The Office of Oil and Gas; Oil and Gas Wells

West Virginia Department of Environmental Protection

Chapter §22 Article 1, Article 6 and Article 6A Office of Oil and Gas
Chapter §22C Article 9 Oil and Gas Conservation

WELL SITE SAFETY PLANS

and Collision Avoidance Protocol
• Deep Well Policy Statement
• Natural Gas Horizontal Well
Control Act §22-6A
West Virginia
Oct 7th, 2015
 Site Safety Plans
• Prevention measures

• Protection procedures

• Action protocols necessary

 Well Site Safety Plans

 Authority requirements by:

• Deep Well Policy Statement
• Natural Gas Horizontal Well Control Act
§22-6A
• Deep Well Policy Statement by the
 Office of Oil and Gas
 Oil and Gas Conservation Commission
Agreement Policy REVISED - October 22nd, 2012 [ doc1 ]
Requires Site Safety Plans -
ALL - DEEP PERMITTED WELLS
 Site specific Safety Plan must be submitted
with each deep well application . . .
which cover and include -
 Deep Well Drilling Procedures and
the Site Safety Plan Requirements
• §22-6A Well Site Safety Plans
Submit with each well permit application
 Applies to any natural gas well drilled using a
horizontal drilling method provided . . .
 Well site disturbance of three acres or more
of surface
 Utilizes more than two hundred ten thousand
gallons of water in any thirty day period
 Address measures to be employed by the operator
 Protection of persons on the site, as well as the
general public and the environment.
• §22-6A Well Site Safety Plans
Site Safety Plans are promulgated by . . .

§35-8- Rules Governing Horizontal Well

Development (Legislative Rule)
sec. 1.1. Scope. -- This rule shall govern and apply to
proceedings under W. Va. Code §22-6A-1, et seq.,
related to horizontal wells. Certain portions of this
rule also govern and apply to W. Va. Code § 22-12-1,
et seq., related to groundwater protection.

1.2. Authority. -- W. Va. Code §§ 22-1-3 and 22-6A-6(a)(4).

1.3. Filing Date. -- April 21, 2014

1.4. Effective Date. -- June 1, 2014

• §35-8-5.7 Well Site Safety Plan
Emphasis and Scope necessities . . .

 Encompass all aspects of the operations

 actual well work during
drilling, completion ,
and production activities
 Provide emergency point of contact
 Provide copy to the *LEPC at least 7 days
prior to well work or site construction
*WV HSEM Information
1(304)558-5380
 Well Site Safety Plan Standards
General Summary of Criteria Needs
– Siting: site descriptions, topographic view
– LEPC emergency planning and ER familiarizations
– Safety meetings, contacts, evacuations
– MSDS availability and where
– Well bore program, casing/cementing
– Strata incl. abnormal expectations
– Well control & BOP equipment
– Testing measures and schedules, training
– Well flaring operations & kill procedures
– H2S operations and handling
– Wellbore collision avoidance protocols
– Notification method and protection zones
 Preamble to Site Safety Plans
§35-8-5.7.a. Rules Governing Horizontal Development
– All well applications shall be accompanied by a well site safety plan (SSP)
– SSP shall address proper safety measures employed to protect:
 The Persons on the well site, and
 The General Public in the area surrounding the well site
– Each SSP shall be specific to the well site and the surrounding area as described
in the well permit application
– SSP shall encompass all aspects of the operation including:
 Actual well work for which the permit is sought
 Anticipated MSDS Sheets, and
 Drilling, completion, production, and work-over activities
– SSP shall be made available on the well site during all phases of the operation
– SSP provides an emergency point of contact and twenty-four (24) hour contact
information for the well operator
– SSP copy shall be provided to the County LEPC at least seven (7) days prior to
well work or site/land disturbance
– SSP shall be provided to the surface owner and any water purveyor or surface
owner subject to notice and water testing as provided in section 15 of this rule
– The Operator should work closely with the local responders to familiarize
them with potential incidents that are related to oil and gas development, so
that the local first responders have the information they need to provide the
support necessary for the operator to implement the well site safety plan.
 Site Safety Plan - OUTLINE
Descriptive Availability On-line [ doc2 ]
• Site Safety Plan Table of Contents . . .
1. Contacts, Schedules, ER coordination, and Meetings
2. Maps and Diagrams
3. Well Work Descriptions
4. Chemical Inventory & MSDS
5. BOP and Well Control
6. Hydrogen Sulfide (H2S)
7. Flaring
8. Collision Avoidance Safeguards, Practices and Standards
9. Deep Well Additional Requirements (Deep Well Distinction)
10. Deep Vertical Well Requirements per Policy Statement*
*selections are needed from the above contents
 Collision Avoidance Protocol
Plans and Outline*
Descriptive Availability On-line [ doc3 ]
Established minimums are in pursuance to:
§35-8-5.7.c.7. Rules Horizontal Development
A protocol and established safeguards
designed to prevent underground collisions
during any drilling on multi-well pads.

