Guide 56

Energy Development
Application Guide

October 2000

Appendices

Volume 2 of 2

Alberta Energy and Utilities Board

ALBERTA ENERGY AND UTILITIES BOARD
Guide 56: Energy Development Application Guide
3rd edition, October 2000

Published by
Alberta Energy and Utilities Board
640 – 5 Avenue SW
Calgary, Alberta
T2P 3G4

Telephone: (403) 297-8311

Fax: (403) 297-7040

Web site: www.eub.gov.ab.ca

Contents
Appendix 1: EUB Policy and Technical Guidelines
Public Involvement Guidelines ...................................................................................... Appendix 1 / 1
EUB Information Package for Public Consultation................................................. Appendix 1 / 7
Letter from EUB Chief Operating Officer ........................................................ Appendix 1 / 9
Guide 62: Responding to Public Concerns about Oil and Gas in Alberta....... Appendix 1 / 11
Guide 17-2: Well Site Selection and the Surface Landowner ......................... Appendix 1 / 15
Guide 17-3: A pipeline or surface facility on my land? .................................. Appendix 1 / 22
Proliferation Guidelines ............................................................................................... Appendix 1 / 26
Pipelines: Technical Guidelines ................................................................................... Appendix 1 / 28
Production Measurement Guidelines ........................................................................... Appendix 1 / 31
Wells: Technical Guidelines ........................................................................................ Appendix 1 / 33

Appendix 2: The Preservation of Archaeological, Palaeontological, and

Historical Resources .............................................................................................. Appendix 2 / 1

Appendix 3: EUB Interim Directives (IDs)

ID OG–76–2: Emergency Procedure Plans for Sour Gas Facilities............................... Appendix 3 / 1
ID 81–3: Minimum Distance Requirements Separating New Sour Gas Facilities
from Residential and Other Developments.............................................................. Appendix 3 / 2
ID 90–2: Gas Meter Calibration ..................................................................................... Appendix 3 / 4
ID 91–2: Corporate-Level Emergency Response Plans ................................................. Appendix 3 / 5
ID 91–3: Heavy Oil/Oil Sands Operations..................................................................... Appendix 3 / 6
ID 94–1: Measurement of Oil, Gas, and Water Production ......................................... Appendix 3 / 10
ID 95–3: Storage Requirements for the Upstream Petroleum Industry........................ Appendix 3 / 12
ID 96-2: Facility Application Requirements ................................................................ Appendix 3 / 13
ID 96-3: Oilfield Waste Management Requirements for the Upstream
Petroleum Industry................................................................................................. Appendix 3 / 17
ID 97–6: Sour Well Licensing and Drilling Requirements .......................................... Appendix 3 / 21
ID 99-4: Deposition of Oilfield Waste into Landfills................................................... Appendix 3 / 33
ID 99-6: Upstream Petroleum Industry Flaring Requirements .................................... Appendix 3 / 34
ID 99-7: CSA Standard Z662-99 Oil and Gas Pipeline Systems ................................. Appendix 3 / 40
ID 99-8: Noise Control Directive ................................................................................. Appendix 3 / 41
ID 2000-3: Harmonization of Waste Management and Memorandum of
Understanding........................................................................................................ Appendix 3 / 44
ID 2000-4: An Update to the Requirements for the Appropriate Management of
Oilfield Wastes ...................................................................................................... Appendix 3 / 50
ID 2000-7: Licence Eligibility and Qualifications for Potential Licensees and
Agents .................................................................................................................... Appendix 3 / 53
(continued)
Contents (continued)
Appendix 4: EUB Informational Letters (ILs)
IL 82–11: Preservation of Archaeological, Palaeontological, and
Historical Resources: Policy Update ....................................................................... Appendix 4 / 1
IL 84–11: Approval, Monitoring, and Control of Sulphur Storage Sites ....................... Appendix 4 / 4
IL 87–1: Compressibility Factors Used in Gas Volume Calculations and
Physical Property Data for Natural Gases ............................................................... Appendix 4 / 5
IL 87–8: Emergency Response Plans for Sour Gas Facilities ........................................ Appendix 4 / 7
IL 88–5: Application for Approval of Natural-Gas-Driven Compressors...................... Appendix 4 / 8
IL 88–13: Sulphur Recovery Guidelines—Gas Processing Operations ....................... Appendix 4 / 11
IL 89–4: Public Involvement in the Development of Energy Resources ..................... Appendix 4 / 12
IL 89–14: Applications for Gas-Oil Ratio Penalty Relief ............................................ Appendix 4 / 16
IL 90–6: Measurement Guidelines—Trucked Oil Production ..................................... Appendix 4 / 22
IL 90–14: Notification to Transport Canada of Drilling Operations
Near Aerodromes ................................................................................................... Appendix 4 / 25
IL 90–17: Emergency Procedure Plans for Sour Gas Facilities—Biennial Meetings.. Appendix 4 / 27
IL 90–21: Oil and Gas Development—Rumsey Block ................................................ Appendix 4 / 28
IL 91–9: Exemption from Gas Measurement: Crude Oil/Bitumen Wells.................... Appendix 4 / 29
IL 92–8: Crude Oil Pipeline Truck Terminal Measurement Guidelines ...................... Appendix 4 / 31
IL 92–13: Well Name Requirements............................................................................ Appendix 4 / 36
IL 93–1: Gas Density Measurement Frequency—Orifice Meters................................ Appendix 4 / 37
IL 93–9: Oil and Gas Developments Eastern Slopes (Southern Portion)..................... Appendix 4 / 38
IL 93–10: Revised Measurement and Accounting Procedures for Southeastern
Alberta Shallow Gas Wells.................................................................................... Appendix 4 / 40
IL 94–6: Discharge of Produced Liquids to Earthen Structures................................... Appendix 4 / 42
IL 94–17: Notification of Pipeline Project to Conservation and Reclamation (C&R)
Inspectors of Alberta Environmental Protection.................................................... Appendix 4 / 43
IL 98-2: Suspension, Abandonment, Decontamination, and Surface Land
Reclamation of Upstream Oil and Gas Facilities................................................... Appendix 4 / 46
IL 99-2: Use of Produced Sand in Road Construction ................................................. Appendix 4 / 53

Appendix 5: Excerpts from Oil and Gas Legislation

Energy Resources Conservation Act .............................................................................. Appendix 5 / 1
Section 29 ................................................................................................................ Appendix 5 / 1
Section 43 ................................................................................................................ Appendix 5 / 1

(continued)
Contents (continued)
Pipeline Act (Chapter P-8) 1(1)(g) ................................................................................. Appendix 5 / 1
Pipeline Regulation ........................................................................................................ Appendix 5 / 2
Section 50 ................................................................................................................ Appendix 5 / 2
Section 53 ................................................................................................................ Appendix 5 / 2
Section 61 ................................................................................................................ Appendix 5 / 2
Section 68 ................................................................................................................ Appendix 5 / 2
Oil and Gas Conservation Regulations........................................................................... Appendix 5 / 2
Part 2: Licensing of Wells........................................................................................ Appendix 5 / 2
2.090.................................................................................................................. Appendix 5 / 2
2.110.................................................................................................................. Appendix 5 / 2
2.120.................................................................................................................. Appendix 5 / 3
Part 7: Production Operations 7.070........................................................................ Appendix 5 / 3
Part 8: Prevention of Losses, Injuries, Damages and Fires...................................... Appendix 5 / 3
Part 11: Well Data 11.010...................................................................................... Appendix 5 / 17
Part 13: Well and Battery Names 13.020............................................................... Appendix 5 / 17
Equipment Spacing Diagram........................................................................................ Appendix 5 / 18

Appendix 6: Unique Well Identifier ........................................................................... Appendix 6 / 1

Appendix 7: Unique Facility Identifier....................................................................... Appendix 7 / 1

Appendix 8: Reference List ......................................................................................... Appendix 8 / 1

Appendix 9: Forms....................................................................................................... Appendix 9 / 1

Appendix 10: Glossary............................................................................................... Appendix 10 / 1

BLANK PAGE
APPENDIX 1—EUB POLICY AND TECHNICAL GUIDELINES

Public Involvement Guidelines

PURPOSE OF THE GUIDELINES and/or people working in the area, as well as

local authorities. The EUB considers it
The Alberta Energy and Utilities Board (EUB)
paramount that effective communication take
is providing you with these guidelines and
place among industry, government, and the
minimum expectations to assist you in carrying
public so that concerns may be raised, properly
out your public disclosure and consultation
addressed, and if possible resolved. All parties
program prior to submitting an Energy
should work cooperatively for the energy
Development Application. However, the EUB
development process to be effective.
cannot predetermine the precise extent and
scope of your public disclosure and consultation
program, because every application is unique BEFORE YOU SUBMIT AN APPLICATION
and each project may present circumstances that
The EUB considers your public disclosure and
must be dealt with on an individual basis.
consultation program to be an extremely
important precursor to filing your Energy
The EUB expects you, as the proponent, to
Development Application. You are expected to
assume your responsibilities for involving the
take your public involvement responsibilities
public and to be alert to and recognize
and obligations seriously. All of the activities
circumstances or applications where your public
outlined in these guidelines and references must
disclosure and consultation program should
be carried out before you submit your
exceed the minimum requirements and
application.
recommendations of these guidelines.
Your approval may be suspended if your
These guidelines apply to all new facilities and
responses to the public involvement questions
all modifications to existing facilities. The
on your application are subsequently found to be
guidelines are to be used in conjunction with
false or inaccurate.
EUB Guide 56: Energy Development
Application Guide.
PUBLIC DISCLOSURE AND CONSULTATION
ENERGY DEVELOPMENT: Failure to adequately consult with the public
A COOPERATIVE VENTURE may have serious consequences. The EUB is
required by statute to consider objections to its
The EUB is responsible for the economic,
issuance of an approval raised by persons whose
orderly, and efficient development in the public
rights may be directly and adversely affected by
interest of the energy resources of Alberta.
the decision (see Section 29 of the Energy
When considering energy development
Resources Conservation Act [ERCA] in
applications, the EUB is obliged to treat all
Appendix 5). In addition, following approval of
parties fairly. This fairness of treatment requires
an application, a person whose rights may be
that all parties who are or may be affected are
directly and adversely affected may request a
entitled to be made aware of energy
hearing and suspension of the approval if a
developments, to voice their concerns, and to
hearing was not held. The EUB may hold a
have their concerns heard. An affected party is a
hearing to consider the application, provided
person whose rights may be directly and
such a request is made within 30 days of the
adversely affected.
issuance of the approval/licence (see Section 43
of the ERCA in Appendix 5). If a member of the
The EUB recognizes that all energy
public identified on Table 1.3: Minimum Public
developments may affect landowners, residents,
Disclosure and Consultation Requirements

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 1
(Schedule 1) was not notified, the EUB will
consider requests beyond the 30 days.
The EUB does not precisely define the scope of
your public disclosure and consultation
program, however; it does expect that the level
of public involvement will reflect the
complexity of the project. The minimum
requirements prescribed vary with the type of
well, facility, or pipeline and reflect an attempt
to define a reasonable distance to identify
potentially affected parties.
These requirements must not be viewed as a
maximum. Different areas of the province may
also influence public expectations for contact
and disclosure. Your program needs to address
public expectations regarding consultation, as
well as issues unique to the area.
You are expected to be proactive and ensure that
technical information is conveyed in a manner
understandable to the public. Your project
should be discussed with the widest possible
audience as early in the planning stages as
practical.
Where personal consultation is required, you
must make all reasonable attempts to personally
contact parties, as specified in Table 1.3,
provide a written description of the project,
discuss the project, and address any questions
and concerns. If you are unable to personally
contact a party as required on Schedule 1, check
the “No” box under 3: Consultation
Requirements, item (2), and provide sufficient
documentation to illustrate your attempts at
personal consultation.
As part of your public disclosure, you are
required to provide project-specific information
in writing to the parties within the radius
indicated in the table and any others that you
have identified.
The EUB encourages you to continue public
communication throughout the life of the
project.
2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
PUBLIC OBJECTIONS AND/OR CONCERNS
As a company, you are expected to attempt to
address objections and/or concerns raised by
members of the public and to reconcile
differences where possible. You must indicate
any outstanding objections and/or concerns you
are aware of, whether the party is inside or
outside the minimum radius specified in Table
1.3, by checking the appropriate box on
Schedule 1. You must attach a written summary
of the outstanding issues when submitting an
application. In such cases, the EUB considers
the application nonroutine and will review the
circumstances in conjunction with its
consideration of the application. If the issues are
not resolved, the EUB may hold a hearing to
consider the application.
Should dispute arise, the EUB expects the
parties to discuss the issues and options for
resolution and strongly encourages the use of
third-party mediators. EUB staff, if requested,
can assist in explaining EUB requirements and
processes and in facilitation. Additional
information in this regard may be found on the
EUB’s Web site under the Appropriate Dispute
Resolution (ADR) Initiative.
DISCLOSURE AND CONSULTATION
RESPONSIBILITIES OF THE PROPONENT
Public Disclosure and Consultation Program
In planning your public disclosure and
consultation program, you will need to complete
the following prior to submitting an application:
• Identify parties whose rights may be directly
and adversely affected in your project area,
such as landowners, residents, occupants,
grazing leaseholders, trappers, and
outfitters.
• Identify and communicate with aboriginal,
environmental, and other groups who may
be interested in your application.
• Identify special sensitivities that exist in the
area. To achieve this, the EUB recommends
that you talk to local residents and other
operators and develop an effective
 communication plan that involves affected
parties at an early stage of planning.
• Begin your public involvement program
before you finalize pipeline routing or well
or facility location, and before you submit
your application.
• Provide sufficient information to the public
for them to assess the impact of the
proposed development and to participate
meaningfully in the decision-making
process concerning the proposed
development. To accomplish this, your
program should provide all interested
parties with the opportunity to obtain
adequate information of the proposal and its
possible impacts.
• Provide documented information about your
project that is consistent and factual.
If your proposal is part of a larger project, you
should be prepared to discuss the entire project
and to explain how your component
complements other energy development in the
area. A company representative with full
knowledge of the issues and concerns should
personally contact any affected parties to
discuss the project. Broader public meetings or
open houses and discussions may also be
necessary in some cases.
Should issues arise that you would like the EUB
to comment on, you may call the applicable
EUB field office. However, you should only do
this after you have investigated the situation and
discussed your proposal with parties who may
be affected.
MINIMUM INFORMATION REQUIREMENTS
Your public involvement program must include
the distribution of information that meets the
minimum requirements outlined below. In
accordance with the public disclosure and
consultation requirements, you must provide the
public with project-specific information so that
they may raise issues and discuss concerns
during the initial planning stages. Because each
project is unique, the EUB cannot specify every
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 3
item that must be raised for your project. The
EUB requires you to provide the following two
sets of information:
1) A copy of the EUB information contained in
the Information Package for Public
Consultation (see page 7). This includes a
covering letter signed by the Chief
Operating Officer of the EUB and Guides
62, 17-2, and 17-3. This information may be
obtained from the EUB Web site or
obtained in brochure format from EUB
Information Services. Updated guides will
be available later in the year.
2) A company package that contains the
following information and any additional
data necessary to address any unique
features of your proposed application:
• applicant information, including
company name, contact person, and
phone number
• full description of the proposed
development, including facility location
and type
• type of substance to be produced or
handled and the presence, if any, of
hydrogen sulphide (H2S) in units of
moles per kilomole and percentage
• a brief description of how the
development complements or is part of
the existing development in the area
• project scheduling and the proposed
date of development initiation and
construction
Depending upon the nature of the applied-for
well, pipeline, or facility, you must also include
relevant information on the following technical
issues as applicable:
• a description of the potential impacts that
may occur from the proposed development
• a brief description of the equipment to be
installed (e.g., number and size of tanks,
size of buildings, safety features)
• type of flaring (continuous or intermittent),
and results of evaluations and explanation
of alternatives (as per EUB Guide 60:
Upstream Petroleum Industry Flaring
Guide, Sections 2.3 and 2.5)
• possible sources of odours and proposed
measures to control or eliminate them
• scope of emissions and control measures
• noise sources at the well, pipeline, or
facility and mitigative measures
• amount and type of vehicular traffic
• an example of a similar existing facility,
preferably in the area (a tour of a similar
facility may be an option to consider where
feasible and warranted)
• implications of any setback restrictions on
surface land use (as per ID 81-3 and ID 97-6
[see Appendix 3])
• details of any emergency response plans in
place
EMERGENCY RESPONSE PLANNING
Where a site-specific emergency response plan
is required prior to drilling or start-up of new
facilities or pipelines, the EUB expects you to
notify the public within the emergency planning
zone during project planning and before you
apply to the EUB.
SETBACK REQUIREMENTS
• You must inform landowners and occupants
within the sour setback distances set out in
ID 81-3 or ID 97-6 (see Appendix 3) of any
land-use restrictions that may apply due to a
new or amended energy development.
• The EUB’s regulatory setback requirements
as set out in Sections 2.090, 2.110 and 2.120
of the Oil and Gas Conservation
Regulations are discussed in Appendix 1,
Wells—Technical Guidelines.
4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
PROGRAM AUDITS
The EUB conducts audits of energy
development applications. Therefore you must
keep detailed documentation of your public
disclosure and consultation program and provide
it to EUB staff upon request.
PUBLIC CONSULTATION CASE HISTORIES
BEYOND MINIMUM REQUIREMENTS
Section 29 of the ERCA requires the EUB to
ensure that all potentially adversely affected
parties have the opportunity to comprehend the
facts of an application, furnish evidence relevant
to the application, and provide input to the
EUB’s decision process.
There are frequently cases where public
disclosure and consultation beyond the
minimum are appropriate. The following two
figures illustrate five cases where an after-the-
fact objection has resulted in suspension of a
licence and initiation of discussion between an
applicant and resident under less than ideal
circumstances. You must understand the
purpose of the public disclosure and
consultation requirements and assess your area
for similar examples where contact is
appropriate.
In case 1, Figure 1, the well location is
strategically positioned to exclude residents
outside of the 0.2 km minimum personal
consultation radius, as outlined in Table 1.3. A
freehold surface lease has been granted by the
northwest quarter landowner. However, the
applicant failed to initiate discussions with
residents adjacent and downwind of the
proposed well. Shifting the radius to place
residents a few metres outside of minimum
consultation area to avoid contact is
unacceptable.
In case 2, Figure 1, a resident in the section to
the south filed a detailed letter of concern with
the applicant, citing public safety issues and a
special land-use (as a certified seed grower) and
requested additional information and a meeting.
The letter was received and ignored by applicant
based on distance separation. Failure to act on
this request is unacceptable given that the
Figure 1
minimum consultation radius is not the
maximum and only the EUB can weigh the
merits of a concern. Both cases 1 and 2 reflect
unacceptable consultation.
In Figure 2, the applicant conducted full public
disclosure and consultation within the
emergency planning zone radius, in accordance
with Table 1.3. In case 3, Figure 2, there was no
review or consideration of special needs—a
summer camp for disabled children was not
contacted. In case 4, Figure 2, the resident in the
northeast quarter of Section 19, affected by an
emergency planning zone on their egress, was
also not contacted. In case 5, Figure 2, partial
consultation of hamlet residents in the northwest
quarter of Section 16 and the southwest quarter
of Section 21 occurred, while the applicant
simultaneously selected to ignore adjacent
neighbours across the road. Failure to consult
with these three example parties is deemed by
the EUB as unacceptable.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 5
Figure 2
REFERENCES
You should use the following references when
developing your public notification and personal
consultation program:
• ID 81-3: Minimum Distance Requirements
(see Appendix 3)
• IL 89-4: Public Involvement in the
Development of Energy Resources, which
provides guidelines you are expected to use
for all new and existing facilities (see
Appendix 4)
• IL 93-9: Oil and Gas Developments Eastern
Slopes (Southern Portion), which outlines
public involvement expectations for the
Eastern Slopes region (see Appendix 4)
• ID 97-6: Sour Well Licensing and Drilling
Requirements, which specifies minimum
distance requirements separating sour wells
from residential and other developments
(see Appendix 3)
6 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
EUB Information Package for Public Consultation

• Letter from EUB Chief Operating Officer

• Guide 62: Responding to Public Concerns about Oil and Gas in Alberta
• Guide 17-2: Well Site Selection and the Surface Landowner
• Guide 17-3: A pipeline or surface facility on my land?

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 7
BLANK PAGE
October 24, 2000

Dear Landowner:

You have been approached by a petroleum company that wants to make an application to the Alberta
Energy and Utilities Board (EUB) for an energy development project (a facility, pipeline, or well) on
your or your neighbours’ lands. As part of the application requirements, the company making this
application to the EUB must provide you with a detailed information package.

It includes what your options are if you disagree with or have concerns about the petroleum
development being proposed. This package also contains information about the EUB’s roles and
responsibilities in the regulation of Alberta’s energy developments and how we can help you. It
includes telephone numbers for both the EUB’s Calgary headquarters and the eight EUB Field
Centres located throughout the province. Please use these numbers to call the EUB for assistance.

The petroleum company you are now dealing with is required to provide you with enough
information about its proposed project, so that you understand
• the facts of the proposal, and
• its possible impacts upon you.

The company must also provide you with the opportunity to have all your questions answered so that
you may participate meaningfully in the decision-making process. Your participation in the
application process is important.

The EUB encourages you to study the information contained in the company package and then meet
with company representatives to discuss the proposal, including any measures that could be in place
to reduce potential impacts and any alternatives that may exist. If you have questions or concerns
before or following your discussions with the company, you may call the EUB for assistance.

If there are matters that cannot be resolved, the EUB can provide you with more information on its
adjudicative process, including information on Appropriate Dispute Resolution (ADR). Unresolved
issues may result in the EUB holding a public hearing to consider the application. However, the EUB
encourages all parties to attempt to cooperatively reach agreement.

If you find that the information contained in the package is difficult to understand, or you have
questions you would like answered, please call the EUB for assistance at the numbers listed on
the back of this letter.

Additional information about the EUB and its regulations may be found on our Web site at
<www.eub.gov.ab.ca>.

Sincerely,

Earle Shirley
Chief Operating Officer

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 • 9

 Alberta Energy and R.10 R.20 R.10 R.10
Utilities Board
W ood
Buffalo
T.120 National T.120
Telephone Numbers* for Park

EUB Field Centres

T.110 T.110
Bonnyville
(780) 826-5352
T.100 T.100

Fourth M eridian
Drayton Valley

Fifth M eridian
Sixth M eridian
(780) 542-5182
T.90 T.90
Grande Prairie
FortM cM urray
(780) 538-5138 11 5 3 1 25 23 19 17 15 13 11 9 7
7 5 3 1 23 21 19 15 13 11 9 7 5 3 1

T.80 T.80

Red Deer G rande Prairie

B onnyville
Field C entre
(403) 340-5454 Field C entre
Grande Prairie
T.70 T.70

St. Albert
(780) 460-3800 St.Albert
Field C entre
Bonnyville
T.60 T.60

Southern Region
St.Albert
D rayton Valley
Field C entre Edm onton
- Midnapore T.50

(403) 297-8303 Jasper

Drayton Valley

National
W ainw right
7 5 3 1
13 11 9

- Medicine Hat Park

19 17 15 13 11 9 7 5 3 1 27 25 23 21 19 15
T.40

(403) 527-3385 Red Deer

W ainw right
Field C entre
R ed D eer
Field C entre
Wainwright Banff T.30

(780) 842-7570 National

Park

Calgary
M idnapore
T.20

EUB Calgary Facilities Southern R egion

Alberta Energy and Utilities Board Field C entre M edicine
Applications Group Hat

Field C entre Boundaries T.10

Martin Vandenbeld Field C entre Location

(403) 297-8135
Re-issued W aterton
October2000 Nat.Park R.10
R.30 R.20
Stephen Smith
(403) 297-8306

Agnes Wiechert
(403) 297-8201
About
E-mail address:
<Guide56.help@eub.gov.ab.ca>
*For toll-free access to all
EUB numbers, dial 310-0000
and follow the instructions to
directly reach the EUB.
About the Alberta Energy and Utilities Board (EUB)
Who we are: The EUB is an independent, quasi-judicial agency
that regulates Alberta’s energy resource and utility sectors.
What we do: The EUB ensures that the discovery, development,
and delivery of Alberta’s resources take place in manner that is
fair, responsible, and in the public interest.

10 • EUB Guide 56: Energy Development Guide, Volume 2 / Appendix 1

Guide 62: Responding to Public Concerns about Oil and Gas in Alberta
November 1999
About This Guide
The Alberta Energy and Utilities Board's (EUB)
regulatory role puts us in a unique position to hear
and deal with public concerns about oil and gas
operations in this province. This information
summarizes concerns and what is being done about
them.
The purpose of this guide is to improve public
awareness of the many existing and new ways to
promote resolution of issues between landowners and
the petroleum industry. The EUB encourages
companies and residents to take full advantage of
these measures.
This guide is best viewed on the EUB Web site
http://www.eub.gov.ab.ca as the electronic version
has direct links to other supporting documents. If you
do not have access to the Internet, paper copies of
EUB materials are available from EUB Information
Services.
1 How the EUB Responds to Public Complaints
We encourage residents with concerns about new or
existing oil and gas developments and facilities to
contact the operating company first. Our experience
suggests direct contact with the company results in
faster responses, the resolution of many issues, and
better industry-public relations. Most companies are
good neighbours and work well with landowners.
If the company doesn't respond appropriately or if
you don't want to call it first, phone the nearest EUB
field centre, all of which provide 24-hour on-call
service. There are eight field centres across the
province whose inspectors are available to respond to
and investigate all public complaints on a priority
basis. The most common complaints relate to odours,
public safety issues, flaring, smoke, noise, and spills.
Complaints outside our jurisdiction are forwarded to
the appropriate agency. These include Alberta
Environment (AENV), Alberta Agriculture, Alberta
Food and Rural Development (AFRD), regional
health authorities, local municipalities, and the
RCMP. It's important to know that the EUB does not
handle compensation disagreements; these are
referred to the Surface Rights Board.
The EUB also supports and participates in the
formation of community advisory groups. These
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 11
groups provide citizens with an ongoing forum for
raising concerns about future development plans and
specific facilities operated by a number of companies
in a larger region.
For more information
• EUB Guide 17-2: Well Site Selection and the
Surface Owner
• EUB Guide 17-3: Pipeline and Surface Rights-A
Guide for Landowners and Occupants
• EUB Guide 38A: Dealing with Energy Industry
Noise
• EUB Guide 50-1: A Landowner's Guide to
Drilling Waste Disposal from Oil and Gas Wells
• AFRD brochure "Negotiating Surface Rights"
2 Expectations for Public Notification and
Consultation
The EUB believes everyone--landowners,
communities, local governments, interest groups, and
companies--must work together in an open and
honest manner from the beginning of a project's
development to ensure good relations throughout the
life of an energy project.
When considering new facility applications, the EUB
is obliged by law to treat all parties fairly. For
example, people affected by a project are entitled to
know what is being proposed and to have their
concerns addressed. Consultation must take place
before a company files an application with us,
preferably before the final location of a facility or
pipeline route is decided. Of the thousands of
applications we receive every year, most are
approved routinely because they meet all site and
environmental requirements, public concerns have
been resolved, and landowners and adjacent residents
have agreed to the location. If concerns are not
resolved, our staff review the application in greater
detail and do not grant approval until all issues under
our jurisdiction are addressed.
The first stage of public consultation is often a
notification process. Companies must identify and
contact those who may be directly affected by the
project. The EUB has guidelines for notifying people
who own or occupy land affected by wells, pipelines,
and oil and gas facilities. This process is used to
confirm that landowners are aware of and agree to a
proposed project. The company must include this
information in its application.
However, public consultation often has wider
community implications. Although each application
is unique, the EUB expects companies, at a
minimum, to
• communicate with people as early as possible to
ensure that special sensitivities are addressed
during project planning,
• provide full disclosure and consistent, factual
information about the project and its impacts to
allow for meaningful public input into decisions,
• discuss the potential scope of the project and
how it relates to other nearby development,
• for sour gas projects, communicate with
residents within an emergency planning zone
during early project preparations,
• inform people about land-use restrictions that
may occur because of sour gas setback
requirements, and
• provide information about the regulatory process
and how people can participate.
The EUB expects industry to use the Guide for
Effective Public Involvement, published by the
Canadian Association of Petroleum Producers
(CAPP). This guide sets out good industry practices
for responsible community involvement in resource
exploration and development. To receive a copy of
the guide, call CAPP directly at (403) 267-1100.
For more information
• EUB Informational Letter 89-4: Public
Involvement in the Development of Energy
Resources
• EUB Guide 56: Energy Development
Application Guide and Schedules, Appendix 1,
Section 1, "Public Involvement Guidelines"
• EUB Informational Letter 93-9: Oil and Gas
Developments-Eastern Slopes
3 New Options to Resolve Landowner-Industry
Disputes
Facilitation can help
The EUB is responding to heightened public concern
in new ways. For example, we are strengthening our
practice of making staff available to facilitate early
discussions between landowners and companies for
new oil and gas wells and facilities. The goal is to
identify and promote resolution of conflicts before
they intensify.
Although not yet required, we are also looking at
other dispute resolution tools such as company-
sponsored consultation or negotiation and third-party
mediation. The EUB encourages senior company
officials to meet with those affected during
12 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
mediation. If appropriate, the EUB will also make
senior technical staff or, occasionally, a Board
Member available to facilitate landowner-applicant
discussions. Even if these efforts do not resolve all
issues, they may narrow the scope of matters that
could be considered at a hearing.
When objections or concerns cannot be resolved, an
EUB hearing may be required. Hearings meet the
EUB's fairness requirement by providing all parties
affected by an application with the opportunity to
have their concerns considered.
For more information
• EUB Guide 29: Hearings
• EUB Guide 31: Guidelines Respecting
Applications for Local Interveners' Costs Awards
New directions for surveillance and enforcement
The EUB has been criticized for reducing field staff
and inspections in recent years. However, we remain
committed to our surveillance and inspection role.
With major resources dedicated to this area, we can
better ensure that companies comply with our
requirements and respond appropriately to landowner
concerns.
Despite resource constraints in the early to mid-'90s,
the EUB's development of modern inspection and
enforcement methods has let us work more
efficiently. Take rig inspections, for example. We
now assess an operator's history, evaluate site
sensitivity, and identify risks, such as the presence of
sour gas. This helps us target our inspections and is
more effective than doing them on a random or quota
basis.
Landowners can be assured that we will act firmly
and fairly when an operator breaks the rules. We
have recently improved our enforcement by
establishing a system of escalating consequences for
minor, major, and serious noncompliance events. Our
actions always include deadlines for fixing a problem
and may be reinforced by penalties, such as
temporary or long-term suspension of operations,
closure or refusal of applications, and even
prosecution.
For more information
• EUB Informational Letter 99-04: EUB
Enforcement Process, Generic Enforcement
Ladder, and Field Surveillance Enforcement
Ladder
4 Soil and Water Quality Concerns
The EUB is aware of public concerns related to soil
and water contamination from oil and gas activity,
although they are often not within our jurisdiction.
We require petroleum facilities to be designed and
operated to prevent spills and minimize the risk of
contamination. When spills occur, we expect
companies to clean them up quickly. If they need
extra help, an extensive network of oil spill
cooperatives is equipped to respond quickly
anywhere in Alberta.
To deal with soil and water concerns, we advise you
to contact the operating company and the appropriate
government department. EUB field staff can help you
make these contacts and are in regular contact with
Alberta Environment (AENV).
Soil contamination
Through a mutual agreement, the EUB and AENV
share similar but distinct responsibilities for soil
contamination. The EUB looks after problems related
to initial containment and cleanup of spills of
unrefined petroleum products; AENV deals with soil
contamination resulting from these spills. Depending
on the nature of the complaint, you should contact the
company, the EUB, or AENV. If you're not sure
whom to call, EUB field staff can refer you to the
right agency.
Water well or water quality concerns
AENV also has responsibility for water well
contamination concerns. Landowner calls to the EUB
are directed to AENV for initial investigation. If
AENV officials suspect oil and gas industry activity
has caused contamination, the EUB participates in
the investigation and efforts to resolve the matter.
Concerns about possible contamination of water
wells should be directed to the Water Management
Division of AENV at (780) 449-3463.
For more information, see AENV's Web site for a
complete list of contacts at http://www.gov.ab.ca/env.
5 Flaring
Flaring has become a prominent source of public
concern related to human and animal health. Many
groups are working to improve this situation.
Solution gas flaring
Solution gas is a by-product of oil production. The
EUB has long required operators to recover solution
gas if it is economic to do so. As a result, Alberta
conserves about 94 per cent of all solution gas
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 13
produced. The rest is typically treated as a waste
stream and flared.
In July 1999, the EUB released a new flaring guide
(Guide 60) based on recommendations of the Clean
Air Strategic Alliance (CASA), a multistakeholder
group of public representatives, special-interest
groups, industry, and government departments and
agencies. The aim is to reduce upstream solution gas
flaring by 15 per cent from 1996 levels by the end of
2000. This will increase to a 25-per-cent reduction by
2001. These targets are firm, and we are
implementing regulatory measures to ensure industry
compliance. Future CASA targets will be re-
evaluated in 2001.
Well test flaring
EUB records show that most flaring from well testing
occurs during initial tests to determine a well's
capability. The EUB is committed to minimizing
volumes flared during well tests. For example, Guide
40 promotes reducing or eliminating well test flaring
where possible. Options include in-line testing
through a pipeline to a processing facility, which
eliminates flaring. While not all cases allow for this,
we encourage companies to use in-line testing where
it is safe and feasible.
As of January 1, 2000, EUB Guide 60 requires a
company to have various approvals before well test
flaring can take place. Depending on the
circumstances, these can include special permits,
EUB approval for higher flare volumes, and
notification of nearby residents and communities.
EUB field centres must also be notified at least 24
hours before the test.
For more information
• EUB Guide 60: Upstream Petroleum Industry
Flaring Guide
• EUB Guide 40: Pressure and Deliverability
Testing Oil and Gas Wells
• EUB News Release 1999-07-29: "EUB adopts
new upstream petroleum industry flaring Guide
60" (includes backgrounder on flaring)
6 Animal Health
An agreement involving five agencies--the EUB,
AFRD, AENV, the Alberta Cattle Commission, and
CAPP--established new guidelines for dealing more
effectively with animal health issues between the
agricultural community and the petroleum industry.
The key piece is a protocol for investigating animal
health incidents using a qualified, independent
veterinarian known as the Animal Health Additional reading material
Investigator. The following documents are available at no cost
from EUB Information Services or via the EUB Web
The agreement details the primary roles, site.
responsibilities, and expectations of the five agencies
and associations, the Animal Health Investigator, the • General information about the EUB
oil and gas facility operator, and the livestock owner. ! Guide 57-1a: The EUB and Energy
For example, if there is a suspected problem, Regulation
livestock owners should keep animals away from ! ST 99-40: Alberta's Energy Resources 1998
areas of concern. They should contact their own in Review
veterinarian, call the EUB to start the investigation ! ST 99-41: Regulatory Highlights for 1998
process, and work with other agencies to provide
access to land, livestock, and records. Farmers and • EUB contacts
ranchers would be well served to keep a diary and
take photos, if required. Calgary Office
640 - 5 Avenue SW
Although the agreement is still in draft form and Calgary, Alberta T2P 3G4
subject to minor revision, the agricultural community Main switchboard: (403) 297-8311*
has been using the services of the Animal Health Communications: (403) 297-4601*
Investigator since September 1998. The EUB urges
people to continue this practice. If you have an EUB field centres (24-hour on-call)
animal health-related concern, contact the EUB field Bonnyville (780) 826-5352*
centre nearest to you. Calgary (403) 297-8303*
Drayton Valley (780) 542-5182*
7 More Information Grande Prairie (780) 538-5138*
Medicine Hat (403) 527-3385*
Note that except for major guides, most EUB Red Deer (403) 340-5454*
documents listed in this brochure are available free of St. Albert (780) 460-3800*
charge to individuals at either Wainwright (780) 842-7570*

• EUB Web site: http://www.eub.gov.ab.ca
The EUB's Web site contains an up-to-date
catalogue of all EUB publications, maps, and
services, as well as an extensive document
repository.
To access the document repository once you are
in the EUB Homepage, click on the "Access
Docs" icon. This will give you lists of the many
documents such as Acts and Regulations,
decisions, guides, reports, news releases, and
more that are available directly from the Web
site. This brochure is listed as Guide 62, and all
additional reading materials referenced here are
linked electronically for your convenience.
* All phone numbers referenced in this publication
are part of the provincial government's RITEdirect
telephone system. RITEdirect is a toll-free, long-
distance service that public callers can use to reach
Alberta Government offices. Anyone outside Calgary
wishing to call toll free should dial 310-0000 and
then enter the seven-digit local number to connect or
press zero and hold for a RITE operator.
November 1999 edition

EUB Information Services

640 - 5 Avenue SW, main floor
Calgary, Alberta T2P 3G4
Tel: (403) 297-8190*

14 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
EUB Guide 17-2: Well Site Selection and the Surface Landowner
An oil or gas well on my land? Consider directional drilling
Land-use considerations
A company has approached you and wants to drill a Domestic water wells
well on your land, or on your neighbour’s land. You Other site restrictions
and the company will be discussing the potential
impact on you, mitigation measures, and alternatives. PART 3: WHAT HAPPENS DURING
You may also be negotiating a surface lease NEGOTIATIONS?
agreement on a location for the well and access road, Case 1: Both parties agree on the site
and discussing compensation. Case 2: You disagree on the site
The EUB public hearing process
The first things most landowners or residents want to
Case 3: You disagree on compensation
know are: “What are my rights?” and “What choices
do I have?” First, you have the right to be fully
PART 4: WHAT HAPPENS AFTER
informed at each step of the process.
DRILLING?
This booklet is intended to help you understand your
rights and choices and aid you in your negotiations. It USEFUL REFERENCES
also describes a company’s obligations under OTHER AGENCIES TO HELP YOU
provincial legislation regarding the licensing and EUB CONTACTS AND FIELD CENTRES
drilling of oil and gas wells.

This booklet answers the most common questions we The Alberta Energy and Utilities Board (EUB)
receive at the EUB from landowners. If you have ensures that the discovery, development, and
additional questions, or if you need more information, delivery of Alberta’s resources take place in a
please contact: manner that is fair, responsible, and in the public
interest.
Facilities Applications
Applications Branch Part 1 Understanding your rights
Alberta Energy and Utilities Board
640 - 5 Avenue SW The right to survey on your land
Calgary, Alberta
T2P 3G4 A company may enter your land to survey
Help Line: (403) 297-4369*
Fax: (403) 297-2143 One of the first steps in the well site selection process
Web site: http://www.eub.gov.ab.ca is a survey. The company needs a survey to identify
the exact location of the well and the surface area
*For toll-free access, dial 310-0000 and ask the RITE required. Under the Alberta Surveys Act, the surveyor
operator for the EUB number required. has the right to enter your property to survey after
making a reasonable attempt to notify you. It is
common practice—and common courtesy—for a
company representative to call on you before
Contents surveying. The purpose of the visit will be to advise
you of the approximate well and road location. The
PART 1: UNDERSTANDING
company is responsible for the cost of any damages
YOUR RIGHTS
caused by the survey.
The right to survey on your land
Mutual rights to use land
The right to enter your land Mutual rights to use land
The right to information
Surface owners and mineral owners share the right to
PART 2: SELECTING A WELL SITE use land

Well spacing units and target areas For any parcel of land in Alberta, there are two titles
Geological considerations and two sets of rights. The surface title gives you

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 15
ownership of the surface of the land and the right to
work it. The mineral title gives the company or
person who owns the minerals under that land the
right to explore for oil and gas. The mineral owner
needs access to the land surface to drill and produce
oil and gas.
Two important conditions apply to the company’s
right to explore. First, drilling and production activity
must be done in a way that is environmentally and
technically acceptable. Second, a company must
operate in ways that cause the least possible
interference with your use of the land.
The right to enter your land
The company has the right to enter land to explore for
minerals
The company must have approvals in place before
entry onto the land. Normally, this would include a
surface lease from you and a drilling licence from the
EUB.
If you and the company are unable to agree on a
surface lease, the company must still obtain a drilling
licence from the EUB and then a right-of-entry order
from the Surface Rights Board (SRB). The right-of-
entry order gives the company the authority to enter
your land to drill the well. If the company proposes to
drill an additional well on an existing lease, the
company must still have your approval and deal with
any concerns you may have about the extra well.
The right to information
Under EUB regulations and guidelines, the company
must provide information to all potentially affected
parties so they can fully understand what is being
proposed. If you are concerned about surface impacts,
the company should give you details about how it
chose the well site and access road location. The
company should also tell you what to expect in terms
of equipment and operations during the production
phase.
If you have concerns or questions about drilling or
production operations, do not hesitate to raise them.
The company should be prepared to answer your
questions in writing. Some questions to consider are:
• Where exactly will the well be located?
• How much surface area is required?
• What other locations are possible if I don’t like
the company’s preferred site?
16 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
• Are there any constraints or restrictions on
relocating the site?
• What access road route is proposed?
• When will the operation start and finish?
• What construction will be required before
drilling starts?
• How will topsoil be conserved?
• How will weeds be controlled during drilling and
production phases?
• How and when will the site be cleaned up after
drilling is completed?
• If no oil or gas is found and the well is
abandoned, what surface reclamation will be
carried out? When?
• If the well is a producer, what surface equipment
may be required? Where will it be located on the
lease? Will these facilities be temporary or
permanent?
• Are there plans to consolidate production
facilities?
• Are there plans to expand the site?
• Are there plans to conserve solution gas? Where?
When? (Solution gas is natural gas produced in
association with oil.)
• Will a power line be needed? Will the power line
be overhead or underground?
• How much noise will there be during drilling and
production? What are the alternatives to reduce
noise levels?
• What safety precautions are there for drilling and
production operations?
• Will there be any land-use or setback
restrictions? (A setback is the minimum distance
that must be maintained between an energy
facility and other surface developments.)
• Will oil be trucked or pipelined from
the well?
• Will the well encounter hydrogen sulphide (sour
gas)? If so, what emergency procedures are in
place?
You may wish to pursue these or other questions in
greater detail. You are entitled to have the company
answer fully.
If you are not getting answers or need information
about regulations that apply to oil and gas wells,
please contact the EUB. Use the government’s RITE
telephone system free of charge, or call collect. The
phone numbers are listed at the back of this guide.
PART 2
Selecting a Well Site
In selecting a well site, the company considers
subsurface geology, land surface conditions, current
and potential land use, environmental sensitivity, and
reclamation.

Well spacing units and target areas

Well spacing regulations can affect the location of a

well

The subsurface location for a well is subject to

spacing units and target areas imposed by the EUB.
These requirements are designed to ensure efficient common target area if there is a chance to encounter
recovery of oil and gas and to protect the rights of both oil and gas.
adjacent mineral owners.

The spacing unit for gas wells in Alberta is normally

one well per section of land. Inside the spacing unit is
a target area where the bottom of the well should end.
The gas target area is the centre 100 hectares (250
acres) of the section, as shown in the diagram below.

There are many areas in Alberta where spacing units

Keep in mind that the target area dictates the
subsurface location for a well, not the surface
location.
The spacing unit for oil wells in Alberta is normally
one well per quarter section of land.
The oil target area is the northeastern 16 hectares
(40 acres) of the quarter section, as shown in the
diagram below.
Together, the oil and gas target areas overlap and
form a common target area, as shown in the shaded
portions below. Many companies prefer to drill the
and target areas vary from the norm. These include:
• parts of eastern Alberta where spacing units
allow four gas wells per section
• older oilfields in which several different patterns
may have been used
• heavy oil areas in eastern Alberta where there
may be four, eight, or more wells in each quarter
section
Drilling a well outside the target area may result in
the company being penalized by the EUB. The
penalty is reduced production from the well.
If you disagree with a proposed well location, you
should ask the company representative to sketch the
spacing unit and target area for the well. This will
help you determine if there is flexibility for moving
the well site. You should ask the company if it has
looked into changing the target area or directionally

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 17
drilling the well from a different surface location.
(Directional drilling means drilling the well
diagonally instead of vertically.)
Geological considerations
Geologic and seismic data are important in choosing
the well site
The company will normally select a well location
based on the geology of nearby wells or on seismic
information. Some of the company’s information may
be confidential. However, the company should give
you basic geologic information so that you know what
restrictions there may be on moving the well.
Moving away from the best geologic location could
increase the risk of drilling a dry hole or recovering
less oil or gas.
Consider directional drilling
If you are having difficulty agreeing on a site,
directional drilling could be a solution
Sometimes landowners have a preferred well location
outside of the target area or away from the best
geologic point. In this case, you can suggest that the
well be directionally drilled to the bottomhole target.
While a directional well may be technically possible
in a number of situations, it increases the cost of
drilling and producing the well. The increased costs
and benefits of a directional well must be weighed
against the impacts of a vertically drilled well. You
may want to ask the company to estimate the
additional costs for a directional well in relation to
the value of anticipated production from the well.
Directional drilling technology has improved in
recent years. It is now fairly routine in some areas of
the province to drill several directional wells from the
same surface location and thus reduce surface
impacts. This practice is prevalent in areas where
spacing is greater than one well per legal subdivision.
Land-use considerations
Before agreeing to a well site, consider how it may
affect your present and future land uses
Potential impacts on present and future land uses are
important to consider when selecting well and access
road locations. The company must have regard for
any negative effect on land use, the environment, and
other people. For example, a location on
18 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
unproductive land, such as a slough or hillside, may
seem like a good choice, but the company must
consider environmental impacts, the ability to reclaim
the site, and the impact on neighbours. Such impacts
could prevent the use of a site that is otherwise
favourable to you and the company.
Domestic water wells
Ensuring that domestic water wells are safe is a
priority
Protection of freshwater supplies is a major concern
of landowners, the EUB, and oil and gas companies.
The EUB ensures that all drilling, casing, cementing,
and abandonment programs for oil and gas wells are
designed to protect usable water zones.
When you are approached by a company, be sure to
tell the company the location and depth of all water
wells on your property. It is reasonable to request that
the company test your water well(s) before and after
the drilling of the oil or gas well. These tests provide
baseline information that can be compared to future
conditions in the water wells.
Other site restrictions
Other restrictions may influence a well site location
A well is normally not permitted within 100 metres
(328 feet) of an occupied dwelling or other surface
improvement without the approval or consent of the
owner. Restrictions may also apply to well sites close
to cities, towns, villages, rural subdivisions,
campgrounds, lakes, rivers, or public buildings, such
as schools and airports.
A well may not be drilled closer than 40 metres (131
feet) from a surveyed road or 100 metres (328 feet)
from a numbered highway without the approval of the
EUB and consent of the administrative authority
concerned. That authority is generally the county,
municipality, or Alberta Infrastructure.
PART 3
What happens during negotiations?
After you begin negotiations with the company,
various situations may arise. You and the company
may agree or disagree about the site of the well and
related facilities. If the well is located directly on
your land, you may agree or disagree about the
compensation you should receive.
Open negotiations usually result in an agreement that
meets the needs of both parties. The EUB encourages
a negotiated agreement and recommends that all
commitments be confirmed in writing. If both parties
live up to their commitments, a good working
relationship can be maintained for the life of the well.
Case 1: All parties agree on the site
If you and the company agree about the location of
the well site and access road, the company applies to
the EUB for a licence to drill the well. If the
application meets all legal and technical
requirements, the EUB grants the licence.
Note that the well licence alone does not give the
company the right to enter your land. See Case 3.
Case 2: You disagree on the site
If you and the company cannot agree on the site for
the well and the location of the access road, either
party may ask the EUB for its involvement. The EUB
will normally require documentation from the
company on the progress of previous negotiations and
an explanation of why an agreement could not be
reached. The EUB may also be asked to facilitate
earlier in the process if the parties have difficulty
getting started.
The EUB may suggest these options:
• The two parties should attempt negotiations
again.
• The EUB should become involved as a
facilitator.
• The parties could use a neutral third-party to
mediate.
The EUB public hearing process
An EUB public hearing provides an opportunity for
different points of view on an application to be heard.
A party must submit, in advance of a hearing, the
evidence that it will rely on at the hearing. This
formal process ensures that all relevant arguments
both for and against the application are heard.
At a hearing, each party presents its evidence and
argument and has the opportunity to ask questions of
each other. Then the EUB assesses the application
and weighs the evidence. The EUB will make one of
three decisions:
1) to issue a well licence unconditionally
2) to issue a licence subject to certain conditions
3) to deny the licence
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 19
You can find sources for more information about the
hearing process in the list of EUB publications on the
inside back of this guide.
Case 3: You disagree on compensation
Agreements about compensation are best reached
between you and the company.
If you and the company cannot agree on
compensation, the Surface Rights Board (SRB), not
the EUB, will decide the amount of compensation to
be paid. The company must first obtain a well licence
from the EUB. It then applies to the SRB for a right-
of-entry order. The order allows company
representatives to enter your land and drill the well.
The SRB will then conduct a hearing to determine the
compensation to be paid for the well site.
PART 4
What happens after drilling?
If the well is unsuccessful
If a well is a dry hole, the company will likely
abandon it and reclaim the site. Before the company
surrenders the surface lease, it must obtain a
reclamation certificate from Alberta Environment.
The reclamation certificate is issued only after the
Department is satisfied that the site has been properly
reclaimed.
If drilling finds worthwhile quantities of oil or gas
If a well is successful, surface equipment is required
to produce the oil or gas from the well. A wellhead or
pump will be required on oil wells; a heater may be
necessary for gas wells. Other equipment, such as
pressure vessels and tanks, may be placed on the well
site where it causes the least interference with farming
operationsfor example, between the well and a
nearby fence line. In some cases, pressure vessels and
tanks may be located at another well site and well
fluids piped there. You may wish to discuss these
options with the company when you negotiate the
well site.
Production facilities such as separators, heaters, and
tanks make up a battery. The company must discuss
the location and details of production facilities with
you and any land occupants. You have the right to ask
questions about these production facilities. You also
have the opportunity to voice concerns or objections
about the construction of production facilities, even if
a well site exists. If you feel you are not getting
answers, please write or call the EUB.
FURTHER REFERENCES EUB CONTACTS AND FIELD CENTRES
The following are available from the EUB’s
Information Services Branch at (403) 297-8190*: Alberta Energy and Utilities Board — Head
• Hearings and Inquiries, Guide 29 Office
• Pipelines and Surface Rights, Guide 17-3 Applications Branch, Facilities Applications
• Guidelines Respecting Applications for Local Telephone: (403) 297-4369*
Interveners’ Costs Awards, Guide 31 or
• Negotiating Surface Rights, Alberta Agriculture E-mail: guide56.help@eub.gov.ab.ca
Farmers’ Advocate or
General Inquiries
EUB Web site: http://www.eub.gov.ab.ca Telephone: (403) 297-8311*
640 – 5 Avenue SW
OTHER AGENCIES TO HELP YOU Calgary, Alberta
T2P 3G4
SURFACE RIGHTS BOARD (SRB)/LAND
COMPENSATION BOARD Bonnyville
For more information about right-of-entry order Telephone: (780) 826-5352
compensation, contact the SRB in Edmonton: Box 5169
18th Floor, 10020 – 101A Avenue 49 Street & 50 Avenue
EDMONTON, Alberta T5J 3G2 Bonnyville, Alberta
Telephone: (780) 427-2444* T9N 2G4
Web site:
http://www.agric.gov.ab.ca/navigation/agencies/ Drayton Valley
surfacerights/index.html Telephone: (780) 542-5182
Box 7048 2nd Floor
THE FARMERS’ ADVOCATE 5136 – 51 Avenue
For advice on resolving land-related problems, Drayton Valley, Alberta
contact T7A 1S3
the Farmers’ Advocate in Edmonton:
Room 305, 7000 – 113 Street Grande Prairie
EDMONTON, Alberta T6H 5T6 Telephone: (780) 538-5138*
Telephone: (780) 427-2433* 200, 11209 – 98 Avenue
Web site: http://www.agric.gov.ab.ca/ Grande Prairie, Alberta
navigation/agencies/farmersadvocate/index.html T8V 5A5

REGISTRAR OF LAND AGENTS Red Deer

The registrar has statutory powers to regulate the Telephone: (403) 340-5454*
conduct of land agents employed in the acquisition of 2nd Floor, 4920 – 51 Street
land. If you have any concerns about the treatment Red Deer, Alberta
you have experienced, contact the registrar: T4N 6K8
2nd Floor, South Tower
9915 – 108 Street St. Albert
EDMONTON, Alberta T5K 2G8 Telephone: (780) 460-3800*
Telephone: (780) 427-3570* 30 Sir Winston Churchill Avenue
Web site: http://www.gov.ab.ca/env/land/land_agents/ St. Albert, Alberta
T8N 3A3
ALBERTA ENVIRONMENT
Alberta Environment administers environmental Wainwright
legislation, polices, and programs to ensure the Telephone: (780) 842-7570*
protection enhancement and wise use of Alberta’s 801 – 2 Avenue
environmental resources. Contact the department at: Wainwright, Alberta
Petroleum Plaza, South Tower T9W 1C4
9915 – 108 Street
EDMONTON, Alberta T5K 2G8
Telephone: (780) 944-0313
Web site: http://www.gov.ab.ca/env

20 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
Southern Region To call toll free, dial 310-0000 and ask the RITE
Medicine Hat operator to connect you to this number.
Telephone: (403) 527-3385*
302, 346 – 3 Street SE
Medicine Hat, Alberta
T1A 0G7

Midnapore
Telephone: (403) 297-8303*
#320, 295 Midpark Way SE
Calgary, Alberta
T2X 2A8

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 21
EUB Guide 17-3: A pipeline or surface facility on my land?
A company has approached you and wants to build a
pipeline or surface facility on your land. You and the
company will be negotiating an agreement on the
pipeline/facility location, construction, operation, and
reclamation.
The first things most landowners want to know are:
“What are my rights?” and “What choices do I
have?” First, you have the right to be fully informed
at each step of the process.
This booklet is intended to help you in your
negotiations concerning a proposed pipeline or
facility and to understand your rights and choices as a
landowner/occupant. It describes the company’s
obligations under provincial legislation and answers
common questions about pipeline and facility
applications under EUB jurisdiction.
This booklet answers the most common questions we
receive at the EUB from landowners. If you have
additional questions or need more information, please
contact
EUB Applications Branch,
Facilities Applications
640 - 5 Avenue SW
Calgary Alberta T2P 3G4
(403) 297-4369*
*To call toll free, dial 310-000 and follow the
instructions to connect you to this number.
Contents
PART 1: UNDERSTANDING YOUR RIGHTS
The right to survey on your land
The pipeline right-of-way or surface agreement
The right to information
PART 2: THE APPLICATION PROCESS
PART 3: SELECTING A PIPELINE OR FACILITY
LOCATION
PART 4: NEGOTIATION
PART 5: THE EUB PUBLIC HEARING PROCESS
OTHER AGENCIES TO HELP YOU
EUB CONTACTS AND FIELD CENTRES
22 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
The Alberta Energy and Utilities Board (EUB)
ensures that the discovery, development, and
delivery of Alberta's resources take place in a
manner that is fair, responsible, and in the public
interest.
PART 1
Understanding your rights
The right to survey on your land
One of the first steps in selecting a pipeline route or
facility site is a survey. The company needs a survey
to identify the exact location of the pipeline/facility.
Under the Alberta Surveys Act, the surveyor has the
right to enter your property to survey after making a
reasonable attempt to notify you. It is common
practice — and common courtesy — for a company
representative to call on you before surveying. The
purpose of the visit will be to advise you of the
approximate location. The company is responsible for
any damages caused by the survey.
The pipeline right-of-way or surface agreement
The pipeline easement (right-of-way) or facility
surface agreement is a legal document that records an
agreement between a landowner and a company. It
should state the rights and obligations of the
company and the landowner with respect to the
pipeline route/facility location. A pipeline easement
or facility surface agreement may be obtained prior to
EUB approval of an application to construct a
pipeline/facility.
If you have an objection related to the proposed
development, you should send a letter to the company
and the EUB detailing your objections. (The EUB
does not deal with compensation issues related to
right-of-way, surface acquisition, or damages. These
issues are dealt with through the Surface Rights
Board, if necessary, after a pipeline or facility
licence has been issued by the EUB.)
If various parties have used every effort possible to
resolve their differences and failed, an EUB public
hearing may be scheduled to hear the outstanding
issues, with notice given to affected landowners and
occupants. The hearing process is described in Part 5
of this booklet.
The right to information
You have the right to be fully informed about what
the company plans to do on your land.
Under EUB regulations and guidelines, the company
must provide all the information you need to fully
understand what is being proposed for your land. If
you are concerned about surface impacts, the
company should give you details about how it chose
the proposed pipeline/facility location. The company
should also tell you what to expect in terms of
equipment and operations during the production
phase.
The company has the following obligations:
• to give you a general description of the project,
and tell you how it will impact your land
• to make sure you fully understand the proposed
construction schedule and method
• to make sure you are familiar with the substance
being transported by the pipeline or handled at
the facility
• to answer your concerns on what the company is
proposing in terms of soil handling and
reclamation techniques
• to address any other concerns related to the
pipeline or facility on your land.
Eight EUB field centres and the head office in
Calgary have staff available to answer your
questions. Their addresses and telephone numbers are
at the back of this booklet.
PART 2
The application process
The application process ensures that the proposed
project complies with regulatory requirements
To build a pipeline or facility, an energy company
must first conduct a public disclosure and
consultation program. This program will vary
depending on the project, but the company must, as a
minimum, disclose and consult with all landowners
and occupants, as set out in the EUB’s application
requirements. Only then may the company file an
application to obtain approval from the EUB.
The application consists of a series of questions to
which the company supplies information about the
proposed project and its commitment to building the
pipeline/facility in compliance with the Pipeline Act
and Regulations and the Oil and Gas Conservation
Act and Regulations. If for any reason the company
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 23
proposes to deviate from the requirements set out in
the acts and regulations, it must supply additional
information to satisfy the EUB that the proposal is
acceptable.
If there are no outstanding objections and the
application meets all legal and technical
requirements, the EUB may issue a licence.
In addition, a portion of all applications processed by
the EUB are selected for an audit review after the
licence has been issued to ensure regulatory
compliance.
PART 3
Selecting a pipeline or facility location
Before agreeing to a location, consider how it may
affect your present and future land uses.
Potential impacts on present and future land uses are
important to consider when selecting a pipeline
right-of-way or a facility site. The company should
have consideration for land surface conditions,
current and potential land use, environmental
sensitivity, and reclamation. The company must also
have regard for any negative effect on land use, the
environment, and other people.
Make sure you understand the company’s soil
handling, lease preparation, and reclamation
methods.
If you have concerns relating to soil conservation or
reclamation, please contact Alberta Environment’s
Reclamation Officer directly (see Other Agencies to
Help You, at the end of this booklet). To obtain a list
of Alberta Environment (AENV) offices in your area,
contact the Land Reclamation Division of AENV and
ask for Informational Letter 94-5.
If you believe the company is not doing an adequate
job of soil handling and conservation, lease
preparation, or clean-up following construction, you
should discuss your concerns with the company
directly. If you are still not satisfied, contact the
regional conservation and reclamation office for
assistance.
Make sure any other questions you have about
construction and operation are addressed.
If you are concerned about issues such as weed
control during construction or noise during facility
operation, you should contact the company personnel
in the field or head office and AENV’s Reclamation
Officer (if applicable). If your concerns remain
unresolved, you should then contact the local field
centre or head office of the EUB.
PART 4
Negotiation
Open two-way negotiations usually result in an
agreement that meets the needs of both parties
Open two-way negotiations usually result in an
agreement that meets the needs of both parties. The
EUB encourages a negotiated agreement and
recommends that all commitments be confirmed in
writing. If both parties live up to their commitments,
a good working relationship can be maintained for
the life of the project.
After you begin negotiations with the company,
various situations may arise. You may agree or
disagree on the location of the pipeline/facility or the
method of construction proposed. You may agree or
disagree on the compensation you should receive for
the right-of-way or surface disturbance and/or
damages.
Compensation does not fall under EUB
jurisdiction and should be referred to the Surface
Rights Board. Matters such as location, safety,
construction, and timing fall under EUB jurisdiction.
If you have no objection to the issuing of a
pipeline/facility licence, the EUB may proceed. If
you object to a pipeline/facility under the jurisdiction
of the EUB, you should send a letter to the applicant
and the EUB stating your objections in detail and
asking the EUB to assist in resolution. The EUB will
require documentation on the progress of previous
negotiations and why an agreement could not be
reached. The EUB may suggest these options:
• The two parties should attempt negotiations
again.
• The EUB should become involved as a mediator.
If the application is to be heard at an EUB public
hearing, notice of the hearing will be sent directly to
you and other affected landowners and occupants.
Newspaper advertising is also possible.
It is in your best interest to have someone represent
you when you are absent. If you go away from home
and do not arrange for someone to represent you or
notify you, then you may miss your opportunity to be
heard at a public hearing.
24 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
PART 5
The EUB Public Hearing Process
At a hearing there is an opportunity for you to
state your position and give evidence to the EUB
regarding the proposed pipeline/facility
Normally, a panel of three EUB Board Members or
appointed examiners hears evidence from you and the
applicant. You may or may not wish to be
represented by a lawyer.
The panel does not make a decision at the hearing.
Instead, it considers the evidence and arguments and
issues a written report giving the decision and the
reasons for it. The report will be made public and
given to all participants.
The Local Interveners’ Costs Regulations allow
reasonable costs, such as lawyer’s fees to normally be
reimbursed. Payment for right-of-way, crop loss, and
other damages are dealt with by the Surface Rights
Board.
Note: Section 42 of the Energy Resources
Conservation Act allows the EUB to review or
change an order or to rehear an application before
deciding it.
OTHER AGENCIES TO HELP YOU
SURFACE RIGHTS BOARD (SRB)/LAND
COMPENSATION BOARD
For more information about right-of-entry order
compensation, contact the SRB in Edmonton:
18th Floor, 10020 – 101A Avenue
EDMONTON, Alberta
T5J 3G2
Telephone: (780) 427-2444*
Web site:
http://www.agric.gov.ab.ca/navigation/agencies/
surfacerights/index.html
THE FARMERS’ ADVOCATE
For advice on resolving land-related problems,
contact the Farmers’ Advocate in Edmonton:
Room 305, 7000 – 113 Street
EDMONTON, Alberta T6H 5T6
Telephone: (780) 427-2433*
Web site:
http://www.agric.gov.ab.ca/navigation/agencies/
farmersadvocate/index.html
THE REGISTRAR OF LAND AGENTS Grande Prairie
The registrar has statutory powers to regulate the Telephone: (780) 538-5138*
conduct of land agents employed in the acquisition of 200, 11209 – 98 Avenue
land. If you have any concerns about the treatment Grande Prairie, Alberta T8V 5A5
you have experienced, contact the registrar:
2nd Floor, South Tower Red Deer
9915 – 108 Street Telephone: (403) 340-5454*
EDMONTON, Alberta T5K 2G8 2nd Floor, 4920 – 51 Street
Telephone: (780) 427-3570* Red Deer, Alberta T4N 6K8
Web site: http://www.gov.ab.ca/env/land/land_agents
Southern Region
ALBERTA ENVIRONMENT
Alberta Environment administers environmental
legislation, polices, and programs to ensure the Medicine Hat
protection enhancement and wise use of Alberta’s Telephone: (403) 527-3385*
environmental resources. 302, 346 – 3 Street SE
Contact the department: Medicine Hat, Alberta T1A 0G7
Petroleum Plaza, South Tower
9915 – 108 Street Midnapore
EDMONTON, Alberta T5K 2G8 Telephone: (403) 297-8303*
Telephone: (780) 944-0313 #320, 295 Midpark Way SE
Web site: http://www.gov.ab.ca/env Calgary, Alberta T2X 2A8

EUB CONTACTS AND FIELD CENTRES St. Albert

Telephone: (780) 460-3800*
Applications Branch, Facilities Applications 30 Sir Winston Churchill Avenue
Telephone: (403) 297-4369* St. Albert, Alberta T8N 3A3
or
E-mail: Guide56.help@eub.gov.ab.ca Wainwright
Telephone: (780) 842-7570*
Surveillance Branch, Field Surveillance Group 801 – 2 Avenue
Telephone: (403) 297-8316* Wainwright, Alberta T9W 1C4
640 – 5 Avenue SW
Calgary, Alberta T2P 3G4
*To call toll free, dial 310-000 and follow the
Bonnyville instructions to connect you to this number.
Telephone: (780) 826-5352
Box 5169
49 Street & 50 Avenue
Bonnyville, Alberta T9N 2G4

Drayton Valley
Telephone: (780) 542-5182
Box 7048 2nd Floor
5136 – 51 Avenue
Drayton Valley, Alberta T7A 1S3

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 25
Proliferation Guidelines
PURPOSE OF THE GUIDELINES
The Alberta Energy and Utilities Board (EUB)
is providing you with these guidelines and
minimum expectations to assist you when
planning to construct new oil or gas treating,
handling and processing facilities, and new
pipelines. You should use these guidelines with
EUB Guide 56: Energy Development
Application Guide.
FACILITY/PIPELINE NEED
The EUB recognizes that as the proponent of a
new oil or gas facility or pipeline, you have
already determined that your proposed project
will meet your company’s business needs. The
EUB, as the approving authority, is also
required to evaluate the need for the proposed
project in the broader public interest. The EUB
considers this interest in terms of economic,
orderly, and efficient development of Alberta’s
oil and gas resources.
The EUB continues to receive strong input from
the public who are aware of the growth of
resource development. The EUB accepts the
public’s view that there is a need to avoid
facility proliferation whenever possible and
practical.
The EUB is required by statute to consider
objections to its issuance of an approval raised
by parties who may be directly and adversely
affected (see Section 29 of the Energy
Resources Conservation Act [ERCA] in
Appendix 5). In addition, if following the
approval of an application, an affected party
contends that proper notice was not given and if
a hearing was not held, the EUB may hold a
hearing to consider the application, provided
such a request is made within 30 days of the
issuance of the approval/licence (see Section 43
of the ERCA in Appendix 5).
26 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
BEFORE YOU SUBMIT AN APPLICATION
You are required to investigate the feasibility of
using alternative facilities and/or pipelines
before you submit your application. The EUB
cannot predetermine a distance from a facility or
pipeline that will protect an applicant from
objections because every application is unique
and each project presents circumstances that
must be dealt with on an individual basis.
SOUR FACILITIES (CATEGORIES D AND E ONLY)
As part of your investigation, you are required
to identify and contact all oil and gas reserve
owners and operators of all similar sour
facilities within the radius given in Schedule 1’s
Table 1.2: Industry Contact Requirements.
TABLE 1.2: INDUSTRY CONTACT REQUIREMENTS
(RADIUS) (from Schedule 1)
PROPOSED FACILITY
FACILITY ONLY* RESERVE OWNER OPERATOR
Sour Gas Processing 5.0 km 10.0 km
Facility (CAT. D&E)
Sour Oil/Bitumen N/A 2.0 km
Production Facility
(CAT.D)
* See Table 1.1: Energy Developments for Categories D and E
(Schedule 1).
As a minimum, you are required to provide
these parties with a written overview of the
proposed facility, including location, type, and
design capacities. The onus is then on these
parties to raise any concerns or objections to
your proposal. The EUB expects this contact to
precede your public involvement program.
During your investigation, you are required to
consider the following:
• All existing facilities in the area that afford
viable alternatives, regardless of ownership
or interest. To preclude the development of
new facilities, you should evaluate the
feasibility of upgrading an existing facility
and of forging commercial partnerships with
existing operators. Note that high processing
fees, in and of themselves, may not be
considered sufficient grounds for rejecting
 the option to use an existing facility. This is
because EUB legislation provides for the
review of facility processing fees.
• The area’s future production potential to
ensure the proposed facility is designed to
meet the area’s longer-term oil or gas
processing/handling needs.
• All inactive commercial wells in the area
with a view to inviting these well owners to
participate in the new facility in some
manner.
OTHER FACILITIES AND PIPELINES
For pipelines and other facilities not listed in
Table 1.2, you must determine what you
consider to be a reasonable area of investigation.
The EUB does not prescribe the area you must
investigate. However, you are strongly
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 27
encouraged to discuss your proposal with
operators of similar facilities and/or pipelines
that you identified as viable alternatives during
your investigation and with those who may be
affected by your application. The EUB believes
a proactive approach is in your best interest,
because failure to do so may result in those
affected filing an objection with the EUB. You
should consider investigation parameters similar
to those specified for sour facilities.
INDUSTRY OBJECTIONS
Any outstanding objections or concerns that are
raised and not resolved must be indicated by
checking the appropriate box(es) on Schedule 1:
Energy Development Application. You are
required to attach a summary of the issues. This
will cause your application to be processed as
nonroutine; if the issues remain unresolved, this
could result in your application being
considered at an EUB hearing.
Pipelines: Technical Guidelines

