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BLM Office In Bakersfield Is Not Performing Casing Or Cementing Inspections
The 2013 update of “Law and Order in the Oil and Gas Fields” which analyzes state inspection data from five western oil-producing states, Colorado, Montana, New Mexico, North Dakota and Wyoming, as well as the federal Bureau of Land Management (BLM) data in the same 5 states Findings include a similar recurring theme as the “Bakersfield BLM Office” in the 2011 Internal Control Review (ICR) the BLM conducted of it's onshore oil and gas Inspection and Enforcement (I&E) program.
BLM Office In Bakersfield Is Not Performing Casing Or Cementing Inspections
According to a mid 2011 Internal Control Review (ICR) the BLM conducted of it's onshore oil and gas Inspection and Enforcement (I&E) program, “The drilling inspection process in Bakersfield is best summarized as a light review of drilling activity and, most importantly, exhibited a lack of proper documentation. Inspections reviewed had few or no comments in the AFMSS database. Supporting documentation, such as cement job reports, tally sheets, Blowout Preventer (BOPE) test results as well as charts of the test, were never included.”
Drilling
“They do not perform casing inspections. There are budget concerns. All Petroleum Expert Technicians (PETs) were concerned about the limited funding to do the required high priority work; instruction is given to leave well locations by 3:00 p.m.”
“Bakersfield staff is not performing casing or cementing inspections. The lack of experienced PETs in this office limits the ability to lead training for the new personnel. PETs do not enter their inspections into AFMSS individually; inspections are entered by a PST. This could lead to details lost on inspections that may be significant. The Automated Fluids Minerals Support System (AFMSS) is used to track oil and gas information on public and Indian land.”
“This area has rigs running for 2 days per well on Federal properties, so the inspector is not allowed much time on an individual well. An inspector often visits multiple wells in one day, sometimes as many as six or seven. Inspectors need to assess the quality and quantity of the casing and cementing details; these were lacking in the office documentation, as well as in the inspections in the field. The ability to cover priority inspections with the appropriate overtime and funding is necessary to ensure compliance of the operations.”
“Environmental - It also appears upon review that staff is doing virtually no Environmental or Production inspections outside of onsite visits (which were improperly coded) and surface abandonments. None of the 13 inspections examined had very descriptive comments; the most explanatory had only a few sentences and no pictures. Often the remarks were limited to very short comments. ES inspections should only be conducted for “post-approval activities” and onsite visits are definitely pre-approval. This type of inspection seems to be the most common conducted by staff.”
The Environmental Protection Specialist (EPS) is a position on the Minerals staff of the BLM whose duties include Hazardous Materials. When oil and gas (O&G) facilities are constructed and removed, an inspection is necessary because of the methods the operator must employ to handle sour gas. For facility removal, asbestos, lead paint, and the concentration of mercury in tank bottoms may occur.
From the: US Department of the Interior BLM, Minerals and Realty Management Division of Fluid Minerals 2011 Inspection and Enforcement Internal Control Review of Documentation of Inspections and Review of Drilling, Environmental, and Production Inspections
http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/ib_attachments.Par.3537.File.dat/Draft%20Inspection%20and%20Enforcement%20-%20ICR%20Report-v8%209%2021%202011.pdf
That same year, there was the potential of lawsuits and an EPA audit of the DOGGR California Underground Injection Control Program in June 2011. DOGGR issued new MOUs with BLM in 2012. But the continued lack of data, lack of knowledge of data, and a 'repetitive parroting' of Industry language skill sets and PowerPoint Presentations, didn't add up and were scrutinized flaw by flaw with no adequate response by DOGGR at the February 12th 2013 Senate Natural Resources and Water and Senate Environmental Quality Joint Informational Hearing in Sacramento on the “Regulation of Hydraulic Fracturing in Oil and Gas Production in California".
“DOGGR insists it added 43 staff positions over 3 years, these staff are working in UIC or closely related programs...” but DOGGR still had no better documentation or knowledge of the existing number of wells in California, or if any horizontal high pressure high volume slick water hydraulic fracturing was happening in California, or if there was any concern for preparations in advance of a ramp up of activities, or planned activities, related to the exploration, leasing, drilling, or production of oil from the Monterey Shale.
