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Don't get fooled by the "no compensation". Please read this post about WRGL from another board.
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=72229546
WRGL - The best part is two websites that released it as a "pick" have not been compensated. But what they don't mention is if they own shares they may have front-loaded. I mean look at the volume in the past week. Not to mention the amount of PR's WRGL has released in the past few days - 6 PR's in a week.
3 of them are acquisitions that were "all stock" transactions. Yet the PR's make no mention of how much stock was given out. All 3 are websites hosted by/related to hostlive.com. Julian Sula was the Principal of Hostlive.com before this deal, and now ends up as CEO of WRGL. So he just got a bunch of stock for merging his own companies into WRGL and now there are "non-compensated" picks coming out.....
WRGL acquires Hostwire.com
http://www.itechpulse.com/2012/02/12/wrgl-acquires-hostwire-com/
Julian Sula listed as "Principal" of Hostwire.com
The next day Julian Sula named CEO of WRGL:
http://finance.yahoo.com/news/WRGL-Names-Julian-Sula-New-prnews-3764260786.html?x=0
What are your thoughts? Legit Reverse Merger or Shaddy Dealing to enrich insiders?
WRGL, Shaddy Dealing to enrich insiders.
It looks like WRGL is starting a new P&D!
Well it looks like WRGL is gearing up for a new Pump and dump.
Warrior Girl Corp. was incorporated in 2002 and is based in Miami, Florida.
The company was formerly known as Legacy Home California, LLC and changed its name to Warrior Girl Corp. in September 2004.
Not long ago they were going to make investors rich on their oil sand play. That went bust as usual.
Then it was on to the education business which went nowhere.
I see the OTC/pinksheet site has this, and the word Waring is in red;
Warning! Unsolicited Quotes Only
Investors should be aware that no firm is making a market in this stock on OTC link.
All prices reflect unsolicited customer orders, and investors may have a difficult time selling this stock. Click here for more info on Unsolicited Quotes;
http://www.sec.gov/answers/unsolicitedquotations.htm
Don't get left holding the bag when this Pump and Dump Scam ends!
Did you just say; " I can make Wilmot performe to our satisfaction."
I think you meant to say; I can't make Wilmot perform to our satisfaction.
"Zero is the only figure anyone needs to know about this company. Zero revenue, zero assets, zero production, zero regulatory filings, zero investor confidence, zero honesty."
Add to those zero's, add GSRE/RRRI's zero's in their share price. Remember, pre split, GSRE/RRRI would now be at .00003, and soon to be back to .0001.
"Please explain how the shareholders got "ripped off". Back it up with some figures and documentation."
Simple! Just read all the past PR's this company has put out!
Care to back that up with some actual FACTS!
Projections are an estimate of future possibilities based on a current trend. What Projections are you referring to, and who made them and when.
Nobody even knows the "fine print" details of EGOH'S farm out agreement with Questus. Not knowing all the details, ie, royalty percentages, unforseen problems, etc., along with a million other details, makes a projection impossible, and worthless.
If the projections you refer to are about the amount of oil still in the Siler lease, that would just be a projection of the amount of oil there, but not the cost of extracting it. I have not seen any valid projections about the profitability of theses leasese.
So basically the only thing we disagree on is the amount of profit to be had with this lease.
That is fine. You think it's high, I think it's low.
If you can give me a viable reason for the fact that nothing is getting done by Wimot, or Questus, who I'm sure knows what the Siler lease capabilities are, then I can agree. I have already given you my reasons for thinking the profits to be had are small, basically nothing getting done for the last several years of higher oil prices.
sem1, thank you. Believe it or not, I do care about other investors. I had to learn the hard way years ago concerning these OTC/Pink Sheet penny stocks. I am now 74 years old, and much wiser.
No offense, but I would guess that you are much younger, or new to penny stocks.
You can make money on these scam stocks, but you better know what you are doing, which takes years of experience. I personally don't play them anymore, even when I know I can make money. I feel like I'm part of the scam by participating in and taking some unsuspecting investors money.
Why the SEC doesn't make Pink Sheet/OTC exchange to be fully reporting/transparent like the big boards is beyond me.
Remember the Golden Rule; "Do unto others as you would have them do unto you". Keep this Rule and you will do well in life!
Another Bible saying that I understand VERY WELL. Paraphrased, "You will reap what you sow". The reason I understand it, is because I farmed most of my life, and guess what, I always reaped what I sowed!
Rest assured, Wilmot will reap what he sowed, and others will (and probably has already) done to him what he's done to others.
With all that said;
I agree with you and many here who know the Siler lease, that there may be enough oil there to be economical to recover, providing the price of oil stays up and goes much higher. IMO if it was very economical to recover what's left, the big companies would have snapped up that lease, or Wilmot would have hired a reputable company to do the job for him instead of these scam operators.
As I said before, he can't be as dumb as some think by not getting serious about getting the oil out. That makes me believe that he knows it's not that economical right now, and he can do just as well doing what he's doing.
And I am truly sorry for any losses to you and others here. Like I said before, I've been there and done that. GL
sem1, you say: "I don't need your help," but you asked me what the point of my post was, and I answered.
Then you said; "I need you to post what factual and current. We all know Wilmot background."
What was not factual about his Forbes bio? It may not have been complete, but it was Factual.
And current? How can you judge a persons "current" abilities without looking at his "past"
abilities in the very same business. And agin, the facts are, Wilmot's failure after failure to get anything done. Now for the current part, it's still Wilmot failure after failure.
As for; "Prove me why Wilmot can make more money by doing nothing vs making money pumping oil," I never said he could make "more" money. I said he could make as "much" money. See my post 7954. Now I can't prove that he could make as much money by doing nothing, vs pumping oil but neither can you prove that he could make 10 times more by pumping oil. Also, if you think he's not making money from EGOH, where is he getting money to live on? I'm sure he's paying himself a fat salary as CEO of EGOH!
As for; no "emotions" just facts? My emotions come from seeing investors continuing to get scammed by conmen like Wilmot over and over, and thinking he will change. Remember my little Edmund Burke quote below each of my post's. Please read it again and think about it.
Also the first words of your post were; "I don't need your help". Is that not your emotions speaking?
I fully understand where you are coming from. I've been there, but I have learned from my mistakes. NEVER, NEVER, believe a word that a Pink Sheet/OTC CEO tells you. And never fall in love with a stock, because when you fall in love, your brain will be weakened, which will blind you from the truth.
Now I know you don't like the PAST facts, but here is a better Wilmot bio from businessweek.
Please read it and then ask yourself the question, why has Wilmot not developed his oil fields?
It's evident from his bio that he's not dumb! Some say he's old and senile! Well he wasn't senile many years ago, and he didn't do any better with the oil fields then than now.
http://investing.businessweek.com/research/stocks/people/person.asp?personId=9240429&ticker=EGOH:US
EXECUTIVE PROFILE*
Brian D. Wilmot
Chairman, Chief Executive Officer, President, Principal Financial Officer and Principal Accounting Officer, Eagle Oil Holding Company, Inc.
Mr. Brian D. Wilmot Founded Eagle Environmental Technologies, Ltd. and serves as its Chairman. Mr. Wilmot serves as the Chairman of the Board, Chief Executive Officer, President , Chief Financial Officer , Principal Accounting Officer of Eagle Oil Holding Company, Inc. He served as Chairman, Chief Executive Officer and Principal Financial Officer of Eagle Oil Holding Company, Inc. and Chief Executive Officer of Eagle Environmental Technologies, Ltd. Mr. Wilmot served as President of Eagle Environmental Technologies Ltd., until July 2005. He served as the Chief Executive Officer of Ford-Spoleti Holdings, Inc., since May 2009 and also served as its President. From June 1966 to January 1967, he was a sales representative for Texaco, Inc. From 1966 to 1973, he was Area Supervisor for Texaco Inc. in Minneapolis. In 1969, Mr. Wilmot ranked second in the nation on sales performance. From 1973 to 1979, he co-founded Office Supply Store and Leasing company in California. From 1973 to 1974, he opened an art gallery and antique shop in the Mother Lode area of California. From 1974 to 1979, he was the Owner and Manager of an office supply business in Angels Camp. From 1979 to 1980, organized and co-founded the New Central Sierra Bank, served as the Chairman of the Board, directed all State and Federal approval processes, recruited the directors and President. Mr. Wilmot served as Chairman of Ford-Spoleti Holdings, Inc., and its Director since June 1990. From 1979 to 1981, he operated JAB Enterprises, Inc., and organized local businessmen to form a full-service bank, for which he acted as the Chairman of the Board. From 1981 to 1986, Managing Partner of a new mining project, wrote ERI report, designed mining operation, facilitated the management organization. From 1981 to 1987, sold real estate in the Angels Camp area; did management consulting with small local businesses concerning financing and management problems in the Angels Camp area. From January 1967 to January 1969, Mr. Wilmot was in the U.S. Army. From 1987 to 1994, formed and operated Jaguar Realty, Inc., and developed alternative financing programs for purchasing businesses, including the leveraged buy-outs and financing plans. From 1990 to 1994, was a real estate broker with two offices. He has been a Director of Eagle Environmental Technologies, Ltd., since June 1990. He holds a California Real Estate Broker's license. Mr. Wilmot received an AA Degree in Liberal Arts from Fresno Junior College, Fresno, California in 1964 and BA degree in History from University of Minnesota, Minneapolis in 1966.
"Wilmot was a oil products salesman for Amoco...That is not a executive title. LOL"
And Wilmot has proven that his OIL executive abilities are in TITLE only!
And now he's a SNAKE oil salesman! LOL
If you don't get the POINT, then I can't help you.
How would you know how much he makes NOW compared to what he might be able to make if he actually developed the fields.
He's is not as dumb as you think! If he could make 10 times as much by developing those fields, he would have already done it.
NOBODY, and I mean NOBODY could be that dumb. He's been at it for 18 years. See the Forbes profile article below.
Brian D. Wilmot
Chairman of the Board and Chief Executive Officer
Eagle Oil Holding Company, Inc.
Reno , NV
Sector: FINANCIAL / Property Management
Officer since May 2009
64 Years Old
Brian D. Wilmot, 64, Chairman/CEO, Director. Mr. Wilmot has over 18 years of experience as an executive in the oil industry and is the founder and CEO of Eagle Environmental Technologies Ltd., the former parent company of Eagle Oil, prior to its acquisition by the Company. Prior to forming Eagle Environmental Technologies, he was the managing partner in a gold mining operation, as well as the co-founder of New Central Sierra Bank, which was acquired in 2003 by Western Sierra Bancorp. He also holds a California Real Estate Broker's license. Mr. Wilmot is a graduate of the University of Minnesota.
"Wilmot will make at least 10x more money if he will be capable to produce Oil"
But he would have to work 10 times harder and get his hands dirty! lol
SE and WC continue to CLEARLY explain the situation here, and CLEARLY there are those here
who just don't get it. It's obvious to them, along with some others, including me, that Wilmot will NEVER change! He's figured out how to make as much money by doing nothing, as he would make having to work! What's amazing to me is how he can continue this con, and some here are still falling for it.
"E-mail from Brian said he has another meeting this month with another company in Texas. So in my opinion oil will flow soon and I don't care who gets it out."
Do you have any clue how many times Wilmot has met and engauged another COMPANY over the last 10-15 years. He just made a deal with Questus a few short months ago, now with another NY outfit a couple of days ago, and now he's meeting with another company.
Now what on earth makes you think any OIL will flow soon. NO OIL WILL FLOW AS LONG AS WILMOT IS IN CHARGE!
GSRE is now RRRI.
http://www.otcmarkets.com/stock/RRRI/quote
RRRI means, Rob, Rook, Rape, Investors. lol
RRRI is also in the STOP sign category (no information) on Pink Sheets!
Wilmot won't sell his properties because it's his cash cow without doing any work. Check all the old PR's, he's been at it with these same properties for over 10 years. He gets together with other scam operators with no intention of doing any work. People need to get their heads out of the sand, and see him for what he is, a con man!
SYMBOL CHANGES
DL Date Date Old Symbol New Symbol/Name
1/18/2012 1/19/2012 GSRE RRRI Rock Ridge Resources, Inc. Common Stock
Found on Pink Sheets Daily list.
"The 1 and 2 year charts on EGOH show that a day like today is usually followed by a strong steady rally, in spite of Wilmont! LOL Will history repeat itself?"
That's because when his latest project/Scam fails, he just starts a new one, with a new batch of investors who believe he will succeed this next time. History will probably repeat it's self, RS new name, new financing, etc., etc.
"the update Looks positive to me"
What looks positive in that Wilmot reply?
Even if he actually said something positive, it would be just another bald face LIE.
How many lies does he have to tell you before you quit believing in him?
I think his first words says it all; ""Questus can still function if they start"
IF they start, that sounds a little to iffy to me, so, they haven't even started. No surprise there!
But then the new PR says; "The developers would be able to develop the entire field".
So which is it, "Questus can still start", or would the new developers be able to develop the "entire field" as stated in the PR. How can they develop the entire field if Questus has a valid contract with EGOH? Is there even a "start" date in the contract?
I think we all know Questus is out, and never really was going to do anything. Remember, Questus is a new company on paper only. Look what Questus has done for GSRE, NOTHING!
If anyone REALLY want's to know where EGOH/Wilmot is headed, just read all their back PR's for the last 10-15 years. Has he EVER did what he said he would do in a PR?
"Don't overestimate my influence on him"
Surely you jest!
What you should worry about is Wilmots influence on you. Don't believe a word he says!
"I have a sneaky feeling that old Wilmot is about ready to do something really stupid any day now... It's been awhile now. He can't go real long."
Well WD, it looks like you were right! Wilmot has done it again!
