News Release
FOR IMMEDIATE RELEASE
EUB ISSUES DECISION ON COMPTON NORTH OKOTOKS DRILLING PROGRAM
Compton required to resubmit emergency plans using 9.7-kilometre planning zone
Calgary, Alberta (June 22, 2005) The Alberta Energy and Utilities Board (EUB) has issued Decision 2005-060, which addresses applications associated with Compton Petroleum Corporation's proposed North Okotoks Horizontal Well Program, located 4.5 kilometres (km) southeast of the nearest community in Calgary.
The EUB found that the proposed wells can be drilled, completed, and operated safely, however the well licences will only be issued if Compton can gain the EUB's approval of its Emergency Response Plan (ERP), which is currently incomplete. If Compton gains approval of its ERP at a future date, the EUB will issue four of the six well licences at that time.
The EUB has denied the application for the reduced Emergency Planning Zone (EPZ). Instead, the EUB has determined that an EPZ of 9.7 km comprised of a 5-km evacuation zone, and 4.7-km sheltering zone would be appropriate. The decision also states that Compton's Emergency Response Plan must incorporate a collaborative command approach with the municipalities and the Calgary Health Region for public protection measures within and beyond the Emergency Planning Zone.
Compton must also meet 14 further EUB conditions, including one requiring that if the EUB approves Compton's well and facility licence applications, the wells and surface facility must be abandoned and removed 15 years from the date of the first well license approval or July 1, 2021, whichever is earlier.
The EUB has established a timetable for Compton to comply with conditions set forth in the decision. If that timetable is not met, the EUB may close the applications.
In a public hearing conducted from Jan. 11 to Mar. 4, 2005 in Calgary, the EUB considered several applications from Compton: to drill up to six critical sour gas wells on the site of the existing producing 10-13 well, to secure a reduce drilling spacing unit, and to reduce its Emergency Planning Zone to four km.
The EUB ensures that the discovery, development, and delivery of Alberta's resources take place in a manner that is fair, responsible, and in the public interest.
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For more information, please contact:
NR 2005-12
Decision Summary
The EUB held a public hearing from January 11 to March 4, 2005, to consider nine applications by Compton Petroleum Corporation (Compton) to drill six horizontal sour gas wells, to construct and operate associated surface facilities, to reduce the emergency planning zone (EPZ) to four kilometres (km) with a corresponding emergency awareness zone (EAZ) of eight km, and to implement the associated emergency response plan (ERP). Compton also applied for a special well spacing unit.
In arriving at decisions of this nature, the EUB is guided at all times by its mandate to consider the public interest. The EUB considered that these sour gas wells, given their H2S content of 35.6 per cent, present a potential hazard during drilling, completion, or production operations, but a low level of risk.
Given the proposed location of the applied-for wells in proximity to densely populated areas, the EUB adopted a particularly cautious approach with respect to questions about public safety.
In order for well licences to be issued, the EUB must approve the associated technical drilling and completion programs, as well as the emergency response plan (ERP).
Following extensive examination and consideration, the EUB determined that the proposed wells can be drilled, completed and operated safely. However, the well licenses will only be issued if Compton can gain the EUB's approval of its ERP, which is currently incomplete. If Compton gains the EUB's approval of its ERP at a future date, the EUB will issue the well licenses at that time.
Reduced Emergency Planning Zone (EPZ)
The EUB agreed with submissions that stated emergency response actions such as evacuation, sheltering and notification must be matched to the appropriate distances to hazard.
The EUB noted that for short-term releases, an effective sheltering program is equivalent to evacuation. However, evacuation actions, which would be initiated prior to any release of H2S, constitute the preferred method of protection for parties most at risk, in this case the rural residents in closest proximity to the proposed wells.
The EUB has determined the following with respect to Compton's reduced EPZ application:
- Compton's proposed modified reduced 4-km EPZ is not sufficiently protective of public safety and is therefore denied, as is the corresponding 8-km EAZ.
- Compton shall use a reduced EPZ of 9.7 km, composed of an evacuation zone of approximately 5 km in radius, and a sheltering zone of approximately 4.7 km in radius
- Compton shall use an EAZ of 15 km
Drilling/Completion Plans
The EUB has approved Compton's drilling, completion and production plans, subject to additional EUB directed conditions and voluntary commitments from Compton. If Compton gains the EUB approval of its resubmitted ERP, the EUB would approve four of the requested six wells.
Emergency Response Plan
Compton acknowledged that its ERP is incomplete as a result of the EPZ not being finalized. The EUB found that the ERP for the proposed modified reduced 4-km EPZ lacked sufficient detail and subsequently directed Compton to resubmit its ERP with EUB the improvements included.
To address the need for improved coordination, the EUB directed Compton to adopt a unified command approach with the municipalities and the Calgary Health Region (CHR) to provide for progressive and collaborative public protection measures within and beyond the EPZ. One of the EUB's conditions is that Compton must complete a major ERP deployment exercise prior to entering the first sour zone.
Surface Facility and Reduced Spacing Applications
The EUB approved the surface facility application, subject to EUB conditions and commitments from Compton, and has approved the special spacing application.
The following table summarizes the EUB's determinations on Compton's applications:
Table 1. Summary of Board Determinations on Applications
|
Application description |
Board decision |
Did the Board impose additional conditions? |
Did Compton make additional voluntary commitments? |
Date of required Compton response |
|
Distance to Hazard
a. EPZ (proposed 4 km)
EAZ (proposed 8 km) |
Denied (increase to 9.7 km)
Denied (increase to 15 km) |
Yes
Yes |
Yes
Yes |
August 15
August 15 |
|
Well Licences
a. Drilling/
completion plans
b. ERP
c. Number of wells |
Approved
Deficient
Partial (4 of 6) |
Yes
Yes
Yes |
Yes
Yes
- |
-
Nov. 1
- |
|
Surface Facilities |
Approved |
Yes |
Yes |
- |
|
Reduced Spacing |
Approved |
- |
- |
- |
Timing
The EUB specified a number of deadlines for Compton:
- August 15, 2005: Advise the EUB if Compton wishes to pursue approval of its applications in accordance with the EUB's determinations in this decision. If Compton advises the EUB that it does not intend to pursue these applications further, or if the EUB has had no response from Compton by the above referenced date, the EUB will consider the applications withdrawn and close its files.
