| Engineer | Form: (06 )
403891507
8/26/2024 | 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) Prior to placing cement above the base of the Upper Pierre (1295') : 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 542’ 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 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 )
403891507
8/26/2024 | 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 )
403891507
8/26/2024 | 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 )
403891507
8/26/2024 | 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 )
403891507
8/29/2024 | 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, 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 )
403891507
8/29/2024 | 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 residential building units (RBUs) all blowdown gasses will be controlled.
Due to proximity of plugging and abandonment (P&A) operations to BUs, operator will comply with Table 423 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.
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. |