PURPOSE OF THE GUIDELINES applications. All markings on the map should be

made with a pen no thicker than 0.7 mm. You
The Alberta Energy and Utilities Board (EUB)
must complete the following tasks and submit
prepared the following technical guidelines to
one original of the applicable map with each
assist those submitting pipeline applications and
application.
the accompanying pipeline segment
identification form. The information outlines
• Indicate the new pipeline(s) in red.
requirements and technical factors you should
consider when submitting a base plan map,
• Indicate pipelines to be abandoned,
modifying a pipeline, determining sour service
discontinued, or removed in green.
material requirements, and/or calculating stress
level.
• Determine the appropriate licence and line
number from the EUB records and identify
You should use these guidelines with EUB
them on the base map(s).
Guide 56: Energy Development Application
Guide. Virtually all the items listed refer to the
• If new construction and new licence are
corresponding items on Schedule 3. Exceptions
required, label base map(s) with substance
are the base plan map requirements, which are
to be transported.
referred to in Schedule 1, and the stress level
calculation required to complete Form 3.1:
When an application is approved, the EUB
Pipeline Segment Identification.
transfers the base map information to the master
graphics file, which is available to any other
BASE PLAN MAP REQUIREMENTS user. The EUB does not require that you submit
The EUB uses pipeline base maps to show the as-built or survey drawings but does require that
approximate location of permitted and licensed the accuracy of plotting pipelines on the base
pipelines under its jurisdiction. You must buy map reflect the actual surveyed route.
these maps or plats from the EUB. You must
attach one original of the required map(s) to Companies that can reproduce their own
each pipeline application. The EUB does not accurate and current base maps may do so
want photocopies, because the scale is distorted. provided the EUB confirms acceptability in
The maps are produced on an individual terms of size and clarity in advance.
township basis; if a township is very congested,
a larger scale is used, e.g., quarter section. MAXIMUM OPERATING PRESSURE (MOP)
INCREASE
These plats show the best pipeline location data
When increasing the MOP, you must consider
available to the EUB and identify the licence
number of each pipeline. Under no
• testing requirements to confirm capability
circumstances should they be used for
for the increased pressure
physically locating pipelines, as they only
provide a general representation of the pipeline
• overpressure protection on upstream and
route. They should be used, however, to identify
downstream pipelines
the pipeline licensee who must be contacted for
the accurate and specific location of pipelines.
• pipeline class redesignation (sour natural
gas only)
You must obtain the most recent base map from
EUB Information Services for all pipeline
• pipeline level reclassification (sour natural
gas only)

28 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
• potential setbacks (sour natural gas only)
• partial pressure of the hydrogen sulphide
• material and component suitability
• notification requirements
MAXIMUM OPERATING PRESSURE (MOP)
DECREASE
When decreasing the MOP, you must consider
• suitability for the new MOP, e.g., the past
integrity of the pipeline
• pressure compatibility with upstream and
downstream pipelines
• pipeline level reclassification (sour natural
gas only)
• potential setbacks (sour natural gas only)
• notification requirements
SUBSTANCE CHANGE
When changing the substance, you must
consider
• pressure-testing requirements
• pipeline level reclassification (sour natural
gas only)
• potential setbacks (sour natural gas only)
• notification requirements
• depth of pipeline cover
• pipeline warning sign requirements
• potential class redesignation (sour natural
gas only)
• emergency response plan changes
• corrosion monitoring and mitigation
requirements
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 29
If the substance is corrosive, effective internal
corrosion mitigation and monitoring programs
must be implemented according to the Pipeline
Regulation, Section 53, in Appendix 5.
You must update pipeline warning signs to
reflect the new substance before operations
begin.
LINER TYPE
Note the following qualifying statements:
Free-standing fibreglass liners—These liners
are considered pressure-retaining devices.
Free-standing polyethylene liners—These
liners are considered pressure-retaining devices.
Expanded polyethylene liners—These liners
are considered to be internal corrosion barriers
and not pressure-retaining devices. Expanded
polyethylene liners and pressure-containing pipe
must be designed and pressure tested according
to current CSA standards. Consideration should
be given to temperature design and hydrocarbon
absorption.
PARTIAL PRESSURE OF H2S IN THE GAS PHASE
The partial pressure is determined by
multiplying the mole fraction of hydrogen
sulphide in the gas phase by the maximum
operation pressure (MOP) in kilopascals (kPa).
The partial pressure of H2S in the gas phase
determines if sour service materials are
required.
For gas pipelines, sour service materials are
required where the partial pressure of H2S in the
gas phase exceeds 0.35 kPa.
For multiphase pipelines (oil-well effluent), sour
service materials are required where the
combination of H2S in the gas phase is in
accordance with either of the following:
• the system pressure is below 1400 kPa and
the H2S content in the gas phase is above 50
mol/kmol, or
• the system pressure is 1400 kPa and the
partial pressure of the H2S in the gas phase
is >70 kPa.
THE PIPELINE MEETS ALL CURRENT
APPLICABLE CSA STANDARDS
Materials intended for sour service must meet
the applicable requirements outlined in IL 91–8
and in all CSA Z245 documents covering steel
line pipe (CSA Z245.1), steel fittings (CSA
Z245.11), steel flanges (CSA Z245.12), and
steel valves (CSA Z245.15). CSA states that
where no standard exists, the material
requirements of the National Association of
Corrosion Engineers NACE MR–0175–92
apply. CSA documents are available from
commercial technical bookstores.
EUB Sour Gas Definition—The CSA definition
of sour service should not be confused with the
EUB’s definition of sour natural gas. For
pipelines, the EUB defines sour natural gas as
10 moles of H2S gas per kilomole of natural gas.
For sour natural gas pipelines, the EUB has
requirements that go beyond material
considerations and focus on reducing the
potential risks associated with high
concentrations of sour natural gas.
CSA standards are considered a minimum.
Where requirements of the EUB’s acts and
regulations differ from the CSA, the EUB’s
requirements govern.
THE PIPELINE WILL INJECT SOUR NATURAL
GAS INTO A PRODUCING RESERVOIR
When considering the effects the reservoir fluid
composition may have on wells and producing
pipelines, consider the potential for
• gas cap breakthrough
• reclassification of existing pipeline systems
due to an increase in H2S content
• reclassification of producing wells as sour
critical wells
30 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
• licence amendments to meet CSA sour
service material requirements for the
pipelines affected
THE PIPELINE WAS DISCONTINUED IN
ACCORDANCE WITH EUB REQUIREMENTS
When confirming the integrity of a pipeline,
consider cathodic protection reports, external
coating survey, internal electromagnetic
inspection, destructive testing (material cut-
outs), etc., as appropriate.
STRESS LEVEL
To calculate the stress level for steel or
aluminum pipe material, use the following
formula:
(maximum operating pressure kPa) (outside diameter mm)
(20 x pipe specified minimum yield strength mPa) (wall thickness mm)
To calculate the stress level for polyethylene
pipe material, use the following formula:
(maximum operating pressure kPa) (outside diameter mm - wall thickness
mm)
(20 x pipe long-term hydrostatic strength mPa) (wall thickness mm)
If the pipe material code is fibreglass,
composite, or polyvinyl chloride, leave the
space blank on Form 3.1: Pipeline Segment
Identification.
REFERENCES
Appendix 4
IL 91-8: Materials Required for Sour Service
Appendix 5
Pipeline Regulation, Section 53
Appendix 8—Reference List
Steel Line Pipe CSA Z245
Steel Fittings CSA Z245.11
Steel Flanges CSA Z245.12
Steel Valves CSA Z245.15
NACE MR–0175–92
Production Measurement Guidelines
PURPOSE OF THE GUIDELINES
The Alberta Energy and Utilities Board (EUB)
prepared these guidelines to assist those
applying to construct, operate, or amend
(modify) oil or gas treating, handling, or
processing facilities.
PRODUCTION MEASUREMENT GUIDELINES
The EUB requires companies to accurately
measure volumes of produced oil, gas, and
water to
• ensure that the appropriate Alberta Crown
royalties are paid,
• provide reservoir management information,
• allow for the accurate assessment of each
equity owner’s share of production, and
• allow for the detection of escaped
substances to the environment.
The EUB regulations, informational letters (IL),
interim directives (ID), and guides that relate to
production measurement and reporting at a
facility are listed below. You are expected to
design and operate your facility to meet all of
the requirements cited in these references. You
do not have to submit supporting documentation
with your Energy Development Application but
must retain it on file for EUB review on request.
You must attach a single diagram to your
application showing a summary of the process
flow and production measurement systems.
Your design, operations, and production
accounting personnel should collaborate on the
facility design to ensure that proper
measurement systems are built into the facility
from the start. It is particularly important that
production measurement configurations at
individual gas wells be designed to ensure that
production metering and reporting are consistent
throughout the overall system. If the EUB finds
that your production measurement systems are
not properly designed, you will have to amend
(modify) them to comply with the applicable
standards.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 31
PROCESS FLOW DIAGRAM REQUIREMENTS
The process flow diagram (PFD) must be in
sufficient detail to enable EUB staff to
understand the proposed processes and to
identify potential issues. PFDs must represent
the actual proposed facility, not typical
drawings. If available, piping and instrument
diagrams (P&IDs) would be preferred. As a
minimum, the PFD must include
1) Major process vessels and equipment,
including heat exchangers, compressors and
pumps—The EUB recommends that design
rates, pressures, and temperatures also be
indicated on the flow diagram.
2) All measurement points coded as to the type
of meter planned (e.g., orifice, turbine, mass
flow).
3) All pressure-controlled and emergency shut-
down valve (ESD) flare points—It is
recommended that pressure shutdown valves
(PSD) and manual flare points be shown.
4) All atmospheric tanks and pressure-
controlled process and ESD vent points
(e.g., where unburned gas will be vented to
atmosphere).
5) All ESD control valves, with indication of
automated or manual control fail-safe mode.
6) All storage, blowdown, and sump tanks.
7) Inlet source(s) and final disposition of
products.
The EUB prefers an original of the PFD;
however, photocopies are accepted as long as
they are clear and legible. Originals will not be
returned. You must keep PFDs up to date and on
file, demonstrating compliance for EUB review
upon request.
REFERENCES
Interim Directives (see Appendix 3)
ID 90-2: Gas Meter Calibration
ID 91-3: Heavy Oil/Oil Sands Operations
ID 94-1: Measurement of Oil, Gas and Water
Production
Informational Letters (see Appendix 4)
IL 87-1: Compressibility Factors Used in Gas
Volume Calculations and Physical
Property Data for Natural Gases
IL 90-6: Measurement Guidelines – Trucked
Oil Production
IL 91-9: Exemption from Gas Measurement –
Crude Oil/Bitumen Wells
IL 92-8: Crude Oil Pipeline Truck Terminal
Measurement Guidelines
IL 93-1: Gas Density Measurement Frequency
– Orifice Meters
IL 93-10: Revised Measurement and Accounting
Procedures for Southeastern Alberta
Shallow Gas Wells
32 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
Other (see Appendix 8)
Alberta Energy IL 87-3: ERCB Reporting
Requirements and Department of Energy
Royalty Regimes for Wells Producing Oil, Field
Condensate or Pentanes Plus
Guides (see EUB Web site <www.eub.gov.ab.ca>
or call EUB Information Services at 403-297-8190)
Guide 4: Determining Water Production at
Gas Wells
Guide 7: Production Accounting Handbook
Guide 34: Guidelines for Automated
Measurement System Applications
Guide 46: Production Audit Handbook
Guide 49: Gas Density Measurement
Frequency
Guide 60: Upstream Petroleum Industry
Flaring Guide
Guide 64: Facility Inspection Manual
Wells: Technical Guidelines

PURPOSE OF THE GUIDELINES 3) the relation of the well location to the

surface topography within 200 m of the
The Alberta Energy and Utilities Board (EUB)
well, including
prepared the following technical guidelines to
a) elevations of the corners of the surface
assist those submitting well licence applications.
lease,
The information outlines specific requirements
b) elevations of any significant water
and technical factors you should consider when
bodies, and
submitting a well licence application, including
c) sufficient information to establish the
survey plan requirements.
general character of the topography and
any predominant drainage patterns;
You should use these guidelines with EUB
Guide 56: Energy Development Application
4) the relation of the well location to
Guide. These guidelines refer to corresponding
a) surface improvements,
items in Schedule 4, with the exception of the
b) wells,
survey plan requirements, which relate to items
c) coal mines, whether working or
in Schedule 1.
abandoned, and
d) water wells within 200 m of the well;
SURVEY PLAN REQUIREMENTS and
The survey plan must provide sufficient detail to
accurately identify surface topography and 5) where the proposal is to drill the well in a
surface improvements adjacent to well sites, water-covered area, the depth of the water.
access roads, etc. In the case of long access
roads or where the well is close to section lines, The survey plan must be 8 1/2" x 14" and be
additional information must be provided for current and valid. Multiple pages of this size
impacts on land that might not normally appear may be used to include all survey information.
on the survey plan. The EUB prefers an original of the survey plan;
however, photocopies are accepted if they are
To meet the requirements, a survey plan must clear.
provide the following details as a minimum:
MINERAL RIGHTS
1) the location of the well tied by bearings and
You must hold the right for the proposed well to
distance to a monument, or in the case of a
produce from the intended formation and the
well in unsurveyed territory, the location
drilling spacing unit (DSU). If for any reason
determined in accordance with the
you do not hold the rights for the entire DSU,
Unsurveyed Territory Regulations;
you must document the specific rights for the
specific area/formation you hold. In the case of
2) the relation of the well to the boundaries of
Freehold minerals, note that the Alberta Crown
the quarter section shown by the coordinates
holds the mineral rights beneath water bodies on
from the two boundaries of the quarter
such lands.
section that are also the boundaries of the
section (assuming a 20 m wide road
The Alberta Department of Resource
allowance) and by calculated distances to
Development (DRD) verifies each Crown
the interior boundaries of the quarter
mineral lease after a well licence is issued. The
section;
producing zone, terminating zone, and DSU
information must agree with DRD’s
information. If not, the EUB will suspend the
well licence until you have made the necessary
arrangements with DRD.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 33
RIGHTS FOR ALL INTENDED PURPOSES the EUB does not agree, the application may go
to a public hearing.
You must obtain the rights for the intended
purpose of the well from the mineral rights
holder. The right to produce is not always SURFACE IMPACT
required, as, for example, in the case of an
To answer the question on the application form
injection well or water disposal well. If the
regarding compliance with setback
Crown mineral rights are undisposed, you must
requirements, you must satisfactorily address
obtain approval for injection, disposal, or water
the following issues or complete the notification
source wells from the Minerals Tenure Branch,
as required.
DRD.
Water Bodies
TERMINATING FORMATION
A water body is defined as the bed and shore of
To facilitate the gathering of geological a river, stream, lake, creek, lagoon, swamp,
information where you do not have the rights to marsh, slough, or other natural body of water or
the deeper formation, you may drill a maximum a canal, drainage ditch, reservoir dugout, or
of 15 m below the base of the terminating other man-made surface feature, whether it
formation. This extra depth accommodates contains or conveys water continuously,
required over-hole for logging tools and casing. intermittently, or seasonally. You may not drill a
The additional 15 m does not form part of the well within 100 m of the high-water mark of a
mineral rights granted. body of water unless you have EUB approval.
To obtain approval in these cases, you must
submit the application as nonroutine and attach
SURFACE RIGHTS
additional information outlining acceptable
In accordance with the Oil and Gas methods to prevent the pollution of the water,
Conservation Regulations, Section 2.020(4), you addressing both the drilling and future
must have the right to access the land on which production operations and considering the
the well is to be drilled. If you cannot obtain the consequences of a spill.
right to access the land in question, you must
provide Surface Improvements
• a complete summary of the negotiation steps
A surface improvement is defined as a railway,
taken,
pipeline, or other right-of-way, road allowance,
• a complete list of the specific concerns or
surveyed roadway, canal, dwelling, industrial
objections the surface owner or occupant
plant, aircraft runway or taxiway, building used
has with respect to the well, and
for military purposes, permanent farm building,
• the measures you propose in order to
school, or church in the Oil and Gas
mitigate the concerns or objections of the
Conservation Regulations, Part 1, Section
surface owner or occupant.
1.020(2)(28). With the exception of a surveyed
roadway/road allowance, no well shall be drilled
If you believe that a surface lease is
within 100 m of a surface improvement. If the
unobtainable from the landowner solely due to
surface improvement is a pipeline/utility right-
compensation, you may request the EUB to
of-way, a gas co-op right-of-way, or a private
issue the well licence to allow you to apply to
access road, you are deemed to have met the
the Surface Rights Board for a Right of Entry
setback requirements if you obtain the consent
Order. You must file the application as
of the owner. However, in all other cases, if the
nonroutine, with supporting information
surface improvement owner agrees to a lesser
attached indicating the reasons why you believe
distance and the EUB is convinced that
that the only issue is compensation and outlining
operations can be conducted safely, the EUB
what steps you have taken to resolve the issue. If
may approve your application. In these cases
the EUB agrees that the issue is solely one of
you must file your application as nonroutine
compensation, it will issue the well licence. If

34 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
and include documentation indicating that you
have obtained surface improvement owner
agreement to the reduced distance.
Surveyed Road/Road Allowance
The minimum separation distance from a
surveyed road or road allowance to a well is 40
m. The EUB will consider a lesser distance if it
is demonstrated that special circumstances exist
and that the owner or administrator of the
surface does not object. In these cases, you must
file your application as nonroutine and attach
supporting documentation, including geological
or topographical information and any proposed
mitigative measures.
Notifications Required
If your proposed well is in close proximity to
airports or coal development, you have notified
the appropriate parties, and they do not object,
you are deemed to have met the setback
requirements.
Airports
If you propose to drill a well within 5 km of a
lighted airport or 1.6 km of an unlighted airport,
you must advise the Regional Manager, Air
Navigation Requirements, Transport Canada,
prior to making your application of the proposed
well site, the height of the derrick to be used,
and the approximate dates between which
drilling operations will take place.
Coal Development
If a well location falls within a potential coal
development area, you must determine if the
coal rights have been leased and who is the
lessee. Information on Crown coal rights is
available from DRD at its Calgary Information
Centre. Information on Freehold coal rights is
available from Alberta Registries, Land Titles.
If the coal rights are leased, you must inform the
lessee of your plans at least 14 days prior to
submitting your application. (In lieu of waiting
14 days, you may obtain the approval of the
lessee.)
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 35
If the proposed well is near a subsurface mine,
either working or abandoned, you must review
the details of the mine plans to ensure that no
drilling takes place within 15 m of a mine shaft.
SOUR WELLS
Each sour well application must include details
regarding maximum hydrogen sulphide (H2S)
content, cumulative drilling release rate, size of
the calculated emergency planning zone radius
distance to nearest occupied dwelling, distance
to urban centre, and number of occupied
dwellings, public facilities and/or businesses
within the emergency planning zone. This
information forms the basis for the public
disclosure and consultation program for your
application.
Cumulative Drilling H2S Release Rate
The EUB participated in a review conducted by
the Canadian Association of Petroleum
Producers (CAPP) Drilling and Completions
Committee that studied the manner in which
H2S release rates are determined. CAPP
undertook this review in an effort to provide
guidelines for the methodology and standards
used in calculating potential H2S release rates,
as well as to provide a consistent documentation
format. The EUB suggests that the applicant
have regard for the recommendations of the
CAPP committee found in the document H2S
Release Rate Assessment Guidelines and Audit
Forms available on the CAPP Web site
(www.capp.ca). In addition, the EUB expects
you to use sound geological and engineering
judgement and due diligence in the
determination of H2S release rates.
To determine the cumulative drilling release
rate, you must consider the development or
exploratory nature of each sour zone that may
possibly be encountered. The maximum H2S
content and maximum flow rate are based on
information from surrounding wells completed
in the same or similar zones. Your search for
H2S analyses and deliverability values should
ensure a minimum of five representative data
points for each potential sour zone. Data points
are representative if they are not discounted for
technical reasons. In situations where multiple
data exist for the same well, only one value will
be considered representative. If higher values or
potential sour zones have been discounted, you
must be prepared to support your decision with
geological, engineering, or other technical data.
The H2S release rate for each potential sour
zone is determined by multiplying the maximum
H2S content by the maximum expected flow
rate. The paired data points need not be from the
same well. The flow rate should represent
surface deliverability against zero back pressure
for the open-hole casing configuration. The sum
of release rates from each zone becomes the
cumulative drilling release rate.
Where a casing point affects this value, choose
whichever is greater: the cumulative release rate
for the intermediate hole section or the
cumulative release rate for the main hole
section.
However, the EUB cautions that in cases where
the producing H2S release rate may exceed the
drilling H2S release rate, it expects you to fulfill
the public disclosure and consultation
requirements applicable to the higher rate.
Emergency Planning Zone
The appropriate emergency planning zone (EPZ)
must be carefully selected and be adequate to
ensure the safety of the public near the well. The
size and shape of the zone must reflect the
maximum drilling H2S release rate and must
also have regard for the local terrain and density
of population in the area.
To calculate the EPZ, use the cumulative
drilling release rate using the following
formulas:
• If RR < 0.3 m3/s: EPZ = RR 0.58 x 2 km
• If RR > 0.3 m3/s but < 8.6 m3/s:
EPZ = RR 0.68 x 2.3 km
• If RR > 8.6 m3/s: EPZ = RR 0.81 x 1.9 km
Although the EUB may consider a reduced
planning zone radius in some instances, you
must record the calculated EPZ radius on
Schedule 4.
Critical Well
A critical well is defined by the following
criteria:
• release rate is > 2.0 m3/s
• release rate is > 0.3 m3/s but < 2.0 m3/s and
the well is located within 5.0 km of an urban
centre
• release rate is > 0.1 m3/s but < 0.3 m3/s and
the well is located within 1.5 km of an urban
centre
• release rate is > 0.01 m3/s but < 0.1 m3/s and
the well is located within 500 m of an urban
centre
If your well is deemed to be critical by the
above standards, you must meet the drilling
requirements outlined in ID 97-6 (see Appendix
3) and the Alberta Recommended Practices
(ARPs).
LAHEE CLASSIFICATIONS
The EUB adopted the Lahee classification
system in 1964 as a standard basis for compiling
drilling statistics. A Lahee classification is
assigned to each new well based on the
geological conditions and the known existence
of hydrocarbons in the area where the well is to
be drilled. The classification assigned to a well
should take into account considerations such as
the geological objectives and projected total
depth of the well and the general degree of the
risk of failure involved.
The Lahee classification is assigned based on
the descriptions below. If in the EUB’s opinion,
the Lahee classification assigned to a well does
not appear to meet the criteria outlined in the
description, the classification will be revised.
Further, the Lahee classification of a well is
intended to take into account the conditions
known when the well is spudded; therefore the
EUB may also revise the classification of a well
on the basis of additional knowledge gained
between the time of licensing and the spudding
of a well. In both cases, the EUB will forward
written notification of its revision to the

36 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
licensee. If the licensee has technical data Outpost (OUT)
supporting the originally assigned Lahee
An OUT well is drilled with the intention of
classification, an appeal of the revision may be
extending a known pool by a considerable
made no later than 14 days following the EUB’s
distance. A well in close proximity to a known
notification letter.
pool but whose outcome is uncertain because of
geological complexities might also be classified
Description of Lahee Classifications
as OUT.
New Field Wildcat (NFW)
An NFW well is located at a considerable Development (DEV)
distance beyond the limits of known pools and
The objective of a DEV well is to further exploit
is outside the boundaries of existing fields. The
the productive zone of a known pool(s). The
well is drilled in an area where hydrocarbons
well may be inside the established limits of the
have not yet been discovered.
pool or in close proximity to the edge of the
pool(s). The DEV classification should be used
New Pool Wildcat (NPW) even if the well is drilled slightly deeper than
the target pool, especially where the deeper
The objective of an NPW well is the discovery
strata to be penetrated have no hydrocarbon-
of a new pool in an already discovered field,
bearing potential.
which includes all zones that the well
encounters. In circumstances where the well is
in relatively close proximity to the limits of a Re-entry (REN)
known pool(s), the NPW classification must be
A REN classification is assigned to a well that
based on technical data suggesting that a new
re-enters an existing wellbore for the purpose of
pool will be encountered. A well pursued with
recompleting the well as a producer or service
the objective of discovering a new pool and
well with no new strata being drilled. If new
drilled within or in close proximity to the limits
strata are to be drilled (e.g., by deepening,
of a known pool(s) but terminating shallower
whipstocks, or sidetracks), then assign the
than the known pool(s) is normally classified as
appropriate classification to the well.
an NPW. Exceptions are made when existing
wells in close proximity to the well have logs or
tests that strongly suggest the existence of the Development Service Well (DSW)
target pool. A DSW well is drilled to introduce fluids into a
formation or observe the performance of a
Deeper Pool Test (DPT) reservoir. Water injection, steam injection, and
observation wells are examples of DSW wells.
A DPT well is located within or in close
proximity to a known pool(s) and drilled with
the object of exploring for new, undiscovered Oil Sands Evaluation (OV)
hydrocarbon accumulations below the deepest An OV well is drilled in an oil sands area to
of the known pool(s). Only the interval below evaluate the oil sands and is not intended to
the deepest of the known pool(s) is exploratory. produce hydrocarbons.
The remaining metreage in a DPT well is
development. In circumstances where the
exploratory portion of the well is in relatively Test Hole (TH)
close proximity to the limits of a known pool(s), A TH well is drilled for geological and
the DPT classification must be based on geophysical stratigraphic evaluation purposes
technical data suggesting that a new pool will be and is not intended to produce hydrocarbons.
encountered.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 37
Experimental (EX)
An EX well is part of an EUB-approved
experimental scheme.
Other (OTH)
A well drilled for water production, brine
production, gas storage, or any other purposes
not covered by other Lahee classifications is
classified as OTH. It may be licensed under the
Oil and Gas Conservation Regulations, Section
2.020 or 2.040, depending on its purpose.
Technical Considerations When Assigning Lahee
Classifications
The oil- and gas-bearing portions of a pool
constitute a single accumulation, as set out in
the Oil and Gas Conservation Act, Section
1(1)(q). Therefore, step-out wells drilled to
encounter the oil leg of a known gas pool are
classified as development wells.
EUB-designated pooling orders (G orders) have
no bearing on the Lahee classification of a well,
although they do affect the well’s confidential
status. Such orders should be disregarded for
Lahee classification purposes because they may
not have been issued for nearby pools and
because their boundaries may not have been
updated to reflect current knowledge regarding
the areal extent and continuity of pools.
ASSIGNING CONFIDENTIALITY TO NEW WELLS
Confidential status on new wells is based on the
provisions described in the Oil and Gas
Conservation Regulations, Section 12.150, and
the Oil Sands Conservation Regulations, Section
15. The following is a guide for determining the
appropriate confidential status of new wells.
• NFW, NPW, OUT, TH, OV, and EX wells
are always CONFIDENTIAL - (C).
• DPT wells are CONFIDENTIAL - (C) if all
zones penetrated by the well are outside the
limits of an EUB-designated pool(s) as
defined by EUB G orders or inside the
boundaries of an existing EUB-designated
confidential pool.
38 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
A DPT well is CONFIDENTIAL BELOW -
(CB) if one or more uphole zones penetrated
by the well is inside an EUB-designated
non-confidential pool as defined by an EUB
G order(s). The well is then licensed as
CONFIDENTIAL BELOW THE—
(formation name of deepest non-confidential
pool the well penetrates).
• DEV, DSW, and REN wells are
CONFIDENTIAL - (C) if all zones
penetrated by the well are outside the limits
of an EUB-designated pool(s) as defined by
EUB G orders or inside the boundaries of an
existing EUB-designated confidential pool.
DEV, DSW, and REN wells are
CONFIDENTIAL BELOW - (CB) if one or
more uphole zones penetrated by the well is
inside an EUB-designated non-confidential
pool(s) as defined by an EUB G order(s).
The well is then licensed as
CONFIDENTIAL BELOW THE—(name of
the deepest non-confidential pool zone the
well penetrates).
If the base of the deepest non-confidential
zone is near the well’s total depth and there
are no potential hydrocarbon zones between
the base of the non-confidential zone and
the total depth, then the well is NON-
CONFIDENTIAL - (NC).
• OTH wells are NON-CONFIDENTIAL.
Requests for confidentiality on OTH wells
are reviewed on a well-by-well basis.
• A well drilled for the purpose of crude
bitumen production in an oil sands area is
NON-CONFIDENTIAL - (NC).
DRILL CUTTING SAMPLE REQUIREMENTS
For all wells with drill cutting sample
requirements, you must submit drill cuttings in
5 m intervals unless otherwise noted. The
following tables indicate the appropriate sample
requirements to be followed based on a well’s
Lahee classification and confidential status.
Areas 1 and 2 are identified on Figure 1, map of
Alberta (page 20).
 For a well being drilled deeper than the
AREA 1
Glauconitic Formation, drill cutting
NFW NPW DPT OUT DEV DSW OTH EX TH REN OV samples are to be submitted from 30 m
C N/A 0 0 above the Glauconitic Formation to total
CB N/A N/A X N/A X X N/A N/A N/A 0 N/A depth. For a well not being drilled deeper
than the Glauconitic Formation, no drill
NC N/A N/A N/A N/A X X X N/A N/A 0 N/A
cutting samples are required.

AREA 2 N/A Not applicable. Well should not be

NFW NPW DPT OUT DEV DSW OTH EX TH REN OV licensed with this combination of
confidential status and Lahee
C X X X X X N/A X 0 0 N/A
classification.
CB N/A N/A X N/A X X N/A N/A N/A 0 N/A
NC N/A N/A N/A N/A N/A N/A 0 N/A
EXCEPTIONS TO DRILL CUTTING SAMPLE
REQUIREMENTS
REST OF PROVINCE
Drill cutting samples are not required if the well
NFW NPW DPT OUT DEV DSW OTH EX TH REN OV meets the following criteria:
C X X X X X N/A X 0 0 0
CB N/A N/A N/A N/A N/A N/A 0 N/A • Total depth of the well is less than 600 m
and the well is classified as DEV or DSW.
NC N/A N/A N/A N/A 0 0 0 N/A N/A 0 N/A

• The well is horizontal and is classified as

0 No drill cutting samples required.
DEV or DSW.
X Drill cutting samples are to be submitted
• The well is drilled in an oil sands area for
from 30 m above the shallowest potential
the purpose of producing crude bitumen or
producing horizon to total depth. Drill
servicing a crude bitumen deposit and
cutting samples are not required to be
classified as DEV or DSW.
submitted over zones shallower than the
Belly River Formation in W5M, Chinook
• The well is classified as DEV and drill
Formation in W6M, or Viking/Bow Island
cutting samples have already been submitted
in W4M unless these zones are
over all potential producing horizons from a
specifically targeted by the well.
well drilled within the past 15 years in the
same quarter section as the proposed well
No drill cutting samples are required over
and to a depth equal to or greater than the
the non-confidential portion of the well.
proposed well.
Drill cutting samples are required to be
submitted from 30 m above the shallowest
Note that periodically the EUB may identify
potential producing horizon in the
areas where geological complexities dictate that
confidential portion of the well to total
additional samples should be taken. In those
depth. Drill cutting samples are not
cases, the EUB will notify the licensee of the
required to be submitted over zones
revised requirements before drilling
shallower than the Belly River Formation
commences.
in W5M, Chinook Formation in W6M, or
Viking/Bow Island in W4M unless these
zones are specifically targeted by the well. SURFACE CASING EXEMPTIONS
Guide 8: Surface Casing Depth Minimum
Drill cutting samples are required to be
Requirements sets out the technical guidelines
submitted from the base of surface casing
for determining surface casing in wells to be
to total depth.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 39
 FIGURE 1

40 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
drilled and also gives specific areas where
surface casing is not required. In addition, you
may obtain an exemption to the requirement to
set surface casing if you meet all of the
following criteria:
• The proposed well terminates at less than
950 m true vertical depth.
• The proposed well is located in or adjacent
to a development-type setting.
• The maximum absolute open flow (AOF)
gas rate from offset wells does not exceed
109 103 m3/day.
• There are no problems such as
overpressuring, severe lost circulation,
kicks, blows or blowouts, or artesian water
flows within 3 km of the proposed site.
If the proposed well meets the above criteria,
you must file the application as nonroutine and
provide the following information, where
applicable, with your well licence application:
1) Geology
• List all zones from surface to total
depth.
• Identify the porous or permeable zones.
• Identify if there is gas potential in the
hydrocarbon-bearing zones; if no gas
potential exists, provide an isopach map
showing how far the productive zone(s)
extends.
• If gas potential exists, state whether the
maximum AOF gas rate from the offset
wells exceeds 109 103 m3/day.
• State if there is an enhanced recovery
scheme within 1 km of the proposed
well.
2) Thermal Schemes
• Describe the method of recovery.
• State the frequency and duration of
cyclic operations.
• Give the volume of steam injected.
• Give the bottomhole distance to active
steaming and/or production-affected
areas.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000) • 41
• State temperatures and pressures at
observation wells.
• State how much of the reservoir is
affected by steaming operations.
• Give the time it takes for a steamed area
to cool once it has been produced.
• Give the temperature and pressure in the
production cycle at which it is safe to
drill.
3) Operations
• Research hole operations within 3 km
down to and including the terminating
formation and provide the location,
zone, depths, and type of hole problems,
including
– severe lost circulation
– artesian water flows
– hole sloughing
– kicks
– blows and blowouts
– abnormal pressures (>10 kPa/m)
– low cement tops
• For horizontal wells, indicate if
intermediate casing will be set prior to
drilling the horizontal section.
• Provide evidence that the conductor
casing will be set into a competent
formation.
• Indicate what cementing method you
will use when setting conductor casing.
In addition to the above, you must also
provide a map of the area showing
• proposed surface and bottomhole
locations
• existing wells within 3 km that are
drilled to the proposed terminating zone
• wells with hole problems within 3 km
• AOF gas rates for existing wells
• proximity to thermal wells
• proximity to water bodies
MINIMUM REQUIREMENTS FOR PRESSURE
TESTING CASING
For drilling operations, the minimum
requirement is to pressure test casing prior to
drilling to a minimum of 67 per cent of required
casing burst pressure or reservoir pressure,
whichever is less.
If the existing casing is to be used for
production purposes, prior to placing the well on
production the casing must be pressure tested to
67 per cent of required casing burst pressure or
reservoir pressure, whichever is less.
ALBERTA ENVIRONMENT
Alberta Environment (AENV) has provided the
following guidelines to enable the oil and gas
industry to identify well sites that are considered
environmentally sensitive or that may require
extraordinary conservation and reclamation
measures:
• Elevation change across the lease is >10 m.
• There are significant elevation changes
along or across the access road.
• Sandy erodible soils, alkaline flats, dry
sloughs, native prairie, or flood-irrigated
areas exist on the well site or access road.
• The well site or access road is within 30 m
of a valley/coulee break.
• The well site or access road is within the 1-
in-100-year floodplain.
42 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 1 (October 2000)
• There is intermittent drainage across the
well site or access road.
• There are known springs on the well site or
access road.
You must provide notification of your
application to AENV’s inspectors for any
well site that meets one or more of these
criteria prior to filing the application with
the EUB. Notification must be on a form
approved by AENV. AENV inspectors may
advise about site-specific issues that you should
take into account when applying for the licence.
You are required to comply with all relevant
requirements of the Environmental Protection
and Enhancement Act and to obtain all
necessary permits and licences required under
other acts, including but not limited to the Water
Act and the Public Lands Act. Advice from the
AENV inspector does not remove these
obligations.
APPENDIX 2—THE PRESERVATION OF ARCHAEOLOGICAL, PALAEONTOLOGICAL, AND
HISTORICAL RESOURCES
BACKGROUND
The Historical Resources Act
The need to preserve, study, and interpret the historical resources of
Alberta has long been recognized and was officially reflected in the
passage of the Alberta Heritage Act (subsequently amended to be the
Alberta Historical Resources Act [HRA]) in 1973. Within the act,
historical resources are defined as:
...any work of nature or of man that is primarily of value for its
palaeontological, archaeological, prehistoric, historic, cultural,
natural, scientific or aesthetic interest including, but not limited
to, a palaeontological, archaeological, prehistoric, historic or
natural site, structure or object.
Currently, the Cultural Facilities and Historical Resources Division
of Alberta Community Development is responsible for the
administration of the HRA. Generally, the implementation of the
HRA and its regulations has focused upon archaeological resources,
palaeontological resources, and historic sites.
HISTORICAL RESOURCES IMPACT ASSESSMENTS
In recognizing the non-renewable nature of historical resources,
Section 33 of the HRA provides the framework for Historical
Resources Impact Assessments and mitigative studies. When, in the
opinion of Alberta Community Development, an activity associated
with the development of a well is likely to result in the alteration,
damage, or destruction of historical resources, the person undertaking
the activity can be required to:
• conduct a Historical Resources Impact Assessment on the lands
to be affected by the activity;
• prepare and submit a report discussing the results of the
assessment; and
• undertake salvage, preservation, or protective measures.
Rethinking Alberta’s Historical Resources Management
Program
Alberta Community Development has been rethinking Alberta’s
historical resources management program with the intention of
revisiting the underlying principles 1 and procedures of the existing
system of resource management and introducing new principles
appropriate to government activities in the 1990s. Under the proposed
program, historical resources consultants would exercise their
professional discretion more independently from government,
meeting acknowledged standards of performance. After internal
discussions and consultation with energy industry representatives, the
following program has been developed for well sites.
THE HISTORICAL RESOURCES MANAGEMENT
PROGRAM FOR WELL SITES
Theoretically, all activities associated with the development of well
sites in the Province of Alberta are subject to the provisions of the
HRA. However, rather than implementing a program that requires the
conduct of a Historical Resources Impact Assessment for every well
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 2 (October 2000) • 1
site, Alberta Community Development has developed a program that
concentrates upon well sites targeted for lands upon which historical
resources have been recorded and/or whose topographic features have
a high potential for the presence of historical resources. The
underlying philosophy of the program is that it is not necessary for
Alberta Community Development to become involved in the review
of all well sites but only as necessary.
The Program
The implementation of the program2 for well sites has two stages.
The first, which has been largely completed as of summer 1997,
involved well sites situated on lands upon which Alberta’s most
significant historical resources are located and buffer zones adjacent
to these lands.
The second stage involves well sites targeted for lands that contain
high-sensitivity zones where historical resources are likely. This
includes areas where historical resources have been recorded and
lands whose topography has been demonstrated as highly likely to
hold historical resources (e.g., the terraces and prairie bluffs
overlooking drainage systems, the valley slopes of the Red Deer
River). It should be recognized that only a very small portion of
Alberta has been examined for historical resources. Accordingly,
most areas remain unknown and evaluations must focus on historical
resource potential.
The Historical Resources Act Clearance Process
Sources of Information: Alberta Community Development will
provide sources of information that applicants can consult to
determine whether their proposed well site involves lands for which
HRA clearance is required. Some of the sources have already been
developed (e.g., Listing of Significant Historical Sites and Areas3 and
integrated management plans); others remain in a conceptual state
(e.g., historical resources management area plans); while others
involve major revisions to existing concepts (e.g., historical resources
sensitivity zones map).
Historical Resources Sensitivity Map: Alberta Community
Development will develop a new historical resources sensitivity
zones map for regulatory approval processes. It has discussed an
earlier proposal with the petroleum and natural gas industry involving
mapping the historical resources referral lands on the 1:1 000 000
provincial base mapping system. Any activities targeted for lands
highlighted on the map would require clearance pursuant to the HRA.
The proposed mapping program could involve different scales. For a
quick reference, the 1:1 000 000 scale provincial base mapping
system may be adequate. The program would also establish an
electronic database.
Applying for Historical Resources Act Clearance: The process for
applying for clearance from the HRA will not be finalized until the
Joint Government-Industry Regulatory Review of well-site surface
access has been completed and approved. This may result in
additional changes to the current review of the application. In the
interim, applicants must submit a completed Historical Resources
Overview form to Community Heritage Services, Alberta
Community Development (see below).
When Does a Well Site Require Historical Resources Act
Clearance?
The implementation of the program for well sites has been phased
into the EUB’s Energy Development Application. HRA clearance is
required for all well sites targeted for:
• lands on which Alberta’s most significant historical resources
are located
• buffer zones adjacent to those lands
These lands are identified within the Listing of Significant Historical
Sites and Areas.
During the next year, the second stage of the Historical Resources
Management program for well sites will be implemented. This
involves well sites that are targeted for:
• lands with a known historical resource
• lands whose topographical features have a potential for the
presence of historical resources
As an applicant, you should consult the sources of information
provided by Alberta Community Development to determine whether
your well site is located on lands requiring HRA clearance. You may
obtain both a hard-copy and an electronic listing of the lands
requiring HRA clearance from Community Heritage Services. The
new edition of the 1:1 000 000 scale Historical Resources Sensitivity
Zones Map will be available in 1998.
Unless your well site is located on those lands listed above, it does
not require HRA clearance. The majority of well sites will not require
formal HRA clearance. On your EUB Energy Development
Application, Schedule 4, Section 9, check the NO box next to the
statement:
The proposed well site requires Historical Resources Act
clearance.
Alberta Community Development believes it unlikely that the
development of well sites and associated access roads will result in
the alteration, damage, or destruction of historical resources.
Should you discover historical resources during the conduct of any
activities associated with the well, you must report the discovery of
these resources to Alberta Community Development.
If your well site does require HRA clearance, on your EUB Energy
Development Application, Schedule 4, Section 9, check the YES box
next to the statement:
The proposed well site requires Historical Resources Act
clearance.
Submitting a Historical Resources Overview Form
If the well site does require HRA clearance, you must complete a
Historical Resources Overview form and submit it directly to
Community Heritage Services, Alberta Community Development.
You can apply for clearance for a single well site or an entire drilling
program on a single form. Alberta Community Development prefers
to deal with drilling programs as opposed to individual wells.
2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 2 (October 2000)
The form has two pages. The first asks for much of the information
already required on EUB Energy Development Application
Schedules 1 and 4. In lieu of filling in the first page of the Historical
Resources Overview form, you may submit copies of the first pages
of EUB Schedules 1 and 4.
The second page of the Overview form concerns land use,
topographic information, and historical resources information,
concluding with a recommendation regarding whether a Historical
Resources Impact Assessment is required. In almost all cases, a
qualified historical resources consultant should complete the second
page. In some cases, the applicant can complete the recommendation
portion of the overview form without a consultant’s services, such as
in the following example: a well is situated in an area that possesses
very high potential for the presence of historical resources, but
resources that are present have already been altered, damaged, or
destroyed.
When the historical resources consultant and/or you, the applicant,
recommend against the need for a Historical Resources Impact
Assessment and Alberta Community Development agrees, HRA
clearance will be granted. In keeping with the principle to avoid
“micro-managing,” Alberta Community Development will normally
concur with careful recommendations.
Historical Resources Impact Assessments
Well sites and/or their associated access roads situated within
historical resources management areas that contain the province’s
most significant historical resources require Historical Resources
Impact Assessments. Such assessments are also usually warranted for
well sites planned for lands where undisturbed historical resources
are likely to be encountered.
Most Historical Resources Impact Assessments require the applicant
to retain the services of a consulting archaeologist qualified to hold
an Archaeological Research Permit within the Province of Alberta.4
In fewer instances, the services of a consulting palaeontologist
qualified to hold a Palaeontological Collection Permit within the
Province of Alberta are required. A Historical Resources Impact
Assessment could have archaeological, palaeontological, and
historical sites concerns and requirements. In some cases, the services
of a qualified historian are required.
To assist applicants and consultants in conducting Historical
Resources Impact Assessments, Alberta Community Development
has prepared Guidelines for Archaeological Permit Holders in
Alberta. While the guidelines are directed to the archaeological
consultant, Sections 4 and 5 provide insight into the Historical
Resources Impact Assessment process. For the most part, the field
studies associated with the assessments are to be prior to initiation of
any land surface disturbance activities (most notably, top-soil
stripping).5
After completing the Historical Resources Impact Assessment, you
must submit a report discussing the results of the assessment to
Alberta Community Development. Based upon an evaluation of the
results of the field studies and the recommendations contained within
the report, Alberta Community Development may grant HRA
clearance for the well site or may require you to undertake salvage,
preservation, or protective measures. These measures could include
excavations, modifications to the boundaries of the well-site lease, or
the relocation of the lease and any associated access roads. Upon
completion of these additional measures, Alberta Community
Development will normally grant HRA clearance.
 3
End Notes
1
The ideas and principles used to shape the rethinking process are
discussed in Cultural Resources Management and the Energy
Industry: New Perspectives and Partnerships. To receive a
4
copy, contact Community Heritage Services, Historic Sites
Service, Cultural Facilities and Historical Resources Division,
Alberta Community Development, Old St. Stephen’s College,
8820-112 Street, Edmonton, Alberta T6G 2P8 (telephone: 403
5
431-2300; fax: 403-427-3956).
2
The Historical Resources Management Program for the
petroleum and natural gas industry is discussed in Cultural
Resources Management and the Energy Industry: New
Perspectives and Partnerships. See note 1.
An updated Listing of Significant Historical Sites and Areas will
be available in April 1998. Copies of the current list, updated to
31 January 1993, can be obtained from Community Heritage
Services (see note 1).
Lists of archaeologists, palaeontologists, and historians who are
interested in conducting Historical Resources Impact
Assessments are available from Community Heritage Services,
Alberta Community Development.
You may obtain an extract of Guidelines for Archaeological
Permit Holders in Alberta, Sections 4 and 5, from Community
Heritage Services.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 2 (October 2000) • 3
BLANK PAGE
APPENDIX 3—EUB INTERIM DIRECTIVES (IDS)

ID OG-76-2: Emergency Procedure Plans for Sour Gas Facilities


  

  
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EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 1
ID 81-3: Minimum Distance Requirements Separating New Sour Gas Facilities from Residential
and Other Developments







hospital, situated out of urban centres; and for the purpose of this
Directive includes any similar development the Board may
designate as a public facility;
MINIMUM DISTANCE REQUIREMENTS SEPARATING NEW
SOUR GAS FACILITIES FROM RESIDENTIAL AND OTHER (5) an urban centre is defined as a city, town, village, or other
incorporated centre, and for the purpose of this Directive includes
DEVELOPMENTS any similar development the Board may designate as an urban


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 facility and developments such as individual permanent dwellings,
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 centres;
The separation distances described in this directive were developed by
Alberta Environment and the Board and have been applied since early
1979 in granting approvals for sour gas facilities near areas of public
use. These distances increase as the potential sour gas release volumes
increase and with increasing population density.
With regard to encroachment of occupied buildings on existing sour gas
facilities, the Subdivision Regulations of The Planning Act, 1977, were
amended by Order in Council 382/79 to require setbacks similar to the
Board’s separation distances.
Interim Directive ID 79-2 is hereby rescinded.
ISSUED at Calgary, Alberta, on 16 December 1981.
APPENDIX 1 TO ID 81-3
MINIMUM DISTANCE REQUIREMENTS SEPARATING NEW
SOUR GAS FACILITIES FROM RESIDENTIAL AND OTHER
DEVELOPMENTS
9,:*7*
*7
For the purpose of this Directive:
(1) sour gas is natural gas having an H2S content of 10 moles per
kilomole or greater, or such lesser or greater H2S content that the
Board may stipulate in a particular case;
(2) a sour gas facility is any facility which produces, processes, or
transports sour gas including:
a) gas wells producing or capable of producing sour gas,
b) gas lines or secondary lines that transport sour gas,
c) gas plants, and
d) any other installations that the Board may designate;
(3) unrestricted country development is defined as any collection of
permanent dwellings situated out of urban centres and having more
than eight permanent dwellings per quarter section; and for the
purpose of this Directive includes any similar development the
Board may designate as an unrestricted country development;
(4) a public facility is defined as a recreational area such as a
campground, or a public building such as a rural school or
2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
(7) the calculated flow rate of potential H2S release from a sour gas
well shall be established using the maximum wellhead
deliverability that can be attained at any time through the tubing
against zero wellhead pressure, and shall be expressed in the unit
m3/s at standard conditions;
(8) the calculated volume of potential H2S release from a sour gas
facility, other than a sour gas well, shall be established using the
maximum operating pressure, shall be expressed in the unit m3 at
standard conditions, and for the purposes of this calculation shall
assume that any automatic block valves close instantaneously upon
failure of the facility.
POLICY:
For the purpose of the policy, sour gas facilities shall be grouped into
levels in accordance with their capability to release sour gas.
(1) A Level 1 facility is a sour gas well with a potential H2S release
rate of 0.3 m3/s or less, or any other sour gas facility with a
potential to release 300 m3 of H2S or less. A new Level 1 facility,
other than a sour gas well shall have no separation distance
requirement other than that associated with the easement for the
right of way. All wells remain subject to Section 2.110 of the Oil
and Gas Conservation Regulations which requires a separation
distance of 0.1 km. Notwithstanding this clause, the Board may
specify some other separation distance for a Level 1 facility should
the circumstances warrant such action.
(2) A Level 2 facility is a sour gas well with a potential H2S release
rate of more than 0.3 m3/s and less than 2.0 m3/s, or any other sour
gas facility with a potential to release more than 300 m3 and less
than 2000 m3 of H2S. A new Level 2 facility shall be situated to
provide 0.1 km separation distance between it and any permanent
dwelling, and 0.5 km separation distance between it and any urban
centre or public facility.
(3) A Level 3 facility is a sour gas well with a potential H2S release
rate of more than 2.0 m3/s and less than 6.0 m3/s, or any other sour
gas facility with a potential to release more than 2000 m3 and less
than 6000 m3 of H2S. A new Level 3 facility shall be situated to
provide 0.1 km separation distance between it and any permanent
dwelling, 0.5 km separation distance between it and any
unrestricted country development, and 1.5 km separation distance
between it and any urban centre or public facility.
(4) A Level 4 facility is a sour gas well with a potential H2S release
rate of more than 6.0 m3/s, or any other sour gas facility with a
 potential to release more than 6000 m3 of H2S. A new Level 4 APPLICATION FOR A WELL LICENCE
facility shall be so situated that as a minimum, it shall meet the APPLICATION FOR A PIPELINE PERMIT
requirements set out for a Level 3 facility. However, the Board
may require greater separation distances or set out other such  



(&
+
 
requirements it deems necessary. • a licence for a well to be drilled into a formation known or expected
(5) For ease of reference a summary of the foregoing policy is to contain sour gas, or
presented in Appendix 2. • a permit for a pipeline to transport sour gas,
(6) The Board recognizes that notwithstanding the level into which an • the applicant, in addition to any other requirement for the licence or
application for a sour gas facility may fall, under some special permit, shall submit
circumstances a detailed review may indicate that another H2S
release level is more applicable. 1 the calculated flow rate or volume of potential H2S release as
defined in Appendix 1,
2 the method of calculating the rate or volume and a statement of
APPENDIX 2 TO ID 81-3 known and assumed parameters used,

SUMMARY OF MINIMUM DISTANCE REQUIREMENTS 3 a plan or map showing:

SEPARATING NEW SOUR GAS FACILITIES FROM 3.1 the location of individual permanent dwellings, unrestricted
RESIDENTIAL AND OTHER DEVELOPMENTS country development or public facilities within the separation
distances set out in Appendix 1, and
3.2 the location of any urban centres within:
Potential H2S Releases
• 1.5 km of a Level 1 facility,
Level of Sour Gas Other Sour Minimum Distance to Various Developments • 2.0 km of a Level 2 facility,
Sour Gas Well Release Gas Facility
Facility Rate m3/s Release • 3.0 km of a Level 3 or 4 facility, and a statement that
Volume m3 the applicant has advised the municipal administration
of its intent to apply for a licence to drill the well, or
1 < 0.3 < 300 Minimum distance for wells 0.1 km as stated
in Section 2.110 of the Oil and Gas 3.3 a statement where appropriate, on the survey plan or
Conservation Regulations. elsewhere, that there are no dwellings, unrestricted country
No minimum distance for other sour gas development, public facilities, or urban centres within the
facilities expect that associated with distances specified in sections 3.1 and 3.2 above.
easement for right of way, unless otherwise
specified by the Board. 4 a list showing names, addresses, and land descriptions of all rural
owners and occupants whose property is, in whole or in part,
2 0.3 – 2.0 300 - 2000 0.1 km to individual permanent dwellings and
unrestricted country development. 0.5 km to
within:
urban centre or public facility. • 0.1 km of a Level l facility,

3 2.0 – 6.0 2000 - 6000 0.1 km to individual permanent dwellings up

to 8 swellings per quarter section.
0.5 km to an unrestricted country
development.
1.5 km to an urban centre or public facility.
4 > 6.0 > 6000 As specified by the Board, but not less than
Level 3.
• 0.5 km of a Level 2 facility,
• 1.5 km of a Level 3 or 4 facility,
5 such other information as the Board may require in the
circumstances.
Where an application is to be made to the Board for a licence for a well
drilled to a formation known or expected to contain sour gas, the
applicant shall submit either:
a) an application for a permit for a pipeline to transport the sour gas
to a processing plant or gathering system, or
b) a plan showing a proposed or possible pipeline route or alternative
routes which would conform with the separation distances set forth
in Appendix 1.

APPENDIX 3 TO ID 81-3

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 3
ID 90-2: Gas Meter Calibration
-# -
3. The licensee of a well or the operator of a battery, gas processing
plant, or compressor station, shall prove or calibrate each orifice
TO: All Oil and Gas Operators
gas meter by a meter proof consisting of
The Energy Resources Conservation Board (ERCB) issued Interim a) inspection of the pen arc, linkage, pressure stops, and pen
Directive ID 84-1 in October 1984 which specified minimum-frequency spacing;
schedules for calibrating gas meters and outlined calibration
requirements. The ID did not, however, specify the Board’s b) a zero, full span, and 9-point ascending/descending
expectations regarding the calibration procedure for orifice meters. calibration of the differential pressure element against a
Results of ERCB production audits and inspections have indicated there manometer or a suitable dead-weight tester;
are significant variations in procedures used by operators and meter c) a zero, 50 per cent of full span, and full span calibration of the
calibration companies to calibrate orifice meters. This directive is issued static pressure element against a suitable dead-weight tester or
to ensure a common understanding of the Board’s expectations other approved device;
regarding orifice meter calibrations.
d) a 3-point calibration of the temperature element; and
The ERCB considers an orifice meter calibration to be conducted
satisfactorily if it is carried out in accordance with the attachment to this e) visual inspection of the condition and installation of the
ID. orifice plate and orifice fitting.1

This directive replaces and supersedes Interim Directive 84-1. 8  '  #
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%  5. A card or tag shall be attached to the meter, on which is set down
the date of last calibration and the meter serial number.
a) Gas Plants - semi-annually
Sweet Gas Wells - annually 6. The orifice meter must be housed within a structure which safe-
Sour Gas Wells - annually guards the meter and will allow reasonable and unrestricted access
Oil Battery Test or Group - annually to the meter for inspection and calibration purposes.
Oil Battery Fuel Gas - annually
Compressor Stations - annually 1
Where an orifice plate is mou
#  a “slow change”
b) immediately following servicing or repairs to the orifice assembly, that should be noted on the calibration sheet and the plate removed
for inspection the next time the system is shut down.
meter.
c) Upon request by a Board representative.
2. Where a meter, other than an orifice meter, is used for gas
measurement, the meter shall be calibrated at the same frequency
as an orifice meter.

4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
ID 91-2: Corporate Level Emergency Response Plans
1) Emergency Definitions and Actions
-=>
--
1.1 A description of the types of occurrences or circumstances
that would, in the view of the company, constitute an
TO: All Oil, Gas and Pipeline Operators
emergency.


#
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 1.2 An outline of the actions and pre-planned procedures that an
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( emergency situation would initiate.

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 $  ! ' #  

 recording what happened and when.
 !*  
 
(," +? 1  2) Emergency Notification

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 2.1 A listing of company personnel to be contacted should an


& #'
The Board therefore believes that all energy companies must develop
and be prepared to implement a corporate-level emergency response
plan. This plan should outline the procedures that would be
implemented should an emergency incident take place that could have
the potential for negative impacts on the public or the environment.
Generally, events such as a sour gas release, blows or blowouts from
drilling, servicing or pipeline operations, major sweet gas releases, large
oil spills, oil, produced water or chemical spills off lease or into bodies
of water, and fires and fatalities would be classified as emergencies
within the context of a corporate plan.
The Board will not require corporate-level plans to be filed routinely,
but in certain situations may request that applicants for energy
developments submit their plans for approval. Through its normal
processing of applications, and its project reviews and inspection
operations, the Board may request submission of corporate plans for
review.
The Board does not expect companies to develop corporate-level plans
to the detail that is required in a site-specific emergency response plan.
Rather, the intent is to have companies address the basic fundamentals
of how the company will handle an emergency. An outline of the key
elements to be addressed in such plans appears in Appendix A. The
Board does not propose to prepare detailed guidelines.
The Board would like to draw particular attention to one of the key
elements in Appendix A, that is, Item 3, Public/Media/Government
Communications. The Board wishes to emphasize the need to prepare
for effective and timely communication between the company, the
public, and the media during an emergency, as any event may attract
considerable attention.
ATTACHMENT: APPENDIX A
emergency situation occur, as well as alternate personnel.
2.2 A brief description of each emergency team member’s area of
responsibility.
2.3 A listing of government agencies (and others) that should be
notified in the event of an emergency and at what stage of the
emergency these agencies should be contacted.
3) Public/Media/Government Communications
3.1 A description of the procedures that will be established to
contact and maintain communications with directly impacted
publics in order to keep them apprised of the situation and
how it is likely to affect them. This would include plans for
evacuating persons living, working or travelling in the
immediate vicinity of the incident.
3.2 A description of the procedures that will be utilized to
respond to the media and keep them informed and updated on
a regular basis. This will include the identification of
corporate-level spokespersons.
3.3 A description of procedures to be followed to establish
effective communication links between company
representatives at the emergency site, corporate-level
decision-makers wherever they may be located, and the
ERCB and other government agencies.
4) Support Services
4.1 A listing of support organizations that could be mobilized to
assist during an emergency. This might include contractors
specializing in public and media communications, air
monitoring, fire fighting, safety, oil spill co-operatives, etc.
5) Review and Updating
5.1 The corporate-level emergency plans should be reviewed and

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ID 91-3 Heavy Oil/Oil Sands Operations
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EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 9
ATTACHMENT 2 TO ID 94-1: 1. ERCB IL 90-6, Measurement Guideline—Trucked Oil Production.
2. ERCB IL 93-10, Revised Measurement and Accounting
STANDARDS OF ACCURACY FOR OIL, GAS, AND WATER PRODUCTION
Procedures for Southeastern Alberta Shallow Gas Wells.
Maximum
Uncertainty 3. ERCB IL 91-9, Exemption From Gas Measurement - Crude
of Monthly Volume Oil/Bitumen Wells.
A. Oil Well Battery 4. ERCB IL 92-8, Crude Oil Pipeline Truck Terminal Measurement
Guidelines.
(i) Total battery oil (group or custody
transfer measurement) (ref. 1,4) 5. ERCB Guide G-49, Gas Density Measurement Frequency.
Delivery point measures
less than 100 cubic metres per day. 1%
Delivery point measures
more than 100 cubic metres per day. 0.5%
(ii) Total battery gas (ref. 3,5)
More than 500 cubic metres per day
and delivered to a gathering system. 3%
More than 500 cubic metres per day and flared. 5%
Less than 500 cubic metres per day. 20%
(iii) Total battery water 5%
(iv) Well oil (proration battery)
Class 1 (High), more than 30 cubic metres per day. 5%
Class 2 (Medium), more than 6 cubic metres per day
but less than or equal to 30 cubic metres per day. 10%
Class 3 (Low), more than 2 cubic metres per day
but less than or equal to 6 cubic metres per day. 20%
Class 4 (Stripper), less than or equal to
2 cubic metres per day. 40%
(v) Well gas (measurement uncertainty only) (ref. 3,5)
More than 16.9 thousand cubic metres per day. 3%
More than 500 cubic metres per day but less
than 16.9 thousand cubic metres per day. 5%
Less than 500 cubic metres per day. 20%
(vi) Well water (measurement uncertainty only) 10%
B. Gas Well Battery
(i) Total battery gas 3%
(ii) Total battery water 5%
(iii) Well gas (ref. 5)
More than 16.9 thousand cubic metres per day. 3%
Less than 16.9 thousand cubic metres per day. 5%
Effluent measurement 5%
Proration battery (ref. 2) 15%
(vi) Well water 10%

