Monthly Archives: August 2016

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All wells are snitches: lessons learned as an Oilfield Pumper

Okay so, there are just some things in the oilfield that are known by all of us, but that we really don’t talk about.

One of those things is the silent rule that after a workover rig has been up on one of your wells, you step carefully around your equipment and stock tanks. New pumpers have discovered this sometimes in a traumatizing way when, in a moment where they really need a rag and realize they used their last one on the last well, they spot one on the ground…you know, over there by the meter house. So they run over and snatch it up and attempt to use it only to find that, uh, it’s been already used and not on any equipment owned by the company, if you know what I mean.

You see, when I was starting in the oilfield, there was no guidebook. I would have given a month’s salary for something like The Lease Pumper’s Handbook. I thought I would take this book on chapter by chapter and discuss a little of it with you every couple of weeks about what is contained in each chapter.

This week we’ll talk about Chapter 1 –Responsibilities of Employee and Employer.

If you don’t read any other chapter, make certain you read this one. It contains at lot of the information that you would think someone would tell you but don’t count on it and here is why:

While this might sound a little negative, there is a very competitive culture that exists in the oilfield. This is true in both contract lease operating and what we call company pumping.

Don’t get me wrong; if I needed help really bad, the guys I worked with would mostly do the right thing and come give me a hand. But I could be sure that when they got together later, they would be discussing how stupid I was over coffee.

Anyone in the business very long learns this reality. It doesn’t mean they’re not your friends. It just is what it is and the sooner you accept that and don’t let it distract you, the happier a pumper you will be.

But when you are the FNG (I’ll let you figure that acronym out but the last two words are ‘New’ and ‘Guy’) it can be pretty uncomfortable.  There is a culture among us pumpers to let you squirm instead of telling you how to do something.

So, often other experienced pumpers will make a guy who asks a lot of questions feel dumb and eventually the guy gets the score and doesn’t ask anyone for any help on anything. This is especially true for company pumpers.

Frankly, it is one of the most dangerous aspects of the oilfield social culture and I still work hard to end it. I have looked into statistics on this tendency and found it to be responsible for up to 42 percent of accidents.

Nevertheless, when I was new…I suffered from this kind of culture and had it not been for my best friend, a 35 year veteran pumper Evelyn Dixon, I could have not only failed but been badly injured.

Evelyn served as my personal “Lease Pumper’s Handbook”.

So, Chapter 1 can help you past some of the most basic questions like who pays for supplies? What all are you supposed to do when you get to each lease? Who buys the pencils? What tools you will need to be successful out there. Anyhoo, read it you will be glad you did.

It can be a mine field out there!

So, back to my first and only lesson about being extra careful after workover rigs have been up on my wells. You see, some companies graciously allow you to take your dog along with you when you are pumping.

This privilege was so high on my list of benefits that they probably could have paid me $1 less per hour than they guys and I would have been happy about it. My dog Nipper was a Cairn terrier – you know, think Toto in the Wizard of Oz.

So she had this really long, wiry hair. She was a wheaten color, so her hair was really blondish. At every lease I operated, Nipper jumped out of my pickup and ran around the lease looking for rabbits to scare up and basically just living a really good life because she got to go all the time. She loved it and it helped me because my days as pumper are long and I am often in remote locations for long periods of time.

It was a Monday and my boss had told me that they had a rig on one of my wells over the weekend and that it was back up and running, but that I should do a report on it right away when I got out to the field.

So I pull up and it’s still pretty cool out, like 45 degrees and Nipper is raring to go. I checked everything out and called Nipper and here she came bounding toward me as fast as she could.

I really wasn’t looking at her, I was just holding the pickup door open so she could get in. And, she jumped into the seat of my pickup covered from her wiry little head to her wiry haired little tail in fairly fresh human poo. I mean, when she decided to roll in this, she took her job very seriously and it was caked even on her underbelly.

oilfiled pumper rules

Now, this dog was not experienced with riding in the back of a pickup and worse, mine was a flatbed. I was about five miles from our central stock tank battery, where I knew I could find a water hose. But I didn’t know how I was going to get her there without the risk of her jumping off the flatbed and hurting herself or what seemed worse at the moment, having her in the cab of my truck.

