3001 Porcupine Drive

Anchorage Alaska 99501-3192
Re:THE APPLICATION OF BP Exploration             )  Conservation Order No. 343	
(Alaska) Inc. for an order exempting             )
the Niakuk oil pool from the requirements        )  Niakuk Field
of 20 AAC 25.280                                 )  Niakuk Oil Pool
                                                    November 2, 1994

1. BP Exploration (Alaska) Inc., operator of the Niakuk Field, submitted an application on September 9, 1994 requesting exemption from the requirements of 20 AAC 25.280(a) and (b) for all wells in the Niakuk oil pool.

2. Notice of public hearing was published in the Anchorage Daily News on September 28, 1994.

3. No protests to the application were filed with the commission.


1. Operators must file an Application for Sundry Approvals (Form 10-403) and receive commission approval prior to performing well workovers (i.e., perforating or reperforating casing, well stimulation, pulling tubing, altering casing, and repairing wells). 20 AAC 25.280(a).

2. Current well activity on the North Slope is dominated by the types of workover operations set forth in 20 AAC 25.280(a).

3. Wells in adjacent pools are drilled and completed similar to those in the Niakuk oil pool.

4. BP Exploration (Alaska) Inc., as a principle North Slope operator, routinely conducts well workover operations in wells within and adjacent to the Niakuk oil pool.

5. BPX's procedures for well workovers have become standard and routine for wells within and adjacent to the Niakuk oil pool (e.g. Prudhoe Bay Field).

6. Information regarding the well condition, well workover program, bottom-hole pressure and well control program must be submitted with an Application for Sundry Approval. 20 AAC 25.280(b).

7. The operator must submit a Well Completion or Recompletion Report and Log (Form 10-407) within 30 days after completing a well. 20 AAC 25.070. Most of the information (name, location, condition, downhole equipment, etc.) required with the Application for Sundry Approvals for workovers also appears on Form 10-407.

8. The operator must maintain records and reports of well workovers for at least five years. 20 AAC 25.280(c) and 20 AAC 25.070. The operator must submit a complete well record, with copy of daily reports and tests, after completing well workovers on a Report of Sundry Well Operations (Form 10-404). 20 AAC 25. 280(d).

9. Conservation Order 329, Rule 8, requires periodic bottom hole pressure surveys in the Niakuk oil pool.

10. Well workovers under 20 AAC 25.280 on development wells do not prompt additional requirements beyond the criteria imposed by regulation.

11. The commission has primacy for all Class II injection wells in the state.

12. Well workover operations on injection wells sometime prompt additional requirements such as mechanical integrity tests.

13. Commission inspectors routinely inspect drilling and well workover operations to ensure compliance with regulations.


1. BP Exploration (Alaska) Inc. is likely to perform well workover operations in Niakuk oil field wells in much the same manner as it has in adjacent established fields. Those operations have become standard and routine.

2. BPX's record of performance shows a long history of safe and responsible well workover operations.

3. Eliminating the requirements of 20 AAC 25.280(a) and (b) for all development wells in the Niakuk oil pool will reduce filing and result in administrative efficiencies for both the operator and the AOGCC.

4. Eliminating the requirements of 20 AAC 25.280(a) and (b) for all development wells in the Niakuk oil pool will not promote waste nor jeopardize correlative rights.

5. In order to administer the Class II UIC program, Form 10-403 must still be required prior to workovers on all service wells (i.e., gas injection, water injection, waste injection).

6. Subsequent report of workover operations (Form 10-404) must still be filed with the commission in order to keep well files current.

7. A current schedule of upcoming workover operations is necessary for the commission to exercise its compliance responsibilities.


Rule 1

The requirements of 20 AAC 25.280(a) are hereby waived for all producible wells (i.e., development wells) in the Niakuk oil pool.

Rule 2

The operator of Niakuk oil pool shall provide the commission with a schedule of planned workover operations including the well and intended operation on a weekly basis.

DONE at Anchorage, Alaska and dated November 2, 1994.

David W. Johnston, Chairman
Alaska Oil and Gas Conservation Commission

Russell A. Douglass, Commissioner
Alaska Oil and Gas Conservation Commission

Tuckerman Babcock, Commissioner
Alaska Oil and Gas Conservation Commission

Conservation Order Index