Recently, operators were notified that Statewide Rule 14, Plugging, had been revised effective September 14, 1998. Since then, a number of questions have been received regarding application and interpretation of the new amendments. These questions generally center around the requirements of Rule 14(d)(12) which require emptying and removal of certain equipment within specified time periods after a well or wells on a lease are plugged.>
Following are responses to some of the frequently asked questions about Rule 14(d)(12):
Question: What types of facilities are covered by the provisions of Rule 14(d)(12)?
Answer: By its terms, Rule 14(d)(12) applies only to equipment located on Commission-designated leases which include production leases as well as disposal and injection well facilities. Rule 14(d)(12) does not apply to facilities such as gas plants and compressor stations.
Question: Is purging a flowline with fresh water sufficient to meet the requirement of Rule 14(d)(12) that flowlines that will not be actively used in the continuing operation of the lease be emptied within 120 days of plugging?
Answer: Yes. The term "empty" as used in Rule 14(d)(12) means empty of potential pollutants such as crude oil and produced salt water. Purging a line with fresh water, air, inert gas, or natural gas is sufficient to meet the "emptying" requirement of Rule 14(d)(12). If the line is purged with gas, the line must be left in an unpressured state. Purged materials must be managed in accordance with Commission regulations.
Question: What is meant by the terms "related surface piping" and "subsurface piping" as used in Rule 14(d)(12)?
Answer: The terms "related surface piping" and "subsurface piping" as used in Rule 14(d)(12) refer to piping between pieces of equipment located at any fluid collection or treatment location. Such piping would include piping between and among headers, manifolds, separators, storage tanks, gun barrels, heater treaters, dehydrators, and any other equipment located at a fluid collection or treatment location. The terms "related surface piping" and "subsurface piping" are not intended to refer to lines such as flowlines, gathering lines, and injection lines that lead up to and away from any such collection or treatment location.
Question: What happens if cover over subsurface piping buried more than three feet below the ground surface is removed in the future such that the piping at such future time is buried only two feet below the ground surface? Will the operator be expected to come back and remove that piping at such future point in time?
Answer: No. Compliance with the provisions of Rule 14(d)(12) will be evaluated on the basis of conditions as they existed at the time of equipment removal.
Question: Does the 120-day clock start with the plugging of the last well on the lease? Or does it apply every time a well is plugged?
Answer: The 120-day clock for a well starts when that well is plugged. The provisions of 14(d)(12) do not apply in the case of any well plugged prior to September 14, 1998.
Question: Must a request for a 120-day extension be in writing?
Answer: For record keeping purposes, the request should be made in writing and should state the reason why an extension is needed.
If you have additional questions regarding Rule 14 requirements you may contact your district office, the Assistant Director of Compliance at (512) 463-6829 or the Assistant Director of Well Plugging at (512) 463-6831. You may obtain a copy of the rule from your district office or the Railroad Commission in Austin (512-463-6882). Copies of proposed and adopted rules may also be downloaded and printed, via the Internet, from the Secretary of State; a link to that site is available through the Commissions website: www.rrc.state.tx.us. When accessing a rule electronically, check the "Source" section at the bottom of the rule to make sure it is the most up-to-date version.