The Division of Oil Gas and Geothermal Resources and the U.S. Bureau of Land Management (BLM) have since updated their Memorandum of Understanding as of October 16, 2012. The purposes of the MOU are to delineate procedures for regulating oilfield operations where both the BLM and Division have jurisdictional authority.
ftp://ftp.consrv.ca.gov/pub/oil/regulations/DOGGR-BLM-%20MOU%202012.pdf
But they have enough procedures that are not carried out as it is! At the BLM site one learns;
“Five of the ten most productive oil fields in the United States are in California, mostly in Kern County. Federal leases in California range in size from one well leases, producing only a barrel or two per day, up to a lease with over 1,200 wells producing more than 4,000 barrels per day. Approximately 7% of the total wells in California are federal wells. At 4,000-4,500 BPD, Chevron’s Section 22-G Lease in the Midway Sunset Field and USL Lease at Lost Hills are two of the highest producing onshore federal leases in the lower 48 states.
Inspection and Enforcement
“BLM technicians are responsible for inspecting field operations, ensuring production accountability, and enforcing safety requirements on over three hundred producing leases and units containing more than 8,000 wells. Contact us at (661) 391-6130 for emergencies or same day witness, or (661) 391-6151 for 24 hour notification of witnessing (messages).”
http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/2012/IM_2012-161.html
The Environmental Protection Specialist (EPS) has quite a job description.
“The Bureau of Land Management (BLM) oil and gas program is only as strong as the quality and completeness of inspections, the coaching provided, and the oversight engagement of leads, supervisors, and management at all levels. In December 2010, the Office of the Inspector General (OIG) agreed and recommended increased BLM oversight of written inspection and file documentation protocols, increased oversight inspections by supervisors, and evidence of inspection completion. Therefore, all staff involved in performing, documenting, reviewing, or overseeing inspections must adhere to the following protocols.”
Certainly sounds good. But as the Internal Control Review audit shows in detail, the job can't be done as described, Any increase in drilling would exacerbate the problem.
The 2013 update of “Law and Order in the Oil and Gas Fields” which analyzes state inspection data from five western oil-producing states, Colorado, Montana, New Mexico, North Dakota and Wyoming, as well as the federal Bureau of Land Management (BLM) data in the same 5 states Findings include a similar recurring theme as the “Bakersfield BLM Office” in the 2011 Internal Control Review (ICR) the BLM conducted of it's onshore oil and gas Inspection and Enforcement (I&E) program.
Growth in the number of oil and gas wells continues to outpace increases in the number of state inspectors. In Montana, each state inspector is responsible over 1,550 active oil and gas wells. Nationwide, BLM inspectors are responsible for just over 3,000 wells each.
The average number of inspections per Montana inspector was 599 in 2011.
BLM and four of the five state agencies studied do not have enough inspectors to inspect each active well at least once a year. Wells are inspected once every 2.6 years on average in Montana and once every 4.8 years by BLM nationwide.
All agencies studied take very few enforcement actions, and fines and penalties are infrequent and trivial. BLM collected less than $150 per violation on average.
“BLM Board of Oil and Gas commission should at least comply with the recommendations of the 2011 Legislative Audit. Now, it would seem easier for companies to just pay the fines and resume business as usual.”
http://www.roundupweb.com/story/2013/02/13/news/oil-and-gas-inspections-falling-further-behind/2130.html
Previous “Law and Order” reports issued by WORC in 2004 and 2009 and the updated report is available at http://www.worc.org.
Drill, Drilled, Re-drilled, Even Overdrilled
Kern County's expanse of drilled oil fields, are “mature steam flood assets” that produce more than one-tenth of the nation's crude. No field in California is more productive than the Midway-Sunset, west of Bakersfield.
In shallow formations of diatomite (a soft and porous rock) steam is injected to soak the heavy crude, thinning it so that it can be pumped to the surface, often from a depth of less than 1,000 feet. From that shallow depth, pressurized steam can break through fragile diatomite.
As much as one-quarter of the oil produced in Kern County is from diatomite, perhaps 10 percent of which is drawn from shallow formations using steam. “Steam fracking, or cyclic steaming, which injects steam underground at high pressure to break up the area's porous soil and release oil, is an increasingly common form of injection drilling, and one that has been connected to surface expressions of steaming earth, violent eruptions that hurl rock and liquid as high as 100 feet in the air, and which claimed the life of an oil worker near Taft in August 2011.
