Regulatory Requirements Associated with Well Production and Water Management

Natural gas production on non-federal lands is regulated by the Arkansas Oil and Gas Commission; on Federal lands, companies must follow relevant requirements from the Bureau of Land Management.

State Requirements

Natural Gas Production: Natural gas production on non-federal lands is regulated by the Arkansas Oil and Gas Commission (AOGC) through a series of AOGC rules.

  • Rule B-14 Surface Equipment

  • Rule B-26 General Lease Operating Requirements

  • Rule B-32 Vacuum Pumps Prohibited

  • Rule B-33 Production Practice

  • Rule D-2 Potential Open Flow

  • Rule D-3 Pressure Test

  • Rule D-4 Supervision of Open Flow and Pressure Tests

  • Rule D-5 Duration of Tests

  • Rule D-6 Notice of Tests

  • Rule D-7 Gas to be Metered

  • Rule D-8 Reports from Gas Purchasers

  • Rule D-9 Gas-Oil Ratio

  • Rule D-10 Gas-Oil Ratio Surveys and Reports

  • Rule D-14 Gas Assessment

  • Rule D-15 Measuring Gas at Custody Transfer Points

  • Rule D-16 Back Pressure Tests for Natural Gas Wells For Production Allowable Determination

Although a few of these rules govern the environmental protection aspects of gas production (primarily B-14 and B-26), most of them, particularly those that are in the "D group," deal with the economic issues of gas production.

When first gas production starts, the operator must submit Form 4 Request for Certificate of Compliance, Notice of Commencement of Production, or Change of Purchaser.

The AOGC website Forms page (http://www.aogc.state.ar.us/aogcforms.htm) lists numerous forms that are used to report monthly production figures. In light of their limited environmental emphasis these items are not discussed further here.

Produced Water Management: The AOGC also regulates the management of produced water through a series of AOGC rules.

  • Rule B-26 General Lease Operating Requirements

  • Rule B-27 Salt Water

  • Rule B-34 Notice of Fire, Breaks, or Blow-Outs and Remediation of Associated Spills of Crude Oil and Produced Water

  • Rule C-7 Disposal of Salt Water (note that this rule is situated within a section of the rules designated as "Oil" rules; it may or may not be relevant to disposal of salt water from natural gas wells)

The AOGC website provides a link to the joint AOGC/Arkansas Department of Environmental Quality (ADEQ) form Application to Inject Salt Water/Enhanced Recovery Fluid, available at: http://www.aogc.state.ar.us/OnlineData/Forms/(.208)%20SWD%20Application.pdf. The application form explains that if the injection is being made for enhanced recovery, only the AOGC is involved.

Operators must file monthly produced water injection reports using Form 14 Saltwater Disposal Report, available at: http://www.aogc.state.ar.us/OnlineData/Forms/Form%2014%20-%20Salt%20Water%20Disposal%20Report.pdf.

The ADEQ also has some responsibility for produced water management as outlined in ADEQ Regulation No. 1 Regulation for the Prevention of Pollution by Salt Water and Other Oil Field Wastes Produced by Wells in All Fields or Pools

The ADEQ has the responsibility for regulating the construction and operation of surface facilities associated with a disposal system for injection of saltwater. ADEQ uses a general permit, Authorization to Construct and Operate the Surface Facilities Associated with a Disposal System for Injection of Salt Water and Other Oil Field Wastes under the Provisions of the Arkansas Water and Air Pollution Control Act In order to be covered under the general permit, operators must file a Notice of Intent Application for Salt Water Disposal Permit.

Federal Requirements

When natural gas and water production occurs on federal lands, companies must follow the relevant requirements from the Bureau of Land Management (BLM) Gold Book.

Operations should be conducted in a manner that ensures the proper handling, measurement, disposition, and site security of leasehold production while protecting other natural resources, environmental quality, life, and property. The primary objective is to maximize the ultimate recovery of oil and gas with minimum waste and with minimum adverse effect on the ultimate recovery of other mineral resources, other natural resources, and environmental quality. Production and sales reports must be filed with the Office of Natural Resources Revenue, as appropriate using the Oil and Gas Operations Report (OGOR) (Form MMS-4054).

Operators should submit Sundry Notices and Reports on Wells (Form 3160-5) within 5 days after any well begins production anywhere on a lease site.

Gas production is regulated by Onshore Oil and Gas Order No. 5 Measurement of Gas. All oil, other hydrocarbons, and gas produced from the leased lands are to be put in a marketable condition to the extent economically feasible.

Produced water management is regulated by Onshore Oil and Gas Order No. 7 Disposal of Produced Water.

See also Endangered Species Act (ESA) Provisions

DISCLAIMER
This regulatory information is provided as guidance to viewers. It should not be used as the sole source of information concerning the relevant and applicable regulatory requirements. Agency organization, laws and regulations, and Web linkages are subject to change. Therefore viewers are encouraged to check with the appropriate regulatory agencies for authorized up-to-date information.
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