alan Bailey'; 'Alex Demarban'; 'Alexander Bridge'; 'Allen Huckabay'; 'Amanda Tuttle'; 'Andrew VanderJack'; 'Anna Raff'; 'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer'; 'Bill Bredar'; 'Bob Shavelson'; 'Brian Havelock'; 'Bruce Webb'; Burdick, John D (DNR); 'Caleb Conrad'; 'Candi English'; 'Cliff Posey'; 'Colleen Miller'; 'Crandall, Krissell'; 'D Lawrence'; 'Dave Harbour'; 'David Boelens'; 'David Duffy'; 'David House'; 'David McCaleb'; 'David Tetta'; 'ddonkel@cfl.rr.com'; 'Dean Gallegos'; Delbridge, Rena E (LAS); DNROG Units (DNR sponsored); 'Donna Ambruz'; 'Ed Jones'; 'Elowe, Kristin'; 'Evans, John R (LDZX)'; 'Frank Molli'; 'Gary Oskolkosf'; 'George Pollock'; 'Gordon Pospisil'; 'Gregg Nady'; 'gspfoff'; Hyun, James J (DNR); 'Jacki Rose'; 'Jdarlington Oarlington@gmail.com)'; 'Jeanne McPherren'; 'Jerry Hodgden'; 'Jerry McCutcheon'; 'Jim Watt'; 'Jim White'; 'Joe Lastufka'; 'Joe Nicks'; 'John Easton'; 'Jon Goltz'; 'Juanita Lovett'; 'Judy Stanek'; 'Julie Houle'; 'Julie Little'; 'Karen Thomas'; 'Kari Moriarty'; 'Kazeem Adegbola'; 'Keith Torrance'; 'Keith Wiles'; 'Kelly Sperback'; 'Laura Silliphant (laura.gregersen@alaska.gov)'; 'Leslie Smith'; 'Louisiana Cutler'; 'Luke Keller'; 'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley@anadarko.com)'; 'Mark Landt'; 'Mark Wedman'; 'Marquerite kremer (meg.kremer@alaska.gov)'; 'Mary Cocklan-Vendl'; 'Mealear Tauch'; 'Michael Calkins'; 'Michael Moora'; 'MJ Loveland'; 'mkm7200'; Morones, Mark P (DNR); Munisteri, Islin W M (DNR); 'nelson'; 'Nichole Saunders'; 'Nick W. Glover'; 'Nikki Martin'; 'NSK Problem Well Supv'; 'Oliver Sternicki'; 'Patty Alfaro'; 'Paul Craig'; 'Paul Decker (paul.decker@alaska.gov)'; 'Paul Mazzolini'; Pike, Kevin W (DNR); 'Randall Kanady'; 'Randy L. Skillern'; 'Renan Yanish'; 'Richard Cool'; 'Robert Brelsford'; 'Ryan Tunseth'; 'Sara Leverette'; 'Scott Griffith'; 'Shannon Donnelly'; 'Sharmaine Copeland'; 'Sharon Yarawsky'; Shellenbaum, Diane P (DNR); Skutca, Joseph E (DNR); 'Smart Energy Universe'; Smith, Kyle S (DNR); 'Sondra Stewman'; 'Stephanie Klemmer'; 'Stephen Hen nigan'; 'Steve Moothart (steve.moothart@alaska.gov)'; 'Suzanne Gibson'; Tamera Sheffield; 'Tania Ramos'; 'Ted Kramer'; Temple Davidson; Teresa Imm; Thor Cutler, 'Tim Mayers'; Todd Durkee; trmjrl; 'Tyler Senden'; Vicki Irwin; Vinnie Catalano; 'Aaron Gluzman'; 'Aaron Sorrell'; Ajibola Adeyeye; Alan Dennis; Ann Danielson; Bajsarowicz, Caroline 1; Brian Gross; 'Bruce Williams'; Bruno, Jeff J (DNR); Casey Sullivan; D. McCraine; 'Don Shaw'; Eric Lidji; Furie Drilling; Garrett Haag; 'Graham Smith'; Hak Dickenson; Heusser, Heather A To: (DIR , Holly Pearen; J. Stuart; 'Jason Bergerson', Tim Magill'; Joe Longo; John Martineck; Josh Kindred; Kasper Kowalewski; 'King, Kathleen J (DNR)'; Laney Vazquez; Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; 'Marie Steele'; Matt Armstrong; 'Mike Franger'; Morgan, Kirk A (DNR); Pat Galvin; 'Pete Dickinson'; Peter Contreras; Richard Garrard; Richmond, Diane M; Robert Province; 'Ryan Daniel'; 'Sandra Lemke'; 'Susan Pollard'; T. Hord; Talib Syed; Tina Grovier (tmgrovier@stoel.com); Tostevin, Breck C (LAW); Vicky Sterling; 'Wayne Wooster'; Whitney Pettus; 'William Van Dyke' Subject: Various Orders Attachments: other110.pdf; aio18C.010.pdf; aio5.025.pdf; aio4F.008.pdf Please see Attached: Other Order 110 (Docket OTH-16-002) AIO 18C-010 (Docket AI0-16-021) A10 5-025 (Docket AI0-16-020) AID 4F-008 (Docket A10-16-019) Jody J. Colombie .AOGCC SpeciaCAssistant .Alaska OilandGas Conservation Commission 333 'West 7" .Avenue .Anchorage, .Alaska 99501 Office: (907) 793-1221 Fax: (907) 276-7542 CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Jody Colombie at 907.793.1221 or iody.colombie@alaska.aov. Jack Hakkila Bernie Karl P.O. Box 190083 K&K Recycling Inc. Anchorage, AK 99519 P.O. Box 58055 Fairbanks, AK 99711 Penny Vadla George Vaught, Jr. 399 W. Riverview Ave. P.O. Box 13557 Soldotna, AK 99669-7714 Denver, CO 80201-3557 Diane Richmond Richard Wagner Performance Management Lead/ P.O. Box 60868 Compliance Representative Fairbanks, AK 99706 BP Exploration (Alaska), Inc. P.O. Box 196612 Anchorage, AK 99519-6612 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 yA �: L 4�4 C� 2'-E t 20 ll� Angel. K. Singh INDEXES 1 ALASKA OIL AND GAS CONSERVATION COMMISSION 2 3 Before Commissioners: Cathy Foerster, Chair 4 Daniel T. Seamount 5 6 In the Matter of the Application of BP ) 7 Exploration Alaska for Administrative ) 8 Waiver, Filing of Mechanical Logs Under ) 9 20 AAC 25.071. ) 10 ) 11 Docket No.: OTH 16-002 12 13 ALASKA OIL and GAS CONSERVATION COMMISSION 14 Anchorage, Alaska 15 16 March 31, 2016 17 9:00 o'clock a.m. 18 19 VOLUME II 20 PUBLIC HEARING 21 22 BEFORE: Cathy Foerster, Chair 23 Daniel T. Seamount 0 TABLE OF CONTENTS 2 Opening remarks by Chair Foerster 03 3 Remarks by Ms. Ohms 13 1 P R O C E E D I N G S 2 9:03:01 3 (On record - 9:03 a.m.) 4 CHAIR FOERSTER: I'll call this hearing to 5 order. Today is March 31, 2016, it's 9:02 a.m. We are 6 located at the offices of the Alaska Oil and Gas 7 Conservation Commission, 333 West Seventh Avenue, 8 Anchorage, Alaska. To my left is Dan Seamount and I'm 9 Cathy Foerster. 10 Today's hearing is in regard to docket number 11 OTH 16-002, the Application of BP Exploration Alaska 12 for Administrative Waiver, Filing of Mechanical Logs 13 under 20 AAC 25.071. BP by letter dated January 11, 14 2016 requests the Oil and Gas Conservation Commission 15 issue a waiver from the requirements of 20 AAC 25.071 16 for the filing of mechanical well logs in any format. 17 Computer Matrix will be recording the 18 proceedings today and you can get a copy of the 19 transcript from them. 20 BP has three people that intend to testify 21 today. Are there any other parties planning to 22 testify? 23 (No comments) 24 CHAIR FOERSTER: I don't think I need to read 25 all these rules to these guys, I think they know these 7 1 rules. What do you think? 2 COMMISSIONER SEAMOUNT: You can just remind 3 them if they forget. 4 CHAIR FOERSTER: Okay. So I won't read them. 5 COMMISSIONER SEAMOUNT: Don't read them. 6 CHAIR FOERSTER: Okay. Thank you. Just 7 remember to speak into the microphones so people in the 8 back of the room can hear you and the court reporter 9 can capture what you say as well. 10 Dan, do you have anything to add before we 11 begin? 12 COMMISSIONER SEAMOUNT: I have nothing at this 13 point. 14 CHAIR FOERSTER: Okay. Probably the easiest 15 thing would be for all three people intending to 16 testify to get sworn in together. Is that all right 17 with you guys? So if the third person wants to come up 18 we can just -- you don't have to stand, but just raise 19 your right hand. 20 (Oath administered) 21 IN UNISON: I do. 22 CHAIR FOERSTER: Okay. And for the record 23 would you please give your names to the court reporter, 24 the people -- the three people who just said that. 25 MS. OHMS: Daniele Ohms, O -H -M -S. 0 • 1 COMMISSIONER SEAMOUNT: That's appropriate. 