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Home My WebLink AboutAIO 017 AAREA INJECTION ORDER 17A Docket Number: AIO -18-044 Badami Oil Pool 1. November 15, 2018 Savant Alaska Inc. request to Modify AIO 17, Well B1-14 and Email from Glacier Oil 2. November 20, 2018 Notice of hearing, affidavit of publication, email distribution, mailings STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: The APPLICATION OF Savant ) Docket Number: AIO-18-044 Alaska, LLC (Savant) for an amendment to ) Area Injection Order No. 17A Area Injection Order No. 17 to allow the ) Badami Oil Pool B1-14 well to be used for gas injection or ) Badami Unit withdrawal as operational conditions dictate ) March 20, 2019 IT APPEARING THAT: 1. By letter dated November 15, 2018, Savant requested the Alaska Oil and Gas Conservation Commission (AOGCC) amend Area Injection Order No. 17 (AIO 17) to allow the Badami B1-14 well (B1-14) (Permit to Drill No. 198-063) to be used for the injection of gas for enhanced oil recovery (EOR) purposes and/or for the production of gas to provide fuel gas for the Badami Field as operational conditions dictate. 2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for December 17, 2018. On November 19, 2018, 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 November 20, 2018, the AOGCC published the notice in the ANCHORAGE DAILY NEWS. 3. No comments or request for hearing were received regarding Savant's application. 4. On December 17, 2018, the tentatively scheduled hearing was vacated. 5. Savant's application provided sufficient information upon which to make an informed decision. FINDINGS: 1. Produced gas from the Badami Unit (BU) is used as fuel for lease and plant operations and any excess gas is injected in the Badami Oil Pool for EOR. The BU B1-21 well is the only well used for EOR gas injection. 2. If gas production is not sufficient to meet the lease and plant fuel gas needs, Savant must purchase gas from the Duck Island Unit (DIU) to compensate for the shortfall in gas production. 3. Gas purchased from DIU is high in hydrogen sulfide content, which is corrosive and may damage equipment at Badami. Area Injection Order No. 17A Badami Oil Pool March 20, 2019 Page 2 B1-14 was previously used as an EOR gas injection well, but for the past five plus years it has been used exclusively to produce fuel gas on an as -needed basis. Savant proposes B1-14 continue to produce fuel gas on an as -needed basis, and also be authorized for use as an EOR gas injector to meet field demands. CONCLUSIONS: 1. The Badami Oil Field currently relies on a single EOR gas injection well, BU BI - 21. A problem with that well would cause production shut-in or necessitate flaring a significant amount of gas until repair could be made or another well could be converted to gas injection. 2. Allowing B1-14 to produce gas when needed to meet BU fuel gas needs or to act as an EOR gas injector when extra injection capacity is needed (i.e., a "Swing Well") will benefit resource recovery by reducing risk and allowing operational flexibility. 3. Converting B1-14 from gas producer to a revised status of "gas injector" is necessary in order to place the well on the mechanical integrity testing schedule. NOW, THEREFORE, IT IS ORDERED THAT Area Injection Order No. 17 is rescinded and its record incorporated by reference into this order. The underground injection of fluids for pressure maintenance and enhanced recovery is authorized in the following area, subject to the following rules and 20 AAC 25, to the extent not superseded by these rules: UMIAT MERIDIAN T9N R19E Section 1. T9N R20E Sections 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 14, 15, 16, 17. TION R19E Sections 24, 25 and 36. TION R20E Sections 19, 29, 30, 31, 32, 33, 34, and 35. Rule 1 Authorized Iniection Strata for Enhanced Recovery (Restated from AIO 17) Within the affected area, fluids may be injected for purposes of pressure maintenance and enhanced recovery into strata defined as those which correlate with and are common to those found in the Badami #1 well between the measured depths of 9,500 feet and 11,500 feet as stated in Conservation Order 402. Rule 2 Fluid Iniection Wells (Restated from AIO 17) 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. Area Injection Order No. 17A Badami Oil Pool March 20, 2019 Page 3 Rule 3 Authorized Fluids for Infection for Enhanced Recovery (New this order) Fluids authorized for injection are: a. Produced gas from the BU and DIU; b. Source and produced water from the BU; c. Fluids preapproved for use during hydraulic stimulation; d. Tracer survey