REFERENCES

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 11
ID 95-3: Storage Requirements for the Upstream Petroleum Industry
26 July 1995
TO: All Oil and Gas Operators
All Oil Sands Operators
All Drilling and Servicing Contractors
All Oilfield Waste Management Facility Operators
STORAGE REQUIREMENTS FOR THE UPSTREAM
PETROLEUM INDUSTRY
This interim directive highlights the material storage requirements for
the upstream petroleum industry and introduces AEUB Guide G-55.
The guide contains aboveground tank, underground tank, container,
oily waste, and bulk pad storage requirements for those materials
produced, generated or used by the upstream petroleum industry,
including associated wastes. These requirements apply to all facilities
under the jurisdiction of the Alberta Energy and Utilities Board
(AEUB). For those facilities that also require an operating approval
from Alberta Environmental Protection (AEP), additional material
storage requirements may also be specified by AEP. However, the AEP
requirements will generally be consistent with these requirements.
The storage requirements are intended to prevent soil and groundwater
contamination by ensuring the integrity of storage tanks and other
primary containment devices and by requiring adequate secondary
containment, leak detection, and weather protection for the storage
device. The AEUB will expect any storage device installed after 1
January 1996 to meet the requirements within Guide G-55.
BACKGROUND
On 11 February 1994, the ERCB initiated a public review of the draft
report Recommended Oilfield Waste Management Requirements
previously published in August of 1993. The public review process
identified a concern that other stored materials besides wastes could
also adversely affect the environment if released. As a result, a
government/industry committee was formed to develop material storage
requirements that would be applicable to all aspects of the upstream
petroleum industry.
GENERAL STORAGE REQUIREMENTS
General environmental protection and safety measures must be
implemented when storing any petroleum industry material that may
adversely affect the environment. Such measures include: choosing an
appropriate site, following appropriate engineering and construction
standards, and implementing secondary containment, leak detection,
and weather protection provisions.
ABOVEGROUND AND UNDERGROUND TANKS
An aboveground tank or collection of aboveground tanks with a total
internal volume greater than 1 m3 but less than 5 m3 must be visually
inspected on a monthly basis to verify integrity and either be externally
coated or made from weather-resistant material. An aboveground tank
or collection of aboveground tanks with a total internal volume equal to
or greater than 5 m3 must have a secondary containment system, leak
detection system, and an exterior coating to protect it from the weather.
12 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
A tank is considered underground when it is partially or completely
buried and does not allow for the visual inspection of the top and
complete external sides of the tank. As a general rule, aboveground
tanks are considered by the Board to be preferable to underground
tanks. Regardless of volume, an underground tank must have a leak
detection system and, in most circumstances, have a secondary
containment system.
The above provisions are relaxed in situations where the fluids being
stored meet surface discharge criteria or where fluids are only
infrequently stored in the tanks and the tanks are emptied immediately
after use.
CONTAINERS
A container is defined as any portable aboveground device (eg. drum,
pail, bag, box, tote, etc.) which has a capacity that does not exceed 1
m3.
A collection of containers with an aggregate volume greater than
1 m3 (ie. approximately five 45 gallon drums) requires a secondary
containment system. Weather protection may also be appropriate to
maintain the integrity of the container. The type of secondary
containment and weather protection depends on the nature of the
contained material, the type of container, and the design of the storage
compound.
OILY WASTE STORAGE FACILITIES
Oily waste storage facilities are typically used to store produced sand
from heavy oil/oil sands schemes or as a waste receiving or residual
solids storage system at an oilfield waste management facility. Oily
waste storage facilities require leak detection systems and in most
circumstances secondary containment.
SOLID MATERIALS ON BULK PADS
Operators storing solid materials on bulk pads shall incorporate an
impervious liner and leachate collection system into the storage area.
INSPECTION, MONITORING, AND RECORD KEEPING
The AEUB will expect operators of storage facilities/areas to maintain
accurate inventory, inspection, and leak detection records for 2 years,
and where applicable groundwater monitoring records for 5 years.
EXISTING FACILITIES
Operators of facilities constructed and operated prior to 1 January 1996
will be required to demonstrate that their storage practices, facilities,
and containment devices meet the intent of the requirements within
AEUB Guide G-55. It is expected that all tanks, aboveground and
underground, will be inspected and/or tested prior to 31 October 2001.
Operators have until 31 October 2001 to meet the storage provisions for
containers, oily waste storage facilities, and bulk pads. See Appendix 1
of the Guide G-55 for more details.
For further information, contact the AEUB Environment Protection
Department at 297-3184.
AEUB Guide G-55 is available from AEUB Information Services
Department, 297-8190.
ID 96-2: Facility Application Requirements
9 April 1996
TO:All Oil, Gas, and Pipeline Operators
This interim directive introduces EUB Guide 56 and identifies the
changes to related interim directives, informational letters, Oil and Gas
Conservation Regulations, and Pipeline Regulation. The changes will
be in effect as of 15 May 1996. Energy development applications
submitted after 15 May 1996 shall utilize the forms and follow the
procedures described in Guide 56.
Guide 56 summarizes and presents the expectations and requirements
for certain energy development applications. It covers a new integrated
application process for specific oil and gas facilities and pipelines
including:
• oil and gas batteries,
• gas-processing facilities,
• compressor stations,
• surface installations associated with pipelines,
• oil and gas gathering systems, and
• transmission pipelines.
Guide 56 deals with applications for new facilities and pipelines as well
as applications for modifications to existing operations. It does not
cover wells.
The goal was to create a user-friendly guide to help companies, agents,
and consultants better understand the EUB's expectations and
requirements so that they can meet these requirements and prepare
complete and accurate applications. If the applicant desires, one
application package can now include all facilities and pipelines
associated with a specific project. Previously, a separate application
was required for each component of the project.
The following are some of the advantages of the new process to the
industry:
• It helps to minimize the administrative burden on industry through
the creation of a streamlined, check-box format.
• It allows for quicker processing of complete, accurate, and
compliant applications, thus reducing application turn-around
time.
• It provides clear, consistent, and accessible requirements and
expectations to the industry.
• It minimizes data submissions.
• It provides a consistent and equitable approach to compliance and
enforcement on a province-wide basis.
The advantages to the EUB include:
• It makes industry more accountable for knowing the EUB's
regulations and standards.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 13
• It reduces data transmission, i.e. applicants keep most support
material.
• It assists in the EUB's efficiency by reducing pre-approval review
and interaction with applicants.
• It helps the EUB continue to fulfil its public interest
responsibilities.
• It provides flexibility to the EUB to respond to changes in
workload triggered by industry activity.
In addition to the application requirements identified in the Guide, the
applicant must continue to comply with all other EUB requirements
identified in the appropriate Interim Directives and Informational
Letters. The new integrated approach does not change the
responsibilities of the EUB, but it places more emphasis on the
company's ongoing responsibility for accurately completing the
applications and for complying with regulatory requirements. As
always, EUB takes full responsibility for the approval and the
enforcement of regulatory requirements. There are serious
consequences associated with non-compliance with the requirements
and regulations as explained in the guide and its associated references.
The changes to the interim directives, informational letters, Oil and Gas
Conservation Regulations, and Pipeline Regulation related to the
implementation of the integrated application process are in Appendix 1
of this Interim Directive. The regulations and other documents affected
by the changes described in this Interim Directive will be revised in due
course.
For further information, contact the EUB Facilities Division at (403)
297-4369.
EUB Guide 56 is available from the EUB Information Services Section,
(403) 297-8190.
Céline Bélanger
Chair
APPENDIX I: CHANGES TO INTERIM DIRECTIVES,
INFORMATIONAL LETTERS, OIL AND CONSERVATION
REGULATIONS AND TO PIPELINE REGULATION
The following changes to interim directives, informational letters, and
regulations are as a result of the implementation of the integrated
energy development application process described in EUB Guide 56.
The changes will be in effect as of 15 May 1996.
INTERIM DIRECTIVES
• ID 81-3 MINIMUM DISTANCE REQUIREMENTS
SEPARATING NEW SOUR GAS FACILITIES FROM
RESIDENTIAL AND OTHER DEVELOPMENTS
Appendix 3 is replaced by the requirements identified in Guide 56.
• ID 88-2 PROPOSED WELLS, PRODUCTION FACILITIES,
AND PIPELINE NOTIFICATIONS OF RURAL AND URBAN
ADMINISTRATIONS
Amend by striking out the reference to ERCB Guide G-35 and
substituting EUB Guide 56. It is further amended by requiring
applicants to meet the requirements of Guide 56 for contact with
applicable Urban Authorities. Meeting the requirements of Guide
56 replaces the necessity to include a statement that the Urban
Authority does or does not have any objections to the application.
• ID 94-6 ONE-STEP PIPELINE PERMIT/LICENCE AND
LICENCE AMENDMENT APPLICATION
This directive and Guide 56 supersede Interim Directive ID 94-6.
The one-step philosophy is incorporated into the procedures and
requirements described in Guide 56. The interim changes to the
Pipeline Regulation described in this directive continue to refer to
a permit and a licence, however, the requirements will be satisfied
through the one-step process described in the Guide 56.
INFORMATIONAL LETTERS
• IL 88-2 PRODUCTION FACILITY APPLICATIONS - NEW
APPLICATION PROCEDURES AND REGULATION
CHANGES
Hereby rescinded.
• IL 88-5 APPLICATION FOR APPROVAL OF NATURAL-GAS-
DRIVEN COMPRESSORS
Amended by striking out the following references, under
Application Procedures:
• section 15.050 of the Oil and Gas Regulations,
• Production Facility Application form, parts 1 and 2 and
ERCB Guide G-35, and
• section 3 of the Pipeline Regulation.
• IL 91-1 APPLICATION FOR APPROVAL OF GAS
PROCESSING SCHEMES - POLICY ON PLANT
PROLIFERATION
Amended by striking out the following reference, under
Availability of Existing Gas Plant Capacity:
• section 15.050(3)(w) of the Oil and Gas Regulations.
• IL 94-3 PRODUCTION FACILITY APPLICATIONS - SWEET
SINGLE WELL OIL BATTERIES
Hereby rescinded.
REGULATIONS
Oil and Gas Conservation Regulations
14 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
The requirements of this directive are modifications to the identified
regulations.
Section 7.002(1)
An application for the location and construction of or modification to a
battery or compressor station shall be submitted in accordance with
section 15.210.
Section 9.020(1)
An application under section 26(1)(b) of the Act, section 3(1)(a) or 4(1)
of the Clean Air Act or section 3(1)(e) or 4(1) of the Clean Water Act
for approval to construct and to operate a new scheme or a major
modification to an existing scheme for the processing of gas, shall be
filed with the Board and shall conform with the requirements of section
15.050.
Section 9.020(2)
REPEALED
Section 9.020(3)
Upon the filing of a completed application for approval, or a major
amendment of approval, of a scheme for the processing of gas and
where it appears to the Board that its decision on the application
(a) may directly and adversely affect the rights of any person, the
Board shall hold a public hearing or publish notice of the
application, or
(b) would not directly and adversely affect the rights of any person,
the Board may process the application without notice or hearing.
Section 9.020(4)
REPEALED
Section 15.050 (1)
An application under section 9.020(1) for approval of a new scheme or
an amendment to an existing scheme for the processing of gas shall
include
(a) a completed form prescribed for that purpose and obtained from
the Board, entitled "Energy Development Application", and the
appropriate documentation to support the information provided on
the form, as detailed in Guide 56, and
(b) any other information that the Board may require.
Section 15.050(2) (3) (4) (5)
REPEALED
Section 15.210(1)
An application under sections 7.001 and 7.002 for approval of a new
battery or compressor station, or modification to an existing battery or
compressor station, shall include
(a) a completed form prescribed for that purpose and obtained from
the Board, entitled "Energy Development Application", and the
appropriate documentation to support the information provided on
the form, as detailed in Guide 56, and
(b) REPEALED
(c) any other information that the Board may require.
Section 15.211
REPEALED
Pipeline Regulation
The requirements in section 2., 3., 4., 5., 60., 61., 62., 63., 64., 65., 66.,
67., 68., 69., 70., 71., and 72. are replaced with the following:
Application for a permit to construct pipeline or station and for a
licence to operate pipeline or station
2. (1) Unless otherwise directed by the Board, an application
under Part 4 of the Act for a permit to construct a
pipeline, gas compressor station, an oil pumping station,
a water injection station, an oil loading and unloading
terminal or a tank farm or other installation and for a
licence to operate such pipelines and installations shall
include the information identified in Guide 56.
(2) An application for a permit and a licence referred to in
subsection (1) is not required to replace portions of a
pipeline if
(a) the length of the replacement is less than 100
metres,
(b) the replaced pipeline is removed, and
(c) the work is carried out within the existing right of
way.
(3) An application for a permit and a licence referred to in
subsection (1) is not required if
(a) the length of the pipeline is less than 50 metres, and
(b) the pipeline will not transmit gas containing more
than 10 moles of hydrogen sulphide gas per
kilomole of natural gas or any lesser hydrogen
sulphide content that the Board may stipulate in a
particular case.
(4) An application for a permit and a licence referred to in
subsection (1) is not required if
(a) the pipeline is within a well, battery, satellite, gas
plant, gas compressor station, an oil pumping
station, a water injection station, an oil loading and
unloading terminal or a tank farm or other
installation lease boundary site,
(b) the pipeline is not within the access road to a
facility listed in (a), and
(c) the pipeline will not transmit gas containing more
than 10 moles of hydrogen sulphide gas per
kilomole of natural gas or any lesser hydrogen
sulphide content that the Board may stipulate in a
particular case, and
(d) the pipeline will not transmit an HVP liquid.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 15
Survey of right-of-way boundaries and emergency shutdown devices
3. (1) The applicant must ensure that the location of the right-
of-way boundaries will be surveyed according to the
Surveys Act before the commencement of construction,
unless otherwise approved by the Board in special
circumstances.
(2) If any part of an emergency shutdown device fails on a
pipeline which transmits gas containing more than 10
moles of hydrogen sulphide gas per kilomole of natural
gas or any lesser hydrogen sulphide content that the
Board may stipulate in a particular case, the emergency
shutdown device shall close and remain closed.
Application for licence to operate pipeline or station
4. REPEALED
Notice to Board of permitted work incompletion
5. The permittee shall advise the Board at least 30 days prior to
the permit expiry date if the work for which a permit has been issued
will not be completed by the permit expiry date.
Pipeline not in operation for a 12-month period
60. Unless otherwise directed by the Board, if a pipeline or any
part of a pipeline has not been in normal operation within the
previous 12-month period, the licensee shall apply to the
Board for consent to discontinue the operation of the pipeline
or for consent to remove or abandon the pipeline.
Discontinuation of pipeline
61. (1) Unless otherwise directed by the Board, an application to
the Board for consent to discontinue the operation of a
pipeline or any part of a pipeline shall include the
information identified in Guide 56.
(2) Unless otherwise directed by the Board, on receipt by the
applicant of the Board's consent to discontinue a pipeline
or any part of a pipeline, the pipeline or part of the
pipeline to be discontinued shall be
(a) physically isolated or disconnected from any
operating facility, and
(b) cleaned if necessary and purged with fresh water,
air or inert gas and left in a safe condition.
Corrosion control on discontinued pipeline
62. Corrosion control measures shall be maintained on a
discontinued pipeline.
Notice to Board of discontinuation incompletion
 63. The licensee shall advise the Board at least 30 days prior to
the expiry of the Board's consent to discontinue a pipeline if
the work will not be completed by the expiry date.
Application to resume operation
64. (1) Unless otherwise directed by the Board, an application to
the Board for consent to resume the operation of a
pipeline or any part of a pipeline which has not been in
normal operation within the previous 12-month period
shall include the information identified in Guide 56.
(2) The Board may require a pressure test and
nondestructive examination of the pipeline or part
thereof before granting consent to resume operations.
Notice to Board of resumption incompletion
65. The licensee shall advise the Board at least 30 days prior to
the expiry of the Board's consent to resume the operation of a
pipeline or part of the pipeline if the work will not be
completed by the expiry date.
Application to remove or abandon
66. (1) Unless otherwise directed by the Board, an application to
the Board for consent for removal or abandonment of a
pipeline shall include the information identified in Guide
56.
(2) Unless authorized by the Board, the licensee shall retain
ownership of the abandoned pipeline.
Abandonment of pipeline
67. (1) On receipt by the applicant of Board consent to the
abandonment of a pipeline or part of a pipeline, the
pipeline or part of the pipeline to be abandoned shall be
(a) physically isolated or disconnected from any
operating facility,
(b) cleaned if necessary and purged with fresh water,
air or inert gas and left in a safe condition, and
16 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
(c) plugged or capped at all open ends.
(2) The licensee shall advise the Board at least 30 days prior
to the expiry of the Board's consent to remove or
abandon a pipeline or part of the pipeline if the work will
not be completed by the expiry date.
Responsibility for abandoned pipeline
68. The Board's consent for an abandonment operation does not
relieve the licensee or its assignee from the responsibility of
further abandonment or other operations that may from time
to time become necessary.
Liner installation
69. (1) Unless otherwise directed by the Board, an application to
the Board for consent to install a liner in a pipeline or a
part of a pipeline shall include the information identified
in Guide 56.
(2) The licensee shall advise the Board at least 30 days prior
to the expiry of the Board's consent to install a liner in a
pipeline or part of the pipeline if the work will not be
completed by the expiry date.
Change in substance or pressure
70. Unless otherwise directed by the Board, an application to the
Board for consent to use a pipeline for the transmission of a
substance other than the substance authorized by the license
or to provide for a change in the licensed maximum operating
pressure of a pipeline shall include the information identified
in Guide 56.
Testing requirements of change in substance or pressure
71. The Board may prescribe any testing requirements it
considers necessary before granting an approval under section
70.
Notice to Board of change in substance or pressure incompletion
72. The licensee shall advise the Board at least 30 days prior to
the expiry of the Board's consent to change of substance
transmitted or maximum operating pressure if the work will
not be completed by the expiry date.
ID 96-3: Oilfield Waste Management Requirements for the Upstream Petroleum Industry
22 November 1996
TO: All Oil and Gas Operators
All Oil Sands Operators
All Drilling and Servicing Contractors
All Oilfield Waste Management Facility Operators
OILFIELD WASTE MANAGEMENT REQUIREMENTS FOR THE
UPSTREAM PETROLEUM INDUSTRY
This interim directive highlights the requirements for the appropriate
management of oilfield waste and introduces the Alberta Energy and
Utilities Board (EUB) Guide 58; Oilfield Waste Management
Requirements for the Upstream Petroleum Industry. This document,
which covers all aspects of the regulation of oilfield waste, applies to
all oil and gas, oil sands, and oilfield waste management facilities
under the jurisdiction of the EUB.
This interim directive as well as Guide 58, supersede the following
EUB Informational
Letters:
IL 81-10 Disposal of Campsite and Wellsite Waste,
IL 85-16 Storage, Handling, and Disposal of Oily Wastes,
IL 93-8 Draft Recommended Oilfield Waste Management
Requirements, and
IL 95-4 Criteria for the Application of Oily Byproducts to
Roads.
Background
On 11 February 1994, the ERCB (now the EUB) initiated a public
review of the draft report, Recommended Oilfield Waste Management
Requirements, which was previously published in August 1993. A
multi-stakeholder Steering Committee was established to identify
areas of the document that required further work, based on the public
review. As the review of each area was completed, either by a
subcommittee or independently by the EUB, the sections were tabled
with the Steering Committee for their endorsement and consolidation
into Guide 58.
Highlights of the Oilfield Waste Management Requirements for the
Petroleum Industry
Significant areas of Guide 58 are highlighted in the following
paragraphs. It is in these areas where surveillance, compliance
auditing, and enforcement will be focussed initially. The onus is
placed on the waste generators and receivers to fully understand and
comply with all requirements as listed and explained in Guide 58.
1. Waste Generator Responsibilities
The oilfield waste generator (i.e. EUB licensee and/or approval
holder) is responsible for ensuring that the requirements within
Guide 58 are followed, including:
C properly characterizing and classifying their oilfield wastes,
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 17
C utilizing appropriate treatment and disposal practices,
C understanding the capabilities and limitations of the
methods selected for the treatment and/or disposal of their
wastes,
C maintaining accurate and complete waste documentation
and manifests,
C informing waste carriers and receivers of the properties of
their oilfield wastes, and
C ensuring operational requirements have been satisfied and,
if applicable, required approvals are in place for any on-site
waste handling, treatment, and disposal method.
2. Waste Receiver Responsibilities
The oilfield waste receiver is responsible for ensuring that the
requirements within Guide 58 are followed, including:
C ensuring required approvals are in place and operational
requirements have been satisfied for all waste handling,
treatment, and disposal methods offered,
C understanding the capabilities and limitations of their
treatment and disposal methods/facilities and
communicating these to waste generators,
C accepting only those wastes their facility is approved to
receive,
C maintaining accurate and complete waste documentation
and manifests,
C operating their facilities in compliance with licences and
approvals, and
C upgrading their equipment and operating practices as
necessary to comply with changes in regulatory
requirements.
3. Importation
Wastes generated outside of Alberta resulting from the
exploration and production of oil and gas and exhibit the
properties that would classify the wastes as dangerous in
accordance with Section 5.0 of Guide 58 may be imported into
Alberta for purpose of treatment only. These wastes must be
directed into the Alberta Special Waste Management System,
which is under the jurisdiction of Alberta Environmental
Protection (AEP).
Oilfield wastes that would be classified as non-dangerous in
accordance with Section 5.0 of Guide 58 may be imported into
Alberta for purpose of treatment and/or disposal. Licensees
and/or approval holders of facilities under the jurisdiction of the
EUB must obtain approval from the EUB to receive imported
non-dangerous oilfield wastes.
4. Waste Characterization/Classification
The waste generator is responsible for properly characterizing
and classifying each oilfield waste. This characterization is then
used in assessing the appropriate handling, treatment, and
disposal of that waste. The waste must be classified as either
dangerous oilfield waste (DOW) or non-dangerous oilfield
waste (non-DOW), in accordance with Section 5.0 of Guide 58.
Oilfield waste must not be mixed with any solid or liquid for the
primary purpose of dilution to avoid any Alberta regulatory
requirement.
5. Manifesting and Tracking
With only a few exceptions, dangerous oilfield wastes generated
in Alberta and transported on public roads within Alberta must
be manifested. The EUB Alberta Oilfield Waste Manifest must
accompany Alberta generated, dangerous oilfield wastes that are
being transported to another site in Alberta (refer to Section 8.2
of Guide 58 for applicable exemptions).
Dangerous oilfield wastes moving across provincial boundaries
or federal boundaries must be transported in compliance with
the Transportation of Dangerous Goods Act and Regulation
(TDG). This includes usage of the federal TDG manifest as
opposed to the EUB waste manifest.
The waste generator is responsible for reconciling any
discrepancies associated with the manifest that accompanies a
shipment of dangerous oilfield waste.
Oilfield waste generators must implement a waste tracking
system for dangerous oilfield wastes and for reportable oilfield
wastes, as identified in Table 9.1 of Guide 58. Information that
must be tracked includes:
C point of waste generation/consolidation,
C waste type,
C waste quantity generated, and
C treatment/disposal methods.
At any time, the EUB may audit a generator's waste tracking
system or request the generator to provide information pertinent
to the waste tracking system.
Each year selected waste generators (licensees and/or approval
holders of wells or other facilities) will be required to submit an
oilfield waste disposition report for the previous calendar year.
The report must summarize the information obtained through
the waste tracking system.
6. Oilfield Waste Management Facilities
An oilfield waste management facility may consist of one or
more of the following components:
C waste storage area/facility,
C waste transfer station,
C waste processing facility,
C surface facility associated with a waste disposal well,
C waste disposal well (Class Ia or Ib),
C cavern (used for the disposal of waste),
18 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
C landfill,
C biodegradation facility, and
C thermal treatment facility.
Applicants must obtain written approval from the EUB to
construct and operate all stand-alone oilfield waste management
facilities. Refer to Part D of Guide 58 for details regarding
whether approval or notification is required to integrate a
specific waste management component into an existing EUB
approved oil and gas or oil sands facility.
All licensees and/or approval holders of oilfield waste
management facilities must comply with the requirements
specified in Part D of Guide 58 for siting, safety, waste
characterization, environmental impact assessment, design and
operation, site assessment and groundwater protection, record
keeping, and closure.
Financial security will be required for EUB approved fixed
thermal treatment facilities (except for small batch feed and
campsite incinerators), all EUB approved landfills, and all
stand-alone oilfield waste management facilities.
(a) Waste Storage Area/Facility and Waste Transfer Station
Waste storage areas are defined as sites on existing EUB
approved oil and gas or oil sands facilities used for the
purpose of collecting oilfield wastes or oily wastes from
one or more of a company's facilities. The licensee and/or
approval holder of the facility where the storage area is
located must be the same as that of the facilities from where
the collected wastes were generated.
A stand-alone facility, which has been constructed for the
purpose of collecting and storing oilfield wastes until
volumes are sufficient for economic transfer to treatment
and disposal facilities, is considered either a storage facility
or a transfer station. The licensee and/or approval holder
of a storage facility must be the same as that of the facilities
from which the wastes are collected (i.e. first party
receiver). A waste transfer station can receive wastes
generated by various companies (i.e. third party receiver),
as well as from various sites owned by a single company.
(b) Surface Facilities Associated With Waste Disposal Wells
The deep well disposal of oilfield waste fluids involves
regulatory requirements for both the disposal well and the
surface facility that is associated with the disposal well.
The surface facility associated with a waste disposal well
requires approval when:
• the disposal well is a stand-alone Class Ia or Ib well,
or
• the surface facilities associated with the well are not
covered in a new application or by an existing EUB
facility approval.
(c) Waste Processing Facilities
A waste processing facility typically consists of a system of
surface equipment designed for the treatment of oilfield
waste material received from any oil and gas or oil sands
operation. Some oilfield waste processing facilities are
 designed specifically for the recovery of crude oil, while
others are designed to reduce volumes, alter chemical
characteristics, and/or remove dangerous components prior
to final disposal. Caverns which accept crude oil laden
wastes for the purpose of crude oil recovery, also require
approval as a waste processing facility.
Waste processing facilities accepting only wastes generated
within the upstream petroleum industry only require
approval from the EUB.
(d) Oilfield Landfills
Oilfield landfills are:
• operated by an oil and gas company for the purpose of
disposing oilfield wastes produced from their own
operations,
• operated as part of an oilfield waste management
facility for the purpose of disposing residual wastes
resulting from their treatment process, or
• operated by an independent company for the purpose
of disposing third party waste generated by the
upstream petroleum industry.
Construction or expansion of all oilfield landfills, including
those to be integrated into an existing EUB approved
production facility, requires EUB approval.
The disposal of any liquid oilfield waste into any landfill is
prohibited.
Only EUB approved Class Ia or Ib landfills, or AEP
regulated landfills which are approved to accept hazardous
waste, shall receive dangerous oilfield wastes.
Generators wishing to dispose oilfield wastes into AEP
regulated landfills must properly characterize their wastes
and ensure the landfill in question is appropriately designed
(as outlined in Section 15.0 of Guide 58) and is approved
to accept wastes exhibiting the properties of the oilfield
waste in question.
(e) Biodegradation
Land treatment is limited to those situations where non-
refined hydrocarbon (i.e. crude oil or condensate)
contaminated soils resulting from leaks/spills, and non-
refined hydrocarbon contaminated pit/pond sludges, are
land treated in a single application on the site on which
they were generated. These production sites must be
active.
Licensees and/or approval holders must document their
land treatment activities to verify that the protocol outlined
in Section 16.0 of Guide 58 has been met, must retain this
information until a reclamation certificate for the site has
been issued, and must make this information available to
AEP or EUB staff upon request.
Biocell or biopile techniques can be used to biologically
degrade oilfield wastes in a contained and controlled
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 19
system. Once the biodegradation process is complete the
material must be removed from the system and forwarded
for further treatment or disposal, or be returned to the
originating site to be used as fill material if it meets
acceptable criteria.
Companies wishing to integrate a permanent
biodegradation system into an existing EUB approved
facility must apply to amend the facility approval to include
the biodegradation system.
(f) Thermal Treatment
Small batch feed incinerators, which do not burn more than
10 tonnes of oilfield waste per month, and campsite
incinerators, which have a burning capacity of less than
90.7 kg/hr and are used to dispose of only kitchen waste,
do not require approval from the EUB, provided the criteria
in Sections 17.3 and 17.4 of Guide 58 are met.
All other fixed thermal treatment facilities operating at oil
and gas, oil sands, or oilfield waste management facilities
require approval to construct and operate from the EUB.
Non-dangerous oilfield waste may be incinerated at AEP
regulated incinerators that are approved for the incineration
of non-hazardous or hazardous wastes. The incinerator
must also be approved to accept third party wastes.
Dangerous oilfield waste may be incinerated at AEP
regulated incinerators that are approved for the incineration
of hazardous wastes. The incinerator must also be
approved to accept third party wastes.
Implementation of Guide 58
The following outlines the effective dates for various sections of
Guide 58; Oilfield Waste Management Requirements for the
Upstream Petroleum Industry:
• All new oil and gas, oil sands, and oilfield waste management
facilities constructed after 30 November 1996 must meet the
design and operational requirements within Guide 58.
• All oilfield waste management facilities constructed after 30
November 1996 must meet the financial security requirements
within Guide 58 by 1 June 1997.
• All oilfield waste management facilities which were constructed
and operating prior to 30 November 1996, must meet the
financial security requirements within Guide 58 by 1 May 1998.
• All oilfield waste manifesting requirements become effective 1
June 1997.
• Surveillance, compliance auditing, and enforcement of Guide
58 begins 1 June 1997.
• All waste tracking requirements become effective 1 June 1997.
• The first annual oilfield waste disposition report must be
submitted 28 February 1998 for the period 1 July 1997 to 31
December 1997. Those oil and gas companies (waste
 generators) selected to submit the report will be notified by 15
January 1998.

For further information, contact the EUB Facilities Division at 297-

3426.

EUB Guide 58 is available from EUB Information Services at 297-

8190 or at the main floor of the Energy Resources Building, 640 - 5
Avenue SW, Calgary, Alberta, T2P 3G4.

Brian F. Bietz
Board Member
Alberta Energy and Utilities Board

20 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
ID 97-6: Sour Well Licensing and Drilling Requirements
13 February 1998 2 MINIMUM DISTANCE REQUIREMENTS SEPARATING PROPOSED
SOUR WELLS FROM RESIDENTIAL AND OTHER DEVELOPMENTS
TO: All Operators and Drilling Contractors
3 SOUR WELL EMERGENCY RESPONSE PLANS
This directive updates and replaces the requirements of Interim
3.1 When a Plan is Required
Directive ID 87-2. Specifically, Sections 1, 2, 3, 4 and 7 are amended as
3.2 Selection of Emergency Planning Zone
herein described. Section 5, "Minimum Setbacks Separating Proposed
3.3 Emergency Plan Contents
Sour Wells from Residential and Other Developments" and Section 6,
3.4 Specific Requirements
"Sour Well Emergency Response Plans" are replaced by Sections 2 and
3 of this directive. However, new emergency response planning
requirements are expected to be announced following the completion of 4 DRILLING REQUIREMENTS AT CRITICAL SOUR WELLS
review work by a joint industry/Board stakeholder committee. 4.1 Planning
Minimum setback requirements for all sour facilities, including wells, 4.2 Well Design
will be published in one document in the near future replacing Section 2 4.3 Equipment
of this directive.
4.3.1 BOP Stack
The requirements in this directive are in addition to those set out in the 4.3.2 BOP Manifold
Oil and Gas Conservation Act, the Oil and Gas Conservation 4.3.3 Mud-Gas Separators
Regulations, and Guide 56 - Energy Development Application Guide 4.3.4 Drill Pipe
and Schedules. The changes in this directive resulted from the 4.3.5 Drill String Valves
integration of the well licensing process with the new energy 4.3.6 Monitoring Equipment
development application process. The technical requirements for
drilling a sour or critical sour well have remained largely unchanged. 4.4 Practices

4.4.1 Tripping
This interim directive also supersedes IL 88-9. 4.4.2 Testing and Coring
4.4.3 Underbalanced Drilling
Applicants requiring further information regarding this directive should
contact the Board's Operations Group at 297-6952. 4.5 Personnel

4.5.1 Supervision
4.5.2 Rig Crew
J. D. Dilay, P.Eng. 4.5.3 Service Personnel
Board Member 4.5.4 Safety Specialists and Equipment

4.6 Inspection
ATTACHEMENT TO INTERIM DIRECTIVE ID 97-6
SOUR WELL LICENSING AND DRILLING REQUIREMENTS 4.7 Blowout Insurance

5. ENFORCEMENT
CONTENTS
TABLES AND FIGURES
1. SOUR WELL REQUIREMENTS
Figures
1.1 Sour Wells
ALTERNATIVE BOP STACK CONFIGURATIONS -
1.1.1 Application
1.1.2 Suspended/Producing H2S Release Rate CRITICAL SOUR WELLS
1.1.3 Audit
MANIFOLD LAYOUT CRITICAL SOUR WELLS
1.2 Critical Sour Wells
Tables
1.2.1 Definition
1.2.2 Application Table 2.1 SUMMARY OF MINIMUM DISTANCE
1.2.3 Receipt of Licence REQUIREMENTS SEPARATING PROPOSED SOUR
1.2.4 Audit WELLS FROM RESIDENTIAL AND OTHER
1.2.5 Change from Critical to Non-critical Status DEVELOPMENTS

Table 4.1 ATMOSPHERIC, OPEN BOTTOM, MUD-GAS

SEPARATOR VESSEL AND VENT LINE DIAMETER
REQUIREMENTS FOR CRITICAL SOUR WELL
DRILLING

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 21
APPENDICES
1 Definitions
2 References
1 SOUR WELL REQUIREMENTS
1.1 Sour Wells
1.1.1 Drilling Release Rate Application (Schedule 4-Guide 56)
The Board requires companies to evaluate the potential hydrogen
sulphide (H2S) release rate of every well which will penetrate
formations that may contain H2S and to plan for safe drilling operations
consistent with potential occurrences. Each application for a well
licence must include the results of that evaluation. Specifically, for any
well which meets the sour well criteria in Guide 56, the applicant must
complete the sour well section of the application and must include the
following details: maximum H2S content; calculated cumulative release
rate during drilling operations; distance to nearest occupied dwelling;
distance to nearest urban centre; number of occupied dwellings; public
facilities and/or places of business within the planning zone1; and size
of calculated emergency planning zone radius. The applicant must
retain documentation supporting the H2S release rate determination
including all relevant details used in the assessment. These must
include, for each formation to be penetrated which may contain H2S:
(1) the maximum concentration of H2S that can be expected and the
source of that information,
(2) the maximum surface deliverability that can be expected against
zero back pressure for casing or open-hole flow configuration, and
(3) the methodology used to determine the above.
1.1.2 Suspended/Producing H2S Release Rate
The maximum potential H2S release rate is used to determine the level
classification and appropriate separation distance requirements of the
well (Section 2). Where stimulation is normal or expected, a
post-stimulation rate must be used.
Where the classification changes from non-critical to critical (for
example after stimulation), the operator is responsible for meeting all
critical well requirements in the post-drilling phase.
The Canadian Association of Petroleum Producers (CAPP) has recently
established a task force to study the methodology used in the
calculation of potential H2S release rates in order to provide guidelines
for standard and consistent format for the proper retention of data. The
guidelines are expected to be available in early 1998.
1 2
If this number is greater than zero, or if the well is declared "critical,"
an emergency response plan will be required.
22 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
1.1.3 Audit
After receipt of a licence for any sour well, the requirements in this
directive are subject to audit as part of the application audit system. In
addition, an EUB representative may inspect any operation at a sour
well .
1.2 Critical Sour Wells (Step 11 of Schedule 4-Guide 56)
1.2.1 Definition
A critical sour well includes any well from which the maximum
potential H2S release rate is:
(1) 0.01 cubic metres per second (m3/s) or greater and less than 0.1
m3/s and which is located within 500 metres (m) of the corporate
boundaries of an urban centre, or
(2) 0.1 m3/s or greater and less than 0.3 m3/s and which is located
within 1.5 km of the corporate boundaries of an urban centre, or
(3) 0.3 m3/s or greater and less than 2.0 m3/s and which is located
within 5 km of the corporate boundaries of an urban centre, or
(4) 2.0 m3/s or greater.
1.2.2 Application
When applying for a well licence, the applicant must complete the
appropriate section to indicate if the well is a critical sour well. If the
applicant does not intend to follow a significant requirement in this
directive or recommended practice within the Alberta Recommended
Practices (ARPs) (e.g. exemption from setting intermediate casing), the
applicant must indicate that it is filing a non-routine application by
using a "No" response in Step 11 of Schedule 4, Guide 56.
1.2.3 Following Receipt of Licence
Within five (5) business days of receiving a well licence for the critical
sour well, the licensee must notify in writing2 the following, located in
Edmonton:
• Alberta Economic Development and Tourism, Corporate
Communications
• Alberta Health, Emergency Health Services
• Alberta Transportation and Utilities, Disaster Services
• Alberta Environmental Protection, Environmental Assessment
Division and
• Land Administration Division
• RCMP (Edmonton)
In addition, the licensee must file one copy of the critical well drilling
plan with the appropriate Board Field Centre, also within five (5)
business days of receiving the well licence.
The notification must include the date of the well licence and the surface
location of the proposed well.
1.2.4 Audit located that as a minimum, it meets the requirements set out for a
Level 3 sour well. However, the Board may require greater
The Board will audit all critical sour well licence applications separation distances or set out other such requirements as it deems
immediately upon issuance of the well licence. A Board representative necessary.
may inspect any operations at a critical sour well at any time.
With regard to encroachment of proposed surface development on
1.2.5 Change from Critical to Non-critical Status existing sour wells, the subdivision and development regulation
pursuant to the Municipal Government Act requires identical separation
Once the Board or the applicant has determined a well to be critical, the distances to be maintained.
well is subject to all critical well requirements at the drilling,
completion, workover, and production phases of the well. In order to TABLE 2.1 SUMMARY OF MINIMUM DISTANCE REQUIREMENTS
change the classification of the well, the licensee must notify the SEPARATING PROPOSED SOUR WELLS FROM
Board's Operations Group of the change in writing. This notification RESIDENTIAL AND OTHER DEVELOPMENTS
will be subject to audit and the Board will require the licensee to
provide the most recent test information available, including the test LEVEL PRODUCING/ MINIMUM DISTANCE FROM
interpretation, and the distance to the nearest dwelling and urban centre. CLASSIFICATION SUSPENDED PROPOSED WELL TO VARIOUS
The licensee is responsible to prove at any stage of the well H2S RELEASE RATE DEVELOPMENTS
(completion, workover, production), that the classification has been m3/s
changed to non-critical and that critical well requirements are no longer
1 0.01 - <0.3 0.1 km as stated in
applicable. The licensee must provide a copy of the notification and
section 2.110 of the Oil
supporting information during a service rig or production inspection by and Gas Conservation
Board field personnel. Regulations

2 0.3 - <2.0 0.1 km to any dwelling

2 MINIMUM DISTANCE REQUIREMENTS SEPARATING 0.5 km to any urban
centre or public facility
PROPOSED SOUR WELLS FROM RESIDENTIAL AND
OTHER DEVELOPMENTS 3 2.0 - <6.0 0.1 km to any dwelling
0.5 km to an unrestricted
country development
In order to select appropriate well locations having regard for both
1.5 km to an urban centre
public safety and present and future land use, the Board has established or public facility
the following level classifications for sour wells. Each classification
level has corresponding minimum separation distances between sour 4 6.0 As specified by the Board
wells and residential and/or other developments. The distances increase but not less than Level 3
as the suspended/producing H2S release rate potential increases, and
with increasing population density. Table 2.1 summarizes the separation NOTE: Any well classified as a Level l, 2, 3, or 4 sour well may also
distances for sour wells. be classified as a critical sour well (Section 4).

(a) Level 1 sour well: Any well with a maximum potential H2S
release rate of 0.01 m3/s or greater and less than 0.3 m3/s. All wells
remain subject to section 2.110 of the Oil and Gas Conservation
Regulations which require a 0.1-km separation distance between
each well and any surface improvement. The Board may specify
some other separation distance for a Level 1 sour well should the
circumstances warrant such action.
(b) Level 2 sour well: Any well with a maximum potential H2S
release rate of 0.3 m3/s or greater and less than 2.0 m3/s. A Level 2
sour well shall be located to provide 0.1-km separation distance
between it and any dwelling, and 0.5-km separation distance
between it and any public facility or corporate boundary of an
urban centre.
(c) Level 3 sour well: Any well with a maximum potential H2S
release rate of 2.0 m3/s or greater and less than 6.0 m3/s. A Level 3
sour well shall be located to provide 0.1-km separation distance
between it and any dwelling, 0.5-km separation distance between it
and any unrestricted country development, and 1.5-km separation
distance between it and any public facility or corporate boundary
of an urban centre.
(d) Level 4 sour well: Any well with a maximum potential H2S
release rate of 6.0 m3/s or greater. A Level 4 sour well shall be so
The 0.l km separation distance to any dwelling is an absolute minimum
distance and the Board would expect that the actual separation distance
for any high H2S release rate wells (particularly for Levels 3 and 4) will
be at least 3 to 4 times the minimum distance. The Board would
approve a setback closer to the prescribed minimum only if it is
satisfied there is minimal risk associated with the proposed well and
provided that the landowner and occupant of the dwelling are in
agreement.
3 SOUR WELL EMERGENCY RESPONSE PLANS
New emergency response planning requirements are expected to be
released in early 1998. The Board anticipates that these requirements
will be centred on emergency response planning guidelines being
prepared by CAPP, and issued by the Board. These will replace the
existing CPA/IPAC guidelines. In the interim, the licensee must file
emergency response plans for review by the Board's Operations Group
prior to the commencement of drilling operations.
The Board believes that operators must ensure public safety in the event
of an H2S release and expects operators will be prepared to deal with all
emergencies that may occur at a well site. Sour wells which exhibit a
high H2S release potential or those near dwellings require site-specific

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 23
emergency response plans which must be reviewed/audited by the
Board. The Board's policy is to ensure that, if there is a significant
release of H2S, the health and safety of the public must be protected
either by their evacuation from or shelter in the area or, if evacuation is
not practical, by ignition of the well.
3.1 When a Plan is Required
An emergency response plan is required for the drilling of a sour well
when:
(1) the well is classified as a critical sour well (Section 4),
(2) there are one or more dwellings, public facilities, work sites, places
of business, or similar activities within the emergency planning zone, or
(3) the Board decides that a plan is required for other reasons.
3.2 Selection of Emergency Planning Zone
The appropriate emergency planning zone (EPZ) must be carefully
selected and must be adequate to ensure the safety of the public near the
well. The size and shape of the zone must reflect the maximum drilling
H2S release rate but must also have regard for the local terrain and
density of population in the area.
To calculate the EPZ, use the cumulative drilling release rate (RR)
using the following formulas:
C if RR < 0.3 m3/sec, EPZ = RR0.58 x 2 km
C if RR > 0.3 m3/sec but < 8.6 m3/sec, EPZ = RR0.68 x 2.3 km
C if RR > 8.6 m3/sec, EPZ = RR.81 x 1.9 km
The Board will consider reduced planning zones for wells which exhibit
very high H2S release rate potential (+3.0 m3/s) and which are near
densely populated areas that may be difficult or impossible to evacuate
in the event of an emergency. In such cases, the ignition criteria and
other response actions specified to ensure public safety must be
appropriate for the reduced planning zone.
3.3 Emergency Response Plan Contents
In 1991, CPA/IPAC prepared "Guidelines for Preparation of Public
Safety Emergency Response Plans for Sour Gas Drilling, Completion
and Servicing." The Board has accepted these guidelines as minimum
standards for emergency response plans. However, the Board retains the
right to decide the amount of detail required in each plan submitted for
review/audit. The Board stresses that each plan must consider
site-specific circumstances. Variations in the plans can be expected
based on factors such as the geological prognosis of the well,
population density and distribution, and the consequences of a blowout.
The Board stresses that public input from local residents and municipal
administrators is an integral part of preparing an effective emergency
response plan. In some instances it may be necessary to hold public
meetings to obtain this input.
The CPA/IPAC guide describes the minimum content and specific
detail required in an emergency response plan. The following list
identifies major components and summarizes the key items to be
addressed in a plan.
24 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
(1) Summary
This section is a summary of the key facts about the proposed
well and the emergency response plan.
(2) Emergency Definition and Action
This section describes the various circumstances that could lead
to a sour gas release and the intended response. It defines the
various stages of alert and describes the action for each stage. In
addition, it describes the responsibility of company and
government personnel involved in an emergency.
(3) Evacuation Procedures
This section defines the criteria to be used to initiate an
evacuation and describes how the evacuation would be carried
out.
Details respecting the proposed air quality monitoring program
and communication procedures are also addressed.
(4) Ignition Criteria
This section defines the ignition criteria and circumstances
leading to the deliberate ignition of the well. The licensee must
have clear and specific plans in place to ignite an uncontrolled
flow where the size of the emergency planning zone has been
reduced because of population density.
(5) Resident Information Package
This section includes a copy of the Resident Information
Package that was or will be left with residents within the
emergency planning zone. The package provides a brief
summary of the proposed well and operator, a summary of
evacuation and ignition procedures, emergency telephone
numbers, and a description of the hazards of H2S and sulphur
dioxide.
(6) Contact Information
This section provides a listing of the residents, company
personnel, and government agencies that would be contacted in
the event of a sour gas release.
(7) Maps
This section includes the maps necessary to show:
(a) the selected emergency planning zone and the dwellings,
other developments, roads, and topographical features within the
zone;
(b) an area equal to at least twice the size of the emergency
planning zone and the public facilities, urban centres, and
evacuation routes within the area.
3.4 Specific Requirements
(1) A copy of the approved emergency response plan must be on site
during drilling operations, prior to drilling out the surface casing,
 and during all completion or servicing operations of designated
critical sour wells.
(2) Copies of the approved emergency response plan must be sent to
each of the following within five (5) business days of receiving the
emergency response plan approval:
Alberta Environmental Protection
Alberta Transportation & Utilities
Workplace Health, Safety & Strategic Services; Occupational
Health & Safety Services
Appropriate Regional Health Authority
Appropriate detachment of the RCMP
Alberta Land & Forest Service
Municipal governments, where applicable
(3) For critical sour wells, the operator shall hold a meeting to review
the emergency response plan before drilling into the potential sour
zones. The operator, its contractors, Board staff, and the
government departments and agencies listed in (2) above should
attend.
(4) For critical sour wells where the emergency planning zone
includes all or a portion of an urban centre, the Board requires
continuous mobile monitoring on lease during the drilling,
servicing or completion of the potential sour zones. The Board will
review the need for continuous mobile electronic monitoring for
other sour wells on a site-specific basis.
4 DRILLING REQUIREMENTS AT CRITICAL SOUR WELLS
The following requirements apply to the drilling of a critical sour well.
The Board also requires the licensee to meet or exceed the Alberta
Recommended Practices (ARPs) when drilling critical sour wells.
Volume 1 (Drilling) and Volume 2 (Completing and Servicing) are
available through the Petroleum Industry Training Service (PITS).
Each component of the drilling plan must include documentation on the
following items. Failure to comply with these requirements may result
in the immediate suspension of operations.
4.1 Drilling Plan
(1) Well Design:
(a) Casing details - Casing depth, grade, weight, size; for surface,
intermediate and production casing. Details of the surface
casing bowl.
(b) Geological zones, including identification of sour and critical
sour zones must be shown on a wellbore diagram.
(c) Details of casing design and sour service suitability of the
casing grades referencing ARP Volume 1 Section 1.6. If
grades other than L-80 are proposed, details on chemistry
specifications must be reviewed and documented. Casing
design for horizontally-drilled wells must also address the
additional stresses and loads.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 25
(2) Offset well map.
(3) Summary of hole problems expected, solutions, and reasons for
selecting casing setting depths.
(4) BOP Stack - The configuration used and its pressure rating; and if
blind shear rams were not planned, the reasons must be included
using the criteria set out under Equipment.
(5) BOP Manifold - The configuration and pressure rating, having
regard for the number of mud-gas separators installed.
(6) Mud-Gas Separators - The number of mud-gas separators planned.
If only one mud-gas separator was planned, include the reasons
using the criteria set out under Equipment.
(7) Drill Pipe - The grade, type (new/used) and class of drill pipe. If
grade is other than E, include:
(a) A discussion of sour-service suitability referencing ARP
Volume 1, Section 1.2.
(b) Drill pipe design of both the grade planned and grade E,
including a comparison of overpull tensile margins at the
surface or other design factors affecting the choice of grade.
(c) H2S exposure control planned, referencing ARP Volume 1,
Sections 1.2 and 1.7.
As an alternative to the above, if the planned grade will meet the
same hardness limitations as grade E (see ARP Volume 1, Section
1.2), make a statement to this effect.
(8) Practices - If underbalanced drilling is planned, a detailed
description of modifications and additions to equipment must be
described referencing ID 94-3 "Underbalanced Drilling," or any
future requirements resulting from the Drilling and Completions
Committee (DACC) subcommittee's review of sour well
underbalanced drilling.
(9) Drilling Fluid System - Provide the type, the density, the pH level,
the amount of weight material on site, if the system will be
pretreated with H2S scavenger, and the type of additional drilling
fluid that will be kept on site.
(10) Blowout Insurance - A statement that the company (including
working interest owners) is self-insured, or other proof of
insurance must be filed and available for audit.
(11) Inspection and Testing Procedures - Provide a description of the
inspection and testing procedures designed to ensure that all
equipment is fully operational prior to the well reaching the critical
depth and procedures to ensure that a state of readiness is
maintained.
Prior to drilling any critical well, a drilling plan must be prepared and
copies must be:
C on site during drilling operations.
C one copy must be filed with the appropriate Board field centre
office for use during a site inspection.
 C available for audit of the application for well licence, or filed
with the well licence application if the application is to be
heard at a public hearing.
4.2 Well Design
(1) Intermediate casing shall be set to an appropriate point above the
zone from which the first critical sour gas or oil is expected, or at a
point before the cumulative release rate becomes critical.
(2) Notwithstanding the above, the Board may exempt an applicant at
the well licencing stage from the requirements to set intermediate
casing. To apply for this exemption, applicants must file a non-
routine application by indicating a "No" response in Step 11 of
Schedule 4-Guide 56 and must attach the following to support
their request:
(a) The geological prognosis of the proposed well. The well must
be in a known and established field area which offsets
existing development.
(b) Summary of offset wells confirming no significant lost
circulation problems or other adverse drilling conditions.
(c) Summary of drill stem test pressures, mud densities, or other
information to verify normal formation pressures are
expected.
(d) Kick tolerance calculations indicating the ability of surface or
other casing in the well bore to handle a 3-cubic-metre gas
kick.
(3) Intermediate and production casing grades must be suitable for
sour service, or if the Board grants exemption from setting
intermediate casing, the surface casing grade must be suitable for
sour service.
(4) If the Board approves exemption from setting intermediate casing,
the wellbore integrity, including the casing and open hole sections,
must be evaluated by an open-hole integrity test prior to
penetrating the critical zone and must be found capable of holding
anticipated formation pressures before continuing to drill without
intermediate casing.
(5) The intermediate casing burst shall be designed, as a minimum, to
67 per cent of maximum bottom-hole pressure. Re-entry of a
critical sour well will require the operator to prove pressure
integrity of at least 67 per cent of maximum bottom-hole pressure
by pressure testing existing casing prior to drilling into the critical
sour zone. New casing run prior to penetrating the critical zone,
must be designed as described above.
(6) For horizontally-drilled critical sour wells, casing design must be
designed for additional stress factors including tri-axial loading.
26 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
4.3 Equipment
4.3.1 BOP Stack
(1) Minimum stack components shall consist of an annular preventer,
two spools, and three rams - except that for maximum projected
depths less than 1800 m, then flanged side outlets on the lower ram
preventer may be substituted for the lower drilling spool. The
C the calculated emergency planning zone size intersects the
boundaries of an urban centre, or
C the calculated emergency planning zone encompasses more
than 100 occupied dwellings.
(2) Whenever blind shear rams are not installed, the operator should
evaluate running a drill string float/internal BOP.
(3) All pressure-containing components within the BOP stack,
inclusive of attached valves and choke lines through to the outside
valves of the choke manifold, with the potential to be exposed to
H2S gas, shall be constructed of materials which meet the
standards of the National Association of Corrosion Engineering
Standard (NACE) MR-01-75.
(4) The BOP master control shall be installed at a location remote
from the rig floor.
(5) The accumulator system shall be sized such that when charged to
its operating pressure and with the recharge pump off, there shall
be sufficient volume to open the HCR, close the annular preventer
on drill pipe, and close, open, and close one ram preventer. The
final accumulator pressure shall not be less than 8400 kPa. In
addition, the accumulator must have sufficient volume to close the
annular preventer on open hole. Where blind shear rams are run,
the accumulator size must be increased, or a separate accumulator
system installed, to provide sufficient volume to shear drill pipe.
(6) Welded casing bowls shall be welded in accordance with an
acceptable welding procedure developed from API Spec 6A,
Specification for Wellhead and Christmas Tree Equipment, NACE
MR-01-75, and Section IX of ASME, Boiler and Pressure Vessel
Code. ARP Volume 1, Section 1.15 contains additional details
regarding welding procedures.
(7) Threaded casing bowls shall be manufactured in accordance with
API Spec 6A, the make-up procedures and torque in accordance
with API RP 5C1, Care and Use of Casing and Tubing, and the
thread compound used in accordance with API Bul 5A2, Bulletin
on Thread Compounds.
(8) Drilling components installed between the top flange of the
uppermost blowout preventer and the bottom of the rig floor shall
be constructed to permit their removal while drill pipe or other
equipment is in the hole.
4.3.2 BOP Manifold (3) A separate bleed-off line from each spool to a separate manifold
wing (side) is required and must be equipped with a separate
The BOP manifold configuration shall be as illustrated in the figure casing pressure gauge.
below.
(4) A remote, hydraulic operated, non-rubber sleeve choke is
(1) The manifold and piping shall provide complete redundancy required on the primary manifold wing (upper BOP spool) and a
from the BOP stack, through the manifold, to the mud-gas manual operated choke is required on the secondary manifold
separators, and finally to the flare pit. wing (lower BOP spool).

(2) Where only one mud-gas separator is being used, redundancy (5) BOP manifolds shall be filled with suitable water-soluble non-
from the manifold to the single mud-gas separator, and from the freezing fluids and be adequately heated during the winter
mud-gas separator to the flare pit is not required. season.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 27
4.3.3 Mud-Gas Separators Table 4.1 ATMOSPHERIC, OPEN-BOTTOM, MUD-GAS SEPARATOR
VESSEL AND VENT LINE DIAMETER REQUIREMENTS FOR CRITICAL
(1) Two mud-gas separation devices are required for the drilling of
SOUR WELL DRILLING
critical sour wells.

(2) One mud-gas separator is acceptable provided: Drilling Depth (m) Minimum Vessel Minimum Vent Line Diameter (mm)
Less Than Diameter1 (mm)
(a) the maximum potential H2S release rate is less than 2.0 m3/s with 1 m of Fluid Head with 2 m of Fluid Head

and the calculated EPZ does not intersect an urban centre, 750 355.6 101.6 101.6

(b) the geological prognosis of the proposed well is clearly 1 800 609.6 152.4 127.0
established on the basis of offset wells,
2 700 660.4 172.9 152.4

(c) normal formation pressures are expected, and 3 600 762.0 203.2 152.4

(d) no significant lost circulation is expected. 5 000+ 914.4 254.0 203.2

(3) The primary device must be an atmospheric, open bottom, mud-gas

1
separator and must conform to the specifications detailed in Table Vessel diameter was determined using a vapour load constant (k)
4.1. The secondary device may be an enclosed mud-gas separator. of 0.11 m/s.

28 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
(4) All materials used in vessels, inlet lines, and vent lines for mud-gas possible to the flowline discharge of the drilling rig. This
separators must be suitable for sour service and have a maximum monitoring unit is to be equipped with an alarm which will
yield strength not exceeding 550 megapascals. Suitable materials indicate a drop in pH.
are as follows:
(2) Sulphide content must be monitored by either a continuous
C Regular Materials sulphide monitor, or by hourly HACH tests which must be
Plate: ASTM A516 Grade 65 recorded throughout the critical period, and whenever sulphides
ASTM A516 Grade 70 are detected. A Garret Gas Train Test must be conducted every two
Pipe: ASTM A106 Grade B (2) hours. A record of the sulphide content in the mud must be
ASTM A53 Grade B maintained throughout the critical period.
API 5L Grade B
API 5L Grade X42 (3) Ambient H2S detection is required and must consist of a
CSA Z245.1 Grade 241 continuous H2S detection monitoring system that activates audible
Category 1 and visual alarms near the driller's position when sensing ambient
API H40, J55, K55 seamless casing (if hardness air H2S concentrations of 10 parts per million (ppm) or greater.
tested) The system must consist of at least one sensor located at the shale
shaker. Additional sensors may be placed at other locations such as
C Low-temperature Materials the bell nipple, rig floor, and mud mixing unit. Sensors must be
Plate: ASTM A516 Grade 65 c/w able to detect H2S concentrations of 5 ppm and greater. Qualified
Supplementary 5 personnel should be on site to test and provide maintenance to this
ASTM A516 Grade 70 c/w instrumentation.
Supplementary 5
Pipe: ASTM A333 Grade 6 (4) At least one portable ambient H2S concentration detection device
CSA Z245.1 Grade 241 shall be on location.
Category II
(5) Each rig shall have installed and operate an automated mud tank
(5) Mud-gas separator vent lines shall slope down volume monitoring system that meets the following specifications:
towards the flare pit.
(a) The system will be designed and installed so that it is capable
of detecting a gain or loss of 1.0 m3 in total drilling fluid
4.3.4 Drill Pipe
volume. This will require a probe in each active compartment.
(1) Selection criteria for drill string outlined in Volume 1 of the
(b) A fluid volume monitoring station with an alarm must be
Drilling ARP, Section 1.2.2 should be referenced to determine
located at or near, and be visible to, the driller's position. The
most appropriate materials.
monitor must be equipped with a recording chart.
(2) Used drill pipe must be inspected in accordance with Section 10 of
(c) The monitoring station must have a large, bright, flashing
API RP 7G, Drill Stem Test Design and Operating Limits. The
indicator light which will come on automatically whenever
inspection personnel's qualifications, equipment, and procedures
the alarm is shut off.
must be in accordance with API RP 5A5, Field Inspection of New
Casing, Tubing and Plain-End Drill Pipe.
(d) When drilling, the alarm must be set to detect a gain or loss in
total drilling fluid volume of not more than 2.0 m3.
(3) New and used drill pipe must be hardness tested, and abnormally
hard joints must be removed from the drill string in use.
(6) Indicators must be in operation for measuring hook load, pump
pressure, pump strokes per minute, and table torque. All such
(4) Only premium or better class drill pipe (API RP 7G) shall be used
indicators must be visible from the driller's position.
for critical sour wells.
(7) A continuous recording device is required to record rate of
(5) The Board's Operations Group must be notified immediately of any
penetration, pump pressure, pump strokes per minute, hook load,
drill string failures.
rotary table revolutions per minute (rpm), and rotary torque. This
record must be kept for the entire drilling operation and be made
4.3.5 Drill String Valves
available for inspection at the well site until rig release.
(1) Lower kelly cocks and stabbing valves must be certified by the
(8) A trip tank is required which is designed such that a change in
manufacturer to be capable of routinely opening with 7000
level of 25 millimetres (mm) equals a volume change of not more
kilopascals (kPa) pressure below the valve.
than 0.075 m3. This equates to a maximum surface area of 3.0 m2.
A minimum usable trip tank volume of 3.0 m3 is recommended.
(2) Lower kelly cocks must be installed.
(9) The hole fill volume must be measured either by manual gauging
4.3.6 Monitoring Equipment
of the trip tank or by reading a mechanical or automated system
visible at the driller's position. If a mechanical monitoring system
(1) Where water-based drilling fluid is in use, a continuous pH
is in use, the volume increments on the monitoring board must be
monitoring system must be installed and located as close as
0.1 m3. If an electronic probe is used, the monitor's measurement

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 29
 increments must not exceed 0.0375 m3 and the monitor must have
a readout to two (2) decimal places.
4.4 Practices
4.4.1 Tripping
(1) The hole must be filled to surface after every 15 singles
(maximum) of drill pipe and after every three (3) singles
(maximum) of drill collars are pulled.
(2) A trip record is required for every trip. During the critical period it
shall be signed and dated by the operator's well site supervisor and
the contractor's rig manager and maintained at the well site until
rig release.
(3) Each trip record must show the actual volume used each time the
hole is filled as specified above. The cumulative total fill volume
must also be recorded after each successive fill. On the same page
the record must show the theoretical volume required at each fill
point, plus the theoretical cumulative fill volumes.
(4) Minimum five (5)-minute flow checks are required at each of the
following stages: prior to beginning a trip out of the hole; after
pulling the first 15 singles of drill pipe from the hole; prior to
pulling the first stand of drill collars from the hole; and after all the
drill string is out of the hole.
4.4.2 Testing and Coring
(1) Critical sour zones shall not be drill stem tested.
(2) Directional surveys are required at a frequency of 60 m for
horizontal, directional and deviated wells.
(3) Coring is permitted at critical sour wells, however if the well is
located in an exploratory/non-development setting, the following
practice must be adhered to:
(a) The porosity of the critical zone must be penetrated prior to
tripping out for the coring assembly, to ensure normal
pressures, or
(b) If upper porous interface must be cored, the ability to
circulate above the core barrel must be available (e.g. ported
string).
4.4.3 Underbalanced Drilling
Equipment requirements will change significantly on a critical sour well
to be drilled underbalanced. In these cases, the requirements of ID 94-3
must be met in addition to this directive.
Licensees must ensure that all equipment exposed to sour fluids
(including tubulars) be constructed of materials with suitable
performance properties for the intended service.
Note: The Board will not approve sour underbalanced drilling
operations which place residents inside the calculated EPZ's - until the
regulatory requirements for these types of wells have been reviewed,
assessed and the findings published.
30 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
4.5 Personnel
4.5.1 Supervision
(1) On-site supervisors must have a current PITS Second Line
Supervisor BOP Well Control certificate, H2S Alive certification
and experience in drilling sour wells.
(2) During the critical period of drilling operation, sufficient
supervision must be on site and available so that no individual
supervisor is required to work a shift longer than 12 hours.
4.5.2 Rig Crew
(1) On-site rig managers must have a current PITS Second Line
Supervisor BOP Well Control certificate, and drillers must have a
current PITS First Line Supervisor BOP Well Control certificate.
(2) On-site rig managers and drillers must have H2S Alive certification
and experience in drilling sour wells.
(3) Each driller must have an adequate understanding of the correct
operation of all kick detection and monitoring equipment.
(4) A minimum five (5)-man drilling crew shall be maintained and all
crew members shall have H2S Alive certification.
4.5.3 Service Personnel
(1) Key on-site service personnel including mud-men, loggers,
geologists, etc. shall have previous experience in sour well drilling
operations.
(2) All well-site personnel shall be trained in H2S safety.
4.5.4 Safety Specialists and Equipment
During the critical period of the drilling operation, safety personnel and
adequate safety equipment for all workers must be on site (minimum
requirements are specified by the Occupational Health & Safety
(OH&S) Act and Regulations).
4.6 Inspection
A weekly detailed rig inspection shall be performed by the operator and
contractor. An inspection check sheet shall be used and retained.
(1) A detailed inspection2 and blowout prevention drill shall be
conducted:
(a) prior to drilling out the surface casing,
(b) prior to drilling out the intermediate casing, and
(c) within the 24-hour period prior to penetrating the critical sour
2
These inspections must include pressure testing all equipment and
casing in accordance with EUB Guide 36, unless the well is being
re-entered, then casing must be pressure-tested to 67 per cent of
maximum bottom-hole pressure. Note that 30-day casing wear tests
must also be conducted in accordance with section 8.141(3) of the
Oil and Gas Conservation Regulations.
 zone (if intermediate casing is set immediately above the
critical zone, this inspection would coincide with (b) above).
(2) The licensee must notify the appropriate EUB field centre at least
48 hours prior to these inspections and drills being initiated.
4.7 Blowout Insurance
Companies licensing a critical sour well must either be self-insured to
cover the costs of a blowout, or must obtain significant liability
insurance. Insurance amounts depend on the well depth and must
include provision for pollution and seepage, evacuation expense,
underground blowout, and care/custody and control. In addition, if the
well is a "joint venture," the company must either hold insurance for
100 per cent of the working interest, or have a copy of insurance
policies for the interest of each partner.
5 ENFORCEMENT
The consequences for failing either an application audit, an operations
audit or field inspection will vary depending on the severity and
frequency of noncompliance. For minor/infrequent noncompliance, the
Board will use enforcement options such as warnings, increased audit
frequency, and temporary shut-down of the operation to rectify the
problem. The Board will use such enforcement options as indefinite
shut-down of the operation or suspension of approval for
severe/frequent non-compliance.
APPENDIX 1
For the purpose of this directive:
(1) Completion/Servicing Stage: includes all operations which are
continuously attended subsequent to the drilling stage, and which are
necessary to prepare the well to produce, or after a period of
production, to restore the well or to repair the well.
(2) Critical Sour Well: a designation that reflects the proposed well's
proximity to an urban centre and its maximum potential hydrogen
sulphide (H2S) release rate during the drilling stage. The casing
flow or open-hole flow configuration is assumed in arriving at this
designation. Included are:
(a) any well from which the maximum potential H2S release rate
is greater than 0.01 cubic metres per second (m3/s) but less
than 0.1m3/s and which is located within 500 metres (m) of
the corporate boundaries of an urban centre, or
(b) any well from which the maximum potential H2S release rate
is greater than 0.1 m3/s but less than 0.3 m3/s and which is
located within 1.5 kilometres (km) of the corporate
boundaries of an urban centre, or
(c) any well from which the maximum potential H2S release rate
is greater than 0.3 m3/s but less than 2.0 m3/s and which is
located within 5 km of the corporate boundaries of an urban
centre, or
(d) any well from which the maximum potential H2S release rate
is greater than 2.0 m3/s, or
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 31
(e) any other well which the Board classifies as a critical sour
well having regard to the maximum potential H2S release rate,
the population density, the environment, the sensitivity of the
area where the well would be located, and the expected
complexities during the drilling phase.
(3) Critical Period: any time or depth starting with some reasonable
period prior to when a well has penetrated or may have penetrated
any formation (or combination of formations) that may be capable
of flowing H2S at critical sour well rates, and continues until such
formations have been rendered incapable of flowing into the
wellbore by running and cementing casing, or by cement
abandonment plug, or approval has been given by the Board to
reclassify the well or formation as no longer critical.
(4) Drilling Stage: includes all operations which are continuously
attended, from spudding-in until production casing is cemented or
the well is abandoned.
(5) Emergency Planning Zone: an area surrounding a well where
residents or other members of the public may be at risk in the event
of an uncontrolled release of H2S and the operator must be
prepared to respond accordingly.
(6) Flow Configuration: the well equipment and flow configurations
to be considered in determining H2S release rate at various stages
of a well's drilling or producing life. These are:
(a) casing flow or open-hole flow where reservoir fluids are free
to flow up the casing or open hole without any other tubular
goods in the wellbore,
(b) tubing and annular flow where reservoir fluids flow up the
tubing and the annular space between the tubular string and
the casing or open hole, and
(c) tubing flow where flow is only up the tubing.
(7) Level Classification: a designation to stipulate separation
distances of sour wells for land-use and public safety purposes.
The level classification for sour wells is determined by assessing
the maximum potential surface H2S deliverability that can be
attained against zero back pressure during the suspended/
producing stage of a well. A well may be completed with a packer
and capable of flowing through tubing only, or completed without
a packer and capable of flowing through tubing and also up the
annulus. The appropriate flow configuration must be considered in
arriving at the level classification.
(8) Potential H2S Release Rate: the calculated H2S deliverability that
can be attained at surface against zero back pressure with various
flow configurations, expressed using the unit of cubic metres per
second (m3/s) at standard pressure and temperature conditions.
(9) Public Facility: a public building such as a hospital, rural school,
or a major recreational facility situated outside of an urban centre;
and for the purpose of this directive, includes other developments
the Board, after consultation with appropriate interested parties,
may designate as a public facility based on the complexity of
evacuation taking into consideration the number of people using
the facility and the frequency and duration of their use.
(10) Separation Distance: the required distance between a sour well
and developments such as individual permanent dwellings,
unrestricted country development, public facilities, and the
corporate boundaries of urban centres.
(11) Sour Gas: natural gas, including solution gas, containing
hydrogen sulphide (H2S).
(12) Sour Well: any oil or gas well expected to encounter sour
gas-bearing formations during drilling or any oil or gas well
capable of producing sour gas.
(13) Surface Improvement: means a railway, pipeline or other right of
way, road allowance, surveyed roadway, dwelling, industrial plant,
aircraft runway or taxiway, building used for military purposes,
permanent farm buildings, school, or church.
(14) Suspended/Producing Stage: includes all operations which are
not continuously attended, at wells that may or may not be capable of
producing.
(15) Unrestricted Country Development: any collection of permanent
dwellings situated outside of an urban centre and having more than
eight permanent dwellings per quarter section; and for the purpose
of this directive includes any similar development the Board may
designate as an unrestricted country development.
(16) Urban Centre: a city, town, new town, village, summer village,
hamlet with not less than 50 separate buildings each of which must
be an occupied dwelling, or other incorporated centre, and for the
purpose of this directive includes any similar development the
Board may designate as an urban centre.
APPENDIX 2 References
API, Bulletin on Thread Compounds, for Casing, Tubing and Line Pipe,
1988 Bul 5A2, Dallas, Texas.
API, Recommended Practice for Care and Use of Casing and Tubing,
1994 RP 5C1, Dallas, Texas.
API, Recommended Practice for Drill Stem Design and Operating
Limits, Fifteenth Edition, 1995, RP 7G, Dallas, Texas.
API, Recommended Practice for Field Inspection of New
Casing, Tubing, and Plain End Drill Pipe, 1993 RP 5A5,
Dallas, Texas.
API, Specification for Line Pipe, 1995 Spec 5L, Dallas, Texas.
32 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
API, Specification for Wellhead and Christmas Tree Equipment,
Sixteenth Edition, 1989, (plus supplements, 1991, 1992).
API, Specification for Drill Pipe, Third Edition, May 1992.
Spec 5D, Dallas, Texas.
API, Specification for Casing and Tubing (Metric Units), Fifth Edition,
1995, Spec 5CT, Dallas, Texas.
ASME, Boiler and Pressure Vessel Code, Welding and Brazing
Qualifications 1989 Section IX, New York, New York. 1989 (Addenda
1989, 1990, 1991).
ASTM, American Society for Testing and Materials, Annual Book of
ASTM Standards (Piping, Tubing, Fittings), 1994 Edition, Volume 1,
Section 1, Philadelphia, Pennsylvania.
CAODC, CPA, ERCB, IPAC, Alberta Recommended Practices for
Drilling Critical Sour Wells, 1987, Volume 1, Calgary, Alberta.
CAPP, Canadian Association of Petroleum Producers, Emergency
Planning Guidelines for the Western Canadian Upstream Petroleum
Industry, 1997, Calgary, Alberta.
CSA, Canadian Standards Association, Steel Line Pipe, 1995.
Z245.1, Toronto, Ontario.
Decision D 84-5 LODGEPOLE BLOWOUT INQUIRY PHASE 2
DECISION REPORT, April 1984, ERCB, Calgary.
Decision D 84-9 LODGEPOLE BLOWOUT INQUIRY PANEL
DECISION REPORT, December 1984, ERCB, Calgary.
Draft Interim Directive ID 84- BLOWOUT PREVENTION AT SOUR
WELLS issued on 27 April 1984 as Appendix 5 of the report.
Lodgepole Blowout Inquiry - Phase 2, Decision D 84-5.
Interim Directive ID 87-2SOUR WELL LICENSING AND DRILLING
REQUIREMENTS issued on 3 June 1987, amendments issued on 13
June 1988.
Interim Directive ID 94-3 UNDERBALANCED DRILLING issued in 1994.
NACE, Sulfide Stress Cracking Resistant Metallic Materials for
Oilfield Equipment, 1992 MR0175-92, Houston, Texas.
ID 99-4: Deposition of Oilfield Waste into Landfills
22 April 1999 Appendix 1: Total Petroleum Hydrocarbon (TPH) and Chloride
Criteria
TO: All Oil and Gas Operators for Acceptance of Non-Dangerous Oilfield Waste* into
All Oil Sands Operators Class II Landfills**
All Drilling and Servicing Operators
All Pipeline Operators
All Oilfield Waste Management Operators Landfill Design Requirements Oilfield Waste Quality

DEPOSITION OF OILFIELD WASTE INTO LANDFILLS

leachate collection/removal TPH no limit
Alberta Environmental Protection (AEP) and the Alberta Energy and engineered clay*** or synthetic liner chloride no limit
Utilities Board (EUB) have developed a Memorandum of
Understanding (MOU) on new hydrocarbon and chloride criteria for the no leachate collection/removal TPH < 30 000 mg/kg
disposal of a range of oilfield wastes into Class II landfills. A summary engineered clay*** or synthetic liner chloride < 5 000 mg/kg
of these requirements (Appendix 1) is attached.
natural clay liner**** TPH < 20 000 mg/kg
Oilfield wastes targeted by this MOU include drilling mud and cuttings, chloride < 3 000 mg/kg
produced sand, tank and treater bottoms, oily sludges, and flare pit
material. Large volumes of these oilfield wastes are produced by oilfield
operations and the improper management of these waste streams can * Oilfield wastes targeted by this MOU include produced sands,
have significant environmental consequences. The disposal of these drilling mud and cuttings, oily sludges, tank and treater bottoms,
oilfield wastes into landfills is still considered an acceptable practice and flare pit material.
provided the wastes are compatible with the receiving landfill.
** All class II landfills require surface water run-on / run-off control
The attached MOU outlines oilfield waste quality criteria and landfill systems, suitable hydrogeology, and groundwater monitoring.
facility design requirements for the deposition of these and similar
oilfield wastes into Alberta landfills. The MOU is intended to enhance *** Engineered clay liner: a liner constructed of appropriate clayey
protection of the environment and the public interest, and to reduce material where the material is laid down in 150 mm to 250 mm
liability through appropriate waste management. lifts and each lift is compacted at 2 to 3% wet of optimum moisture
using a sheep's foot roller such that a thickness of 0.5 metres or
Questions regarding the MOU should be directed to either Ms. Susan more and a hydraulic conductivity of 10-8 m/s or less is achieved.
Halla (EUB, (403) 297-3184) or Mr. Tony Fernandes (AEP, (780) 427-
0636). **** Natural clay liner: a liner constructed by scarifying and
recompacting the native material (soil) in which the cell is built.

Note: The EUB and AEP have acknowledged the

Brian Bietz appropriateness of relating hydrocarbon limits to
Board Member molecular weight and mobility and have committed to a
Alberta Energy and Utilities Board future review of the total petroleum hydrocarbon criteria.