I don't know how many more times he can do this before people will believe that his PAST history DOES matter. He is still running true to form, SCAMMING investors!
Maybe now those who complained about all the NEGATIVE posts will learn to pay attention to them. Like I've said before, selling shares is much easier than working out in the dirty, smelly, oil fields.
" I am not an oil man Se and Wd are and they knew about this and still own shares and if there here I am here."
No offense WC an SE, but do you know, or have you met them personally, or just from their postings. I think they are legit, but you should never take other posters opinions for DD, especially in these pink sheet stocks. Often people like Wilmot will have his own people posing as investors to trick others into buying his shares.
And you don't have to be an "oil man" to read that TRRC report, or EGOH'S PR's, and realize something is BAD WRONG here! I mean, Wilmot has been doing this (scamming investors) for many years here. I must say though that I am surprised that WC and SE believed in Wilmot enough to invest here, given Wilmots past track record. But that was their call to make, not mine, and I respect that.
Also remember that around 99% of these pink sheet stocks are SCAMS. EGOH to me is a NO BRAINER!
"All Wilmont has to do is pay the fine and we are pumping. Lets face it that is all it takes. I am not selling."
Let's face it, that is NOT all it takes!
If it was that simple I'm sure he would have done it by now, but it's not that simple.
In addition to all those EXPENSIVE fines, he has to correct all those violations that he got fined for,
and that takes LOTS of MONEY and TIME! My guess is that it's not WORTH the TIME and MONEY!
I know I'm being redundant, but here it is again, all 18 pages worth of enforcement actions, failures to comply, violations, fines, etc. These wells will never produce oil on Wilmot's watch, and probably not on anyone else's watch, unless oil prices doubles or triples soon.
http://www.rrc.state.tx.us/meetings/ogpfd/6E-0258475PFD.pdf
November 15, 2010 OIL AND GAS DOCKET NO. 6E-0258475
______________________________________________________________________________
ENFORCEMENT ACTION AGAINST B & B OIL, INC. (OPERATOR NO. 039791) FOR VIOLATIONS OF STATEWIDE RULES ON THE W.H. SILER R/A -C- (07611) LEASE, WELL NO. 165, EAST TEXAS FIELD, RUSK COUNTY; W.H. SILER R/A -A1- (08749) LEASE, WELL NOS. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS AND 171, EAST TEXAS FIELD, RUSH COUNTY; AND W.H. SILER R/A -A2- (08750) LEASE, WELL NOS. 140, 173 AND 174, EAST TEXAS FIELD, RUSK COUNTY, TEXAS. ______________________________________________________________________________
APPEARANCES: FOR RESPONDENT:
Joseph F. Wallen, CEO Fred P. Churchman, Field Supervisor
FOR THE RAILROAD COMMISSION OF TEXAS:
Christopher Hotchkiss Keith Barton, Engineer
B & B Oil, Inc. “
Enforcement Section, RRC Field Operations
PROPOSAL FOR DECISION PROCEDURAL HISTORY
COMPLAINT FILED: NOTICE OF HEARING: DATE CASE HEARD: HEARING CLOSED: PFD PREPARED BY: CURRENT STATUS: PFD CIRCULATION DATE:
August 7, 2008 July 20, 2009 September 17, 2009 September 17, 2009 Marshall Enquist, Hearings Examiner Contested
November 15, 2010
STATEMENT OF THE CASE
This proceeding was called by the Commission on the recommendation of the District Office to determine the following:
1. Whether the respondent B & B Oil, Inc. (“B & B”) should be required to place in compliance with Statewide Rule 9(12) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.9(12)] the
W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 149 and 171 (permitted as brackish water disposal wells), East Texas Field, Rusk County;
2. Whether B & B Oil, Inc. should be required to place in compliance with Statewide Rule 13(b)(1)(B) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.13(b)(1)(B)] the W.H. Siler R/A -A1- (08749) Lease, East Texas Field, Rusk County;
3. Whether B & B Oil, Inc. should be required to plug or otherwise place in compliance with Statewide Rule 14(b)(2) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.14(b)(2)] the W.H. Siler R/A -C- (07611) Lease, Well No. 165; the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171; and the W.H. Siler R/A -A2- (08750) Well Nos. 140, 173 and 174, East Texas Field, Rusk County, Texas;
4. Whether B & B Oil, Inc. should be required to place in compliance with Statewide Rule 14(b)(3) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.14(b)(3)] the W.H. Siler R/A - A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 149, 169WS and 170WS, East Texas Field, Rusk County, Texas;
5. Whether B & B Oil, Inc. should be required to place in compliance with Statewide Rule 46(j) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.46(j)] the W.H. Siler R/A -C- (07611) Lease, Well No. 165, East Texas Field, Rusk County;
6. Whether B & B Oil, Inc. violated provisions of Title 3, Oil and Gas, Subtitles A, B and C, Texas Natural Resources Code, Chapter 27 of the Water Code and Commission rules and laws pertaining to safety or prevention or control of pollution by failing to plug the subject wells and/or otherwise failing to place the subject wells and lease into compliance with Statewide Rules 9(12); 13(b)(1)(B); 14(b)(2); 14(b)(3); and 46(j);
7. Whether, pursuant to Texas Natural Resources Code §81.0531, B & B Oil, Inc. should be assessed administrative penalties of not more than $10,000 per day for each offense committed regarding the subject leases and wells; and
8. Whether any violations of Statewide Rules 9(12); 13(b)(1)(B); 14(b)(2); 14(b)(3); and 46(j) made by B & B Oil, Inc. should be referred to the Office of the Attorney General for further civil action pursuant to Texas Natural Resources Code §81.0534.
A Notice of Hearing was issued in this case on July 20, 2009 for the hearing date of September 17, 2009. B & B Oil, Inc. President/Secretary/Treasurer Joseph F. Wallen and B & B Field Supervisor Fred Churchman appeared at the hearing on behalf of B & B Oil, Inc. and offered evidence. Christopher Hotchkiss, Staff Attorney, appeared to represent Enforcement. Enforcement’s certified hearing file was entered into evidence.
MATTERS OFFICIALLY NOTICED
The examiner has taken Official Notice of Commission Mainframe records of B & B Oil, Inc., including the P-5 screen, Officer screen, P-5 Financial Assurance, and “On-Schedule Leases, Wells and Wellbore by Operator” as of September 28, 2010. These show that B & B is an active operator with financial assurance in the form of $250,000 Letter of Credit. B&B operates 52 leases and approximately 355 wells, of which 330 are inactive under Statewide Rule 14(b)(2).
AUTHORITY
Statewide Rule 9(12) [16 TEX. ADMIN. CODE §3.9(12)] requires that each disposal well completed with surface casing set and cemented through the entire interval of protected usable quality water shall be tested for mechanical integrity at least once every five years.
Statewide Rule 13(b)(1)(B) [16 TEX. ADMIN. CODE §3.13(b)(1)(B)] provides that wellhead assemblies shall be used on wells to maintain surface control of the well. Maintenance of surface control is necessary not only to prevent fluids from being discharged from the wellbore onto the ground surface, but also to prevent any oil and gas wastes present in the wellbore from being displaced to the surface by influxes of surface water into the open wellbore.
Statewide Rule 14(b)(2) [16 TEX. ADMIN. CODE §3.14(b)(2)] requires the commencement of plugging operations on each dry or inactive well within one year after drilling or operations cease, unless the operator is eligible for and obtains an extension of the plugging deadline under Statewide Rule 14(b)(2).
Statewide Rule 14(b)(3) [16 TEX. ADMIN. CODE §3.14(b)(3)] requires the operator of any well more than 25 years old that becomes inactive and subject to the provisions of this subsection to plug the well or successfully conduct a fluid level or hydraulic pressure test establishing that the well does not pose a potential threat of harm to natural resources, including surface and subsurface water, oil and gas.
Statewide Rule 46(j) [16 TEX. ADMIN. CODE §3.46(j)] provides that each injection well shall be pressure tested at least once every five years to determine if there are leaks in the casing, tubing or packer.
DISCUSSION OF THE EVIDENCE
Enforcement
B & B Oil, Inc. (“B & B”) has reported itself to the Commission as a Corporation performing activities in the State of Texas regulated by the Commission. Joseph F. Wallen is the sole officer of B & B and was listed as President, Secretary and Treasurer during the time of the pled violations.
B & B designated itself the operator of the W.H. Siler R/A -C- (07611) Lease, Well No. 165, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority),
effective July 1, 2004, approved July 7, 2004. B & B designated itself the operator of the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008 [this was a lease subdivision]. B & B designated itself the operator of the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008 [this was a lease subdivision].
Statewide Rule 9(12)
The W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 149 and 171 were permitted as brackish water disposal wells on February 1, 1984 (Permit No. 02930). The wells are required to be pressure tested annually and the Form H-5s (Disposal/Injection Well Pressure Test Report) submitted to the Commission. The wells were most recently tested on April 4, 2005 for Well No. 11, most recently on July 6, 2007 for Well No. 146, most recently on May 26, 2006 for Well No. 149 and most recently on January 31, 2004 for Well No. 171. No tests have been submitted since those dates.
Commission District office inspection reports made on May 15, 2008 for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 147 and 171 indicate the wells are inactive and have not passed the required H-5 tests. The lease was severed by Commission personnel on May 16, 2008 for the delinquent H-5 violations.
By failing to demonstrate the mechanical integrity of the subject wells in accordance with the provisions of the corresponding disposal permits and the Commission Statewide Rule 9(12), B & B violated Statewide Rule 9(12) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.9(12)].
B & B’s violations of Statewide Rule 9(12) are serious and threaten the public health. Mark England, Engineering Specialist in the RRC Field Operations Section stated in an affidavit “A disposal well that has not been tested for mechanical integrity, as required by its permit and by Commission Rule 9(12)(c)(i), is a potential source of pollution in that if the subject well is leaking, waste may not be confined to the permitted injection interval so that usable quality water zones are properly isolated from possible contamination.” Statewide Rule 13(b)(1)(B)
Statewide Rule 13(b)(1)(B) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.13(b)(1)(B)] provides that wellhead assemblies shall be used on wells to maintain surface control of the well. Maintenance of surface control is necessary not only to prevent fluids from being discharged from the wellbore onto the ground surface, but also to prevent any oil and gas wastes present in the wellbore from being displaced to the surface by influxes of surface water into the open wellbore.
Commission District office inspection reports made on May 14, 2008 and May 15, 2008 for the W.H. Siler R/A -A1- (08749) Lease showed that Well Nos. 9, 29, 97 and 121 had casing open to atmosphere. By leaving the wells open to atmosphere, B & B violated Statewide Rule 13(b)(1)(B).
A more recent District Office inspection, made on September 15, 2009, indicates that on the W.H. Siler R/A (08749) Lease, Well No. 9 remains open to atmosphere. Well Nos. 29 and 97 are capped. Well No. 121 is capped but is leaking pressure at the casing head. The inspection also revealed that Well Nos. 83, 94 and 118 are open to atmosphere. However, these two additional violations were not pled in Enforcement’s Complaint.
B & B’s violation of Statewide Rule 13(b)(1)(B) is serious and a hazard to the public health and safety because wells left uncontrolled or open to atmosphere may discharge oil and gas waste onto the land surface and affect the health of humans and animals. These discharges may eventually make their way to surface or subsurface waters, causing pollution.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “Open wellbores prohibited by Statewide Rule 13(b)(1)(B) are pollution/safety hazards due to the possibility of surface run-off entering the wellbore and the possibility of well fluids flowing out of the wellbore.”
Statewide Rule 14(b)(2)
Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.14(b)(2)] requires the commencement of plugging operations on each dry or inactive well within one year after drilling or operations cease, unless the operator is eligible for and obtains an extension of the plugging deadline under Statewide Rule 14(b)(2).
A Commission District Office inspection report made on May 15, 2008, and reports filed by B & B with the Commission (reflecting zero injection) since June 30, 2007, showed that the W.H. Siler R/A -C- (07611) Lease, Well No. 165 has been inactive for a period greater than one year. Injection in the subject well ceased on or before April 1, 1995. A follow-up District Office inspection report made on September 15, 2009 showed that Well No. 165 was still inactive.
Commission District office inspection reports made on May 14, 2008 and May 15, 2008 and reports filed by B & B with the Commission (reflecting zero production and/or injection) since June 30, 2007, showed that the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 have been inactive for a period greater than one year. Production and/or injection for the subject wells ceased on or before February 28, 2005. A follow-up District Office inspection report made on September 15, 2009 showed that Well Nos. 9, 11, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 were still inactive. The follow-up inspection did not note the status of Well No. 15.
A Commission District Office inspection report made on May 14, 2008, and reports filed by B & B with the Commission (reflecting zero production) since June 30, 2007, showed that the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 have been inactive for a period greater than one year. A follow-up District Office inspection report made on September 15, 2009 showed that Well Nos. 140, 173 and 174 remained inactive. Production from the subject wells ceased on or before June 1, 2007.
No workovers, re-entries or subsequent operations have taken place on any of the leases and subject wells in this complaint. None of the subject wells have been plugged and the plugging extensions for all of the subject wells as allowed by Statewide Rule 14 were cancelled August 29, 2007 based on:
a. Respondent’s failure to submit to the Commission a Form H-5 (Injection/Disposal Well Pressure Test Report) for the the W.H. Siler R/A -C- (07611) Lease, Well No. 165 and the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 149 and 171;
b. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS;
c. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174; and
d. Respondent’s rules violations on the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 29, 97 and 121.