fluids to monitor reservoir performance; e. Fluids used to improve near wellbore injectivity; f. Fluids used to seal wellbore intervals which negatively impact recovery efficiency; g. Fluids associated with freeze protection; and h. Standard oilfield chemicals. Rule 4 Monitoring the Tubing -Casing Annulus Pressure Variations (Modified and renumbered this order) Inner annulus, outer annulus, and tubing pressures shall be monitored and recorded at least weekly, except if prevented by extreme weather condition, emergency situation, or similar unavoidable circumstances for all injection and production wells. Each injection well must be checked at least weekly to ensure there is no leakage and that it does not exceed a pressure that will subject the casing to a hoop stress greater than 70% of the casing's minimum yield strength. Rule 5 Demonstration of Tubing -Casing Annulus Mechanical Integrity (Modified this order The mechanical integrity of each injection well must be demonstrated before injection begins and before returning a well to service following any workover affecting mechanical integrity. An AOGCC-witnessed mechanical integrity test (MIT) 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. The AOGCC must be notified at least 24 hours in advance to enable a representative to witness an MIT. Unless an alternate means is approved by the AOGCC, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1,500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, but not to exceed a hoop stress greater than 70% of the minimum yield strength of the casing to be used. The test must show a stabilizing pressure and does not change more than 10 percent during a 30 -minute period. Results of MITs must be readily available for AOGCC inspection. Area Injection Order No. 17A Page 4 Badami Oil Pool March 20, 2019 Rule 6 Well Integrity Failure and Confinement (Modified this order) The Operator shall immediately shut in the well if continued operation would be unsafe or threaten contamination of freshwater. If fluids are found to be fracturing through a confining interval or migrating out of the approved injection stratum, the operator must immediately shut in the well. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. Injection may not be restarted until approved by the AOGCC. Whenever any pressure communication or leakage is indicated by an injection rate, operating pressure observation, test, survey, log, or any 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. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC if the well indicates any well integrity failure or lack of injection zone isolation. The AOGCC may immediately suspend, revoke, or modify this authorization if injected fluids fail to be confined to the approved injection interval. Rule 7 Plugging and Abandonment of Iniection Wells (Restated from AIO 17) An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission. Well abandonment must be done in accordance with 20 AAC 25.105. Rule 8 Swing Wells (New this order) The operator must submit an Application for Sundry Approvals (Form 10-403) to convert the status of the BU B1-14 well from a gas producer to a gas injector. The well shall remain classified as a gas injector for as long as the well remains in use as a swing well. The operator must comply with all mechanical integrity testing and monitoring requirements stated above even if the well is not being regularly used for injection purposes. Additional swing wells may be authorized, at the AOGCC's sole discretion, via administrative approval. Rule 9 Badami Oil Pool Annual Reservoir Report (Restated from AIO 17) An annual Badami Oil Pool surveillance report is required by April 1 of each year after commencement of enhanced oil recovery operations. The report shall include but is not limited to the following: a. Progress of the enhanced recovery project and reservoir management summary including engineering and geological parameters. b. Voidage balance by month of produced fluids and injected fluids. C. Analysis of reservoir pressure surveys within the pool. d. Results and where appropriate, analysis of production and injection logs, tracer surveys and observation well surveys. e. Results of any special monitoring. f Evaluation of well testing and allocation. Area Injection Order No. 17A Page 5 Badami Oil Pool March 20, 2019 g. Future development plans. h. Review of Annual Plan of Operations and Development. Rule 10 Notification of Improver Class II Iniection (New this order) Injection of fluids other than those listed in Rule 3 without prior authorization is improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. This