RAILROAD COMMISSION OF TEXAS

Field Operations and State-Managed Plugging

Overview

Presenter: Clay Woodul

Presentation Overview

• Organization• Responsibilities• Activities

Deputy Director

District Office

District Director

Assistant Director

Clerical Staff Technical Staff Lead Technician

Field Inspectors

State Managed Plugging

State Managed Cleanup

Admin Staff Tech Staff

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

43,27921,367

24,243

45,292

25,852

39,184

133,408

56,890

32,358

Population of Oil & Gas Wells in Texas

San AntonioHoustonCorpus ChristiKilgoreAbileneSan AngeloMidlandWichita FallsPampa

As of May 30, 2014

420,181 2,839

Requirement vs. Resources148 Inspectors

Total WellsWells per Inspector

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 Inspections55,030 Violations16,443 Pollution related violations

22 Blowouts14 H2S Incidents27 Fires10 Accidents791 Complaints5,250 Industry Pluggings

1,943 Surface Casing7,346 MITs2,015 Spills

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

• 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

Questions?