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Brammer Broadcast

October 2022 | Issue 2022.4

Welcome to Brammer Broadcast. Brammer Engineering, Inc. is a full service contract operating, property management and consulting firm founded in 1968 in Shreveport, Louisiana. Thanks for taking a moment to let us share some news and information about our industry and our company...a longtime outsourcing resource for the oil and gas industry.
Background: Brammer Engineering, Inc. began managing the subject well in late 2020. The well was drilled and completed in Northwest Louisiana during the mid-1950’s and had been producing in the same zone since. When Brammer first got involved, the well had averaged 271 MCF/mo and 0 BO/mo over the past 12-months. It was “flowing” into a low pressure gathering system (Line Pressure = 45#). Our client was ready to shut in the well and put it on their P&A list since the leasehold was held by other producing wells in a fieldwide unit. Brammer’s operational team over the asset was not ready to shut in the well until they had thoroughly evaluated every opportunity for improvement. There were very poor records kept on the well by the previous operator(s). However, when reviewing the production history on the state website, our operational group got encouraged that this well may have some meat left on the bone. The Brammer team quickly got to calling vendors in the area to gather all information they could related to the subject well. 

Click here to read about Brammer's approach and result on revitalizing this mature well. 
The new Inflation Reduction Act includes a provision for levying a methane charge to onshore and offshore oil and gas production, natural gas processing, transmission, and storage sectors of the oil and natural gas industry. This is the first time the federal government has directly imposed a charge, or tax on Greenhouse Gas emissions. The details are still somewhat “up in the air,” but the directive will apply to companies that are subject to filing annual greenhouse gas inventories under Part 98 Subpart W. The fee is set at $900 per metric ton of methane emissions for calendar year 2024, $1,200 for 2025, and $1,500 for 2026 and future years and will be based on emissions reported in the companies’ greenhouse gas inventory reports. There are some potential exemptions to the fee tied to compliance with the proposed NSPS OOOOb and OOOOc amendments which have not been finalized to date. 
More information can be found in the summary titled Inflation Reduction Act Methane Emissions Charge: In Brief published August 29, 2022 by the non-partisan Congressional Research Service.

Please contact Will Ward, Environmental Manager, if you have any questions or would like to discuss how we can help you manage your air quality compliance requirements.
A reminder from for  Louisiana operators regarding semiannual reports due November 1, 2022:

The Office of Conservation requires all Louisiana Operators with oil and gas wells to electronically file their semiannual DM-1R and DT-1 Well Tests and Inactive Well Reports.

The online reporting system can be accessed at www.sonris.comFollow this link for the User Guide.

A bulk upload feature has been added as of Fall 2019. Once logged in, select the "Upload Excel Template" icon to learn more.

Please note well tests are due November 1st and May 1st each year. All test dates shall be within 60 days prior to the due date of the report.

Any test filed after May 1st or November 1st shall be considered delinquent. Reports more than 30 days delinquent will result in a fine.

Please contact Amanda Wallace, Brammer's Regulatory and Production Reporting Supervisor, for more information.

Federal Register Volume 86, No. 217 Published 11/15/21.  Effective Date 5/16/22.

The new federal regulation will add an estimated 400,000 miles of previously unregulated gathering lines to the Pipeline and Hazardous Materials Safety Administration (PHMSA) jurisdiction. The primary target of the new rule addresses 8.625 inches outside diameter and larger gathering lines that were historically exempt from regulation due to their location in unpopulated areas (Class 1 locations). The new rule also includes non-metallic pipe (plastic, composite, etc.) that is 8.625 inches or greater gathering lines with MAOP greater than 125 psig. Historically, regulated gathering lines in populated areas were classified as Type A or B lines depending on MAOP and populations density. The newly regulated segment is classified as Type C. All other gathering lines that do not fall under Type A, B, or C are designated as Type R gathering lines. 

By November 2022, gathering pipe operators must identify their gathering pipelines. This includes doing class surveys and applying the API RP 80 document (Guidelines for the Definition of Onshore Gas Gathering Lines) to determine gathering status. In addition to expanding the scope of regulated gathering lines, all operators of gathering lines (including Type R) must file annual reports for 2022 due by March 15, 2023. The annual reports must include information including:   

  • Miles of gathering lines by decade of installation 
  • Miles by pipeline diameter 
  • Miles by pipe material and corrosion protection status 
  • Number of leaks repaired or scheduled for repair 
The new rule requires Incident Reporting for both Type C and Type R lines for any event meeting the definition of an incident that occurs after the effective date of the rule (5/16/22).

