Energy Resources 640 Fifth Avenue SW Conservation Board Calgary, Alberta Canada T2P3G4 Informational Letter IL 89-1 TO: All Oil and Gas Operators 24 January 1989 ISOLATION PACKER TESTS TESTING AND REPORTING REQUIREMENTS The intent of section 6.120 of the Oil and Gas Conservation Regulations is to ensure that all injected fluids other than potable water are isolated from the production casing above the production packer. Section 7.050 requires that the production casing in a well producing sour gas with a concentration greater than 50 moles per kilomole, unless the well is produced by artificial lift, be similarly protected. Suspended wells within these categories are not exempt from these requirements. These sections of the regulations further require that annual isolation tests be performed and the results submitted to the appropriate area office. The Board is finding that in many cases these tests are not being performed or reported to the area offices, the test procedures are not adequate, and remedial action is not being taken to restore isolation. Industry is reminded that (1) isolation tests must be performed annually and the results submitted to the appropriate area office no later than 1 September of each year; (2) if the test shows that the liquid between the tubing and casing is not isolated from the fluid being produced or injected, remedial action must be initiated immediately to restore isolation. The ERCB area office is to be notified as soon as the corrective action has been completed and isolation has been confirmed; (3) if the test indicates loss of casing integrity as a result of fluid loss or a pressure build-up that cannot be correlated to the fluid injected or produced, a program of operations to determine the depth of pressure loss or intrusion and proposed remedial action must be submitted to' the Completions and Servicing Section for approval prior to commencement of operations. The attached recommended testing procedures were developed to clarify ERCB requirements and to provide a consistent format for reporting and evaluation of test results. Test procedures, other than those outlined in the attached guide, should be reviewed with the appropriate ERCB area office staff to ensure that the test results will be acceptable to the ERCB. All isolation packer test results are to be submitted to the ERCB area offices using the attached recommended Isolation Packer Test Data form. - 2 - Further information regarding this matter can be obtained from the appropriate area office or from the Completions and Servicing Section of the Drilling and Production Department at 297-3554. jUr. Nichol Manager Drilling and Production ENERGY RESOURCES CONSERVATION BOARD ISOLATION PACKER TESTS RECOMMENDED TESTING PROCEDURES AND REPORTING REQUIREMENTS JANUARY 1989 i CONTENTS PAGE 1 INTRODUCTION c «o o . 1 2 THE REGULATIONS. o . 3 2.1 Section 6.120 « * . c , 3 2.2 Section 7«050 , 4 3 TEST PROCEDURES FOR WELLS ON STREAM. o ....... . 5 4 TEST REQUIREMENTS FOR SUSPENDED WELLS » 9 5 RECORDS AJJD REPORTS. ................... 11 1 1 INTRODUCTION The purpose of this guide is to outline recommended test procedures with respect to sections 6.120 and 7.050 of the Oil and Gas Conservation Regulations. The testing of injection, disposal, and flowing H2S wells (>5% H2S) to ensure the integrity of the casing, tubing, and packer is a requirement of the regulations, and this guide is devised to inform the operators of a step-by-step procedure that will, in most cases, conclusively prove whether or not the well is in a satisfactory condition to remain on stream as an injection/disposal, or a producing H2S well. Alternate test methods may be conducted if an operator can demonstrate to the satisfaction of the Board that the proposed procedure will fulfil the intent of the Oil and Gas Conservation Regulations . Also included in this guide are the following: (1) the relevant sections of the regulations, (2) the requirement for testing suspended wells, and (3) a copy of a form that will assist in recording and reporting the test data. Digitized by the Internet Archive in 2015 https://archive.org/details/energyresources198916 3 2 THE REGULATIONS The regulations governing Isolation packer tests for wells In Alberta are the Oil and Gas Conservation Regulations, sections 6.120 and 7.050, as quoted below. 