| Engineer | Form: (04) 403838202 08/12/2024 | 1. Operator will 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. Bradenhead gas is not to be vented to the atmosphere; any gas from the Bradenhead will routed to to specified abatement system. Shut in bradenhead pressure shall not exceed 50 psig. Operator will implement measures to get an estimate of the gas flow rate and/or volume from the bradenhead.
3. No later than 1/31/25, conduct a bradenhead test, submit a Form 17, and submit a Form 4 Sundry that summarizes current well condition. The well should be shut in for seven days to monitor and collect data to characterize build up pressures prior to conducting the bradenhead test. The sundry should include details of the future plans, sample analysis interpretation, bradenhead test description, and the flow rate information and pressure data.
4. If a sample has not been collected from surface casing within the last twelve months collect bradenhead gas samples for laboratory analysis. Sampling will comply with Operator Guidance - Bradenhead Testing and Reporting Instructions, Appendix A: Liquid and Gas Sampling. Copies of all final laboratory analytical results will be provided to the ECMC within three months of collecting the samples.
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| Engineer | Form: (04) 404304885 08/20/2025 | 1. Operator will 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. Bradenhead gas is not to be vented to the atmosphere; any gas from the Bradenhead will be routed to the specified abatement system. Shut in bradenhead pressure shall not exceed threshold pressure. Operator will implement measures to get an estimate of the gas flow rate and/or volume from the bradenhead.
3. If not already plugged, then no later than 1/7/26, conduct a bradenhead test, submit a Form 17, and submit a Form 4 Sundry that summarizes current well condition. The well should be shut in for seven days to monitor and collect data to characterize build up pressures prior to conducting the bradenhead test. The sundry should include details of the future plans, sample analysis interpretation, bradenhead test description, and the flow rate information and pressure data.
4. If a sample has not been collected from surface casing within the last twenty-four months collect bradenhead gas samples for laboratory analysis. Sampling will comply with Operator Guidance - Bradenhead Testing and Reporting Instructions, Appendix A: Liquid and Gas Sampling. Copies of all final laboratory analytical results will be provided to the ECMC within three months of collecting the samples.
5. Due to bradenhead tests that demonstrate liquid flow, on the next bradenhead test form include an estimate on liquid volume and identify the correct fluid flow and type within the table. |
| OGLA | Form: (06) 404396255 10/30/2025 | 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 residential building units (RBUs) all blowdown gasses will be controlled. |
| OGLA | Form: (06) 404396255 10/30/2025 | Due to proximity of plugging and abandonment (P&A) operations to BUs, operator will comply with Table 423-1 Maximum Permissible Noise Levels for residential land use. Prior to initiating work, operator will install temporary sound walls, straw bales, or other BMPs to dampen noise if necessary for compliance. |
| OGLA | Form: (06) 404396255 10/30/2025 | Due to close proximity to Residential Building Units (RBUs): prior to commencing operations, at a minimum, the operator will provide an informational sheet to the owners/occupants of RBUs that are nearby and adjacent to the parcel on which the well is located. The sheet will include the operator's contact information and the nature, timing, and expected duration of the P&A operations. |
| Engineer | Form: (06) 404396255 11/06/2025 | 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) Prior to placing cement above the base of the Upper Pierre (1390') : 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.
3) 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 – must be at 345’ or shallower and provide a minimum of 10 sx plug at the surface.
4) Leave at least 100’ of cement in the wellbore for each plug without mechanical isolation.
5) 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.
6) With the Form 6 SRA operator must provide written documentation which positively affirms each COA listed above has been addressed.
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| Engineer | Form: (06) 404396255 11/06/2025 | 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 details with the Form 27. |
| Engineer | Form: (06) 404396255 11/06/2025 | 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) 404396255 11/06/2025 | 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. |