PERMFILE54123

• Permit No: M1999002
• IBM Index Class Name: Permit File
• Doc Date: 6/18/1999
• Doc Name: OBJECTORS EXHIBITS
• Media Type: D
• Archive: No

After lengthy negotiat~, the Division and AlliedSignal agr~in ]993 to a definition of the
work that would constitute a "reasonable effort" to clean out and plug each well as deeply as possible.
The agreement was crafted based on the practical experience of technical and field staff in the Division
with an intimate working knowledge of field conditions and previous plugging efforts in Tully Valley.
Once this agreement was secured and guidelines developed, AlliedSignal committed to plugging the
remaining wells.
Under terms of the agreement, the objective at each well was to clean the wellbore out to the salt
cavern, remove all uncemented casing and tubing, set a mechanical bridge plug just above the salt
cavern, and fill the wellbore ~~th cement. Guidelines for implementing the agreement recognized that
subsidence-related field conditions, combined with the age of many of the wells, could preclude
attainment of this goal. A "reasonable effort" to plug each well to the deepest attainable depth was
defined as 32 hours of "progress-yielding" dotvrthole time. Thirty-two hours was neither a maximum
nor minimum required effort, but an evaluation point for assessing downhole progress and determining
whether 2dditional work would result in any measurable advancement toward the stated goal. "Progress-
yielding" work for the 32-hour calculation included:
1) working down the hole,
2) cutting and pulling casing,
3) milling obstacles, -•
4) cutting/fishing tubing,
5) tripping associated with progress-yielding work, and
6) running into or out of the hole with: `
- logging tools to estimate dowmhole conditions,
- impression blocks, or
-mills to condition or dress pipe or hole. -
Activities not considered "progress-yielding" downhole time included:
1) rigging up/rigging down,
2) fishing to recover lost tools,
3) logging,
4) perforating,
5) cementing,
6) plugging,
7) activities after reaching the deepest attainable depth,
8) conditioning trip to prepare for cementing, _
9) making up tools and equipment on the surface,
10) running a cement basket or bridge plug, and
11) tripping associated with excluded work.
The 32-hour time frame s+~as based on prior Tully Valley plugging experience, which showed that four
days was generally adequate to clean a wellbore out to the 1,000- to 1,400-foot deep salt cavern when
site-specific do«nhole conditions were such that this could be reasonably accomplished.
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