BEFORE THE OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO
IN THE MATTER OF THE ESTABLISHMENT OF A BRADENHEAD MONITORING AREA IN THE RULISON, MAM CREEK AND BUZZARD FIELDS, GARFIELD AND  MESA COUNTIES, COLORADO	) ) ) )	CAUSE NO.   1, 139, 191 and 369 ORDER NO.   1-107,  139-56,                  191-22 and 369-2

REPORT OF THE COMMISSION

                        This cause came on for hearing before the Commission at 9:00 a.m. on September 20, 2004 in Suite 801, 1120 Lincoln Street, Denver, Colorado for an order to establish a bradenhead monitoring area for wells drilled in Townships 6 through 9 South, Ranges 91 through 93 West, 6^th P.M.

FINDINGS

                        The Commission finds as follows:

            1.  Due notice of the time, place and purpose of the hearing has been given in all respects as required by law.

                        2.  The Commission has jurisdiction over the subject matter embraced in said Notice, and of the oil and gas operators affected by this matter, and jurisdiction to promulgate the hereinafter prescribed order.

3.  Rule 207.b. of the Rules and Regulations of the Colorado Oil and Gas Conservation Commission (“COGCC”) gives the Director the authority to designate specific fields or portions of fields as bradenhead test areas within which, on any well, the bradenhead access to the annulus between the production and surface casing, as well as any intermediate casing, shall be equipped with fittings to allow safe and convenient determinations of pressure and fluid flow.  Any such proposed designation shall occur by notice describing the proposed bradenhead test area.

4.  On or around August 25, 2004, Notice of Hearing was sent to all oil and gas operators with wells located in Townships 6 through 9 South, Ranges 91 through 93 West, 6^th P.M., proposing the establishment of a bradenhead monitoring area.

5.  No protests to the proposed bradenhead testing and reporting requirements were filed with the Commission and the proposal was placed on the Commission’s consent agenda for adoption at its September 20, 2004 hearing.

ORDER

NOW THEREFORE IT IS ORDERED, that a bradenhead monitoring area is hereby established for Townships 6 through 9 South, Ranges 91 through 93 West, 6^th P.M.

IT IS FURTHER ORDERED, that by November 1, 2004, the following bradenhead testing and reporting requirements shall be performed on all wells in the above-described lands as follows:

a.  Upon completion of any well, and on wells presently completed, the operator shall equip the bradenhead access to the annulus between the production and surface casing, as well as any intermediate casing, to above ground level with approved fittings to allow safe and convenient determination of pressure and fluid flow.  This rule shall apply to all wells in the field.  The operator shall test all wells for pressure and flow on an annual basis, with results submitted to COGCC no later than November 1 of each calendar year.

b.  Operators shall notify COGCC staff a minimum of ten (10) days prior to monitoring to allow COGCC staff to witness testing on a random basis.  Remedial requirements and additional subsequent monitoring will be determined based on the results of the annual tests.

c.  The test shall be performed by verifying the tubing and casing pressures and flow characteristics of the well.  A pressure gauge with a range of one thousand (1000) psig shall be used to measure the bradenhead (surface and intermediate casing) pressure(s).

d.  The results of the annual bradenhead test for pressure and flow for each well shall be provided to the COGCC Northwest Area Engineer electronically in the form of an Excel Spreadsheet containing the information and format as shown in the attached example.

e.  If bradenhead pressures greater than one hundred fifty (150) psig are observed or a continuous flow of liquid at any pressure, such conditions and pressures shall be immediately reported to the COGCC Northwest Area Engineer.  A Bradenhead Test Report, Form 17 and a Sundry Notice, Form 4 containing the bradenhead monitoring results and proposed remediation procedure shall be submitted electronically to the COGCC Northwest Area Engineer within seven (7) days of the report.

            The Northwest Colorado Area Engineer is Jaime Adkins

            Office telephone (970) 285-9000/Cell telephone (970) 250-2440

            E-mail:   jaime.adkins@state.co.us

                        IT IS FURTHER ORDERED, that the provisions contained in the above order shall become effective forthwith.

                        IT IS FURTHER ORDERED, that the Commission expressly reserves its right, after notice and hearing, to alter, amend or repeal any and/or all of the above orders.

                        IT IS FURTHER ORDERED, that under the State Administrative Procedure Act the Commission considers this order to be final agency action for purposes of judicial review within thirty (30) days after the date this order is mailed by the Commission.

IT IS FURTHER ORDERED, that an application for reconsideration by the Commission of this order is not required prior to the filing for judicial review.

ENTERED this  day of October, 2004, as of September 20, 2004.

                                             IN THE NAME OF THE STATE OF COLORADO

                                                                        OIL AND GAS CONSERVATION COMMISSION

                                                                               OF THE STATE OF COLORADO

                                                                        By

                                                                                         Patricia C. Beaver, Secretary

Dated at Suite 801

1120 Lincoln Street

Denver, CO  80203

October 1, 2004