U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
United States Department of the Interior
January 17, 2014
In Reply Refer To:
The AFMSS carries the risk information forward to a matrix in AFMSS for the FOs to plan their technical field inspections (e.g., drilling, abandonment, production) based on their available workforce and their workload. Due to budget and staffing limitations, however, the BLM has not yet automated the records analysis/records verification inspections, or the environmental inspection portions of the strategy. Therefore, for FY 2014, the FOs must plan these inspections manually using the attached spreadsheet (attachment 2).
For FY 2014, the minimum high risk factor is 4.0 for production inspections and 4.0 for idle well inspections. For production inspections, the goal is to inspect all high risk factor cases (overall production inspection risk factor of 4.0 and above) and at least one-third of the cases with overall risk factors lower than 4.0. For idle well inspections in FY 2014, the goal is to have each FO inspect 20 percent of the high risk factor wells (risk rating greater than 4.0). For records analysis/records verification inspections, the goal is to complete a records analysis on 10 percent of the cases with a production inspection overall rating of 4.0 or higher and to complete a records verification inspection on 10 percent of the remainder of the production inspection cases. The cases selected for review are to be a mix of various operators and geographic locations. For environmental inspections, the goal is to inspect all wells/facilities rated as high priority.
For FY 2014, the FOs must create the I&E strategy using a combination of AFMSS and spreadsheets. For the technical field inspections (e.g., drilling, abandonment, production), the FOs will use the matrix in AFMSS (IEP.13S screen). Attachment 3 provides the instructions for running the risk-based reports for production inspections and idle well inspections, along with instructions for completing the matrix in AFMSS. The AFMSS database automatically created the FY 2014 priorities on November 18, 2013. This information is available for FOs to run the risk-based reports and create their strategy matrices.
For the records analysis/records verification portions of the strategy and the environmental inspection portions of the strategy, the FOs will use the spreadsheet provided. Attachment 4 provides the instructions for completing the spreadsheet. For the FOs with Indian Trust responsibility, the FOs must complete two separate spreadsheets: one for Federal data and one for Indian Trust data.
In addition to completing the technical inspection strategy in AFMSS, the FOs must complete and return the attached Excel spreadsheet in attachment 2 to the Washington Office Division of Fluid Minerals (WO-310) and their state office (SO) by January 31, 2014.
Due to the number of inspection databases, it is difficult for the WO to know when the FOs create new versions of the matrix. Therefore, FOs must notify the WO-310 and their SO by email of all “Official Versions” of the matrix created after January 31, 2014, within 7 calendar days.
For Production Accountability Technicians (PAT)
In FY 2013, the BLM added some new Inspection Types and Inspection Activities to AFMSS and changed the definition of others (see attachment 6). The BLM modified some of these for FY 2014. Attachment 6 replaces and supersedes appendix 1 in the Inspection and Enforcement Documentation and Strategy Development Handbook, H-3160-5, and all other definitions for “Inspection Type” and “Inspection Activity.” Attachment 7 contains clarification for using some of the codes.
In previous years, the FOs would close incomplete (open) inspections at the end of the FY with remarks reflecting that the FO would re-open and complete the inspection during the following FY. This is no longer an approved practice. Once an inspection is open in AFMSS, the inspection remains “Open” until the inspection is completed. Do not close inspections at the end of the FY (including the end of FY 2013) and re-open after the start of the next FY in order to complete the inspection later. However, inspections are not to remain open while enforcement actions (Incidents of Noncompliance (INC), Written Orders) are pending (see H-3160-5, Inspection and Enforcement Documentation and Strategy Development Handbook, IV.L.). Therefore, in summary, close an inspection when the last inspection activity is complete; do not leave the inspection open because there is an outstanding enforcement action.
This change is necessary so the BLM can accurately count and report the number of inspections the BLM completes each FY. Closing an incomplete inspection and re-opening it the follow year has led to inconsistent reporting of accomplishments. The goal remains to close all open inspections by the end of each FY; however, there are circumstances that may prevent that from occurring.
The National Operations Center (NOC) Fluid Minerals Section is available to assist FOs in performing production accountability reviews and will issue an Information Bulletin (IB) when it is ready to accept new cases. State I&E Coordinators may then submit a list of potential leases or agreements for NOC review, ranked in priority order per each FO. The NOC issued OC-IM- 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. Exercise special care in classifying field development drilling wells as High for routine casing and cementing operations.
All SO I&E Coordinators will be responsible for ensuring the proper rating of drilling inspection items.
In development of the strategy matrices, the FOs must coordinate several different areas, including:
FOs must elevate all suspected oil and gas theft immediately to the local BLM Law Enforcement, the BLM Washington Office (AD-300 and WO-310), and the BLM Law Enforcement Special Investigations Group (SIG) following standard protocol as outlined in IM WO-IM-2013-056, Oil and Gas Theft Reporting Guidelines and Format. Attachment 8 contains links to this and other useful IMs, IBs, and other resources.
Timeframe: FOs must complete the technical field inspection matrix in AFMSS and save it in AFMSS as “Official” by January 31, 2014. If the FOs save a new “Official” version of the matrix after January 31, 2014, they must notify Michael Wade (firstname.lastname@example.org) and William Lambert (email@example.com) via email within 7 calendar days. FOs must also submit the matrix spreadsheets to WO-310 and their SO by January 31, 2014.
Three years ago, the BLM implemented a risk-based strategy as suggested by both the Government Accountability Office and the Office of Inspector General and agreed to by the BLM. Last year, the WO-310 automated the strategy for field inspections performed by PETs (e.g., drilling, abandonment, production, idle well).
Manual/Handbook Sections Affected: BLM Handbook H-3160-5, Inspection and Enforcement Documentation and Strategy Development Handbook, will incorporate the interim policy contained in this IM during its next revision.
Contact: If you have any questions concerning the content of this IM, please contact me at
|Last updated: 01-24-2014|
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