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Section 5.4 states:

7) The applicant must file an application for a multiwell facility when:
a) multiple zones are producing from one wellbore but the production remains segregated (i.e. not commingled in the wellbore)
b) production from a second well is pipelined to an existing single well facility; or
c) multiple single well facilities are operating within one surface lease.

Under the conditions noted above, a grouping of surface equipment becomes a multiwell facility when, in the case of:

a) Crude bitumen operations located within defined oil sands areas, typically conventional process vessels (i.e. separators) are not used and separation often occurs by gravity in the production tanks. If this is the case and a number of individual wells are all producing to individual or common tanks on one surface lease, a multiwell bitumen battery licence is required (B071, C331, D431). If using conventional separation, a multiwell bitumen battery licence is still required.

b) Conventional oil operations, typically conventional process vessels (i.e. separators) are used. A grouping of this type of equipment with multiple wells on or pipelined to a common site requires licensing as a multiwell oil battery (B030, C321, D421). There are exceptional cases where a number of individual wells are all producing to individual or common tanks on one surface lease, without using conventional separation, which would also be viewed as a multiwell oil battery.

c) Gas production operations, a multiwell gas battery must have at least conventional separation or more equipment to require licensing as a multiwell gas battery (B020, C311, D411). The use of a FlowDrip separator is not viewed as conventional separation and by itself would not trigger a licence.

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Gas Battery - a system or arrangement of tanks and other surface equipment (including interconnecting piping) that receives the effluent from one or more wells that might provide measurement and separation, compression, dehydration, dew point control, H ₂ S scavenger where < 0.1 t/d of sulphur is being treated, line heater or other gas handling functions prior to the delivery to market or other disposition. This does not include gas processing equipment that recovers more than 2m ³ /d of liquids or processes more than 0.1 t/d of sulphur.

The requirements set out in Section 5.5.1 of Directive 056 for single well sweet production sites are still applicable. However, in the case of a single well sour gas site (H ₂ S > 10 ppm); the following rules have been incorporated into Section 5.5.1:

An application is not required under Directive 056 if the facility is a single well gas production site where:

• the H ₂ S content is greater than 0.01 mol/kmol (10 ppm)
• there are no liquid hydrocarbon/produced water tanks,
• no compression,
• no gas processing, and
• no injection/disposal component.

Note that these revisions and clarifications to Directive 056 are effective immediately and apply to single well sour gas production sites only. The current licensing rules for oil facility sites or multiwell gas facility sites have not been revised.

Furthermore, these revisions will result in the deletion of Case 5 and Case 25 from Appendix 10 of Directive 056, and will impact the current practice of licensing line heaters at sour wellsite leases. Effective immediately, single well sour line heaters located at a wellsite lease are no longer required to be licensed as either a single sour gas battery (C310 or D410) or a pipeline installation (C384 or D531) unless they meet the revised gas battery definition or pipeline installation requirements.

Grandfathering of Existing Licences
Those companies who have licensed single well sour line heaters at wellsite leases as pipeline installations may request that the EUB cancel the pipeline installation licence that was issued, provided the current equipment configuration does not require licensing as a gas battery (i.e.; there are no hydrocarbon and/or produced water tanks on the wellsite lease). Line heaters located along a pipeline right-of-way will continue to be licensed in accordance with Section 6 of Directive 056.

Those companies who have received a licence for sour single well gas battery (C310 or D410) for a site that does not meet the revised definition of a gas battery (i.e.; there are no hydrocarbon and/or produced water tanks on site) may request that the EUB cancel its existing licence. Alternatively, the company may choose to retain the single well sour battery licence it received so that it could add surface equipment that would now meet the revised gas battery definition. In this case, operators are reminded that a formal application under Directive 056 may not be required for the additional equipment but applicants are still required to fulfill the consultation and notification requirements for exempted facilities and activities as outlined in Section 5.5 of Directive 056.

Those companies who have constructed facilities that meet the revised gas battery definition but did not obtain a facility licence are required to contact Facilities Applications to self-declare the licensing oversight and seek advice.

A matrix has been developed to assist industry in determining if the equipment proposed for installation will require the submission of a Directive 056 facility licence application. This matrix is located under "I. Directive 056 Tools" on the Directive 056 Web page.

Further questions or clarification on this matter may be directed to the Directive 056 phone helpline at 297-4369 or email helpline at directive56.Help@eub.ca

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Surface Development Clarification
The distance required to the nearest "surface development" provides the EUB with an indication as to whether a site specific ERP is required. Please note that the distance has no bearing on the Directive 056 participant involvement requirements.

