| Engineer | Form: (02) 400563126 01/26/2015 | 1) Operator shall comply with the most current revision of the Northwest Notification Policy. See attached notice.
2) Operator shall comply with the most current revision of the Garfield County Rulison Field Notice to Operators, with the following exception: All field notice requirements specified in that Notice to Operators are superseded by the requirements of the most current revision of the Northwest Colorado Notification Policy (see Condition of Approval #1). See attached notice.
3) Operator shall provide cement coverage from the intermediate casing shoe (7+5/8" first string) to a minimum of 200' above all Mesa Verde Group (and Ohio Creek Formation, if present) oil, gas, and water-bearing sandstone and coalbed formations. Verify intermediate casing cement coverage with a cement bond log. |
| OGLA | Form: (04) 400821393 05/13/2015 | The following COAs provide procedures and requirements that may already be reflected in the operator's submitted BMPs for the use of oil-based drilling mud for the curve and lateral portions of the wellbores at this location. If there are any questions about the COAs, contact Dave Kubeczko at 970-309-2514 or email at dave.kubeczko@state.co.us.
A closed loop system must be implemented during drilling. All cuttings generated during drilling with oil based mud (OBM) must be kept in tanks/containers, or placed on a lined/bermed portion of the well pad; prior to disposition. The moisture content of any OBM-generated drill cuttings in tanks/containers, or in a cuttings containment area or pile, shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts. At the time of closure, if the drill cuttings are to be left onsite, they must also meet the applicable standards of Table 910-1. Representative cuttings samples will be analyzed for all Table 910-1 constituents. Any material which does not meet Table 910-1 criteria will either be manifested and disposed offsite at the facility identified by the operator, or amended further onsite to comply with Table 910-1. If operator determines that long-term onsite management of oil based mud cuttings is necessary, an approved Form 27 remediation plan will be required. Any liners associated with oil based drilling mud and cuttings must be disposed of offsite per CDPHE rules and regulations.
The moisture content of water/bentonite based mud (WBM) generated drill cuttings managed onsite shall be kept as low as practicable to prevent accumulation of liquids greater than de minimis amounts. After drilling and completion operations have been completed, the WBM drill cuttings that will remain on the well pad location (cuttings management area, the cut portion of the pad, cuttings trench, dry cuttings drilling pit), must meet the applicable standards of Table 910-1. After the drill cuttings have been amended (if necessary) and placed on the well pad, sampling frequency of the drill cuttings (to be determined by the operator) shall be representative of the material left on location. No offsite disposal of cuttings to another oil and gas location shall occur without prior approval of a Waste Management Plan (submitted via a Form 4 Sundry Notice) specifying disposal location and waste characterization method. Commercial disposal of drill cuttings will only require notification to COGCC via a Form 4 Sundry Notice. |
| Engineer | Form: (04) 401620628 05/01/2018 | 1)Temporary venting to maintain the bradenhead pressure below 0.25 times the surface casing setting depth (TVD) in psi is approved during an evaluation period not to exceed one month. Provide a remediation plan with concurrence from the BLM on a Sundry Notice Form 4 by June 1, 2018. |
| Engineer | Form: (04) 401654912 05/31/2018 | 1)Venting to maintain the bradenhead pressure below 0.25 times the surface casing setting depth (TVD) in psi is approved. Perform annual Bradenhead tests reported on a Form 17 and an annual update sundry with the duration of venting or number of times the annulus was vented.
2)COGCC staff encourages the use of a combustor for vented bradenhead gas when feasible without the use of supplemental fuel for the combustor. An enclosed flare shall be used, unless an open flare is specifically allowed by Colorado Department of Public Health and Environment (CDPHE) Regulation 7.
3)Comply with any CDPHE, Air Pollution Control Division rules or requirements for all atmospheric discharges.
4)Any liquids blown down are to be collected, stored, handled, and treated or disposed as E&P waste per COGCC’s 900 series rules.
5)Annular spaces may be tied to low pressure sales lines with COGCC engineering approval on a Sundry Notice, Form 4, describing equipment configuration, proper pressure regulation and check valves. At least one check valve is required for annular spaces that are tied to sales. Maintain equipment for pressure regulation and check valves in good working order.
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