Is Your Facility in Compliance?

With over 20 years of experience in the California oil and gas industry, and long standing working relationships with local and state agencies, InterAct PMTI is ideally placed to provide expert DOGGR permitting assistance.

Idle Well Management

Effective January 1, 2018, AB 2729 affects the management of idle wells. More wells may now be considered ‘idle’ and become eligible for idle well fees as the definition of an ‘observation well’ is tightened. Long term idle wells will need to be eliminated at a minimum rate of 4% per year. Category definitions for blanket indemnity bonds are changing and bond amounts are increasing with a new upper limit of $3MM. Annual fees are also changing, with more fee categories based on the length of time the well has been idle, with fees of up to $1,500 per well!

How InterAct Can Help:

  • Assess your current well inventory and determine exactly what the regulations will mean to you.
  • Prepare a tailored Idle Well Management Plan outlining the most efficient way to prepare your well inventory for the new requirements and prioritizing wells for abandonment, and minimize costs to your operation.
  • Develop a compliant and cost-effective strategy for well P&A, assist with managing tendering and selection of sub-contractors, and oversee abandonment operations.
  • Manage ongoing reporting requirements, such as those needed for active observation wells, or update plans to eliminate idle wells.

DOGGR WellSTAR Data Management

DOGGR is implementing a new Statewide Tracking And Reporting system (WellSTAR) to better handle data collection and analysis, streamline operations and processes, and comply with new reporting regulations. Under the new requirements, operators will need to provide well history and production/injection data, submit Notices of Intention (NOIs), and submit underground injection project applications (UICs) in DOGGRs WellSTAR format. In many cases the new reporting system requires more detail than operators have previously been required to report.

How InterAct Can Help:

  • Assist with the conversion and QC of well history and production/injection data into WellSTAR. InterAct has WellSTAR trained specialists to assist you.
  • Prepare NOI and UIC applications and facilitate the multiple agency review process.
  • Manage the initial data upload and transition to WellSTAR, or act as an operator agent and provide ongoing support, ensuring DOGGR reporting deadlines are met.

Oil Spill Contingency Planning - SPCC and C-Plans

DOGGR, EPA and Office of Spill Prevention and Response (OSPR) require operators to maintain spill contingency plans for their facilities. Plan requirements include facility maps, emergency procedures, secondary containment calculations, discharge prevention and countermeasures, piping and tank inspections and testing, and employee training. OSPR Spill Contingency plans (C-Plans) are required to protect inland state waters and sensitive resources. Operators must calculate potential worst case spill volumes and demonstrate  financial responsibility.

How InterAct Can Help:

  • Prepare comprehensive spill plans, develop spill prevention and mitigation measures, identify and evaluate environmentally sensitive areas, and train operators in preparation for oil spill response. InterAct is an OSPR-approved consultant.
  • Determine whether your oil-related facility is located near “Waters of the State” or where an oil spill could impact State waters, and whether you may qualify for an exemption.
  • Prepare technical documentation for exemption requests.
  • Identify and develop protection strategies for any sensitive environmental areas using our in-house GIS, ESRI and CNDDB databases.
  • Take field measurements and calculate containment volumes; determine drainage volumes and areas that could be impacted.

Oil Spill Reponse Training

OSPR requires to operators to conduct emergency drills to ensure their spill plan will function in an emergency. Operators are required to contract with an OSPR rated oil response organization (OSRO) to ensure adequate personnel and equipment are available to respond to all spill plan needs. Drill requirements include assembling the spill management team, coordinating with OSROs, planning for media interface and conducting site safety assessments. Drills must be scheduled with OSPR and operators are subject to unannounced drills to test their spill plan’s effectiveness.

How InterAct Can Help:

  • Provide on-site operator and contractor training on OSPR drill and exercise requirements. InterAct is an OSPR-approved consultant.
  • Develop an incident command system and identify key operator / contractor  personnel to fill spill response team roles.
  • Develop tabletop exercises and conduct mock oil spill drills to assess operators’ response capabilities and potential gaps, and provide recommendations, checklists, and training to fill identified gaps.

DOGGR UIC Permits & US EPA Aquifer Exemptions

A renewed and rigorous enforcement of regulations for US EPA Aquifer Exemptions by DOGGR in its Underground Injection Control (UIC) program will require additional evaluation and quick action from oil and gas operators desiring to continue injecting into existing disposal and enhanced oil recovery (EOR) wells or apply for new injection wells. A significant part of UIC compliance is providing DOGGR with the supporting documentation for evaluating zonal isolation within the Area of Review (AOR) surrounding the injector well.

How InterAct Can Help:

  • Evaluate groundwater in the injection area and determine potential for beneficial use.
  • Prepare necessary supporting documentation to justify Aquifer Exemptions.
  • Provide storage, tracking and analysis of detailed wellbore data via database-driven well diagramming system.
  • Conduct detailed reviews of well history and mechanical condition, with representation of pertinent data in a wellbore diagram, allowing easy review by DOGGR.  InterAct has completed over 10,000 well histories.
  • Provide preliminary isolation review of all wells, allowing remediation of potential problem wells prior to application submittal.
  • Work with DOGGR engineers to ensure the best outcome with the U.S. EPA.

DOGGR & Cal/OSHA Pipeline Management Plans

Both DOGGR and Cal/OSHA require operators to maintain a Pipeline Management Plan that outlines the inspection and maintenance program the operator will follow to ensure all piping has sufficient integrity for the intended service of the pipeline. Operators are required to rank pipelines by risk category and follow specific inspection schedules for each type of pipeline. Operators are also required to document design and operating pressure, construction data, inspection history, testing history, leak history and repair history for all pipelines.

How InterAct Can Help:

  • Prepare comprehensive inspection and maintenance plans that meet DOGGR, Cal/OSHA, CA State Fire Marshall, and DOT Pipeline Management Plan requirements.
  • Determine pipeline risk rankings and develop an inspection program.
  • Assess pipeline inspection results and advise on corrective actions.
  • Provide personnel training in the various inspection, testing, and recordkeeping requirements of the pipeline management plan.

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