9| Well Activity: Completions, Maintenance and Abandonment

9. Well Completions, Maintenance and Abandonment

Please Note:
This manual is written as a whole and provided to industry in sections to allow permit holders to access activity
chapters. It is prudent of the permit holder to review the manual in its entirety and be aware of the content in other
sections of the manual.

9.1 Well Equipment

Equipment must adhere to the regulatory requirements.

9.1.1 Wellheads

Wellheads are required to operate safely under the conditions anticipated during
the life of the well and the wellhead is not to be subjected to excessive force.
Review the ESC’s IRP Volume#5: Minimum Wellhead Requirements for more
information.

9.1.2 Tubing

Tubing is required for the production of gas containing greater than or equal to
five per cent H2S and for all injection and disposal except for the injection of fresh
water. This excludes initial completions and/or hydraulic fracturing.

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9.1.3 Packers

A production packer must be used for:

 All injection and disposal except for the injection of fresh water.
 Wells not on artificial lift, containing gas with greater than five per cent
H2S, or if a numbered highway or populated area is located within the
emergency planning zone for the well.
“populated area” means a dwelling, school, picnic ground or other place
of public concourse.
To facilitate future abandonments, packers are required to be set in the
zone of interest or as close as reasonably possible to perforations.

Annual packer isolation testing is required for all regulated packer installations.
The report is to be submitted to the OGC within 30 days of the test. If a packer
test fails, the permit holder must complete the repairs without unreasonable
delay.

Operators of disposal wells, injection wells and sour gas production wells should
adhere to the requirements under the Drilling and Production Regulation Section
16(2) and Section 39(6):
 Set a production packer in the well as near as is practical above the
injection interval or production formation, and fill the space between
tubing and casing with corrosion and frost inhibiting fluid. This prevents
production or injection fluids from contacting and potentially
compromising the integrity of the well casing.

The Commission has defined a preferred PIT procedure, outlined in Appendix D

of the Water Service Well Summary Information document. This procedure is
based on the Alberta Energy Regulator’s (AER) Interim Directive ID 2003-01,
altered to provide a robust and consistent procedure delivering comparable
results, and eliminating the need to choose a case method dependent on casing
pressure upon arrival. PIT results are continually reviewed by the Commission
and the testing procedure may be modified in the future if warranted.

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9.1.4 Subsurface Safety Valves

In accordance with Section 39 (6) of the Drilling and Production Regulation,

subsurface safety valves may be required in cases where the H2S content of the
gas exceeds 5%, or where a populated area or numbered highway is located
within the emergency planning zone.

In the above cases, a subsurface safety valve is required if:

a) The calculated AOF, under current conditions, is greater than 30 E3m3/d,
and
b) The well is located within 800m of a populated area, or within 8km of a city,
town or village

Unless specified otherwise in an Order approving an acid gas disposal well,

subsurface safety valves are required for all acid gas disposal wells.

As per section 16(1)(a) of the Drilling and Production Regulation, function testing
of the subsurface safety valve is to be done in accordance with the
manufacturer’s recommendation, or sound engineering practices. Function
testing, maintenance and inspection requirements may also be specified in an
Order approving a well for use as an acid gas disposal well. Guidance on
acceptable leak rates can be found in the American Petroleum Institute’s (API)
RP 14B: Design, Installation, Repair and Operation of Subsurface Safety Valve
Systems errata document.

In general, the distance from a city, town or village should be measured from the
corporate limits. In cases where the corporate limits do not reasonably
correspond with the boundaries of the community, the permit holder may take a
functional approach such as delineation of the extent of developed areas.

9.1.5 Oil Wells

Oil wells completed after October 4, 2010 equipped with an artificial lift, if the H2S
content of the gas exceeds 100 ppm, must install the following:

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 If a pumpjack is the method of artificial lift:

 install on the stuffing box a device that will seal off the well in the
event of a polish rod failure, and
 Automatic shutdown on the stuffing box that will shut down the
pumping unit in the event of a stuffing box or polish rod failure.
 Automatic vibration shutdown system.

 If a pumpjack is not used as an artificial lift, maintain a system that will

shut down the artificial lift if a leak is detected.

9.1.6 Fencing

Permit holders of completed wells that:

 Are located within 800 metres of a populated area.
 Have a populated area within the emergency planning zone of the wells.

Fencing or other suitable measure to prevent unauthorized access to the well

must be installed. An exemption can be requested if the intent of section 39 of
the Drilling and Production Regulation is met or exceeded. For wells that are
located on private land, the method of access control should be developed in
consultation with the landowner.

9.2 Well Servicing Operations

9.2.1 Notice of Operations

A Notice of Operation (NOO) must be submitted for all work being performed on a
well. This includes initial completions, completions workovers, abandonments and
maintenance. The complete list can be found in the Commission’s Notice of
Operations and Completion / Workover Report Reference Guide. The NOO is to be
submitted electronically through the eSubmission portal on the Commission’s website.

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The Notice of Operations submission requires the well authorization number and is
submitted using eSubmission portal within at least 24 hours prior to the start of
completion operations. Notice of Operations submitted at least 7 days prior to the
start of abandonment operations.
If an activity at a well is expected to result in gas being flared, a Notice of Flare must be
submitted using the eSubmission Portal. This Notice may be submitted in conjunction with
a Notice of Operation if a well operation is taking place, or as a standalone submission.

To report actual flare volumes, ensure all volumes flared at a well are included in
production reporting via Petrinex.

Please Note:
Shallow Fracturing operations at a depth of 600 metres or less must be approved in the
well permit. Refer to the Commission’s Oil and Gas Activity Application Manual for more
information.

9.2.2 Inter-wellbore Communication

Subject well permit holders (the well undergoing hydraulic fracture stimulation) are
obligated to manage the risks of inter-wellbore communication between the subject
well and an offset well. The subject well permit holder must have a documented
hydraulic fracturing program that includes the following elements:
 Identify all offset wells that could be affected.
 Conduct a risk assessment of the identified offset wells.
 Develop a well control plan for all offset wells that are at risk.
 Modify the hydraulic fracturing program if risks cannot be mitigated.

The subject well permit holder must notify the permit holder of an at-risk offset well of
its planned hydraulic fracturing program and make all reasonable efforts to develop a
mutually-agreeable well control plan. The subject well permit holder must maintain a
copy of the at-risk well control plan for the duration of hydraulic fracturing operations.

The permit holder of an at-risk offset well, upon receiving notification of a planned
hydraulic fracturing program, is expected to engage and work cooperatively with the
subject well permit holder in development of well control plans.

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During the design and execution of the fracturing program, the subject well permit
holder must ensure the fracture will not extend into any unintended formations. Any
communications with unintended formations are in conflict Section 22 of the Drilling
and Production Regulation.

All fracture communication “incidents” must be reported in accordance with the

Commission’s Incident Reporting Instructions and Guidelines. An incident means the
communication resulted in a spill, equipment overpressure, equipment damage, injury
or drilling kick. For inter-wellbore communications, a kick is defined as a pit gain of
three cubic metres or greater, or a casing pressure of 85 per cent of the Maximum
Allowable Casing Pressure (MACP).

Communication events should be reported even if contact did not reach the defined
“incident” level. A database of all communication events will further the understanding
of the resource and assist in the development of effective technology.

Permit holders are requested to report all fracture communication events using the
Inter-Wellbore Communication Report Form. Permit holders are also expected to
follow the ESC’s Industry Recommended Practice 24 for specific methodology and
procedures regarding the inter-wellbore communication management process.

9.2.3 Multi-zone or Commingled Wells

Refer to Section 23 of the Drilling and Production Regulation.

All zones in a well must remain segregated unless permission has been granted for
commingled production. Permission may be granted in an individual well permit or by
a special project for commingling under Section 75 of OGAA.

