1. Annual Disposal / Injection Well
Monitoring Report (Form H-10)
August 2017
Margot Buyens & Jim Moore

2. This presentation covers:
Filing Form H-10 online.
Filing hard copy Form H-10.
Violations and rejected Forms H-10.
H-10 related issues and problems.
Transfers and inactive well issues.
H-10 Query information.
These are the items that we will discuss today.
If you have questions, please write them down and we will handle them at the end of the presentation.
We will also be available after the presentation in the hallway if you have questions.
Feel free to me at the address you will find later in this presentation.
Let’s get started!

3. Everyone received an example form H-10 that is posted in the Oil & Gas Forms menu on the RRC website.
If you find that form and want to use it, don’t!
Hard copy H-10 filing is allowed but you need to use the pre-populated form that is designated to your injection well and posted online.

4. Who has to file a Form H-10? File Form H-10 if:
well is on proration schedule as injection well.
there is an injection permit but well is not on proration schedule and not completed.
Note: A well can have an injection permit but is on the proration schedule as a producer.
This is when you file a Form W-10 or G-10.
Jim Moore will explain.

5. Notification
The operator is notified via mail 3 months before the Form H-10 due date. Example: Cycle year starts 01/2015 and ends 12/2015. Due date of the Form H-10 is 02/01/2016. Notification is mailed to operator 10/21/2015.
The RRC still sends out a courtesy letter 3 months prior to the H-10 due date.
At the same time, the H-10 entry is posted online.
There is a variety of reasons that can stop the letters from going out so don’t just rely on our system.
Jim Moore elaborate.

6. Online filing advantages
expedites the process
RRC receives it immediately
can be filed 24/7
error messages
violations showing online
Note: Hard copy filing is still accepted.
Go over bullet points.

7. Getting started
To file H-10s online, you will need an RRC Online account.
If you go to the RRC Website, click on “RRC Online Log in”, it will take you to to the online filing account.

8. Log in to online system
If you don’t have an online account, print out the SAD form, complete it and send it to the address on the form.
The RRC Helpdesk will send you an Online User ID and temporary password and instructions on how to set up the admin account.
You will create an Admin account. With the Admin account, you will create one or more Filer accounts.
You will have to assign filing rights to the filers for all the forms that you want them to file.
From the filer account, you will file the Forms H-10 online. You will log in here with your User ID and Password.

9. You will then click on “H10 Filing system”.

10. Next you will click on “File H10”.

11. This is a screen shot of the H10 filing screen that has 3 sections:
-On top: In this section you can file one H-10 at a time. Enter District-lease and well number OR UIC number OR API number. Never all 3 because it will not work. When you enter the UIC #, do NOT use preceding zeros.
-In the middle: This is the section that we will use to file H10s. We can pull all the H10s that are due for the operator.
-At the bottom: This section will allow you to make a correction
on an H-10 that was filed previously.
I will explain later how to make corrections.

12. Let’s go to the section in the middle of the H-10 filing screen
Let’s go to the section in the middle of the H-10 filing screen. We will open the district box and pick “Statewide”.

13. Here you will find all the forms H-10 for the operator that need to be filed.
You will notice that there are some H10s posted with the 1995 due date. That was before the website was created in 2007 so you can ignore those.
There is one H10 that is a “Work in progress”. That means that the operator has worked on it and saved it but did not submit. It will still need to be processed and submitted.
“Current” means that the H10 has not been filed yet and needs to be filed by the due date.
To file an H10, you will click on File at the end of the line.

14. This is the H-10 filing screen.
If you have 0 volumes to report (no injection during the cycle year), or if your well has not been drilled, you will click on “No Volumes to report”.
That will automatically enter zeros in the pressure and volume columns (items 13 and 14).
You can not enter other information.
Just scroll down to slick process & submit.

15. On top of your H10 filing screen is a link where you can click to the H10 department in case you have problems.
You can and click “save” if you want to come back later after you received an answer from the H-10 department.

16. Pressures – item #13 report average and maximum pressures
for vacuum pressures, enter zeros
If you have injected during the cycle year, you will start by entering your injection pressure amounts in item 13.
You will calculate the average injection pressure amounts by month and enter them in the left column.
You will then find the highest pressure amount for each month and enter that amount in the right column.
Remember that the Max PSIG required here is NOT the permitted maximum amount from the permit.

17. Volumes – item #14 report amount of BBLS/liquid or MCF/gas
inactive wells, enter zero each month
Now you will enter the volume amounts, totaled by month.
The left column is for barrels injected (fluids) and the right column MCF (1000 cubic feet) is for gas injected.

18. Annulus pressures – item #15
pressure between tubing and casing (TCAM)
Item #15 – complete 3 columns
required only if TCAM special condition on UIC permit
You will ONLY complete item 15 if you have a special condition on your permit that requires you to monitor the annulus pressure between the tubing and the casing, usually weekly.
If you don’t have that special condition on your permit, leave these 3 columns blank.
If you do have that special condition, enter the amount of readings for each month in the left column.
Enter the min & max annulus pressures that you observed in the middle and right columns.
If you did not observe annulus pressures, make sure to enter 0 in those two columns or it will cause a violation. There are many violations created by operators who enter only the left columns but leave the middle and right columns blank.