2 MS. BAJSAROWICV-BORG: Caroline Bajsarowicv- 3 Borg. Do you need that spelled? 4 CHAIR FOERSTER: Sure. 5 MS. BAJSAROWICV-BORG: B -A -J -S -A -R -O -W -I -C -V -B- 6 O -R -G. 7 MS. RICHMOND: Diane Richmond. 8 CHAIR FOERSTER: Thank you. Okay. 9 COMMISSIONER SEAMOUNT: Can't Ms. Richmond sit 10 right there? 11 CHAIR FOERSTER: She can if she wants to. 12 COMMISSIONER SEAMOUNT: That'll save some 13 exercise. 14 CHAIR FOERSTER: Well, maybe she wanted the 15 exercise. 16 MS. RICHMOND: I don't mind. 17 CHAIR FOERSTER: Okay. So as each of you 18 testifies we'll provide you the opportunity to be 19 accepted as an expert and should you decide you want to 20 be recognized as an expert you give us the area of 21 expertise and your credentials and then we'll make a 22 determination of whether we intend to accept you as an 23 expert in that area. And as each of you testifies, I 24 assume you're going to go in some sort of a chronology, 25 start by introducing yourself, who you represent and X 1 what you do for that party and then if you want to be 2 recognized as an expert. And anytime you do tag 3 teaming, anytime someone else interjects please try to 4 remember to start by naming yourself because when the 5 court reporter takes this back home your voices may 6 sound similar enough to him that it's hard for him to 7 get an accurate account of who said what. And as you 8 refer to the PowerPoint presentation, since the pages 9 are not numbered, as you refer to a particular page say 10 we're now looking at the slide title blah so that 11 people looking back on the record 20 years from now can 12 reconstruct it intelligibly. 13 Okay. All right. So you may begin. 14 MS. OHMS: Good morning, Chair Foerster and 15 Commissioner Seamount. My name's Daniele Ohms and I'd 16 like to testify as an expert witness. 17 CHAIR FOERSTER: And you represent BP? So..... 18 MS. OHMS: My name is Daniele Ohms, I'm 19 employed by BP Alaska, working at BP's Anchorage 20 office. I have a bachelor's degree of science in 21 petroleum engineering from the University of Texas at 22 Austin. I also have a master's of science degree in 23 environmental engineering from the University of Alaska 24 Anchorage. I have worked in the oil industry for 25 approximately 28 years all in Alaska. I started as a 10 1 petroleum engineer at ARCO in 1988 working the Kuparuk 2 reservoir as a combined production and reservoir 3 engineer. I've also worked onsite at Kuparuk for 4 approximately four years while I was (indiscernible) 5 engineer, field petroleum engineer and environmental 6 coordinator. In 197 I worked as a petroleum engineer 7 in the Prudhoe Bay field transitioning to BP in 2000. 8 From 2001 through 2010 I worked as a petroleum and lead 9 petroleum engineer for various field areas in Prudhoe 10 Bay and Milne Point fields though a lead petroleum 11 engineering role at BP entailed providing technical 12 review and approval of non -rig well work procedures and 13 coordination of associated state sundries. For the 14 following three years I was BP technology lead and 15 since 2013 I have been the BP Alaska petroleum 16 engineering technical -- the discipline lead and with 17 the responsibility of providing technical guidance and 18 oversight of the base management regulatory compliance. 19 My colleagues here, Diane, Richmond and 20 Caroline Bajsarowicv were part of the initial 21 discussions with AOGCC, but I will be the primary 22 expert witness. 23 CHAIR FOERSTER: Thank you. Do you have any 24 questions for Ms. Ohms? 25 COMMISSIONER SEAMOUNT: Yes. Ms. Ohms, is your 11 1 named spelled O -H -M -S? 2 MS. OHMS: Uh-huh. 3 COMMISSIONER SEAMOUNT: Wow. That is 4 appropriate. Okay. Now you have a bachelor's degree 5 in geology..... 6 CHAIR FOERSTER: Petroleum engineer. 7 MS. OHMS: No, petroleum engineer. 8 COMMISSIONER SEAMOUNT: Oh, petroleum engineer. 9 Okay. All right. And what kind of expert do you want 10 to be designated? 11 MS. OHMS: Petroleum engineering. 12 COMMISSIONER SEAMOUNT: Okay. Regardless of 13 the school you went to I have no objections. 14 CHAIR FOERSTER: I have one question. Am I 15 correct in my premise that Janet Weiss has a strategy 16 of sending people that she thinks I like to testify so 17 that the..... 18 (Laughter) 19 CHAIR FOERSTER: .....results can be 20 predetermined? 21 MS. OHMS: I don't know if she knows I'm here. 22 (Laughter) 23 CHAIR FOERSTER: Okay. All right. She's 24 professed to me before that she doesn't that if Ryan 25 Stramp testifies for Conoco that BP can't have anyone 12 1 who can outdo him because I like him so much, but he's 2 retired now so that doesn't matter. But this just 3 seemed to fit in with that belief of hers. And having 4 gone to the same university and having worked with you 5 at ARCO i know that you are an expert petroleum 6 engineer so we have no problem recognizing you as such. 7 Please proceed. 8 DANIELE OHMS 9 previously sworn, called as a witness on behalf of 10 BPXA, stated as follows on: 11 DIRECT EXAMINATION 12 MS. OHMS: I will go to slide two, our 13 introduction. And BP..... 14 COMMISSIONER SEAMOUNT: They're numbered. 15 MS. OHMS: .....Alaska would like to thank you 16 for the opportunity to respond to AOGCC's request on 17 December 2nd, 2015 for hard copies of mechanical logs. 18 BP wants to comply with all regulations and has been 19 actively working with the AOGCC since this request was 20 received. BPXA provides required geologic data and 21 logs. In 1998 the AOGCC confirmed that BP was not 22 required to provide mechanical logs. The most recent 23 AOGCC request for hard copies of all mechanical log 24 references Article 1 of the Alaska Administrative Code 25 Title 20, Chapter 25, that refers to drilling in 13 • • 1 Section 71 that pertains to geologic data and logs. 2 CHAIR FOERSTER: They are numbered. They are 3 numbered. I was mistaken. 4 MS. OHMS: Okay. 5 CHAIR FOERSTER: So you can refer to the 6 numbers. 7 MS. OHMS: BP has viewed the reference to all 8 logs in this section over here as all geologic logs 9 such as sonic, resistivity and Bit meter, BP asks that 10 the Commission recognize that mechanical logs do not 11 fall under this section. Records related to well work 12 operations and production practices are provided to the 13 Commission, but under Title 20 of Alaska Administrative 14 Code, Chapter 25, Section 280. 