Notional Field Development Final Report - EBN

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EBN Notional Field Development Plan applicable in the case of direct discharge to surface water. The maximum allowable concentration of salt is also within the range of 150 to 500 mg/l, and also dependent upon where the water will be discharged. Operator needs to obtain a license to discharge surface water, which will require the water treated to near drinking water quality. 4.3.14.3 Re-injection of Water One of the most common disposal methods is the re-injection of these waters back into geological formations. There are a variety of considerations which must be taken into account prior to re-injection. Geological formations must be evaluated to determine injection rates, in order to ascertain whether reinjecting the water is economically and ecologically viable. Geological conditions and formations must be evaluated within the proximity of the drilling operations in order to determine whether any potential salt caverns or depleted reservoirs are present, which can be used to store these waters effectively. Figure 4-31. Diagram of Injection Well 4.3.14.4 Injection into an aquifer The legislation to infiltrate water is very stringent. In some cases, the maximum allowable concentrations are more stringent than for drinking water. In addition, local policies have been developed to preserve precious groundwater, as described in the Grondwaterwet / Infiltratiebesluit (Groundwater legislation). © 2011 Halliburton All Rights Reserved 172
EBN Notional Field Development Plan 4.3.14.5 Injection into a Depleted Oil / Gas Well In the Netherlands, water injection into depleted gas reservoirs is mainly performed by Dutch Oil Company (NAM). Injection first began in 1972 and since 1991 many studies have been conducted including LCA’s (Life Cycle Assessments) and EIA. Water injection into depleted gas reservoirs, both on and offshore is allowed. With respect to the legal framework, offshore injection is slightly different to injection onshore. Current legislation is based on conventional oil and gas production, including regularly used types of chemical additives. Unconventional gas production (e.g. shale gas) differs significantly in terms of type and concentrations of additives which becomes an important issue since an injection permit requires substantial and credible evidence that the (structural) integrity of the geological formation is not compromised. Currently, the Dutch legal framework for underground water injection consists of the following components. 4.3.14.5.1 Mining aspects Mining Act, Mining Decree and Mining Regulation (eg. application for the use of chemical additives, is regulated by paragraph 9.2 ‘Use and discharge of chemicals’ of the Mining regulation). 4.3.14.5.2 Environmental Aspects EU Directives · EU Directive on industrial emissions (integrated pollution prevention and control; 2010/75/EU): focuses on Best Available Techniques (BAT) and relevance in case of underground storage of hazardous waste with a total capacity exceeding 50 tonnes. · EU Directive on waste (2008/98/EU): Definition of ‘Disposal operation D3: Deep injection (eg. injection of pumpable discards into wells, salt domes, or naturally occurring repositories, etc.)’. · National Waste Management Plan. · In the Netherlands, the treatment of waste is regulated by the National Waste Management Plan (NWMP), which is part of the Environmental Management Act. An updated version of the NWMP was published for the period 2009 – 2021 and Chapter 21.17 of this regulation addresses onshore water injection. The NWMP is based on the principle that no substances can be injected, other than substances directly coming from a geological formation. Other relevant aspects are: · The European list of waste materials (Eural) is used to identify the stream of water as hazardous or non-hazardous. In case of conventional gas production, the injection stream is classified as non-hazardous. · Water injection protocol – this protocol provides guidelines to assess the impact of water injection. The terms of the NWMP are met by applying this protocol. © 2011 Halliburton All Rights Reserved 173
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