Surface Development Definition
The following definition replaces the previous "distance to nearest occupied dwelling" in Schedule 4, Step 10 of the Guide 56 (October 2000). The change in text was required to coincide with the new "surface development" definition set out in Directive 071: Emergency Response Planning. The definition in Appendix 3 of Directive 056 (October 2003) quotes Directive 071, stating that a surface development is:

"An occupied permanent or part-time dwelling, a publicly used facility, including a campground, a place of business, and any other surface development where the public may gather"

Place of Business
A "place of business" with respect to oil and gas developments will include the nearest off-lease building that is manned by staff or where people may work or gather on a regular basis. An example of a nearest off-lease place of business would be a field office located at a compressor station in the adjacent section where people may gather on a regular basis. A compressor, pipeline, or wellhead without a manned building would not be considered a place of business.

Please do not record the distance to the nearest well, facility, or pipeline as the distance to the nearest "surface development" unless there is a building on the lease or right-of-way where people may gather on a regular basis.

Distance to Nearest Surface Development
In order to answer the question "Distance to nearest surface development" on Schedule 2, 3 (pipeline installations only), or 4 the applicant must locate the distance to the nearest surface development from either:

• the well centre 
• edge of pipeline right-of-way, or
• the edge of the facility lease 

Survey Plan or Plot Plan 
The survey plan or plot plan must meet all Directive 056 requirements and should reflect the distance to the nearest: 

• dwelling whether occupied part time or fulltime (e.g.; house, seasonal cottage, trapper's cabin), 
• publicly used facility (e.g.; church, community centre, campground, curling rink), 
• place of business (as described above), or 
• other surface development where the public may gather 

Remote or Undeveloped Areas
The distance to the nearest surface development is used to determine if a site specific ERP is required. In remote or undeveloped areas, the applicant must initially search to the distance of the emergency awareness zone  (EAZ) (two times the  size of the emergency planning zone  EPZ ) for any surface developments. If there is no surface development within the EAZ, the applicant may record a distance to the nearest town, village, or urban centre. Where there is no EPZ the search should encompass at least 1.5 km. The applicant may then choose to use 1.5 km as the distance to the nearest surface development. This process is to be used only in remote or undeveloped areas for the purpose of a Directive 056 licence application.

PREPARATORY WORK

(a) a licence or approval has been granted and is in full force and effect and the person is the licensee or approval holder, or 

(b) the facility is exempt from the requirement of a licence or approval by regulation or by direction of the Board.

Section 12(1) prohibits any preparatory or incidental operations at a facility site, on private or public lands, before a facility approval or licence is issued. However, Section 12(2) of the OGCA allows for surveying the proposed facility site prior to issuance of a licence or approval.

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How does the April 2008 edition of Directive 071 affect my Directive 056 participant involvement program for applications submitted after April 8, 2008?

• and the Directive 056 participant involvement program was not completed prior to April 8, 2008, you are required to ensure that the new EPZ based on the requirements of the April 2008 edition of Directive 071 has been reflected in the project-specific information package and that the radius of personal consultation and confirmation of nonobjection for category C, D, and E wells is based on the new EPZ prior to submitting a Directive 056 application; or
   
• if the Directive 056 participant involvement program was completed prior to April 8, 2008, based on EPZ calculations from the 2005 edition of Directive 071 , you will be required to renotify residents in accordance with Table 3 of the 2008 edition of Directive 071 prior to the submission of your Directive 056 application. This means that if the EPZ increased, notification of residents within the expanded portion of the EPZ is required, or if the EPZ is smaller, notification of residents who are no longer in the EPZ is required. Enforcement action will not be applied to applications processed during the Directive 071 (April 2008) transition period, April 8 to July 2, 2008, for noncompliance issues related to Directive 056 EPZ requirements

For applications currently before the Board in a hearing process, the decision to require the applicant to recalculate the EPZ using ERCBH2S and rewrite its plan in accordance with the requirements in the April 2008 edition of Directive 071 will be at the discretion of the Board and considered on a case-by-case basis.

• the highest H2S content based on all pipelines entering the facility, or
• the highest H2S content from any well associated with the raw gas inlet.

Applicants will continue to be required to support the H2S content recorded (and corresponding sulphur inlet) by either submitting representative gas analyses or by identifying the pipeline licences associated with the facility upon request.