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Directive 056: Frequently Asked Questions – Wells Technical
| SURFACE DEVELOPMENTS |
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Question:
| With regard to Surface Development, please clarify "place of business", "distance to the nearest surface development", and what to capture as the nearest surface development in a remote area. |
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SETBACK REQUIREMENTS
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Question:
| If you have a water body within 100 m of well centre, and the site is located on freehold land, is this a routine or nonroutine application? |
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Question:
| During the audit process, what deficiencies is the Facilities Applications Group finding with regard to setback requirements for wells containing H
2
S? |
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Question:
| With regard to the 40 m setback to a surveyed lease/access road described in section 7.9.12.3 of Directive 056, if an applicant is within the 40 m setback but owns the lease/access road, is it required to submit a non-routine application? |
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Question:
| In section 2.2.2(16)(h) the applicant is required to provide a discussion of the potential restrictions regarding developing lands adjacent to the proposed development, such as setbacks, in the project-specific information package. What information should be included in this discussion? |
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Question:
| What are the requirements for filing a well licence application when drilling a well in proximity to a subsurface coal mine? |
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ENVIRONMENTAL REQUIREMENTS
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Question:
| Is there an EUB requirement to notify Alberta Environment (AENV) prior to submitting a well licence application with the EUB? |
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H
2
S RELEASE RATES
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Question:
| Should the terminating formation or 15 m overhole formation be included in the H
2
S release rate assessment? |
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Question:
| Is a geological discussion, mapping, and engineering discussion required for only the H
2
S bearing zones that the applicant intends to produce from the wellbore? |
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PREPARATORY WORK
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Question:
| If a company has obtained landowner approval, all applicable agreements are in place, the lease is surveyed, and an EUB well licence application is underway but not yet approved, can that company commence preparatory work regarding the well or well site? |
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Question:
| We have preset surface casing in a well, but the main drilling rig has not been moved on hole to complete the drilling to the approved projected total depth. We intend to drill the well to total depth, but it is possible that a significant period of time may pass before we do and we are concerned about the well licence expiring. Do we need to inform the EUB? If so, how, and what information is required? |
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Question:
| We have preset surface casing in a well and do not intend to move a rig on to drill to the approved projected total depth. Are we required to report this information to the EUB? If so, how, and what information is required? |
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DIRECTIVE 071: EMERGENCY PREPAREDNESS AND RESPONSE REQUIREMENTS FOR THE PETROLEUM INDUSTRY
(April 2008)
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Question:
| What EPZ should I record on my
Directive 056
application schedule? |
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Question:
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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?
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SURVEY PLANS
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Question:
| I am planning to submit a new well licence application that will include a survey plan based on remotely sensed data (i.e., LiDAR). Will the ERCB accept my application if the information on my survey plan is based on remotely sensed survey data? |
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SURFACE DEVELOPMENTS
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Question:
| With regard to Surface Development, please clarify "place of business", "distance to the nearest surface development", and what to capture as the nearest surface development in a remote area. |
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Answer:
| The following information will provide some background and clarification:
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 Directive 056. 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.
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.
Surface Development and Surface Improvement
The term "surface development" should not be confused with the definition for "surface improvement". Please refer to Directive 056, Appendix 3 for a definition of "surface improvement".
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TOP
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SETBACK REQUIREMENTS
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Question:
| If you have a water body within 100 m of well centre, and the site is located on freehold land, is this a routine or nonroutine application? |
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Answer:
| If the applicant plans to meet the mitigative requirements outlined in section 7.9.12.1 Water Bodies, then a well being drilled within 100 m of a water body may be applied for routinely. For Directive 056 audit purposes, the applicant must keep documentation describing the steps that it will take during drilling operations to ensure the water body is protected.
Although there may be instances where a nonroutine application is required, the applicant would file the supportive documentation describing the acceptable measure(s) the applicant will take to ensure the environment is protected during drilling program and with future operations at the site with its nonroutine application and keep the documentation on file for audit purposes.