By failing to timely plug the subject wells or to obtain an extension of the plugging deadline, B & B has violated Statewide Rule 14(b)(2). B&B’s violations of Statewide Rule 14(b)(2) are serious and threaten the public health and safety. Unplugged wellbores are likely to cause pollution of usable quality groundwater and surface water, as defined in Statewide Rule 8(a)(28) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.8(a)(28)] by serving as a conduit for the migration of oil, gas, saltwater and other substances from one stratum or formation to another or to the surface or from the surface downward.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “A well that is in violation of Statewide Rule 14, by having been inactive for one year, must be plugged in accordance with the technical requirements of Statewide Rule 14 in order to prevent pollution of usable quality surface or subsurface waters. Any wellbore, cased or otherwise, is a potential conduit for flow from oil or saltwater zones to zones of usable quality water or to the surface.”
Pursuant to calculations by District office personnel, the total estimated cost to the State for plugging the W.H. Siler R/A -C- (07611) Lease, Well No. 165 is $27,000; the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 is $621,000 (23 wells at $27,000 each); and the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 is $81,000 (3 wells at $27,000 each).
Statewide Rule 14(b)(3)
Statewide Rule 14(b)(3) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.14(b)(3)] requires the operator of any well more than 25 years old that becomes inactive and subject to the provisions of this subsection to plug the well or successfully conduct a fluid level or hydraulic pressure test
establishing that the well does not pose a potential threat of harm to natural resources, including surface or subsurface water, oil and gas.
Commission records indicate no Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS. Commission records further show that:
a. Well No. 15 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and that the well was again ruled “Delinquent” on April 15, 2008;
b. Well No. 16 was completed on August 7, 1980, an H-15 test was due in May, 2006, that a test was done on December 14, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 15, 2008;
c. Well No. 30 was completed March 7, 1977, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 16, 2005, and again the well was ruled “Delinquent” on April 16, 2008;
d. Well No. 65 was completed prior to 1977, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 20, 2005, and the well was again rule “Delinquent” on April 15, 2008;
e. Well No. 83 was completed November 20, 1948, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 22, 2005, and that the well was again ruled “Delinquent” on April 16, 2008;
f. Well No. 84 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
g. Well No. 85 was completed on August 23, 1975, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, ruled “Nor Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
h. Well No. 94 was completed September 13, 1973, an H-15 test was due in May, 2005, that a test was done on November 15, 2005, submitted to the Commission, ruled “Not Approved” on December 15, 2005, and the well was again ruled “Delinquent” April 15, 2008;
i. Well No. 118 was completed on February 28, 1976, an H-15 test was due in May, 2006, a test was done on December 21, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 16, 2008;
j. Well No. 119 was completed prior to 1980, an H-15 test was due in May, 2005, a test was done on October 4, 2005, was submitted to the Commission, was ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
k. Well No. 120 was completed October 8, 1975, an H-15 test was due in May, 2005, a test was done on October 4, 2005, submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2005;
l. Well No. 134 was completed prior to 1980, an H-15 test was due in May, 2006, a test was done on September 2, 2005, was submitted to the Commission, was ruled “Not Approved” on September 12, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
m. Well No. 148 was completed November 12, 1973, an H-15 test was due in May, 2005, a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and the well was again ruled “Delinquent” on April 15, 2008;
n. Well No. 169WS was completed May 27, 1976, an H-15 test was due in May, 2006, a test was done on March 2, 2006, was submitted to the Commission, and ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on April 16, 2008;
o. Well No. 170WS was completed July 16, 1974, an H-15 test was due in May, 2005, no test was done, and the well was ruled “Delinquent” on April 15, 2008; and
p. None of the above wells have been plugged.
Commission records indicate no Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174. Commission records further show that:
a. Well No. 140 was completed May 27, 1976, an H-15 test was due in May, 2006, that a test was done on March 2, 2006, was submitted to the Commission, was ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on March 19, 2009;
b. Well No. 173 was completed January 7, 1978, an H-15 test was due in May, 2005, that a test was done on September 2, 2005, was submitted to the Commission and
ruled “Not Approved” on September 12, 2005;
c. Well No. 174 was completed July 7, 1979, an H-15 test was due in May, 2005, that a test was done on October 4, 2005, was submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008; and
d. None of the above wells have been plugged.
By failing to timely test and file the required successful H-15 test results with the Commission, or plug the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS, and 170WS, or the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174, B&B violated Statewide Rule 14(b)(3) [Tex, R.R. Comm’n, 16 TEX. ADMIN. Code §3.14(b)(3)].
B & B’s violations of Statewide Rule 14(b)(3) are serious and are hazardous to the public health and safety because wells over twenty-five years old may develop holes or leaks in the casing, allowing oil or saltwater to communicate with usable quality water zones or to flow to the surface.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “Any inactive well that is greater than 25 years of age must be plugged or tested to determine whether the well poses a potential threat of harm to natural resources, including surface and subsurface water, oil and gas. Casing leaks and/or fluid levels above the base of usable quality water indicate a possible pollution hazard. Without the required test and supporting documentation (Commission Form H-15), the Commission cannot determine if the well poses a threat to natural resources.
Statewide Rule 46(j)
Statewide Rule 46(j) [Tex, R.R. Comm’n, 16 TEX. ADMIN. Code §3.46(j)] provides that each injection well shall be pressure-tested at least once every five years to determine if there are leaks in the casing, tubing or packer.
A Commission District Office inspection report made on May 15, 2008 for the W.H. Siler R/A -C- (07611) Lease indicated Well No. 165 was delinquent for the submission of a Form H-5. The most recent test for the subject well, dated October 31, 2003, was ruled “Inconclusive” and no subsequent tests have been submitted.
By failing to timely test the subject well, B & B violated Statewide Rule 46(j) [Tex, R.R. Comm’n, 16 TEX. ADMIN. Code §3.46(j)] and the terms and conditions set forth in the injection permit dated April 14, 1975.
B & B’s violation of Statewide Rule 46(j) is serious and threatens the public health and safety. The required test is designed to determine the integrity of the well’s casing and that leakage is not occurring. Untested disposal/injection wells, if leaking, may cause pollution of usable quality ground water and surface water by serving as a conduit for the passage of oil, gas saltwater and other
substances to the surface, or from one stratum or formation to another.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “Any injection or disposal of fluid down a wellbore could be a potential source of pollution. Under Statewide Rule 46(j)(1)-(4), operators must pressure test each injection well at least once in every five years to show that the well is not leaking and that waste is being confined to the permitted injection interval and that usable quality water zones are properly isolated from possible contamination.”
Enforcement believes B & B has acted in bad faith because it failed to correct Commission rule violations on the subject leases and failed to adequately explain its inaction to the Commission.
Enforcement’s Recommended Penalty
Commission staff requests that an order be entered assessing B & B an administrative penalty of $104,000.00. The penalty consists of four Rule 9(12) violations at $2,000 each, four Rule 13(b)(1)(B) violations at $1,000 each, twenty seven Rule 14(b)(2) violations at $2,000 each, eighteen Rule 14(b)(3) violations at $2,000 each and one Rule 46(j) violation at $2,000. Staff also requests that the order direct B & B to plug or place the subject leases and wells in compliance with all Commission Statewide Rules.
B & B Oil, Inc.
B & B states that it is caught in the middle in this situation. B & B is acting as contract operator for Eagle Environmental, a publicly traded company which is the owner of the working interest in the lease. B & B acquired responsibility for the leases by Form P-4 transfer in January, 2007 and has spent its own money trying to bring the leases into compliance since that date. However, it has had no reimbursement from Eagle Environmental.
All Commission correspondence related to the subject leases goes to B & B as the operator. Eagle Environmental has complained to B & B that it does not get notice of possible problems in a timely manner as a result.
Fred Churchman of F&D Churchman Enterprises was employed by B & B to service the leases. Mr. Churchman stated at hearing that he is owed $164,000 for work done on the leases, but has not been paid. He states that the work will be done as money is sent to pay for it.
B & B has tried to transfer the Form P-4 responsibility for the subject wells to Eagle Environmental, but the P-4s cannot transfer due to the fact that the lessor of the Siler leases has filed suit alleging the leases under which Eagle Environmental claims the right to operate have terminated. Consequently, the P-4s will not transfer until the courts rule on the title issue.
B & B states that H-5s and H-15s will be filed for the subject wells. B & B has acquired an echometer and Mr. Churchman took possession of the echometer on September 10, 2009. B & B also stated that Eagle Environmental is sending checks in the amount of $15,000, $25,000 and $200,000 to pay for further work.
B & B’s offered one exhibit in this hearing, which consisted of three two-signature P-4s which attempt to transfer all wells on the Siler, W.H. R/A A-1 (08749) Lease, all wells on the Siler, W.H. R/A A-2 (08750) Lease and the Siler, W.H. R/A -C- (07611) Lease to Hohle Energy Services, Inc. (Operator No. 391458). The exhibit also included a two-signature P-4 for the Siler, W.H. R/A A (07609) Lease.
EXAMINER’S OPINION
B & B did not object to the entry of Enforcement’s file or exhibits in this docket. B & B’s primary defense is that it placed the subject leases and wells under its bond as a contract operator for Eagle Environmental, but has not been reimbursed for its work. While this may place B & B in a difficult position, it does not change the fact that B & B is the operator responsible for the leases and wells in this docket. Enforcement proved all the alleged violations. B & B had no effective rebuttal.
Conditions on the subject leases appear to be deteriorating. For example, District Office inspections made on May 14, 2008 and May 15, 2008, show that Well Nos. 9, 29, 97 and 121 on the Siler, W.H. R/A -A1- (08749) Lease were in violation of Statewide Rule 13(b)(1)(B). A District Office inspection over a year later, made on September 15, 2009, indicates that the Statewide Rule 13(b)(1)(B) violations on the lease have been only partially remediated and, in total, are actually worse. The W.H. Siler R/A -A1- (08749) Lease, Well No. 9 remains open to atmosphere. Well Nos. 29 and 97 are capped. However, Well No. 121 is capped but is leaking pressure at the casing head. The inspection also revealed that Well Nos. 83, 94 and 118 are open to atmosphere. These additional violations were not included in the notice of this hearing and were not pled in Enforcement’s Complaint. On balance, four wells were in violation of Statewide Rule 13(b)(1)(B) in May of 2008, and five wells were in violation of the rule in September of 2009.
Based on the record in this docket, the examiner recommends adoption of the following Findings of Fact and Conclusions of Law:
FINDINGS OF FACT
1. B & B Oil, Inc. (“B & B”) (Operator No. 039791) was given at least 10 days notice of this proceeding. B & B appeared through its CEO, Joseph F. Wallen and presented evidence at the hearing.
2. B & B Oil, Inc. is a corporation, and its President/Secretary/Treasurer is Joseph F. Wallen. Wallen was in a position of ownership or control of Respondent at the time the subject violations were committed.
3. The P-5 Organization Report of B & B Oil, Inc. was delinquent at the time of the hearing but has since been re-activated, and remains active. B & B is the designated operator of 355 wells, of which 330 are inactive. B & B has approved financial assurance on file in the form of a Letter of Credit in the amount of $250,000.
4. The violations involved in this docket were violations of Commission rules related to safety and the prevention or control of pollution.
5. B & B designated itself the operator of the W.H. Siler R/A -C- (07611) Lease, Well No. 165, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority), effective July 1, 2004, approved July 7, 2004.
6. B & B designated itself the operator of the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008.
7. B & B designated itself the operator of the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008.
8. Commission District office inspection reports made on May 15, 2008 for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 147 and 171 (which are permitted as brackish water disposal wells) showed the wells are inactive and have not passed the H-5 tests required by Statewide Rule 9(12).
9. B & B’s violations of Statewide Rule 9(12) are serious and threaten the public health because a disposal well that has not been tested for mechanical integrity, as required by its permit and by Commission Rule 9(12)(c)(i), is a potential source of pollution in that if the subject well is leaking, waste may not be confined to the permitted injection interval so that usable quality water zones are properly isolated from possible contamination.
10. Commission District office inspection reports made on May 14, 2008 and May 15, 2008 for the W.H. Siler R/A -A1- (08749) lease showed that Well Nos. 9, 29, 97 and 121 had casing open to atmosphere. A District Office inspection report, made on September 15, 2009, showed that on the W.H. Siler R/A (08749) Lease, Well No. 9 remained open to atmosphere. Well Nos. 29 and 97 were capped. Well No. 121 was capped but was leaking pressure at the casing head. The inspection also revealed that Well Nos. 83, 94 and 118 were open to atmosphere.
11. B & B’s violation of Statewide Rule 13(b)(1)(B) is serious and a hazard to the public health and safety because wells left uncontrolled or open to atmosphere may discharge oil and gas waste onto the land surface and affect the health of humans and animals; these discharges may eventually make their way to surface or subsurface waters, causing pollution.
12. A Commission District Office inspection report made on May 15, 2008, and reports filed by B & B with the Commission (reflecting zero injection) since June 30, 2007, showed that the W.H. Siler R/A -C- (07611) Lease, Well No. 165 has been inactive for a period greater than one year. Injection in the subject well ceased on or before April 1, 1995. A follow-up District Office inspection report made on September 15, 2009 shows that Well No. 165 is still inactive.
13. Commission District office inspection reports made on May 14, 2008 and May 15, 2008 and
reports filed by B & B with the Commission (reflecting zero production and/or injection) since June 30, 2007, showed that the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 have been inactive for a period greater than one year. Production and/or injection from the subject wells ceased on or before February 28, 2005. A follow-up District Office inspection report made on September 15, 2009 shows that Well Nos. 9, 11, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 still inactive. The follow-up inspection did not note the status of Well No. 15.
14. A Commission District Office inspection report made on May 14, 2008, and reports filed by B & B with the Commission (reflecting zero production) since June 30, 2007, showed that the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 were inactive. A follow-up District Office inspection report made on September 15, 2009 showed that Well Nos. 140, 173 and 174 remained inactive. Production from the subject wells ceased on or before June 1, 2007.
