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Home My WebLink AboutO 185Other Order 185 Docket No: OTH-21-017 Eni's Failure to Test 19 Injection Wells at Nikaitchuq Unit 1. March 17, 2021 2. March 18, 2021 3. March 22, 2021 4. March 23, 2021 5. March 25, 2021 6. April 10, 2021 7. April 27, 2021 8. May 11, 2021 9. May 18, 2021 10. May 25, 2021 11. May25, 2021 12. June 8, 2021 13. July 8, 2021 Eni's emailed notice to the AOGCC regarding Mechanical Integrity Tests (MIT) that were missed and overdue Email communications regarding AOGCC test witness notification Eni's notice regarding four wells that failed MIT on 3/21/21 Eni's documented MITs that were conducted on 3/21 and 3/22/21 Eni's notice regarding a failed TxIA pressure communication on SI-26 (PTD 214-157) Eni's notice regarding TxIA pressure communication on SI-29 (PTD 212-006) Email communications regarding numerous wells that missed MIT deadlines AOGCC's email to Eni regarding Proposed Enforcement action Eni's notice regarding successful installation of 4 tubing patches in 0I13 (PTD 211-100) Email communications regarding next MIT due dates for wells tested in March and April 2021 AOGCC's official Notice of Proposed Enforcement Action Eni's Response to the Notice of Proposed Enforcement Action Eni's Presentations during the AOGCC Informal Review ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Failure of Eni US Operating Company, Inc. to ) Docket Number: OTH-21-017 Test 19 Injection Wells for Tubing/Casing ) Other Order 185 Annulus Mechanical Integrity at Nikaitchuq Unit. ) July 21, 2021 DECISION AND ORDER On May 25, 2021, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Eni US Operating Company, Inc. (Eni) regarding late mechanical integrity tests (MIT). The Notice was based upon Eni's performance of well operations at its Nikaitchuq Unit (NU) after failing to test 19 injection wells for mechanical integrity as required by AOGCC Order and regulation. The Notice proposed specific corrective actions and a $440,000 civil penalty under AS 31.05.150(a). Eni requested an informal review. That review was held July 8, 2021. Summary of Proposed Enforcement Action: A review of injection well activities performed at NU by Eni revealed 19 wells were not tested for mechanical integrity within the required four-year cycle, a violation of Area Injection Order 36 and AOGCC regulations. After gathering information and further discussions with Eni, AOGCC proposed a $440,000 civil penalty. Informal Review: Eni met with AOGCC on July 8, 2021 to present the results of its internal review. Eni's presentation outlined the summary of events, the root causes for missing the MIT deadlines, and solutions in response to the proposed enforcement. Eni did not dispute the violations alleged in the Notice. Eni acknowledged that this violation is a reoccurrence of the missed MITs of four years previous as documented in Other Order 124, and that the 2016 changes to Eni's tracking system proposed to rectify the 2016 violations were insufficient to prevent reoccurrence. Eni questioned the penalty amount during the review, suggesting it be reduced. Other Order 185 July 21, 2021 Page 2 of 5 Discussion MITs for the 19 injection wells were due during the month of December 2020 based on the previous tests being completed in December 2016 (Table 1). Eni notified AOGCC that the MITs were missed and overdue on March 17, 2021. Eni never requested additional time to complete the tests. The MIT violations at NU are not isolated and demonstrate Eni's ongoing compliance problems, including: - Failure to test l I injection wells for tubing/casing annulus MIT at NU resulted in a penalty of $110,000 to Eni on July 26, 2017.1 Since that time, two other enforcement actions have been issued; - Failure to submit blow out prevention equipment (BOPE) test reports at Nordic Rig 4 of November 8 and November 15, 2018, resulting in a Notice of Violation (NOV) issued by AOGCC on December 6, 20182; and - Failure to complete a required sundry report of well work within the required time for NU well SD37-DSPI; $10,000 s The failure to conduct MITs on the 19 NU wells occurred after AOGCC fined Eni $110,000 for its failure to conduct MITs on 11 NU wells in 2016. Those tests were witnessed in December 2016, making the next testing due date December 2020. The failure to test in December 2020 — the subject of this enforcement action — is the exact same violation and occurred after the imposition of the $ 110,000 penalty. Other Order 124 states: "In addition to the civil penalty, Eni is required to develop and implement a tracking system for regulatory obligations, including an automated alert for approaching and past -due obligations, with notifications provided to Eni personnel responsible for the regulatory obligation. " ' Other Order 124, Issued July 26, 2017, Docket OTH-17-001 'Docket OTH-18-059 ' Other Order 171 issued September 20, 2020 (AOGCC Docket OTH-20-043) Other Order 185 July 21, 2021 Page 3 of 5 For these violations, the AOGCC intends to impose civil penalties on Eni as follows.4 - $380,000 — ($20,000 for each of the initial violations of 19 wells) failure to perform the required MITs of the 19 injection wells in compliance with testing protocols specified in Rule 6 of AIO 36; - $60,000 — ($10,000 for each of the four wells that failed the overdue MIT witnessed on March 21, 20215 and the two wells that exhibited tubing by inner annulus (TX1A) pressure communication and subsequently failed their MITs. 6) Findin¢s and Conclusions: Eni continues to violate Area Injection Order 36 during the operation of injection wells at NU by failing to perform the required MITs on 19 wells. The factors in AS 31.05.150(g) have been considered in the determination of penalties for the violations.' Eni worked with diligence and urgency to coordinate with AOGCC to witness the required testing. The passing tests on 13 of the 19 NU injection wells, witnessed by AOGCC on March 21, 2021, and April 30, 2021, have mitigated the penalty imposed. Although daily penalties have not been imposed, AOGCC notes the violations occurred after the imposition of a $110,000 penalty for the same conduct in 2016 and is imposing a $20,000 civil penalty for each of the 19 wells with the overdue MITs, in addition to a $10,000 civil penalty for each of the six wells failing the required MIT. No additional mitigations to the penalty are being applied. Now Therefore It Is Ordered That: Eni is assessed a civil penalty in the amount of $440,000 for violating Area Injection Order 36, for missed mechanical integrity tests on 19 NU injection wells, and for failing the required MITs on six wells. If Eni chooses not to appeal this Order, the fine must be paid within 30 days of issuance. If appealed, the fine will be held in abeyance until the appeal process is complete. In addition to the civil penalty, Eni is required to improve its tracking system for regulatory obligations by implementing the corrective actions to the identified causal factors as detailed in the Eni investigation report "2021 Spy Island and Nikaitchuq Overdue Four -Year Mechanical Integrity Tests." 4 AS 31.05.150(a) provides for not more than $100,000 for the initial violation and not more than $ 10,000 for each day thereafter on which the violation continues. 5 0106-05 (PTD 2101650); 0113-03 (PTD 2111000); 0115-S4 (PTD 2111410); and 0120-07 (PTD 2111400) 6 S126-NW2 (PTD 2141570) and S129-S2 (PTD 2120060) 7 AS 31.05.150(g) requires AOGCC to consider nine criteria in setting the amount of a civil penalty. Other Order 185 July 21, 2021 Page 4 of 5 As an operator involved in an enforcement action, Eni is required to preserve documents concerning the above action until after resolution of the proceeding. Done at Anchorage, Alaska and dated July 21, 2021. pgI4YYsgxd lry Jeremy Price""m°°'"` wmzwiuxm ISA331 {6W Jeremy M. Price Chair. Commissioner Daniel DlIWIl091Mbywnai YamxM Seamount.arzov.wn oe:axoa Daniel T. Seamount, Jr. Commissioner Jessie L. Digitally signed by lessle L. Chmielowski Chmielowski Date: 2031.0130 14:23s2-08ar Jessie L. Chmielowski Commissioner As provided in AS 31.05.030(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 I0days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration. UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to ran is not included in the period; the last day of the period is included, unless it falls on a weekend or slate 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. Other Order 195 July 21, 2021 Page 5 of 5 Table 1- Status of the 19 Nikaitchua Wells Missing MITs (as of May 11.20211 Well PTO It Status Date of Last Test Result Freq. (Years) Due Date Injecting since MIT due date? ITTest ate NitneSsed Result OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 4errera Pass 016-05 210-165 WIND 12/6/2016 P 4 12/5/2020 Yes /21/2021 errera Fail 3/21/2021 MIT. workover plan. eline on tractor 017-04 210-153 WIND 12/6/2016 P 4 12/5/2020 Yes /22/2021 lerrera Pass 1 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 errera Pass 3 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 errera Fail 3/21/2021 MIT. workover Ian. ellne on tractor 54 222-141 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 errera ail 3/21/2021 MIT. workover Ian. eline on tractor 7 221-140 WINJ 12/6/2016 P 4 12/S/2020 Yes /21/2021 errera Fail 3/21/2022 MIT. workover Ian. eline on tractor 8 qS120-N4 212-230 WINJ 12/6/2016 P 4 12/5/2020 Yes /23/2021 cLeod Pass E4 214-100 WINJ 12/20/2016 P 4 12/9/2020 Yes /1/2021 k Pass SillN6 213-128 WIN) 22/10/2016 P 4 12/9/2020 Yes /1/2021 ook Pass N4 212-156 WINJ 22/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass 6 213-194 WINJ 22/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass SE2 224-041 WINI 12/10/2016 P 4 12/9/2020 Yes /30/2021 k ass N2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook Pass N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2022 ook ass 5125-N2 212-090 WINJ 12/10/2026 P 4 12/9/2020 Yes /30/2022 ook ass 5126-NW2 214-157 WINJ 12/30/2016 1 P 4 12/9/2020 Yes AA tracking reported /25/2021, shut in, MIT fail, plan or eline on tractor 5129-52 212-006 WINJ 22/10/2016 P 4 12/9/2020 Ves x1A tracking reported /10/2021, MIT fail. 5132-W2 213-013 WINJ 12/10/2026 P 4 12/9/2020 Ves /30/2021 ook ass Salazar, Grace (CED) From: Salazar, Grace (CED) Sent: Wednesday, July 21, 2021 9:09 AM To: AOGCC Public Notices Subject: AOGCC Other Order No. 185 Attachments: OTH 185.pdf The Alaska Oil and Gas Conservation Commission has issued the following Order: (Attached) Re: Failure of Eni US Operating Company, Inc. to Test 19 Injection Wells for Tubing/Casing Annulus Mechanical Integrity at Nikaitchuq Unit. �2acv Respectfully, M. Grace Salazar, Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7tn Avenue Anchorage, AK 99501 Direct: (907) 793-1221 Email: grace.salazar@alaska.gov https://www.commerce.alaska.goy/web/aogcc/ Docket Number: OTH-21-017 Other Order 185 July 21, 2021 Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 jp Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 INDEXES ENI Failure to Conduct Injector 4-year MIT's (Rule 6 of Area Injection Order 36) December 2020 Investigation ENI 7/08/21 2n� Nikaitchuq 4 Year MIT— Background ■ April 2016 - 11 injector MIT's past due • AOGCC NOV requiring ENI to • Implement tracking system • Automated alert for approaching obligations • Notifications to ENI personnel responsible ■ April 2017 — ENI AOGCC Informal Hearing • ENI Proposed Solutions • MIT PM's added to SAP (automatically populated to "Hitch List") • Clear Division of Responsibility between departments (Prod Ops maintain MIT compliance) • Full -Time slope positions with focus on regulatory compliance ■ Dec 2020 - 19 injector MIT's past due 2ni Nikaitchuq 4 Year MIT— 2021 Investigation • 2017 ENI Proposed Solutions • MIT PM's added to SAP (automatically populated to "Hitch List") • Clear Division of Responsibility between departments (Prod Ops maintain MIT compliance) • Full -Time slope positions with focus on regulatory compliance ■ 2021 Investigation • CF 1- There is no formal procedure for getting things added to the SAP hitch list, who is responsible for verification of accuracy of items, review of items completed to verify they are complete, and timelines for each step. • CF 3 -SAP Hitch list identified "MIT Testing of SID INJ Well 4 year" w- it�i a start date of Nov 1, 2020. Inadequate description. • CF 4 - Incomplete hitch list items that are not completed need to e�manually carried over to next hitch lists. • CF 5 -There was limited training for operators on some aspects of i tTie Area Injection Order for NIK. eni Nikaitchuq 4 Year MIT— 2021 Investigation • 2017 ENI Proposed Solutions • MIT PM's added to SAP (automatically populated to "Hitch List" • Clear Division of Responsibility between departments (Prod Ops maintain MIT compliance) • Full -Time slope positions with focus on regulatory compliance= ■ 2021 Investigation • CF 2 — Though the Compliance Coordinator position was added in March 2018, there was no training on information related to AOGCC to the Compliance Coordinators. The Compliance Coordinators were intentionally not given those responsibilities because there was a system in place for managing anything with AOGCC compliance. Nikaitchuq 4 Year MIT— 2021 Investigation ■ 2021 Investigation (additional Causal Factors) • CF 6 - Two normal lead operators at OPP were on vacation on October 28th and did not return to site until December. Their normal hitch would have placed them back on site on Nov 4. The Step -Up Lead Operator on duty did not see the hitch list item. • CIF 7 - For NIK MIT due dates, there is currently no vehicle being used to notify the Production Engineer of those MIT due dates 2rnni Corrective Actions (Notification and Tracking System) ■ Entry of MIT Requirements Into TruApp and Avocet • Adequate description of the MIT requirements • Notification to wide distribution (management included) • Procedure with a RACI chart to define responsibilities and tracking through the execution of MIT's • Prod Sup will review TruApp list once per week of Step -Up Leads • TruApp will be used as primary PM and Compliance Tool • Avocet will be used for redundant notification system 2n� Avocet Oooguruk Success ■ 2016 Oooguruk Implement Avocet for Regulatory Notices Wells overdue for SVS Test as of 7/7/2021 - Integrated Avocet2017 WELL NAME TYPE SVS TEST LAST MIT DATE NEXT SVS OVRD STATUS FRED DATE K14 PRODUCTION 180 Feb 28, 2020 Aug 15, 2020 -- K33 PRODUCTION 180 Feb 26. 