Times like this are when you are really glad that you supplied yourself with a box of rags and plenty of disposable gloves, something I never leave without now. So I started trying to clean off as much as I could with rags. I then found a piece of wire and used that as a “leash” of sorts and tied her to the headache rack so she couldn’t fall of the pickup and then I drove to a water hose. It was a cold bath, but we managed.

Lesson learned. I now was firmly in possession of that bit of knowledge about some of the more basic things one must consider after other personnel have spent a couple of days and nights on one of your wells. And now, you know it too!

Remember this; all wells are snitches

Okay, so as a pumper, you get to choose what kind of pumper you will be. In Chapter 1 of the Lease Pumper’s Handbook there is a part that talks about honesty. The section covers the importance of correct information being recorded onto your daily books and other basic truths that need to be told; even when you don’t want to.

For a new pumper, this may seem simple. Yet when you get out there you will eventually be faced with a serious mistake and you will likely be tempted to cover it up. I implore you, please do not do this. Obviously, in the first place, it can be dangerous. If you have shut something off that was supposed to be on for instance, and someone comes behind you to work on the well and you don’t tell the truth, it can hurt someone in some cases.

I often have said the oilfield offers more opportunities for the average field worker to lie than any other industry I have seen. So, if you got stuck on a well that was not operating properly on a day and didn’t make it to some of your other wells, tell them that. No, I can assure you it will not be popular. But tell them anyway. Because there is another ugly truth about the oilfield and that is, if you lie, your wells will tell on you – without fail, they will reveal your mistakes and lies and I swear to you, you will think the horse’s head is laughing at you.

Perhaps the most obvious of these examples happened to one of my fellow pumpers; let’s call him Kyle. Kyle was young. His father was a resounding success in the oilfield and owned a business in the industry in a nearby town. But Kyle just didn’t have the drive his father had. So, it wasn’t four weeks after we had hired him and we began noticing that Kyle was completing his pumping days far, far sooner than we all did.

That said, Kyle never seemed to have a well go down or one that was not producing. His books were perfect. If a well was supposed to usually make 35 mcf of gas, by golly it made 35 mcf of gas.

As many pumpers know, and so did Kyle, along with our digital readout meters, some wells also still used paper charts. You know the ones – they show every minute of activity with a red pen that shows gas differential and a blue pen line that shows static pressure. The paper chart is something I always check because I know their proclivity to write a friggin novel about everything you’ve ever done wrong.

And…these eight day charts, well, you have to remember to change on the 1st, 9th, 17th and 25th.

But see, Kyle didn’t understand the significance of those charts because he was new. So after at least 7 days of skipping a certain well, he went by to pick up the chart and found that the day after he had changed the chart, everything stopped.

The chart was still moving but the needle showed zero gas had been sold from that lease for six full days. Being so young, Kyle didn’t even really understand the marks on the chart and so happily handed it in and then pencil-whipped yet another day into his fraudulent books. Job well done, right.

Now, as you smart readers have already guessed, this did not jibe with his glowing reports on the well over the last several days. And those get sent to our corporate office daily. Those charts were laughing at Kyle.

Instead of learning from that mistake, Kyle just got a little better at covering his tracks until one day the boss called him around 3 p.m. and asked him, “Hey, have you been by the “Harper 3-1” yet today?” Kyle nimbly lied, because he had become quite comfortable lying and said “Yes” that he had been by the well.

The lease had a compressor on it and the boss said, “How’s that compressor running?” Again, Kyle lied and said, “Great, running really smooth.” The boss said, “Well, that’s funny because I’m standing right here with it and the supply gas has been turned off and according to the chart, it hasn’t sold gas in three days.”

Kyle didn’t make it in the business. I think the moral to the story is painfully clear. First, do your job. If you are a person who tends to shortcut things, just don’t get into the business. Second, if you forget to turn on or off a valve (you most certainly will make this mistake at some time in your career) just own up to it.