Doug Tupper
Assistant Deputy Minister
Alberta Environmental Protection

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 33
ID 99-6: Upstream Petroleum Industry Flaring Requirements
29 July 1999
TO: All Oil and Gas Operators
UPSTREAM PETROLEUM INDUSTRY FLARING REQUIREMENTS
Introduction
EUB Guide-60: Upstream Petroleum Industry Flaring Guide details
new Alberta Energy and Utilities Board (EUB) requirements for
upstream flaring in Alberta.
Guide 60 is effective 1 January 2000.
Guide 60 represents the end of several multistakeholder processes that
examined concerns respecting upstream flaring in Alberta. It
incorporates recommendations made to the EUB by the Clean Air
Strategic Alliance (CASA), introduces new requirements to address
some flaring issues not specifically addressed by CASA, and
consolidates other existing EUB flaring requirements into one
document.
Management Framework
CASA recommended a goal to “work toward elimination of routine
solution gas flaring.” CASA also recognized that reaching this goal can
not be accomplished easily within a short time frame. As a result, it
recommended a flaring management framework which includes
significant short- and long-term targets for flare reductions, as well as
improved flare performance requirements. It also recommended that the
associated regulatory aspects of the recommended framework include
public involvement, monitoring, and enforcement.
The Board believes that CASA’s recommended goal and management
framework, while recommended in the context of solution gas
management, are consistent with the EUB’s overall intent to optimize
resource conservation and ensure appropriate levels of environmental
protection. Accordingly, the EUB has adopted them to encompass
flaring in general.
A summary of changes introduced by Guide-60 is attached. Key
requirements of the management framework include:
• A firm provincial solution gas flare volume reduction schedule:
- 15 per cent reduction from 1996 baseline by 31 December
2000 (reduce flaring to 1445 106m3/year)
- 25 per cent reduction from 1996 baseline by 31 December
2001 (reduce flaring to 1275 106m3/year)
• New flare performance requirements for all flares, including the
following compliance deadlines:
- all new flares by 1 January 2000
- all existing solution gas flares by 31 December 2002
- all flares at other existing permanent facilities by 31
December 2004
34 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
• Required evaluation of all solution gas flares by 31 December
2002 using a flaring management decision tree, including a
streamlined common economic assessment process
• Commencing 1 January 2000, reduction to the New Oil Well
Production Period (NOWPP) flare limit set out in Informational
Letter (IL) 87-91 to 300 103m3/month from 500 103m3/month,
implementation of a maximum gas oil ratio (GOR) criterion of
3000 m3/m3, above which conservation would be required; and tie
in of development wells within one month in pools where gas
conservation exists
• Personal consultation and public notification requirements for new
and existing solution gas batteries
• Requirements for reduced flaring at normally conserving facilities
during planned or emergency flaring
•
Sulphur recovery requirements for facilities outside the scope of IL
3
88-132 and the related report ERCB-AE 88-AA
• Clarified flaring and venting reporting requirements for all
facilities
• Annual reporting of regional and overall provincial flaring
performance
Other important aspects addressed in the guide include
• Conflict resolution process to address flaring concerns
• Making available flaring and venting (S-2 statement) data to
support increased use of otherwise flared gas
• Progress towards minimizing requirements for electricity
generators using otherwise flared gas
• Annual EUB reporting of industry performance
Flare Efficiency Standard
The EUB has concluded that establishing an efficiency standard is not
practical at this time, primarily because there are no practical
methodologies for measuring either combustion or destruction
efficiencies under field conditions. However, it believes that the use of
“performance standard” equipment will allow industry the greatest
flexibility in achieving the desired environmental protection and safety
results in a cost-effective manner.
1
IL 87-9: Revised Procedures for Oil Production Allowable
Controls and New Oil Well Production Period, EUB, 1987.
2
IL 88-13: Sulphur Recovery Guidelines Gas Processing
Operations, EUB, 1988.
3
ERCB – AE 88-AA: Sulphur Recovery Guidelines for Sour Gas
Plants in Alberta, EUB, 1988.
It is the EUB’s view that achievement of combustion efficiencies of 98
per cent or better on both a design and operational basis would be the
expected result of focused continuous improvement in flare technology
research and flare performance standards. To this end, the EUB
anticipates the focused attention of industry and government towards
the development of flare equipment certification and field efficiency
measurement protocols for consideration during the review of the
management framework in 2001.
enforcement processes. For example, existing facility application audit
protocols will be revised to ensure that personal consultation and public
notification specific to flaring takes place.
The following table summarizes some key implementation and
compliance dates.
Implementation and Compliance Dates

Notwithstanding the ongoing work towards a practical efficiency-based Item Effective Date Compliance Date
standard, the EUB expects operators, as they implement the Solution Gas Reduction Schedule
requirements of Guide 60, to be able to demonstrate that they have 15% from 1996 baseline 1 January 2000 31 December 2000
assessed and incorporated appropriate operational practices and new 25% from 1996 baseline 1 January 2000 31 December 2001
technology developments that maximize combustion efficiency in the
Reduced NOWPP Flare Limit; GOR Limit; 1 January 2000 1 January 2000
design of new or modified flare systems. Development Well Tie-in

Implementation Flaring at Conserving Facilties 1 January 2000 1 January 2000

The EUB requires companies to assess their individual flaring policies Evaluation of Solution Gas Flares/
and practices as outlined by the management framework detailed in Compliance with Flare Performance
Requirements
Guide 60. Further, it requires companies to exercise diligent operating New Flares 1 January 2000 1 January 2000
practices and deliberate development of field facilities to enhance Existing Solution Gas Flares 1 January 2000 31 December 2002
conservation and minimize flaring. EUB personnel will ensure the Other Existing Flares 1 January 2000 31 December 2004
consistent application of the requirements detailed in Guide 60
throughout the province. Consultation and Notification
New Flares – revise Guide 56 1 January 2000 1 January 2000
IL 91-2: Sour Gas Flaring Requirements and Changes to Regulations Existing Solution Gas Flares – 1 January 2000 31 December 2000
residents within 500 m
and IL 96-6: Solution Gas Conservation and Emissions Review Management Framework 31 March 2001 N/A
Reduction are rescinded.
Other Matters
Compliance and Enforcement
While Guide 60 sets out existing requirements for various types of
The EUB considers the following to be critical aspects of the flaring, the feedback received on the review draft suggests further
management framework: stakeholder discussion is necessary for some matters, including:

• the review of existing flares, • well test volume approval criteria,

• completion of the required personal consultation and public
notification,
• compliance with the flare performance requirements,
• reducing flaring at conserving facilities, and
• accurate reporting of flare and vent data.
Accordingly, it will focus audit and enforcement efforts as necessary to
these key elements.
• gas plant flare volume limits,
• the development of flare and vent data submission business rules,
• site venting control criteria, and
• minimum heating values required for flame stability.
The EUB will initiate further discussions in due course.
Management Framework Review

In the context of the enforcement process detailed in IL 99-4,4 the The EUB intends to assess all aspects of the overall flare management
critical aspects noted above will be considered “major” non-compliance framework set out in Guide 60 in 2001. While the EUB anticipates that
events. Non-compliance with other requirements set out in the guide flares upgraded to meet the flare performance requirements set out in
will be considered “minor.” Guide 60 prior to the 2001 review would not be subject to further
revisions, it will consider this matter in light of flaring research
The EUB reserves the right to escalate non-compliance issue(s) to any available at that time.
level should conditions warrant.
Inquiries
If in the opinion of the EUB a non-compliance causes odours above
allowable limits or unacceptable impacts on the public, the operations Should you have any questions regarding Guide 60, please contact the
may be suspended if the impacts cannot be resolved. EUB at (403) 297-8311 and ask to be referred to one of the following:
Where possible, the EUB intends to utilize existing audit and • General Inquiries • Flare Performance
• Oil Batteries • Dispersion Modeling
4 • Gas Plants/Gas Batteries • Electricity Generation
IL 99-4:EUB Enforcement Process, Generic Enforcement Ladder,
• Well Test Volumes • S Statements
and Field Surveillance Enforcement Ladder, EUB, 1999.
• Flare Permits • Battery Codes

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 35
You can also contact any one of the following Field Centres: St. Albert (780) 460-3800
Wainwright (780) 842-7570
Bonnyville (780) 826-5352
Calgary (403) 297-8303 Guide 60 is available on the EUB Web site at http//www.eub.gov.ab.ca
Drayton Valley (780) 542-5182 or through the EUB’s Information Services at (403) 297-8190.
Grande Prairie (780) 538-5138
Medicine Hat (403) 529-3626
Red Deer (403) 340-5454
F. J. Mink, P.Eng.
Board Member

36 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
EUB Interim Directive (ID) 99-6: Summary of Changes
Existing
Solution Gas Conservation
• By application and/or Gas Conservation
Order
• Facility approvals: per Guide 56
• Reporting: per Guide 7
Well Test Flaring
• 600 103m3 volume approval
• Flare design requirements >1% H2S
• Flare permit greater than 5% H2S
• Notification: > 1 % H2S; 3 km, 24 hours
• Reporting: per Guide 40, Guide 7
New
Solution Gas Management Framework
• 15% solution gas flare reduction by end 2000
• 25% solution gas flare reduction by end 2001
• Evaluation of new and existing solution gas flares using decision tree,
including streamlined common economic assessment process, i.e.,
discount rate equal to Alberta Treasury Branch prime lending rate plus
3%
• Personal consultation and public notification required respecting
evaluation results for existing facilities
• Evaluation of flares within 500 m of residents with notification of
results—compliance by 31 December 2000
• Flare performance requirements: compliance for all existing flares by 31
December 2002
• Reduction to NOWPP flare limit to 300 103m3/month;
setting of a maximum GOR limit of 3000 m3/m3; and early tie-in
requirement – compliance by 1 January 2000
• Facility approvals: revise Guide 56.
• Decision tree must be used for new facilities
• Expanded personal consultation and public notification requirements
specific to flaring
• Electricity generation: streamlined small generator approval process to
expedite use of otherwise flared solution gas for electricity generation
• Flare reduction requirements for conserving facilities during planned or
emergency flaring, including EUB and public notification, effective
1 January 2000
• Log of flare events and complaints
• Conflict resolution process to address flare-related concerns
• Reporting: per Guide 7; review requirements to improve data quality;
data submission enforcement; battery type definitions in Guide 7; flare
and vent data publicly available
• Regional and provincial company benchmarking (ranking)
See Guide 60, Section 2
Well Test Flaring
• 600 103m3 volume approval
• Volume approval criteria to be reviewed
• Flare performance requirements
• Flare permit greater than 5% H2S
• Streamlined temporary facility approvals to promote in-line testing
• Notification: residents within 3 km, and EUB 24 hours in advance
• Reporting: per Guide 40, Guide 7
See Guide 60, Section 3
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 37
EUB Interim Directive (ID) 99-6: Summary of Changes (cont’d)
Existing
Gas Battery Flaring
• Facility approvals: per Guide 56
• Flare design requirements
• Reporting: per Guide 7
Gas Plant Flaring
• Facility approvals: per Guide 56
• Sulphur recovery: per IL 88-13
• Flare design requirements
• 0.5% raw gas inlet/year volume limit
• Release reporting: per IL 98-01
• Reporting: per Guide 7
Pipeline Emissions
• Notification: residents within 3 km (GGS
flaring) and EUB 24 hours in advance;
EUB 24 hours in advance (transmission
system venting or flaring)
• Reporting: per Guide 7 (gas gathering
systems); Annual Transporter Statements
(transmission systems)
Flare Design Requirements
• Scope: > 1% H2S
Flare Stack Design and Operation
• Ignition: continuous ignition available
• Flame stability: 9 MJ/m3
• Stack height: Ambient Guidelines
• Liquid separation: no liquids to flare
• Spacing: 100 m from residence
• Visible emissions: 40% opacity
• Dispersion modelling: single-point source
38 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
New
Gas Battery Flaring
• Facility approvals: per Guide 56
• Flare performance requirements
• Sulphur recovery requirements
• Reporting: per Guide 7
See Guide 60, Section 4
Gas Plant Flaring
• Facility approvals: per Guide 56
• Sulphur recovery: per IL 88-13
• Flare performance requirements: compliance by 1 January 2005; flare
stability effective 1 January 2000
• 0.5% raw gas inlet/year volume limit
• Flare volume limit to be reviewed
• Flare measurement requirements
• Notification: EUB 24 hours (advance or after)
• Release reporting: per IL 98-01
• Log of flare events and complaints
• Reporting: per Guide 7; EUB business rules to improve data quality;
data submission enforcement
See Guide 60, Section 5
Pipeline Emissions
• Notification: residents within 3 km (GGS flaring) and EUB 24 hours in
advance; EUB 24 hours in advance (transmission system venting or
flaring)
• Review need for transmission system requirements
• Reporting: per Guide 7 (gas gathering systems); transmission system –
report venting and flaring separately
See Guide 60, Section 6
Flare Performance Requirements
• Scope: All flares, regardless of composition
Flare Stack Design and Operation
• Ignition: flame must be present
• Flame stability: 12-20 MJ/m3.
• Exit velocity guidelines
• Stack height: Ambient Guidelines
• Documented procedures for emergency flares
• Liquid separation: No liquids to flare; designed for specific operation;
visual liquid level indicators and high-level alarms on knockout drums
• Spacing: 100 m from residence
• Visible emissions: 40% opacity
• Dispersion modelling: cumulative emission assessment if single source
exceeds 1/3 of Ambient Air Quality Guideline for SO2
See Guide 60, Section 7
EUB Interim Directive (ID) 99-6: Summary of Changes (cont’d)
Existing
Venting Limits
• Significant volumes to be burned
• Ambient Air Quality Guidelines
Sulphur Recovery Guidelines
• Gas plants
Industry Performance Reporting
• Annual solution gas conservation
Enforcement
• New facility consultation and notification
• Flare design requirements
• Individual facility focus
New
Venting Limits
• Significant continuous volumes to be burned; no continuous off-site
odours
• Site venting control criteria to be reviewed
• Benzene emission requirements of IL 97-04
• Ambient Air Quality Guidelines
See Guide 60, Section 8
Sulphur Recovery Guidelines
• Facilities emitting more than 1 tonne/day
• Review of facilities emitting 1-5 tonne/day
See Guide 60, Section 9
Industry Performance Reporting
• Reduction schedule progress (line chart)
• Annual flaring by type (pie chart)
• Annual solution gas conservation (bar chart)
• Regional and provincial company solution gas flare benchmarking
(ranking)
• Annual venting by type (pie chart)
See Guide 60, Section 11
Enforcement
• New facility consultation and notification
• Evaluation process including consultation and notification respecting
existing flares
• Flare performance requirements
• Flaring at conserving facilities
• Corporate focus
• Reference IL 99-4
See Guide 60, Section 12
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 39
ID 99-7: CSA Standard CSA Z662-99 Oil and Gas Pipeline Systems
28 July 1999
TO: All Oil and Gas Operators
CSA STANDARD CSA Z662-99 OIL AND GAS PIPELINE SYSTEMS
This interim directive supersedes Interim Directive (ID) 97-3, and
Informational Letter (IL) 91-8 is rescinded.
The Alberta Energy and Utilities Board (EUB) is responsible, pursuant
to Part 4 of the Pipeline Act, for approving pipelines and associated
installations for the transportation of oil, gas, synthetic crude oil, and
fluids incidental to or associated with such production within Alberta.
This interim directive addresses the EUB’s approach towards
implementation and adoption of the Canadian Standards Association
standard CSA Z662-99 Oil and Gas Pipeline Systems (the standard).
The EUB adopted CSA Z662-96 in June 1997 as the minimum
requirements for pipeline systems in Alberta. The main changes from
CSA Z662-996 are
• Revision of pressure control and overpressure protection
definitions and requirements
• Modification of requirements for class location end boundaries
• Addition of restrictions concerning the design pressure for piping
containing pipe made to a standard or specification other than CSA
Standard Z245.1 and API Specification 5L
• Revision making it now permissible to use pipe and components
manufactured to specific non-CSA standards or specifications
without first having to determine that CSA pipe and components
are not available
• Modification of requirements for proven notch toughness
properties for pipe
• Addition of requirements for the management of the integrity of
pipeline systems during operation, maintenance, and upgrading
40 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
• Addition of requirements to cover reactivation of deactivated
piping and to cover abandonment of piping
• Addition of requirements to cover polyethylene pipelines for dry
gas gathering
• Addition of requirements as Clause 15 to cover the design,
construction, operation, and maintenance of aluminum piping;
CSA Standard Z169-M1978, Aluminum Pipe and Pressure Piping
Systems, is no longer in effect
• Addition in Appendix B of non-mandatory guidelines for risk
evaluation, so that it now covers the risk assessment component of
risk management
• Addition as Appendix D of non-mandatory guidelines for in-line
inspection of pipelines
The EUB endorses both the intent and the purpose of the changes.
Therefore, effective 1 November 1999, the EUB requires that the
minimum requirements for the design, construction, testing, operation,
maintenance, and repair of pipeline systems in Alberta shall be in
accordance with the standard, insofar as it is inconsistent with the
Pipeline Act and Pipeline Regulation.
Notwithstanding the above, the EUB recognizes variances may be
appropriate under certain circumstances and would be prepared to
consider such variances where supported by appropriate technical data
and operational history.
Questions regarding this interim directive should be directed to the
EUB’s Regulatory Support Branch at (403) 297-3642.
F. J. Mink, P.Eng.
Board Member
ID 99-8: Noise Control Directive
1 November 1999
TO: All Energy Industry and Industrial Development Permit Facility
Operators and Drilling and Servicing Rig Contractors
INTRODUCTION
This directive supersedes Interim Directive (ID) 94-4. It is effective
immediately and will be reviewed after a two-year period, in November
2001, or as required.
With the continued widespread growth of energy operations throughout
the province, additional sources of energy industry-related sound are
appearing. While residents, particularly in rural areas, would generally
prefer no increase in sound levels resulting from energy-related
developments, it is sometimes not possible to completely eliminate
these increases. However, if proper sound control features are
incorporated into facility design in the planning stages, increases in
sound levels can be kept to acceptable minimums.
This directive views noise from a receptor viewpoint, rather than
considering sound levels at the property line. Criteria based on property
line measurements were considered to be too restrictive in rural settings,
since a natural buffer often exists between operating facilities and any
occupied dwellings.
This directive applies to all facilities under the EUB’s jurisdiction or
where the EUB has issued a permit to operate. Facilities approved prior
to April 1988 will be dealt with on a case-by-case basis, while new
facilities will be designed to meet this directive. Although the directive
is comprehensive, it is expected some cases will need to be dealt with
on a site-specific, issues-oriented basis. For example, while the
directive is not applicable to construction activity, these activities must
be conducted with some consideration for noise. Any related complaints
must be dealt with by the facility operator. For details about
construction noise, see Guide 38: Noise Control Directive User Guide,
Section 5.1, note 1.0.
This directive takes into consideration the existing ambient sound level,
character of the sound, temporary or permanent nature of the source,
and seasonal sensitivity to sound in order to establish reasonable sound
levels. It was developed by a committee composed of members from the
acoustical consulting community, industry, universities, rural
landowners, governmental agencies, and EUB staff.
The directive attempts to take a balanced viewpoint by considering the
interests of both the nearby residents and the facility owner/operator.
The directive does not guarantee that a resident will not hear sounds
from a facility even if it is in compliance; rather it aims for a situation
where sound level increases will be kept to acceptable minimums and
overall quality of life and indoor sound levels for neighbours to a
facility will not be adversely affected. For example, the attenuation of
sound through the walls of a dwelling should decrease indoor sound
levels to a point where normal sleep patterns are not disturbed.
GUIDE 38
Guide 38: Noise Control Directive User Guide has been revised to help
you better understand this directive. It presents the rationale for the
directive, provides background information, and outlines an approach to
dealing with noise problems. Those not familiar with noise and related
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 41
terminology used in this directive are encouraged to review Section 3:
The Leq Concept and Appendix 1: Glossary in Guide 38.
What’s New in Guide 38: This 1999 edition of Guide 38, which
replaces earlier editions, integrates the section formerly identified as
“Supplement to the Interim Directive” into the guide itself.
Although the technical requirements in this edition of the directive and
Guide 38 have not changed, many enhancements have been made to
help users better understand the complexities of this policy. Some of the
more significant areas of interest are as follows:
Construction Noise (Section 5.1)—Industrial operators must consider
construction noise. This guide provides a number of suggestions that
operators can implement to help minimize the noise impact on nearby
residents.
Complaint Investigation Process (Section 6)—The directive and guide
now provide tools to assist operators and their neighbours in
determining the conditions when industrial noise is a problem so that
noise surveys can be performed under similar representative conditions.
Noise Impact Assessments (Section 7)—The improved section on noise
impact assessments enables operators to better understand EUB
expectations and carry out assessments as part of their facility
applications.
Measurement Instrumentation and Techniques (Appendix 2)—
Calibration requirements have been added for sound level meters in
accordance with the appropriate American Noise Standards Institute
requirements.
COMPLAINT INVESTIGATION
The EUB expects operators to deal expeditiously with any noise-related
complaint brought to their attention. When attempting to resolve a noise
complaint, it is critical that operators first establish direct contact with
the complainant to understand their concerns and create a dialogue. At
this point, the operator should explain the requirements of this directive
and clearly outline the process, including time lines, it intends to follow
in addressing the matter. If a comprehensive sound survey is to be
performed, to be technically valid the operator or its consultant must
determine the representative conditions that exist when noise would
impact a residence. For more information on complaint investigation,
see Guide 38, Sections 2 and 6. Section 6 includes a sample Complaint
Investigation and Event Log form to assist in resolving the concern.
NOISE IMPACT ASSESSMENT
Intent and Objective: The intent of a noise impact assessment (NIA) is
to ensure that applicants consider possible noise impacts before a
facility is constructed or operated, since the cost to retrofit may be
significantly more than if noise mitigation measures are incorporated
into the design of a facility. The objective of an NIA is to predict what
the expected design sound level from the facility is at the nearest or
most impacted permanently or seasonally occupied dwelling. Best
practical technology (accounting for cost versus benefit) should be
considered to minimize the potential noise impacts to existing dwellings
and future infringement. Operators should discuss noise matters with
area residents during the design, construction, and operating phases of a
facility. Should a valid complaint be registered after the facility is
constructed and in operation, the operator must meet the permissible
sound level (PSL) referenced in the NIA.
Eligible Facilities: An NIA must be completed as part of the facility
application process for any new permanent facilities or for
modifications to existing permanent facilities where there is a
reasonable expectation of a continuous or intermittent noise source. For
the purposes of this directive, a permanent facility is defined as any
facility that will be at a location longer than two months. Compressor
stations, pumping stations, electric power plants, coal mines, gas
processing plants, industrial development permit facilities, and batteries
with compressors are examples of facilities where an NIA is required.
Drilling and servicing rigs fall into the temporary facility category even
if they are expected to be at a location more than two months.
Temporary activities will generally not require an NIA and will be
handled on a complaint basis. Nevertheless, when selecting equipment,
such as rigs, for these temporary activities, operators should bear in
mind the EUB’s expectation of expeditious compliance if complaints
occur. The EUB may require an NIA for any facility it deems necessary.
Compliance and Enforcement: An NIA must be conducted for any
new permanent facilities or for modifications to existing permanent
facilities where there is a reasonable expectation of a continuous noise
source (see Section 7 in Guide 38). However, you do not have to
include the assessment with the facility application if the analysis
indicates compliance (see EUB Guide 56: Energy Development
Application Guide). In cases where the assessment indicates
noncompliance, you must consider further attenuation measures. Where
such measures are not practical, you can include the assessment with the
application, along with reasons why the measures proposed to reduce
the impacts are not practical.
The EUB conducts random comprehensive sound surveys and audits on
facilities and facility applications and expects sound levels to be in
compliance and NIAs to be complete and understandable. Upon audit,
failure to have an appropriate or complete NIA is considered a
noncompliance event. If you are unsure of the requirements for an NIA,
contact an appropriate consultant or the EUB’s Regulatory Support
Branch (403-297-3642).
The EUB considers the following to be “major” noncompliance events:
C Submission of an NIA that is inappropriate, incomplete, and
contains significant errors or omissions
C Failure of a new facility to meet the permissible sound levels at the
nearest or most impacted residence as determined by a post-
construction/start-up comprehensive survey
C Failure to respond expeditiously to a legitimate noise complaint
regarding an existing facility
Noncompliance with other requirements of ID 99-8 or Guide 38 are
considered “minor” events.
The EUB reserves the right to escalate noncompliance issue(s) to any
level should conditions warrant.
If in the opinion of the EUB a noncompliance event causes noise levels
greater than the permissible sound level or unacceptable impacts on
nearby residents, it may suspend operations if the impacts cannot be
resolved.
42 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
Where possible, the EUB intends to utilize existing audit and
enforcement processes. For example, Field Surveillance Group
enforcement ladders may be used to provide consistent consequences
with other similar field facility noncompliance events. For more
information on this, contact the appropriate EUB Field Centre office.
Technical Methodology: The EUB does not automatically require
detailed calculations to prove the validity of the predictions, but it does
expect a reasonable technical basis for the values presented in the NIA.
Computer modelling, field measurements of similar equipment,
accepted acoustical engineering examples from literature, or
calculations may be used as tools to predict comprehensive sound levels
(CSL).
Legitimate manufacturers’ specifications rated for the type of service
expected are also acceptable, but applicants are cautioned to use only
manufacturers’ data that indicate sound levels in the acoustic far or free
fields. Manufacturers’ data are often provided as the sound pressure
level in the near or reverberant field (e.g., sound pressure levels
measured at 1 m from the source), which are not indicative of those
expected in the far or free field. Using near or reverberant sound
pressure levels results in inaccurate noise impact assessment
predictions. A sound pressure level value measured at 1 m is not
applicable for inverse square law calculations and therefore does not
qualify for the 6 dB reduction in sound level for each doubling of
distance from the source. Once the predicted CSL has been established,
it should be compared to the calculated PSL to determine the possible
impact of the facility on any permanent or seasonal residents.
Special Considerations: Operators planning facilities in an area where
there is already an energy industry presence are responsible for ensuring
that their facility either will not cause the overall sound levels to exceed
the PSL or, in situations where the existing noise levels are acceptable
to residents even though they may be higher than the PSL, will not
cause an increase in overall sound levels. In the latter case, the existing
sound levels become the new PSL. Applicants may wish to discuss their
proposed projects with adjacent operators to examine potential sound
attenuation measures that are both effective and economical. For
example, it may be more cost effective to install silencers on existing
equipment, rather than design additional sound attenuation measures
into the proposed facility.
For operators proposing projects in an area with established energy
facilities, a comprehensive sound survey or modelling using
measurements from similar existing sources should be considered to
determine the sound environment. For areas with no energy industry
presence where noise may be an issue with local residents, operators
may want to conduct an ambient sound survey to identify existing
sound levels. However, neither sound survey is required to conduct an
NIA.
For more information on the requirements of an NIA, refer to Guide 38,
Section 7, which includes a worksheet form to assist in completing an
assessment.
GRANDFATHERING
It is the EUB’s view that noise impacts are either acceptable or
unacceptable, irrespective of the age of the facility, and that a separate
formula based on facility age would be inappropriate. However, the
EUB remains willing to address individual cases on their own merits,
since a vast number of variables may affect the level of noise impacts
and an operator’s ability to respond effectively. The EUB is also aware
that each decision by an operator with regard to noise attenuation may
affect its ability to provide overall net public benefits in other areas
(e.g., facility consolidation). The EUB is willing to consider noise as
one component of an overall public benefit/cost assessment for a facility
and to consider a range of options in assessing project acceptability.
Further information regarding this interim directive may be obtained
from the EUB’s Regulatory Support Branch (403-297-3642) or from
the appropriate Field Centre.

Brad McManus, QC
Board Member

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 43
ID 2000-3: Harmonization of Waste Management and Memorandum of Understanding
May 31, 2000
TO: All Oil and Gas Operators
All Oil Sands Operators
All Drilling and Servicing Operators
All Pipeline Operators
All Oilfield Waste Management Operators
HARMONIZATION OF WASTE MANAGEMENT
The Alberta Energy and Utilities Board (EUB) and Alberta
Environment (AENV) have developed a Memorandum of
Understanding (MOU) on the harmonization of waste management in
Alberta. The MOU is intended to clarify the jurisdictional roles of the
EUB and AENV, reduce regulatory duplication, promote an equivalent
level of environmental protection and public safety, and reduce liability
through appropriate waste management.
The MOU outlines guiding principles that the EUB and AENV have
agreed to implement to harmonize requirements surrounding the
management of oilfield and nonoilfield wastes. The harmonization
agreements include the division of regulatory responsibilities based on
the type of waste management facility or activity.
Questions regarding the MOU should be directed to either the EUB at
(403) 297-6952 or AENV at (780) 427-5883.
Brian Bietz Doug Tupper
Board Member Assistant Deputy Minister
Alberta Energy and Utilities Board Alberta Environment
Memorandum of Understanding Between
the Alberta Energy and Utilities Board
and Alberta Environment on
Harmonization of Waste Management
May 31, 2000
1 Introduction
Responsibility for the regulation of wastes in Alberta is divided
between the Alberta Energy and Utilities Board (EUB) and Alberta
Environment (AENV). The EUB is responsible for the regulation of
upstream oilfield wastes, while AENV is responsible for the regulation
of all other wastes generated in Alberta. This regulatory framework was
established in 1993. The jurisdictional split was based on the premise
that each agency’s requirements would provide an equivalent level of
environmental protection and public safety, while acknowledging that
operationally the EUB’s and AENV’s processes might not be exactly
the same.
To harmonize and clarify waste management requirements in Alberta,
the EUB and AENV have agreed that each agency’s responsibilities
should be based on its specific expertise and experience related to
certain types of wastes and waste management options. As a result, the
EUB and AENV have agreed to divide regulatory responsibilities based
on the type of waste management facility or activity. This new division
44 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
will ensure the effective use of resources and technical expertise within
each agency, reduce duplication, and eliminate uncertainty regarding
who approves what.
The purpose of this memorandum of understanding (MOU) is to
communicate fundamental waste harmonization principles that will
promote equivalency and then to communicate the division of roles and
responsibilities between the EUB and AENV regarding the regulation
of wastes in Alberta.
2 Principles
To support the goal of a credible, responsible, effective, and practical
system for the management of wastes in Alberta, the EUB and AENV
agree that the following guiding principles shall be applied to the
management of oilfield and non-oilfield wastes:
• An equivalent level of environmental protection and public safety
will be achieved through either the EUB’s or AENV’s
requirements and enforcement practices.
• The waste classification and characterization system will be
consistent, such that the criteria or properties that render a waste
hazardous or an oilfield waste dangerous shall be the same.
• A waste management facility will be approved pursuant to one set
of regulatory requirements, either the EUB’s or AENV’s. AENV
will regulate activities/facilities managing non-oilfield wastes or
mixtures of non-oilfield and oilfield wastes, while the EUB will
regulate
activities/facilities managing oilfield wastes. In situations where an
EUB-regulated facility wishes to manage small quantities of non-
oilfield wastes, the EUB will review the request with input from
AENV on a case-by-case basis.
• The approval process for waste management facilities shall be
coordinated so that in situations where both the EUB and AENV
have an interest in a facility (e.g., a facility that intends to manage
oilfield and non-oilfield wastes), the appropriate approving
authority will act as the “one window” and coordinate the
application review with input from the other agency.
• Waste volume minimization involving reuse, recycle, reduce, and
recover philosophies will be promoted through either the EUB’s or
AENV’s requirements.
• The shared responsibility between the waste generator and the
waste receiver for the appropriate management of wastes shall be
supported and enforced by the appropriate regulatory agency,
either the EUB or AENV.
3 Harmonization
Through this MOU the EUB and AENV agree to conduct their
regulatory operations in accordance with the above-noted principles and
to harmonize the requirements surrounding the management of wastes
in Alberta. Refer to Appendix 1 for a list of EUB and AENV legislative
documents and background information pertaining to waste
management. See Appendix 2 for a list of definitions pertaining to
waste management.
3.1 Approval and Regulation of Waste Management Facilities and
Activities
To simplify the regulatory framework established in 1993, the EUB and
AENV have agreed to the following division of waste management
regulatory responsibilities.
a) EUB responsibilities include
• schemes for deep well injection, slurry fracture injection, and
cavern disposal of wastes, as well as associated surface facilities
for these activities on upstream petroleum sites,
• oilfield waste transfer stations feeding solely to an oilfield waste
management facility,
• all waste management activities occurring on oil or gas sites within
a production system, including one-time treatment and permanent
waste management components (e.g., biopiles/biocells, small
incinerators, landfills, waste processing technology), and
• with the exception of stand-alone landfills and incinerators, all
waste management facilities established for recovery of crude oil
or other processing of oilfield wastes (e.g., oilfield waste
processing facilities, biodegradation facilities, and facilities
established to clean oilfield rags, pipes, or filters).
Waste management activities regulated by the EUB will be subject to
the requirements set out in the pertinent documents listed in Appendix
1.1.
b) AENV responsibilities include
• all off-site and mobile incinerators and thermal treatment units,
• all off-site landfills and dedicated land treatment facilities,
• surface facilities for deep well injection, slurry fracture injection,
and cavern disposal of wastes within an AENV-approved non-
oilfield plant,
• compost facilities,
• waste management or recycling facilities handling non-oilfield
wastes/recyclables or mixtures of non-oilfield and oilfield
wastes/recyclables, and
• transfer stations, other than those feeding solely to an oilfield
waste management facility.
Waste management activities regulated by AENV are subject to the
pertinent documents listed in Appendix 1.2.
Based on the above division of waste management regulatory
responsibilities, the EUB will not be the agency responsible for stand-
alone sites established as a landfill or as a thermal treatment facility
(fixed incinerator or thermal treatment unit), regardless of whether
oilfield wastes are the intended waste streams. For facilities not listed in
(a) or (b), the responsible regulatory authority will be determined by
agreement between the EUB and AENV using the principles in this
MOU as a guide.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 45
3.2 Waste Characterization and Classification
The properties and criteria identified in EUB and AENV legislation
defining dangerous oilfield wastes and hazardous wastes will be the
same. Guidance documents developed by each agency and
recommendations given to industry on the characterization and
classification of specific wastes, the properties to be measured, the
analytical methods to be used, and the chemical parameters to be tested
will be consistent with the Alberta User Guide for Waste Managers,
published by Alberta Environment.
3.3 Importation and Exportation
The regulatory distinction of oilfield wastes from other industrial wastes
and their classification into non-dangerous and dangerous oilfield
wastes are designations specific to wastes generated in Alberta. The
legislation regarding the importation and exportation of all wastes,
including oilfield wastes, in and out of Alberta resides within the
Environmental Protection and Enhancement Act (EPEA). As such,
wastes or recyclables entering or leaving Alberta must be classified as
non-hazardous or hazardous. Anyone who consigns, transports, or
receives hazardous wastes or imported/exported hazardous recyclables
must have a personal identification number (PIN) from AENV and/or
be authorized under EPEA.
The EUB and AENV agree that EUB-regulated oilfield waste
management facilities may receive imported recyclables (non-
hazardous or hazardous) provided that
• the recyclables are generated from the exploration and production
of oil and gas,
• the waste management process produces a recoverable material
(e.g., crude oil, clean rags, or pipes), and
• the facility approval authorizes the receipt of the type of wastes in
question.
AENV will provide written authorization and a PIN to EUB-regulated
oilfield waste management facilities that import hazardous recyclables
and meet the above criteria.
3.4 Manifesting and Tracking
Currently EUB Guide 58: Oilfield Waste Management Requirements
for the Upstream Petroleum Industry requires dangerous oilfield wastes
being transported on public roads to destinations within Alberta to be
manifested using the Alberta Oilfield Waste Manifest. Effective July 1,
2000:
• The EUB will not require submission of the white (fifth) copy of
the Alberta Oilfield Waste Manifest and will eventually reduce the
manifest to an EUB four-part form (Alberta Oilfield Waste Form).
• Dangerous oilfield wastes destined for AENV-regulated hazardous
waste facilities for destruction, disposal, or consolidation must be
accompanied by the Alberta Oilfield Waste Manifest or its
reduced four-part form. Further transportation of these wastes
from AENV-regulated facilities requires classification,
manifesting, and a PIN, as per the requirements in the Waste
Control Regulation under EPEA.
• Imported and exported hazardous recyclables and hazardous
wastes generated from exploration and production of oil and gas,
regardless of their destination, are subject to the Transportation of
 Dangerous Goods Regulation (TDGR) and manifest requirements
under EPEA.
• A recycle docket pursuant to AENV requirements or the Alberta
Oilfield Waste Manifest or its reduced four-part form must
accompany any shipment of dangerous oilfield wastes going to an
AENV-approved recycling facility.
The tracking and reporting requirements under Guide 58 remain
applicable to oilfield wastes sent out of province or to AENV-regulated
waste management or recycling facilities. The tracking systems required
for the movement of dangerous oilfield wastes are shown in Figure 1.
Facilities regulated by the EUB and AENV must retain records and
report waste management information. Information requirements are
outlined in the respective approval for a waste management facility or
by policy directives specific to the EUB or AENV.
3.5 Environmental Impact Assessments
The environmental impact assessment (EIA) process is supported by
two regulations pursuant to EPEA: the Environmental Assessment
(Mandatory and Exempted Activities) Regulation and the
Environmental Assessment Regulation. The regulations outline those
activities for which EIAs are either mandatory or exempted and
establish the public information and notice requirements for the
process. For projects not on the exempted or mandatory lists, the need
for an EIA is assessed on a site-specific basis (i.e., discretionary
projects). The EUB will refer any oilfield waste management facility
application that it considers might require an EIA to AENV for further
assessment. If AENV assesses that an EIA is required, AENV will
manage the EIA process.
3.6 Financial Security
Both the EUB and AENV, as part of their respective application
processes, require financial security for certain types of waste
management facilities. The amount of security is based on the nature
and the amount of wastes/recyclables managed, the type of facility, the
estimated cost of reclamation, and any associated post-closure
monitoring for the facility.
3.7 Enforcement
Waste generators and receivers are expected to manage wastes created
or received in accordance with the current legislative requirements of
EPEA or the Oil and Gas Conservation Act, as applicable. The EUB
and AENV will engage the appropriate resources within the regulatory
agencies to fully enforce waste management. In general, by the nature of
the legislation approaches may be different in each agency, but the goal
of both is to ensure compliance with requirements. Both agencies will
work together to coordinate their enforcement activities.
a) EUB Surveillance and Enforcement
The EUB uses a combination of audits and inspections to ensure that
oilfield waste generators and receivers under its jurisdiction comply
with
• the EUB regulatory documents listed in Appendix 1.1, as well as
any subsequent oilfield waste management requirements
established by the EUB, and
• the terms and conditions specified in a facility’s approval.
46 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
Each oilfield waste management facility is inspected at least once a
year and audited every four to five years unless circumstances warrant
more frequent evaluations. A generator audit is based on the Annual
Waste Disposition Report and is intended to verify appropriate waste
disposition locations, ensure that waste types and volumes are tracked,
and confirm that on-site waste management activities comply with
protocols in Guide 58. A generator audit may also be triggered as a
result of questionable waste management activities found during an
EUB inspection of oil or gas production sites.
Noncompliance issues are managed in accordance with the EUB’s
enforcement ladders, which are based on a concept of escalating
consequences for repeat noncompliance. For further information, see
EUB Informational Letter (IL) 99-4: EUB Enforcement Process,
Generic Enforcement Ladder, and Field Surveillance Enforcement
Ladder and IL 99-4 Clarification. In situations where audit findings
indicate that oilfield wastes were inappropriately disposed at AENV-
regulated facilities, the EUB will inform AENV and coordinate
enforcement actions.
b) AENV Surveillance and Enforcement
AENV has an active Compliance Inspection Program (part of the
department’s overall Compliance Assurance and Enforcement Program)
to ensure that facilities comply with EPEA requirements. Inspections
are generally unannounced and cover all aspects of a facility’s approval
or registration. How frequently AENV inspects a facility depends on its
priority, which the department assigns based on a number of factors.
They include
• potential to cause an adverse effect,
• compliance history,
• environmental performance, and
• time elapsed since last inspection.
Companies with greater potential to cause an adverse effect or with a
history of noncompliance can expect to be inspected more frequently
than others.
The overall Compliance Assurance and Enforcement Program outlines
AENV’s approach to enforcement. All cases follow a well-defined path
moving from incident through investigation to an enforcement outcome.
Enforcement decisions can involve file closure, issuing a warning letter
or an administrative penalty, forwarding the file to Alberta Justice for
prosecution, and/or issuing an enforcement order.
4 Summary
The EUB and AENV both have responsibilities related to the
management of wastes in Alberta. Each agency is committed to
developing and implementing its waste-related regulatory programs in a
manner that minimizes overlaps and ensures environmental protection
and public safety. This MOU outlines the principles and actions that are
being or will be followed to achieve harmonization pertaining to the
regulation of wastes in Alberta.
 AENV Hazardous Waste
Management Facility (landfill,
incinerator, transfer station)

F&T

Exported Out
of Alberta AENV
Dangerous Oilfield Recycling
M&T
Wastes RD or Facility
F&T

T
F&T

On-site EUB Oilfield

Treatment Waste
(Guide 58 Management
options) Facility

F - Four-part form or Oilfield Waste Manifest (EUB)

T - Tracking (as per Guide 58)
M - Manifest and PIN (as per EPEA)
RD - Recycle docket (AENV)
Figure 1. Tracking systems for movement
of dangerous oilfield wastes

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 47
Appendix 1 Legislative Background
The division of responsibilities between the EUB and AENV is based
on the regulatory distinction between oilfield wastes and nonoilfield
wastes. Oilfield waste is defined in both agencies’ legislation as an
unwanted substance or mixture of substances that results from the
construction, operation, or reclamation of a well site, oil and gas
battery, gas plant, compressor station, crude oil terminal, pipeline, gas
gathering system, oil production site, or oilfield waste-related facility.
The EUB and AENV have agreed to amend the definition of oilfield
wastes to not include a substance or mixture of substances from the
above-cited sources when received at facilities regulated by AENV.
Oilfield wastes must, first, not contravene any EUB requirement for the
management of oilfield wastes and then, second, qualify for acceptance
at the AENV-regulated facility. Upon entering the facility, the oilfield
waste then becomes a waste regulated by AENV for the purpose of
storage, treatment, disposal, or further transportation.
1.1 EUB Legislation
The EUB regulates the management of oilfield wastes under the
authority of the Oil and Gas Conservation Act and the Oil and Gas
Conservation Regulation. The details regarding the management of
oilfield wastes at the generator’s facility site, the transportation of
oilfield wastes on Alberta’s public roads, and the treatment and disposal
of oilfield wastes at waste management facilities are outlined in the
following EUB documents:
• ID 96-3 and Guide 58: Oilfield Waste Management Requirements
for the Upstream Petroleum Industry
• IL 96-13 and Guide 50: Drilling Waste Management
• IL 94-2 and Guide 51: Injection and Disposal Wells, Well
Classifications, Logging, and Testing Requirements
• ID 95-3 and Guide 55: Storage Requirements for the Upstream
Petroleum Industry
• ID 99-4: Deposition of Oilfield Waste into Landfills
• IL 99-2: Use of Produced Sand in Road Construction
• IL 98-2: Suspension, Abandonment, Decontamination, and
Surface Land Reclamation of Upstream Oil and Gas Facilities
• IL 98-1: Coordination of Release Notification Requirements and
Subsequent Regulatory Response
• IL 99-4: EUB Enforcement Process, Generic Enforcement Ladder,
and Field Surveillance Enforcement Ladder (with Clarification
dated February 24, 2000)
• Guide 36: Drilling Rig Inspection Manual
• Guide 37: Service Rig Inspection Manual
• Guide 63: Oilfield Waste Management Facility Inspection Manual
(in draft)
• Guide 64: Facility Inspection Manual
48 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
1.2 AENV Legislation
The AENV waste management framework is based on the following
legislation and guidance documents:
• Environmental Protection and Enhancement Act (EPEA), which
establishes the principles and legal requirements for waste
management, including environmental assessment processes,
approvals and registrations, waste manifesting, release of
substances, and enforcement activities
• Activities Designation Regulation (ADR), which identifies those
waste management activities that require approval, registration, or
notification
• Waste Control Regulation (WCR), which establishes the
administrative procedures and technical criteria for waste and
recyclables management, waste importation, manifesting, and
financial security
• Approvals and Registrations Procedure Regulation, which outlines
the requirements for approval and registration applications
• Release Reporting Regulation
• Substance Release Regulation
• Environmental Assessment (Mandatory and Exempted Activities)
Regulation
• Environmental Assessment Regulation
• Alberta User Guide for Waste Managers, which interprets and
details the regulatory requirements applicable to AENV hazardous
waste/recyclable management
• Code of Practice for Landfills
• Code of Practice for Composting Facilities
• Code of Practice for Small Incinerators (draft)
• Code of Practice for Alternate Fuels (draft)
• Code of Practice for Land Treatment and Disposal of Soil
Containing Hydrocarbons (draft)
In addition to the legislation and guides to above, the federal
Transportation of Dangerous Goods Act and Regulation, administered
in Alberta by the Department of Alberta Infrastructure, contains
dangerous goods classification, packaging, and transportation
requirements.
Appendix 2 Definitions
Approved Landfill (AENV)An AENV-regulated landfill that accepts
more than 10 000 tonnes of wastes per year, that accepts hazardous
wastes, or that is located in a ravine, gully or coulee, or over a buried
valley and is approved under the Environmental Protection and
Enhancement Act.
Biodegradation Facility (EUB) A type of oilfield waste management
facility where oilfield wastes are biologically degraded in a contained
and controlled environment, whether it is in an impermeable cell
structure (biocell) or piled on a impermeable liner (biopile). (Does not
include land treatment.)
Compost (AENV) The stable humus-like material that results from the
biological decomposition and stabilization of organic materials under
aerobic and thermophilic conditions. It is potentially beneficial to plant
growth and is sanitized to a degree that protects human health.
Compost Facility (AENV) A waste management facility where waste,
not including hazardous waste, is (AENV) decomposed through a
controlled bio-oxidation process that results in a stable humus-like
material but does not include a residential composter or a compost
facility that receives only sludge as defined in the Wastewater and
Storm Drainage Regulation.
Facility (EUB) Any building, structure, installation, equipment, or
appurtenance over which the Board has jurisdiction and that is
connected to or associated with the recovery, development, production,
handling, processing, treatment, or disposal of hydrocarbon-based
resources or any associated substances or wastes, and includes, without
limitation, a battery, a processing plant, a gas plant, an oilfield waste
management facility, a central processing facility as defined in the Oil
Sands Conservation Regulation (AR 76/88), a compressor, a
dehydrator, a separator, a treater, a custom treating plant, a produced
water-injection plant, a produced water disposal plant, a miscible flood
injection plant, a satellite, or any combination of them, but does not
include a well, a pipeline as defined in the Pipeline Act, a mine site or
processing plant as defined in the Oil Sands Conservation Regulation
(AR 76/88), or a mine site or coal processing plant as defined in the
Coal Conservation Act.
Land Treatment (AENV) The controlled application of a substance on
the soil surface and incorporation of the substance into the upper soil
zone in such a manner that physical, chemical, or biological degradation
of the substance takes place. (Dedicated facilities allowed.)
Land Treatment (EUB) A planned and controlled mixing of oilfield
wastes and soil surface in which the inherent soil processes are used to
biodegrade, transform, and assimilate the waste constituents. (Limited
to one-time, on-site application of non-refined hydrocarbon
contaminated soil or pit/pond sludge.)
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 49
Off-site (AENV) An independent site established to manage third-
party wastes.
Oilfield Waste An unwanted substance or mixture of substances that
results from the construction, operation, abandonment, or reclamation
of a facility, well site, or pipeline but does not include an unwanted
substance or mixture of substances from such a source that is received
for storage, treatment, disposal, and/or recycling at a facility regulated
by Alberta Environment.
On-site (AENV) Management of a generator’s hazardous wastes at a
site owned by the generator of the wastes.
On-site (EUB) The management of oilfield waste on the site on which
it was generated or on another site within the same production system,
provided that both sites have the same licensee or approval holder.
Personal Identification Numbers A registration number from AENV
required by anyone who consigns, transports, or receives hazardous
wastes.
Registered Landfill (AENV) An AENV-regulated class II or class III
landfill not located in a ravine, gully or coulee, or over a buried valley,
where not more than 10 000 tonnes per year of non-hazardous and inert
waste is disposed and its construction, operation, reclamation, and
registration are in compliance with the requirements specified in the
Code of Practice for Landfills.
Same Production System (EUB) An interconnected system of
upstream production facilities (e.g., wells, pipelines, batteries). An
oil/gas production site receiving oilfield wastes for on-site management
or storage must be within the same interconnected system of upstream
production facilities as the oil/gas production site from which the
oilfield wastes originated. Both the receiving and the originating site
must have the same licensee or approval holder.
ID 2000-4: An Update to the Requirements for the Appropriate Management of Oilfield Wastes
June 19, 2000
TO: All Oil and Gas Operators
All Oil Sands Operators
All Drilling and Servicing Operations
All Pipeline Operators
All Oilfield Waste Management Operators
The purpose of this interim directive is to communicate requirements
specific to the management of oilfield wastes. Some of the requirements
outlined here are a clarification or modification of the requirements
detailed in EUB Guide 58: Oilfield Waste Management Requirements
for the Upstream Petroleum Industry, while others are new. The Alberta
Energy and Utilities Board (EUB) believes that these requirements
complement EUB Interim Directive (ID) 2000-3: Harmonization of
Waste Management and its attached memorandum of understanding
(MOU) between the EUB and Alberta Environment (AENV).
To enhance protection of the environment and public safety and to
reduce liability through appropriate waste management, the EUB
requires oilfield waste generators to comply with all pertinent EUB
requirements as referenced in Appendix 1, as well as the following
additional requirements:
• It is prohibited, with the exception of construction and demolition
debris, garbage and domestic wastes, and scrap metal, to deposit
oilfield wastes into any registered landfill or any landfill currently
operating under an Alberta Public Health Permit that will qualify
for registration under the Code of Practice for Landfills pursuant
to the Environmental Protection and Enhancement Act (EPEA).
• Oilfield wastes, with the exception of suitable cellulose materials
(e.g., trees, and other vegetative material resulting from lease
construction, decontamination, or decommissioning), must not be
sent to compost facilities or managed by compost components at
waste management facilities, including AENV-regulated landfills.
• Oilfield wastes must not be sent to dedicated land treatment
facilities, with the exception of petroleum hydrocarbon-
contaminated soils that are suitable for biodegradation, as outlined
in Section 16.2 of EUB Guide 58.
• Dangerous oilfield wastes being sent off site for collection,
treatment, disposal, or recycling must only be sent to facilities
approved for the management of hazardous wastes, hazardous
recyclables, or dangerous oilfield wastes.
• Provided the above requirements are not contravened, oilfield
wastes may be sent to AENV regulated facilities. The oilfield
wastes must be
- similar in characteristics and source to other wastes
authorized by AENV,
- within all waste acceptance limitations specified by AENV,
and
- only managed by activities that AENV has authorized for the
facility.
50 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
• For liability management and to complement Alberta’s Expanded
Orphan Program, only wastes generated within the same
production system may be managed as one-time treatment or by an
on-site waste management component.
• Mobile treatment technologies (e.g., incinerators) may be used to
manage oilfield wastes on EUB- approved or licensed sites
provided that the technology is approved or registered, as required,
under EPEA and the notification requirements in Section 17.5 of
EUB Guide 58 are followed.
Refer to Appendix 2 for a list of definitions pertaining to waste
management.
Currently, Section 6.0, Alternative Disposal Options, of EUB Guide 50:
Drilling Waste Management, identifies that when drilling waste is
disposed at an approved waste management facility, the generator must
meet information requirements specific to the waste management
facility.
To ensure a consistent level of tracking for drilling wastes disposed in
this manner, effective July 1, 2000, the following additional
requirements will be applied:
• All drilling wastes sent to waste management facilities (EUB or
AENV regulated) shall be considered trackable oilfield wastes
under EUB Guide 58.
• The waste codes for drilling sumps (gel chem, hydrocarbon, and
KCL) in Table 7.4, Waste Management Table, of EUB Guide 58
shall be used to track the drilling wastes.
The EUB acknowledges that the publication of this interim directive, ID
2000-4, as well as other publications listed in Appendix 1 will
necessitate the review and update of EUB Guide 58. The EUB will
undertake the timely completion of this review.
Brian Bietz
Board Member
Alberta Energy and Utilities Board
Attachments
Appendix 1 EUB Legislation
The EUB regulates the management of oilfield wastes under the
authority of the Oil and Gas Conservation Act and the Oil and Gas
Conservation Regulation. The details regarding the management of
oilfield wastes at the generator’s facility site, the transportation of
oilfield wastes on Alberta’s public roads, and the treatment and disposal
of oilfield wastes at waste management facilities are outlined in the
following EUB documents:
• ID 96-3 and Guide 58: Oilfield Waste Management Requirements
for the Upstream Petroleum Industry
• IL 96-13 and Guide 50: Drilling Waste Management Facility (EUB)
• IL 94-2 and Guide 51: Injection and Disposal Wells, Well
Classifications, Logging, and Testing Requirements
• ID 95-3 and Guide 55: Storage Requirements for the Upstream
Petroleum Industry
• ID 99-4: Deposition of Oilfield Waste into Landfills
• IL 99-2: Use of Produced Sand in Road Construction
• IL 98-2: Suspension, Abandonment, Decontamination, and
Surface Land Reclamation of Upstream Oil and Gas Facilities
• IL 98-1: Coordination of Release Notification Requirements and
Subsequent Regulatory Response
• IL 99-4: EUB Enforcement Process, Generic Enforcement Ladder,
and Field Surveillance Enforcement Ladder (with Clarification
dated February 24, 2000)
Land Treatment
(AENV)
• Guide 36: Drilling Rig Inspection Manual
• Guide 37: Service Rig Inspection Manual
• Guide 63: Oilfield Waste Management Facility Inspection Manual Land Treatment
(in draft) (EUB)
• Guide 64: Facility Inspection Manual
Appendix 2 Definitions
Approved An AENV-regulated landfill that accepts more than Off-site (AENV)
Landfill 10 000 tonnes of wastes per year, that accepts
hazardous wastes, or that is located in a ravine,
gully or coulee, or over a buried valley and is Oilfield Waste
approved under the Environmental Protection and
Enhancement Act.
Biodegradation A type of oilfield waste management facility where
Facility (EUB) oilfield wastes are biologically degraded in a
contained and controlled environment, whether it is
in an impermeable cell structure (biocell) or piled
on a impermeable liner (biopile). (Does not include
land treatment.) On-site (AENV)
Compost (AENV) The stable humus-like material that results from the
biological decomposition and stabilization of On-site (EUB)
organic materials under aerobic and thermophilic
conditions. It is potentially beneficial to plant
growth and is sanitized to a degree that protects
human health.
Personal
Compost Facility A waste management facility where waste, not Identification
(AENV) including hazardous waste, is decomposed through Numbers
a controlled bio-oxidation process that results in a
stable humus-like material but does not include a Registered
residential composter or a compost facility that Landfill (AENV)
receives only sludge as defined in the Wastewater
and Storm Drainage Regulation.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 51
Any building, structure, installation, equipment, or
appurtenance over which the Board has jurisdiction
and that is connected to or associated with the
recovery, development, production, handling,
processing, treatment, or disposal of hydrocarbon-
based resources or any associated substances or
wastes, and includes, without limitation, a battery, a
processing plant, a gas plant, an oilfield waste
management facility, a central processing facility as
defined in the Oil Sands Conservation Regulation
(AR 76/88), a compressor, a dehydrator, a
separator, a treater, a custom treating plant, a
produced water-injection plant, a produced water
disposal plant, a miscible flood injection plant, a
satellite, or any combination of them, but does not
include a well, a pipeline as defined in the Pipeline
Act, a mine site or processing plant as defined in the
Oil Sands Conservation Regulation (AR 76/88), or
a mine site or coal processing plant as defined in the
Coal Conservation Act.
The controlled application of a substance on the soil
surface and incorporation of the substance into the
upper soil zone in such a manner that physical,
chemical, or biological degradation of the substance
takes place. (Dedicated facilities allowed.)
A planned and controlled mixing of oilfield wastes
and soil surface in which the inherent soil processes
are used to biodegrade, transform, and assimilate
the waste constituents. (Limited to one-time, on-site
application of non-refined hydrocarbon
contaminated soil or pit/pond sludge.)
An independent site established to manage third-
party wastes.
An unwanted substance or mixture of substances
that results from the construction, operation,
abandonment, or reclamation of a facility, well site,
or pipeline but does not include an unwanted
substance or mixture of substances from such a
source that is received for storage, treatment,
disposal, and/or recycling at a facility regulated by
Alberta Environment.
Management of a generator’s hazardous wastes at a
site owned by the generator of the wastes.
The management of oilfield waste on the site on
which it was generated or on another site within the
same production system, provided that both sites
have the same licensee or approval holder.
A registration number from AENV required
by anyone who consigns, transports, or receives
hazardous wastes or recyclables.
An AENV-regulated class II or class III landfill not
located in a ravine, gully or coulee, or over a buried
valley, where not more than 10 000 tonnes per year
of non-hazardous and inert waste is disposed and its
construction, operation, reclamation, and
 registration are in compliance with the requirements
specified in the Code of Practice for Landfills.
Same Production An interconnected system of upstream production
System (EUB) facilities (e.g., wells, pipelines, batteries). An
oil/gas production site receiving oilfield wastes for
on-site management or storage must be within the
same interconnected system of upstream production
facilities as the oil/gas production site from which
the oilfield wastes originated. Both the receiving
and the originating site must have the same licensee
or approval holder.

