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Home My WebLink AboutDIO 004 INDEX DISPOSAL INJECTION ORDER NO 4 Beaver Creek Field 1. May 12, 1987 2. May 15, 1987 3. July 1, 1996 4. July 8, 1996 5. October 7, 1999 6. October 22 1999 7. June 1, 1987 8. September 27, 2004 Marathons Application for Underground Injection Notice of Hearing and Affidavit of Publication Marathons request for clarification AOGCC response to 7/1/961tr Marathon's ltr to BLM re: Authorization to inject the wolf Lake Development area into Beaver Creek Unit injection/disposal wells AOGCC's ltr re Marathon's Authorization to inject the wolf Lake Development area into Beaver Creek Unit injection/disposal wells AOGCC response to Marathon request of 10/7/1999 Proposal to amend underground injection order Disposal Injection Order 4 ~$ 1 dl i ( f FRANK H. MURKOWSKI, GOVERNOR AIr-AN OIL AND GALS 333 W. 7O1AVENUE, SUITE 1GO CONSERVATION COMUSSION ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (90n 27&7542 September 27, 2004 Proposals to Amend Underground Injection Orders to Incorporate Consistent Language Addressing the Mechanical Integrity of Wells The Alaska Oil and Gas Conservation Commission ("Commission"), on its own motion, proposes to amend the rules addressing mechanical integrity of wells in all existing area injection orders, storage injection orders, enhanced recovery injection orders, and disposal injection orders. There are numerous different versions of wording used for each of the rules that create confusion and inconsistent implementation of well integrity requirements for injection wells when pressure communication or leakage is indicated. In several injection orders, there are no rules addressing requirements for notification and well disposition when a well integrity failure is identified. Wording used for the administrative approval rule in injection orders is similarly inconsistent. The Commission proposes these three rules as replacements in all injection orders: Demonstration of Mechanical Inte rity The mechanical integrity of an injection well must be demonstrated before injection begins, at least once every four years thereafter (except at least once every two years in the case of a slurry injection well), and before returning a well to service following a workover affecting mechanical integrity. Unless an alternate means is approved by the Commission, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 minute period. The Commission must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Well Integrity Failure and Confinement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall immediately notify the Commission and submit a plan of corrective action on a Form 10-403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. • • Administrative Actions Unless notice and public hearing is otherwise required, the Commission may administratively waive or amend any rule stated above 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 fluid movement outside of the authorized injection zone. The following table identifies the specific rules affected by the rewrite. Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Integrity" Confinement" Area Injection Orders AIO 1 -Duck Island Unit 6 7 9 AIO 2B - Kupanxk River Unit; Kuparuk River, Tabasco, Ugnu, West Sak 6 ~ 9 Fields AIO 3 -Prudhoe Bay Unit; Western Operating Area 6 ~ 9 AIO 4C -Prudhoe Bay Unit; Eastern Operating Area 6 ~ 9 AIO 5 -Trading Bay Unit; McArthur River Field 6 6 9 AIO 6 -Granite Point Field; Northern Portion 6 ~ 9 AIO 7 -Middle Ground Shoal; Northern Portion 6 ~ 9 AIO 8 -Middle Ground Shoal; Southern Portion 6 ~ 9 AIO 9 -Middle Ground .Shoal; Central Portion 6 ~ 9 AIO l OB -Milne Point Unit; Schrader Bluff, Sag River, 4 5 8 Kuparuk River Pools AIO 11 -Granite Point Field; Southern Portion 5 6 8 AIO 12 -Trading Bay Field; Southern Portion 5 6 8 AIO 13A -Swanson River Unit 6 ~ 9 AIO 14A -Prudhoe Bay Unit; Niakuk Oil Pool 4 5 8 AIO 15 -West McArthur 5 6 9 • • Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Inte 'ty" Confinement" River Unit AIO 16 - Kuparuk River Unit; Tarn Oil Pool 6 7 10 AIO 17 - Badami Unit 5 6 8 AIO 18A -Colville River Unit; Alpine Oil Pool 6 7 11 AIO 19 -Duck Is~,and Unit; Eider Oil Pool 5 6 9 AIO 20 -Prudhoe Bay Unit; Midnight Sun Oil Pool 5 6 9 AIO 21 - Kuparuk River Unit; Meltwater Oil Pool 4 No rule 6 AIO 22C -Prudhoe Bay Unit; Aurora Oil Pool 5 No rule 8 AIO 23 - Northstar Unit 5 6 9 AIO 24 -Prudhoe Bay Unit; Borealis Oil Pool 5 No rule 9 AIO 25 -Prudhoe Bay Unit; Polaris Oil Pool 6 g 13 AIO 26 -Prudhoe Bay Unit; Orion Oil Pool 6 No rule 13 Dis osal In'ection Orders DIO 1 -Kenai Unit; KU WD-1 No rule No rule No rule DIO 2 -Kenai Unit; KU 14- 4 No rule No rule No rule DIO 3 -Beluga River Gas Field; BR WD-1 No rule No rule No rule DIO 4 -Beaver Creek Unit; BC-2 No rule No rule No rule DIO 5 -Barrow Gas Field; South Barrow #5 No rule No rule No rule DIO 6 -Lewis River Gas Field; WD-1 No rule No rule 3 DIO 7 -West McArthur River Unit; WMRU D-1 2 3 5 DIO 8 -Beaver Creek Unit; BC-3 2 3 5 DIO 9 -Kenai Unit; KU 11- 17 2 3 4 DIO 10 -- Granite Point Field; GP 44-11 2 3 5 Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Integrity" Confinement" DIO 11 -Kenai Unit; KU 24-7 2 3 4 DIO 12 - Badami Unit; WD- 1, WD-2 2 3 5 DIO 13 -North Trading Bay Unit; S-4 2 3 6 DIO 14 -Houston Gas Field; Well #3 2 3 5 DIO 15 -North Trading Bay Unit; S-5 2 3 Rule not numbered DIO 16 -West McArthur River Unit; WMRU 4D 2 3 5 DIO 17 -North Cook Inlet Unit; NCIU A-12 2 3 6 DIO 19 -Granite Point Field; W. Granite Point State 3 4 6 17587 #3 DIO 20 -Pioneer Unit; Well 1702-15DA WDW 3 4 6 DIO 21 - Flaxman Island; Alaska State A-Z 3 4 7 DIO 22 -Redoubt Unit; RU D1 3 No rule 6 DIO 23 -Ivan River Unit; IRU 14-31 No rule No rule 6 DIO 24 - Nicolai Creek Unit; NCU #5 Order expired DIO 25 -Sterling Unit; SU 43-9 3 4 7 DIO 26 - Kustatan Field; KF 1 3 4 7 Storage Injection Orders SIO 1 -Prudhoe Bay Unit, Point McIntyre Field #6 No rule No rule No rule SI0 2A- Swanson River Unit; KGSF # 1 2 No rule 6 SIO 3 -Swanson River Unit; KGSF #2 2 No rule ? Enhanced Recove In'ection Orders EIO 1 -Prudhoe Bay Unit; Prudhoe Bay Field, Schrader No rule No rule 8 Bluff Formation Well V-105 • • Affected Rules Injection Order "Demonstration of "Well Integrity "Administrative Mechanical Failure and Action" Integrity" Confinement" EIO 2 -Redoubt Unit; RU-6 5 g 9 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving Ao.FEt,v1 STATE OF ALASKA NOTICE TO PUBLISHER ADVERTISING ORDER NO. ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVE~ TISING ORDER NO., CERTIFIED A 002 S'1401 ~ ORDER AFFIDAVIT OF PUBLICATION PART 2 OF THIS FORM WITH ATTACHED COPY OF A ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE SEE BQTTOM FOR INVOrCE'ADDRESS F AOGCC AGENCY CONTACT DATE OF A.O. R 333 West 7`" Avenue, Suite 100 ° Anchorage, AK 99501 PHONE PC M 907-793-1221 DATES ADVERTISEMENT REQUIRED: o Journal of Commerce October 3, 2004 301 Arctic Slope Ave #350 Anchorage, AK 99518 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRL'CT[ONS: AFFIDAVIT OF PUBLICATION United states of America REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE. who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2004, and thereafter for consecutive days, the last publication appearing on the day of .2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2004, Notary public for state of MY commission expires Public Notices i C Subject: Public Notices From: Jody Colombe <jody colombie@admin.state.ak.us> Date: Wed, 29 Sep 2004 13:01:04 -0800 To: >undisclosed-recipients:; BCC'.: Cynthia B IVlciver ~bren mciver@adrnin.state.ak.us>, Angela Webb . <angie_webb@admin.state.ak.us>, Robert'E Mintz <robert_mintz(a;law.state.alc.us>, Christine Hansen ~c:hansen~u~iogcc.state.ok.us>, Terrie Hubble <hubbletl~bp.com%, Sondra Stewman <StewmaSL~@BPcorn>, Scott & Camn~y Taylor.<sta@~r~c~~alaska.net>, stanekj <stanekj@unocal.corn==, ecolaw <ecolaw@trustees.org>, roseragsdale <roseragsdalec~~gci.net>, trmjrl <trm~jrl@aol.com>, jbriddle <jbriddle@rnarathohoit.eom>, rockhill <rockhill cc~aoga.e~rg>, shaneg ' <shaneg@evergreengas.c:om>; jdarlington <jdarlington@forestoil.com=, nelson <knelson@petroleumne~~vs.corri>, cboddy <ebodd~'@ usiBelli.coin%, Mark Dalton . <mark.dalton@hdrinc.com>, Shannon Donnelly <Shannondormeily(a;,conocophillps:com>, "Mark P. Worcester" <mark.p.warcester@conocophilips.co~n>, "Jerry C. Dethlefs" <ferry.c.dethlefs@onocophillps.com>, Bob <b@@inletkeeper.org=>, ~vd~ <wd~~~Ldnr.state.ak.us>, tjr <tjr@dnr.state.ak.us>, bbriteh <bbritci~@alaska.net>, mjnelson <mjnelSOn(~purv~ingertz,corri>, Charles ODonnell`<charles.o'donnell@veco.com>, "Randy L. Sl:illern" <:SkilleRLc~LBP.eom>, "Deborah J. Jones" <JonesD6@BP.com>, "Paul G Hyatt" <hyattpg@BP.com>, "Steven R. Rassberg" <RossbeRS@BP.com>, Lois <lois@inletkeeper.org=, Dan Br@s ~~kuacnew~s(~i:kuac.org>, Gordon Paspisl <PospisG@BP.com>, "Francis S. Sommer" ~'SomtnerFSi'a BP.com?, l\"likel Schultz <Mik~l.Schultz@BP.com~, "Nick ~: Glo~~er" <Glo~erNW@~~BP.com=, "Daryl J. Kleppin" <KleppiDE@BP.eom>, "Janet D. Platt" <PIattJD@BP.eam->, "Rosanne M. Jacobsen" <JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, Collins l~~lount <eollins_maunt@revenue.state.ak.us>, mekay <mckay@gci.net=. Barbara F Fullmer <Barbara.f.fullmer@conocophillips.com>, bocastwf <bocastwf@p.com=>, Charles Barker <barker@sgs.gov>, doug_schultze <doug Schultze@taenerg~~.ct~m?, Hank Alford <hankalford@exxonmobil.com>, Mark Kovac <yesnof@gci.riot=~, gspfaff ~gspfoff@aurorap©wer.com=}, Gregg l~iady <greggnady(«shell.com>, Fred Steece <fred.steece@state.sd.ns>. rcrotty <rcrotty@ch2mcom>, jejones ~- jejone~ru?aurorapo~~ercom>, dapa dapa@alaska.net =, jroderick <jroderick@gei.net>, evancy <eyanc~ (ci%.seal-tite.net%, "James M. Ruud" <fames.m.ruudcci~conocophillips.eom>, Brit Li`ely <mapalaska(c~ak.net>, jal~ <jah@dnr.sta#e.ak.us= , Kurt E Olson <kurt olson@legis.state.ak.us=~, buonoje <buom~je~cc'bp.cc3m>, Mark Hanley <mark hanley@anadarko.com>, Loren. Leman `Lorenleman(~i:ga~ .state.ak.us °, Julie Houle <julieJhoule(~r.;dnr.state:ak.us>, John ViW Katz <jwkatz@sc~.org>, Suzal~ J Hill <suzan hill@dec.state.ak.us=~, tablerk <tablerk(c~unocal.com>, Brady <brady(%aoaa.org>, $rian Havelock <beh@dnr.state.ak.u5 ; Bpopp <Bpopp@borou@.kenai.ak.us%. Jim ~~'hite <jimw~ite@atx.rr.;com>, "John S. I-1aw~rth" <johh.s.haworth~:ex~onmobil.com=>, marry <marty@rkindustral.com>, ~hammons _@arnrnons(g-aol.com~, rmclean ~rmclean c poBoY.alaska.net=-, niknl?2()0 'mkm7?