| Engineer | Form: (06)
403679270
03/07/2024 | 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) ECMC has no record of CBL's. Operator shall provide a CBL to ECMC for verification of plugging orders prior to MIRU. Alternatively, operator may run a new CBL after placing plug at 7198'.
3) After placing plug at 3100’ 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 cement above the base of the Upper Pierre (1615') : 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.
5) 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 544’ or shallower and provide a minimum of 10 sx plug at the surface.
6) Leave at least 100’ of cement in the wellbore for each plug without mechanical isolation.
7) 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.
8) 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)
403679270
03/07/2024 | 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)
403679270
03/07/2024 | 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)
403679270
03/07/2024 | 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.
If there is a need for sampling, contact ECMC engineering for verification of plugging procedure. |
| OGLA | Form: (06)
403679270
03/22/2024 | Due to proximity to mapped wetlands and mapped surface waters, 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. |
| OGLA | Form: (06)
403679270
03/22/2024 | This oil and gas location is within a CPW-mapped bald eagle roost or communal roost Rule 309.e.(1) consultation habitat. CPW may choose to consult on this planned P&A to develop site specific measures to avoid, minimize, and mitigate impacts to wildlife prior to conducting the work. Please note that non-emergency plugging and abandonment (PA) activities should not take place from November 15 to March 15. Please confirm via email if a consultation with CPW has or will occur and provide any operator BMPs that are the result of that consultation. |
| OGLA | Form: (06)
403679270
03/22/2024 | Operator and CPW consulted on the location and operator provided the following commitment:
Operations will be conducted outside the bald eagle roost season (Nov 15 - Mar 15).
CPW agrees with the Operator proposed BMP and has no further concerns. |