American Oil and Gas Reporter - January 2017 - 16

IndustryDigest
Horizon spill killed an estimated 17
percent of the species, and also concludes
energy exploration and development, and
oil spills and spill response, are
increasing the risk of extinction."
The Natural Resources Defense
Council petitioned NMFS to list the
species in 2014. The Independent
Petroleum Association of America says
it responded to that petition, arguing in
comments filed in 2015 that the Gulf of
Mexico population of Bryde's whale
was not a distinct subspecies, and that
the Gulf of Mexico population could and
did move freely in and out of the Gulf.
NMFS says it is accepting comments
on its listing determination until Jan. 30.
❒

Oklahoma Issues
Completions Guidance
For Seismic In New Plays
OKLAHOMA CITY-In what the
Oklahoma Corporation Commission
describes as a proactive approach that
will ready the state for more
development, the OCC's Oil & Gas
Conservation Division and the
Oklahoma Geological Survey have
developed seismicity guidelines for
fracturing operations in a couple
burgeoning plays.
According to OCC, the guidelines
deal with operations in the South
Central Oklahoma Oil Province
(SCOOP) and the Sooner Trend
Anadarko Basin Canadian and
Kingfisher counties (STACK) plays.
The guidelines address a protocol for
completions within 1.25 miles of
anomalous seismic activity. In such
events, if the OGS-determined
magnitude is at least:
* Equal to or greater than 2.5,
OGCD will contact any operator with
active completion operations within the
two kilometer radius of the seismic
event, after which the operator will
implement his internal mitigation
practices and continue operations;
* 3.0 or greater, the operator is to
pause operations for no fewer than six
hours while he confers with OGCD staff
on mitigation practices and seismic
activity declines, after which the
operator will be permitted to resume
under the revised completion procedure;
and
* 3.5 or greater, the operator is to
16 THE AMERICAN OIL & GAS REPORTER

suspend operations for an in-person
technical conference with OGCD staff
to examine whether the operation can
resume with changes.
According to OGS Director Jeremy
Boak, both old and new data have
prompted a plan to mitigate earthquake
risk in the SCOOP and STACK.
"Then-state seismologist Austin
Holland did some work on small
earthquakes some years ago in what is
now widely known as the SCOOP and
STACK, and showed some of them
might have been related to hydraulic
fracturing," Boak says. "More recent
small events outside the (injection well)
area of interest (AOI) may also be
linked to hydraulic fracturing. While the
data indicate that seismicity related to
the SCOOP and STACK would be far
less frequent and much lower in
magnitude than the activity we are
addressing in the main earthquake
region of the state that has been linked
to wastewater disposal, we have enough
information to develop a plan aimed at
reducing the risk of these smaller events
as operations commence.
"Unlike the strong earthquake
activity in areas of the AOI linked to
disposal activity, response to seismic
activity that may be related to hydraulic
fracturing can be more precisely defined
and rapidly implemented," he adds.
Fortunately, says OGCD Director
Tim Baker, neither the STACK nor
SCOOP plays generate anywhere near
as much produced water as the region's
Mississippian Limestone and Hunton
dewatering plays. "There is broad
agreement among researchers that
disposing of these large amounts of
water into the Arbuckle can be linked to
the high earthquake rate in parts of the
AOI," Baker relates. "By comparison,
the SCOOP and STACK plays have
very small amounts of produced water."
❒

Wyoming, Montana Ask
Federal Court To Vacate
Venting Rule From BLM
CHEYENNE, WY.-Wyoming and
Montana, with North Dakota joining
three weeks later, are asking a federal
court to review the Bureau of Land
Management's final rule on venting and
flaring from oil and natural gas
activities on public and tribal lands. The

bureau published the rule in the Nov. 18
Federal Register, with an effective date
of Jan. 17.
The states' action follows a similar
petition for review filed Nov. 15 by the
Western Energy Alliance and
Independent Petroleum Association of
America (AOGR, December 2016, pg.
32).
In mid-December, California and
New Mexico asked the court to allow
them to intervene in support of BLM.
According to media reports, state
officials argue the petitioning states
failed to demonstrate they were likely to
succeed in their lawsuit or that the final
venting rule would cause them
irreparable harm.
The proposed rule would require
operators to adopt technologies and
equipment to limit the flaring rate at oil
wells, periodically inspect their
operations for leaks, and replace
equipment that vents large quantities of
gas, BLM says. The rule also limits
venting from storage tanks, and clarifies
when operators owe royalties on flared
gas.
"The bureau's rule is a blatant
attempt by a land management agency
to impose air quality regulations on oil
and gas operations under the guise of
waste prevention," the
Wyoming/Montana petition says.
"Congress specifically delegated
authority to regulate air pollution to the
U.S. Environmental Protection Agency
and the states, because they are in the
best position to regulate air quality
matters. The bureau's rule conflicts with
the Clean Air Act, and unlawfully
interferes with Wyoming and Montana
air quality regulations."
The states assert BLM lacks the
authority and expertise to impose the
final rule's air quality control
requirements. According to court
documents, BLM is claiming authority
through the Federal Land Policy and
Management Act, and the Mineral
Leasing Act, although the states
maintain neither statute shows any
evidence that Congress intended BLM
to develop and implement air quality
regulations.
"The bureau's rule assumes that
every oil and gas operation on a federal
lease emits nothing but federal minerals,
as opposed to a mix of constituents that
may or may not include federal
minerals. It is arbitrary and capricious



American Oil and Gas Reporter - January 2017

Table of Contents for the Digital Edition of American Oil and Gas Reporter - January 2017

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