2.1 Section 6.120 "(1) Before any fluid other than potable water is injected to a subsurface formation through a well, the licensee shall (a) set a production packer in the well as closely above the injection interval as is practicable, and (b) fill the space between the tubing and outer steel casing with a non-corrosive, corrosion inhibited liquid, but the Board, upon application in writing, may relieve the licensee from any requirement of this section. "(2) Where a well is equipped with a production packer as required by subsection (1), the licensee of the well shall, not later than September 1, of each year, submit to the appropriate area office of the Board, (a) evidence to show, to the satisfaction of the Board, that the liquid between the tubing and the casing is isolated from the fluid being injected, and (b) the data which substantiates isolation." 4 2.2 Section 7.050 "(1) This section applies to a well at which the hydrogen sulphide concentration in a representative sample of gas from the well is found to exceed 50 moles per kilomole, or such higher or lower ratio as the Board may, by order, stipulate with respect to any well or group of wells in a battery, pool or area, having regard to pressures, nature of production, remoteness of the area and other circumstances. "(3) Unless the well is produced by artificial lift, the licensee shall equip the well with (a) two master valves, (b) a production packer set as closely above the producing formation as is practicable, with the annular space between the tubing and production casing filled with a suitable non-corrosive, corrosion inhibited liquid, and (c) a wellhead whose working pressure rating is not less than the bottom hole pressure of the producing formation, but the surface casing vent may be in accordance with section 6.100, subsection (3). "(3.1) Where a well is equipped with a production packer, as required by subsection (3), clause (b), the licensee of the well shall, not later than September 1 of each year, submit to the appropriate area office of the Board, (a) evidence to show, to the satisfaction of the Board, that the liquid between the tubing and the casing is isolated from the fluid being produced or injected, and (b) the data which substantiates isolation. 5 3 TEST PROCEDURES FOR WELLS ON STREAM WELL MODE Producing or on in ject ion/disposal . - No pressure on casing. TEST PROCEDURES - Record operating tubing pressure. Fill annulus with appropriate fluid. Record volume. - Apply pressure to tubing/casing annulus (minimum 1400 kPa for 15 minutes). Record pressure . - Note and record pressure after 15 minutes. - If unable to maintain pressure or pressure drops significantly, test indicates a problem that must be identified and appropriate remedial measures must be undertaken. - If pressure remains constant, test indicates well is in satisfactory condition. WELL MODE - Producing or on in jection/ disposal . - Pressure on casing (not externally applied) . TEST PROCEDURES Record operating tubing pressure. - Record casing pressure. 6 - Bleed down casing. Record time required to bleed down casing and type and volume of fluid recovered. - Fill annulus with appropriate fluid. Record volume. - Close casing valve and monitor casing pressure for 24 hours. - If there is no pressure increase in casing, apply pressure to tubing/casing annulus (minimum 1400 kPa for 15 minutes). Record pressure. - Note and record pressure after 15 minutes . - If unable to maintain pressure or pressure drops significantly, test indicates a problem that must be identified and appropriate remedial measures must be undertaken. - If pressure remains constant, test indicates well is in satisfactory condition. WELL MODE - Producing or on injection/ disposal. - Pressure on casing (externally applied) . TEST PROCEDURES - Record operating tubing pressure. - Record casing pressure. Compare to pressure recorded 1 year ago. - Bleed off casing slowly, and record the type and volume of fluid recovered. - When casing is bled off to zero, close casing valve and monitor casing pressure for 24 hours. - If there is no pressure increase in casing, casing may be re-pressured to original level. 7 If operator does not wish to bleed down casing pressure to zero because of excessive annular fluid (liquid) loss, a partial bleed down (40 per cent - 50 per cent of original pressure) is acceptable, provided that the reduced casing pressure is monitored and recorded for a minimum of 7 days before re-pressuring. Casing pressures that are significantly different from the original level, or are equalized with the tubing pressure, are indicative of a problem that requires attention. 