N.M. Admin. Code § 19.15.12.11 - DOWNHOLE COMMINGLING

A. The director may grant an exception to 19.15.12.9 NMAC to permit the commingling of multiple producing pools in existing or proposed well bores when the following conditions are met.

(1) The fluids from each pool are compatible and combining the fluids will not damage the pools.

(2) The commingling will not jeopardize the efficiency of present or future secondary recovery operations in the pools to be commingled.

(3) The bottom perforation of the lower zone is within 150 percent of the depth of the top perforation in the upper zone and the lower zone is at or below normal pressure with normal pressure assumed to be 0.433 psi per foot of depth. If the pools to be commingled are not within this vertical interval, then evidence is required to demonstrate that commingling will not result in shut-in or flowing well bore pressures in excess of any commingled pool's fracture parting pressure. The fracture parting pressure is assumed to be 0.65 psi per foot of depth unless the applicant submits other measured or calculated pressure data acceptable to the division.

(4) The commingling will not result in the permanent loss of reserves due to cross-flow in the well bore.

(5) Fluid-sensitive formations that may be subject to damage from water or other produced liquids are protected from contact with the liquids produced from other pools in the well.

(6) If any of the pools being commingled is prorated, or the well's production has been restricted by division order in any manner, the allocated production from each producing pool in the commingled well bore shall not exceed the top oil or gas allowable rate for a well in that pool or rate restriction applicable to the well.

(7) The commingling will not reduce the value of the total remaining production.

(8) Correlative rights will not be violated.

B. The director may rescind authority to commingle production in a well bore and require the operator produce the pools separately if, in the director's opinion, waste or reservoir damage is resulting, correlative rights are being impaired or the efficiency of a secondary recovery project is being impaired, or any changes or conditions render the installation no longer eligible for downhole commingling.

C. When the conditions set forth in Subsection A of 19.15.12.11 NMAC are satisfied, the director may approve a request to downhole commingle production in one of the following ways.

(1) Individual exceptions. An operator shall file applications to downhole commingle in well bores located outside of an area subject to a downhole commingling order issued in a "reference case" and not within a pre-approved pool or area on form C-107-A with the division.

(a) The director may administratively approve a form C-107-A in the absence of a valid objection filed within 20 days after the division's receipt of the application if, in the director's opinion, waste will not occur and correlative rights will not be impaired.

(b) In those instances where the ownership or percentages between the pools to be commingled is not identical, applicant shall send a copy of form C-107-A to interest owners in the spacing unit by certified mail, return receipt requested.

(c) The applicant shall send copies of form C-107-A to the state land office for wells in spacing units containing state lands or the BLM for wells in spacing units containing federal or tribal lands.

(d) The director may set an administratively filed form C-107-A for hearing.

(2) Exceptions for wells located in pre-approved pools or areas. Applicants shall file applications to downhole commingle in well bores within pools or areas that have been established by the division as "pre-approved pools or areas" pursuant to Paragraph (2) of Subsection D of 19.15.12.11 NMAC on form C-103 at the appropriate division district office. The district supervisor of the appropriate division district office may approve the proposed downhole commingling following receipt of form C-103. In addition to the information required by form C-103, the applicant shall include:

(a) the number of the division order that established pre-approved pool or area;

(b) the names of pools to be commingled;

(c) perforated intervals;

(d) allocation method and supporting data;

(e) a statement that the commingling will not reduce the total remaining production's value;

(f) in those instances where the ownership or percentages between the pools to be commingled is not identical, a statement attesting that applicant sent notice to the interest owners in the spacing unit by certified mail, return receipt requested of its intent to apply for downhole commingling and no objection was received within 20 days of sending this notice; and

(g) a statement attesting that applicant sent a copy of form C-103 to the state land office for wells in spacing units containing state lands or the BLM for wells in spacing units containing federal or tribal lands using sundry notice form 3160-5.

(3) Exceptions for wells located in areas subject to a downhole commingling order issued in a "reference case". Applicants shall file applications to downhole commingle in well bores within an area subject to a division order that excepted any of the criteria required by 19.15.12.11 NMAC or form C-107-A with the district supervisor of the appropriate division district office and, except for the place of filing, shall meet the requirements of the applicable order issued in that "reference case".

