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In Reply To:
United States Department of the InteriorBUREAU OF LAND
MANAGEMENT
3160
Attn:
Re: Receipt and Acceptability of Application for Permit to Drill
(APD)
Well Name / Number:Legal Description: County, State:Date APD
Received:
Dear Operator:
on . The BLM reviewed the APD package pursuant to part III.B.2
of Onshore Oil and Gas Order No.1 and it is:
1. Incomplete/Deficient (The BLM cannot process the APD until
you submit the identifieditems within 45 calendar days of the date
of this notice or the BLM will return your APD.)
Well Plat Drilling Plan Surface Use Plan of Operations
(SUPO)
Certification of Private Surface Owner Access Agreement
Bonding
Onsite (The BLM has scheduled the onsite to be on )
[Please See Addendum for further clarification of
deficiencies]
This requirement is exempt of the 45-day timeframe to submit
deficiencies. This requirement will be satisfied on the date of the
onsite.
Other
The BLM received your Application for Permit to Drill (APD), for
the referenced well,
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2. Missing Necessary Information (The BLM can start, but cannot
complete the analysisuntil you submit the identified items. This is
an early notice and the BLM will restate this in a 30-day deferral
letter, if you have not submitted the information at that time. You
will have two (2) years from the date of the deferral to submit
this information or the BLM will deny your APD.)
[Please See Addendum for further clarification of
deficiencies]
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NOTE: The BLM will return your APD package to you, unless you
correct all deficiencies identified above (item 1) within 45
calendar days.
The BLM will not refund an APD processing fee or apply it to
another APD for anyreturned APD.
Extension Requests: If you know you will not be able to meet the
45-day timeframe for reasons beyond your
control, you must submit a written request through
email/standard mail for extension prior to the 45th calendar day
from this notice,
The BLM will consider the extension request if you can
demonstrate your diligence(providing reasons and examples of why
the delay is occurring beyond your control) inattempting to correct
the deficiencies and can provide a date by which you will
correctthe deficiencies. If the BLM determines that the request
does not warrant an extension,the BLM will return the APD as
incomplete after the 45 calendar days have elapsed.
o The BLM will determine whether to grant an extension beyond
the required 45calendar days and will document this request in the
well file. If you fail to submitdeficiencies by the date defined in
the extension request, the BLM will return theAPD.
APDs remaining Incomplete: If the APD is still not complete, the
BLM will notify you and allow 10 additional
business days to submit a written request to the BLM for an
extension. The request must describe how you will address all
outstanding deficiencies and the timeframe you request to complete
the deficiencies.
o The BLM will consider the extension request if you can prove
your diligence(providing reasons and examples of why the delay is
occurring) in attempting tocorrect the deficiencies and you can
provide a date by which you will correct thedeficiencies. If the
BLM determines that the request does not warrant anadditional
extension, the BLM will return the APD as incomplete.
If you have any questions, please contact
Sincerely,
cc:
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ADDENDUM - Incomplete/Deficient Clarifications
ADDENDUM - Deficient Adjudication Comments Legal Description
Deficiency/Deficiencies: - Production zone entry point(s) submitted
is conflicting or incorrect. Surface Comments - Location and Type
of Water Supply Deficiency: Discuss Water Supply options in greater
detail. Per OO#1 describe potential source and route, i.e.
municipal water from Wright, Wyoming, trucked on roads approved for
Habanero-Serrano POD. Any proposed above ground pipelines from
potential water sources will be submitted via Sundry Notice for
approval. 2/28/17 Corrected, detail on options provided. Sundry
required for above ground pipelines; potential route would need
cultural clearance. - Plans for Surface Reclamation Deficiency: 1.
Interim Reclamation must be completed within 6 months of well
completion. On page 9 of 19 on SUPO Data Report, under
Reconstruction Method, one year is stated for interim reclamation.
Text in attached SUPO, Interim Reclamation, is correct (6 Months).
Correct page 9 of the SUPO Data Report. 2/28/17 Corrected in SUPO.
2. Provide statement that Operator will drill the multiple wells on
pad sequentially; and that interim reclamation will be accomplished
on pad within 6 months of well completion, even if remaining
approved Habanero-Serrano PODs APDs have not been drilled to date.
Modification to this time line may be approved by the BLM
authorized officer. 2/28/17 Statement has been provided in SUPO.
