| Agency | Form: (02)
1698551
06/18/2010 | 1) Provide 24 hour notice of MIRU to Jim Precup at 303-469-1902 or e-mail at james.precup@state.co.us
2) Comply with Rule 317.i and provide cement coverage from TD to a minimum of 200' above Niobrara and from 200’ below Shannon to 200’ above Sussex. Verify coverage with cement bond log.
3) Comply with Rule 321. Run and submit Directional Survey from TD to base of surface casing. Ensure that the wellbore complies with setback requirements in commission orders or rules prior to producing the well.
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| Engineer | Form: (06)
401861320
03/18/2019 | 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.
•COGCC Change: Move CIBP with 2 sx of cement from 8145’ to 8130’.
• COGCC Change: Move casing cut to 2500’ and open hole plug to 2500-2300’.
• If there is any bradenhead pressure reported on the pre-plugging Form 17, operator must wait 8 hrs after pumping plug at 2500-2300’ and check for fluid migration or shut-in pressure on the well. Contact COGCC Area Engineer for revised plugging orders prior to continuing with plugging operations if well is not static at that time.
• Tag 2500-2300’ plug if circulation is not maintained while pumping and displacing plug to depth, 100’ minimum required.
• COGCC Change: Increase surface plug to 175-0’, adjust cement volume accordingly.
• 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. Document well conditions in operations summary attached to the Form 6 SRA.
• 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.
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| Engineer | Form: (06)
401861320
03/18/2019 | 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.
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| Engineer | Form: (06)
401861320
03/18/2019 | 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)
402302220
02/24/2020 | 1. Operator shall implement measures to control venting, to protect health and safety, and to ensure that vapors and odors from well operations do not constitute a nuisance or hazard to public welfare.
2. Prior to starting bradenhead mitigation, if a sample has not been collected within the last twelve months collect bradenhead and production gas samples for laboratory analysis. Sampling shall comply with Operator Guidance - Bradenhead Testing and Reporting Instructions, Appendix A: Liquid and Gas Sampling. Copies of all final laboratory analytical results shall be provided to the COGCC within three months of collecting the samples.
3. During the first day of mitigation operator shall implement measures to get an initial estimate of the gas flow rate and/or volume from the bradenhead. During the shut-in period record pressure data to adequately characterize the build-up. This mitigation plan may be used for six consecutive months.
4. At the conclusion of the six months, conduct a new bradenhead test and submit the Form 17 within ten days of the test and submit a Form 4 Sundry that summarizes current well condition. The sundry should include details of the future plans and the flow rate information and pressure data.
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