| Engineer | Form: (04)
402373864
05/15/2020 | 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)
402567853
02/02/2021 | 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 02/02/2022, 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)
403025398
04/28/2022 | 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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| Engineer | Form: (04)
403089089
07/08/2022 | 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. Prior to starting bradenhead abatement, if a sample has not been collected 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.
3. Bradenhead gas is not to be vented to atmosphere; any gas from the Bradenhead will be routed to an enclosed tank and/or combustor. Operator will implement measures to get an initial estimate of the gas flow rate and/or volume from the bradenhead. The abatement program may be used for six consecutive months.
4. Operator will submit a Form 42 (“OTHER”) stating that “bradenhead abatement program has started.”
5. 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, flow rate information, pressure data and a discussion of the sample analysis.
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| Engineer | Form: (04)
403089089
07/08/2022 | Shut in bradenhead pressure shall not exceed 50 psig. |
| Engineer | Form: (04)
403303701
02/07/2023 | 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. If not plugged by 01/31/2024, 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. Summary of well monitoring and mitigation to be submitted on a Form 4 Sundry after well has been plugged and abandoned. |
| Engineer | Form: (04)
403672177
02/02/2024 | 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. 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 01/31/2025, 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 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 ECMC within three months of collecting the samples.
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| OGLA | Form: (06)
403925947
10/08/2024 | 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.
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| OGLA | Form: (06)
403925947
10/08/2024 | 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. |
| OGLA | Form: (06)
403925947
10/08/2024 | 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.
Notification will be given to any adjacent building unit occupants within a 1000 feet of the wellhead of planned P&A start date.
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. |
| Engineer | Form: (06)
403925947
10/09/2024 | 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 (1140') : 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 AAA’ 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)
403925947
10/09/2024 | 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)
403925947
10/09/2024 | 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)
403925947
10/09/2024 | 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. |