4 TEST REQUIREMENTS FOR SUSPENDED WELLS All suspended injection/disposal and H2S wells that require testing under sections 6.120 and 7.050 must be tested annually, and the results and analyses of the tests must be submitted to the appropriate Board office no later than 1 September of each year. 11 5 RECORDS AND REPORTS It is recommended that the test data be recorded and submitted on the attached Isolation Packer Test Data form. The test results must be evaluated and noted on the data form whether test was satisfactory or not. If it is determined from the test results that a problem exists, an explanation of the cause and the action that will be taken must be included on the form or submitted on a separate document. -o R < o ^ ^ S ^ < ^ i3 S > d < t- lu o i: P i H- M ^ O < ot oe CK s < < 000 fo - O H — u S 9 3 ^ s 3 i r z iZ < < o _ i§ Q Q z z 2 £ A < 15 !5 uj ^ * ^ ^ ° a « a S5 If) =; — A S S nT o o Z 0 TT rbU No . Joi renn— Dig vaiiey u z a PCTT LNO . jD / renn Dig vaiiey u z a T5CTT rbU NO . ^7 9 J / Z renn u— j r PCTT INO . 1 1 renn u—j r rbU \T~ No . J renn u—j c PCTT INO . renn u~j r DCTT r bU NO . o Fenn D-i F ■DOTT rbU No . Q o j?enn u-j i? PSU No. 1 O 12 Fenn D-3 F T)CTT r bU NO . 1 1 J Fenn West D-2 A "DOTT rbU No . iU Ferrier Belly River A T)CTT rbU INO . A 't Ferrier Belly River A PCTT rbU NO . c J Ferrier Belly River A PCTT iNO • 7 Garrington Cardium A & B PCTT r o U iNO . 9 Garrington Viking A PSU No. Garrington Viking A PCTT INO . 9 z Garrington Viking A PCTT INO . Garrington Viking A PCTT NO • Garrington Viking A DCTT r bU NO . 0 Garrington Viking A TiC TT rbU No . / Garrington Viking A PCTT r bU NO . 1 1 Glen Park D-3 A PSU No . 1 1 Glen Park D-3 A PCTT INO • o J Glen Park D-3 A DOTT rbU No • c J Glen Park D-3 A PCTT IT OU Golden Slave Point A PCTT rbU NO » 1 A i't Golden Slave Point A PCTT INO . 1 s Haynes D-2 A & D-3 A DCTT r bU NO . 1 1 Hussar Glauconitic A PCTT INO . CI J Joarcam Viking PCTT CO U iNO • 1 lU Judy Creek South BHL C No INU • Medicine River Pekisko N PCTT r o u iNO • •3 J Mitsue Gilwood A Pll Lt ~J r\ R1 nrk No- il • Al ovi c Ratiff A R1 f\^\r LNO • 1 i DOnnie vjxen u~j i\ DlOCK. INO • 1 1 Donnie ^jrjLen u j a J310CK. INO • Z Dontiie tjien u j t\ R1 r\n\e DIOCK. iNO • J Bonnie b±en u— j a "D1 ^ A^lr DiOCK No • A isonnie trien u j a R1 nr»lr DIOCK. LMO • o Donnie uxen u j a DlOCiv INO • Q Donnie ij±eu u j a R1 /-k/-»lr DIOCK LNO • 1 1 1 1 Donnie lr DlOCK INO • i ouurgeon Liaive oouun u j TJ1 r^n^r■ DlOCK No . Sylvan Lake Pekisko B Block No. 1 Sylvan Lake Pekisko B Block No. 2 Sylvan Lake Pekisko B Block No. 3 Utikuma Lake Keg River Sand A Block No. 1 Utikuma Lake Keg River Sand A Block No. 3 Wintering Hills Viking A Block No. 3 ATTACHMENT 1 - IL 89-2 Simonette D-3 PSU No. 15 Sturgeon Lake South D-3 PSU No. 65 Sturgeon Lake South D-3 PSU No. 87 Sturgeon Lake South D-3 PSU No. 91 Sturgeon Lake South D-3 PSU No. 102 Sturgeon Lake South D-3 PSU No. 106 Sturgeon Lake South D-3 PSU No. 112 Sturgeon Lake South D-3 PSU No. 137 Sundre Rundle A PSU No. 3 Swan Hills BHL A & B PSU No. 117 Swan Hills South BHL A & B PSU No. 6 Sylvan Lake Jurassic A PSU No. 5 Sylvan Lake Jurassic A PSU No. 6 Utikuma Keg River Sandstone A PSU No. 32 Utikuma Keg River Sandstone A PSU No. 38 Utikuma Keg River Sandstone A PSU No. 40 Utikuma Keg River Sandstone A PSU No. 41 Utikuma Keg River Sandstone A PSU No. 42 Virginia Hills Beaverhill Lake PSU No. 9 Virginia Hills Beaverhill Lake PSU No. 12 Wintering Hills Viking A PSU No. 7 Wintering Hills Viking A PSU No. 8 Wintering Hills Viking A PSU No. 24 Yekau Lake D-3 A PSU No. 3 c Energy Resources 640 Fifth Avenue SW I armf_n mMm^^A^ ^^^S I conservation Board Ca.gar. A.e ta ^ I nTOnTiatlOnai IL 89-2 RESCISSION OF PRODUCTION SPACING UNITS AND BLOCKS The Board issued IL 89-2 on 31 January 1989 indicating its plan to rescind all production spacing units (PSUs) and Blocks contained therein effective 1 May 1989. The Board subsequently received a letter from Alberta Energy requesting the rescissions be delayed to avoid conflict with implementation of the new Production Injection Data Base. Further, several letters were received from Industry requesting that certain entitles be retained or that rescission be deferred for a period of time. With regard to these latter requests, the Board has concluded that the entitles Involved no longer serve a proration transfer purpose and should be rescinded. To accommodate Alberta Energy with its work schedule and at the same time provide the aforementioned operators time to evaluate alternatives, the Board will defer rescission for 2 months. Accordingly, all PSUs and Blocks listed in IL 89-2 will be rescinded effective 1 July 1989. Any questions with regard to this matter can be directed to the Oil Department at 297-8570. Amendment TO: ALL OIL AND GAS OPERATORS 3 April 1989 N. G. Berndtsson, P. Eng. Manager Oil Department Energy Resources 640 Fifth Avenue SW | 1^1^%/% ^^^1 ^ I conservation Board Calga ,*-^ 1^0111101101101 IL 89-3 Letter AMENDMENT OF THE ATHABASCA OIL SANDS AREA Recent drilling within the shaded area on the attached map has indicated the presence of potential oil sands resources beyond existing oil sands area (OSA) boundaries. Consequently, the Board intends to expand the current Athabasca OSA to include