* Table of Contents . . .
Introduction – Purpose and Scope
A. Established definitions
B. Established descriptions of risk
C. Plan components
 Preamble to Collision Avoidance
Safeguards, Practices and Standards Plan
Introduction and Recognition - Purpose and Scope
 Measures keeping wellbores separated and HSE restrained
 Recognizes survey accuracy and the survey maintenance
 Shall be well specific to the proposed wellbore
 Shall address all items within the contents outlined
 Shall provide survey designs throughout the proposed
wellbore including the QC / QA activities and the counter-
actions necessary
 Minimum separation factors and standards apply
 Shall include proposed counter-actions necessary if a
collision occurs or if surveys observe an imminent risk for a
collision
 All wellbore collisions shall be treated as high-risk events
 Approved plans are conditions and terms of the well permit
and any modifications are subject to approval
 Collision Avoidance Safeguards,
Practices and Standards Plans
A. Established definitions:
 Proposed Wellbore - vertical top-hole, the curve, and the lateral.
 Nudging – intentional well path diverted (generally in vertical section)
 KOP - kick off Point. Diverting a well path one trajectory to another
 MWD – Measurement While Drilling.
 LWD – Logging While Drilling.
 SF – Separation Factor or Clearance Factor:
 SF* = CC ÷ [ URref + URoff ] Collision Avoidance Calculation
*R Type Rule Common Practice – Recognized by ISCWSA
The Industry Steering Committee on Wellbore Survey Accuracy
 CC - well separation distance (center to center of wellbores)
 URref - radius ellipse of uncertainty on reference well
 URoff - radius ellipse of uncertainty on offset well
 Calculation options may be considered
 TMD – Total Measured Depth.
 Gyro – High accuracy well bore survey instrument unaffected by
magnetic interference.
 QC / QA – Quality Control and Quality Assurance.
 HSE – Health Safety and the Environment.
 Collision Avoidance Safeguards,
Practices and Standards Plans

B. Established collision risks:

SF ≤ 1.0 Level 1 Extreme risk
SF = 1.0 to 1.5 Level 2 High risk
SF = 1.5 to 2.0 Level 3 Moderate risk
SF > 2.0 Level 4 Low to no risk
 Collision Avoidance Safeguards,
Practices and Standards Plans
C. Plan components:
1) Describe the scope of work and the type of survey
techniques by use of gyros, MWD, LWD, or others and
include the following:
a) The survey intervals or frequencies proposed as
adjustments to address each level of risk covering the
vertical top-hole section of the proposed wellbore.
b) Provide TOOL ALIGNMENT and MULESHOE procedures**
when drilling in critical areas covering the vertical top-
hole section of the proposed wellbore. These
procedures are visual verification for alignment and
orientation QC/QA purposes. Provide the responsible
personnel (minimum two representatives) and their
titles of those involved for QC/QA purposes during the
drilling activities. **Provide other orientations or survey
methods and procedures if utilized.
 Collision Avoidance Safeguards,
Practices and Standards Plans
C. Plan components: (cont.)
1) (Cont.) Describe the scope of work and the type of survey
techniques by use of gyros, MWD, LWD, or others and
include the following:

c) Description of any nudge activity proposed in the vertical top-

hole section.
d) The survey tools to be utilized from the KOP to the lateral
landing and the lateral section to the TMD.
e) Description of any software utilized for the directional and
anti-collision planning proposed. (Rule Type Policy utilized)
 Collision Avoidance Safeguards,
Practices and Standards Plans
C. Plan components: (cont.)
2) The following shall be addressed in the plan for the
proposed wellbore:
a) Vertical top-hole section beginning at the surface and to the
lateral landing –
i. Minimum SF standards (thresholds) required - SF ≥ 1.5
shall be obtained early as practical and maintained.
(Indicate the frequency of survey intervals proposed)
ii. Minimum SF standards (thresholds) required - SF ≥ 2.0***
applies when in proximity to any fractured or any
producing well that exists on the well pad. (Indicate the
frequency of survey intervals proposed) ***Risk
management and technological mitigations, i.e. downhole
plugs, are critical and should be considered along with
other safety measures necessary. The OOG may require
additional safety measures of a specific well application
for permitting as deemed necessary.
 Collision Avoidance Safeguards,
Practices and Standards Plans
C. Plan components: (cont.)
2) (Cont.) The following shall be addressed in the plan for the
proposed wellbore:
b) Lateral section beginning at the lateral landing and
to the TMD -
i. Provide a general protocol to declination, grid correction,
and magnetic interference correction during the drilling
of the proposed lateral. Also provide the responsible
personnel (minimum two representatives) and their titles
of those involved for QC/QA purposes during the drilling
activities.
ii. For any existing horizontal or vertical wells found
adjacent to this lateral section, provide the protocols for
separation safeguards and the spacing planned during the
drilling of this section. A reconnaissance review is
required for each proposed lateral; OOG may establish a
minimum footage for review as deemed necessary.
 Collision Avoidance Safeguards,
Practices and Standards Plans
C. Plan components: (cont.)
3) Provide a well pad surface diagram depicting the wellhead
arrangement (API labeled) of all existing wells adjacent to the
proposed wellbore. Indicate the surface footage separation
between wellheads and each wellbore status.
4) Describe the gyro surveying or other type surveying conducted
within each existing wellbore located on the pad.
5) Provide descriptive actions if a collision should occur or if surveys
should observe imminent risk for a collision.
6) Provide method to notify the OOG Oil and Gas Inspector
immediately of any underground collision or if the SF Level 1 is
determined within the extreme collision risk zone (ellipses of
uncertainty overlap).
7) Provide other supportive resources or proposed safety measures
as needed.
 Flaring Operations
Please contact the
Division of Air Quality* WVDAQ
WVDEP

*New Source Review Permitting

Phone: 304 926 0475 • Fax: 304 926 0479
 • In Conclusion
 Recently incidents are reduced and isolated,
and nothing is reported with downhole collisions.

 Continue Planning and Implementations -

 Site Safety Plans – Complete and Indexed Content
 Maintain Trainings and Certifications
 Continue Safety Meetings and Practice Drills
 Communications, Contacts and Notifications
 Personnel - Public Protections
 Environmental Protections - Waste Conservation.

 Continue QC/QA efforts Designs / Activities -

 Wellbore and Well Controls
 Surface Managements and Controls.

 Explore Areas: Training/Certification/Conservation.

 David J. Belcher
Office of Oil and Gas
Department of Environmental Protection
601 57th Street, SE
Charleston, WV 25304
304-926-0450

[email protected]
www.dep.wv.gov
doc1
Revised (3/15) doc2

Site Safety Plan Table of Contents

For H6A Well Work Permits and Deep Well Work Permits

Please prepare a Site Safety Plan to accompany each applicable H6A and/or Deep well work permit, adhering
to the following organizational and informational structure. Plans submitted must contain an index of the
content entirety including page-number references.

