The short version
- Odessa is the seat of Ector County, which is in RRC District 08 and handled by the district office in Midland.
- Ector County is old, deep oil country: the Texas State Historical Association counts about 2.73 billion barrels from 1926 through 1990, second among Texas counties, from fields on the Central Basin Platform and the Midland Basin.
- In 2019, a pumper and his spouse died from hydrogen sulfide at a waterflood station in Odessa. The federal Chemical Safety Board found no personal H2S detector in use, no lockout/tagout, a failed alarm system and unlocked gates.
- The RRC's Gardendale Seismic Response Area runs from northeast Ector County into Martin County, and deep disposal there has been suspended since December 2021.
Ector County and the District 08 office
Ector County, with Odessa as its county seat since 1891, is in RRC District 08. The district office is in Midland.
The county's oil history is long. TSHA records the first discovery in 1926, followed by the Penn field in 1929 and the Cowden field in 1930. Production peaked at nearly 62.2 million barrels in 1948, and through 1990 the county had produced about 2.73 billion barrels, making it the second most productive oil county in Texas at the time.
Odessa grew up as the shipping and oilfield supply center for that boom, and a petrochemical complex was built near the city in the mid-1960s. Supply, rental and fabrication businesses are part of that tradition, and their contracts raise their own questions.
That matters for contracts. Texas Chapter 127 defines an agreement pertaining to a well to include acts collateral to well services, "including furnishing or renting equipment, incidental transportation, or other goods and services." Rental and supply agreements can be in scope. The same definition excludes construction, maintenance or repair of pipelines and fixed associated facilities. If you do both kinds of work, see Texas oilfield anti-indemnity act.
Old fields, waterfloods and the Central Basin Platform
Northern Ector County includes fields on the Central Basin Platform. A 1998 study published through the National Energy Technology Laboratory describes the Goldsmith field (Permian and younger reservoirs) and Andector field (Ellenburger) as one structure in northern Ector County, extending northwest into Andrews County, on an Ellenburger thrust anticline at the eastern edge of the platform. The UT Bureau of Economic Geology also lists Ector among the Spraberry Trend counties of the Midland Basin.
Old fields mean a lot of lease maintenance, waterflood stations, injection lines, pump houses and well workovers. That work is roustabout and well servicing work, and the MSA questions are specific:
- Care, custody or control. If your crew is working on the operator's pump or line when it fails, your GL may exclude damage to property in your care. See what is the care, custody and control exclusion.
- Pollution. A leak from an injection line is a pollution event. See contractors pollution liability.
- Completed operations. A fitting you installed can fail months later. See ongoing vs completed operations additional insured.
See roustabout company insurance and well servicing insurance.
What the 2019 Odessa H2S deaths showed
On October 26, 2019, a pumper responded to an alarm at a waterflood station in Odessa. According to the U.S. Chemical Safety and Hazard Investigation Board, water containing hydrogen sulfide released from a pump, and he was fatally exposed. His spouse later drove through the unlocked gates looking for him and was also fatally exposed. Odessa Fire Rescue and the Ector County Sheriff's Office responded.
The CSB listed six safety issues:
- no personal H2S detector worn,
- no lockout/tagout performed, and no written lockout/tagout procedure,
- H2S confined inside the pump house,
- no safety management program,
- an H2S detection and alarm system that did not work, and
- deficient site security.
Texas regulates H2S through Rule 36. Where it applies, operators must use trained service company personnel and get written certification from the service company that its people were trained. The rule's definition of a public area includes dwellings, businesses and public roads, and new warning signs must say "Caution" and "Poison Gas."
The insurance side has two pieces. An injury to your own worker is a workers' comp and employers liability claim. An injury to someone who is not your employee, on a site you are working or controlling, is a liability claim, and some policies treat a gas release as pollution. Ask how your GL and pollution coverage handle an H2S release. See what is employers liability coverage and what happens if an employee is hurt on an operator's lease.
Gardendale: disposal limits from northeast Ector County
In September 2021 the RRC told operators that saltwater disposal injection "likely contributes" to seismic activity in the Gardendale Seismic Response Area, which it described as running from northeast Ector County to southwest Martin County. It counted six felt earthquakes of magnitude 3.5 or greater since February 2020, including two magnitude 3.6 events northeast of Odessa, and notified the operators of 76 permitted disposal wells in writing.
In December 2021 the RRC suspended the permits of 33 deep disposal wells in the SRA. The current operator plan keeps deep disposal shut in.
For Odessa water haulers and SWD service crews, that means:
- routes and disposal sites that change when regulators act,
- more miles and more auto exposure,
- an RRC waste hauler permit for produced water hauled for hire off the lease, and
- a clear answer on who pays for a spill at the disposal site.
See water hauling insurance and what is an RRC waste hauler permit.
Heavy haul on I-20, US 385 and county roads
TSHA lists Interstate 20 with US 80 running west to east through Ector County, US 385 running north and south, and State Highway 302 running west to east. Rigs, tanks and fabricated equipment move out of Odessa on all of them.
- Oversize and overweight loads need a TxDMV permit before they travel on public roads. Transportation Code 623.142 provides a permit for oil well servicing and drilling machinery on TxDOT roads, and TxDMV issues an annual permit for well servicing units.
- County roads can carry load limits set by the commissioners court with TxDOT's concurrence under Transportation Code 621.301.
- Your equipment floater should cover overturn and collision in transit, and your auto policy should list the units that pull it.
See oilfield equipment insurance and what is contractors equipment inland marine.
Common questions
Which RRC district covers Odessa?
Ector County is in District 08. The District 08 office is in Midland.
What does Rule 36 require from my Odessa crew?
Where Rule 36 applies, the operator must use trained service company personnel and get written certification from your company that your people were trained. Keep those records current, because operators and compliance platforms ask for them.
Does Chapter 127 apply to equipment rental out of Odessa?
It can. The statute covers acts collateral to well services, including furnishing or renting equipment. It excludes pipeline construction and repair. Have the attorney confirm how it applies to your contract.
Is Ector County in a seismic response area?
Part of it. The RRC describes the Gardendale SRA as running from northeast Ector County to southwest Martin County, and it includes part of Midland County. Deep disposal there is suspended.
Sources
- Railroad Commission of Texas: Oil and gas counties by district. Ector County is District 08.
- Railroad Commission of Texas: Locations. District 08 office in Midland.
- Texas State Historical Association: Ector County. Discovery 1926, Penn and Cowden fields, 2.73 billion barrels through 1990, supply center, highways.
- NETL EDX: Structural geology of the Central Basin Platform, Delaware Basin and Midland Basin (1998). Goldsmith and Andector fields in Ector and Andrews counties.
- UT Bureau of Economic Geology: Wolfberry and Spraberry play. Ector County in the Spraberry Trend.
- U.S. Chemical Safety Board: 2019 H2S release at an Odessa waterflood station, executive summary. Incident facts and the six safety issues.
- 16 Tex. Admin. Code 3.36 (Rule 36). Service company training certification, public area definition, sign language.
- RRC: Notice to operators, Gardendale seismic response action (Sept. 2021). Northeast Ector to southwest Martin County, felt earthquakes, 76 disposal wells.
- RRC: Seismicity response. December 2021 deep disposal suspension; operator plan.
- Texas Civil Practice and Remedies Code Sec. 127.001. Equipment rental in scope; pipeline construction excluded.
- Texas Transportation Code Sec. 621.301. County road load limits.
- Texas Transportation Code Sec. 623.142. Oil well machinery permits.
This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.
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