15 So slide three is our overview of current logs 16 submitted to the AOGCC. So BP does submit open hole 17 logs and mud logs obtains from drilling -- during 18 drilling operations and also cement evaluation logs. 19 Per requirements of conservation orders for the various 20 pools BP obtained and submits production and injection 21 logs and other reservoir surveillance logs such as 22 fluid contact and saturation logs. 23 Slide four would be specific mechanical logs 24 requested for waiver. BP defines mechanical logs to 25 include the following records, perforating records, 14 1 jewelry logs, inflatable bridge plug records, tubing 2 patch setting records, chemical tubing cut records, 3 tubing punch records, jet cutter records, pack off gas 4 lift mandrel records, leak detect logs and caliper 5 surveys. The addition of caliper surveys here was not 6 on our original list in our letter, but we do consider 7 that part of mechanical logs. These logs provide 8 mechanical information pertinent to the particular well 9 work job and do not analyze the formation in any way or 10 provide any geologic knowledge -- any additional 11 geologic knowledge. Reporting of the mechanical well 12 work operations listed in the regulation under Article 13 3 of Code Title 20, Chapter 25, that refers to 14 production practices and Section 280 that pertains to 15 workover operations and the sundry matrix. The AOGCC 16 sundry matrix outlines reporting requirements for these 17 well work operations which BP does follow. Required 18 reports of sundry operations are submitted with the 10- 19 404 form. 20 So in summary BP is asking the Commission to 21 recognize that these mechanical logs do not fall under 22 the 20 AAC 25.071 that references Article 1, drilling, 23 and Section 71 that provides to geologic data and logs. 24 Related records are already provided to the Commission 25 under 20 AAC 25.280 that reference Article 3, 15 1 production practices, and Section 28 that pertains to 2 workover operations and the sundry matrix. 3 If the Commission disagrees and asserts that 4 the 20 AAC 25.071 does include more than geologic logs 5 then BP respectfully requests a waiver as noted on our 6 January 11th, 2016 letter that pursuant to Section 7 71(c), the Commission grant a waiver of the requirement 8 to file mechanical logs as they provide no additional 9 geologic value. 10 CHAIR FOERSTER: Thank you. 11 MS. OHMS: That's the conclusion so open to 12 questions. 13 CHAIR FOERSTER: Do you have any questions, 14 Commissioner Seamount? 15 COMMISSIONER SEAMOUNT: I have a few. Ms. 16 Ohms, you've mentioned by hard copies and electronic 17 copies or you made a distinction between the two. Are 18 you saying you want a waiver on both electronic and the 19 hard copies? 20 MS. OHMS: We were -- yes, we were asking that. 21 COMMISSIONER SEAMOUNT: Okay. 22 MS. OHMS: I believe the letter was primarily 23 referencing hard copies, but it would be for both. 24 COMMISSIONER SEAMOUNT: Okay. Let's see. Next 25 question is -- if I can find it. Go to slide number -- 16 1 these ones are not numbered, is it 4. The list of the 2 waiver logs. 3 MS. OHMS: I have that up here. 4 COMMISSIONER SEAMOUNT: Would this be for all 5 BP operated fields now and in the future and would that 6 include exploration wells? 7 MS. OHMS: For these -- these logs are on wells 8 that are already developed wells. So, yes, going 9 forward these are mechanical logs runs primarily 10 through tubing after completion. 11 COMMISSIONER SEAMOUNT: Okay. I'm wondering if 12 we did waive all of these logs for you guys if we have 13 to waive them for all the operators, that's something 14 to discuss later. Perforating records. You said that 15 you will be reporting on perforating intervals on the 16 404; is that correct? 17 MS. OHMS: Yes, we do. 18 COMMISSIONER SEAMOUNT: And are you going to be 19 reporting on shots per foot, that sort of thing? 20 MS. OHMS: I believe so. I have an example one 21 in the backup where you can't read it. There is 22 records that go with that. But these forms -- I'll 23 just make this larger because even I can't read that, 24 but these typically include the perf depths. Let me 25 double check if they include -- I don't believe they 17 1 always include the shots per foot on these, but then we 2 do have operating records that also go with it. And 3 sometimes these provide details of the shots per foot, 4 it depends on the details in the operating -- the daily 5 report of well operation. 6 CHAIR FOERSTER: So there's no guarantee? 7 MS. OHMS: No. 8 COMMISSIONER SEAMOUNT: What about tubing 9 conveyed perforating. 10 MS. OHMS: And they are on the schematic that's 11 applied. 12 COMMISSIONER SEAMOUNT: Oh, you would -- okay. 13 You still..... 14 MS. OHMS: And this is sent with it too. So 15 these actually..... 16 COMMISSIONER SEAMOUNT: Why do you think a leak 17 detection log is not important geologically? 18 MS. OHMS: A leak detect log is primarily in 19 the tubing itself so it is -- we're -- we're looking 20 for leaks which we later go and patch or shut the well 21 in if we cannot do anything about it. But it's 22 primarily in the tubing that we're doing leak detect 23 logs. 24 COMMISSIONER SEAMOUNT: Okay. In the tubing, 25 but what if it's in the casing? 19 1 MS. OHMS: In the casing it is identifying 2 potentially a hole in the casing, but we would also be 3 looking at production logs to do that. 4 COMMISSIONER SEAMOUNT: Okay. Now when you 5 talk about caliper surveys, you're not including the 6 caliper survey that's run along with the density 7 neutron log are you, the open hole logs? 8 MS. OHMS: No, that would be included. Any 9 open hole -- well, case hole logs that we run that in 10 with geologic data that's automatically included with 11 those. This would be a separate log. Most of our perf 12 logs, the caliper with it is just for tie in purposes. 13 And very often it doesn't even contain a gamma ray, 14 sometimes they do, sometimes they don't, but it's only 15 for tie in purposes with the perf logs and most of 16 these other setting logs. 17 COMMISSIONER SEAMOUNT: Okay. And then will 18 all these logs be retained by BP and be available to 19 the AOGCC as not confidential if in the future there is 20 some geologic use for them? 21 CHAIR FOERSTER: Or mechanical use for them, 22 even..... 23 MS. OHMS: Okay. 24 CHAIR FOERSTER: .....a non -geologic use for 25 them. 19 1 MS. OHMS: Yeah. BP does maintain copies and 2 electronic copies of all of our logs. So we maintain 3 our own logs for our records. 4 COMMISSIONER SEAMOUNT: Okay. That's all I 5 have, Ms. Ohms. Thank you. 6 CHAIR FOERSTER: Just for the lay of the land, 7 for several years now BP has not been providing this 8 information and then recently someone from the AOGCC 9 requested it..... 10 MS. OHMS: Uh-huh. 11 CHAIR FOERSTER: .....is that what happened? 12 MS. OHMS: That's what's inferred. And we've 13 just read the regulation that we were not needing to 14 send the logs, we were following the sundry matrix..... 15 CHAIR FOERSTER: Okay. 16 MS. OHMS: .....and providing everything which 17 those pieces of well work are included in the sundry 18 matrix. 19 CHAIR FOERSTER: Okay. And you just said that 20 you keep -- BP will keep all of these records 21 electronically..... 