15. No workovers, re-entries or subsequent operations have taken place on any of the leases and subject wells in this complaint; none of the subject wells have been plugged; the plugging extensions for all of the subject wells as allowed by Statewide Rule 14 were cancelled August 29, 2007 based on:
a. Respondent’s failure to submit to the Commission a Form H-5 (Injection/Disposal Well Pressure Test Report) for the the W.H. Siler R/A -C- (07611) Lease, Well No. 165 and the W.H. Siler R/A -A1- (08749) lease, Well Nos. 11, 146, 149 and 171;
b. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS;
c. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174; and
d. Respondent’s rules violations on the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 29, 97 and 121.
16. Pursuant to calculations by District Office personnel, the total estimated cost to the State for plugging the W.H. Siler R/A -C- (07611) Lease, Well No. 165 is $27,000; the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 is $621,000 (23 wells at $27,000 each); and the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 is $81,000 (3 wells at $27,000 each).
17. B & B’s violations of Statewide Rule 14(b)(2) are serious and threaten the public health and safety. Unplugged wellbores are likely to cause pollution of usable quality groundwater and surface water, as defined in Statewide Rule 8(a)(28) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.8(a)(28)] by serving as a conduit for the migration of oil, gas, saltwater and other
substances from one stratum or formation to another or to the surface or from the surface downward.
18. No Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS. Commission records further show that:
a. Well No. 15 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and that the well was again ruled “Delinquent” on April 15, 2008;
b. Well No. 16 was completed on August 7, 1980, an H-15 test was due in May, 2006, that a test was done on December 14, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 15, 2008;
c. Well No. 30 was completed March 7, 1977, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 16, 2005, and again the well was ruled “Delinquent” on April 16, 2008;
d. Well No. 65 was completed prior to 1977, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 20, 2005, and the well was again rule “Delinquent” on April 15, 2008;
e. Well No. 83 was completed November 20, 1948, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 22, 2005, and that the well was again ruled “Delinquent” on April 16, 2008;
f. Well No. 84 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
g. Well No. 85 was completed on August 23, 1975, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, ruled “Nor Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
h. Well No. 94 was completed September 13, 1973, an H-15 test was due in May, 2005, that a test was done on November 15, 2005, submitted to the Commission, ruled “Not Approved” on December 15, 2005, and the well was again ruled “Delinquent” April 15, 2008;
i. Well No. 118 was completed on February 28, 1976, an H-15 test was due in May, 2006, a test was done on December 21, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 16, 2008;
j. Well No. 119 was completed prior to 1980, an H-15 test was due in May, 2005, a test was done on October 4, 2005, was submitted to the Commission, was ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
k. Well No. 120 was completed October 8, 1975, an H-15 test was due in May, 2005, a test was done on October 4, 2005, submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2005;
l. Well No. 134 was completed prior to 1980, an H-15 test was due in May, 2006, a test was done on September 2, 2005, was submitted to the Commission, was ruled “Not Approved” on September 12, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
m. Well No. 148 was completed November 12, 1973, an H-15 test was due in May, 2005, a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and the well was again ruled “Delinquent” on April 15, 2008;
n. Well No. 169WS was completed May 27, 1976, an H-15 test was due in May, 2006, a test was done on March 2, 2006, was submitted to the Commission, and ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on April 16, 2008;
o. Well No. 170WS was completed July 16, 1974, an H-15 test was due in May, 2005, no test was done, and the well was ruled “Delinquent” on April 15, 2008; and
p. None of the above wells have been plugged.
19. Commission records indicate no Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174. Commission records further show that:
a. Well No. 140 was completed May 27, 1976, an H-15 test was due in May, 2006, that a test was done on March 2, 2006, was submitted to the Commission, was ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on March 19, 2009;
b. Well No. 173 was completed January 7, 1978, an H-15 test was due in May, 2005,
that a test was done on September 2, 2005, was submitted to the Commission and ruled “Not Approved” on September 12, 2005;
c. Well No. 174 was completed July 7, 1979, an H-15 test was due in May, 2005, that a test was done on October 4, 2005, was submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008; and
d. None of the above wells have been plugged. 20. B & B’s violations of Statewide Rule 14(b)(3) are serious and are hazardous to the public
health and safety because wells over twenty-five years old may develop holes or leaks in the casing, allowing oil or saltwater to communicate with usable quality water zones or to flow to the surface.
21. A Commission District Office inspection report made on May 15, 2008 for the W.H. Siler R/A -C- (07611) Lease showed Well No. 165 was delinquent for the submission of a Form H-5. The most recent test for the subject well, dated October 31, 2003, was ruled “Inconclusive” and no subsequent tests have been submitted.
22. B & B’s violation of Statewide Rule 46(j) is serious and threatens the public health and safety. The required test is designed to determine the integrity of the well’s casing and that leakage is not occurring. Untested disposal/injection wells, if leaking, may cause pollution of usable quality ground water and surface water by serving as a conduit for the passage of oil, gas saltwater and other substances to the surface, or from one stratum or formation to another.
23. B & B has acted in bad faith because it failed to correct Commission rule violations on the subject leases and failed to adequately explain its inaction to the Commission.
CONCLUSIONS OF LAW
1. Proper notice of hearing was timely issued to the appropriate persons entitled to notice.
2. All things necessary to the Commission attaining jurisdiction have occurred.
3. B & B Oil, Inc. was the operator of the W.H. Siler R/A -C- (07611) Lease, Well No. 165, East Texas Field , Rusk County, as defined by Statewide Rules 14, 58 and 79 [Tex. R.R. Comm’n, 16 Tex. Admin. Code §§3.14, 3.58 and 3.79] and Chapters 85 and 89 of the Texas Natural Resources Code from at least July 1, 2004 through at least the date of the hearing on September 17, 2009.
4. B & B Oil, Inc. was the operator of the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171,, East Texas Field , Rusk County, as defined by Statewide Rules 14, 58 and 79 [Tex. R.R. Comm’n, 16 Tex. Admin. Code §§3.14, 3.58 and 3.79] and Chapters 85 and 89 of the Texas Natural Resources Code from at least June 1, 2007 through at least the date
of the hearing on September 17, 2009.
5. B & B Oil, Inc. was the operator of the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174, East Texas Field , Rusk County, as defined by Statewide Rules 14, 58 and 79 [Tex. R.R. Comm’n, 16 Tex. Admin. Code §§3.14, 3.58 and 3.79] and Chapters 85 and 89 of the Texas Natural Resources Code from at least June 1, 2007 through at least the date of the hearing on September 17, 2009.
6. As Operator of the subject leases, B & B Oil, Inc. had the primary responsibility for complying with Statewide Rules 9(12), 13(b)(1)(B), 14(b)(2), 14(b)(3) and 46(j) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.9(12); §3.13(b)(1)(B); §3.14(b)(2); §3.14(b)(3) and §3.46(j)], Chapters 89 and 91 of the Texas Natural Resources Code, and other applicable statues and Commission rules respecting the subject leases and wells.
7. B & B Oil, Inc. violated Statewide Rule 9(12) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.9(12)] by failing to provide the Commission H-5 tests for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 147 and 171.
8. B & B Oil, Inc. violated Statewide Rule 13(b)(1)(B) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.13(b)(1)(B)] by failing to maintain wellhead control on the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 29, 97 and 121.
9. B & B Oil, Inc. violated Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(2)] by allowing the W.H. Siler R/A -C- (07611) Lease, Well No. 165 to remain inactive for a period over one year. The wells ceased production/injection on or before February 28, 2005. The well was in violation of Statewide Rule 14(b)(2) from at least the date of the cancellation of its Statewide Rule 14(b)(2) extension on August 29, 2007, through at least the date of the last District Office inspection made on September 15, 2009, a period of two years.
10. B & B Oil, Inc. violated Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(2)] by allowing the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 to remain inactive for a period over one year. The wells ceased production/injection on or before February 28, 2005. The wells were in violation of Statewide Rule 14(b)(2) from at least the date of the cancellation of their Statewide Rule 14(b)(2) extensions on August 29, 2007, through at least the date of the last District Office inspection made on September 15, 2009, a period of two years.
11. B & B Oil, Inc. violated Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(2)] by allowing the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 to remain inactive for a period over one year. Production from the subject wells ceased on or before June 1, 2007. The wells were in violation of Statewide Rule 14(b)(2) from at least the date of the cancellation of their Statewide Rule 14(b)(2) extensions on August 29, 2007, through at least the date of the last District Office inspection made on September 15, 2009, a period of two years.
12. B & B Oil, Inc. violated Statewide Rule 14(b)(3) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(3)] by failing to file successful H-15 tests for the W.H. Siler R/A -A1- (08749) Lease, Well Nos.15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS.
13. B & B Oil, Inc. violated Statewide Rule 14(b)(3) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(3)] by failing to file successful H-15 tests for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174.
14. B & B Oil, Inc. violated Statewide Rule 46(j) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.46(j)] by failing to file a successful Form H-5 pressure test for the W.H. Siler R/A -C- (07611) Lease, Well No. 165.
15. The documented violations committed by B & B Oil, Inc. constitute acts deemed serious and a hazard to the public health and safety within the meaning of Texas Natural Resources Code §81.0531.
16. B & B Oil, Inc. has not demonstrated good faith within the meaning of Texas Natural Resources Code §81.0531.
17. As the sole officer of B & B Oil, Inc. at the time B & B violated Commission rules related to safety and the prevention or control of pollution, Joseph F. Wallen, and any organization subject to the Commission’s jurisdiction in which he may hold a position of ownership or control, is subject to the restrictions of Texas Natural Resources Code §91.114(a)(2).
RECOMMENDATION
The examiner recommends that B & B Oil, Inc. be required to pay an administrative penalty of $104,000.00 (four Statewide Rule 9(12) violations at $2,000 each; four Statewide Rule 13(b)(1)(B) violations at $1,000 each; twenty-seven Statewide Rule 14(b)(2) violations at $2,000 each; eighteen Statewide Rule 14(b)(3) violations at $2,000 each and one Statewide Rule 46(j) violation at $2,000) and place the W.H. Siler R/A -C- (07611) Lease, the W.H. Siler R/A -A1- (08749) Lease and the W.H. Siler R/A -A2- (08750) Lease in compliance with all Commission rules and regulations.
MFE\PFD\Enforcements\B&B-6E-0258475-8-16-10.wpd
Respectfully submitted,
Marshall Enquist Hearings Examiner
"Who is, was Joe Wallen?"
Joe Wallen is the President/CEO of Quest Oil. (QOIL)
It is another scam operation like EGOH, GRSED, and B&B oil, to name a few.
For anyone who thinks that Wilmot would try to sue a message board poster, think again. That would be suicide on his part with all his lies in PR's over the years. The problem is that he has to prove that his company was harmed by the accusations. That would be impossible with his track record! Also he would open the door for a counter suit, which I'm sure he wants no part of.
"Your posts are redundant ,so will be my answers. We need to inject someone with oil experience into EGOH, thats what I'm trying to do !!!!!"
Did you not read my post's!
I and others, including SE and wildcat have been saying the same thing, Wilmont needs someone with experiance, like an SE, to do the work in the field, or better yet, be in charge!
Now you say that my posts are redundant, but you then say the same thing, that; "We need someone with oil experience to run EGOH!"
Your problem is in trying to reform Wilmot! It's NOT going to happen, Wilmot doesn't want anyone with experiance, or he would have done it years ago!
You say to crowin; "OK I agree, but what is YOUR solution ? Seat on our A$$$ and do nathing, as we've been doing all this years ?"
NO, but you can expose his lies like some are doing here in order to stop Wilmot from selling his worthless shares to other unsuspecting investors. Remember my Edmund Burke quote?
But as you can see from the flack some of us get for exposing CEO's like Wilmot, it's not a popular pastime.
It's much easier to SHOOT the messenger! Right!
"You just prove my point."
And just what do you think my POINT has always been here?
IMO, from looking at Wilmot's track record over the years, all he's been interested in is selling shares and scamming investors. He can't be this ignorant as to how to run an oil business after all these years of being in the business. In fact, all he needs to do is hire someone like SE, but I don't think he wants to. Like I, and others have said before, it's easier to sell shares than to do the hard work of being a REAL CEO.
And as for my Edmund Burke quote; That's why I'm here!
"Tell us something we don't know !!!!!"
That is exactly what you need to ask Wilmot!!!
Because all anyone on this board knows is what the FACTS/truth are,
and the FACTS/truth are laid out by the TRRC for all to see.
Then you say; "This is a reason I try to incorporate into EGOH somebody with experience SE and WK have, if they will be interested."
Well, Wildcat and SC have already told us their thought's about Wilmot and the TRRC, and they are CORRECT. Here are some of their posts below.
Wildcat has already said in # 7248 that; "Questus is fixing all of the screw ups that Wilmot and B&B created. Wilmot created Hohol oil to work this field and work it he did. He screwed it up and was working on creating a enviromental catastrophy.. He must pay the fines as his company Hohol oil caused the majority of them B&B just put the cherry on top."
In post #7260 to you; "Sorry, you remember wrong. Questus gets 75% for doing all of the work and investing all of the capital and taking all of the risk and correcting the violations. Listen up and understand. Wilmot created the violations and Wilmot will have to pay the violations. It is the way it is. Wilmot must take care of his own fines. Perhaps SE and I were not clear on that point. Questus will correct the violations in the field with their own money, but Wilmot needs to pay for his own violations and wrong doing."