2013 May 27,2013 - K41 PRODUCTION 180 Mar 3, 2021 Aug 15, 2021 - N01A PRODUCTION 180 Mar 3, 2021 Aug 15, 2021 - NO2 PRODUCTION 180 Mar 14, 2021 Aug 15, 2021 - N04 PRODUCTION 180 Apr 17, 2021 Aug 15, 2021 - N06 PRODUCTION 180 Mar 3, 2021 Aug 15, 2021 - N70 PRODUCTION 180 Mar 15, 2021 Aug 15, 2021 - N16 PRODUCTION 180 Mar 3, 2021 Aug 15, 2021 -- N17 PRODUCTION 180 Feb 28, 2020 Aug 15, 2020 OVERDUE NIS PRODUCTION 180 Mar 3, 2021 Aug 15, 2021 - N19 INJECTION 180 May S 2021 Aug 15, 2021 - N22 PRODUCTION 180 Mar 28, 2021 Aug 15, 2021 - N24 PRODUCTION 180 Od 10, 2020 Feb 15, 2021 - N25 PRODUCTION 180 May 6, 2021 Aug 15, 2021 - Wells overdue for MIT as of 7/7/2021 - Integrated Avocet2017 WELL NAME TYPE MIT TEST FREO LAST MIT DATE PRE NEXT MIT OVRD STATUS INJECTION DATE DW1-44 DISPOSAL 365 Od20. 2020 False Oc120. 2021 -- K35A INJECTION 1460 Nov 20, 2015 False Nov 19. 2019 OVERDUE K36 INJECTION 1460 Jan 26 2021 False Jan 25 2025 -- NO3 INJECTION 730 Ju125, 2020 False Ju125, 2022 -- N07 INJECTION 730 Od 25, 2020 False OCI25. 2022 -- N15 INJECTION 1460 Dec 29, 2019 False Dec 28, 2023 - N79 INJECTION 1461 Mar 8, 2019 False Mar 8, 2023 - N23 INJECTION 1461 Jul 13, 2020 False Jul 13, 2024 -- N26 INJECTION 1461 Oct 25, 2020 False Od 25, 2024 -- N27 INJECTION 1461 Dec 8, 2018 False Dec 8, 2022 -- N32 INJECTION 1461 Aug 26, 2017 False Aug 26, 2021 -- N34 INJECTION 1461 Mar 3, 2018 False Mar 3, 2022 -- N40 INJECTION 1461 Jul 25, 2020 False Ju125, 2024 -- N48 INJECTION 1461 Sep 12, 2019 False Sep 12, 2023 -- T46 INJECTION 1461 Jan 26, 2021 False Jan 26, 2025 Corrective Actions (Compliance Coordinator) ■ Compliance Coordinator • Update the Compliance Coordinator's job description to reflect that they are responsible for ensuring compliance with MIT completion obligations. • Conduct an MOC to document these roles and responsibilities to acknowledgment the Compliance Coordinator has received them. 2021 Spy Island and Nikaitchuq Overdue Four Year Mechanical Integrity Tests Eni S.p.A. INDACO Case Number 130971 jr Investigation Report • Case INDACO N. 2rnnl II Overdue Four Year Mechanical Integrity Tests Title: Overdue Four Year Mechanical Integrity Tests (MIT) Investigation team: Name Company/Unit David Hart Alaska Operations Manager Larry Burgess Alaska SEQ Manager Mike Dibello Alaska Production Manager Keith Lopez Alaska Production Engineer Dan Lyden/Stephen Alaska Production Superintendents Dexheimer Keith Hendrickson/Tim Nik Production Supervisors Brown Jane Thomas North Slope Environmental Advisor Rich Vicente North Slope Compliance Coordinator Bobby Carroll Alaska Production Safety Coordinator Distribution: Name Company Role First Last Company or contractor Title/role name Insert all Investigation Report 2c n Q Overdue Four Year Mechanical Integrity Tests Revisions Table Rev. a Date List of modifications xx/xx/xxxx First issue Case INDACO N. > Investigation Report 2 fl Overdue Four Year Mechanical Integrity Tests Index 1. HSE Event Summary ...................................... 2. Introduction..................................................... 3. Context Analysis (Background) .................... 4. Description of Events ..................................... 5. Cause Analysis and Corrective Actions ....... 6. Final results/outcomes of the Investigation 7. Lesson Learned and Safety Golden Rule.... 8. Continuous Improvement ............................. 9. Signatures......................................................... 10. Attachments .................................................. Case INDACO N. ............................................................................ 4 ............................................................................ 5 ............................................................................ 5 ............................................................................ 8 ............................................................................ 9 .........................................................................13 .........................................................................14 .........................................................................14 ..................................................................I......14 .........................................................................14 Investigation Report e Case INDACO N. 2 nng Overdue Four Year Mechanical Integrity Tests 1. HSE Event Summary GENERAL INFORMATION BU - Company involved Geographic Area Site Location of the event Eni Us Operating Co, North Slope, AK SID and NIK SID and NIK Inc. Date of event December 30, 2020 Time of event N/A ACCIDENT ❑ NEAR MISS ❑ UNSAFECONDITION/ACi ❑ HIPOEVENT ❑ EVENT DETAILS If multiple event, specify number of people involved: EXTERNALEXTE If CONTRACTOR, indicate name of company Injured type RNAL Company: XXXX INJURY ❑ YES ® NO Indicate the category of harmful events ❑ ❑ ❑ ❑ ❑ Fatality Lost Time Injury Medical Restricted Work First Aid Treatment Day Case ❑ ❑ ❑ ❑ Fire/Explosion Spill Gas Leak Business DAM EGES TO ASSET / Interruption ENVIRONMENT/ ® YES ❑ NO REPUTATION ❑ ® ❑ Vehicle Accident Impact to Reputation Asset Damages EMERGENCY LEVEL Second Level EmergencySecond Level Emergency INVESTIGATION LEVEL ® B yellow NOTES Investigation Report o Case INDACO N. 2nOverdue Four Year Mechanical Integrity Tests 2. Introduction On December 30, 2020, the deadline for completion of mechanical integrity tests (MIT) for 19 injector wells, on OPP and SID had been reached without completion. MITs of wells are governed by the Alaska Oil and Gas Conservation Commission (AOGCC) and in this particular instance, Eni failed to complete the four year MIT for these nineteen injector wells prior to the due date. The investigation team, which consisted of Production, Compliance, Environmental, and Safety Personnel, identified several system failures and software deficiencies that led to this event. The team members were selected due to their knowledge of the systems used for tracking MIT due dates, familiarity of the processes used, and perspectives on how to improve identified gaps to prevent reoccurrence. All persons interviewed and all persons requested to deliver information and documentation were fully cooperative and helped tremendously in the findings from this investigation. In compliance with Annex S-B to Eni HSE Management System Guidelines, an investigation team was appointed in order to establish the sequence of events, the causal factor, as well as possible corrective and improvement actions and recommendations. The investigation took place via Microsoft teams meeting platform between the North Slope and the Anchorage office between May 24, 2020 and June 2, 2020. 3. Context Analysis (Background) The following information was determined by the investigation team to not be the causal factors that led to this event, but relevant background information to provide an overview of how the event occurred. The casual factors and corrective action will be captured later in this report in Section 5. • 2011 Production Engineer would notify Production Operators/Supervisor about wells that needed MIT and when. • 2014, the original hitch lists in SAP were created for maintenance and operations PMs only, not for MITs. • The Maintenance Supervisors would facilitate the items that went into SAP but each department managed the content of the task list. • 10/2016 - During the creation of the MIT procedure, the operator found the MIT 4 year rule in AOGCC. • This procedure did capture the AOGCC 4 year requirement for MIT. • Due dates for the overdue MITs range from 4/26/2016 - 9/11/2016 I= Investigation Report Case INDACO N. enl i Overdue Four Year Mechanical Integrity Tests • An informal hearing with AOGCC was held to cover these missed MITs March 2017 • 11/2016 — MIT PM's are added to the SAP hitch list • Clear division of responsibilities between groups has been discussed and documented. • Production Operations was tasked with maintaining compliance of MIT's. • A North Slope based position was to be created to manage AOGCC compliance. A complete review of AOGCC processes and procedures was completed to ensure that all compliance standards would be adhered to. • 12/2016 - In the email from the SID Lead Operator to the Production Supervisor, the Lead Operator listed out all the wells, and their new 4 year MIT due date of 12/6/2020 and 12/10/2020. • 12/2016 Email from the Production Supervisor to the SAP Coordinator stated Eni had previously gone over the state regulated 4 year MIT mandate. The Production Supervisor requested that the hitch list with the MITs being due come out 2-3 weeks ahead due to needing to get the State Rep on site to witness the test. • SAP is not a compliance tracking system, but it was being used as such. • Proposed title of task from the SAP Coordinator to the Production Supervisor: "Disposal Practices and Applicable Regulations" • The SAP Coordinator referenced the disposal well regulations mistakenly in his proposed draft to the Production Supervisor for entering this 4 year MIT into SAP. • The description of the MIT test that was entered into SAP was the MIT procedure and aligned per regulatory requirements. • 5/2017 — In the job description developed for the new Compliance Coordinator position it was listed that monitoring of AOGCC and DOT regulatory was to be their responsibility. • SAP was being used to generate the notification for MITs that need be completed. SAP hitch list would go straight to the Lead Operators. 