(?0(z:'aol.com~, Brian Gillespie <ifbmg(~iuaa:alaska.edu>, David L Boelens <dboclens(a~aurorapower.com>, Todd Durkee <TDLJRKEE(~I~ti1G.com=, Gary Schulte ~gary_s~;hultz~c'dnr.state.ak.us= , Wane Ranci~;r <RANCIER@petro-canada_ca=>, Bill Filler <Bill_?l~liller(aJxtoalaska_com >, Brandon Gagnon Cbga~non@brenalaw.com>, Paul Winslow- ~:prttwitlslo«~(~~:forestoil.com>, Garry Catron <cat:rongr@bp.com~=~, Sharmaine Copeland <copelasv@p.com>, Suzanne Alletan <salle~an(%helmener~~.com~, KristinDirks ~~kristin_dirks@.dnr.state.ak.us~, Kavnell Zeman. <k}zemanrc"i;;marathonoiLcom>, John Tower <Jottn.Tow~er@eia.doe.gov>, Bill Fowler <Bill_Fowler@anadarko.COM>, Vaughn Swartz <vaughn.swartz @ rbccm.com>, Scott Cranswick 1 of 2 9/29/2004 1:10 PM Public Notices ~ i <scott.cransvvick@mms.gov>; Brad McKim <mckimb@BP.com> Please find the a torched Notice and Attachment for the proposed amendment of underground, injection orders and the Public. Notice Happy Valley #1Q. Jody Colombie Content-Type: application,~msword 'Mechanical Integrity proposai.doc ,Content-Encodutg: base64 Ca~ntent-Type: application/msword l~Techanical Integrity of Wells Notice.doc 4 Content-Encodin : base6 g :Content-Type: applicationltnsword H appyV alleyl0_HearingNotice.doc Content-Encoding: base64 Public Notice i • Subject: Public Notice From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 29 Sep 2004 12:.55:26 -0800 To: legal@alaskaj ournal: co m Please publish the attached Notice on October 3, 2004. Thank you. Jody Colombie Content-Type: application/msword 'Mechanical Integrity of Wells Notice.doc' Content-Encoding: base64 _ _ _ __ Content-Type: application/msword '' ''Ad Order form.doc- Content-Encoding: base64 1 of 1 9/29/2004 1:10 PM • • ~: ~~~~ ~~~ Citgo Petroleum Corporation Mary Jones David McCaleb PO Box 3758 XTO Energy, Inc. IHS Energy Group Tulsa, OK 74136 Cartography GEPS 810 Houston Street, Ste 2000 5333 Westheimer, Ste 100 Ft. Worth, TX 76102-6298 Houston, TX 77056 Kelly Valadez Robert Gravely George Vaught, Jr. Tesoro Refining and Marketing Co. 7681 South Kit Carson Drive PO Box 13557 Supply & Distribution Littleton, CO 80122 Denver, CO 80201-3557 300 Concord Pfaza Drive San Antonio, TX 78216 Jerry Hodgden Richard Neahring John Levorsen Hodgden Oil Company NRG Associates 200 North 3rd Street, #1202 408 18th Street President Boise, ID 83702 Golden, CO 80401-2433 PO Box 1655 Colorado Springs, CO 80901 Kay Munger Samuel Van Vactor Michael Parks Munger Oil Information Service, Inc Economic Insight Inc. Marple's Business Newsletter PO Box 45738 3004 SW First Ave. 117 West Mercer St, Ste 200 Los Angeles, CA 90045-0738 Portland, OR 97201 Seattle, WA 98119-3960 I Mark Wedman Schlumberger David Cusato Halliburton Drilling and Measurements 200 West 34th PMB 411 6900 Arctic Blvd. 2525 Gambell Street #400 Anchorage, AK 99503 Anchorage, AK 99502 Anchorage, AK 99503 Baker Oil Tools Ciri Jill Schneider 4730 Business Park Blvd., #44 Land Department US Geological Survey Anchorage, AK 99503 PO Box 93330 4200 University Dr. Anchorage, AK 99503 Anchorage, AK 99508 Gordon Severson Jack Hakkila Darwin Waldsmith 3201 Westmar Cr. PO Box 190083 PO Box 39309 Anchorage, AK 99508-4336 Anchorage, AK 99519 Ninilchick, AK 99639 James Gibbs Kenai National Wildlife Refuge Penny Vadla PO Box 1597 Refuge Manager 399 West Riverview Avenue Soldotna, AK 99669 PO Box 2139 Soldotna, AK 99669-7714 Soldotna, AK 99669-2139 Richard Wagner Cliff Burglin Bernie Karl PO Box 60868 PO Box 70131 K&K Recycling Inc. Fairbanks, AK 99706 Fairbanks, AK 99707 PO Box 58055 Fairbanks, AK 99711 Williams Thomas North Slope Borough Arctic Slope Regional Corporation PO Box 69 Land Department Barrow, AK 99723 PO Box 129 Barrow, AK 99723 ` [Fwd: Re: Consistent Wording for Injection O'l'tsers -Well Integrity Subj;eet: [Fwd: Re: Consistent Wording for Injection Orders - From; John Norman <john_norrnan@admin.state.ak.us> Date: Fri; O1 Oct 2004 11:09:26 -0800 To: Jody J Colombie <jody colombie@admn.state.ak.us> more • well Integrity (Revised)];.. ------- Original Message -------- Subjeet:Re: Consistent Wording for Injection Orders -Well Integrity (Revised) Date:Wed, 25 Aug 2004 16:49:40 -0800 From:Rob Mintz <robert mintz(c~law.state.ak.us> To:jim regg(c~admin.state.ak.us CC:dan seamount(a~admin.state.ak.us, john norman(r,~,admin.state.ak.us Jim, looks good, but I still think maybe it would be good to include the following sentence or something like it in the well integrity and confinement rule: "The operator shall shut in the well if so directed by the Commission." My thinking is that otherwise, an operator might argue that the Commission can only require the well to be shut in by going through an enforcement action, issuing an order after notice and opportunity for hearing, or meeting the strict requirements for an emergency order under the regulations. The proposed language makes clear that it is a condition of the authorization to inject, that the operator must shut in the well if directed by the Commission after a notification of loss of integrity, etc. »> James Regg <jim regg~admin.state.ak.us> 8/25/2004 3:15:06 PM »> Rob -Thanks for the review; here's a redraft after considering your comments. I have accepted most of the suggested edits; also attached is response to questions you pose (responses are embedded in the comments, using brackets [JBR - ...] to set apart from your questions). Jim Regg Rob Mintz wrote: Jim, I have some questions about the draft language, which are shown as comments on the first document attached. Based on my current guesses about what the answers will be to my questions, I also have some suggested edits, which are shown as redlines on the second document attached. »> James Regg <jim reQ~(aadmin.state.ak.us> 8/17/2004 4:33:52 PM »> Please delete previous version (email sent 8/9/04); I found another inconsistency in the injection orders regarding well integrity that I have integrated into the proposed fix. Attached is a proposal for consistent language in our injection orders addressing 3 rules related to well integrity: - "Demonstration of Tubing/Casing Annulus Mechanical Integrity" - "Well Integrity Failure" - "Administrative Actions". This proposal includes input from all Sr. staff (except Jack). If you agree with the approach, I'll work with Jody to prepare the public notice. Main points - Demonstration of Tubing/Casing Annulus Mechanical Integrity - standardizes the wording used for mechanical integrity demonstrations, and establishes abililty to grant alternate methods (e.g., temp survey, logging, pressure monitoring in lieu of pressure testing 1 of 2 10/2/2004 4:07 PM [Fwd: Re: Consistent Wording for Injection ~rs -Well Integrity ... • - specific to AIO 2C for Kuparuk, there is wording that is more appropriately included in Well Integrity Failure (i.e., more frequent MITs when communication demonstrated) - establishes more frequent MIT schedule for slurry injection wells (every 2 yrs) which is consistent with our current practice (but not addressed in regulations) Well Integrity Failure - retitles to "Well Integrity Failure and Conftnement"; inserted language regarding injection zone integrity (see DIO 25 and 26) - consistent language regardless of type of injection (disposal, EOR, storage); - eliminates requirement for immediate shut in and secure; allows continued injection until Commission requires shut in if there is no threat to freshwater; - eliminates delay in notifying Commission after detect leakage or communication ("i.e., "immediately notify"}; - removes language about notifying "other state and federal" agencies; - requires submittal of corrective action plan via 10-403; - requires monthly report of daily injection rate and pressures (tubing and all casing annuli); this is a requirement we currently impose when notified of leak or pressure communication; - notice and action not restricted to leaks above casing shoe as stated in several DIOs Administrative Actions - adopts "Administrative Actions" title (earlier rules used "Administrative Relief'); -consistent language regardless of type of injection (disposal, EOR, storage); - uses "administratively waive or amend" in lieu of terms like "revise", "reissue", etc.; - adds geoscience to "sound engineering principles"; - language is more generic regarding fluid movement out of zone; existing versions mention varying combinations of protecting "freshwater", "aquifers", "USDWs"; "risk of fluid movement"; "fluid escape from disposal zone" Jim Regg John K. Norman <John Normanna,admin.state.us> Commissioner Alaska Oil & Gas Conservation Commission 2 of 2 10/2/2004 4:07 PM [Fwd: Re: Consistent Wording for Injection ~rs -Well Integrity ... Subject: [Fwd: Re Consistent Wordingfor Injection Orders - V4'ell Integrity (Revised}] From: John. Norman <john norxnan@admin.state.ak.us> Date.:. Fri, O1 Oct 2004 11:08:55 -0800 To Jody J Colombe <jody_colombeCadmin.state.ak.us> please print all and put in file for me to review just prior to hearing on these amendments. thanx ------- Original Message -------- Subject:Re: Consistent Wording for Injection Orders -Well Integrity (Revised) Date:Thu, 19 Aug 2004 15:46:31 -0800 From:Rob Mintz <robert mintz~law.state.ak.us> To:dan seamount(a~admin.state.ak.us, jim reggnaadmin.state.ak.us, john normanna,admin.state.ak.us Jim, I have some questions about the draft language, which are shown as comments on the first document attached. Based on my current guesses about what the answers will be to my questions, I also have some suggested edits, which are shown as redlines on the second document attached. »> James Regg <iim re~gtiiadmin.state.ak.us> 8/17/2004 4:33:52 PM »> Please delete previous version (email sent 8/9/04); I found another inconsistency in the injection orders regarding well integrity that I have integrated into the proposed fix. Attached is a proposal for consistent language in our injection orders addressing 3 rules related to well integrity: - "Demonstration of Tubing/Casing Annulus Mechanical Integrity" - "Well Integrity Failure" - "Administrative Actions". This proposal includes input from all Sr. staff (except Jack). If you agree with the approach, I'll work with Jody to prepare the public notice. Main points - Demonstration of Tubing/Casing Annulus Mechanical Integrity - standardizes the wording used for mechanical integrity demonstrations, and establishes