Field Inspection Report Resolution

FIRR

Intro

Goals of the Lean Event A team of Operators and COGCC Personnel were challenged to propose changes so that:

There is a standard, easy to understand and well documented Field Inspection and reporting process.

Information is communicated in a manner in which Operators can read a Field Inspection Report (FIR) and immediately have a clear understanding of what needs to be done next to resolve the issues.

Corrective Action (CA) dates are perceived as both fair and consistent.

Team Operators -- Sabre Beebe, Randall Ferguson, Rusty Frishmuth,

Mike Gardner, Dwayne Knudson, Susi Lara-Mesa

COGCC -- Chuck Browning, Alex Fischer, Mike Leonard, Craig Quint, Jeff Rickard

Facilitators – Dave Kulmann, Greg Bellomo

Process Summary Over 5 days across 2 weeks, the team: • Mapped the current process • Recognized pain points and wastes • Documented 29 issues with the current inspection

and reporting process • Specified improvements for 21 issues in 7 categories

(Parking lot the others)

Within the 7 categories: • The team developed drafts of procedures, guidance,

and forms, where possible • The team created an implementation plan to

complete and follow-up on remaining items

Seven Recommendations Redesign the FIR (#1)

FIR is too long, info is hidden, apply consistent ratings

Bring information upfront in first page summary, shorten the

report, put general comments in blue text while leaving

actionable language red text

Develop an FIR Resolution Process / Form (#2 & 3)

Implement a process to address factual errors in the report

before the reports go public.

Allow for easier way to approve CAs

Seven Recommendations Develop a CA Matrix (#4)

Ensure greater consistency in how long an operator has to

address an issue.

Consistent language and rule citation

Clarify Internal FIR Guidance (#5)

Develop immediate operator notification standards (#6)

Develop Alternative Means of Inspection (#7)

Updated Forms

FIRR Process ● Inspection Is performed

● Inspection Report (FIR) Is Uploaded - Submitted

● Factual Review Clock Starts – 7 Days

● Process can take 2 tracks I. Request for Factual Review of all or some CA’s

II. No Factual Reviews are requested

FIRR Process ● Inspection is performed

● Observations are documented

● If corrective actions are required corrective action matrix should be used where possible

FIRR Process ● Inspection is uploaded to database

● Operator receives notice via email

FIRR Process ● Factual Review Clock Starts

— 7 days from day of submission

— Inspection is “In Process” in system

— Is not publicly available

● Operator reviews inspection form

● Operator determines which of 2 tracks to pursue — Both of these options are OPTIONAL!!

Review FIR – Updated PDF

07/30/2016

Executive Summary on first page Inspection and submission date Auto populated if CAs exist

FIR Updated (shortened)PDF

Only pages with text will populate on pdf

FIR Updated (shortened)PDF

Only wells checked as inspected will populate on pdf

FIR Updated PDF

COA’s & BMP’s will populate in the field form

COA’s & BMP’s will not populate in the pdf received by the operator

Review FIR

Blue Text = General Comments Red Text = Corrective Actions

Track 1 – Factual Errors ● Operator has determined there are factual errors in the

report

● These can only be in the categories of: — The location is not owned or operated by the operator.

— The equipment is not owned, operated or under the control of the operator

— The equipment belongs to the surface owner and a waiver exists.

— Findings were tied to multiple wells when it should have been tied to either a single well or the location.

— The corrective action date is not per the established guidelines.

— The corrective action dates are not attainable due to recent or current weather conditions or seasonal limitations.

— Requested documentation was submitted prior to the inspection (Attached documentation is required to verify).

— Action was already completed prior to inspection (Attached documentation is required to verify).

● Interpretation issues not allowed!!

Track 1 – Factual Errors ● Operator accesses COGCC eForm

● Choose FIRR

● Open FIRR with Operator # and Inspection Document #

E-form

Choose FIRR & use FIR Document #

Tab 1 Operator Information

Click “Bring Contacts From FIR”

You can add other contacts if necessary

Tab 2 FIR Summary This Tab is information from FIR . No edits can be made.

Tab 3 Corrective Actions and Response

Click on left side to expand CA Field

Example of an expanded CA

Example of a non- expanded CA

Factual Review Request Choose which CA’s you are responding to. Then pick Factual Review Request

Then pick appropriate category

Factual Review Request

Insert appropriate and complete comment. You are allowed only one Factual Review Request per corrective action

Attach all pertinent documents and photos and Name them in “Desc”

Factual Review Request

Insert your name, title, email address and any other comments you may have

Submit Form

Fill in Submittal Tab

Save will validate and save changes to the form. Validate only ensures the form business rules have been met

If no business rules are broken the “Submit “ button will be available. Clicking will submit this form to the COGCC database

Factual Review Request ● Upon Submitting a Factual Review Request

the time for the inspection report to be publically posted on the website increases from 7 to 17 days from day of submission

● When a review request is made notice will go to the inspector and the inspector’s supervisor

● The supervisor must determine the status of the request

Factual Review Request

Factual Review Request

● Supervisor opens eForm

● Chooses appropriate form

Factual Review Request

● Bring Contacts from FIR

● Review

Factual Review Request

Factual Review Request

● For review requests supervisor must choose either “Approve” or “Not Approved”

● Add comments as to decision.

● Supervisor may choose to delete entire CA or modify it in the inspection report

Factual Review Request ● Supervisor needs to pass both status

tasks and click “Save” or “Save and Exit” to approve this FIRR.

● Supervisor should immediately open inspection report (to be described in detail)

Factual Review Request

● After the tasks are Passed an email notice is sent to the supervisor, inspector and contacts listed on the form.

Factual Review Request

● It is important to note that there is only one chance to make a Factual Review Request per corrective action

● The supervisor’s decision is final

2nd Track -- No Review request ● The operator may resolve a CA at any

time, even prior to the form being publically available on the website

● The goal is to allow operators to show they are meeting their CA dates and alerting inspectors to re-inspect as necessary

● There are also cases where an inspector may approve the CA with documentation provided without the need to re-inspect

E-form

Choose FIRR & use FIR Document #

Tab 1 Operator Information- Repeat

Click “Bring Contacts From FIR”

You can add other contacts if necessary

Tab 2 FIR Summary (Repeat) This Tab is information from FIR . No edits can be made.

Tab 3 Corrective Actions and Response (Repeat)

Click on left side to expand CA Field

Example of an expanded CA

Example of a non- expanded CA

CA Response Choose which CA’s you are responding to. Then pick “CA Completed”.

CA Completed

Insert appropriate and complete comment.

Attach all pertinent documents and photos and Name them in “Desc”

No Review request

Insert your name, title, email address and any other comments you may have

Submit Form

Fill in Submittal Tab

Save will validate and save changes to the form. Validate only ensures the form business rules have been met

If no business rules are broken the “Submit “ button will be available. Clicking will submit this form to the COGCC database

No Review request- Inspector

Inspector receives notice; Supervisor will not see the form

No Review Request -- Inspector

Inspector opens FIRR in Eforms and opens CA Response Box reviews response

Review and chooses appropriate decision

Decisions ● Approved Pending Re-inspection

● Approved via an AMI (Alternate method of inspection

● AMI can be photos or other adequate documentation that will approve the CA

● AMI is completely at the inspectors discretion. See guidance document on AMI at “About Us>Lean” webpage

No Review Request

Inspector chooses decision and Passes Status

Notices

● In all transaction operator or inspector will receive email notice of changes

FIR POSTED

When criteria for “In Process” has been met, the FIR will “POST” to the website. At this point it is publically viewable and no changes to the form can be made

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