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Note: References to Information Letter (IL) 99-4 EUB Enforcement Process, Generic Enforcement Ladder, and Field Surveillance Enforcement Ladder on page 1 and in Sections 1.5 Enforcement and 2.6 Enforcement, have been replaced by Directive 019 EUB Compliance Assurance-Enforcement (Latest release: February 20, 2007).
The Alberta Energy and Utilities Board (EUB) has streamlined and consolidated the reporting processes for isolation packer test results, surface casing vent flows (SCVFs), gas migration (GM), and casing failure, as detailed in this interim directive (ID).
This ID replaces the following documents, which are rescinded:
This ID provides details on the following changes:
1 ISOLATION PACKER TESTING, REPORTING, AND REPAIR REQUIREMENTS
1.1 Regulation
Section 6.120 of the Oil and Gas Conservation Regulations requires all injected fluids, other than potable water, to be isolated from the production casing above the production packer. Section 7.050 requires the production casing in a well producing sour gas with a concentration greater than 50 moles per kilomole to be similarly protected, unless the well is produced by artificial lift.
1.2 Testing and Repair Requirements
The EUB requires the licensee
1) to conduct packer isolation tests annually, and
2) to have the test results certified as conclusively proving hydraulic isolation by personnel qualified, through training and experience, to make such interpretations.
When packer isolation tests do not prove hydraulic isolation, the licensee must complete necessary remedial work and retest for packer isolation. The licensee must begin repair planning immediately and repair, retest, and report the repair results to the EUB within 90 days of failure detection. A licensee may submit to the EUB Well Operations Section a request for an extension to the repair deadline, if exceptional circumstances exist.
1.3 Reporting Requirements
Licensees must submit isolation packer test results using the DDS Packer Test Reporting application by September 1 of each year. The new DDS Packer Test Reporting application will now list all wells that the EUB believes require isolation packer tests performed on them. (Previously, licensees were not provided with an initial list of wells to test.) If a well that should be tested is not listed, licensees must perform the test as required by regulations and report the test results using the DDS system. If a well is listed that does not appear to require testing, the licensee should contact the EUB Well Operations Section to request that the well be removed from the list.
Note that if as a result of packer testing, a casing failure is discovered, the casing failure must be reported separately.
1.4 Records Retention
The licensee must keep all packer isolation testing and repair information on file for the life of the well plus two years. The EUB will use an audit system to confirm licensees' compliance and to help measure the effectiveness of the packer test reporting process. Upon written notification that the well has been selected for audit, the licensee must submit the required information within 20 days.
1.5 Enforcement
In accordance with IL 99-4, the following enforcement ladder applies to noncompliance related to isolation packer testing.
Level of Enforcement and Examples of Noncompliance
Minor Level 1
Major Level 2
Major Level 3
1.6 Recommended Test Procedures
The EUB has developed recommended test procedures to provide guidance for evaluation of the test results. Licensees should design a test procedure that best suits their specific well situation and will provide an accurate evaluation of the hydraulic isolation of the tubing/casing annulus. In all cases, the person who will certify the test results should review the test procedure prior to conducting the test to ensure that the test method is adequate to prove hydraulic isolation. Variations to the recommended test procedure should be clearly identified and retained on file with the test results.
In general, the EUB will accept, as a maximum, a 3 per cent pressure decline over a 10-minute interval as a successful packer isolation test. However, factors such as annular fluid capacity and the mode of operation should be considered when designing the test and evaluating the test data. Prior to beginning the test, the following information should be measured and recorded:
CASE 1-Casing pressure greater than 1400 kilopascals (kPa) prior to bleed down
CASE 2-Casing pressure less than 1400 kPa prior to bleed down
CASE 3-No initial casing pressure
2 SURFACE CASING VENT FLOW (SCVF)/GAS MIGRATION (GM) TESTING, REPORTING, AND REPAIR REQUIREMENTS
2.1 Regulation
Section 6.100 of the Oil and Gas Conservation Regulations specifies that the annulus between the second casing string and the surface casing of a well completed to produce oil or gas or to inject any fluid must be left open to atmosphere and describes the equipment and minimum working pressure required. The licensee must test the surface casing for a vent flow or gas migration in the manner set out below. If a surface casing vent flow or gas migration problem is detected, the licensee must report and repair it as set out below.
2.2 Definitions
Surface Casing Vent Flow (SCVF) is the flow of gas and/or liquid or any combination out of the surface casing/casing annulus (often referred to as internal migration).
A SCVF is serious if there is a
Note that a SCVF where any usable water zone is not covered by cement may be considered nonserious if
If a producing domestic or agricultural water well from an unprotected aquifer is subsequently established within the 1 km radius, the licensee of a well that has previously been considered to have a nonserious SCVF must complete the reporting and repair requirements outlined in Sections 2.3 and 2.4 of this interim directive.
An SCVF is nonserious if it has not been classified as a serious vent flow.
Gas Migration (GM) is a flow of gas that is detectable at surface outside of the outermost casing string (often referred to as external migration or seepage). A GM is serious if there is a fire or public safety hazard or off-lease environmental damage, such as groundwater contamination. A GM is nonserious if it has not been classified as serious migration.