requirement is in addition to and does not relieve the operator of any other obligations under the notification requirements of any other State or Federal agency, regulation or law. Rule 11 Administrative Action (Modified and renumbered this order) Upon proper application, or its own motion, and unless notice and public hearing are otherwise required, the AOGCC may administratively waive the requirements of any rule stated herein or administratively amend this order 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. DONE at Anchorage, Alaska and dated March 20, 2019. Daniel T. eamount, Jr. Je e L. Chmielowski Commissioner missioner As provided in AS 3I.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 oftime 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. STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: The APPLICATION OF Savant ) Docket Number: AIO-18-044 Alaska, LLC (Savant) for an amendment to ) Area Injection Order No. 17A Area Injection Order No. 17 to allow the ) Badami Oil Pool B1-14 well to be used for gas injection or ) Badami Unit withdrawal as operational conditions dictate ) March 20, 2019 IT APPEARING THAT: By letter dated November 15, 2018, Savant requested the Alaska Oil and Gas Conservation Commission (AOGCC) amend Area Injection Order No. 17 (AIO 17) to allow the Badami B1-14 well (B1-14) (Permit to Drill No. 198-063) to be used for the injection of gas for enhanced oil recovery (EOR) purposes and/or for the production of gas to provide fuel gas for the Badami Field as operational conditions dictate. 2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for December 17, 2018. On November 19, 2018, 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 November 20, 2018, the AOGCC published the notice in the ANCHORAGE DAILY NEWS. 3. No comments or request for hearing were received regarding Savant's application. 4. On December 17, 2018, the tentatively scheduled hearing was vacated. 5. Savant's application provided sufficient information upon which to make an informed decision. FINDINGS: 1. Produced gas from the Badami Unit (BU) is used as fuel for lease and plant operations and any excess gas is injected in the Badami Oil Pool for EOR. The BU B1-21 well is the only well used for EOR gas injection. 2. If gas production is not sufficient to meet the lease and plant fuel gas needs, Savant must purchase gas from the Duck Island Unit (DIU) to compensate for the shortfall in gas production. 3. Gas purchased from DIU is high in hydrogen sulfide content, which is corrosive and may damage equipment at Badami. Area Injection Order No. 17A Badami Oil Pool March 20, 2019 Page 2 4. BI -14 was previously used as an EOR gas injection well, but for the past five plus years it has been used exclusively to produce fuel gas on an as -needed basis. Savant proposes B1-14 continue to produce fuel gas on an as -needed basis, and also be authorized for use as an EOR gas injector to meet field demands. CONCLUSIONS: 1. The Badami Oil Field currently relies on a single EOR gas injection well, BU Bl - 21. A problem with that well would cause production shut-in or necessitate flaring a significant amount of gas until repair could be made or another well could be converted to gas injection. 2. Allowing B1-14 to produce gas when needed to meet BU fuel gas needs or to act as an EOR gas injector when extra injection capacity is needed (i.e., a "Swing Well") will benefit resource recovery by reducing risk and allowing operational flexibility. 3. Converting B1-14 from gas producer to a revised status of "gas injector" is necessary in order to place the well on the mechanical integrity testing schedule. NOW, THEREFORE, IT IS ORDERED THAT Area Injection Order No. 17 is rescinded and its record incorporated by reference into this order. The underground injection of fluids for pressure maintenance and enhanced recovery is authorized in the following area, subject to the following rules and 20 AAC 25, to the extent not superseded by these rules: UMIAT MERIDIAN T9N R19E Section 1. T9N R20E Sections 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 14, 15, 16, 17. TION R19E Sections 24, 25 and 36. TION R20E Sections 19, 29, 30, 31, 32, 33, 34, and 35. Rule 1 Authorized Iniection Strata for Enhanced Recovery (Restated from AIO 17) Within the affected area, fluids may be injected for purposes of pressure maintenance and enhanced recovery into strata defined as those which correlate with and are common to those found in the Badami #1 well between the measured depths of 9,500 feet and 11,500 feet as stated in Conservation