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BLM & AOGCC sign legacy well agreement MOU clarifies roles and responsibilities for remediating abandoned wells in federal land in the NPR-A, to meet state requirements ALAN BAILEY Petroleum News
In the latest twist in the thorny saga of dealing with abandoned legacy wells in the National Petroleum Reserve-Alaska, the Bureau of Land Management and the Alaska Oil and Gas Conservation Commission have signed a memorandum of understanding that clarifies the roles of the two agencies in the plugging of the renegade wells.
A key purpose of the MOU is to ensure that the wells are plugged and abandoned in compliance with state regulations - BLM owns the land in which the wells are located and is responsible for dealing with the well cleanup, while AOGCC is the Alaska state regulator responsible for oversight of well safety within the state’s borders.
The wells in question were drilled by the U.S. Navy and the U.S. Geological Survey between 1944 and 1982 - many of the wells were not properly plugged. Consequently, with aging and deteriorating wellheads, the wells pose safety risks and raise the possibility of environmental damage.
Remediation program BLM began a remediation program in 2002, having identified a total of about 136 legacy wells that required attention. In 2013 BLM put together a strategic plan, identifying 68 wells that had by that time been cleaned up or that did not need further action; 18 wells that were still being used by the U.S. Geological Survey for Arctic climate monitoring; and 50 wells that required some level of remediation. Also in 2013, in an act of Congress that passed that year, Sen. Lisa Murkowski arranged for the inclusion of $50 million in funding for the NPR-A legacy well program.
In early 2016 BLM contracted with Marsh Creek LLC to proceed with the remediation and cleanup of wells in the Utqiagvik (Barrow) and Cape Simpson areas.
But the work did not proceed smoothly. In October 2016 AOGCC commented that two of the wells dealt with that year had not been plugged properly and would require to be reworked. Commission Chair Cathy Foerster commented that the BLM contractor had left one of these wells in a state that would render the ultimate plugging of the well difficult or impossible. And, for another well, AOGCC issued a notice of violation for the failure to use the required well control equipment and a subsequent flow of fluids to the surface.
The MOU The new MOU says that there are now fewer than 80 wells that require additional remediation work.
The document assigns to BLM responsibility for the management and oversight of contracts for the surface and subsurface remediation of the wells, ensuring compliance with applicable state and federal laws, and selecting contractors that have an understanding of Alaska well-work operations and regulatory requirements. BLM will use experienced oil and gas engineering technicians to oversee critical plugging and abandonment work, the MOU says. BLM will also work with the contractor and AOGCC for the coordination of the draft plans and associated comments for the plugging and abandonment procedures. The approval process for the plans will depend on whether the relevant subsurface land is privately owned or owned by the federal government.
AOGCC will review and comment on the draft remediation plans for the wells, to ensure compliance with state regulations. The agency will deal with the approval of well work for wells in privately owned subsurface, while BLM will approve plans involving federal subsurface land. Prior to any approval, both agencies will participate in meetings with the BLM contractor to discuss the well remediation procedures.
The MOU will remain in effect indefinitely, unless terminated by written notice by either agency. And, while either agency may request changes to the MOU, changes must be approved by both parties before going into effect.
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