22 MS. OHMS: Yes, we do. 23 CHAIR FOERSTER: .....and can you foresee any 24 reason that those would not be made available to the 25 AOGCC if we requested them? 20 0 1 MS. OHMS: I don't see any reason why that 2 couldn't be..... 3 CHAIR FOERSTER: Okay. 4 MS. OHMS: .....if there's a specific request. 5 CHAIR FOERSTER: Right. And, you know, what 6 I'm thinking of, say that there's an instance where 7 there's an offset operator who says, hey, they say they 8 perforated here, but I think they perforated in this 9 other zone that has a bigger drainage area and 10 they're..... 11 MS. OHMS: Uh-huh. 12 CHAIR FOERSTER: .....draining me. 13 MS. OHMS: We have all those records if 14 there's..... 15 CHAIR FOERSTER: Yeah. 16 MS. OHMS: .....anything, but we do report 17 through the sundry where we have perforated in that 18 well and the well bore schematics. 19 CHAIR FOERSTER: But someone writes it down and 20 there is human error..... 21 MS. OHMS: Uh-huh. 22 CHAIR FOERSTER: .....yeah, there's room 23 for..... 24 MS. OHMS: Can be. 25 CHAIR FOERSTER: .....human error. So if 21 1 someone purported that you didn't perf where you said 2 you would then the electronic record would be an 3 important part. 4 COMMISSIONER SEAMOUNT: That would be later I 5 guess. 6 CHAIR FOERSTER: Yeah. Okay. All right. I 7 don't have any other questions at this time. I'm 8 wondering if we should take a brief recess to see if 9 someone in the back of the room from our staff has a 10 desire to be -- to ask a question or be heard. I think 11 that would be a good idea. 12 COMMISSIONER SEAMOUNT: How much time do the 13 other presenters need? 14 MS. OHMS: That was -- they were here just for 15 backup..... 16 COMMISSIONER SEAMOUNT: To answer questions. 17 MS. OHMS: .....if we had anything. 18 CHAIR FOERSTER: They're here -- let's take a 19 brief recess. And we're recessed at 9:22 and we'll 20 come back at 9:35. 21 (Off record) 22 (On record) 23 CHAIR FOERSTER: We'll come back on the record 24 at 9:31. Ms. Ohms, when we were conferring with staff 25 they had a slightly different view of the chronology in 22 1 this. And let me help you get -- you know, how when 2 you go to the eye doctor and he says tell me when these 3 things come together, let's do that. What they said 4 was that prior to a request for hard copies BP had been 5 sending an electronic copy of all this information to 6 the AOGCC and then as part of a compliance check a 7 newer employee said, oh, maybe we need a hard copy and 8 he requested hard copy and that's when the push back 9 occurred. And now your -- the request is that we not 10 -- you not provide the information at all. And so I 11 hear you saying that you never provided it and then all 12 of a sudden we asked for it and our folks saying they 13 provided it electronically, we asked for a hard and now 14 they don't want to provide it at all. So help me come 15 together to make this one image? 16 MS. OHMS: So from my understanding speaking 17 with the employees at BP that do the distribution we -- 18 there were some -- there were some of the leak detect 19 logs that may have been sent in, but they were even 20 questioning if that even fit. But as of 1998 the 21 understanding was from our PDC group that handles the 22 distribution of the logs, that they were not sending in 23 mechanical logs. So with the exception of a few that 24 they commented that they may have sent in some electric 25 -- electronic logs that they were not aware -- they 23 1 were debating that that was even required. 2 CHAIR FOERSTER: Okay. 3 MS. OHMS: So that's my understanding from 4 speaking with those that distribute the logs. 5 CHAIR FOERSTER: Okay. And..... 6 MS. OHMS: And we do send in hard copies and 7 electronic of all the geologic logs and the other logs 8 that I mentioned. So production profiles and reservoir 9 surveillance logs such as the gas/oil -- for gas/oil 10 contact monitoring. 11 CHAIR FOERSTER: Okay. Now BP's typically in 12 recent history been in the opposite role of what I'm 13 about to layout, but put yourself in the other 14 position. If BP were coming in acquiring a property 15 from another operator and that other operator didn't 16 give BP a complete record of what was in every well 17 first without a complete record of what's in every well 18 would that make it harder for BP to work on those 19 wells? 20 MS. OHMS: Potentially, yes. 21 CHAIR FOERSTER: And if..... 22 MS. OHMS: You could..... 23 CHAIR FOERSTER: .....it did make it harder and 24 BP was concerned that they wanted to know what was in 25 the well before they got into it where would BP go to 24 0 1 try to get that data? 2 MS. OHMS: Well, the sundry matrix does require 3 a lot of the data be sent in..... 4 CHAIR FOERSTER: A lot. 5 MS. OHMS: .....but there's some that they 6 regulate that do not such as hog runs (ph), some of the 7 caliper surveys, but any perf records we do have to 8 send in, they would be able to see that, tail pipe 9 cutting, there's some of the casing repair patches we'd 10 be sending that in. 11 CHAIR FOERSTER: Okay. 12 MS. OHMS: And you could run a survey in the 13 well if you were unsure and determine what jewelry 14 was..... 15 CHAIR FOERSTER: So but your first thing was 16 you refer to the sundry matrix and what is reported to 17 the AOGCC. So if BP took over a field and wanted to 18 get the data about that field and it wasn't provided by 19 the old operator you'd come to us for it? 20 MS. OHMS: We would look in the sundries, yeah. 21 CHAIR FOERSTER: Yeah, you'd look and see if 22 the data was available to us. 23 MS. OHMS: Uh-huh. 24 CHAIR FOERSTER: So if you guys were to leave 25 some -- another operator with your field then they 25 1 might be in that same position took, anything that 2 wasn't in the data that you pass on to them, they might 3 come to us and hope to get it from us? 4 MS. OHMS: And I -- yeah, because we do keep 5 our -- all the completion diagrams up to date and when 6 we do send any records or sundries in they're always on 7 that and that has our complete record. 8 CHAIR FOERSTER: And BP..... 9 MS. OHMS: BP we do. 10 CHAIR FOERSTER: .....does a great job of this, 11 but..... 12 MS. OHMS: Right. 13 CHAIR FOERSTER: .....can you appreciate that 14 anything that we do for you we have to do for everyone. 