| Engineer | Form: (02)
401600194
04/17/2018 | 1)Operator shall comply with the most current revision of the Northwest Notification Policy.
2)Operator shall provide cement coverage from the production casing shoe (5 1/2" FIRST STRING) to a minimum of 200' above the surface casing shoe to provide isolation of all Green River, Wasatch, and Mesaverde Group oil, gas, and water-bearing sandstone and coalbed formations that are not otherwise covered by surface casing. Verify production casing cement coverage with a cement bond log.
3)Oil-based drilling fluid is to be used only after all fresh water aquifers are covered. |
| OGLA | Form: (02)
401600194
04/27/2018 | COA 11 - A closed loop system must be implemented during drilling (as indicated on the Form 2). The moisture content of water/bentonite-based mud (WBM) generated cuttings managed onsite shall be kept as low as practicable to prevent accumulation of liquids greater than de minimis amounts.
COA 13 - All cuttings generated during drilling with oil-based mud (OBM-) must be segregated from water/bentonite based mud-(WBM-) generated drill cuttings and placed separately on the well pad. All OBM-generated drill cuttings 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 a tank, cuttings containment area, or pile shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts. The operator has indicated that ‘Cuttings Disposal’ will be “ONSITE” and that the ‘Cuttings Disposal Method’ will be “OTHER” (as shown in the ‘DRILLING WASTE MANAGEMENT PROGRAM SECTION’ of the Form 2). Any liners associated with oil-based drilling mud and OBM-generated drill cuttings must be disposed of offsite per CDPHE rules and regulations. Any cuttings to remain on location will require submittal (via a Form 4 Sundry Notice) and approval of a revised Waste Management Plan detailing the changes (specifying cuttings characterization methods, cuttings management, amendment, and onsite disposal location[s]). All cuttings dispoiosed of onsite must meet all levels listed in Table 910-1. |
| OGLA | Form: (06)
402829313
10/05/2021 | 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. |
| Permit | Form: (06)
402829313
12/27/2021 | Submit Operator's Monthly Production Reports (Form 7) required for compliance with Rule 413 within 30 days
Form 7 reporting missing 06/2018-04/2021, 10/2021 |
| Engineer | Form: (06)
402829313
12/29/2021 | 1) Provide 48 hour notice of plugging MIRU via electronic Form 42.
2) The approved Form 6, Notice of Intent will be at the location during all phases of plugging operations.
3) Operator shall implement measures to control venting and to ensure that vapors and odors from well plugging operations do not constitute a nuisance or hazard.
4) Properly abandon flowlines as per Rule 1105. Pursuant to Rule 911.a. Closure of Oil and Gas Facilities, Operator will submit Site Investigation and Remediation Workplans via Form 27 for COGCC prior approval before cutting and capping the plugged well, conducting flowline abandonment, and removing production equipment. Pursuant to Rule 1105.f. Abandonment Verification, within 90 days of an operator completing abandonment requirements for a flowline or crude oil transfer line, an operator must submit a Field Operations Notice, Form 42-Abandonment of Flowlines for on-location flowlines, and a Flowline Report, Form 44, for off-location flowlines or crude oil transfer lines.
5) Check bradenhead annulus pressure prior to MIRU. Perform a bradenhead test if bradenhead pressure is greater than 25 psi, submit results electronically on a Form 17, and contact COGCC area engineer.
If a well has a bradenhead pressure greater than 25 PSI measured at the time of the test then a sample of both the production and bradenhead gas (if sufficient volume to analyze) shall be collected and submitted 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.
If the Bradenhead pressure is greater than 25 psi, the operator shall provide notice to Environmental Supervisor Alex Fischer at alex.fischer@state.co.us or 303-894-2100 X 5138 and COGCC Engineer Craig Burger at craig.burger@state.co.us or 970-319-4194, a minimum of 72 hours prior to conducting field operations. Bradenhead testing and sample collection shall be completed if the Bradenhead pressure is greater than 25 psi. 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.
6) This well has federal minerals. Operator shall notify COGCC engineering staff of any plugging changes required by the BLM or unexpected conditions in the field as soon as feasible.
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