Code of Colorado Regulations
400 - Department of Natural Resources
404 - Oil and Gas Conservation Commission
2 CCR 404-1 - PRACTICE AND PROCEDURE
Section 419 - BRADENHEAD MONITORING, TESTING, AND REPORTING

Universal Citation: 2 CO Code Regs 404-1 ยง 419

Current through Register Vol. 47, No. 17, September 10, 2024

a. Equipment Requirements.

(1) The Operator will equip Bradenhead access on all Wells to the Annulus between the production and surface casing as well as any intermediate casing with appropriate fittings to allow safe and convenient determination of pressure and Fluid flow.

(2) To allow for Commission visual inspection at all times, all valves used for annular pressure monitoring will remain exposed and will not be buried. An Operator may use a rigid housing to protect the valves so long as the housing can be easily opened or removed by the Operator upon request.

(3) These equipment requirements apply to all Wells, regardless of function.

b. Bradenhead Monitoring. The Operator will monitor all Wells at a Director-indicated frequency for aspects of Well integrity necessary to protect and minimize adverse impacts to public health, safety, welfare, the environment, and wildlife resources, including Groundwater, Potential Flow Zones, and formations and pursuant to this Rule 419.

(1) After Rig Release, Prior to Stimulation. An Operator will monitor all annular casing pressures on a monthly basis. If at any point the Bradenhead monitoring pressure is greater than 30% of the TVD in feet of the surface casing shoe expressed in psig, the Operator will contact the Director before proceeding with Stimulation to determine whether mitigation or other measures are necessary to ensure isolation consistent with the Commission's Rules.

(2) During Hydraulic Fracturing Treatment.
A. An Operator will confine the placement of all Stimulation fluids to the objective formations during Hydraulic Fracturing Treatment to the extent practicable.

B. During Hydraulic Fracturing Treatment operations, an Operator will continuously monitor and record Bradenhead Annulus pressure on all Wells being Stimulated.

C. If intermediate casing has been set on the Well Stimulated by Hydraulic Fracturing Treatment, an Operator will monitor and record the pressure in the Annulus between the intermediate casing and the production casing during Stimulation operations.

D. During Hydraulic Fracturing Treatment operations, an Operator will monitor the Bradenhead Annulus and casing pressures for all Wells within 300 feet of the wellbore being Stimulated.

E. If at any time during Hydraulic Fracturing Treatment operations, the Bradenhead Annulus pressure in psig in the Well being Stimulated or any Well being monitored has a Bradenhead pressure exceeding 30% of the TVD in feet of the surface casing shoe expressed in psig, or the Operator has reason to suspect any potential failure of the production casing or Stimulation string, the Operator will:
i. Safely and quickly discontinue the Stimulation and dissipate the annular pressure.

ii. Notify the Director as soon as practicable but no later than 24 hours following the occurrence with a Form 42 - Notice of High Bradenhead Pressure During Stimulation.

iii. Perform diagnostic testing on the Well and related equipment as is necessary to determine:
(i) whether such a failure has actually occurred;

(ii) if the pressure observations can be accounted for due to thermal expansion or pressure "ballooning" of the casing; or

(iii) the presence or absence of a downhole failure or whether a migration pathway has actually occurred. The Operator will perform diagnostic testing as soon as is reasonably practical after Operator has reasonable cause to know of or suspect any such failure.
aa. If the Operator does not identify a downhole failure or a migration pathway, the Operator will notify the Director of the results. The Director will timely grant approval to proceed with stimulation and may do so orally.

bb. If the Operator identifies a downhole failure or migration pathway, the Operator will consult with the Director and, upon request, provide and implement a corrective plan prior to continuing any further Stimulation operations on the Well and any additional Well on the Oil and Gas Location.

iv. Submit a Form 4, providing all details, including whether a downhole failure or migration pathway occurred, cause of the high pressure or suspected failure, and corrective measures taken within 15 days after the occurrence.

(3) Thirty Days After Hydraulic Fracturing Treatment. For the first 30 days after Hydraulic Fracturing Treatment or completion, an Operator will monitor and record production casing pressure and all annular casing pressures for a Well on a daily basis, at a minimum.

(4) Through the Remaining Life of the Well. For all Wells in the state, an Operator will monitor and record production casing pressure and all annular casing pressures on a monthly basis or at a Director-approved frequency. If a Well's Bradenhead pressure is greater than 30% of the TVD in feet of the surface casing shoe expressed in psig, or a lower threshold set by a Commission order, or if a Well flows liquids or continuous gas from the Bradenhead Annulus, an Operator will:
A. Report the Bradenhead pressure to the Director on a Form 17, Bradenhead Test Report;

B. Take immediate action to remedy such an annular pressure; and

C. Perform diagnostic testing to determine if the annular casing pressure is sustained. An Operator will report diagnostic testing results to the Director on a Form 4 within 60 days of submitting a Form 17 pursuant to Rule 419.b.(4).A. If the diagnostic testing confirms sustained casing pressure, an Operator will develop and implement a pressure management plan and provide the plan with the Form 4.

(5) Records. An Operator will keep Bradenhead monitoring records required by Rule 419.b available for inspection by the Director for a minimum of 5 years after the monitoring was performed.

c. Annual Bradenhead Testing and Reporting. For all Wells other than coalbed methane Wells, an Operator will perform an annual Bradenhead test and submit the data to the Director on a Form 17 or other Director-approved method. For coalbed methane Wells, an Operator will perform Bradenhead testing pursuant to Rule 614.e.

d. Bradenhead Test Observations.

(1) If an Operator observes a deficiency, the Operator will immediately take action to address the deficiency. Actions taken may include the Operator performing diagnostic testing on the Well to determine whether a deficiency does exist and the best method of repair or if a pressure management plan is needed.

(2) The Director may impose a remediation plan if a deficiency exists, and if imposed, the Operator will implement an approved remediation plan or pressure management plan and report results within 30 days or as required by the approved plan.

(3) If the Operator is not able to effectively address the deficiency or implement a pressure management plan, the Operator will Plug and Abandon the Well within 6 months of discovering the deficiency.

Disclaimer: These regulations may not be the most recent version. Colorado may have more current or accurate information. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or the information linked to on the state site. Please check official sources.
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