Many upstream and midstream organizations operate leases under the jurisdiction of the U.S. Bureau of Land Management (BLM) and utilize Quorum’s measurement solutions such as FLOWCAL, TESTit, and PROVEit. The proposed changes to the BLM Site Security and Measurement Rules have been published to the federal register for comment. Quorum is committed to providing products that will assist our customers in meeting their obligations and continuing our work to meet the requirements of the new rules.
BLM Proposed Revisions
As a part of the America-First Energy Strategy, the BLM has announced proposed revisions to three key regulations (43 CFR 3170 - Onshore Oil and Gas Production: General, 43 CFR 3174 – Measurement of Oil, and 43 CFR 3175 – Measurement of Gas) that govern oil and gas measurement requirements and recordkeeping on Federal and Tribal lands. Now that the proposed changes have been published to the federal register, a 60-day public comment period has begun. The Production Management Team (PMT) will review and respond to substantive comments before finalizing and may use any new information gathered to help guide the development of the revisions.
Quorum’s Initiatives
Jason Rigg and Scott Tanner have been nominated to be Quorum’s API COPM Onshore Orders TG and GPA Midstream WG representatives. We will facilitate customer and manufacturer meetings and work directly with the PMT to resolve questions to assist us in our activities.
Community Involvement
Quorum will regroup the previously created BLM Working Group to provide a platform for continued involvement, collaboration, and direction from the Quorum user community. We invite all customers to participate in the working group meetings for regulation updates and to ensure we are heading in the right direction. As part of that effort, we will solicit detailed input from the working group during and after the comment period for continued alignment and potential product planning.
Make sure to get involved! If you are interested in participating in the BLM Working Group sessions as a representative for your company, please email BLMregs@qbsol.com.
Next Steps
The public comment period for the proposed rules has begun; comments are due on or before November 9th, 2020. Quorum, with our user community, will work together to provide comprehensive feedback.
Additionally, we will hold BLM Working Group meetings to seek customer feedback and provide updates.
Summary of BLM Modifications
43 CFR subpart 3170 – Onshore Oil and Gas Production: General
- Various changes are required to conform with the substantive changes to 43 CFR subparts 3173, 3174, and 3175.
- 43 CFR subparts 3173 – Requirements for Site Security and Production Handling
- Reduce certain equipment seal requirements for equipment locations deemed to be of low risk to mishandling or theft;
- Reduce recordkeeping requirements associated with water draining operations;
- Reduce requirements for co-located facility on-site facility diagrams;
- Remove a requirement to submit a new site facility diagram when change of operator occurs;
- Increase volume thresholds for submitting FMP applications; and
- Remove immediate assessment for seals associated with LACT units.
43 CFR subpart 3174 – Oil Measurement
- Update all incorporated API standards to the latest published edition;
- Create a third low-volume FMP category with no measurement uncertainty requirements;
- Add Production Measurement Team (PMT) review and BLM approval requirements for electronic thermometers, LACT sampling systems, temperature and pressure transducers, and temperature averaging devices;
- Delay the requirement for using BLM-approved equipment on existing high-volume FMPs and low-volume FMPs until such time as the equipment is replaced or the FMP elevates to a very-high-volume FMP; and
- Remove the immediate assessment for failure to notify the BLM of a LACT component failure.
43 CFR subpart 3175 – Gas Measurement
- Update all incorporated API standards to the latest published edition;
- Add PMT review and BLM approval requirements for Gas Chromatograph (GC) software and water vapor detection methods;
- Reduce basic meter-tube inspection frequency and remove detailed meter-tube inspection requirement for low-volume FMPs;
- Add initial meter-tube inspections for high- and very-high volume FMPs;
- Eliminate the requirement of installing composite samplers or on-line GCs for very-high volume FMPs; and
- Add language to make portions of the rule apply to gas meters associated with gas storage agreements.
Conclusion
Quorum recognizes the impact that the BLM revisions have had and will continue to have on our measurement customers. Understanding and meeting new regulatory revisions can be challenging, but Quorum is committed to this process and will ensure that they help customers to comply with requirements and have a voice in the path forward. For any questions regarding the BLM regulations or if you would like to participate in the Quorum BLM Working Group meetings, please send an email to BLMregs@qbsol.com.
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