It you don’t, eventually your well will tell on you.

By Rachael Van Horn

AKA Wench with a Wrench

Oilfield Pumper Etiquette: Testing one’s manhood with the Fairbanks 503 “slave master”

Okay so, when my dad starts a project, there is no lunch, no water, no anything until we have finished the job. I feel certain it is today, why I am always the last pumper in the field – and the dirtiest.

So anyway, it was a long time ago – a hot summer in Oklahoma and we had been suffering for some time without rain. I was about 16-years-old (I’m 54 now) and my dad woke me early on a Saturday morning. We were building fence.

On this day, we were digging post holes with a two-man auger he had proudly purchased at an estate sale. You know the kind; a man and a woman in this case, on each side of it holding it steady as it grinds its way into the ground.

So the digging began and the work was grueling. The Oklahoma red dirt was packed hard – I mean land a C-5 cargo jet on it hard or tear up a Tri Cone Drill Bit hard. You get the picture.

Anyway through the day, the holes were getting dug. However, I had noticed that when my dad stopped that auger he had to push a wrench that had a rubber handle on it onto the spark plug. I really hadn’t noticed it much up to about 4 p.m. I was hot, I was thinking about going out that night with my boyfriend Roger and I didn’t much care about how he had rigged that damned auger to stop.

And then it happened…

We had started on another hole – the last one for the day. The dirt seemed even harder and it just felt like that auger was spinning around, bouncing on concrete. All of a sudden, it hit a rock and bounced out of the hole.

It was still grinding full speed (the speed lever was also broken) and it started augering up my father’s leg. It was like a dragon chewing him up. I had to do something! I had to act! I just knew it was going to auger my father in half if I didn’t!

And so I did it. I just grabbed a hold of that spark plug with my whole hand. The current coursed through my hand and up to my shoulder. But that bit of insanity worked and the auger died.

I was bending over holding my arm and I looked up at my father, who was bleeding but not profusely. His plants were down around his ankles. He was wearing boxers with pink flamingos on a grey background. I’m sorry but I just can’t unsee that.

He pulled his pants up and laughed. I said, ‘Oh, you thought that was funny huh?”

He said, “You should have seen the look on your face when you grabbed that spark plug.”

I said, “Yeah, nice stop-switch dad. What’s wrong with it?”

He said, “I don’t know. It’s just broke.”

This week, in that wondermous blogosphere on Greasebook.com, read and enjoy the “It’s Broke” edition – Great stories about people in the oilfield who found themselves with equipment they couldn’t diagnose, yet found work-arounds to keep it running.

Now, when Greasebook reached out to me and asked me write some material for pumper and oilfield executives, they thought it’d be a wonderful idea to work and write from the “Lease Pumper’s Handbook” – expanding on the topics contained within the text and throwing in color and insight where necessary.

The handbook is a guide put together by the Oklahoma Marginal Well Commission offering great guidance on all things pumper.

I mean, this thing even includes some of the things that are never really talked about, but are sort of pumper etiquette items that, if not handled properly can get you blackballed by other pumpers. It’s a must read.

So for you pumpers who find yourselves wondering why your gas well made zero even though your plunger seemed to be coming up all night, give it a read. It will help you with some possible causes. It includes everything from pencils to pumping units in there.

Through the next several blogs, I will be dragging some fun subjects out of that Lease Pumper’s Handbook and sharing some zany and I hope enjoyable stories with you that almost certainly would not have happened if we would have had the handbook.

Snap

So, this first story is about one of my pumping units with a Fairbanks 503 engine on it.

While there is a ton of great information in the Lease Pumper’s Handbook, this is one of the painful lessons I had to learn without a handbook. There are no individual instructions anywhere on how to run pumping unit engines. They are like women, I am told – all pretty temperamental if you don’t take some time with them.

The Fairbanks 503 is an ancient, slave master. It can be a terribly hearty engine though, that can take a lot of abuse and still run. And that is why it is still in the field today. But if you let it go down, even for one minute, you will live to rue the day.

