Request for Modified or Missing Oil and Gas Operations Report from the Office of Natural Resources Revenue
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
http://www.blm.gov
January 7, 2013
In Reply Refer To:
3100 (310) P
EMS TRANSMISSION DATE 01/09/2013
Instruction Memorandum No. 2013-041
Expires: 09/30/2014
To: All State and Field Officials
From: Assistant Director, Minerals and Realty Management
Subject: Request for Modified or Missing Oil and Gas Operations Report from the Office of Natural Resources Revenue
Program Area: Fluid Minerals.
Purpose: This Instruction Memorandum (IM) replaces WO-IM-2009-174, Request for Modified or Missing Oil and Gas Operations Report from the Minerals Management Service; and sets forth information required by the Office of Natural Resources Revenue (ONRR) for modified report requests; states the Bureau of Land Management (BLM) policy for volume amounts for such modified reports; and identifies the ONRR addresses for various types of requests. It also outlines the process and procedures to follow when contacting the ONRR regarding modified or missing wells on the Oil and Gas Operations Report (OGOR).
Policy/Action: During the BLM production inspections or production accountability reviews, the BLM may discover production reporting discrepancies. When the BLM field office (FO) determines there is a reporting discrepancy, the FO will inform the operator, in writing, of the discrepancy. This is not a Written Order. The FO will not enter or track the discrepancy in the Automated Fluid Minerals Support System (AFMSS).
Attachment 1 is a sample decision letter to the operator notifying them of the discrepancy. The FO will allow the operator 20 working days to file an appeal to the State Director. After 30 working days and no appeal is filed, the FO will contact the ONRR to determine if the operator has submitted the modified OGOR(s). The FO may contact the ONRR by telephone or email, or use the ONRR Brio Portal to see if the report is on file.
If the operator has not submitted the modified OGOR(s), the FO will request the ONRR, via memorandum, to send the operator an Order to Report, requesting the modified OGOR for the volumes listed in the memorandum. The FO will include a copy of the letter to the operator notifying them of the production reporting discrepancy in their request memorandum to the ONRR.
Attachment 2 contains a sample memorandum to the ONRR showing the required information. The FO must send signed copies of both the memorandum and letter previously sent to the operator as email attachments (in a pdf format) to blm.ogorrequests@onrr.gov. When the ONRR receives the request from the FO for modified OGOR(s), the ONRR will determine if they have received the modified report. If the ONRR determines they have not received the modified OGOR(s), the ONRR 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 ONRR regardless of the amount or mineral interest percentage to the Federal Government. However, it is the ONRR’s policy not to request modified OGOR(s) when:
- The BLM has not notified the operator of the volume or quality discrepancy;
- The volume differences are based solely on comparing OGOR volumes to commercial well service volumes, such as Dwight’s Energy Data, Inc.; or
- Except for Indian minerals, the request exceeds the 7-year record retention requirement.
In those cases where the ONRR determines not to request modified OGOR(s), the ONRR will notify the FO via an email containing a signed copy of the memorandum as an attachment (in a pdf format). The ONRR 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, the ONRR will send an Order to Report to the appropriate operator and track the request. The ONRR will notify the FO via an email containing a signed copy of the memorandum as an attachment (in a pdf format), when the ONRR receives the reports.
Please note that the format for Attachment 1 is a decision of the authorized officer to the operator and requires the FO to notify the operator of specific corrected volumes or quality for specific dispositions.
When a FO discovers OGORs with discrepancies (quantity or quality) or missing wells, the FO must:
1. Contact the ONRR production analyst/technician responsible for the particular operator in order to verify that the reports/wells are actually missing or if the ONRR is holding the reports for any reason. A list of contact names can be found at http://www.onrr.gov/FM/PDFDocs/operasgn.pdf; or
2. If the FO has access to the ONRR Brio Portal, check to see if the report is on file or held for further research.
When the FO determines that the operator has not filed corrected OGOR(s), the FO must send a memorandum to ONRR identifying the BLM agency-assigned lease or agreement number, operator name, and specific production month/year of the missing report(s). See Attachment 3 for a sample memorandum from the FO to the ONRR. The FO must email a signed copy of the memorandum as an attachment (in a pdf format) to blm.ogorrequests@onrr.gov. The ONRR will send a signed copy of the memorandum notifying the FO by email as an attachment (in a pdf format), when ONRR receives the reports.
To improve the process, the FOs must:
1. Use only an accepted OGOR for verification purposes; verify using the AFMSS OGOR.7 screen or the ONRR Brio Portal;
2. When corresponding with the ONRR, use the BLM agency assigned number for the lease/agreement;
3. Round all volumes to the nearest barrel (bbl) or thousand cubic feet (Mcf) because the OGOR does not allow decimals; and
4. Not request modified OGOR(s) for warning errors devised for informational purposes unless the FO discovers a subsequent volume discrepancy. For example, the warning error “Volume Required for Gas or Water (55)” appears when the operator reports that a gas well is in producing status but the operator does not submit any volumes. 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 alerts the BLM to a reporting situation that could lead to abuse. A follow-up inspection may verify the need for a modified OGOR, in which case, the FO will request a modified OGOR from the operator.
The address for requesting missing reports/wells, specific volumetric changes, or reclassification OGOR well detail (OGOR-A) and production disposition (OGOR-B) resulting from BLM field inspections and other verification efforts is:
Office of Natural Resources Revenue
Production Reporting and Verification
Manager of Production Reporting Mail Stop 63310B
P. O. Box 25627
Denver, Colorado 80225-0627
The address for inquiries concerning volumes associated with royalties reported to the ONRR for a specific lease or agreement is:
Office of Natural Resources Revenue
Audit and Compliance Management
P. O. Box 25165
Denver, Colorado 80225-0165
The address for final determinations concerning compensatory royalty assessments, unauthorized flaring, and/or avoidably lost volumes is:
Office of Natural Resources Revenue
Program Director Audit and Compliance Management
P. O. Box 25165
Denver, Colorado 80225-0165
Timeframe: Implementation will begin immediately upon issuance.
Budget Impact: None.
Background: This IM gives updated policy on the correct procedures to follow to request modified OGORs when the BLM identifies production discrepancies during production inspections or there are missing OGORs. This IM supersedes WO-IM-2009-174.
Manual/Handbook Section 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.
Coordination: The Division of Fluid Minerals has coordinated preparation of this IM with the ONRR, State Office Inspection and Enforcement Coordinators, and FO personnel.
Contact: If you have any questions concerning the content of this IM, please contact me at 202-208-4201, or your staff may contact Steven Wells, Chief, Division of Fluid Minerals, at 202-912-7143 (s1wells@blm.gov) or Michael Wade at 303-236-1930 (mwade@blm.gov).
Signed by: Authenticated by:
Michael Nedd Catherine Emmett
Assistant Director, Minerals and Realty Management Division of IRM Governance
3 Attachments
1 – Sample Letter for Notifying Operator of Production Discrepancies (2 pp)
2 – Sample Memorandum for Requesting Amended OGORs (1 p)
3 – Sample Memorandum for Requesting Missing OGORs (1 p)