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

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If it is anticipated that water volumes equal to or greater than 5 m 3 /well/month could be<br />

produced from any or all intervals in the well that has per<strong>for</strong>ations above the BGWP, a<br />

licensee may not commingle production using the DE or SD process.<br />

If an existing well that is to be recompleted <strong>for</strong> commingled production has produced greater<br />

than 5 m 3 /well/month of water from the well in any of the last 12 months, a licensee may not<br />

commingle production using the DE or SD process.<br />

If the licensee wishes to commingle production in this circumstance, an application in<br />

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

provide a case that water produced with commingled production will not contaminate<br />

groundwater or adversely impact the recovery of gas from coals. Licensees should note that<br />

commingling of production in wells with completions above the BGWP that have actual or<br />

anticipated water production equal to or greater than 5 m 3 /month conflicts with <strong>Directive</strong> 044.<br />

Licensees must also ensure that operations comply with the AENV Water Act, taking<br />

particular note that non-saline water may not be produced without a groundwater diversion<br />

permit, non-saline aquifers may not be mixed, <strong>and</strong> saline <strong>and</strong> non-saline aquifers may not be<br />

mixed.<br />

4. Are there any water wells within a 600 m radius with a total depth less than 25 m from the<br />

top of the per<strong>for</strong>ations of the well proposed <strong>for</strong> commingling?<br />

This requirement has consideration <strong>for</strong> <strong>Directive</strong> 027: Shallow Fracturing Operations—<br />

Interim Controls, Restricted Operations, <strong>and</strong> Technical Review <strong>and</strong> <strong>for</strong> AENV’s St<strong>and</strong>ard <strong>for</strong><br />

Baseline Water—Well Testing <strong>for</strong> Coalbed Methane/Natural <strong>Gas</strong> in Coal Operations, April<br />

2006. If the situation as illustrated below exists, the licensee may not commingle production<br />

using the DE or SD process. If the licensee wishes to commingle production in this<br />

circumstance, an application in accordance with Section 3.1.8 of <strong>Directive</strong> <strong>065</strong> must be<br />

submitted.<br />

ERCB <strong>Directive</strong> <strong>065</strong>: <strong>Resources</strong> <strong>Applications</strong> / Commingled Production (October 2011) • 3-15

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