| Engineer | Form: (06)
401861283
04/09/2019 | Plugging
• Provide 48 hour notice of plugging MIRU via electronic Form 42.
• Plugs and squeezes will be placed as stated in the plugging procedure of the approved NOI unless revised by COA or prior approval from COGCC is obtained.
• If there is bradenhead pressure reported on the pre-plugging Form 17 operator will contact COGCC Area Engineer for revised plugging orders prior to proceeding with plugging operations.
• COGCC Change: Move CIBP with 2 sx of cement from 8364’ to 8350’, away from collar.
• COGCC Change: Move casing cut to 2500’, open hole plug to 2500-2300’, below base of UPA, no Form 17 on file.
• Tag 2500-2300’ plug if circulation is not maintained during pumping and displacement of plug to depth, 100’ minimum height required.
• COGCC Change: Increase surface plug to 110-0’, adjust cement volume accordingly, aquifer.
• Submit gyro survey with Form 6 SRA if available.
• Check for fluid migration or shut-in pressure on the well prior to pumping any plug(open hole, annular or casing) that isolates deepest aquifer or the surface casing shoe (whichever is deeper). Contact COGCC Engineer for revised plugging orders if well is not static at this time, prior to continuing with plugging operations.
• Tag required if the shoe plug, or combined stub/shoe plug, is not circulated to the surface. Shoe plug shall be placed as specified herein and the top of cement must be a minimum 50’ into the shoe, or 50’ above the stub (if not cut below the shoe), whichever is shallower.
• Place a 50' plug (minimum) at the surface, both inside the inner most casing and in all annular spaces. All other cement plugs, without mechanical isolation, shall have at least 100' of cement left in the casing.
• Properly abandon on-location flowlines as per Rule 1105. File electronic Form 42 once abandonment complete. Within 30 days of an operator completing abandonment requirements for an off-location flowline or crude oil transfer line the operator must submit a Flowline Report, Form 44.
• Document all COAs have been satisfied on Form 6 SRA.
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| Engineer | Form: (06)
401861283
04/09/2019 | Bradenhead Testing
• Prior to the start of plugging operations, a bradenhead test shall be performed and reported if there has not been a reported bradenhead test within the 60 days immediately preceding the start of plugging operations.
• If any of the following conditions exist then sampling of all fluids is required and sampling methods shall comply with Operator Guidance – Bradenhead Testing and Reporting Instructions, Appendix A: Liquid and Gas Sampling as found on the COGCC website, cogcc.state.co.us.
1) The initial pressure measurement on the bradenhead is greater than 25 psi, prior to blowing down any liquid or gas from the bradenhead valve, or
2) Pressure remains at the conclusion of the test, or
3) Any liquids are present anytime during the test. If so, then stop the test as soon as liquids are present and sample before resuming the test.
• Form 17 Bradenhead Test Report shall be submitted within 10 days of the test.
• If samples are collected, copies of all final laboratory analytical results shall be provided to the COGCC within three (3) months of collecting the samples. Submit via a Form 43 to upload the laboratory results to the COGCC Environmental Database. Form 43 instructions are on COGCC’s website under Regulation => Forms => Form 43 COGCC Environmental Database.
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| Engineer | Form: (06)
401861283
04/09/2019 | Venting
Operator shall implement measures to control unnecessary and excessive venting, to protect the health and safety of the public, and to ensure that vapors and odors from well plugging operations do not constitute a nuisance or hazard to public welfare.
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| Engineer | Form: (04)
402573624
01/15/2021 | Operator shall implement measures to control venting, to protect health and safety, and to ensure that vapors and odors from well plugging operations do not constitute a nuisance or hazard to public welfare. |
| Engineer | Form: (04)
402573624
01/15/2021 | Provide all applicable paperwork to the COGCC to document work done. |
| Engineer | Form: (06)
403846881
07/17/2024 | 1) Provide electronic Form 42 Notice of MIRU 2 business days ahead of operations and electronic Form 42 Notice of Plugging Operations 48 hours prior to mobilizing for plugging operations. These are two separate notifications, required by Rules 405.e and 405.l.