The underground injection method of fracturing, used in the Midway-Sunset field involves forcing steam through horizontal or vertical wells in intervals of three to four days. Because these oil fields have been producing for so long, the last amount of oil needs coaxing.
Subsidies Explained As Assets Are Good To The Last Drop
Steam Floods Assets production relies on thermal enhanced oil recovery (EOR) methods, primarily cyclic steaming, to place steam effectively into the remaining oil column. These are some of the most thermally mature assets.
Shutting Off The Steam to 10% of one fourth of Kern County Oil Production got the Heads of the Department of Conservation, and the Head of DOGGR fired.
“Concerns about the impacts of injection drilling, including the possibility of contamination of underground sources of drinking water or irrigation water and frustration with an industry that routinely refused to follow state regulatory policies” are detailed in more than 700 interagency emails provided in response to The Sacramento Bee's California Public Records Act request.”
The price of gas is down, the price of oil is up.
The Price Of Water vs The Price Of Steamed Oil and Gas
Not only is there concern for safe non-polluted “underground drinking water aquifers” but also non-toxic “brackish irrigation aquifers” used on farms and ranches.
“DISCUSSION DRAFT” OF CALIFORNIA HYDRAULIC FRACTURING REGULATIONS
The Department of Conservation/Division of Oil, Gas, and Geothermal Resources on December 18, 2012 released a “discussion draft” of regulations for the oil and natural gas production technique known as hydraulic fracturing (“fracking”).
DOGGR conducted the first of several stakeholder workshops to receive input on the "discussion draft" regulations on February 19, 2013 in Los Angeles.
Two additional workshops have been scheduled. The next workshop is in Bakersfield, Wednesday, March 13 from 9 a.m. to 4 p.m. at the Four Points Sheraton, 5101 California Avenue. The agenda can be found here.
http://www.conservation.ca.gov/index/Documents/Agenda%20Bakersfield%20Workshop_Mar2013.pdf
On Thursday, March 21, a workshop will be held in Sacramento at the Capitol Plaza Holiday Inn, 300 J Street. That workshop will also run from 9 a.m. to 4 p.m. Agenda available soon.
http://www.conservation.ca.gov/DOG/Pages/Index.aspx
Tomas DiFiore
According to a mid 2011 Internal Control Review (ICR) the BLM conducted of it's onshore oil and gas Inspection and Enforcement (I&E) program, “The drilling inspection process in Bakersfield is best summarized as a light review of drilling activity and, most importantly, exhibited a lack of proper documentation. Inspections reviewed had few or no comments in the AFMSS database. Supporting documentation, such as cement job reports, tally sheets, Blowout Preventer (BOPE) test results as well as charts of the test, were never included.”
Drilling
“They do not perform casing inspections. There are budget concerns. All Petroleum Expert Technicians (PETs) were concerned about the limited funding to do the required high priority work; instruction is given to leave well locations by 3:00 p.m.”
“Bakersfield staff is not performing casing or cementing inspections. The lack of experienced PETs in this office limits the ability to lead training for the new personnel. PETs do not enter their inspections into AFMSS individually; inspections are entered by a PST. This could lead to details lost on inspections that may be significant. The Automated Fluids Minerals Support System (AFMSS) is used to track oil and gas information on public and Indian land.”
“This area has rigs running for 2 days per well on Federal properties, so the inspector is not allowed much time on an individual well. An inspector often visits multiple wells in one day, sometimes as many as six or seven. Inspectors need to assess the quality and quantity of the casing and cementing details; these were lacking in the office documentation, as well as in the inspections in the field. The ability to cover priority inspections with the appropriate overtime and funding is necessary to ensure compliance of the operations.”
“Environmental - It also appears upon review that staff is doing virtually no Environmental or Production inspections outside of onsite visits (which were improperly coded) and surface abandonments. None of the 13 inspections examined had very descriptive comments; the most explanatory had only a few sentences and no pictures. Often the remarks were limited to very short comments. ES inspections should only be conducted for “post-approval activities” and onsite visits are definitely pre-approval. This type of inspection seems to be the most common conducted by staff.”