For information and guidelines in regards to commingling, including forms and

requirements, refer to the Commingling section within the Reservoir Engineering
documentation page on the Commission’s web site.

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The Notification of Commingled Well Production form must be submitted to the

Commission within 30 days of the commencement of commingled production.

9.3 Well Suspension

Activity means:
 Production, injection or disposal of fluids.
 Drilling, completion or workover operations.
Inactive well means a well that has not been abandoned but:
 Has not been active for 12 consecutive months.
 If the well is classified as a special sour or an acid gas disposal and has not been
active for six consecutive months.
For active production, injection and disposal wells, the date of the last activity is defined as the
first day of the month following the last month for which production, injection and disposal
volumes were reported.

Observation wells are deemed to be active (see section 9.3.1 of this manual).

Well Suspension Activity Dates

 For active production, injection and disposal wells, the date of last activity is defined
as the first day of the month following the last month for which production, injection
and disposal volumes were reported.
 For drilling activity, including new wells and re-entries, the date of last activity is
defined as the rig release date.
 For completion and workover activity, the date of last activity is defined as the
completion date.

A permit holder may apply to the Commission to declassify a special sour well. The context
here is that as production rates fall, the H2S release rate may fall such that the well no longer
should be classified as a special sour well.

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9.3.1 Observation Wells

The Drilling and Production Regulation defines that a well or a portion of a well
may be designated as an observation well under Section 2(7). Reservoir
observation wells typically gather data on:
 Formation pressure, fluid quality or fluid migration related to production,
injection or disposal.
 Monitoring well completion operations (microseismic) or seismicity
observation.

For use of either a purpose-drilled well, or conversion of an existing production or

injection well to observation type, an application and approval is required from the
Reservoir Engineering Department of the Commission. An observation well
designation under Section 2(7) contains conditions for monitoring, data collection
and reporting to maintain a valid designation. After issuing approval, the
Commission will update the well status to reflect the observation well designation.

A well permit holder must ensure that the static bottom hole pressure of each
observation well is measured at least once per calendar year, unless stated
otherwise in the approval. All static bottom hole pressure measurements and
resulting shut-in time must be reported to the Commission.

Observation wells are treated as active and do not require suspension unless
observation designation is withdrawn:
 Observation well designation may be withdrawn if approval conditions
are not met.

9.3.2 Suspension Requirements

All wells must be suspended within 60 days of attaining inactive status in a

manner that ensures the ongoing integrity of the well.

Any well may be suspended to a higher standard than the minimum requirements
described in Tables 9A to 9D. Reporting requirements are described in Section
9.5.1.
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Permit holders may apply to the Commission Drilling and Production department
for an extension of a deadline.

The following tables describe the Commission’s minimum requirements for each
category.

Table 9A: General Requirements for All Inactive Wells

Annual inspections include the requirements from the following sections:

 Visual Inspection
Annual Inspection  Wellhead maintenance
 Surface casing vent flow (if applicable)
 Lease maintenance
Unperforated wells may use a welded steel plate atop the production
casing stub. The plate must provide access to the wellbore for pressure
measurement. All other wells must use standard wellheads as described
Wellheads
in Energy Safe Canada (ESC)’s IRP Volume #2 (Completing and
Servicing Critical Sour Wells) and IRP Volume #5 (Minimum Wellhead
Requirements).
There shall be no wellhead leaks.
Pressure recording must be taken from all annuli and production conduit.
Bullplugs or blind flanges with needle valves must be installed on all
outlets except the surface casing vent.
The surface casing vent valve must be open and the surface casing vent
Wellhead unobstructed unless otherwise exempted by an official.
Maintenance All valves must be chained and locked or valve handles must be removed.
The flowline must be disconnected or isolated from the wellhead. Isolation
does not include a valve.
Polish rod removal is not required to suspend low risk oil wells as long as
the polish rod remains connected to the pump jack.

Pressure testing Low Risk and Medium Risk wells, do not require seals to be pressure
seals tested if integrity can be proven. Criteria for proving integrity are:

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 The well does not have a Surface Casing Vent Flow

OR
 If a positive pressure test is achieved on the casing string of
which the seals are isolating
AND
 There is no evidence of failed seals based on the pressure in the
intermediate casing string (if applicable)
Must indicate the method of confirming seal integrity on suspension report.
For wellheads that do not have adequate test ports, pressure tests may be
omitted and visual observation for leaks is acceptable. An explanatory
note must be included on the well suspension report.
High risk wells must pressure test the seals.
Surface casing vent flows and gas migration occurrences are to be
Surface Casing
managed and reported in accordance with Commission requirements. See
Vent Flows and
Sections 9.7.3 through 9.7.5 (surface casing vent flow) and 9.7.6 (gas
Gas Migration
migration) of this manual for more information.
A sign stating the well’s surface location, current permit holder, the current
permit holder’s emergency contact number and appropriate warning
symbols as defined in Section 15 of the Drilling and Production Regulation
must be in place.

Lease Maintenance An area of 10 metres radius around the wellhead must be maintained to
prevent brush from growing and causing a fire hazard.
Noxious weeds must be controlled.
Hazards associated with, but not limited to, pits, rat hole and storage
materials, must be limited.
A visual inspection of the lease and wellhead must be conducted at least
yearly to observe for wellhead integrity, noxious weeds and other hazards.
Visual Inspection
For wells with helicopter access (limited year-round access), the visual
inspection frequency is the pressure testing / monitoring frequency.
Update the status of the well event in Petrinex.

Reporting If the suspension of a wellbore requires a subsurface well operation, then

a Notice of Operations and Completion/Workover report must be
submitted as per section 9.2.1 and 9.8.1 of this Manual.

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A Well Suspension/Inspection report must be submitted via eSubmission

within 30 days of the suspension of the wellbore.
All pressure test reports must be submitted through the eSubmission
portal. For information regarding pressure testing frequency, please refer
to Tables 9B, 9C and 9D.
When submitting a suspended well pressure test report, the annual
suspended well inspection for that year must also be submitted through
the eSubmission portal.
If all zones in a non-special sour well are abandoned and the well has not
Downhole
yet been surface abandoned, the well shall be categorized as “Low Risk -
Abandoned
All cased wells (no perforations or open hole)”.
For classification criteria for special sour wells, see section 8.4.9 of this
manual.
For re-classification and other information see section 9.4 of this manual.
Special Sour and
Acid Gas Disposal Before suspension is considered, see Directive 20 Level-A requirements.
It is preferred to conduct a zonal abandonment rather than a suspension.
If a zone is deemed at capacity, the well should be abandoned.

Table 9B: Requirements Specific to Inactive High Risk Wells

Type 1: Special sour wells1.

Well Types
Type 2: Acid gas disposal wells.
Suspension Options Option A Option B
Downhole Bridge plug or packer and Bridge plug capped with 8 m lineal
Requirements tubing plug. of cement.
Pressure test both tubing and Pressure test the casing to 7 MPa
Pressure Testing / annulus to 7 MPa for 10 for 10 minutes.
Monitoring / Servicing minutes.
Service and pressure test wellhead
Requirements Service and pressure test sealing elements
wellhead sealing elements. (if applicable).

1If applicable, install a bridge plug or packer and tubing plug within 100 metres of the liner top on uncompleted special sour
wells. If this option is used, ensure the plug is placed within zone or 15 meters or perforations. This Commission encourages
Permit Holders to review AER Directive 20 prior to suspending a Level-A well.
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Pressure Testing /
At the time of suspension and At the time of suspension and then
Monitoring / Servicing
then annually. every 5 years.
Frequency
Wellbore must be filled with
Wellbore must be filled with non-
non-saline water or corrosion
saline water or corrosion inhibited
inhibited water. A minimum of
Wellbore Fluid water. A minimum of the top 2 m
the top 2 m must be freeze
must be freeze protected by the
protected by the use of a non-
use of a non-freezing fluid.
freezing fluid.