Me in front of an old, Fairbanks 503 "slave master" ;-)
Me in front of an old, Fairbanks 503 “slave master” 😉

On this particular engine, the clutch to engage the pumping unit, once you have the engine good and going, is a round wheel about 12 or so inches in diameter. You have to grab that wheel and push the clutch plate straight forward away from your chest to engage this clutch. It can really test your manhood, especially when you’re a woman.

Most other clutches, such as on the Continental 106s and 96s as well as the Ajax, the clutch handle is just that; a long handle that sticks up where you can grab it and apply some leverage to the situation.

On this particular Fairbanks 503, the clutch was really tight. I mean this thing felt like you were trying to jab two inch pegs in one inch holes. One day, after fighting to start this bad girl for about 30 minutes, I finally got her going again and was pretty tired from physically kick starting that engine. (Did I mention how huge they are?) I walked around to the clutch wheel and gave it a shove. The pumping unit weights started going and all appeared ok, but I knew it wasn’t. I could smell the clutch plate burning.

I’m really tired, right? And so I put all of my upper body strength into this and give it a mighty shove. Nope. Sweat is pouring down my face. I’m starting to lose my religion. I’m getting frustrated. I try again. Still no dice.

So now I’ve worked for 30 minutes getting the stubborn engine started and now it won’t matter if I cannot get this clutch pushed in because I can’t just leave an engine running without running the pumping unit.

Now, I know all the men are thinking, “Geesh, this is why women shouldn’t be in the oil field.”

Well, you aren’t alone. Because that is what my boss said when I called him and politely asked (this was a new well to me) if there was anything special about this clutch that I should maybe know. I won’t tell you how that conversation went.

So I admit, I went a little crazy after I got off the phone with him. I ran around the outside of the entire pumping unit screaming and yelling , shaking my fists to the heavens.

I came back to the spot, looked around to make sure no one had seen my lapse in sanity and focused all my attention on that clutch. I then played around with it for about two more minutes just looking at it and feeling of it gently – you know, getting to know it. And then I saw it.

I realized that it wanted me to snap it in at just the right place where the weights were on their way up. I snapped it right in. It did have a secret to it and I had figured it out.

Fast forward four weeks later. My boss had gone by to place a new rocker arm on the external valve on that engine. He restarted it and stood there on the phone before engaging the unit talking to me. He was pretty satisfied with himself and was going on about how he was pretty muchly all that was man.

He had “only called to let you know what I had done on the pumping unit just so you could mark it in you book.”

I said, “Roger that. Consider it marked.”

A full hour later, he called me. He was out of breath and sounding pretty disgusted.

“Is there something you can tell me about this clutch?”, he asked.

I smiled to myself. “Nope, you’ll just have to man up.”

He never did get that clutch in. I had to go back and put it in for him.

Aka, Wench with a Wrench

Confused about the EPA’s New Methane Regulations?

So were we!  So, we decided to do something about it and see how the folks here at GreaseBook might be able to help!
First a little background…
In May 2016, organizations like the National Stripper Well Association (NSWA) among others fought for an exemption of small producers from the effects of the new methane control rules, but in the issuance of the final rule, the exemption for low-producing wells was eliminated.
However, on June 3, EPA published its newest oil and natural gas production regulations – Subpart OOOOa (we found this a helpful summary when trying to understand both new and amended requirements for operators…)
This significant and radical change was unannounced for most producers, and they have been struggling to comply since the announcement.
We found there was also an EPA Regulatory Impact Analysis that stated that within 60 days, EPA would issue a “Small Entity Compliance Guide” to help stripper well producers comply with the rule.
Unfortunately, at the writing of this post, we are nearly 80 days from the May 12 announcement of the rule and 60 days from the June 3 Federal Register notice and the EPA implementation website contains no compliance guide. And, as unprepared as small producers were to be included in this rule, the EPA is as equally unprepared to give us guidance.
That said, last week the Texas Alliance of Energy Producers put together a informative webinar for members of their organization addressing rules and policy changes.
From what the Alliance states, the EPA’s new rule is directed at new, modified, and reconstructed sources, but the action also includes an Information Collection Request that the EPA will send to over 22,500 oil and gas companies to gather data on existing facility sources.
Now, enter Katie  Carmichael (Texas Alliance Public Affairs Consultant),
John Tintera (a regulatory expert, licensed geologist, and Executive VP of the Texas Alliance), Jim Standley (Policy Advisor at Texas Alliance of Energy Producers), Lee Fuller (President of Independent Petroleum Association of America), and Bill Stevens (Alliance Chief Lobbyist).
GreaseBook Sidenote: All info below has been transcribed for you. However, if you’d rather hear the meeting in it’s raw form, here you go!! (slides attached below 😉
Enter the Alliance
Katie: At this time, I’d like to briefly introduce our presenters. Joining us today is [inaudible 00:00:15] Executive Vice President John Tintera. Mr. Tintera has been former executive director at the Texas Railroad Commission and a certified geologist.
Also lending their expertise is [inaudible 00:00:27] senior policy advisor Jim Standley and [inaudible 00:00:28] Bill Stevens.

