STATE OF ALASKA

ALASKA OIL AND GAS CONSERVATION COMMISSION

3001 Porcupine Drive

Anchorage Alaska 99501-3192

Re: THE APPLICATION OF BP EXPLORATION ) Conservation Order No. 347
(ALASKA) INC. for an order exempting the )
Milne Point Unit, Kuparuk River Field ) Milne Point Unit
from the requirements of 20 AAC 25 .280. ) Kuparuk River Field
Kuparuk River Oil Pool
Schrader Bluff Oil Pool
November 17, 1994
IT APPEARING THAT:

1. BP Exploration (Alaska) Inc., operator of the Milne Point Unit, 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 Milne Point Unit, Kuparuk River Field.

2. Notice of public hearing was published in the Anchorage Daily News on October 11, 1994.

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

FINDINGS:

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 in the Milne Point Unit, Kuparuk River Field, 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 Milne Point Unit, Kuparuk River Field.

4. BP Exploration (Alaska) Inc., as a principle North Slope operator, also routinely conducts well workover operations within these adjacent North Slope fields (e.g., Prudhoe Bay Field).

5. BP's procedures for well workovers have become standard and routine for wells within and adjacent to the Milne Point Unit, Kuparuk River 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 well 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 173, Rule 8, as amended, requires periodic bottom hole pressure surveys in the Kuparuk River oil pool. Conservation Order 255, Rule 7, requires periodic pressure surveys in the Schrader Bluff 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.

CONCLUSIONS:

1. BP Exploration (Alaska) Inc. performs well workover operations in the Milne Point Unit, Kuparuk River Field in much the same manner as it has in other established fields on the North Slope. Those operations have become standard and routine.

2. BP'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 Milne Point Unit, Kuparuk River Field, Kuparuk River oil pool and Schrader Bluff 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 Milne Point Unit, Kuparuk River Field, Kuparuk River oil pooi and Scbrader Bluff 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.

NOW, THEREFORE IT IS ORDERED THAT:

Rule 1

The requirements of 20 AAC 25.280(a) are hereby waived for all producible wells (i.e., development wells) in the Milne Point Unit, Kuparuk River Field, Kuparuk River oil pool and Schrader Bluff oil pool.

Rule 2

The operator of Milne Point Unit, Kuparuk River Field, Kuparuk River oil pool and Schrader Bluff 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 17, 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

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