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

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Requirements<br />

Comments<br />

4) When submitting <strong>Directive</strong> 051 in<strong>for</strong>mation<br />

after the approval has been issued, provide<br />

the field <strong>and</strong> pool name, the disposal<br />

scheme approval number, <strong>and</strong> the well<br />

location(s).<br />

If you do not submit the <strong>Directive</strong> 051<br />

requirements within the three months or<br />

other approved period, the ERCB will<br />

rescind the gas storage approval or portion<br />

referencing the specific well(s).<br />

If <strong>Directive</strong> 051 has been met <strong>for</strong> the<br />

proposed gas storage wells, you must include<br />

the completion logs <strong>and</strong> associated<br />

discussion required by the directive. The<br />

ERCB will then h<strong>and</strong>le all matters pertaining<br />

to the completion approval(s) concurrently<br />

with the scheme approval.<br />

If you have not met <strong>Directive</strong> 051<br />

requirements <strong>for</strong> the proposed storage<br />

well(s), in no case shall injection to the gas<br />

storage well(s) commence until you have<br />

received a letter from the ERCB<br />

indicating that <strong>Directive</strong> 051 requirements<br />

have been met.<br />

5) If the injected fluid contains any H 2 S, a<br />

statement is required indicating that<br />

notification of the scheme <strong>for</strong> emergency<br />

response plan (ERP) purposes has been<br />

made to all potentially adversely affected<br />

parties. You must include the details of any<br />

outst<strong>and</strong>ing objections or concerns from the<br />

notified parties.<br />

Where facilities may pose a risk to the<br />

public, ERP requirements must be met prior<br />

to commencement of operations. Generally,<br />

an ERP is required if a risk assessment<br />

indicates that there are members of the public<br />

within a defined hazard area. ERPs are<br />

submitted to the Emergency Planning <strong>and</strong><br />

Assessment Section to ensure that<br />

requirements to <strong>Directive</strong> 071: Emergency<br />

Preparedness <strong>and</strong> Response Requirements<br />

<strong>for</strong> the Petroleum Industry have been met.<br />

Questions may be directed to the EPA Help<br />

line at 403-297-2625.<br />

Monitoring Scheme Operation<br />

After a storage scheme has been approved <strong>and</strong> is placed into operation, the per<strong>for</strong>mance of<br />

the scheme becomes an issue. The ERCB is interested in ensuring that the scheme will be<br />

operated within the conditions of the approval.<br />

Requirements<br />

1) A discussion of the monitoring program,<br />

including the frequency <strong>and</strong> method of<br />

measuring the bottomhole <strong>and</strong>/or top-hole<br />

pressures.<br />

Comments<br />

This discussion will determine how the<br />

scheme will be operated to ensure that the<br />

approval conditions will not be exceeded.<br />

4-22 • ERCB <strong>Directive</strong> <strong>065</strong>: <strong>Resources</strong> <strong>Applications</strong> / Underground <strong>Gas</strong> Storage (October 2011)

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