3/2018 - The Compliance Coordinators manage various aspects of compliance with DOT and PSM requirements. • Compliance Coordinators had not received training on well integrity or AOGCC regulations. • No MOC was created for the organizational change of adding the Compliance Coordinator position, or job description for position. • 2020 TruApp was rolled out and time was needed for training and implementation of the TruApp program. However, some continued to use the hitch list from SAP In transition from SAP to TruApp not 100% of items got transferred into TruApp r� Investigation Report • Case INDACO N. enn fl Overdue Four Year Mechanical Integrity Tests • Unlike SAP, in TruApp items on the hitch list that are not completed will automatically roll over to the next hitch list until they are completed. • 11/2020 - 13 well MITs on SID were due to be completed by December 2020. • This SAP hitch list for the 4 year MITs was released on Nov 1, 2020 allowing for 8 weeks to complete. • SAP hitch list comes out on the 1st of the month and 16th of the month, but users typically only look at the hitch list for the time they are on shift. • The Hitch List title for the task was not detailed and the step-up SID Lead Operator did not review the detailed description. Title: MIT Testing of SID Inj Well 4 year" • Step-up SID Lead Operator addressed the Hitch list item and commented that the "SD37 DSP01 well is down". • The SID MIT hitch list items did get carried over by the SAP Coordinator for the next two hitches. • 11/2020 — Olitok Production Pad (OPP) hitch list came out however, the hitch list item was missed by OPP step up Production Lead Operators. The language on the hitch list title stated injection well and it was interpreted as waste injection well and not an injector well. No MIT testing was performed. • The criteria used for selection of step up lead operators is a minimum of 3.5 years as an onsite operator, A operator status, and observed leadership capabilities. • SAP Coordinator was hospitalized for personal medical reasons. • There was a fill in for the SAP coordinator when they were in the hospital. • The SAP Coordinator would, as standard practice, call the Maintenance Supervisors at the 14th and 30th of the month to let them know that hitch list items were not completed. Then the Maintenance Supervisors would call the appropriate work group to see what the responsible party wanted to do with hitch list items that were not completed • The SAP hitch list for the OPP MIT items that did not get completed, did not get manually carried over to the next hitch. • 12/30/2020 — The deadline date for completing the MITs per AOGCC was missed and no one was aware. • 19 of the injection wells had an MIT due date December 2020 • Not having recollection of submitting the MITs to the State, the Production Engineer reaches out to the Production Supervisor and Superintendent. • Out of the total number of MITs overdue, all but six passed. Two of those six (01 13 & OI 20) have been patched and received a passing test. Four are c needing repair and retest. Investigation Report 2 rnnl i Overdue Four Year Mechanical Integrity Tests Case INDACO N. • Tubing failure could have been detected with a more robust rate of change alarm within the DCS, much like 03 has. • Without a rate of change alarm, the operating conditions of the well, before and after the T x IA communication were well within operating boundaries. 4. Description of Events In 2011, the Production Engineer was responsible for ensuring that all required MITs were completed on time and reporting back to AOGCC on this matter. Sometime between 2012 and 2013, the person working as the Production Engineer moved to a different position in the organization and the Production Engineer vacancy was filled. Because neither of these individuals work for Eni any longer, the investigation team was unable to ascertain if this responsibility for the MITs was transferred. And it is the team's assumption that it was not. Then in January of 2014 the creation of the SAP hitch list occurred, but this was only for the maintenance and operations preventative maintenance tasks, not the MITs. In October of 2016 a Production Operator who was reviewing and editing operational procedures began creating the NIK MIT procedure. During their research for this activity, they discovered that eleven injector wells were past due for their 4 year MIT. Operations immediately began the process to complete the MITS and ensure compliance. All of the injector wells were tested by December of 2016. Also in December of 2016, after this discovery, the SID Lead Operator emailed the Production Supervisor a list of all the wells that needed MITs and when their new due date would be for 2020. The Production Supervisor relayed this information to the SAP Coordinator to have them added into the SAP hitch list. In January of 2017 the SAP Coordinator responded to the Production Supervisor with a proposed draft of the entry to go into SAP for the MITs. Because these wells were overdue, AOGCC required eni to investigate the causes and develop corrective actions. March of 2017, eni had an informal hearing with AOGCC to share the findings and corrective action stemming from this event. From this 2016-2017 investigation, AOGCC was told that a Compliance Coordinator position would be created. Then in May of 2017 a draft job description was developed for this position. In March of 2018 the Compliance Coordinator position was filled. One month later, the Anchorage Production Management Leadership had a change in personnel, but the vacancy was not filled for two months. In the meantime, because operations felt they had a good system of tracking these MITs, the responsibility for tracking compliance of the MITs was not given to the Compliance Coordinator position. In October of 2019, the MIT procedure that was developed for OPP was customized for use at SID. In the fall of 2020 TruApp was rolled out to the slope to be used in leiu of the hitchlist. However, time was needed for training and implementation of this new program. November 1, 2020, the SAP hitch list that was still being used by the OPP and SID Operations Leads showed a title for the MIT testing of "MIT Testing of SID INJ Well 4 Year". On SID, this Investigation Report Fyn 2n II Overdue Four Year Mechanical Integrity Tests Case INDACO N. statement was misunderstood, and the step up Lead Operator took it to mean testing of the waste injection well was needed. However, the waste injection well was down at that time, and the step up Lead Operator did not conduct the required MITs for 13 wells on SID. At OPP the step up Lead Operator missed this item on the hitch list, and no MITs were conducted for OPP. The deadline of December 30, 2020 for these MITs elapsed unbeknownst to anyone until March of 2021. The overdue MITs were discovered by the Production Engineer while updating the Annual Surveillance Report. Not having recollection of submitting the MITs to the AOGCC, the Production Engineer reached out to the Production Supervisor and Superintendent to make them aware. In April and early May of 2021 the MITs on the water injection wells were completed and reported to AOGCC. List of statemen& Name Role Company Tim Brown Production Supervisor Eni Keith Hendrickson Production Lead Operator Eni Personnel Stephen Dexheimer Production Superintendent Eni interviewed Keith Lopez Production Engineer Eni Rich Vicente / Marty Slade Compliance Coordinator Competenia/Eni David Coombes Maintenance Supervisor Eni 5. Cause Analysis and Corrective Actions Briefly report causal factors and corrective actions in the summary table. CAUSAL FACTOR CF1— There was no formal procedure for adding action items to the SAP hitch list, identifying responsible position to verify accuracy of entries, verifying action items were completed, and CORRECTIVE ACTIONS CAl — Verify the entry of all MITs 4 year testing requirements into TruApp and Avocet. Ensure they are assigned to the right position, the title is sufficiently descriptive, and notifications are made to the Production Supervisor, Production Superintendent. Production Eneineer. RESPONSIBLE / SIGN uction Supervisors TruApp 7/1/2021 Avocet 12/1/2021 >) Investigation Report en1 A Overdue Four Year Mechanical Integrity Tests Case INDACO N. CAUSAL FACTOR CORRECTIVE ACTIONS RESPONSIBLE / SIGN establishing timelines for Production Manager and Compliance each step. Coordinator for the proper dates. (this needs to cover 03 and Nik) CA2 — Develop a procedure with an roduction and SEQ Managers embedded RACI chart that identifies ue: 9/1/2021 the positions responsible for tracking and execution of MITs, the position responsible for making AOGCC notifications, the parties to be notified about upcoming due dates, the lead times for notifications, and all associated responsibilities related to MITs. (this needs to cover 03 and Nik) CA3 — Document through signature on the procedure and RACI chart that all roduction Manager parties with any required participationDue: 30/1/2021 have been informed of their roles and responsibilities in the 4 year MITs. CA4 — Ensure the Compliance Coordinator is tasked with the specific responsibilities of confirming MITs are completed by mandatory deadlines; capture this in the developed procedure and RACI chart. CF2 — CA1— laska SEQ Manager The Compliance Update the Compliance Coordinator's ue: 8/1/2021 Coordinators were job description to reflect that the intentionally not given position is responsible for ensuring responsibilities for AOGCC compliance with MIT completion compliance because there obligations. was a system in place for managing AOGCC CA2 — compliance. Do an MOC to document these roles and responsibilities and obtain acknowledgment that the Compliance Coordinator has received them. Investigation Report Case INDACO N. e nl i Overdue Four Year Mechanical Integrity Tests CAUSAL FACTOR CORRECTIVE ACTIONS RESPONSIBLE / SIGN CF3 — CAI — Production Supervisors SAP Hitch list identified Verify the entry of all MITs 4 year Due: TruApp 7/1/2021 "MIT Testing of SID INJ testing requirements into TruApp and Avocet 12/1/2021 Well 4 year" with a start Avocet. Ensure they are assigned to date of Nov 1, 2020 the right position, the title is sufficiently descriptive, and that notifications are made to the Production Supervisor, Production Superintendent, Production Engineer, Production Manager and Compliance Coordinator for the proper dates. (this needs to cover 03 and Nik) CF 4 — CAI — Production Supervisors Incomplete hitch list items Verify the entry of all MITs 4 yearDue: TruApp 7/1/2021 that are not completed testing requirements into TruApp and Avocet 12/1/2021 need to be manually Avocet. Ensure they are assigned to carried over to next hitch the right position, that the title is lists. sufficiently descriptive, and that notifications are made to the Production Supervisor, Production Notes: Hitch list are no Superintendent, Production Engineer, longer used because of the Production Manager and Compliance use of TruApp Coordinator for the proper dates. (this needs to cover 03 and Nik) Tasks in TruApp stay open until closed. CF 5 — CAI — There was limited training Develop a procedure with a RACI chart Production and SEQ Managers for operators on some embedded to identify what position is Due: 9/1/2021 aspects of the Area responsible for tracking and execution Injection Order for NIK. of MITs, who makes AOGCC notifications, who gets notified about upcoming due dates, lead times for notifications, and all associated responsibilities related to MITs to prevent missing due dates. (this needs to cover 03 and Nik) Investigation Report • Case INDACO N. 2 f Overdue Four Year Mechanical Integrity Tests CAUSAL FACTOR CORRECTIVE ACTIONS RESPONSIBLE / SIGN CA2 - Document through signature on the Production Manager procedure and RACI chart that all Due: 10/1/2021 parties with any required participation have been informed of their roles and responsibilities in the 4 year MITs. CF 6 — CA1— Two normal lead operators Document through signature on the Production Manager at OPP were on vacation procedure and RACI chart that allDue: 10/1/2021 on October 28th and did parties with any required participation not return to site until have been informed of their roles and December. Their normal responsibilities in the 4 year MITs. hitch would have placed them back on site on Nov CA 2 — Production Superintendent 4. The Step -Up Lead Ensure that Production Supervisors,Due: 8/1/2021 Operator on duty did not when step ups are in lead roles, the see the hitch list item. Production Supervisors will review the TruApp list of the step up leads once per week. CF7— CAI — For NIK MIT due dates, Verify the entry of all MITs 4 year Production and SEQ Managers there is currently no testing requirements into TruApp and Due: 9/1/2021 vehicle being used to Avocet. Ensure they are assigned to notify the Production the right position, the title is Engineer of those MIT due sufficiently detailed, and that dates. notifications are made to the Production Supervisor, Production Superintendent, Production Engineer, Production Manager and Compliance Coordinator for the proper dates. (this needs to cover 03 and Nik) Investigation Report • Case INDACO N. 2 rnl II Overdue Four Year Mechanical Integrity Tests 6. Final results/outcomes of the Investigation There were multiple contributing factors that resulted in the overdue four year mechanical integrity tests. The Compliance Coordinators were not given the responsibilities for AOGCC compliance because there was a system in place for managing AOGCC compliance. There was no formal procedure for entering action items to the SAP hitch list, identifying responsible position to verify accuracy of entries, verifying action items were completed, and establishing timelines for each step. The SAP Hitch list (used for tracking MITs) entry was not clear. Incomplete SAP hitch list items that are not completed need to be manually carried over to next hitch lists. Hitch list are no longer used because of the use of TruApp. There was limited training for Operators on some aspects of the Area Injection Order for NIK. Two normal Lead Operators at OPP were on vacation on October 28th and did not return to site until December. Their normal hitch would have placed them back on site on Nov 4. The Step -Up Lead Operator on duty did not see the hitch