2) Prior to placing cement above the base of the Upper Pierre (1934') : verify that all fluid (liquid and gas) migration has been eliminated. If evidence of fluid migration or pressure remains, contact ECMC Engineer for an update to plugging orders.
3) Pump surface casing shoe plug at 1001' only after isolation has been verified. If surface casing cement is not circulated to surface, shut-in, WOC 4 hours then tag plug – must be at 718’ or shallower and provide a minimum of 10 sx plug at the surface.
4) Leave at least 100’ of cement in the wellbore for each plug without mechanical isolation.
5) After cut and prior to cap, verify isolation by either a 15 minute bubble test or 15 minute optical gas imaging recording. If there is indication of flow contact ECMC Engineering. Provide a statement on the 6SRA which method was used and what was observed. Retain records of final isolation test for 5 years.
6) With the Form 6 SRA operator must provide written documentation which positively affirms each COA listed above has been addressed. |
| Engineer | Form: (06)
403846881
07/17/2024 | Consistent with Rule 911.a, a Form 27 must be approved prior to cut and cap, conducting flowline abandonment, or removing production equipment. Allow 30 days for Director review of the Form 27; include the Form 27 document number on the Form 44 for offsite flowline abandonment (if applicable) and on the Form 6 Subsequent.
Properly abandon flowlines per Rule 1105. If flowlines will be abandoned in place, include with the Form 27: pressure test results conducted in the prior 12 months as well as identification of any document numbers for a ECMC Spill/Release Report, Form 19, associated with the abandoned line. |
| Engineer | Form: (06)
403846881
07/17/2024 | Prior to starting plugging operations a bradenhead test shall be performed if there has not been a reported bradenhead test within the 60 days immediately preceding the start of plugging operations.
1) If, before opening the bradenhead valve, the beginning pressure is greater than 25 psi, sampling is required.
2) If pressure remains at the conclusion of the test, or if any liquids were present during the test, sampling is required.
The Form 17 shall be submitted within 10 days of the test. Sampling shall comply with Operator Guidance - Bradenhead Testing and Reporting Instructions. If samples are collected, copies of all final laboratory analytical results shall be provided to the ECMC within three (3) months of collecting the samples.
If there is a need for sampling, contact ECMC engineering for verification of plugging procedure. |
| OGLA | Form: (06)
403846881
07/22/2024 | Due to the proximity and density of the neighboring subdivision: Prior to commencing operations, the operator will notify the appropriate local governing bodies to inform them of the planned operations (HOAs, local government, etc). The operator will post signs in conspicuous locations that will remain in place throughout the duration of the plug and abandonment activities. The signs will indicate plugging and abandonment operations are being conducted, the well name, well, and the applicable contact information. Signs will be placed so as not to create a potential traffic hazard. |
| OGLA | Form: (06)
403846881
07/22/2024 | Operator will implement measures to capture, combust, or control emissions to protect health and safety, and to ensure that vapors and odors from well plugging operations do not constitute a nuisance or hazard to public health, welfare and the environment. Due to the proximity of residential building units (RBUs) all blowdown gasses will be controlled.
Due to proximity of plugging and abandonment (P&A) operations to BUs, operator will comply with Table 423 Maximum Permissible Noise Levels for residential land use. Prior to initiating work, operator will install temporary sound walls, straw bales, or other BMPs to dampen noise if necessary for compliance.
Due to close proximity to Residential Building Units (RBUs), prior to commencing operations, at a minimum, the operator will provide an informational sheet to the owners/occupants of the RBUs nearby and adjacent to the parcel with the well. The sheet will include the operator's contact information and the nature, timing, and expected duration of the P&A operations. |