the area within Townships 88 to 103 in Ranges 4, 5, and 6 W5M, Townships 88 to 92 in Range 7 W5M, and Townships 83 to 88 in Range 4 W5M, as shown on the attached map. The Athabasca OSA includes all strata between the top of the Viking Formation and the base of the Woodbend Group as declared by Order No. OSA 1. If this proposal becomes a reality the Department of Energy is prepared to consider, upon request, preferential issuance of oil sands permits to those operators currently holding P&NG leases that include these rights within the shaded area. Operators are encouraged to notify the Board by 30 June 1989 of any concerns associated with this proposal. Any questions regarding this proposal may be directed to Mr. W. A. Mayer, Oil Sands Department, at 297-2883. MAY - 3 1989 TO: ALL OIL, GAS, AND OIL SANDS OPERATORS 26 April 1989 R. G. Evans, P. Eng. Manager Oil Sands Department Attachment ALBERTA'S OIL SANDS AREAS Area to be added to OSA 1 Energy Resources 640 Fifth Avenue SW I -^X^ m0W/%/% ^^^1 ^ I conservation Board Calgar. Alberta ^ | nTOl 11191101191 IL 89-4 Letter To: All Oil, Gas, Oil Sands, Pipeline, JUN 2 8 j989 Hydro and Electric, and Coal Operators 22 June 1989 PUBLIC INVOLVEMENT EST THE DEVELOPMENT OF ENERGY RESOURCES The Energy Resources Conservation Board and Alberta Environment (ERCB/AE) together have developed these guidelines concerning the involvement of Albertans in energy developments. Both the energy industry and the public also have made major contributions to their development. We believe these guidelines will be useful to the proponents of new energy facilities, and to the operators of existing facilities. While ERCB/AE recognize that the major players in any energy development are the company involved and the people living in the area, we also recognize that we have associated responsibilities. These are explained more fully in Section 5 of the Guidelines. Alberta's Department of the Enviromnent has in its mandate the IVliiiisterial right to order an Environmental Impact Assessment (EIA) for any energy facility deemed to have the ix>tential for significantly affecting people, communities, or the environment. While the typical EIA includes many of the elements of public involvement discussed in these guidelines, in no manner do the guidelines infringe upon the requirements of an EIA. ERCB/AE are aware that the Canadian Petroleum Association (CPA) presently is developing a major public consultation handbook. This handbook will indicate how energy companies may effectively carry out the broad philosophical concepts of public and community considtation. We look forward to its publication later this year, and widespread use. We commend the CPA on this important initiative. The ideas and suggestions presented here are basically those which ERCB/AE have found to be effective as we have worked with individuals, families, communities, and local governments located near energy developments. The suggestions and ideas of others involved in energy developments are actively solicited. Please write or call: 1. ERCB: Calgary 297-3381; Communications Department, 10 Fir, 640 - 5 Avenue S.W., Calgary, Alberta, T2P 3G4. 2. AE: Edmonton 427-5852; Environment Assessment Division, 6 Fir, Oxbridge Place, 9820 106 Street, Edmonton, Alberta, T5K 2J6. Vance MacNichol Deputy Minister Alberta Environment Energy Resources Conservation Board 1 Attachment to Informational Letter IL 89-4 Public Involvement in the Development of Energy Resources .Guidelines for Alberta's Energy Industry Section 1 Introduction These public involvement ideas and suggestions are not fixed in regulation. However, the energy industry should understand that the ideas presented here are the kinds of things that ERCB/AE urge companies to consider when they are submitting energy applications for evaluation. It should also be imderstood that these are broad guidelines. All actions suggested here do not apply to all energy projects. Obviously, what might apply very well to a small oil-field battery installation might be totally inadequate for a major oil sands plant. 