What does an oilfield contractor in Seminole and Gaines County need to have covered?

Seminole is the seat of Gaines County, which is in RRC District 8A. The 8A office is in Lubbock at 6302 Iola Avenue. That surprises some contractors who think of Seminole as part of the Midland market. Andrews County, just south, is District 08.

TSHA describes Gaines County as bounded by New Mexico on the west, Andrews County on the south, Dawson County on the east, and Yoakum and Terry counties on the north. Production began in 1935, and in 1936 drillers struck the Seminole pool at 5,000 to 6,000 feet. Output peaked at about 60.7 million barrels in 1978, and cumulative production from 1936 through January 1991 was about 1.67 billion barrels.

District 8A is a smaller district by drilling activity. In the RRC's July 2026 figures it had 37 permits to drill new holes, compared with 275 in District 08. The fields described below are mature floods that have been producing for decades.

Two monitoring plans filed with the U.S. EPA describe the kind of fields Seminole contractors work:

• Seminole East Field, about one and a half miles northeast of Seminole. Production is from the San Andres at an average depth of 5,500 feet. The field was discovered in 1959, waterflooding began in 1983, and CO2 flooding began in 2013 in both the main pay and the residual oil zone.
• Wasson San Andres Field, in Yoakum and Gaines counties near Seminole and Hobbs, New Mexico. It was discovered in 1935, and CO2 flooding began in 1983 in two of its units, with others following in 1986 and 1995. It runs water-alternating-gas injection.

A 2018 USGS-authored paper on East Seminole Field notes that CO2 enhanced recovery has expanded from the main pay zone into the underlying residual oil zone.

CO2 flood work means injection wells, satellite test stations, recycle compression, high-pressure lines and frequent well work. Questions for your MSA and insurance:

• Does the MSA treat the operator's injection system and CO2 as the operator's property and risk, or does damage during your work land on you?
• Does your pollution coverage respond to a release of produced fluids and gas from a line you were working on? See contractors pollution liability.
• Is your equipment covered for corrosion or contamination damage, or does the MSA put that on the operator? See oilfield equipment insurance.

The EPA-filed plan for Seminole East Field states that H2S in the recycled or produced gas is "in excess of 18,000 ppm." H2S monitors are worn by all field personnel at all times, and they alarm at 10 ppm. The Wasson plan describes the same kind of personal monitors.

Texas regulates H2S through Rule 36. It applies where gas contains 100 ppm or more of H2S. Where it applies:

• Operators must use only trained service company personnel and get written certification from the service company that its people were trained.
• Additional requirements apply where the 100 ppm radius of exposure exceeds 50 feet, and contingency plans are required in certain cases, including where the 500 ppm radius of exposure is greater than 50 feet and includes any part of a public road.

For a Seminole contractor, H2S training records are as much a part of getting on the vendor list as your certificate. On the insurance side, ask how your GL and pollution coverage treat a gas release, and make sure your workers' comp and employers liability are written for the work your crews actually do. See what is employers liability coverage and how ISNetworld reviews your insurance.

Gaines County borders New Mexico, and the Wasson field plan describes the field as near both Seminole and Hobbs. A Seminole crew can be on a New Mexico lease the same day.

Two New Mexico rules change your insurance:

• Workers' comp. The New Mexico Workers' Compensation Administration says coverage is required for an employer with three or more workers. New Mexico must be on your policy before crews cross.
• Indemnity. NMSA 56-7-2 voids indemnity for the indemnitee's own negligence on New Mexico wells, and Subsection C voids additional insured and waiver of subrogation requirements that would get around that ban.

See the Hobbs and Lovington pages and the Permian Basin guide.

TSHA lists US 62, US 180 and US 385, State Highway 214 and Farm Road 181 meeting at Seminole. It also describes Gaines County as major cotton country with about 400,000 irrigated acres.

That means oilfield trucks share highways and farm roads with farm equipment and agricultural trucks. For your auto program:

• County roads and bridges can carry load limits set by the commissioners court with TxDOT's concurrence under Transportation Code 621.301.
• Oversize or overweight units need a TxDMV permit, and an annual well servicing unit permit requires a USDOT number in your company's name.
• Third-party property damage, like a fence, gate or irrigation equipment hit on a lease road, is a liability claim. Report it early.

See does my auto policy cover lease roads and oilfield auto insurance and MCS-90.