| Engineer | Form: (04)
402310352
04/28/2020 | 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. 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.
4. This mitigation plan may be used for six consecutive months from the approved sundry date. 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. |
| Engineer | Form: (04)
402567387
01/11/2021 | 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. This well is scheduled to be plugged in 2022. Operator will continue to manage, monitor and mitigate pressures for this well. A Form 4 bradenhead plan report of work done will be submitted within 30 days of 01/11/2022 (12 months from approval date). The sundry should include monthly pressure monitoring data, flow rate information, sample analysis interpretation, and bradenhead test description.
3. Shut in bradenhead pressure shall not exceed 50 psig. |
| Engineer | Form: (04)
402943800
02/18/2022 | 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. Well to plugged no later than 12/31/2022. Pressure is to be managed and mitigated until plugging is complete. Summary of well monitoring and mitigation will be submitted on a Form 4 Sundry within 30 days of the well being plugged and abandoned but no later than 12/31/2022. The sundry should include monthly pressure monitoring data, flow rate information, sample analysis interpretation, and bradenhead test description.
3. Shut in bradenhead pressure shall not exceed 50 psig.
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| OGLA | Form: (04)
403138687
08/26/2022 | Operator will implement measures to capture, combust, or control emissions to protect health and safety, and to ensure that vapors and odors from well completion(s), well repair/maintenance, well perforating, temporary abandonment activities, additional equipment installation, and/or testing operations with a workover rig, wireline rig, or other heavy equipment do not constitute a nuisance or hazard to public health, welfare and the environment. |
| Engineer | Form: (04)
403138687
08/30/2022 | 1) Provide electronic Form 42 Notice of MIRU 2 business days ahead of operations.
2) The additional cement referenced shall be placed as indicated. The placed cement shall be verified with a cement bond log.
3) After repairs, operator will successfully pressure test the production casing for a minimum of 15 minutes and to a minimum of 300 psi.
4) Cement bond logs and successful pressure test to be submitted on the Form 5 within 30 days of repair operations.
5) Bradenhead tests shall be performed within 60 days of repair. The Form 17 shall be submitted within 10 days of the test. |
| Engineer | Form: (04)
403319258
02/17/2023 | Operator shall continue to monitor pressure, and report to COGCC through annual testing. If monitored well conditions meet the thresholds defined by Order 1-232 a new bradenhead test and sundry must be filed.
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| OGLA | Form: (04)
403902822
08/28/2024 | Operator committed to the following Best Management Practices in the attached email of the CPW consultation: Bald Eagle NEST .25 / .5: KMOG will not conduct operations between 12/1 – 7/31 |
| Engineer | Form: (04)
403902822
09/17/2024 | 1) Provide electronic Form 42 Notice of MIRU 2 business days ahead of operations.
2) 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.
3) Form 4, Sundry Notice for temporarily abandoned status required for all wells incapable of production. Submit a Form 4 TA Sundry within 30 days of temporarily abandoning the well.
4) A Form 5A, Completed Interval Report, is required to report all plugs downhole which isolate any perforated interval. Submit a Form 5A within 30 days of temporarily abandoning the well.
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| Engineer | Form: (04)
403902822
09/17/2024 | Per well records, the J sand was placed under a sand plug in August 2011. Operator shall correct Form 7 reporting to correctly report TA status for the JSand from 9/2011 onward. Currently the Jsand is reported as SI for large periods since the sand plug was set. |
| OGLA | Form: (06)
404361944
10/02/2025 | COA's provided by the operator as Best Management Practices under Technical Detail / Comments:
Signage for P&As:
Prior to commencing operations, Kerr McGee will post signs in conspicuous locations. The signs will indicate plugging and abandonment operations are being conducted, the well name, well, and the Operator’s contact information. Signs will be placed so as not to create a potential traffic hazard.
Notifications:
Courtesy notifications will be sent to all parcel owners with building units within 1,500 feet of the location letting them know about out plugging and abandonment operations and providing contact information for Kerr McGee's response line and online resources.
Wellbore Pressure:
In some cases, wellbore pressure drawdown operations may occur approximately 1-2 days prior to Move In Rig Up (MIRU) of the workover rig. This is conducted to allow for reduced time that the workover rig is needed on location. These operations will be conducted in accordance with Form 4 and/or Form 6 requirements.
Water:
Water will be placed on dirt access roads to mitigate dust as needed.
Lighting:
Operations are daylight-only; no lighting impacts are anticipated from operations.
Noise:
Operations will be in compliance with Table 423-1 requirements. Based off the rig sound signature, rig orientation will be considered to reduce noise levels to nearby building units.
Environmental Concerns:
This location was reviewed using a desktop method to review publicly available wildlife data (including CPW & ECMC data) as well as internal wildlife datasets and aerial imagery. All field personnel are trained to identify wildlife risks and raise concerns noticed during operations with the KMOG Health, Safety, and Environment (HSE) department. |
| OGLA | Form: (06)
404361944
10/02/2025 | Due to proximity to a wetland, surface water and expected shallow groundwater, 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. |
| Engineer | Form: (06)
404361944
10/02/2025 | 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 (1430') : 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 at 1120' 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 540' 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 cut and prior to cap, verify isolation by either a 15 minute bubble test or 15 minute optical gas imaging recording. 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. |
| Engineer | Form: (06)
404361944
10/02/2025 | 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 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. |
| Engineer | Form: (06)
404361944
10/02/2025 | 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. |
| Engineer | Form: (06)
404361944
10/02/2025 | WITH KNOWN BRADENHEAD PRESSURE
After placing plug at 2200' 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. |
| OGLA | Form: (06)
404361944
10/13/2025 | Per email correspondence on 10/10/25, Operator and CPW have agreed to the following BMPs:
Bald Eagle Nest Buffer .25 / .5: KMOG will not conduct operations between 12/1 – 7/31
Mule Deer Severe Winter Range & Winter Concentration Area: KMOG will not conduct operations between 12/1 -
4/30 |
| Engineer | Form: (06)
404361944
10/13/2025 | 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. |