uic completion reporting guidance - jim moore - revised ...copy. to work on one of these packets,...
TRANSCRIPT
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Completion reports provide required well information to RRC in 2 main areas:
wellbore construction & proration schedule.
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This is an overview of the relations between the Injection Permit, the Drilling Permit
and the Completion Report. This is important. The Completion Report has to tie the 2
permits together. Here I am indicating that the Field Name & Field Number have to
match on all 3 forms.
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Here is a summary of the 4 forms used for Injection or UIC permit types. UIC stands for
Underground Injection Control. The term “Enhanced Recovery” is used to distinguish
injection from disposal. The term injection is used broadly for all 4 categories.
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Wells are listed on the Proration Schedule by the unique combination of this
numbering system: District No. + Lease No. (or Gas ID) + Well No.
The API No. is not a unique number in that sense. This allows the Proration Schedule
to list dual/multiple completions for the same API No. such as producing and injecting
in the same wellbore.
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Definitions that refer to Injection / Disposal Permitting.
For “H-1/H-1A Field Name” the preferred method is to use the Field Name correlative
to the deepest Formation if more than 1 Formation is permitted. An equally preferred
method is to use the current Field Name under this scenario: injection / disposal is
permitted in Formations “A”, “B”, and “C” in descending order; well is on current
schedule in Field Name correlative to Formation “B”; well should stay in current Field
Name thereby avoiding the paperwork for workover to “C”.
“W-14 Field Name” is chosen from Field Names in the area.
The guiding principle is that the Field Name must match on Injection / Disposal
Permit, Drilling Permit (if required), and Completion Report.
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Here is a list of the important Injection/Disposal permit detail that is evaluated during
the Completion review.
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The link to Online Research Queries is shown here as a quick link below the
Commissioner’s photos. It will also appear as a link on many of the webpages. So, I
will proceed with a quick tour of the Data Queries.
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The Online Research Queries webpage acts as a table of contents or a list of links. I am
briefly pointing out a few examples.
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“Injection/Disposal Permit Query” is part of the group of links including Proration
Query. “Completions Query” can search by tracking number all the online completions
that started in 2009; online login is not required. Also, for “Drilling Permit (W-1)
Query” online login is not required. This allows Operators to view and print any online
completion or drilling permit. “Oil & Gas Imaged Records Menu” is also called Neubus.
Click on “Oil & Gas Imaged Records Menu”.
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Here are some examples of how the Neubus records are divided into groups. Neubus
is the system that manages the Oil & Gas Imaged Records. “Oil & Gas Well Records”
contains completion records from the years before the Online System.
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Click on a category such as “Groundwater Protection Determination Letters”, “Disposal
Permits (W-14)”, or “Injection/Disposal Permits (H-1/H-1A)” to see the Neubus key
search screen. Call for assistance to search this system.
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The Online Completion is arranged in these 5 steps to submit a new Packet, and I will
go through an example of each step starting with Packet Data. Here, “Check for
Messages” is part of step #6, updating a Packet. We at the RRC want the Operators
and Agents to have success filing their packets, and to have the Packets approved on a
timely basis.
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Here we are logged in to the Online System, and ready to do Completions.
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The first example I will discuss is to update an Existing Completion Packet. Also, from
this screen there are options for checking Messages. Messaging is how deficiencies
with Completion packets are communicated back to the Operator or Agent, and how
responses from the Operator or Agent are communicated back to RRC staff.
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This slide is what you might see if there are numerous Packets pending for your
Company. “View By” options allow all packets for this Filing Operator to be shown, or
only packets submitted under your User ID. The Packet Status could be Work In
Progress - Packets waiting to be Submitted by the Operator, Pending Operator Update
- Packets that have been reviewed by RRC and found to have a deficiency, or Hard
Copy. To work on one of these packets, click “Edit”. I want to clarify here the
difference between Pending Operator Update and other updates. Suppose your packet
has been submitted, reviewed, and found to have deficiencies and those deficiencies
are communicated in a Message. The Online System distinguishes between the parts
of the Packet that have been released for corrections or additional data. I will be
explaining the parts of a Packet in the upcoming slides. They are the W-2 or G-1,
Additional Forms, and Attachments. Pending Operator Update means that RRC has
released the entire Packet for corrections. This is required to change Packet Data for
example changing a Packet from Injection to Producing. Typically, only certain parts of
the Packet are released for correction. In that case, you would have to enter the
Tracking No. to search for and edit the Form or Attachment since the Packet is still
classed as Submitted. The guiding principle here is that Packets are locked from edits
in Submitted Status until specific parts are unlocked for corrections or additions.
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Next, let’s look at starting a New Completion Packet. Enter Drilling Permit No. or API
No.
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If the correct Field Name is found, then click “New Packet”.
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Here is a slide that emphasizes choosing the correct Drilling Permit. The Drilling Permit
will auto-populate parts of the Packet. Match Field Name and Issued Date to select the
correct Drilling Permit. This illustration shows the correct Field Name in 2 rows, so the
recent Issued Date marks the correct one. It usually isn’t that complicated.