abililty to grant alternate methods (e.g., temp survey, logging, pressure monitoring in lieu of pressure testing - specific to AIO 2C for Kuparuk, there is wording that is more appropriately included in Well Integrity Failure (i.e., more frequent MITs when communication demonstrated) - establishes more frequent MIT schedule for slurry injection wells (every 2 yrs) which is consistent with our current practice (but not addressed in regulations) Well Integrity Failure - retitles to "Well Integrity Failure and Confinement"; inserted language regarding injection zone integrity (see DIO 25 and 26) - consistent language regardless of type of injection (disposal, EOR, storage); - eliminates requirement for immediate shut in and secure; allows continued injection until Commission requires shut in if there is no threat to freshwater; - eliminates delay in notifying Commission after detect leakage or communication ("i.e., "immediately notify"); - removes language about notifying "other state and federal" agencies; - requires submittal of corrective action plan via 10-403; - requires monthly report of daily injection rate and pressures (tubing and all casing annuli); this is a requirement we currently impose when notified of teak or pressure communication; - notice and action not restricted to leaks above casing shoe as stated in several DIOs Administrative Actions 1 of 2 10/2/2004 4:07 PM [Fwd: Re: Consistent Wording for Injection ~rs -Well Integrity ... • - adopts "Administrative Actions" title (earlier rules used "Administrative Relief'); - consistent language regardless of type of injection (disposal, EOR, storage); - uses "administratively waive or amend" in lieu of terms like "revise", "reissue", etc.; - adds geoscience to "sound engineering principles"; - language is more generic regarding fluid movement out of zone; existing versions mention varying combinations of protecting "freshwater", "aquifers", "USDWs"; "risk of fluid movement"; "fluid escape from disposal zone" Jim Regg ''i' John K. Norman <John Normannaadmin.state.us> Commissioner '' Alaska Oil & .Gas Conservation Commission Content-Type: application/msword ;Injection Order language - questions.doc Content-Encoding: base64 Content-Type: application/msword ;Injection Orders language edits.doc Content-Encoding: base64 2 of 2 10/2/2004 4:07 PM • • Standardized Language for Injection Orders Date: August 17, 2004 Author: Jim Regg Demonstration of Tubing/Casing Annulus Mechanical Inte rity The mechanical integrity of an injection well must be demonstrated before injection begins, after a workover affecting mechanical integrity, and at least once every 4 years while actively injecting. For slurry injection wells, the tubing/casing annulus must be tested for mechanical integrity every 2 years. The MIT surface pressure must be 1500 psi or 0.25 psi/ft multiplied by the vertical depth, whichever is greater, must show stabilizing pressure and may not change more than 10% during a 30 minute period. Any alternate means of demonstrating mechanical integrity must be approved by the Commission. The Commission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. Well Inte rite Failure and Confinement The tubing, casing and packer of an injection well must demonstrate integrity during operation. The operator must immediately notify the Commission and submit a plan of corrective action on Form 10-403 for Commission approval whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, or log. If there is no threat to freshwater, injection may continue until the Commission requires the well to be shut in or secured. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for ail injection wells indicating pressure communication or leakage. Administrative Actions Unless notice and public hearing is otherwise required, the Commission may administratively waive or amend any rule stated above 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 fluid movement outside of the authorized injection zone. • ~ Standardized Language for Injection Orders Date: August 17, 2004 Author: Jim Regg Demonstration of Tubin Casing Annulus Mechanical Integrity The mechanical integrity of an injection well must be demonstrated before injection begins, at least once every four years thereafter (e~ccept at least once every two nears in the case of a slurry inf cction well), anal. before returning a «=oll to sen~ice follocvinzY a workover affecting mechanical integrity, u~-' ut 1:.~:;* ,,,,.,.... ~ ;,;:. ,r ~e«z ~ .~,; ~ . .* ~ - ~ .,+• -v .. ~ } Unless an alternate means is approved by the Commission mechanical integrity must be dcz~zonstrated by a ttzbin~ pressure test using a ~ ?vll-surface pressure ofm-t>~-b~ 1500 psi or 0.25 psi/ft multiplied by the vertical depth, whichever is greater, that ~rtz~t-shows stabilizing pressure that doesan not change more than 10°=percent during a 30 minute period. -4~y The Commission must be notified at least 24 hours in advance to enable a representative to witness pressure tests. Well Inte rity Failure and Confinement Except as otherwise provided in this rule Tthe tubing, casing and packer of an injection well must deme~~znaintain integrity during operation. ~~jhenever any pressure communication, leakage or lack of infection zone isolation is indicated by infection rate. oneratin~ oressure obsen~ation, test, suz-vev log, oz- other evidence tThe operator shall immediately notify the Commission and submit a plan of corrective action on a Form 10-403 for Commission approval: -~~~,.+;~ ~+.-; ;~po,.~+;~g pr:,3° .~. v ~ .,+• ~ t _ +~ -J. - 7 The operator shall shut in the well if so directed by the Commission. The operator shall shut in the well without awaiting a response from the Commission if continued operation Lvould he unsafe or would threaten Contam2nation C?f fresl2wat~r7f that„~IO-*cry"'.a-cirr-c~c~zrcan:-~vir`cc~m~cvcrvzrzizay-~-vrrcm-ucancrrcni, i;°:^" °'j" +' '~" + ' ~, + r °~. Until corrective. action is successfully ~'onzpleted, Aa monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating pressure communication or leakage. Administrative Actions Unless notice and public hearing is otherwise required, the Commission may administratively waive or amend any rule stated above 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 fluid movement outside of the authorized injection zone. s [Fwd: Re: [Fwd: AOGCC Proposed WI Lange for Injectors]] • Subiect: [Fwd: Re: [Fwd: AOGCC Proposed WI Language for Injectors)] From: Winton Aubert <wintan aubert@admin.state.ak.us> Date: Thu,. 2$ Oct 2004 09:48:53 -0800 To: 7ody J Colombie <jody calombie@admin.state.ak.us> This is part of the record for the Nov. 4 hearing. WGA -------- Original Message -------- Subject: Re: [Fwd: AOGCC Proposed WI Language for Injectors] Date: Thu, 28 Oct 2004 09:41:55 -0800 From: James Regg <jim regg@admin.state.ak.us> Organization: State of Alaska To: Winton Aubert <winton aubertQadmin.state.ak.us> References: <41812422.8080604Qadmin.state.ak.us> These should be provided to Jody as part of public review record Jim Winton Aubert wrote: FYI. -------- Original Message -------- Subject: AOGCC Proposed WI Language for Injectors Date: Tue, 19 Oct 2004 13:49:33 -0800 From: Engel, Harry R <Enge1HRQBP.com> To: winton aubert@admin.state.ak.us Winton... Here are the comments we discussed. Harry *From: * NSU, ADW Well Integrity Engineer *Sent: * Friday, October 15, 2004 10:43 PM *To: * Rossberg, R Steven; Engel, Harry R; Cismoski, Doug A; NSU, ADW Well Operations Supervisor *Cc: * Mielke, Robert L.; Reeves, Donald F; Dube, Anna T; NSU, ADW Well Integrity Engineer *Subject: * AOGCC Proposed WI Language for Injectors Hi Guys. John McMullen sent this to us, it's an order proposed by the AOGCC to replace the well integrity related language in the current Area Injection Orders. Listed below are comments, not sure who is coordinating getting these in front of Winton/Jim. Overall, looks okay from an Operations perspective. We do have a few comments, but could live with the current proposed language. Note the proposed public hearing date is November 4. The following language does not reflect what the slope AOGCC inspectors are currently requiring us to do: "The mechanical integrity of an injection well must be demonstrated before injection begins, at least once every four years thereafter (except at least once every two years in the case of a slurry injection well), and * before*_** 1 of 3 10/28/2004 11:09 AM [Fwd: Re: [Fwd: AOGCC Proposed WI Lange for Injectors]] return'.ng a well to service following a workover affecting mechanical integrity." After a workover, the slope AOGCC inspectors want the well warmed up and on stable injection, then we conduct the AOGCC witnessed MITIA. This language requires the AOGCC witnessed MITIA before starting injection, which we are doing on the rig after the tubing is run. Just trying to keep language consistent with the field practice. If "after" was substituted for "before", it would reflect current AOGCC practices. It would be helpful if the following language required reporting by the "next working day" rather than "immediately", due to weekends, holidays, etc. We like to confer with the APE and get a plan finalized, this may prevent us from doing all the investigating we like to do before talking with the AOGCC. "Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall* immediately*_** notify the Commission" This section could use some help/wordsmithing: "A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation." Report content requirements are clear, but it's a little unclear what triggers a well to be included on this monthly report. Is it wells that have been reported to the AOGCC, are currently on-line and are going through the Administrative Action process? A proposed re-write would be: "All active injection wells with well integrity failure or lack of injection zone isolation shall have the following information reported monthly to the Commission: daily tubing and casing annuli pressures, daily injection rates." Requirements for the period between when a well failure is reported and when an administrative action is approved are unclear. This document states "the operator shall immediately notify the Commission and submit a plan of corrective action on a Form 10-403". If we don't plan to do any corrective action, but to pursue an AA, does a 10-403 need to be submitted? The AOGCC has stated they don't consider an AA as "corrective action". Let me know if you have any questions. Joe -----Original Message----- From: Kleppin, Daryl J Sent: Wednesday, September 29, 2004 1:37 PM To: Townsend, Monte A; Digert, Scott A; Denis, John R (ANC); Miller, Mike E; McMullen, John C Subject: FW: Public Notices FYI -----Original Message----- From: Jody Colombie [ mailto:jody colombiec~admin.state.ak.us Sent: Wednesday, September 29, 2004 1:01 PM Subject: Public Notices Please find the attached Notice and Attachment for the proposed amendment of underground injection orders and the Public Notice Happy Valley #10. Jody Colombie «Mechanical Integrity proposal.ZlP» «Mechanical Integrity of Wells Notice.doc » r 2 of 3 10/28/2004 11:09 AM ~7 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Re: REQUEST BY MARATHON OIL ) COMPANY to dispose of ) non-hazardous oil field ) wastes by underground ) injection in well Beaver) Creek Unit (BCU) 2, ) Beaver Creek Field. ) Disposal Injection Order No. 4 Beaver Creek Unit Beaver Creek Field June 1, 1987 IT APPEARING THAT: 1. Marathon Oil Company (Marathon) requested on May 4, 1987 the Alaska Oil and Gas Conservation Commission to authorize the use of well BCU 2 as a disposal well in the Beaver Creek Unit, Beaver Creek Field. Marathon will inject non-hazardous waste fluids generated by normal drilling and production operations. 