Corrected. - Surface ownership Deficiency: Certify that a Surface
Use Agreement has been reached with WI Moore, or submit a Bond
number. 2/28/17 Operator certifies that Surface Use Agreement has
been reached with WI Moore. - SUPO Review: Other submitted
information are inadequate and/or incomplete 1. Certify that a
Water Well Agreement has been offered to surface owners with
permitted water wells within 1/2 mile of proposed wells. 2/28/2017
This deficiency has been retracted by BFO. Management Team reviewed
and decided that requirement is specific to Coal Bed Methane wells
and not applicable to deep oil wells. 2. Provide an Integrated Pest
Management Plan. SUPO states that Operator will submit one at a
future date. Include all information provided on page 12 of 19,
SUPO Data Report, on weed treatment plan description, monitoring
plan description, and success standards. 2/28/17 Corrected and all
information provided in Plan. 3. BLM Civil Engineer has not yet
reviewed Engineered Plats for Option 2 Access Road. Therefore there
may be additional deficiencies under item for "New and
Reconstructed Roads" once that review is complete, resulting in a
second Post Onsite Deficiency Letter. 2/28/17 Engineering
Deficiencies have been addressed: existing culvert replaced with
18" culvert (see sheet 3 of 20 of revised plat package); ADT
provided in Section 2.p of revised SUPO; Acceptable Site specific
soils data is provided in Section 2.o of revised SUPO; curve has
been widened into existing Y intersection for Option 1 (sheet 10 of
20). The Section 34 road at the Y-intersection is designed with a
24' travelway width and 75' centerline radius. The curve widening
consists of a 10'
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ADDENDUM - Incomplete/Deficient Clarifications
turnout transitioning into a 30' turnout, then back to 10'
before returning to the original roadway width. the overall curve
length of the widened section is 235', increasing turn radius and
sight distance. Engineering Comments - BOP requirements are not met
1. The choke diagram was not attached. BWM: Corrected on 3/1/2017 -
Casing design information is inadequate and/or incomplete 1. For
the production liner, the information entered in the A2 system
shows it to be LTC while the attached drilling plan shows it to be
BTC. Also, the casing design for the liner is using load ratings
for BTC in the tensile design. STILL DEFICIENT - Cementing design
information is inadequate and/or incomplete 1. The Top MD and
Bottom MD for the cement segments is entered incorrectly for the
lead and tail cements. These values should reflect the proposed
tops and bottoms for each segment. BWM: Corrected on 3/1/2017 2.
The information entered in the A2 system indicates that the
intermediate casing will be cemented from 12,302' back to the
surface; however, the proposed cement volumes would not be able to
cover that entire interval. Since the Lance is identified as having
usable water, the intermediate casing will need to be cemented to
at least 100' above the top of the Lance Formation. BWM: Corrected
on 3/1/2017 - Engineering Review: Other identified drilling plan
deficiencies 1. While not technically a deficiency, any
non-municipal water sources that are planned to be used for
cementing MUST have a water quality analysis submitted to the BLM
prior to APD approval. ADDENDUM - Incomplete or Necessary
Information Adjudication Comments - Adjudicator additional
information: 1. Surface bond for landowner for the WI Moore Ranch
Company will need to be submitted prior to approval of this APD.
The bond WYB001610 is not applicable as a surface bond it only
covers oil and gas operations. Corrected 3/1/2017 LEM 2. Add to
Section 3 - Well Location Table - a PPP for "Fee" SWSW Sec 24 and
rest of well information. Corrected 3/1/2017 LEM Surface Comments -
SUPO Review: APD additional necessary information are inadequate
and/or incomplete Cultural Requirements: 1. Please send three
copies of the final report to BLM Buffalo Field Office (one for
BFO, one for CFO, and one for WY-SHPO).
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ADDENDUM - Incomplete/Deficient Clarifications
2. DBI cover page: Under Inventory Method, Protocol, please
select the appropriate linear survey width rather than class III.
Use the class III option for block inventory only. 3. VCR forms:
Please attach the appropriate photos to the VCR forms. 4. Project
map: Per the BLM Wyoming Standard Permit Conditions, Part
III-Fieldwork and Reporting(u): Permittee will insure that all
cover pages of reports and accompanying maps contain the following
statement in large font, bold type: For Official Use Only:
Disclosure of site locations prohibited (43 CFR 7.18). Please add
this statement to the project map. Note: There will be a 15day
formal SHPO consultation for the no adverse effect to the Bozeman
Trail before approval of these APDs. 2/28/17 Corrected. There will
be a 15 day formal SHPO consultation for the no adverse effects to
Bozeman Trail before approval of APDs.
Blank Page
onsiteDate: extensionDate: 04/16/2017.pocName: Debby Green at
(307) 684-1058.chkIncomplete: chkWellPlat: chkDrillPlan:
chkSurfPOP: chkCertSurfOwner: chkOnsite: officeName: BUFFALO FIELD
OFFICEofficeStreet: 1425 FORT STREETofficeCityStateZip: BUFFALO, WY
82834leaseNum1: [ WYW145575 ]attnClient: BRADY LEWIScompanyAddress:
1200 17TH STREET, SUITE 2200companyName: LIBERTY RESOURCES
MANAGEMENT COMPANY LLCcompanyCityStateZip: DENVER, CO
80202currentDate: 03/02/2017wellNum: SERRANO W 4175-24-13-2FH /
4legalDesc: T41N, R75W, SEC 25, NWNWsiteCountyState: CAMPBELL,
WYapdReceivedDate: 12/23/2016url:
[email protected]: 12/23/2016chkMissingInfo:
chkBonding: signature1: Jim Verplanckesignature2: Supervisory
Natural Resources Specialistsignature3: signature4: signature5:
ccAgencyTribeService1: ccAgencyTribeService2:
ccAgencyTribeService3: chkMissingOther: fedIndLeaseNum: FEDERAL -
WYW145575