Order 402. Rule 2 Fluid Iniection Wells (Restated from AIO 17) 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. Area Injection Order No. 17A Badami Oil Pool March 20, 2019 Page 3 Rule 3 Authorized Fluids for Infection for Enhanced Recovery (New this order) Fluids authorized for injection are: a. Produced gas from the BU and DIU; b. Source and produced water from the BU; C. Fluids preapproved for use during hydraulic stimulation; d. Tracer survey fluids to monitor reservoir performance; e. Fluids used to improve near wellbore injectivity; f. Fluids used to seal wellbore intervals which negatively impact recovery efficiency; g. Fluids associated with freeze protection; and h. Standard oilfield chemicals. Rule 4 Monitoring the Tubine-Casing Annulus Pressure Variations (Modified and renumbered this order) Inner annulus, outer annulus, and tubing pressures shall be monitored and recorded at least weekly, except if prevented by extreme weather condition, emergency situation, or similar unavoidable circumstances for all injection and production wells. Each injection well must be checked at least weekly to ensure there is no leakage and that it does not exceed a pressure that will subject the casing to a hoop stress greater than 70% of the casing's minimum yield strength. Rule 5 Demonstration of Tubing -Casing Annulus Mechanical Integrity (Modified this order) The mechanical integrity of each injection well must be demonstrated before injection begins and before returning a well to service following any workover affecting mechanical integrity. An AOGCC-witnessed mechanical integrity test (MIT) 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. The AOGCC must be notified at least 24 hours in advance to enable a representative to witness an MIT. Unless an alternate means is approved by the AOGCC, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1,500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, but not to exceed a hoop stress greater than 70% of the minimum yield strength of the casing to be used. The test must show a stabilizing pressure and does not change more than 10 percent during a 30 -minute period. Results of MITs must be readily available for AOGCC inspection. Area Injection Order No. 17A Page 4 Badami Oil Pool March 20, 2019 Rule 6 Well Integrity Failure and Confinement (Modified this order) The Operator shall immediately shut in the well if continued operation would be unsafe or threaten contamination of freshwater. If fluids are found to be fracturing through a confining interval or migrating out of the approved injection stratum, the operator must immediately shut in the well. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. Injection may not be restarted until approved by the AOGCC. Whenever any pressure communication or leakage is indicated by an injection rate, operating pressure observation, test, survey, log, or any 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. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC if the well indicates any well integrity failure or lack of injection zone isolation. The AOGCC may immediately suspend, revoke, or modify this authorization if injected fluids fail to be confined to the approved injection interval. Rule 7 Plugging and Abandonment of Iniection Wells (Restated from AIO 17) An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission. Well abandonment must be done in accordance with 20 AAC 25.105. _Rule 8 Swing Wells (New this order) The operator must submit an Application for Sundry Approvals (Form 10-403) to convert the status of the BU BI -14 well from a gas producer to a gas injector. The well shall remain classified as a gas injector for as long as the well remains in use as a swing well. The operator must comply with all mechanical integrity testing and monitoring requirements stated above even if the well is not being regularly used for injection purposes. Additional swing wells maybe authorized, at the AOGCC's sole discretion, via administrative approval. Rule 9 Badami Oil Pool Annual Reservoir Report (Restated from AIO 171 An annual Badami Oil Pool surveillance report is required by April 1 of each year after commencement of enhanced oil recovery operations. The report shall include but is not limited to the following: a. Progress of the enhanced recovery project and reservoir management summary including engineering and geological parameters. b. Voidage balance by month of produced fluids and injected fluids. C. Analysis of reservoir pressure surveys within the pool. d. Results and where appropriate, analysis of production and injection logs, tracer