2 Section 2 Olg'ectives While reviewing these objectives, it will be helpful to refer to the time-line chart which is Attachment A to this paper. The time-line shown extends from a point in time prior to development of an energy project through to final close-down. Thus, the objectives shown also extend across a similar time period. The ERCB/AE objectives include: • To foster a more thorough understanding, by everyone concerned, of the needs and concerns of all those involved in energy developments, including industry, government, and the people of Alberta. • To improve the public's imderstanding of the value of energy developments to this province, in terms of income to the province, benefits to its citizens arising from their ownership of the resources, a broader job base for its workers, and diversification of the provincial industrial base. • To improve industry's understanding of public awareness, priorities, and experience, as these relate to energy developments locally and province- wide. • To facilitate the direct involvement of concerned people in the work associated with planning, constructing, and operating specific energy facilities. • To ensure that public involvement occurs in such a manner and time that people's concerns may be properly addressed and resolved. • To encourage industry and government to work with Albertans in a language all may understand. • To encourage the energy industry to more fully tell its story — ^both the negative and positive sides — ^to the widest possible audience. • To sponsor and encourage the use of innovative approaches to issue discussion and conflict resolution, in order that win/lose confrontations and lengthy public hearings may no longer be necessary. • To facilitate effective communication between all of the parties to an energy development, not only as the project begins, but throughout its operating lifetime and to final close-down, no matter the number of years involved. 3 Sections Support from the People This guide opens with an explanation of the kinds of things the pubhc could do to make the entire energy development process more workable, more productive, and less confrontational. It seems logical to begin with the people of Alberta because industry and government must have the involvement and co-operation of the public in order for anything else to work. Despite all arguments regarding the significant benefits gained by Albertans from the development of energy resources, the fact is some Albertans do experience negative impacts from those developments. Those Albertans who are — or who perceive themselves to be—directly and negatively affected by energy developments must have their concerns fully identified and sensitively addressed. In order for all the other players to work towards a better way of handling energy developments, there is need for the following kinds of co-operation from the people and communities directly affected: 3.1 Albertans are encouraged to take every opportimity to learn more about the business of resource development, including about the EIA process, and the application review, public hearing, and regulatory and surveillance systems already in place. This would include attending important energy- related public meetings scheduled for their areas, and requesting small- group or one-on-one meetings, with government and industry, whenever they have concerns about specific projects. 3.2 Albertans directly affected by specific energy projects should adopt a practice of bringing their concerns forward to the company involved or to the ERCB or AE as early as possible, so that attempts may be made to resolve outstanding issues, preferably without public hearings or inquiries. In situations where ERCB/AE do not have jurisdiction to address certain issues, but where those issues are companion to a development proposal, the two organizations will endeavour to assist concerned citizens in taking their issues to the appropriate people for resolution. 3.3 Albertans who may be directly affected by specific energy projects are encouraged to take the necessary steps to fully understand the development proposals being presented. This step can include professional review of applications and independent research. 4 3.4 People directly concerned with a specific application should attempt to resolve as many issues as possible prior to public hearing, bringing only imresolved issues that fall within the ERCB's jurisdiction to the actual hearing. 3.5 When energy projects are approved, directly involved citizens are encouraged to continue bringing their concerns to the company involved or to ERCB/AE. People are also encouraged to participate in on-going problem solving, identifying issues requiring mitigation, and planning for final close-down, abandonment, and reclamation of a facility. It is anticipated, too, that specific concerns regarding violations or incidents will be reported immediately to the appropriate authorities (usually AE or ERCB). 