The Environmental Protection Specialist (EPS) is a position on the Minerals staff of the BLM whose duties include Hazardous Materials. When oil and gas (O&G) facilities are constructed and removed, an inspection is necessary because of the methods the operator must employ to handle sour gas. For facility removal, asbestos, lead paint, and the concentration of mercury in tank bottoms may occur.
From the: US Department of the Interior BLM, Minerals and Realty Management Division of Fluid Minerals 2011 Inspection and Enforcement Internal Control Review of Documentation of Inspections and Review of Drilling, Environmental, and Production Inspections
http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/ib_attachments.Par.3537.File.dat/Draft%20Inspection%20and%20Enforcement%20-%20ICR%20Report-v8%209%2021%202011.pdf
That same year, there was the potential of lawsuits and an EPA audit of the DOGGR California Underground Injection Control Program in June 2011. DOGGR issued new MOUs with BLM in 2012. But the continued lack of data, lack of knowledge of data, and a 'repetitive parroting' of Industry language skill sets and PowerPoint Presentations, didn't add up and were scrutinized flaw by flaw with no adequate response by DOGGR at the February 12th 2013 Senate Natural Resources and Water and Senate Environmental Quality Joint Informational Hearing in Sacramento on the “Regulation of Hydraulic Fracturing in Oil and Gas Production in California".
“DOGGR insists it added 43 staff positions over 3 years, these staff are working in UIC or closely related programs...” but DOGGR still had no better documentation or knowledge of the existing number of wells in California, or if any horizontal high pressure high volume slick water hydraulic fracturing was happening in California, or if there was any concern for preparations in advance of a ramp up of activities, or planned activities, related to the exploration, leasing, drilling, or production of oil from the Monterey Shale.
The Division of Oil Gas and Geothermal Resources and the U.S. Bureau of Land Management (BLM) have since updated their Memorandum of Understanding as of October 16, 2012. The purposes of the MOU are to delineate procedures for regulating oilfield operations where both the BLM and Division have jurisdictional authority.
ftp://ftp.consrv.ca.gov/pub/oil/regulations/DOGGR-BLM-%20MOU%202012.pdf
But they have enough procedures that are not carried out as it is! At the BLM site one learns;
“Five of the ten most productive oil fields in the United States are in California, mostly in Kern County. Federal leases in California range in size from one well leases, producing only a barrel or two per day, up to a lease with over 1,200 wells producing more than 4,000 barrels per day. Approximately 7% of the total wells in California are federal wells. At 4,000-4,500 BPD, Chevron’s Section 22-G Lease in the Midway Sunset Field and USL Lease at Lost Hills are two of the highest producing onshore federal leases in the lower 48 states.
Inspection and Enforcement
“BLM technicians are responsible for inspecting field operations, ensuring production accountability, and enforcing safety requirements on over three hundred producing leases and units containing more than 8,000 wells. Contact us at (661) 391-6130 for emergencies or same day witness, or (661) 391-6151 for 24 hour notification of witnessing (messages).”
http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/2012/IM_2012-161.html
The Environmental Protection Specialist (EPS) has quite a job description.
“The Bureau of Land Management (BLM) oil and gas program is only as strong as the quality and completeness of inspections, the coaching provided, and the oversight engagement of leads, supervisors, and management at all levels. In December 2010, the Office of the Inspector General (OIG) agreed and recommended increased BLM oversight of written inspection and file documentation protocols, increased oversight inspections by supervisors, and evidence of inspection completion. Therefore, all staff involved in performing, documenting, reviewing, or overseeing inspections must adhere to the following protocols.”
Certainly sounds good. But as the Internal Control Review audit shows in detail, the job can't be done as described, Any increase in drilling would exacerbate the problem.
The 2013 update of “Law and Order in the Oil and Gas Fields” which analyzes state inspection data from five western oil-producing states, Colorado, Montana, New Mexico, North Dakota and Wyoming, as well as the federal Bureau of Land Management (BLM) data in the same 5 states Findings include a similar recurring theme as the “Bakersfield BLM Office” in the 2011 Internal Control Review (ICR) the BLM conducted of it's onshore oil and gas Inspection and Enforcement (I&E) program.