1. Contacts, Schedules, and Meetings

A. Emergency point of contact for the well operator covering all phases of activities and including 24 hour
contact information (35-8 5.7.b.4)
B. List of telephone numbers for (35-8 5.6.4):
1) Operator
2) Contractors
3) DEP office and oil/gas inspector
4) Local emergency response units
5) Local ER personnel
6) All schools and public facilities within a one mile radius of proposed well site (35-8 5.7.b.5)
C. Method of notification of public of H2S gas presence and how access will be controlled. (applicable
horizontal wells include all residents and emergency response personnel who may be affected by an
event. Such events may include the presence of H2S, blow-outs, and flaring) (35-8 5.7.f.1)
D. Pre-spud meeting held prior to drilling operations, including (35-8 5.7.h):
1) Attendance log, including personnel to be employed and involved in drilling operations
2) Notification of County oil and gas inspector or other designated Office of Oil and Gas
representative
E. Describe schedule for conducting regular well site safety meetings. Log attendance at all meetings and
also initiate check in check out during drilling, completion, and workover phases. (35-8 5.7.h)

2. Maps and Diagrams

A. Plan view map of location, access road, pit(s), flare lines, nearby dwellings, note the north direction
and the prevailing wind direction (35-8 5.7.b.1)
B. Topographic map of well location, including
1) 1 mile radius of well location
2) UTM NAD 83 coordinates of well site entrance (35-8 5.7.b.2)
3) UTM NAD 83 coordinates of the point the access road intersects the public route (35-8 5.7.b.2)
4) Identify public route number and/or route name (35-8 5.7.b.2)
C. Evacuation plan for the removal of personnel from the drilling location and residents in the
surrounding area who have the potential to be affected by an emergency. (35-8 5.7.b.3)

3. Well Work
A. Detailed written descriptions of well work and procedure to be used during the drilling, completion,
and production phases, including schematic plan views of each (35-8 5.7.a)
B. Statement detailing how a copy of the plan will be provided to the local emergency planning
committee or county emergency services office within at least 7 days from land disturbance or well
work. (35-8 5.7.a)

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Revised (3/15)

4. Chemical Inventory & MSDS

A. Material Safety Data Sheets for all chemicals anticipated to be used in all aspects of the operation (can
be provided on CD or USB drive) (35-8 5.7.a)
B. Statement that all MSDS are to be readily available at the well site and their location indicated in the
site safety plan including contact information for person(s) responsible maintaining them on site. (35-8
5.7.g)
C. Inventory of all materials on site for mixing of mud including numbers and type of mixing units - mixed
mud amount and weight, amount of weighting material and volume of mixing fluid. (35-8 5.7.d.1 &
5.7.d.2)

5. BOP and Well Control

A. BOP equipment and casing heads with types, sizes and ratings to be utilized and available during the
drilling for both intermediate and lateral drilling phases (35-8 5.7.c.1 & 5.7.c.8)
B. Procedure and schedule for testing the BOP stack for intermediate drilling phase the BOP tested upon
initial set up and the annular tested to 70% of capacity and the ram preventers tested to 80%. Same
testing % for bottom and horizontal phase except testing to be done upon initial installation, weekly
and after each bit trip (35-8 5.7.c.2)
C. BOP equipment and assembly installation schedule (35-8 5.7.c.3)
D. List and names of all personnel with well control training (35-8 5.7.c.4)
E. Description of system of maintaining detailed records of and for immediate notification to OOG
inspector for all significant drilling issues, including but not limited to (35-8 5.7.c.5):
1) Lost circulation
2) Hydrogen sulfide gas
3) Fluid entry
4) Abnormal pressures
F. Notification of the oil and gas inspector or designated representative as soon as possible of any
unusual drilling events, hydrogen sulfide gas* or large kicks that occur during drilling operations).
*(Mandatory immediate notification is required of any encounter of hydrogen sulfide gas - 22-6A wells
>10ppm H2S Gasses!) (35-8 5.7.c.5)
G. Schematic and detailed written description of the wellhead assembly to be placed on the well upon
completion (35-8 5.7.c.6)
H. Method and type of kill procedures as recognized by the IADC – Wild Well Control Kill Sheet. (35-8
5.7.d.3)