Table 9C: Requirements Specific to Inactive Medium Risk Wells

Type 1: Medium risk gas wells (see Appendix C for more information).
Type 2: Non-flowing oil wells ≥ 5% H2S.
Type 3: Flowing oil wells2.
Well Types Type 4: All injection and disposal wells except for acid gas disposal wells.
Type 6: Completed low risk wells that became inactive on or before 2009-05-30.
Type 7: All non-special sour cased wells that became inactive on or before 2009-
05-30.

Suspension Option C (type 7

Option A (All types) Option B (All types)
Options only)
Downhole /
Wellhead Packer and tubing plug. Bridge plug. N/A
Requirements
Pressure test the
Pressure Pressure test both the
Pressure test the casing casing to 7 MPa
Testing / tubing and annulus to 7
to 7 MPa for 10 minutes. for 10 minutes.
Monitoring / MPa for 10 minutes.
Servicing Service wellhead.
Service wellhead. Service wellhead.
Requirements

2Flowing oil wells are oil wells with sufficient reservoir pressure to sustain flow against atmospheric pressure without artificial lift.
The flowing product is a fluid.
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Pressure At the time of

Testing / At the time of suspension and
At the time of suspension
Monitoring / suspension and then then every 5
and then every 5 years.
Servicing every 3 years. years.
Frequency
Wellbore must be
filled with non-
Wellbore must be filled Wellbore must be filled saline water or
with non-saline water or with non-saline water or corrosion
corrosion inhibited corrosion inhibited water. inhibited water. A
Wellbore
water. A minimum of the A minimum of the top 2 m minimum of the
Fluid
top 2 m must be freeze must be freeze protected top 2 m must be
protected by the use of by the use of a non- freeze protected
a non-freezing fluid. freezing fluid. by the use of a
non-freezing
fluid.

Table 9D: Requirements Specific to Inactive Low Risk Wells

Type 1: All non-special sour cased wells (no perforations or open hole
sections).

Well Types Type 2: Low risk gas wells (see Appendix D of this manual).
Type 3: Water source wells.
Type 5: Non-flowing3 oil wells < 50 mol/kmol H2S.

Suspension Option A Option B

Options (Types 2,3 and 5 only) (Type 1 only)
Downhole
None. None.
Requirements

Pressure Testing / Read and record shut-in tubing

Pressure test casing to 7 MPa for
Monitoring / pressure (if applicable) and shut-
10 minutes.
Servicing in casing pressure.
Requirements Service wellhead.
Pressure test wellhead seals.

3
Non-flowing oil wells are oil wells without sufficient reservoir pressure to sustain flow against atmospheric pressure without
artificial lift. The flowing product is a fluid. Removal of polish rods is not required to suspend low-risk oil wells as long as the
polish rod remains connected to the pump jack.
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Service wellhead.

Pressure Testing / At the time of suspension and

Monitoring / then every 5 years. At the time of suspension and then
Servicing After 10 years of inactivity every 5 years.
Frequency annually.
Wellbore must be filled with non-
saline water or corrosion inhibited
Wellbore Fluid None. water. A minimum of the top 2 m
must be freeze protected by the
use of a non-freezing fluid.

9.3.3 Packer Testing

Wells requiring installation and yearly testing of a production packer are exempt
from the testing requirements if the well is suspended in accordance with the
Drilling and Production Regulation. Information on packer isolation testing
procedures is available in the Commission’s Water Service Wells Summary
Information document.

9.3.4 Long Term Inactive Wells

For information and requirements regarding long term inactive wells, refer to the
Dormancy and Shutdown Regulation and associated guidance.

9.3.5 Reactivating Suspended Wells

The following procedures should be followed for the reactivation of a suspended

well.
 All Wells:
 Inspect, service and pressure test the wellhead.
 Inspect and service control systems and lease facilities.
 Low Risk Type 1, Medium and High-Risk Wells:
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 Pressure test the casing to 7 MPa for 10 minutes

(if applicable). If the test fails, investigate and repair the problem.
 Pressure test the tubing (if present) to 7 MPa for 10 minutes. If
the test fails, investigate and repair the problem.

Reactivating Suspended Wells to Water Source Wells

Permit amendments are required for converting an existing suspended well into a
water source well. Specific requirements are described in the Commission’s
Supplementary Information for Water Source Wells document.

9.4 Suspended Well Reporting Requirements

9.4.1 Commission Reporting

Well Suspensions
A Well Suspension / Inspection Report must be submitted to the Commission’s,
Drilling and Production Department within 30 days of suspension of a well. The
completed suspension report must be submitted through the eSubmission portal.
All downhole activities to plug and suspend are considered Workover operations and
must be submitted to the Commission in a Completion/Workover Report. Suspensions
are to be reported as Workovers on report cover pages and in Notices of Operation.
Refer to the Well Data Submission Requirements Manual for further information.

Reactivations
Submission of a reactivation report is not required. Reactivations are identified by
alternate means (i.e. spud date, production reporting).

Inspections and Pressure Tests

All pressure test reports must be submitted through the eSubmission portal. For
information regarding pressure testing frequency, please refer to Tables 9B, 9C and
9D of this manual.

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When submitting a suspended well pressure test report, the annual suspended well
inspection for that year must also be submitted through the eSubmission portal.

9.5 Well Abandonment

Notification or approval is not required prior to conducting open hole plugbacks or

abandonments.

Drilling wells that are downhole, but not surface abandoned at the time of rig release, are not
considered abandoned. An abandonment notification and abandonment report must be
submitted to the Commission at the time of surface abandonment as outlined below for the well
status to be changed to abandoned.

9.5.1 Abandonment Notification

Notification is required 7 days prior to conducting all other well abandonments;

however the notification requirement may be waived on a case by case basis. An
abandonment program must be included with the notification.

9.5.2 Abandonment Procedures

Wells must be abandoned in a manner to ensure:

 Adequate hydraulic isolation between porous zones.
 Fluids will not leak from the well.
 Excessive pressure will not build up in any portion of the well.
 Long-term integrity of the wellbore is maintained.

For the wells only with conductor casing, permit holders are expected to conduct
abandonments and plugbacks in accordance with the Groundwater Protection Regulation
(Water Sustainability Act).

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For water supply wells associated with oil and gas sites, permit holders are required to
conduct abandonments and plugbacks in accordance with the Groundwater Protection
Regulation (Water Sustainability Act).

For a well source well providing water for waterflood and fracturing, the permit holder:

 is expected to conduct abandonment and plugback in accordance with the

AER Directive 20 in case that the total depth of the well is deeper than the
base of ground water protection, or
 is required to conduct abandonment and plugback in accordance with the
Groundwater Protection Regulation (Water Sustainability Act) and Section
26(1) of Drilling and Production Regulation in case that the total depth of the
well is equal to or shallower than the base of usable groundwater.

For the wells drilled for oil and gas activities, permit holders are expected to conduct
abandonments and plugbacks in accordance with the AER Directive 20.

If there is any doubt about the adequacy of a plugging or abandonment program, discuss
the abandonment plans with the Commission. Failure to adequately plug or abandon a
well may result in an order for remedial work.

Abandonment reports may be submitted using a Completion/Workover Report Form.

In cases where a well was cut and capped, but not reported to the Commission at the
time the work was completed, the Commission will accept the following as evidence of
cut and cap:

 A photograph of the signpost (grave marker) and wellsite. The

signpost must contain adequate identifying information.

 Copies of invoices / welder’s tickets for the work.

