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Bulletin 2007-06

April 24, 2007

Streamlining the Review of Applications for Oilfield or Industrial Waste Fluid (Class I) Disposal Schemes

The Alberta Energy and Utilities Board (EUB) and Alberta Environment (AENV) have developed the attached memorandum of understanding (MOU) on the review of applications for Class Ia and Class Ib disposal schemes. The MOU is intended to simplify the current review process by limiting the referral to AENV for a Ministerial Approval to applications for Class Ia disposal wells only. Applications for Class Ib wells will be reviewed solely by the EUB within the framework of EUB Directive 051: Injection and Disposal Wells, Well Classifications-Completion, Logging, and Testing Requirements, Directive 065: Resources Applications for Conventional Oil and Gas Reservoirs, and this MOU.

The MOU outlines guiding principles and clarifies the roles of the EUB and AENV. The EUB and AENV have agreed to implement a streamlined application review process while ensuring the optimal use of subsurface waste management technology and the protection of nonsaline groundwater.

Questions regarding the MOU should be directed to either the EUB at (403) 297-5290 or AENV at (780) 427-0636.

    
<original signed by>

D. K. Boyler, P.Eng. 
Executive Manager
Compliance, Environment, and Operations Branch
Alberta Energy and Utilities Board
 
Attachment
 

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

April 24, 2007

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 Alberta Energy and Utilities Board (EUB). Prior to issuing an approval, the EUB 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 EUB 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 storage and disposal of fluids into geologic formations through Class Ib wells.

2 Principles
The EUB and AENV have reviewed the need for the continued referral of Class I applications to AENV to ensure groundwater protection. Currently, the EUB 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 storage or 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 EUB has developed requirements for subsurface waste disposal schemes, which are contained in Directive 065: Resources Applications for Conventional Oil and Gas Reservoirs and Directive 051: Injection and Disposal Wells, Well Classifications-Completion, Logging, and Testing Requirements, and requirements for the testing of injection packers, which are set out in EUB 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 EUB 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 EUB have agreed on the following:

• The EUB will continue to refer applications for Class Ia subsurface waste disposal schemes to the Minister of Environment for Ministerial Approval.
• Pursuant to Section 39(4) of the OGCA, the Minister of Environment has directed that applications for Class Ib subsurface waste disposal schemes do not need to be referred for Ministerial Approval, as the EUB requirements for these applications are protective of groundwater.
• With regard to Class Ib subsurface waste disposal schemes, the EUB will continue to

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

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

2) require an appropriate combination of surface, intermediate, or production casing cemented to surface from a minimum of 25 metres below the base of groundwater protection;

3) ensure that the disposal fluid will be confined to the injection formation, including hydraulic isolation at the wellbore;

4) review and approve applications in accordance with the principles set out in Section 2; and

5) record the type, classification, and volumes of fluids injected.

<original signed by> B. T. McManus, Q.C.  Acting Chairman Alberta Energy and Utilities Board

<original signed by>  C. Peter Watson, P.Eng.   Deputy Minister Alberta Environment