| Engineer | Form: (04)
402317116
02/19/2020 | 1) Venting to maintain the bradenhead pressure below 0.25 times the surface casing setting depth (TVD) in psi is approved. Perform annual Bradenhead tests reported on a Form 17 and an annual update sundry with the duration of venting or number of times the annulus was vented.
2) COGCC staff encourages the use of a combustor for vented bradenhead gas when feasible without the use of supplemental fuel for the combustor. An enclosed flare shall be used, unless an open flare is specifically allowed by Colorado Department of Public Health and Environment (CDPHE) Regulation 7.
3) Comply with any CDPHE, Air Pollution Control Division rules or requirements for all atmospheric discharges.
4) Any liquids blown down are to be collected, stored, handled, and treated or disposed as E&P waste per COGCC’s 900 series rules.
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| Engineer | Form: (04)
403088422
08/11/2022 | 1) If the bradenhead pressure exceeds the adjusted threshold pressure, submit a new Form 4 Sundry -Bradenhead Plan
2) Sample bradenhead gas and submit for laboratory analysis of the gas composition and stable isotopes. The compositional analysis should include hydrogen, argon, oxygen, carbon dioxide, nitrogen, methane (C1), ethane (C2), ethene, propane (nC3), isobutane (iC4), butane (nC4), isopentane (iC5), pentane (nC5), hexanes +, specific gravity and British Thermal Units (BTU).The stable isotope analysis should include delta DC1, delta 13C1, delta 13C2, delta 13C3, delta 13iC4, delta 13nC4, delta 13iC5 (if possible), delta 13nC5 (if possible), and delta 13C of CO2 (if possible). The analytical results shall be submitted to the COGCC via Form 43 (Analytical Sample Submittal Form).
Gas sample containers should be filled in accordance with container manufacturer or laboratory recommendations; purging multiple container volumes may not be feasible due to limited gas volumes.
If water is encountered in the bradenhead during testing then samples (if sufficient quantity to analyze) should be collected and submitted for the laboratory analysis of major anions (chloride, carbonate, bicarbonate, and sulfate), cations (sodium, potassium, calcium, and magnesium) total dissolved solids (TDS), BTEX, DRO, GRO, and dissolved gasses (RSK 175). If there is a limited amount of water available then anions, cations and BTEX should be given first priority. Data from bradenhead water samples shall be submitted to the COGCC via Form 43.
Please refer to Appendix A of the COGCC Operator Instructions for Bradenhead Testing and Reporting for more information regarding testing and sampling protocol.
3) Monitor fluid level in bradenhead annulus and report any changes to the COGCC |