 

We’ll also hear from a special guest President of Independent Petroleum Association of America, Lee Fuller, who will provide update on methane rule litigation [inaudible 00:00:40] and commenting activity. Without further ado, I’ll turn it over to the experts.

Joe: Thank you, Katie. First, a little bit of background. I appreciate everybody joining today in our very first methane webinar with specific to the rule that has come out, the requirements associated with that. This is the information collection request that will form the basis for existing sources.

The rule that has come out recently was for new and reconstructed or recently constructed sources. So this rule, if we go from ICR ultimately to a rule that’s going to be a degree of magnitude more difficult to meet.

OOOOa

EPA wants a comprehensive methane regulation from all existing sources as part of [inaudible 00:01:38] initiatives. They want to know how the [inaudible 00:01:41] are configured, installed, being used, to monitor the level of staffing that’s needed, the time to that. John will take us through some of the detail data requirements here in a little bit. Your response to the ICR is mandatory, non-confidential, and maybe most importantly the information submitted can be used for enforcement purposes.

We’re on a short fuse for this. All of the comments have to be pulled together and submitted by August the 2nd. The actual process is that that’s the deadline to get it to the EPA, the EPA then has to take that and push it to the Office of Management and Budget for review because the impact is over $100 million. It will then be either commented on by the ONBA, or the EPA will respond to our comments and issue the rule.

So, the timing going forward after August 2nd is going to be a little bit up in the air but we’ll keep you informed.

Just to let you let you know, as Katie mentioned, we’re pleased and privileged to have Lee Fuller from IPAA leading a coalition of a group of industry associations on both the litigation of the rule and the submittal of the information collection request.

Screen Shot 2016-07-28 at 2.33.19 PM

As a little more background, estimates in terms of what…and these all come from the EPA, in terms of their feeling of what it’s going to take to get this done. So, you got two phases that they’re looking at.

Phase one goes out to everyone. They’ve accounted for something on the order of 22,500 companies that are going to get the phase one data request. Phase two goes to their so-called statistically accurate sample of about approximately 3,500 companies. The coverage based on their estimates you can see is almost 700,000 wells, 5,000 gathering visiting stations, almost 700 processing facilities, and almost 230,000 hours to complete, with of the cost of completion at over $40 million.

Screen Shot 2016-07-28 at 2.35.21 PM

We will be challenging all of that.

In some cases, historically, to EPA, has always presented estimates that benefit themselves and typically turn out to be very wrong. I’m going to turn it to John now to talk about… I’m sorry, let’s talk a little bit more about the ICR. No, I think it’s John’s turn right now.

John: Yes, this is Johnathan Detiera. And, Joe, thanks for the overview. Let me just recap a little bit of this.

What you have is a rule that’s in place, and that rule is in place to modify the civil use of new facilities that are coming online. It’s a very burdensome rule and it currently exists. [inaudible 00:04:45] have an information request. An information request we expect to have a short fuse. That will be even more information than what you would have to do to comply with the rule that’s currently in place. Then we fully expect that once the EPA gets this information they will then try to modify the rule that’s in place to capture every possible existing facility in extremely burdensome, regulatory effort that will provide the federal government more information on the oil field and oil field activities that any state currently possesses. So, the impact and significance of this could not be underestimated.