15 So we don't have a BP set of rules and then an 16 everybody else set of rules in this state, that's just 17 not how we do business. So in looking over our 18 regulations I think that perhaps a misstatement was 19 made about the mechanical logs following under 20 AAC 20 25.071, but I think you're correct that they -- that 21 the data that we're talking about better fits into 22 25.280. And let me see what (g) says. The operator 23 shall file with the Commission within 30 days after 24 completion of workover operations on a report of sundry 25 well operations, form 10-404, a complete record of the 26 0 1 work performed and the tests conducted and a summary of 2 daily well operations. So a complete record is 3 different from a summary. So you do a summary of the 4 work, but a complete record of the work performed and 5 the tests conducted. And I think a casing leak test is 6 a test. 7 So I think there is some room for discussion 8 among the Commission and our legal staff, this isn't as 9 black and white as it might appear from a -- you know, 10 it's not as simple as a four page PowerPoint. And I'm 11 going to give you a chance to comment on that statement 12 that I just made. 13 MS. OHMS: Right. And as far as that goes, I 14 mean, for what is required of the sundry, you know, we 15 have been complying with that, you know, for a very 16 long time. And this is an example of what is included 17 along with the form here. So for what had been 18 required. There's clarification of what needs to be 19 included, you know, that's maybe something we need, but 20 this historically has been very typical of what we've 21 sent in for a very long time. 22 CHAIR FOERSTER: Okay. Do you have any 23 questions, Commissioner Seamount? 24 COMMISSIONER SEAMOUNT: Yeah, I just have one 25 or two. As far as hard copies are concerned we do have 27 1 a problem with storage space around here, but this is a 2 question that Chair Foerster had and she forgot to ask 3 and that is what's the driver behind this request? 4 MS. OHMS: The driver is the volume of logs 5 that we would have to handle and manage and the cost 6 associated with that. We currently submit about three 7 to 400 logs is what were sent in of what we have been 8 interpreting as being required to send. If we included 9 all mechanical logs of what I reference there we'd be 10 talking about a thousand to 1,200 logs per year so 11 about two to three times the volume of logs. And 12 managing that distribution already takes a number of 13 staff and as you know we're in challenging time so 14 increasing that by two to three times would be an 15 administrative burden as well as a cost burden. 16 COMMISSIONER SEAMOUNT: If we were to just go 17 with the -- a requirement for electronic submission 18 would that cut down a lot on what your driver is? 19 MS. OHMS: It reduces the cost of the hard copy 20 logs, but the administrative management of that process 21 still would take people away from other work in a time 22 where we're already pretty tight and tightening up. 23 COMMISSIONER SEAMOUNT: But isn't -- wouldn't -- 24 I mean, wouldn't it be up to the contractor to supply 25 the electronic copies? NM 0 1 MS. OHMS: No, right now that's handled -- 2 well, we have PDC, but they work directly with BP or 3 the -- and they help distribute the logs for BP to 4 AOGCC and help us manage that. So they get it from the 5 vendors, make sure we have the final version and they 6 make sure the distributions take place. So it's 7 somewhat a coordinated process and it's internal in the 8 BP Anchorage office. 9 COMMISSIONER SEAMOUNT: So you're talking about 10 QC? 11 MS. OHMS: There is -- yeah, QC and making sure 12 we receive the log from them so that we're responsible 13 for sending it in, not the vendor. 14 COMMISSIONER SEAMOUNT: Okay. That's all I 15 have. 16 CHAIR FOERSTER: Okay. All right. Unless 17 there's anyone else in the audience who feels the need 18 to testify, going once, twice, this hearing is 19 adjourned at 9:41. 20 (Hearing adjourned 9:43 a.m.) 21 9:43:11 22 (END OF PROCEEDINGS) PQ 1 C E R T I F I C A T E 2 UNITED STATES OF AMERICA ) 3 )ss 4 STATE OF ALASKA ) 5 6 I, Salena A. Hile, Notary Public in and for the 7 state of Alaska, residing in Anchorage in said state, 8 do hereby certify that the foregoing matter: Docket 9 No.: OTH 16-002 was transcribed to the best of our 10 ability; Pages 05 through 30; 11 IN WITNESS WHEREOF I have hereunto set my hand 12 and affixed my seal this 10th day of April 2016. 13 14 15 16 17 18 Salena A. Hile Notary Public, State of Alaska My Commission Expires: 09/16/2018 30 STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Docket Number: OTH-16-002 The application of BP Exploration (Alaska) Inc. March 31, 2016 NAME AFFILIATION Testify (yes or no) C A v Ccs 1C3"Yub i E� A'o Cr C C �1 C-) LAMS 0 �7 C- kw.,v + z lid G CG N • C7 1 ALASKA OIL AND GAS CONSERVATION COMMISSION 2 3 Before Commissioners: Cathy Foerster, Chair 4 Daniel T. Seamount 5 6 In the Matter of the Application of BP ) 7 Exploration Alaska for Administrative ) 8 Waiver, Filing of Mechanical Logs Under ) 9 20 AAC 25.071. ) 10 ) 11 Docket No.: OTH 16-002 12 13 ALASKA OIL and GAS CONSERVATION COMMISSION 14 Anchorage, Alaska 15 16 March 22, 2016 17 9:00 o'clock a.m. 18 19 VOLUME I 20 PUBLIC HEARING 21 22 BEFORE: Cathy Foerster, Chair • TABLE OF CONTENTS • Opening remarks by Chair Foerster 03 1 P R O C E E D I N G S 2 9:02:38 3 (On record) 4 CHAIR FOERSTER: I'd like to call this hearing 5 to order. Today is March 22, 2016, it's 9:00 a.m. 6 We're located at 333 West Seventh Avenue, Anchorage, 7 Alaska, the offices of the Alaska Oil and Gas 8 Conservation Commission. I'm Cathy Foerster, the 9 Chair. 10 We're meeting on docket number 0TH 16-002, the 11 Application of BP Exploration for Administrative Waiver 12 for Filing of Mechanical Logs under 20 AAC 25.071. 13 Computer Matrix will be recording these 14 proceedings. You can get a copy of the transcript from 15 them. 16 This is a calendaring hearing only. The AOGCC 17 does not have an quorum to hold this hearing today so 18 it is being continued until March 31st, 2016 at 9:00 19 a.m. 20 (Hearing adjourned) 21 9:03:30 22 (END OF PROCEEDINGS) 3 1 C E R T I F I C A T E 2 UNITED STATES OF AMERICA ) 3 )ss 4 STATE OF ALASKA ) 5 6 I, Salena A. Hile, Notary Public in and for the 7 state of Alaska, residing in Anchorage in said state, 8 do hereby certify that the foregoing matter: Docket 9 No.: OTH 16-002 was transcribed to the best of our 10 ability; Pages 02 through 04; 11 IN WITNESS WHEREOF I have hereunto set my hand 12 and affixed my seal this 10th day of April 2016. 