2. Notice of an opportunity for a public hearing on June 16, 1987 was published in the Anchorage Daily News on May 15, 1987. 3. No protest or request for a public hearing was timely filed. Accordingly, the Commission will, in its discretion, issue an order without a public hearing. FINDINGS : 1'V~l ~~-~~ "'` ~~~6~ 1. All aquifers below 1650 feetp within the Beaver Creek Field, and one-quarter (4) m31e beyond, are exempted under 40 CFR 147.102(b)(1)(B) for Class II injection activities. 2. Permeable strata, that will accept injected fluids, are present below 2261 feet in well BCU 2. 3. A series of confining strata are present above 2261 feet in well BCU 2 that will prevent upward movement of the injected waste fluids into non-exempt aquifers. 4. The strata into which fluids are to be injected will accept fluids at injection pressures which are less than the fracture pressure of the confining strata. Disposal Injectlon Order No. 4 June 1, 1987 ~ Page 2 5. To ensure that waste fluids are confined to injection strata, the mechanical integrity of BCU 2 will be demonstrated periodically and monitored routinely for disclosure of possible abnormalities in operating conditions. 6. BCU 2 is constructed in conformance with the require- ments of 20 AAC 25.412. CONCLUSIONS: The stratigraphic sequence present ~~'the well~AGS~e and maint- enance of the mechanical integrity of BCU 2 will prevent movement of injected fluids into non-exempt aquifers. NOW, THEREFORE, IT IS ORDERED THAT: Non-hazardous oil field waste fluids may be injected in conformance with Alaska Administrative Code Title 20, Chapter 25, for the purpose of disposal into the Sterling formation below the measured depth of 2261 feet in well BCU 2. DONE at Anchorage, Alaska, and dated June 1, 1987. ~L, ~..M „y ~ _ ~rloN cod` p, oI L ~~ ~d y ~ ~ ~ ~ le L. Jmlth, l;OmmlSSloner ka Oil and Gas Conservation Commission W. W. Barnwell, Commissioner Alaska Oil and Gas Conservation Commission Alaska Oil and Gas Conservation Commission ~~ .- TONYKNOWLES, GOVERNOR ALASKA OIL A1QD GAS 3001PORCUPINEDRIVE 1~~ ~t ~1~~~r~r 1~~ ANCHORAGE, ALASKA 99501-3192 COIQSERQATIOI~T COMMI-S-SIO1Q PHONE: (907) 279-1433 FAX: (907)276-7542 October 22, 1999 Lyndon Ibele Marathon Oil Company PO Box 196168 Anchorage, AK 99516-6168 Re: Authorization to Inject Produced Water from the Wolf Lake Development Area .into Beaver Creek Unit Disposal Wells. Dear Mr. Ibele: By letter dated October 7, 1999 you have asked Commission for approval to inject produced water from future Wolf Lake area natural gas. wells into two existing Beaver Creek Unit Class II disposal wells. Disposal Injection Order No. 4 limits injection in the Beaver Creek Unit #2 (BCU-2} well to nonhazardous oil field waste fluids. Disposal Injection Order No. 8 authorizes the injection of Class II oil field fluids into the Beaver Creek #3 (BCU-3) well. Other than the requirement that injected fluids be Class II in nature, the disposal injection orders place no limitations on the source of the injected fluid. Commission .regulations, Alaska Administrative Code Title 20, Chapter 25 also do not limit the source of injected fluid. The Commission does not object to Marathon's request to transfer produced water from the Wolf Lake wells to the two permitted Class II disposal wells at Beaver Creek Unit. Marathon must maintain compliance with the conditions of the disposal injection orders and relevant Commission regulations at all times. Care must be taken to properly track and manifest waste material. Marathon should also ensure .that adequate training is provided for any personnel handling waste prior to disposal. The. Commission must be notified .immediately if Marathon learns of any injection of waste that is not Class II into either the BCU-2 or BCU-3 wells.. Sinc y Robert N. Christenson, P.E. Chairman ~5 • M Marathon MARATHON Oil Company October 7, 1999 David W. Johnston Commissioner Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3120 Alaskan Domestic Production P.O. Box 196168 Anchorage, AK 99519-6168 Telephone 907/561-5311 RE: Authorization to inject produced water from the Wolf Lake Development area into Beaver Creek Unit injection/disposal wells. Dear Mr. Johnston: Attached please find a copy of the letter that Marathon sent to BLM requesting authorization to inject produced water from future Wolf Lake area natural gas wells into existing Beaver Creek Unit injection/disposal wells. BLM's authorization for the proposed action is required due to certain restrictions within the Beaver Creek lease agreements between the BLM and Marathon. Marathon is the sole working interest owner and operator for all of the affected wells and facilities. There are two permitted disposal wells at Beaver Creek Field, BCU-2 (AOGCC Disposal Injection Order No. 4, dated 6/1/87) and BCU-3 (AOGCC Disposal Injection Order No. 8, dated 5/13/93). The orders limit disposal activities to Class II wastes only, but do not restrict the source of injection fluids. Therefore, it is Marathon's interpretation that the AOGCC injection disposal orders for BCU-2 and BCU- 3 allow for the disposal of produced water from the future Wolf Lake area wells. Marathon will comply with all conditions of the disposal-injection orders in conducting the proposed actions. Because of the thorough reviews being conducted in support of an Environmental Impact Statement for the Wolf Lake natural gas project, Marathon Oil Company respectfully requests your confirmation of the above interpretation and non-objection to the proposed action. Additional details are provided in the attached letter to BLM. Your prompt review is appreciated, and if desired you may use the signature line provided below to respond. Please return one signed original in the enclosed envelope. If you have any questions, please call me at 564-6327. Thank you very much. Sincer ~~ .~.~ / yndon C. e Project Manager Approved by: Title: Date: A subsidiary of USX Corporation Environmentally aware for the long run. Marathc-n MARATHON Oil Company October 7, 1999 Alaska ~segion Domestic Production P.O.Box 196168 Anchorage, AK 99519-6168 Telephone 907/561-5311 Mr. Peter Ditton ^ n r ., ; U. S. Department of the Interior `-' ~ ~ ~ ~`' ~~~~' Bureau of Land Management 6881 Abbott Loop Road =~3Sk3 Oil & ~iSS GCQS. l;Ot111CttSSi011 Anchorage, AK 99507-2591 anel~ora~e RE: Authorization to inject produced water from the Wolf Lake Development area into Beaver Creek Unit i~jection/disposal wells. Dear Mr. Ditton: Mazathon Oil Company requests written authorization from BLM to allow the injection of produced water from Wolf Lake area wells into permitted Class II disposal wells at the Beaver Creek Field. BLM's authorization to dispose of'Wolf Lake area produced water at Beaver Creek is required due to certain restrictions within the Beaver Creek lease agreements between the BLM and Marathon. Mazathon will comply with all conditions of the existing AOGCC disposal-injection orders for Beaver Creek unit disposal wells. 'The AOGCC orders do not place any restriction on the source of injected fluids but limits injection authority to Class II wastes only. Produced water from the Wolf Lake area natural gas wells falls within the definition of a Class II waste. Marathon is in the process ~~, of obtaining a right of way (ROW) permit from the US Fish and Wildlife Service for activities related to the production of natural gas from the Wolf Lake area. Requirements for the ROW permit include preparation of an Environmental Impact Statement (EIS) with details for all phases of the future operations. The EIS includes plans to cpnstruct a buried natural gas pipeline from the Wolf Lake area to Mazathon's facilities at the Beaver Creek Field. An additional line will be installed at the same time in the same trench to transport produced water to the Beaver Creek Field for injection into permitted Class II disposal wells. These plans were discussed with you by Mr. Brock Riddle several months ago, and received your verbal approval. ', Presently, there are two permitted disposal wells at Beaver Creek Field, BCU-2 (AOGCC Disposal Injection Order No. 4, dated 6/1/87) and BCU-3 (AOGCC Disposal Injection Order No. 8, dated 5/13/93). The Wolf Lake development area includes wells at the existing Wolf Lake and Galena wellsites, and one additional potential site nealrby. The daily volume of produced water which may be generated at Wolf Lake area wells is unknown at this time and will be dependent upon the reservoir characteristics and the ultimate number of wells drilled. There are no disposal wells or facilities available in the Wolf Lake area. Use of the existing disposal wells and facilities at Beaver Creek will minimize the impacts of the Wolf Lake development. ', A subsidiary of USX Corporation Environmentally aware for the long run. ' ., r' ` ~ Mr. Peter Ditton U. S. Departmen4 of the Interior Bureau of Land Management October 5, 1999 Page 2 Marathon seeks BLM's cooperation in obtaining written authorization for the above plans to ensure that the Wolf Lake project EIS, is complete and accurate prior to its