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

Unit 3 Production Control
3.1 Commingled Production
3.1.1 Background
Historically, the standard practice for producing oil and/or gas in Alberta has been to
maintain segregation between pools in the wellbore, unless otherwise approved by the ERCB,
in accordance with Sections 3.050 and 3.060 of the Oil and Gas Conservation Regulations
(OGCR). Reasons for this control include
• avoiding wellbore and/or reservoir conditions that may adversely affect resource
recovery,
• maintaining the ability to gather data on an individual-pool basis for resource evaluation
and reservoir management,
• ensuring operational safety, and
• ensuring the protection of non-saline groundwater.
While these reasons for segregated production remain valid, commingling of production from
multiple pools in the wellbore following approval by the ERCB is a longstanding practice in
Alberta that has occurred over a wide range of formations and depths. The ERCB recognizes
that commingling maximizes conservation in many cases and is necessary for economic and
orderly development of lower productivity resources.
Recognizing the advantages of commingled production for situations where there is low risk
associated with the commingling, the ERCB has implemented processes that allow
commingling to occur subject to specific requirements being met. For higher risk situations, if
the commingling of production from two or more pools in the wellbore is desired, an
application for approval to commingle must be submitted to the ERCB in accordance with
Section 3.1.8 of Directive 065.
3.1.2 Processes for the Management of Commingled Production
Three processes exist for the management of commingled production in the wellbore:
• development entity (DE),
• self-declared (SD) commingling, and
• approval of an application in accordance with Directive 065.
If the proposed commingling does not meet the requirements for commingling through the
DE or SD process, the licensee must obtain approval for the commingling through the
application process (Figure 3.1 in Section 3.1.4).
3.1.3 ERCB Expectations, Notification Requirements, and Compliance Assurance for All Commingled
Production
3.1.3.1 Commingled Operations
The ERCB expects licensees to use good engineering practices when commingling
production. This includes
• a good understanding of the reservoir and fluid properties prior to commingling;
ERCB Directive 065: Resources Applications / Commingled Production (October 2011) • 3-1