6. Hydrogen Sulfide (H2S)

A. Detection, monitoring and warning equipment including location of the monitoring detection
equipment on the site (35-8 5.7.e.1)
B. Statement of H2S personnel training provided (35-8 5.7.e.2)
C. Method to notify the OOG of H2S presence (35-8 5.7.e.4)
D. Establish and maintain Protection Zones. Describe detailed written general procedures proposed in
drilling phases. (application horizontal wells must include the completion, work-over, and production
phases) (35-8 5.7.f.2)
E. List of personal protective equipment (PPE) and the amount of each piece of PPE that will be
maintained and available on site. (35-8 5.7.e.3)

7. Flaring
A. Proposed written description and plan including schematic of installation for duration of flaring
activities. (35-8 5.7.f.1)

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Revised (3/15)

8. Collision Avoidance Safeguards, Practices and Standards Plans

Protocol and established safeguards designed to prevent underground collisions during any drilling on
multi-well pads (35-8 5.7). Collision avoidance plans are measures in keeping wellbores separated and
in preventing HSE risk. Such plans describe the survey accuracy and the survey maintenance by
systematic management efforts throughout the drilling of the proposed wellbore. These plans
submitted shall be well specific to the proposed wellbore and shall address all items within the
components section as outlined below. The scope of these plans shall provide survey designs
throughout the proposed wellbore including the QC / QA activities and the counter-actions necessary;
minimum separation factors (SF), standards and thresholds apply as specified in the components
section. These plans shall include proposed counter-actions necessary if a collision occurs or if surveys
observe an imminent risk for a collision; all wellbore collisions shall be treated as high-risk events.
Approved plans are conditions and terms of the well permit and any modifications are subject to
approval by the Office of Oil and Gas (OOG).
A. Established definitions:
1) Proposed Wellbore – Involves sections of the vertical top-hole, the KOP, the lateral landing, and
the lateral drilling to the total measured depth TMD.
2) Nudge – Technique generally used in the vertical top-hole section. The well path is nudged from
vertical to pass areas of possible magnetic interferences and to reduce the risk of collision by
maintaining separation with other wellbores.
3) KOP – Kick off Point. Diverting a well path from one trajectory to another.
4) MWD – Measurement While Drilling.
5) LWD – Logging While Drilling.
6) SF – Separation Factor or Clearance Factor:
SF* = CC ÷ [ URref + URoff ]
CC - well separation distance (center to center of wellbores)
URref - radius ellipse of uncertainty on reference well
URoff - radius ellipse of uncertainty on offset well
Note: ellipses are half-axes or radii.
*Calculation options may be considered
7) TMD – Total Measured Depth.
8) Gyro – High accuracy well bore survey instrument unaffected by magnetic interference.
9) QC / QA – Quality Control and Quality Assurance.
10) HSE – Health Safety and the Environment.

B. Established descriptions of risk:

1) SF ≤ 1.0 Level 1 Extreme collision risk
2) SF = 1.0 to 1.5 Level 2 High collision risk
3) SF = 1.5 to 2.0 Level 3 Moderate collision risk
4) SF > 2.0 Level 4 Low to no collision risk

C. Plan components:
1) Describe the scope of work and the type of survey techniques by use of gyros, MWD, LWD, or
others and include the following:
a) The survey intervals or frequencies proposed as adjustments to address each level of risk
covering the vertical top-hole section of the proposed wellbore.

Page 3 of 5
Revised (3/15)