publication. Your prompt response is appreciated. BLM may indicate its approval by signing below and returning one original in the enclosed envelope. Please call me at 564-6327 if you have any questions. ~~- Sinc lv ~ ~~ v ;i/ Lyndon C. Ibele Project Manager ', Appr Title` I -~ [[-%- 1JdlG. LCUkz:M:\W P\ENG\wolfdoc cc: David W. Johnston Commissioner ' Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3120 ', Condition of Approval:. Approval is contingent upon analysis of the disposal fluids to ensure Che fluids meet class II criteria. '~i' r f r~ '+,~j ' t ~ i j'~l, ALASSA OIL A1~TD GAS CO1~T5ERQATIOI~T COMA'II551O1Q July 8, 1996 Chick Underwood HES Technician Marathon Oil Company P.O. Box 196168 Anchorage, Alaska 99519-6168 Re: Beaver Creek #2 Class II Injection Well Dear Mr. Underwood: TONY KNOWLES, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 FAX: (907) 276-7542 ~~ `' This letter is in response to your July 1, 1996 request for clarification of the acceptable fluids for injection in the Beaver Creek #2 Class II disposal well. Disposal Injection Order #4 allows the injection of non-hazardous oilfield waste fluids into the Sterling formation of the Beaver Creek #2 well. Class II fluids are those that "are brought to the surface in connection with natural gas storage operations, or conventional oil or natural gas production." In the July 1988 Regulatory Determination for Oil and Gas and Geothermal Exploration, Development and Production Wastes, fluids that are exempt from regulation under RCRA subtitle C are. defined as those wastes, related. or associated, "generated during the exploration, development and production of crude oil, natural gas, and geothermal energy resources." In the 1992 document entitled Management of Wastes from Crude Oil and Natural Gas Exploration. DeveloQment, and Production on Alaska's North Slope, associated wastes are additionally defined by EPA as unique and intrinsic to exploration, development and production operations and associated with primary field operations. The 1.993 Clarification of the Re u~ry Determination for Wastes from the Exploration, Development and Production of Crude Oil, Natural Gas and Geothermal Energy states that a "simple rule of thumb for determining the scope of the exemption is whether-the waste in question has come from downhole or has been otherwise generated by contact with the oil and gas production stream during the removal of produced water or other contaminants from the product." 40 C.F.R. §261.4 (b)(5), also lists under the heading: of solid wastes which are not hazardous, "drilling fluids,. produced waters, and other wastes associated with the exploration, development, or production or crude oil, natural gas or geothermal energy." f a r Chick Underwood July 8, 1996 page 2 Although E&P exempt wastes are not regulated as hazardous waste, they must come into contact with fluids that have been brought to the surface in order to be eligible for injection into a Class II disposal well. You also mentioned in your letter stormwater that has come into contact with E&P exempt waste. According to the mixture rule on page 17 of the May 1995 document Crude Oil and Natural Gas Exploration and Production Wastes: Exemption from RCRA Subtitle C Re 1,gu ation, mixing anon-hazardous waste with an exempt waste produces an exempt waste. If the E&P waste has additionally come into contact with fluids that have been brought to the surface, the stormwater may be disposed of in the Class II well. The stormwater may also be used to help facilitate disposal activities by creating a sufficient slurry for injection into the Class II well. The Commission would require more information before making a determination on specific wastes that are not listed E&P exempt wastes. Sincerely, ~a~M~- Wendy Mahan Natural Resource Officer ~3 • M Marathon MARATNON Oil Company July 1, 1996 Wendy Mahan, Natural Resource Officer Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Wendy: Alaska Domestic uction P.O. Box 196168 Anchorage, AK 99519-6168 Telephone 907/561-5311 n~0`--\ Marathon Oil Company is requesting a clarification for allowed injectables into the Beaver Creek No. 2 well which is a Class II Injection Well. This was converted over to disposal and is permitted by Disposal Injection Order No. 4 dated June 1, 1987. We currently have stormwater at Beaver Creek that has come in contact with E&P Exempt wastes and would like to inject this water, as well as have further clarification on what the Commission will allow for injection down this well. Thank You, Chick Underwood HES Technician CAU/I¢:H:1W PIENGUNJBCU.WPD ~'~`~;~ ;<<{ c, ~..' ~ 1 ~yC~~ ~4laska ~!i c?, ~~~~ ~n ~i'`J`'Vfn p ~~rrt7i5S101~ A subsidiary of USX Corporation Environmentally aware for the long run. F r Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: The application of Marathon Oil Company (Marathon) for an order authorizing the underground disposal by injection of non-hazardous oil field waste fluids at the Beaver Creek Field. The Alaska Oil and Gas Conservation Commission has been requested by letter from Marathon dated May 4, 1987 to issue an order in conformance with 20 AAC 25.252. The order would authorize the disposal of non-hazardous liquid waste by injection into Beaver Creek No. 2 well. This .well would be converted to an injector, and used for disposal of non-hazardous oil field waste fluids by injection into the Sterling Formation at the Beaver Creek Field, Kenai Peninsula, Alaska. A person who may be harmed if the requested order is issued may file a written protest, prior to June 1, 1987, with the Alaska Oil and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska 99501, and request a hearing on the matter. If the rotest is filed timel and raises a substantial and materia issue crucia to t e Commission s etermination, a hearin on the matter will e held at the a ove address at a.m. June in con ormance wit AAC I ~ a hearing is to e e d, interested parties may con irm this by calling the Commission's office, (907) 279-1433, after June 1, 1987. If no ro er rotest is filed, the Commission will consider the issuance o the or er without a Baring. ~~ Lonnie C. Smith Commissioner Alaska Oil & Gas Conservation Commission Published May 15, 1987 :STATE OF ALASKA ADVERTISING ORDER NO. ADVERTISING- ORDER Ad• 48-5595 AGENCY CONTACT DATE OF A.O. R P. O. D4~JtiL 1'F7VOl PHONE ~ nn Anchorage, Alaska 9951-~9fl0I t907> 27}-Ik33 DATES ADVERTISEMENT REQUIRED: T ~ Alaska ®~ $c Gas C~seYVation ConmiSSi~ ~~ 15, -1987 ~ 3U01 Porcupine Drive a Anchorage, Alaska 99501 ~ SPECIAL INSTRUCTIONS: I $ ~~' H E R, AFFIDAVIT OF PUBLICATION UNITED STATES OF AMERICA REM I NDER- STATE OF ' ss INVOICE MUST BEIN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. DIVISION. A CERTIFIED COPY OF THIS AFFiDAVITOF PUBLICATION - MUST BE SUBMITTED .WITH THE INVOICE. BEFORE ME; THE UNDERSIGNED, A NOTARY PUBLIC THIS DAY N~-r~of~~hc~r~ PERSONALLY APPEARED WHO ~ sTA~~ of AI_a~slcA AT' Alaska cut anataar CATION HERE. s Conservation Cori9rnllWn qa: The applf~catiort of A6K~- BEING'FIRST DULY SWORN ACCORDING TO LAW -SAYS T AT e + on cwnrany tnnacaMlMrt .for an grder euthori ~ 111M¢r#'~6tMd disposal !~ flort of norrhatardrau HE/SHE IS THE OF nu}ds at tne, e~1r iaield. tnlf~rwka~*?t~anariasc.~wi_ PUBLISHED AT IN SA D DIVISION wlial Commission. has ~`~" by Yeller from MN-t ' 111~n sled M8y 4, 1487 1~ hM1-' AND STATE OF ND THAT THE 0-d~c in conformance MANt ~i"~ u•2sz The order wwM- M111Mr1at ipe disposab 64 6M- - INtMd~45 liquid waste b4.ln- i6,to-968v~~~ t10.." 'f~is weir ~utd be car wlt ADVERTISEMENT OF WHICH THE ANNEXED IS A TRUE COPY WAS s .-, MN4ad'b 0iti ilNeetor. a~ we ~~ gip, . q non-hatMda '0~8 NNi w lasPe ttuids tit ante I'liw+frn~emestariins>c~wstio PUBLISHED N SAID PUBLICATION ON THE _! DAY OF d tM Beaver creek Pl.w. QQ~~ © Ksp6i f~6nirtsula, Alaska. ' Awl wno may he-tnrrMi' 19_.L, AND THEREAFTER FOR H wasted order Is IlwMO aNW #IQ a written pnRWA, 10r to June 1, 198,7 w/Nl tlr y ~ CONSECUTI E DAYS, THE LAST PUBLICATION APPEARING ON THE A . HHItn~GalnisSion3001 ~j ~ pp~~ psbre, AnGWra9e, Alsl~i i/l~t, int! request a heaWrke~~ aw Mw 1natNer: ll tfle,: prolsi k -DAY OF __ 19 AND THAT THE ~ try bed ra,ees s ewF sa+t m~t6tf61 issYe cA- m 16 ' t - 11 o NitG5 9 1ME ~r .RATE CHARGED THER N IS .NOT IN EXCESS OF THE RATE breti~ ~.~ .rr ~ii ne iMws ag6rass. at 9:0.8 r-w. .' - CHARGE P IVATE INDIVID LS. L Jrls! ii. 1487, in cafforl~INO aaw~d~ntS40er'e'steah~ - ~-+~ (Ary p~firrn'thls by oalµi~ pMr s office. (907) ~• 1111, r June 1, 1987. M f>r pmt ~r'otestF4 fit wiu coal SUBSCRIBED AND SWORN TO BEFORE ME ~ ~ p~ oFthe order r ~ . M6f1~ ,. . ~-i7AY OF ~~!1?.K.;~; ~~~ THtS ~ . .. /s/Gsmfll, a~._ n NOTARY PUBLIC FOR STATE OF , . _~.....~.tason Expires: ws: +wr rs,1~p MY COMMPSSI~N EXPIRES ~~,,,~ 18.1989 Aoa~-sage `. F 02.901 (Rev.B-85) : PUBLfSHER I, ~~ Marathon MARATHON Oil Company r4~~S.',~ ~i8j tpt 42S L~:t!3 z'?:..: !z ,~ii :t., ?e~~.•:-rte Anchorage District, Anchorage, Alaska • • BEAVER CREEK FIELD ~ ~' APPLICATION TO THE ~r~ AOGCC ~~ FOR UNDERGROUND INJECTION • BEAVER CREEK FIELD INJECTION WELL APPLICATION TABLE OF CONTENTS Section/Regulatory Cite Subject A. 20 AAC 25.252(aj Injection Order B. 20 AAC 25.252(c)(1) Plat ATTACHMENT ATTACHMENT C. 20 AAC D. 20 AAC E. 20 AAC ATTACHMENT F. 20 AAC G. 20 AAC ATTACHMENT H. 20 AAC ATTACHMENT I. 20 AAC J. 20 AAC K. 20 AAC L. 20 AAC ATTACHMENT M. 20 RAC N. 20 AAC B-1 B-2 25.252(c)(2) 25.252(c)(3) 25.252(c)(4) E-1 25.252(c)(5) 25.252(c)(6) G-1 25.252(c)(7) H-1 25.252(c)(8) 25.252(c)(9) 25.252(c)(10) 25.252(c)(11) L-1 25.252(d) 25.252(h) Operators/Surface Owners Affidavit Geological Information Well Logs Casing Information Injection Fluid Injection Pressure Fracture Information Formation Fluid Aquifier Exemption Mechanical Integrity Wells Within Area Page 1 2 3 4 5 6 7 8 9 10 11 12-13 14-17 18 19-20 21 22 23 24 25 • • ' SECTION A j 20 AAC 25.252 (a) Marathon Oil Company is requesting an injection permit to authorize the conversion of BC#2 from a producer to a Class II disposal well. BC#2 was last completed on October 14, 1982. It is proposed to use ' BC#2 for the disposal of fluids that are brought to the surface in connection with conventional oil and gas operations and commingled with nonhazardous fluids which are an integral part of production and operation of Beaver Creek Field. Injection into BC#2 will be accomplished in two phases. In Phase I, it is proposed to inject into existing perforations open in the ' Sterling B-2 gas sands from 5125'-5140' and proposed perforations reopening the Sterling B-3 gas sands from 5155'-5220'. These sands watered out in early 1987. Phase II would be initiated after Phase I is completed. In Phase II, it is proposed to abandon the perforations from Phase I and inject into the Sterling formation. through perforations below 2261'. fl • • SECTION B PLAT 20 AAC 25.252(c)(1) Attachment B-1 is a regional plat showing the location of Beaver Creek Field. Attachment B-2 is a plat showing Beaver Creek Field, 1/4 mile radius area of review for well BC#2. There are no other wells. within the area of review. -2- • ?