| Engineer | Form: (04 )
402310619
4/29/2020 | 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 )
402568175
2/1/2021 | 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. Bradenhead gas is not to be vented to the atmosphere; any gas from the Bradenhead will be routed to an enclosed tank and/or combustor. 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. Within thirty days of 02/01/2022, conduct a bradenhead test, submit a Form 17, and submit a Form 4 Sundry that summarizes current well condition. The sundry should include details of the future plans, sample analysis interpretation, bradenhead test description, and the flow rate information and pressure data.
4. Shut well in for at least seven days to monitor build up pressures then conduct a new bradenhead test and submit the Form 17 within ten days of the test. |
| Engineer | Form: (04 )
403016955
4/22/2022 | 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. Bradenhead gas is not to be vented to the atmosphere; any gas from the Bradenhead will be routed to an enclosed tank and/or combustor. 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. Within thirty days of 04/15/2023, conduct a bradenhead test, submit a Form 17, and submit a Form 4 Sundry that summarizes current well condition. The sundry should include details of the future plans, sample analysis interpretation, bradenhead test description, and the flow rate information and pressure data.
4. Shut well in for at least seven days to monitor and collect data to characterize build up pressures then conduct a new bradenhead test and submit the Form 17 within ten days of the test.
5. 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 COGCC within three months of collecting the samples. |
| Engineer | Form: (04 )
403391413
5/5/2023 | 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 an enclosed tank and/or combustor. 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. Within thirty days of 05/02/2024, conduct a bradenhead test, submit a Form 17, and submit a Form 4 Sundry that summarizes current well condition. The sundry should include details of the future plans, sample analysis interpretation, bradenhead test description, and the flow rate information and pressure data.
4. Shut well in for at least seven days to monitor and collect data to characterize build up pressures then conduct a new bradenhead test and submit the Form 17 within ten days of the test.
5. If a sample has not been collected from surface casing within the last twelve months collect bradenhead and production 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 COGCC within three months of collecting the samples. |
| Engineer | Form: (04 )
403788565
5/20/2024 | 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 be routed to an enclosed tank and/or combustor. 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 05/31/2025, 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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| OGLA | Form: (06 )
403846709
7/9/2024 | Operator committed to the following Best Management Practices under the Technical Detail/ Comments section on the Submit Tab:
Signage for P&As:
Prior to commencing operations, KMG 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 )
403846709
7/9/2024 | 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 the RBUs nearby and adjacent to the parcel with the well. The sheet will include the operator's contact information and the nature, timing, and expected duration of the P&A operations. |
| OGLA | Form: (06 )
403846709
7/9/2024 | 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 building units (BUs) all blowdown gasses will be controlled.
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| OGLA | Form: (06 )
403846709
7/9/2024 | Due to proximity to a mapped 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.
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| Engineer | Form: (06 )
403846709
7/11/2024 | 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 )
403846709
7/11/2024 | 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 (1945'), operator must wait a sufficient time to confirm static conditions.
3) After placing plug at 1945’ 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 1245’ 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 590’ or shallower and provide at least 10 sx plug at the surface.
6) After surface plug 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.
7) With the Form 6 SRA operator must provide written documentation which positively affirms each COA has been addressed. |
| Engineer | Form: (06 )
403846709
7/11/2024 | 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. |