If the above materials are unavailable, excavate and photograph the casing stub.

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9.6 Well Servicing Equipment and Procedures

9.6.1 Blowout Prevention

The following section outlines blowout prevention standards that a permit holder
should follow to comply with the requirements of Part 4, Division 2 of the Drilling and
Production Regulation. It is the responsibility of the permit holder to ensure that
blowout prevention equipment and procedures are adequate.

A permit holder may use alternate blowout prevention equipment and techniques if
they can demonstrate by means of a detailed engineering analysis that the alternate
equipment or techniques are adequate as required by Section 16(1) of the Drilling and
Production Regulation.

9.6.2 BOP Equipment Classes

For the purposes of well servicing, blowout prevention equipment classes are as
follows:
 Class A equipment is required for a well where the minimum pressure rating
of the production casing flange is less than or equal to 21,000 kilopascals
(kPa) and the hydrogen sulphide content in a representative sample of the
gas is less than one mol per cent.
 Class B equipment is required for a well where the minimum pressure rating
of the production casing flange is:
 Greater than 21,000 kPa.
 Less than or equal to 21,000 kPa and the hydrogen sulphide
content in a representative sample of the gas is one mol per cent or
greater.
 Class C equipment is required for a special sour well (see IRP #2).
 Minimum stack components shall conform to the BOP stack configuration as
shown in Appendix B of this manual.
 Minimum manifold design shall conform to a Class B manifold.

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 Shear rams are required

 All metallic BOP components which may be exposed to sour effluent must be
certified as being manufactured from materials meeting the requirements of
NACE MR-01-75.
 Flanged BOP working spools with two flanged side outlets are required on
critical sour wells.
 Working spool outlets must include full opening gate valves to serve as
primary control. The kill side shall include a primary valve and a check valve,
while the bleed off line shall have a primary and a secondary (back-up)
valve. The valves shall be rated to a working pressure equal to or greater
than the BOP.

9.6.3 General

At all times during well servicing, the well must be under control, adequate blowout
prevention equipment must be installed and must be able to shut off flow from the well
regardless of the type or diameter of tools or equipment in the well.

The blowout prevention equipment must have a pressure rating equal to or greater
than the pressure rating of the production casing flange or the formation pressure,
whichever is the lesser.

Hydraulic ram type blowout preventers which are not equipped with an automatic ram
locking device must have hand wheels available.

An accurate pressure gauge to determine the well annulus pressure during a well
shut-in must be either installed or readily accessible for installation.

A service rig used at the well site must have an operable horn on the drilling control
panel for sounding alerts.

A sour service separator and flare system, including appropriate manifolding, must be
used to process sour well effluent.

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The well control system must be adequately illuminated.

9.6.4 Accumulator systems

All blowout preventers must be hydraulically operated and connected to an

accumulator system.

The accumulator system must be installed and operated in accordance with the
manufacturer's specifications. The system must be:
 Connected to the blowout preventers with lines of working pressure equal to
the working pressure of the system, and within seven metres of the well, the
lines must be of steel construction unless completely sheathed with
adequate fire resistant sleeving.
 Capable of providing, without recharging, fluid of sufficient volume and
pressure to effect full closure of all preventers, and to retain a pressure of
8,400 kPa on the accumulator system.
 Recharged by a pressure controlled pump capable of recovering the
accumulator pressure drop resulting from full closure of all preventers within
5 minutes.
 Capable of closing any ram type preventer within 30 seconds.
 Capable of closing the annular preventer within 60 seconds.
 Equipped with readily accessible fittings and gauges to determine the pre-
charge pressure.
 Equipped with a check valve between the accumulator recharge pump and
the accumulator.
 Connected to a nitrogen supply capable of closing all blowout preventers
installed on the well.

The accumulator nitrogen supply must:

 Be capable of providing sufficient volume and pressure to fully close all
preventers and to retain a minimum pressure of 8,400 kPa.

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 Have a gauge installed, or readily available for installation, to determine the

pressure of each nitrogen container.

9.6.5 Requirements Specific to Class A Systems

Class A blowout prevention system:

 May utilize the rig hydraulic system to recharge the accumulator.
 Must have operating controls for each preventer in a readily accessible
location near the operator's position and an additional set of controls located
a minimum of 7 metres from the well.

9.6.6 Requirements Specific to Class B and C

Systems

Class B and Class C blowout prevention system must have:

 An independent accumulator system with operating controls for each
preventer located at least 25 metres from the well, shielded or housed to
protect the operator from flow from the well.
 An additional set of controls in a readily accessible location near the
operator's position.
 Working spools with flanged outlets.

Refer to IRP#2 for further information.

9.6.7 Flow Line Requirements

The following requirements do not apply to snubbing units and service rigs completing
rod jobs. A blowout prevention system must have two lines, one for bleeding off
pressure and one for killing the well, which must:
 Be either steel or flexible sheathed hose to provide adequate fire resistant
rating.

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 Be valved and have a working pressure equal to or greater than that required
for the blowout prevention equipment.
 Have one line connected to the rig pump and one line connected to the tank.
 Be at least 50 mm nominal diameter.
 Be securely tied down.

9.6.8 Stabbing Valve

A full opening ball valve (stabbing valve) which can be attached to the tubing or other
pipe in the well must:
 Be ready for use and located in a readily accessible location on the service
rig.
 Be maintained in the open position.
 Have an internal diameter equal to or greater than the smallest restriction
inside the tubing or casing.
 Be kept clean and ice free.

9.6.9 Blowout Prevention Manifold

The blowout prevention system must include a manifold that:

 Has a working pressure greater than or equal to that of the blowout
prevention system installed on the well
 Contains a check valve to prevent flow from well to rig pump
 Contains a pressure relief valve upstream of the check valve
 Is equipped with an accurate pressure gauge which shall be either installed
or readily accessible for installation

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9.6.10 Testing of Blowout Prevention Equipment

Before commencing servicing operations at a well, a 10-minute pressure test must be

conducted on each ram preventer to 1,400 kPa, prior to the tests described as follows:
 Each ram preventer, the full opening safety valve and the connection
between the stack and the wellhead, tested to the wellhead pressure rating
or the formation pressure, whichever is less.
 Each annular preventer to 7,000 kilopascals or the formation pressure,
whichever is less. For an annular type blowout preventer, all mechanical and
pressure tests must be conducted with pipe in the blowout preventer.

All blowout prevention equipment, except for shear rams on special sour wells, must
be mechanically tested daily, if operationally safe to do so; any equipment found
defective must be made serviceable before operations are resumed.

A pressure test is considered a pass if the pressure decrease is less than 10% over
the 10 minute test.

All tests must be reported in the servicing log book and in the case of a pressure test,
the report must state the blowout preventer tested, the test duration and the test
pressure observed at the start and finish of each test.

At least once every three years, all blowout preventers must be shop serviced and
shop tested to their working pressure and the test data and the maintenance
performed must be recorded and made available to an official on request.

9.6.11 Special Sour Wells

Refer to Energy Safe Canada (ESC)’s IRP Volume #2: Completing and Servicing
Critical Sour Wells for detailed information.

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9.6.12 Slickline, Snubbing and Coil Tubing

Operations

 Refer to the ESC’s IRP Volume #13: Slickline Operations.

 Refer to the ESC’s IRP Volume #15: Snubbing Operations.
 Refer to the ESC’s IRP Volume #21: Coiled Tubing Operations.

9.6.13 Hammer Unions

Hammer unions should not be used in the manifold shack or under the rig
substructure.

9.6.14 Personnel Certification

The following people must possess a valid Well Service Blowout Prevention certificate
issued by Energy Safe Canada (ESC), or a Well Intervention Pressure Control Level 4
certificate issued by IWCF, or a WellSharp Oil and Gas Operators Representative
certificate (WSOGOR) issued by IADC:
 The driller on tour.
 The rig manager (tool push).
 The permit holder’s representative.