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TOP
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Question:
| During the audit process, what deficiencies is the Facilities Applications Group finding with regard to setback requirements for wells containing H
2
S? |
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Answer:
| The most common deficiency is where the applicant selects the incorrect minimum setback distance from Table 7.5. The setbacks in Table 7.5 are based on the potential producing H
2
S release rate. Therefore, the applicant must compare the potential producing H
2
S release rate for the proposed well to the release rate in Table 7.5 and select the corresponding minimum setback distance from Table 7.5. |
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TOP
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Question:
| With regard to the 40 m setback to a surveyed lease/access road described in section 7.9.12.3 of
Directive 056
, if an applicant is within the 40 m setback but owns the lease/access road, is it required to submit a non-routine application? |
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Answer:
| Applicants who are within 40 m of their own surveyed access or lease road do not have to submit a nonroutine application. Companies have been submitting applications in this situation routinely and should continue to do so. |
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Question:
| In section 2.2.2(16)(h) the applicant is required to provide a discussion of the potential restrictions regarding developing lands adjacent to the proposed development, such as setbacks, in this project-specific information package. What information should be included in this discussion? |
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Answer:
| In order to meet Directive 056 requirements, the applicant should include a statement in its project-specific information package that any future surface improvements within 100 m of the wellhead may be subject to County/Municipal development setbacks. |
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Question:
| What are the requirements for filing a well licence application when drilling a well in proximity to a subsurface coal mine? |
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Answer:
| If the proposed well is within 3 km of a working mine or within 400 m of an abandoned mine, a routine well licence application can be filed as long as the requirements of Sections 6.140 to 6.190 of the Oil and Gas Conservation Regulations will be met. If the proposed well will not meet these requirements or if the well is within 15 m of a coal mine shaft, a nonroutine application must be filed by answering No to question 1a in Step 11 of Schedule 4. |
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ENVIRONMENTAL REQUIREMENTS
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Question:
| Is there an EUB requirement to notify Alberta Environment (AENV) prior to submitting a well licence application with the EUB? |
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Answer:
| The EUB no longer monitors the notification process to AENV prior to filing a well licence application. However, prior to construction or preparation of a well lease site or well site access road on either Crown or Freehold land, it is the licensee's responsibility to meet all applicable AENV requirements.
The applicant is expected to meet all relevant requirements of provincial and federal legislation and regulation, see section 7.9.13 for details regarding EUB environmental requirements and references to provincial and federal legislation and regulations, including AENV Informational letters.
When submitting an E610, E620, or E621 pre-submission well licence application, the applicant must include the audit documents outlined in Table 7.6, item 7.10.11.2 on page 192 of Directive 056. This requires that the applicant submit documentation describing the steps that will be taken to ensure the protection of the environment and that all EUB requirements are met, as described in Section 7.9.13 Environmental Requirements. Failing to submit this or any required documentation along with the pre-submission application my delay the review of the application.
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TOP
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H
2
S RELEASE RATES
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Question:
| Should the terminating formation or 15 m overhole formation be included in the H
2
S release rate assessment? |
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Answer:
| The terminating horizon is the formation where the applicant intends to terminate the well and to which the applicant has the mineral rights. In addition, the applicant is required to evaluate any 15 m overhole zone being penetrated for the purpose of accommodating logging tools and if there is a potential to encounter H
2
S, then the applicant must incorporate this data into the potential H
2
S release rate assessment. |
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TOP
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Question:
| Is a geological discussion, mapping, and engineering discussion required for only the H
2
S bearing zones that the applicant intends to produce from the wellbore? |
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Answer:
| In order to develop a drilling, completion/servicing, and suspended/producing potential H
2
S release rate assessment, the applicant must review and assess the potential of all possible H
2
S bearing formations that may be encountered by the proposed well. The applicant must provide: a geological discussion that addresses the H
2
S potential of all prospective formations encountered by the well; geological maps for all prospective formations that will be noted on Schedule 4; and an engineering discussion for each potentially productive zone in the well that may contain H
2
S. For further details see Directive 056 sections 7.9.15.1, 7.9.15.2, and 7.9.15.3. |
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PREPARATORY WORK
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Question:
| If a company has obtained landowner approval, all applicable agreements are in place, the lease is surveyed, and an EUB well licence application is underway but not yet approved, can that company commence preparatory work regarding the well or well site? |
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Answer:
| Part 6, Section 11(1) of the Oil and Gas Conservation Act (OGCA) states that:
No person shall commence to drill a well or undertake any operations preparatory or incidental to the drilling of a well or continue any drilling operations, any producing operations or any injecting operations unless
(a) a licence has been issued and is in full force and effect, and
(b) the person is the licensee.
Section 11(1) prohibits any preparatory or incidental operations at a well site, on private or public lands, before a well licence is issued. However, Section 11(2) of the OGCA allows for surveying the proposed well site prior to issuance of a licence.
