The Wise Report
Henry M. Wise, P.G.
May 13, 2018
The Railroad Commission of Texas (Commission) proposes amendments to §3.53, relating to Annual Well Tests and Well Status Reports Required. The amendments would adjust the testing requirements for oil wells to minimize the frequency of such tests, thereby reducing the administrative burden for those wells and associated costs to industry. The Commission also proposes amendments to §3.52, relating to Oil Well Allowable Production, to reflect the changes in §3.53.
Requirements for oil well production capability testing are found in both §3.52 and §3.53, as well as §3.51, relating to Oil Potential Well Test Forms Required. The current version of §3.53 requires operators to test the production capability of oil wells annually and report the results of the test to the Commission on Form W-10, Oil Well Status Report. The Commission proposes new subsection (a)(4) to specify that an operator may elect not to perform or file a test for a well after the initial potential test has been filed, except in certain circumstances. If the operator elects not to perform such a test, then the Commission would use the results of the most recent test or optional allocation on file with the Commission.
Notwithstanding subsection (a)(4), proposed new subsection (a)(5) would require that an operator perform the initial potential test in the following situations: when the well is recompleted into a different regulatory field; when the well is reclassified from gas to oil; when an inactive well is returned to production; when necessary to reinstate an allowable; or when required by Commission order, special field rule, or other Commission rule. For example, operators of wells authorized to surface commingle production pursuant to §§3.26 and 3.27 of this title (relating to Separating Devices, Tanks, and Surface Commingling of Oil, and Gas To Be Measured and Surface Commingling of Gas, respectively) would be required to conduct and report tests at the same frequency at which those tests are currently required by those rules and §3.52 or by the order authorizing the commingling.
The overall effect of the proposed amendments would be to require testing in specific instances, rather than as a general requirement. Under the proposed amendments, operators would still be required to file Form W-10 annually to report the status of each well. For more information go to: http://www.sos.state.tx.us/texreg/archive/May112018/Proposed%20Rules/16....
Henry M. Wise, P.G.
The Wise Report
5/13/2018