| Engineer | Form: (06 )
401878287
2/19/2019 | Plugging
• Provide 48 hour notice of plugging MIRU via electronic Form 42.
• Plugs and squeezes will be placed as stated in the plugging procedure of the approved NOI unless revised by COA or prior approval from COGCC is obtained.
• COGCC Change: Add 50 sx squeeze at 2500’.
• Submit gyro survey with Form 6 SRA if available.
• Delete Step 9 in the attached procedure. “9. Tie-in pump to bradenhead. Attempt to establish injection down bradenhead with pressure limit of 265 psi. If injection is established, RU to pump nanosealant. Slowly pump nanosealant down bradenhead, monitoring injection pressures to not exceed 265 psi. Shut-in bradenhead, monitoring pressure for 15 minutes. Contact engineering with pressure results and discuss path forward.” No pumping down the bradenhead will be allowed unless previously approved by the COGCC.
• Check for 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). Contact COGCC Area Engineer for revised plugging orders if well is not static at this time prior to continuing with plugging operations. Document well conditions in operations summary attached to the Form 6 SRA.
• 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. Confirm cement to surface in all strings during cut and cap and document in operations summary attached to the Form 6 SRA.
• Properly abandon flowlines as per Rule 1105. File electronic Form 42 once abandonment complete. Within 30 days of an operator completing abandonment requirements for an off-location flowline or crude oil transfer line the operator must submit a Flowline Report, Form 44.
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| Engineer | Form: (06 )
401878287
2/19/2019 | 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.
• Form 17 Bradenhead Test Report shall be submitted within 10 days of the test.
• 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 via a Form 43 to upload the laboratory results to the COGCC Environmental Database. Form 43 instructions are on COGCC’s website under Regulation => Forms => Form 43 COGCC Environmental Database.
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| Engineer | Form: (06 )
401878287
2/19/2019 | 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.
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