IL 2001-05 Construction of a Well Site Prior to the Issuance of Well Licence
provides further clarification on this matter.
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| Question: | We have preset surface casing in a well, but the main drilling rig has not been moved on hole to complete the drilling to the approved projected total depth. We intend to drill the well to total depth, but it is possible that a significant period of time may pass before we do and we are concerned about the well licence expiring. Do we need to inform the EUB? If so, how, and what information is required? |
| Answer: | Yes. Report a Drilling Activity Notification through the Digital Data Submission (DDS) system with the drilling activity type of “Drilling to Set Surface Casing Only.” Direct any questions regarding the entry of a Drilling Activity Notification to the FIS Administrator FIS.Administrator@eub.ca.
This notification indicates that the well licence has been acted on and will ensure that the well licence is not inadvertently cancelled due to expiry of the well licence. |
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| Question: | We have preset surface casing in a well and do not intend to move a rig on to drill to the approved projected total depth. Are we required to report this information to the EUB? If so, how, and what information is required? |
| Answer: | Yes. Report a Drilling Activity Notification through the Digital Data Submission (DDS) system with the drilling activity type of “Drilling to Set Surface Casing.” Direct any questions regarding the entry of a Drilling Activity Notification to the FIS Administrator at FIS.Administrator@eub.ca.
In addition to the Drilling Activity Notification, a licensee is required to report the summary of drilling operations in accordance with
Directive 059: Well Drilling and Completion Filing Requirements using the Well Records System (WRS)
upon completion of drilling to the final depth of the well. Direct any questions regarding the data entry of the summary details for the drilling operations in WRS to Well Data Services at WellDataServices@eub.ca. |
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DIRECTIVE 071: EMERGENCY PREPAREDNESS AND RESPONSE REQUIREMENTS FOR THE PETROLEUM INDUSTRY
(April 2008)
|
|
Question:
| What EPZ should I record on my
Directive 056
application schedule? |
| Answer: | For category C, D, and E applications submitted after April 8, 2008, you are required to record the EPZ determined by the April 2008 edition of
Directive 071
unless the proposed project is exempt for reasons set out in Attachment A, Section 2 of
Bulletin 2008-15
.
If exempt, you are required to record the EPZ determined by the 2005 edition of
Directive 071
and to attach a description of the
Directive 071
exemption that is applicable to your application. |
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Question:
|
How does the April 2008 edition of
Directive 071
affect my
Directive 056
participant involvement program for applications submitted after April 8, 2008?
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| Answer: | Section 2.2.2 of
Directive 056
requires applicants to include in their project-specific information package the participants’ location relative to the EPZ. In the case of category C, D, and E wells, applicants are also required to personally consult with and obtain confirmation of nonobjection from residents within the EPZ (Table 7.1 of
Directive 056
).
If exempt
for reasons set out in Attachment A, Section 2 of
Bulletin 2008-15
, there should be no impact to your
Directive 056
participant involvement program.
If not exempt:
- 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.
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SURVEY PLANS
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| Question: | I am planning to submit a new well licence application that will include a survey plan based on remotely sensed data (i.e., LiDAR). Will the ERCB accept my application if the information on my survey plan is based on remotely sensed survey data? |
| Answer: | LiDAR (Light Detection and Ranging) is a form of remotely sensed, 3-dimensional survey data that provides an accurate representation of the Earth’s surface. It is a type of aircraft-based remote sensing, using laser-driven pulses of light and multispectral cameras to scan and process digital information about a landscape. This acquired data can allow for the preparation of a survey plan for well licence application purposes.
The ERCB will accept well licence applications where survey plans are based on remotely sensed, 3-dimensional survey data like LiDAR only if the survey plan clearly identifies that the data the survey is based on was acquired from remotely sensed data. Applicants must still ensure that the plan is prepared in accordance with the
Alberta Land Surveyors’ Manual of Standard Practice
and meets all applicable
Oil and Gas Conservation Regulations
(Section 2.020) and Directive 056 (Section 7.10.1) requirements.
In addition, upon the proposed surface lease being surveyed or staked for construction, the applicant must complete a final survey plan that is prepared by a certified Alberta land surveyor within 60 days of the start of construction. This final survey plan must be retained on file by the applicant for ERCB audit purposes.
Applicants are reminded that the staking or marking of boundaries for well sites, pipeline rights-of-way, and other oil- and gas-related surface facilities must be performed by a certified Alberta land surveyor.
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Page Last Updated: May 22, 2009 |
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