By David Harsell
As part of an effort to keep pace with the ever-changing technology of the oil industry, the BLM issued new Federal Onshore Orders in Jan 2017. These new regulations affected numerous topics including administration, reporting, operations, site security, and oil and gas measurement on Federal leases. Many of the significant portions of these regulations included implementation dates that were being phased-in to allow the industry adequate time to comply with their requirements and the BLM to create the necessary procedures and software for proper administration.
Because of the complexity of Onshore Order 3173 Requirements for Site Security and Production Handling, the BLM placed a temporary hold on implementing certain aspects of this regulation so that it could be re-written to provide more clarity to the industry’s operators. The new re-written Onshore Order 3173 is planned to be released to the public in the next several weeks and will be posted for 60 days to allow operators to review the requirements and provide comments. The re-write should address common issues/concerns with flowback equipment, commingling, allocation meters, bypasses, and Facility Measurement Points (FMPs). The BLM highly recommends and encourages operators to read the proposed re-write and submit comments as available on the Federal Register website.
Applications for the assignment of FMPs are still on hold until several development stages are completed after the introduction of the AFMSS 2 WISx system which will replace the Well Information System (WIS). The introduction of WISx will not happen until mid-March and the FMP reporting module will not be available until late 2020.
CAMS in-house technical staff is familiar with the requirements of the new Federal Onshore Orders and has experience working with the BLM to resolve compliance problems. As your operations encounter issues with understanding or complying with these new regulations, you should consider contacting CAMS to conduct a survey of your overall compliance level or assist in addressing problems. CAMS can be reached by sending an email or calling 713-380-4719.
This article is written by David Harsell, a CAMS senior engineering advisor, with over 45 yrs of industry engineering, facilities and operating experience working with the BLM.