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Field Operations and State-Managed Plugging Overview. Presenter: Clay Woodul. Presentation Overview. Organization Responsibilities Activities. Field Operations Austin. Complaint Monitoring Enforcement Referrals State Managed Plugging Program Regulatory Reports
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Field Operations and State-Managed Plugging Overview Presenter: Clay Woodul
Presentation Overview • Organization • Responsibilities • Activities
Field Operations Austin • Complaint Monitoring • Enforcement Referrals • State Managed Plugging Program • Regulatory Reports • Public and Industry Inquiries • Technical Assistance for other Departments
Form H-1525-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
Monitoring & Inspections Monitoring Emergency Incidents • Blowouts • Fires • H2S Incidents • Accidents/Injuries/Deaths • Spills Witness Industry Operations • 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 14 H2S Incidents 27 Fires 10 Accidents 791 Complaints 5,250 Industry Pluggings 1,943 Surface Casing 7,346 MITs 2,015 Spills
Compliance & Enforcement • Notice of Violation • Notice of Intent • Legal Referral
Compliance & Enforcement §81.0531 – Administrative Penalty • 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 • All wells require a permit to be drilled, deepened, reentered, or plugged back. • Operations may not commence until the permit has been issue. • Failure to notify prior to setting Surface, Intermediate, or Production casing. • 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 • 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