Gas PR Form filing presents unique challenges due to the continuous flow nature of gas production, multiple gas streams, processing plant operations, and complex balancing requirements. This comprehensive guide covers all aspects of gas-specific PR Form reporting.
Gas Types and Classification
Understanding different gas types is fundamental to accurate PR Form reporting. The RRC requires specific classification of gas based on its source and characteristics.
Primary Gas Classifications:
- Well Gas (Product Code 02): Gas produced from gas wells
- Casinghead Gas (Product Code 02): Gas produced from oil wells
- Condensate (Product Code 03): Liquid hydrocarbons from gas processing
- Residue Gas: Dry gas remaining after processing
Well Production → Separator → Pipeline/Plant → Processing → Products
Gas Quality Considerations:
- BTU Content: Energy content per unit volume
- Specific Gravity: Density relative to air
- H2S Content: Hydrogen sulfide concentration
- CO2 Content: Carbon dioxide percentage
- Water Content: Moisture in the gas stream
Gas Disposition Codes
Gas disposition codes are more complex than oil codes due to the variety of gas handling methods and processing options.
| Code | Description | Usage Guidelines | Authorization Required |
|---|---|---|---|
| 01 | Sold | Gas sold to pipelines, utilities, or marketers | No |
| 02 | Used for fuel | Lease fuel, compressor fuel, heating | No |
| 03 | Flared | Gas flared with proper authorization | Yes - RRC permit |
| 04 | Vented | Gas vented (emergency situations only) | Yes - emergency only |
| 05 | Injected | Gas injected for enhanced oil recovery | Yes - injection permit |
| 06 | Plant intake | Gas delivered to processing plants | No |
| 07 | Line loss | Normal pipeline and system losses | No |
Gas Balance Requirements
Gas balancing is more complex than oil due to continuous flow, measurement timing differences, and processing plant operations. The RRC allows specific tolerances for gas balance variances.
Balance Tolerance Rules:
- Volumes > 10,000 MCF: ±2% tolerance
- Volumes < 10,000 MCF: ±200 MCF tolerance
- Zero tolerance: Negative disposition volumes
- Special cases: Plant processing may have extended tolerances
Balance Calculation Example
Production: 50,000 MCF
Tolerance: ±1,000 MCF (2% of 50,000)
Acceptable Range: 49,000 - 51,000 MCF
Dispositions:
• Sales: 45,000 MCF
• Fuel: 3,000 MCF
• Flare: 1,500 MCF
• Line Loss: 500 MCF
• Total: 50,000 MCF ✓ (Perfect Balance)
Commingling Operations
Commingling occurs when gas from multiple leases is combined before measurement or processing. This requires special reporting procedures and RRC authorization.
Commingling Requirements:
- RRC Authorization: File Form P-4 before operations
- Allocation Method: Document how volumes are allocated
- Measurement Points: Identify where measurements occur
- Quality Adjustments: Account for BTU and quality differences
- Record Keeping: Maintain detailed allocation records
Common Allocation Methods:
- Proportional by Production: Based on individual well production
- BTU Weighted: Adjusted for gas quality differences
- Meter-Based: Using individual lease meters
- Engineering Estimates: Based on reservoir characteristics
Commingling Allocation Example
Total Commingled Sales: 100,000 MCF
Individual Lease Production:
• Lease A: 30,000 MCF (30%)
• Lease B: 45,000 MCF (45%)
• Lease C: 25,000 MCF (25%)
• Total: 100,000 MCF
Allocated Sales:
• Lease A: 30,000 MCF
• Lease B: 45,000 MCF
• Lease C: 25,000 MCF
Plant Processing and Reporting
Gas processing plants extract valuable liquids from raw gas, creating multiple products that must be properly allocated back to the originating leases.
Plant Reporting Components:
- Plant Intake: Raw gas delivered to plant
- Plant Products: Condensate, propane, butane, etc.
- Residue Gas: Dry gas after processing
- Plant Fuel: Gas used for plant operations
- Plant Losses: Processing losses and shrinkage
Raw Gas Input → Processing → Liquids + Residue Gas + Fuel + Losses
Product Allocation Methods:
- Volumetric Basis: Based on input gas volumes
- Energy Basis: Based on BTU content
- Liquid Content: Based on GPM (gallons per MCF)
- Contract Terms: As specified in processing agreements
Flare and Vent Reporting
Flaring and venting require special attention due to environmental regulations and RRC oversight. Proper documentation and authorization are essential.
Flare Authorization Requirements:
- RRC Permit: Obtain flaring authorization before operations
- Volume Limits: Stay within authorized volumes
- Time Limits: Comply with authorization duration
- Reporting: Include authorization numbers in PR Forms
- Renewals: Apply for extensions before expiration
Acceptable Flaring Reasons:
- Initial production testing
- Equipment maintenance and repairs
- Pipeline capacity constraints
- Safety and emergency situations
- Temporary processing plant outages
Venting Restrictions:
- Emergency Only: Venting allowed only for safety
- Immediate Reporting: Report venting incidents promptly
- Minimize Duration: Reduce venting time to minimum necessary
- Documentation: Maintain detailed incident records
Common Gas PR Form Errors
Avoid these frequent mistakes that cause gas PR Form rejections:
Balance Errors:
- Measurement timing: Production and sales measured at different times
- Plant processing delays: Input/output timing mismatches
- Meter calibration: Inaccurate measurement equipment
- Pressure/temperature corrections: Improper standard conditions
Authorization Issues:
- Missing flare permits: Flaring without RRC authorization
- Expired authorizations: Using outdated permit numbers
- Exceeded limits: Flaring beyond authorized volumes
- Wrong authorization numbers: Incorrect permit references
Commingling Problems:
- Unauthorized commingling: Operations without Form P-4
- Incorrect allocations: Wrong allocation methodology
- Missing documentation: Inadequate allocation records
- Quality adjustments: Failure to account for BTU differences
Best Practices for Gas PR Forms
Follow these proven strategies for accurate gas PR Form filing:
Measurement and Data Collection:
- Calibrate meters regularly and maintain calibration records
- Apply proper temperature and pressure corrections
- Synchronize measurement timing across all points
- Document all gas quality measurements
Authorization Management:
- Maintain current flare and vent authorizations
- Track authorization expiration dates
- Apply for renewals well in advance
- Keep authorization numbers readily available
Balance Validation:
- Implement automated balance checking
- Investigate variances exceeding tolerances
- Document reasons for balance adjustments
- Maintain supporting calculation records