What are wireline operations?

Wireline operations are part of special services during the completion and production of oil and gas wells to serve several purposes like equipment transport, swabbing, reservoir evaluation, logging, well intervention, perforation, pipe recovery, downhole tool setting, and bailing. They include both electric and slickline operations.

What is the difference between electric lines and slicklines?

Electric lines are cables that gather and transmit data about a well; they consist of single or multi-
strands for well intervention and formation evaluation. In contrast, slicklines are single-strand non-
electric cables for placing and recovering wellbore equipment like gauges, plugs, and valves. They can also be utilized for tubing repair in the wellbore and for valve and sleeve adjustment in the downhole.

How to prevent masts or booms from toppling over?

It is always important to install foundations, guying, and outriggers according to the recommendations of the manufacturer.

A co-worker was suddenly exposed to an unexpected release of pressure. What are the possible steps to be done?

Install a pressure-release valve in the lubricator sub before bleeding pressure from it. Break the connections and look out for an unusually tight connection. It may indicate that pressure has not been released.

What are the measures that could be implemented to minimize hand injuries and sprains?

Encourage workers to practice proper hand placement and taglines to prevent pinching hands. If possible, minimize handling lubricators and other equipment manually to avoid overexertion.

What is well logging?

Well logging is the identification and recording of information regarding subsurface geologic formations. It includes well bore properties; mud records; cutting analysis; drill stem tests; core analysis; and electric, acoustic, and radioactivity procedures. Tools utilized for well logging include mechanical, electrical, radioactive, and sonic tools.

What are the potential hazards of well logging and how to prevent them?

As mentioned, some tools can expose a worker to radiation. Injuries could also occur due to unexpected release of pressure. It is very important to ensure that workers wear appropriate personal protective equipment (PPE). Logging personnel who are duly authorized and qualified should only be allowed to handle logging tools. Should any radioactive tools be damaged, report immediately. Keep non-essential workers away from the rig floor and marked-off areas of radiation hazards.

Who is an oil and gas waste hauler?

Any person who transports oil and gas waste for hire by any method other than pipeline, such as hauling flowback water via truck.

What is oil and gas waste?

Waste resulting from activities associated with the exploration, development, or production of oil or gas. Oil and gas waste includes salt water, brine, sludge, and drilling mud. It also includes waste materials generated during drilling, operation and plugging of wells such as domestic septage and trash.

What permits are needed for oil and gas waste haulers?

Oil and gas waste haulers must file Form WH-1: Application for Oil and Gas Waste Hauler’s Permit with the Railroad Commission of Texas (RRC). The application must be approved and a permit application fee must be paid. Haulers must register and properly mark their vehicles. Each vehicle must be operated and maintained in such a manner to prevent spills, leaks and other discharges during transportation. A copy of the permit must be kept in each vehicle as identified in the permit application. Oil and gas waste haulers must keep waste manifests to document proper disposal of wastes. You can download the application form (WH-1) and other applications from the RRC website. Based on the waste hauler FAQ guidance at http://www.rrc.state.tx.us/media/8672/waste-hauler-2012-faqs.pdf, forms WH-2 and WH-3 are also required.

Where is disposal of oil and gas waste allowed?

Oil and gas waste haulers must ensure the waste is disposed of at an authorized facility. The disposal facility used by the hauler must be documented in the waste hauler’s permit. Waste generated from oil and gas operations may be disposed of at authorized RRC facilities or certain TCEQ regulated landfills. In order to dispose of oil and gas waste at TCEQ Municipal Solid Waste (MSW) landfills, the waste generator must obtain a special waste authorization by completing and submitting Form 00152 to the TCEQ. Contact your local TCEQ regulated landfills for specific information on types of waste they are permitted to accept. Transporters and generators must keep manifests to document proper disposal of waste. More information regarding disposal regulations is available in TCEQ’s publications titled Disposal of Special Wastes Associated with the Development of Oil, Gas, and Geothermal Resources (RG-003) and Common Environmental Requirements for Regulated Oil and Gas Operations (RG-482).

Who enforces the rules?

State and local agencies are authorized to ensure compliance with applicable waste hauler regulations. State agencies with jurisdiction include: Texas Department of Public Safety, TCEQ, and RRC. County sheriffs and city police departments may request compliance documentation from waste haulers and are authorized to issue civil and criminal penalties, which may include monetary fines, and may impound unauthorized or improperly operated vehicles.

How are truck wash facilities regulated?