Click here for additional resources, such as class location definitions, incident report forms, and annual report forms. Brammer's industry experience can help you navigate this new regulation easily, please contact Russ Rogers for more information.
SPCC Plans

SPCC (Spill Prevention, Control & Countermeasures) plans are required by the EPA for facilities with above ground storage capacity greater than 1320 US Gallons (31.4 bbls) with reasonable expectation of discharge into navigable waters of the United States. The definition for a navigable water way listed in (40 CFR 112.2) is rather lengthy and describes anything that has potential to have water in it and could flow towards a larger body of water. In Louisiana, it would be difficult to have an oil & gas well located where it would not flow to waters of the United States. The SPCC plans provide a formal framework to manage and maintain the primary containment (generally above ground tanks) and the secondary containment (generally dirt levees or berms) on most every oil & gas well in the US.

Both the Clean Water Act of 1972 and the Oil Pollution Act of 1990 led to the creation of the SPCC federal regulations 40 CFR 112. The EPA is a federal agency and requires all states to abide by 40 CFR 112 However if a state chooses to have stricter regulations, then you will be required to follow the regulations proposed by the state. In Louisiana the LDEQ is the governing body and requires all SPCC plans to contain: the name of the facility and operator, mailing and physical addresses, date of initial operation, size and containments of each tank on site, a map of the facility, and goes one step farther to add produced water tanks to the applicability of SPCC regulations. These plans also require the stamp of a PE (professional engineer) registered in the state where that facility is located (we are currently registered in nine states).

One of the main things that helps companies remain proactive about preventing spills is the inspection checklist. The checklist makes the operator aware of the corrosion around tank bottoms, worn down berms, and corroded pipes. This inspection shouldn’t take more than a few minutes and most people conduct the inspection without realizing it. However, filling out the checklist and storing it with the plan will make you more mindful of potential problem areas.

It is important to conduct these inspections and make notes of any changes to the facility, whether that be changing tank size or having a company representative retire. If the SPCC plan is not kept up to date, it is not as helpful when responding to an emergency. The plan contains emergency contact numbers and has information pertaining to the storage equipment on location. If the contact information of the responsible parties has changed, it could slow down the response time. It is required that all SPCC Plans be reviewed and revised every 5 years or when something regarding personnel or equipment changes.

Brammer Engineering has created, maintained, and updated thousands of SPCC plans for our vast array of clients. We manage the 5-year reviews and are informed when field equipment or personnel change necessitating the need to make SPCC plan revisions. We keep track of the latest regulatory changes and developments and adapt to make sure all our clients’ SPCC plans are being properly managed and up to date. SPCC Plans are a great way to keep everyone mindful of potential issues that can arise, how they can be avoided, and what to do in case of the worst-case scenario. If you have any questions or if we can help you manage and maintain your SPCC plans, please call or email Matt Henry at (318) 429-2265 or

What is your position at Brammer?
Revenue Accountant 

What responsibilities does that include?
Distribute revenue to owners and general accounting duties.
How long have you been at Brammer?
Six months.

How long in the energy industry?
Six months.

What do you enjoy most about working at Brammer?
I enjoy working with the people and learning a new industry. This is crazy but I have enjoyed learning Quorum, the accounting software. 

What do you think sets Brammer apart?
Brammer is set apart from other organizations by focusing on service and serving others. Brammer has made me feel like part of the "family."

What is the most important thing you have learned since starting at Brammer?
I am coming from a non-profit organization, so everything that I am learning is new and exciting. I cannot think of one most important thing that I have learned since starting at Brammer. It seems all the things that I am learning are important. I guess if I had to narrow it down to one most important thing that I have learned, it would be where Brammer keeps the chocolate!  LOL!

Click here to read the full interview with Becky Booher.


Amanda Wallace
Ashley Rockett
We go the extra mile for our clients!


"Self-praise is for losers. Be a winner. Stand for something. Always have class, and be humble."

- John Madden
Hall of Fame NFL Coach


Ark-La-Tex Production Office
2505 Beech Street
P.O. Box 120
Arcadia, Louisiana 71001
Phone: (318) 263-7500
Fax: (318) 263-7504

Corporate Headquarters
401 Edwards Street, Suite 1510
(Louisiana Tower)
Shreveport, Louisiana 71101
Phone: (318) 429-2345
Fax: (318) 429-2340

Gulf Coast Production Office
113 Heymann Boulevard, Building 7
Lafayette, Louisiana 70503
Phone: (337) 232-2215
Fax: (337) 232-7437

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