I’m going to take you deep into the womb of the information request. Now, I wanted to explain it to you using EPA’s own forums of what’s coming down the road that you will likely have to fill out and which we think is going to be very difficult, if not impossible, to try to stop or slow the EPA on this effort.

You can see there’s an instruction form in front of you in green. Please note that it’s got four steps to it, and the first two steps is what everybody’s going to have to fill out.

Screen Shot 2016-07-28 at 2.36.31 PM

 

You’re going to have to have at step one, complete a parent company information. And that information is going to be for the highest level, the majority corporate owner. And then, in step two, you’re going to have to complete operator information. That operator information is going to be for the people that are actually managing, handling, or delegated by the regulations they work under as the operator of the facility.

So, if you’re a subsidiary of the parent company that you’re a subsidiary to, will be involved. If you’re a contract operator, you’re going to have to be working with your clients and your companies in order to make sure that the parent companies, etc., are fully represented.

I think we are going to see some confusion as people try to sort out what they need to do in step one and step two, but again, this is on track, and the common period is rapidly approaching. We will have comments.

I’d like you then go on to step three which begins the phase two process, which is going to be given to a statistically significant number of companies. We do not know how many that’s going to be, and I think that it will cover a high percentage of the number of oil and gas operators and companies that are currently in the business. This facility-level information request is going to be for all your facilities. I’ll be talking and showing you examples of [inaudible 00:07:29] facilities later. And then, you will have a step four. That’s where you have to complete and sign the acknowledgment sheet.

This is an example of the acknowledgment sheet that’s coming up.

Screen Shot 2016-07-28 at 2.39.19 PM

Please notice that there’s going to be two boxes that are going to have to be checked, and then, a signature page. This could be considered an [inaudible 00:07:48] by some, which means that it’ll have some legal standing. It means that the people that check these boxes are going to be taking the responsibility that they have the authority to submit this information and that they know that this information is accurate and correct. We highlighted that in a previous conversation. I’d like to emphasize again the importance of making sure that the people that sign this page are well aware of the obligations that we’ll put them under with the federal government.

With [inaudible 00:08:22] we step into some of the facility-loaned information that they’re going to have in part two.

NSPS OOOO and OOOOa Rules

This is going to go through what the EPA is considering the omission source specific information. We’re going to have a series of slides that are going to have the EPA definitions. The facility itself is going to be focused on the overall facility and with some definitions of what the facility can entail. And at the same time, it’s going to also require detail-specific information of the equipment that’s on the lease.

For example, well sites and pads are going to be required to be included in the information, so the number of well sites, the number of pads that are associated with this are going to have to be tabulated and accounted for. You’re going to have to account for tanks and tankage. You’re going to have account for separators. At the same time, any [inaudible 00:09:22] devices are going to have be separately handled and counted for. You’re going to have acid gas removal units to be highlighted and identified and submitted. Dehydrators, you’re going to have to have all your compressors, including vapor-recovering units that are going to be highlighted. You’re going to have to have any leaks that are detected to be reported in this. If you do a blow-down in your facility, you’re also going to have to have blow-down information. Please note that flares, conductors, and vapor recovery units that are used at the facility are considered patrol devices. Those will also have to be handled and highlighted.

The way that you’re going to be relaying this information is through an Excel spreadsheet to the Environmental Protection Agency.

Sidenote: Savvy Operators note that ALL information required by EPA today or in the future could easily be collected by the GreaseBook app…

You’re going to be having a facility ID number, a facility name and description, you’re going to have to [inaudible 00:10:16] and of course, most are no 24 hours, you have pumpers that go [inaudible 00:10:22]. The electrical status distance to the nearest field office, other distance information, what the type of production is, what the types of liquids is coming, the number of producing wells, the number of capped or abandoned wells that are in place. They are going to want hydro-fractioning information of the wells that have been hydro-fractioned.