SE post #7396
You are very correct. Mr. Wilmot is and has been a share printing/selling machine. It can't be disputed, this has been his pattern in every company that he has been involved with. I was aware of this when I decided to speculate here. History most times dictates the future. It always amazed me how guys like him get involved in "no brainer" opportunities that a fifth grader could run, but guys like him struggle,can't bring things together and eventually fail. It seems every decision that guys like this make is always the wrong decision. They will always destroy value in some way, shape or form.
In my opinion, here is where we stand. EGOH controls a valuable asset. There is plenty of oil that can be recovered in this field. The research that I had conducted indicates 12,500,000 MMBLs recoverable as she sits. However, there are other pay zones that are known to exist within this field that contain several million more barrels of oil that could be recovered pretty easily, along with 6 undrilled, low risk locations. This field is also a prime candidate for a salt water disposal facility.
I have always had a rule about investing. Always invest in great people! Great people will always find a way to give great returns! You see, I did not invest here, I speculated. I always said that I looked at this like a leveraged call option on oil. I speculated that someone would come along and develop this project. I was correct in my thinking, however, I did not think that management would continue to not get it's house in order.
Now the takeover legal smegal talk... Get it out of your head. While it is disgusting as hell to watch and set through, well there just is not much you really can do about it. You have to prove beyond any doubt that he has intentionally committed fraud against shareholders. What is your smoking gun and silver bullet?? Just because someone sucks as a CEO, doesn't mean he is doing anything illegal. It just means he sucks.
Now as far as the 51% percent theory. Forget it. How can you buy 51% of a company that is printing shares like the Fed prints dollar bills?? The very second he would even sense this was taking place, he would issue himself shares as payment for past services performed for the company or dilute like a madman. You would do better to make a offer to buy the company andleases.
That has been tried before and to no avail. He is not selling under any circumstances. You see IMO guys like this are weasels. Do you folks know what a weasel is? Do you know what they do? Weasels take what they want, they eat what they want and then they piss all over the rest so it can't be consumed or used by anyone else... Get the picture?? So forget a takeover. It would be much easier to takeover a company like GMX Resources than EGOH... Been involved in the takeover game with two very high profile gentleman, so believe me, I know I'm correct.
I think we should all be honest here. We all knew this company was a non operating company,with debt, with a history of broken promises, poor management, a history of failures and very limited knowledge of the oil business. The only things that they have proven is they cannot keep a pump jack running, they do not have the ability to bring wells online,they do not have the ability to develop this resource, they have the ability to piss off the TRRC and they have the ability to create possible enviromental issues.
I'm in a setting tight,as there has been some progress made in the field. I have a stomach of iron and nerves of steel. I still think Questus will make a positive impact here. I will say this, everything that the management at Questus has told me has happened and pretty much on the timeline they said it would. I will have faith until that changes. I do not have much faith in our CEO. It will take Questus to bring this project online.
" I've establish pretty good relationship with Wilmot, mainly newer bushing him and trying to support him."
sem1, since you have "establish pretty good relationship with Wilmot" ask him how many of the TRRC violations, dated 11/15/2010, that have been taken care of, if any, that crowin posted in post #7137 below. Let us know what he says. GL
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=69563631
Well problems per the TRRC
http://www.rrc.state.tx.us/meetings/ogpfd/6E-0258475PFD.pdf
November 15, 2010 OIL AND GAS DOCKET NO. 6E-0258475
______________________________________________________________________________
ENFORCEMENT ACTION AGAINST B & B OIL, INC. (OPERATOR NO. 039791) FOR VIOLATIONS OF STATEWIDE RULES ON THE W.H. SILER R/A -C- (07611) LEASE, WELL NO. 165, EAST TEXAS FIELD, RUSK COUNTY; W.H. SILER R/A -A1- (08749) LEASE, WELL NOS. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS AND 171, EAST TEXAS FIELD, RUSH COUNTY; AND W.H. SILER R/A -A2- (08750) LEASE, WELL NOS. 140, 173 AND 174, EAST TEXAS FIELD, RUSK COUNTY, TEXAS. ______________________________________________________________________________
APPEARANCES: FOR RESPONDENT:
Joseph F. Wallen, CEO Fred P. Churchman, Field Supervisor
FOR THE RAILROAD COMMISSION OF TEXAS:
Christopher Hotchkiss Keith Barton, Engineer
B & B Oil, Inc. “
Enforcement Section, RRC Field Operations
PROPOSAL FOR DECISION PROCEDURAL HISTORY
COMPLAINT FILED: NOTICE OF HEARING: DATE CASE HEARD: HEARING CLOSED: PFD PREPARED BY: CURRENT STATUS: PFD CIRCULATION DATE:
August 7, 2008 July 20, 2009 September 17, 2009 September 17, 2009 Marshall Enquist, Hearings Examiner Contested
November 15, 2010
STATEMENT OF THE CASE
This proceeding was called by the Commission on the recommendation of the District Office to determine the following:
1. Whether the respondent B & B Oil, Inc. (“B & B”) should be required to place in compliance with Statewide Rule 9(12) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.9(12)] the
W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 149 and 171 (permitted as brackish water disposal wells), East Texas Field, Rusk County;
2. Whether B & B Oil, Inc. should be required to place in compliance with Statewide Rule 13(b)(1)(B) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.13(b)(1)(B)] the W.H. Siler R/A -A1- (08749) Lease, East Texas Field, Rusk County;
3. Whether B & B Oil, Inc. should be required to plug or otherwise place in compliance with Statewide Rule 14(b)(2) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.14(b)(2)] the W.H. Siler R/A -C- (07611) Lease, Well No. 165; the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171; and the W.H. Siler R/A -A2- (08750) Well Nos. 140, 173 and 174, East Texas Field, Rusk County, Texas;
4. Whether B & B Oil, Inc. should be required to place in compliance with Statewide Rule 14(b)(3) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.14(b)(3)] the W.H. Siler R/A - A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 149, 169WS and 170WS, East Texas Field, Rusk County, Texas;
5. Whether B & B Oil, Inc. should be required to place in compliance with Statewide Rule 46(j) [Tex. R.R. Comm’n., 16 TEX. ADMIN. CODE §3.46(j)] the W.H. Siler R/A -C- (07611) Lease, Well No. 165, East Texas Field, Rusk County;
6. Whether B & B Oil, Inc. violated provisions of Title 3, Oil and Gas, Subtitles A, B and C, Texas Natural Resources Code, Chapter 27 of the Water Code and Commission rules and laws pertaining to safety or prevention or control of pollution by failing to plug the subject wells and/or otherwise failing to place the subject wells and lease into compliance with Statewide Rules 9(12); 13(b)(1)(B); 14(b)(2); 14(b)(3); and 46(j);
7. Whether, pursuant to Texas Natural Resources Code §81.0531, B & B Oil, Inc. should be assessed administrative penalties of not more than $10,000 per day for each offense committed regarding the subject leases and wells; and
8. Whether any violations of Statewide Rules 9(12); 13(b)(1)(B); 14(b)(2); 14(b)(3); and 46(j) made by B & B Oil, Inc. should be referred to the Office of the Attorney General for further civil action pursuant to Texas Natural Resources Code §81.0534.
A Notice of Hearing was issued in this case on July 20, 2009 for the hearing date of September 17, 2009. B & B Oil, Inc. President/Secretary/Treasurer Joseph F. Wallen and B & B Field Supervisor Fred Churchman appeared at the hearing on behalf of B & B Oil, Inc. and offered evidence. Christopher Hotchkiss, Staff Attorney, appeared to represent Enforcement. Enforcement’s certified hearing file was entered into evidence.
MATTERS OFFICIALLY NOTICED
The examiner has taken Official Notice of Commission Mainframe records of B & B Oil, Inc., including the P-5 screen, Officer screen, P-5 Financial Assurance, and “On-Schedule Leases, Wells and Wellbore by Operator” as of September 28, 2010. These show that B & B is an active operator with financial assurance in the form of $250,000 Letter of Credit. B&B operates 52 leases and approximately 355 wells, of which 330 are inactive under Statewide Rule 14(b)(2).
AUTHORITY
Statewide Rule 9(12) [16 TEX. ADMIN. CODE §3.9(12)] requires that each disposal well completed with surface casing set and cemented through the entire interval of protected usable quality water shall be tested for mechanical integrity at least once every five years.
Statewide Rule 13(b)(1)(B) [16 TEX. ADMIN. CODE §3.13(b)(1)(B)] provides that wellhead assemblies shall be used on wells to maintain surface control of the well. Maintenance of surface control is necessary not only to prevent fluids from being discharged from the wellbore onto the ground surface, but also to prevent any oil and gas wastes present in the wellbore from being displaced to the surface by influxes of surface water into the open wellbore.
Statewide Rule 14(b)(2) [16 TEX. ADMIN. CODE §3.14(b)(2)] requires the commencement of plugging operations on each dry or inactive well within one year after drilling or operations cease, unless the operator is eligible for and obtains an extension of the plugging deadline under Statewide Rule 14(b)(2).
Statewide Rule 14(b)(3) [16 TEX. ADMIN. CODE §3.14(b)(3)] requires the operator of any well more than 25 years old that becomes inactive and subject to the provisions of this subsection to plug the well or successfully conduct a fluid level or hydraulic pressure test establishing that the well does not pose a potential threat of harm to natural resources, including surface and subsurface water, oil and gas.
Statewide Rule 46(j) [16 TEX. ADMIN. CODE §3.46(j)] provides that each injection well shall be pressure tested at least once every five years to determine if there are leaks in the casing, tubing or packer.
DISCUSSION OF THE EVIDENCE
Enforcement
B & B Oil, Inc. (“B & B”) has reported itself to the Commission as a Corporation performing activities in the State of Texas regulated by the Commission. Joseph F. Wallen is the sole officer of B & B and was listed as President, Secretary and Treasurer during the time of the pled violations.
B & B designated itself the operator of the W.H. Siler R/A -C- (07611) Lease, Well No. 165, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority),
effective July 1, 2004, approved July 7, 2004. B & B designated itself the operator of the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008 [this was a lease subdivision]. B & B designated itself the operator of the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008 [this was a lease subdivision].
Statewide Rule 9(12)
The W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 149 and 171 were permitted as brackish water disposal wells on February 1, 1984 (Permit No. 02930). The wells are required to be pressure tested annually and the Form H-5s (Disposal/Injection Well Pressure Test Report) submitted to the Commission. The wells were most recently tested on April 4, 2005 for Well No. 11, most recently on July 6, 2007 for Well No. 146, most recently on May 26, 2006 for Well No. 149 and most recently on January 31, 2004 for Well No. 171. No tests have been submitted since those dates.
Commission District office inspection reports made on May 15, 2008 for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 147 and 171 indicate the wells are inactive and have not passed the required H-5 tests. The lease was severed by Commission personnel on May 16, 2008 for the delinquent H-5 violations.
By failing to demonstrate the mechanical integrity of the subject wells in accordance with the provisions of the corresponding disposal permits and the Commission Statewide Rule 9(12), B & B violated Statewide Rule 9(12) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.9(12)].
B & B’s violations of Statewide Rule 9(12) are serious and threaten the public health. Mark England, Engineering Specialist in the RRC Field Operations Section stated in an affidavit “A disposal well that has not been tested for mechanical integrity, as required by its permit and by Commission Rule 9(12)(c)(i), is a potential source of pollution in that if the subject well is leaking, waste may not be confined to the permitted injection interval so that usable quality water zones are properly isolated from possible contamination.” Statewide Rule 13(b)(1)(B)
Statewide Rule 13(b)(1)(B) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.13(b)(1)(B)] provides that wellhead assemblies shall be used on wells to maintain surface control of the well. Maintenance of surface control is necessary not only to prevent fluids from being discharged from the wellbore onto the ground surface, but also to prevent any oil and gas wastes present in the wellbore from being displaced to the surface by influxes of surface water into the open wellbore.
Commission District office inspection reports made on May 14, 2008 and May 15, 2008 for the W.H. Siler R/A -A1- (08749) Lease showed that Well Nos. 9, 29, 97 and 121 had casing open to atmosphere. By leaving the wells open to atmosphere, B & B violated Statewide Rule 13(b)(1)(B).
A more recent District Office inspection, made on September 15, 2009, indicates that on the W.H. Siler R/A (08749) Lease, Well No. 9 remains open to atmosphere. Well Nos. 29 and 97 are capped. Well No. 121 is capped but is leaking pressure at the casing head. The inspection also revealed that Well Nos. 83, 94 and 118 are open to atmosphere. However, these two additional violations were not pled in Enforcement’s Complaint.
B & B’s violation of Statewide Rule 13(b)(1)(B) is serious and a hazard to the public health and safety because wells left uncontrolled or open to atmosphere may discharge oil and gas waste onto the land surface and affect the health of humans and animals. These discharges may eventually make their way to surface or subsurface waters, causing pollution.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “Open wellbores prohibited by Statewide Rule 13(b)(1)(B) are pollution/safety hazards due to the possibility of surface run-off entering the wellbore and the possibility of well fluids flowing out of the wellbore.”
Statewide Rule 14(b)(2)
Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.14(b)(2)] requires the commencement of plugging operations on each dry or inactive well within one year after drilling or operations cease, unless the operator is eligible for and obtains an extension of the plugging deadline under Statewide Rule 14(b)(2).
A Commission District Office inspection report made on May 15, 2008, and reports filed by B & B with the Commission (reflecting zero injection) since June 30, 2007, showed that the W.H. Siler R/A -C- (07611) Lease, Well No. 165 has been inactive for a period greater than one year. Injection in the subject well ceased on or before April 1, 1995. A follow-up District Office inspection report made on September 15, 2009 showed that Well No. 165 was still inactive.