If gas containing H2S is expected, every crew member must be trained in H2S safety.

Blowout prevention drills should be performed by each rig crew every seven days or
once per well, whichever is more frequent. Blowout prevention drills should be
recorded in the servicing log book.

Evidence of the qualifications of any person referred to in this section must be made
available to an official on request.

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The rig crew must have an adequate understanding of, and be able to operate, the
blowout prevention equipment and, when requested by an official and if it is safe to do
so, the contractor or rig crew must:
 Test the operation and effectiveness of the blowout prevention equipment.
 Perform a blowout prevention drill in accordance with the Well Control
Procedure placard issued by the Canadian Association of Oilwell Drilling
Contractors (CAODC) or as outlined by the ESC Blowout Prevention Manual.
Refer to the ESC’s IRP Volume #7: Standards for Wellsite Supervision of Drilling,
Completions and Workovers for more information.

9.6.15 Fire Precautions and Equipment Spacing

Refer to Sections 45 and 47 of the Drilling and Production Regulation.

Engines
Permit holders must ensure that, if engines are located at a wellsite, suitable
safeguards are installed and tested to prevent a fire or explosion in the event of a
release of flammable liquids or ignitable vapours.
For engines located within 25 metres of a well, petroleum storage tank or other
unprotected source of ignitable vapours, the Commission recommends that:
 The engine exhaust pipe is insulated or cooled to prevent ignition in the
event that flammable material contacts the exhaust pipe.
 The exhaust pipe is directed away from the well or source of ignitable
vapours.
 The exhaust manifold is sufficiently shielded to prevent contact with
flammable materials.

For diesel engines located within 25 metres of a well, the Commission recommends
that one of the following devices be installed:
 A positive air shutoff valve, equipped with a readily accessible control.
 A system for injecting inert gas into the engine’s cylinders, equipped with a
readily accessible control.

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 A suitable duct so that air for the engine is obtained at least 25 metres from
the well.
Permit holders must also ensure compliance with the requirements in Work SafeBC’s
(Section 23.8) Occupational Health and Safety Regulation.

Fuel
Gasoline or liquid fuel, except for fuel in tanks that are connected to operating
equipment, must not be stored within 25 metres of a well and drainage must be away
from the wellhead.

Smoking
Smoking is prohibited within 25 metres of a well.

Recommended Spacing Distances

Ensure appropriate spacing is maintained between potential sources of flammable
liquids or ignitable vapours and ignition sources. Table 9E provides a matrix for
recommended spacing distances. All fires must be sufficiently safeguarded and all
vessels and equipment from which ignitable vapours may issue must be safely
vented.

Flares and incinerators must be located at least 80 metres from any public road,
utility, building, installation, works, place of public concourse or reservation for
national defence.

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Table 9E: Recommended Spacing Distances

Liquids Crude Oil

Equipment, Teg*

Produced Water

Other Sources

& Condensate
Boiler, Steam

Flame Type
Of Ignitable
Generating

Flammable
Equipment
Incinerator

Separator

Produced
Wellhead

Vapours
Flare Or

Tanks
Tank
Wellhead 50 25 Ns Ns Ns 25* 50

Flare Or Incinerator 50 Ns 25 25 25 25 50

Boiler, Steam
Generating 25 Ns 25 25 25 25 25
Equipment, Teg*

Produced Water
Ns 25 25 Ns Ns 25* Ns
Tank

Other Sources Of
Ns 25 25 Ns Ns 25* Ns
Ignitable Vapours

Separator Ns 25 25 Ns Ns 25* Ns**

Flame Type
25* 25 25 25* 25* 25* T 25*
Equipment

Produced
Flammable Liquids
50 50 25 Ns Ns Ns** 25*
Crude Oil &
Condensate Tanks

All distances are in metres (M). * 25 m without flame arrestors, not specified with flame arrestors. ** Separator cannot be in the same dyke.
T treaters should be at least 5 m (shell to shell) from other treaters.

Note: A) boilers etc. includes steam generating equipment, electric generators and teg units. B) Other sources of ignitable vapours include
compressors. C) Flame type equipment includes: treaters, reboilers and line heaters. D) All electrical installations must conform to the Canadian
Electrical Code.

Flare Stacks
A sufficient area beneath and around flare stacks must be cleared of flammable
materials and vegetation.

The recommended blackened area beneath a flare stack is 1.5 times the stack height
to a minimum of 10 metres in cultivated areas and 30 metres in forested areas, unless
conditions support a lesser distance.

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The Commission recognizes that a lesser area may be justified depending on the
circumstances. It is the responsibility of the permit holder to maintain a sufficient area,
given the location and the conditions under which flaring will or may occur.

Flare blackened areas must be maintained within permissioned land area. If new
area is required to accommodate the blackened area, an amendment to the
well/facility area is required.

Explosives
Explosives must be stored in properly constructed magazines and be located a
minimum of 150 metres from any well servicing operation.

9.6.16 Inter-Wellbore Communications

Inter-wellbore communication may occur as a fluid and/or pressure communication

event at an offset well resulting from fracture stimulation on a subject well.
Communication levels include:
 Incident level communication is a communication resulting in a spill,
equipment overpressure, equipment damage, injury or a drilling kick.
 Event level communication is any communications not at the incident level.

Permit holders are obligated to manage the risks of inter-wellbore communication

between the subject well and an offset well. Document hydraulic fracturing programs
and include the following elements:
 Identify all offset wells that could be affected.
 Conduct a risk assessment of the identified offset wells.
 Develop a well control plan for all offset wells that are at risk.
 Modify the hydraulic fracturing program if risks cannot be mitigated.

Subject well permit holder must notify a permit holder of an at-risk offset well of a
planned hydraulic fracturing program and make all reasonable efforts to develop a

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mutually-agreeable well control plan. The subject well permit holder must maintain a
copy of the at-risk well control plan for the duration of hydraulic fracturing operations.

The permit holder of an at-risk offset well, upon receiving notification of a planned
hydraulic fracturing program, is expected to engage and work cooperatively with the
subject well permit holder in development of well control plans.

Report all fracture communication events using the Commission’s Inter-Wellbore

Communication Report Form (located on the Commission’s Wells Documentation web
page) and follow the ESC’s IRP Volume #24: Fracture Stimulation (Draft) for specific
methodology and procedures regarding the inter-wellbore communication
management process.

All fracture communication incidents must also be reported in accordance with the
Commission’s Incident Reporting Instructions and Guidelines.

9.7 Environmental Considerations

The environmental considerations section outlines and explains the regulatory requirements for
testing, repairing and reporting environmental impacts: hydraulic fracturing, seismic activity,
surface case venting flows, gas migration, casing leaks and failures, noise, fluid storage and
spills.

In addition, refer to the Flaring and Venting Reduction Guideline for detailed guidance.

9.7.1 Hydraulic Fracturing Fluid Report

Section 37 of the Drilling and Production Regulation states that permit holders
carrying out hydraulic fracturing operations must maintain detailed records of fracture
fluid composition, and submit records to the Commission within 30 days of well
completion. Hydraulic fracture fluid reports are submitted to the Commission via
Kermit. More information on hydraulic fracture fluid reporting is available in the
Fracture Fluid Disclosure Manual.

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9.7.2 Seismic Activity

Infrastructure must be built to withstand the effects of the elements or seismic

disturbance. Requirements to monitor, report and address seismic disturbances must
be followed.