52 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
ID 2000-7: Licence Eligibility and Qualifications for Potential Licensees and Agents
September 21, 2000
TO: All Oil, Gas, Oil Sands, and Pipeline Operators
LICENCE ELIGIBILITY AND QUALIFICATIONS FOR POTENTIAL
LICENSEES AND AGENTS
As provided for in recent amendments to the Oil and Gas Conservation
Act and the Pipeline Act, this interim directive (ID) introduces the
requirement for a potential licensee to apply for and obtain an
appropriate identification code prior to making any application to
acquire an Alberta Energy and Utilities Board (EUB) licence.1
The EUB is implementing an enhanced process to qualify applicants to
be eligible to obtain EUB well, pipeline, and/or facility licences. The
requirements and procedures contained within this ID and Guide 67:
Identification Code and Agent Registration—Application Guide for
Potential Licensees replace the requirements for qualifying as a first-
time licensee contained in ID 93-2: Requirements for the Issuance of a
Well Licence or Approval of Well Licence Transfers. They also
supersede and replace the requirements set out in Informational Letter
(IL) 95-2: Agent Appointments and IL 94-9: Licence Criteria for Front
Companies.
This ID is part of an EUB regulatory program being implemented to
support the expanded Orphan Program announced in General Bulletin
2000-17: Expanded Orphan Program Implementation.
The requirements of this ID are effective immediately.
EUB identification codes (formerly referred to as company or operator
codes) will now incorporate a licence eligibility attribute. This attribute
will identify whether the holder of an EUB identification code is eligible
to acquire licences and the nature and extent of licences that can be
acquired. The licensee eligibility attribute will be assigned by the EUB and
is for internal administrative purposes only. New and existing holders of
EUB identification codes do not need to attach this attribute to their code
in any dealings with the EUB.
The EUB will assign a licence eligibility attribute based on the categories
in Table 1.
Existing Company/Operator Codes
As provided for in Section 15.1(6) of the Oil and Gas Conservation Act,
an existing EUB company/operator code is deemed to be an
identification code. The code currently assigned to an individual or
company by the EUB will not be changed. The EUB will, however,
associate a licensee eligibility attribute with each identification code
holder to facilitate EUB administrative processes. Any terms or
conditions attached to an existing company/operator code will apply to
the new identification code.
1
The Oil and Gas Conservation Act and the Pipeline Act were amended by Bill
13, which was proclaimed in force on June 30, 2000. References to these two acts
are references to the acts as amended by Bill 13.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000) • 53
Table 1. Licence eligibility attributes
Attribute Description Licence eligibility
01 None Ineligible to acquire or hold any licence, but
valid for administrative purposes
02 Any Eligible to acquire or hold any type of
licence, well pipeline, or facility
03 Farm gas/water well Eligible to hold only a farm gas well licence
acquired prior to July 1, 1996, and/or a farm
water well licence
04 Domestic gas well Eligible to hold only a domestic gas well
licence acquired after July 1, 1996
05 Mineral exploration Eligible to hold only a mineral exploration
well well licence
A holder of an existing company/operator code is not required to take
any action to convert it to an identification code. Holders of
identification codes will continue to use only their four-character code
for all interactions with the EUB.
On September 22, 2000, the EUB will publish a list of all active
identification codes and their respective licence eligibility attributes on
the EUB’s Web site.2 Holders of identification codes are encouraged to
check this list to ensure that the licence eligibility attribute assigned by
the EUB correctly reflects their licence holding requirements.
New Identification Codes for Administrative Purposes
An individual or company that interacts with the EUB for
administrative and reporting purposes (e.g., service companies,
consultants, and gas exporters) can acquire an identification code by
contacting the Corporate Compliance Group at (403) 297-8320. A
holder of this type of identification code is restricted from subsequently
acquiring well, facility, and/or pipeline licences without further
qualification and approval of an amended licensee eligibility attribute.
New Identification Codes for Licence-Holding Purposes
An individual or company that wishes to acquire a well, facility, and/or
pipeline licence and that does not already hold an EUB identification
code must apply for an EUB identification code. An application for an
EUB identification code must be submitted in accordance with Guide
67. EUB approval of an identification code that allows acquisition of
the required licence type must be obtained before an applicant can
acquire well, facility, or pipeline licences through application for a new
licence or transfer of an existing licence.
Amending an Existing Identification Code
An individual or company whose identification code does not allow the
acquisition of a required licence type must apply to have its licence
eligibility attribute changed to a category that does allow acquisition of
the required licence type. An application to amend the licence eligibility
attribute of an existing identification code must be submitted in
accordance with Guide 67. An applicant must have an approved EUB
identification code that allows acquisition of the required licence type
before an application to acquire a licence of that type will be
considered.
2
http://www.eub.gov.ab.ca
Qualifications to Obtain an Identification Code
For Administrative Purposes: Individuals or companies requiring an
EUB identification code for administrative purposes are required to
provide their full legal name, a mailing address, and a business
telephone number. Gas exporters requiring an EUB identification code
are required to be an Alberta registered corporation.
For Licence-Holding Purposes: As provided for in Section 15.1 of the
Oil and Gas Conservation Act, an application for an identification code
must
• be made in a form and manner,
• contain the information required, and
• be accompanied by the fee prescribed by the regulations.
The following requirements of this ID apply until such time as these
requirements have been incorporated into the appropriate sections of the
Oil and Gas Conservation Regulations.
The eligibility requirements are as follows:
• If a corporation, the applicant must be
a) registered, with an active status, under the Business
Corporation Act;
b) incorporated by or under an act of the Legislature other than
the Business Corporations Act and approved by the EUB as a
corporation that may acquire or hold a licence;
c) incorporated under the Bank Act (Canada);
d) a railway company incorporated under an act of the
Parliament of Canada;
e) registered under the Loan and Trust Corporations Act; or
f) an insurance company licensed under the Insurance Act.
• The applicant must be a resident of the province of Alberta or must
appoint an agent within Alberta in accordance with Section 83 of
the Oil and Gas Conservation Act and Section 25 of the Pipeline
Act. For these purposes, “resident” means
a) in the case of a corporation, a corporation that has a corporate
presence in Alberta and an established corporate office in
Alberta with a functional address, carries on business and
performs duties on a daily basis, and has staff who can
perform and are authorized to carry out all obligations and
duties of a licensee, and
54 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 3 (October 2000)
b) in the case of an individual, an individual who has an
established residence in Alberta with a functional address and
who can perform all obligations and duties of a licensee.
• The applicant must have reasonable and appropriate insurance
coverage and submit either a certificate of proof of insurance or a
statement of the insurer describing the coverage and the effective
date of the insurance.
• The applicant must submit the corporate profile information
specified in Guide 67 and sign the declaration on the EUB
identification code application form.
• The applicant must pay a $10 000 fee as per Section 17.010(1.1) of
the Oil and Gas Conservation Regulations unless it is waived by
the EUB upon application.
A limited partnership may not hold an identification code that allows
the acquisition of licences. In addition, a front company, created to
provide anonymity to another company by acquiring licences in the
front company’s name, must meet all requirements and acquire an
identification code that permits the holding of EUB licences.
Approval of Identification Codes
As provided for in Section 15.1 of the Oil and Gas Conservation Act, the
EUB may issue an identification code subject to any terms or conditions
it considers appropriate. As well, Section 15.2 of the Oil and Gas
Conservation Act allows the EUB to impose any terms or conditions it
considers appropriate on the holder of the identification code or on any
licence or approval issued to the holder of an identification code. The EUB
may refuse to consider an application for an identification code made by
an applicant affected by a declaration issued by the EUB pursuant to
Section 95.1(1) of the Oil and Gas Conservation Act.
Agents
Information on the requirements for becoming an agent, appointing an
agent, and obtaining EUB approval of an agency appointment are
contained in Guide 67.
Questions regarding this interim directive should be directed to the
Corporate Compliance Group at either (403) 297-8320 or (403) 297-
8448.
J. D. Dilay, P.Eng.
Board Member
APPENDIX 4—EUB INFORMATIONAL LETTERS
IL 82-11: Preservation of Archaeological, Palaeontological, and Historical Resources: Policy
Update
5 March 1982
TO: All Oil, Gas, and Oil Sands Operators
PRESERVATION OF ARCHAEOLOGICAL,
PALAEONTOLOGICAL, AND HISTORICAL RESOURCES:
POLICY UPDATE
This informational letter supersedes Information Letter 79-18 and
Interim Directive ID -G 77-1
The Energy Resources Conservation Board hereby updates the winter
construction policy of Alberta Culture and consolidates its policy on
archaeological, palaeontological, and historical resources.
Conditions to be Met
In order to assist implementation of Alberta’s Historical Resources Act,
the Board now requires as follows:
1 When requested by the Board, developers making application for
permits, licences, or approvals for major projects under statutes
and regulations administered by the Board shall include as part of
their application the results of an inspection of archaeological,
palaeontological, and historical resource sites that might be
disturbed by the proposed development. To avoid delays in the
processing of an application, the applicant may therefore wish to
consult with the Board during early planning stages, to confirm the
necessity for such an inspection.
Should an historical-resource assessment be deemed necessary,
take note of the policy statement regarding winter construction,
dated June 1981 and attached to this informational letter.
Companies contemplating major developments during the winter
would be well advised to determine the need for these assessments
at such time as to allow the investigation of the project area during
that time of the year best suited to the gathering of information
required for a complete assessment.
To assist developers, a set of guidelines entitled “Interim Guidelines:
Historical Resource Impact Assessments” and a provincial map entitled
“The Archaeological Resources Sensitivity Map” may be obtained
through:
The Archaeological Survey of Alberta
Old St. Stephen’s College
8820 - 112 Street
Edmonton, Alberta
T6G 2J6
or
The Energy Resources Conservation Board
Maps and Publications Desk
640 - Fifth Avenue S.W.
Calgary, Alberta
T2P 3G4
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 1
2 Any holder of a permit, licence, or approval who becomes aware of
an apparent archaeological, palaeontological, or historical site in
the course of his development work, shall immediately notify the
Board of the find and take steps to ensure that the site is preserved
until its significance can be assessed. To avoid undue delay of
development work the Board will arrange with the Historical
Resources Division of Alberta Culture to inspect such sites
brought to the Board’s attention. This inspection will take place
within three days of notice being received by the Board.
Notices under (2) and all inquiries in connection with archaeological,
palaeontological, and historical resources, should be directed to the
Manager of the Board’s Environment Protection Department (261-
8121).
Alberta CultureJune 1981
POLICY STATEMENT
HISTORICAL RESOURCES CONSERVATION WORK
CONDUCTED ON PROJECTS WITH A WINTER CONSTRUCTION
SCHEDULE
When historical resources conservation work is requested of proponents
for development projects having winter construction schedules, Alberta
Culture has, in the past, often encountered difficulty in meeting its
mandate as expressed in the Policy Statement: Historical Resources
Conservation Work Occasioned by Development Programmes (May 12,
1977).
Historical resources, consisting of archaeological, palaeontological,
historic, and some natural sites, are generally found as an integral
component of the ground surface and upper soil deposits.
Consequently, winter conditions, such as snow cover and frozen
ground, severely impede the successful survey and investigation of
these resources. In some instances it has been necessary to relax the
technical requirements usually demanded of Historical Resource Impact
Assessments on mitigative projects rather than delay significant and
costly development projects until winter conditions have abated.
Unfortunately, the relaxation of these technical requirements greatly
limits the successful assessment and mitigation of historical resource
sites that may be impacted by development, thereby reducing the
effectiveness of Alberta Culture in meetings its mandate as provided for
in the Alberta Historical Resources Act. This is not an acceptable
solution, and as a result it will henceforth be necessary for Alberta
Culture to require that the following policy be observed.
POLICY RESPONSIBILITIES
In order to ensure that historical resource assessments are conducted in
sufficient detail to satisfactorily provide the Minister with all
information relevant to the question of the probable impact of a specific
development proposal on historical resources, no special concessions
will be made relative to difficulties encountered in winter programmes
when assessing the results of the investigations necessitated by the
project. Consequently, all reports will be evaluated strictly in terms of
the content and quality of their results regardless of the season in which
the project is initiated, and developers are advised to schedule their
investigations for that time of year which will best enable their
investigators to obtain the information necessary to provide a complete
Historical Resources Impact Assessment.
Alberta CultureMay 12, 1977
POLICY STATEMENT
HISTORICAL RESOURCES CONSERVATION WORK
OCCASIONED BY DEVELOPMENT PROGRAMS
One of the greatest strengths of any people is their appreciation of their
common past. The ability to identify with a shared history results in the
development of a bond amongst individuals and groups which
frequently transcends all other affiliations, and gives those
acknowledging this bond an identity marking them as unique in the
world. For a nation, or a part of a nation, it is a priceless asset.
Until quite recently in Alberta a truly common sense of provincial
identity was absent. Historical affiliations generally centred on other
parts of the work or on local communities, for the population was
basically composed of arrivals only one or two regional generations
removed from a distant homeland, or native people with very strong
ties. In keeping with this pattern, traditional values and practices were
also transplanted or reinforced, resulting in the rich and diverse ethnic
communities which characterize this province. These communities, and
the affiliations they have created, continue to thrive today as testaments
to the importance of a historical sense of belonging.
While the historic ethnic groups continue to flourish within Alberta,
there has in recent years been an ever growing awareness that in
addition to their ethnic affiliations, individual Albertans are participants
in another historical tradition, that of the Province itself. This tradition,
which is equally rich in both natural and human elements, has a strength
and character of its own which identifies Albertans as having a world
image all their own. It reflects contributions not only from the ethnic
background of settlers and their descendants, but also from the Native
inhabitants and the elements of nature which constitute the framework
for the provincial pageant. Thus dinosaur fossils, buffalo jumps, fur
trading posts and early homesteads all play a part in Alberta’s historical
tradition.
Appreciation of their common past is today becoming ever more
apparent among Alberta’s citizens, and they are asserting increasing
pressure to have this historical tradition investigated, documented and
presented in public displays and publication. Unfortunately, however,
the realities of modern life are such that major elements of this shared
identity are in grave danger of being lost before they can be properly
integrated into the structure of our historical traditions.
While some facets of real significance to the early history of Alberta
still survive, many of the physical vestiges of this history exist only as
palaeontological, prehistoric or historic sites. At the same time, because
these sites exist on or near the surface of the ground they are very
susceptible to damage or destruction through land surface
modifications. In an era of rapid and major land development associated
with such things as resource extraction, recreation, transportation and
urbanization, a substantial number of Alberta’s prehistoric and historic
sites and structures have been and will continue to be destroyed before
their significance can be properly established and documented. The
irony of this situation is that although the evolution of Alberta’s
character as a Province has finally reached the stage where citizens are
actively seeking identity with a common past, the evidence testifying to
this common past is now being destroyed by development at a rate far
in excess of anything seen in previous years.
2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
In recognition of this situation, the Alberta Provincial Government
enacted the Alberta Historical Resources Act. Among other things the
Act provides the Minister responsible for Culture with the authority to
require developers to prepare assessments of the effect of their proposed
developments on historical resources and to undertake such studies or
modification to the development plan as may be necessary to retain
important historical resource values. It is the intention of this
Department to make use of this opportunity to maximize the retention
of important historical resource sites, specimens and information for the
benefit of all Albertans, both those now living and those yet to be born.
POLICY OBJECTIVES
1. To avoid unnecessary impact on all historical resource sites.
2. To preserve the most important historical resource sites wherever
technically and economically feasible.
3. To promote the recovery of information and specimens of value
from those historical resource sites which cannot be preserved.
In order to meet the above Policy Objectives, the following shall be
considered to be the allocation of responsibilities:
POLICY RESPONSIBILITIES
1. The developer shall be responsible for the conduct of sufficiently
detailed studies in the planning stage to enable the preparation of
an historical resource impact assessment report, and for the
production of such a report.
2. The Historical Resources Division of Alberta Culture will be
responsible for the technical and professional review of historical
resource impact assessments and the preparation of review
statements concurring with, rejecting or requesting a modification
of such recommendations relative to historical resource sites as
cannot be avoided by the development because of technical or
economic limitations.
3. The developer is responsible for the conduct of all mitigative
measures deemed appropriate at historical resource sites which
cannot be avoided by the development because of technical or
economic limitations.
4. Where the Historical Resources Division and the developer cannot
agree on appropriate mitigative measures (as above), the Minister
of Culture will be responsible for the final decision as to
appropriate mitigative measures to be undertaken in situations
where historical resource sites cannot be avoided by a development
because of technical or economic limitations.
5. The responsibilities of the developer will be the same for both
government and private agencies..
In order to meet the respective Policy Responsibilities, the following
shall be considered to be the normal procedures for implementation:
Policy Implementation
1. At the planning stage of any major development; and well prior to
the commencement of any ground surface disturbance, an
inventory of the historical resources to be affected by the
development will be prepared by the developer utilizing
information obtained from archival sources when available and
field reconnaissance when necessary.
2. On the basis of this inventory the developer will prepare an
historical resources impact assessment report which details the
nature and location of each historical resource site, the postulated
 effect of the development on each historical resource site, and the
proposed mitigative measures to be undertaken by the proponent to
minimize the loss of historical resources relative to each site that
cannot be avoided by the development because of technical and/or
4.
economic limitations.
3. The historical resources impact assessment report will be reviewed
by the Historical Resources Division, Alberta Culture, prior to the
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 3
commencement of land surface disturbance by the development,
which will accept, reject or request modifications to the report and
its recommendations as appropriate.
The development will be permitted to proceed in accordance with
the recommendations of an acceptable historical resource impact
assessment report, provided such mitigative measures as are
deemed necessary are carried out in advance of any possible
modification, damage or destruction of the said historical
resources.
IL 84-11: Approval, Monitoring, and Control of Sulphur Storage Sites
29 October 1984
TO: All Oil, Gas, Oil Sands, and Gas Plant Operators
APPROVAL, MONITORING, AND CONTROL OF
SULPHUR STORAGE SITES
Alberta Environment (AE), Alberta Energy and Natural Resources
(ENR), and the Energy Resources Conservation Board (ERCB) have
reviewed the existing approval system and inspection procedures for
sulphur handling facilities. This Informational Letter summarizes the
responsibilities of each agency and the current guidelines for installing
and operating sulphur handling facilities.
I New Facilities
Applications for new or modified primary sulphur handling facilities1
associated with sour gas plants are to be sent to the Gas Department of
the ERCB. Applications for new or modified primary sulphur handling
facilities associated with primary crude bitumen upgrading plants are to
be sent to the Oil Sands Department of the ERCB. Primary sulphur
handling facilities have been and will continue to be approved as part of
an application for a gas processing scheme pursuant to the Oil and Gas
Conservation Regulations or an oil sands processing plant pursuant to
the Oil Sands Conservation Act. It is intended that distinct approvals or
licences would not be issued for these facilities.
Approvals and regulation of secondary sulphur handling facilities are
the sole responsibility of AE. Applications for new or modified
secondary sulphur handling facilities are to be sent to the Standards and
Approvals Division of AE.
It is expected that operators will select sites for primary and secondary
sulphur handling facilities and design and operate such facilities in a
manner that minimizes environmental impact on the surrounding area.
Particular emphasis is to be placed on minimizing sulphur dust
emissions, minimizing the release of entrained gases, and preventing
releases of contaminated waters to surface or ground-water systems.
II Modification of Existing Facilities or Operations
Primary sulphur handling facility operators who are contemplating
major changes in mode of operation are to notify either the Oil Sands or
Gas Department of the ERCB (whichever is appropriate) in advance,
outlining the changes in operations and addressing action that will be
taken to minimize the potential for environmental impacts. The ERCB
will then refer this notice to the appropriate divisions within AE or
ENR. A major change in mode of operation would include, but is not
limited to:
(i) commencement of sulphur block recovery by any method,
(ii) development of a new block or stockpile,
(iii) installing new or additional prilling, slating, or forming
facilities,
(iv) recovery of contaminated sulphur or sulphur base pad, and.
1
This and other terms are defined in Section V.
(v) final clean-up of sulphur product.
4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
Notification of changes to mode of operations at a secondary sulphur
handling facility are to be made to the Standards and Approvals
Division of AE.
III Facility Operation Responsibility
The operator of a primary sulphur production facility will be deemed
responsible for clean-up, reclamation, and rehabilitation of the primary
sulphur handling facilities site and any off-site rehabilitation effort
required as a result of the operation of the primary sulphur handling
facilities, regardless of ownership of the sulphur being handled or
stored. The operator of a primary sulphur handling facility shall be the
company recognized by the ERCB in its respective approvals, and in
the case of public lands, includes the lessee as defined in the Public
Lands Act.
IV Monitoring and Corrective Action
The ERCB is the primary contact for operations, inspection, and
corrective action at the site of primary sulphur handling facilities.
Where off-site monitoring by the operator, AE, or ENR indicates
undesirable environmental impacts are occurring, the ERCB will be the
contact agency respecting initiation and inter-agency co-ordination of
corrective action.
AE is the primary contact and co-ordinating agency for operations,
inspection, and corrective action at the site of secondary sulphur
handling facilities.
Specific off-site air, water, and soil monitoring requirements are a direct
responsibility of AE. In addition, the following on-site matters should
be dealt with directly between operators of primary sulphur handling
facilities and AE:
(i) all systems that discharge liquid waste off-site to surface,
(ii) ground-water systems, and
(iii) site decontamination and reclamation.
ENR manages the publicly-owned resources of timber, public land, fish,
and wildlife in Alberta. In addition to approving surface uses of public
lands, ENR will become involved through the respective lead agency
for sulphur handling facilities in any matters that have or may impact
these resources, including problem identification.
V Definitions
For the purpose of this Informational Letter:
(a) sulphur production facility means any facility producing sulphur at
a sour gas plant or a crude bitumen upgrading plant,
(b) primary sulphur handling facility means any location, structure, or
equipment which is associated directly with and proximal to a
sulphur production facility and which handles, stores, forms,
remelts, or loads sulphur, and
(c) secondary sulphur handling facility means any location, structure,
or equipment which receives sulphur from a sulphur production
facility or from a primary sulphur handling facility for the purposes
of handling, storing, forming, remelting, or loading sulphur and is
located a significant distance from the facility from which it
receives its sulphur or operates by virtue of an approval
independent of the sulphur production facility.
IL 87-1: Compressibility Factors Used in Gas Volume Calculations and Physical Property Data for
Natural Gases
7 April 1987
TO: All Oil and Gas Operators and Chemical Laboratories
COMPRESSIBILITY FACTORS USED IN GAS VOLUME
CALCULATIONS AND PHYSICAL PROPERTY DATA FOR
NATURAL GASES
This Informational Letter addresses two related topics. Part 1 deals with
acceptable methods of calculating compressibility factors for natural gas
used in computing gas volumes; Part 2 deals with data for the physical
properties of natural gases.
1. CALCULATION OF COMPRESSIBILITY FACTORS
(SUPERCOMPRESSIBILITY)
Produced or injected gas volumes reported to the Board that are
measured by an orifice meter or other metering device must be
corrected for pressure, temperature, gas density, and the compressibility
of the natural gas. These corrections are to be made in accordance with
ANSI/API Standard 2530 (formerly referred to as AGA Report No. 3)1,
as required by section 14.070(8) of the Oil and Gas Conservation
Regulations. This standard was revised and updated in 1985. The most
significant change was in the use of a more accurate absolute
temperature conversion of 459.67°R instead of 460°R. In 1986, a new
method of calculating the compressibility factor for sweet, dry natural
gas was adopted. This method, described in AGA Report No. 82,
replaces the NX-193 method that was formerly a part of the ANSI/API
2530 Standard.
Since the Board adopts the ANSI/API 2530 Standard, it requests
operators who are currently using the NX-l9 Method to change to the
new AGA No. 8 Method, or to one of the other acceptable methods
outlined later in this Informational Letter. Operators who are already
using one of these other acceptable calculation methods may continue
to do so without change.
The AGA No. 8 publication includes several approaches for estimating
the properties of natural gas for use in the AGA No. 8 calculation. The
full compositional analysis method should be used rather than the less
accurate partial composition methods given in that publication. Also
note that base conditions used in the calculation of Zb (compressibility
at base conditions) should be the standard metric base conditions of
101.325 kPa (14.696 psi) and 15°C (59°F) and not 14.73 psi and 60°F
as given in AGA No. 8.
The AGA No. 8 Method is currently limited to gases having less than a
1 per cent concentration of a total of H2S plus water plus other diluents
(He, Ar, CO). Work is continuing on AGA No. 8 to adapt it to higher
concentrations of these diluents.
For gases with compositions outside the range of AGA No. 8, a number
of alternate methods exist for calculating compressibilities. These
methods are applicable to a much wider range of gas compositions and
include the sweet, dry natural gases where AGA No. 8 is recommended.
For these sweet, dry natural gases, the AGA No. 8 Method does offer
increased accuracy. However, rather than requiring operators to use
AGA No. 8 for sweet gases and some alternate method for sour gases,
the Board will accept any of the following calculation methods for the
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 5
entire range of natural gas compositions normally experienced from
producing reservoirs in Alberta.
• Pitzer et al4 with Wichert-Aziz5 sour gas corrections
• Redlich-Kwong6,5 with Wichert-Aziz5 sour gas corrections
• Dranchuk, Purvis, Robinson7 with Wichert-Aziz sour gas corrections
• Dranchuk, Abou-Kassam8 with Wichert-Aziz sour gas corrections
• Hall, Yarborough9,l0 with Wichert-Aziz sour gas corrections
• Standing-Katz11,14 charts with Wichert-Aziz sour gas corrections
With the exception of the last method, which is graphical in nature, all
of these procedures are applicable to the computer. As the availability
of adequate computing power and memory is no longer the problem it
once was, it is expected that the compressibility factor will be calculated
at least once for each gas chart. Flow computers and other automated
measurement systems used for gas measurement should calculate and
update the compressibility factor at frequent intervals. These intervals
will be set according to variations in the operating conditions of
pressure and temperature and will be reviewed when the automated
measurement system is approved.
As a general reference, Wichert5,l2 and Takacsl3 provide comparisons of
methods of calculating compressibility and evaluate each for its
applicability to the computer.
The Board will consider applications to use methods of calculating gas
compressibility other than the ones mentioned above. A suitable
reference and comparisons to one of the above approved methods, or to
experimental results, should be provided to support any proposed
alternative method.
It is expected that all gas flow calculations will be made using the latest
edition of ANSI/API 2530 with compressibilities calculated by one of
the accepted methods. These changes must be implemented by 1
October 1987. After this date, calculations made using the NX-l9
Method will not be accepted. We believe that this deadline will provide
industry with sufficient time to make the necessary adjustments.
Any questions with regard to the calculation of gas flows and
compressibility may be directed to the Development Department at 297-
8321.
2 PHYSICAL PROPERTIES OF NATURAL GAS COMPONENTS
The Board is aware that some companies are using, either directly or in
computer routines, an out-of-date list of physical properties for natural
gas components titled “Standard Values for Gas Analysis Calculations”.
This list was issued by the Board in or about 1973. The Board currently
adopts the physical properties contained in the most recent edition of
the Gas Processors Suppliers Association (GPSA) SI Engineering Data
Bookl4. Please investigate to see if you are making use of the out-of-
date list and, if necessary, update your data. While the use of the out-of-
date physical property values is not likely to have caused significant
errors, the GPSA SI values should be used for all future calculations.
REFERENCES
1. American National Standards Institute/American Petroleum
Institute. 2530, 1985. “Orifice Metering of Natural Gas” .
2. American Gas Association Transmission Measurement Committee
Report No. 8, 1986. “Compressibility and Supercompressibility for
Natural Gas and Other Hydrocarbon Gases”.
3. American Gas Association Par Research Project NX-l9, 1962.
“Manual for the Determination of Supercompressibility Factors for
Natural Gas”.
4. Pitzer, K.S., Lippman, D.Z., Curl, R.F., Huggins, C.M., and
Petersen, D.E., “The Volumetric and Thermodynamic Properties of
Fluids II. Compressibility Factor, Vapour Pressure and Entropy of
Vapourization”. Journal of A.C.S., Vol. 77, No. 13, July 1955.
5. Wichert, E., and Aziz, K., “Calculate Z’s for Sour Gases”,
Hydrocarbon Processing, Vol. 51, May 1972, pp 119-122.
6. Redlich, 0., and Kwong, J. N.S., “On the Thermodynamics of
Solutions. V An Equation of State. Fugacities of Gaseous
Solutions”, Chem. Rev. 44, 1949, pp 233-244.
7. Dranchuk, P.M., Purvis, R.A., Robinson, D.B., “Computer
Calculation of Natural Gas Compressibility Factors Using the
Standing and Katz Correlation”. Institute of Petroleum Technical
Series No. 1, IP 74-008, 1974.
6 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
8. Dranchuk, P.M., Abou-Kassam, J.H., “Calculation of Z Factors for
Natural Gases Using Equations of State”. The Journal of Can. Pet.
Technology, Vol. 14, No. 3, July-Sept. 1975, pp 34-36.
9. Hall, K.R., and Yarborough, L., “A New Equation of State for Z
Factor Calculations”. The Oil and Gas Journal, June 18, 1973, pp
82-92.
10. Yarborough, L., and Hall, K.R., “How to Solve Equation of State
for Z-Factors”. The Oil and Gas Journal, February 18, 1974, pp
86-88.
11. Standing, M.B., and Katz, D.L., “Density of Natural Gases”.
Petroleum Transactions AIME, Vol. 146, 1942, p 140.
12. Wichert, E., “Z Factor Calculation for Sour Gases”, presented at
P.I.T.S. Seminar, October 8-9, 1986.
13. Takacs, G., “Comparisons Made for Computer Z-Factor
Calculations”. The Oil and Gas Journal, December 20, 1976, pp
64-66.
14. Gas Processors Suppliers Association, 1980. “SI Engineering Data
Book”. (Note: A new edition of the GPSA Data Book is to be
published in 1987.).
IL 87-8: Emergency Response Plans for Sour Gas Facilities
16 July l987
TO: All Operators of Sour Gas Wells, Plants, and Pipelines
EMERGENCY RESPONSE PLANS FOR SOUR GAS
FACILITIES
Sections 7.060 and 9.060 of the Oil and Gas Conservation Regulations
and section 65 of the Pipeline Regulations set out emergency
procedures requirements for sour gas processing plants, wells, and
pipelines. The primary purpose of these procedures is to ensure public
safety.
In this regard, the Board notes that the Canadian Petroleum Association
has recently released a document dated April 1987 entitled “Guidelines
for Preparation of Sour Gas Emergency Response Plans for Sour Gas
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 7
and Oil Facilities”, copies of which may be obtained from the
Association’s offices.
These Guidelines have been reviewed by the Board and found to be an
acceptable standard, under normal circumstances, for the preparation
and maintenance of emergency response plans. Therefore, the Board
encourages all operators to use these Guidelines in the preparation of
emergency response plans for new facilities. However, operators should
bear in mind when preparing plans in accordance with these Guidelines
that the Board may require more stringent or additional features to any
proposed plan or may otherwise vary features of the Guidelines
depending upon specific circumstances. The Board also encourages
operators to refer to the CPA Guidelines when preparing annual updates
of existing plans.
IL 88-5: Application for Approval of Natural-Gas-Driven Compressors
9 May 1988
TO: All Oil, Gas, and Pipeline Operators
This informational letter supersedes Informational Letter IL 80-30
issued on 22 December 1980 and subsequently amended on 21
November 1984.
Alberta Environment and the ERCB, with assistance from the Alberta
Petroleum Industry-Government Environmental Committee, have
completed a review of Alberta’s oxides of nitrogen (NOX) emission
requirement for compression facilities. As a result of this review, a
number of changes were made to the design requirements for
compressor stations and to the application procedures for obtaining
approval to construct and operate these facilities. This informational
letter describes
(1) the revised application procedures for approval of compression
facilities including application requirements and changes to the
method of designing engine exhaust stacks, and
(2) the requirements for the use of low NOX emission engines.
There were several reasons for initiating the review:
• To establish an application procedure that is easier to understand and
administer than the previous ones.
• To update the exhaust stack design method including use of a new,
recently developed dispersion model which better reflects the results
of field studies involving actual measurements. The result is stack
design parameters that are less conservative and more valid than
those applicable using the older design model.
• To focus on the objective of minimizing overall provincial NOX
emissions over the longer term by control at the source.
• To recognize NOX control practices for compression facilities in
other jurisdictions and NOX control practices in other industries such
as transportation and power generation.
1 APPLICATION PROCEDURES
Unless exempt from the requirement to obtain a Clean Air Permit and
Licence as discussed in Sections 1.3.1 and 3 of this letter, an
application under the Clean Air Act must be filed for each new or
expanding compression facility. Such applications are submitted along
with the ERCB application and must include exhaust stack height
calculations using the SEEC1 dispersion model and the information
noted in Section 1.2 of this letter.
For administrative purposes, applications for compressors are divided
into three categories; gas plant compressors, field compressor stations
and battery compressors, and transmission system compressors. Each
type of application is processed by a different Board department.
1 Copies of the SEEC model and related documentation are available
through the Standards and Approvals Division of Alberta
Environment.
1.1 Compressor Application Requirements
(a) Gas Plant Compressors
8 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
A gas plant compressor is part of a gas processing plant as defined in
section 1(1)(q.1) of the Oil and Gas Conservation Act and requires
approval under section 26 of the Oil and Gas Conservation Act.
Applications for approval of gas plant compressors, either at a new gas
processing plant or for additional compression facilities at an existing
gas processing plant, are to be submitted to the ERCB’s Gas
Department and must address the requirements of section 15.050 of the
Oil and Gas Conservation Regulations. When appropriate, a copy of the
application will be forwarded by the ERCB to Alberta Environment for
review and approval under the Clean Air Act.
(b) Field Compressor Stations and Battery Compressors
Field compressor stations and battery compressors are used for the
purpose of delivering gas from one or more wells to a gas plant, to a
pipeline, or for a downhole injection. Field compressor stations as
defined in section 1.020(2)4.1 of the Oil and Gas Conservation
Regulations, and battery compressors which are included in the
definition of a battery given in section 1(1)(b) of the Oil and Gas
Conservation Act, require approval under section 7.001 of the Oil and
Gas Conservation Regulations.
Applications for approval of field compressor stations and battery
compressors are to be submitted to the ERCB’s Drilling and Production
Department using the “Production Facility Application” form, parts 1
and 2, as outlined in the ERCB Guide G-35 2. When appropriate, a
copy of the application will be forwarded by the ERCB to Alberta
Environment for review and approval under the Clean Air Act. Guide
G-35 explains the requirements for completing the application forms
and the information to be included with an application. The forms and
the guide are available from the ERCB’s Maps and Publications
Counter located on the ground floor of the Energy Resources Building.
(c) Transmission System Compressors
This group includes all compressors that are downstream of gas
processing plants and that are located on transmission or utility system
pipelines. These compression facilities require approval under Part 4 of
the Pipeline Act.
Applications for approval of these compression facilities are to be
submitted to the ERCB’s Pipeline Department and must address the
requirements of section 3 of the Pipeline Regulations. When
appropriate, a copy of the application will be forwarded by the ERCB to
Alberta Environment for review and approval under the Clean Air Act.
1.2 Clean Air Act Application Requirements
Unless exempt from the requirements to obtain a Clean Air Permit and
Licence, applications shall contain the following details for each
compression unit in addition to the requirements specified in the Oil
and Gas Conservation Regulations and the Pipeline Regulations:
2 ERCB Guide G-35. Guide for Completing a Production Facility
Application. March 1988.
• size of proposed compressor unit in kilowatts (kW),
• exhaust stack height in metres,
• exhaust stack diameter in metres,
• exhaust gas exit temperature in degrees Celsius,
• exhaust gas exit velocity in metres/second,
• NOX emission rate in kilograms per hour (kg/h),
• width, length, and peak height of the compressor building in metres,
• distance from the compressor exhaust stacks to all facility boundary
fence lines in metres,
• distance between compressor exhaust stacks in metres (also should be
shown on the plot plan), and
• all of the above information for all existing compressor units if the
application is for additional compression.
1.3 Calculation of Minimum Exhaust Stack Height
1.3.1 Compression Facilities Exempted from Clean Air Act Permits
and Licences
Compression facilities that emit less than 16 kg/h of NOx are exempt
from the permit and licence requirements of the Clean Air Act. These
facilities include reciprocating engines, gas turbines, and any single- or
multiple-unit facility that meets the exemption criteria. Refer to Section
3.1 of this letter to determine eligibility for exemption.
The exhaust stack height for these exempt facilities may be determined
by using the lesser of 1.2 times the peak height of the compressor
building or the height as determined using the SEEC model. Should the
applicant wish to use the SEEC model for determining exhaust stack
height, the complete calculations, together with the information listed in
Section 1.2 of this letter, must be submitted as part of the application. In
no case should the exhaust stack height be less than the building peak
height.
1.3.2All Other New or Expanded Compression Facilities
The requirements of this section apply to both reciprocating engines and
gas turbines.
Stack heights for all other new or expanding compression facilities must
be sufficient to meet the maximum ground-level concentration (MGLC)
of 0.21 parts per million (ppm) of NO2 using the SEEC model and the
following:
• Ground-level rather than tree-top concentrations are to be calculated.
• Ground-level concentrations within the boundary (usually the fence)
of the facility are to be ignored.
• Any significant NOX emission sources within 0.5 kilometres must be
identified by the operator. If the source is licensed under the Clean
Air Act, its NOX emission must be included in the stack design
calculation for the applied-for compressor. If the source is not
licensed under the Clean Air Act, it shall be listed together with any
readily available information which would assist Alberta
Environment to expeditiously determine whether the unlicensed NOX
source would affect the stack design for the applied-for compressor.
• Standby equipment and emergency-only equipment are not included
in calculations but must be listed in the application. Standby
equipment and emergency-only equipment are defined in Section 3.1
of this letter.
• Emissions from heaters and boilers may be determined from the
manufacturer’s rating or the United States Environmental Protection
Agency rating factors and maximum heat inputs. Such emissions are
not included in the calculations if their combined contribution to the
total NOX emission is less than 3 per cent. However, they must be
listed in the application in any event.
• For reciprocating engines, the lower of either the engine
manufacturer’s maximum rated power or the rated power at 1000
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 9
revolutions per minute (rpm), corrected to site conditions, may be
used in calculations. For turbines, the manufacturer’s maximum site-
rated power should be used.
The exhaust stack height shall be determined using the following
method:
(a) Input a proposed stack height and values of the other parameters to
the SEEC model as described in Alberta Environment’s
publication “User’s Manual for Alberta Environment Dispersion
Models”.
(b) If the MGLC of NO2 exceeds 0.21 ppm, increase the proposed
stack height by small increments until the MGLC is less than or
equal to 0.21 ppm.
(c) In no case may the height of a new or modified stack be less than
the building peak height.
1.4 Liquid Waste Handling
Though an application for a Clean Water Act permit and licence will
not be required, compressor sites should be designed and constructed in
a manner that precludes the continuous discharge of process waste
waters and sanitary sewage to the environment within the vicinity of the
site. Storage tanks should be used to confine process waste waters, and
septic tank and tile-field installations must be used to confine and treat
sanitary wastes where necessary. In addition, the engine and compressor
lubricants and any chemicals shall be stored in suitable tankage and
disposed of in a manner satisfactory to the ERCB and Alberta
Environment.
1.5 Noise Guidelines
The ERCB has issued noise guidelines with which any new or expanded
facility must comply. If questions arise regarding noise guidelines,
applicants should consult with the ERCB’s Environment Protection
Department.
2 USE OF “LOW NOX” COMPRESSOR DRIVERS
2.1 New or Expanded Facilities
In order to achieve the longer term objective of controlling NOX
emissions at the source, effective June 1988, Alberta Environment
requires “low NOX” emission technology to be used at all new
compression facilities and at all expansions of existing compression
facilities when the unit size is greater than 600 kW. Alberta
Environment defines “low NOX” as any driver emitting less than 6
grams N0X/kW/h Any technology that is able to achieve this level or
lower is acceptable to Alberta Environment. However, using some
technologies such as catalytic converters or used engines rebuilt to the
low NOX criterion, will require proof that they can meet the low NOX
criterion. Such proof might include tests by the United States
Environmental Protection Agency or an independent laboratory, general
acceptance in other jurisdictions, or in the case of retrofitting used
drivers, certification by the applicant or the driver rebuilder that the
driver has been rebuilt to meet the low NOX criterion.
In order to allow operators to gain experience with low NOX emission
technology, there will be a 12-month phase-in period commencing June
1988 for all new compression facilities or expansion of existing
facilities where the unit size is greater than 600 kW but less than 900
kW. In other words, units between 600 kW and 900 kW will not be
required to satisfy the low NOX criterion until June 1989; units greater
than 900 kW applied for on or after June 1988 must satisfy the low
NOXx criterion. Should serious operating problems with low NOX
drivers be encountered during this phase-in period, the ERCB and
Alberta Environment may extend the phase-in period or modify the
requirements.
Relocating a used driver in the 600- to 2200-kW size range without
retrofitting to meet the low NOX criterion will be permitted only on an
individual, show-cause basis. Companies wishing to do so may submit
an application to the ERCB’s Gas Department, Drilling and Production
Department, or Pipeline Department, as appropriate, documenting the
impact that retrofitting the used driver to meet the low NOX criterion
would have on the economic viability of the overall project. Such
documentation should include an economic analysis comparing the two
cases and showing the assumptions and input data used. Other reasons
or information pertinent to the situation that may aid the Board in
reaching its decision should also be included. However, the principal
consideration will be the impact on the project viability. The Board will
review the application and the reasonableness of the economic analysis
having regard for the internal economic criteria that it uses, then render
its decision.
In order to retain flexibility in handling such applications and because
the criteria may change over time to reflect changing circumstances, the
Board does not believe it appropriate to publish its internal economic
criteria here. However, these criteria are consistent with other areas
such as gas conservation.
Replacement of an old unit with another used unit of the same size with
no increase in NOX emissions is exempt from the low NOX
requirement.
2.2 Existing Facilities
The term ”grandfathering” means to exempt from a new policy those
existing facilities which would otherwise contravene the policy. For
purposes of this letter, all facilities which have not increased NOX
emissions since December 1980 and which have a calculated MGLC of
NO2 greater than 0.21 ppm as determined by the SEEC model, will be
grandfathered except those currently under review by Alberta
Environment. Facilities will retain the grandfathered status as long as
there is no increase in the total NOX emissions nor in the calculated
MGLC of NO2. Facilities which have increased NOX emissions since
10 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
December 1980 either already meet the calculated MGLC of NO2 or
have already been contacted by Alberta Environment as part of the
special review.
3 CRITERIA FOR EXEMPTION FROM CLEAN AIR PERMIT
AND LICENCE REQUIREMENTS
3.1 Permanent Facilities
A compression facility, whether it be an existing, expanded, modified,
or new facility, is exempt from sections 3, 4, and 5 of the Clean Air Act
if its total NOX emissions are equal to or less than 16 kg/h.
To determine if a compression facility is exempt from licensing under
the Clean Air Act, estimate the total NOX emission (NO + NO2) using
one of the following:
• manufacturer’s NOX emission factors, or
• United States Environmental Protection Agency NOX emission
factors (“Compilation of Air Pollutant Emission Factors, Publication
AP-42 (1981)”).
For reciprocating engines, the lower of either the manufacturer’s
maximum engine power rating or the power rating at 1000 rpm,
corrected for site elevation, may be used to determine total NOX
emission. For turbines, the manufacturer’s maximum site-rated power
should be used. Corrections for site elevation must be documented in
the application.
Intermittent NOX emissions from standby equipment or equipment used
only for emergency purposes may be omitted from the NOX calculation.
Note that the standby or emergency equipment does not include
equipment idle as a result of over-design or temporary reductions in
throughput but refers to equipment used only as a temporary substitute
for a normally operating unit. NOX emissions from flare stacks and pits
may also be excluded.
Any subsequent expansion or modification to a compression facility
that results in the total NOX emissions exceeding 16 kg/h will render
the facility subject to the approval requirements of the Clean Air Act.
3.2 Temporary Facilities
All temporary facilities are exempt from sections 3, 4, and 5 of the
Clean Air Act. Temporary facilities are those in existence for not more
than 1 year. Extension of the use of temporary facilities beyond 1 year
will render them subject to the requirements of permanent facilities.
IL 88-13: Sulphur Recovery Guidelines—Gas Processing Operations
15 August 1988

TO: All Oil and Gas Operators and Gas Processing Consultants

SULPHUR RECOVERY GUIDELINES

GAS PROCESSING OPERATIONS
This informational letter supersedes Informational IL 80-24.
The Energy Resources Conservation Board and Alberta Environment
have detailed their decision respecting new guidelines for sulphur
recovery at all Alberta sour gas plants in the attached report ERCB-AE
88-AA, entitled Sulphur Recovery Guidelines for Sour Gas Plants in
Alberta. These guidelines are effective immediately.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 11
IL 89-4: Public Involvement in the Development of Energy Resources
22 June 1989
TO: All Oil, Gas, Oil Sands, Pipeline, Hydro and Electric,
and Coal Operators
PUBLIC INVOLVEMENT IN THE DEVELOPMENT
OF ENERGY RESOURCES
The Energy Resources Conservation Board and Alberta Environment
(ERCB/AE) together have developed these guidelines concerning the
involvement of Albertans in energy developments. Both the energy
industry and the public also have made major contributions to their
development.
We believe these guidelines will be useful to the proponents of new
energy facilities, and to the operators of existing facilities.
While ERCB/AE recognize that the major players in any energy
development are the company involved and the people living in the
area, we also recognize that we have associated responsibilities. These
are explained more fully in Section 5 of the Guidelines.
Alberta’s Department of the Environment has in its mandate the
Ministerial right to order an Environmental Impact Assessment (EIA)
for any energy facility deemed to have the potential for significantly
affecting people, communities, or the environment. While the typical
EIA includes many of the elements of public involvement discussed in
these guidelines, in no manner do the guidelines infringe upon the
requirements of an EIA.
ERCB/AE are aware that the Canadian Petroleum Association (CPA)
presently is developing a major public consultation handbook. This
handbook will indicate how energy companies may effectively carry out
the broad philosophical concepts of public and community consultation.
We look forward to its publication later this year, and widespread use.
We commend the CPA on this important initiative.
The ideas and suggestions presented here are basically those which
ERCB/AE have found to be effective as we have worked with
individuals, families, communities, and local governments located near
energy developments. The suggestions and ideas of others involved in
energy developments are actively solicited. Please write or call:
1. ERCB: Calgary 297-3381; Communications Department, 10 Flr,
640 - 5 Avenue S.W., Calgary, Alberta, T2P 3G4.
2. AE: Edmonton 427-5852; Environment Assessment Division, 6
Flr, Oxbridge Place, 9820 106 Street, Edmonton, Alberta, T5K
2J6.
ATTACHMENT TO INFORMATIONAL LETTER IL 89-4
PUBLIC INVOLVEMENT IN THE DEVELOPMENT OF ENERGY
RESOURCES…GUIDELINES FOR ALBERTA’S ENERGY
INDUSTRY
SECTION 1: INTRODUCTION
These public involvement ideas and suggestions are not fixed in
regulation However, the energy industry should understand that the
12 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
ideas presented here are the kinds of things that ERCB/AE urge
companies to consider when they are submitting energy applications for
evaluation. It should also be understood that these are broad guidelines.
All actions suggested here do not apply to all energy projects.
Obviously, what might apply very well to a small oil-field battery
installation might be totally inadequate for a major oil sands plant.
SECTION 2: OBJECTIVES
While reviewing these objectives, it will be helpful to refer to the time-
line chart which is Attachment A to this paper. The time-line shown
extends from a point in time prior to development of an energy project
through to final close-down. Thus, the objectives shown also extend
across a similar time period. The ERCB/AE objectives include:
• To foster a more thorough understanding, by everyone concerned, of
the needs and concerns of all those involved in energy developments,
including industry, government, and the people of Alberta.
• To improve the public’s understanding of the value of energy
developments to this province, in terms of income to the province,
benefits to its citizens arising from their ownership of the resources, a
broader job base for its workers, and diversification of the provincial
industrial base.
• To improve industry’s understanding of public awareness, priorities,
and experience, as these relate to energy developments locally and
province-wide.
• To facilitate the direct involvement of concerned people in the work
associated with planning, constructing, and operating specific energy
facilities.
• To ensure that public involvement occurs in such a manner and time
that people’s concerns may be properly addressed and resolved.
• To encourage industry and government to work with Albertans in a
language all may understand.
• To encourage the energy industry to more fully tell its story—both
the negative and positive sides—to the widest possible audience.
• To sponsor and encourage the use of innovative approaches to issue
discussion and conflict resolution, in order that win/lose
confrontations and lengthy public hearings may no longer be
necessary.
• To facilitate effective communication between all of the parties to an
energy development, not only as the project begins, but throughout
its operating lifetime and to final close-down, no matter the number
of years involved.
SECTION 3: SUPPORT FROM THE PEOPLE
This guide opens with an explanation of the kinds of things the public
could do to make the entire energy development process more
workable, more productive, and less confrontational.
It seems logical to begin with the people of Alberta because industry
and government must have the involvement and co-operation of the
public in order for anything else to work.
Despite all arguments regarding the significant benefits gained by
Albertans from the development of energy resources, the fact is some
Albertans do experience negative impacts from those developments.
Those Albertans who are—or who perceive themselves to be—directly
and negatively affected by energy developments must have their
concerns fully identified and sensitively addressed.
In order for all the other players to work towards a better way of
handling energy developments, there is need for the following kinds of
co-operation from the people and communities directly affected:
3.1 Albertans are encouraged to take every opportunity to learn more
about the business of resource development, including about the
EIA process, and the application review, public hearing, and
regulatory and surveillance systems already in place. This would
include attending important energy-related public meetings
scheduled for their areas, and requesting small-group or one-on-
one meetings, with government and industry, whenever they have
concerns about specific projects.
3.2 Albertans directly affected by specific energy projects should
adopt a practice of bringing their concerns forward to the company
involved or to the ERCB or AE as early as possible, so that
attempts may be made to resolve outstanding issues, preferably
without public hearings or inquiries.
In situations where ERCB/AE do not have jurisdiction to address
certain issues, but where those issues are companion to a
development proposal, the two organizations will endeavour to
assist concerned citizens in taking their issues to the appropriate
people for resolution.
3.3 Albertans who may be directly affected by specific energy projects
are encouraged to take the necessary steps to fully understand the
development proposals being presented. This step can include
professional review of applications and independent research.
3.4 People directly concerned with a specific application should
attempt to resolve as many issues as possible prior to public
hearing, bringing only unresolved issues that fall within the
ERCB’s jurisdiction to the actual hearing.
3.5 When energy projects are approved, directly involved citizens are
encouraged to continue bringing their concerns to the company
involved or to ERCB/AE. People are also encouraged to
participate in on-going problem solving, identifying issues
requiring mitigation, and planning for final close-down,
abandonment, and reclamation of a facility. It is anticipated, too,
that specific concerns regarding violations or incidents will be
reported immediately to the appropriate authorities (usually AE or
ERCB).
SECTION 4: INDUSTRY INITIATIVES
The suggestions appearing in this section are expectations of the energy
industry held by both ERCB/AE.
In the view of ERCB/AE, effective human and community relations are
not subjects which can be regulated into existence. The energy industry
and the people of Alberta must continue to deal with each other on a
fully considerate basis. They must recognize each other’s needs, and
work together to resolve other’s concerns.
The Alberta energy industry already has demonstrated its willingness to
communicate with people well in advance of development, and to work
to resolve people’s concerns in a proactive way. ERCB/AE hope that
the ideas expressed in this section will become the norm for energy
industry/public relationships:
4.1 Wherever practical, industry is encouraged to bring together the
people involvement and communication plans of all developers
working in a single area. It is believed this will reduce the
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 13
possibility of public confusion and disturbance arising from
piecemeal development. It certainly will avoid duplication of
message and effort.
4.2 Industry is encouraged to step up the telling of its story to the
people of Alberta, particularly those people directly affected by its
development proposals. Included in this work would be
widespread distribution of such publications as the CPA
Environmental Code of Practice and the CPA Public Involvement
Manual.
4.3 Company representatives working in communities should undergo
specific training to better understand and more effectively address
public concerns.
4.4 Industry is encouraged to begin its public involvement and
communication activities well before submission of any
application to ERCB/AE, and also to establish effective two-way
lines of communication with directly affected people prior to
application submission.
4.5 Industry should make a special effort to explain to directly affected
communities and people the employment and business
opportunities expected from its projects and, wherever possible, to
also indicate the overall benefits to the province.
4.6 Industry should explore every avenue of problem solving available
to it before bringing the unresolved concerns of citizens to an
ERCB public hearing. (This is quite apart from any work arising
out of item 5.6 in the section following.)
4.7 Applications made to ERCB/AE for specific projects should be
presented in language understandable to the lay reader, and strong
efforts should be made to explain the application to directly
affected citizens, both during community meetings and one on one.
Specifically, project applications should include an understandable
executive summary, and those sections of an application dealing
with the community, social costs and benefits, the environment,
human and animal health, and emergency preparedness, should be
framed at an easily understood language level.
4.8 When preparing for an ERCB public hearing, the company should
place considerable emphasis on communicating information
directly related to the concerns of people and to how those
concerns will be addressed.
4.9 If an application is approved, the company involved should
continue its communication and consultation efforts. It is felt, for
example, that a company might actually step up its contacts with
directly affected citizens after project approval. There should be an
immediate and all-out effort to bring about a fuller understanding
of what has been approved and what will be done next, including
emphasis on any problem-solving processes which will be put in
place.
4.10 When facility construction begins, companies are encouraged to
involve citizens in every way practical in being aware of the work
as it progresses, and to proactively address any new issues or
concerns as they may be brought forward.
4.11 Companies are encouraged to invite citizens to visit facilities
during construction, to hold opening ceremonies to which all
neighbours may be invited, and to encourage—as a corporate
objective—having facility staff become involved members of
nearby communities.
4.12 Companies are encouraged to establish smoothly functioning
communications networks, permitting citizens to bring forward any
concerns arising out of facility operations. Longer-range,
companies are encouraged to involve citizens in problem solving
and, when the time comes, in the planning associated with facility
close-down.
4.13 Companies are encouraged to communicate effectively with, and to
obtain proactive input from, any special interest groups concerned
with or interested in the important issues posed by any energy
development.
SECTION 5: ERCB/AE ACTIONS
In co-operation with Alberta Environment, the ERCB intends to carry
out a variety of programs falling in the general categories shown below:
5.1 Beginning with widespread distribution of these public
involvement guidelines, ERCB/AE will continue to make their
positions regarding the need for effective public involvement and
public communication well known throughout the Alberta energy
industry.
5.2 In a variety of ways, ERCB/AE also will continue to make known
to the Alberta public how the current process of application
review, intervener funding, regulation, on-going surveillance, and
provisions for intervention by concerned citizens, works to protect
the public interest. Alberta Environment also will encourage other
government departments to similarly explain their individual roles
in energy developments.
5.3 Increased training opportunities will be provided to ERCB/AE
staff in order that they may become more effective in working with
those people directly affected by energy developments.
5.4 ERCB/AE will endeavour to proactively inform locally elected
representatives about current and proposed energy developments
in their areas.
5.5 When invited, ERCB/AE will attempt to ensure staff
representation at key meetings between the industry and directly
affected people. The two organizations also will make themselves
available to any group of citizens wishing to discuss particular
issues of concern related to specific energy proposals or
operations. Insofar as may be practical, ERCB/AE also will
attempt to ensure that this community contact work continues
through project start-up and operation, and for as long as directly
affected people perceive the need.
5.6 Utilizing either their own staff or contracted expertise, ERCB/AE
will, where appropriate, offer to citizen/industry groups
experiencing conflict the opportunity to enter into informal or
formal consultation/mediation to resolve outstanding issues of
concern. This may be done either prior to or after submission of an
application, or after project approval (if ERCB/AE approval is
gained for the project).
5.7 ERCB/AE will develop and implement a follow-up mechanism to
ensure that commitments falling under their jurisdictions that have
been made during a project application, including those made
during public hearing of the application, are indeed kept.
5.8 ERCB/AE will ensure that trained staff are present during any tests
of the emergency plans developed for specific energy facilities, and
that test reports are carefully evaluated, with appropriate
modifications being made to the emergency plans in order to meet
sound public safety practices. Alberta Environment also will
14 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
encourage other government departments to have representatives
present during such tests.
5.9 ERCB/AE will continue to ensure that inspections of operating
facilities do not become a tedious routine exercise, and that the
standards which have been developed for the protection of people
and the environment will continue to be fully enforced throughout
the lifetime of any energy project.
5.10 Alberta Environment, working closely with the ERCB, will
continue with the development of guidelines and regulations
leading to the safe and environmentally sound shut-down of energy
facilities when their operating lifetimes are finished.
ATTACHMENT A: PUBLIC INVOLVEMENT IN THE
DEVELOPMENT OF ALBERTA’S ENERGY RESOURCES
OVERALL OBJECTIVES: To promote increased awareness and
knowledge of each participant’s role and activities; to increase two-way
communication and public input and the mutual understanding of
issues.
MAJOR ACTION POINTS ALONG THE ENERGY DEVELOPMENT
TIME-LINE AND OBJECTIVES AT EACH ACTION POINT
ACTION POINTS
WHAT IS HAPPENING AT EACH ACTION POINT
1 On-going public and community involvement activities
Activities at this point will usually occur apart from site-specific
projects. (*1)
2 Development of project concept (new or modification) and first
public contacts
Companies are initially considering and planning a project. Thus, many
activities at this point are largely internal to the companies, but initial
contacts with the public may be taking place.
ACTION POINTS
WHAT IS HAPPENING AT EACH ACTION POINT
3 Application preparation and continued community contact
The activities in this phase may involve considerable technical,
environmental, and socio-economic research in preparing the
application, as well as an on-going community program.
4 ERCB public hearing and decision reports
The activities in this phase may focus on the hearing process itself,
ensuring that it is understood by all and that it is conducted in a
way that allows all issues and information to be fairly reviewed.
The decision report needs to be fully understood by all those
involved.
5 Post ERCB/AE decisions, through to project construction and
start-up
If the project is approved and construction proceeds, the public
involvement activities in this phase are intended to keep all those who
may be directly affected by it fully informed on the status of the project.
Included will be discussion of how conditions will be imposed and
existing regulations will be met, with emphasis on addressing any new
concerns which may arise.
6 Routine operation of project, through to close-down
The activities in this final phase are on-going operations, perhaps this time frame that the company and the community may work to
extending over many years through to final close-down. It is within become “good neighbours”.
(*1) They could be on-going in areas where site-specific projects exist
or have been proposed.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 15
IL 89-14: Applications for Gas-Oil Ratio Penalty Relief
13 September 1989
To: All Oil and Gas Operators
APPLICATIONS FOR GAS-OIL RATIO PENALTY RELIEF
The gas-oil ratio (GOR) penalty schedule provides an effective tool for
dealing with oil and gas conservation matters, and further serves to
maintain equity by equalizing reservoir voidage in multi-well pools of
mixed ownership. It helps to control reservoir withdrawals and the
excessive flaring of solution gas where the feasibility of gas
conservation or pressure maintenance has not been fully addressed.
Control of gas flaring is particularly important in environmentally
sensitive areas.
The Board's current practice is to accept requests for GOR penalty relief
on the basis of a suitably supported application submitted in accordance
with section 15.090 of the Oil and Gas Conservation Regulations
(Regulations)*. While the Board continues to believe that the GOR
penalty base should be retained in its current form, it is endeavouring to
simplify and expedite the application process. This informational letter
seeks to clarify and update industry on the Board's view with respect to
GOR penalty relief, and introduce new measures designed to assist
industry and make the overall process more efficient.
* Sections 10 (1) (o) and 10 (3) of the Oil and Gas Conservation
Act and sections 10.050 and 10.060 of the Regulations provides
the Board with authority to establish a GOR base for determining
penalty factors and to consider applications for relief from GOR
penalties.
Criteria for Penalty Relief
When evaluating applications for GOR penalty relief, the Board seeks
to find answers to the following:
1. Is the excess gas production from solution gas or does it
involve an associated gas cap?
2. Can remedial work be done to reduce excess gas production?
3. If the gas is being conserved and oil conservation and equity
matters are not an issue, GOR penalty relief on the basis of net
gas production is virtually automatic. Net gas production is
defined in clause 1 of the Special Provisions to the MRL
Order.
4. If the gas is not being conserved, evidence must be provided to
show that gas conservation is not economically viable. Where
this is clearly demonstrated to the satisfaction of the Board and
other requirements including environmental and aesthetic
impacts of gas flaring are satisfied, penalty relief is normally
approved by removal or altering of the GOR penalty base. In
certain cases, the Board may be willing to improve the
economics of gas conservation by granting a special maximum
rate limitation (MRL) or good production practice (GPP),
where explicit limitations on production are not deemed
necessary.
5. Is there potential for further pool development? Could GOR
penalty relief impact on the pool's future depletion strategy?
6. Is the pool a likely candidate for enhanced oil recovery? If so,
penalty relief would generally not be considered appropriate
until this issue has been resolved.
16 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
7. Where primary depletion is deemed the optimum mode of
depletion, will production at unpenalized rates prejudice
ultimate recovery or have an adverse effect on correlative
rights?
8. Where an associated gas cap is present in the pool, has the
question of concurrent production been considered and have
owners of the gas rights been contacted and involved in the
pool's depletion planning?
9. Where a pool has mixed ownership, has the issue of correlative
rights been addressed on a pool basis?
Regional Penalty Relief
Where appropriate, the Board would encourage that application for
GOR penalty relief be made on a regional rather than individual pool
basis. A request of this nature would require a joint submission from all
interested parties within a group of fields and pools which share similar
geology, production performance, and pool depletion strategies. It is
important that the reservoir geology and fluid properties be reasonably
defined, and that reliable early performance and pressure data be
obtained to substantiate interpretations.
For example a regional approach was used successfully in an
application for penalty relief for pools completed in the Banff
Formation in the Craigmyle, Michichi, and Watts Fields. After
concluding that enhanced recovery was not feasible and recognizing
that gas was to be conserved, the Board granted net GOR penalty relief
and a special MRL of 25 m3 per day per well for all Banff wells in the
region. Attached is a copy of the letter to all operators in the subject
fields regarding this decision. Also attached is a letter where, on a
regional basis, the Board approved GPP for all Dina Pools in the Hayter
and Provost Fields.
Application Form - Small Pools
To further simplify applications for GOR penalty relief for small, poor
quality pools the Board is introducing a new application form, Board
Form 0-33 (attached). It is anticipated that this form will help to
minimize the number of deficiencies observed with this type of
application. Where appropriate an operator is expected to supplement
this form by providing expanded explanations and documentation of
technical arguments. Applications involving larger, more complex pools
should address the issues mentioned above and observe the more
detailed requirements of section 15.090 of the Regulations.
Other Considerations
The Board's normal practice will be to approve GOR penalty relief
effective the first day of the month following the month a final decision
is made. However, where gas is already being conserved and all other
issues have been adequately resolved, the Board will consider approval
of penalty relief at an earlier date.
The Board has placed several hundred pools on GPP with the
expectation that these pools will be operated in accordance with good
engineering principles so as to maximize hydrocarbon recovery. It
should be recognized that GPP status may be revoked where conditions
change such that conservation, equity, or the environment are being
compromised. For instance where further development is occurring or
where substantial volumes of gas are being flared, GPP may be revoked.
Finally, due in part to increased public awareness, environmental
concerns regarding the flaring of solution gas have become more
pronounced in recent years. Where such concerns are present, the Board
would carefully weigh environmental and aesthetic impacts, in addition production administration option because of the potential impact on the
to technical and economic matters, in making decisions related to GOR Modified Proration Plan.
penalty relief.
The Board believes that a special MRL of 25 m3 per day per well in
Questions concerning this letter should be directed to the Board's Oil conjunction with GOR penalty relief provides a reasonable production
Department at 297-8566 or 297-8570. level for Banff oil wells in that area shown on the attached plat. Wells
developing the Banff formation outside this area will be subject to
<signed by> normal allowable administration and GOR penalties. However, the
Board will entertain applications for GOR penalty relief and special
N. G. Berndtsson, P.Eng. MRLs where appropriate.
Manager
Oil Department In summary, the Board has approved the following:
1) Continuation of GOR penalty relief for those Banff pools
previously granted interim relief. Any new wells placed on
APPLICATION FOR GAS-OIL RATIO (GOR) PENALTY production from the Banff formation in that area shown on the
RELIEF (FORM) attached plat shall receive GOR penalty relief upon notification of
gas conservation.
1 February 1989
2) All existing and future Banff pools within the subject area, with
To: All Operators the exception of those pools subject to GPP, shall be entitled to a
(see attached list) special MRL of 25 m3/day/well which will become effective 1
March 1989.
GOR PENALTY RELIEF AND SPECIAL MAXIMUM RATE LIMITATION If you have any questions regarding this letter, please contact Mary
CRAIGMYLE - MICHICHI - WATTS AREA Anne Cairns of the Board's Oil Department at 297-8563.
On 28 January 1987, the Board issued a letter to all operators approving
temporary gas-oil ratio (GOR) penalty relief on the basis of net gas Yours truly,
production for wells producing from the Banff formation within an area
encompassing the Chain, Craigmyle, Delia, Michichi, Pearl and Watts <signed by>
fields. The interim period of penalty relief commenced 1 February 1987
and was to terminate 31 July 1988. The purpose of this period was to R. J. Willard, P.Eng.
establish pool delineation and optimum depletion strategies. The GOR Assistant Manager
penalty relief period was subsequently extended until the Board Oil Department
completed its review of the required studies. To further expand the
study base a number of pools were granted a special maximum rate AO/js
limitation (MRL).
bcc:
In response to the Board's letter of 28 January 1987, performance N. Strom, Vice Chairman
studies were received from Preco Petroleum Consulting Ltd. on behalf P. Prince, Board Member
of Poco Petroleums Ltd. (dated 7 June 1988) and Renaissance Energy S. Wanka, Allowables
Ltd. (dated 11 May 1988) in support of continued GOR penalty relief A. Burrowes, Oil Proration
and increased MRL's for wells exhibiting capabilities in excess of their G. Kimber, Oil Proration
reserve-base MRL. These reports concluded that: E. Moeller, Gas Department
• the Banff geology in the study area is very complex making pool B. Fairgrieve, Geology
delineation difficult GOR penalty relief and special MRL aproval area (GRAPHIC)
• the formation is highly fractured which is believed to not only
control well productivities, but precludes any pressure LIST OF OPERATORS
maintenance feasibility alternatives Banff Formation Craigmyle - Michichi - Watts Area
• neither GOR penalty relief or increased production rates under the
special MRL's has negatively impacted well performance. Poco Petroleums Ltd.
600, Bow Valley Square II
A review by the Board staff of the geology, well performance and 205 - 5th Avenue S.W.
available pressure data supports the general conclusions of the studies. Calgary, Alberta
Although more detailed work is believed necessary to determine T2P 2V7
recovery potential of the Banff formation, the Board agrees that primary
depletion and continued GOR penalty relief for wells producing from
the Banff formation in this area is appropriate.
Summit Resources Limited
With regards to the request for higher MRL's, the Board notes that 700, 340 - 12th Avenue S.W.
optimum production rates were not discussed to any detail in the Calgary, Alberta
reports. In its own review, the Board compared individual well rates to T2R 1L5
determine an appropriate MRL level as well as the implications of good
production practice (GPP). Good production practice was ruled out as a Renaissance Energy Ltd.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 17
2500, 801 - 6th Avenue S.W. 2) typically, wells producing from the Dina formation demonstrate
Calgary, Alberta good initial oil productivities and within the first year the
T2P 3W2 producing water-cuts increase significantly with rapidly
deteriorating oil rates. This performance indicates the critical
Amoco Canada Petroleum Company Ltd. coning rate for wells producing from the Dina pools is low and
444 - 7th Avenue S.W. hence oil recovery is maximized by optimizing up-front economics
Calgary, Alberta during the early high productive life of the wells and investing in
T2P 0Y2 adequate water disposal facilities to handle the expected high
volumes of produced water.
Esso Resources Canada Limited
3) there has been no evidence presented to the Board to show that
237 - 4th Avenue S.W.
equity is of concern for those pools producing under GPP
Calgary, Alberta
administration.
T2P 0H6
In view of these observations the Board believes that it would be
Intensity Resources Ltd. technically advisable and administratively expedient to approve GPP
600, 531 - 3rd Avenue S.W. for all remaining designated and undesignated Dina pools in the Hayter
Calgary, Alberta and Provost fields effective 1 March 1989 and to permit those pools
T2P 3T3 which have GPP approval on an interim basis to continue to produce
under GPP administration. In addition, for a newly completed well in an
Bankeno Resources Ltd. undesignated or designated pool, GPP will be permitted from it's on
700, 112 - 4th Avenue S.W. production date. The approval of GPP does not affect the requirements
Calgary, Alberta for submitting the appropriate application for a "New Well Base
T2P 4B2 Allowable or Maximum Rate Limitation" (O-38 form).

Encor Energy Corporation Ltd. Renaissance also requested that all pressure surveying requirements for
P.0. Box 2670, Station M Dina pools in the Hayter and Provost fields be waived indefinitely. The
Calgary, Alberta Board does not believe that complete waiver of all pressure surveys is
T2P 3C1 appropriate at this time considering the active development of the Dina
formation. Although available pressure information does support the
Enron Oil Canada Ltd. existence of an active aquifer, it does not conclusively indicate that the
Western Canada Place aquifer will be able to maintain, or as a minimum, retard pressure
1300, 700 - 9th Avenue S.W. depletion in high well density GPP pools. In this regard the Board
Calgary, Alberta offers the following guidelines for obtaining pressures in the Hayter and
T2P 3V4 Provost Dina pools:

Preco Petroleum Consulting Ltd. 1) initial and two subsequent pressure surveys are required for all
1620, 840 - 7th Avenue S.W. new pools during the first two years of production. Subsequent
Calgary, Alberta pressure surveys, survey frequency, or waiver of surveys would be
T2P 3G2 considered after evaluation of the available pressure data.
2) for pools of reasonable reservoir quality having ten or more
Energy Resources Conservation Board productive wells, the Board suggests that at least 2 or more wells
640 Fifth Avenue located to provide the optimum areal coverage be surveyed. As in
Calgary, Alberta item (i) above, the Board would consider the appropriateness of
Canada T2P 3G4 continued surveys or a change in survey frequency after a
minimum of 3 pressure surveys over a period of 2 years.

23 January 1989
To: All Operators
(see attached list)
GOOD PRODUCTION PRACTICE HAYTER AND PROVOST DINA POOLS
In September 1988 Renaissance Energy Ltd. submitted a regional
performance study of the Dina pools in the Hayter and Provost fields.
The study was prepared to support the continuation of good production
practice (GPP) administration conditionally approved for a number of
these pools. The Board has completed its review of the study and makes
the following observations:
1) the Dina pools located between Ranges 1 to 10 W4M inclusive
and between Townships 34 to 41 inclusive are associated with a
large underlying aquifer. The general opinion is that this aquifer is
reasonably effective in maintaining reservoir pressure.
3) if it appears that at the end of two years, abnormal pressure
depletion in any pool or area is evident or pressure data obtained is
completely lacking credibility, a proper and adequate pressure
survey program will be discussed with the operator(s). Such
discussions would require the operator(s) to address pressure
depletion concerns if such were necessary.
The Board's Gas Department considered the feasibility of gas
conservation for the Dina pools. It concluded that for most pools, gas
conservation was not considered a viable option due to declining oil
production and low volumes of produced gas. However, the Gas
Department will continue to monitor the development of the Dina
formation with regards to future gas conservation concerns.
Questions regarding this letter should be directed to Mr. Alyn Olive of
the Board's Oil Department at 297-8555.

18 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
<signed by> Calgary, Alberta
T2P 0M2
Yours truly,
Commercial Oil & Gas Ltd.
R. J. Willard, P.Eng. 1122 - 4th Street S.W.
Assistant Manager Calgary, Alberta
Oil Department T2R 1M1
AO/js
Blake Resources Ltd.
LIST OF OPERATORS c/o Woodb O & G
Dina Formation Hayter - Provost Fields 800, 1122 - 4th Street S.W.
Calgary, Alberta
Altana Exploration Company T2R 1M1
1240, 700 - 9th Avenue S.W.
Calgary, Alberta Corrida Oils Ltd.
T2P 3V4 1800, 311 - 6th Avenue S.W.
Calgary, Alberta
Canadian Occidental Petroleum Ltd. T2P 3R2
1500, 635 - 8th Avenue S.W.
Calgary, Alberta BP Resources Canada Limited
T2P 3Z1 333 - 5th Avenue S.W.
Calgary, Alberta
Altavista Resources Ltd. T2P 3J4
310, 355 - 4th Avenue S.W.
Calgary, Alberta Cougar Resources Ltd.
T2P 0J1 260, 700 - 4th Avenue S.W.
Calgary, Alberta
Carlyle Energy Ltd. T2P 3B6
800, 1122 - 4th Street S.W.
Calgary, Alberta Cabre Exploration Ltd.
T2P 1M1 1000, 635 - 8th Avenue S.W.
Calgary, Alberta
Altex Resources Ltd. T2P 3M3
1500, 700 - 4th Avenue S.W.
Calgary, Alberta Eagle Resources Ltd.
T2P 3J4 3500, 1212 - 31st Avenue N.E.
Calgary, Alberta
Chauvco Resources Ltd. T2E 7S8
2900, 255 - 5th Avenue S.W.
Calgary, Alberta Canada Northwest Energy Limited
T2P 2R9 2700, 300 - 5th Avenue S.W.
Calgary, Alberta
Amoco Canada Petroleum Company Ltd. T2P 3C4
444 - 7th Avenue S.W.
Calgary, Alberta Encounter Energy Resources Limited
T2P 0Y2 1800, 311 - 6th Avenue S.W.
Calgary, Alberta
Coachwood Resources Ltd. T2P 3W2
520, 999 - 8th Street S.W.
Calgary, Alberta Glen Isle Exploration Ltd.
T2R 1J5 750, 202 - 6th Avenue S.W.
Argyll Resources Ltd. Calgary, Alberta
1800, 717 - 7th Avenue S.W. 3700, T2P 3P4
Calgary, Alberta
T2P 0Z3 Mont Resources Limited
301, 805 - 8th Avenue S.W.
Coho Resources Limited Calgary, Alberta
700 - 2nd Street S.W. T2P 1H7
Calgary, Alberta
T2P 2W2 Gulf Canada Limited
401 - 9th Avenue S.W.
Banff Oil (1970) Ltd. Calgary, Alberta
2000, 540 - 5th Avenue S.W. 910, T2P 3C5

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 19
 1800, 311 - 6th Avenue 5.W.
Morgan Hydrocarbons Inc. Calgary, Alberta
2200, 205 - 5th Avenue S.W. T2P 3H2
Calgary, Alberta
T2P 2V7 Ladd Exploration Company
800, 707 - 7th Avenue S.W.
Hillcrest Resources Ltd. Calgary, Alberta
575, 441 - 5th Avenue S.W. T2P 0Z2
Calgary, Alberta
T2P 2V1 Omega Hydrocarbons Ltd.
1300, 112 - 4th Avenue S.W.
Morrison Petroleums Ltd. Calgary, Alberta
2700, 801 - 6th Avenue S.W. T2P 0H3
Calgary, Alberta
T2P 3W2 Maxon Energy Inc.
455, 520 - 5th Avenue S.W.
Husky Oil Operations Ltd. Calgary, Alberta
P.O. Box 6525 T2P 3R7
Calgary, Alberta
T2P 3G7 PanCanadian Petroleum Limited
Box 2850
Murphy Oil Company Ltd. Calgary, Alberta
P.0. Box 2721 T2P 2S5
Calgary, Alberta
T2P 3Y3 Petro-Canada Inc.
P.0. Box 2844
Joffre Resources Ltd. Calgary, Alberta
600, 708 - 11th Avenue S.W. T2P 3E3
Calgary, Alberta
T2R 0E4 Suncor Inc. Resources Group
P.0. Box 38, 500 - 4th Avenue S.W.
Noramex Resources Ltd. Calgary, Alberta
321 - 50th Avenue S.E. T2P 2V5
Calgary, Alberta
T2G 2B3 Pinnacle Resources Ltd.
1750, 736 - 6th Avenue S.W
Kanata Gas & Oil Ltd. Calgary, Alberta
220, 801 - 6th Avenue S.W. T2P 3T7
Calgary, Alberta
T2P 3W2 Tintagel Energy Corporation
3000, 400 - 3rd Avenue S.W.
Norcen Energy Resources Limited Calgary, Alberta
3100, 715 - 5th Avenue S.W. T2P 4112
Calgary, Alberta
T2P 2X7
Ranchmen's Resources Ltd.
800, 112 - 4th Avenue S.W.
Keles Production Company Ltd. Calgary, Alberta
100, 1301 - 8th Street S.W. T2P 0113
Calgary, Alberta
T2R 1B7 Westmin Resources Limited
1800, 255 - 5th Avenue S.W.
NSM Resources Ltd. Calgary, Alberta
300, 555 - 4th Avenue S.W. T2P 3G6
Calgary, Alberta
T2P 3E7 Renaissance Energy Ltd.
3300, 400 - 3rd Avenue S.W.
Knee Hill Energy Canada Ltd. Calgary, Alberta
400, 505 - 8th Avenue S.W. T2P 4112
Calgary, Alberta
T2P 1G2

Oakwood Petroleums Ltd.

20 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
Woodbend Oil & Gas Ltd.
800, 1l22 - 4th Street S.W.
Calgary, Alberta
T2R 1H1

Strathfield Oil & Gas Ltd.