5 Section 4 Industry Initiatives The suggestions appearing in this section are expectations of the energy industry held by both ERCB/AE. In the view of ERCB/AE, effective human and community relations are not subjects which can be regulated into existence. The energy industry and the people of Alberta must continue to deal with each other on a fully considerate basis. They must recognize each other's needs, and work together to resolve each other's concerns. The Alberta energy industry already has demonstrated its willingness to communicate with people well in advance of development, and to work to resolve people's concerns in a proactive way. ERCB/AE hope that the ideas expressed in this section will become the norm for energy industry/public relationships: 4.1 Wherever practical, industry is encouraged to bring together the people involvement and communication plans of all developers working in a single area. It is believed this will reduce the possibility of public confusion and disturbance arising from piecemeal development. It certainly will avoid duplication of message and effort. 4.2 Industry is encouraged to step up the telling of its story to the people of Alberta, particularly those people directly affected by its development proposals. Included in this work would be widespread distribution of such publications as the CPA Environmental Code of Practice and the CPA Public Involvement Manual. 4.3 Company representatives working in commimities should undergo specific training to better understand and more effectively address public concerns. 4.4 Industry is encouraged to begin its public involvement and communication activities well before submission of any application to ERCB/AE, and also to establish effective two-way lines of commimication with directly affected people prior to application submission. 4.5 Industry should make a special effort to explain to directly affected communities and people the emplo5rment and business opportunities expected from its projects and, wherever possible, to also indicate the overall benefits to the province. 4.6 Industry should explore every avenue of problem solving available to it before bringing the unresolved concerns of citizens to an ERCB public hearing. (This is quite apart from any work arising out of item 5.6 in the section following.) ) 6 4.7 Applications made to ERCB/AE for specific projects should be presented in language understandable to the lay reader, and strong efforts should be made to explain the application to directly affected citizens, both during commimity meetings and one on one. Specifically, project applications should include an understandable executive summary, and those sections of an application dealing with the commimity, social costs and benefits, the environment, himian and animal health, and emergency preparedness, should be framed at an easily understood language level. 4.8 When preparing for an ERCB public hearing, the company should place considerable emphasis on commimicating information directly related to the concerns of people and to how those concerns will be addressed. 4.9 If an application is approved, the company involved should continue its commimication and consultation efforts. It is felt, for example, that a company might actually step up its contacts with directly affected citizens after project approval. There should be an inmiediate and all-out effort to bring about a fiiller imderstanding of what has been approved and what will be done next, including emphasis on any problem- solving processes which will be put in place. 4.10 When facility construction begins, companies are encouraged to involve citizens in every way practical in being aware of the work as it progresses, and to proactively address any new issues or concerns as they may be brought forward. 4.11 Companies are encouraged to invite citizens to visit facilities during construction, to hold opening ceremonies to which all neighbours may be invited, and to encourage — as a corporate objective — having facility staff become involved members of nearby commimities. 4.12 Companies are encouraged to establish smoothly functioning communications networks, permitting citizens to bring forward any concerns arising out of facility operations. Longer-range, companies are encouraged to involve citizens in problem solving and, when the time comes, in the planning associated with facility close-down. 4.13 Companies are encouraged to communicate effectively with, and to obtain proactive input from, any special interest groups concerned with or interested in the important issues posed by any energy development. 7 Sections ERCB/AE Actions f In co-operation with Alberta Environment, the ERCB intends to carry out a variety of programs falling in the general categories shown below: 5.1 Beginning with widespread distribution of these public involvement guidelines, ERCB/AE will continue to make their positions regarding the need for effective public involvement and public communication well known throughout the Alberta energy industry. 