NSPS OOOO and OOOOa Rules  Screen Shot 2016-07-28 at 2.41.08 PM

You can see that this a long reach and extensive document of request that is going to be very repetitive to fill out, but it’s also going to have to be very specific because [inaudible 00:10:52] has all of these in common. Everyone one of them has some sort of variability associated with it.

In that regard, they have tried to indicate that there is an adjacency. So, definition, that will demonstrate how you can try to combine equipment into one portion [inaudible 00:11:10]. The simplest way of putting it in terms of equipment is within a quarter mile and connected, then you can comp that as a single source of determination. You give a series of factors that are include through there. We think that this is going to require some fairly diligent efforts by your [inaudible 00:11:31] and your mappers to make sure that the facilities, that they are positioning and locating the location of in the field far within this quarter mile [inaudible 00:11:41] that you have proper placement. So, this will require likely a new date gathering.

I’d like to now introduce Bill Stevens, our chief lobbyist for the alliance. Bill is going to go through how some of our political leadership and regulators are reacting to this. Mr. Stevens.

Bill: Thanks, John. Last month, the Railroad Commission issued a letter to the Texas Attorney General requesting his office to consider filing litigation related to the EPA’s methane rules.

As you can see from this press release, the Railroad commissioners have strong opinions regarding these new rules. The commissioner [inaudible 00:12:17] is saying, “These overbearing regulations accomplish nothing other than encumbering business, polluting our economy, and cutting jobs.”

Commissioner [00:12:25] points out that the methane emissions have dramatically fallen during recent energy growth thanks to technology and industry leadership on the issue.

And commissioner [inaudible 00:12:34] adds that the rules will harm Texas energy producers and accomplish very little in terms of protecting the environment.

NSPS OOOO and OOOOa Rules

In response to this letter from the Railroad Commission, the Texas Attorney General is preparing to file paperwork for a notion of reconsideration of the rule. It will be signed on behalf of the state of Texas, the Railroad Commission of Texas, and the Texas Commission of Environmental Quality. The motion will be filed and should be placed [inaudible 00:13:02] the deadline of August 3rd. The alliance scene has worked with each of the commissioner’s offices, and both executive directors of the Railroad Commission and TCQ are urging them to act.

We appreciate the state and the leadership of these agencies and recognize the debilitating and unnecessary overreach by the federal government with regards to methane production.

Joe: That was very helpful, Bill. And I appreciate that analysis. Now, Jim Standley (Policy Advisor at Texas Alliance of Energy Producers), if you would introduce our guest speaker, Mr. Lee Fuller (executive vice president of the Independent Petroleum Association of America).

Jim: Will do. Was Mr. Fuller successful to get even on the phone?

John: Yes, he is.

Lee: Can you hear me?

Jim: Yeah, great.

Lee: I’m on the phone.

Jim: Yeah, I [inaudible 00:13:48]. I wasn’t, so I’m happy you were.

Joe: Jim, [inaudible 00:13:54].

Jim: With that, I would like to introduce Mr. Lee Fuller, President of the Independent Petroleum Association of America. And the gentleman that has the tip of the spear and leading the effort on the methane rule litigations and to stand the ICR combatting activities. And with that, I’d like to turn it to Lee.

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Lee: Well, thank you very much, I appreciate it. I clarify that I’m the Executive Vice President. My president of…Barry Russell is probably with…they want me to do that. But I do appreciate the chance to talk to you, to give you an update on where we are on a variety of these issues. I’m going to start with the methane rule litigation.

As the fires start to strive, there’s a very tight clock on actions to get a litigation initiated on that. We have to file by Tuesday of next week, August the 2nd. We have a group that’s been put together, [inaudible 00:14:54]. It’s probably generally [inaudible 00:14:59] the leader of the Texas Alliance as one of the many state associations that’s participating with us as well, along with some other national [inaudible 00:15:08] like the American Exploration & Production Council.