surveys and observation well surveys. e. Results of any special monitoring. f. Evaluation of well testing and allocation. Area Injection Order No. 17A Page 5 Badami Oil Pool March 20, 2019 g. Future development plans. It. Review of Annual Plan of Operations and Development Rule 10 Notification of Improper Class II Infection (New this order) Injection of fluids other than those listed in Rule 3 without prior authorization is improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. This requirement is in addition to and does not relieve the operator of any other obligations under the notification requirements of any other State or Federal agency, regulation or law. Rule 11 Administrative Action (Modified and renumbered this order) Upon proper application, or its own motion, and unless notice and public hearing are otherwise required, the AOGCC may administratively waive the requirements of any rule stated herein or administratively amend this order 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. DONE at Anchorage, Alaska and dated March 20, 2019. //signature on file// //signature on file// Daniel T. Seamount, Jr. Jessie L. Chmielowski Commissioner Commissioner 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. Ifthe 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. Bernie Karl K&K Recycling Inc. Gordon Severson Penny Vadla P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave. Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 2 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: AIO-18-044 Badami Unit, Badami Lisburne Oil Pool The application of Savant Alaska, LLC. (Savant) to amend Area Injection Order No. 17 (AIO 17) to allow the Badami Unit B1-14 (BU B1-14) well to be used as a dual purpose well. Savant, by letter dated November 15, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend AIO 17 to allow the BU B1-14 well to be used either as an enhanced oil recovery gas injection well or as a gas source well for Badami Unit operations based on the amount of gas available under the current operations. The AOGCC has tentatively scheduled a public hearing on this application for December 27, 2018, at 10:00 a.m. at 333 West 7th 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 December 7, 2018. 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 December 10, 2018. 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 December 21, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 27, 2018 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 December 24, 2018. Hollis S. French Chair, Commissioner Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: AIO-18-044 Badami Unit, Badami Lisburne Oil Pool The application of Savant Alaska, LLC. (Savant) to amend Area Injection Order No. 17 (AIO 17) to allow the Badami Unit B1-14 (BU B1-14) well to be used as a dual purpose well. Savant, by letter dated November 15, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend AIO 17 to allow the BU B1-14 well to be used either as an enhanced oil recovery gas injection well or as a gas source well for Badami Unit operations based on the amount of gas available under the current operations. The AOGCC has tentatively scheduled a public hearing on this application for December 27, 2018, at 10:00 a.m. at 333 West 7`" 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 December 7, 2018. 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 December 10, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7h Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 21, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 27, 2018 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 December 24, 2018. //signature on file// Hollis S. French Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT INVOICE SHOW G ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION WITH ATTACHED COPY OF ADVERTISMENT. ADVERTISING ORDER NUMBER 1 AO-19-016 FROM: AGENCY CONTACT: Jody Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OF A.O.AGENCY PHONE: 333 West 7th Avenue 11/19/2018 907 279-1433 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: (907) 276-7542 TO PUBLISHER: Anchorage Daily News, LLC SPECIAL INSTRUCTIONS: PO Box 140147 Anchorage, Alaska 99514-0174 TYPE OF ADVERTISEMENT: r LEGAL f— DISPLAY W CLASSIFIED F OTHER (Specify below) DESCRIPTION PRICE AIO-I8-044 Initials of who prepared AO: Alaska Non -Taxable 92-600185 :ORMT100a $H03Yj .t; APvxknsili?G: :'::OItUE,R Nti�(.YR'1'iF1EIf p;FCIUAYIfbP:::: PUBtICAT{ON:WITH n.1Twc"0to)-voP:' AOGCC 333 West 7th Avenue Anchorage, Alaska 99501 Pae 1 of 1 Total of All Pa es $ REF Type Number Amount Dem Comments I PVN VCO21795 z All IAO-19-016 3 a FIN AMOUNT SY Act. Templet, PGM LGR Object FY I DIST LIQ I 19 1 A14110-0--F 3046 19 2 3 5 Pareha e ATitle: Purehasing Authority's Signature Telephone Number . A receiving agency name must appear an all invoices and documents relating to this purchase. 