Transcript Requirement vs. Resources 148 Inspectors

RAILROAD COMMISSION OF TEXAS
Field Operations and
State-Managed Plugging
Overview
Presenter: Clay Woodul
Presentation Overview
• Organization
• Responsibilities
• Activities
Deputy
Director
District Office
Admin Staff
Tech Staff
State Managed
Plugging
State Managed
Cleanup
District
Director
Assistant
Director
Clerical Staff
Technical Staff
Lead
Technician
Field
Inspectors
Field Operations Austin
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Complaint Monitoring
Enforcement Referrals
State Managed Plugging Program
Regulatory Reports
Public and Industry Inquiries
Technical Assistance for other Departments
Form H-15
25-year Inactive Well Program
• Monthly Listings
• Fluid Level or Mechanical Integrity Tests
• 14(b)(2) extension
• Severance/Seal
• Extensions
Bringing Wells back into Production
SWR 15(l)(7) Effective 2010:
An operator of an inactive well that is more than 25
years old may not return that inactive well to active
operation unless the operator performs either a fluid
level test on the well within 12 months prior to the
return to activity or a hydraulic pressure test of the
well within five years prior to the return to activity.
Returning Well to Active Status
• H-15 test must be run as noted in 15(l)(7)
• W-10 or G-10 Retest Form must be filed
• Well must produce 10 BO or 100 MCF per
month for 3 consecutive months
• Extensions of time has to be approved
District Office Responsibility
•Facilities and activities associated with
• Oil & Gas Exploration
• Production
• Processing
• Transportation
• Waste Handling and Disposal
Population of Oil & Gas Wells in Texas
As of May 30, 2014
32,358
56,890
43,279
21,367
San Antonio
24,243
Houston
Corpus Christi
Kilgore
45,292
Abilene
San Angelo
Midland
Wichita Falls
25,852
133,408
39,184
Pampa
Requirement vs. Resources
148 Inspectors
420,181
2,839
Total Wells
Wells per Inspector
Monitoring & Inspections
Monitoring Emergency Incidents
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Blowouts
Fires
H2S Incidents
Accidents/Injuries/Deaths
Spills
Witness Industry Operations
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Surface Casing Jobs
P&A Operations
Mechanical Integrity Tests
Operator Cleanups
Drilling rig inspections
Commercial Waste and Disposal Facilities
Monitoring & Inspections
125,878 Inspections
55,030 Violations
16,443 Pollution related violations
22 Blowouts
1,943 Surface Casing
14 H2S Incidents
7,346 MITs
27 Fires
2,015 Spills
10 Accidents
791 Complaints
5,250 Industry Pluggings
Compliance & Enforcement
• Notice of Violation
• Notice of Intent
• Legal Referral
Compliance & Enforcement
§81.0531 – Administrative Penalty
(a) If a person violates provisions of this title which
pertain to safety or the prevention or control of
pollution or the provisions of a rule, order, license,
permit, or certificate which pertain to safety or the
prevention or control of pollution and are issued
under this title, the person may be assessed a civil
penalty by the commission.
(b) The penalty may not exceed $10,000 a day for each
violation. Each day a violation continues may be
considered a separate violation for purposes of
penalty assessments.
Compliance & Enforcement
• Enforcement Recommendations
• Plug Hearings
• Non-Compliance with SWR 14(b)(2)
• Penalty Action Hearings
• Non-Compliance with Commission Rules
Enforcement Referrals
Plug Hearings
• Violation of SWR 14(b)(2)
• Has not produced in > 12 months
• Does not have an approved 14(b)(2) Extension
• Does not have “Good Faith Claim” to operate
• May include violations of other Commission
Rules
Enforcement Referrals
• Rule 3—Signs
• Rule 8—Leaks, spill, pits
• Rule 9/46-Delinquent H-5, pressure on
annulus
• Rule 13—Open or leaking wellheads
• Rule 17—Pressure on bradenhead
• Rule 36—H2S violations
Enforcement Referrals
SWR 5—Drilling Permits
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All wells require a permit to be drilled, deepened,
reentered, or plugged back.
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Operations may not commence until the permit has
been issue.
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Failure to notify prior to setting Surface,
Intermediate, or Production casing.
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Failure to notify of plugging a dry hole
Enforcement Referrals
SWR 14—Plugging rule
• Failure to file plugging forms (W3A & W3)
• Failure to notify
• Failure to properly plug
• Failure to remove equipment
Enforcement Referrals
SWR 20—Notification of Fires, Leaks, Blowout
• Requires immediate notification of
• Fires
• Blowouts and loss of well control
• Leaks, spills, or breaks
Field Operations Activities
Complaint Process
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Investigate all complaints
Coordinate inspections
Complaint Coordinator Monitors Progress
Complainant kept informed
Refer to State Managed Plugging & Cleanup
Field Operations Activities
State Managed Plugging Program