Prudhoe Bay injection fluids standardized

In response to BP request, AOGCC amends injection orders for fluids used for EOR, pressure maintenance

Kristen Nelson

Petroleum News

In response to a request from BP Exploration (Alaska), the Alaska Oil and Gas Conservation Commission has standardized fluids authorized for injection for enhanced recovery and pressure maintenance for oil pools in the Prudhoe Bay field.

BP requested a change to Prudhoe Bay field injection orders in April, citing “the complexity of field operations with multiple pools serviced by common facilities and potential confusion that results from the different language in the various orders.” BP said proposed changes in language were “intended to clarify and document the fluids that are authorized for enhanced oil recovery (EOR) and pressure maintenance injection” within the Prudhoe Bay field “and provide greater compliance assurance for our field operations.”

Language in area injection orders for Prudhoe Bay pools varied, with some orders containing very general language and some very specific language in defining fluids authorized for injection; in some cases, the company said, the language in specific injection orders had changed over time. BP said that in addition to the variation in the injection orders, “some fluids have received specific authorization via administrative approvals.”

“The diversity of language and changes over time has resulted in confusion over which fluids are actually authorized for injection,” BP told the commission.

BP included a four-page list summarizing language differences in fluids authorized for EOR and pressure maintenance in nine Prudhoe Bay pools.

BP proposed language for standardizing the list of authorized fluids, noting that in some pools, “additional clarification may be required to capture specific conditions or restrictions contained in current orders.”

In multiple administrative approvals issued Sept. 4 the commission generally approved BP’s request, with what it called “a minor change in the wording proposed” by the company.

It said the change BP proposed “will result in increased production, is based on sound engineering and geotechnical reasons, does not promote waste or jeopardize correlative rights, and will not result in increased risk of fluid movement into freshwater.”

The commission further noted that correlative rights (rights of adjacent leaseholders) “are protected because all lands subject to these orders have been unitized.”

However, the commission said, the language suggested by BP used the terms “includes” and “includes but not limited to,” “inappropriately” delegating to BP “the authority to determine what additional fluids are approved” and it deleted such language in its approvals.