Introduction
Regulations play a crucial role in the oil and gas industry, particularly in the field of hydrocarbon measurement. Hydrocarbon measurement technicians are responsible for accurately measuring the flow of oil and gas in pipelines, and other facilities. Regulatory compliance requires the maintenance of meters and reporting of measurement data meet all rule requirements in order to ensure both legal and financial accountability. For measurement technicians, regulatory requirements have a significant impact on their work and daily tasks at the physical meter both in testing, and in the data documentation that captures meter test data. Meter test reports are legal documents which means it is imperative the technician keep careful attention while filling out any documentation that relates to meter testing. Regulations can also dictate the type of equipment and technology that must be used for compliant measurement. For example, flow meters can be defined as needing to be orifice meters or electronic flow computers to ensure accurate and compliant data according to the rule.
Industry Standards Impact on Regulations
While it is not the role of standards committees to write standards with regulation as their primary goal, industry standards play a significant role in the development of the regulations that govern measurement. Becoming familiar with industry standards is fundamental for a measurement technician to understand measurement regulations.
Here are a few reasons regulatory agencies adopt industry standards and why measurement technicians should have the same knowledge, if not a stronger understanding, of these documents:
- Standards provide consistency and uniformity by setting best practices that are agreed upon by industry.
- Standards provide regulators with a path to monitor and enforce compliance.
- Standards provide guidance on accuracy and reliability. Regulatory agencies understand that standards are written to give technical specifications on how to properly calibrate instruments, collect samples, and how to properly collect data.
- Standards include guidance to help minimize errors and discrepancies in measurement data, which in turn helps to ensure that production and revenue calculations are accurate and reliable.
State and Federal Regulations
State regulations typically govern the measurement of hydrocarbons within a specific state’s jurisdiction. It is important that organizations review state requirements relevant to the state(s) in which you work.
Here are a few examples of state regulatory bodies:
- The General Land Office of Texas (GLO)
- Ohio Laws and Administrative Rules
- Oklahoma Corporate Commission
Federal regulations, such as those established by the Bureau of Land Management (BLM), Department of Transportation (DOT) or the Environmental Protection Agency (EPA), regulate across several states and can serve as the foundation for state rules. As a measurement technician, it is necessary to have an understanding of all federal requirements specific to oil and gas measurement, as well as state regulations.
Regulations dictate the proper reporting and documentation of measurement data, which is essential for tax assessments, royalty payments, and regulatory compliance. Inaccurate or incomplete measurement data can result in fines, penalties, or legal actions against companies, highlighting the importance of adherence to state and federal regulations.
For example, the BLM, in certain instances noncompliance will issue an “Immediate Assessment”. Table 1 from 43 CFR 3175.150 provides specific items that will trigger “Immediate Assessment” violations.
Technician Considerations
- Invest and get involved in industry standards committees.
As stated, regulations dictate the specific procedures and methods that must be followed in the measurement of oil and gas. This includes calibration of equipment, proper documentation, and adherence to specific industry standards and guidelines. Failure to comply with these requirements can result in fines, penalties, or even legal action against the technician or their employer. Having a strong knowledge of state & federal regulations as well as industry standards reduces the risk of technicians and their employer being subject to repercussions of non-compliance. How do you do this? Get involved in the industry through the American Petroleum Institute (API), GPA Midstream, the American Gas Association (AGA), and other regional trade schools. You don’t need to be an expert to have a seat at the table, everyone has to start somewhere.
- Take the training.
Regulations may require measurement technicians to undergo specialized training and obtain certification to perform their duties. This training ensures that technicians have the knowledge of industry standards and technical skills necessary to maintain meters and documents to comply with regulations. Technicians may also need to undergo regular re-certification to stay up to date with changing regulations and industry standards. Review these with your organization and take ownership of making sure that you are up to date on required training and certifications.
- Stay the course with your scheduled maintenance requirements.
Regulations set standards for the equipment used by measurement technicians, including their calibration devices, types of flow meters, transmitters, and other measuring devices. These standards ensure that equipment is accurate, reliable, and properly maintained. Technicians must routinely have their calibration equipment tested to ensure that these devices are accurate and in compliance with regulations.
- Don’t take shortcuts.
Regulations require hydrocarbon measurement technicians to accurately record and report measurement data that may be audited by regulatory authorities and other stakeholders. This data is used to monitor production, calculate royalties, and ensure compliance with regulations. Technicians must maintain detailed records of meter maintenance, calibrations, sample data and other relevant information to demonstrate compliance with regulations.
- You are accountable.
For a technician working on federal royalty bearing meters, it is critical to remember that once the technician is trained on the regulations that govern that meter, that any knowing and willfulness of ignoring the regulation can lead to civil penalties. Civil penalties can carry monetary fines and may be enforced on any person, including the individual technician. Once the technician understands these rules, it is in their best interest to follow the rules precisely.
Conclusion
Regulations have a significant impact on hydrocarbon measurement technicians, influencing their daily tasks, training requirements, equipment standards, and reporting obligations. Compliance with these regulations is essential to ensure accurate measurement, protect the environment, and maintain the integrity of the oil and gas industry. By following regulations and staying up to date with industry best practices, hydrocarbon measurement technicians can fulfill their vital role in ensuring the safe and efficient production of oil and gas while promoting transparency, accountability, and environmental stewardship within the sector.
References:
Texas.gov, (2024, July 14) Oil and Gas: Statutes and Rules, Statutes & Rules (texas.gov)
Codes.Ohio.gov, (2024, July 7) Ohio Laws and Administrative Rules: Chapter 1509, Division of Oil and Gas Resources Management – Oil and Gas, Chapter 1509 – Ohio Revised Code | Ohio Laws
Oklahoma.gov, (2024, July 15) Oklahoma Corporation Commission, Rules, Current Rules, Statutes (oklahoma.gov)
U.S. Department of the Interior, Bureau of Land Management, (2024, July 18), Regulations and Notice to Lessees (NTL), 43 CFR 3170, Onshore Orders | Bureau of Land Management (blm.gov)
U.S. Department of the Interior, Bureau of Land Management, (2024, July 18), Production Measurement Team, 43 CFR 3175, CFR-2017-title43-vol2-sec3175-31.pdf (govinfo.gov)
National Archives, Code of Federal Regulations, (2024, July 18), Subpart-3163 Noncompliance, Assessments, and Penalties, eCFR :: 43 CFR Part 3160 Subpart 3163 — Noncompliance, Assessments, and Penalties
Justin Richardson, Technical Advisor
With nearly 30 years of experience in the upstream oil and gas industry, Justin Richardson has dedicated his career to advancing measurement technology and ensuring compliance with industry standards. Over the past 16 years, he has specialized in equipment design, gas chromatography, and regulatory requirements.
Justin is an active member of several American Petroleum Institute (API) standards committees, including API 14.3.2, API 14.1, API 21.1, and API 21.2. He also serves on the General Committee of the International School of Hydrocarbon Measurement (ISHM) and has previously served on the Board of Directors for the Midwest Measurement Society.