D. Applications for establishing a "reference case" or for pre-approval of downhole commingling on an area-wide or pool-wide basis.

(1) Reference cases. If sufficient data exists for a lease, pool, formation or geographical area to render it unnecessary to repeatedly provide the data on form C-107-A, an operator may except any of the various criteria required under 19.15.12.11 NMAC or set forth in form C-107-A by establishing a "reference case". The division, upon its own motion or application from an operator, may establish "reference cases" either administratively or by hearing. Upon division approval of such "reference cases" for specific criteria, the division shall require subsequent form C-107-A only to cite the division order number that established the exceptions and not require the applicant to submit data for those criteria. The division may approve applications involving exceptions to the specific criteria required by 19.15.12.11 NMAC or by form C-107-A after the applicant sends notice to the interest owners in the affected spacing units by certified mail, return receipt requested, based on evidence that the approval would adequately satisfy the conditions of Subsection A of 19.15.12.11 NMAC.

(2) Pre-approval of downhole commingling on a pool-wide or area-wide basis. If sufficient data exists for multiple formations or pools that have previously been commingled or are proposed to be commingled, the division, upon its own motion or application from an operator, may establish downhole commingling on a pool-wide or area-wide basis either administratively or by hearing.

(a) Applications for pre-approval shall include the data required by form C-107-A, a list of the names and address of operators in the pools, previous orders authorizing downhole commingling for the pools or area and a map showing the location of wells in the pools or area and indicating those wells approved for downhole commingling.

(b) The director may approve applications for pre-approval of downhole commingling on a pool-wide or area-wide basis after the applicant sends notice to operators in the affected pools or area by certified mail, return receipt requested, based on evidence that such approval adequately satisfies the conditions of 19.15.12.11 NMAC.

(c) Upon approval of certain pools or areas for downhole commingling, an operator may obtain approval for subsequent applications for approval to downhole commingle wells within those pools or areas by filing form C-103 in accordance with Paragraph (2) of Subsection C of 19.15.12.11 NMAC.

(3) The division shall maintain and continually update a list of pre-approved pools or areas in Subsection E of 19.15.12.11 NMAC.

E. Pre-approved pools and areas. Downhole commingling is approved within the following pool combinations or geographical areas (provided, however, that the operator shall file form C-103 with the appropriate division district office in accordance with the procedure set forth in Paragraph (2) of Subsection C of 19.15.12.11 NMAC):

