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Bulletin 2010-17

June 8, 2010

Clarification to the “Memorandum of Understanding Between the Alberta Energy and Utilities Board and Alberta Environment Regarding Subsurface Waste Disposal Applications” (Bulletin 2007-06)

The Energy Resources Conservation Board (ERCB) and Alberta Environment (AENV) have jointly amended the memorandum of understanding (MOU) on the review of applications for Class Ia and Class Ib disposal schemes that was originally issued in April 2007 under Bulletin 2007-06 . The attached updated MOU clarifies that

• applications to the ERCB for Class Ib waste disposal schemes will not be referred to AENV for Ministerial Approval, and
• the ERCB will require an appropriate combination of cemented surface, intermediate, or production casing for potential Class Ib wells as specified in the version of ERCB Directive 051: Injection and Disposal Wells—Well Classifications, Completions, Logging, and Testing Requirements applicable at the time of approval.

The update also replaces references to the Alberta Energy and Utilities Board (EUB; predecessor to the ERCB) with “ERCB.”

Questions regarding the MOU can be directed to either the ERCB at 403-297-3655 or AENV at 780-644-1122.

< original signed by >

Stephen Smith
Executive Manager
Applications Branch

Attachment

Memorandum of Understanding Between the Energy Resources Conservation Board and Alberta Environment Regarding Subsurface Waste Disposal Applications

June 8, 2010

1 Introduction

Under Section 39 of the Oil and Gas Conservation Act (OGCA), an application for a Class Ia or Ib subsurface waste disposal scheme must be submitted to the Energy Resources Conservation Board (ERCB). Prior to issuing an approval, the ERCB refers the proposed disposal scheme to Alberta Environment (AENV) for review. AENV’s involvement is limited in most cases to determining whether nonsaline groundwater is protected by cemented casing and whether the proposed ERCB approval conditions are sufficient to protect groundwater quality. If AENV concurs with the scheme in areas that relate to environmental protection, a Ministerial Approval is issued.

The purpose of this memorandum of understanding (MOU) is to simplify the current administrative review process with respect to the handling of applications for subsurface disposal of fluids into geologic formations through Class Ib wells.

2 Principles

The ERCB and AENV have reviewed the need for the continued referral of Class I applications to AENV to ensure groundwater protection. Currently, the ERCB and AENV apply the principles set out below in determining whether to approve an application:

• The fluids or other substances injected must be suitable for subsurface disposal.
• The receiving formation must provide long-term confinement of the fluids or substances injected.
• The design, construction, and monitoring of disposal wells must ensure well integrity, groundwater protection, and hydrocarbon conservation.

In addition, the ERCB has developed requirements for subsurface waste disposal schemes, which are in Directive 065: Resources Applications for Conventional Oil and Gas Reservoirs and Directive 051: Injection and Disposal Wells—Well Classifications, Completions, Logging, and Testing Requirements, and requirements for the testing of injection packers, which are in ERCB Interim Directive 2003-01: 1) Isolation Packer Testing, Reporting, and Repair Requirements, 2) Surface Casing Vent Flow/Gas Migration Testing, Reporting, and Repair Requirements , 3) Casing Failure Reporting and Repair Requirements . The ERCB also places conditions on approvals of these schemes to ensure environmental protection and responsible and effective management of subsurface waste disposal.

3 Agreement

As a result of the above, AENV and the ERCB have agreed on the following:

1) The ERCB will continue to refer applications for Class Ia subsurface waste disposal schemes to the Minister of Environment for Ministerial Approval.

2) Pursuant to Section 39(4) of the OGCA , the Minister of Environment has directed that applications for Class Ib subsurface waste disposal schemes will not be referred for Ministerial Approval, as the ERCB requirements for these applications are protective of groundwater.

3) With regard to Class Ib subsurface waste disposal schemes, the ERCB will continue to

a) require and assess the following environment-related information in applications:

i) base of groundwater protection,
ii) maximum wellhead injection pressure,
iii) an explanation of why the proposed disposal is required, including an assessment of alternative use/disposal options, and
iv) type, source, classification, and estimated annual volumes of the fluids to be disposed of;

b) require an appropriate combination of cemented surface, intermediate, or production casing as specified in the version of ERCB Directive 051 applicable at the time of approval;
c) ensure that the disposal fluid will be confined to the injection formation, including hydraulic isolation at the wellbore;
d) review and approve applications in accordance with the principles set out in Section 2; and
e) record the type, classification, and volumes of fluids injected.