Bulletin 2016-03: Invitation for Feedback on Amendments to Directive 013: Suspension Requirements for Wells
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Invitation for Feedback on Amendments to Directive 013: Suspension Requirements for Wells
Mar 01, 2016
The Alberta Energy Regulator (AER) is inviting stakeholder feedback on specific changes to Directive 013: Suspension Requirements for Wells (Directive 013). The purpose of Directive 013 is to ensure the long-term integrity of a well and to mitigate risk to public safety and the environment.
Suspension is a step in the life-cycle management of wells that comes before abandonment and reclamation certification. A suspended well can be reactivated (put back into production/injection) or moved into the next life-cycle phase (abandonment). The Directive 013 changes are expected to improve resource recovery and promote regulatory compliance without compromising effective regulation of inactive well integrity.
The scope of the proposed revisions to Directive 013 is limited to the following items:
- The method by which compliance deadlines are calculated in section 2.1 would be changed to provide more efficient and integrated regional approaches to managing inactive wells:
- Suspension deadline—the suspension deadline date is to be 12 months after the inactive status date.
- Inspection deadline—the deadline for inspections will be calculated based on the inspection due date in the AER’s Digital Data Submission System (DDS). All inspection deadlines will be moved from a specific date to the end of that calendar year. For example, an inspection deadline date of July 13, 2016, would be moved to December 31, 2016.
- The requirements for changing a high-risk well to medium or low risk are to be included in section 2.2 to clarify an existing process.
- For inactive cavern wells, the licensee would submit a nonroutine application to the AER for the suspension of the well and cavern (section 3.2).
- Suspension requirements would be amended to provide consistency between well risk types and to align with AER Directive 020: Well Abandonment requirements:
- Nonsaline water or inhibited (noncorrosive) fluid is to be used in the wellbore, and the top two metres of the wellbore must be filled with a nonfreezing fluid (sections 3.1.1, 3.2.1, and 3.3.1).
- Pressure testing of low-risk type 1 wells is not required for the purpose of initial suspension nor at the time of ongoing inspections (section 3.1.1).
- Changes in reactivation criteria are provided in section 4 to align with operational practices for low productivity producing wells and for intermittently used injection wells.
- For a well to attain active status and to be reactivated on DDS, it would report volumetric activity for at least one hour per month for three consecutive months.
- Pressure testing of casing and tubing for the reactivation of a well would not be required if the initial well suspension was completed less than 12 months ago.
- The inactive well licence list would be available to all stakeholders on the Directive 013 page of the AER website. It would include all the inactive wells in accordance with Directive 013, and it is automatically updated daily.
- Unclear or conflicting definitions to be clarified:
- The critical sour well definition from Directive 056: Energy Development Applications and Schedules is used (section 1.2).
- The H2S-level discrepancy between low- and medium-risk well definitions (section 3.1) would be eliminated.
- It was clarified that “noncritical sour cased wells” means “cased-hole wells that are not critical sour” for low-risk wells (section 3.1).
- All low-risk wells inactive for more than 10 years are to be moved to the medium-risk well category (section 3.2).
- This revision of Directive 013 does not include any other changes. Broader policy matters, including timely abandonment of suspended wells, are not in the scope of this project. Please confine any comments to the specific bulleted items above.
The draft directive is available for review on the Directive 013 page of the AER website under Rules & Directives > Directives (http://www.aer.ca/rules-and-regulations/directives/directive-013). Paper copies of the draft directive can be purchased from AER Information Services, Suite 1000, 250 – 5 Street SW; telephone: 403-297-8311; fax: 403-297-7040; e-mail: firstname.lastname@example.org.
To provide the AER with feedback on the draft directive, complete the comment form available on the Directive 013 page of the AER website. Send the form and any questions about the proposed directive changes by e-mail to email@example.com. Feedback will be accepted until March 31, 2016.
All feedback related to the specific in-scope changes noted in this bulletin will be reviewed and used for finalizing the directive sections mentioned above. All comments provided through this consultation will form part of the public record, and any comment received will be attributed to the specific individual providing it. Personal information provided with comments will be collected, used, and disclosed in accordance with the Freedom of Information and Protection of Privacy Act. The AER may use the personal contact information you provide for follow-up communication related to your feedback.
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Executive Vice President