list item. There was no vehicle being used to notify the Production Engineer of the MIT due dates. Essentially, this task was not clearly owned by any party and was not communicated adequately to the Operators; this resulted in it being overlooked. In order to correct this we will: • Verify the entry of all MITs 4 year testing requirements into TruApp and Avocet to ensure they are assigned to the right position, the title is sufficiently descriptive, and that notifications are made to the appropriate parties for the proper dates. • Develop a procedure with an embedded RACI chart that identifies the positions responsible for tracking and execution of MITs, the position responsible for making AOGCC notifications, the parties to be notified about upcoming due dates, the lead times for notifications, and all associated responsibilities related to MITs. • Document through signature on the procedure and RACI chart that all parties with any required participation have been informed of their roles and responsibilities in the 4 year MITs. • Ensure the Compliance Coordinator is tasked with the specific responsibilities of confirming MITs are completed by mandatory deadlines; capture this in the developed procedure and RACI chart. • Update the Compliance Coordinator's job description to include responsibility for ensuring compliance with MIT completion obligations. Investigation Report 211 11 II Overdue Four Year Mechanical Integrity Tests Case INDACO N. • Do an MOC to document these roles and responsibilities and obtain acknowledgment that the Compliance Coordinator has received them. • Ensure the Production Supervisors, that when step ups are in lead roles, the Production Supervisors will review the TruApp list of the Step -Up Leads once per week. 7. Lesson Learned and Safety Golden Rule No Golden Rule is associated with this investigation S. Continuous Improvement With the implementation of the Compliance Coordinator as oversight for the timely completion of the 4 year MITs, the use of the TruApp and Avocet to make redundant notification of due date, this should lend to continuous improvement of maintaining compliance with AOGCC requirements. 9. Signatures Reviewed By: Verified By., Approved By Bobby Carroll Larry Burgess Dave Hart Alaska Production Safety Alaska SEQ Manager Alaska Operations Manager Coordinator Signature: Signa e: Signature: - cv 10.Attachments List ofAttachments Attachment 1 — Attachment2 — Attachment 3 — Attachment 4 — Attachment 5 — 12 eni less operrafing 2n� June 8, 2021 Mr. Jeremy M. Price Chair, Commissioner Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, AK 99501 eni us operating co. inc. 3700 Centerpoint Dr., Suite 500 Anchorage, AK 99503 - U.S.A. Tel. 907-865-3300 Fax 907-865-3380 N09?021 AOGCC Subject: Re: Notice of Proposed Enforcement Action Failure to completed required Mechanical Integrity Tests (MITs) Nikaitchuq Unit, 19 wells Dear Mr. Price: Eni has received the Notice of Proposed Enforcement Action dated May 25, 2021 and acknowledges the violation of provisions of Rule 6 of Area Injection Order 36 (AIO 36) ("Demonstration of Tubing/Casing Annulus Mechanical Integrity") for 19 Nikaitchuq Unit wells. Once the violation was discovered by Eni, the AOGCC was immediately notified and all but 6 of the wells passed a state witnessed MIT. All 6 of the wells that failed the MIT have since been shut in except for diagnostic purposes. One of the 6 wells that failed the MIT (0I-20) has been repaired, passed a state witnessed MIT, and has been returned to service. Workovers are planned to repair the remaining 5 wells, with at least two temporary waiver applications being prepared to temporarily operate 0I-15 and 0I-34. Upon discovery of the violation, Eni started an extensive internal investigation to determine the root cause of the failure and to develop and implement corrective actions. Included in this response is a flow chart of events that was developed during the investigation. This flow chart explains the events leading up to the recent testing failure. In addition, it clearly demonstrates that Eni did not willfully or knowingly violate the provisions of AIO 36, and indeed disclosed the failure immediately upon learning of it. Eni has identified the root causes of the procedural and system failures and has begun implementing corrective actions to avoid future failures within our Alaska operations. Those actions include, but are not necessarily limited to: ernni us ®perraNi nng 2ni • Verify entry of all 4-year MIT testing requirements into TruApp CMMS (Computerized Maintenance Management System) and Avocet Production Operations software and ensure the titles are sufficiently descriptive, they are assigned to the right position, and that notifications are made to the appropriate parties for the proper dates. • Develop a procedure with an embedded RACI (Responsible, Accountable, Consulted, Informed) chart that identifies the positions responsible for tracking and execution of MITs, the position responsible for making AOGCC notifications, the parties to be notified about upcoming due dates, the lead times for notifications, and all associated responsibilities related to MITs. • Document through signature on the procedure and RACI chart that all parties with any required participation have been informed of their roles and responsibilities with the 4-year MITs. • Ensure the Compliance Coordinator is tasked with the specific responsibilities of confirming MITs are completed by mandatory deadlines, and capture this in the procedures and RACI chart. • Complete a Management of Change (MOC) to document these roles and responsibilities and obtain acknowledgment that the Compliance Coordinator has received them. • The Production Supervisors will review all open TruApp work activities weekly whenever there is a Step -Up in the Lead Operator position. • Incorporate these actions not only at Nikaitchuq, but at the Oooguruk Unit as well, to ensure no similar failures occur at any other Eni Alaska asset. Eni prides itself and its people in being transparent and working diligently to comply with all regulations, permit stipulations and conditions required to operate within Alaska, and throughout the world. We do this not simply to "check the box", but rather because it is the right thing to do. Eni respectfully requests the AOGCC consider a lesser civil penalty based on the fact Eni did not willfully or negligently violate the conditions of AID 36, and immediately reported the violation to the AOGCC as soon as it was discovered. For the purpose of clarifying a point in the AOGCC's enforcement letter, Eni successfully contested one of the previously mentioned NOV's regarding Sundry notification to AOGCC for well work on SD37. The contested NOV was removed and the civil penalty reduced to $10,000. Eni requests this current Notice of Enforcement reflect this minor correction. eni us operrafing In closing, Eni requests an audience with the AOGCC staff to personally explain the results of our internal investigation, answer any questions, provide clarification to the historical flowchart leading to the failure, and explain the corrective actions we are implementing. Should you have any additional questions or require any additional information, please contact me at my office 907-865-3330, or my cell at 907-351-5615. Thank you. Sincerely, � OUJ #0-�- Dave Hart Alaska Operations Manager Eni US Operating Co. Inc. brm,nbo itdi—Ifirnaings. ■Hedeoc=event AOGCCfeguffons nit /0122013 Eaatt Date Drinown Ian 1, 2014 O[t 2016 - oa2016 Nov 2016 an operator demonstthat n[al tlemonyat production Engineer was Produ[tlon Enginew New Produ0ce Sao hit[h bsl was Diedrich-Opentorroweeng Operations immediately begins Greater Clarity needed regarding (onto integrity least one keeping track Stepped up'ntoa �eed-s movedrolepaced. &eaien is g pon prxes pl( MIT of Me[baniwl err. every4 Vpars stanefIT,, fra[kofall Mlls, different po(t on. purposes engheer of Pal begl' creation of , . All of i .meld "Iyon'p In [egi ryTes[ing (ecording. maintaining ppening confu M Testing no Do, wells are tested by 0ec 2036. by Pouting OPs& Maintenance Sour[e: 20ppC255en io ns records - write mills Pm[Pd tarp, Sn arpa inlprm anon nalkicallntps, pM's ode logged In Spp. lisp The 2529fd1 and0121[)prea Screw, Intervilut Sourcern andtlemals with lead operator who Source EnipOGCC Informal syHemarm, art..,, Inpttbn Order em protlu[lion Polcipmar m Pmtludion polmon serprod svpeMsor wntiderfor lector wells are Nearing Ppt&operanons Ales n in vital otiOealions In advance ofPM's. S CC Supervisor lT81 SUVrervism li6l pas, derfor MIT. formal kepro InlaWal Hearing PIT, and Source Fni ADGCC Informal interview with Source: En tnforcnal Hearing PPi anducion Superintenden[antl T. and 3 Hearing PPi. and 3/22/201] Marnmeninso'ervhm letter ADGCC Solution: MIT PM'z will now auto ado to Hitch Uv, Production Engineer ould notify Pmduce.in Operators/Supron or about wells he, needed MIT and when Se.h.deloiew with current Ped Suriname, l78f Original hitch liatlin SAP were coated for maratenorlyantl WeerauonS PM ... Is, not for MITI. 5omce purified melts of current stood superaHm and interview will, when, Mainlenan[e 5u ,cool the Maileamse[e Supervisors would nitrate theme,, I'll wenlam SAPbuteack department managed Ole mntem of the u5k list. Sou e: Prodirlsweand Mource... a 5uperviso.s elerview During this creation, IM1e operator found the MIT 4 year rvle in AOGCC Olboak Point Pad Produ[ed Water Imildian Well Mechanical l ntegriy Tait Procedure Ia0o5121D1DPMoo12001 Si Interview w'db[erearr and no pm[edure did .,lure the ADGCC 4 Vwor re4uirement for MII. Source: Interview with comfort, Writer Due dates for the over due MITI .anal, from 4/26/2016 9/11/2016 SOume Em ADGCC Informal Hearine PIT Gear division of ... peruibllilies between groups has been III Bcu53ant end documented. Si fm AOGCCinfrmal Hearing LET Production operations was Linked with mainnium, compliance of MIT a. Sam—: Eni ADGCC I .formal Hearing Pi A once, Slope based position e, w be coaled To manage ADGCC compliance. Source: Fni ADGCC Informal Hearing PPT A complete review, of ADGCC proprours .,it pra[edurei was ampleted to ensure that all compliance standards would be adhered to. Sour[e Eni ADGCC Informal Hearing, PPT can 11. sole The s Olead Operemremark me Protluters Supervisor and elates ,be, hill, oa all( erojMorS at OPP and 11 of 13 injectors at SID passed. Source Email from Slo lead operator In the email (amen In. SID lead Operator to the Production Supervisor.the tend Operator fists [alllhe Ifindlbeiroew4 Year MlTdue date of 12/612020 and 12/l0/2020 Source: Email from SID lead Operator to Pmeuclve, superve.r Dec 11, 2016 The production Supervsor mall t he SAP Ccardspular fepuesting the III of nevi ay an, MIT due dates be entered into SAP Source'. Email from Production Supervisor to 541 Casim r The email states Em had ma iouny Mee .,a, me sale Regulated n year mandate Source: Emailfrempordscrien Supervisarte5Ap Co0rdinal Or the Production Supervisor 11mical Thal IM1e rich fist will the MIT, being due tome out )3 xeek5 ahead ace 1. meeting to gel he Spite Pep.. suet, wnne55 he test. Source: Email from Production Internist by SAP Coordinator SAP is not a compliance tracking system. but It was being used as such. S..", Statement of Fd[t ,an If, i it The Sao Coord natorrcremated to the emal from the production Supervaor-In adraft ofeel, for MIT mckfiiwton before nis "boadmto system. Source Email from SAP Coordinator 1.',adult,., Supervisor and Maintenance supeasm, Proposed title of task from the SAP COordiunor to the Production SiGervimr; Ciapten(Pm[thesond Appliroble Aegulptions Source; 2015emaillmmSAP Coortlinalorlo thePmduc(ion Supervisor. The SAP Comiinator referenced the did -al wall.eGootmes mistakenly in his proposed draft to the Production Supervisor for entering this ycan T into SAP. Source: 20l6ema0from SAP canmmal.,1. Pmauctien supe tell.,. The description of the MIT lest that was entered into SAP we, the MIT procedure and aligned per regulatory requirements. Source; Work Order Eaecl ion fleport 512017 The rbmdanw Caocarnotite Description was developed. [e: file concomitantly nme [onlem was started to be written. PegulatOW compliance Coordinator job Description lists monitoring of ADGCC & DOT regulatory requlremen[s Soccer cote on A drive with afilecloila n del—FS/2011 Date: E912az0 Nov t, 2020 uv....ul:,i :.: Je ,)I:e M¢rch 161R. 2021 Myr,112018 AWil 20t8 tune 2018 002019 TrWpp Try snow CAMS) was The mdogriom Orgasm, Ypd¢tin6 M1ovewr same were SAP H Khl' i Identified MIT the pnnual'ema 0 My Report COmplan[e Creatin., position Anchorage Pmdutlian A neon An¢hmill Pmdud'on [dktl out, r lest rag Of OPP InI Well J I nmtl iM OPP Pmdu[ed Water sMedo detn fin the filled. Management Leatlenbp he' a Manager was Fired from S.Pb t.list gen atetl Inlalipn Me[hahRllnteSnlV from 54P M1itcF list MILze then„¢ Source'. prNiVed Rewrds ien lmieedl uSerOn 51D. Sou ¢Email from Prod -on Source: Complrinrz Coprdlwlol Saar[¢: prcMVM fle<oNi #o m soma:ln wrM Nik Plod $Wrce: XY[F fill CnginPr Interview Supervisor LiDl,Malnt¢nan[e ' r 5upervisp[1p[1 13we11 M1is 0n 5Nweredue to $ourtt: interview wiM fprmn be nominated by IXa¢mbe12020 procedurewfi4( HitcF IiA Fem missetl bYDPP refdle[lion of Stty YPP10dY[tian lead <he Mlli to McStIP, Tim needed for training and "ahnOraLhremq¢ on hitcn IX! 19 of Mo inpction wells had anron Engyneerreachelmdem nW of the TmApp tile#med selectnn wen and it MIT due date December 2010 Pmm1on wpeMrorprogram merweted as wills intend¢nthll.m. well and not as inknor Sourt¢Intervew wMl3Fis5APFIKM1 bs[forlhe4yea/ wen NO Mo [¢sing Wai SWrtt. SpreadiFeel homail hom ProdY[tlonrommenance Some -Or 11Y MITI was r¢kased pn Nav 1. 