| OGLA | Form: (06 )
403918387
9/19/2024 | Due to proximity to a wetland 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. |
| Engineer | Form: (06 )
403918387
9/20/2024 | 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 (2800') : 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 at 670' 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 135' 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 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.
6) With the Form 6 SRA operator must provide written documentation which positively affirms each COA listed above has been addressed. |
| Engineer | Form: (06 )
403918387
9/20/2024 | 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 )
403918387
9/20/2024 | 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. |
| Engineer | Form: (06 )
403918387
9/20/2024 | Verify existing cement coverage by CBL - submit to ECMC for verification of plugging orders prior to continuing plugging operations. |