2. T e late is registered far tar free transactions under Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the stale and not for resat Drvumn Flsc$UQngmaFAQ -..... Coples Publisher (fazedk:Drvulbn Iilscs1 R Form: 02-901 Revised: 11/19/2018 Bernie Karl Gordon Severson Penny Vadla K&K Recycling Inc. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 58055 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Fairbanks, AK 99711 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 ANCHORAGE Max NEANTS AFFIDAVIT OF PUBLICATION Account#: 270227 ST OFAK/AK OILAND GAS Order# 0001430724 Product ADN -Anchorage Daily News CONSERVATION COMMISSION Cost $234.08 Placement 0300 333 WEST 7TH AVE STE 100 Position 0301 enirunwarc erooSmasgo STATE OF ALASKA THIRD JUDICIAL DISTRICT Sarah Jennett being first duly sworn on oath deposes and says that he/she is a representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on November 20, 2018 and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in a cess of the rate chad private individuals. Signed Subsy`ribed and swam to bef,6(e me this 20th day of November, 2018 Notary Pj-ic n and for The Stateb Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES "7 - STATE OF I ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: AIO-18-044 Theaappl cationo Of I Savant eAlalska I LLC. (Savant) to amentl Area Injection Order N0, 17 (AID 17) t0 allow the Badami Unit 81-14 (SU 81-14) well t0 be Used as a dual purpose well. Savant, by letter dated November 15, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend AID 17 to allow the BU 81-14 well to be Used either as an enhanced oil recovery gas injection well or as a gas source well for Badami Unit operations based on the amount of gas available under the current operations. The AOGCC has tentatively scheduled a public hearin$W on this Avelnue,10n for Decernber27, AnCh0 aBe, Alaska 099501 10:00To request 3that t the tentatively scheduled hearing be held, a written request must be filed with the AOGCC 2015. no later than 4:30 P.M. on December 7, If a request for a hearing is not timely filed the AOGCC may consider the issuance of an order without a hearing. To learn (f the AOGCC will hold the hearing, Call (907) 793-1221 after December 10, 2018. 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 Omments December received ono later than the conclusionsof the December 27, 2018 hearing. If, because of a disability, special accommodations may be e AOGCC'S Spec all Assistant, Jody Colombia, at 07) 793-122mment or attend the hearin& 1, not ter than December 24, 2018. 2018 //signature on file// Hollfs S. French Chair, Commissioner BRIiNEY l Stale o1 (vies .- 201. eb 2 My Commission `X4^-�=.:i 1 GLACIER November 15, 2018 Commissioner Hollis French Alaska Oil & Gas Conservation Commission 333 W. 7`" Avenue, Suite 100 Anchorage, AK 99501 RE: Badami Unit, Well B1-14 Modification of Area Injection Order No. 17 Dear Commissioner French, RECEIVED NOV 19 2018 AOGCC Savant Alaska, LLC a Glacier Oil & Gas Corporation company (GLA), requests an amendment to Area Injection Order No. 17, dated August 26, 1998. The amendment is to include use of well B 1-14 for injection of excess natural gas into the Badami Oil Pool and also as a withdrawal well for the same gas to be used as fuel in the conduct of lease and plant operations. Excess gas produced from the Badami Oil Pool is and has been utilized for lease and plant use since the start of production operations. There is no separate natural gas accumulation in the Badami Oil Pool and the needed gas, as fuel gas for lease and plant, is recovered during oil production and utilized for production operations. There are periods when there is excess gas production and to avoid flaring, reinjection of the excess gas back into the oil pool for future use and reservoir support is the optimal use of this resource. None of the gas injected or produced back will be sent for sales. The addition of well B1-14 as a dual-purpose gas injection or gas production well will enhance and support production operations. Ultimately, this modification will assist with maximizing ultimate oil recovery and avoid waste in the Badami Field. The well is already configured to be operated in this capacity without a workover operation. If additional information is required to complete