b) Provide TOOL ALIGNMENT and MULESHOE procedures** when drilling in critical areas
covering the vertical top-hole section of the proposed wellbore. These procedures are
visual verification for alignment and orientation QC/QA purposes. Provide the responsible
personnel (minimum two representatives) and their titles of those involved for QC/QA
purposes during the drilling activities.
**Provide other orientations or survey methods and procedures if utilized.
c) Description of any nudge activity proposed in the vertical top-hole section.
d) The survey tools to be utilized from the KOP to the lateral landing and the lateral section to
the TMD.
e) Description of any software utilized for the directional and anti-collision planning proposed.
2) The following shall be addressed in the plan for the proposed wellbore:
a) Vertical top-hole section beginning at the surface and to the lateral landing -
i) Minimum SF standards (thresholds) required -
SF ≥ 1.5 shall be obtained early as practical and maintained.
(Indicate the frequency of survey intervals proposed)
ii) Minimum SF standards (thresholds) required -
SF ≥ 2.0*** applies when in proximity to any fractured or any producing well
that exists on the well pad.
(Indicate the frequency of survey intervals proposed)
***Risk management and technological mitigations, i.e. downhole plugs, are
critical and should be considered along with other safety measures necessary.
The OOG may require additional safety measures of a specific well application
for permitting as deemed necessary.
b) Lateral section beginning at the lateral landing and to the TMD -
i) Provide a general protocol to declination, grid correction, and magnetic
interference correction during the drilling of the proposed lateral. Also provide the
responsible personnel (minimum two representatives) and their titles of those
involved for QC/QA purposes during the drilling activities.
ii) For any existing horizontal or vertical wells found adjacent to this lateral section,
provide the protocols for separation safeguards and the spacing planned during the
drilling of this section. A reconnaissance review is required for each proposed
lateral; OOG may establish a minimum footage for review as deemed necessary.
3) Provide a well pad surface diagram depicting the wellhead arrangement (API labeled) of all
existing wells adjacent to the proposed wellbore. Indicate the surface footage separation between
wellheads and each wellbore status.
4) Describe the gyro surveying or other type surveying conducted within each existing wellbore
located on the pad.
5) Provide descriptive actions if a collision should occur or if surveys should observe
imminent risk for a collision.
6) Provide method to notify the OOG Oil and Gas Inspector immediately of any underground collision
or if the SF Level 1 is determined within the extreme collision risk zone (ellipses of uncertainty
overlap).
7) Provide other supportive resources or proposed safety measures as needed.

9. Deep Well Additional Requirements

A. List of anticipated freshwater, saltwater, oil and gas, hydrogen sulfide, thief zones, high pressure and
volume zones and their expected depths.

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Revised (3/15)

B. Detailed casing and cementing program that employs a minimum of three strings of casing which are
sufficient weight and quality for the anticipated conditions.
C. Flaring activities: Size, construction and length of flare line-anchor method and choke assembly
description, Flare lighting system and back up igniters, Notify local fire department (if possible) prior
to igniting flares, Minimum clearing distance beyond end of flare.
D. List of names, addresses, and telephone numbers of all residents, businesses, churches, schools and
emergency facilities within 1 mile radius that may be affected by specific events during the drilling
process. Such events may include presence of hydrogen sulfide, and flaring, etc.

10. Deep Vertical Well Requirements per Policy Statement (Deep Well
Drilling Procedures and Site Safety Plan Requirements)
The following selections are needed from the above contents:
1. A - E (E. drilling phase only)
2. A - C
3. A (drilling phase only)
4. B - C
5. A - H
6. A - E
9. A - D.

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3/10/15 doc3

8. Collision Avoidance Safeguards, Practices and Standards Plans

Protocol and established safeguards designed to prevent underground collisions during any
drilling on multi-well pads (35-8 5.7). Collision avoidance plans are measures in keeping
wellbores separated and in preventing HSE risk. Such plans describe the survey accuracy and the
survey maintenance by systematic management efforts throughout the drilling of the proposed
wellbore. These plans submitted shall be well specific to the proposed wellbore and shall
address all items within the components section as outlined below. The scope of these plans
shall provide survey designs throughout the proposed wellbore including the QC / QA activities
and the counter-actions necessary; minimum separation factors (SF), standards and thresholds
apply as specified in the components section. These plans shall include proposed counter-actions
necessary if a collision occurs or if surveys observe an imminent risk for a collision; all wellbore
collisions shall be treated as high-risk events. Approved plans are conditions and terms of the
well permit and any modifications are subject to approval by the Office of Oil and Gas (OOG).
A. Established definitions:
1. Proposed Wellbore – Involves sections of the vertical top-hole, the KOP, the lateral landing,
and the lateral drilling to the total measured depth TMD.
2. Nudge – Technique generally used in the vertical top-hole section. The well path is nudged
from vertical to pass areas of possible magnetic interferences and to reduce the risk of
collision by maintaining separation with other wellbores.
3. KOP – Kick off Point. Diverting a well path from one trajectory to another.
4. MWD – Measurement While Drilling.
5. LWD – Logging While Drilling.
6. SF – Separation Factor or Clearance Factor:
SF* = CC ÷ [ URref + URoff ]
CC - well separation distance (center to center of wellbores)
URref - radius ellipse of uncertainty on reference well
URoff - radius ellipse of uncertainty on offset well
Note: ellipses are half-axes or radii.
*Calculation options may be considered
7. TMD – Total Measured Depth.
8. Gyro – High accuracy well bore survey instrument unaffected by magnetic interference.
9. QC / QA – Quality Control and Quality Assurance.
10. HSE – Health Safety and the Environment.

