| Engineer | Form: (06)
402246622
12/02/2019 | Bradenhead Testing
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 COGCC within three (3) months of collecting the samples.
If there is a need for sampling, contact COGCC engineering for verification of plugging procedure.
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| Engineer | Form: (06)
402246622
12/02/2019 | Plugging
1) Provide 48 hour notice of plugging MIRU via electronic Form 42.
2) 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.
3) Plugs and squeezes will be placed as stated in the Plugging Procedure section of the approved NOIA unless revised by COA or prior approval from COGCC is obtained.
4) The wellbore must be static prior to placing cement plugs which are to be a minimum of 100' in length for all but surface plugs. Mechanical isolation requires a 25' cement plug, minimum.
5) Place a 50' plug (minimum) at the surface, both inside the inner most casing and in all annular spaces. Confirm cement to surface in all strings during cut and cap.
6) With the Form 6 SRA operator must provide written documentation which positively affirms each COA has been addressed.
7) Contact area inspector prior to commencing plugging operations.
8) No current Form 17 on file with COGCC. Contact COGCC area engineer with results of pre-plugging bradenhead test for confirmation of plugging procedure prior to commencing plugging operations.
9) Due to no pre-plugging Form 17, wait 8 hours after pumping plug at 2500-2300’, in order to assure that there is no pressure or flow before proceeding with plugging procedure, additional plugs may be necessary to shut off pressure or flow prior to isloating the surface shoe. Contact COGCC Area Engineer if well is not static prior to placing any subsequent plugs.
10) After placing the shallowest hydrocarbon isolating plug (2500-2300'), operator must wait a sufficient time on all subsequent plugs to confirm static conditions. If at any time after placing this plug there is evidence of pressure or of fluid migration, contact COGCC engineering before continuing operations.
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| Engineer | Form: (06)
402246622
12/02/2019 | 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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| Engineer | Form: (04)
402308870
07/08/2020 | 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. This mitigation plan may be used for six consecutive months from the planned start date reported on the Form 4. ( 08/17/2020)
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. |
| Engineer | Form: (04)
402476054
10/15/2020 | Samples submitted.
Subsequent 17 submitted.
Follow up sundry has pressure data.
Enforcement review: No flow rate estimate.
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| OGLA | Form: (06)
403287850
01/23/2023 | 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)
403287850
01/26/2023 | 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 COGCC within three (3) months of collecting the samples. |
| Engineer | Form: (06)
403287850
01/26/2023 | 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)
403287850
01/26/2023 | 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 405.e and 405.I.
2) Prior to placing the 775’ plug: verify that all fluid migration (liquid and gas) has been eliminated. If evidence of fluid migration or pressure remains, contact COGCC Engineer for an update to plugging orders.
3) After isolation has been verified, pump surface casing shoe plug. If cement is not circulated to surface, shut-in, WOC 4 hours then tag plug – must be at 625’ or shallower and provide 10 sx plug at the surface.
4) Leave at least 100’ of cement in the wellbore for each plug without mechanical isolation.
5) With the Form 6 SRA operator must provide written documentation which positively affirms each COA listed above has been addressed. |
| Engineer | Form: (06)
403287850
01/26/2023 | 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 COGCC Spill/Release Report, Form 19, associated with the abandoned line. |