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From time to time, the Board reviews crude oil pools in the province that are subject to rate controls to identify potential candidates for good production practice (GPP). In this particular assessment the Board focused on those pools or parts of pools undergoing pressure maintenance operations and single well (primary depletion) pools that are incapable of producing their penalized MRL. The pressure maintenance schemes/projects proposed for GPP are listed on Attachment 1 and the single well (primary depletion) pools are listed on Attachment 2. Assigning GPP to these pools will simplify administration and may provide increased production flexibility to some pressure maintenance schemes.
The Board reviewed all pressure maintenance schemes to identify potential GPP candidates. The schemes were reviewed to confirm that the terms and conditions of the pressure maintenance approval are adequately being met, and to confirm that general performance is satisfactory. In particular the Board attempted to ensure that
The Board proposes to place the 117 schemes listed in Attachment 1 on GPP. The Board expects that each scheme will continue to be operated in a prudent manner, using good engineering principles and in accordance with the Board-approved depletion plan. In cases where a scheme or part of a scheme is not being operated in a satisfactory manner, the Board will take the appropriate action where necessary. For example, non-compliance with voidage replacement requirements on a scheme, pattern, or regional basis may result in the assignment of an MRL commensurate with the ability to replace voidage. The Board appreciates that it may be necessary to revise operational strategies and when this occurs, operators are advised to ensure that their pressure maintenance approval is amended to reflect any significant operational changes.
The Board emphasizes that both progress report submission and reservoir pressure testing requirements do not change as a result of these schemes being placed on GPP. Further, any outstanding requests from the Board, dealing with scheme operation/depletion, must continue to be addressed.
The Board reviewed single well (primary depletion) pools that are incapable of producing their penalized MRL. Those pools for which a rate control is not considered necessary and where there are no outstanding gas conservation issues, have been identified as GPP candidates. As a result of this review, the Board proposes to place the 922 pools listed in Attachment 2 on GPP for administrative reasons.
The Board periodically reviews the appropriateness of GPP and may rescind GPP where conditions change such that oil and gas conservation are compromised. This would include situations where gas flaring and pressure maintenance feasibility become issues. Further, the appropriateness of GPP may also be reconsidered where concurrent depletion of an associated gas cap occurs without an order of the Board. The Board also advises operators within a given pool to monitor overall operations. Any obvious conservation or equity related problems should be resolved as soon as possible or brought to the Board's attention.
Operators are also reminded that normal spacing regulations apply to wells in GPP pools. Should an affected party raise a valid issue related to an off-target well in a GPP pool, the Board may rescind GPP or assign an MRL to the well against which to apply the off-target penalty factor.
Operators may apply, pursuant to Informational Letter IL 90-3, for GPP status or revisions to rate controls for any pool, but must address the matters of conservation and equity.
The Board proposes to place the pools listed in Attachments 1 and 2 on GPP status commencing 1 August 1991. Operators are asked to consider the impact this proposal may have on their operations and advise the Board in writing no later than 5 July 1991 of specific objections or concerns.
Questions regarding this letter can be directed to the Board's Oil Department at 297-8570.
<original signed by>
N. G. Berndtsson, P.Eng.
Manager, Oil Department