Permit conditions may be employed to regulate induced seismicity. During fracturing

operations, permit holders must contact the Commission Emergency Contact at 1-
800-663-3456 in the following seismic event:
 Recorded by the permit holder or any source available to the permit holder
as being magnitude 4.0 or greater and within a three kilometre radius of the
drilling pad.
 Felt on the surface within a three kilometre radius of the drilling pad.

In the event of a well pad is responsible for a seismic event, the permit holder will
suspend fracturing operations on the well immediately. The seismic event may be
identified by either the permit holder or the Commission as described above.

Suspended fracturing operations may be continued if: Permit holder presents to the
Commission a plan for mitigation aimed at reducing the seismicity or eliminating well
operations related to the induced seismicity.
 Commission is satisfied with the plan.
 Permit holder implements the plan.

The Commission tracks northeast B.C. seismic events and compares these seismic
events alongside the locations of oil and gas permit holders. Further information and
recommendations from the Commission’s investigation into seismic activity is detailed
in the Investigation of Observed Seismicity in the Montney Basin and the Investigation
of Observed Seismicity in the Horn River Basin.

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9.7.3 Surface Casing Vent Flow

Permit holders must carry out surface casing vent flow activities, checks and
tests, repairs where applicable and as detailed in this section and according to
Section 41 of the Drilling and Production Regulation.

Surface Casing Vent Flow (SCVF) means:

 The flow of gas and/or liquid from the surface casing/ casing annulus.

Serious Surface Casing Vent Flow means:

 Vent flows with hydrogen sulphide (H2S) present.
 Vent flow with a stabilized gas flow rate equal to or greater than 300
cubic metres per day (m3/d).
 Vent flow with a surface casing vent stabilized shut-in pressure greater
than one half the formation leak-off pressure at the surface casing shoe
or 11 kPa/m times the surface casing setting depth.
 Hydrocarbon liquid (oil) vent flow.
 Vent flow due to wellhead seal failures or casing failure.
 Water vent flow if the water contains substances that could cause soil or
groundwater contamination.
 Vent flow where any usable water zone is not covered by cemented
casing.
 Other vent flow constituting a fire, public safety, or environmental
hazard.

Checking for Surface Casing Vent Flows

In accordance with Section 41 (2) of the Drilling and Production Regulation, a
permit holder must check each well for evidence of a surface casing vent flow:
(a) immediately after initial completion or any recompletion of the well,

Guidance: Wells shall be checked for the presence of a surface

casing vent flow no later than 7 days after the final date of a well

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operation which resulted in the completion of the well, the

recompletion of the well, or the stimulation of a formation by
hydraulic fracture or acidization.
(b) at the time of rig release,

Guidance: Wells shall be checked for the presence of a surface

casing vent flow no later than 7 days after the release of the drilling
rig. In the event a surface casing vent flow is discovered, and a well
operation that will result in the completion of the well is to be
initiated within 60 days of rig release, the flow rate and buildup
pressure tests required under Section 41 (4) of the Regulation may
be performed no later than 7 days after the final date of that well
operation, provided there is no risk to health, safety or the
environment.
(c) as routine maintenance throughout the life of the well,

Guidance: Wells shall be checked for the presence of a surface

casing vent flow at an interval the permit holder deems appropriate
to maintain a full and accurate understanding of the well conditions.
This may involve annual vent flow checks for new wells, or less
frequent checks for older, stable wells.
(d) before suspension of the well,

Guidance: Wells shall be checked for the presence of a surface

casing vent flow no earlier than 7 days prior to the commencement
of suspension operations. If the suspension of the well requires a
service rig, slickline or wireline, the well can be checked for the
presence of a surface casing vent flow between the commencement
of activities and the release of the service rig, slickline or wireline.
(e) before abandoning the well, and

Guidance: Wells shall be checked for the presence of a surface

casing vent flow no earlier than 7 days prior to the commencement
of abandonment operations. If surface abandonment is being
completed as a separate operation from the downhole
abandonment, wells shall also be checked for the presence of a
surface casing vent flow prior to final surface abandonment (cut &
cap).
(f) before applying for a transfer of the well permit.

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Guidance: Wells shall be checked for the presence of a surface

casing vent flow no earlier than 2 years prior to the proposed
transfer of the well permit. If the well proposed to be transferred has
been checked within the last 2 years for a purpose listed above, no
additional checking is required.
Note that if a vent flow is discovered under subsections (a), (b), (c), (d) or (f), it is
recommended that further testing continue for a minimum 5-year period. This
period of continued testing is described below, in the subsection entitled Testing
and Reporting Surface Casing Vent Flows.

Permit holders are encouraged to check for the presence of, and test, surface
casing vent flows only during non-freezing months to ensure that the buildup of
ice in the surface casing vent does not influence the results.

Bubble Test Information

A 10-minute bubble test is adequate to test for the presence of a surface
casing vent flow. The recommended procedure is as follows:

 Bubble Test Equipment:

 Container of water (from 500 ml to 1L).
 Pipe fittings, small hose (minimum 6mm), or other equipment
necessary to direct gas flow from vent downward in the water
container.
 Bubble Test Procedure:
 Ensure no gas leaks at fittings and welds.
 Ensure there is no H2S present.
 Ensure all valves in the vent line are open.
 If necessary, connect test fittings to the vent so gas flow can
be directed into the container of water.
 Immerse vent or hose a maximum of 2.5 cm below the water
surface.
 Observe for 10 minutes. Note any gas flow (for example,
bubbles) which must be recorded as a positive vent flow.
 Record observations.

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Visual observation is sufficient to confirm the presence of a liquid SCVF. The

presence of H2S in a SCVF can be confirmed by the use of a personal monitor,
onsite H2S tests, or other methods as appropriate.

Testing and Reporting Surface Casing Vent Flows

Serious surface casing vent flows present a safety or environmental hazard
and must be reported to the Commission immediately.

On discovery of a surface casing vent flow that does not present an

immediate safety or environmental hazard, a well permit holder must test the
surface casing vent flow rate and buildup pressure, and report the surface
casing vent flow test results to the Commission within 30 days of the
discovery of the surface casing vent flow.

Following discovery and initial reporting, permit holders should perform

annual surface casing vent flow tests for a minimum of five years. The permit
holder may select appropriate yearly testing measures, however, the
Commission may order specific test measures for surface casing vent flows
of particular concern.

In the event a significant change to a previously-identified SCVF is observed,

permit holders should report their findings to the Commission. Examples of a
significant change are:

(a) from no vent flow to non-serious vent flow or serious vent flow,

(b) from non-serious vent flow to serious vent flow, or vice-versa,

(c) from non-serious vent flow or serious vent flow to no vent flow

The results of SCVF tests required as part of a Commission inspection must

be reported.
The Commission recommends that permit holders report all surface casing
vent flow test results. Non-reported test results must be maintained on file
and provided to the Commission on request.

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All reporting of SCVF test results must be done via the Commission’s
eSubmission portal.

Measuring Flowrate
Once a positive vent flow is detected, the flow rate and stabilized shut in
pressures must be recorded. To measure venting gas volumes, a positive
displacement gas meter, turbine meter or an orifice well tester may be used.
Equipment selection should be based on previous observations indicating
what flow rate and pressure range can be expected. A positive displacement
meter will be necessary to measure low volumes accurately. An orifice well
tester, with proper orifice plate, may provide satisfactory measurements if the
24 hour shut in pressure is 200 kPa or greater and builds quickly.

Install and use the equipment according to manufacturer’s instructions:

 Do not exceed the pressure/volume range of the equipment.
 Ensure there are no leaks.

Measuring Buildup Pressure

While conducting a surface casing buildup pressure test, a pressure relief
valve should be installed on the surface casing vent testing assembly. This
pressure relief valve should be calibrated to release at a pressure no greater
than 11 kPa/m times the surface casing setting depth.