~rUG,~' ~ - ~•~. ~ _ goo _ . - -- _-- ~~ ~I '' '-- •~- 1,~: X19. \ -=• 0• ~•~~,., j21 _ Sys'' -- ,. - .'}1;•• 24 ' , -\, - ~. A{(UIO '~~_° _ iSS.. ~23 ', X19 O . ,_ ''_, Ermine '~' __r_-_ ~ _ -lane .'t_ .'_.. _ -- ,a~' ' \ Y - - - -- -- - - r t -- - -~rJ - - ~ : - .i5 ,26 Jc•-' U ~~ 027 ~ V ( - - - - -- ~ LOCATION OF I `r _~_ _ I_\ ~-26~ - 25`x- _~, 3oCJ~~, - - • BEAVER- CREEK ~2 BEAVER J ~~`~~ _ CREE~ ~-~ ~ ~" ° -J-'~V• °~ o~NoiF l;. _ f y_ - ;- _ _-- - -G ~~ ~ zs ,1J ~_ ~ - ~ _ _ - 35 ti --- f - o ~ ~ ° ° .~ -mss r - ~ .• 31 - j ~ 32 \. ©33 .. ~e° 35 i o - °. ~- _-- - _ - _ - ~ - - - -- -~ - - - - - x'.._- - G~ .250 - Q S - -- -- ^= ~~i3o1 ~ ° .. - ~~ ,2 ~ o- . _ ~ -- 1~_ ..- -- - - _. - GA _ S~- . . _. - -- - - _ ELD ~ O ~... ~=- - - ~ , .~__ _ - - .., _ _ i - 1 _ _ _-' S - - _ -- - -- - .rte; < ~~so-- _ -_ = 3 2 xb ~ n\ ~ ~//- ~ - - - _~~'•. - - - - ~ O ~ ~ U Lake .. _ .---- - _ - - _ -_ , - _ _ - - . - _ .~ _ - . _ _ - _ ~ - O .- ~ a0 - .- ,1 _ _ _~~ ,. ~ - - s - 7 _ r~l_~_a~ - _-9- ° 10-\O ~ tl 1 '~ ~;~y .3 12 a~~ ~} 7 ~ r^; - ,_ _ 'tnJ _ ~ r 1~ ~" _ 7-- -.''' _ - i•~- ~.j_ - ~ - ~ O f •~ 15. i ~a~ X14 - 3 O18 ~ i- - - .e- .r ` • ~ - _. o _ -.125- - - --- --- - ~ lCK9`~ f \ O -_ - -_-----~'JRT--a1'S•RS---_-• O - ~ r5~ V~ ~~ ti~ _.-a• --.!--.~ ~~,_ _ _-_ _ -_ - 111 , {~~ --•_---.f._ -- -- -.~-_-~-_::~--_q-.g---- - i - - - O'-• '~ P - Con' ` •~ _ " - -- -' .. - _. - --•-~-- -y-- - _. _ o•. u 1 p Key ~ j` _ -_(. - 29 _ 281 •~ 27 ~; ° 26 •~ v ~.~ ~ ~ ~ _ hviN City -. O - lei' ~: - - - ~- ~ - _ ~~' - ~ _ ~ ~ \~~ 1 -- ~ C//tar..,, ~y•S ~iSI.. --- _ -.• `~ _...-.. - / .' 2 ~J S/- Gam' ~ ~?~ l`ll ~ / ~ ( ~C ~~ J6 - // ' 32 - - - -- ~~ D~_ ~ 0 l - ~ % ~;+ 3c.:vERCR~-- ';~- C"~ •.7i' _, ~ti. 3d •.- ^~%`~ -_.. 3S - ~36••~ (~ ~ ~~ • iN° 9EAV:q •I~X a~a =~- - -- --- - ~ EJ ~ 31 - ~f~1 i - nOUSc ~. ~. - •• -- • o ~ - - - . x ~~ L/ - v ,. ~dc ~~~~ ;~:.- :" . •• -- h ~=- ``- ATTACHMENT '-'~ ~ •~~- _ ~j1o ~ ~ ~'' - _ 'li _ _ ~~• ___"' :'-~ / .ice. 1 _- (Q,?s - ,~~ ~ ~2-~ ~~L P ~ - <i ' i ~~: ~ l\~ ---- /.r' -_r-' - :'~- - _ $- ---- /BOUNDARY! _~- )) ~,--~--~`` : r e // _ . __ . _ ~ ~ t°1 sA 1 ~/ -C. ~ o :; ~ _ - $<,v~_ na L•7~•~0': - _ ~ _ ~ b (,ili o c ~- - 7J _ - V ,~ c - - '~~ - o : - ~_ 1, ~ ~~ <~•- /~ r~ - - ~• ~.i 1 ~ - - - -- ~ - - I "• •.. .e.w ro A` -~- + ~' •5256 + e .• 1 .~ :. .5~~ ~ 19 2/ 21 22 2] so,1,' ' ~ .. 4 ~5 'S e xAfATMOx • Bo 1hf r.•.T w. A•Daw xox-uwow uxrow ~ (~. ~- /t i •5~~~ .x- Tzs .. es / -^_----e ----~___ __________ ' • • • i i fc-f'TA ~ ~ :,. ~ I g zs. ~~~~~ ----z• 650 s 5 1 ,„ coal ~. BEAYER CREEK --~ r a UNIT BOUNDARY • •' • TVD e ~• GAB PARTN;HATNfB ARlR ,56~p.. ,j. • s oe] ,~7}..y; a ur: 111 D'a~'`~,F .ao sa: • Q. a 6 ~,° 9 • +-•i[ _ 3 B 71 O T 2 ~ •/ I •. 33 ~O 34 35 rv:MxeN:w.eo V P r9 `M1 O ]_A I • ~° r • D ou>'T • a - - - T 7 N ,. Tai w .. ~: / ,.. eP e. e = • T 6 N 6 •]D.A r ev _ ,t Y ii 1 .' T E ~ T• ]s.eas V 1. .,+ • 5--+~~ 3 r---- z . ~ ' - ., ~ p ,. U ,.. ~• ~ .56©• i ,. .• .•'~ ~ : ~ ~-----t -- ~s __--______~ ~ a .5666 E •~O i <N-1)ie .51p6 ~ • ' I aeeon - 0 ~ ' 575 i ~_ -~~~ ~. 11 • ~ 16 ATTACHMENT B-2 ," O •• MARATHON OIL COMPANY ALAfEAx DIfTxICT I LEGEND BEAVER CREEK FIELD • Troxcx •B• zaxe oR Moo. TOP B-3 STRUCTURE • • MAIe0011ED TTONEK OR MOB. .~ ~ fTERlIxO BM MOO. • •1 oee• x seos• ~ C.L •N• I 19 ~ A 21 ~xOD11CTlOx BA0 • , ~ •. sr•rr•LL•r Q euu •• sew: ~ Ael•er. •. •4w ABAMDOx[O OAf •Ell D•~ LeeeM ~~ DAY MOLE • • SECTION C OPERATORS/SURFACE OWNERS 20 AAC 25.252(c)(2) The surface owners and operators within the area extending "1 /4 mile from the well bore: - Marathon Oil Company - UNOCAL 909 West 9th P. O. Box 190247 Anchorage, AK 99519 - U. S. Fish & Wildlife Service 1011 East Tudor Road Anchorage, AK 99503 Attn: Bob Richey - CIRI 2525 C Street P. O. Box 93330 Anchorage, AK 99509-3330 Attn: Kurt Humphrey - U. S. Bureau of Land Management 4700 East 72nd Avenue Anchorage, AK 99507 Attn: Joe Dygas -5- ~ • SECTION D AFFIDAVIT 20 AAC 25.252(c)(3) Affidavit of Thomas R. Brooks STATE OF ALASKA THIRD JUDICIAL DISTRICT I, Thomas R. Brooks, declare and affirm as follows: 1. I am over 19 years of age. I am employed by Marathon Oil, Company as the Environmental & Safety Supervisor. I have personal knowledge of the matters set forth in this affidavit. 2. On ~`~~„ `z.~q ~~ 1987, the surface owner /operators listed in Section C were provided a copy of this permit application. DATED at Anchorage, Alaska this \ 2- day of -----~~a _, 19 8 7 . ~~ ~~ Thomas R. Brooks Subscribed and affirmed before me at Anchorage, Alaska on ~..,.' ~z 19 8 7 . .:.. Notary Public in and for the State of Alaska My commission expires: My Commission Expire' Marcfi 17, 3988 -6- • • SECTION E GEOLOGICAL INFORMATION 20 AAC 25.252(c)(4) 40 CFR 147.102(b)(1)(B) states Beaver Creek Field aquifiers 1650 ~ feet below the ground surface, and described by a 1/4 mile area beyond Beaver Creek Field are exempt. The exempted areal distance from the BC#2 well bore is 3300 feet. The Beaver Creek Sterling Formation gas reservoirs were discovered while drilling the well Beaver Creek Unit #1, during January of 1967. The Sterling Formation is the current principal gas-producing reservoir in Beaver Creek Field and also contains the subject strata intended for injection. The Sterling Formation is of Pliocene Age and consists of meandering river and stream (fluvial) sands and conglomerates of moderate depositional energy. A lack of interbedded clay and silt within the various producing zones contribute to the high porosities and permeabilities observed. Phase I water injection is intended to occur within the water-wet sands of the Sterling "B" series, which is found between 4,822' MD (-4,667' Vss) and 5,917 MD (-5,762' Vss) in the Well BC #2. Tops and bases of specific sands in this. well are: TABLE 1 Well BCU #2 Sterling Fm. Sand Tom Base B-2 5,121 (-4,966) 5,136 (-4,981) B-3 5,153 (-4,998) 5,220 (-5,065) B-3A 5,230 (-5,075) 5,249 (-5,094) Porosities range from 30 to 36°s, and the sands vary from 10-60 feet in thickness, with the exception of Sand B-4, which is approximately 600' thick in Well. BCU #2. The sands are moderate- to well-sorted fluvial sandstones with minor conglomerate, consisting of sub-angular to sub-rounded quartz-rich sand with variable. amounts of chert and volcanic rock fragments. Intervening confining beds range up to 60 feet thick and consist of coals and claystones. In the 1650'-2261' interval there are numerous coal/clay/sand sequences that are sufficient to insure protection of sands above 1650'. (See Attachment E-l) -7- 1 1 i 1 1 1 1 1 1 1 1 1 1 1 1 ~'1 1 1 1 ... 0 ...- ---- ° .. .... .... .... .... ... 5 0 0 '-, ATTACHMENT F ~ _ ll L W CC og -from B e o showing confininc <- intervals - measi ~ in feet <- ~" / -- t /~ im -F' ~ /1 O ~~ Jr ' I J ~ ~/ / C ~ ~. N O . . O _. ' - --_.. C _ 3 N \ N_ O O I ' f !~ N Q 1 _. _~ . ~_. ~- ~-_ -.-. ~--1 -. I-._ __ _ ~ .-_~ __.. : _. I - ___. -_~ ____ _. _.~ .-__ __-.. -._ .._. ti.___ ~_. - _____. .-. - _- -1 l COAL/SHALE .red depths • • SECTION F WELL LOGS 20 AAC 25.252(c)(5) All logs- have been submitted as required by 20 AAC 25.071(a) and (b). -9- • SECTION G CASING INFORMATION 20 AAC 25.252(c)(6) The well is cased as shown in Attachment G-l. Wellbore schematics for Phase I and Phase II are also described in Attachment G-1. Casing is cemented in accordance with 20 AAC 25.252(b) and will be tested prior to injection in accordance with 20 AAC 25.030(g). Integrity of the 32" tubing will be tested by injecting fluid into the tubing at approximately 500 psig and monitoring the annulus pressure for 30 minutes. -10- ! J P~~ASE 1 ~Ep1JCRCRLI:KFICLI~ P'1 AsE: ~.1.,' h ~ ID Dept h ' ~0' Tu6i.~ I~er Y0' gr [6g CIN 'DC-FB8 ) (~ p ~I Ci C f'~ (3-I/1 EUE Srd b x t • Ported for 1/4-'-eon,t•rol line 20" . 94A N-40 to 280' 20" , 94/ N-40 to 280' .683' 2.75" Otis,'XL' Ball valve nipple (3-1/2" Butt pxb) , r ~~s f~6i ~ 9-1/ 1 8" 72L681' N-80 and ,. 13-7% ,~81' M'8~ a^d 8" T2t6 ~ J-55 to 2211' J-55 to 2211' ' 3-1/2" 9.2A Bu tt, N-80 tbg ~ ' Phdsc 3I Per~ora~iows N-(t0--~~ 4 " 9-51 8", 43.5A N-aO-s~ 9-5/ ;.5A 8 , Srd csg 4889' 2.75" Otis XA circ sleeve Srd csg ~_ • -_ ' ' f_.~~' Esfiw af!ed ToC (3-1/2" butt p x..b)_ .. " .•_,. ) , ~ . 4923' 3.00" Bkr FH hyd pkr (3'1/2" 4923' 3.00" Bkr FH hyd pkr (3'1/2 butt p x b) butt P x b) 496i' 3.00" Bkr IJL entry guide 4961' 3,00" Bkr NL entry guide _ - PERFORATIONS f01L) _ p~acnuerlnu t (DIL1 ~ • : ~ SIZ5=940 8-i B11PF sns' -Si'lo' g-2 H (iPF _ - ' 0 5155''5220' B-3 2 HPF 0 5155'-5220' B-3 2 NPF _, e r-I o . ~ ~ I o ,, ° ~ ° Bkr "K" rtnr 5221' DIL F Bkr "K" rtnr 5221' DIL ~ (5233' DPN) „ •, , (5233' DPM) „-, ,•, , •,, a .';','~ ;;•, • 0 5230'-5244' B-;A 2 NPF ;,', ,-•, , 0 5230'-5244' B-3A Z NPF Bkr "K" rtnr 5158' OR ' x Bkr "K" rtnr 51$8' DIL (5210' DPN) ' (5170' DPM) 5263'-5165' .squeeze perfs U 5163'-5165' squeeze Derfs " 5166' Dll Bkr "N" BP H 5266' DIL BP Bkr "N Top 7" lnr stub 5168' DIL [-~ Top 7" lnr stub 5268' OIL - (5280' DPM) 5196' DPM BOT hyd pkr ~ (5280' DPM) 5196' DPM BOT hyd pkr o a ° 5314''5344' 8-4 2 HPF (perfd In error) 0 5324'-5344' B-4 2 HPF (perfd in error) 5600' Baker BP 5600' Baker BP 6500' Ann cmt top 6500' Ann cmt top • ' 84D0'-8715' Cmt in 7" Inr ' ~ ,.,1;,.,_„ %; 8400'-8115' Cmt in 7" inr ' ~•;f;•~~-~• ~' ~ ]" Inr tie back slv 8594 %~ p' Inr tie back slv 8594 ~,,~ =t' q-5/8". 40. 43.5 L 41A. 9-5/ 8". 40, 43.5 L 47A. N-80 L 5-95 csg to 8835' N-80 L 5-95 csg to 8835' ,, . • 11,740' Cmt tov ~•: ~•'-'•,-~ 11,74p' Cmt top , . ,,; , 11,950' Baker BP 11,950' Baker BP 14,465' Cmt top 14,465' Cmt top 14,680' Bkr FB-I Perm pkr w/ Q ~~' 14,680' Bkr FB-I Perm pkr w/ Q nipple L blanking plug nipple L blanking plug 14,915' Bkr "N" Bp 14,915, _, Bkr „N.. BP 15,407' Howco 7" Drillable CIB% 15,407' Howco 7" Drillable CIBp S" Inr top 15,415' 5" Inr top 15,415' 7", - 29 L 3ZA, N-80 L P-110 T', 29 L 31A, N•80 L P-110 to 15,439' to 15,439' °• 652' ,.,, , . 