Pre-approved pools or geographic areas for downhole commingling, permian basin
All Blinebry, Tubb, Drinkard, Blinebry-Tubb, Blinebry-Drinkard and Tubb-Drinkard pool combinations within the following geographic area in Lea County:
township 18 south, ranges 37, 38 and 39 east	township 23 south, ranges 36, 37 and 38 east
township 19 south, ranges 36, 37, 38 and 39 east	township 24 south, ranges 36, 37 and 38 east
township 20 south, ranges 36, 37, 38 and 39 east	township 25 south, ranges 36, 37 and 38 east
township 21 south, ranges 36, 37 and 38 east	township 26 south, ranges 36, 37 and 38 east
township 22 south, ranges 36, 37 and 38 east
Blinebry pools
6660 Blinebry oil and gas pool (oil)	34200 Justis-Blinebry pool
72480 Blinebry oil and gas pool (pro gas)	46990 monument-Blinebry pool
6670 west Blinebry pool	47395 Nadine-Blinebry pool
12411 Cline lower paddock-Blinebry pool	47400 west Nadine paddock-Blinebry pool
29710 Hardy-Blinebry pool	47960 oil center-Blinebry pool
31700 east Hobbs-Blinebry pool	96314 north Teague lower paddock-Blinebry assoc.
31680 Hobbs upper-Blinebry pool	58300 Teague paddock-Blinebry pool
31650 Hobbs lower-Blinebry pool	59310 east Terry-Blinebry pool
33230 house-Blinebry pool	63780 Weir-Blinebry pool
33225 south house-Blinebry pool	63800 east Weir-Blinebry pool
Tubb pools
12440 Cline-Tubb pool	47530 west Nadine-Tubb pool
77120 Fowler-Tubb pool	58910 Teague-Tubb pool
26635 south Fowler-Tubb pool	96315 north Teague-Tubb associated pool
78760 house-Tubb pool	60240 Tubb oil and gas pool (oil)
33460 east house-Tubb pool	86440 Tubb oil and gas pool (pro gas)
33470 north house-Tubb pool	87080 Warren-Tubb pool
47090 monument-Tubb pool	87085 east Warren-Tubb pool
47525 Nadine-Tubb pool
Drinkard pools
7900 south Brunson Drinkard-abo pool	47505 west Nadine-Drinkard pool
12430 Cline Drinkard-abo pool	47510 Nadine Drinkard-Abo pool
15390 D-K Drinkard pool	57000 Skaggs-Drinkard pool
19190 Drinkard pool	96768 northwest Skaggs-Drinkard pool
19380 south Drinkard pool	58380 Teague-Drinkard pool
26220 Fowler-Drinkard pool	96313 north Teague Drinkard-Abo pool
28390 Goodwin-Drinkard pool	63080 Warren-Drinkard pool
31730 Hobbs-Drinkard pool	63120 east Warren-Drinkard pool
33250 house-Drinkard pool	63840 Weir-Drinkard pool
47503 east Nadine-Drinkard pool
Blinebry-Tubb pools
62965 Warren Blinebry-Tubb oil and gas pool
Tubb-Drinkard pools
18830 dollarhide Tubb-Drinkard pool	33600 imperial Tubb-Drinkard pool
29760 Hardy Tubb-Drinkard pool	35280 Justis Tubb-Drinkard pool
96356 north Hardy Tubb-Drinkard pool
pool-combinations, Lea county
airstrip-bone spring (960) and airstrip-wolfcamp (970) pools Baish-wolfcamp (4480) and maljamar-abo (43250) pools Blinebry oil and gas and Wantz-abo (62700) pools Blinebry oil and gas and south Brunson-Ellenburger (8000) pools Blinebry oil and gas and paddock (49210) pools cerca lower-wolfcamp (11800) and cerca upper-pennsylvanian (11810) pools Drinkard (19190) and paddock (49210) pools Drinkard (19190) and Wantz-abo (62700) pools Drinkard (19190) and Wantz-granite wash (62730) pools lazy J penn (37430) and south Baum-wolfcamp (4967) pools mesa verde-Delaware (96191) and mesa verde-bone spring (96229) pools west red tank-Delaware (51689) and red tank-bone spring (51683) pools south shoe bar-wolfcamp (56300) and south shoe bar upper-penn (56285) pools Skaggs-glorieta (57190) and Skaggs-Drinkard (57000) pools west Triste draw-Delaware (59945) and south sand dunes bone spring (53805) pools Triste draw-Delaware (59930) and Triste draw-bone spring (96603) pools Tubb oil and gas and paddock (49210) pools north vacuum-Abo (61760) and vacuum-wolfcamp (62340) pools vacuum-Blinebry (61850) and vacuum-Glorieta (62160) pools vacuum-Blinebry (61850) and vacuum-Drinkard (62110) pools vacuum upper-penn (62320) and vacuum-wolfcamp (62340) pools Wantz-abo (62700) and Wantz-granite wash (62730) pools
pool combinations, Eddy county
red lake queen-grayburg-san andres (51300) and northeast red lake-glorieta yeso (96836) pools
pool combination, San Juan basin