2.3 Testing and Reporting Requirements
2.3.1 Testing for SCVF
Within 90 days of drilling rig release, licensees must test new wells for a vent flow. Within 30 days of initial detection of an SCVF problem at a well, the EUB must be notified via the DDS SCVF/GM system. After reporting a nonserious SCVF, the licensee must perform an SCVF test on the well on an annual basis for the next five years, measuring the flow and stabilized pressure buildup to detect possible change. Annual test results do not need to be reported. If there is no change in the flow and pressure after five years of testing, or if the vent flow dies out, no further testing is required. However, if a nonserious vent flow becomes serious, the licensee must notify the EUB by DDS within 30 days of the test. Licensees must check all wells for a vent flow prior to abandonment.
2.3.2 Testing for GM
Within 90 days of drilling rig release, licensees must test new wells for GM problems in Townships 45-52, Ranges 1-9, West of the 4th Meridian, and Townships 53-62, Ranges 4-17, West of the 4th Meridian. If a GM problem is detected, the licensee must notify the EUB by DDS within 30 days. While GM testing will only be enforced in the problem regions specified, the EUB recommends that industry check all wells for GM at the time of abandonment.
If as a result of testing for vent flow or gas migration, a casing failure is discovered, the casing failure must be reported separately.
If a flow is detected after completing the initial test, the licensee must report the incident using the DDS SCVF/GM application. EUB Guide 20: Well Abandonment Guide outlines SCVF/GM testing procedures.
2.4 Repair Requirements
The licensee of a well determined to have a serious SCVF/GM problem as defined above must repair the problem as soon as possible and not later than 90 days from discovery. If the licensee plans to request a deferral of repair as outlined in Section 2.4.3, the request must be received by the EUB Well Operations Section within 90 days from the failure date.
Nonserious SCVF/GM problems must be addressed at the time of well abandonment. Should a nonserious SCVF/GM problem escalate to the serious category, the licensee must conduct repairs within 90 days of determining the change in category. A licensee may submit to the EUB Well Operations Section a request for an extension to the repair deadline, if exceptional circumstances exist. Once an SCVF or GM repair has been attempted, regardless of the repair result, the licensee must notify the EUB Well Operations Section.
2.4.1 Option 1-Routine Repair Program (EUB approval not required)
The EUB does not require industry to submit proposed repair programs for routine SCVF/GM repairs, provided that all of the following conditions are incorporated and followed in the repair program:
2.4.2 Option 2-Nonroutine Repair Program (EUB approval required)
If the licensee designs a repair program that deviates from the criteria outlined in Option 1 or if the initial attempt was unsuccessful in eliminating the flow, a repair program must be submitted to the EUB Well Operations Section for approval prior to implementation. The program must include all of the following:
2.4.3 Option 3-Deferral of Repair (EUB approval required)
There are two ways to defer repair of a serious vent flow: produce the vent flow and/or cap the well with pressure remaining on the annulus. Approval to defer repairs on serious vent flows must be received before work begins.
a) SCVF Production
The licensee must submit an application to the EUB Well Operations Section to produce any serious vent flow. An application is not required to produce a nonserious vent flow. The application must show the following in detail:
The EUB will rescind the approval to produce if the licensee fails to comply with any of the above conditions and will require that the SCVF be repaired immediately.
b) Capping with Pressure
The objective of any abandonment is to cap the well without pressure remaining on the casing annulus. The EUB will consider an application to cap a well with pressure only after the licensee has made serious attempts to completely eliminate any vent flow. The EUB Well Operations Section will review all applications to ensure that the licensee has considered every option to eliminate the problem. An application to cap a well with pressure must meet the requirements listed in Guide 20: Well Abandonment Guide.
2.5 Records Retention
The licensee must keep all SCVF/GM testing and repair information on file for the life of the well plus two years. The EUB will use an audit system to confirm licensees' compliance and to help measure the effectiveness of the SCVF/GM regulatory process. Upon written notification that the well has been selected for audit, the licensee must submit the required information within 20 days.
2.6 Enforcement
In accordance with IL 99-4, the following enforcement ladder applies to noncompliance related to SCVF/GM.
Level of Enforcement and Examples of Noncompliance
Minor Level 1
Major Level 2
Major Level 3
3 CASING FAILURE REPORTING AND REPAIR REQUIREMENTS
3.1 Regulation
The Oil and Gas Conservation Regulations, Section 12.141, requires that the licensee of a well notify the EUB immediately on detection of a casing leak or failure and, if requested by a representative of the EUB, provide a report assessing the leak or failure, including a discussion of the cause, duration, damages, proposed remedial program, and measures to prevent future failures.
3.2 Definition
A casing leak or failure is any loss of casing integrity, including casing damage that results in suspension of operations or in abandonment of the well.
3.3 Reporting and Repair Requirements
The licensee of the well must report a casing failure incident within 30 days of initial detection using the DDS Casing Failure application. The licensee must begin repair planning immediately and perform remedial action within 90 days of the reporting date. A licensee may submit to the EUB Well Operations Section a request for an extension to the repair deadline, if exceptional circumstances exist. Once a casing failure repair has been attempted, regardless of the repair result, the licensee must notify the EUB Well Operations Section.
3.4 Records Retention
The licensee must keep all casing failure testing and repair information on file for the life of the well plus two years. The EUB will use an audit system to confirm licensees' compliance and to help measure the effectiveness of the casing failure regulatory process. Upon written notification that the well has been selected for audit, the licensee must submit the required information within 20 days.
3.5 Enforcement
In accordance with IL 99-4, the following enforcement ladder applies to noncompliance related to casing failures.
Level of Enforcement Example of Noncompliance
Minor Level 1
Major Level 2
Major Level 3
<original signed by>
J. R. Nichol, P.Eng.
Board Member