19. Injection interval – item #16
Enter the completed interval, not the permitted interval.
In some cases, the completed injection interval can be the same as the permitted interval.
Jim Moore?
Now you will enter the interval in item 16. You are required to report the completed interval, the current perfs. Don’t enter the interval from the permit because it may be different.
The completed interval on the last W2 completion report, last H5 MIT test and the H10 interval should all be the same.

20. Tubing packer depth – item #17
Enter completed packer setting depth, not permitted packer depth.
In some cases, the completed packer setting depth can be the same as the permitted packer depth.
Some permits have packer exceptions, obtained via permit application process.
Jim Moore?
In item 17, you will then enter the tubing packer depth.
Again, the reported packer depth should be same on your last W2, H5 MIT test and H10.

21. Sources of injected fluids– item #18
Report the source of the injection / disposal fluids.
Are the injected fluids from other sources than your own? If so, enter “yes”.
Item 18 is self explanatory.
Did you inject fluids from other sources than your own?

22. Injection tubing / casing – item #19
Checkmark box for tubing or casing.
If injecting through casing, tubing packer exception needed, obtained via permitting process.
This is self-explanatory but there are sometimes violations that are caused by operators who make a data error.

23. Injected fluid types– item #20
Reported liquid / gas must equal 100%.
Enter numbers, no check marks.
If no injection during the reported cycle year, leave item 20 blank.
Prior to 2011, a checkmark in the fluid boxes was sufficient. The recent form H10 is different and now requires % to be entered.
If you had no injection, do NOT enter anything in item 20 for fluids. The question is “What fluids did you inject during the reporting cycle year”.
There are many violations from hard copy H10s that have 0 injection but fluids reported in item 20 which is conflicting.

24. Injected fluid types – item #20
File online: use drop down arrow to view additional fluids.
File hard copy: use “other” and specify.
Here you will enter your injected fluids or gas.
When you use the “other fluid total” box, you will chose from the “Other Fluids Injected” box, max 3.
When you highlight a fluid type, it will transfer the fluids and place them in the right box.
“RCRA Exempt waste” is the same as “Other Non-Hazardous O/G Waste”.
Do NOT use the remarks box at the bottom.

25. System error message will not allow you to submit H-10.
Find red triangle and correct. Click “process”.
A red error message will prevent you from filing the H10. Find the red triangle and resolve the error.
Just call me if you don’t know how to handle the error message.
In this example you see that the interval was blank (item 16). If that is resolved and you try processing again, you will get another error message and triangle in front of the tubing packer (item 17) because it is also blank.
Resolve both and then process.
If you would have filed this H10 in hard copy, you would have received a reject letter. This shows how much more effective it is to file online.

26. You will go to the bottom of the H10 to click on process when you are done.
When you process an H10, you will see a message asking you to submit, you confirm the submittal and then you will see the message on top.

27. Print Form H-10 after filing
Anytime you would like to print your H10, you can use the PDF logo at the bottom.
Click on “Printable version”.
You don’t have to do that now. You can always go to Search for H10 and print out any H10 that you filed online since 2007.
The operator now can click on Return to list and file the next H-10 from the list we showed earlier.

28. Hard copy Form H-10 filing
Form is outsourced, 5 – 6 days turnaround.
Time sensitive, affects severances / seals.
Enforcement continues even if form is received.
Outdated forms are rejected and not entered.
Use pre-populated form posted online.
Let’s talk about hard copy H10 filing.
It is outsourced so the H10 information is entered by a third party. This means that it takes time for the form to be received by the third party and for the data to be entered.
If there are errors, the form is rejected and not entered. Enforcement continues until the form is entered by the third party.
Old forms and example forms that are missing information are rejected and returned to the operator.

29. How to find pre-populated Form H-10 at the RRC website.
Find Form H-10
How to find pre-populated Form H-10 at the RRC website.
If that did not scare you and you still want to file a hard copy H10, let’s try to find the correct form H10.
Go to the RRC website
Under the pictures of the Commissioners, click on Data-Online Research Queries.

30. Scroll down to the list of the Queries and the H10 Query is the fifth on the list. Click on Launch Application.

31. H-10 Query
Here you will click on “Print H10…”

32. You will now have to enter the Operator number. Then click Search.
Use the Operator Query to find the operator number if you don’t have it.

33. That takes you to the screen where the H10s are posted that need to be completed. Click on “Blank H10” and print out the blank Form H10.

34. Violations / rejects System checks for violations and rejections.
System may place them in queue for review.
Violation notification is mailed to operator.
If no response within 30 days, certified letter is mailed to operator.
If not resolved in 30 days, automatic severance / seal is issued.
To lift severance / seal, resolve violation and pay $750 reconnect fee.
Now let’s talk about violations and rejects.
Rejects are hard copy H10s that have a problem and they are returned to the operator via mail. Think about the red triangle we saw earlier when we filed online.
Some examples are: No UIC # on the form, API is blank, Form H10 from the forms library is used, well # is not valid…
The system may place violations in a queue for review.
Sometimes I will resolve violations internally from the queue after review.
Sometimes, violation letters are sent to operators. The operator then needs to respond.
The letter reminds you that this is urgent because there is an automatic enforcement process that will sever / seal the lease if there is no response within 30 days.
Call me if you have questions. If a data error was made in the H10 filing and a correction will resolve the violation, you can just make a correction. I will explain how that works later.
To resolve a severance/seal, resolve the violation first, then pay the fee via phone or with a check.

