Forproduction, drilling, and abandonment inspectors (Petroleum Engineering Technicians (PET)): 

1.      High Priority drilling wells.

2.      High Priority plugging and abandonment operations.

3.      Federal and Indian production cases with a risk factor of 4.0 and above.  (Inspections are generally to be conducted in risk-factor order considering location of cases to minimize travel times and cost.)

4.      Meter Calibrations, Gas Sample Collections, Orifice Plates Inspections, and Meter Tube Activities.

5.      Cases that have had a change of operator (see Attachment 3 for details).

6.      Inspections during any well production testing occurring during or after High Priority drilling operations but before the well is placed on a producing well status (see Attachment 3 for details).

7.      High Priority workover operations.

8.      One-third of Federal and Indian production cases with a risk factor below 4.0. (Inspections are to be conducted in risk-factor order and not random.)

9.      Well status checks. 

For surface compliance specialists: 

1.      High Priority drilling wells (surface compliance).

2.      High Priority environmental inspections (see Attachment 3 for details).

3.      Interim Reclamation inspections (see Attachment 3 for details).

4.      High Priority workover operations (surface compliance).

5.      Final Reclamation inspections. 

Please note that emphasis continues to be placed on Environmental/Surface (ES) inspection types. High Priority environmental inspections should receive the same attention as other High Priority inspection types. Fee surface/Federal mineral locations are not exempt from ES inspections and should be included when developing the Inspection Strategy Matrices. All FOs must ensure that all surface inspectors have been adequately trained (i.e. a good understanding of applicable regulations, BLM surface standards, and the ability to determine inadequate surface operations) before allowing them to conduct ES inspections.

• The National Operations Center (NOC) Fluid Minerals Section is available to assist FOs in performing production accountability. State I&E Coordinators may submit a list of potential leases or agreements to be reviewed by the NOC, ranked in priority order per each FO. The NOC issued IM OC-2011-037, dated April 7, 2011, with details on procedures in working with the NOC Fluid Minerals Section.    

• All drilling inspections rated High must meet the criteria rating as outlined in the Inspection and Enforcement Documentation and Strategy Development Handbook. Special care should be exercised in classifying field development drilling wells as High for routine casing and cementing operations.  

In addition to completing the strategy in AFMSS, the attached excel spreadsheet in Attachment 5 must be completed and returned to WO-310 through the state office by November 30, 2011. This spreadsheet gives the details needed to show GAO and OIG that their recommendations are being fulfilled. At the end of FY 2012, each FO is required to submit the spreadsheet again showing the inspections accomplished during the year. This year end completed spreadsheet is to be submitted to WO-310 through the state office no later than October 12, 2012.  

All State Office I&E Coordinators will be responsible for ensuring the proper rating of all inspection items. 

• Oversight and Guidance: Inspection priorities for all inspections rated High will be reviewed by the State Office I&E Coordinators to ensure compliance with the priority rating standards. 

• Rating inspections to the correct criteria ensures that inspection resources are maximized. Example: All drilling wells should not be rated High if they do not meet the criteria in the “Inspection and Enforcement Documentation and Strategy Development Handbook.” 

• Coordination must take place with the applicable tribes and/or the Bureau of Indian Affairs to ensure their concerns are met regarding the prioritization of cases.

• Interdisciplinary coordination must occur within the FOs to ensure that all environmental priority ratings are coordinated with appropriate staff such as Natural Resource Specialists or Environmental Scientists. 

• Coordination must occur to ensure that idle/orphan well inspections related to that initiative, or other concerns, are incorporated and prioritized in the Inspection Plan Matrices.  

• Coordination between the SO and reporting FOs is essential to ensure all inspection goals are met.  

• Documentation must be complete and accurate. 
• Managers and supervisors on a regular basis must be engaged and understand the level of completeness in the recordation. 
• Orders and INCs need to be documented and completed with follow-up. 
• The State Leads for Inspection and Enforcement will participate actively in the program, and even across state lines to provide a cadre of needed expertise, program leadership and support. 
• There will be regular meetings, at least by monthly teleconference calls to assess enforcement progress, identify emerging needs, address challenges, and provide remedies by generating guidance. 
• Production and production accountability must remain a priority for inspection and expanded in emphasis. 
• The safety of the staff while in the field is paramount, just as is the proper training to maintain technical proficiency across all disciplines. 
• Offices may need to adjust staffing and funding on a periodic basis, including sharing resources where it makes good business sense.