this action please contact our consulting Landman, Chick Underwood, at 907.433.3811 or by email at cunderwoodPglacieroil com. Respectfully, !r"�eR.orris / COO, Savant Alaska, LLC (GLA) Ro_ by, David S (DOA) From: Roby, David S (DOA) Sent: Thursday, November 15, 2018 2:22 PM To: 'George Morris' Subject: RE: Badami 61 14 Letter grm George, The letter looks good. Go ahead and formally submit it. I'll get a docket file started so we can get this noticed as soon as possible after we receive the letter. Regards, Dave Roby 907-793-1232 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 Dave Roby at 907- 793-1232 or dave.robv(a alaska.eov. From: George Morris <gmorris@glacieroil.com> Sent: Thursday, November 15, 2018 1:21 PM To: Roby, David S (DOA) <dave.roby@alaska.gov> Subject: RE: Badami 131 14 Letter grm David Please see the attached draft. I have made the two changed you recommended. Below you will find a detailed answer to your other questions. Let me know your thoughts. From: Roby, David 5 (DOA) <dave.roby@alaska.gov> Sent: Thursday, November 15, 2018 9:54 AM To: George Morris <gmorris@giacieroil.com> Subject: RE: Badami Bl 14 Letter grm Hi George, I have just a few comments. First, I'd get rid of the references to storage. They make it sound like we should be doing a storage injection order instead of amending an area injection order.[GRMj done Second, 1'd get rid of the first sentence in the last paragraph. We're going to announce it for possible hearing regardless of what you put in the letter and by you putting "a hearing is requested" it sounds like you want to have a hearing Which, if you want to have the hearing that's your right but if we don't have to have the hearing the process should go quicker since we have to provide for 30 days comment period but hearings are usually scheduled 40+ days out since we have to pick a date at least 30 days out that fits in our schedule.IGRMJ I spoke with our land man on this and he told me that one time he was scolded for not putting in the hearing request which is why he put it in there. At your direction I will take it out. If a hearing is requested we will of course be there. Finally, can you please put in a little more technical details. For example: - do you have an estimate of the ratio between the time you'd expect to be gas short and thus need to produce versus the amount of time you'd have excess gas and would be injecting? Can you provide a little more description on what types of events would trigger the need to produce gas? [6PM] I will answer your last two questions at one time. It is a little detailed and I am not sure how to put it in the letter requesting the amendment. Badami has 8 producing oil wells. The 81-07 is the only flowing well and the remaining 7 wells are all on gas lift. 81-07 gas lift installation is planned to occur in early December. At that time we will have 8 oil wells on gas lift. We also have a paraffin problem with the oil wells. We cut the wax on some wells every other day and on other wells it may be every 3rd or 4th day. Plus the entire facility runs on electric power generated by gas fired turbines. So as you can imagine we cycle and burn a lot of gas. For the most part we burn and use what we produce and produce a little supplement from 81 -14. When certain wells are shut in to cut wax there could be a time when we have a surplus of gas in the system and we want to inject it to save the gas for future use. Additionally from time to time the system is interrupted and may stall or go completely down. For startup purposes we then call on our gas sources for startup fuel. On top of all this we do have a gas line from Endicott however that gas is pretty dirty and can cause more problems than good if we have to use too much of it. This gas source is our last resort. All of that said there is no real pattern to predict for production vs injection. We want to keep ourselves in the position to capture all of our gas for lease use and prevent flaring any. George Regards, Dave Roby 907-793-1232 CONFIDENTIALITY NOTICE. This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (ACG CC), 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 Dave Roby at 907- 793-1232 or dave.robyE2alaska zov. 2 From: George Morris <gmorris@glacieroil.com> Sent: Thursday, November 15, 2018 8:43 AM To: Roby, David S (DOA) <dave.robv@alaska.gov> Subject: Badami Bl 14 Letter grm Dave Please see the attached draft letter to Commissioner French regarding the Bi -14 well that we discussed on the phone yesterday. Feel free to comment or edit as you see fit. Thank you for your help. George Morris