basin-dakota (71599) and angels peak-Gallup associated (2170) pools basin-dakota (71599) and Armenta-Gallup (2290) pools basin-dakota (71599) and Baca-Gallup (3745) pools basin-dakota (71599) and bisti lower-Gallup (5890) pools basin-dakota (71599) and BS mesa-Gallup (72920) pools basin-dakota (71599) and Calloway-Gallup (73700) pools basin-dakota (71599) and devils fork-Gallup associated (17610) pools basin-dakota (71599) and ensenada-Gallup (96321) pools basin-dakota (71599) and flora vista-Gallup (76640) pools basin-dakota (71599) and Gallegos-Gallup associated (26980) pools basin-dakota (71599) and ice canyon-Gallup (93235) pools basin-dakota (71599) and Kutz-Gallup (36550) pools basin-dakota (71599) and Largo-Gallup (80000) pools basin-dakota (71599) and otero-Gallup (48450) pools basin-dakota (71599) and Tapacito-Gallup associated (58090) pools basin-dakota (71599) and wild horse-Gallup (87360) pools basin-dakota (71599) and Aztec-pictured cliffs (71280) pools basin-dakota (71599) and Ballard-pictured cliffs (71439) pools basin-dakota (71599) and blanco-pictured cliffs (72359) pools basin-dakota (71599) and south blanco-pictured cliffs (72439) pools basin-dakota (71599) and Fulcher Kutz-pictured cliffs (77200) pools basin-dakota (71599) and west Kutz-pictured cliffs (79680) pools basin-dakota (71599) and Tapacito-pictured cliffs (85920) pools basin-fruitland coal (71629) and Aztec-pictured cliffs (71280) pools basin-fruitland coal (71629) and Ballard-pictured cliffs (71439) pools basin-fruitland coal (71629) and blanco-pictured cliffs (72359) pools basin-fruitland coal (71629) and east blanco-pictured cliffs (72400) pools basin-fruitland coal (71629) and south blanco-pictured cliffs (72439) pools basin-fruitland coal (71629) and carracas-pictured cliffs (96154) pools basin-fruitland coal (71629) and choza mesa-pictured cliffs (74960) pools basin-fruitland coal (71629) and Fulcher Kutz-pictured cliffs (77200) pools basin-fruitland coal (71629) and west Kutz-pictured cliffs (79680) pools basin-fruitland coal (71629) and Gavilan-pictured cliffs (77360) pools basin-fruitland coal (71629) and gobernador-pictured cliffs (77440) pools basin-fruitland coal (71629) and huerfano-pictured cliffs (78840) pools basin-fruitland coal (71629) and Potwin-pictured cliffs (83000) pools basin-fruitland coal (71629) and Tapacito-pictured cliffs (85920) pools basin-fruitland coal (71629) and twin mounds fruitland sand-pictured cliffs (86620) pools basin-fruitland coal (71629) and W. A. W. fruitland sand-pictured cliffs (87190) pools blanco-mesaverde (72319) and basin-dakota (71599) pools blanco-mesaverde (72319) and blanco-pictured cliffs (72359) pools blanco-mesaverde (72319) and south blanco-pictured cliffs (72439) pools blanco-mesaverde (72319) and gobernador-pictured cliffs (77440) pools blanco-mesaverde (72319) and west lindrith Gallup-dakota (39189) pools blanco-mesaverde (72319) and Tapacito-pictured cliffs (85920) pools blanco-mesaverde (72319) and Armenta-Gallup (2290) pools blanco-mesaverde (72319) and BS mesa-Gallup (72920) pools blanco-mesaverde (72319) and Calloway-Gallup (73700) pools blanco-mesaverde (72319) and ensenada-Gallup (96321) pools blanco-mesaverde (72319) and flora vista-Gallup (76640) pools blanco-mesaverde (72319) and Largo-Gallup (80000) pools blanco-mesaverde (72319) and west lindrith Gallup-Dakota (39189) pools blanco-mesaverde (72319) and McDermott Gallup (81050) pools blanco-mesaverde (72319) and Potter-Gallup (50387) pools blanco-mesaverde (72319) and Tapacito-Gallup associated (58090) pools blanco-mesaverde (72319) and wild horse-Gallup (87360) pools otero-chacra (82329) and Aztec-pictured cliffs (71280) pools otero-chacra (82329) and basin-dakota (71599) pools otero-chacra (82329) and blanco-mesaverde (72319) pools otero-chacra (82329) and south blanco-pictured cliffs (72439) pools otero-chacra (82329) and Fulcher Kutz-pictured cliffs (77200) pools

Notes

N.M. Admin. Code § 19.15.12.11

19.15.12.11 NMAC - Rp, 19.15.5.303 NMAC, 12/1/08