| Engineer | Form: (04) 402349417 01/05/2021 | 1. Operator shall 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. Prior to starting Bradenhead mitigation, if a sample has not been collected within the last twelve months collect Bradenhead and production gas samples for laboratory analysis. Sampling shall comply with Operator Guidance - Bradenhead Testing and Reporting Instructions, Appendix A: Liquid and Gas Sampling. Copies of all final laboratory analytical results shall be provided to the COGCC within three months of collecting the samples.
3. During the first day of mitigation operator shall implement measures to get an initial estimate of the gas flow rate and/or volume from the Bradenhead. During the shut-in period record pressure data to adequately characterize the build-up. This mitigation plan may be used for six consecutive months.
4. At the conclusion of the six months, conduct a new Bradenhead test and submit the Form 17 within ten days of the test and submit a Form 4 Sundry that summarizes current well condition. The sundry should include details of the future plans and the flow rate information and pressure data.
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| Engineer | Form: (04) 402349417 01/05/2021 | Shut in Bradenhead pressure shall not exceed 50 psig. |
| OGLA | Form: (06) 403490584 08/15/2023 | Due to proximity to a mapped wetland, 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) 403490584 08/15/2023 | Due to the proximity and density of the neighboring subdivision: Prior to commencing operations, the operator will notify the appropriate local governing bodies to inform them of the planned operations (HOAs, local government, etc). The operator will post signs in conspicuous locations that will remain in place throughout the duration of the plug and abandonment activities. The signs will indicate plugging and abandonment operations are being conducted, the well name, well, and the applicable contact information. Signs will be placed so as not to create a potential traffic hazard. |
| OGLA | Form: (06) 403490584 08/15/2023 | Due to close proximity of plugging and abandonment (PA) operations to RBUs, Operator will ensure compliance with maximum permissible noise levels in COGCC Rule Table 423-1 and install temporary sound walls, straw bales, or other BMPs to dampen noise if necessary. |
| OGLA | Form: (06) 403490584 08/15/2023 | 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. Due to the proximity of RBUs, all blowdown gasses will be controlled. |
| Engineer | Form: (06) 403490584 08/25/2023 | 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. |
| Engineer | Form: (06) 403490584 08/25/2023 | For Wells with known Bradenhead pressures:
1) Provide 2 business day notice of plugging MIRU via electronic Form 42, and provide 48 hours Notice of Plugging Operations, prior to mobilizing for plugging operations via electronic Form 42. These are 2 separate notifications, required by Rules 408.e and 408.I.
2) After placing the shallowest hydrocarbon isolating plug (1450'), operator must wait a sufficient time to confirm static conditions.
3) After placing plug at 1450’ 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.
4) Prior to placing the 605’ plug: verify that all fluid migration (liquid or gas) has been eliminated. If evidence of fluid migration or pressure remains, contact ECMC Engineer for an update to plugging orders.
5) After isolation has been verified, pump plug and displace. If cement is not circulated to surface, shut-in, WOC 4 hours then tag plug – must be at 355’ or shallower and provide at least 10 sx plug at the surface.
6) With the Form 6 SRA operator must provide written documentation which positively affirms each COA has been addressed. |
| Engineer | Form: (06) 403490584 08/25/2023 | FLOWLINE AND SITE CLOSURE
1) 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.
2) 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. |