| Engineer | Form: (04)
404206580
05/28/2025 | 1. Operator will 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. Well to be plugged or repaired within 6 months of identifying integrity issue- 10/24/25. Pressure is to be managed and mitigated until repair or plugging is complete. Summary of well monitoring and mitigation will be submitted on a Form 4 Sundry within 30 days of the well being cut and capped or repaired. The sundry should include monthly pressure monitoring data, flow rate information, sample analysis interpretation, and bradenhead test description.
3. Shut in bradenhead pressure shall not exceed threshold pressure.
4. If a sample has not been collected within the last twelve months collect bradenhead and production gas samples for laboratory analysis. Sampling will comply with Operator Guidance - Bradenhead Testing and Reporting Instructions, Appendix A: Liquid and Gas Sampling. Copies of all final laboratory analytical results will be provided to the COGCC within three months of collecting the samples.
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| Engineer | Form: (04)
404206580
05/28/2025 | Within 30 days submit 2023, 2024 and 2025 monthly pressure monitoring data on a Form 4 BHP Sundry and include a diagnostic summary of this information. |
| OGLA | Form: (06)
404247003
06/26/2025 | Due to proximity to a mapped wetland and surface water, Operator will use secondary containment for all tanks and other liquid containers. Operator will implement stormwater BMPs and erosion control measures as needed to prevent sediment and stormwater runoff from entering the wetland and surface water. |
| OGLA | Form: (06)
404247003
06/26/2025 | Location is within CPW mapped areas for the following High Priority Habitats: Elk Winter Concentration Area, Elk Severe Winter Range, Mule Deer Winter Concentration Area, and Mule Deer Severe Winter Range. Although plugging and abandonment operations with heavy equipment will be allowed, the Operator is strongly encouraged to avoid them from December 1 through April 30.
Operator completed CPW consultation 6/18/25 [Doc # 404250984]. The following Conditions of Approval were agreed to during the consultation:
1. Wildlife – Minimization: To minimize the potential for wildlife related traffic accidents, TEP has implemented speed restrictions for all lease roads and requires that all TEP employees and contractors adhere to these posted speed restrictions.
2. Wildlife – Minimization: TEP will make best efforts to minimize operations at these location during winter months by conducting operations, when possible, between 9:00am to 4:00pm when wildlife activity minimal.
3. Wildlife – Minimization: TEP will minimize vehicle numbers and traffic by carpooling to the site whenever possible. |
| Engineer | Form: (06)
404247003
07/07/2025 | Well to be plugged or repaired within 6 months of identifying integrity issue- 10/24/25. Pressure is to be managed and mitigated until repair or plugging is complete. Summary of well monitoring and mitigation will be submitted on a Form 4 Sundry within 30 days of the well being cut and capped or repaired. The sundry should include monthly pressure monitoring data, flow rate information, sample analysis interpretation, and bradenhead test description. |
| Engineer | Form: (06)
404247003
07/07/2025 | 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.
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| Engineer | Form: (06)
404247003
07/07/2025 | 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: (06)
404247003
07/07/2025 | 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.
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| Engineer | Form: (06)
404247003
07/07/2025 | 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 surface casing shoe. 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 only after isolation has been verified. If surface casing cement is not circulated to surface, shut-in, WOC 4 hours then tag plug
4) Leave at least 100’ of cement in the wellbore for each plug without mechanical isolation.
5) After surface plug and prior to cap, verify isolation by either a 15 minute bubble test or 15 minute optical gas imaging. 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.
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