Echols_2006_Re:A3WorkoverRRC

Echols, Darrell

I just finished speaking to the Railroad Commission (RRC) regarding the work that was conducted on the A3 well location. There appears to be some confusion regarding what is being proposed, what has been accomplished, and what is covered by the existing compliance for the A3 well. It is our understanding that the work proposed by BNP for A3 was to prepare the well for re-drilling and then move the Parker rig to re-drill the A3 well through the existing well bore based on the letter that we received on November 2. This work is covered in the existing Plan of Operations that BNP adopted from Vector and is similar to what was proposed and accomplished for the A8 well previously. However, it appears that the A3 well has been plugged and abandoned. This assessment is based on conversations with the RRC, examination of the logs completed by the workover rig, and examination of the A3 site location. If the A3 well has been plugged, this is not what was originally proposed. We understand that conditions can change especially in light of a well drilled several decades ago. However, if something changed from the original plan, the NPS should have been notified that conditions were different or that changes were needed prior to completion of the workover operation. We have not receive notification and hence the confusion about what is being planned compared to what was proposed.