5.2 In a variety of ways, ERCB/AE also will continue to make known to the Alberta public how the current process of application review, intervener funding, regulation, on-going surveillance, and provisions for intervention by concerned citizens, works to protect the public interest. Alberta Environment also will encourage other government departments to similarly explain their individual roles in energy developments. 5.3 Increased training opportunities will be provided to ERCB/AE staff in order that they may become more effective in working with those people directly affected by energy developments. 5.4 ERCB/AE will endeavour to proactively inform locally elected representa- tives about current and proposed energy developments in their areas. 5.5 When invited, ERCB/AE will attempt to ensure staff representation at key meetings between the industry and directly affected people. The two organizations also will make themselves available to any group of citizens wishing to discuss particular issues of concern related to specific energy proposals or operations. Insofar as may be practical, ERCB/AE also will attempt to ensure that this community contact work continues through project start-up and operation, and for as long as directly affected people perceive the need. 5.6 Utilizing either their own staff or contracted expertise, ERCB/AE will, where appropriate, offer to citizen/industry groups experiencing conflict the opportunity to enter into informal or formal consultation/mediation to resolve outstanding issues of concern. This may be done either prior to or after submission of an application, or after project approval (if ERCB/AE approval is gained for the project). 5.7 ERCB/AE will develop and implement a follow-up mechanism to ensure that commitments falling imder their jurisdictions that have been made during a project application, including those made during public hearing of the application, are indeed kept. 8 5.8 ERCB/AE will ensure that trained staff are present during any tests of the emergency plans developed for specific energy facilities, and that test reports are carefully evaluated, with appropriate modifications being made to the emergency plans in order to meet sound public safety practices. Alberta Environment also will encourage other government departments to have representatives present during such tests. 5.9 ERCB/AE will continue to ensure that inspections of operating facilities do not become a tedious routine exercise, and that the standards which have been developed for the protection of people and the environment will continue to be fully enforced throughout the lifetime of any energy project. 5.10 Alberta Environment, working closely with the ERCB, will continue with the development of guidelines and regulations leading to the safe and environmentally sound shut-down of energy facilities when their operating lifetimes are finished. JUN 191989 Informational Letter IL 89-5 TO: ALL IN SITU OIL SANDS OPERATORS 11 May 1989 WATER RECYCLE GUIDELINES AND WATER USE INFORMATION REPORTING FOR IN SITU OIL SANDS FACILITIES IN ALBERTA The Energy Resources Conservation Board and Alberta Environment have detailed their decision respecting water recycle and water use information reporting at all in situ oil sands facilities in the attached document ERCB-AE 89-AA Water Recycle Guidelines and Reporting of Water Use Information for In Situ Oil Sands Facilities in Alberta. The guidelines and reporting requirements are effective immediately. Inquiries concerning this letter or the attached document may be directed to the ERCB's Oil Sands Department at 297-3510, or to the Planning Division of Alberta Environment at 427-8985. ENERGY RESOURCES CONSERVATION BOARD ALBERTA ENVIRONMENT N. A. Strom Vice Chairman P. G. Melnychuk Assistant Deputy Minister ERCB-AE 89-AA U My^Zyi^Z/ ENVIRONMENT Water Recycle Guidelines and Reporting of Water Use Information for In Situ Oil Sands Facilities in Alberta MAY 1989 1 INTRODUCTION Recognizing that the continued development of oil sands resources by in situ recovery methods will place large demands on Alberta's water resources, the Energy Resources Conservation Board (ERCB) and Alberta Environment (AE) have set out goals and guidelines to manage and conserve the available water supply. The ERCB and AE, with the objectives of reducing freshwater requirements and wastewater disposal volumes, have as a goal the maximization of water recycling at all in situ oil sands projects. In working toward this goal, operators can expect regulatory approvals for those projects to address water reuse and to include water recycle stipulations. Such stipulations will include as a minimum the expected rate of recycle and a timetable for the implementation of water recycle. To assist those operators in the preparation of the necessary regulatory applications, the following guidelines have been adopted to outline and clarify the criteria used by the ERCB and AE when setting the recycle requirements for specific projects. 