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Directive 065: Resources Applications for Oil and Gas Reservoirs ...

Directive 065: Resources Applications for Oil and Gas Reservoirs ...

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An application <strong>for</strong> approval to commingle production must include the in<strong>for</strong>mation <strong>for</strong> those items as<br />

specified in the table above <strong>and</strong> as described below.<br />

Requirements<br />

1) A statement of what is being requested,<br />

including<br />

a) a reference that the application is being<br />

made under Section 3.050 of the OGCR,<br />

<strong>and</strong><br />

b) if approval <strong>for</strong> commingling is requested<br />

on a well or pool basis, the name of the<br />

well(s) <strong>and</strong> pools that are the subject of<br />

the application, together with<br />

identification of each productive interval<br />

(kelly bushing [KB] elevation, in<br />

metres) in each well of interest from<br />

which you propose to commingle<br />

production, or<br />

Comments<br />

If the pools involved have not been defined<br />

by the ERCB at the time of application, the<br />

pools should be referred to as undefined.<br />

Inclusion of the intervals ensures that there is<br />

no confusion about the pools involved, which<br />

might occur if the ERCB <strong>and</strong> an applicant<br />

have different terminology <strong>for</strong> the same<br />

zones.<br />

c) if an area-based commingling approval<br />

is being requested, a list of the sections<br />

in the area of application <strong>and</strong> the zones<br />

to which the commingling would apply,<br />

together with a geophysical log of a type<br />

well with annotations identifying the<br />

subject zones.<br />

2) A discussion of the reasons why you are<br />

requesting commingling, including, as<br />

appropriate,<br />

a) a statement of the DE or SD criteria<br />

that were not met or the operational<br />

issues that would be addressed by<br />

commingling, <strong>and</strong><br />

b) justification as to why commingling<br />

should be granted, including, where<br />

required,<br />

(i) why commingling will not<br />

contaminate any non-saline water<br />

interval, with supporting technical<br />

evaluation as appropriate,<br />

(ii) why commingling will not cause<br />

any issues in the water well(s), with<br />

supporting technical evaluation,<br />

including<br />

• the geological setting of the<br />

shallowest per<strong>for</strong>ated zone <strong>and</strong><br />

water-bearing zone(s),<br />

• the details of the fracture<br />

stimulation proposed or done,<br />

<strong>and</strong><br />

In general, improved economics with<br />

commingling alone or the ability to conduct<br />

fewer tests under a commingling approval<br />

are not considered valid reasons <strong>for</strong> an<br />

application.<br />

Your discussion of why commingling should<br />

be permitted should draw on the in<strong>for</strong>mation<br />

<strong>and</strong> evaluations included elsewhere in the<br />

application.<br />

3-22 • ERCB <strong>Directive</strong> <strong>065</strong>: <strong>Resources</strong> <strong>Applications</strong> / Commingled Production (October 2011)

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