15,657' PBTD 5„ ' , Nyd_,, -.0 1S .. 5 .EL., .._..~..' ..... _ 15.697' TD _ • • SECTION H ' INJECTION FLUID 20 AAC 25.252(c)(7) ' 1. Injection Rates 7 The average injection rate will be dependent on the daily volume of produced. water and whether or not any drilling/completion fluids need to be injected. Initial daily rates will average less than 1,000 BBLS per day. Water production is expected. to increase but it should not average more than 3,000 BBLS per day. Drilling/completion fluids will be injected on a periodical basis as drilling and/or remedial work dictates. These fluids, along with produced water or fresh water used to dilute the drilling/completion fluid, will not average over 3,000 BBLS per day. ' The maximum injection rate will be held at or below 5,000 BBLS per day by mechanical means. 2. Physical and Chemical Characteristics of the Injection Fluid: a) Produced Water - Currently water produced within the Beaver Creek Field averages less than 4,000 PPM total dissolved solids (TDS) with typical properties as shown on thews er analysis reports. for Wells 1-A, 3, 6, 7 (Attachment H-1). b) For drilling/completion it is anticipated that a lightly treaded Chrom-Free Lignosulfonate with 3o KCL will be used within the Beaver Creek Field. The undiluted mud has an average weight of 10.0-12.0 ppg; diluted 2 to 1 the average weight is 8.8-9.55 ppg. This mud is similar to type 1 mud approved by the EPA for NFDES General permits. ' The general properties and composition is; ' -12- • • Percent Pounds Pounds Material by Weight per Barrel per Gallon Fresh Water 80-90 350 8.33 Bentonite 3-4 12-18 0.30-0.40 Barite 12-24 45-100 1.07-2.38 Potassium Chloride (KCL) 0-5.2 11-22 0.26-0.52 Polyanionic Cellulose 0-0.7 0-3 0-0.07 Potassium Hydroxide 0-0.1 0-0.5 0-0.01 Caustic Soda 0-1.1 0.5 0-0,11 Acrylic Polymer 0-0.5 0-2.0 0-0.05 (Bentonite Extender) Sodium Nitrate 0-0.02 0-0.1 0-0.002 Lime 0.5 0-20.0 0-0.5 Caustic Soda 0-1.1 0-5.0 0-0.11 Soda Ash/ 0-0.5 0-2.0 0-0.05 Sodium Bicarbonate Lost Circulation Material 0-2.5 0-10.5 0-0.25 Total 100.0 420-504 10.0-12.0 c) Completion fluid: Norma lly a 3o KCL and saturated NaCl brine with the properties (undilu ted 10.0 ppg, diluted 2 to 1 - 9.9 ppg): Percent Pounds. Pounds Material by Weight per Barrel per Gallon Fresh Water 83.3 350 8.33 Potassium Chloride (KCL) 3.0 12 0.30 Sodium Chloride (NaCl) 13..3 57 1.35 XC Polymer 0.4 1 0.02 (Xanthumgum biopolymer) Total 100.0 420 10.00 The drilling/completion fluids proposed for injection are not defined as hazardous by the Resource Conservation and Recovery Act (Re: 40 CFR 261.4(b)(5)). -13- ` z ~ °° ~_ _ `~ usowwTOw~[s i OPERATOR WELL NO. FIELD COUNTY _ STATE REMARKS & CONCLUSIONS: Barium, mq/1 19 Strontium, mq/1: 0.84 _ __ __ I ron~mg/ 1 57 __ Cations mgll megli Anions mgli meg/1 Sodium ............ . __ __.-_1009 43.90 Sulfate.............. ND (1 }- -- ----- Potassium .......... . _.______ 430 1 1 .01 Chloride ............. 1 750 _ 49 .35 Calcium ............ . ____._ 36 _ 1 .80 Carbonate ........... -' -- Magnesium ......... . _____~7 2.14 _ Bicarbonate ......... `~_- _~ 50 Iron ............... . __ -' _ _-- Hydroxide ........... -- -- Total Cations ......... _58~ Total Anions .......... ~8~ Total dissolved solids, mgll .......... ___3537 Specific resistance @ 68° F.: NaCi equivalent, mg/1 .............. _ -3 34 2 Observed .......... __! ~ 67 ohm-meters Observed pH ....................... __~•6 Calculated ......... _ ~ X90 ohm-meters WATER ANALYSIS PATTERN Scale Sample above described MEQ per Unit Na Ca Mg Fe ......... . ~_ ~'" r ATTACHMENT H-1 • 9' CHEMICAL 8c GEOLOGICAL LABORATORIES OF ALASKA, INC. P.O. BOX 4-1276 TELEPHONE ANCHORAGE INDUSTRIAL CENTER Anchorage, Alaska 99509 (907) 562-2343 5633 B Street WATER ANALYSIS REPORT Marathon Oil Co. DATE 3/11/87 1-A LOCATION heaver C reek_ FORMATION _ INTERVAL Alaska SAMPLE FROM C1 10 Na HCO' 1 Ca SO' 1 Mg CO' 1 Fe C1 HC03 SO' C03 LAB NO. 5670- 1 T-Pak (N salt~3 ;n ~+6ave graphs includes Na, K, ar.d U;; P:OT~: ?t ui ~ 'v±;i+Iprams' per liter Megl1 =Milligram equiva.~sn? per ~i!e+ + +. ~ ><,~ot= bq Dunlap & Hawthorne calcula +~ ~_ ,.. ~, °~ of ~r .:. fi -. usow~row~cs • • WATER ANALYSIS REPORT OPERATOR Marathon Oi 1 Co. DATE 3/11/87 WELL NO. 3 LOCATION FIELD Beaver Creek FORMATION COUNTY INTERVAL_ STATE Alaska SAMPLE FROM REMARKS & CONCLUSIONS: Barium mg/1 _ __ Strontium, mq/1: Iron m /1 _lc/ Cations mg/1 Sodium ............ . 1081 - --- Potassium .......... 8 g . -- Calcium ............ 164 . ---- Magnesium ......... . ___. 6.3 Iron ............... . meg/i Anions 47.03 Sulfate .............. 2.25 Chloride ............. 8.18 Carbonate........... 5.18 Bicarbonate ........ . Hydroxide .......... . mgll ND (1) n ,. ,. 700 Total Cations ......... 62.64 Total Anions .......... 62.64 Total dissolved solids, mgll .......... _3553 Specific resistance CU 68° F.: NaC1 equivalent, mg/1 .............. 3455 Observed .......... 1 •56 _ohm-meters Observed pH ....................... 8.34 Calculated ......... 1 •90 ohmmeters WATER ANALYSIS PATTERN Scale Sample above described ME(2 per Unit Na Ca Mg Fe CHEMICAL & GEOLOGICAL LABORATORIES OF ALASKA, INC. P.O. BOX 4-1276 TELEPHONE ANCHORAGE INDUSTRIAL CENTER Anchorage, Alaska 99509 (907) 562-2343 5633 B Street megll 50.76 0.40 -__ C1 10 Na HCO'1 Ca SO" 1 Mg CO' 1 Fe C1 H C03 SO" C O' LAB NO. 5670-2 T-Pak (Na value in above graphs includes Na, K, and L1) «':~ r~ Mgh =Milligrams per liter Meq/1 =Milligram equivalent per liter >oc`iun dce P ;i.~alent=by Dunlap & Hawthorne calculation from r urr~ents ...~~:..: .._ .- ._~e __-______ ~ _-_... ~_. _ _ _ _ _ °~ ~ CHEMICAL 8c GEOLOGICAL LABORATORIES OF ALASKA, I1VC. _ ~ ` . C 4 r P.O. BOX 4-1276 TELEPHONE ANCHORAGE INDUSTRIAL CENTER u°°^•*°^~ES Anchorage, Alaska 99509 (907) 562-2343 5633 B Street WATER ANALYSIS REPORT OPERATOR Marathon Oi 1 Co. DATE 3/11/87 LAB NO. 5670-3 WELL NO. 6 LOCATION FIELD Beaver Creek FORMATION COUNTY INTERVAL_______ ____.______- STATE Alasra SAMPLE FROM T-Pak REMARKS & CONCLUSIONS: Barium, mg/1 0.16 Strontium, mg/1: ND 0.05 Iron, mg/1 39 Cations mg/1 megli Anions mgll megll Sodium 44 1 •92 Sulfate .............. ND (1) -- __. Potassium........ ... ____.~____. _ 1.00 Chloride ............. 64 1.80 Calcium .......... ... ~`~__ _ ~~ -- -- Carbonate ........... __ Magnesium ....... ... 1 .4 __ _ 0.12 Bicarbonate ......... ___-_~- _~ 1 Iron Hydroxide ........... -- -- ___ Total Cations ......... 3' 31 Total Anions .......... 3.31 Total dissolved solids, mgll ..... __ 199 Specific resistance Cu 68° F.: NaC1 equivalent, mgll .............. 180 Observed .......... 30.3 _ohm-meters -- Observed pH ....................... _ 6.4 Calculated ......... ~~ ohm-meters WATER ANALYSIS PATTERN Scale Sample above described MEQ per Unit Na Ca Mg Fe C1 1 Na HC03 1 Ca SO" 1 Mg CO' .1 Fe C1 HCO' SO' C03 {Na value in above graphs includes Na, iC, and Lt) N0T6: MGf1 = Pdilligrams per liter Megti =Milligram ecuivalen! per liter Sodium CMaridc epu!~~alent=by Dunlap & Hawthorne ca'culahon from comp:,nena .. ~1 tl _ °w e+ - °j ~ - `i IASORATORrl4 • • CHEMICAL & GEOLOGICAL LABORATORIES OF ALASKA, INC. P.O. BOX 4-1276 TELEPHONE ANCHORAGE INDUSTRIAL CENTER Anchorage, Alaska 99509 (907) 562-2343 5633 B Street WATER ANALYSIS REPORT OPERATOR Marathon O i 1 Co. DATE 3/ i 1 /87 LAB NO. 5670-4 WELL NO. ~ LOCATION FIELD Beaver Creek FORMATION COUNTY _ INTERVAL__ __ STATE Alaska SAMPLE FROM T-Pak REMARKS & CONCLUSIONS: Barium mq/1 1 .6 Strontium mq /1: 0.60 Iron m 1 0.20 Cations mgli meg/i Anions mgll meg/1 Sodium ...... ....... __1324 S] _ 4_~ Sulfate .............. N D (1) _ _ __. Potassium .... ....... _ 44 1 _ 1 ~ Chloride ............. 1900 -- 53 58 Calcium ...... ....... 30_ 4.4~ Carbonate ........... 24 0.80 --- Magnesium ... ....... ____ _2D_ _ 1 .64 Bicarbonate ......... _ -~~ .___ 10_~_~_ Iron ......... ....... Hydroxide .......... . Total Cations ......... _ Tota{ Anions ......... . Total dissolved solids, mg/1 .......... ___ 037 8 NaC1 equivalent, mgli .............. ~5~ Observed pH ....................... g • ~ Na Ca Mg Fe Specific resistance C 68° F.: Observed .......... __ 1_~3 ohm-meters Calculated ......... 1 ~~ ohm meters WATER ANALYSIS PATTERN Scale Sample above described MEQ per Unit C1 { 0 Na HCO' ~ Ca SO' ~ Mg CO' ~ Fe C1 HCO' SO° C03 (Na value in above graphs includes Na, K, and !-ii NOTE Mglt = t'.~illigrams per liter Megl1 =Milligram equivalent per liter _ _., ~ "-Inride e , ~-• .tens=lay Dunlap & Hawthorne calculation from smpn~ents • SECTION I Injection Pressure 20 AAC 25.252(c)(8) Average and Maximum Injection Pressures: The average injection pressure will be 500-700 psi surface. During Phase I, the maximum surface injection pressure will be limited to the working pressure of the casing head which is 3000 psi. -18- i Doyle L. Tones / Production Manager 1,/-L/ Alaskan District Production United States M Marathon MARATHON Oil Company P.O. Box 102380 Anchorage, Alaska 99510 Telephone 907/561-5311 May 12, 1987 Mr. C. V. Chatterton, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 RE: UNDERGROUND INJECTION BEAVER CREEK FIELD KENAI PENINSULA, ALASKA Pursuant to our recent correspondence, Marathon Oil Company, requests that an injection order be issued to authorize the conversion of BC~~2 from a Shut-In Producer to a Class II disposal well. Attached is a completed permit application. Should you have any questions regarding this proposal, please contact Th as R. Brooks at 564-6316. 