2 GUIDELINES FOR WATER RECYCLE 1. All in situ operators with freshwater requirements exceeding approximately 500 dam^/year (500 000 m^/year) will be required to recycle produced water. All in situ operators with freshwater requirements below 500 dam^/year will be required to actively investigate and test recycle technology. Oil sands operators have demonstrated that water recycle at large- scale projects can be efficient and economic. Experience to date would indicate that recycling is practical for projects where the freshwater demand exceeds approximately 500 dam-^/year. Recycling at some smaller projects may not be as practical given the absence of the economics of scale characteristic of larger projects. Also, in some other cases, there may be only limited data available on produced water quality and quantity. In each case, however, the ERCB and AE would require that operators actively pursue the development and implementation of an appropriate recycle technology. 2. The target recycle rate assigned to a project will be based on produced water and will be defined as an annual level. As produced water recycle accounts for the greater part of the potential water reuse , target recycle rates will be based on produced water. The upper limit of the target rate will be 100 per cent or a rate sufficient to meet the total project water requirement, whichever is less . The actual target recycle rate designated by the ERCB and AE would be based primarily on the produced water quality - more specifically, the concentration of dissolved solids, the hardness, and the silica content. The target recycle rate would also take into consideration any environmental, technical, and economic factors that are demonstrated to be significant and limiting. It will be the responsiblity of the applicant to demonstrate that factors are significant and limiting for a specific project. The ERCB and AE recognize that, in the province, experience with water recycle technology is varied and with some companies limited. Therefore, for those projects where new recycle facilities are to be incorporated into the plant, a phase-in period of 1 year, or other such period as stipulated in approvals and licences, would be allowed to reach the designated target recycle rate "granted" . 3. These guidelines must be addressed in regulatory applications that are reviewed by the ERCB and AE. The ERCB and AE consider the development and incorporation of water recycle technology an integral part of all in situ oil sands projects. As such, water recycling must be addressed in the appropriate regulatory applications and supporting documents for these projects. These may include but are not limited to Environmental Impact Assessments, project and subsurface disposal applications to the ERCB, and any application to AE pursuant to the Water Resources Act and the Clean Water Act. 3 WATER USE REPORTING Improved reporting of water use information is required by Alberta Environment to confirm that this goal is being achieved. A review of industry monitoring indicates the basic data needed by Alberta Environment is currently collected as part of the S series of monthly reports to the ERCB. The ERCB has agreed to provide the Department with the pertinent water information reported on these forms. The resulting administrative change between the ERCB and Alberta Environment will not require any major changes in data collection or reporting by industry. More effective use of information now reported by industry to the ERCB will improve decision-making, minimize duplication ^ and reduce reporting under environmental protection approvals. Inquiries regarding these guidelines may be directed to the ERCB's Oil Sands Department at 297-3510, or the Planning Division of Alberta Environment at 427-8985. Energy Resources 640 Fifth Avenue SW Conservation Board Calgary, Alberta Canada T2P 3G4 Informational 'l 89-6 Letter CANADliVNA 14 June 1989 JUN 2 0 1989 To: ALL OIL AND GAS OPERATORS 1989 ADMINISTRATION FEB ON WELLS AND OIL SANDS PROJECTS The Board has set the 1989 Administration Fee at 84 per cent of the rate specified in sections 16.070 and 16.080 of the Oil and Gas Conservation Regulations, and invoices will be mailed on 10 July 1989. Again, where the operation of a well is undertaken by a contract operator, the fee will be directed to the owner rather than the operator upon the written request of the owner. This request should include a complete description of the well and the name of the operator, should be addressed to the attention of R. D. Batten, and should be forwarded to our office no later than 1 July 1989. R. T. Bordin, Manager Accounting