| Engineer | Form: (06)
401218666
03/10/2017 | 1) Provide 48 hour notice of plugging MIRU via electronic Form 42.
2) Submit copy of CBL run with the subsequent form 6.
3) For the 1500’ plug: pump plug and displace. If surface casing plug is not circulated to surface then tag plug – must be at 332’ or shallower and provide 10 sx plug at the surface. Leave at least 100’ of cement in the casing for each plug.
4) Properly abandon flowlines as per Rule 1103. File electronic Form 42 once abandonment complete.
5) Prior to starting plugging operations a Bradenhead test shall be performed. If the beginning pressure is greater than 25 psi, or if pressure remains at the conclusion of the test, or if any liquids were present contact COGCC Engineering for sampling requirements. The Form 17 shall be submitted within 10 days of the test.
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| Permit | Form: (06)
401514613
02/20/2018 | Please revise production reporting to shut in status instead of TA, since it doesn't seem to have been TA'd. |
| Engineer | Form: (06)
401514613
02/21/2018 | Post Plugging Reporting
• Form 17 Bradenhead Test Report shall be submitted within 10 days of the test.
• File electronic Form 42 once flowline abandonment is complete.
• 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.
• Submit the CBL (with SROA) to have been run during P&A to confirm top of primary cement. |
| Engineer | Form: (06)
401514613
02/21/2018 | Plugging
• Provide 48 hour notice of plugging MIRU via electronic Form 42.
• 75 sx open hole plug at 1600’ +/- must be tagged if circulation is not maintained or fluid level drops during or after placement.
• Contact COGCC Engineer for revised plugging orders if there is 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).
• Tag required if the shoe plug, or combined stub/shoe plug, is not circulated to the surface and top of cement must be 50’ into the shoe, or 50’ above the cut, 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 flowlines as per Rule 1103. |
| Engineer | Form: (06)
401514613
02/21/2018 | 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. |
| Engineer | Form: (06)
401514613
02/21/2018 | 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. |