0' , DOYLE JON mrh ES5:44 cc: T. R. Brooks J. A. Dygas B. Richey K. Humphrey ii • • SECTION J Fracture Information 20 AAC 25.252(c)(9) f1 From time to time it will be necessary to fracture the injection interval to move accumulated solids or solids bearing fluid throught the perforations into the injection strata. The fracturing will be confined to the injection zone. Approximately 61.1'. of claystone separates the Phase II perforated intervals from the top of the exempted zone. Because of the ductile nature of these claystone stringers, they should serve as effective barriers to vertical migration of any hydraulic fracture. Well logs indicate there are several coal layers present above the injection interval. Coals are also known to be good barriers to fracture propagation. Previous injection testing has demonstrated that with water or oilfield brines at expected viscosities and requested pumprates, a fracture cannot be propagated in the subject formation. The only time it will be necessary to fracture the well will be to move solids. and/or highly viscous fluids through and away from the perforations. Since any fracture will be unpropped, once injection ceases, the induced fracture will close. Sufficient time will be available between occasional periods of high viscosity fluid injection to allow fracture closure. As an additional demonstration that vertical fractures will nat enable fluids to reach non-exempt fresh water strata, a worst case scenario, without benefit of the claystone stringers, was analyzed. The worst case scenario assumes that an undiluted drilling mud. is injected under the conditions present in BC#2. To model the interval, we assume a homogeneous reservoir of 30000 (600' x 50 md) and-ft of capacity. Further assume a vertically unconstrained "penny type fracture" 600' in height with a wing length (Xf) of 150'. Given a worst case mud viscosity of 100 cp and a o P(FBHP-P) of 2000 psi the dimensionless pressure is given by _----- P,~ _ k h p P _ so C(ooo> 200 l~-l. z'°f ~`~ ~ \ 4 \.2 C3ooo~1. o~C \oo~ v 1,42 -19- • • Entering the Gringarten type curve for a well with an infinite conductivity vertical fracture, for an infinite reservoir a tD value of 1.6 is read. Substituting this into the formula for dimensionless time: k~ Sort `~'4 - 1•lc = .ooo~. ~ ~`C~ xf2 - . oao2~o 4 , 30~~oo`,~Co,zxto )L~So t (hrs) can be calculated. When using this type curve to model injection, t is the amount of time that fluid. of 100 cp viscosity ~C. must be pumped at 3000 BPD and 200 psi pressure differential before ~)^~`~~`~ the fracture area is extended out of the exempted interval (600'. '~ above the top perforation). In this case, it is 21 days. This would be approximately ten times the volume and 2-3 times the viscosity of any mud we would expect to inject at any time. It is doubtful that fluids of this viscosity will ever be pumped in the well. Usual viscosities will be close to 1 cp. -20- • • SECTION K FORMATION FLUID 20 AAC 25.252 (c)(10) The injection fluid for disposal will be predominently produced water from the other Beaver Creek wells (See. Attachment H-1). The source of the produced water is from the Sterling B-2, 3, 3A, and 4 sands: Full compatibility with the formation is anticipated as injection will also be into the B-2 and B-3 sands. -21- ~ • 1 ~ SECTION L ' AQUIFIER EXEMPTION 20 AAC 25.252(d)> S The a uifier within 3300 feet of the BC#2 well bore is exam tad q P pursuant to 40 CFR 147 (b)(1)(B) to a vertical depth 1650 feet from ' the surface (See Attachment L-1). t t 1 ~ -z,_ it , ~`f, C 1 1 1 ~c 1 1 1 1 1 1 1 _ __ _.._ ,~r~~ ~- ATTACHMENT. L-1 * *t't'' 132:0502 FEDERAL REGULATIONS made a part of the applicable UIC pro- gram under the SDWA .for the State of Alabama. This incorporation by reference was approved by the. Director of the Fed- oral Register on June 25, 1984. (1) Code of Alabama 1975, §§ 9-17.1 through 9-17-110 (1980 and Supp. 1983 ); (2) State Oil and Gas Hoard of Ala- bama, Oil and Gas Report 1 (supple- mented) (1981), General Order Pre- scribing Rules and Regulations Governing the Conservation of Oil and Gas in Alabama .(Order No. 76-100) as amended by Board Order No. 82-96 (May 14, 1982) amending Rule E-4). (b) The Memorandum of Agreement between EPA Region IV and the Alabama Oil and Gas Board, signed by the EPA Regional Administrator on June 15. 1982. (c) Statement ojLegal Authority. "State Oil and Gas Board has Authority to Carry Out Underground Injection Con- trol Program Relating to Class II Wells as Described in Federal Safe Drinking Water Act -Opinion by Assistant Attorney General,".May 28, 1982. (d) The Program Description and any other materials submitted as part of the application or as supplements thereto. §147.51 State-administered program - .Class I, III, IV and V wells The UIC program for Class I, III, IV and V wells in the State of Alabama is the program administered by the Alabama Department of Environmental Manage- ment, approved by EPA pursuant to Sec- tion 1422 of the SDWA. Notice of this approval was published. in the Federal Register on August 25, 1983 (48 FR 38640); the effective date of this program is August 25, 1983. This program consists of the following elements, as submitted to EPA in the State's program application: (a) Incorporation by reference. The re- quirements set forth in the State statutes and regulations cited in this paragraph are hereby incorporated by reference and made a part of the applicable UIC pro- gram under SDWA for the State of Ala- bama. This incorporation by reference was approved by the Director of the Federal Register on June 25, 1984. (1) Alabama Water Pollution Control Act, Code of Alabama 1975, §§22-22-1 through 22-22-14 (1980 and Supp. 1983); (2) Regulations, Policies and Proce- dures of the Alabama Water Improve- ment Commission, Title I (Regulations) Rev. December 1980),. as amended May 17, 1982, to add Chapter 9, Underground Injection Control Regulations (effective June 10, 1982), as amended April 6, 1983 (effective May 11, 1983). (b) The Memorandum of Agreement between EPA Region IV and the Alabama Department of Environment Management signed by the EPA Regional Administra- tor on May 24, 1983. (c) Statement of Legal Authority. (1) "V1~'ater Pollution-Public Health-State has Authotity to Carry Out Underground injection Control Program Described in Federal Safe Drinking Water Act- Opinion by Legal Counsel for the Water Improvement Commission," June 25. 1982; (2) Letter from Attorney, Alabama Water Improvement Commission, to Regional Administrator. EPA Region IV, "Re: AWIC Response to Phillip Tote's (U.S. EPA. Washington) Comments on AVJIC's Final Application for Class I. III, IV, and V U1C Program," September 21. 1982: - __ (3) Letter from Alabama Chief Assistant Attorney General to Regional Counsel, EPA Region IV, "Re: States of Independent Legal Counsel in P.labama Water Improvement Commission's Underground Injection Control Program," September 14, 1982. (d) The Program Description and any other materials submitted as part of the application or as supplements thereto. Subpart C-Alaska § 147.1Q0 State-administered program. [Reserved] §147.101 EPA-administered program. (a) Contents. The UIC program for the State of Alaska is administered by EPA. This program consists of the UIC program requirements of 40 CFR Parts 124, 144, and 146, and additional requirements set forth in the remainder of this subpart. Injection well owners and operators, and EPA, shall comply with these requirements. ' (b) Effective date. The effective date of the UIC program for Alaska is: June 25, 1984. §147.102 Aquifer exemptions. (a) This section identifies any aquifers or their portions exempted in accordance with §§ 144.7(b) and 146.4 of this chapter at the :time of program promulgation. EPA may in the future exempt other aquifers or portions., according to applica- ble procedures, without codifying such ez- emptions in this section.. An updated list of exemptions will be maintained in the Re- gional office... (b) The following aquifers are exempted in accordance with the provisions of §§144.7(b) and 146.4 of this chapter for Class II injection activities only: (1) The portions of aquifers in the Kenai Peninsula, greater than the indicat- ed depths below the ground surface, and described by a '/: mile area beyond and lying directly below the following oil and .gas producing fields:. (A) Swanson River Field-1700 feet. - (B) Beaver Creek Field-160 feet. (C) Kenai Gas Field-1300 feet. (2) The portion of aquifers beneath Cook. Inlet described by a !4 mile. area beyond and lying directly below the fol- lowing ail and gas producing fields: (A) Granite Point. (B) McArthur River Field. (C) IVliddle Ground Shoal Field. (D) Trading Bay Field. (3) The portions of aquifers on the North Slope described by a '!, mile area beyond and lying directly below the Ku- paruk River Unit. oil and gas producing field._ §147.103 Existing class I, II (except en- • hanced recovery and hydrocarbon storage and III wells authorized by rule Maximum injection pressure. The own- er or operator shall limit injection pressure to the lesser of: _ (a) A value whicTi will not exceed the operating requirements of §144.28(f)(3)(i) or (ii) as applicable; or (b) A value for well head pressure cal- culated by using the following formula:. Pm=(0.733-0.433 Sg)d where Environment Roporter [SeC. 147.103(b)] t52 ~ • SECTION M MECHANICAL INTEGRITY 20 AAC 25.252(d) A mechanical integrity test will be performed as specified in 20 AAC 25.412 prior to injeciton. The casing tubing annulus pressure will be monitored monthly and reported on Forms 10-406. -24- • • SECTION N WELLS IN THE AREA 20 AAC 25.252 (h) There are no wells within the BC#2 area of review. -25- i M Marathon MARATHON Oil Company May 4, 1987 Doyle L. Jones Product' anager Alaska rict Productio~~ United States P.O. Box 102380 Anchorage, Alaska 99510 Telephone 907/561-5311 Mr. C. V. Chatterton, Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive ~ ~~ Cry ~ ®~' Anchorage, AK 99501 ~"rti ~ "~ "' ~~ -~ tc ~, RE: UNDERGROUND INJECTION BEAVER CREEK FIELD KENAI PENINSULA, ALASKA _O'; ~_ .g >~., r s :~ 'i~ ~' r.. - . is _ ,=~ Y:" , ,c. , ~,. ; , ~. ~. ~~ y `s { a `. ~;~-/ Marathon Oil Company, as operator of Beaver Creek Field, requests that an injection order be issued to authorize the conversion of ~C~~2 from a producer to a Class II disposal well. The wastes proposed for injection consist of nonhazardous waste fluids generated during normal drilling, workover and production operations. The proposed injection depth would be those zones suitable for injection 50 feet below the 13 3/8" (2211') casing or below 2261'. Injection into BC~12 will be accomplished in two phases. In Phase I, it is proposed to inject into existing perforations open in the Sterling B-2 gas sands from 5125'-5140'and proposed perforations reopening the Sterling B-3 gas sands from 5155-5220'. These sands watered out in early 1987. Phase II would be initiated after Phase I is complete. In Phase II, it is proposed to abandon the perforations from Phase I and inject into the Sterling formation through perforations below 2261'. Should you have any questions regarding this proposal, please contact Thomas R. Brooks at 564-6316. Sincerely, Doyle Jone mrh ES5:50 cc: T. R. Brooks J. A. Dygas Bob• Richey y~_ E.:;,,_.