13 14 15 Salena A. Hile 16 Notary Public, State of Alaska 17 My Commission Expires: 09/16/2018 18 4 BPXA Administrative Waiver Request Submission of Mechanical Logs k Introduction • BPXA wants to comply with all regulations and has been actively working with AOGCC representatives since the request for mechanical hard copy logs was received (12/2/15) . • • In 1998, the AOGCC confirmed that BPXA was not required to provide "mechanical logs" BPXA continues to provide required geologic data and logs. • BPXA asks that the Commission recognize that "mechanical logs" do not fall under Section 20 AAC 25.071. Drilling: 20AAC 25.071 (b)(6) for Geologic Data and logs "a sepia and a reproduced copy of all logs run, including common derivative formats • such as tadpole plots of dipmeter data and borehole images produced from sonic or resistivity data, and including composite log formats; however, copies of velocity surveys and experimental logs need not be included; an electronic image file in a format acceptable to the commission may be substituted for the sepia;" • Belated records associated with 'mechanical logs' are already provided to the Commission under 20 AAC 25.280 Workover operations VA Overview of current logs submitted to •' AOGCC Open Hole logs (geologic logs during drilling operations) Mud logs (from drilling operations) • Cement Evaluation logs Production/Injection logs (per individual Conservation Orders) F; Surveillance logs (i.e. fluid saturation logs per Conservations Orders) 0 Specific 'Mechanical Logs' requested for waiver ➢ Perforating Records w, Jewelry Logs Inflatable Bridge Plugs Tubing Patch Setting Records ➢ Chemical Tubing Cut Records ➢ Tubing Puncher Records ➢ Jet Cutter Records AOGCC Regulabons Alaska Administrative Code: Legislative Site Tine 20 - CHAPTER 25 • 1. Drilling (20 AAC 25.005 - 20 AAC 25.080) • 2. Abandonment and Plugging (20 AAC 25.105 20 AAC 25.172) • 3. Production Practices (20 AAC 25.200 - 20 AAC 25.290) • 4. Reports (20 AAC 25.300 - 20 AAC 25.320) • 5. Enhanced Recovery (20 AAC 25.400 - 20 AAC 25.460) • 6. General Previsions (20 AAC 25.505 - 20 AAC 25.630) • 7. Geothermal Resources (20 AAC 25.705 - 20 AAC 25.740) • 8. Definitions (20 AAC 25.990) ➢ Pack Off Gas Lift Mandrel (POGLM) Records ➢ Leak Detect Logs ➢ Caliper Surveys • These "logs" are mechanically oriented and do NOT analyze the formation in any way or provide any additional geologic knowledge. • Reporting of the mechanical wellwork operations listed above are regulated under Production Practices: 20 AAC 25.280 for Workover operations. • Required Reports of Sundry Operations (form 10-404) are submitted. 0 • -7,141 Summary BPXA asks that the Commission recognize that these mechanical logs do not fall under 20 AAC 25.071. , Related records are already provided to the Commission under 20 AAC 25.280 Workover operations and the Sundry Matrix. If the commission disagrees, then BPXA requests a waiver as noted in our January 11 t", 2016 request per 20 AAC 25.071(c), as mechanical logs provide no additional geologic value. • NAME Ll STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Docket Number: OTH-16-002 The application of BP Exploration (Alaska) Inc. March 22, 2016 AFFILIATION Testify (yes or no) Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Thursday, March 17, 2016 12:29 PM To: 'Caroline.Bajsarowicz@bp.com' Subject: Hearing scheduled for March 22, 2016 Caroline, We will be having a very short calendaring hearing on March 22, 2016 at 9am. BPXA does not need to be present for the calendaring hearing. At that time the AOGCC will be continuing the hearing until March 31, 2016 at 9:00 am at such time the AOGCC will be proceeding with the hearing. If BPXA needs a laptop computer for the hearing on March 31, 2016, please let me know. Jody J. CoComd ie .AOGCC SpeciaC..Assistant .ACaska Oil and Gas Conservation Commission 333 West 7`h .Avenue .Anchorage, .Alaska 99501 Office: (907) 793-1221 Fax. (907) 276-7542 CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Jody Colombie at 907.793.1221 or iody.colombie@alaska.aov. • Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: OTH-16-002 The application of BP Exploration (Alaska) Inc. (BPXA) for Administrative Waiver, Filing of Mechanical Logs under 20 AAC 25.071. BPXA, by letter dated January 11, 2016, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue a waiver from the requirements of 20 AAC 25.071 for the filing of mechanical well logs in any format. The AOGCC has tentatively scheduled a public hearing on this application for March 22, 2016, at 9:00 a.m. at 333 West 7t Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 4, 2016. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after March 7, 2016. In addition, written comments regarding this application may be submitted to the AOGCC at 333 West 7th Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on March 17, 2016, except that, if a hearing is held, comments must be received no later than the conclusion of the March 22, 2016 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than March 16, 2016. / Cathy P. oerster Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION WITH ATTACHED COPY OF ADVERTTSMENT. ADVERTISING ORDER NUMBER AO -16-015 FROM: Alaska Oil and Gas Conservation Commission AGENCY CONTACT: Jody Colombie/Samantha Carlisle DATE OF A.O. 02/16/16 AGENCY PHONE: 1(907) 793-1223 333 West 7th Avenue Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: 2/17/2016 FAX NUMBER: (907)276-7542 TO PUBLISHER: Alaska Dispatch News SPECIAL INSTRUCTIONS: PO Box 149001 Anchorage, Alaska 99514 LEGAL DISPLAY ��( CLASSIFIED`` OTHER (Specify below) WE � Iri4A r ,', w� --m' ni �rF,. �^ Iii -,MV- _€ hp; _ app DESCRIPTION PRICE OTH-16-002 Initials of who prepared AO: Alaska Non -Taxable 92-600185 stTs v* InwUICE SHovyt�iGAAD*AY ITSI�G:: QRDEB �PiO„ CERTIFIED AFFII)pi'I*:(*'':': ;::usl>carloiy:wiTtinr►aciiiecirv:oF:::: anvttsEo::::::::::::::::::: of Administration Department Division of AOGCC 333 West 7th Avenue Anchorage, Alaska 99501 Pae 1 of 1 Total of All Pages $ - REF Type Number Amount Date Comments I PVN ADN84501 2 Ao AO -16-015 3 4 FIN I AMOUNT SY Appr Unit PGM LGR Object FY DIST LIQ 1 16 021147717 3046 16 2 3 4 5 Purchasing Authority Name: Title: P i Autho ' 's Signature Telephone Number f. A.O. # and receiving agency name must appear on all invoices and documents relatin to this purchase. 2. The state is registered for tax free transactions under Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and not for resale. .......... 1S C.. �?...... .... . DIV' 'mA:Vlsca#FOriC6pi09;::P0 fisher (faxed); Division ... C. l;;Rece,y..g.. , • .......................... . Form: 02-901 Revised: 2/16/2016 270227 0001380599 $204.20 STATE OF ALASKA AFFIDAVIT OF PUBLICATION THIRD JUDICIAL DISTRICT Emma Dunlap being first duly sworn on oath deposes and says that he/she is a representative of the Alaska Dispatch News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on February 17, 2016 and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. 