Texas Railroad Commission Compliance Assistance

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TEXAS RAILROAD COMMISSION COMPLIANCE ASSISTANCE SHELL EXPLORATION & PRODUCTION COMPANY

KEY PROJECT ELEMENTS

HOUSTON, TEXAS

 Oil and Gas Exploration & Production  Regulatory Compliance  Texas Railroad Commission (TRRC)  Production Well Permit Applications  Well Completion Report Submittals

CLIENT: SHELL EXPLORATION & PRODUCTION COMPANY DURATION: 2011

 Hydrogen Sulfide Well Compliance

Conestoga-Rovers & Associates provided full-time, contract personnel to assist Shell Exploration & Production Company (Shell) with exploration and production (E&P) regulatory compliance activities

 Fracture Fluid Voluntary Disclosure Submittals

associated with assets in the Eagle Ford shale natural gas play. Compliance activities included preparation and submittal of Texas Railroad commission (TRRC) permit to drill (PTD) applications, well completion reports, well initial potential (IP) reports, and evaluation of state and federal

 Flowback Water Disposal Well Permit Applications

regulations potentially applicable to hydrogen sulfide gas production, and collection of supporting documentation from Shell and subcontractor personnel.

 Development and Use of Regulatory Compliance Training Materials for Client Personnel

CRA coordinated with Shell regulatory compliance personnel, E&P drilling and operations personnel, subcontract surveyors, land men, and regulatory agency contacts, to collect necessary data for online completion and submittal of PTD applications to TRRC. CRA also coordinated with well completion and cementing contractors to gather necessary information for online completion and submittal to TRRC of well completion reports and other completed well documentation (e.g., initial potential reports, cement contractors’ affidavits, hydrogen sulfide well evaluation forms, etc.). In addition, CRA gathered information for preparation and completion of hydraulic fracture fluid content forms for online posting through the Ground Water Protection Council (GWPC) voluntary disclosure website. In support of the activities listed above, CRA coordinated extensively with Shell personnel and contractors, collected applicable information through access to Shell’s well drilling and completion database, and organized supporting document files for each well PTD application and completion documents, including regulatory agency responses (e.g., permits to drill, protective surface casing approvals, etc.). CRA also assisted with other regulatory compliance evaluation and training activities. CRA prepared a 200002 / 029081 / WD / July.2008

summary of potentially applicable Federal Aviation Administration (FAA) requirements for the erection or construction of permanent or temporary structures within regulatory airspace limits near private airfields on or near Shell-operated lease assets. CRA also created regulatory compliance management training documents for Shell personnel.


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