Bulletin 2011-22

Bulletin 2011-22: Revised Edition of Directive 044: Requirements for Surveillance, Sampling, and Analysis of Water Production in Hydrocarbon Wells Completed Above the Base of Groundwater Protection

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Revised Edition of Directive 044: Requirements for Surveillance, Sampling, and Analysis of Water Production in Hydrocarbon Wells Completed Above the Base of Groundwater Protection

Jul 14, 2011

The Energy Resources Conservation Board (ERCB) is releasing a revised edition of Directive 044: Requirements for Surveillance, Sampling, and Analysis of Water Production in Hydrocarbon Wells Completed Above the Base of Groundwater Protection (BGWP). This initiative is consistent with the ERCB’s commitment to improve its regulatory processes.

The revised Directive 044 includes the following key changes:

  • The title is now Directive 044: Requirements for Surveillance, Sampling, and Analysis of Water Production in Hydrocarbon Wells Completed Above the Base of Groundwater Protection (BGWP).
  • The trigger for when monthly water production must be reported for hydrocarbon wells with completions above the BGWP has been increased to 30 cubic metres per month (m3/month) from the previous limit of 5 m3/month.
  • To avoid retesting hydrogeological units in areas where data has already been collected, the ERCB will on a case-by-case basis identify completed intervals that require testing, This replaces the current requirement to test every well that exceeds the prescribed trigger volume and that is completed above the BGWP.
  • To avoid multiple testing in the same hydrogeological unit within the well, the ERCB will on a case-by-case basis identify completed intervals that require segregated testing. This replaces the current requirement of segregated testing of completed intervals more than 2 m apart.
  • Downhole camera surveys have been added as an acceptable method to demonstrate lack of water production or to confirm that most of the produced water is from the aquifers below the BGWP.
  • Production accounting errors that trigger a Directive 044 review will now require a 24-hour in-line production test at the wellhead of the subject well to confirm water production volumes.
  • How to calculate the concentration of total dissolved solids (TDS) has been clarified.

These changes considered the ERCB’s analysis of data collected to date under Directive 044. The analysis determined that

  1. hydrocarbon wells producing more than 30 m3/month of water from wells completed above the BGWP present a potentially higher risk to the quantity and quality of groundwater than are presented by wells producing smaller volumes of water (less than 30 m3/month);
  2. the surveillance process requires revisions to ensure that resources are directed at identifying wells that produce larger volumes of non-saline water; and
  3. a detailed case-specific hydrogeological assessment of the sampling and mitigation requirements is, compared with indiscriminate sampling, more protective of the shallow groundwater resources.

The requirement that a hydrocarbon well that produced water and is completed above the BGWP must not be shut in unless approved by the ERCB is not affected by this revision.

This revised Directive 044 considers stakeholder feedback received during the ERCB’s consultation on the directive’s requirements. Stakeholder feedback and the ERCB’s responses are available to view at www.ercb.ca.

The revised edition of Directive 044 is available on the ERCB Web site www.ercb.ca and from ERCB Information Services, Suite 1000, 250 – 5 Street SW, Calgary, Alberta; telephone: 403-297-8311 or 1-855-297-7040 (toll free); fax: 403-297-7040; email: infoservices@ercb.ca.

<original signed by>

Kevin Parks, P.Geol., Ph.D
Executive Manager
Geology, Environmental Science, and Economics Branch