State Office Review and Oversight of Oil and Gas Inspection and Enforcement (I&E) Program
March 26, 2018
In Reply Refer To:
3100 (920) P
EMS TRANSMISSION 03/28/2018
Instruction Memorandum No. CA-2018-007
Expires: 09/30/2021
To: District Managers and Field Managers
From: State Director
Subject: State Office Review and Oversight of Oil and Gas Inspection and Enforcement
(I&E) Program
Program Area: Fluid Minerals
Purpose: This Instruction Memorandum (IM) provides an Implementation Schedule for I&E Program Review (attached) and guidance for State implementation of WO IM No. 2012-161 (attached) documenting and conducting oversight of the oil and gas inspection program.
Policy/Action: Pursuant to WO IM No. 2012-161, State Offices are responsible for programmatic oversight of Field Office operations. The IM contains guidance to ensure consistent, timely, and quality review of Field Office records for inspections and enforcement. Per WO IM No. 2012-161, the Bureau of Land Management California State Office will be taking the following actions:
a) Conduct Internal Control Review of the I&E program, quarterly, for each Field Office
in California.
b) The California State Director will submit a report of findings, annually, or at least
once every 3 years, to the Chief, Division of Fluid Minerals (WO-310), for each
office reviewed within 30 days after completing the review.
The State Director’s report must address the items (1 – 10) in the schedule (Attachment 1), which are also described below:
- Explain if the inspections (drilling, production, abandonment, environmental, follow-up, and oversight) are conducted in accordance with policy.
- Describe inspection documentation in AFMSS and the official file.
- Determine and discuss if enforcement actions (INCs, written orders, verbal warnings) are accurate, appropriate, properly documented (AFMSS, official files), and in accordance with policy.
- Discuss the I&E strategy and determine if it is being followed and if the planned inspections are being completed.
- Review staffing (PE, PET, PAT, NRS/EPS, and support) and training needs.
- Identify areas where existing program guidance (local, State, or National) is not clear, contradictory, inconsistent, or nonexistent.
- Note the number and types of inspections reviewed (PI, DW, OV, etc.).
- Note the name and title of the person(s) that perform the program review.
- If appropriate, include an action plan detailing what, when and how issues will be resolved with a follow-up schedule to verify the action plan progress and success.
- If the required action plan is complete, attach a close-out report.
The State Director may, at his/her discretion, authorize the release of the above report to OIG or GAO, as a matter of policy, in response to inquiries.
Timeframe: The policies outlined in this IM are effective immediately.
Impact on Budget: None.
Background: This IM provides documentation of BLM California’s responsibilities for review and oversight of the oil and gas inspection and enforcement (I&E) program, pursuant to WO IM No. 2012-161 (Attachment 2), as amended.
Manual/Handbook Affected: None.
Coordination: Scheduling oversight of the oil and gas inspection program will occur between California State Office and each Field Office.
Contact: If you have any questions regarding the above procedures, please contact Deputy State Director, Energy and Minerals, BLM California State Office, (916) 978-4361; or, Petroleum Engineer/Inspection and Enforcement Coordinator, BLM California State Office, Energy and Minerals Division, (916) 978-4367.
Signed by: Authenticated by:
Jerome E. Perez Larry Weitzel
State Director GIS/Applications Mgmt Branch, CA-946
Attachments
1. BLM-California Implementation Schedule for I&E Program Review
2. WO IM-2012-161 Oversight of the Oil and Gas Inspection and Enforcement
Program