202o PerformM RotluRian EnginPH antl allowing fore works to ccmpkte. 312L2o121s.., lmm AOGCC Source: Immunity, With M urre-Eap, of M1hN lnA m Ele r 1 [ f SgPnirugpP mO bill isl 0. on he I51 I100X 1' goi banslerrea dtnemomh d16M Itl T qpp mF,Futu Vp IIV b mpgxme nit[h rnlm\n tine SAP M., bin, sold m generate they are onsh'X. monotdngh,onor MEn Matneetl. Stara: Comp'antt! dilator Sourm ln[ewew wiT ProduRionThae An.-U, Dead Operates pan step ups are A lead notes the be tommeted 5nP ninfa lw amuid SnpervisOr antl Cuertnt iqRProduction S.I.M. WIN raystai duty dfid Me eye the hadelf 141 QO straight to the Lead Operde0 rt, plannershe On ase Inds of the sue P - A soutta Ptn—u iMproldn"Ah Unike SgP.ln Trvgpp hemB sagared: Sediment aff production It", no. par here. On Supenntendent JIDl Te Filch lis[tM1at are rot The Nitcx Li#title br tM1e ask waspuppeadjuar beard can his listamareas so Proportion superintendent d tleblka antl the #e0'Yp SIDItb Due W.: SIVIDI1 wmPle\ed will amwnatically mil teas OpnMmatl no[fevlew Me TFe Cemphants Cwramaars mevtoe[Omq nian ii#umn ceaailed aessripti0n. mars, -renal aspMs of m etetl. The criteria used for ulectlon coombam .1m o01 and PSM it\le: MILTesWg OISIDInI WPII B requirements source Cnmpnanm mmdmams aBe, of step uplead operators iza Ym Of 3.5 yearsas an lationg noire Opemmc, A operate. gAmplu Irate C."mmen 5ourt inRrview wiM PrMUPlion sotatus, and observed Camplunm COIXGname Supervisor (101aM copyaltne IeadershipcapalrlNes. S W rw: I nterview will, the Compnantt Cmrdinaaes had rat Produetiron SYPervism (T8) wed hmming an Y,eu mtegrnV m AOGCCreg.luyons. Aepap 5101nd Operame etltlresQd Mp XNd1 n4 rt¢m and Source interview will, COmpllance Ommenleatbttne"SD3I DSPOt SFPCOortlinalor was FaspiMliaea Candlemas wNl F.tlawn". brpersonalmMlcal reasons. Sawa NgcF Li# wiM HO MOCwBs vested Im Me Swrte: Interview 4laimenana wpemsor IDq Ore Commnal, Cnords em, the Con or obpfaordtionf position arpb aes[.ipnml far pozibon. There w>z a fllin lOr MP SqP Com Ansel Source. Cnmplian¢ CowalnatOr ceordina or wFen [nrywere in me nomhal son. wail Mainleoancesu0prwmr The YsP Comtlinator wouk as The 51O MR M1itcn b5\irons doge( tandiN practice, cellMe talriM OVP[byNesgp Mdlm cp SYTnvi50 aithe Cmrtlinaarbrfienwrtwo 1Mh aM 30lh a1 Me momntokt xi1Mn Mem knw� Ma[FiIc1111#items ere not mmple[td. $purce: XM1M Lis( bar[¢: InleMeSv wrlh XlC PrOdu[tiOn Wpervism liB YM on(mmM by Maintenance SupeMwr IOCI If homes Ware fepoMd with and USTheSgP nimM1 frs[tar Me OPP MIi Llle hicN list the Rodudim R ticil, 7 Arropeatersomenchiminfigooleferman CA2 and W. the Ameas Intention Order for NIK.TM1en Me Malmenanm Supevior would.olly:lead Suvervisars w0um n0 \ne item[mat did not gn mmpkled. hadreachadapointwhese Imso epprOprNle WohgrWpta see did not gPl manualyurtietl OMr tome ne#M1itrn. theyweremamgialgtht, the MIT 71.dn,,�uiemnonta. cabs\ tM1e responsible carry pretty well. Agoo f system wmlea totlowGM1 hHCM1 tin hems SWrte: Sqv gecords wasinplicefrraheall fledameblen,perphimseCtuarderythowthat wxe not wmpleletl. from the SAP Foordlnator if SWtt¢: InteMeW wFh Nlg 'Itefewa5an issue. Rmhaionwcerdsor (iel sport¢:IAmrYihlnim wP Production Supeorvisor 081 MRz — youn, injectioneps were saimpleted and reports 10 AECKC. Source: Ifrom ew wM N.an"_ Out of the [out number of MITs oreMue, all but6passed. lot Moae 611avebeen pahlend and eoseed ¢passing test 5 are still needing rep air and rams'. Sansone: m1houre, wlM PrWY[tmn Engineer Tubing'stay tomb hace been duets, wBM1a there, robust rate of thew tlamr wimm Me OCS. mud like 03 has. Source mbrmatim hem ho0url en Engineer W IMmI a rate of P W rage maim, wnaliirg mndllons of Me Wen. beforeanaaHerlhe TYU. undadonWttewabsorrin apnem gbWndnies. $cart¢: RCere Sight Treari THE S7'AI'E oIALASKA Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1431 Fax: 907.276.7542 www.aogcc.alaska.gov May 25, 2021 Mr. Keith Lopez Senior Production Engineer Eni US Operating Company, Inc. 3700 Centerpoint Dr., Suite 500 Anchorage, AK 99503 Sent Certified Mail: 7018 0680 0002 2052 9440 Re: Notice of Proposed Enforcement Action Failure to complete required Mechanical Integrity Tests (MITs) Nikaitchuq Unit, 19 wells Area Injection Order 36 Nikaitchuq Unit (NU), Nikaitchuq Field, Schrader Bluff Oil Pool Docket Number: OTH-21-017 Dear Mr. Lopez: The Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Eni US Operating Company, Inc. (Eni) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)) Eni violated the provisions of Rule 6 of Area Injection Order 36 (AIO 36) ("Demonstration of Tubing/Casing Annulus Mechanical Integrity") for 19 NU wells. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)) AIO 36 was approved January 19, 2011. The order authorizes the underground injection of fluids for enhanced oil recovery in the Nikaitchuq Schrader Bluff Oil Pool. The rules require MITs on NU injection wells: - Before injection begins; - Before returning a well to service following any workover affecting mechanical integrity; - After injection is commenced for the first time in a well, for witness by AOGCC; and - At least once every four years following the initial MIT. AOGCC Industry Guidance Bulletin 10-02A dated August 16, 2013, allowed for efficiencies in testing and witnessing by allowing an MIT to be performed anytime during the anniversary month to satisfy the MIT due date. On March 17, 2021, Eni contacted AOGCC by email to report that 19 wells were injecting after Eni had failed to perform the required four-year MITs that were due December 2020. Rule 6 of AIO 36 states "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. A Commission -witnessed 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 (except at least once every two years in the case of a slurry injection well). " The last AOGCC-witnessed MITs occurred December 2016. Therefore, MITs were required on or before December 2020. Though out of compliance, the 19 wells continued to inject. Em's failure to demonstrate the mechanical integrity of the 19 injection wells within the required four-year cycle violated both AOGCC's regulations and AIO 36. Proposed Action (20 AAC 25 535(b)(3) The MIT violations at Nikaitchuq are not isolated and demonstrate Em's ongoing compliance problems, including: Failure to test 11 injection wells for tubing/casing annulus MIT at Nikaitchuq Unit resulted in a penalty of $110,000 to Eni on July 26, 2017. ' Since that time, two other enforcement actions have been issued; - Failure to submit blow out prevention equipment (BOPE) test reports at Nordic Rig 4 of November 8 and November 15, 2018, resulting in a Notice of Violation (NOV) issued by AOGCC on December 6, 20182; and Failure to obtain AOGCC approval prior to performing well work and failure to complete a required sundry report of well work within the required time for Nikaitchuq well SD37-DSPI; $20,000.1 . The failure to conduct MITs on the 19 NU wells occurred after AOGCC fined Eni $110,000 for its failure to conduct MITs on 11 NU wells in 2016. Those tests were eventually witnessed in December 2016 which set the next testing due date of December 2020. The failure to test in December 2020 is the subject of this enforcement action. ' Other Order 124, Issued July 26, 2017, Docket OTH-17-001 2 Docket OTH-18-059 3 Other Order 171 issued September 20, 2020 (AOGCC Docket OTH-20-043) Other Order 124 states, "In addition to the civil penalty, Eni is required to develop and implement a tracking system for regulatory obligations, including an automated alert for approaching and past -due obligations, with notifications provided to Eni personnel responsible for the regulatory obligation." For these violations, the AOGCC intends to impose civil penalties on Eni as follows.' - $380,000 ($20,000 for each of the initial violations of 19 wells for failure to perform the required MITs of the 19 injection wells in compliance with testing protocols specified in Rule 6 of AIO 36); - $60,000 ($10,000 for each of the four wells that failed the overdue MIT witnessed on March 21, 2021' and the two wells that exhibited tubing by inner annulus (TxIA) pressure communication and subsequently failed their MIT).6 In addition to the imposed civil penalty, AOGCC intends to require Eni to provide a detailed written explanation as to how it intends to prevent recurrence of this violation. AOGCC also intends to require Eni to demonstrate to AOGCC's satisfaction a more robust regulatory compliance tracking system that addresses all AOGCC-mandated obligations. The total proposed civil penalty is $440,000. Violations relating to Underground Injection Control Class II well integrity practices warrant the imposition of civil penalties. Eni's repeated failure to comply with fundamental wellbore MIT requirements raises the potential for similar behavior with more serious consequences. Mitigating circumstances were considered in the assessment of the proposed civil penalty including the operator's practices, the existing aquifer exemptions of the NU, and Eni's notification to AOGCC once Eni determined the wells were out of compliance. Rights and Liabilities (20 AAC 25.535(b)(4)) Within 15 days after receipt of this notification — unless the AOGCC, in its discretion, grants an extension for good cause shown — Eni may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide Eni an opportunity to submit documentary material and make a written or oral statement. If Eni disagrees with the AOGCC's proposed decision or order after that review, it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10-day period, the proposed decision or order will become final on the 11 w day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. 4 AS 31.05.150(a) provides for not more than $100,000 for the initial violation and not more than $10,000 for each day thereafter on which the violation continues. 5 0106-05 (PTD 2101650); 0113-03 (PTD 2111000); 0115-S4 (PTD 2111410); and 0120-07 (PTD 2111400) 6 S126-NW2 (PTD 2141570) and 5I29-S2 (PTD 2120060) If Eni does not concur in the proposed action described herein, and the AOGCC finds that Eni has violated or failed to comply with a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action or remedial work; (ii) suspension or revocation of a permit or other approval; (iii) payment under the bond required by 20 AAC 25.025; and (iv) imposition of penalties under AS 31.05.150. In taking action after an informal review or hearing, the AOGCC is not limited to ordering the proposed action described herein, as long as Eni received reasonable notice and opportunity to be heard with respect to the AOGCC's action. Any action described herein or taken after an informal review or hearing does not limit the action the AOGCC may take under AS 31.05.160. Sincerely, Jeremy Dr9r.11y a,,r,d by Jeremy Price Price Date; 20210525 14--.19.15 08X Jeremy M. Price Chair, Commissioner Alaska Oil and Gas Conservation Commission cc: Timothy Mayers, U.S. Environmental Protection Agency, Region 10 AOGCC Inspectors Table I: Status of Nineteen Nikaitchu0 Wells Missing MITs (as of May 11. 