Growth in the number of oil and gas wells continues to outpace increases in the number of state inspectors. In Montana, each state inspector is responsible over 1,550 active oil and gas wells. Nationwide, BLM inspectors are responsible for just over 3,000 wells each.
The average number of inspections per Montana inspector was 599 in 2011.
BLM and four of the five state agencies studied do not have enough inspectors to inspect each active well at least once a year. Wells are inspected once every 2.6 years on average in Montana and once every 4.8 years by BLM nationwide.
All agencies studied take very few enforcement actions, and fines and penalties are infrequent and trivial. BLM collected less than $150 per violation on average.
“BLM Board of Oil and Gas commission should at least comply with the recommendations of the 2011 Legislative Audit. Now, it would seem easier for companies to just pay the fines and resume business as usual.”
http://www.roundupweb.com/story/2013/02/13/news/oil-and-gas-inspections-falling-further-behind/2130.html
Previous “Law and Order” reports issued by WORC in 2004 and 2009 and the updated report is available at http://www.worc.org.
Drill, Drilled, Re-drilled, Even Overdrilled
Kern County's expanse of drilled oil fields, are “mature steam flood assets” that produce more than one-tenth of the nation's crude. No field in California is more productive than the Midway-Sunset, west of Bakersfield.
In shallow formations of diatomite (a soft and porous rock) steam is injected to soak the heavy crude, thinning it so that it can be pumped to the surface, often from a depth of less than 1,000 feet. From that shallow depth, pressurized steam can break through fragile diatomite.
As much as one-quarter of the oil produced in Kern County is from diatomite, perhaps 10 percent of which is drawn from shallow formations using steam. “Steam fracking, or cyclic steaming, which injects steam underground at high pressure to break up the area's porous soil and release oil, is an increasingly common form of injection drilling, and one that has been connected to surface expressions of steaming earth, violent eruptions that hurl rock and liquid as high as 100 feet in the air, and which claimed the life of an oil worker near Taft in August 2011.
The underground injection method of fracturing, used in the Midway-Sunset field involves forcing steam through horizontal or vertical wells in intervals of three to four days. Because these oil fields have been producing for so long, the last amount of oil needs coaxing.
Subsidies Explained As Assets Are Good To The Last Drop
Steam Floods Assets production relies on thermal enhanced oil recovery (EOR) methods, primarily cyclic steaming, to place steam effectively into the remaining oil column. These are some of the most thermally mature assets.
Shutting Off The Steam to 10% of one fourth of Kern County Oil Production got the Heads of the Department of Conservation, and the Head of DOGGR fired.
“Concerns about the impacts of injection drilling, including the possibility of contamination of underground sources of drinking water or irrigation water and frustration with an industry that routinely refused to follow state regulatory policies” are detailed in more than 700 interagency emails provided in response to The Sacramento Bee's California Public Records Act request.”
The price of gas is down, the price of oil is up.
The Price Of Water vs The Price Of Steamed Oil and Gas
Not only is there concern for safe non-polluted “underground drinking water aquifers” but also non-toxic “brackish irrigation aquifers” used on farms and ranches.
“DISCUSSION DRAFT” OF CALIFORNIA HYDRAULIC FRACTURING REGULATIONS
The Department of Conservation/Division of Oil, Gas, and Geothermal Resources on December 18, 2012 released a “discussion draft” of regulations for the oil and natural gas production technique known as hydraulic fracturing (“fracking”).
DOGGR conducted the first of several stakeholder workshops to receive input on the "discussion draft" regulations on February 19, 2013 in Los Angeles.
Two additional workshops have been scheduled. The next workshop is in Bakersfield, Wednesday, March 13 from 9 a.m. to 4 p.m. at the Four Points Sheraton, 5101 California Avenue. The agenda can be found here.
http://www.conservation.ca.gov/index/Documents/Agenda%20Bakersfield%20Workshop_Mar2013.pdf
On Thursday, March 21, a workshop will be held in Sacramento at the Capitol Plaza Holiday Inn, 300 J Street. That workshop will also run from 9 a.m. to 4 p.m. Agenda available soon.
http://www.conservation.ca.gov/DOG/Pages/Index.aspx
Tomas DiFiore
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