7 Signed Subscribed and sworn to before me this 17th day of February, 2016 Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES RECEIVE® FEB 2 3 2016 AOGCC Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: OTH-16-002 The application of BP Exploration (Alaska) Inc. (BPXA) for Administrative Waiver, Filing of Mechanical Logs under 20 AAC 25.071. BPXAConserGas bvatiotner Commissiondated January (AOGCC) 2016, req Ue tsathe waiver l a from t e requirements of 20 AAC 25.071 for the filing of mechanical well logs in any format. The AOGCC has tentatively scheduled a public hearing on this ascheduled pplicatioon for March 22, 2016, at 9:00 a.m. at 333 West 7th Avenue, hearing be hells Alaska Written requesgtumustest hbe filed at the twith tlthe AOGCC no later than 4:30 P.M. on March 4, 2016.Jer consider If a request for a hearing is not timely filed, the AOGCC may the hold the hearo fan or 907) 793ut a 1221 after March 7, 201lern if6 he AOGCC will In addition, written comments regarding this application may be submitted r°ments must be received edsno later t 7th than Avenue, 30cp.ma on March 17, 2016, except that, if a hearing is held, comments must be received no later than the conclusion of the March 22, 2016 hearing. needed to If, because of a disability, special accommodations ma be Assistant, comment or attend the hearing , contact the AOGCC's Sp Jody Colomble, at (907) 793-1221, no later than March 16, 2016. Cathy P. Foerster Chair, Commissioner AO -16-015 17 2016 Published: February Notary Public L. THOMPSON State of AlaskaLBRITNEY mission Expires Feb 23, 2019 Singh, Angela K (DOA) From: Carlisle, Samantha 1 (DOA) Sent: Wednesday, February 17, 2016 8:47 AM To: Ballantine, Tab A (LAW); Bender, Makana K (DOA); Bettis, Patricia K (DOA); Bixby, Brian D (DOA); Brooks, Phoebe L (DOA); Carlisle, Samantha J (DOA); Colombie, Jody 1 (DOA); Cook, Guy D (DOA); Davies, Stephen F (DOA); Eaton, Loraine E (DOA); Foerster, Catherine P (DOA); Frystacky, Michal (DOA); Grimaldi, Louis R (DOA); Guhl, Meredith D (DOA); Herrera, Matthew F (DOA); Hill, Johnnie W (DOA); Jones, Jeffery B (DOA); Kair, Michael N (DOA); Link, Liz M (DOA); Loepp, Victoria T (DOA); Mumm, Joseph (DOA sponsored); Noble, Robert C (DOA); Paladijczuk, Tracie L (DOA); Pasqual, Maria (DOA); Quick, Michael J (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); Wallace, Chris D (DOA); AKDCWellIntegrityCoordinator; Alan Bailey; Alex Demarban; Alexander Bridge; Allen Huckabay; Amanda Tuttle; Andrew Vanderlack; Anna Raff; Barbara F Fullmer; bbritch; bbohrer@ap.org; Bob Shavelson; Brian Havelock; Bruce Webb; Burdick, John D (DNR); Caleb Conrad; Carrie Wong; Cliff Posey; Colleen Miller, Crandall, Krissell; D Lawrence; Dave Harbour; David Boelens; David Duffy; David House; David McCaleb; David Steingreaber; David Tetta; ddonkel@cfl.rr.com; Dean Gallegos; Delbridge, Rena E (LAS); DNROG Units (DNR sponsored); Donna Ambruz; Ed Jones; Elowe, Kristin; Evans, John R (LDZX); Frank Molli; Gary Oskolkosf, George Pollock; Gordon Pospisil; Gregg Nady; gspfoff; Hyun, James J (DNR); Jacki Rose; Jdarlington oarlington@gmail.com); Jeanne McPherren; Jerry Hodgden; Jerry McCutcheon; Jim Watt; Jim White; Joe Lastufka; Radio Kenai; Easton, John R (DNR); Jon Goltz; Juanita Lovett; Judy Stanek; Houle, Julie (DNR); Julie Little; Kari Moriarty; Kazeem Adegbola; Keith Wiles; Kelly Sperback; Gregersen, Laura S (DNR); Leslie Smith; Lisa Parker; Louisiana Cutler; Luke Keller; Marc Kovak; Dalton, Mark (DOT sponsored); Mark Hanley (mark.hanley@anadarko.com); Mark Landt; Mark Wedman; Kremer, Marguerite C (DNR); Mary Cocklan-Vendl; Mealear Tauch; Michael Calkins; Michael Duncan; Michael Moora; Mike Bill; MJ Loveland; mkm7200; Morones, Mark P (DNR); Munisteri, Islin W M (DNR); knelson@petroleumnews.com; Nichole Saunders; Nick W. Glover, Nikki Martin; NSK Problem Well Supv; Oliver Sternicki; Patty Alfaro; Paul Craig; Decker, Paul L (DNR); Paul Mazzolini; Pike, Kevin W (DNR); Randall Kanady; Randy L. Skillern; Renan Yanish; Richard Cool; Robert Brelsford; Ryan Tunseth; Sara Leverette; Scott Griffith; Shannon Donnelly; Sharmaine Copeland; Sharon Yarawsky; Shellenbaum, Diane P (DNR); Skutca, Joseph E (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Sondra Stewman; Stephanie Klemmer; Stephen Hennigan; Moothart, Steve R (DNR); Suzanne Gibson; sheffield@aoga.org; Tania Ramos; Ted Kramer, Davidson, Temple (DNR); Terence Dalton; Teresa Imm; Thor Cutler; Tim Mayers; Todd Durkee; trmjrl; Tyler Senden; Vicki Irwin; Vinnie Catalano; Aaron Gluzman; Aaron Sorrell; Ajibola Adeyeye; Alan Dennis; Andrew Cater, Anne Hillman; Brian Gross; Bruce Williams; Bruno, Jeff J (DNR); Caroline Bajsarowicz; Casey Sullivan; Diane Richmond; Don Shaw; Donna Vukich; Eric Lidji; Smith, Graham O (DNR); Dickenson, Hak K (DNR); Heusser, Heather A (DNR); Holly Pearen; Jason Bergerson; Jim Magill; Joe Longo; John Martineck; Josh Kindred; Kenneth Luckey; King, Kathleen J (DNR); Laney Vazquez; Lois Epstein; Longan, Sara W (DNR); Marc Kuck, Marcia Hobson; Steele, Marie C (DNR); Matt Armstrong; Franger, James M (DNR); Morgan, Kirk A (DNR); Pat Galvin; Pete Dickinson; Peter Contreras; Richard Garrard; Robert Province; Ryan Daniel; Sandra Lemke; Pollard, Susan R (LAW); Talib Syed; Terence Dalton; Tina Grovier (tmgrovier@stoel.com); Todd, Richard J (LAW); Tostevin, Breck C (LAW); Wayne Wooster; William Van Dyke Subject: Public Hearing Notice, OTH-16-002 (BPXA) Attachments: OTH-16-002 Public Hearing Notice.pdf • Please see attached. Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 7h Avenue Anchorage, AK 99501 (907) 793-1223 • CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Samantha Carlisle at (907) 793-1223 or Samantha.Carhsle@alaska.eov. 0 James Gibbs Jack Hakkila Bernie Karl P.O. Box 1597 P.O. Box 190083 M Recycling Inc. Soldotna, AK 99669 Anchorage, AK 99519 P.O. Box 58055Fairbanks, AK 99711 Gordon Severson Penny Vadla George Vaught, Jr. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 13557 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Denver, CO 80201-3557 Richard Wagner Darwin Waldsmith Diane RichmondAlaska), Inc. ( P.O. Box 60868 P.O. Box 39309 P.O. Box Bp Exploration radon Fairbanks, AK 99706 Ninilchik, AK 99639 196612 Anchorage, AK 99519-6612 Angela K. Singh Colombie, Jody J (DOA) From: Davies, Stephen F (DOA) Sent: Thursday, February 18, 2016 12:24 PM To: Richmond, Diane M Cc: Bajsarowicz, Caroline J; Schwartz, Guy L (DOA); Carlisle, Samantha J (DOA); Douglas, David W (Wipro); Tzvetcoff, Chris Subject: RE: Mechanical Log Waiver Request Attachments: NOTICE_OTH-16-002 Public Hearing Notice.pdf Diane, The public hearing for BP's requested Administrative Waiver from Filing of Mechanical Logs is scheduled for March 22, 2016 (see attached). BP's requested extension to June 1, 2016 for delivery of mechanical logs is acceptable to the AOGCC. Please let me know if you have any questions or if I can help further. Regards, Steve Davies Senior Petroleum Geologist Alaska Oil and Gas Conservation Commission (AOGCC) Phone: 907-793-1224 AOGCC: 907-279-1433 Fax: 907-276-7542 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 CONFIDENTIALITY NOTICE. This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Richmond, Diane M [mailto:Diane.Richmond@bp.com] Sent: Tuesday, February 16, 2016 3:13 PM To: Davies, Stephen F (DOA) Cc: Bajsarowicz, Caroline J; Schwartz, Guy L (DOA); Carlisle, Samantha J (DOA); Douglas, David W (Wipro); Tzvetcoff, Chris Subject: RE: Mechanical Log Waiver Request Steve, BP is requesting an extension approval for