1500, 255 - 5th Avenue S.W.
Calgary, Alberta
T2P 3G6

Summit Resources Limited

2300, 144 - 4th Avenue S.W.
Calgary, Alberta
T2P 3N4

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 21
IL 90-6: Measurement Guidelines-Trucked Oil Production
23 May 1990
TO: All Oil and Gas Operators
The Energy Resources Conservation Board is responsible for ensuring
accurate measurement and accounting procedures at all oil and gas
production facilities. Measurement and accounting accuracy is
necessary for appropriate allocation of oil and gas production to
individual wells to provide for meaningful technical reservoir and
production assessments, as well as to facilitate both royalty and working
interest equity allocations.
The Board has reviewed measurement and accounting practices at
facilities receiving trucked oil production. It has concluded that receipt
of trucked production, in the absence of suitable measurement and
accounting procedures, can be a significant source of measurement and
accounting error. This applies to proration batteries receiving both
trucked and flowlined production, as well as to facilities receiving only
trucked production. As a significant portion of the province’s crude oil
is transported by truck, the Board believes this matter warrants some
direction.
BACKGROUND
Receipt of trucked production at a proration battery and the method of
volume and basic sediment and water (BS&W) determinations
introduce an error system additional to that already inherent in the
proration battery. Errors in both the inlet volume and BS&W
determination of the trucked volumes are generally absorbed by the
flowlined production, as the trucked volumes are considered as
measured such that these errors are not prorated back to the trucked
wells.
Although one apparent solution would be to prorate any differences
between estimated and actual battery production back equally to both
flowlined and trucked wells, the Board does not believe that this is a
reasonable approach. The concept of proration requires that all wells
contributing to the proration battery be subject to an equivalent error or
uncertainty regime. In the case of trucked production, each load or unit
volume from the well or battery is subjected to measurement such that
the total production is in fact a measured volume. This is significantly
different from the flowlined wells which are subjected to periodic test
measurements with the total well production estimated from these tests.
Measurement devices and procedures are also typically distinctly
different between the trucked and flowlined systems. Given the
difference between error regimes, the Board believes a more appropriate
solution is to minimize the error or uncertainty in trucked production
measurement.
The Board will continue to require operators of facilities receiving only
trucked production, such as central treating stations, to prorate errors
back equally to all contributing wells despite the fact that each load is
measured. This is consistent with the aforementioned philosophy, as all
wells included in the proration are subject to the same uncertainty
regime. Similarly, trucked production at proration batteries may be
subject to proration when separate treating facilities are available to
determine the trucked volume available for sale.
22 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
As a result of its review of existing facilities, the Board expects that all
facilities receiving trucked production either have in place or take steps
to implement measurement systems sufficient to provide for accurate
determination of both the volumes and BS&W cuts of the production
being trucked. In accordance with the Board’s production accuracy
standards as listed in Schedule 9 of the Oil and Gas Conservation
Regulations, it is intended that total battery oil trucked from single well
batteries be determined to within 0.5 per cent error. As trucked volumes
are considered measured and accounted for as a delivery to the
receiving battery, the accuracy guideline must be consistent with
custody transfer measurement. Unlike typical custody transfer
measurement, however, the Board recognizes that the untreated and
potentially high water content characteristics of the trucked volumes
from single well batteries makes the 0.5 per cent accuracy guideline
extremely difficult to achieve. Such accuracy can be achieved on a
volume basis but is compounded by uncertainties in BS&W
determination. Accordingly, the Board recognizes the accuracy
guideline in this case as a target rather than a requirement.
To achieve the desired accuracy would require either a separate treating
process train for the trucked volume or refusal of proration batteries to
accept trucked production, thereby requiring all trucked volumes to be
processed through central treating stations. The Board believes the
former may be warranted where trucked volumes are significant in
comparison to flowlined volumes. The latter, however, is recognized as
impractical from an operational perspective. Receipt of trucked
production at proration batteries without separate treating facilities
therefore represents a compromise between measurement accuracy and
operational practicality.
Inlet measurement systems for receiving trucked production are
therefore expected to have both a means of determining inlet truck
volumes and appropriate procedures for BS&W determination to assist
in approaching the target accuracy. It is not the Board’s intent at this
time to stipulate specific equipment designs, configurations, or
procedures. The Board prefers to leave the operators flexibility in
implementing measurement systems. In recognition of the wide variety
of operational scenarios to which this informational letter may apply,
the Board believes it appropriate to present the following recommended
guidelines for volume and BS&W determination. Much of the
following guidelines has been derived from work performed by a
committee formed to study measurement accuracies at pipeline
terminals, tailored to fit the situation of battery level measurement.
INLET VOLUME MEASUREMENT
A system must be in place to provide for accurate measurement of inlet
volumes of trucked oil production. Truck tickets are not considered
accurate for the purpose of well or battery level measurement. The
Board believes an accuracy of 0.5 per cent can be achieved with respect
to gross volume alone through a system consisting of either inlet
tankage, inlet meter, or weigh scale.
i) Tankage
Inlet tankage used for the purpose of truck volume measurement must
be of sufficiently small diameter in relation to load volume to facilitate
gauging accuracy to within the Board’s accuracy guideline. Having
regard for uncertainties in gauge tape accuracy and gauge tape reading,
the maximum acceptable tank diameter (metres) can be approximated as
1.04 times the square root of the delivery volume (cubic metres). Tanks
must be gauged prior to and after each well delivery, and gauging
should be in accordance with the applicable sections of API Standard
2545. Calculation of volumes as obtained from gauging must be based
on appropriate strapping tables and should include temperature
compensation factors to 15°C. In cases where density differences
between adjacent loads exceed 40 kg/m3, consideration should be given
to use of dedicated tankage or the appropriate density blending tables as
per API Bulletin 2509C.
The use of differential pressure transmitters is an acceptable option to
gauging if appropriate procedures are followed to determine a
representative load density as per API Manual of Petroleum
Measurement Standards, Chapter 9.1. Gauge boards are not considered
accurate enough for the purpose of this measurement.
ii) Meters
Metering devices for the purpose of measuring inlet truck volumes
should be installed in conjunction with a strainer and air eliminator. The
meter must be operated within the meter design flow range either
through installation of a back pressure control system or an alternative
means of regulation of the truck unloading rate. Meter selection must be
appropriate for the intended range of service having regard for the range
of fluid characteristics (ie. density, viscosity, temperature) to be
encountered. Meters must be calibrated monthly and temperature
compensation should be included with the meter.
iii) Weigh Scales
Weigh scales for the purpose of inlet measurement must be calibrated
monthly in accordance with Canada Weights and Measures Standards.
Systems employing weigh scales must also provide for density
determination. Determination of density for oil and water should be in
accordance with API Manual of Petroleum Measurement Standards,
Chapter 9.1.
BS&W DETERMINATION
The largest component of uncertainty in trucked production
measurement typically pertains to the determination of BS&W.
Procedures for determination of the BS&W cut of individual truckloads
must provide for obtaining a representative sample of the entire
truckload, and reliable phase separation of the sample obtained.
Difficulties can be encountered when dealing with emulsions subject to
significant free-water breakout prior to treating, as free water may
separate in the truck and unload for a short period prior to unloading
emulsion. Sampling procedures therefore become vitally important with
respect to ensuring that the entire load is represented. Automatic
sampling procedures are preferred; however, manual or tank sampling
systems may also be appropriate.
i) Automatic Sampling
Automatic sampling is typically conducted through the use of either
proportional samplers or product analysers. The frequency of sampling
or readings must be sufficiently high to ensure an accurate
representation of the entire truck volume. Consideration must be given
to both conditioning the flow stream and locating the probe or sampler.
Flow conditioning to ensure turbulent mixing can be achieved through
velocity control, piping configurations, or introduction of a mixing
element upstream of the probe or sample point. Mid-pipe probe location
should then provide for accurate sampling. API Manual of Petroleum
Measurement Standards, Chapter 8.2, provides further details on flow
conditioning, probe location, and sampling frequency.
ii) Manual Sampling
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 23
Manual grab sampling may be acceptable in situations involving a tight
emulsion with little or no free-water separation in the truck. As with
automatic sampling, the frequency of grab samples obtained during the
unloading process must be sufficiently high to ensure an accurate
representation of the entire truck volume. There is some question as to
the validity of limited grab samples due to BS&W stratification with the
truck. Limited data available to date have indicated that single-point
grab sampling may be appropriate in heavy oil production scenarios
where lease tank heating results in a tight, stable emulsion. Available
data from conventional oil production scenarios, however, suggest that
single or limited multi-point grab sampling may not be appropriate due
to stratification of BS&W within the truck.
The use of manual sampling techniques such as truck tank thiefing (full
height or intermittent) may also be acceptable. However, concerns exist
over this procedure where stratification of water and emulsion or within
the emulsion itself exists within the truck. The concern is that, in the
presence of stratification, one unit of height at the bottom of the truck
tank represents a significantly lesser volume than the same unit of
height at the midpoint of the truck tank because of the elliptical shape
of the tank. The resulting BS&W from a full height core thief therefore
may not be representative of the entire load.
Lease tank thiefing is subject to similar stratification concerns
(excluding the non-uniformity of the tank). These concerns can be
reduced by locating any water-emulsion interface and obtaining bottom,
middle, and top samples of the emulsion to determine an average cut.
However, lease tank thiefing requires dedicated tankage per load to
avoid mixing of product between deliveries.
It is clear that numerous problems may exist with manual sampling
techniques. It is the expectation of the Board that the operator confirm
the accuracy of the method employed, having regard for emulsion
characteristics and stratification and BS&W consistency of the load.
API Manual of Petroleum Measurement Standards, Chapter 8.1,
provides further reference to manual sampling procedures.
iii) BS&W Determination
The most practical method for field determination of BS&W is by
centrifuge as described in API Manual of Petroleum Measurement
Standards, Chapter 10.4. The method includes the following
components:
Heat—The sample should be heated to 60°C by heat both prior to and
during centrifuging. Higher temperatures may be necessary for waxy
crudes.
Solvent—Water-saturated solvent should be used to assist in obtaining
a representative cut. Varsol, although not referenced in the API
procedure, is a common solvent in Alberta. Care must be taken to
ensure that the solvent is free of suspended water. Regular centrifuging
of the solvent alone to confirm the absence of suspended water would
be prudent practice.
Demulsifier—Enhancement of oil/water separation can be obtained
through addition of an appropriate demulsifier. Demulsifier should be
added to the sample in accordance with the manufacturer’s
recommendations.
Centrifuge—The centrifuge must be capable of spinning two or more
centrifuge tubes at a speed resulting in a minimum relative centrifugal
force of 500 gravities at the tip of the tube, as defined in the API
manual.
The procedure for determining the BS&W of the sample is described in
the API manual. Some deviations from this procedure may be
appropriate; however, operators are expected to confirm that any
deviation from these procedures does not compromise the accuracy of
the BS&W determination. Operators are encouraged to adopt an
appropriate standard procedure (ie. API or modification) and ensure
that field personnel follow such procedures constantly.
The centrifuge method as described above is most appropriate for low
BS&W samples as the resolution and accuracy of many centrifuge tubes
decrease as BS&W increases. When the BS&W exceeds 25 per cent, it
may be appropriate to consider an alternative procedure referred to as
the graduated cylinder method. This method involves
the collection and transfer of an entire sample to an appropriately sized
graduated cylinder. Phase separation is achieved through the addition of
demulsifier and retention in a heat bath until an oil/water interface is
obtained. Centrifuging the oil layer is advised, with the BS&W of the
sample calculated accordingly from the centrifuge and graduated
cylinder data. As with the centrifuge method, operators are encouraged
to adopt an appropriate procedure and ensure that field personnel follow
the procedure constantly.
IMPLEMENTATION
As these systems and procedures are recommended guidelines, the
Board is prepared to allow some deviation from these guidelines having
regard for specific circumstances. In all cases, it is expected that the
operator will determine which system, or modification to a system, is
appropriate having regard for overall measurement and accounting
accuracy. As indicated previously, receipt of trucked production at
proration batteries represents a compromise between accuracy
24 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
requirements and operational practicality. Circumstances may well exist
where installation of dedicated treating facilities to process trucked
production may be warranted. As a general guideline, the Board would
be concerned about the need for a dedicated treating train where the
volume of trucked emulsion exceeds 1000 cubic metres per month or 25
per cent of the flowlined emulsion. The decision to require this extra
equipment would have to be made in light of the actual circumstances
having regard for equity, royalty, and overall measurement accuracy
considerations.
Effective immediately, the Board expects that these guidelines be
considered for all new facilities intending to receive trucked oil
production. The proposed measurement system for the trucked
production must be fully addressed in the production facility application
submitted to the ERCB in accordance with section 7.001 of the Oil and
Gas Conservation Regulations. Operators should be reminded that
commencement of the receipt of trucked oil production at an existing
battery constitutes a modification to that battery. Operators are therefore
required under section 7.002 of the Regulations to submit an
appropriate application to the Board.
Although no formal submission to the Board is required, facilities
currently accepting trucked oil production are expected to address this
matter immediately. Modifications, where appropriate, are expected to
be implemented by 1 April 1991 with the required documentation
forwarded to the Board.
IL 90-14: Notification to Transport Canada of Drilling Operations Near Aerodromes
14 August 1990 Attached is a form available from Transport Canada and the ERCB
Well Licensing Section that outlines the information required by
TO: All Oil and Gas Operators Transport Canada for its review of wells to be drilled near aerodromes.
All Drilling Rig Contractors The Board recommends this form be used by all applicants when
submitting notice to Transport Canada. It will facilitate the efficient
processing and disposition of these notifications.
NOTIFICATION TO TRANSPORT CANADA OF DRILLING
OPERATIONS NEAR AERODROMES Any questions respecting this matter should be directed to the Board's
As a result of concerns expressed by Transport Canada, the Energy Well Licensing Section at 297-8554.
Resources Conservation Board (ERCB) wishes to remind applicants of
well licences for drilling operations near aerodromes of the need to <signed by>
provide notification in accordance with section 2.090 of the Oil and Gas
Conservation Regulations. An applicant for a well licence is required to J.R. Nichol, P.Eng.
give notice as follows: Manager
Drilling and Production Department
2.090
A person proposing to drill a well within 5 kilometres of a Attachment Drilling Rig Clearance Form
lighted aerodrome, or within 1.6 kilometres of an unlighted
aerodrome shall, before applying for a well licence, advise the
Regional Manager, Air Navigation Requirements, Transport
Canada, Edmonton, Alberta, of the proposed well site, the
height of the derrick to be used and the approximate dates
between which drilling operations are expected to take place.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 25
26 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
IL 90-17: Emergency Procedure Plans for Sour Gas Facilities—Biennial Meetings
5 September 1990 4) When a new facility is constructed for which an emergency
procedure plan is required, the operator shall hold a meeting with
TO: All Oil and Gas Operators all government departments and other agencies at least 30 days
before start-up to ensure that all parties understand their
responsibilities in the event of a sour gas release. For this new
EMERGENCY PROCEDURE PLANS facility, the operator shall have at least two more review meetings
FOR SOUR GAS FACILITIES— BIENNIAL at least every 2 years.
MEETINGS
5) For any major modification to existing facilities, the operator shall
Currently, under Interim Directive ID-OG-76-2, all operators are
review its emergency procedure plan with all government
required to review, at least every 2 years, their emergency response
departments and agencies before start-up of the modification.
procedures for sour gas facilities with the government and other
agencies to ensure that all parties understand their responsibilities in the 6) The operator shall continue to communicate effectively on a
event of a sour gas release. regular basis with local levels of government regarding the
relationship of its emergency procedure plan to the responsibility
The Board, after some concerns expressed by the industry and its own
of the local authorities during sour gas release.
staff, has decided to eliminate this review and replace it with the
following requirements: The Board will endeavour to audit an emergency procedure plan from
each operator once every 2 years.
l) Once a year, the operator shall hold an internal exercise for each of
its facilities that has an emergency procedure plan filed with the The Board will also select an operator to participate in an annual
Board. exercise. Other operators may be invited to observe the exercises. These
exercises will involve the implementation of the Government of Alberta
2) The emergency procedure plan must be reviewed at least annually
Emergency Response Plan for Sour Gas Release.
by the operator and changes forwarded to the Board.
3) The operator shall ensure that the general public in the emergency
planning zone are advised of the hazards and characteristics of
hydrogen sulphide gas, the emergency response procedures, and
safety measures employed by the operator.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 27
IL 90-21: Oil and Gas Development-Rumsey Block
26 November 1990
To: All Operators and Mineral Lease Holders in the Rumsey Area
The Rumsey Block is made up of approximately 50 sections of
relatively undisturbed aspen parkland, as shown on the attached map.
The rarity of such a large contiguous area of this type of ecosystem led
to the development of site-specific guidelines for off and gas
development within the Block which have been in effect since 1982.
The guidelines represent a policy established by Forestry, Lands and
Wildlife, Recreation and Parks, and the ERCB.
A decision was taken by the above agencies to proceed with the
development of a management plan for the area in the form of a
Regionally Integrated Decision (RID) early in 1989. The Central
Region’s Resource Management Committee (RRMC) endorsed the RID
approach in November 1989 and initiated the RID Committee in
January 1990. The participating team members on the RID committee
include representatives from the Department of Forestry, Lands and
Wildlife (Public Lands, Fish and Wildlife), and the Departments of
Energy, Recreation and Parks, and Culture, along with the ERCB. The
consultative team members consist of grazing lessees, industry,
municipalities, and the Alberta Wilderness Association (AWA).
The RID timetable projects completion and public review of the draft
Management Plan for the area by June 1991.
APPLICATION REVIEW PROCESS
Alberta Energy, Alberta Forestry, Lands and Wildlife, and the ERCB
are committed to ensure that any new developments within the Block
are carried out in an orderly and consistent fashion. In order to do this,
and also to provide all stakeholders with an opportunity to learn in
advance of any proposed developments, the following principles in
reviewing development applications will be followed:
28 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
1. Issuance of Mineral Leases
The Department of Energy will
(a) upon application, grant term extensions to expiring leases,
pursuant to section 8(l)(h) of the Mines and Minerals Act, where
surface access is denied, and
(b) not issue any new agreements until the RID has been completed
and approved.
2. Issuance of Mineral Surface Leases
The Public Lands Division of Forestry, Lands and Wildlife will
(a) advise companies requesting Mineral Surface Leases (MSLS) that
they must have a well licence granted by the ERCB prior to any
access road or lease construction, and
(b) submit any applications for the upgrading of existing roads or
construction of new, permanent access roads within the Block, to
the RID committee for comment before processing of such
applications.
3. Issuance of Well Licences
The ERCB will advise the RID committee and the AWA of receipt
of any applications for well licences within the Rumsey proposed
parkland boundary.
This process is being initiated as an interim measure to ensure
protection of the Rumsey Block while the RID planning process is
under way. It is expected that the RID process will establish a general
framework for all forms of land use and development in the Block,
including oil and gas, grazing, and recreational uses.
IL 91-9: Exemption from Gas Measurement: Crude Oil/Bitumen Wells
17 July 1991
TO: All Oil, Gas, and Oil Sands Operators
Under sections 14.040 and 15.140(3) of the Oil and Gas Conservation
Regulations, the Energy Resources Conservation Board currently
requires applications from operators seeking exemption from the
measurement of gas produced from a crude oil or crude bitumen well.
Such exemptions are frequently requested and approved where gas
production rates are sufficiently low to make measurement difficult by
conventional orifice measurement devices. This is typical in heavy oil
operations but also frequently occurs in conventional oil production
areas.
Accurate gas production data and the associated gas-oil ratio (GOR) are
of significant reservoir engineering importance as diagnostic tools for
monitoring and implementing reservoir depletion strategies. Exemption
from continuous measurement recognizes the operational difficulties in
obtaining low-rate gas measurements using conventional devices, but is
not intended to downplay the importance of obtaining representative
GOR data.
The Board has decided to discontinue the requirement for these
applications for those situations where the exemption criteria as
described within this informational letter are met, with the intent of
reducing the administrative workload of both Industry and the Board.
Although the requirement for application has been removed, the
Board’s expectations regarding gas measurement remain essentially the
same. Eligibility criteria for exemption from gas measurement, and the
Board’s expectations of the respective operators, are described in the
remainder of this informational letter.
CONVENTIONAL OIL PRODUCTION
Crude oil wells, batteries, or groups of wells are exempt from gas
measurement when the volume of gas produced through the meter is
less than 500 cubic metres per day (m3/d). This applies to test gas
measurement at multi-well batteries, group gas measurement, and
single-well oil batteries. Some latitude to this limit exists where gas
volumes marginally exceed the 500-m3/d level, particularly in multi-
well facilities at which most but not all wells qualify for test gas
measurement exemption. Exemption would be considered appropriate
where the remaining wells are marginally above 500 m3/d and the
number of these wells represents a small proportion of the total wells
producing to the facility.
Note that the 500-m3/d criterion represents an increase from the 300-
m3/d limit previously administered by the Board. This limit was
increased to achieve some degree of consistency between conventional
and heavy oil criteria.
For conventional oil production, an initial representative 24-hour
production test is required to establish eligibility for exemption and
determination of the appropriate GOR to be used for production
reporting purposes. Annual 24-hour tests are required to determine
continuing exemption eligibility and to update the GOR value.
HEAVY OIL PRODUCTION
For the purpose of this informational letter and to be consistent with
ERCB Interim Directive ID 91-3, heavy oil is defined as any liquid
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 29
hydrocarbon with a density of 920 kilograms per cubic metre (kg/m3) or
greater (22°API or less) at standard conditions. With respect to gas
measurement requirements, heavy oil is administered differently inside
the designated Oil Sands Areas as compared to outside.
1. WITHIN DESIGNATED OIL SANDS AREAS
Within the designated Oil Sands Areas, gas produced in association
with heavy oil or crude bitumen may be estimated at the point of
collection or emission as follows:
a) For single-well batteries, an initial representative 24-hour GOR
test is required within 6 months of the on-production date. The
resulting GOR must be updated annually if greater than 100 m3/m3,
and every 3 years if less than 100 m3/m3.
b) Where associated gas from a number of wells is flow lined to a
central point and the total gas rate at the point of collection or
emission is less than 2000 m3/d, gas production may be estimated
on the basis of a group or battery GOR, updated annually. Note
that in accordance with the Alberta Recommended Practices for
Heavy Oil and Oil Sands Operations, gas production estimated in
this way need not be allocated back to individual wells. Whereas
the Alberta Recommended Practices indicated it would be
appropriate to report the gas production as a delivery to and from
the same facility on the S-2 Report, certain data dissemination
problems are now apparent with this process. Gas reported without
allocation back to individual wells is now to be reported to a
pseudo-well identifier and listed on the S-l Report. The location
for the pseudo-well identifier should be obtained through the
Board’s Drilling and Production Department at 297-7232. Where
total gas rates exceed 2000 m3/d, the gas must be continuously
measured. Again, allocation back to individual wells is not
necessary.
2. OUTSIDE DESIGNATED OIL SANDS AREAS
Outside the designated Oil Sands Areas, heavy crude oil wells,
batteries, or groups of wells are exempt from gas measurement under
the following criteria:
Gas Rate (m3/d) GOR Test Frequency
less than 500 annually
501 to 1000 semi-annually
1001 to 2000 monthly
greater than 2000 continuous measurement
EXPECTATIONS OF OPERATORS
In the absence of the requirements for application, surveillance of gas
measurement and exemption eligibility will be conducted through
routine ERCB field facility inspections, detailed inspections, production
audits, and proration well test verifications. The Board’s expectations of
the operators are as follows:
• An initial representative GOR test is to be conducted to establish
eligibility for exemption under the appropriate heavy or conventional
oil criterion.
• The GOR is to be applied to the oil production data on the S-l Report
to estimate gas production, and the resulting gas production estimate
must be reported on the S-l Report. Where group or battery GORs are
 obtained within the designated Oil Sands Areas, the GOR is to be
applied to total bitumen production with the resulting gas estimate
reported on the S-l Report against the appropriate pseudo-well
identifer.
• Tests are required to update the GOR at the frequency specified in
accordance with the appropriate heavy or conventional oil criterion
as well as immediately following any workover or alteration to the
producing characteristics of the well.
• Consideration should be given to using positive displacement meters
for conducting GOR tests at gas rates below 500 m3/d. Where gas
measurement is difficult because of very low rates or operational
problems, the Board may accept GORs determined by alternative
suitable means such as PVT analysis.
• The operator is required to retain records of the initial and update
GOR tests for a l-year period for verification by ERCB staff through
field inspection, production audits, or proration well test
verifications. ERCB Form S-16, Gas-Oil Ratio Test Report, is
available to assist in retention of the appropriate information.
30 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
Existing sections 14.040 and 15.140(3) of the Oil and Gas Conservation
Regulations will be amended to reflect these changes.
The Board stresses that exemption from gas measurement does not
remove the operator’s responsibility to ensure safe surface handling of
the gas production. Where an operator chooses to remove process
equipment designed to facilitate continuous measurement, ERCB
regulations and policies pertaining to the venting or flaring of gas
production must still be adhered to.
POOL-WIDE EXEMPTIONS
In situations where all or most of the wells within a pool would qualify
for gas measurement exemption, the Board encourages the operator or
operators within the pool to submit a joint application, under section
15.140(1) of the regulations, for exemption on a pool basis. These
applications provide for an appropriate review of reservoir engineering-
related matters, and are therefore still required. The Board’s
administration of Gas Exemption (GE) orders on a pool basis and
submission of associated GOR updates remain unchanged by this
informational letter.
IL 92-8: Crude Oil Pipeline Truck Terminal Measurement Guidelines
25 May 1992
TO: All Oil, Gas, and Oil Sands Operators
A significant portion of the province’s crude oil production is trucked
to pipeline terminals for disposition to market. The measurement of the
crude oil at the truck terminal is a custody transfer measurement which
determines total oil battery production. From Industry’s perspective,
this measurement represents a significant revenue point. From the
ERCB’s and Department of Energy’s perspective, this measurement
provides the total battery production which is subsequently allocated
back to individual producing wells for engineering, equity, and royalty
purposes. As a result of concerns and queries as to the quality of this
measurement, a committee comprised of Industry, ERCB and
Government representatives was formed to establish practices and
procedures for both crude oil volume and quality determination.
The Crude Oil Truck Terminal Measurement Review Committee has
developed guidelines for measurement of this product. As the ERCB is
a stakeholder in ensuring accurate truck terminal measurement the
committee believed the ERCB, through this Informational Letter, to be
the appropriate means of communicating these guidelines to the
industry. The guidelines developed by the committee are attached to
this IL.
It should be noted that these guidelines refer to the custody transfer of
pipeline quality crude oil and should not be confused with those of
ERCB Informational Letter IL 90-6 pertaining to the receipt of trucked
emulsion at proration batteries.
The scope of the committee’s work focused on light and medium crude
oils with densities ranging from 760-900 kilograms per cubic metre.
Heavy oil was not directly considered due to the comparatively small
volumes trucked to pipeline terminals, although many of the practises
and procedures may well be appropriate for heavy oil also.
The attached guidelines represent a summary of the recommendations
of the committee. Significant background work has been conducted to
support the guidelines which has not been included in the attachment. A
copy of the complete report of the committee is available for reference
by interested parties at the ERCB Library, 2nd Floor, 640 - 5th Avenue
SW, Calgary.
Effective immediately, it is expected that these guidelines be considered
and followed at all crude oil pipeline truck terminals. Deviations from
these guidelines would be appropriate only where such alternative
methods have been proven to be capable of providing equivalent or
better accuracy.
ATTACHMENT TO IL-92: GUIDELINES FOR CRUDE OIL
TRUCKER TERMINAL MEASUREMENT
The information contained within this attachment represents guidelines
and recommended practises for the quantitative measurement of light
and medium crude oils (760-900 kg/m3) at pipeline truck terminals. The
guidelines were developed by determining the level of accuracies that
could be expected using
common present technologies and then establishing practices to ensure
these accuracies are achieved.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 31
Strict consideration of accuracy is restricted to volume measurement.
Determination of basic sediment and water (BS&W) is considered to be
a qualitative matter and although reference is made to matters of
sampling and density/BS&W determination, no attempt has been made
to calculate associated accuracies or uncertainties.
It is expected that these guidelines will be used by all parties involved
in measurement of crude oil deliveries to pipeline truck terminals to
establish practises and procedures to ensure the accuracy of this
measurement.
1.0 ACCURACY REQUIREMENTS
Crude oil truck terminal measurement is a custody transfer
measurement requiring tight limits on measurement uncertainties.
Schedule 9 of the Oil and Gas Conservation Regulations specifies a
permissible error of 0.5% for total battery production, which is typically
a custody transfer measurement. It is recognized, however, that
terminals receiving smaller volumes of crude oil may warrant some
relaxation of acceptable measurement accuracy standards.
1.1 Accuracy
The following limits are recommended based on the level of production
received at a truck terminal location:
Level of Production Maximum Uncertainty
Less than 100m3/d 1.0%
Greater than 100 m3/d 0.5%
Note that locations handling less than 100m3/d currently account for
less than 5% of all production trucked to terminals.
1.2 Operating Guidelines
To achieve the recommended accuracy limits, volumetric measurement
resolution must be 0.01 m3. Positive displacement (PD) meters, weigh
scales and stationary tanks may be used to achieve 0.5% uncertainty in
accordance with these guidelines. Truck gauge measurement, however,
can only achieve 1.0% uncertainty following these guidelines.
1.3 Uncertainty Analysis
The guidelines are based on statistical uncertainty which has been
calculated using the “root-sum-square” method. While it is recognized
that there are many methods of determining statistical uncertainty, this
method was used due to its simplicity and the varying degrees of
component uncertainty. This is consistent with an accepted method
referenced in the API Manual of Petroleum Measurement Standards
(API-MPMS), Chapter 13, Statistical Aspects of Measuring and
Sampling.
The calculation of statistical uncertainties required consideration of
certain minimum accuracy or resolution capabilities of specific devices
or instruments. In all cases the instrument accuracies are achievable
through the use of standard and readily available equipment. Details of
instrument accuracies and resolutions used in uncertainty calculations
are given in Appendix 1.
2.0 VOLUME DETERMINATION
2.1 Lease Tank Gauges
To determine the net volume of crude oil in a transaction it is necessary
to gauge the tank twice (before and after an oil transfer) then determine
the difference in height. This height is converted to volume through the
use of gauge tables which have been calculated using measurements of
the tank. The temperature and density of the tank contents must then be
taken in order to correct the indicated volume to standard conditions.
During the transaction if dissimilar oils are mixed a shrinkage may
occur and any associated errors may have to be accounted for.
The following items contribute to the overall uncertainty:
• Tank strapping uncertainty
• Gauge tape uncertainty
• Gauge reading uncertainty
• Temperature reading uncertainty
• Shrinkage uncertainty due to mixing
Lease tank gauging can provide the required level of accuracy if
conducted in accordance with the following:
• Gauging must be done according to API Standard 2545, Method of
Gaging Petroleum and Petroleum Products
• Tank calibration must be performed according to API Standard 2550,
Measurement and Calibration of Upright Cylindrical Tanks, or
equivalent.
• The minimum volume that can be unloaded (Vm) is determined by
the formula
Vm = αd2 (m3)
Where d is the diameter of the tank in metres
a is the accuracy coefficient
= 0.92 for 0.5% uncertainty
= 0.39 for 1.0% uncertainty
Example: The minimum volume that can be unloaded to a common1y
used 164.9m3 (1000 bbl) tank of 6.09m diameter to meet an uncertainty
of 0.5% would be calculated as follows:
Vm = αd2
Where a = 0.92 for 0.5% uncertainty
α = 6.09m
Therefore: Vm = 0.92 (6.09)2
= 34.12m3
For comparison, the minimum volume required to be unloaded to the
same tank to achieve an uncertainty of 1.0% would be calculated as
follows:
Vm = 0.39 (6.09)2
= 14.46m3
• Errors due to shrinkage need to be accounted for according to API
Bulletin 2509C, Volumetric Shrinkage Resulting From Blending
Volatile Hydrocarbons with Crude Oils if the difference between the
density of the load and the density of the product in the tank exceeds
40 kg/m3.
32 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
2.2 Weigh Scales
Custody transfer of crude oils can be measured to within 0.5%
uncertainty using a truck weigh scale. Using larger net loads in
comparison to the truck weight, the accuracy can be further enhanced.
That is, the smaller the net weight in comparison to gross vehicle
weight, the greater the uncertainty in the measurement. Other
measurement inaccuracies can be caused by loss of weight other than
the payload. These inaccuracies can be significantly reduced by
following guidelines for good measurement practice.
The procedure for determining the volume of liquid on a truck using a
scale is to weigh the truck before and after loading or unloading and
determining the difference to obtain the net weight. To determine the
density of the load a representative sample must be obtained and the
density and temperature measured with a hydrometer and thermometer.
The observed density must then be corrected to 15°C. The net weight
determined during the weighing process divided by the sample density
results in the net volume trucked.
It is recommended that 0.5% be used as the guideline for uncertainty for
truck terminal measurement by weigh scales. The following items
contribute to the overall uncertainty:
• Scale resolution uncertainty
• Scale repeatability
• Scale calibration uncertainty
• Density uncertainty
• Hydrometer accuracy
• Observed temperature uncertainty
• Thermometer accuracy
• Sampling uncertainty
• Fuel consumption (uncertainty always positive)
The use of truck weigh scales can provide the required level of accuracy
if the following procedures are conducted:
• The weigh scale must be approved by Consumer and Corporate
Affairs Canada. Calibration of the weigh scale must be done
according to the rules and procedures set out by Consumer and
Corporate Affairs Canada.
• The only weight to be removed during loading and unloading must
be the payload. For example:
a) Scale must be clear of debris.
b) Trucks must have all debris removed prior to the first
weighing which could potentially be lost during the loading
or unloading period (ice, snow, mud).
c) The driver must be either in or out of the truck during both
weighings.
• The design of the weigh scale must be such that the truck must be
fully on the scale.
• Resolution of the final calculated truck volume must be to 0.01 cubic
metres.
• To maintain an uncertainty of 0.5% or less the net weight of the
payload must not be less than 40% of the gross vehicle weight with
the added provision that in any case the net weight must not be less
than 6500 kilograms.
• The sample used to determine the density must be representative of 1.
the entire volume being considered. The density must be determined
2.
using the equipment and procedures described in API-MPMS,
Chapter 9, Section 1, Hydrometer Test Method for Density, Relative
Density (Specific Gravity), or API Gravity of Crude Petroleum and
Liquid Petroleum Products.
3.
2.3 Truck Gauge Markers
The overall uncertainty that can be expected due to the individual
4.
uncertainties listed below is 1.0%. This should be used as the guideline
for uncertainty for terminal measurement by truck gauge marker.
Truck trailers consist of one or more compartments. Each compartment
has a hatch with a rigid steel channel extending downwards into the
liquid. Several “gauge marker” plates are bolted onto the rigid channel
at various heights and are wire sealed. The corresponding volume is
5.
stamped beside each marker.
The following items contribute to the overall uncertainty:
6.
• Tank calibration
• Liquid level
• Trailer incline
7.
• Temperature reading and associated Volume Correction Factor
(VCF)
Temperature devices must be read to within 1°C.
The difference between actual density and compensation density
must be less than 40 kg/m3. The compensation density
(mechanically-set density for ATC, user-entered density for
electronic flow computers) should be a volume weighted average.
Flow rate must be between 30% and 100% of rated flow for the
meter.
Product temperature must be between -10°C and +40°C. Where
product temperatures exceed 40°C, it may be necessary to reduce
the allowable density difference as given in item 2 to maintain a
0.5% uncertainty. In all cases, temperature compensation devices
must be designed for the actual range of operating temperatures
seen.
Proving of meters must be in accordance with the latest edition of
API-MPMS, Chapter 4, Proving Systems.
Metered volumes must be determined in accordance with API-
MPMS, Chapter 12, Section 2, Instruction for Calculating Liquid
Petroleum Quantities Measured by Turbine or Displacement
Meters.
Temperature determination must be in accordance with API-
MPMS, Chapter 7, Section 2, Dynamic Temperature
Determination.

An uncertainty of 1.0% can be obtained based on the following: 8. Measurement resolution must be 0.01m3.

• The stated depth of liquid must be within one half inch of a known
gauge marker.
• The depth of liquid must be determined while the trailer wheels are
level to within 15 cm over its length.
• The product temperature must be determined to within 1°C.
• The minimum load on the trailer must not be less than 65% of full
load.
• The truck gauge markers must initially be set by calibration to a meter
with a demonstrated uncertainty of 0.2%.
2.4 Meters
The overall uncertainty that can be expected due to normal maximum
uncertainties of the individual factors listed below is 0.5% for the type
of metering normally used for terminal measurement. This should be
used as the guideline for accuracy for terminal measurement by
metering based on the considerations listed below.
The following items contribute to the overall uncertainty:
• Meter repeatability
• Proving accuracy
• Water draw accuracy
• Maximum meter accuracy shift
• Volume Correction Factor (VCF) shift due to temperature uncertainty
• VCF shift due to density uncertainty
• Meter accuracy shift due to back pressure and viscosity fluctuations
An uncertainty of 0.5% can be achieved for truck terminal metering of
medium and light crudes. The use of positive displacement (PD) meters
will allow this accuracy with the following qualifications:
9. Turbine metering is not recommended for unloading crude oil at
truck terminals.
10. Proving should be performed at intervals frequent enough to verify
meter integrity.
The minimum equipment requirements for truck terminal metering are
as follows:
1. Air eliminator properly sized using good engineering practices
having regard for the operating conditions and maximum and
minimum flow rates of the meter.
2. Sample point to provide for obtaining a representative sample of
the metered volume.
3. Positive displacement meter complete with temperature
compensation. Temperature compensation can be achieved by
mechanical Automatic Temperature Compensators, with or without
gravity selection (ATG, ATC respectively) or through electronics
using flow computers. Where manual temperature compensation is
used, an average temperature based on an opening temperature (2-
5 minutes after the start) and a closing temperature (2-5 minutes
prior to the end) should be used.
4. Unless the prover is connected directly to the vehicle unloading
the product, a proving assembly consisting of an inlet valve, outlet
valve, and bypass valve is required. All bypass valves and any
other valve or device located between the meter and the prover that
can be a source of leakage must be designed to provide bubble
tight shutoff and must provide a method of detecting leakage (ie.
block and bleed).
5. A method of backpressure control to ensure operation above
vapour pressure of product. This can be achieved through the
existing piping configuration or the use of flow restriction devices
such as orifices or valves.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 33
6. Thermowell to provide for a temperature check. The thermo-well
must be located in close proximity to the meter.
7. Pressure indication point located downstream of the meter to check
backpressure.
3.0 QUALITY DETERMINATION
3.1 Sampling
Procedures for determining the BS&W of individual truckloads must
provide a sample or composite of several samples that will be truly
representative of the crude oil product within the truck. Two basic
sampling methods are available from API-MPMS; Chapter 8, Section 1,
Tank Sampling; and Chapter 8, Section 2, Automatic Sampling.
Automatic sampling procedures are generally preferred; however,
manual or tank sampling systems and procedures may also be
appropriate. Where automatic sampling procedures are used, a manual
procedure should also be in place to use when the automatic system is
out of service.
3.1.1Automatic Sampling
When using automatic sampling procedures, extreme care should be
taken in probe location and stream conditioning. The probe can be
installed in a horizontal run of pipe provided the flow velocity is high
enough to provide adequate turbulent mixing of the product in the
pipeline. Table 1 of API-MPMS; Chapter 8, Section 2 should be used
as a guideline to determine what flow velocity is required to provide a
good concentrated mix from the bottom to the top of the pipe.
Mounting the sampler probe in the mid-pipe location should provide an
average concentration that will be representative of the entire stream at
the sampling point.
Where adequate flow velocity is not available a suitable device for
mixing fluid flow should be installed upstream of the sampling point.
Mixing can be accomplished with lengths of reduced diameter piping,
valves, elbows, tees, or other piping disturbances. A static mixer may
also be used for mixing.
The preferred probe location is on a vertical line with adequate
upstream mixing. Given a choice between vertical and horizontal lines
with other conditions held constant, locate the automatic sampler probe
in the vertical lines. The sampling point should be as near as is
practicable to the truck unloading connection on the meter run.
Additional guidelines that should be followed when using an automatic
sampling system are described as follows:
• Plastic bottles made of suitable material for handling and storage of
crude oils should be used. Screw tops providing a good vapour-tight
seal shall be used. All sample containers must be clean and dry when
installed. Sample bottles should not be completely filled and should
allow adequate room for expansion, taking into consideration the
temperature of the liquid at the time of filling. Adequate sample
mixing is difficult if the container is more than 75 percent full.
• The sample containers should be housed in a heated enclosure and
locked to prevent any tampering with the composite sample.
• The sample lines should be as short as practical and sloped
downward to reduce the possibility of plugging up the sample line.
• The minimum size of representative sample should be one milli-litre
per cubic metre. The volume in the composite sample container
should be no less than two litres in size, which is the minimum
quantity required to do an analysis for the sample.
34 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
• Care should be taken when removing the composite sample container
so as not to have any spillage which could destroy the value of the
composite sample.
• The sample container should be thoroughly mixed before pouring any
product out of the container to do an analysis. A very important step
in any analysis is to ensure the crude oil from the sample container is
representative of the crude oil obtained from the unloading line.
3.1.2Manual/Tank Sampling
Manual sampling procedures may involve obtaining thief samples from
the truck tank prior to unloading or grab samples taken from the truck
during the loading or unloading process. Tank samples may not be
representative because:
• the concentration of entrained water is higher near the bottom,
• the interface between oil and free water is difficult to measure,
especially with a wax build up in the tank, or
• the determination of the volume of free water is difficult because the
level of free water may vary across the tank bottom due to a build up
of wax in the tank.
Manual sampling procedures can be acceptable, however, where the
product in the truckload is of a consistent quality either through mixing
or due to the nature of the crude oil product. Alternatively, manual
sampling can be acceptable by ensuring the number or frequency of
samples obtained are sufficiently high to provide an accurate
representation of the entire truckload.
3.2 BS&W Determination
The recommended procedure for determination of BS&W in crude oil is
the centrifuge method as described in API - MPMS; Chapter 10,
Section 4, Determination of Sediment and Water in Crude Oil by the
Centrifuge Method (Field Procedure).
This method is considered the most practical for field determination of
sediment and water. However, for the purpose of these guidelines, the
following exceptions to the API procedure are appropriate:
• Toluene and Xylene (refer to API-MPMS; Chapter 10, Section
4.5.2.1) If consent is obtained from all parties involved, water
saturated solvent at 20°C (room temperature) may be used to test
crude oils heated to 60 to 70°C.
• Centrifuge (refer to API-MPMS; Chapter 10, Section 4.7.1) The
centrifuge does not have to be heated as long as the sample maintains
the minimum temperature of 52°C (125°F) for the five minute test.
• Centrifuge Tubes (refer to API-MPMS; Chapter 10, Section 4.7.2.1)
If consent is obtained from all parties involved, existing pear jars may
be used, but any new installations shall use the cone-shaped tubes
that are 167 mm (6”) or 203 mm (8”) in length.
• Test Conditions (refer to API-MPMS; Section 10, Section 4.10.5) If
consent is obtained from all parties involved, the specified report of
deviations from the procedure is not required.
3.3 Density Determination
Density of the load may be determined by either of the following
methods:
1. Samples may be collected from the receiving point and sent to an
independent laboratory for analysis to determine density. The density
found on this analysis would be applied to all crude oil coming from
 this specific well or lease. Lab tests to determine density would be • Gauge Tapes
conducted on a yearly basis minimum or more frequently as reservoir
– accurate to within +/- mm (1/32 inch)
conditions warrant. Sample containers must be sealed to prevent a
loss of light ends from the sample between the time of sampling and – read to within +/- 3 mm (1/8 inch)
analysis.
Note that the metric values here represent approximate conversions
2. Truck load samples or samples from automatic samplers may be from the Imperial units published in API Standard 2545. Using a metric
tested for density as outlined in API-MPMS; Chapter 9, Section 1, gauge tape, it is expected that the tape be read to the nearest millimetre.
Hydrometer Test Method for Density, Relative Density (Specific
Gravity), or API Gravity of Crude Petroleum and Liquid Petroleum • Thermometers
Products. If consent is obtained by all parties involved, the use of a – accurate to within +/-0.1°C
thermohydrometer is acceptable.
– read to within +/- 1°C

APPENDIX 1—INSTRUMENT RESOLUTIONS AND • Hydrometers

UNCERTAINTIES USED IN CALCULATING OVERALL – accurate to within +/-0.3 kg/m3
UNCERTAINTIES – read to within +/-1 kg/m3
The following lists details of specific instrument and device accuracies
and resolutions used in the calculation of overall uncertainties for truck • Weigh Scales
terminal measurement. – resolution of +/- 10 kg
– repeatability of 0.1% of load

• PD Meters
– repeatability of 0.1%

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 35
IL 92-13: Well Name Requirements
6 November 1992
To: All Oil and Gas Operators
INTRODUCTION
The Energy Resources Conservation Board (the
Board) will be amending sections 2.050, 13.010,
13.020, and 17.010 of the Oil and Gas
Conservation Regulations (the Regulations) with
respect to the administration of well names.
These amendments are in response to concerns
raised by industry regarding well name
administration and the need to simplify the
application requirements and process. The Board
has discussed and reviewed the changes with the
Canadian Petroleum Association and the
Independent Petroleum Association of Canada
(Canadian Association of Petroleum Producers),
the Small Explorers and Producers Association of
Canada, and the Canadian Association of
Petroleum Landmen.
BACKGROUND
Historically, an individual well name was
established as part of the well licensing
process in accordance with the specifications
outlined in section 13.020 of the Regulations.
This well name then became part of the file in
the Board’s data systems and the requirement to
keep the well name current was set out in
section 13.010. The contents of the well name
were based on section 13.020 of the Regulations.
The well name has traditionally been used by
industry and others to identify ownership of the
well; however, this was not the intended usage.
Additionally, a well’s purpose was often gleaned
out of a well name. Again, although it was not
an intended use, the well name has also been
utilized by industry to identify hard copy data
submitted to the ERCB. The preferred or expected
identification should have been in the form of
the unique well identifier or the well licence
number.
As it was not practical to eliminate well names,
a simpler approach to the functionality and
maintenance of this data element was required.
Since the unique well identifier and well
licence number are the most accurate means of
identifying a well, the Board believes that the
usage and maintenance of well names needs to be
de-emphasized. This belief was confirmed through
review and discussion with the above mentioned
industry associations.
The changes to the Regulation will make well
name changes optional and to be done primarily
at the licensee’s discretion. Additionally, the
permitted/required contents of well names will
be reduced.
36 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
REGULATION CHANGES
The initial creation of a well name and any
changes by the licensee thereafter, will be
administered as follows:
• The length of the well name shall not exceed 36 characters and
spaces.
• A well name shall consist of four components placed in the
following order:
1. The licensee name by approved
abbreviation.
2. An open space for the applicant’s use.
3. The Board designated field containing the
well location or approved abbreviation of
the field, or where the well location is
not contained in or adjacent to a
designated field, the name of the strike
area or approved abbreviation.
4. The legal subdivision, section, township,
and range in which the bottom hole of the
well is located.
• The use of alpha designations in the location or prefixed to the
location as presently set out in section 13.020 of the Regulations
will be discontinued. No two well names will be allowed to be the
same. The Board will no longer require the maintenance of a well
name subsequent to its initial creation. Should the licensee wish to
change a well name after its initial creation, the normal application
requirements and fees will still apply.
SUMMARY
Industry co-operation is required to ensure that
all well correspondence and data filed with the
Board clearly contains the unique well
identifier and/or well licence number. Data
containing only a well name may be returned for
proper identification.
These changes are effective immediately and
amendments to the Regulations will be
forthcoming. All future well licence
applications shall adhere to the new well naming
conventions.
If there are any questions regarding these
changes, please contact the Board’s Well
Licensing Section at 297-3700 or 297-8554.
IL 93-1: Gas Density Measurement Frequency—Orifice Meters
12 February 1993
TO: All Oil and Gas Operators
All In Situ Oil Sands/Heavy Oil
Operators
GAS DENSITY MEASUREMENT FREQUENCY—
ORIFICE METERS
Section 14.070 (8.1) of the Oil and Gas
Conservation Regulations currently stipulates
that gas density factors used to compute gas
production from a well or group of wells be
determined by correlation tables or by semi-
annual measurements of gas density. Gas density
factors are an integral component of orifice
meter gas volume calculations and the accuracy
of the computed volume is very sensitive to the
accuracy of the gas density. The correlation
tables referenced have not been updated for some
time and are very seldom used. In addition, ERCB
field inspections indicate that semi-annual gas
density determinations are not being
consistently conducted by operators and that a
wide variety of philosophies and procedures
respecting gas density measurements exist
throughout industry. Accordingly, the Board has
reviewed its policy respecting these
measurements with the intent of providing
industry with practical requirements for density
determination while also providing for accurate
gas measurement.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 37
With this as background, the Board has decided
to establish minimum requirements for the
frequency of gas density measurements based on
the nature of the gas production and the volume
produced through the meter. Frequencies range
from semi-annual measurements where gas
compositions are changing rapidly (e.g. gas
cycling or miscible flood schemes) to once every
two years where the gas is dry and consistent in
composition. Extended frequencies in some cases
are also considered appropriate where production
rates are low (less than or equal to 16.9
thousand cubic metres per day). Provision has
also been made for permanent exemption from
density measurements where a history of
consistent densities exist.
Therefore, effective immediately, the density
factor used to compute the gas production from a
well or group of wells shall be determined in
accordance with the frequency schedule outlined
in ERCB Guide G-49 Gas Density Measurement
Frequency. A summary of the frequency schedule
is attached. For further details and elaboration
of exemption criteria, operators are encouraged
to reference Guide G-49, available through the
ERCB Information Services Section for a fee of
$10.
Section 14.070(8.1) will be amended to remove
reference to the correlation tables and semi-
annual measurements and to make reference to
Guide G-49.
(See Attachment to IL 93–1 on next page)
IL 93-9: Oil and Gas Developments Eastern Slopes (Southern Portion)
13 December 1993
TO: All Oil and Gas Operators
OIL AND GAS DEVELOPMENTS EASTERN SLOPES
(SOUTHERN PORTION)
This informational letter (IL) was developed by
the Energy Resources Conservation Board (ERCB)
to confirm to all oil and gas operators the
information required for developments along the
southern portions of Alberta’s Eastern Slopes.
These requirements have already been
communicated by ERCB staff directly to some
companies with active development plans in this
region. This IL is intended to ensure a common
understanding of ERCB requirements exists among
any other potential operators in this area, as
well as other potentially affected parties.
THE KEY POINTS OF THE IL ARE:
Any company intending to develop a project in
the region is expected to carry out a thorough
and effective public consultation program
consistent with the sensitivity of the area
proposed for development. The program should
document both issues identified and resolved.
At each stage of development (i.e. initial pool
delineation, subsequent delineation, pool
development) a potential operator will provide,
in as much detail as practical, its best
estimate of the overall extent of development.
This is required in order to avoid piecemeal
proposals and to ensure that the overall scope
and potential impacts of the development, if
permitted, are clearly understood.
• Applicants will be required to carry out
environmental assessments for each proposed
development stage. These environmental
assessments will be of sufficient detail to
allow the Board to determine whether the
project’s economic benefits and mitigation
programs sufficiently outweigh any remaining
social and environmental costs (i.e. that the
project is in the overall public interest).
The level of detail expected in any
environmental assessment will vary with
project stage, the ultimate scope of
development, the relative sensitivity of the
proposed development area, and the extent of
other existing and potential developments
(both energy and non-energy related) in the
area.
• Operators proposing developments within this
region are expected to consolidate their plans
and activities with other operators to the
greatest degree practical wherever this may
reduce area impacts.
The ERCB is of the view that this approach to
the planning of new developments within the
Alberta Eastern Slopes will be of benefit to
operators, directly-affected parties, and to the
general public. Ultimately, it is expected that
this program of public consultation, project
pre-planning, environmental assessment, and
coordination of corporate activities will
38 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
significantly help to ensure that, should
developments proceed with the Eastern Slopes,
they will occur in a manner which best meets the
interests of all Albertans.
INTRODUCTION
The Eastern Slopes region of Alberta,
particularly from Highway #l south to the United
States border (Figure l) has the potential for
significant oil and gas exploration,
development, and production activity. At the
outset, it must be acknowledged that the
environmental sensitivities of localized areas
within the region defined by Figure 1 are highly
variable. As a general guideline this IL applies
to undeveloped or minimally-developed areas;
however, circumstances may exist such that the
expectations are appropriate for certain
developed areas also. Initial consultation with
ERCB staff and other stakeholders would assist
in determining the applicability of this IL to a
given area.
The Board recognizes that this IL presents a
broader regulatory approach to oil and gas
development in the Eastern Slopes which is still
evolving. For this reason the ERCB considers
this IL as an interim document, and is prepared
to revise it as circumstances
warrant.
BACKGROUND
Following the posting and subsequent sale of
mineral leases for several large parcels of land
in the southern portion of the Eastern Slopes,
various interest groups and individuals raised
concerns about the possible impacts of the
potential development. These mineral leases were
reviewed by the Crown Mineral Disposition Review
Committee (CMDRC) prior to posting and sale by
the Alberta Department of Energy (AE).
The CMDRC is chaired by the Land Reclamation
Division of Alberta Environmental Protection
(AEP) and includes representation or available
advice from all departments, agencies and boards
which have a direct interest in land use,
resource development and utilization, and
protection of the environment and the natural
resources of the province. It reviews each
parcel requested for posting to determine
whether surface access is possible and, if so,
whether access restrictions are necessary.
Surface access may be unrestricted (except for
specific requirements under existing
legislation), subject to additional restrictions
such as increased setbacks from valley breaks,
limited to specific time frames to protect
wildlife, or may be prohibited. This committee
follows the resource management policies and
guidelines contained in the cabinet-approved
Integrated Resource Plans (IRPs) and forwards
its requirements to AE, also a CMDRC member, for
inclusion in the postings.
The ERCB is responsible for the licensing of oil
and gas wells in Alberta. As a part of that
responsibility, the ERCB must ensure that
exploration and development drilling, as well as
subsequent production operations in a given (b) an analysis of baseline environmental
area, are appropriate and in the public interest conditions and major areas of concern;
and that environmental impacts are acceptable.
(c) a description and analysis of the
significance of environmental, economic, and
cultural impacts including regional, temporal,
GENERAL EXPECTATIONS and cumulative effects;
This phase should include baseline environmental (d) options and plans to mitigate these
information for the impacted area of the impacts, including reasons why they should or
potential development. This information, should not be implemented;
referred to as an “ environmental assessment” ,
would be intended to assess specific (e) plans to monitor predicted impacts and
sensitivities of a given area to evaluate the success of mitigation measures;
whether or not development is indeed appropriate (f) emergency response plans and contingency
within that area. plans to deal with unpredicted impacts;
2 Pool Delineation (subsequent)— Recognizing (g) description and results of initial public
that further delineation needs may result consultation programs and details of any
from initial development (should this future programs proposed; and
proceed), a subsequent delineation plan may
be necessary. Should this be the case, the
ERCB expects composite plans rather than
single-well proposals and more definite plans
for mitigation of impacts from drilling,
production, and testing operations (e.g.
pads, innovative testing methods).
Elaboration of pipeline/facility proposals
would be expected also. Delineation proposals
are to include well locations and associated
drilling and waste management aspects,
access, and test/short-term production
scenarios.
3. Pool Development— Upon delineation, a pool
development plan encompassing all facilities,
pipelines, and associated infrastructures
would be expected. The overall objective
would be to minimize the intrusion and to
mitigate the impacts wherever possible.
The Board accepts that initial and subsequent
delineation phases would typically provide only
conceptual future plans which are subject to
revision depending on drilling and testing
results. Each phase is subject to a separate
application and, if appropriate, public hearing
process. It is therefore intended that the
initial delineation phase establish whether
development in the area is appropriate and, if
so, what issues must be addressed in subsequent
development phases. The application process for
subsequent phases then provides for assurance
that previously-defined issues are properly
addressed, and also provides for review of new
issues.
• Environmental Assessments— The oil and gas
well developments currently proposed for the
Eastern Slopes region are set out in Part 2,
Division 1 of the AEP Environmental Protection
and Enforcement Act (EPEA) as activities for
which an environmental impact assessment is
not required by AEP. Notwithstanding, the ERCB
will require proponents to file quality
environmental data to properly assess the
overall benefit/cost of these proposals.
Applicants will be requested to provide to the
ERCB a thorough “ environmental assessment”
which includes, but is not limited to, the
following information:
(a) an analysis of surface site and access
road selection and construction procedures;

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 39
(h) plans to minimize accidental substance
release to the environment and to minimize
waste.
The aforementioned represents areas that the
ERCB believes necessary to assess the overall
impacts of a proposed development. The ERCB
believes, however, that the level of detail to
which this information can or should be provided
will vary depending on the phase of development
being proposed. For example, requiring a full,
comprehensive environmental assessment may not
be reasonable or even necessary during the
exploratory or “ initial delineation” phases of
a project.
It may still be necessary, however, to conduct
sufficient environmental baseline analyses to
determine what specific sensitivities exist and
also to determine whether some form of
development is appropriate within the project
area. At the point where the potential for full
field development is more clearly defined, by
comparison, comprehensive attention to the full
range of environmental assessment criteria may
be warranted. It is also recognized that the
environmental sensitivities of regions within
the Eastern Slopes are variable, and it is
reasonable to expect that the level of detail of
the environmental assessment information be
consistent with the sensitivity of the area
proposed for development. That is to say that
for areas of lower sensitivity, an overview
assessment may suffice, compared to an area of
high sensitivity where thorough treatment of all
environmental assessment criteria would be
appropriate. As a rule areas that have had
little or no intrusions will be considered to be
more sensitive.
In any event, the ERCB will expect the applicant
to identify the sensitivity of the area and
matters of potential impact early in this
process and to discuss these with both
government and the public to ensure the final
application deals with all relevant issues, and
in the appropriate level of detail to allow the
Board to consider the applications.
• Consolidated Plans Amongst Operators—
Operators proposing developments within the
Eastern Slopes area would be expected to
consolidate efforts, to whatever degree
possible, involving sharing seismic or
reservoir-test data, pooling efforts and
resources, and use of common roads, pipeline
and utility right-of-ways, and general
infrastructure with efforts aimed at
minimizing surface impacts and disturbances.
The ERCB’s objective in documenting these
expectations is to ensure sufficient information
is available to make informed decisions that are
in the public interest. Given the level of
public interest, the Board has assigned staff to
assist with and aid in coordination of the
process, particularly when discussing
applications under the jurisdiction of the ERCB.
Notwithstanding these resources, the ERCB
reiterates that it relies on the proponents of
the developments to take the lead role in
identifying issues, contacting interested and
affected parties, and resolving issues where
possible.

40 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
IL 93-10: Revised Measurement and Accounting Procedures for Southeastern Alberta Shallow Gas
Wells
20 December 1993
TO: All Southeastern Alberta Shallow Gas Operators
REVISED MEASUREMENT AND ACCOUNTING
PROCEDURES FOR SOUTHEASTERN ALBERTA
SHALLOW GAS WELLS
Informational letter IL 91-7, issued in September 1991, updated and
reduced testing and reporting requirements for Southeastern Alberta
shallow gas wells. These changes recognized the unique nature of the
production from the Medicine Hat, Milk River, and Second White
Specks shallow gas pools in Southeastern Alberta. Since that time,
General Bulletin GB 93-6, issued 31 March 1993, eliminated the
control well program which was no longer necessary for reservoir
management purposes.
The Energy Resources Conservation Board (ERCB) continued to
review the measurement and accounting procedures in this area and
have identified further opportunities to reduce regulatory requirements
while maintaining appropriate operational and reporting practices. The
recent changes are now being consolidated into this IL, which
supersedes IL 91-7.
The key revisions are:
• removal of area size limitations for a Southeastern Alberta shallow
gas well proration battery,
• establishment of operational criteria for determining battery size, and
• removal of mandatory use of the ERCB deliverability equation for
test gas volume adjustments.
In addition, the ERCB has established procedures which should ensure
that a simplified transition occurs between the previous requirements
and the new ones. These include the following:
• conversion of existing proration batteries to the new sizing criteria,
and
• automatic conversion of the ERCB production data base for control
wells from measured to prorated status.
The following sections discuss the changes in more detail and also
identify those requirements that remain unchanged from the IL 91-7.
QUALIFIED WELLS
Gas wells which produce from the Medicine Hat, Milk River,
or Second White Specks pools or which have commingled production
from any two or more of these pools and are located in fields
and areas specified in Schedule I of Board Order No. MU804,
as amended, are qualified to be included in a gas well proration
battery. Commingling of production without segregation in the
wellbore continues to require approval by the ERCB’s Gas Department.
MEASUREMENT OF GROUP PRODUCTION
The total gas production of a proration battery must be accurately and
continuously measured. Any variance from this requirement, such as
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 41
utilizing the difference between two or more meters, requires written
approval from the ERCB.
SIZE OF A GAS WELL PRORATION BATTERY
There is no longer any specific size limit for shallow gas proration
batteries. The appropriate size must be considered in terms of a
gathering system’s operation with the key factor being the ability to
conduct the deliverability tests in a manner that treats each well in a
battery equitably. This approach will generally result in the main
pipeline system laterals being used to establish a group measurement
point.
TESTING REQUIREMENTS
Each individual well must have a deliverability test conducted at least
once per calendar year, subject to the following requirements being met.
If these requirements cannot be satisfied, the operator must either
reconfigure the system or test each of the individual wells within the
battery once per month.
• The test must be of sufficient duration to clearly establish a stabilized
flow rate.
• The test must be representative of the well’s capability under normal
operating conditions.
• Testing programs must ensure that all wells are treated equitably
within their respective batteries. In particular, the ERCB would
expect an operator to test a well as soon as practical after being tied
in, and at least monthly until the production rate has stabilized.
GAS REPORTING REQUIREMENTS
The gas well production must be determined and reported as outlined in
ERCB Guide G-7, Production Accounting Handbook. If gas is vented
during well blowdowns it must be accounted for and included with the
prorated production of each well. The use of the ERCB deliverability
equation is no longer mandatory; however, any adjustments to test gas
rates prior to proration must be applied to all wells in a consistent
manner.
WATER REPORTING REQUIREMENTS
The ERCB will continue to waive the reporting of water production for
the qualified wells. However, the ERCB is concerned about the
potential for environmental damage which can result from using earthen
pits for water disposal or blowing down to the well-site surface, and is
currently reviewing this practice.
If an operator is currently blowing a well to surface or using a pit, a
water production rate test must be completed annually and a permanent
record of the following Information retained on file and made available
to the ERCB’s staff upon request:
• the location of all surface pits and well-site surfaces utilized for
disposal;
• a record of the volume of water produced into each pit or onto each
well-site surface;
• the details of the annual well water production rate test;
• an analysis of the produced water, which must contain these
parameters: TDS, pH, specific conductivity, boron, and major ions
(Ca, Mg, Na, K, Cl, S04, HC03, C03, OH).
Under no circumstances may the volume of water disposed to an CONVERSION OF EXISTING PRORATION BATTERY SIZE
earthen pit or onto a well-site surface exceed 15 cubic metres per
Operators may merge existing proration batteries to meet the new sizing
month.
criteria by submitting a request letter and two copies of a gathering
TRANSITION METHODS system map, which indicates the proposed modifications and
consolidations, along with a table showing battery codes which are to
Conversion of Existing Control Wells
be deleted and battery codes which are to be retained.
The conversion of control wells to prorated wells will not require an S-
7 submission to change the well testing frequency from measured to
prorated as would normally be required. Board staff made a one time
system change on 15 April 1993. However, commingling of segregated
zones must receive prior approval from the ERCB’s Gas Department.