35. Finding Violations using the H-10 Query.
Anyone can find violations in the H-10 Query. You don’t have to be logged in.
If you would like to research your violations, go to the H10 Query.
Click on “Search for Violations”.

36. Enter any of these search criteria to find the UIC well.
Use UIC or API#. Again, no preceding 0’s before the UIC#.
OR you can use the middle section.
Enter the date range.
Click search.

37. Internal and external violations. Check violation status.
The first violation was resolved by the operator, either by correcting the data error or by contacting the H-10 dep.
Look at the second violation. It is an internal violation that I would resolve.
The violations that are not resolved will show an “Active” status.

38. Send hard copy corrections via mail or email to h10info@rrc.texas.gov
Contact H-10 Department to resolve violation if needed.
Contact H-10 Department if permit amendment needed to resolve violation.
The H10 Department can be contacted via or phone. Here you see the address.
When you need to resolve a violation, send an to this address and explain. Make sure to include the UIC# or API# in the .
You will also need to contact the H10 Department when a permit amendment is needed to resolve the violation.
All second year violations need to be resolved with the H-10 department so they require a call or .

39. Violation hold is removed when permit is amended.
60 Day violation hold is implemented pending preparation of permit amendment.
Hold is removed if amendment application is not received within 60 days.
Violation hold is removed when permit is amended.
When a permit amendment is needed to resolve a violation, the operator will need to call the H10 Department.
I will place the violation on a 60-day hold.
This means that the operator has 60 days to prepare the permit amendment packet and it have it stamped at the UIC Department.
If the amendment packet is not received within those 60 days, the violation hold is removed and the enforcement process will continue.
When the permit is amended, the hold is removed and that should automatically resolve the violation.

40. Make correction on a filed H-10.
If you need to make a correction on a hard copy H-10, you will just have to send a corrected copy via mail or .
I will show you quickly how you can correct an H-10 that was filed and already processed online.
To make a correction on an H10 that was filed and processed previously, you will log in with User ID and Password and click in “File H10”.

41. We are back in the H-10 filing system.
This time we will scroll down to the bottom of the page and enter the UIC number (no preceding zeros), the due date – month and year only and do not use a slash or dash. Click search.
You will then click on File and you are back into the report. See instructions on next slide.

42. Instructions for correcting H-10.
Go to: File H-10.
Scroll down to the bottom of the page.
Enter UIC#, no preceding zeros.
Enter H-10 due date, month and year only, no slash or dash.
Click “Search”.
Click File at end of the line.
Make correction.
Submit corrected H-10.
I am not going to explain step by step how you can make an H10 correction online but here are the steps in case you ever need to make a correction in the future. I wanted to include it in this packet in case you ever need the instruction. I do receive calls about this.

43. Form H-10 not set up online?
Please contact the H-10 department Tel: or
Online Forms H-10 can be set up quickly.
Jim Moore explains some of the reasons an H10 is not set up online because the mail date ended.

44. Partial H-10 can not be filed.
Transfers
Partial H-10 can not be filed.
Well transfers in the middle of H-10 cycle year, new operator files H-10.
UIC permits (wells not drilled) have no lease #. Application can be submitted by new operator to obtain permit.
I receive this question very often.
Who files the H-10 if the well transfers to a new operator in the middle of the year? You can not file a partial H10.
This is how it works. The previous operator provides the H10 information to the new operator at time of transfer.
The new operator can then file the H10 for the entire cycle year when it is due.
Another question that I receive frequently.
An operator will receive a letter that they need to file an H10 for a well not drilled. This is what we call a 0 lease well. They call me and say that they sold that lease. Wells that are drilled are transferred via P4 (lease transfer) but not these 0 lease permits. The new operator will need to submit a permit amendment to obtain that permit or the current operator may request to cancel the permit.

45. Inactive well problems?
Please contact the H-10 department Tel: or
Injection well on the W10 (producing) schedule, will be corrected.
W2/G1 (active injection) may be required to bring well in compliance.
W2/G1 (well record only) may be required for well to become active (HB 2259 P5 Dep).
Jim Moore will elaborate.

46. What else can I find on the H-10 Query?
The “Injection Volume Query” will give you total volumes, not by well but by county – district – operator etc.
The “Fluid Type Query” is for research on the fluids that are injected.
The “Filing Cycles by Field” will give you the H10 due date and cycle year.
The “Search for UIC” Query will give you the UIC number of an injection well.
The “Search for H10” will show you all H10s online since 2007 and the status. If you are logged in, you can also print out H10s from this Query.

47. H-10 department: Tel: 512-463-2903 h10info@rrc.texas.gov
Contact information
H-10 department:
Tel:
Here is the contact information.