Notifying well integrity incidents

The Petroleum and Geothermal Energy Resources (Resource Management and Administration) Regulations 2015 (Regulations) requires a titleholder to have approved well management plan before undertaking a well activity in the title area. However, this requirement does not apply if there is an emergency in which there is a likelihood of injury, significant discharge of fluids from the well, or damage to an underground formation that contains petroleum or geothermal energy resources. It also doesn’t apply to an aquifer or any other part of the environment; and when the title holder undertakes a well activity to avoid the injury, discharge or damage.

Under the above circumstances, the title holder must give the Minister oral or written notice of the emergency within 2 hours after becoming aware of the emergency. After becoming aware of the emergency, the title holder must also notify the Minister within 3 days through written notice of the well activity undertaken.

When an approved well management plan is in force, the Regulations also requires a title holder to undertake well activity in accordance with an approved well management plan. This is unless the afore mentioned circumstances apply.

A title holder must make an application under the Regulations for approval of a revision of the well management plan if any of the following circumstances exists — 

• a change in the understanding of the geology or underground formation that may have a significant impact on the integrity of a well or a well activity to which the approved well management plan relates;
• the occurrence or potential occurrence of a significant new detrimental risk to or effect on the integrity of a well or a well activity to which the approved well management plan relates;
• a significant increase in a detrimental risk to or effect on the integrity of a well or a well activity to which the approved well management plan relates.

Under the Petroleum and Geothermal Energy Resources (Resource Management and Administration) Regulations 2015 (Regulations), there is a requirement to control well integrity hazard or risk if a title holder is operating a well in a title area. This also applies when a well integrity hazard has been identified for the well or if there has been a significant increase in an existing risk for the well.

Other reporting obligations

The Regulations have requirements for submission of daily well activity reports and final well activity data and report.

A daily well activity report includes the information listed in Schedule 5 of the Regulations. An instrument holder must provide the Minister a daily well activity report before midday following the activity day.

A final well activity data includes the type of data mentioned in an item in Schedule 6 of the Regulations. A final well activity report includes the information listed in Schedule 7 of the Regulations.

If the instrument holder undertakes a well activity (other than a drilling activity) in an instrument area, the instrument holder must give the Minister a final well activity report and all final well activity data within 6 months after the well activity’s completion date. These reports are as approved by the Minister or if the Minister authorises the instrument holder to give the report and data within another period.

Compliance and enforcement

If the Department of Mines, Petroleum and Exploration determines that a well activity may have, or has, resulted in non-compliance with the Regulations and/or the approved well management plan, actions outlined below may be taken:

• Undertake a compliance inspection.
• Issue a warning.
• Issue a direction under the Petroleum and Geothermal Energy Resources Act 1967 or Petroleum (Submerged Lands) Act 1982.
• Withdraw the well management plan approval.
• Pursue prosecution.