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

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3.1.7 Explanatory Notes to Determine If the DE or SD Processes May Be Utilized<br />

1. Are the pools involved already approved <strong>for</strong> commingling in the well?<br />

To answer this question, the list of pools approved <strong>for</strong> commingling, as identified in the fieldbased<br />

MU orders, must be checked. An evaluation needs to be made as to whether each<br />

productive interval in the well proposed <strong>for</strong> commingling is currently part of an existing pool<br />

as defined by the ERCB. If each interval proposed <strong>for</strong> commingling is within the boundaries<br />

of existing pools as defined at the time the licensee is conducting its evaluation <strong>and</strong> these<br />

pools are already approved <strong>for</strong> commingling, production from the pools may be commingled<br />

in the subject well without any notice to the ERCB. Commingled production must be<br />

reported to the Registry using the existing commingled production code <strong>for</strong> the pools<br />

involved.<br />

If at the time of the evaluation, the pools in the well have not been approved <strong>for</strong> commingling<br />

as set out in the field-based MU orders, the licensee may proceed to use the DE or SD<br />

decision tree to determine whether the well is a c<strong>and</strong>idate <strong>for</strong> commingling through the DE or<br />

SD process. If the well is a c<strong>and</strong>idate <strong>for</strong> commingling using the DE or SD process,<br />

production may be commingled in the wellbore immediately. Commingled production must<br />

be reported to the Registry using the DE or SD code available <strong>for</strong> each field, <strong>and</strong> the licensee<br />

must operate within the DE <strong>and</strong> SD criteria at all times. If the proposed commingling does<br />

not meet the criteria <strong>for</strong> either DE or SD commingling <strong>and</strong> commingling is desired, an<br />

application in accordance with Section 3.1.8 of <strong>Directive</strong> <strong>065</strong> must be submitted.<br />

2. Are there any intervals proposed <strong>for</strong> commingling that are not within the area or<br />

stratigraphic interval of the DE?<br />

To answer this question, the licensee must confirm if the well <strong>and</strong> intervals proposed <strong>for</strong><br />

commingling are within the area <strong>and</strong> stratigraphic interval of the related DE. This in<strong>for</strong>mation<br />

is provided on the order <strong>for</strong> each DE, which is available on the ERCB Web site www.ercb.ca<br />

under Industry Zone : Rules Regulations Requirements : Management of Commingling in the<br />

Wellbore. If the well is outside the area of the DE or there are any per<strong>for</strong>ated intervals within<br />

the wellbore that are outside the stratigraphic interval of the DE, the well is not permitted to<br />

commingle production under the DE process. If commingling of production is desired in this<br />

circumstance, the licensee may proceed to the SD decision tree <strong>and</strong> determine if the proposed<br />

commingling meets the criteria <strong>for</strong> SD commingling. If the proposed commingling does not<br />

meet the criteria <strong>for</strong> either DE or SD commingling <strong>and</strong> commingling is desired, an<br />

application in accordance with Section 3.1.8 of <strong>Directive</strong> <strong>065</strong> must be submitted.<br />

3. If there are any per<strong>for</strong>ations above the BGWP, is it anticipated that there would be water<br />

production equal to or greater than 5 m3/well/month from all intervals in the well?<br />

A licensee may determine whether any interval proposed <strong>for</strong> commingling is above BGWP<br />

from the data provided in ERCB ST55: Alberta’s Base of Groundwater Protection (BGWP)<br />

In<strong>for</strong>mation.<br />

The volume of 5 m 3 /well/month is proposed as a practical cutoff to allow <strong>for</strong> small volumes<br />

of water, including water of condensation that may periodically need to be cleaned out of the<br />

well.<br />

3-14 • ERCB <strong>Directive</strong> <strong>065</strong>: <strong>Resources</strong> <strong>Applications</strong> / Commingled Production (October 2011)

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