To determine the stabilized surface casing buildup pressure, the following

equipment can be used:
 Single pen static pressure recorder with 24-hour chart, or
 Electronic pressure recorder, or
 Deadweight pressure gauge
If it is anticipated that the buildup pressure will exceed the maximum
allowable pressure specified above, then a recording device must be used,
such as an electronic pressure recorder, in order to capture a record of the
rising pressure and the point at which the relief valve opens.

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Once the surface casing flow rate test has been completed, a buildup
pressure test must be conducted. The recommended buildup pressure test
procedure is as follows:
 Install pressure recorder (or deadweight gauge) and pressure
relief valve.
 Ensure that there are no leaking fittings, welds or connections.
 Close the surface casing vent test assembly downstream of the
pressure recorder and pressure relief valve.
 Monitor the buildup pressure as required until a stabilized
maximum pressure is reached, or the pressure relief valve opens.
 If using a deadweight pressure gauge, record the buildup
pressure at appropriate intervals until a stabilized pressure is
reached or the pressure relief valve opens.
 If a pen pressure recorder is being used, and the pressure does
not stabilize within 24 hours, change the chart as required to
obtain a full and complete record of the buildup pressure test.
The buildup pressure has reached a stabilized value if over the last 6 hours
of the test, the pressure changes at a rate of less than 2 kPa per hour - 12
kPa or less in a 6 hour period.

9.7.4 Surface Casing Vent Flow Repairs

Non-Serious Repair
Remedial repair may be deferred until well abandonment for non-serious
surface casing vent flows.

In an effort to minimize the amount of venting from a non-serious surface

casing vent flow, the permit holder may consider the installation of a burst
plate or pressure safety valve (PSV). The permit holder must obtain an
exemption to Section 18(9)(a) of the Drilling and Production Regulation to
allow the installation of a burst plate or pressure safety valve.

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Non-serious surface casing vent flows must be repaired at the time of well
abandonment.

Repair of a Serious Surface Casing Vent Flow

The permit holder of a well determined to have a serious surface casing vent
flow should contact the Commission as soon as possible to discuss repair or
management requirements.

9.7.5 Surface Casing Vent Flow Production

If the permit holder wishes to explore the option of producing the surface
casing vent flow, an application must be made to the Drilling and Production
Department to obtain an exemption to Section 18(9)(a) of the Drilling and
Production Regulation. Requests will be considered if:
 The source depth and formation of origin has been clearly identified.
 The permit holder owns the mineral rights to produce the source
formation.
 The cemented portion of the surface casing or the next casing string
covers the deepest known usable groundwater.
 The flow has been analyzed and determined to be sweet (0 per cent
H2S).

The Commission may rescind the approval to produce from the surface
casing vent and may require the surface casing vent flow to be repaired at
any time if the Commission determines a safety or environmental hazard
exists.

9.7.6 Gas Migration Reporting, Testing and Risk

Assessment

“Gas migration” means a flow of gas outside of the surface casing of a well.

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Gas Migration Reporting

In accordance with Section 41 (4.1) of the Drilling and Production Regulation
DPR), upon the discovery of an occurrence of gas migration, a permit holder must
notify the Commission of the gas migration within 72 hours by the submission of a
completed gas migration report submitted via the eSubmission portal.

Notification is required:
 if gas migration is visible as bubbles in water at the wellhead.
 If gas migration is confirmed by any field testing.

Field testing at the ground surface outside the surface casing to confirm the presence
or absence of gas should be conducted if:
 there is any visual, auditory, olfactory, or other evidence of possible gas
migration, or
 issues with well drilling and completion, or with well condition, indicate the
potential for gas migration.

Gas Migration Risk Assessment

A risk assessment report must be submitted within 90 days of the Commission’s
notification of gas migration, unless an alternate submission schedule is
authorized by the Commission. Based on review of the report, the Commission
will provide a written response confirming the requirement to submit a risk
assessment report in accordance with Section 41(4.1) of the DPR has been met,
and specifying any requirements for further investigation, monitoring, mitigation,
and/or reporting.

The risk assessment must be completed under the direction of a Qualified

Professional. A Qualified Professional must possess an appropriate combination
of formal education, knowledge, skills, and experience to conduct a technically
sound and rational assessment for the area of practice, and be familiar with
applicable regulations, standards, policies, protocols and guidelines.
The risk assessment and risk assessment report must include the following
unless previously submitted to the Commission.
 Documentation of Well and Site Information, including:

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 A summary of well construction details and relevant well history.

 Evidence of gas migration (e.g., bubbles, stressed vegetation).
 Description of site geographic location, site facilities and structures,
topographic information and features, land surface conditions (vegetation,
land clearing), and surrounding land use (including protected areas and
parkland).
 Supporting maps and site plans.
 Documentation of Field Investigation and Results, including:
 The completion of a Shallow Gas Survey as described in this manual
 The collection and analysis of one or more gas samples (e.g., from surface
casing vent, area(s) of gas migration, and from the well) for the purposes of
evaluating the source of the gas. Samples must be submitted to a qualified
laboratory for analysis of hydrocarbons, H2S, and isotopic analysis.
Laboratory analytical reports must be included with the report.
 Measurement of gas flow rates including surface casing vent flow, and gas
migration between surface casing and conductor casing or elsewhere, if
possible.
 Results of any groundwater monitoring that has been conducted at the
wellsite with information on well locations, geological conditions, and well
construction specifications.
 Measurement of gas concentration or LEL’s at ground level, in the same
pattern as the Shallow Gas Survey.
 An assessment of the source and cause of gas migration, including:
 A description of the interpreted source of gas migration and known or
suspected cause of gas migration based on well information and field
testing.
 Identification of Potential Human and Environmental Receptors, including:
 Documentation of desktop information for a 2 km radius surrounding the
well related to proximity to potential human or environmental receptors
including: information for water supply wells, mapped aquifers, mapped
capture zones (i.e., water well source areas), provincial observation wells,
residential areas, public and protected areas, surface water bodies,
Provincial water authorizations (e.g., water use approvals or licences), or
other relevant information. The Commission’s Groundwater Review
Assistant (GWRA) should be used to compile desktop information and
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a copy of the GWRA output report shall be included with the Risk
Assessment Report. Additional land use information may be compiled
using iMapBC, Google Earth, and/or review of aerial photographs or
imagery where available.
 Documentation of a “windshield” field reconnaissance, conducted where
practicable, to verify the desktop information related to land occupancy/use
and the locations of water supply wells.
 Supporting maps as appropriate.
 Assessment of Risk and Proposed Mitigation and Management Measures,
including:
 Tabulated risks using the BC OGC Risk Assessment Framework for
Wellsites with Gas Migration (see Table 9F), which includes identification of
hazards and assessment of potential safety, health, and environmental risks
based on the compiled well, desktop, and field investigation information.
A fillable form version of Table 9F can be found on the Commission’s
website.
 Proposed mitigation and management measures for identified risks. These
must include, where appropriate, gas migration repair measures, site
restoration measures, well abandonment plan, groundwater and/or soil
quality assessment (installation of monitoring wells), long term monitoring
of gas flow and extent of gas migration, air quality monitoring,
enhancements to site security (e.g., fencing), any or other appropriate
measures.

The proposed mitigation and management measures will be reviewed

by the Commission.