42 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
IL 94-6: Discharge of Produced Liquids to Earthen Structures
24 March 1994
TO: All Oil and Gas Operators
DISCHARGE OF PRODUCED LIQUIDS TO EARTHEN
STRUCTURES: NOTICE OF INTENTION TO AMEND
EXISTING REGULATIONS
As of 31 December 1996, oil and gas operators will no longer be
permitted to place or store produced liquids into earthen pits or
structures. Produced fluids are considered to include crude bitumen,
liquid hydrocarbons, process chemicals, and water produced from oil
wells, gas wells, and associated batteries and other similar facilities
regulated by the ERCB. To accomplish this, the ERCB intends to
amend sections 8.010, 8.020, and 8.040 of the Oil and Gas
Conservation Regulations (Appendix A).
These changes are intended to help ensure that oil and gas
developments do not result in contaminated soils or groundwater. Pits
and other earthen structures containing produced liquids are found to
present a significant risk of such contamination. Operators who
discover such contamination in the course of meeting these regulations
must modify their existing facilities to prevent ongoing contamination
and to initiate remediation appropriate to the level of environmental
risk.
For a description of current acceptable approaches to the storage and
disposal of produced fluids, operators should refer to ERCB
Informational Letter IL 93-8 and the ERCB’s 1993 draft
“Recommended Oilfield Waste Management Requirements”. Earthen
structures, if properly designed, will continue to be acceptable for
purposes such as fire-walls, run-on and run-off control, and emergency
containment (eg. tank dyking).
Flare pits will also continue to be acceptable, provided that there is
virtually no probability of produced liquids entering the pit. This can be
accomplished through both good design (eg. flare knock-outs, oversized
separators) and good operating practices. Because of the inherent risk of
contamination, the Board would expect operators to consider various
alternatives before selecting a flare pit.
It should be noted that the amended regulations will not apply to:
• oil and gas facilities where produced liquid storage is approved by
Alberta Environmental Protection,
• drilling sumps (see ID 93-1 and Guide G-50 for these requirements),
and
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 43
• shallow gas wells in southeastern Alberta (see IL 93-10 for these
locations and associated requirements).
Should oil and gas operators continue to have concerns or questions as
to how and when the Board intends to enforce these amended
regulations, they are encouraged to contact the ERCB’s Environment
Protection Department.
APPENDIX A: INTENDED AMENDMENTS TO THE OIL AND
GAS CONSERVATION REGULATIONS
Effective 31 December 1996, the Energy Resources Conservation
Board will amend the Oil and Gas Conservation Regulations as follows:
Oil and Gas Conservation Amendment Regulation
1. The Oil and Gas Conservation Regulations (Alberta Regulation
151/71) are amended by this Regulation.
2. Section 8.010 is repealed and the following is substituted:
8.010—Earthen structures or excavations shall not be used as
receptacles for crude bitumen, liquid hydrocarbon, process chemicals,
or water produced from a well or associated facility either by design or
normal operating practice without the written approval of the Board.
3. Section 8.020 is repealed. Amendments to section 8.010 now make
this section redundant.
4. Section 8.040 is repealed and the following is substituted:
8.040(1) The licensee of a well or the operator of a battery or
processing plant or associated facility shall store and dispose
of all water produced from a well in a matter satisfactory to
the Board.
(2) No water produced from a well shall be discharged into an
earthen structure or excavation either by design or normal
operating practice without the written approval of the Board.
(3) All water produced to a battery, or produced at a well not
connected to a battery, or produced at a processing plant, shall
be disposed of in accordance with a scheme approved by the
Board pursuant to section 26 of the Act.
IL 94-17: Notification of Pipeline Project to Conservation and Reclamation (C & R) Inspectors of
Alberta Environmental Protection
Stony Plain AB T7Z 1N4
7 September 1994 Phone: 963-5351

TO: All Oil, Gas, and Pipeline Operators Westlock Office

10003 - 100 Street
Provincial Building
NOTIFICATION OF PIPELINE PROJECT TO CONSERVATION Westlock AB TOG 2LO
AND RECLAMATION (C & R) INSPECTORS OF ALBERTA Phone: 349-3445
ENVIRONMENTAL PROTECTION
St. Paul Office
Alberta Environmental Protection administers the Environmental Box 308
Protection and Enhancement Act (EPEA). Therefore, Alberta 3rd Floor, 5025 - 49 Avenue
Environmental Protection is a directly affected party in any pipeline St. Paul AB TOA 3A4
application to the Energy Resources Conservation Board (ERCB). To Phone: 645-6394
avoid a delay in the approval of a pipeline application, the ERCB and
Alberta Environmental Protection require the proponent to discuss
conservation and reclamation procedures with the regional Wainwright Office
Conservation and Reclamation Inspector early in the planning stage of Box 2169
any new pipeline project (Land Reclamation Division on patented land, 810 - 14 Avenue
Land and Forest inspectors on public land in the Green Area, and Wainwright AB TOB 4PO
Agriculture, Food and Rural Development inspectors on public land in Phone: 842-7535
the White Area). This requirement applies to all pipelines under the
Pipeline Act and the EPEA. The results of the discussion with the Camrose Office
Conservation and Reclamation Inspector should be included in the 2nd Floor, Room 203
pipeline permit application to the ERCB. 4867 - 50 Street
Camrose AB T4V IT6
A list of the regional Conservation and Reclamation Offices is enclosed. Phone: 679-1274
Alberta Environmental Protection has the following publications
available from the Land Reclamation Division at 427-6323: SOUTHERN REGION
Red Deer Office
1. Environmental Protection Guidelines for Pipelines. 3rd Floor, 4920 - 51 Street
2. Guide for Pipelines Pursuant to the Environmental Protection and Red Deer AB T4N 6K8
Enhancement Act and Regulations. Phone: 340-7741

3. Environmental Handbook for Pipeline Construction. Hanna Office

Box 1088
Should you have questions regarding this Informational Letter, please
Centre Street
call the Land Reclamation Division (Alberta Environmental Protection)
Hanna AB TOJ IPO
at 427-6323 or the Pipeline Department (ERCB) at 297-8135.
Phone: 854-5579

ATTACHMENT 1: OFFICES FOR NON-PUBLIC LAND Calgary Office

(Alberta Environmental Protection, Land Reclamation Division, Field 2nd Floor, Deerfoot Square
Services Branch) 2938 - 11 Street NE
Calgary AB T2E 7L7
NORTHERN REGION Phone: 297-8295

Peace River Office Lethbridge Office

Bag 900, Box 5 200 - 5 Avenue S
2nd Floor, 9621 - 96A Avenue Lethbridge AB T1J 4C7
Peace River AB T8S IT4 Phone: 381-5491
Phone: 624-6333

Grande Prairie Office

2nd Floor, Room 2001
10320 - 99 Street
Grande Prairie AB T8V 6J4 Medicine Hat Office
Phone: 538-5459 Room 204
346 - 3 Street SE
Stony Plain Office Medicine Hat AB TlA OG7
2nd Floor, 4709 - 44 Avenue Phone: 529-3685

44 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
 WHITECOURT FOREST
Whitecourt Office
ATTACHMENT 2: OFFICES FOR PUBLIC LAND 4004 - 47 Street
IN THE GREEN AREA Whitecourt AB T7S lM8
(Alberta Environmental Protection, Land and Forest Services) Phone: 778-7153

ATHABASCA FOREST
Fort McMurray Office ATTACHMENT 3: OFFICES FOR PUBLIC LAND
168 Airport Road IN THE WHITE AREA
Fort McMurray AB T9H 4Pl (Alberta Agriculture, Food and Rural Development, Rural Development
Phone: 743-7124 Division)

BOW/CROW FOREST PEACE RIVER REGION

Calgary Office Fairview Office
8660 Bearspaw Dam Road NW Box 159
Box 70028 Provincial Building
Bowness Postal Outlet Fairview AB TOH ILO
Calgary AB T3B 5K3 Phone: 835-2209
Phone: 297-8800
Grande Prairie Office
EDSON FOREST Box 24, Room 3001
Edson Office Provincial Building
203, 111 - 54 Street 10320 - 99 Street
Edson AB T7E 1T2 Grande Prairie AB T8V 6J4
Phone: 723-8269 Phone: 538-5260

FOOTNER LAKE FOREST High Level Office

High Level Office Box 127
Bag 900 Provincial Building
High Level AB TOH IZO High Level AB TOH 1ZO
Phone: 926-3761 Phone: 926-3512

GRANDE PRAIRIE FOREST High Prairie Office

Grande Prairie Office Box 1380
10811 -84 Avenue Provincial Building
Grande Prairie AB T8V 3J2 High Prairie AB TOG 1EO
Phone: 538-8080 Phone: 523-6580

LAC LA BICHE FOREST Peace River Office

Lac La Biche Office Bag 900, Box 35
Provincial Building Provincial Building
Box 450 Peace River AB TOH 2XO
Lac La Biche AB TOA 2CO Phone: 624-6116
Phone: 623-5240
Spirit River Office
PEACE RIVER FOREST Box 579
Peace River Office M & J Building
Postal Bag 900-39 Spirit River AB TOH 3GO
Peace River AB T8S IT4 Phone: 864-3574
Phone: 624-6221

ROCKY/CLEARWATER FOREST
Rocky Mountain House Office
Box 1720
Rocky Mountain House AB TOM ITO Valleyview Office
Phone: 845-8211 Box 1470
SLAVE LAKE FOREST Provincial Building
Slave Lake Office Valleyview AB TOH 3NO
301 Birch Road NE Phone: 524-5522
Box 390
Slave Lake AB TOG 2AO NORTHEAST REGION
Phone: 849-3061 Bonnyville Office
Box 6009

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 45
Bonnyville AB T9N 2G4 Sherwood Park Office
Phone: 826-4297 182 Chippewa Road
Sherwood Park AB T8A 4H5
Lac La Biche Office Phone: 464-7955
Box 839
Provincial Building
Lac La Biche AB TOA 2CO CENTRAL REGION
Phone: 623-5279 Calgary Office
Main Floor
St. Paul Office 703 - 6 Avenue SW
Box 1959 Calgary AB T7P OT9
4916 -51 Avenue Phone: 297-6426
St. Paul AB TOA 3AO
Phone: 645-6336 Ponoka Office
Box 4304
Wainwright Office Provincial Building
Box 516 Ponoka AB T4J IR7
810 -14 Avenue Phone: 783-7090
Wainwright AB TOB 4PO
Phone: 842-7548 Red Deer Office
Room 504
NORTHWEST REGION First Red Deer Place
4911 - 51 Street
Athabasca Office Red Deer AB T4N 6V4
Box 660 Phone: 340-5451
Athabasca AB TOG OBO
Phone: 675-4277 Rocky Mountain House Office
P. 0. Box 1590
Barrhead East Office Provincial Building
Box 1660 4919 - 51 Street
6203 - 49 Street Rocky Mountain House AB TOM 1TO
Barrhead AB TOG OEO Phone: 845-8242
Phone: 674-8231
SOUTH REGION
Drayton Valley Lethbridge Office
Box 6411 2nd Floor, Sun Centre
Fidelis Building 530 - 8 Street South
Drayton Valley AB TOE OMO Lethbridge AB TIJ 2J8
Phone: 542-3537 Phone: 381-5487

Evansburg Office Medicine Hat Office

Box 360 Room 106
Dieckman Building Provincial Building
Evansburg AB T0E 0T0 346 - 3 Street SE
Phone: 727-3673 Medicine Hat AB TlA OG7
Phone: 529-3677

46 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
IL 98-2: Suspension, Abandonment, Decontamination, and Surface Land Reclamation
of Upstream Oil and Gas Facilities
26 March 1998
TO: All Oil, Gas, Oil Sands, and Pipeline Operators
SUSPENSION, ABANDONMENT,
DECONTAMINATION, AND SURFACE LAND
RECLAMATION OF UPSTREAM OIL AND GAS
FACILITIES
This document supersedes Informational Letter 96-3, which
is hereby rescinded.
Alberta Environmental Protection (AEP) and the Alberta
Energy and Utilities Board (EUB) have reached agreement
which further clarifies their responsibilities for the
regulation of the suspension, abandonment,
decontamination, and surface land reclamation activities at
upstream oil and gas facilities. This agreement is set out in
the attached Memorandum of Understanding (MOU) which
is intended to clarify the jurisdictional roles of AEP and the
EUB to reduce regulatory duplication and enhance
protection of the environment and the public interest.
The MOU will alter the way in which the industry, EUB,
and AEP have interacted previously in the area of site
decontamination. In the future, oil and gas companies may
have more interaction with AEP during the
decontamination process. The EUB will continue to focus
greater efforts on the prevention of contamination and the
timely suspension and abandonment of non-economic
facilities.
Questions regarding the MOU should be directed to the
appropriate contacts shown in Section 8 of the attached
MOU.
Céline Bélanger J. R. Nichols
Chair Deputy Minister
Alberta Energy and Utilities Board Alberta
Environmental Protection
Attachment
46 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
MEMORANDUM OF UNDERSTANDING BETWEEN
AEP AND EUB ON SUSPENSION,
ABANDONMENT, DECONTAMINATION, AND
SURFACE LAND RECLAMATION
OF UPSTREAM OIL AND GAS FACILITIES
26 March 1998
1 ABOUT THIS DOCUMENT
This Memorandum of Understanding (MOU) details the
division of responsibilities between Alberta Environmental
Protection (AEP) and the Alberta Energy and Utilities
Board (EUB) for suspension, abandonment,
decontamination, and surface land reclamation of active
and inactive upstream oil and gas facilities. It is intended
to clear up uncertainties regarding roles and
responsibilities, and to clarify expectations when upstream
oil and gas facilities are suspended, abandoned,
decontaminated, or where surface land reclamation occurs.
It addresses jurisdictional and procedural issues for
reclamation activities at active sites, such as flare pit
reclamation and on-lease and off-lease spill reclamation.
The MOU applies to all upstream oil and gas facilities,
whether licensed/approved solely by the EUB, or jointly by
AEP/EUB, including but not limited to, well sites, oil and
gas batteries, gas plants, compressor stations, crude oil
terminals, pipelines, gas gathering systems, oil production
sites, and oilfield waste related facilities. It does not
include facilities approved by the National Energy Board.
The MOU does not address issues regarding release
notification requirements. These are addressed in a
separate MOU and Informational Letter IL 98-1 entitled
“AA Memorandum of Understanding Between Alberta
Environmental Protection and the Alberta Energy and
Utilities Board Regarding Coordination of Release
Notification Requirements and Subsequent Regulatory
Response.” Drilling waste management, material storage,
and oilfield waste management are addressed in EUB
Guides 50, 55, and 58. Section 4 of this document
provides an overview of some of the regulatory
responsibilities for managing oilfield wastes.
2 DEFINITIONS in situ treatment: A term used to describe a method of
managing or treating contaminated soils, sludges and
In order to understand the content of this MOU, you should
waters Ain-place@ in a manner that does not require the
be familiar with the following terminology. Figure 1
contaminated material to be physically removed or
illustrates some of these terminology relationships.
excavated from where it originates. Contaminated material
treated in situ is not considered an oilfield waste.
suspension: The cessation of normal production,
operation, or injection activities at a facility pursuant to its
ex situ treatment/disposal: A term used to describe a
EUB licensed use. The facility need not be rendered
method of treatment and/or disposal for contaminated soils,
permanently incapable of its licensed use, but must be left
sludges, and waters (generated as a result of
in a safe and stable state during this period of suspension as
decontamination activities) once they have been physically
prescribed by the appropriate EUB regulation(s) and
removed or excavated from where they originate.
guidelines.
Contaminated material treated/disposed ex situ is
considered an oilfield waste.
abandonment: The permanent dismantlement of the
licensed facility so that it is permanently incapable of its
land treatment: The planned and controlled mixing of
EUB licensed use. This includes leaving downhole or
oilfield waste within the top 15 cm of the soil (not top soil)
subsurface structures in a permanently safe and stable
on an area of an upstream oil and gas facility, which must
condition in accordance with EUB requirements; the
be a specified land as defined in the Conservation and
removal of associated equipment and structures; the
Reclamation Regulation. The inherent soil processes are
removal of all produced liquids; and the removal and
then used to biodegrade, transform, and assimilate the
appropriate disposal of structural concrete.
waste constituents.
decontamination: The removal, reduction, or
one-time land treatment: The activity of land treatment
neutralization of substances, dangerous oilfield waste,
where oilfield waste is applied in a single application onto
and/or hazardous material from a site so as to prevent or
a specific area of an upstream oil and gas facility or another
minimize any adverse effects on the environment now or in
area related to that facility and is limited to occurring only
the future. Decontamination is also referred to as
once on that specific area during the entire lifetime of the
remediation.
facility.
surface land reclamation: The stabilization, contouring,
reclamation: The term is defined in the Environmental
maintenance, conditioning, reconstruction, or revegetation
Protection and Enhancement Act (EPEA) to mean any or
of the land surface to a state that permanently renders the
all of the following:
land with a capability equivalent to its pre-disturbed state
or for an alternate designated land use.
• the removal of equipment or buildings and other
structures, or appurtenances; the decontamination of
decommissioning: The permanent closure of all or part of
buildings or other structures, or other appurtenances,
an industrial facility, including upstream oil and gas
or land or water;
facilities, followed by the removal of process equipment,
• the stabilization, contouring, maintenance,
buildings and other structures, and the decontamination of
conditioning, or reconstruction of the surface of the
the surface and subsurface.
land; and

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 47
• any other procedure, operation, or requirement
specified in the regulations.
A Reclamation Certificate will be issued for sites that fall
within the EPEA definition of specified land (defined in
the Conservation and Reclamation Regulation, sec 1(t))
when reclamation is completed to the satisfaction of AEP.
Those facilities that are not on specified land will have to
meet the remediation objectives set out by AEP (see section
7), but will not be issued a Reclamation Certificate.
oilfield waste: An unwanted substance or mixture of
substances that results from the construction, operation, or
reclamation of a well site, oil and gas battery, gas plant,
compressor station, crude oil terminal, pipeline, gas
gathering system, oil production site, or oilfield waste-
related facility.
upstream oil and gas facilities: All facilities licensed or
approved by the EUB, including but not limited to, well
sites, oil and gas batteries, gas plants, compressor stations,
crude oil terminals, pipelines, gas gathering systems, oil
production sites, and oilfield waste related facilities.
same production system: A term referenced in the MOU
to limit off-site, one-time land treatment to a receiving site
(any upstream oil and gas facility) that is within the same
interconnected system of upstream production facilities
(e.g., wells, pipelines, batteries, etc.) as the facility from
which the land treatment material originated. The
receiving site shall be connected to, or common to the
upstream oil and gas facility from which the land treatment
material originated and both facilities shall have the same
licensee or approval holder.
contamination: The condition or state of soil, water, or air
caused by a substance release or escape that results in an
impairment of, or damage to the environment, human
health, safety, or property.
3 GENERAL ROLES AND RESPONSIBILITIES FOR
SUSPENSION AND RECLAMATION OF
UPSTREAM OIL AND GAS FACILITIES
The EUB, AEP, and industrial operators all have separate
roles and responsibilities when active and inactive
upstream facilities are suspended or reclaimed or both. The
following guidelines help clarify what is expected of each
party during these processes:
Industry operator responsibilities:
• suspend and abandon inactive upstream oil and gas
facilities properly and safely according to EUB
requirements,
• contain and recover all free produced fluids to the
expectations of the EUB,
• assess the extent and degree of contamination, and
develop and implement a remediation plan to the
satisfaction of AEP,
• decontaminate active and inactive upstream oil and
gas facilities and any associated impacts occurring off-
site (e.g., spills) to the satisfaction of AEP, as per the
48 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
Remediation Objectives identified in section 7 of this
document,
• manage all upstream petroleum wastes according to
EUB Guides 50, 51, 55 and 58,
• manage in situ treatment of contaminated soils,
sludges, and water to the satisfaction of AEP,
• manage the ex situ treatment/disposal of contaminated
soils, sludges, and water (oilfield wastes) generated as
a result of decontamination activities to the
satisfaction of the EUB as per Guide 58 and this
MOU,
• conduct surface land reclamation, and closure
monitoring and reporting if necessary, to the
satisfaction of AEP, and
• obtain a Reclamation Certificate from AEP or AAFRD
once an inactive upstream oil and gas facility has met
the appropriate certification requirements.
EUB responsibilities:
• ensure inactive upstream oil and gas facilities are
properly suspended and left in a safe and stable state,
• make certain inactive upstream oil and gas facilities
are properly abandoned and dismantled and that free
produced liquids and structural concrete are removed,
• develop guidelines for the management of drilling
wastes and oilfield wastes and ensure these wastes are
properly stored, treated, and disposed of according to
EUB Guides 50, 51, 55, 58 and this MOU,
• oversee the management of ex situ treatment/disposal
for contaminated soils, sludges, and waters (oilfield
wastes) generated as a result of decontamination
activities, in accordance with EUB Guide 58 and this
MOU, and
• conduct inspections and take enforcement action when
necessary.
AEP responsibilities:
• develop soil and groundwater remediation objectives,
and set policy for the application of risk assessments,
• ensure that facility owners and operators
decontaminate impacted sites, to meet remediation
objectives referenced in section 7 of this document,
• develop and maintain surface land reclamation
requirements and ensure that facility owners and
operators meet these requirements,
• issue Reclamation Certificates (AEP has delegated the
authority to issue Reclamation Certificates and
manage land based activity on public land in the
White Area to Public Lands in Alberta Agriculture,
Food and Rural Development (AAFRD). The Land
and Forest Service (LFS) manages land based activity
and has been delegated the authority to issue
Reclamation Certificates for public land in the Green
Area), and
• conduct inspections and take enforcement action
where necessary.
Figure 2 summarizes the division of regulatory
responsibility, and procedure for suspending and
reclaiming an inactive and active oil and gas facility.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 49
Also attached in Appendix 1 are some examples of typical
suspension and reclamation activities and the identification
of which agency has the regulatory jurisdiction.
4 OILFIELD WASTES
4.1 General
It is the EUB's responsibility to maintain and administer
oilfield waste management requirements for the upstream
oil and gas industry. The EUB released ID 96-3 and Guide
58, Oilfield Waste Management Requirements for the
Upstream Petroleum Industry, in November 1996. Any
questions regarding these documents should be directed to
the EUB.
All oilfield waste generated from suspension,
abandonment, decontamination, and surface land
reclamation of an active or inactive upstream oil and gas
facility fall under the jurisdiction of the EUB.
Contaminated soils, sludges, and waters that are physically
removed or excavated (from where the waste originated) as
a result of decontamination activities (e.g., earthen pit/pond
reclamation, spill reclamation, underground, and above
ground tank reclamation, etc.) are considered oilfield
wastes. All oilfield wastes must be managed as an ex situ
treatment/disposal (see definition) in accordance with EUB
Guide 58 and this MOU.
Should an operator wish to use an alternative method not
mentioned in Guide 58, an application must be made to the
EUB Operations Group (see section 4.3). Sometimes
operators may wish to deal with contaminated soils,
sludges, and waters in situ. EUB ID 96-3 and Guide 58 do
not apply to in situ treatment activities. In situ treatment
activities fall under the jurisdiction of AEP, and any
questions about this should be directed to them.
4.2 One-Time-Only Land Treatment of Oilfield Wastes
Approvals are not required for on-site, one-time land
treatment of unrefined hydrocarbon contaminated soils or
sludges (oilfield wastes). However, all land treatment
activities including in situ land treatment must be
conducted in accordance with section 16.0 of EUB Guide
58. Currently, one-time land treatment is only permitted to
occur on the site where the waste material originated or was
generated. All contaminated material moved from an
originating site must be sent to an EUB-approved oilfield
waste management facility, or to an AEP-approved facility
capable of accepting the material.
Since the release of Guide 58, it has become acceptable for
oilfield waste material to be moved off-site to a more
suitable location for one-time land treatment, provided the
following conditions are met:
• land treatment is conducted according to EUB Guide
58,
• the receiving site is within the same production system
(see section 2 Definitions “same production system”)
50 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
and the licensee/approval holder is the same for both
locations,
• the receiving site is specified land as per the
Conservation and Reclamation Regulation under
EPEA,
• written consent is obtained from the landowner of the
receiving site, and
• notice of the off-site land treatment is provided to the
EUB Waste Operations Team prior to the movement
of material off-site. (Notice must include the company
name, contact number, date of movement, site of
origin, total amount and characterization of the
material land treated, a copy of landowner consent,
and the legal description of the off-site land treatment
location.)
4.3 Use of Oilfield Waste Management
Technologies/Alternatives Not in Guide 58
Alternatives for the treatment and disposal of oilfield
wastes other than those in Guide 58 may exist. If an
operator wishes to propose a different method, an
application must be made to the EUB Operations Group. A
joint EUB/AEP working group is being formed to review
these applications and proposals on a case-by-case basis.
5 RECLAMATION OF ON-LEASE AND OFF-LEASE
SPILLS, RELEASES, OR PIPELINE BREAKS
Whether a spill occurs on-lease or off-lease, the division of
regulatory responsibility between AEP and the EUB for the
reclamation process remains unchanged. Once a spill,
release, or pipeline break (herein referred to as a “spill”)
has occurred, the operator is responsible to report the spill
to the appropriate agency (see EUB IL 98-1 for notification
requirements). The EUB is responsible for ensuring that
the operator contains the spill adequately and any free
produced fluid is recovered. Upon notification, the EUB
will assess the need for EUB staff to be on-site to oversee
the operator's spill response, specifically the containment
and recovery of any free produced fluids. Factors such as
environmental and public sensitivity, spill volume, and
concentration characteristics, operator expertise,
complexity of the cleanup, and other details are examined
prior to the deployment of EUB staff to a spill site.
In all cases, the operator is responsible for containing and
recovering as much of the free produced fluids or waste
product as possible before decontaminating the impacted
spill area. Questions or inquiries regarding containment
and recovery of free produced fluids should be directed to
the local EUB Field Centre.
In emergency situations (where an operator cannot
immediately respond), the EUB may take control of initial
containment and recovery operations, until the operator
responds. Costs incurred by the EUB will be recovered
from the operator.
All contained/recovered spill fluids are considered to be
oilfield waste, and must be managed according to EUB
Guide 58.
Once any free produced fluid or waste product is contained
and recovered, the operator must decontaminate any
remaining contaminated soils or waters on the spill site. As
the operator is accountable to AEP for this
decontamination, any questions regarding this should be
directed to AEP. AEP may not be on-site or directly
involved in all spill situations. Upon being made aware of
a spill (IL 98-1) AEP will assess the need for their presence
at the spill site to oversee decontamination activities. AEP
expects that all companies will utilize the remediation
objectives referenced in section 7 of this document as the
basis for decontaminating a spill site. Operators should
reference section 7 when determining if soils or waters are
contaminated and in determining a decontamination
endpoint.
AEP will ensure that operators have properly
decontaminated the spill area by conducting follow-up
inspections or audits of the spill site, and/or by requesting
an operator's written report on the spill and
decontamination status. (This Astatus@ report is in
addition to the seven day report requirement stipulated in
IL 98-1). Any contaminated soils, sludges, or water
physically removed or excavated from a spill site is
considered to be an oilfield waste, and must be managed as
an ex situ treatment/disposal activity, in accordance with
EUB Guide 58 and this MOU.
Once a spill site has been decontaminated, surface land
reclamation (see definitions) is then required. Questions
regarding surface land reclamation should be addressed to
AEP or AAFRD.
6 RECLAMATION OF EARTHEN PITS AND PONDS
Recently, the EUB has taken steps to reduce the use of pits
and ponds at upstream oil and gas facilities (see IL 96-4).
Operators are no longer permitted to discharge any
produced liquid to earthen pits or ponds and are
encouraged to reclaim existing ones in a timely fashion.
AEP requires that these pits/ponds be removed if an actual
or potential adverse effect exists. Neither AEP nor EUB
staff intend to be on-site to oversee pit/pond reclamation,
however, the operator must maintain documentation to
demonstrate that each pit/pond has been properly
decontaminated and any resulting oilfield wastes have been
appropriately treated/disposed.
Free produced fluids removed from a pit or pond are
considered oilfield waste and must be managed in
accordance with EUB Guide 58 and this MOU. Free
produced fluids include any fluid that can be drawn off
with a pump or vacuum truck.
Following the removal of produced fluids, the pit/pond
must be decontaminated. AEP expects all operators to
utilize the remediation objectives referenced in section 7 as
the basis for decontaminating earthen pits/ponds. AEP has
the regulatory jurisdiction for all pit/pond contaminated
soils, sludges, and water that are treated in situ.
Contaminated soils, sludges, and water that are removed
from a pit/pond and treated/disposed ex situ (see definition)
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 51
must be managed as an oilfield waste in accordance with
EUB Guide 58 and this MOU. All land treatment
activities, and other bioremediation alternatives (biopiles
and biocells) for contaminated pit/pond soils are considered
an ex situ treatment/disposal and must therefore be
managed as an oilfield waste as per EUB Guide 58 and this
MOU. Land treatment and other bioremediation
alternatives are complete once the contaminated soils and
receiving soils have met the requirements of Guide 58 and
this MOU. Questions on ex situ treatment/disposal of
oilfield wastes generated as a result of pit/pond
decontamination should be directed to the EUB.
Once a pit/pond has been decontaminated, and any
associated oilfield waste has been adequately managed, the
disturbed area(s) must undergo proper surface land
reclamation (see definition). AEP and AAFRD are the
regulatory agencies responsible for all surface land
reclamation issues.
Any closure monitoring and reporting for earthen
pits/ponds should be addressed by the operator in
consultation with AEP. Operators are expected to
document their reclamation activities and be able to verify
the site has been adequately decontaminated.
7 REMEDIATION OBJECTIVES
At the majority of sites the remediation objectives will be
the AEP 1994 Alberta Tier 1 Criteria for Contaminated
Soil Assessment and Remediation and the 1995 Canadian
Water Quality Standards (and updates). In situations
where there is historic contamination and the property is,
and will continue to be, zoned commercial/industrial, use
of the commercial/industrial remediation objectives in the
1991 CCME Interim Canadian Environmental Quality
Criteria for Contaminated Sites may be used for soil.
As an alternative to the generic approach, a proponent may
choose to conduct a site-specific risk assessment study to
derive risk-based remediation objectives or to support a
risk management plan. Risk-based remediation objectives
must be derived in accordance with the 1996 CCME A
Protocol for the Derivation of Environmental and Human
Health Soil Quality Guidelines. Site-specific risk
assessment approaches must be approved by AEP and
accepted by any affected parties.
8 CONTACTS
Suspension and Abandonment Issues (EUB):
Appropriate Field Centre:
Bonnyville Area (403) 826-5352
Calgary South Area (403) 297-8303
Drayton Valley Area (403) 542-5182
St. Albert Area (403) 460-3800
Grande Prairie Area (403) 538-5138
Medicine Hat Area (403) 527-3385
Red Deer Area (403) 340-5454
Wainwright Area (403) 842-7570
Decontamination Issues (AEP):
Contaminated Sites &
Decommissioning Branch
Oilfield Waste Treatment and/or Disposal Issues (EUB):
General Inquiries
Waste Operations Team
Land Reclamation Issues:
Green Area
Land Services Branch,
Land and Forest Services, AEP
Public Land in White Area
Public Land Management Branch,
AAFRD
APPENDIX 1
Examples
(403) 427-6182
The following examples provide a typical list of potential
activities that may happen during the suspension,
abandonment, decontamination, and surface land
(403) 297-3426 reclamation cycle on active and inactive upstream oil and
(403) 297-2496 gas facilities. The list associated with each example is not
intended to show a step-by-step process for suspension,
abandonment, decontamination, and surface land
reclamation activities. The purpose of the list is to:
• define the agency which has the regulatory
(403) 427-3570 responsibility for each specific activity. Any
proponent undertaking these activities is not required
to contact the agency before they do that activity
unless required to do so by an Act, regulation, ID, IL,
(403) 427-3595 guideline, or approval condition, and

• identifies the agency the proponent should contact if

Non-Public Land in White Area
Environmental Services, AEP Appropriate Field Centre: they require assistance on a particular activity.

Calgary (403) 297-8295

Camrose (403) 679-1274
Edmonton (403) 427-6212
Fairview (403) 835-7139
Grande Prairie (403) 538-5459
Hanna (403) 854-5579
Lethbridge (403) 381-5156
Medicine Hat (403) 529-3685
Red Deer (403) 340-7052
St. Paul (403) 645-6394
Stony Plain (403) 963-5351
Wainwright (403) 842-7535
Westlock (403) 349-3445

52 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
IL 99-2: Use of Produced Sand in Road Construction
28 May 1999
TO: All Oil and Oil Sands Operators
USE OF PRODUCED SAND IN ROAD CONSTRUCTION
EXECUTIVE SUMMARY
Significant volumes of reservoir (produced) sands are produced along
with heavy oil in northeast Alberta. The EUB classifies this produced
sand as “non-dangerous oilfield waste.”
The heavy oil industry has been actively investigating a range of
options for the safe re-use and/or disposal of this sand. Recently,
using this sand in roadbed construction has become a significant
disposal option.
A task force was formed to determine guidelines for produced sand
use in roadbed construction. Participation of various stakeholders
included environmental groups, the public, the heavy oil industry,
waste processors, Alberta Transportation and Utilities, Alberta
Environmental Protection, and the EUB. The attached IL is the result
of extensive research and review by the task force. The
recommendation that this practice be allowed is based on extensive
and rigorous scientific research and opinion.
The EUB is prepared, under very restricted conditions (strict limits
on contaminants for example), to allow this sand to be incorporated
or encapsulated into roads during construction. The primary
contaminants of concern are chlorides (salt) and hydrocarbon (oil).
As such, two key restrictions are:
• the chloride concentration of sand encapsulated into roads must
not exceed 3000 milligrams per kilogram, and
• the concentration of entrained crude oil in the sand cannot
exceed five per cent.
Other conditions will also apply, including strict controls limiting
contaminants such as free water, benzene, or heavy metals. In
addition, the produced sand must not be contaminated by any sources
of halogenated hydrocarbons, hazardous chemicals, refined or lube
oils, drilling waste, flare pit sludge, or spill clean-up materials or any
other deleterious materials. Requirements for storage and sampling of
the produced sand are also set out.
Companies must follow a clearly defined application process that
involves both the EUB and the local county or municipal district. The
appropriate EUB Field Centre will issue an approval to use produced
sand in road construction, should a tendered application meet all
EUB requirements.
The EUB notes that, because of varying native soil properties and
other geographical features, not all roads are suitable for using
produced sand during construction. The Board expects the local
county or municipal district accepting the produced sand and the oil
company which generated the material to carefully evaluate site
characteristics and ensure proper practices are adhered to.
Failure by a company to comply with the requirements of the new
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 53
guidelines will result in EUB enforcement actions, which may
include immediate suspension of the road project and immediate
implementation of corrective action. Future approvals for using
produced sand in road construction may also be withheld.
A key issue considered in formulating this guideline was who would
be liable for any environmental contamination that might result from
using produced sand in roadbed construction? Both the task force
and Board sought legal advice on this question.
The understanding of the Board, based on that advice, is that there
are four parties that could potentially be held liable for addressing
any contamination. These parties are: owners and past owners of the
produced sands, those in charge, management and control of the
produced sands, directors and officers of the companies and
successor companies that generated the produced sands, and owners
and past owners of the roads.
These guidelines will be subject to review every two years, or as
necessary.
1 INTRODUCTION
This Informational Letter outlines the EUB guideline for produced
sand to be used as construction material in roads. The produced sands
referred to in this document are limited to the solids (reservoir sand)
recovered from heavy oil operations in north-east Alberta. This
material contains small quantities of hydrocarbons and chlorides and
may be used in road construction in accordance with this document.
This guideline, includes criteria, site restrictions, application
requirements, audit, and enforcement expectations for produced sand
generators.
As a companion to Part F Section 29.0 “Spreading of Oily By-
Products to Roads” in Guide 58, Oilfield Waste Management
Requirements for the Upstream Petroleum Industry, this guideline
will be subject to regular review every two years or as required.
Further, it will be added into Guide 58 in due course. Some of the
terminology used in this guideline have been given specific
definitions, as noted below, which are consistent with road
construction practice but may not necessarily match other accepted
definitions for those terms.
Produced Sand Reservoir sand (oily by-product material) with
small quantities of hydrocarbon and chloride
typically stung (the practice of using a washing
wand and vacuum truck to recover the sand) or
augured from production tanks in heavy oil
operations.
Incorporation Mixing of the produced sand and native clay to a
uniform consistency during road construction.
Encapsulation Encasement of produced sand into an impervious
roadbed cell.
Statutory Road Designated municipal road or highway
2 CHARACTERISTICS OF PRODUCED SAND
Based on the characteristics noted below, produced sand is typically
classified as non-dangerous oilfield waste and therefore, is equivalent
to waste classified as non-hazardous under the Alberta
Environmental Protection and Enhancement Act, Waste Control
Regulation. Produced sand typically found in north-east Alberta,
generally falls within the ranges for the parameters1 listed here:
flashpoint greater than 61 degrees Celsius
total petroleum
hydrocarbon 10 000 to 150 000 mg/kg
(using Dean Stark Method)
chloride 200 to 30 000 mg/kg
sodium 150 to 20 000 mg/kg
trace metals similar to soil background values
particle size fine to very fine sand (250 to 62.5
microns)
pH 6-8
Although the information indicates that within produced sand the
concentrations of crude oil, sodium, and chloride can range
drastically, the average concentrations typically found are around 3.5
per cent or 35 000 mg/kg oil, 2000 mg/kg sodium, and 3500 mg/kg
chloride. Considering that 93 per cent or more of the components
within heavy crude oil boil at a temperature greater than 225o C, the
residual crude oil within the produced sand is of high molecular
weight and therefore, monoaromatic hydrocarbons (benzene, toluene,
ethylbenzene, and xylenes) occur at extremely low levels.
Although the pH of produced sand typically ranges from 6 to 8, the
receiving road material would easily buffer a pH range between 4 and
9. Therefore, the requirement to measure the pH of the produced sand
has been dropped from the criteria listed below.
Publications and scientific literature relating to road construction
practices indicate that higher molecular weight hydrocarbons such as
bitumens and asphaltenes are used as soil stabilizers in the
preparation of road sub-bases and grades. The literature also indicates
that the presence of sodium in clay material decreases the
permeability of the admixed soils while chlorides provide additional
stabilization and freezing point depression. Relating this information
to the characteristics of produced sand, the Task Force deems that
produced sand is an acceptable construction material for roads and
poses minimal environmental and safety risks provided the criteria
and requirements set out below are met.
3 CRITERIA
Produced sand generated during in situ oil sands and heavy oil
production in north-eastern Alberta may be incorporated or
encapsulated into roads during their construction provided the
following criteria are met:
3.1 The chloride concentration in the produced sand must not
exceed 3000 mg/kg. The
1 Established from EUB and industry databases. Variances are the
result of different reservoir conditions and operator production and
storage practices.
54 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
1:9 water extraction method shall be used to analyze the
concentration of chloride in the produced sand.
Note: Taking into consideration a road functions as a
commercial/industrial use and not as an agricultural
field, the chloride limit was calculated by relating it back
to the CCME commercial/industrial value for EC, which
is 4 dS/m.
3.2 The concentration of crude oil entrained in the produced sand
does not exceed 5 per cent as determined using the Dean Stark
toluene soxhlet extraction method. Information must be
available that verifies the crude oil from which the produced
sands are recovered has a density greater than or equal to 920
kg/m3.
3.3 The produced sand must have a flashpoint greater than 61o C.
Note: Operators of sand storage facilities may eliminate the
necessity to analyze the produced sand for flashpoint
provided they have sufficient information to demonstrate
the flashpoint meets the criteria, the source of sand has
not changed, and the production process has not
changed.
3.4 The produced sand shall be incorporated at a rate of 1 part sand
to 3 or more parts native road construction material or
encapsulated such that the volume of sand within the
encapsulated lens does not exceed 25 per cent of the entire road
construction material.
3.5 Every reasonable effort shall be made to minimize free water
within the produced sand storage facility. Prior to disposition
free water on the surface or lying within the storage facilities
must be removed.
3.6 The produced sand must not be contaminated by any sources of
halogenated hydrocarbons, hazardous chemicals, refined or lube
oils, drilling waste, flare pit sludge, or spill clean-up materials or
any other deleterious materials.
3.7 The produced sand must be analyzed for strong acid digest
metals using US EPA method 3050 or 3051 and compared to
the following CCME (Agricultural) criteria:
Cd 1.4
Hg 6.6
Pb 70
Ni 150
Cu 63
Zn 200
Note: Except for nickel, the above metal concentrations have
been taken from the 1997 CCME Recommended Soil
Quality Guidelines for agricultural soils. The nickel
concentrations are from the CCME 1991 criteria for
agricultural soils. As the concentrations of metals
within produced sand are typically similar to soil
background values, levels exceeding the above
concentrations could be an indication that other
wastes/materials have been mixed with the produced
sand. Operators may eliminate the necessity to analyze
 for metals provided they have sufficient information
that concludes the metals don't exceed the above
criteria, the source of the sand has not changed, and
the production process has not changed.
3.8 The produced sand must be analyzed for total BTEX using EPA
method 8240 or 8020 and shall not exceed the following criteria
taken from the 1997 CCME Recommended Soil Quality
Guidelines for residential/parkland soils.
benzene 0.5 mg/kg
ethylbenzene 1.2 mg/kg
toluene 0.8 mg/kg
xylene 1.0 mg/kg
Note: Although a road functions as a
commercial/industrial use, the Task Force
acknowledges that in a rural setting a road would
be adjacent to residential, parkland, or
agricultural land. Considering the concerns
related to BTEX components, it was deemed that
it would be prudent to not potentially expose
adjacent land uses to industrial levels for BTEX.
Furthermore, as the volume of produced sand
used in road construction cannot exceed 25 per
cent of the entire road material, it was deemed
that parkland/residential levels would protect
adjacent land uses, including agricultural.
Operators may eliminate the necessity to analyze
for BTEX provided they have sufficient
information that concludes the BTEX
components do not exceed the above criteria, the
source of the sand has not changed and the
production process has not changed.
4 STORAGE FACILITY MANAGEMENT
4.1 Operators under the jurisdiction of the EUB must store all
materials used, produced, and generated on their sites in
accordance with EUB ID 95-3 and Guide 55, Storage
Requirements for the Upstream Petroleum Industry. In addition
to storing the produced sand in a facility that complies with the
storage requirements, produced sand from tank bottoms must be
stockpiled separately from other materials that may be placed in
the same storage cell (e.g., spill materials). It is the
responsibility of the operator to ensure that:
• produced sand is segregated from other materials,
• the sand stockpile is accessible for sampling,
• water within produced sand storage facilities be managed
by controlling or removing any free water, and
• the sand is kept separate from other material once it has
been sampled (i.e., no extra sand being added to the
sampled pile).
5 SAMPLING PROCEDURES
5.1 Operators of sand storage facilities are responsible to ensure
representative samples are obtained from sand stockpiles that are
to be used in road construction. Appropriate sampling methods,
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 55
such as those in Appendix 1 “Recommended Practices of
Sampling Protocol for Roadbed Construction”, must be used to
obtain a representative composite sample. If the sand stockpile
is over 2.5 metres (m) in height, the following also applies:
• sampling is required for each 1.5 - 2.5 m intervals,
• as each interval is sampled, it must be removed and
stacked, or segregated from any additional materials
entering the storage facility, and
• no additional material can be added to the pile after the
samples have been taken.
5.2 The representative composite sample for every 1.5 - 2.5 m of
sand within the sand storage facility must be analyzed for
parameters outlined in Section 3 of this document. The results of
the analyses must be recorded on the Produced Sand
Characterization for Roadbed Incorporation/Encapsulation Data
Sheet, which is found in Appendix 2, and then submitted to the
recipient (local authority) and the appropriate EUB Field Center
office.
5.3 For audit purposes and for comparison to the storage facility
analyses, samples shall be taken of the produced sand during
road construction activities by the operator and handled in the
following manner:
• for each kilometre (km) of road, eight - one litre samples
shall be taken as the trucks are unloading to make a
representative composite sample; less may be used if the
length of the road is reduced, and
• the composite samples must be retained (stored in 1 litre
(L) glass jars sealed tightly with a teflon lid at a
temperature of 4°C) for a period of one calendar year, and
• as the result of the road construction project being audited
or at the request of the EUB, these samples must be
analyzed for the characterization parameters identified in
Section 2, including BTEX, and compared to the criteria
limits identified in Section 3 and to the analyses from the
sand storage facility. These results must also be submitted
to the local authority (MD/County) and appropriate EUB
Field Center office.
Note: At the request of the EUB, additional sampling and
analyses may be required.
6 SITE CHARACTERISTICS AND RESTRICTIONS
As a result of native soil properties and other geographical features,
not all roads will be suitable for the encapsulation or incorporation of
produced sand during their construction. In addition to the produced
sand meeting the criteria specified in Section 3.0, the following road
site characteristics and restrictions provide added environmental
protection against the potential migration of salt or hydrocarbon
contained within the produced sand used in a road construction
project.
It is the responsibility of the local authority (county/municipal
district) and operator (generator of the produced sand) to ensure these
site characteristics and restrictions are adhered to. It is also expected
that roads having produced sand incorporated or encapsulated into
them, must be constructed following acceptable engineering practices
(current Alberta Transportation and Utilities Standard Specifications
for Highway Construction). The local authority, by allowing
produced sand to be used as a road construction material, must agree
that it will be used in accordance with this document.
6.1 The native soil of the selected road site shall:
• have an electrical conductivity that does not exceed 2 dS/m
(determined on a saturated paste extract) to ensure
excessive salt loading is prevented, and
• be clayey, meet the criteria for durable roads (minimum
plasticity index of 15 per cent, minimum liquid limit of 30
per cent, and minimum clay fraction of 20 per cent), and
occur to a minimum depth of 1.6 m (five feet) below the
base of the produced sand.
6.2 The suitability of the existing soil type of the selected road must
be assessed on site and confirmed by lab analyses.
• test holes must be drilled every 200 m to a depth of 1.6 m.
If the soil type changes based on field testing for electrical
conductivity and clay content, the point in the road where
the change occurs must be determined. Produced sand
cannot be added past that point.
• provided that the soil type does not change noticeably,
analysis of one soil sample every 1.6 km by a certified lab
is required to confirm suitability of the soil (electrical
conductivity, plasticity index, liquid limit, per cent clay).
Material representing the entire profile to 1.6 m depth must
be submitted as part of the soil sample.
6.3 The following restrictions apply to roads selected for
construction with incorporated or encapsulated produced sand:
• only statutory road allowances shall be used. This is to
ensure road allowances cannot be cancelled or abandoned,
• the road shall be a minimum of 30 m horizontally from the
high water mark of any surface body of water; roads that
are likely to contact a surface body of water cannot be used,
• the road shall not be within 100 m of a private or
community water well or dugout, and
• the produced sand must not be incorporated or
encapsulated within 30 m of any culvert installed through
the road.
Note: Future pipeline crossings must be bored under these
roads. The bore hole must be a minimum of 1.2 m
below the incorporated or encapsulated sand. An
alternative procedure that will not compromise the
integrity of the produced sand within the road may be
acceptable.
6.4 For roads constructed with produced sand incorporated into
them, the incorporation thickness (mixture of produced sand and
56 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
native road material) shall not exceed 2 m. In addition, the
produced sand shall be spread and uniformly mixed with the
native road material at a ratio of 1 part sand to 3 or more parts
road material to produce a homogeneous mixture, such that the
electrical conductivity will not exceed CCME
commercial/industrial criteria (Section 3.1).
Note: The produced sand must be delivered, spread, and
incorporated into the road all within the same day.
Produced sand must not be allowed to migrate off the
road during or after construction.
6.5 For roads constructed with produced sand encapsulated into
them, the produced sand cell shall not exceed a depth of 0.45 m
and be limited to a single layer within a road. The volume of
sand within the encapsulated cell shall not exceed 25 per cent of
the road material. In addition, the clayey roadbed material
encapsulating the produced sand cell (above, below and on the
sides) shall be a minimum compacted thickness of 0.6 m. Each
produced sand cell must be horizontally separated with a
minimum of 2 m of compacted clayey roadbed material.
Note: Produced sand having a high silt content (greater than
30 per cent), based on particle size distribution, must
not be encapsulated due to frost heave problems. The
size of the produced sand cell is defined as the amount
of produced sand that can be delivered, spread, and
encapsulated within one day. The produced sand
within a cell cannot be left exposed on the road
overnight or during periods of precipitation. Produced
sand must not be allowed to migrate off the road
during or after construction.
6.6 The operator is responsible to ensure the engineering plans and
as-built plans for the road construction project incorporating or
encapsulating produced sand, as identified in Appendix 6, are
prepared and completed. The local authority is accountable for
the road and thus responsible to ensure road construction
projects incorporating or encapsulating produced sand comply
with the site characteristics and restrictions identified in this
section. The engineering plans and as-built plans must be
retained by the local authority in perpetuity, so that appropriate
precautions will be taken if a road that has produced sand
incorporated or encapsulated in it, requires future work.
7 APPLICATION PROCESS
7.1 If the produced sand is acceptable for road construction
(incorporation or encapsulation), the operator must, prior to the
commencement of the incorporation/encapsulation activities,
provide the following information to the recipient (local
authority) and the appropriate EUB Field Center office for
review:
• a copy of the Produced Sand Characterization for Roadbed
Incorporation/Encapsulation Data Sheet (Appendix 2). The
data sheet must be signed by a representative from the
laboratory and by the operator. The data sheet must confirm
that the sand is non-dangerous oilfield waste (non-DOW),
and
• a copy of the Application/Approval for Roadbed
Incorporation/encapsulation Check Sheet (Appendix 3),
 and
• a map outlining the section of road to be used for
incorporation or encapsulation, the legal land description of
that road, and confirmation that the Engineering
Assessment has been done, and commitment that the site
characteristics and restrictions in Section 6.0 will be
adhered to.
7.2 The operator shall have written consent that the recipient (local
authority) agrees to have produced sand incorporated/
encapsulated into the road and that it will only be used in
accordance with this document . A copy of the written
agreement shall be submitted to the appropriate EUB Field
Center office with the information from 7.1 above. Directly
adjacent landowners/residents to the proposed road shall be
notified of the project. A letter or documented personal visit
from the recipient of the produced sand at least one week before
construction begins would be considered appropriate notice.
Operators must include information regarding any complaints
following the landowner/resident notification.
7.3 Operators must discuss any potential applications, which may
deviate from the requirements of this document for any reason,
with the appropriate EUB Field Centre Office.
8 APPROVAL
8.1 Approval by the appropriate EUB Field Centre Office shall be
granted if the above information is received and meets all EUB
requirements and the operator ensures the items below are met.
The operator shall then proceed with the method of
incorporation encapsulation, to the indicated road, at the
appropriate depth/mix. Any concerns or appeals regarding an
approval must be made to the appropriate EUB Field Centre.
8.2 The operator and the receiver (local authority), shall ensure the
following requirements are met during incorporation/
encapsulation activities:
• the produced sand is used in road construction according to
good engineering practices, and Section 6.0 Site
Characteristics and Restrictions are adhered to,
• no product is lost during transportation of this material
from the storage area to the incorporation/encapsulation
point (e.g., by using truck tarps, if necessary), and
• the appropriate EUB Field Center office shall be notified
once incorporation/encapsulation operations have
commenced.
The approval may be rescinded at any time should the produced sand
not meet criteria or the operator fails to meet the requirements set out
above.
9 SUPERVISION
9.1 The generator of the produced sand (operator) is responsible to
complete an On-site Incorporation/Encapsulation Check
Sheet(s) (Appendix 4), or the equivalent. The receiver will
complete similar information. This is needed to ensure the
following items are addressed and that the
incorporation/encapsulation is being carried out as per the
approval:
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000) • 57
• the produced sand being hauled to the road construction
site is from the pile that was analyzed,
• the transportation of the produced sand is being carried out
in a satisfactory manner,
• the produced sand is being applied as per approval (i.e.,
proper mix ratio and location),
• grab samples are taken as the trucks are unloading and then
used to make up a composite sample as outlined in Section
5.3. Information must be recorded on the Daily Road
Information Check Sheet (Appendix 5), and
• all details of this document and approval are being
followed.
9.2 The operator must ensure that each road construction project is
adequately managed by monitoring the project and ensuring the
check sheets are completed for each project and submitted to
their project file and retained for a minimum of two years.
10 COMPLIANCE AND ENFORCEMENT
10.1 Failure to comply with the requirements outlined in this
document shall result with the EUB taking the following
actions:
• Immediate suspension of the road project,
• corrective action to remedy the situation shall be performed
immediately, and/or
• withhold future approvals for road
incorporation/encapsulation.
10.2 The EUB will determine the significance of the event (minor,
major, serious) as defined below, in accordance with the EUB
Generic or Field Surveillance Enforcement Ladders.
• Minor Non-compliance Issue defined as a contravention of
regulation(s)/requirement(s) which does not result in a
direct threat to the public and/or the environment and does
not adversely effect oil and gas operations. An example is
missing information on a data sheet.
• Major Non-compliance Issue defined as a contravention of
regulation(s)/requirement(s) that an operator has failed to
address and/or has the potential to cause an adverse impact
on the public and/or the environment. An example is the
quality of produced sand, as determined by the original
analysis is significantly different from control sample
analysis taken while produced sand is being incorporated or
encapsulated. Another might be where a produced sand cell
is left exposed overnight.
• Serious Non-compliance Issue defined as a total disregard
for regulation(s)/requirement(s) that is causing or may
cause a significant impact on the public and/or the
environment. An example is encapsulation or incorporation
of produced sand without approval to do so.
 Enforcement consequences for any non-compliance issues will
be taken to ensure regulatory requirements are being met and
operators are treated in a similar fashion. The enforcement
actions taken by the EUB will be determined based on the
severity of non-compliance, in accordance with the EUB
Generic and Field Surveillance Group’s enforcement ladders.
Actual definitions of minor, major, and serious non-compliance
issues and examples of consequences relating to this document
will be developed as part of the audit process (expected
completion 15 June 1999). A copy can be obtained by
contacting the appropriate EUB Field Center.
10.3 The appropriate EUB Field Center will conduct audits on a
minimum of 10 per cent of the incorporation/encapsulation
operations. The emphasis of the audits will be on compliance
with the quality criteria specified for the produced sand and on
accountability of the operator by ensuring the check sheets have
been properly completed and signed. Corrective action resulting
from the audit will be consistent with the consequences noted in
10.1 and 10.2 above.
11 PRODUCED SAND (WASTE) TRACKING
Section 9.0 of EUB Guide 58, Oilfield Waste Management
Requirements for the Upstream Petroleum Industry, requires oilfield
waste generators to implement and maintain a waste tracking system
for the oilfield wastes listed on Table 9.1, Reportable Oilfield
Wastes. As produced sand is an oilfield waste that is listed on Table
9.1, it must be tracked from the point of initial generation to final
disposition. A road that has been constructed with produced sand
incorporated or encapsulated into it, would be considered a final
disposition point for the produced sand. Therefore, the volumes of
produced sand used in the road construction and the location of the
road must be recorded in the tracking system.
All tracking systems must be effective and capable of displaying due
diligence. At any time, the EUB may audit a generator's waste
tracking system or request the generator to provide information
pertinent to the waste tracking system. As well, generators must be
58 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 4 (October 2000)
able to summarize the tracking information into an oilfield waste
disposition report. For further information on oilfield waste tracking
and reporting please refer to Part C, Guide 58.
12 LIABILITY
Although the Task Force believes produced sand is an acceptable
construction material for roads and poses minimal environmental and
safety risks, a key issue considered was who would be liable for any
environmental contamination that might result from the use of
produced sands in road construction. While the final answer to such a
question may ultimately reside with the Courts, the Task Force and
the Board did obtain legal advice on the question. The understanding
of the Board, based on the results of that review, is there are four
general parties that could potentially be held liable for addressing any
contamination that might occur. These are:
• owners and past owners of the produced sands,
• those in charge, management, and control of the produced sands,
• directors and officers of the companies and successor companies
that generated the produced sands, and
• owners and past owners of the roads.
On the basis of the above, the Board believes that landowners whose
property abuts onto roads incorporating/encapsulating produced sand
should not, provided that they do not also fall into one of the above
categories, face any liability or bear any subsequent responsibility for
clean up to either their land or water, in the unlikely event that
contamination might arise from the use of produced sand as road
construction material.
J. D. Dilay, P.Eng.
Board Member
BLANK PAGE
APPENDIX 5—EXCERPTS FROM OIL AND GAS LEGISLATION
ENERGY RESOURCES CONSERVATION ACT
Section 29
29(1) Unless it is otherwise expressly provided by this Act
to the contrary, any order or direction that the Board is
authorized to make may be made on its own motion or
initiative, and without the giving of notice, and without
holding a hearing.
(2) Notwithstanding subsection (1), if it appears to the
Board that its decision on an application may directly and
adversely affect the rights of a person, the Board shall
give the person
(a) notice of the application,
(b) a reasonable opportunity of learning the facts
bearing on the application and presented to the
Board by the applicant and other parties to the
application,
(c) a reasonable opportunity to furnish evidence
relevant to the application or in contradiction or
explanation of the facts or allegations in the
application,
(d) if the person will not have a fair opportunity to
contradict or explain the facts or allegations in
the application without cross-examination of the
person presenting the application, an
opportunity of cross-examination in the
presence of the Board or its examiners, and
(e) an adequate opportunity of making
representations by way of argument to the
Board or its examiners.
(3) When by subsection (2) a person is entitled to make
representations to the Board or its examiners, the Board is
not, or examiners are not by subsection (2) required to
afford an opportunity to the person
(a) to make oral representations, or
(b) to be represented by counsel,
If the Board or examiners afford the person an opportunity
to make representations adequately in writing, unless the
statutory provision authorizing the Board’s decision
requires that a hearing be held.
RSA 1980 cE-11 s29
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 1
Section 43
Review of Order Made Without Hearing
43(1) A person affected by an order or direction made by
the Board without the holding of a hearing may, within 30
days after the date on which the order or direction was
made, apply to the Board for a hearing.
(2) A person affected by an order or direction made by
the Board after a hearing and to whom notice of the hearing
was not directly given may, within 30 days after the date on
which the order or direction was made, apply to the Board
to vary, amend or rescind it.
(3) An application under this section shall set out the
matters complained against and the reasons for the
complaint.
(4) On making an application under this section, the
applicant may request that the order or direction referred to
in the application be suspended until the application is
heard, and the Board may suspend the order or direction on
the terms and conditions it prescribes or may refuse the
request.
(5) When an application is made under this section, the
Board shall, after not less than 10 days’ notice to all
persons affected by the order or direction, hold a public
hearing of the application, and may confirm, vary or
rescind the order or direction, as to the Board seems just.
RSA 1980 cE-11 s43
PIPELINE ACT
Chapter P-8
Section 1(1)(g)
Definitions
1(1) In this Act,
(g) “installation” means
(i) any equipment, apparatus, mechanism,
machinery or instrument incidental to the operation of
a pipeline, and
(ii) any building or structure that houses or protects
anything referred to in subclause (i), but does not include
a refinery, processing plant, marketing plant or
manufacturing plant;
RSA 1980 cP-8 s1;1981 c30 s2;1983 cO-5.5 s30;
1984 c32 s2;1985 c46 s2;1990 cM-14.s279;2000 c12 s2(2)
PIPELINE REGULATION
Alberta Regulation 122/87
Section 50
Emergency procedures and exercises
50(1) A licensee of a pipeline transmitting gas containing
10 or more moles of hydrogen sulphide gas per kilomole of
natural gas or of a liquid filled pipeline transporting an
HVP liquid shall maintain an emergency procedures
manual for
(a) assessing an emergency situation from available
information when there is an uncontrolled
emission of fluid from the pipeline,
(b) mobilizing field and plant personnel,
(c) co-ordinating control measures in an emergency
situation,
(d) setting up lines of communication and
responsibilities, and
(e) any other matters concerning actions necessary
to ensure public safety.
(2) The emergency procedures manual referred to in
subsection (1) shall be updated at least once each year and
submitted to the Board upon request.
(3) The licensee of a pipeline transmitting HVP liquids
shall periodically conduct emergency exercises structured
to test the licensee’s internal capabilities for initial response
to the emergency procedures described in the manual
required by subsection (1) and to test any leak detection
and supervisory control and data acquisition systems
associated with the pipeline.
AR 122/87 s50;148/92;220/99;221/99
Section 53
53 A licensee shall
(a) record the results of any inspection or test
conducted to determine the effectiveness of
internal corrosion mitigative measures,
(b) retain the record for a period of at least 6 years
from the date the record is made, and
(c) submit the record to the Board on request.
AR 122/87 s53;148/92;220/99
Notice to Board of Maintenance Activity
53.1 The licensee of a pipeline that transmits natural gas
containing more than 10 moles of hydrogen sulphide per
kilomole of natural gas or an HVP liquid shall notify the
appropriate Board area office at least 48 hours prior to
commencing
2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
(a) the replacement of short portions of pipeline
allowed by section 2(3), or
(b) instrumented internal inspections of the
pipeline.
AR 148/92 s33
Section 61
Discontinuation of Pipeline
61 Unless otherwise authorized by the Board, within 6
months of the receipt by an applicant of the Board’s
consent to discontinue the operation of a pipeline or a part
of a pipeline, the applicant shall ensure that the pipeline or
the part of the pipeline to be discontinued is
(a) physically isolated or disconnected from any
operating facility,
(b) cleaned, if necessary,
(c) purged with fresh water, air or inert gas, and
(d) left in a safe condition.
AR 122/87 s61;7/98
Section 68
Responsibility for Abandoned Pipeline
68 The Board’s consent to an abandonment operation does
not relieve the licensee from the responsibility of further
abandonment or other operations with respect to the same
pipeline or part of a pipeline, that may become necessary.
OIL AND GAS CONSERVATION REGULATIONS
Alberta Regulation 151/71
Part 2: Licensing of Wells
Well Near Aerodrome
2.090 A person proposing to drill a well within 5 kilometres
of a lighted aerodrome, or within 1.6 kilometres of an
unlighted aerodrome shall, before applying for a well
licence, advise the Regional Manager, Air Navigation
Requirements, Transport Canada, Edmonton, Alberta, of
the proposed well site, the height of the derrick to be used
and the approximate dates between which drilling
operations are expected to take place.
AR 151/71 s2.090;295/78;350/87
Surface Improvements
2.110(1) No well shall be drilled at any point that is within
(a) 100 metres of any surface improvement
other than a surveyed roadway or road
allowance, or
 (b) 40 metres of a surveyed roadway or road
allowance unless there exist special
circumstances which in the opinion of the
Board justify the drilling of a well within a
lesser distance.
AR 151/71 s2.110;295/78;89/82
Water Pollution Control
2.120(1) No person shall
(a) drill a well or cause or permit a well to be
drilled, or
(b) construct a pit for containing mud, oil, water
and other fluid associated with the well or
cause or permit such a pit to be constructed,
closer than 100 metres, or such greater
distance as the Board may direct, to the
normal high water mark of a body of water
or permanent stream unless he has obtained
written approval from the Board of his plans
to prevent pollution of the water.
(2) The plans referred to in subsection (1) shall
(a) indicate the elevations of the normal high
water mark and surrounding land, and
(b) set forth measures to meet the particular
circumstances that may be encountered
including
(i) the construction and maintenance of
dikes, reservoirs and other installations,
as may be required, and
(ii) the final disposal of mud, oil, water and
other fluid associated with the well or
drilling operation.
AR 151/71 s2.120;2/76;295/78
Part 7: Production Operations
7.070(1) This section applies to any battery that receives gas
containing more than 10 moles per kilomole of hydrogen
sulphide or a higher or lower ratio as the Board may by
order stipulate having regard to the nature of production,
the remoteness of the area and other circumstances.
(2) Repealed
(3) The licensee of a well or the operator of a battery
shall not discharge or permit to be discharged to the
atmosphere stock tank vapours or any other gas produced
from the well, unless they are burned so that essentially all
sulphur compounds are converted to sulphur dioxide, but
the Board on written application may approve another
method of disposal.
(4) Gas burned or disposed of by a method approved
under subsection (3) shall be burned or disposed of so as to
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 3
ensure that the concentrations of hydrogen sulphide and
sulphur dioxide do not exceed
(a) the maximum permissible concentrations set
out in the Alberta Ambient Air Quality
Guidelines as established and amended from
time to time by the Minister of
Environmental Protection,
(b) standards to which the battery is subject
under the Environmental Protection and
Enhancement Act, and
(c) standards specified by the Board.
(5) Gas that is required under subsection (3) to be
burned shall be discharged from a flare line that is in
accordance with the specifications outlined in section
7.060(4).
(6) The Board may, on application, exempt a battery
from any provision of this section where, in the opinion of
the Board, the nature of production, the remoteness of the
area or any other circumstance warrants the exemption.
AR 151/71s7.070;241/71;69/72;71/74;144/74;264/74;229/79;70/88;
321/90;25/98
Part 8: Prevention of Losses, Injuries, Damages
and Fires
Storage
8.010 Earthen structures or excavations shall not be used as
receptacles for crude bitumen, liquid hydrocarbon, process
chemicals or water produced from a well or associated
facility, either by design or normal operating practice,
without the written approval of the Board.
AR 151/71 s8.010;13/98
8.020 Repealed
8.030(1) Each tank or group of tanks containing oil or any
fluid other than fresh water at a battery or processing plant
shall be surrounded by a dike or firewall of a net capacity
greater than that of the largest tank within the dike or
firewall, or such greater capacity as the Board may in any
case require, and the dike or firewall shall be maintained in
good condition and the dike or firewall and the area
encompassed by it kept free from grass, weeds or other
extraneous combustible material, but the Board may
suspend any requirement of this subsection in a particular
case.
(2) Each oil tank or battery of tanks at a well,
production battery or processing plant shall be located so
that the distance from the outer perimeter of the dike to any
surface improvement other than a public roadway is not
less than 60 metres.
 (3) Notwithstanding subsection (2), the Board, where
in its opinion special circumstances exist, may permit the
location of tanks closer to any surface improvement than
the distance therein prescribed.
AR 151/71 s8.030;341/74;229/79
8.031 Notwithstanding section 7.060(3.1), where a pressure
relief valve, rupture disk or burst plate is installed on a
separator, treater or other pressure vessel which receives
production from an oil well, the licensee shall connect the
valve, rupture disk or burst plate fitting by suitable piping
to an open tank, but the Board, upon application, may allow
a licensee to use a system of automatic controls or other
method of avoiding oil spills if it is satisfied that the degree
of protection provided is equivalent to or better than the
venting of relief devices to an open tank.
AR 241/71 s6;70/88
Water Disposal
8.040(1) The licensee of a well or the operator of a battery
or processing plant or associated facility shall store and
dispose of all water produced from a well in a manner
satisfactory to the Board.
(2) No water produced from a well shall be discharged
into an earthen structure or excavation, either by design or
normal operating practice, without the written approval of
the Board.
(3) All water produced to a battery, produced at a well
not connected to a battery or produced at a processing plant
shall be disposed of in accordance with a scheme approved
by the Board pursuant to section 26 of the Act.
AR 151/71 s8.040;241/71;51/74;229/79;350/87;13/98
Control of Oil and Salt Water Spills
8.050(1) When oil or salt water is spilled from a break or
leak in a wellhead, tank, separator, treater or process vessel,
the licensee of the well or operator of the battery, plant, oil
sands scheme or other facility from which the spill
occurred shall take immediate steps to contain and clean up
the oil or salt water that is spilled and shall ensure that the
contaminated product is processed in the operator’s
facilities or is sent to an approved waste processing and
disposal facility unless otherwise approved by the Board.
(2) Where a spill of oil or salt water occurs from a
facility described in subclause (1) and
(a) the oil or salt water is not confined to the
site of the facility from which the spill
occurred, or
(b) the oil or salt water spilled is in excess of 2
cubic metres, the licensee or operator shall
immediately report the size and location of
the spill to the Board by the quickest
effective means.
(3) When so directed by the Board, a report made
pursuant to subclause (2) shall, within two weeks of the
date of the spill, be confirmed in a written report to the
4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
Board and be supplemented with at least the following
additional information:
(a) the time the spill occurred,
(b) a description of the circumstances leading
to the spill,
(c) a discussion of the spill containment and
recovery procedures,
(d) a discussion of steps to be taken to prevent
similar future spills, and
(e) an outline of the proposed spill site
rehabilitation program.
AR 151/71 s8.050;69/72;144/74;2/76;179/76;229/79;399/83
8.051 Where oil or salt water is spilled while being
transported, otherwise than by pipe line, from a well,
battery, gas plant, pipe line or other facility over which the
Board has jurisdiction, to any other like facility, the
licensee of a well or pipe line or operator of a battery, gas
plant or other facility and the owner of the transportation
facility shall immediately
(a) report the spill to the Board and to the
Department of Environmental Protection,
(b) take steps to contain and clean up the oil or
salt water that is spilled, and
(c) ensure that the contaminated oil and salt
water is sent to an approved waste
processing and disposal facility unless
otherwise approved by the Board.
AR 93/73 s5;399/83;25/98
8.052(1) Where any facility poses an environmental hazard
to a water body, the licensee of oil wells, salt water
disposal wells and liquid pipelines shall file with the Board,
on request, a contingency plan encompassing production
and pipeline facilities and trucking routes.
(2) The operator of a facility referred to in subsection
(1) is not required to file a contingency plan if the operator
is an active member of an oil spill co-operative.
(3) A company that is not a member of an oil spill
co-operative shall submit a contingency plan and purchase
spill clean-up equipment to satisfy the Board that no
environmental hazard to a water body exists.
(4) The operator of facilities referred to in subsection
(1) shall meet the objectives set out by the Board and the
Department of Environmental Protection through
(a) participation in spill equipment deployment
training exercises to be conducted
annually,
(b) ready access to equipment and materials
that will enable containment and recovery
of spilled substances, and
 (c) the update and maintenance of manuals at
effective levels.
(5) Where contingency plans are submitted by each
operator or jointly by 2 or more operators or by a spill
co-operative acting on behalf of 1 or more operators, the
plan shall be kept up to date at all times and shall contain
the following:
(a) a description of initial emergency
procedures and response action;
(b) the operator and government contacts and
notification procedures;
(c) topographical maps showing designated
spill control points, access roads, urban
centres, bodies of water and streams, water
supply intakes for municipal and industrial
operations, pipelines, wells and other
operator facilities;
(d) a map index;
(e) a description of all control points in the
area;
(f) river hydrology information;
(g) spill containment and recovery equipment
locations and inventory;
(h) spill containment and recovery and
clean-up procedures effective for the
conditions and spills that may be expected
in the area the plans encompass;
(i) policies for worker safety at an oil spill
containment site;
(j) job descriptions of various personnel
positions in the training exercise.
(6) Where spill equipment deployment training
exercises are conducted, as required by subsection (4)(a),
the operator shall submit, not less than 30 days before any
exercise occurs, an application for approval to the Board
through the Manager, Environment Protection Department,
Energy Resources Conservation Board.
(7) An application referred to in subsection (6) shall
contain the following:
(a) the type of training exercise to be
conducted and the date and legal
description of the lands on which the
training exercise will be conducted;
(b) a map showing the general topography and
location of and the access routes to the
deployment area and the location of any
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 5
municipal water intakes within 3
kilometres of the deployment area;
(c) the proposed spill material and volume to
be used, if any;
(d) comments on the public use of the area,
collection and disposal of garbage and a
statement indicating the extent, if any, of
anticipated surface disturbance to stream
banks or shoreline at the test site;
(e) the name of the landowner on whose land
the training exercise will be held and a
statement indicating that the landowner has
no objection to the exercise proceeding at
the proposed test site;
(f) if the exercise is held on public land, the
necessary clearances obtained by the Board
from the Department of Environmental
Protection.
(8) A report summarizing the training exercise shall
be submitted in quadruplicate to the Board within 30 days
after completion of the training exercise.
(9) If the training exercise is a co-operative training
exercise, the report shall list co-operative membership and
delinquent membership attendance at the exercise and
contain a discussion of the general effectiveness of the
exercise, recovery of oil and any observed deleterious
environmental effects resulting from the training exercise.
(10) Oil spill treating agents are not approved for use
in Alberta.
(11) The Board may, on application, exempt an
operator from any provision of this section where, in the
opinion of the Board, the nature of production, the
remoteness of the area or any other circumstance warrants
the exemption.
AR 70/88 s7;25/98
8.060 Where a well or battery is located closer than 100
metres to the normal high water mark of a body of water or
permanent stream or is in a location such that in the opinion
of the Board an oil spill or leak may reach the water, the
licensee or operator shall
(a) where a well is not on pump, install on the
well head a valve which closes
automatically to shut off an uncontrolled
flow of oil from the well in the event of a
failure of the well head, surface facilities or
gathering line,
(b) at the direction of the Board, install in the
well a packer and a subsurface valve to shut
off automatically an uncontrolled flow of oil
from the well in the event of a failure of the
well head or production casing,
 (c) construct pits, dikes, trenches or other
structures or installations to contain the oil,
and
(d) submit at the request of the Board, a plan to
limit the spread of and to recover oil from
the surface of the water in the event of a leak
or spill, such plan to include details of
procedures, materials and equipment
proposed to be used.
AR 151/71 s8.060;250/77;295/78
8.070 Where in the opinion of the Board, the location or
condition of a well or battery is such that it may become a
source of serious water pollution, the Board may require
that the well or battery be abandoned.
AR 151/71 s8.070
Burning Vented Gas
8.080(1) The licensee of a well or the operator of an oil
sands scheme shall burn any significant volume of gas that
is vented to the atmosphere.
(2) The licensee shall construct and safeguard all flare
pits and ends of flare line so that no hazard to public
property and forest cover will be created and so that they
are not located closer than 100 metres to a surface
improvement, except a surveyed roadway, but the Board
where, in its opinion, special circumstances exist, may
prescribe a greater or lesser distance.
(3) No flare pit or open end of a flare line shall be
placed or remain within 50 metres of a well or oil storage
tank, or within 25 metres of any oil or gas processing
equipment, but the Board, having regard to the volume and
nature of the gas and the flash point and other
characteristics of the oil being produced, may suspend the
application in a field or pool of the requirement herein
respecting the distance of a flare pit or open end of a flare
line from a well and in such case, notwithstanding
subsection (1), gas vented from the flare line shall not be
burned.
AR 151/71 s8.080;295/78
Fired Equipment and Engine Exhausts
8.090(1) In this section
(a) “fire” means any unprotected flame or
source of ignition;
(b) “flame type equipment” means any electric
or fired heating equipment using an open
flame, electric arc or element and includes a
space heater, torch, heated process vessel,
boiler, electric arc or open flame welder, or
an open element electric heater or appliance;
(c) “process vessel” means a heater, dehydrator,
separator, treater or any vessel used in the
processing or treatment of produced gas or
oil.
6 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
(2) No person shall create or cause to be created any
fire within 50 metres of a well, oil storage tank or other
source of ignitable vapour.
(3) No oil storage tank shall be placed or remain
within 50 metres of any well, but the Board may prescribe a
distance of less than 50 metres but not less than 15 metres
in any field or at any well, having regard to the products of
the well.
(4) No flame type equipment shall be placed or
operated within 25 metres of a well, oil storage tank, or
other source of ignitable vapour, except
(a) where the well is
(i) a water supply well, or
(ii) a water injection well equipped with a
suitable packer and with the surface
casing annulus vented outside any
building,
or
(b) that emergency work requiring the use of
flame type equipment may be conducted
within 25 metres of a well, if the wellhead
valves and the blow out preventer, if one is
installed, are closed, or
(c) where extenuating circumstances exist, the
Board suspends the application of this
subsection in any field or area.
(5) No flame type equipment shall be placed or
operated within 25 metres of any process vessels unless,
where such is applicable, the flame type equipment is fitted
with an adequate flame arrester.
(6) No flame type equipment shall be located in the
same building as any process vessel or other source of
ignitable vapour, unless
(a) the air intakes and flues of all burners are
located outside the building,
(b) relief valves, safety heads, and other
sources of ignitable vapours are vented
outside the building and discharged above
roof level, and
(c) the building is adequately cross ventilated.
(7) All process vessels and equipment from which
any ignitable vapour may issue shall be safely vented to the
atmosphere, and all vent lines from oil storage tanks which
are vented to flare pits or flare stacks shall be provided with
flame arrestors or other equivalent safety devices.
(8) All installations at or near any well, process
vessel, oil storage tank or other source of ignitable vapour
shall be made in compliance with regulations made under
the Electrical Protection Act or under the Occupational
Health and Safety Act.
 (9) An exhaust pipe from an internal combustion
engine, located within 25 metres of any well, process
vessel, oil storage tank or other source of ignitable vapour,
shall be so constructed that
(a) any emergence of flame along its length or
at its end is prevented, and
(b) the end is not closer to the vertical centre
line of the well projected upward than 6
metres and is directed away from the well.
(10) Each licensee of a well or operator of a battery or
other facility at which there is located an oil storage tank or
other source of ignitable vapour shall enforce the
provisions of this section.
AR 151/71 s8.090;93/73;2/76;179/76;295/78;416/83
8.100(1) The licensee of the well or a contractor who has
contracted to perform any operation at the well shall
provide any diesel engine within 25 metres of the well with
(a) adequate air intake shut-off valves, equipped
with a remote control readily accessible
from the driller’s station, or
(b) a system for injecting an inert gas into the
engine’s cylinders, which system shall be
equipped with a remote control readily
accessible from the driller’s station, or
(c) a suitable duct so that air for the engine is
obtained at least 25 metres from the well, or
(d) another approved device.
(2) Where an installation has been made in accordance
with clause (a) or (b) of subsection (1), the licensee of the
well and the operator shall test the stopping of the engine
by remote control
(a) before the cement plug at the shoe of the
surface casing is drilled out, or
(b) if the well has been completed, before any
servicing operations commence,
and thereafter, at least once in each seven-day period
during the drilling or servicing of the well, shall test the
installation to make sure the valve closes or inert gas is
injected.
(3) If upon testing pursuant to subsection (2) the
equipment is found defective, it shall be made serviceable
at once.
(4) Each test pursuant to this section shall be reported
with full particulars on the daily record of operations.
AR 151/71 s8.100;295/78
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 7
Use of High Vapour Pressure Hydrocarbons
8.110(1) In this section a “high vapour pressure
hydrocarbon” means any hydrocarbon and stabilized
hydrocarbon mixture with a Reid vapour pressure greater
than 14 kilopascals.
(2) Where the licensee or operator of a well uses a
high vapour pressure hydrocarbon in an operation at a well
other than in the hydraulic fracturing of a formation, he
shall observe the following rules:
(a) no open tanks shall be used for storing or
gauging or measuring the pumping rate;
(b) a minimum distance of 50 metres shall be
maintained between the wellhead and
storage tank;
(c) positive shut-off valves shall be installed
between the tank and pump and between
the pump and wellhead;
(d) a check valve shall be installed between the
pump and the well to prevent backflow
from the well;
(e) all surface lines downstream from the
pump shall be pressure tested to 10 000
kilopascals above anticipated maximum
pressure to be encountered;
(f) no significant wastage shall occur.
(3) High vapour pressure hydrocarbons shall not be
blended with propping agents for the purpose of
hydraulically fracturing a formation, but the Board may, on
application, approve a given fracturing program if
conclusive evidence is submitted to show that there is not
another carrying fluid available that will be similarly
effective.
AR 151/71 s8.110;69/72;286/82
Smoking
8.120(1) No person shall smoke within 25 metres of a well,
separator, oil storage tank or other unprotected source of
ignitible vapour or on a rig or derrick at a well site.
(2) Each licensee of a well and each contractor who
has contracted to manage or perform any operation at a
well shall enforce the provisions of subsection (1) at the
well.
(3) Where a person smokes within 25 metres of a well
or on, or within 25 metres of, a rig, derrick, separator, oil
storage tank or other unprotected source of ignitable vapour
at a well site,
(a) the person so smoking is guilty of a
contravention of subsection (1), and
 (b) a contractor who is the employer of the
person so smoking and the licensee of the
well each is guilty of a contravention of
subsection (2) regardless of whether he had
knowledge of the smoking and regardless
of whether he had taken any steps to guard
against smoking.
AR 151/71 s8.120;295/78
Blowout Prevention Requirements
8.129(1) The provisions of sections 8.130 to section 8.149,
inclusive, apply to any well that is being drilled, tested,
abandoned, completed, reconditioned or serviced.
(2) Regulations 8.130 to 8.143, inclusive, shall be
defined as the Drilling Blowout Prevention Requirements
and shall be applied to any well where production casing
has not been set and cemented.
(3) Regulations 8.144 to 8.148, inclusive, shall be
defined as the Servicing Blowout Prevention Requirements
and shall be applied to any well where production casing
has been set and cemented.
(4) The Board may, upon its own motion or upon
application, vary or specify the blowout prevention
requirements which apply to any well or wells.
(5) The Board may, upon its own motion or upon
application, vary the classification set out in sections 8.131
and 8.144 for any well or wells in any pool, field or area.
(6) The Board may, upon its own motion or upon
application, vary the design or requirements for any
classification set out in sections 8.131 and 8.144.
AR 15/77 s6;51/81
Drilling Blowout Prevention Requirements
8.130(1) The licensee of a well shall ensure that the well has
installed thereon and maintained at all times blowout
prevention equipment that is
(a) adequate to shut off any flow at the well
head whether or not any type of tool or
equipment is being used in the hole, and
(b) in accordance with the well classification set
out in section 8.131 and with the
specifications set out in Schedule 8.
(2) Drilling-through components installed between the
top flange of the uppermost blowout preventer element and
the rotary table shall be constructed so as to permit their
removal while drill pipe or other equipment is in the drilled
hole.
(3) Subsection (2) does not apply to Class I and Class
II wells as defined in section 8.131 or to drilling operations
utilizing a rotating head.
AR 151/71 s8.130;15/77;104/77;51/81;217/88
8 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
8.131 For the purpose of the drilling blowout prevention
requirements, and the blowout prevention equipment
required in Schedule 8, wells are classified as set out
below:
(a) Class I: a well in which no surface casing
is set,
(b) Class II: a well in which the depth is less
than or equal to 750 metres,
(c) Class III: a well in which the depth is
greater than 750 metres and less than or
equal to 1800 metres,
(d) Class IV: a well in which the depth is
greater than 1800 metres and less than or
equal to 3600 metres,
(e) Class V: a well in which the depth is
greater than 3600 metres and less than or
equal to 6000 metres,
(f) Class VI: a well in which the depth is
greater than 6000 metres.
8.132(1) The casing bowl shall have
(a) the flange as an integral part of the casing
bowl,
(b) at least one side outlet which shall be
flanged or studded for wells in Classes V
and VI, and
(c) at least one valve except where a drilling
spool has been installed between the casing
bowl and the lower ram type blowout
preventer.
AR 15/77 s8;104/77;51/81
8.133(1) All blowout preventers shall be hydraulically
operated, and except for wells in Class I, shall be connected
to an accumulator system.
(2) The accumulator system required by subsection (1)
shall be
(a) capable of providing without recharging,
fluid of sufficient volume and pressure to
open the hydraulically operated valve on
the bleed-off line, to effect full closure of
the annular preventer and to retain a
pressure of 8400 kilopascals on the
accumulator system,
(b) installed and operated in accordance with
the manufacturer’s specifications,
(c) connected to the blowout preventers and
the hydraulically operated valve on the
bleed-off line with lines of working
pressure equal to the working pressure of
the accumulator, and where lines are
 located under the substructure, be of steel
construction unless completely sheathed
with adequate fire resistant sleeving,
(d) recharged by an automatic, pressure
controlled pump capable of recovering
within 5 minutes the accumulator pressure
drop resulting from the operation of the
hydraulically operated valve and the full
closure of the annular preventer,
(e) capable of closing any ram type blowout
preventer within 30 seconds using only the
accumulator,
(f) capable of closing any annular type
blowout preventer of a size up to an
including 350 millimetres bore diameter
within 60 seconds,
(g) capable of closing any annular type
blowout preventer of a size greater than
350 millimetres bore diameter within 90
seconds, and
(h) equipped with readily accessible fittings
and gauge to determine the precharge
pressure.
(3) The accumulator system shall be connected to a
nitrogen supply capable of opening the hydraulically
operated valve and capable of closing the annular blowout
preventer and one ram type preventer.
(4) The nitrogen supply required pursuant to
subsection (3) shall
(a) be under a pressure of not less than 12 500
kilopascals, and
(b) have a gauge installed, or readily available
for installation, to determine the pressure
of each nitrogen container.
(5) Ram type blowout preventers which are not
equipped with automatic ram locking devices shall have
hand wheels either installed or readily accessible for
installation.
(6) The blowout prevention system shall include
(a) operating controls for each blowout
preventer and the hydraulically operated
valve on the bleed-off line, located near the
driller’s position so that access to them is
not restricted, and
(b) an additional set of operating controls that
are
(i) capable of closing each blowout
preventer and opening the
hydraulically operated valve on the
bleed-off line,
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 9
(ii) located at least 15 metres from the
well, and
(iii) readily accessible and shielded or
housed to protect the operator from
the flow from the well.
AR 15/77 s9;51/81
8.134(1) The blowout prevention system shall, except for
wells in Class I, include a kill system for the purpose of
pumping fluid into the well.
(2) The kill system required by subsection (1) shall
(a) consist of an arrangement of valves and
steel lines which have a working pressure
equal to that of the blowout prevention
system specified in Schedule 8 for the
applicable class of well,
(b) have a kill line connecting the mud line to
the drilling spool,
(c) for wells in Classes V and VI, have the kill
line connected to each drilling spool so that
fluid may be pumped through either or
both spools,
(d) be valved to isolate the kill line from the
stand pipe,
(e) have two flanged valves installed on each
drilling spool, and
(f) have lines of at least 50 millimetre nominal
diameter, except for wells in Classes V and
VI which shall be 75 millimetres.
(3) A flexible hose may be installed in place of the
steel kill line provided that the hose
(a) has a pressure rating equal to that of the
blowout preventer system,
(b) has the same internal diameter as the steel
line,
(c) has factory installed connections,
(d) is sheathed to provide an adequate fire
resistant rating,
(e) is marked so that its manufacturer can be
readily identified,
(f) does not contain bends with a radius less
than the manufacturer’s specified minimum
bending radius,
(g) is secured to prevent stresses on connecting
valves and piping, and is protected from
mechanical damage, and
 (h) is shop serviced and shop tested to its
working pressure at least once every three
years and the test data and maintenance
performed shall be recorded and made
available to the Board upon request.
AR 15/77 s9;51/81
8.135(1) The blowout prevention system shall include a
bleed-off system for the purpose of bleeding off well
pressure.
(2) An accurate pressure gauge and other necessary
equipment must be installed or readily accessible for
installation on the stand pipe or other suitable connection to
provide the drill pipe pressure at the choke control location.
(3) The bleed-off system required by subsection (1)
shall
(a) consist of an arrangement of valves, chokes
and steel lines which have a working
pressure equal to that of the blowout
prevention system specified in Schedule 8
for the applicable class of well, except that
part of the bleed-off line downstream from
the last valve on the bleed-off manifold,
and
(b) contain only straight pipe or 1.57 radian
bends constructed of tees and crosses
blocked on fluid turns, and
(c) be securely tied down.
(4) The bleed-off system for wells in Class I shall
consist of
(a) a line having a minimum nominal diameter
of 75 millimetres, containing a quick
opening valve and terminating in an
earthen pit at least 50 metres from the well
when drilling with mud, or
(b) a line having a minimum nominal diameter
of 100 millimetres and terminating in an
earthen pit at least 50 metres from the well
when drilling with air.
(5) The section of bleed-off line connecting the
drilling spool to the choke manifold shall
(a) have a nominal diameter of at least 75
millimetres,
(b) be connected by flanges and conform to the
requirements specified in subsection (3),
(c) be connected to both spools for wells in
Classes V and VI,
(d) contain 2 flanged valves installed on the
drilling spool, one of which must be
hydraulically operated, and where 2 spools
are installed the hydraulically operated
10 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
valve shall be connected to the upper spool,
and
(e) for wells in Classes V and VI contain a
valved outlet on the line from the lower
spool for the purpose of installing an
auxiliary bleed-off line directly to the flare
pit.
(6) A flexible hose may be installed in the section of
bleed-off line connecting the drilling spool to
the choke manifold provided the hose conforms
to the requirements specified in section 8.134,
subsection (3).
(7) The choke manifold shall
(a) be constructed in conformance with the
requirements of subsection (3),
(b) have flanged connections for wells in
Classes IV, V and VI,
(c) permit the flow from the well to be
diverted
(i) to the flare pit through a 75 millimetre
minimum nominal diameter line, and
(ii) to a mud system line and a flare pit
line through either of two 50
millimetre minimum nominal
diameter choke lines, 75 millimetre
minimum for wells in Classes V and
VI,
(d) contain two adjustable chokes, one in each
choke line, valves to isolate each choke,
and for wells in Classes V and VI one
choke must be remotely operated,
(e) be constructed with a valved outlet located
so that regardless of which line is in use,
the casing pressure can be monitored by an
accurate pressure gauge which shall be
either installed or readily accessible for
installation,
(f) be equipped so as to provide the casing
pressure at the choke control where a
remotely operated choke is installed,
(g) be constructed to provide the flow paths
illustrated in Schedule 8, although not
necessarily conforming to the exact
configurations there shown,
(h) be located outside the substructure, readily
accessible and heated to protect the
manifold from freezing.
(8) A line from the manifold to the mud system shall
(a) be connected to each choke line,
 (b) be at least the same nominal diameter as
the choke lines, and
(c) direct the flow to a mud tank through a
mud-gas separator except where the pump
suction is taking fluid from earthen pits.
(9) The section of bleed-off line downstream from the
last valve on the choke manifold to the flare pit shall
(a) have a nominal diameter of at least 75
millimetres,
(b) extend at least 50 metres from the well and
be securely tied down, and
(c) terminate in a slightly downward direction
into an earthen pit which shall
(i) be excavated to a depth of not less
than 2 metres,
(ii) have side and back walls rising not
less than 2 metres above ground level,
(iii) be constructed to resist the erosion of
a high pressure flow of gas or liquid,
and
(iv) be shaped to contain the liquid.
(10) Auxiliary bleed-off lines, where installed, shall be
at least the same nominal diameter as the lines being
extended and conform to the requirements of subsection
(9).
AR 15/77 s10;51/81;217/88
8.136 Where a mud tank is in service, the licensee shall
install and maintain a mud-gas separator connected to a
separate flare line with a diameter at least 25 millimetres
larger than the inlet line and terminating in an earthen pit
50 metres from the well.
AR 15/77 s11;51/81
8.137(1) Where a mud tank is in use, a device shall be
installed and maintained to provide warning at the driller’s
position of a change of the level of fluid in the mud tank or
of an imbalance in the volume of fluids entering and
returning from the well, and for wells in Classes V and VI,
the device shall be either electrically, pneumatically or
hydraulically operated.
(2) The drilling mud system shall be equipped with a
device to accurately measure the volume of drilling fluid
required to fill the hole while pulling pipe from the well.
(3) The licensee, while pulling pipe from a well, shall
ensure that
(a) the hole is filled with drilling fluid at
sufficiently frequent intervals so that the
fluid level in the wellbore does not fall
below a depth of 30 metres or such greater
depth as the Board may approve, and
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 11
(b) the volume of fluid is recorded each time
the hole is filled.
AR 15/77 s11;104/77;51/81
8.138 During cold weather operations, the licensee shall
ensure that
(a) sufficient heat is provided to the blowout
preventer stack and associated valves, kill
system, and accumulator system and choke
manifold to maintain their effectiveness,
and
(b) all lines in the bleed-off system, including
those sections between the blowout
preventers and the choke manifold, are
(i) empty,
(ii) filled with a non-freezing fluid that is
miscible with water, or
(iii) heated.
AR 15/77 s12;51/81;217/88
8.139 The licensee shall maintain on the drilling rig in a
readily accessible location a full opening drill string safety
valve in the open position and a device capable of stopping
back-flow, both of which can be stripped into the well
when installed in the drill pipe or drill collars.
AR 15/77 s12;51/81
8.140 Where a well is being drilled with air, the licensee
shall install and maintain
(a) in addition to the blowout prevention
equipment required in Schedule 8, a
rotating head that diverts the flow during
the period the well will be drilled with air,
(b) a diverter line not less than 50 metres in
length,
(c) a reserve volume of drilling fluid equal to
at least 1.5 times the capacity of the hole,
(d) when drilling formations that may contain
hydrogen sulphide, a continuous hydrogen
sulphide monitor on the diverter line, and
(e) a continuous ignition device at the end of
the diverter line.
AR 151/71 s8.140;15/77;51/81
8.141(1) The licensee of a well shall ensure that a ten
minute pressure test is conducted on the casing and
(a) each ram type blowout preventer prior to
drilling the cement out of the surface,
intermediate and production casing, to
1400 kilopascals with a low viscosity fluid,
and the test shall be conducted prior to
each ram type test described in clauses (b)
and (c),