2021 J Well PTD rt Status Date of Last Test Result Freq. (Years) Due Date Injecting since MIT due date? ITTest ate Nitnessed Result OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 lerrera Pass 016-05 210-165 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 Aerrera :all 3/21/2021 MIT. workover Aan. eline on tractor 017-04 21D-153 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 ierrera lass 0111-01 210-106 1 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 errera ass 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 Aerrera ail 3/21/2021 MIT. workover Ian. eline on tractor 0115-54 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 lerrera ail 3/21/2021 MIT. workover Ian. eline on tractor 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/2021 Aerrera ail 3/21/2021 MIT. workover Ian. eline on tractor 0124-08 211-130 WINJ 12/6/2016 P 4 12/5/2020 Yes /23/2021 cLeod ass 5107-SE4 224-100 WINJ 12/10/2016 P 4 12/9/2020 1 Yes /1/2021 ook ass Sill-FN6 223-128 WINJ 12/10/2016 P 4 12/9/2020 Yes 11/2021 ook ass 5113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass 5114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass 5117-SE2 214041 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass 5119-FN2 213-043 WINI 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass 5120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass S12S-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 ook ass SI26-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes x1A tracking reported /25/2021, shut in, MIT fail, plan r oeline on tractor SI29-52 222-006 WINJ 12/10/2026 P 4 12/9/2020 Yes xIA tracking reported /10/2D21, MIT fail. 5132-W2 213-013 WINJ 12/10/2016 P 4 12/9/2020 Yes /30/2021 Cook ass Salazar, Grace (CED) From: Lopez Keith <Keith.Lopez@eni.com> To: Salazar, Grace (CED) Sent: Tuesday, May 25, 2021 4:35 PM Subject: Read: AOGCC Notice of Proposed Enforcement Action Your message To: Subject: AOGCC Notice of Proposed Enforcement Action Sent: Wednesday, May 26, 2021 12:35:22 AM (UTC+00:00) Monrovia, Reykjavik was read on Wednesday, May 26, 2021 12:35:05 AM (UTC+00:00) Monrovia, Reykjavik. ■ Complete items 1, 2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: k-elt'41' I -„ fez 00 C`Ake-" ,f �Y o Sk S° III'lllll I'll I'IIIII IIII II�IIIIIII IIII IIII I III 9590 9402 4351 8190 1878 43 2. Article Number (Hensler From awrvaa,e�ov 018 0680 0002 2052 9440 U.S. Postal Service'" CERTIFIED MAIL° RECEIF Domestic Mail Only For delivery information, visit our website at ww $l) Certified Mail Fee $ 171J .rF�.co,�l�oox Rccc rh.ox eo,. eddreessaoe ivslel ❑Re rn R"c faNwpy) $ ru❑ Retum Receipt lelectronle) $ Posinark ❑ cv, c,,d Mall Rewcw nellvery $ Here C3 E3 ❑ Adult Signature Repuled $ EJ Adun Signature Restricted Der ay $ Postage C3 ro $ 1 OTotal Postage and Fees $ Sent To I-1 O $beet---NG.; or Frd-Hox [ti it ❑ Agent C. Date of Delivery D. Is delivery addifferent from item 1? U Yes If YES, enter delivery address b 6,'fo R JuN o 1 2021 U 3. Service Type ❑ Adult Signature ❑ Adult Signature Restricted Delivery ❑ Distilled Mail® ❑ Certmed Mall ResMcted Delivery Cl Collect on Delivery ❑ Collect on Delivery Regincfed Delivery ❑ Insured Mail ❑ Insured Mall Restricted Delivery ❑ Priority Melt Express® ❑ Registered MatITM ❑ Registered Maii Restdcted Delivery ❑ Return Receipt for Merohandise D Signature Confirmaf rn ❑ Signature Confirmation Restricted Delivery Domestic Return Receipt ; PS Form 3811, July 2016 PSN 7530-02-000-9053 Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, May 25, 2021 2:21 PM To: Wallace, Chris D (CED); Regg, James B (CED) Cc: Brooks, Phoebe L (CED) Subject: RE: ENI Injector 4-year MIT's Thank you for the clarification. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3700 Centerpoint Drive, Suite 500 Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Lonez(a)eni.com W eni From: Wallace, Chris D (CED) <chris.wallace@alaska.gov> Sent: Tuesday, May 25, 2021 1:58 PM To: Lopez Keith <Keith.Lopez@eni.com>; Regg, lames B (CED) <jim.regg@alaska.gov> Cc: Brooks, Phoebe L (CED) <phoebe.brooks@alaska.gov> Subject: RE: ENI Injector 4-year MIT's Keith, For the wells with witnessed MITs in March and April 2021, they will need to be tested on or before the March and April 2025. The witnessed MIT resets the clock. A late MIT without prior AOGCC agreement would be subject to an enforcement action which would nullify any perceived operator benefit gained by the extension of the MIT test timeline. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7t^ Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.eov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.ciov. Thanks, Chris. From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, May 25, 2021 1:22 PM To: Regg, James B (CED) <aim.reaa@alaska.aov>; Wallace, Chris D (CED) <chris.waIlace C@alaska.eov> Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, Looking at the next MIT's due on the Nikaitchuq injectors I had a question about the due date. Since the 4 year MIT's were due in Dec 2020 but did not get conducted until March and April 2021, are the next due dates still in December 2024? 1 was assuming conducting them late would not restart the 4 year clock to the month they were actually completed but wanted to check with the AOGCC. Thank you for any clarity. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3700 Centerpoint Drive, Suite 500 Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.LODezOO eni.com W eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Wednesday, March 17, 2021 2:43 PM To: chris.wallace@alaska.aov; iim.ree¢@alaska.eov Cc: Burgess Larry <Larrv.Buraess@eni.com>; Dibello Mike<Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothy.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smaaae@eni.com>; Lopez Keith <Keith. Lopez@en i.com> Subject: ENI Injector 4-year MIT's Mr. Wallace, Today (3/17/21) ENI discovered that 19 Nikaitchuq injection wells were due for their 4-year MIT-IA's in December 2020. These MIT's were not performed and are out of compliance. We are working to secure the resources to complete these pressure tests and get back in compliance as soon as possible. I will communicate the estimated timing when we have it. We will also conduct an investigation as to how these were able to lapse including changes to our compliance system that can better insure this doesn't happen again. These improvement will be shared with the AOGCC. Injecting since Date of Last Frequency MIT due Well PTD # Status Test Result (Years) Due Date date? OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes 016-05 210-165 WINJ 12/6/2016 P 4 1 12/5/2020 Yes 017-04 210-153 WINJ 12/6/2016 P 4 12/5/2020 Yes 0111-01 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes 0115-S4 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes 0124-08 211-130 WINJ 12/6/2016 P 4 12/5/2020 Yes 5107-SE4 214-100 WINJ 12/10/2016 P 4 12/9/2020 Yes 5111-FN6 213-128 WINJ 12/10/2016 P 4 12/9/2020 Yes S113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes S114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes S117-SE2 214-041 WINJ 12/10/2016 P 4 12/9/2020 Yes S119-FN2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes S120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes S125-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes S126-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes S129-S2 212-006 WINJ 12/10/2016 P 4 12/9/2020 Yes S132-W2 213-013 WINJ 12/10/2016 P 4 12/9/2020 Yes Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. LODeZ(d)eni.com eni Message for the recipient only, if received in error, please notify the sender and read htti),//-www.eni.com/disclaimer/ Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, May 18, 2021 12:42 PM To: Wallace, Chris D (CED); Regg, James B (CED) Cc: Burgess Larry; Dibello Mike; Hart David; Lyden Dan; Brown Timothy; Dexheimer Stephen; Smagge Lorne; Pierfelici Stefano; Lopez Keith; Atencio Lucas; Morgan Michael; Zuber Joshua Subject: 0113 (PTD# 211-100) ENI has successfully installed 4 tubing patches in 0113 to regain tubing integrity. A state witnessed MIT was conducted on 5/6/21 and will be officially submitted shortly. Please let me know if you need any additional information. Thank you. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3700 Centerpoint Drive, Suite 500 Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Looez(cDeni. com rA eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, March 30, 2021 11:18 AM To: chris.wallace@alaska.gov; jim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lyden@eni.com>; Brown Timothy <Timothy.Brown@eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Pierfelici Stefano <Stefano.Pierfelici@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, ENI has conducted the initial diagnostics on the 4 OPP injectors and has determined that the leak point is deeper than the well deviation will allow us to get with slickline. ENI is now working to mobilize eline with tractor to continue the diagnostics. The wells will remain shut in until further diagnostics are performed. OI-06 OI-13 OI-15 OI-20 SI-26 Please let me know of any further information the AOGCC may need. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. LODez0eni.com eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, March 23, 2021 11:27 AM To: chris.wallace@alaska.gov; jim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lyden@eni.com>; Brown Timothy <Timothy.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Pierfelici Stefano <Stefano.PierfeIici@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Regg, ENI has mobilized a slickline unit to begin diagnostics on these 4 injectors that failed their 4-year MIT's starting as soon as tomorrow (3/24/21). 1 do not believe this work will require a Form 10-403 submission that the AIO states should be submitted. Please advise if I am incorrect. We will keep the AOGCC updated on our progress. Please let me know if the AOGCC has any questions or concerns. Thank you. Area Injection Order 36 January 19, 2011 Page 15 of 16 Rule 7 Well Integrity and Confinement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by an injection rate, operating pressure observation, test, survey, log, or any other evidence (including OA pressure monitoring of all wells within a '/o-mile radius of where the Nikaitchuq is not cemented), the Operator shall notify the Commission by the next business day 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. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.Looez a0eni.com enl From: Lopez Keith Sent: Monday, March 22, 2021 2:35 PM To: chris.wallace@alaska.gov; jim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike<Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothy.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Regg, Conducting the Injector 4-year MIT -Ws at OPP we have 4 failures on 3/21/21. 0I-06, 0I-13, 0I-15, and 0I-20 all failed the pressure test and were shut in waiting further review and diagnostics. We will submit any plan for corrective action to the AOGCC. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. LOpez(7eni. corn eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Thursday, March 18, 20219:58 AM To: chris.wallace@alaska.gov; iim.regg@alaska.gov Cc: Burgess Larry <Larrv.Burgess@eni.com>; Dibello Mike<Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothy.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, We may be ready to start the MIT's at SID as early as tomorrow. We will put in the 48 hour notice as part of the normal process. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Lovez(a)eni. com From: Lopez Keith Sent: Wednesday, March 17, 2021 2:43 PM To: chris.wallaceC@alaska.gov; lim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lyden@eni.com>; Brown Timothy <Timothy.Brown@eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: ENI Injector 4-year MIT's Mr. Wallace, Today (3/17/21) ENI discovered that 19 Nikaitchuq injection wells were due for their 4-year MIT-IA's in December 2020. These MIT's were not performed and are out of compliance. We are working to secure the resources to complete these pressure tests and get back in compliance as soon as possible. I will communicate the estimated timing when we have it. We will also conduct an investigation as to how these were able to lapse including changes to our compliance system that can better insure this doesn't happen again. These improvement will be shared with the AOGCC. Well PTD # Status Date of Last Test Result Frequency (Years) Due Date Injecting since MIT due date? OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes 016-05 210-165 WINJ 12/6/2016 P 4 12/5/2020 Yes 017-04 210-153 WINJ 12/6/2016 P 4 12/5/2020 Yes 0111-01 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes 0115-54 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes 0124-08 211-130 WINJ 12/6/2016 P 4 12/5/2020 Yes 5107-SE4 214-100 WINJ 12/10/2016 P 4 12/9/2020 Yes SI11-FN6 213-128 WINJ 12/10/2016 P 4 12/9/2020 Yes 5113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes 5114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes 5117-SE2 214-041 WINJ 12/10/2016 P 4 12/9/2020 Yes 5119-FN2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes 5120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes 5125-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes 5126-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes 5129-52 212-006 WINJ 12/10/2016 P 4 12/9/2020 Yes 5132-W2 213-013 WINJ 12/10/2016 P 4 12/9/2020 Yes Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Lopez(Uieni. com eni ------------ Message for the recipient only, if received in error, please notify the sender and read http://www.eni.com/disclaimer/ Wallace, Chris D (CED) From: Wallace, Chris D (CED) Sent: Tuesday, May 11, 2021 4:12 PM To: Lopez Keith Cc: Regg, James B (CED) Subject: RE: Nik 4-Year MIT Compliance Investigation Keith, AOGCC is in the process of finalizing a Notice of Proposed Enforcement for this. It would be my preference for us to wait and have a meeting and discuss your investigation after you have received and evaluated the proposed enforcement action. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 711 Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallacepalaska.aov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.aov. From: Lopez Keith <Keith.Lopez@eni.com> Sent: Thursday, April 29, 2021 11:03 AM To: Wallace, Chris D (CED) <chris.wallace@alaska.gov> Cc: Regg, James B (CED) <jim.regg@alaska.gov>; Lopez Keith <Keith.Lopez@eni.com> Subject: Nik 4-Year MIT Compliance Investigation Mr. Wallace, ENI has completed its investigation as to how and why the 4-year MIT's at OPP and SID were missed and out of compliance when due December 2020. We would like to share the findings of the investigation along with planned corrective actions with the AOGCC. An in -person meeting is usually preferred and most effective but we can also schedule and Microsoft Teams meeting or summarize the information and send the documents via email. Whichever form of communication the AOGCC would prefer and fits with your policies we will look to schedule. Please advise how you would like us to share this information. Thank you. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3700 Centerpoint Drive, Suite 500 Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 7 Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, April 27, 2021 11:03 AM To: Wallace, Chris D (CED) Cc: Regg, James B (CED); Dibello Mike; Dexheimer Stephen; Brown Timothy; Smagge Lorne; Burgess Larry Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, In late March we had a COVID 19 outbreak at SID. Through the inspector, we postponed the witnessed MIT's on the island until the COVID issues were contained (I believe Mr. Regg approved). I will check with our safety team if we have a clean bill of health on the island and can now safely schedule the remaining MIT's. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Looez a(,eni. com eni From: Wallace, Chris D (CED) <chris.waIlace @alaska.gov> Sent: Tuesday, April 27, 2021 10:54 AM To: Lopez Keith <Keith.Lopez@eni.com> Cc: Regg, James B (CED) <jim.regg@alaska.gov> Subject: RE: ENI Injector 4-year MIT's Keith, Reviewing the MIT's from Eni I come up with: Well PTD# Status Date of Last Test Result Frequency (Years) Due Date Injecting since MIT due date? IT Test ate Witnessed R OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 016-05 210-165 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 017-04 210-153 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 0111-01 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 0115-54 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes /21/21 Herrera 0124-08 211-130 WINJ 12/6/2016 P 4 1 12/5/2020 Yes /23/21 McLeod S107-SE4 214-100 WINJ 12/10/2016 P 4 12/9/2020 Yes Sill-FN6 213-128 WINJ 12/10/2016 P 4 12/9/2020 Yes S113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes S114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes S117-SE2 214-041 WINJ 12/10/2016 P 4 12/9/2020 Yes S119-FN2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes S120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes 5125-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes S126-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes S129-S2 212-006 WINJ 12/10/2016 P 4 12/9/2020 Yes S132-W2 213-013 WINJ 12/10/2016 P 4 12/9/2020 Yes Are there any more MIT's or what is the reason I don't have all 19 wells tested and results? Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7t" Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallaceC@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.aov. From: Lopez Keith <Keith.Lopez(c@eni.com> Sent: Tuesday, March 30, 2021 11:18 AM To: Wallace, Chris D (CED) <chris.wallace@alaska.eov>; Regg, James B (CED) <jim.reee@alaska.eov> Cc: Burgess Larry <Larrv.Burgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothy.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagae@eni.com>; Pierfelici Stefano <Stefano.Pierfelici@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, ENI has conducted the initial diagnostics on the 4 OPP injectors and has determined that the leak point is deeper than the well deviation will allow us to get with slickline. ENI is now working to mobilize eline with tractor to continue the diagnostics. The wells will remain shut in until further diagnostics are performed. 01-06 01-13 OI-15 01-20 SI-26 Please let me know of any further information the AOGCC may need. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.LODezOO eni.corn eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, March 23, 2021 11:27 AM To: chrismallace@alaska.gov; iim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike<Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothy.Brown@eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Pierfelici Stefano <Stefano.Pierfelici@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Regg, ENI has mobilized a slickline unit to begin diagnostics on these 4 injectors that failed their 4-year MIT's starting as soon as tomorrow (3/24/21). 1 do not believe this work will require a Form 10-403 submission that the AIO states should be submitted. Please advise if I am incorrect. We will keep the AOGCC updated on our progress. Please let me know if the AOGCC has any questions or concerns. Thank you. Area Injection Order 36 January 19, 2011 Page 15 of 16 Rule 7 Well Integrity and Confinement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by an injection rate, operating pressure observation, test, survey, log, or any other evidence (including OA pressure monitoring of all wells within a '/<-mile radius of where the Nikaitchuq is not cemented), the Operator shall notify the Commission by the next business day 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. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.LooezOeni.com eni From: Lopez Keith Sent: Monday, March 22, 2021 2:35 PM To: chris.wallace@alaska.gov; iim.regg@alaska.gov Cc: Burgess Larry <Larrv.Burgess@eni.com>; Dibello Mike<Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothv.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Regg, Conducting the Injector 4-year MIT-IA's at OPP we have 4 failures on 3/21/21. 0I-06, 01-13, 01-15, and 0I-20 all failed the pressure test and were shut in waiting further review and diagnostics. We will submit any plan for corrective action to the AOGCC. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.LODeZ aneni.com eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Thursday, March 18, 20219:58 AM To: chris.wallace@alaska.eov; iim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike<Mike.Dibello@external.eni.com>; Hart David <David.Har @eni.com>; Lyden Dan <Dan.Lvden@eni.com>; Brown Timothy <Timothy.Brown@eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Lopez Keith < Ke i t h .Lopez @ e n i. c o m> Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, We may be ready to start the MIT's at SID as early as tomorrow. We will put in the 48 hour notice as part of the normal process. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Lonez(a)eni. com PA ano From: Lopez Keith Sent: Wednesday, March 17, 2021 2:43 PM To: chris.wallace@alaska.gov; jim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lyden@eni.com>; Brown Timothy <Timothy.Brown@eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: ENI Injector 4-year MIT's Mr. Wallace, Today (3/17/21) ENI discovered that 19 Nikaitchuq injection wells were due for their 4-year MIT-IA's in December 2020. These MIT's were not performed and are out of compliance. We are working to secure the resources to complete these pressure tests and get back in compliance as soon as possible. I will communicate the estimated timing when we have it. We will also conduct an investigation as to how these were able to lapse including changes to our compliance system that can better insure this doesn't happen again. These improvement will be shared with the AOGCC. Well PTD # Status Date of Last Test Result Frequency (Years) Due Date Injecting since MIT due date? 0 P-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes 016-05 210-165 WINJ 12/6/2016 P 4 12/5/2020 Yes 017-04 210-153 WINJ 12/6/2016 P 4 12/5/2020 Yes 0111-01 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes 0115-S4 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes 0124-08 211-130 WINJ 12/6/2016 P 4 12/5/2020 Yes S107-SE4 214-100 WINJ 12/10/2016 P 4 12/9/2020 Yes SI11-FN6 213-128 WINJ 12/10/2016 P 4 12/9/2020 Yes S113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes S114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes S117-SE2 214-041 WINJ 12/10/2016 P 4 12/9/2020 Yes S119-FN2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes S120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes S125-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes S126-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes S129-S2 212-006 WINJ 12/10/2016 P 4 12/9/2020 Yes S132-W2 213-013 WINJ 12/10/2016 P 4 12/9/2020 Yes Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. LoDez(a)eni. com eni Message for the recipient only, if received in error, please notify the sender and read htto•//www.eni.com/disclaimer/ Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Saturday, April 10, 2021 12:04 PM To: Wallace, Chris D (CED); Regg, James B (CED) Cc: Burgess Larry, Dibello Mike; Hart David; Lyden Dan; Brown Timothy, Dexheimer Stephen; Smagge Lorne; Pierfelici Stefano; Lopez Keith Subject: SI-29 (PTD# 212-006) Mr. Wallace, ENI noticed the TAA pressures tracking on SI-29 and became concerned about a potential pressure communication. Today (4/10/21) we attempted to pressure test the IA but the annulus would not hold pressure. The injector is shut in and will remain so until further diagnostics can be conducted. Please let me know of any questions or concerns. Thank you. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Lonez()eni. com Message for the recipient only, if received in error, please notify the sender and read http://www.eni.com/disclaimer/ Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Thursday, March 25, 2021 7:18 PM To: Wallace, Chris D (CED); Regg, James B (CED) Cc: Burgess Larry; Dibello Mike; Hart David; Lyden Dan; Brown Timothy, Dexheimer Stephen; Smagge Lorne; Pierfelici Stefano; Lopez Keith Subject: SI-26 (PTD# 214-157) Mr. Regg, After conducting a thorough review of all injection wells at Nikaitchuq, we believe that SI-26 may have tubing by IA pressure communication. We immediately shut in the well today (3/25/21) and attempted to pressure test the annulus, which did not pass. The well is shut in and will remain so until we can conduct further diagnostics. Please let me know of any questions or concerns. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.LoDezOleni. com rA eni Message for the recipient only, if received in error, please notify the sender and read http://www.eni.com/disclaimer/ Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Tuesday, March 23, 2021 11:57 AM To: Brooks, Phoebe L (CED); Regg, James B (CED); DOA AOGCC Prudhoe Bay; Wallace, Chris D (CED) Cc: Lyden Dan; Dexheimer Stephen; Dibello Mike; Burgess Larry; Brown Timothy; Hoppe Kirsten; Pierfelici Stefano; Smagge Lorne; Lopez Keith; Vaala Brandy Subject: MIT OPP ENI 3/21/21 - 3/22/21 Attachments: MIT OPP ENI 03-21-21.xlsx; MIT 0I-24-08 03-23-21.xlsx Attached are the MIT's conducted at OPP on 3/21/21 and 3/22/21. The 4 failing wells are shut in pending further diagnostics. Let me know of any questions or concerns. Thank you. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.Loaez(a)eni. com eni Message for the recipient only, if received in error, please notify the sender and read http://www.eni.com/disclaimer/ STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Mechanical Integrity Test Submits, iim.reacutSalaska.aov: AOGCC. IcapectersRalaska.aoY: phoebebmoksidalaske.nov OPERATOR: Eni US Operating Cc Inc FIELD I UNIT I PAD: NikaitchudOPP Onshore DATE: 03/21/21 OPERATOR REP: Brandy Vaala AOGCC REP: Matt Herrera chess wallace�alaska.aov Well OI-02 Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTD 2061440 Type Inj W Tubing 484 484 484 484 Type Test P Packer TVD 3404 BBL Pump 2.2 IA 60 7721 1854 1843 Interval 4 Test psi 1500 JBBLRNum 1.3 1 OA 1 195 1 250 210 200 Result P says, 1700 PSI per Ops lO%olmlMmurn TVDBBBL§ Well 0I-08-05 1 Pressures: Pretest Initial 15 Min. 30 Min. 45 Mr. 60 Min. PTD 2101650 1 Type Inj I W Tubing 488 560 Type Test P Packer TVD W89 BBL Pump 8.0 IA 624 800 Interval 4 Test psi 1500 1 BBL U.1 I OA 1 180 180 1 1 1 Result F Notes: BBBLS PKR Leak Commlmicabon. Wall wasebul in on W1/21 pendant, 6ssircuBCs. Well 01-07-04 Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 63 Min. PTD 2101530 Type Inj W Tubing 489 489 488 488 Typo Test P Packer TVID 3471 BBL Pump 4.3 IA 3 1730 1890 1676 Interval 4 Test psi 1500 1 BBL Return 2.5 OA 185 340 340 330 Result P tom: 2.3 Refill LRS WNI 01-11-01 Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTD 2101060 Type Inj W Tubing 355 355 355 355 Type Test P Packer TVD 3489 BBL Pump 4.0 IA 5 1727 1635 1614 Interval 4 Test psi 1500 BBL Return 2.0 OA 190 230 205 200 Result P Notes: IA bIedi to 300 psi perops Well 01-13-03 Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Mr. PTD 2111000 Type Inj W Tubing 480 510 Type Tesl P Packer TVD 3529 BBL Pump 23.0 IA 568 1000 Interval 4 Test psi 15W BBL Return OA 220 MO Result F MOOS, 6.5 Pupil UPS 23bbls. Wall was shut in on 3l21/21 pendn9 Nagooll. Well 01-1631 Pressures: Pretest Initial 15 Mn. 30 Mn. 45 Min. 80 Min. PTD 2111410 Type Inj W Tubing 498 525 Type TesI P Packer TVD 3675 BBL Pump 11.0 IA 523 1500 Interval 4 Test psi 1500 BBL uml I OA I 200 1 200 1 1 Result I F Notes: 116BLSsWdWW152Wl MD 01A?BGCanmuNc bn:PKR. Well was shed in on=1/21 peMlrg Eiagrol Well 0I-2047 1 Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTD 2111400 Type IN I W Tubing 371 375 1 372 1 1 Type Tesl P Packer TVD 3345 1 BBL Pump 11.0 IA 479 1710 SOD interval 4 Test psi 1500 IBBLRetumi I OA 1 145 150 145 Result I F Noted, Wellwaashulinon122121 pendllg EiaglNsbcs. well Pre ssures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTD Type Inj Tubing Type Test Packer TVD BBL Pump IA Interval Test psi BBL Return OA It"uR Nobs, TYPE HIM Codas TYPE TEST Cedes IMERVAL Codes Result Cedes W - Weber P=Pressure Test 1=Well T.. P=Pass G=Gee 0= 01Mr(Esxneen Noleq 4• Four Year Cycle F=Fail s= Slum V - Required by Val I - Incomluahs I - InduWal Wesawear 0= also (d... In mus) N • Net Inp[tin] Form 10426 (Revised 0112017) MIT OPP ENI03.21- 1 ant STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Mechanical Integrity Test Submit to: 'em mQQ(&alaska.pov: AOGCC Insoectors@alaska.aov: ph be brpoks9talaska pov OPERATOR: Ent US Operating Cc Inc FIELD / UNIT / PAD: N k 1 h g/OPP Onshore DATE: 03123/21 OPERATOR REP: Brandy VaaW AOGCC REP: Austin Mcleod chits Wallace®alaska.pov Well 0I-24-08 Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTO 2111300 Type Inj W Tubing 1 463 464 463 463 Type Test I P Packer ND 3498 BBLPump I 3.0 IA 362 1T2T 1663 1868 Interval 4 Teaf psi 1500 BBL Retum 3.0 OA 190 280 220 210 Result P Notes: Well Pressures: Pretest Initial 15 Min. 30 Mo. 45 Min. 60 Min. PTO Type Inj Tubing Type Test Packer ND BBLPump IA Interval Test psi BBL ReIum OA Result Notes Well Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTO Type Inj Tubing Type Test Packer TVD BBL Pump IA Interval Test psi BBL Return OA Result Notes: Well Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTO Type Inj Tubing Type Test Packer ND BBLPump IA Interval Test psi BBL Return OA Result N as: Well Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTO Type Inj Tubing Type Test Packer ND BBLPump a Interval Test psi BBL ReturnOA Result Nelas: Well Pressures: Pretest Initial 15 Min. 30 Min. 45 Mn. 60 Min. PTO Type Inj Tubing Type Teat Packer ND BBL Pump IA Interval Test psi BBL ReIum OA Result Notes: Well Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTO Typo Inj Tubing Type Test Packer ND BBLPump IA Interval Test psi BBL Return OA Result Notes: Well Pressures: Pretest Initial 15 Min. 30 Min. 45 Min. 60 Min. PTO Type Inj Tubing Typa Test Packer ND BBL Pump IA Interval Test psi BBL Return OA RasuN Notes: WPE INJ COO. T 11 TEST Cetlee INTERVAL COS.. Result Celle W-Water P=Pressure Teat I=Inifal TeA P-P. G=Geu 0= 01Mr(tlevuiMin Notes) 4-Four Year Cyde F=Fail S=31uny V=S.,insl Ey Veru 1=l....Iuane I • IMUWUI W....., 0=01ker (d.rW in note.) N - Nut lnpcnng Form 10426 (Reed 01/201 ]) NIT o1.34-116032131.4ax Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Monday, March 22, 2021 2:35 PM To: Wallace, Chris D (CED); Regg, James B (CED) Cc: Burgess Larry; Dibello Mike; Hart David; Lyden Dan; Brown Timothy; Dexheimer Stephen; Smagge Lorne Subject: RE: ENI Injector 4-year MIT's Mr. Regg, Conducting the Injector 4-year MIT-IA's at OPP we have 4 failures on 3/21/21. 0I-06, 0I-13, 01-15, and 01-20 all failed the pressure test and were shut in waiting further review and diagnostics. We will submit any plan for corrective action to the AOGCC. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. Looez(a)eni. com W eni From: Lopez Keith <Keith.Lopez@eni.com> Sent: Thursday, March 18, 2021 9:58 AM To: chris.wallace@alaska.gov; jim.regg@alaska.gov Cc: Burgess Larry <Larry.Burgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lyden@eni.com>; Brown Timothy <Timothy.Brown@eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smagge@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: RE: ENI Injector 4-year MIT's Mr. Wallace, We may be ready to start the MIT's at SID as early as tomorrow. We will put in the 48 hour notice as part of the normal process. Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith. L opez(@ eni. com From: Lopez Keith Sent: Wednesday, March 17, 2021 2:43 PM To: chris.waIlace @alaska.eov; lim.rega@alaska.aov Cc: Burgess Larry <Larry.BUrgess@eni.com>; Dibello Mike <Mike.Dibello@external.eni.com>; Hart David <David.Hart@eni.com>; Lyden Dan <Dan.Lyden@eni.com>; Brown Timothy <Timothy.Brown @eni.com>; Dexheimer Stephen <Stephen.Dexheimer@eni.com>; Smagge Lorne <Lorne.Smaege@eni.com>; Lopez Keith <Keith.Lopez@eni.com> Subject: ENI Injector 4-year MIT's Mr. Wallace, Today (3/17/21) ENI discovered that 19 Nikaitchuq injection wells were due for their 4-year MIT-IA's in December 2020. These MIT's were not performed and are out of compliance. We are working to secure the resources to complete these pressure tests and get back in compliance as soon as possible. I will communicate the estimated timing when we have it. We will also conduct an investigation as to how these were able to lapse including changes to our compliance system that can better insure this doesn't happen again. These improvement will be shared with the AOGCC. Well PTD # Status Date of Last Test Result Frequency (Years) Due Date Injecting since MIT due date? OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes 016-05 210-165 WINJ 12/6/2016 P 4 12/5/2020 Yes 017-04 210-153 WINJ 12/6/2016 P 4 12/5/2020 Yes 0111-01 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes 0115-54 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes 0124-08 211-130 WINJ 12/6/2016 P 4 12/5/2020 Yes 5107-SE4 214-100 WINJ 12/10/2016 P 4 12/9/2020 Yes SI11-FN6 213-128 WINJ 12/10/2016 P 4 12/9/2020 Yes 5113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes 5114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes 5117-SE2 214-041 WINJ 12/10/2016 P 4 12/9/2020 Yes 5119-FN2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes 5120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes 5125-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes 5126-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes 5129-52 212-006 WINJ 12/10/2016 P 4 12/9/2020 Yes 5132-W2 213-013 WINJ 12/10/2016 P 4 1 12/9/2020 Yes Keith Lopez Senior Production Engineer Eni Petroleum, Alaska 3800 Centerpoint Drive, Anchorage, AK 99503 Direct 907-865-3316 Mobile 907-903-5432 Keith.LOoez(a)eni.com eni Message for the recipient only, if received in error, please notify the sender and read http://www.eni.com/disclaimer/ Wallace, Chris D (CED) From: Regg, James B (CED) Sent: Thursday, March 18, 2021 4:52 PM To: Wallace, Chris D (CED) Subject: FW: AOGCC Test Witness Notification Request: MIT, Doyon 15, SID, Nikaitchuq FYI Jim Regg Supervisor, Inspections AOGCC 333 W. 71^ Ave, Suite 100 Anchorage, AK 99501 907-793-1236 From: Cook, Guy D (CED) <guy.cook@alaska.gov> Sent: Thursday, March 18, 20214:35 PM To: Vaala Brandy <Brandy.Vaala@eni.com> Cc: Regg, James B (CED) <jim.regg@alaska.gov> Subject: RE: AOGCC Test Witness Notification Request: MIT, Doyon 15, SID, Nikaitchuq Tim Brown/Brandy Vaala, As per our conversation on the phone earlier today, please resubmit when you know you are ready to test on shore (OPP). As a reminder please reference Guidance Bulletin 10-02B Mechanical Integrity Testing from the AOGCC website to help you prepare. As for testing on SID, an AOGCC inspector will not come and witness until the COVID19 outbreak you have had in the last week has got under control and your crew is COVID19 free. In addition, since there will be a delay in testing that may last a while due to the virus, there will be no action taken from the State of Alaska towards ENI for this portion of the delay in testing that is related to COVID19. This however, has no bearing on any action that may come from the late testing of these wells, that were due to be tested in December of 2020, that is not related to the virus. If you have any questions please feel free to contact me at the number below. Thank you, Guy Cook Petroleum Inspector AOGCC 907-227-2614 euy.cook@alaslca.eov 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 Guy Cook at 907-227-2614 or guy.cook@alaska.gov. From: Vaala Brandy <Brandy.Vaala@enl.com> Sent: Thursday, March 18, 20214:32 PM To: Cook, Guy D (CED) <guV cook alaska.gov> Cc: Brown Timothy <Timothy.Brown eni.com> Subject: FW: AOGCC Test Witness Notification Request: MIT, Doyon 15, SID, Nikaitchuq Guy Due to the Covid 19 situation at SID please disregard my MIT request at SID. We will be summiting a new request for SID at a later date, when are Coivd situation is resolved. Thanks for the guidance Brandy Vaala ENI 907-670-8633 From: Cook, Guy D (CED) <guv.cook@alaska.gov> Sent: Thursday, March 18, 2021 12:55 PM To: Vaala Brandy <Brandy.Vaala@eni.com> Cc: DOA AOGCC Prudhoe Bay <doa aogcc.prudhoe.bay alaska.gov> Subject: Re: AOGCC Test Witness Notification Request: MIT, Doyon 15, SID, Nikaitchuq Notification received. The phone number you supplied is not in service. Please give me a call. Thank you, Guy Cook AOGCC 907-227-2614 Sent from my iPhone On Mar 18, 2021, at 12:47 PM, Brandy Vaala <noreply,'a]iotform.com> wrote: ' Ic t f�rn�a 2 Question Answer Type of Test Requested: MIT Requested Time for 03-20-2021 7:00 AM Inspection Location Doyon 15, SID, Nikaitchuq Name Brandy Vaala E-mail Brandy.Vaalala?eni.com Phone Number (907) 685-8633 Company ENI Please arrive at NOC and logistics will shuttle you to SID. Other Information: Thanks Submission ID: 4919096460318276498 Message for the recipient only, if received in error, please notify the sender and read htti),Ilwww.eni.com/d.isclaimer/ 3 Wallace, Chris D (CED) From: Lopez Keith <Keith.Lopez@eni.com> Sent: Wednesday, March 17, 2021 2:43 PM To: Wallace, Chris D (CED); Regg, James B (CED) Cc: Burgess Larry; Dibello Mike; Hart David; Lyden Dan; Brown Timothy; Dexheimer Stephen; Smagge Lorne; Lopez Keith Subject: ENI Injector 4-year MIT's Mr. Wallace, Today (3/17/21) ENI discovered that 19 Nikaitchuq injection wells were due fortheir 4-year MIT-IA's in December 2020. These MIT's were not performed and are out of compliance. We are working to secure the resources to complete these pressure tests and get back in compliance as soon as possible. I will communicate the estimated timing when we have it. We will also conduct an investigation as to how these were able to lapse including changes to our compliance system that can better insure this doesn't happen again. These improvement will be shared with the AOGCC. Well PTD # Status Date of Last Test Result Frequency (Years) Due Date Injecting since MIT due date? OP-12 206-144 WINJ 12/6/2016 P 4 12/5/2020 Yes 016-05 210-165 WINJ 12/6/2016 P 4 12/5/2020 Yes 017-04 210-153 WINJ 12/6/2016 P 4 12/5/2020 Yes 0111-01 210-106 WINJ 12/6/2016 P 4 12/5/2020 Yes 0113-03 211-100 WINJ 12/6/2016 P 4 12/5/2020 Yes 0115-54 211-141 WINJ 12/6/2016 P 4 12/5/2020 Yes 0120-07 211-140 WINJ 12/6/2016 P 4 12/5/2020 Yes 0124-08 211-130 WINJ 12/6/2016 P 4 12/5/2020 Yes 5107-SE4 214-100 WINJ 12/10/2016 P 4 12/9/2020 Yes 5111-FN6 213-128 WINJ 12/10/2016 P 4 12/9/2020 Yes 5113-FN4 212-156 WINJ 12/10/2016 P 4 12/9/2020 Yes 5114-N6 213-194 WINJ 12/10/2016 P 4 12/9/2020 Yes 5117-SE2 214-041 WINJ 12/10/2016 P 4 12/9/2020 Yes 5119-FN2 213-043 WINJ 12/10/2016 P 4 12/9/2020 Yes 5120-N4 212-029 WINJ 12/10/2016 P 4 12/9/2020 Yes 5125-N2 212-090 WINJ 12/10/2016 P 4 12/9/2020 Yes 5126-NW2 214-157 WINJ 12/10/2016 P 4 12/9/2020 Yes 5129-52 212-006 WINJ 12/10/2016 P 4 12/9/2020 Yes 5132-W2 213-013 WINJ 12/10/2016 P 4 12/9/2020 Yes