Commission District office inspection reports made on May 14, 2008 and May 15, 2008 and reports filed by B & B with the Commission (reflecting zero production and/or injection) since June 30, 2007, showed that the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 have been inactive for a period greater than one year. Production and/or injection for the subject wells ceased on or before February 28, 2005. A follow-up District Office inspection report made on September 15, 2009 showed that Well Nos. 9, 11, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 were still inactive. The follow-up inspection did not note the status of Well No. 15.
A Commission District Office inspection report made on May 14, 2008, and reports filed by B & B with the Commission (reflecting zero production) since June 30, 2007, showed that the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 have been inactive for a period greater than one year. A follow-up District Office inspection report made on September 15, 2009 showed that Well Nos. 140, 173 and 174 remained inactive. Production from the subject wells ceased on or before June 1, 2007.
No workovers, re-entries or subsequent operations have taken place on any of the leases and subject wells in this complaint. None of the subject wells have been plugged and the plugging extensions for all of the subject wells as allowed by Statewide Rule 14 were cancelled August 29, 2007 based on:
a. Respondent’s failure to submit to the Commission a Form H-5 (Injection/Disposal Well Pressure Test Report) for the the W.H. Siler R/A -C- (07611) Lease, Well No. 165 and the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 149 and 171;
b. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS;
c. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174; and
d. Respondent’s rules violations on the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 29, 97 and 121.
By failing to timely plug the subject wells or to obtain an extension of the plugging deadline, B & B has violated Statewide Rule 14(b)(2). B&B’s violations of Statewide Rule 14(b)(2) are serious and threaten the public health and safety. Unplugged wellbores are likely to cause pollution of usable quality groundwater and surface water, as defined in Statewide Rule 8(a)(28) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.8(a)(28)] by serving as a conduit for the migration of oil, gas, saltwater and other substances from one stratum or formation to another or to the surface or from the surface downward.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “A well that is in violation of Statewide Rule 14, by having been inactive for one year, must be plugged in accordance with the technical requirements of Statewide Rule 14 in order to prevent pollution of usable quality surface or subsurface waters. Any wellbore, cased or otherwise, is a potential conduit for flow from oil or saltwater zones to zones of usable quality water or to the surface.”
Pursuant to calculations by District office personnel, the total estimated cost to the State for plugging the W.H. Siler R/A -C- (07611) Lease, Well No. 165 is $27,000; the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 is $621,000 (23 wells at $27,000 each); and the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 is $81,000 (3 wells at $27,000 each).
Statewide Rule 14(b)(3)
Statewide Rule 14(b)(3) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.14(b)(3)] requires the operator of any well more than 25 years old that becomes inactive and subject to the provisions of this subsection to plug the well or successfully conduct a fluid level or hydraulic pressure test
establishing that the well does not pose a potential threat of harm to natural resources, including surface or subsurface water, oil and gas.
Commission records indicate no Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS. Commission records further show that:
a. Well No. 15 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and that the well was again ruled “Delinquent” on April 15, 2008;
b. Well No. 16 was completed on August 7, 1980, an H-15 test was due in May, 2006, that a test was done on December 14, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 15, 2008;
c. Well No. 30 was completed March 7, 1977, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 16, 2005, and again the well was ruled “Delinquent” on April 16, 2008;
d. Well No. 65 was completed prior to 1977, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 20, 2005, and the well was again rule “Delinquent” on April 15, 2008;
e. Well No. 83 was completed November 20, 1948, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 22, 2005, and that the well was again ruled “Delinquent” on April 16, 2008;
f. Well No. 84 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
g. Well No. 85 was completed on August 23, 1975, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, ruled “Nor Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
h. Well No. 94 was completed September 13, 1973, an H-15 test was due in May, 2005, that a test was done on November 15, 2005, submitted to the Commission, ruled “Not Approved” on December 15, 2005, and the well was again ruled “Delinquent” April 15, 2008;
i. Well No. 118 was completed on February 28, 1976, an H-15 test was due in May, 2006, a test was done on December 21, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 16, 2008;
j. Well No. 119 was completed prior to 1980, an H-15 test was due in May, 2005, a test was done on October 4, 2005, was submitted to the Commission, was ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
k. Well No. 120 was completed October 8, 1975, an H-15 test was due in May, 2005, a test was done on October 4, 2005, submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2005;
l. Well No. 134 was completed prior to 1980, an H-15 test was due in May, 2006, a test was done on September 2, 2005, was submitted to the Commission, was ruled “Not Approved” on September 12, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
m. Well No. 148 was completed November 12, 1973, an H-15 test was due in May, 2005, a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and the well was again ruled “Delinquent” on April 15, 2008;
n. Well No. 169WS was completed May 27, 1976, an H-15 test was due in May, 2006, a test was done on March 2, 2006, was submitted to the Commission, and ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on April 16, 2008;
o. Well No. 170WS was completed July 16, 1974, an H-15 test was due in May, 2005, no test was done, and the well was ruled “Delinquent” on April 15, 2008; and
p. None of the above wells have been plugged.
Commission records indicate no Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174. Commission records further show that:
a. Well No. 140 was completed May 27, 1976, an H-15 test was due in May, 2006, that a test was done on March 2, 2006, was submitted to the Commission, was ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on March 19, 2009;
b. Well No. 173 was completed January 7, 1978, an H-15 test was due in May, 2005, that a test was done on September 2, 2005, was submitted to the Commission and
ruled “Not Approved” on September 12, 2005;
c. Well No. 174 was completed July 7, 1979, an H-15 test was due in May, 2005, that a test was done on October 4, 2005, was submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008; and
d. None of the above wells have been plugged.
By failing to timely test and file the required successful H-15 test results with the Commission, or plug the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS, and 170WS, or the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174, B&B violated Statewide Rule 14(b)(3) [Tex, R.R. Comm’n, 16 TEX. ADMIN. Code §3.14(b)(3)].
B & B’s violations of Statewide Rule 14(b)(3) are serious and are hazardous to the public health and safety because wells over twenty-five years old may develop holes or leaks in the casing, allowing oil or saltwater to communicate with usable quality water zones or to flow to the surface.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “Any inactive well that is greater than 25 years of age must be plugged or tested to determine whether the well poses a potential threat of harm to natural resources, including surface and subsurface water, oil and gas. Casing leaks and/or fluid levels above the base of usable quality water indicate a possible pollution hazard. Without the required test and supporting documentation (Commission Form H-15), the Commission cannot determine if the well poses a threat to natural resources.
Statewide Rule 46(j)
Statewide Rule 46(j) [Tex, R.R. Comm’n, 16 TEX. ADMIN. Code §3.46(j)] provides that each injection well shall be pressure-tested at least once every five years to determine if there are leaks in the casing, tubing or packer.
A Commission District Office inspection report made on May 15, 2008 for the W.H. Siler R/A -C- (07611) Lease indicated Well No. 165 was delinquent for the submission of a Form H-5. The most recent test for the subject well, dated October 31, 2003, was ruled “Inconclusive” and no subsequent tests have been submitted.
By failing to timely test the subject well, B & B violated Statewide Rule 46(j) [Tex, R.R. Comm’n, 16 TEX. ADMIN. Code §3.46(j)] and the terms and conditions set forth in the injection permit dated April 14, 1975.
B & B’s violation of Statewide Rule 46(j) is serious and threatens the public health and safety. The required test is designed to determine the integrity of the well’s casing and that leakage is not occurring. Untested disposal/injection wells, if leaking, may cause pollution of usable quality ground water and surface water by serving as a conduit for the passage of oil, gas saltwater and other
substances to the surface, or from one stratum or formation to another.
Mark England, Engineering Specialist in the RRC Field Operations Section, stated in an affidavit “Any injection or disposal of fluid down a wellbore could be a potential source of pollution. Under Statewide Rule 46(j)(1)-(4), operators must pressure test each injection well at least once in every five years to show that the well is not leaking and that waste is being confined to the permitted injection interval and that usable quality water zones are properly isolated from possible contamination.”
Enforcement believes B & B has acted in bad faith because it failed to correct Commission rule violations on the subject leases and failed to adequately explain its inaction to the Commission.
Enforcement’s Recommended Penalty
Commission staff requests that an order be entered assessing B & B an administrative penalty of $104,000.00. The penalty consists of four Rule 9(12) violations at $2,000 each, four Rule 13(b)(1)(B) violations at $1,000 each, twenty seven Rule 14(b)(2) violations at $2,000 each, eighteen Rule 14(b)(3) violations at $2,000 each and one Rule 46(j) violation at $2,000. Staff also requests that the order direct B & B to plug or place the subject leases and wells in compliance with all Commission Statewide Rules.
B & B Oil, Inc.
B & B states that it is caught in the middle in this situation. B & B is acting as contract operator for Eagle Environmental, a publicly traded company which is the owner of the working interest in the lease. B & B acquired responsibility for the leases by Form P-4 transfer in January, 2007 and has spent its own money trying to bring the leases into compliance since that date. However, it has had no reimbursement from Eagle Environmental.
All Commission correspondence related to the subject leases goes to B & B as the operator. Eagle Environmental has complained to B & B that it does not get notice of possible problems in a timely manner as a result.
Fred Churchman of F&D Churchman Enterprises was employed by B & B to service the leases. Mr. Churchman stated at hearing that he is owed $164,000 for work done on the leases, but has not been paid. He states that the work will be done as money is sent to pay for it.
B & B has tried to transfer the Form P-4 responsibility for the subject wells to Eagle Environmental, but the P-4s cannot transfer due to the fact that the lessor of the Siler leases has filed suit alleging the leases under which Eagle Environmental claims the right to operate have terminated. Consequently, the P-4s will not transfer until the courts rule on the title issue.
B & B states that H-5s and H-15s will be filed for the subject wells. B & B has acquired an echometer and Mr. Churchman took possession of the echometer on September 10, 2009. B & B also stated that Eagle Environmental is sending checks in the amount of $15,000, $25,000 and $200,000 to pay for further work.
B & B’s offered one exhibit in this hearing, which consisted of three two-signature P-4s which attempt to transfer all wells on the Siler, W.H. R/A A-1 (08749) Lease, all wells on the Siler, W.H. R/A A-2 (08750) Lease and the Siler, W.H. R/A -C- (07611) Lease to Hohle Energy Services, Inc. (Operator No. 391458). The exhibit also included a two-signature P-4 for the Siler, W.H. R/A A (07609) Lease.
EXAMINER’S OPINION
B & B did not object to the entry of Enforcement’s file or exhibits in this docket. B & B’s primary defense is that it placed the subject leases and wells under its bond as a contract operator for Eagle Environmental, but has not been reimbursed for its work. While this may place B & B in a difficult position, it does not change the fact that B & B is the operator responsible for the leases and wells in this docket. Enforcement proved all the alleged violations. B & B had no effective rebuttal.
Conditions on the subject leases appear to be deteriorating. For example, District Office inspections made on May 14, 2008 and May 15, 2008, show that Well Nos. 9, 29, 97 and 121 on the Siler, W.H. R/A -A1- (08749) Lease were in violation of Statewide Rule 13(b)(1)(B). A District Office inspection over a year later, made on September 15, 2009, indicates that the Statewide Rule 13(b)(1)(B) violations on the lease have been only partially remediated and, in total, are actually worse. The W.H. Siler R/A -A1- (08749) Lease, Well No. 9 remains open to atmosphere. Well Nos. 29 and 97 are capped. However, Well No. 121 is capped but is leaking pressure at the casing head. The inspection also revealed that Well Nos. 83, 94 and 118 are open to atmosphere. These additional violations were not included in the notice of this hearing and were not pled in Enforcement’s Complaint. On balance, four wells were in violation of Statewide Rule 13(b)(1)(B) in May of 2008, and five wells were in violation of the rule in September of 2009.
Based on the record in this docket, the examiner recommends adoption of the following Findings of Fact and Conclusions of Law:
FINDINGS OF FACT
1. B & B Oil, Inc. (“B & B”) (Operator No. 039791) was given at least 10 days notice of this proceeding. B & B appeared through its CEO, Joseph F. Wallen and presented evidence at the hearing.
2. B & B Oil, Inc. is a corporation, and its President/Secretary/Treasurer is Joseph F. Wallen. Wallen was in a position of ownership or control of Respondent at the time the subject violations were committed.
3. The P-5 Organization Report of B & B Oil, Inc. was delinquent at the time of the hearing but has since been re-activated, and remains active. B & B is the designated operator of 355 wells, of which 330 are inactive. B & B has approved financial assurance on file in the form of a Letter of Credit in the amount of $250,000.
4. The violations involved in this docket were violations of Commission rules related to safety and the prevention or control of pollution.
5. B & B designated itself the operator of the W.H. Siler R/A -C- (07611) Lease, Well No. 165, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority), effective July 1, 2004, approved July 7, 2004.
6. B & B designated itself the operator of the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171, by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008.
7. B & B designated itself the operator of the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 by filing a Commission Form P-4 (Certificate of Compliance and Transportation Authority) effective June 1, 2007, approved February 26, 2008.
8. Commission District office inspection reports made on May 15, 2008 for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 147 and 171 (which are permitted as brackish water disposal wells) showed the wells are inactive and have not passed the H-5 tests required by Statewide Rule 9(12).
9. B & B’s violations of Statewide Rule 9(12) are serious and threaten the public health because a disposal well that has not been tested for mechanical integrity, as required by its permit and by Commission Rule 9(12)(c)(i), is a potential source of pollution in that if the subject well is leaking, waste may not be confined to the permitted injection interval so that usable quality water zones are properly isolated from possible contamination.
10. Commission District office inspection reports made on May 14, 2008 and May 15, 2008 for the W.H. Siler R/A -A1- (08749) lease showed that Well Nos. 9, 29, 97 and 121 had casing open to atmosphere. A District Office inspection report, made on September 15, 2009, showed that on the W.H. Siler R/A (08749) Lease, Well No. 9 remained open to atmosphere. Well Nos. 29 and 97 were capped. Well No. 121 was capped but was leaking pressure at the casing head. The inspection also revealed that Well Nos. 83, 94 and 118 were open to atmosphere.