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I am going to show a series of slides on “Packet Data”. There is a handy guide on the
upper right that follows the recommended sequence of steps that I showed earlier as
the Online Completion Overview. I am going to go through each of these items under
“Initial Packet Description”.
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“Purpose of Filing” is typically one of the 2 marked here. Many Injection/Disposal
Packets are marked as Initial Potential for New Drills. That is also OK. It is
informational only. It is also OK to think of Initial Potential as for Producing packets
only.
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“Type of Completion” could be any one of these for UIC wells. Usually a new Drilling
Permit is required for all except “Other”.
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“Well Type” is shown here. I will have more to say about “Active UIC” vs. “Shut-In UIC”
later in the presentation.
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If “Wellbore Profile” is Horizontal, then this row is activated.
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Injection/Disposal wells are classed as Gas or Oil based on the Field Name.
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Now we are done with “Initial Packet Description”.
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This shows that we can “Change Packet Description” before continuing, if needed.
Continue filling in “Well Data”. The next few slides are some blow-ups from this
screen.
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The item “Date of first production after rig released” is the Completion/Recompletion
Date that is appropriate for this packet. Pick the most recent date that is
representative of this Completion. Enter UIC Permit No. & Date, labeled here “Fluid
Injection Permit No.”, and the “O&G Waste Disposal Permit No.” Only 1 at a time
applies. You should recognize these as the H-1 or W-14 Permit number, respectively
and most recent Permit Date.
For UIC purposes a “Recompletion” or workover is a change of Field Name which
requires a new Drilling Permit. “Reclass” is changing from Producing to Injection, but
the Field Name is not changing.
If the Packet is a “Recompletion” or “Reclass”, then this table applies. I am going to
zoom in to this area of the screen. Suppose I clicked “Clear” at the end of the row,
then clicked “Search for Field & Reservoir”.
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1 result is found in this case that is the current Proration Schedule of the subject well
from the RRC database. Click “Select”.
Online system will find all completions for this well.
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Now the table is auto-populated from the RRC database. Just one more thing, you
must select “Prior Service Type” manually.
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Select “W-2” or “G-1” from the group of tabs near the top. “Completion or W-2 Data”
is arranged on 6 pages. The print function on Completions Query combines Packet
Data with Completion Data to make a printed version of the completion report.
“Potential Test Data” is blank for injection/disposal wells.
If you have “Potential Test Data” , then file the Completion Packet as Producing. Then
file a follow-up Packet with a new Tracking No. to Reclass from Producing to Injection.
That way, any “Potential Test Data” is captured in the system.
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On Page 2 of the W-2 or G-1 I am emphasizing that the Online System will prompt
with red-text warnings if critical data is missing on this page. That check is for the
current page only. Likewise for pages 3-5. When we get to Page 6, the last page, the
system will check all 6 pages.
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On Page 3 of the W-2 or G-1 there are data fields regarding “GAU Groundwater
Protection Determination ”, and “SWR 13 Exception”. For “new drill or re-entry” select
appropriate checkbox.
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On Page 4 of the W-2 or G-1 is the “Casing Record”. The “Type of Casing” pull-down
menu is shown on the lower part of the slide. The 2nd pull-down menu is “Top of
Cement Determined By”. If the Packet was submitted in 2013, then it is fine as is until
the Completion Form is released for edits or corrections to any of the 6 pages. Then,
the Online System will prompt for these pull-down selections to be filled in before Re-
Certifying the Form W-2 or G-1.
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On Page 4 of the W-2 or G-1 is the “Casing Record”. Shown are important details.
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Continuing on Page 4 are the “Liner Record”, “Tubing Record”, and “Remarks”. I am
showing that Well Type Active UIC needs Tubing and Packer set. So, Well Type Shut-In
UIC could have no “Packer Depth” entered.
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Here I will give an example that ties Page 4 to Page 5 of the W-2 or G-1. Page 4
contains the Packer data & Page 5 will contain the Perforated Injection Interval data.
Here is an illustration of a typical well construction with the Packer set within 100 feet
of the top of the Permitted Injection Interval. It is common for Operators to use the
lower part of a Permitted Interval in the early life of a well, then move up-hole later.
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This slide shows that the Actual Packer Depth of 5800’ from a completion report is
below the Permitted Top Interval of 5577’ which is allowed.
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The illustration shows a reporting error where the Packer appears to be deeper than
the “Perforated Interval” which it cannot be. The reporting error is to state the
Perforated Interval top at 5577’.
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On Page 5 of the W-2 or G-1 the “Injection/Disposal Interval” is entered. This data is
required for Well Type Active UIC.
“Open Hole” is allowed.
This data can be left blank for Well Type Shut-In UIC. Also, this question is only
answered “Yes” for Shut-In UIC, in the case of a new drill with un-perforated casing.