It’s basically a group of associations that are all representing independent producers. We wanted to begin the litigation and the reconsideration process where we would have an ability to be a clear and direct voice for independent producer issues since many of the challenges with these rules, they fall much more heavily on smaller operations than on larger ones. But nevertheless, everybody in the business is being affected by it.

The attorney that has worked with the independent producer group on fire regulations, notability, the subpart [inaudible 00:15:56] regulations that were released in 2012 and also worked with us on comments from [inaudible 00:16:03] array, and control technique guideline, [inaudible 00:16:09] of EPA as far as last year. Then they finalized the [inaudible 00:16:15] regulations in June of this year, where we’re now facing a litigation.

We’re looking at tracking two paths, with respect to [inaudible 00:16:25]. Why is the petition for review of the regulation itself, and the second is petitions for reconsideration of specific parts of it.

There’s a tactical question that we’re dealing with there and deciding what issues are abroad and speaking [inaudible 00:16:42] for litigation and what areas do we think we want to focus on trying to get EPA to address a reconsideration process.

Part of the tactical decision there is that if we pursue both at the same time on a particular issue, its opportunity to be litigated gets diminished because of a petition for reconsideration. And secondly, we expect to see a consolidation with other petitioners for review that can limit the size of the brief that can be filed. So, you don’t want to lose your ability to raise your issues as strongly as possible in the litigation by having too many issues limited by the number of words. It’s a legal dynamic in these court cases that we always have to grapple with.

So, the action we have to take by next week is really just to make the courts aware that we intend to seek petition for review and they will give us a schedule for a subsequent further information, and we’ll have to file.

Simultaneously, and on the same day, we have to consummate comments on the ICR proposal that EPA has published. The fire slides went through a lot of specifics with that. I apologize, but they already covered this other part I would mention now. But this is all coming under the paperwork production act where EPA has to get authority not to stand out this information collection request.

What we’re completing next week is a 60-day comment period on the draft ICR proposal. After that, EPA will make possibly modifications to the proposal and then send it to review at the office of Management and Budget. It has a 30-day comment period there. We’ll be filing additional comments depending on how EPA responds to the comments that are filed next week in the ICR. And then, Office of Management and Budget will make the decision on whether to allow EPA to send out the ICR.

EPA’s target is to try to get this ICR transmitted by October 30th, or no later than October 30th of this year in order to try to get responses back…

Joe: Lee?

Jimmy: Okay. Well, thank you very much. I suspect we have a technical difficulty there with Mr. Fuller, but we do thank you for what he shared with us. I hope you all heard that last date, October 30th is the goal for the EPA to have this information request out and circulating, and possibly even back. That is not our [inaudible 00:19:53] and it is something that I think we just drew our conclusions that we have. One is that what we’re presenting to do with the information request is just the beginning of what we think will happen because there is a rule in place, it’s going to require new and modified facilities to do these surveys, and once those information requests, which is going to be coming in the fall, is in place, we expect the rule to be reworked.

At the same time, the actual rule itself is going to require the use of [inaudible 00:20:25] cameras, or sniffers, and all the equipment that you are listing in this information request is going to be checked by the EPA to determine whether you are actually stiffing the right equipment. So, what you say in the first part is going to be important down the road, and you’re going to want to get it right.

Information collection request

Finally, the EPA have verbally informed us that they will consider penalizing operators who do not comply cooperatively with the information collection request. They are going to use their environmental [inaudible 00:20:55] schedule for doing that. Our understanding is that it could be up to $25,000 per day.

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With that, that concludes our presentation. We’d like to highlight to you the helpful links that we have up here. They should take you to some of the information or slides that you saw today.

I’d like to thank Mr. Fuller, I’d like to thank Mr. Stanley, I’d like to thank Mr. Stevens and Katie Carmichael. If you have any questions, please feel free to send them to us and we’ll be happy to try to respond. Katie, any final words?

Katie: No. If you all have any questions, feel free to email me at [inaudible 00:21:30] @gmail.com, but please take a minute to respond to the evaq that I’ll email tomorrow. That’s all. Thank you.

Jamie: Thank you.

Information collection request