B. Established descriptions of risk:

1. SF ≤ 1.0 Level 1 Extreme collision risk
2. SF = 1.0 to 1.5 Level 2 High collision risk
3. SF = 1.5 to 2.0 Level 3 Moderate collision risk
4. SF > 2.0 Level 4 Low to no collision risk

C. Plan components:
1. Describe the scope of work and the type of survey techniques by use of gyros, MWD, LWD,
or others and include the following:

Page 1 of 2
3/10/15

a) The survey intervals or frequencies proposed as adjustments to address each level of

risk covering the vertical top-hole section of the proposed wellbore.
b) Provide TOOL ALIGNMENT and MULESHOE procedures** when drilling in critical
areas covering the vertical top-hole section of the proposed wellbore. These
procedures are visual verification for alignment and orientation QC/QA purposes.
Provide the responsible personnel (minimum two representatives) and their titles of
those involved for QC/QA purposes during the drilling activities.
**Provide other orientations or survey methods and procedures if utilized.
c) Description of any nudge activity proposed in the vertical top-hole section.
d) The survey tools to be utilized from the KOP to the lateral landing and the lateral
section to the TMD.
e) Description of any software utilized for the directional and anti-collision planning
proposed.
2. The following shall be addressed in the plan for the proposed wellbore:
a) Vertical top-hole section beginning at the surface and to the lateral landing -
1) Minimum SF standards (thresholds) required -
SF ≥ 1.5 shall be obtained early as practical and maintained.
(Indicate the frequency of survey intervals proposed)
2) Minimum SF standards (thresholds) required -
SF ≥ 2.0*** applies when in proximity to any fractured or any producing
well that exists on the well pad.
(Indicate the frequency of survey intervals proposed)
***Risk management and technological mitigations, i.e. downhole
plugs, are critical and should be considered along with other safety
measures necessary. The OOG may require additional safety measures
of a specific well application for permitting as deemed necessary.
b) Lateral section beginning at the lateral landing and to the TMD -
1) Provide a general protocol to declination, grid correction, and magnetic
interference correction during the drilling of the proposed lateral. Also
provide the responsible personnel (minimum two representatives) and their
titles of those involved for QC/QA purposes during the drilling activities.
2) For any existing horizontal or vertical wells found adjacent to this lateral
section, provide the protocols for separation safeguards and the spacing
planned during the drilling of this section. A reconnaissance review is
required for each proposed lateral; OOG may establish a minimum footage
for review as deemed necessary.
3. Provide a well pad surface diagram depicting the wellhead arrangement (API labeled) of all
existing wells adjacent to the proposed wellbore. Indicate the surface footage separation
between wellheads and each wellbore status.
4. Describe the gyro surveying or other type surveying conducted within each existing wellbore
located on the pad.
5. Provide descriptive actions if a collision should occur or if surveys should observe
imminent risk for a collision.
6. Provide method to notify the OOG Oil and Gas Inspector immediately of any underground
collision or if the SF Level 1 is determined within the extreme collision risk zone (ellipses of
uncertainty overlap).
7. Provide other supportive resources or proposed safety measures as needed.
Page 2 of 2