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Continuing on Page 5 of the W-2 or G-1 is the “Acid, Fracture, Cement Squeeze, …Etc.”
table. The pull-down menu for “Process” is shown here. This table is important for
showing compliance with UIC Permit Special Conditions. Examples of Special
Conditions are Cement Squeeze and Cast Iron Bridge Plug.
Make an entry for new perforations if different from an existing completion.
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Continuing on Page 5 are “Formation Record” and “Remarks” sections. For new drills
after January, 2014, this table is pre-populated with Formation Names.
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A thorough explanation of the terms “Encountered” & “Isolated” is shown on the
screen in the small print. I will summarize it. Provide a Depth for each Formation Top
Encountered based on the Total Depth of the well. You may give approximate depths.
Use the “Remarks” column by row if the Formation Top was not “Encountered”.
Examples of “Remarks” are “pinched-out” or “well is not deep enough”. “Isolated”
means there is cemented casing at that formation/zone depth pursuant to SWR 13. If
the formation/zone is part of the completion interval, and is adequately confined by
cemented casing, then mark “Isolated”. If “Encountered” is checked, but “Isolated” is
not checked, then “Remarks” for that row must be filled in.
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I am making a detour back to the webpage to show a reference to “Geologic
Formation Tops”.
From the homepage, use the “Oil & Gas” pull-down menu, then select “Compliance &
Enforcement”.
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Here is a link to “Revised Statewide Rule 13 – Casing, Cementing, Drilling …”.
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The group of links to Excel spreadsheets are found here by Oil & Gas District.
Inside a spreadsheet, there are worksheets by County.
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Here is an example for Lavaca County in District 02.
Each Formation Top is shown as a likely range of depths across the County. Remarks
indicate what type of zone it is.
Check for actual permitted injection intervals within ¼ mile.
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Back to Page 6 of the W-2 or G-1. Click “Certify” to finalize the W-2 or G-1. The Online
System will give a red-text warning if critical data is missing on any of Pages 1-6.
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Now we are ready to “Complete Additional Forms”. The idea here is to determine all
required forms based on the type of Completion. Some of that determination is
automated based on “Packet Summary Data”. The 1st example is Form P-4.
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Form P-4 is required when a new “Oil Lease No.” or “Gas ID” needs to be assigned.
“Gatherer(s) and/or Purchaser(s)” information may be blank for UIC Completions,
then filed later by online or hard-copy P-4.
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There is a 2nd page to “Certify” the P-4.
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Next example is “W-12 Inclination Report”. The “Well Information” & “Shot Point
Information” has to match the paper record of Form W-12 that is an Attachment to
the Packet. I will be showing Attachments later in the presentation.
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“L-1 Electric Log Status Report” has several options. For “Basic Electric Log Run”, 1st
option is to mark “Confidentiality …”. Then, proceed to use “Load Attachments” for a
copy of the Log Header. 2nd option is to mark “Log Attached …”, check “A”, “B”, or “C”,
then mail the continuous log to RRC Austin.
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Next, I will show “Complete Additional Forms” / “Load Attachments”. The 1st example
is “W-15 Cementing Report”.
Launch “W-15” attachment from the “Complete Additional Forms” screen.
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Required formats are .pdf or .tif for all Attachments. Step 1 “Attachment Type” is
shown pre-selected from the previous screen. I will show a 2nd method for Step 1 on
the next slide. Step 2 “Browse” to the file to be attached located on your computer.
Click “Open” (not shown). Step 3 “Upload” loads the attachment.
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Attach “W-12 Inclination Report”.
A 2nd way to initiate “Attachment Type” is to use the pull-down menu on “Load
Attachments” screen.
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Refer back to the previous slides for steps Browse & Upload since they are the same
for each Attachment.
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This is the 1st “Submit” screen. There is a listing of “Form Names”. “Status of Packet
Data” will be “Work In Progress”. All other “Status” should be “Certified”. There is a
listing of “Attachments”.
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This is the 2nd “Submit” screen. Try to Submit with both questions answered “No”. If
the system responds with red text warnings, then you have the option to Submit again
from this same screen with one or both answered “Yes”. This procedure is “Submit
with Forms Lacking”.
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Here is a description of the likely outcome of “Submit with Forms Lacking”. The RRC
analyst will either require the missing Form or Attachment through Messaging prior to
Final Approval of the Completion Packet, or grant Final Approval to the Completion
Packet with Forms Lacking which will provide extra time for the Operator or Agent to
provide the missing items.
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Now, we have submitted the Packet successfully.
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A Completion Packet may need problem resolution. The Online System allows RRC
analysts to release each Form separately, or to release the Packet back to the Operator
or Agent for corrections. Forms are Re-Certified and the Packet is Re-Submitted. Also
separately, the Packet can be set to add or delete Attachments. Permit Amendment
can be required, for example, to make Field Name match. A Certified Letter can be
sent after Messages are not responded to for 30 days. Severance of the P-4 can occur
30 days after the Certified Letter Date if problems are not resolved.
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