Reporting of Undesirable Events

UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240–0036
http://www.blm.gov

January 30, 2019

Supersedes IM 2011-186

In Reply Refer To:
3162 (310) (P)

EMS TRNASMISSION 12/21/2018

Instruction Memorandum No. 2019- 020
Expires:  09/30/2022

To:                  All Field Office Officials

From:             Assistant Director, Energy, Minerals and Realty Management

Subject:          Reporting of Undesirable Events

Program Area:  Fluid Minerals

Purpose:  This Instruction Memorandum (IM) replaces the existing policy and guidance
(IM 2011-186, Reporting of Undesirable Events) for immediate reporting requirements of all Major Undesirable Events (MUE) by the Bureau of Land Management (BLM) Field Offices (FO) to the Washington Office (WO) and State Offices (SO) for operations on Federal oil and gas leases.  This IM describes the immediate reporting requirements of all MUEs by the BLM FOs to the WO and SOs.  It also clarifies the reporting requirements, and updates the notification list for WO contact information.

Policy/Action:  The Notice to Lessees 3A (NTL-3A), 44 Fed. Reg. 2205 (Jan. 10, 1979) requires oil and gas operators on public lands to provide notification of all MUEs to the BLM FO within 24 hours and to follow this notification with a written report within 15 days.  FO personnel who have oil and gas inspection and enforcement program responsibilities must notify the appropriate WO and SO personnel, including the email distribution group for MUEs as listed in Attachment 3, of a MUE as soon as practicable, but no later than 24 hours from either the BLM’s discovery of the MUE or the operator’s or public’s initial notification about the MUE to the BLM. 

Attachment 1 describes the reporting requirements for an MUE.  Attachment 2 contains the reporting format and list of items required per NTL-3A for the MUE.  The written report[1] that the operator submits to the BLM needs to contain additional and updated information from the initial notification.  The FO must send to the appropriate SO personnel and WO personnel an updated/final MUE report once the operator sends the report with information on containment and cleanup.  The FO will send to the WO MUE primary contacts listed in Attachment 3 (List B).  If the containment and cleanup for the site is not completed within the 15-day reporting period, then the FO must send a follow-up final report in addition to the 15-day report to the appropriate SO and primary MUE contacts when the operator completes the containment and cleanup. Attachment 3 contains the updated email group list (List A) for initial notification, BLM_WO_MUE@blm.gov.  It includes the WO and SO recipients for the initial notification and the list of recipients for final MUE report (List B), group email BLM_WO_Primary_MUE@blm.gov.  WO-310 will periodically update the group email lists of recipients and will maintain the email contact group for FO notifications. 

Timeframe:  This IM is effective immediately.

Budget Impact:  None.

Background:  The BLM’s NTL-3A defines an MUE.  The BLM requires oil and gas operators on public lands to notify BLM FOs about an event within 24 hours.  These events can include fatal injuries, blowouts, large spills, leaks, liquid overflows into local streams or channels, equipment failures resulting in venting of natural gas and fires.  Because an MUE may affect public health and safety, production accountability, and the environment, it is the BLM’s policy that FOs must notify the WO and the appropriate SO, including the email distribution group for MUEs as listed in Attachment 3.  The FOs must follow this notification with a written report within 15 days.[2]

Manual/Handbook Sections Affected:  None.

Coordination: Coordinated with the Office of the Solicitor and the FOs.

Contact:  If you have any questions concerning the content of this IM, please contact Michael Nedd, at 202-208-4201, or your staff may contact Jamie Sellar-Baker, Acting Division Chief, Washington Office Division of Fluid Minerals (WO-310), at 202-912-7143 or jsellarb@blm.gov,  Subijoy Dutta, Senior Petroleum Engineer, WO-310, at 202-912-7152 or sdutta@blm.gov, or Michael Riches, Petroleum Engineer, WO-310, at 202-912-7144 or mriches@blm.gov.

Signed By:                                                                  Authenticated By:

Michael D. Nedd                                                        Ambyr Fowler

Assistant Director                                                       Division of Business Resources (WO-850)

Energy, Minerals, and Realty Management

3 Attachments:

1 - Reporting Requirements for Major Undesirable Events (1 p)
2 - Bureau of Land Management Major Undesirable Event Report (1 p)
3 - Notification List for Reporting of Major Undesirable Events (2 pp)