RRC has jurisdiction over wastes such as vacuum truck rinsate and tank rinsate generated from:

• oil and gas exploration, development, or production sites
• a facility operated by an oil and gas waste hauler permitted by the RRC
• a facility such as a warehouse, pipeyard, or equipment storage facility belonging to an oil and gas operator and used solely to support that operator’s oil and gas exploration, development, or production activities

The TCEQ regulates rinsate from vacuum trucks generated at commercial service company facilities such as truck washing operations, or companies that provide equipment, materials, or services to the oil and gas industry if the facility is not operated by an RRC-permitted waste hauler. Examples of commercial service company facilities include facilities that provide drilling and work over rig rental and tank rental services, equipment repair services, drilling fluid supply services, and acidizing, fracturing, and cementing services.

Questions and concerns frequently arise when owners of residential property in suburban and rural areas discover that oil and gas operations are being conducted in the vicinity. Although the Railroad Commission of Texas generally lacks jurisdiction over these issues, the information below is intended to provide general answers to some of the most common questions.

Mineral & Surface Estates

Under Texas law, land ownership includes two distinct sets of rights, or “estates”: the surface estate and the mineral estate. Initially, these two estates were owned by the same person and they may continue to be owned together by one person. However, in many areas of Texas, especially those where there has been extensive historical oil and gas development, it is common for the mineral estate and surface estate to be owned by different people. The division, or “severance,” of the mineral estate and surface estate occurs when an owner sells the surface and retains all or part of the minerals (or, less commonly, an owner sells the minerals and retains the surface). If an owner does not expressly retain the minerals when selling the surface, the mineral estate he owns automatically is included in the sale.

Dominance of Mineral Estate

Regardless of whether the mineral estate and surface estate are held by one owner or have been severed, Texas law holds that the mineral estate is dominant. This means that the owner of the mineral estate has the right to freely use the surface estate to the extent reasonably necessary for the exploration, development, and production of the oil and gas under the property. This right to freely use the surface estate for the benefit of the mineral estate may be exercised by a company or individual that has taken a mineral lease from the actual owner of the mineral estate. The company that takes a lease and actually operates the property is frequently referred to as the “lessee” and the mineral interest owner who granted the lease is the “lessor.”

Lessees have broad rights to use the surface for the purpose of exploring for and producing oil and gas. These rights include the right to: conduct seismic testing; drill wells at locations they select; enter and exit well sites and other facilities; build, maintain and use roads for access to and from well sites and facilities; build and use pipelines to serve wells and facilities on the property; use surface and subsurface water on the leased premises for drilling and production operations; and drill and operate injection wells to enhance lease recovery and dispose of lease-produced water.

With the limited exceptions discussed below, the lessee has the right to conduct the activities set out above and otherwise reasonably use the surface without getting permission from the surface owner and without restoring the surface or paying for any non-negligent damages it causes. However, if a lessee’s use of the surface is found to be negligent, unreasonable or excessive, the lessee may be liable to pay damages to the surface owner for the resulting injury.

Exceptions and Limitations

The general rules regarding free use of the surface to benefit the mineral estate may be changed by the specific terms of the mineral lease covering the property or of the deed that severed the mineral estate from the surface estate. In addition, many cities have municipal ordinances restricting oil and gas activities on property within city jurisdiction. The rights of the lessee may also be limited by the “accommodation doctrine.” This legal doctrine applies in limited circumstances to require the lessee to modify its operations to accommodate an existing surface use when reasonable alternatives are available. In specific circumstances in counties in or near large metropolitan areas, developers can impose restrictions on drilling and operation sites by creation of a qualified subdivision as provided by Chapter 92 [http://www.statutes.legis.state.tx.us/Docs/NR/htm/NR.92.htm] of the Texas Natural Resources Code.

Control by Surface Owner

The best method of controlling oil and gas development by a surface owner is the purchase of all or a significant portion of an undivided interest in the mineral estate. This allows the surface owner to control the timing and terms of any future leases. However, purchase of the mineral estate is not always possible or practical. In the alternative, although under no obligation to do so, a mineral interest owner may be willing to agree to include surface use and surface damages clauses in future leases.

If the mineral estate is already under lease, the surface owner may wish to contact the lessee company to attempt to negotiate an agreement restricting use of the surface or agreeing to set damages for surface use. Although there is no legal requirement to do so, a lessee may be willing to enter into a reasonable surface use/damages agreement to avoid potential disputes.

This document is provided for general information purposes only as a service by the Railroad Commission of Texas. It is not legal advice and is not a substitute for legal advice. For specific questions and situations, it is strongly recommended that you consult with an experienced oil and gas or real estate attorney.