11. B & B’s violation of Statewide Rule 13(b)(1)(B) is serious and a hazard to the public health and safety because wells left uncontrolled or open to atmosphere may discharge oil and gas waste onto the land surface and affect the health of humans and animals; these discharges may eventually make their way to surface or subsurface waters, causing pollution.
12. A Commission District Office inspection report made on May 15, 2008, and reports filed by B & B with the Commission (reflecting zero injection) since June 30, 2007, showed that the W.H. Siler R/A -C- (07611) Lease, Well No. 165 has been inactive for a period greater than one year. Injection in the subject well ceased on or before April 1, 1995. A follow-up District Office inspection report made on September 15, 2009 shows that Well No. 165 is still inactive.
13. Commission District office inspection reports made on May 14, 2008 and May 15, 2008 and
reports filed by B & B with the Commission (reflecting zero production and/or injection) since June 30, 2007, showed that the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 have been inactive for a period greater than one year. Production and/or injection from the subject wells ceased on or before February 28, 2005. A follow-up District Office inspection report made on September 15, 2009 shows that Well Nos. 9, 11, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 still inactive. The follow-up inspection did not note the status of Well No. 15.
14. A Commission District Office inspection report made on May 14, 2008, and reports filed by B & B with the Commission (reflecting zero production) since June 30, 2007, showed that the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 were inactive. A follow-up District Office inspection report made on September 15, 2009 showed that Well Nos. 140, 173 and 174 remained inactive. Production from the subject wells ceased on or before June 1, 2007.
15. No workovers, re-entries or subsequent operations have taken place on any of the leases and subject wells in this complaint; none of the subject wells have been plugged; the plugging extensions for all of the subject wells as allowed by Statewide Rule 14 were cancelled August 29, 2007 based on:
a. Respondent’s failure to submit to the Commission a Form H-5 (Injection/Disposal Well Pressure Test Report) for the the W.H. Siler R/A -C- (07611) Lease, Well No. 165 and the W.H. Siler R/A -A1- (08749) lease, Well Nos. 11, 146, 149 and 171;
b. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS;
c. Respondent’s failure to submit to the Commission a Form H-15 (Test on Inactive Well More Than 25 years Old) for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174; and
d. Respondent’s rules violations on the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 29, 97 and 121.
16. Pursuant to calculations by District Office personnel, the total estimated cost to the State for plugging the W.H. Siler R/A -C- (07611) Lease, Well No. 165 is $27,000; the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 is $621,000 (23 wells at $27,000 each); and the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 is $81,000 (3 wells at $27,000 each).
17. B & B’s violations of Statewide Rule 14(b)(2) are serious and threaten the public health and safety. Unplugged wellbores are likely to cause pollution of usable quality groundwater and surface water, as defined in Statewide Rule 8(a)(28) [Tex. R.R. Comm’n, 16 TEX. ADMIN. CODE §3.8(a)(28)] by serving as a conduit for the migration of oil, gas, saltwater and other
substances from one stratum or formation to another or to the surface or from the surface downward.
18. No Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS. Commission records further show that:
a. Well No. 15 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and that the well was again ruled “Delinquent” on April 15, 2008;
b. Well No. 16 was completed on August 7, 1980, an H-15 test was due in May, 2006, that a test was done on December 14, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 15, 2008;
c. Well No. 30 was completed March 7, 1977, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 16, 2005, and again the well was ruled “Delinquent” on April 16, 2008;
d. Well No. 65 was completed prior to 1977, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 20, 2005, and the well was again rule “Delinquent” on April 15, 2008;
e. Well No. 83 was completed November 20, 1948, an H-15 test was due in May, 2005, that a test was done on December 14, 2005, was submitted to the Commission, was ruled “Not Approved” on December 22, 2005, and that the well was again ruled “Delinquent” on April 16, 2008;
f. Well No. 84 was completed prior to 1980, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, was ruled “Not Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
g. Well No. 85 was completed on August 23, 1975, an H-15 test was due in May, 2005, that a test was done on August 4, 2005, was submitted to the Commission, ruled “Nor Approved” on August 8, 2005, and that the well was again ruled “Delinquent” on April 15, 2008;
h. Well No. 94 was completed September 13, 1973, an H-15 test was due in May, 2005, that a test was done on November 15, 2005, submitted to the Commission, ruled “Not Approved” on December 15, 2005, and the well was again ruled “Delinquent” April 15, 2008;
i. Well No. 118 was completed on February 28, 1976, an H-15 test was due in May, 2006, a test was done on December 21, 2007, was submitted to the Commission, was ruled “Not Approved” on January 15, 2008, and the well was again ruled “Delinquent” on April 16, 2008;
j. Well No. 119 was completed prior to 1980, an H-15 test was due in May, 2005, a test was done on October 4, 2005, was submitted to the Commission, was ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
k. Well No. 120 was completed October 8, 1975, an H-15 test was due in May, 2005, a test was done on October 4, 2005, submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2005;
l. Well No. 134 was completed prior to 1980, an H-15 test was due in May, 2006, a test was done on September 2, 2005, was submitted to the Commission, was ruled “Not Approved” on September 12, 2005, and the well was again ruled “Delinquent” on April 15, 2008;
m. Well No. 148 was completed November 12, 1973, an H-15 test was due in May, 2005, a test was done on January 27, 2006, was submitted to the Commission, was ruled “Not Approved” on February 6, 2006, and the well was again ruled “Delinquent” on April 15, 2008;
n. Well No. 169WS was completed May 27, 1976, an H-15 test was due in May, 2006, a test was done on March 2, 2006, was submitted to the Commission, and ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on April 16, 2008;
o. Well No. 170WS was completed July 16, 1974, an H-15 test was due in May, 2005, no test was done, and the well was ruled “Delinquent” on April 15, 2008; and
p. None of the above wells have been plugged.
19. Commission records indicate no Form H-15 (Test On An Inactive Well More Than 25 Years Old) has been filed and approved for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174. Commission records further show that:
a. Well No. 140 was completed May 27, 1976, an H-15 test was due in May, 2006, that a test was done on March 2, 2006, was submitted to the Commission, was ruled “Not Approved” on April 3, 2006, and the well was again ruled “Delinquent” on March 19, 2009;
b. Well No. 173 was completed January 7, 1978, an H-15 test was due in May, 2005,
that a test was done on September 2, 2005, was submitted to the Commission and ruled “Not Approved” on September 12, 2005;
c. Well No. 174 was completed July 7, 1979, an H-15 test was due in May, 2005, that a test was done on October 4, 2005, was submitted to the Commission and ruled “Not Approved” on October 10, 2005, and the well was again ruled “Delinquent” on April 15, 2008; and
d. None of the above wells have been plugged. 20. B & B’s violations of Statewide Rule 14(b)(3) are serious and are hazardous to the public
health and safety because wells over twenty-five years old may develop holes or leaks in the casing, allowing oil or saltwater to communicate with usable quality water zones or to flow to the surface.
21. A Commission District Office inspection report made on May 15, 2008 for the W.H. Siler R/A -C- (07611) Lease showed Well No. 165 was delinquent for the submission of a Form H-5. The most recent test for the subject well, dated October 31, 2003, was ruled “Inconclusive” and no subsequent tests have been submitted.
22. B & B’s violation of Statewide Rule 46(j) is serious and threatens the public health and safety. The required test is designed to determine the integrity of the well’s casing and that leakage is not occurring. Untested disposal/injection wells, if leaking, may cause pollution of usable quality ground water and surface water by serving as a conduit for the passage of oil, gas saltwater and other substances to the surface, or from one stratum or formation to another.
23. B & B has acted in bad faith because it failed to correct Commission rule violations on the subject leases and failed to adequately explain its inaction to the Commission.
CONCLUSIONS OF LAW
1. Proper notice of hearing was timely issued to the appropriate persons entitled to notice.
2. All things necessary to the Commission attaining jurisdiction have occurred.
3. B & B Oil, Inc. was the operator of the W.H. Siler R/A -C- (07611) Lease, Well No. 165, East Texas Field , Rusk County, as defined by Statewide Rules 14, 58 and 79 [Tex. R.R. Comm’n, 16 Tex. Admin. Code §§3.14, 3.58 and 3.79] and Chapters 85 and 89 of the Texas Natural Resources Code from at least July 1, 2004 through at least the date of the hearing on September 17, 2009.
4. B & B Oil, Inc. was the operator of the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171,, East Texas Field , Rusk County, as defined by Statewide Rules 14, 58 and 79 [Tex. R.R. Comm’n, 16 Tex. Admin. Code §§3.14, 3.58 and 3.79] and Chapters 85 and 89 of the Texas Natural Resources Code from at least June 1, 2007 through at least the date
of the hearing on September 17, 2009.
5. B & B Oil, Inc. was the operator of the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174, East Texas Field , Rusk County, as defined by Statewide Rules 14, 58 and 79 [Tex. R.R. Comm’n, 16 Tex. Admin. Code §§3.14, 3.58 and 3.79] and Chapters 85 and 89 of the Texas Natural Resources Code from at least June 1, 2007 through at least the date of the hearing on September 17, 2009.
6. As Operator of the subject leases, B & B Oil, Inc. had the primary responsibility for complying with Statewide Rules 9(12), 13(b)(1)(B), 14(b)(2), 14(b)(3) and 46(j) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.9(12); §3.13(b)(1)(B); §3.14(b)(2); §3.14(b)(3) and §3.46(j)], Chapters 89 and 91 of the Texas Natural Resources Code, and other applicable statues and Commission rules respecting the subject leases and wells.
7. B & B Oil, Inc. violated Statewide Rule 9(12) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.9(12)] by failing to provide the Commission H-5 tests for the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 11, 146, 147 and 171.
8. B & B Oil, Inc. violated Statewide Rule 13(b)(1)(B) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.13(b)(1)(B)] by failing to maintain wellhead control on the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 29, 97 and 121.
9. B & B Oil, Inc. violated Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(2)] by allowing the W.H. Siler R/A -C- (07611) Lease, Well No. 165 to remain inactive for a period over one year. The wells ceased production/injection on or before February 28, 2005. The well was in violation of Statewide Rule 14(b)(2) from at least the date of the cancellation of its Statewide Rule 14(b)(2) extension on August 29, 2007, through at least the date of the last District Office inspection made on September 15, 2009, a period of two years.
10. B & B Oil, Inc. violated Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(2)] by allowing the W.H. Siler R/A -A1- (08749) Lease, Well Nos. 9, 11, 15, 16, 29, 30, 65, 83, 84, 85, 94, 97, 118, 119, 120, 121, 134, 146, 148, 149, 169WS, 170WS and 171 to remain inactive for a period over one year. The wells ceased production/injection on or before February 28, 2005. The wells were in violation of Statewide Rule 14(b)(2) from at least the date of the cancellation of their Statewide Rule 14(b)(2) extensions on August 29, 2007, through at least the date of the last District Office inspection made on September 15, 2009, a period of two years.
11. B & B Oil, Inc. violated Statewide Rule 14(b)(2) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(2)] by allowing the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174 to remain inactive for a period over one year. Production from the subject wells ceased on or before June 1, 2007. The wells were in violation of Statewide Rule 14(b)(2) from at least the date of the cancellation of their Statewide Rule 14(b)(2) extensions on August 29, 2007, through at least the date of the last District Office inspection made on September 15, 2009, a period of two years.
12. B & B Oil, Inc. violated Statewide Rule 14(b)(3) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(3)] by failing to file successful H-15 tests for the W.H. Siler R/A -A1- (08749) Lease, Well Nos.15, 16, 30, 65, 83, 84, 85, 94, 118, 119, 120, 134, 148, 169WS and 170WS.
13. B & B Oil, Inc. violated Statewide Rule 14(b)(3) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.14(b)(3)] by failing to file successful H-15 tests for the W.H. Siler R/A -A2- (08750) Lease, Well Nos. 140, 173 and 174.
14. B & B Oil, Inc. violated Statewide Rule 46(j) [Tex. R.R. Comm’n, 16 Tex. Admin. Code §3.46(j)] by failing to file a successful Form H-5 pressure test for the W.H. Siler R/A -C- (07611) Lease, Well No. 165.
15. The documented violations committed by B & B Oil, Inc. constitute acts deemed serious and a hazard to the public health and safety within the meaning of Texas Natural Resources Code §81.0531.
16. B & B Oil, Inc. has not demonstrated good faith within the meaning of Texas Natural Resources Code §81.0531.
17. As the sole officer of B & B Oil, Inc. at the time B & B violated Commission rules related to safety and the prevention or control of pollution, Joseph F. Wallen, and any organization subject to the Commission’s jurisdiction in which he may hold a position of ownership or control, is subject to the restrictions of Texas Natural Resources Code §91.114(a)(2).
RECOMMENDATION
The examiner recommends that B & B Oil, Inc. be required to pay an administrative penalty of $104,000.00 (four Statewide Rule 9(12) violations at $2,000 each; four Statewide Rule 13(b)(1)(B) violations at $1,000 each; twenty-seven Statewide Rule 14(b)(2) violations at $2,000 each; eighteen Statewide Rule 14(b)(3) violations at $2,000 each and one Statewide Rule 46(j) violation at $2,000) and place the W.H. Siler R/A -C- (07611) Lease, the W.H. Siler R/A -A1- (08749) Lease and the W.H. Siler R/A -A2- (08750) Lease in compliance with all Commission rules and regulations.