- November 1, 2005: File a complete revised ERP following appropriate consultation with all affected parties. The EUB will provide an opportunity for interveners who participated in the hearing to offer comments on the revised ERP.
- January 1, 2008: Licences for any wells that have not yet been spudded will be cancelled.
- July 1, 2021 or 15 years from the first well license approval, whichever is earlier: all wells and surface facilities at the 10-13 site must be abandoned. The well and surface facility for the 11-24-22-29W4M must be abandoned 7.5 years from the approval of the first new well license for the 10-13 site.
The EUB will consider requests from Compton for alterations to the deadlines imposed for Compton's advice as to its intention to pursue approvals of the applied-for well licences and for the filing of the ERP.
EUB Conditions
This section is provided for the convenience of readers. In the event of any difference between the conditions in this section and those in the main body of the decision, the wording in the main body of the decision shall prevail. The number following each item below is the page on which it is stated in the decision report.
1. Given that completion operations would yield the highest potential release rate, the EUB asked Compton at the hearing to consider the use of a permanent production packer that would be installed prior to the initiation of any completion operations and would not be removed from the well, even in the event of a subsequent packer failure. The adoption of this completion practice would ensure that the highest potential release rate would be that associated with the drilling scenario. The EUB notes that Compton committed at the hearing to follow the procedure suggested by the EUB, thereby limiting the maximum release rate to below that of the drilling rate. The EUB will make this a condition of any well licences that are granted. (Page 20)
2. Conduct a test firing of each of the specific Firefly units that would be deployed on site during the drilling and completion of the wells. These tests are to be conducted on site, provided that the testing can be done safely, having regard for the site-specific conditions at the time of the test and obtaining prior agreement to the test from the landowner. If the on-site test is not possible for the aforementioned reasons or any others that it may not be aware of, the EUB would accept an off-site test, provided it was conducted immediately prior to the transfer of the Firefly units to the well site. If an off-site test is required, the EUB would prefer a site in relatively close proximity, such as a neighbouring farm or gravel pit, if possible, to minimize any travel-induced disruption to the functioning of the units. The EUB is aware that this test would reduce the discharges available in each unit from 20 to 19, but is satisfied that the presence of the fuel gas-supplied ignition system would be capable of maintaining ignition if an uncontrolled flow from the well were to extinguish itself. (Page 22)
3. Test the satisfactory functioning of the under-rig igniter on site before drilling commences. (Page 22)
4. Revise the sections of the applications addressing drilling, completion, and testing to reflect the commitments and revisions made as a result of the hearing and this decision and resubmit them at the time that it submits any revisions to its ERP. (Page 22)
5. Provide an independent nitrogen booster system connected to the shear ram via a shuttle valve, in addition to the accumulator system and the nitrogen backup system. This booster system must comprise a minimum of three 34 000 kPa, 50 litre nitrogen bottles. These nitrogen bottles must each contain a minimum pressure of 30 000 kPa and be connected to the shuttle valve with a 34 000 kPa fireguard hose. A minimum 34 000 kPa regulator must be installed in the above system and set at 24 000 kPa. (Page 22)
6. There may be no drilling or completion operations in the critical sour zones of the wells during the months of December, January, and February. (Page 22)
7. Notify EUB Field Surveillance staff so that detailed inspections may be conducted prior to drill-out of the intermediate casing shoe, prior to removal of the bridge plug during completion operations, and during the testing of each well. (Page 22)
8. Test the quantity and quality of George White's water well before and after drilling and completion operations. (Page 22)
9. The EUB is satisfied that the concerns of the White family may be addressed by their relocation during drilling and completion operations. The EUB will make it a condition of any licence to require Compton to offer to relocate Gerald White's and George White's families during drilling and completion operations. The EUB expects the parties to agree upon the details of the relocation. (Page 24)
10. The EUB notes that Compton has committed to cause the Chestermere pipeline to be abandoned or ceased to be used as a sour gas pipeline within the timeframe specified in the LRD agreement. The EUB will condition any well licence approvals to reflect this commitment. (Page 30)
11. With respect to the term of any well licences issued, the EUB is not prepared to extend the validity of well licences for a period of three years after issuance. The EUB finds that the window for depletion of this reservoir is closing rapidly. The EUB will make it a condition of any approval that the licences will therefore expire on January 1, 2008. Licences for wells that have not been spudded by that date will become invalid. (Page 31)
12. The EUB will make it a condition of the approvals that the wells and surface facility at the 10-13 site must be abandoned and removed 15 years from the date of the first well licence approval or July 1, 2021, whichever is earlier. (Page 31)
13. The EUB notes that Compton has committed to abandon the 11-24 well within 7.5 years of the date of issuance of the first applied-for well licence. In light of Compton's stated intention and the integral nature of the early abandonment of facilities to Compton's overall plan for the area, the EUB will make this a condition of any licences issued for the applied-for wells. (Page 31)
14. The EUB notes Compton's commitment to execute an ERP exercise in conjunction with the municipal authorities to the satisfaction of all concerned before drilling commences. The EUB will make it a condition of its approvals that Compton may only enter the first sour zone following successful completion of a major ERP deployment exercise. (Page 50)