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Table 9F: BC OGC Risk Assessment Framework for Wellsites with Gas Migration
1Risk rating must be supported by information documented in or appended to the Risk Assessment Report.
Risk rating may be updated following implementation of management, monitoring, mitigation, or further investigation.
Well Authorization Number: _____________ Risk Assessment Report Date: _______________
1Risk
Risk Potential Hazard Risk Rating Guidance Rating and
Category Description and Risk Low Moderate High Proposed Management, Monitoring,
Rationale Mitigation or Further Investigation
General Identify potential public safety No potential hazards One or more potential One or more
Public Safety hazards within the lease area identified site hazards identified potential site
(site), including general hazards AND low potential for hazards identified
associated with infrastructure public access to site AND reasonable
and potential confined space potential for public
hazards, with consideration of access to site
the potential for unintentional or
intentional public access.
Fire or Identify potential hazards based Gas Concentrations < Gas Concentrations > Gas Concentrations
Explosion on shallow gas survey results 100% LEL 100% LEL > 100% LEL
with consideration of potential OR AND low potential for AND potential for
ignition sources. >100% LEL and access is ignition source ignition source
restricted
Air Quality Identify potential concerns No odour observed AND Odour is apparent Gas contains H2S
related to air quality due to gas does not contain H2S AND members of the OR
odour and H2S based on field public are highly odour is apparent
observations or gas analysis, unlikely to be within and potential exists
with consideration of potential 100 m of the site for members of the
human receptors. public to be within
100 m of the site
Groundwate Identify potential hazards to Gas is not thermogenic Gas is thermogenic Gas is thermogenic
r groundwater quality based gas AND gas migration does OR gas is not AND water wells,
analysis and the shallow gas not extend off site thermogenic and water intakes, or
survey results, with shallow gas extends licensed springs are
consideration of the potential for off site within 600 m of the
groundwater to reach potential well
human receptors.
Surface Identify potential hazards based Gas is not thermogenic Gas is thermogenic Gas migration flow
Water and on the gas analysis with OR gas is thermogenic AND there is potential rates could result in
Riparian consideration of the potential for with low potential for for groundwater the accumulation of
Areas groundwater discharge to groundwater discharge to discharge to a riparian gas at surface water
surface water bodies/riparian a riparian area or surface area or surface water bodies or riparian
areas. water body body areas on or off site
A fillable version of Table 9-F is available on the Commission’s website.

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Shallow Gas Survey Procedure

The Commission requires testing to be carried out to identify the extent of gas
migration in the shallow subsurface by completion of a shallow gas survey extending
radially around the wellhead as follows.
 Required Equipment:
 Bar or auger (64 mm or less in diameter) capable of penetrating a minimum
of 50 cm.
 Calibrated monitor or other instrument capable of detecting hydrocarbons at
on per cent lower explosive limit (LEL).
 Equipment or material to seal the hole at surface while soil gases are being
evacuated from the soils through the instrument.
 Preparation for testing:
Testing must be done in frost free months only and periods immediately after
rainfall should be avoided. If contaminated soils are suspected across the
survey area, the soil should be excavated and removed prior to testing.
Instrument calibration must be performed.
 Sampling points:
Two sampling points must be located within 30 cm of the wellbore on opposite
sides. Additional sampling points must be placed at two meter intervals outward
from the wellbore, every 90 degrees (centered at the wellbore), to a minimum
radius of 6 m.
If detectable gas is identified at a 6 m distance from the wellhead, the shallow
gas survey must be extended by appropriate distance intervals over an area
sufficient to delineate the extent of gas in the shallow subsurface.
In addition to the above sampling locations, at least four additional point
measurements should be made outside the four sides of a compacted well pad if
the well pad could be considered to be a potential barrier to the efflux of gas at
the ground surface.
 Test Procedure:
 Insert auger or make a bar hole a minimum of 50 cm deep.
 Isolate the hole from atmospheric contaminants.
 Obtain sample a minimum of 30 cm into the hole, maintaining a seal at
surface to prevent atmospheric gas and soil gas mixing.

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 Withdraw soil gas sample. The volume, rate, etc., will depend on the
instrumentation being used. Ensure that a sufficient sample is removed to
purge lines and instrumentation.
 Purge instrument and lines prior to taking next measurement.
 Document preparation, procedures and results.

9.7.7 Casing Leaks and Failures

A permit holder must notify the Commission of any casing leak or casing failure
as soon as possible. The leak or failure must be repaired within a reasonable time
frame, giving consideration to the accessibility of the site and the seriousness of
the leak or failure.

9.7.8 Noise

Section 40 of the Drilling & Production Regulation states:

 A permit holder must ensure operations at a well or facility for which the
permit holder is responsible does not cause excessive noise.

Review Section 40 of the DPR and the Commission’s British Columbia Noise Control
Best Practices Guideline for an understanding of noise levels, requirements and
suggested best practice standards. In addition, work with area residents to minimize
noise impacts when undertaking construction, drilling, completions, and operations
activities near populated areas.

9.7.9 Fluid Storage at Well Sites

Secondary containment of tanks associated with completions operations is

generally not required. For extended, unmanned flowback operations requiring a
facility permit, secondary containment in accordance with the National Fire
Protection Agency’s Flammable and Combustible Liquids Code (NFPA 30) is
required.

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The Commission’s Management of Saline Fluid for Hydraulic Fracturing Guideline

details the requirements and expectations for siting, design, construction,
operation, and decommissioning of lined containment systems used for the
storage of saline fluids.

The Management of Saline Fluid for Hydraulic Fracturing Guideline provides

guidance for permit holders to demonstrate ongoing compliance with OGAA and
EMA, and the regulations with respect to the storage of saline fluids.

9.8 Well Data Submission

9.8.1 Completion /Workover / Abandonment

Report

The Completion / Workover / Abandonment Report is due within 30 days of the end of
main operations. Refer to the Notice of Operation and Completion Report Reference
Guide for a list of activities that require submission of a completion / Workover report.

For more information on operations not listed in the Notice of Operation and Completion
Report Reference Guide, contact Drilling and Production by email at
[email protected] or phone 250-794-5258.

Required Information/Attachments to
Completion/Workover Report

The Completion / Workover / Abandonment Report must include the following

attachments:
 Chronological summary - either on this form if a short summary, or on
separate enclosed page, list the major events in this completion report
by date, such as perforations or frac port openings, stimulation
operations, setting temporary or permanent plugs/zonal abandonments,

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milling operations, type of production string installed and flowing

operations.
 Detailed completion/workover daily reports.
 Downhole schematic diagram.
 Completion/Workover Report Cover Page.
 Copy of the Notice of Operation.

The Completion / Workover Report cover page requires the following:

 Completion type: kind of completion done (such as, Open Hole well,
Single if one zone capable of producing, Dual or Multi if 2 or more zones
capable of producing separately, Commingled if two or more formations
producing together).
 Completion activity: all operations performed within this completion
report.
 Stimulation type: which achieved breakdown or well flow. If Acid
Stimulation, state the acid volume pumped in the stimulation in cubic
meters (m3) and the maximum pressure used in the acid stimulation in
kilopascals (kPa). If hydraulic fracturing conducted, submit Hydraulic
fracture data in comma separated value (.csv) files through the
eSubmisison portal.
The Commission provides the following documents to guide the
submission of comma separated value files for hydraulic fracture data:
 Hydraulic Fracture Comma Separated Value (CSV) How-
To Guide
 Flow summary (for each formation): the hydrogen sulphide (H2S) per
cent, oil rate, water rate, choke size or API gravity.
 Flow rate in 103m3/day.
 Flow pressure in kPa.
 Final flow date.
 Radioactive material used in the workover (such as frac sand). If used,
attach documentation explaining the method of disposal or, if buried on
site, attach sketch of location showing burial location and indicate depth
of burial and volume of material.

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 Results of work done and the outcome of the operation (such as,
successful completion of the Montney; well on production; productivity
increased; water flow successfully shut-off; well successfully suspended)
For the above example, the result would be, “Bluesky tested and
suspended with BP”.

The Completion / Workover / Abandonment Report is submitted to the eSubmission

portal within 30 days of the end of main operations.

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