MFE\PFD\Enforcements\B&B-6E-0258475-8-16-10.wpd
Respectfully submitted,
Marshall Enquist Hearings Examiner
I posted this about a month ago how Wilmot operates. (see post's 7390 & 7394 below) Looks like he still does business the same way, since Wilmot told you that he was going to "fly to Taxes on a field and see what's going on with job being conducted."
And some here still wonder why nothing ever gets done???? My conclusion, he's running a scam on his investors, and some just don't get it!
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Post7394
If you will notice from the different shareholder meeting updates Wilmont gives from time to time, (See post 7390 links) he comes to the oil field site for just a few days, sometimes only once a year, gets updated on everything, and then catches a plane back to Dallas. Does he not stay in touch with those in the field between visits? From reading his updates, he must not. It's no wonder that nothing gets done. When the cats away, the mice will play.
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Post #7390
For those wondering what is going on here with EGOH, just read their past history. Wilmont has been running this scam for over 10 years. If you don't believe me read through his old shareholder updates from years ago on these same oil fields. Nothing ever gets done, and it's excuse after excuse.
http://www.egvr.com/shareholder.htm
http://www.egvr.com/news.htm
That may very well be true, but ask yourself, why would Wilmot not pay the fines, especially if they have wells that are supposed to be producing by now.
Note this line in the 12/1/2011 PR below; "The electrical restoration may take up to a week to conclude, but pumping can begin immediately upon completion."
Also see this line from their 11/21/2011 PR below; "Eagle Oil Holding Company, Inc. (OTC: EGOH) (the “Company”) today announced that the Company has secured a new financing program utilizing Rule 504. In connection with the financing, the Company has signed an equity funding agreement with a Cayman Island company with offices in Delaware. Rule 504 allows non-reporting to companies to raise up to $1,000,000 annually. The Company has already received a portion of the financing which will be used for working capital at a discount to market of approximately 50%. Additional draws can be taken by the Company as needed, at the Company’s option."
So, was Wilmot lying? This is where his PAST record of lying in PR'S comes in. It's just the same old lies over and over.
Now ask yourself, if he has the money as stated, and some wells are ready to produce, what's going on? One answer, looks like a SCAM to me!
Eagle Oil Announces Initiation of Questus Field Development
RENO, Nev., December 1, 2011 — Eagle Oil Holding Company, Inc. (OTC: EGOH) (the “Company”) today announced that it has received confirmation that Questus Energy LLC (“Questus”) its Farmout Agreement partner, will be commencing field development.Questus will begin the reconditioning of the electrical grid that had been damaged in past Texas wild fires, and will also service the compliance requirements of the Texas Rail Road Commission that held up production in the past.The Agreement allows Questus to perform operations under the Texas P4 and P6 “operators’ permission” to restore pumping. The electrical restoration may take up to a week to conclude, but pumping can begin immediately upon completion.
news Nov 21 2011 Reg 504 PG
Eagle Oil Announces An
Additional New Financing Program RENO, Nev., November 21, 2011 — Eagle Oil Holding Company, Inc. (OTC: EGOH) (the “Company”) today announced that the Company has secured a new financing program utilizing Rule 504. In connection with the financing, the Company has signed an equity funding agreement with a Cayman Island company with offices in Delaware. Rule 504 allows non-reporting to companies to raise up to $1,000,000 annually. The Company has already received a portion of the financing which will be used for working capital at a discount to market of approximately 50%. Additional draws can be taken by the Company as needed, at the Company’s option.The Agreement represents the Company’s additional strategy to capitalize on its oil assets through multiple financial sources as the needs arise. This agreement on funding will not affect the Farmout Agreements that cover the work-overs on the wells. However, if our Farmout partners should fail to proceed, this allows another format to proceed with the Company’s plan on the field development. Production is expected to begin in November with the completion of the re-working of the wells. There are still conditions to be met with the Texas Rail Road Commission to get permission to sell any oil that will be produced.
Eagle Oil Announces Commencement of Oil Field Work
RENO, Nev., October 24, 2011 — Eagle Oil Holding Company, Inc. (OTC: EGOH) (the “Company”) today announced that its Farmout partner Questus Energy LLC (“Questus”) expects to commence on the “work-over” of five wells this month. The specific work to be performed is dependent upon the condition of each well, but includes well cleaning and servicing submersible pumps. As the work-overs are completed, the wells will be brought back into production.According to Eagle President Brian Wilmot “the commencement of field work by Questus is a major step for Eagle Oil and represents the culmination of two and one-half years worth of effort to restore the production of oil from our East Texas oil field.” All oil produced from the wells will be stored on the Company’s property until permission to sell is granted by the Texas Rail Road Commission, which is expected once compliance requirements are completed. The Company’s Farmout Agreement with Questus covers up to 120 of the 173 wells owned by the Company.The Company also announced that it has terminated its Farmout agreement with Nitro Capital Partners for lack of payment. The Nitro agreement covered up to 20 additional wells not included with the Questus Agreement.
RENO, Nev., June 9, 2011 /PRNewswire via COMTEX/ -- Eagle Oil Holding Company, Inc. (OTC: EGOH) (the "Company") today announced the execution of a Farmout Agreement with Questus Energy LLC, a Texas Company ("Questus").
Pursuant to the Agreement, Questus will provide the funding and other resources necessary to recondition and restart up to 173 wells at the Company's East Texas field, including the previously announced farmout agreements that totaled up to 20 wells, the Questus Agreement represents the completion of the Company's strategy to outsource the reconditioning of its oil resources. The Agreement is subject to an initial payment being made by Questus by June 22, 2011. The parties expect work on the wells to commence shortly thereafter. Questus will also complete the compliance requirements of the Texas Rail Road Commission.
Right on! It's seems that EGOH, GSRE, and several other questionable Pink Sheet companies, just pass these leases back and forth with each other. They milk it for what they can, then move on to another worthless lease. I'm sure there is a little oil left in these fields, but just not worth the expense of getting it out of the ground. Also, that's how they keep the SEC off their backs, and get away with their PR's, etc., just enough truth to make them look and sound legit.
As I have said before, it's much more profitable to the CEO'S to just sell shares with no intention of
trying to get the any oil. They know it's not profitable to get the oil.
Well first off, why do you use the word "bashing" when what is presented here concerning Wilmot's track record as a CEO is the TRUTH.
If the TRUTH isn't to your liking, why are you defending it by saying things like; "I just would like to know why everyone who is bashing on this business can't show anything other then old PR's?"
Then what are investors supposed to use for DD if they can't use what has happened in the past?
Wouldn't you use the "PAST" track record of a successful CEO when investing?
As for your statement that; "There's value in this company" that is fine, but that is just your opinion.
And for "someone who doesn't think so, I would like to ask them why they are here?" that is their opinion, and their right to be here. This forum is here for the pros and cons of any given issue.
Back to your statement; "There's value in this company".
If there is any VALUE here, where are the big boys?
If there is VALUE here, why have these leases been used to scam investors for the last 10 years instead of being developed properly?
The truth is, their only value is to do just what Wilmot and others have been doing, selling shares and scamming investors.
Thanks for your reply, and GL on your investment here!
Try reading some past posts for "evidence as to Wilmot's intentions with this field". I have picked out just a few below. If over 10 years of Wilmot's failures is not enough PROOF of his INTENTIONS,
then?????
I would like for you to show some material/information showing his successes, like REVENUE/PROFIT from any company he has ever run.
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liketotravel
Thursday, December 15, 2011 7:54:23 PM
For those wondering what is going on here with EGOH, just read their past history. Wilmont has been running this scam for over 10 years. If you don't believe me read through his old shareholder updates from years ago on these same oil fields. Nothing ever gets done, and it's excuse after excuse.
http://www.egvr.com/shareholder.htm
http://www.egvr.com/news.htm
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SCREAMING EAGLE
You are very correct. Mr. Wilmot is and has been a share printing/selling machine. It can't be disputed, this has been his pattern in every company that he has been involved with. I was aware of this when I decided to speculate here. History most times dictates the future. It always amazed me how guys like him get involved in "no brainer" opportunities that a fifth grader could run, but guys like him struggle,can't bring things together and eventually fail. It seems every decision that guys like this make is always the wrong decision. They will always destroy value in some way, shape or form.
In my opinion, here is where we stand. EGOH controls a valuable asset. There is plenty of oil that can be recovered in this field. The research that I had conducted indicates 12,500,000 MMBLs recoverable as she sits. However, there are other pay zones that are known to exist within this field that contain several million more barrels of oil that could be recovered pretty easily, along with 6 undrilled, low risk locations. This field is also a prime candidate for a salt water disposal facility.
I have always had a rule about investing. Always invest in great people! Great people will always find a way to give great returns! You see, I did not invest here, I speculated. I always said that I looked at this like a leveraged call option on oil. I speculated that someone would come along and develop this project. I was correct in my thinking, however, I did not think that management would continue to not get it's house in order.
Now the takeover legal smegal talk... Get it out of your head. While it is disgusting as hell to watch and set through, well there just is not much you really can do about it. You have to prove beyond any doubt that he has intentionally committed fraud against shareholders. What is your smoking gun and silver bullet?? Just because someone sucks as a CEO, doesn't mean he is doing anything illegal. It just means he sucks.
Now as far as the 51% percent theory. Forget it. How can you buy 51% of a company that is printing shares like the Fed prints dollar bills?? The very second he would even sense this was taking place, he would issue himself shares as payment for past services performed for the company or dilute like a madman. You would do better to make a offer to buy the company andleases.
That has been tried before and to no avail. He is not selling under any circumstances. You see IMO guys like this are weasels. Do you folks know what a weasel is? Do you know what they do? Weasels take what they want, they eat what they want and then they piss all over the rest so it can't be consumed or used by anyone else... Get the picture?? So forget a takeover. It would be much easier to takeover a company like GMX Resources than EGOH... Been involved in the takeover game with two very high profile gentleman, so believe me, I know I'm correct.
I think we should all be honest here. We all knew this company was a non operating company,with debt, with a history of broken promises, poor management, a history of failures and very limited knowledge of the oil business. The only things that they have proven is they cannot keep a pump jack running, they do not have the ability to bring wells online,they do not have the ability to develop this resource, they have the ability to piss off the TRRC and they have the ability to create possible enviromental issues.
I'm in a setting tight,as there has been some progress made in the field. I have a stomach of iron and nerves of steel. I still think Questus will make a positive impact here. I will say this, everything that the management at Questus has told me has happened and pretty much on the timeline they said it would. I will have faith until that changes. I do not have much faith in our CEO. It will take Questus to bring this project online.
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There are so many questions that I have. If I was the CEO, the first thing we would do is kiss the ass of the TRRC and get in compliance ASAP. We would not meet their standards, but would exceed them in every way. The damn violations would be paid, even if I didn't think it was my responsibilty, because at this point we are letting 104,000.00 stand in the way of millions.
Then we would make it as easy on our JV partners and contractors as we could. I would also contact drillers to come evaluate the eastern part of the field and it's undrilled prospects, then negotiate a fair JV for those prospects.
Field engineering/development plan would be developed and managed by Haliburton,Key energy or a firm of that nature... Very simple deal...EASY MONEY!
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SCREAMING EAGLE
He has diluted over 100 million shares and doesn't have a pot to piss in or a window to throw it out... I don't mind dilution tooooo awful much if it is going to lead to value creation... I see no value that it created here, that is what gets me steamed.
I offered my expertise. I recieved no response. When I was the man in charge, I surrounded myself with the smartest people that I could assemble and we got aggressive, we made things happen. We developed a business plan and we pushed forward. Time is money.
He can put out all the PR's that he wants at this point, the effect they will have will be minor, until investors can see revenue on the balance sheet. He has blown his credibility with the market. It is a shame.
Ya know at one time he had 10 million dollars worth of financing for this field and he blew it sky high... KaBOOM!!!!!!!!!!!
Crowin, thanks for the older TNOG/GSRE DD link. Got it bookmarked!
I'm sure GSRED management would like as little past info as possible to be available to would be investors.
"Was the money collected in december as expected?"
Of course not! That's why they use words like "expected".
Notice they also said in that same PR that; "In the first full month of production the company "EXPECTS" to produce approximately 2,000 barrels of oil from the wells that are being worked over."
Also notice all the other inconsistent statements in that PR. (See PR below)
They first state; "The company has scheduled workover of the first 30 wells in its Eastland County, Texas property to commence next week."
Then 2 sentences later they say; "Of the 166 oil and gas wells awaiting completion and hook-up, 35 of the wellbores are equipped and ready for production."
Well if 35 wells are equipped and ready for production, why didn't they start production right away.
Instead, notice they say the "expected" 2000 barrels are to come from the 30 wells that are being worked over.
What about the 35 wellbores they said were equipped and ready for production, or are 30 of those wells the one's they are referring to when they say "30 wells that are being worked over." If so, then 35 wells weren't "equipped and ready for production" as stated.
GSRED PR
Today : Friday 23 September 2011
Green Star Energies, Inc. (PINKSHEETS: GSRE) announced today that the proxy vote to increase the amount of authorized shares in the company was passed at the recent Special Shareholder Meeting. This clears the way for the acquisition of assets from Questus Energy, LLC. Management expects the acquisition to be finalized within the next week.
The company has scheduled workover of the first 30 wells in its Eastland County, Texas property to commence next week. The property consists of 166 wells on 1,100 acres comprised of two leases and is just 10 miles south of Cisco, Texas. The field has experienced shallow production at average depth of 1,200 feet. Of the 166 oil and gas wells awaiting completion and hook-up, 35 of the wellbores are equipped and ready for production. In the first full month of production the company expects to produce approximately 2,000 barrels of oil from the wells that are being worked over. The associated revenue is expected to be collected by the company in December 2011.
The acreage is located in a trend that also has the Barnett Shale Combo play upside potential. The company is exploring available options to take advantage of this play.