U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
July 10, 2009
In Reply Refer To:
3160 (310) P
EMS TRANSMISSION -7/16/2009
Instruction Memorandum No. 2009-174
To: All Field Officials
From: Assistant Director, Minerals and Realty Management
Subject: Request for Modified or Missing Oil and Gas Operations Report from the Minerals Management Service
Program Area: Fluid Minerals.
Purpose: This Instruction Memorandum (IM) sets forth information required by the Minerals Management Service (MMS) for modified report requests, states the Bureau of Land Management (BLM) policy for volume amounts and/or American Petroleum Institute (API) gravity or British Thermal Units (BTUs) for such modified reports, and identifies the MMS addresses for various types of requests. It also outlines the process and procedures to follow when contacting the MMS regarding modified or missing wells or Missing Oil and Gas Operations Reports (OGOR).
Policy/Action: During the BLM production inspections or production accountability reviews, production reporting discrepancies in volumes and/or API gravity or BTUs may be discovered. When the BLM determines there is a reporting discrepancy, the BLM will inform the operator, in writing, of the discrepancy and request a modified OGOR be sent to the MMS or give reasons why the found discrepancy is in error. This is not a Written Order and will not be tracked in the Automated Fluid Minerals Support System (AFMSS). Attachment 1 is a sample letter to the operator, which must be sent via Certified Mail, Return Receipt Requested. Please note that the format for attachment 1 requires the field office (FO) to request specific corrected volumes for specific dispositions.
If the operator contacts the FO that the discrepancy is in error, the FO will work with the operator to determine the appropriate production. The FO will allow the operator 20 business days from receipt of the letter or the date when the appropriate production was determined to submit the OGOR to the MMS, after which the FOs will contact the MMS to determine if the
OGOR had been submitted. The FOs may view AFMSS to see if the OGOR has been
submitted, contact the MMS by telephone, email, or use the MMS Brio Portal to see if the report is on file.
If the operator has not submitted the modified OGOR within 30 days or the FO and operator cannot reach an agreement as to the amount of production in a reasonable time, the BLM will send a memorandum, with a copy of the letter to the operator and any other documentation generated while working with the operator, to the MMS requesting that the MMS send an Order to Report to the operator for the modified OGOR for the volumes listed in the memorandum. Attachment 2 contains a sample memorandum to the MMS showing the required information. When the MMS receives the request from the BLM for modified OGOR(s), the MMS will determine if the modified report has been received. If it determines the modified OGOR(s) has not been received, the MMS will send an Order to Report to the operator and a copy to the FO.
It is the policy of the BLM to send all production discrepancies to the MMS regardless of the amount or mineral interest percentage to the Federal Government.
In those cases where the MMS determines modified OGOR(s) will not be requested, or the OGORs have already been received, it will notify the FO in writing of this determination. The MMS pursues all Indian OGOR differences referred from the BLM regardless of volume differences.
For all requests from the BLM for modified OGOR(s) that contain specific timeframes and volumes and the MMS has determined that a modified OGOR is required, the MMS will send an Order to Report to the appropriate operator, track the request, and notify the originating FO, via email, when the reports are received.
When a FO discovers OGORs or wells are missing, the FO will contact the MMS production analyst/technician responsible for the particular operator to verify that the reports are actually missing or are being held by the MMS for any reason. A list of contact names can be found at: http://www.mrm.mms.gov/ReportingServices/PDFDocs/operasgn.pdf.
When the FO determines that the operator has not filed an OGOR for a specific time period, the FO will contact the MMS in writing or by email (a copy of the email must be placed in the case file), identifying the BLM agency assigned lease or agreement number, operator name, and specific production month/year time period of missing reports. See attachment 3 for a sample memorandum from the BLM to the MMS.
To further improve the process, the FOs are required to:
a. Use only an accepted OGOR for verification purposes. This is indicated in the AFMSS OGOR.7 screen.
b. When corresponding with the MMS, use the BLM Agency Assigned Number for the lease/agreement. Do not use the Case Recordation Number unless the agreement, not just the Participating Area (PA), was effective after 01/01/1988.
c. Round volumes to the nearest bbl or Mcf because decimals are not allowed on the OGOR.
d. Do not request modified OGOR(s) for warning errors unless a subsequent volume discrepancy is discovered. For example, the warning error “Volume Required for Gas or Water (55)” is caused when a gas well is reported in producing status but no volumes are submitted. This situation occurs when the operator is trying to produce a well, but there is insufficient pressure to bring the gas to the surface. The reporting method is correct. The warning message was devised to alert the BLM to a reporting situation that could easily be abused. A follow-up inspection may verify the need for a modified OGOR, in which case one should be requested.
Requests for missing reports/wells, specific volumetric changes or reclassification in the OGOR operations report (OGOR-A), and production disposition (OGOR-B) resulting from BLM field inspections and other verification efforts must be addressed to:
Minerals Management Service
Production Accounting and Verification Services
P. O. Box 17110
Denver, CO 80217-0110
Inquiries concerning volumes associated with royalties reported to the MMS for a specific lease or agreement must be addressed to:
Minerals Management Service
Compliance and Asset Management
Federal Onshore Oil and Gas CAM
P. O. Box 173702
Denver, CO 80217-3702
Final determinations concerning compensatory royalty assessments, unauthorized flaring and/or avoidably lost volumes must be addressed to:
Minerals Management Service
Deputy Associate Director for Audit MS 3600
P. O. Box 25165
Denver, CO 80225-0165
Budget Impact: None.
Background: This IM gives updated policy on the correct procedures to follow to request modified OGOR(s) when production discrepancies are identified during production inspections or to request missing OGOR(s) from the MMS. This IM supersedes Washington Office (WO) Instruction Memorandum No. 2007-168. During a recent meeting with the MMS, needed updates in IM 2007-168 were identified and this IM makes those necessary changes.
Manual/Handbook Section Affected: When the Inspection and Enforcement Production Accountability Handbook is developed, the guidelines in this IM will be incorporated.
Coordination: This IM has been coordinated with the MMS.
Contact: If you have any questions concerning the content of this IM, please contact me at
202-208-4201, or your staff may contact William Gewecke, Senior Petroleum Engineer for Inspection and Enforcement, at 202-452-0337.
Signed by: Authenticated by:
Timothy R. Spisak Robert M. Williams
Acting, Assistant Director Division of IRM Governance,WO-560
Minerals and Realty Management