| Engineer | Form: (02) 400587235 01/26/2015 | 1) Operator shall comply with the most current revision of the Northwest Notification Policy. See attached notice.
2) Operator shall comply with the most current revision of the Garfield County Rulison Field Notice to Operators, with the following exception: All field notice requirements specified in that Notice to Operators are superseded by the requirements of the most current revision of the Northwest Colorado Notification Policy (see Condition of Approval #1). See attached notice.
3) Operator shall provide cement coverage from the intermediate casing shoe (7+5/8" first string) to a minimum of 200' above all Mesa Verde Group (and Ohio Creek Formation, if present) oil, gas, and water-bearing sandstone and coalbed formations. Verify intermediate casing cement coverage with a cement bond log. |
| OGLA | Form: (04) 400821398 05/13/2015 | The following COAs provide procedures and requirements that may already be reflected in the operator's submitted BMPs for the use of oil-based drilling mud for the curve and lateral portions of the wellbores at this location. If there are any questions about the COAs, contact Dave Kubeczko at 970-309-2514 or email at dave.kubeczko@state.co.us.
A closed loop system must be implemented during drilling. All cuttings generated during drilling with oil based mud (OBM) must be kept in tanks/containers, or placed on a lined/bermed portion of the well pad; prior to disposition. The moisture content of any OBM-generated drill cuttings in tanks/containers, or in a cuttings containment area or pile, shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts. At the time of closure, if the drill cuttings are to be left onsite, they must also meet the applicable standards of Table 910-1. Representative cuttings samples will be analyzed for all Table 910-1 constituents. Any material which does not meet Table 910-1 criteria will either be manifested and disposed offsite at the facility identified by the operator, or amended further onsite to comply with Table 910-1. If operator determines that long-term onsite management of oil based mud cuttings is necessary, an approved Form 27 remediation plan will be required. Any liners associated with oil based drilling mud and cuttings must be disposed of offsite per CDPHE rules and regulations.
The moisture content of water/bentonite based mud (WBM) generated drill cuttings managed onsite shall be kept as low as practicable to prevent accumulation of liquids greater than de minimis amounts. After drilling and completion operations have been completed, the WBM drill cuttings that will remain on the well pad location (cuttings management area, the cut portion of the pad, cuttings trench, dry cuttings drilling pit), must meet the applicable standards of Table 910-1. After the drill cuttings have been amended (if necessary) and placed on the well pad, sampling frequency of the drill cuttings (to be determined by the operator) shall be representative of the material left on location. No offsite disposal of cuttings to another oil and gas location shall occur without prior approval of a Waste Management Plan (submitted via a Form 4 Sundry Notice) specifying disposal location and waste characterization method. Commercial disposal of drill cuttings will only require notification to COGCC via a Form 4 Sundry Notice. |
| OGLA | Form: (06) 403957710 10/28/2024 | Due to proximity to a wetland, surface water and expected shallow groundwater, 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.
LAS review complete. |
| Engineer | Form: (06) 403957710 06/09/2025 | 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) After placing plug at 6620’ assure that all fluid migration has been eliminated by monitoring the well for a minimum of 8 hours before proceeding to the next plug. If at any time after placing this plug there is evidence of pressure or of fluid migration, contact ECMC engineering before continuing operations.
3) 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.
4) 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
5) Leave at least 100’ of cement in the wellbore for each plug without mechanical isolation.
6) 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.
7) With the Form 6 SRA operator must provide written documentation which positively affirms each COA listed above has been addressed.
8) This well has federal minerals. Operator shall notify ECMC engineering staff of any plugging changes required by the BLM or unexpected conditions in the field prior to continuing operations.
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| Engineer | Form: (06) 403957710 06/09/2025 | 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.
If there is a need for sampling, contact ECMC engineering for verification of plugging procedure.
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| Engineer | Form: (06) 403957710 06/09/2025 | 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) 403957710 06/09/2025 | 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. |