American Oil and Gas Reporter - June 2016 - 109

quiring operator qualification (OQ) training
for anyone working on or around meters
at well sites, Gill says. He adds that National Fuel Gas, the lead utility in western
New York, is working with IOGA NY to
provide that training to producers and
operators.
"The training consists of a session of
computer training online, and then one
session of hands-on instruction. National
Fuel has been very good to work with,"
Gill applauds.
He adds that OQ was supposed to be
done by June 1, but because voluntary
compliance had been low, he expected
that deadline would be extended.
There have been no significant reported
problems or incidents involving meters
in the recent past, Gill says. He characterizes the OQ program as part of PSC's
increased oversight of pipeline maintenance and safety. He points out that IOGA
NY does have some issues with the program.
"One of our concerns is that PSC is
saying anyone who touches this equipment has to be qualified," Gill describes.
"Companies used to be able to hire summertime help to paint tanks and wellheads. Those people, who work around
wellheads and meter sets when they are
painting, thus have to be trained. There
are cases where gas wells are in the
yards of some homes. Often those homeowners are good enough to mow the
grass around the wellheads and meters.
But, homeowners technically cannot do
that anymore, because they are working
around industry equipment and they are
not OQ trained and certified."
Gill says National Fuel's training is
free now, but the state will charge for recertification in three years, as well as fees
for mandated drug testing and compliance
costs. "Now is the worst time for increased
regulations and mandates such as this,"
he says. "It's just one more way to overregulate an industry in New York state
and put more people out of business."
Produce Or Plug
Gill says he has informal word from
the New York Department of Environmental Conservation that regulators are
revisiting the state's produce-or-plug policy. DEC now allows an operator to keep
a well shut in for a limited time before
having to plug it.
Operators have been using reasons
such as a desire for improved market
conditions or waiting for a buyer to delay
plugging decisions, Gill says. "It got to
the point several years ago that DEC
would not accept those reasons," he
recalls. "DEC really dropped a hammer
on its plug-or-produce policy."

In 2015, IOGA NY raised the issue
with several pro-industry legislators, Gill
says. Soon after, he says, a DEC representative contacted him to resolve several
issues, including plugging. According to
the agency, state rules have been relaxed.
"If the DEC approves an operator's
application, he can leave a well shut in
without plugging for one or two years,"
Gill says. "DEC is not going to be forcing
operators to plug. Rather, they can leave
them temporarily abandoned almost indefinitely, as long as there is an operator
of record attached to the well, there is a
plugging bond, and most importantly,
that well poses no environmental threat.
This is welcome news for our producer
members, especially during these tough
times."

Summer Meeting
The technical session that opens the
annual summer meeting at the Peek'n
Peak Resort will include presentations
on the OQ program and plugging wells,
as well as a New York regulatory update,
discussions covering well cleaning and
ultrahigh-definition stratigraphy, and news
about the state's 2015 aboveground storage
tank regulations.
Gill points out this year's meeting
will feature a cocktail reception after the
technical session at the resort's inn on
the upper golf course. Other social events
include a golf tournament and sporting
clays event, as well as the annual barbecue
and equipment show.
For information, visit the association's
website at www.iogany.org.
❒

BSEE Plan For Well Control Has
Safety, Cost Issues, Group Says
WASHINGTON-The possible unintended consequences of the Bureau of
Safety and Environmental Enforcement's
final offshore well control regulations
include decreasing safety and increasing
risks, as well as negative national economic
impacts, warn seven oil and gas industry
groups.
BSEE published the regulations in the
April 29 Federal Register, and they become effective July 28. The agency says
the rule represents one of the Interior
Department's most significant safety and
environmental protection reforms. Begun
after the 2010 Deepwater Horizon blowout
and spill in the Gulf of Mexico, BSEE
says the rule builds on offshore energy
standards, reforms and oversights instituted
during the past six years.
According to the agency, the final rule
addresses all dimensions of well control,
including more stringent design requirements and revised operational procedures
for critical well control equipment used
in oil and gas operations on the U.S.
Outer Continental Shelf.
In joint comments filed before publication of the final rule, the American Petroleum
Institute, International Association of Drilling
Contractors, Independent Petroleum Association of America, National Ocean Industries Association, Offshore Operators
Committee, Petroleum Equipment & Services Association, and U.S. Oil & Gas Association said the regulations' deviation
from multiple API standards could stress
equipment and increase risks of compromised cement jobs or lost circulation.
"Congress has required that federal

agencies use voluntary consensus standards
(such as API's) and consult with consensus
standards bodies about using those standards. Deviations from these standards
are allowed only in limited situations,"
the industry coalition asserts.
Offshore Rules
According to BSEE, it analyzed nearly
370 specific recommendations during the
rule-making process, receiving input from
stakeholders and academia. The regulations
cover systems and equipment related to
well-control operations, and focus on
blowout preventer requirements, well design and control casing, monitoring, and
subsea containment, BSEE says. It points
out the measures are designed to improve
equipment reliability, especially for BOPs.
The agency is imposing new equipment
requirements, such as double-shear rams
and centralizers, as well as stricter mandates regarding third-party reviews of
equipment, drilling margins, and other
reforms related to casing, cementing, and
subsea containment.
Under the rules, BSEE requires realtime monitoring (RTM) of certain data for
well operations that use either a subsea
BOP or a BOP on a floating facility, or that
are conducted in high-pressure/high-temperature environments. The RTM system
is required to gather and immediately
transmit data on the BOP control system,
the well's fluid-handling systems on the
rig, and the well's downhole conditions to
an onshore facility monitored "by qualified
personnel in 'continuous contact' with rig
personnel during operations," the agency
JUNE 2016 109

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American Oil and Gas Reporter - June 2016

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