STATE OF ALASKA

ALASKA OIL AND GAS CONSERVATION COMMISSION

3001 Porcupine Drive

Anchorage Alaska 99501-3192
Re:THE APPLICATION OF UNOCAL CORP.                   )  Conservation Order No. 351
for an order exempting fields in the Cook Inlet      )	
area from the requirements of 20 AAC 25.280.         )  Unocal Operated
                                                     )  Cook Inlet Fields
                                                        December 29, 1994
IT APPEARING THAT:

1. Unocal Corporation (Unocal) operator of several Cook Inlet oil and gas fields, submitted an application on November 1, 1994, requesting exemption from the requirements of 20 AAC 25.280(a) and (b) for Unocal operated wells in the following fields and pools:

FIELD POOL
McArthur River Hemlock
Middle Kenai - G
West Foreland
Swanson River Hemlock
Undefined
Middle Ground Shoal Middle Ground Shoal - A
Middle Ground Shoal - B,C,D
Middle Ground Shoal - E,F,G
Granite Point Middle Kenai
Hemlock
Trading Bay Hemlock
Undefined
Middle Kenai - B
Middle Kenai - C
Middle Kenai - D
Middle Kenai - E
Ivan River Undefined
Lewis River Undefined

2. Notice of public hearing was published in the Chugiak-Eagle River Alaska Star on December 3, 1994.

3. The Commission received no protest or request for hearing regarding the petition.

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 Cook Inlet area is dominated by the types of workover operations set forth in 20 AAC 25.280(a).

3. Unocal Corporation, as a principle Cook Inlet operator, has routinely conducted well workover operations within the aforementioned Cool Inlet fields for the past 30 years.

4. Unocal's procedures for well workovers have become standard and routine for wells it operates in the Cool Inlet area.

5. 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).

6. 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.

7. 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).

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

9. The Commission has primacy for all Class II injection wells in the state.

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

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

CONCLUSIONS:

1. Unocal performs standard and routine well workover operations in fields it operates in the Cook Inlet area.

2. Unocal'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 Unocal operated fields in the Cook Inlet area 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 Unocal operated fields in the Cook Inlet area 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 following Unocal operated fields/pools in the Cook Inlet area:

FIELD POOL
McArthur River Hemlock
Middle Kenai - G
West Foreland
Swanson River Hemlock
Undefined
Middle Ground Shoal Middle Ground Shoal - A
Middle Ground Shoal - B,C,D
Middle Ground Shoal - E,F,G
Granite Point Middle Kenai
Hemlock
Trading Bay Hemlock
Undefined
Middle Kenai - B
Middle Kenai - C
Middle Kenai - D
Middle Kenai - E
Ivan River Undefined
Lewis River Undefined

Rule 2

The operator of the aforementioned fields and pools, 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 December 29, 1994.

David W. Johnston, Commissioner
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