the delivery of mechanical logs for BP wells to June 1, 2016. This extension approval will allow for a public hearing to be scheduled regarding BP's Request for Administrative Waiver, Filing of Mechanical Logs under 20 AAC 25.071. Please respond with your approval to this extension request. Thanks Diane Diane M. Richmond • AK Reservoir Development Compliance SPA 907-564-4136 907-440-0835 (Cell) From: Davies, Stephen F (DOA) [mai Ito: steve.davies@alaska.gov] Sent: Tuesday, February 16, 2016 11:41 AM To: Richmond, Diane M Cc: Bajsarowicz, Caroline J; Schwartz, Guy L (DOA); Carlisle, Samantha J (DOA) Subject: RE: Mechanical Log Waiver Request Diane, On January 11, 2016, the Alaska Oil and Gas Conservation Commission (AOGCC) received BP's Request for Administrative Waiver, Filing of Mechanical Logs under 20 AAC 25.071. A public hearing — which requires at least 30 days public notice — will be scheduled regarding BP's request. At that hearing, BP will bear the burden of providing evidence to support its request, including specifically evidence as to why filing of such logs in any format would not significantly add to the geologic knowledge of the area in light of information that is available from other wells in the area. Please let me know if you have any questions or if I can help further. Regards, Steve Davies Senior Petroleum Geologist Alaska Oil and Gas Conservation Commission (AOGCC) Phone: 907-793-1224 AOGCC: 907-279-1433 Fax: 907-276-7542 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.eov. From: Richmond, Diane M [mailto:Diane. RichmondCcbbp.coml Sent: Monday, February 15, 2016 2:59 PM To: Davies, Stephen F (DOA) Cc: Bajsarowicz, Caroline J; Schwartz, Guy L (DOA) Subject: RE: Mechanical Log Waiver Request Steve, I wanted to follow up and understand the progress for the Mechanical Log Waiver Request. As you know we have until March 1, 2016 under the approved 60 -day extension. Depending on the status, I may ask for a further extension if appropriate, if not I need to inform our vendors so that they can prepare for the March 1 date. Thanks -for your help. Diane Diane M. Richmond AK Reservoir Development Compliance SPA 907-564-4136 907-440-0835 (Cell) From: Bajsarowicz, Caroline J Sent: Thursday, January 07, 2016 2:16 PM To: Davies, Stephen F (DOA) Cc: Richmond, Diane M; Schwartz, Guy L (DOA) Subject: RE: Mechanical Log Waiver Request Steve - Thank you for the advice. I will add this in to the first sentence. "BP Exploration (Alaska) Inc., as the Operator of the Prudhoe Bay Unit, respectfully requests that the Commission administratively waive the requirement for filing of mechanical logs in any format under 20 AAC 25.071." Thank you again, Caroline Bajsarowicz From: Davies, Stephen F (DOA)[mailto:steve.davies@alaska.govl Sent: Thursday, January 07, 2016 2:12 PM To: Bajsarowicz, Caroline J Cc: Richmond, Diane M; Schwartz, Guy L (DOA) Subject: RE: Mechanical Log Waiver Request Caroline, Please add this clarification to the text of BP's formal application letter. Thank you, Steve Davies AOGCC CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Bajsarowicz, Caroline J[mai Ito: Caroline.Bajsarowicz@bp.com] Sent: Thursday, January 07, 2016 2:07 PM To: Davies, Stephen F (DOA) Cc: Richmond, Diane M; Schwartz, Guy L (DOA) Subject: RE: Mechanical Log Waiver Request Steve - BP is requesting a waiver from filing mechanical logs in any format at this time. 1 0 Thank you for requesting the clarificoon and feel free to contact me if you have any further questions, Caroline Bajsarowicz From: Davies, Stephen F (DOA) [mailto:steve.davies@alaska.gov] Sent: Thursday, January 07, 2016 1:38 PM To: Bajsarowicz, Caroline J Cc: Richmond, Diane M; Schwartz, Guy L (DOA) Subject: RE: Mechanical Log Waiver Request Caroline, To be clear, is BP requesting a waiver from filing of only paper copies of mechanical logs, or is BP requesting a waiver for filing of mechanical logs in any format (digital data, electronic images—pdf, tif, and paper copies)? Thanks, Steve Davies AOGCC CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Bajsarowicz, Caroline J[mailto:Caroline.Bajsarowicz@bp.coml Sent: Thursday, January 07, 2016 11:54 AM To: Davies, Stephen F (DOA); Schwartz, Guy L (DOA) Cc: Richmond, Diane M Subject: Mechanical Log Waiver Request Dear Steve and Guy, Attached is a copy of the request BP is planning to make to waive the requirement for filing of mechanical logs. A formal letter to Cathy Foerster will be sent on Monday, but we wanted to give you the opportunity to review and provide any comments. Please feel free to call me if you have any questions. Thank you in advance, e u ihm y. J3apavcacm" BP Exploration (Alaska) Inc. (907) 564-4314 wk (907) 887-3383 cell RECEIVED JAN 12 2016 AMCC BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, AK 99519-6612 USA Main 907 564 5111 January 11, 2014 JC Cathy Foerster Commission Chair Alaska Oil & Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Re: Request for Administrative Waiver Filing of Mechanical Logs under 20 AAC 25.071 Dear Chair Foerster, BP Exploration (Alaska) Inc., as the Operator of the Prudhoe Bay Unit, respectfully requests that the Commission administratively waive the requirement for filing of mechanical logs in any format under 20 AAC 25.071. For this waiver request BP defines "mechanical logs" as: perforation records, jewelry logs, inflatable bridge plug records, tubing patch setting records, chemical tubing cut records, tubing puncher records, jet cutter record, pack off gas lift mandrel records, and leak detection logs. BP runs approximately 600-800 mechanical logs on wells in the Prudhoe Bay Unit each year. These mechanical logs consist of a significant amount of both paper and electronic data, but do not significantly add to the geologic knowledge of the area in light of other logs and records that BP is already filing with the Commission for unit wells. BP respectfully asserts that providing mechanical logs to the Commission benefits neither the Commission nor the public. However, this filing requirement does impose a significant administrative burden on the Prudhoe Bay Unit operator and increases the cost of unit operations. We therefore respectfully request that, pursuant to 20 AAC 25.071 (c), the Commission grant an administrative waiver of the requirement to file mechanical logs with the Commission. Request for AOGCC AAstrative Waiver 01/11/16 Page 2 Please direct any questions you may have to the undersigned or to Caroline Bajsarowicz at 907-564-4314, Caroline.Bajsarowicz@bp.com. Sincerely, Diane Richmond Performance Management Lead / Compliance Representative Alaska Reservoir Development, BPXA (907) 564-4136 cc: Steve Davies, AOGCC Senior Petroleum Geologist Guy Schwartz, AOGCC Senior Petroleum Engineer Chris Tzvetcoff, BP GWO Joe Lastufka, BP GWO David Douglas, BP PDC Chris Wyatt, BP Legal