(b) each ram type and annular blowout
preventer and the bleed-off manifold prior
to drilling the cement out of the surface
casing, to 7000 kilopascals or to a pressure
numerically equivalent in kilopascals to 50
times the setting depth in metres of the
surface casing, whichever is the lesser,
(c) each ram type blowout preventer and the
bleed-off manifold prior to drilling the
cement out of the intermediate and
production casing to a pressure equivalent
to the working pressure of the ram type
preventer, except that, where the pressure
at the casing shoe would exceed 67 per
cent of the casing burst pressure, the casing
shall be excluded from the test by using a
casing hanger plug, and
(d) each annular preventer, prior to drilling the
cement out of the intermediate and
production casing, to a pressure equivalent
to one-half its working pressure.
(2) The licensee shall not proceed with any operation
at a well until the tests required in subsection (1) have been
satisfactorily completed.
(3) Casing exposed to drill pipe wear shall be tested
every 30 days to determine its adequacy for pressure
control by either
(a) running a casing inspection log to
determine casing wear, or
(b) pressure testing to a pressure not greater
than 50 per cent of the burst pressure of the
weakest section of the casing, or to the
working pressure of the blowout
preventers, whichever is lesser.
(4) The licensee of a well shall ensure that the
appropriate blowout prevention equipment is mechanically
tested at least daily and any equipment found defective
shall be made serviceable before operations are resumed.
(5) For any annular type blowout preventer, all
mechanical and pressure tests required by this section shall
be conducted with pipe in the hole.
(6) All tests shall be reported in the drilling log book,
and in the case of a pressure test, the report shall show the
blowout preventer tested, the test duration and the test
pressures observed at the start and finish of each test.
(7) At least once every three years all blowout
preventers shall be shop serviced and shop tested to their
working pressure and the test data and maintenance
performed shall be recorded and made available to the
Board upon request.
AR 15/77 s13;51/81
12 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
8.142(1) The licensee of a well shall at all times ensure that
(a) the rig crew is trained in the operation of
the blowout prevention equipment,
(b) the driller has a “First Line Supervisor”
certificate issued within the previous three
years by the Petroleum Industry Training
Service in blowout prevention and kick
control procedures,
(c) a Licensee Wellsite Representative and a
Rig Manager (Tool Push) possess a
“Second Line Supervisor’s” certificate in
well control procedures, issued within the
previous 2 years by the Petroleum Industry
Training Service, and that a Licensee
Wellsite Representative or a Rig Manager
(Tool Push), or both, are readily available
at all times,
(d) blowout prevention drills are performed
prior to drilling out the surface casing shoe,
(e) blowout prevention drills are performed by
each drilling crew every seven days,
(f) drills performed in accordance with clauses
(d) and (e) are recorded in the drilling log
book, and
(g) the procedures, calculations, formulas and
current data needed to control a kick at a
well are posted at the rig in a form
acceptable to the Board.
(2) The licensee shall make available to the Board
upon request evidence of the qualifications of any person
referred to in subsection (1), clauses (b) and (c).
AR 15/77 s14;51/81;224/98
8.143 When a drill stem test is conducted on a well, the
licensee shall ensure that there is
(a) a device installed above the down-hole test
equipment to allow circulation of fluids
through the drill string, and
(b) a remote controlled master valve installed
on the testing head.
AR 15/77 s15;51/81
Servicing Blowout Prevention Requirements
8.144(1) For the purpose of the servicing blowout
prevention requirements and the blowout prevention
equipment required in Schedule 10, wells are classified as
set out below:
(a) Class I: a well in which the reservoir
pressure of the zone is less than 5500
kilopascals, there is no hydrogen sulphide
present in a representative sample of the
gas and the well
 (i) is a gas well, or
(ii) produces heavy oil with a density
greater than 940 kilograms per cubic
metre, a gas-oil ratio of less than 70
cubic metres per cubic metre, and the
well produces by primary recovery or
is included in a waterflood scheme.
(b) Class II: a well where the pressure rating of
the production casing flange is less than or
equal to 21 000 kilopascals and the
hydrogen sulphide content in a
representative sample of the gas is less than
10 moles per kilomole, and
(c) Class III: a well where the pressure rating
of the production casing flange is
(i) greater than 21 000 kilopascals, or
(ii) less than or equal to 21 000
kilopascals and the hydrogen sulphide
content in a representative sample of
the gas is 10 moles per kilomole or
greater.
(2) The licensee of a well during completion, servicing
or reconditioning shall ensure that
(a) the well is under control,
(b) blowout prevention equipment is installed
and maintained to enable the shutoff of any
flow from the well regardless of the type or
diameter of tools or equipment in the well,
(c) the blowout prevention equipment installed
is in accordance with the well classification
set out in subsection (1) and with the
specifications set out in Schedule 10,
(d) the blowout prevention equipment has a
pressure rating equal to or greater than the
pressure rating of the production casing
flange, or the formation pressure,
whichever is the lesser, and
(e) hydraulic ram type blowout preventers
which are not equipped with an automatic
ram locking device have hand wheels
either installed or readily accessible for
installation.
(3) Notwithstanding subsection (2), clause (a), gas
wells in Class I may be completed, serviced, or
reconditioned while the well is flowing.
AR 15/77 s15;51/81
8.145(1) All blowout preventers shall be hydraulically
operated and connected to an accumulator system.
(2) The accumulator system required by subsection (1)
shall be
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 13
(a) installed and operated in accordance with
the manufacturer’s specifications,
(b) connected to the blowout preventers with
lines of working pressure equal to the
working pressure of the system and within
7 metres of the well the lines shall be of
steel construction unless completely
sheathed with adequate fire resistant
sleeving,
(c) capable of providing, without recharging,
fluid of sufficient volume and pressure to
effect full closure of all preventers, and to
retain a minimum pressure of 8400
kilopascals on the accumulator system,
(d) recharged by a pressure controlled pump
capable of recovering within five minutes
the accumulator pressure drop resulting
from full closure of all preventers,
(e) capable of closing any ram type preventer
within 30 seconds,
(f) capable of closing the annular preventer
within 60 seconds,
(g) equipped with readily accessible fittings
and gauge to determine the pre-charge
pressure, and
(h) equipped with a check valve between the
accumulator recharge pump and the
accumulator.
(3) The accumulator system shall be connected to a
nitrogen supply capable of closing all of the blowout
preventers installed on the well.
(4) The nitrogen supply required pursuant to subsection
(3) shall
(a) be capable of providing sufficient volume
and pressure to effect full closure of all
preventers, and to retain a minimum
pressure of 8400 kilopascals, and
(b) have a gauge installed, or readily available
for installation, to determine the pressure
of each nitrogen container.
(5) For wells in Classes I and II the blowout prevention
system
(a) may utilize the rig hydraulic system to
recharge the accumulator, and
(b) shall have operating controls for each
preventer in a readily accessible location
near the operator’s position, and an
additional set of controls located at a
distance from the well of not less than 7
metres.
 (6) For wells in Class III the blowout prevention
system shall have
(a) an independent accumulator system with
operating controls for each preventer
located at least 25 metres from the well,
shielded or housed to protect the operator
from flow from the well, and
(b) an additional set of controls in a readily
accessible location near the operator’s
position.
AR 51/81 s5;19/90;169/90
8.146(1) For gas wells in Class I the blowout prevention
system shall have
(a) a diverter system consisting of two 50
millimetre nominal diameter lines, or one
75 millimetre line, connected to a valved
spool below the blowout preventers,
extending at least 50 metres from the well
and securely tied down,
(b) a shut-off device installed in the bottom
joint of tubing to prevent flow when
tripping the tubing into or out of the well,
and
(c) a tubing stripper.
(2) For wells in Classes II and III the blowout
prevention system shall have two lines, one for bleeding off
pressure and one for killing the well, which shall
(a) be either steel, or flexible hose,
(b) be valved and having a working pressure
equal to or greater than that required for the
blowout prevention equipment described in
section 8.144, subsection (2), clause (c),
(c) have one line connected to the rig pump
and one line connected to the tank,
(d) be fitted with the necessary equipment to
allow one line to be connected to the tubing
and a second line to be connected to the
well annulus using
(i) a flanged outlet on the blowout
preventer below the lowest set of
rams, or
(ii) an outlet on a spool located below the
blowout preventers,
(e) be at least 50 millimetres nominal
diameter, and
(f) be securely tied down.
(3) The blowout prevention system for wells in Classes
II and III shall include a manifold which shall
14 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
(a) consist of an arrangement of valves and
steel lines which have a working pressure
equal to that of the blowout prevention
system specified in Schedule 10 for the
applicable class of well,
(b) contain a check valve to prevent flow from
the well to the rig pump,
(c) contain a pressure relief valve upstream of
the check valve, and
(d) be equipped with an accurate pressure
gauge which shall be either installed or
readily accessible for installation.
(4) An accurate pressure gauge to determine the well
annulus pressure during a well shut-in shall be either
installed or readily accessible for installation.
(5) When a diesel ignition engine is used for
transferring fluid either to or from the rig tank, it shall be
equipped with
(a) adequate air intake shut-off valves,
(b) a system for injecting an inert gas into the
engine’s cylinders,
(c) a suitable duct so that air for the engine is
obtained at least 25 metres from the well,
or
(d) another approved device.
(6) The licensee shall maintain on the service rig in a
readily accessible location a full opening safety valve in the
open position which can be attached to the tubing or other
pipe in the well.
AR 51/81 s5;19/90
8.147(1) Before commencing operations at a well, except
for a well in Class I, the licensee shall ensure that a
10-minute pressure test is conducted on
(a) each ram preventer to 1400 kilopascals,
prior to the tests described in clauses (b)
and (c),
(b) each ram preventer, the full opening safety
valve and the connection between the stack
and the wellhead to the wellhead pressure
rating or the formation pressure, whichever
is less, and
(c) each annular preventer to 7000 kilopascals
or the formation pressure, whichever is
less.
(1.1) For an annular type blowout preventer, all
mechanical and pressure tests required by this section shall
be conducted with pipe in the hole.
 (2) The licensee of a well shall ensure that the blowout
prevention equipment is mechanically tested daily and any
equipment found defective shall be made serviceable
before operations are resumed.
(3) All tests shall be reported in the servicing log book,
and in the case of a pressure test the report shall state the
blowout preventer tested, the test duration and the test
pressure.
(4) At least once every three years all blowout
preventers shall be shop serviced and shop tested to their
working pressure and the test data and the maintenance
performed shall be recorded and made available to the
Board upon request.
AR 51/81 s5;19/90
8.148(1) At all times the licensee of the well shall ensure
that
(a) a Driller who is the holder of a valid
certificate issued by the Petroleum Industry
Training Service in servicing blowout
prevention and well control procedures is
on the well site at any time operations are
in progress,
(b) the rig crew is trained in the operation of
the blowout prevention equipment,
(c) blowout prevention drills are performed by
each rig crew every seven calendar days,
and
(d) drills performed in accordance with clause
(c) are recorded in the servicing log book.
(2) The licensee shall make available to the Board
upon request evidence of the qualifications of any person
referred to in subsection (1), clause (a).
(3) During cold weather operations sufficient heat
shall be provided to maintain the effectiveness of the
blowout prevention system.
(4) Repealed
(5) Repealed
(6) The location of the equipment used at the well site
shall be spaced in accordance with the minimum distances
specified in Schedule 11.
AR 51/81 s5;19/90;169/90;79/91
Drilling and Servicing Inspections
8.149(1) The Board or its authorized representative may
make a direction requiring the licensee of the well to
(a) test the operation and effectiveness of the
equipment required by sections 8.100,
8.130, 8.133, 8.135, 8.144 and 8.145,
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 15
(b) conduct a pressure test of the blowout
prevention equipment, using where
necessary a hanger plug or casing packer,
and
(c) perform a blowout prevention drill.
(2) Upon a direction made by the Board or its
authorized representative and if the licensee believes it is
safe to do so, the licensee of a well shall suspend or cause
to be suspended any operation or service being performed
at a well until any test required to be made, pursuant to
subsection (1), has been completed.
(3) Any direction made by the Board or its authorized
representative pursuant to subsection (1) may be made to
the licensee of the well or to any contractor or other person
performing an operation or service, referred to in
subsection (2).
AR 51/81 s5
Care of Well Sites and Battery Sites
8.150(1) In this section “waste material” means water,
rubbish, debris, drilling fluids, oil, oily waste, sand tailings
or other products from a well, oil sands operation, tank,
pipeline or other production installation.
(2) The licensee of the well or operator of the battery
or scheme shall
(a) ensure that waste material is contained at
all times,
(b) dispose of, or cause to be disposed of, all
waste material in such a manner that no
soil, surface water or underground source
of potable water is or may be polluted, and
(c) ensure that waste material does not create
or constitute a safety hazard or nuisance.
(3) An earthen pit at a well site used to store liquid
wastes from a drilling or servicing operation shall
(a) be excavated to a depth to which it may be
filled with liquid, and
(b) be so located and constructed that it will
not collect natural run-off water.
(4) Where the surface topography is such that a
satisfactory storage pit of sufficient capacity cannot be
constructed, the licensee of a well or operator of a battery
shall contain all liquid waste in tanks and shall remove such
liquid waste without undue delay to an area approved under
subsection (2) clause (b).
(5) Upon the completion, suspension or abandonment
of a well or the abandonment of a battery, the licensee of
the well or operator of the battery shall
(a) dispose of all liquid waste,
 (b) clear the area of debris,
(c) fill all excavations made in connection with
the well or battery, and
(d) advise the appropriate Board Area Office
when the operation is completed.
(6) The licensee of a well or the operator of a battery
shall maintain the well or battery site in a clean condition.
(6.1) All waste material, except rubbish and drilling
fluids, shall be disposed of at an approved waste processing
and disposal facility unless otherwise approved by the
Board.
(7) If the Board is satisfied that such disposal methods
will not pollute air, soil or potable water sources it may,
upon application, approve other disposal methods instead
of those prescribed by this section.
AR 151/71 s8.150;241/71;69/72;51/81;399/83
8.160 The operator of a waste processing and disposal
facility shall
(a) ensure that waste material is contained at
all times,
(b) dispose of, or cause to be disposed of, all
waste material in such a manner that no
soil, surface water or underground source
of potable water is or may be polluted,
(c) ensure that waste material does not create
or constitute a safety hazard or nuisance,
(d) maintain the site in a clean condition, and
(e) erect identification signs and post warning
symbols in accordance with section 6.020.
AR 151/71 s8.160;69/72;399/83;321/90
Fencing
8.170(1) At each battery at which the hydrogen sulphide
concentration in a representative sample of the gas from
any well producing to the battery is found to exceed 10
moles per kilomole, or such higher or lower ratio as the
Board may by order stipulate in a particular case, the
licensee shall construct and maintain an adequate fence
around the battery, but the Board, on application, may
exempt a battery from the provisions of this section where
it is of the opinion that the pressures, nature of production,
remoteness of area or other circumstances warrant the
exemption.
(2) For the purpose of subsection (1) a fence shall be
considered adequate if,
(a) where a battery is within 800 metres of an
occupied dwelling, rural school, picnic
grounds or the like, it is at least 2 metres
high, small mesh industrial type,
completely enclosing the battery, and
16 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
equipped with a gate that is locked when
the battery is unattended, or
(b) where a battery is located elsewhere, it is a
cattle type fence with a minimum of four
strand barbed wire and either a gate or
cattle guard.
AR 151/71 s8.170;229/79
8.180(1) The licensee of a well that is equipped with a
pumping unit and located in or within 800 metres of the
boundaries of a city, town, new town, village, summer
village, hamlet or other incorporated centre, unrestricted
country development, public facility, picnic area or
campground shall enclose the well and pumping unit with a
fence suitable for preventing access to or tampering with
the well and pumping unit.
(2) A fence required by subsection (1) shall be
(a) of steel mesh, with the mesh not greater
than 130 square centimetres,
(b) not less than 2 metres high,
(c) placed around the entire pumping unit, well
head and cellar, and
(d) equipped with a gate that is locked when
the well is unattended.
(3) If, in the opinion of the Board, the location of a
well that is equipped with a pumping unit is such that it is
or may become a serious hazard to the general public, the
Board may require that the well be fenced in accordance
with subsection (2).
(4) The Board may, on application, exempt the
licensee from or vary any of the requirements of this
section if, in the opinion of the Board, circumstances
warrant the exemption or variation.
AR 151/71 s8.180;229/79;321/90
General
8.190(1) The licensee or operator of a well shall not permit a
well to flow uncontrolled.
(2) The licensee shall
(a) record in the drilling log book, any
uncontrolled flow of gas or liquid from the
well, and
(b) record the remedial measures taken to
control the flow.
(3) The licensee shall advise the appropriate area
office of the Board immediately by the quickest, most
effective means, of any well flowing uncontrolled.
 (4) Within 30 days after a well flowing uncontrolled is
controlled, the licensee shall submit to the Board a detailed
written report of the reasons for the uncontrolled flow and
the operations undertaken to control the well.
AR 151/71 s8.190;15/77
8.191 The licensee shall, upon request from the Board or its
representative, determine the formation fracture pressure at
the casing shoe.
AR 15/77 s16
Part 11: Well Data
Drill Cuttings
11.010(1) The licensee of a well shall take samples of drill
cuttings in accordance with Guide G-56, “Energy
Development Application Guide and Schedules”, published
by the Board.
(2) The licensee shall
(a) wash, dry and preserve the samples in bags
that fulfil the labelling and packaging
requirements of the Board, and
(b) within two weeks of the finished drilling
date of the well, deliver the samples at his
expense to the Board’s Core Research
Center, 3545 Research Way N.W.,
Calgary.
AR 151/71 s11.010;51/81;11/98;12/98
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000) • 17
Part 13: Well and Battery Names
13.020(1) The length of a well name shall not exceed 36
characters and spaces.
(2) A well name shall be created at the time the well
is licensed and shall include
(a) the licensee name by an abbreviation which
is satisfactory to the Board,
(b) any optional particulars that the applicant
proposing the well name desires and the
Board approves, or as may be required to
distinguish it from an existing well name,
(c) one of the following:
(i) if a well is located in or adjacent to a
field, the designated field name or the
approved abbreviation;
(ii) if the well is not located in or adjacent
to a designated field, the name of the
strike area or the approved
abbreviation;
(iii) if a crude bitumen well is located in a
sector, the sector name or the
approved abbreviation;
and
(d) the legal subdivision, section, township and
range in which the bottom hole of the well
is located, in that order, indicated by
numbers separated by hyphens.
;229/79;9/93
Equipment Spacing Diagram

2)]
30(
Tank dike m [8.0
60 Surface
[8.030(1)]
improvement 3

Public
property Internal combustion
motor exhaust [8.090(9)] )] ]
or forest
.0 90(3 0(4)
[8.080(2)]
50 m [8 [8.09 Tanks

25m

50 m [8.030(2)]
Wellhead
25 m [8.090(4)]
6m
25

(5)]
] m[
)b 8.0
0(1

[8.090
80( Flame
1 3)]
[2.1 50 m
[8.080 arrester
0m
Surveyed road

4 100 m (3)]
25 m requirements
(1)a]

[2.12
0(1)a Surface [8.090(7)]
]
.110

25 m [8.080(3)] pit
m [2
100

)]
[8.080(2
100 m
Stream or
body of
Surface Lease Lease boundary water
improvement 3 road

Treaters, heaters (without flame arresters) 2

Oil and gas processing equipment

1
The spacing requirements illustrated here are as specified in the Oil and Gas Conservation Regulations
sections indicated within square brackets alongside or underneath each measurement.
Note that there is no smoking within 25 m of a well, separator, oil storage tank, or other unprotected
source of ignitable vapour [Section 8.120(1)].
2
Treaters and heaters without flame arresters are not to be housed in the same building unless air intakes,
flues, vents, ignitable vapours, etc., are vented outside above roof level and the building is cross-ventilated
[8.090(6)a,b,c]. Treaters and heaters with flame arresters must also be 25 m from a well, storage tank, or
other source of ignitable vapour [8.090(4)]. Gas compressors are deemed to be “flame type equipment” and
therefore section 8.090(4) spacing shall apply.
3
“Surface improvement” means a railway, pipeline or other right-of-way, road allowance, surveyed
roadway, dwelling, industrial plant, aircraft runway or taxiway, building used for military purposes,
permanent farm building, school, or church [1.020(1)28].

18 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 5 (October 2000)
APPENDIX 6—UNIQUE WELL IDENTIFIER
General Description
Dominion Land Survey
System
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 1
The unique well identifier (UWI) is the standard well identification that
was developed for the petroleum industry by the Geoscience Data
Committee of the Canadian Petroleum Association (CPA) and has been
adopted by the oil and gas regulatory agencies of the four western
provinces and federal areas. It consists of 16 characters, which make up
four basic components:
1) legal survey location
2) survey system code
3) location exception code
4) event sequence code
Together these define the approximate geographical location of the bottom
of a drillhole and a specific drilling or producing event at the drillhole.
The unique well identifier, although based on the legal survey position of a
well, is primarily for identification rather than location. The location
component describes the bottomhole location of the well, not the surface
position of the well.
The legal survey location component for Alberta is the Dominion Land
Survey (DLS) system, which is used in Alberta, Saskatchewan, Manitoba,
and a portion of British Columbia.
Unique Well Identifier The correct unique well identifier format is the 16-character format
Format shown below:

SS LE LSD SC TWP RG W M P ES

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

The DLS system is designated in the unique well identifier format by a 1

in the first position.

SS LE LSD SC TWP RG W M P ES

Acceptable value(s): 1 for Alberta

Abbreviation: S or SS

Meridian For the purposes of survey locations, the province of Alberta is

subdivided into three areas defined by the meridians of longitude.

For unique well identifier purposes, these are referred to as west (W) of
the fourth, fifth, and sixth meridians.

2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
 Example:

SS LE LSD SC TWP RG W M P ES

1 W 4

Acceptable values: W4, W5, W6

Range Each area (i.e., West 4, West 5, and West 6) subdivides into ranges, as
shown below:

Example:

SS LE LSD SC TWP RG W M P ES

1 0 5 W 4

Acceptable values: Ranges are numbered from 1 to 30. Note that

West 6 meridian contains a maximum of
14 ranges only.

Approximate size: A range measures 9.7 km (6 miles) east to west.

Township Each area west of a meridian subdivides north-south into townships, as

shown below:

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 3
 Example:

SS LE LSD SC TWP RG W M P ES

1 0 0 6 0 5 W 4

Acceptable values: Townships are numbered 001-126.

Approximate size: A township measures 9.7 km (6 miles)

north to south.

Abbreviation: TWP

Section After township, range, and meridian have been located for a drillhole,
the next portion of the DLS is the section.

Example:

SS LE LSD SC TWP RG W M P ES

1 3 6 0 0 6 0 5 W 4

Acceptable values: Sections are numbered 1-36.

Approximate size: A section measures 1.609 by 1.609 km

(1 mile by 1 mile).

Abbreviations: SEC or SC

4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
Legal Subdivision The smallest division in the DLS system is the legal subdivision.

Example:

SS LE LSD SC TWP RG W M P ES

1 1 1 3 6 0 0 6 0 5 W 4

Acceptable values: Legal subdivisions are numbered from

1 to 16.

Approximate size: A legal subdivision measures 402 by 402 m

(1320 by 1320 feet).

Abbreviation: LS or LSD

Location Exception Code The location exception code is used to identify cases where there is more
than one drillhole on the smallest land area described by the DLS
system. That is, the location exception code is used to describe more
than one drillhole in a legal subdivision.

Example:

SS LE LSD SC TWP RG W M P ES

1 0 2 1 1 3 6 0 0 6 0 5 W 4

This example illustrates the second hole drilled in

LSD 11-36-006-05W4.

Abbreviation: LE

In addition, the location exception is generally used to describe the

sequence in which the drillholes were drilled in the legal subdivision.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 5
Event Sequence Code The event sequence code is a one-character code indicating the
chronological sequence of a significant drilling and/or completion
operation of a drillhole that yields a separate and unique set of
geological or production data.

Example:

SS LE LSD SC TWP RG W M P ES

1 0 2 1 1 3 6 0 0 6 0 5 W 4 2

This example illustrates a second “event” in the second drillhole in

LSD 02/11-36-006-05W4/2.

Acceptable values: 0-9

Exceptions: 1 is not acceptable.

Abbreviation: ES

Padding Character This is an unused character in the unique well identifier format and is
left blank. This position is required in other survey systems.

SS LE LSD SC TWP RG W M P ES

1 0 2 1 1 3 6 0 0 6 0 5 W 4 2

Abbreviation: P

Application to Resource The following section explains the exact usage of the unique well
Areas identifier as it applies to the oil and gas, oil sands, and coal resource
areas.

Oil and Gas Areas Examples:

The first well drilled in an LSD is indicated as

SS LE LSD SC TWP RG W M P ES

0 0

The second well drilled in an LSD is indicated as

SS LE LSD SC TWP RG W M P ES

0 2

6 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
 The thirteenth well drilled in an LSD is indicated as

SS LE LSD SC TWP RG W M P ES

1 3

Acceptable values: 00-19

Exceptions: 01 is not used.

Oil Sands Resource Area The oil sands resource area employs the same components of the unique
well identifier as the oil and gas identifiers. However, the location
exception portion of the unique well identifier has different code
designations.

Oil Sands Location The following location exception designations are used for oil sands
Exemption Codes evaluation (OV) drillholes.

Example:

SS LE LSD SC TWP RG W M P ES

A A

Acceptable values: AA through HZ, with the sequence

AA, AB, AC… AZ, BA, BB,
BC… HW, HX, HY, HZ

Exceptions: The use of I or O is not acceptable (e.g., BI,

BO, GI, GO, etc., are not acceptable).

The location exception codes for OV wells may not be assigned in the
chronological order of drilling. For example, the first OV well drilled in
an LSD may have a location exception code other than AA.

Coal Resource Area The Coal Act specifies that coal drillholes are identified by section,
township, range, meridian, and coordinates from the section boundaries.
For the purpose of consistency throughout the resource areas, coal
drillholes are additionally identified by the unique well identifier.

Coal Location Exception Coal drillholes employ the unique well identifier in the same manner as
Code oil and gas and oil sands resource areas, but with modifications to the
location exception code.

Example:

SS LE LSD SC TWP RG W M P ES

1 A

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 7
 Acceptable values: 1A through 9Z, with the sequence 1A, 1B,
1C… 1Z, 2A, 2B … 2Z, 9A… 9X, 9Y, 9Z

Exceptions: The use of I or O is not acceptable (e.g., 1I,

1O, 7I, 7O, etc., are not acceptable).

The location exception may or may not be assigned in the chronological

order of drilling. For example, the first coal drillhole in an LSD may
have a location exception code other than 1A.

Multiple Resource Where more than one resource is encountered by a drillhole, each
Occurrences resource is identified by a unique well identifier with the appropriate
location exception code.

Examples:

For a drillhole location of

SS LE LSD SC TWP RG W M P ES

1 1 0 2 0 0 3 0 1 5 W 4 0

that encounters both gas and coal, the gas resource would be identified as

SS LE LSD SC TWP RG W M P ES

1 0 0 1 0 2 0 0 3 0 1 5 W 4 0

and the coal resource would be identified as

SS LE LSD SC TWP RG W M P ES

1 1 A 1 0 2 0 0 3 0 1 5 W 4 0

Although physically only one drillhole exists, there are two unique well
identifiers, each designating the appropriate resource. It is possible to have a
single drillhole penetrate three different resources. The resulting
identification or view of the drillhole from each resource perspective is
shown in the following example:

For a drillhole location of

SS LE LSD SC TWP RG W M P ES

1 1 0 2 0 0 3 0 1 5 W 4 0

8 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
 the oil and gas identification (first well in LSD) would be identified as

SS LE LSD SC TWP RG W M P ES

1 0 0 1 0 2 0 0 3 0 1 5 W 4 0

the oil sands identification (first oil sands occurrence in LSD) would be

SS LE LSD SC TWP RG W M P ES

1 A A 1 0 2 0 0 3 0 1 5 W 4 0

the coal identification (first coal occurrence in LSD) would be

SS LE LSD SC TWP RG W M P ES

1 1 A 1 0 2 0 0 3 0 1 5 W 4 0

Quadrants When the drilling spacing unit (DSU) is less than 16 hectares (40 acres) or
one LSD, the following designation is used:

Example:

SS LE LSD SC TWP RG W M P ES

Acceptable values: A, B, C, D

Approximate size: One quadrant measures 201 by 201 m.

The second digit of the location exception code indicates the

chronological sequence in which the wells were drilled in the quadrant.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 9
 Example:

SS LE LSD SC TWP RG W M P ES

A 0

This example indicates the first well drilled in Quadrant A.

Acceptable values: 0-9

Exceptions: 1 is not acceptable.

Road Allowances

The above darkened lines indicate road allowances. A well drilled in a

road allowance is referenced either south (S) or west (W) of the legal
subdivision indicated in the identifier.

Example:

SS LE LSD SC TWP RG W M P ES

Acceptable values: S or W

Approximate size: A road allowance is 20 m wide.

The second digit of the location exception code indicates the logical
sequence in which the wells were drilled in the road allowance.

Example:

SS LE LSD SC TWP RG W M P ES

S 0

This example indicates the first well drilled in the road allowance.

10 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
 Acceptable values: 0-9

Exceptions: 1 is not acceptable.

Freshwater Sources The location exception portion of the unique well identifier is also used
to designate locations from which fresh water is drawn. Freshwater
sources are
• wells (F)
• lakes (L)
• rivers (R)

Example:

SS LE LSD SC TWP RG W M P ES

Acceptable values: F, L, R

The second digit of the location exception code indicates the chronological
sequence in which the freshwater source locations were activated.

Example:

SS LE LSD SC TWP RG W M P ES

F 1

This example indicates the first freshwater source well (or location).

Acceptable values: 1-9

Exceptions: 0 is not acceptable.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 11
Identifier Usage Examples of Unique Well

1. Dual completion

Initial completion retains the originally assigned identifier

with the zero event sequence, e.g., 00/06-12-045-12W4/0.

Subsequent completions are assigned the next event sequence.

e.g., 00/06-12-045-12W4/2.

Event sequence codes are assigned chronologically. However,

if both zones are completed in the same operation, the lower
zone is deemed to be completed first.

2. Deepening of an existing well to a new

geological horizon

Existing well A-B has identifier of 00/06-14-045-12W4/0.

Deepened portion of the well B-C is assigned a new identifier

of 00/06-14-045-12W4/2.

3. Deepening of an existing well to a new

geological horizon by whipstocking

Existing well A-B has an identifier of 00/04-14-045-12W4/0.

When the deepened portion is projected to bottom in LSD 5 or

it inadvertently bottoms in LSD 5, the new hole from A to C is
assigned a new identifier of 00/05-14-045-12W4/2.

It is given an event sequence of 2 to indicate that the new borehole

originated from an existing well.

12 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
4. Re-entry of an existing abandoned well

This case applies when the abandonment plugs are drilled out.

Existing abandoned well A-B has an identifier of 00/06-17-045-12W4/0.

Re-entry data are assigned a new identifier of 00/06-17-045-12W4/2.

5. Directionally drilled well projected to

bottom in a specified legal location

At the time of licensing the well is assigned its projected location.

When projected to LSD 08 it is assigned an identifier of

00/08-18-045-12W4/0.

When projected to LSD 07 but inadvertently bottomed in

LSD 08, the identifier at time of licensing would be
00/07-18-045-12W4/0 and it would subsequently be changed to
00/08-18-045-12W4/0.

6. Whipstocked hole from an existing well

Existing well A-B has an identifier of 00/13-20-045-12W4/0.

When the whipstocked hole is projected to bottom in LSD 13, it

is assigned an identifier of 00/13-20-045-12-W4/2, which remains
unchanged if it actually bottoms in LSD 13 (e.g., hole A-C).

When the whipstocked hole is projected to bottom in LSD 13

but inadvertently bottoms in LSD 14 (hole A-D), it is assigned
a new identifier of 00/14-20-045-12W4/3. It is given an event
sequence of 3 to indicate that the new borehole originated from
an existing well.

7. Horizontal Wells

Existing well A-B has an identifier of 00/10-21-045-12W4/0.

Bore hole A-C would have an identifier of 00/09-21-045-12W4/2.

Bore hole A-D would have an identifier of 00/11-21-045-12W4/3.

Each new borehole (A-C and A-D) is given a sequential event to

indicate that it originated from an existing well.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000) • 13
14 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 6 (October 2000)
 APPENDIX 7—UNIQUE FACILITY IDENTIFIER

General Description
Borrowing conceptually the guidelines of the unique well identifier - as
outlined in Appendix 6: Unique Well Identifier, the new unique facility
identifier (UFI) provides an approximate geographical location for the in
situ location of a facility. Unlike the unique well identifier (Appendix 6),
the UFI describes the surface position of the facility within the legal
subdivision (LS or LSD).

Dominion Land Survey The legal survey location component for Alberta is the Dominion Land
System Survey (DLS) system, which is used in Alberta, Saskatchewan, Manitoba,
and a portion of British Columbia.

Unique Facility Identifier The correct unique facility identifier format is the 13-character format
Format shown below:

LE LSD SC TWP RG W M

1 2 3 4 5 6 7 8 9 10 11 12 13

Meridian For the purposes of survey locations, the province of Alberta is

subdivided into three areas defined by the meridians of longitude.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 7 (October 2000) • 1
 For unique facility identifier purposes, these are referred to as west (W)
of the fourth, fifth, and sixth meridians.

Example:

LE LSD SC TWP RG W M

W 4

Acceptable values: W4, W5, W6

Range Each area (i.e., West 4, West 5, and West 6) subdivides into ranges, as
shown below:

Example:

LE LSD SC TWP RG W M

0 5 W 4

2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 7

 Acceptable values: Ranges are numbered from 1 to 30. Note that
West 6 meridian contains a maximum of
14 ranges only.

Approximate size: A range measures 9.7 km (6 miles) east to west.

Township Each area west of a meridian subdivides north-south into townships, as

shown below:

Example:

LE LSD SC TWP RG W M

0 0 6 0 5 W 4

Acceptable values: Townships are numbered 001-126.

Approximate size: A township measures 9.7 km (6 miles)

north to south.

Abbreviation: TWP

Section After township, range, and meridian have been located for a facility,
the next portion of the DLS is the section.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 7 (October 2000) • 3
 Example:

LE LSD SC TWP RG W M

3 6 0 0 6 0 5 W 4

Acceptable values: Sections are numbered 1-36.

Approximate size: A section measures 1.609 by 1.609 km

(1 mile by 1 mile).

Abbreviations: SEC or SC

Legal Subdivision The smallest division in the DLS system is the legal subdivision.

Example:

SS LE LSD SC TWP RG W M

1 1 1 3 6 0 0 6 0 5 W 4

Acceptable values: Legal subdivisions are numbered from

1 to 16.

Approximate size: A legal subdivision measures 402 by 402 m

(1320 by 1320 feet).

Abbreviation: LS or LSD

4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 7

Location Exception Code The location exception code is used to identify cases where there is more
than one facility on the smallest land area described by the DLS system.
That is, the location exception code is used to describe more than one
facility in a legal subdivision. It also describes the historical sequence in
which the facilities were constructed.

For the UFI, the location exemption for facilities is a two-digit number
designating the chronological sequence in which the facilities were
constructed in the legal subdivision.

Example:

LE LSD SC TWP RG W M

0 2 1 1 3 6 0 0 6 0 5 W 4

This example indicates the second constructed facility in Quadrant A.

Acceptable values: 0-9

Exceptions: 1 is not acceptable.

Abbreviations: LE

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 7 (October 2000) • 5
BLANK PAGE
APPENDIX 8—REFERENCE LIST
References cited in Guide 56: Energy Development Application Guide are listed here with sources for
obtaining them.

Alberta Acts Alberta Department of Resource Development

Information Centre (Calgary)
Alberta Environmental Protection and 3rd Floor, Monenco Place
Enhancement Act (EPEA) 801 – 6 Avenue SW
Water Act Calgary, AB T2P 3W2
are available from Tel: (403) 297-6324
Queen’s Printer Bookstore Fax: (403) 297-2576
Public Affairs Bureau Alberta Dept. of Resource Development
11510 Kingsway Avenue, Main Floor Information Centre
Edmonton, AB T5G 2Y5 7th Floor, Petroleum Plaza, North Tower
Tel: (780) 427-4952 9945 – 108 Street
Fax: (780) 452-0668 Edmonton, AB T5K 2G6
Queen’s Printer Bookstore Tel: (780) 427-7425
Public Affairs Bureau Fax: (780) 427-3198
McDougall Centre Web site: www.resdev.gov.ab.ca/room/
455 – 6 Street SW updates/letters/index.htm
Calgary, AB T2P 4E8
Tel: (403) 297-6251 Alberta Environment Documents
Fax: (403) 297-8450
Air Quality Model Guidelines
Web site: www.gov.ab.ca/qp
Environmental Protection Guidelines
Code of Practice for Pipeline and
Alberta Conservation and Reclamation Documents Telecommunication Lines Crossing a Water
IL 94-6: Environmental Protection Guidelines for Body
Oil Production Sites Code of Practice for Watercourse Crossings
IL 97-1: Conservation and Reclamation Code of Practice for Oil Production Sites
Guidelines for Alberta Code of Practice for Compressor and Pumping
are available from Stations and Sweet Gas Processing Plants
are available from
Alberta Environment
3rd Floor, Oxbridge Place Alberta Environmental Protection
9820 - 106 Street Regulatory Approvals Centre
Edmonton, AB T5K 2J6 Main Floor, Oxbridge Place
Tel: (780) 944-0313 9820 - 106 Street
Fax: (780) 427-4407 Edmonton, AB T5K 2J6
Web site: www.gov.ab.ca/env/info/ Tel: (780) 427-6311
infocentre/publications/landrec Fax: (780) 422-0154
Web site: www.gov.ab.ca/env
Alberta Resource Development Documents
Canadian Association of Petroleum Producers
IL 87-3: Reporting Requirements and Royalty Documents
Regimes
IL 92-9: Trespass on Undisposed Crown Mineral Canadian Petroleum Association Recommended
Rights Practice for Liquid Petroleum Pipeline Leak
IL 97-14: Disposition of Crown Petroleum and Prevention and Detection in the Province of
Natural Gas Rights Alberta (1991)
are available from and

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 8 (October 2000) • 1
 CPA-IPAC Guidelines for the Preparation of Sour Guide 34: Guidelines for Automated
Gas Emergency Response Plans for Sour Gas Measurement System Applications
and Oil Facilities - April 1987 Guide 38: Noise Control Guidelines
are available from Guide 46: Production Audit Handbook
Guide 48: Monthly Custom Treating Plant
The Canadian Association of Petroleum Producers Statement
2100, 350 - 7 Avenue SW Guide 49: Gas Density Measurement Frequency
Calgary, AB T2P 2Z1 Guide 51: Injection and Disposal Wells
Tel: (403) 267-1100 Guide 55: Storage Requirements for the Upstream
Fax: (403) 261-4622 Petroleum Industry
Web site: www.capp.ca Guide 58: Oilfield Waste Management
Requirements
Canadian Standards Association Documents Guide 59: Well Drilling and Completion Data
Filing Requirements
Z169: Aluminum Pipe and Pressure Piping
Guide 60: Upstream Petroleum Industry Flaring
Systems
Guide, and Guide 60 Updates and
Z245.1: Steel Line Pipe
Clarifications
Z245.11: Steel Fittings
Guide 62: Responding to Public Concerns About
Z245.12: Steel Flanges
Oil and Gas in Alberta
Z245.15: Steel Valves
Guide 64: Facility Inspection Manual
Z662: Oil and Gas Pipeline Systems
Guide 67: Identification Code and Agent
are available from commercial technical bookstores
Registration Application Guide for Potential
and can be viewed at the EUB reference library:
Licensees
EUB Library Guide 68: Retrospective Facility Licensing Guide
640 - 5 Avenue SW are available from
Calgary, AB T2P 3G4
EUB Information Services
Tel: (403) 297-8242
640 – 5 Avenue SW, Main Floor
Fax: (403) 297-3517
Calgary, AB T2P 3G4
Tel: (403) 297-8190
EUB Guides Fax: (403) 297-7040
Guide 4: Determining Water Production at Gas E-mail: EUB.Info_Services@eub.gov.ab.ca
Wells EUB Web site: www.eub.gov.ab.ca
Guide 7: Production Accounting Handbook
Guide 8: Surface Casing Depth Minimum
Requirements

2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 8 (October 2000)
APPENDIX 9—FORMS
The forms contained in Guide 56 represent the official EUB forms for facilities applications. To submit
printed forms you may freely duplicate the forms found in Guide 56 or download the pdf format from the
EUB Web site (www.eub.gov.ab.ca).

Companies are free to develop their own computer-generated forms to accompany facility applications,
providing they meet the following requirements:

1. Appearance of the forms must closely resemble the Guide 56 printed form and the template must be
an exact match.

2. Use comparable font style and size (Arial Narrow 11 point for headings, 9 point for body). Use same
size paper and margins.

3. All data fields must be included and be the same size as on the Guide56 printed form.

4. DO NOT SHADE any areas, even if they are shaded on the printed form.

5. To fill in data use 10, 11, or 12 point type. The ink must be black and of good quality, not faded. All
characters must be fully formed.

6. Boxes must be the same size as on Guide 56 original forms and must be filled in using an X, not a
check mark (i.e., X ).

7. Logos: Use the form maker’s or your company logo, but not the EUB logo, so that the source of the
form can be easily identified.

When developing and/or filing computer-generated hard-copy forms, please keep in mind that they must
be of a high quality, taking into account the needs of those who will be keying, processing, reviewing,
and/or updating EUB computer records, as well as microfilming the hard copy. These requirements are to
allow for reproducibility as an official EUB record. As well, since many replacement forms are faxed in
response to deficiency requests, design must allow for the limitations presented by faxing.

If a format problem is found during the processing of a computer-generated form filed as required by the
EUB, the form will be rejected and the application closed.

EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 9 (October 2000) • 1
BLANK PAGE
APPENDIX 10—GLOSSARY
Abandoned well - A well that has been drilled,
abandoned, cut, and capped at surface.
Abandonment - The permanent dismantlement
of a well, pipeline, or facility in the manner
prescribed by the regulations; includes any
measures required to ensure that the well,
pipeline, or facility is left in a permanently safe
and secure condition.
Abandoned zone - A previously completed zone
that has been officially abandoned with cement
and/or packing device(s). The well may have
other producing zones.
Abandoned and whipstocked - A portion of a
well that has been drilled and then abandoned
and requires an event sequence to be created. A
whipstocked leg is then drilled from the original
borehole.
Acid gas - Gas that is separated in the treating of
solution or nonassociated gas that contains
hydrogen sulphide (H2S), totally reduced
sulphur compounds, and/or carbon dioxide
(CO2).
Battery - A system or arrangement of tanks or
other surface equipment or devices that receives
the effluent of one or more wells for the purpose
of separation and measurement prior to delivery
to market or other disposition (see also
Oil/bitumen battery).
Blow - The uncontrolled flow of wellbore fluids
to the atmosphere. The flow can be shut in with
the wellhead valve or blowout prevention
equipment, or it can be directed to the flare
system if the well cannot be shut in indefinitely
without exceeding maximum allowable casing
pressure (MACP).
Blowout - The complete loss of control of the
flow of fluids from a well to the atmosphere or
the flow of fluids from one underground
reservoir to another (an underground blowout).
Wellbore fluids are released uncontrolled at or
near the wellbore. Well control can only be
regained by installing or replacing equipment to
shut in or kill the well or by drilling a relief well.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000) • 1
Central oil treating plant - A battery system or
arrangements of tanks or other surface
equipment without any directly associated wells.
Compressor station/site - Service equipment
intended to maintain or increase the flowing
pressure of the gas that it receives from a well,
battery, or gathering system prior to delivery to
market or other disposition.
Condensate - A hydrocarbon liquid recovered
either from a natural gas well or at some point in
the field handling system consisting primarily of
pentane and heavier hydrocarbons.
Contact damage - Damage to a pipeline that
results in a puncture of or crack in the pipeline, a
scratch, gouge, flattening, or dent on the pipeline
surface, or damage to its protective coating.
Container - Any portable aboveground
containment device (e.g., drums, pails, bags,
boxes, totes) that has a capacity less than 1 m3.
Critical sour well – An EUB designation of a well
for drilling purposes which identifies a well with
an H2S release rate of > 2.0 m3/second or certain
sour wells in close proximity to an urban centre.
Custom treating plant - A system or arrangement
of tanks and other surface equipment receiving
oil/water emulsion exclusively by truck for
separation prior to delivery to market or other
disposition.
Dehydrator - Equipment designed to remove
water from raw gas.
Design capacity - The maximum capable
throughput of liquid and gas volumes based on
the engineering design of the facility.
Development - Any proposed project, operation,
or activity likely to have an impact on existing
resources, the environment, and the public.
Disclosure/notification - Informing parties of the
details of the proposed development such that
the parties understand the proposed development
and the impact it may have on them. A written
description of the project, as outlined in
Schedule 1, Table 1.3 – Glossary and in
Appendix 1, must be provided and the applicant
must be prepared to discuss the project as
required.
Directionally drilled well - A well drilled on an
angle from a surface location to a subsurface
location some horizontal distance away from the
surface location of the well.
Drilled and cased - A well that has been drilled
and cased but not immediately put on
production.
Emulsion - A combination of two immiscible
liquids, or liquids that do not mix together under
normal conditions.
Emergency response plan - A comprehensive
plan including criteria for assessing an
emergency situation and procedures for
mobilizing responsible personnel and agencies
and establishing communication and
coordination that is to be followed by all parties
in the event of an accident to protect the public
and the environment during an incident.
Emergency planning zone - The area surrounding
a well or facility where residents or other
members of the public may be at highest risk
during the early stages of an emergency and for
which the operator must have an emergency
response plan.
Environment - All components of the earth
including air, land, and water; all layers of the
atmosphere, all organic and inorganic matter and
living organisms; and interacting natural
systems.
Event sequence code (ES) - A one-character
code indicating the chronological sequence of a
significant drilling and/or completion operation
of a drillhole that yields a separate and unique
set of geological or production data. See
Appendix 6: Unique Well Identifier.
Facility - Any building, structure, installation,
equipment or appurtenance over which the EUB
has jurisdiction and that is connected to or
associated with the recovery, development,
2 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000)
production, handling, processing, treatment, or
disposal of hydrocarbon-based resources or any
associated substances or wastes; includes,
without limitation, a battery, processing plant,
gas plant, oilfield waste management facility,
central processing facility as defined in the Oil
Sands Conservation Regulation (AR 76/88),
compressor, dehydrator, separator, treater,
custom treating plant, produced water injection
plant, produced water disposal plant, miscible
flood injection plant, or satellite or any
combination of any of these, but does not
include a well, pipeline as defined in the
Pipeline Act, mine site, processing plant as
defined in the Oil Sands Conservation
Regulation (AR 76/88), or mine site or coal
processing plant as defined in the Coal
Conservation Act.
Fire - Any unprotected flame or source of
ignition.
Flame type equipment - Any electric or fired
heating equipment using an open flame, electric
arc, or element, including a space heater, torch,
heated process vessel, boiler, electric arc, open
flame welder, open element electric heater, or
appliance.
Gas battery - A system or arrangement of
surface equipment receiving the effluent from
one or more wells that might provide
compression, separation, dehydration, dew point
control, or other gas handling functions prior to
the delivery to market or other disposition; does
not include gas processing equipment.
Gas processing plant - A system or arrangement
of equipment used for the extraction of hydrogen
sulphide, helium, ethane, natural gas liquids, or
other substances from raw gas; does not include
a well head separator, treater, dehydrator, or
production facility that recovers less than 2
m3/day of hydrocarbon liquids without using a
liquid extraction process (e.g., refrigeration,
desiccant). In addition, this does not include an
arrangement of equipment that removes small
amounts of sulphur (less than 0.1 tonne/day)
through the use of nonregenerative scavenging
chemicals that generate no hydrogen sulphide or
sulphur dioxide.
Gas well - A well that produces primarily gas
from a pool or portion of a pool wherein the
hydrocarbon system is gaseous or exhibits a dew
point on reduction of pressure, or any well so
designated by the EUB.
High vapour pressure hydrocarbon - Any
hydrocarbon and stabilized hydrocarbon mixture
with a Reid vapour pressure greater than 14 kPa.
High vapour pressure pipeline - A pipeline
system containing hydrocarbon mixtures in the
liquid or quasi-liquid state with a vapour
pressure greater than 110 kPa absolute at 38°C.
Some examples are liquid ethane, ethylene,
propane, butanes, and pentanes.
Injection/disposal facility - A system or
arrangement of surface equipment associated
with the injection or disposal of any substance
through one or more wells.
Junked and abandoned - If a well has been
drilled and abandoned due to drilling or
mechanical problems at a total depth of 150 m or
less, it is not considered to be a well. No
information is required by the EUB for such a
drilling operation. If the rig is skidded and the
well is respud, the same licence can be used. If
the same situation occurs but the well is drilled
to a total depth greater than 150 m, it is
considered to be a well and all drilling and
abandonment information, with the status
changed to junked and abandoned, is required to
be sent to the EUB. If the rig is to be skidded
and a new well spud, an application for a new
licence must be filed with the EUB Applications
Branch.
Landowner
1) The person in whose name a certificate of
title has been issued pursuant to the Land
Titles Act, or
2) If no certificate of title has been issued, the
Crown or other body administering the land.
3) In the case of Metis settlement land, the
person registered in the Metis Settlements
Land Registry as owner of the Metis title
pursuant to the Metis Settlements Land
Registry Regulation.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000) • 3
Large diameter/high pressure hydrocarbon
pipeline - A hydrocarbon pipeline with both an
outside diameter equal to or greater than 323.9
mm and a maximum operating pressure equal to
or greater than 3475 kPa.
Licensee - The holder of a licence according to
the records of the EUB; includes a trustee or
receiver-manager of property of a licensee.
Linked facility - The licensed facility that both
accepts a majority of product from a
nonproduction reporting facility (satellite and
some compressor stations) and reports that
production.
Local authority
1) The corporation of a city, town, village
municipal district, county, or Metis
settlement.
2) The board of administrators of a new town.
3) In the case of an improvement district or
special area, the Minister of Municipal
Affairs.
Location exemption code (LE) - A code that
identifies cases when there is more than one
drillhole or facility on the smallest land area
described by the Dominion Land Survey system
(DLS). See Appendix 6: Unique Well Identifier
and Appendix 7: Unique Facility Identifier.
Lost circulation - The loss of drilling fluids from
the wellbore into permeable formations
penetrated during drilling of the well.
Multileg well - A well having more than one
drilled hole or leg that can be created during the
initial drilling of the well or during re-entry into
an existing well and whipstocking. It also
applies to horizontal drilling. Event sequences
are to be assigned in the order that the legs are
drilled.
Nonobjection - Nonobjection means that an
applicant has personally contacted, either in
person or by telephone, the landowner(s),
occupant(s), and resident(s) of the land where
the development is to occur and that they do not
object to the EUB issuing a licence.
Notification/disclosure - Informing parties of the
details of a proposed development such that the
parties understand the proposed development
and the impact it may have on them. A written
description of the project, as outlined in
Schedule 1, Table 1.3 – Glossary and in
Appendix 1, must be provided and the applicant
must be prepared to discuss the project, as
required.
Occupant
1) A person other than the owner who is in
actual possession of land.
2) A person who is shown on a certificate of
title or by contracts as having an interest in
the land.
3) An operator granted a right of entry as
defined in the Surface Rights Act in respect
of land pursuant to a right of entry order as
defined in that act.
4) In the case of Crown land, a person shown
on the records of the department or other
body administering the land as having an
interest in the land.
5) In the case of Metis settlement land, a
person having a right or interest in land
recorded on the Metis title register pursuant
to the Metis Settlements Land Registry
Regulation.
6) The holder of a permit for a coal mine.
7) The owner of a private access road.
Oil/bitumen battery - A system or arrangement of
tanks or other surface equipment or devices
receiving the effluent of one or more wells for
the purpose of separation and measurement prior
to the delivery to market or other disposition, but
not including a custom treating plant, tank farm,
oil loading and unloading terminal, or oil sands
processing plant.
Oil and gas development - Refers to any of the
following:
• oil/bitumen and gas batteries
• satellite batteries
• custom treating plant
• gas processing facilities
• straddle plants
• compressor stations
• injection/disposal facilities
• pump stations
• tank farm
4 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000)
• pipelines
• wells
• oil loading and unloading facility
Oil well - A well that produces primarily liquid
hydrocarbons from a pool or portion of a pool
wherein the hydrocarbon system is liquid or
exhibits a bubble point on reduction of pressure,
or any well so designated by the EUB.
Oil loading and unloading facility - A system or
arrangement of tanks and other surface
equipment receiving crude oil by truck for the
purpose of delivering crude oil into a pipeline.
Oil sands scheme approval number - The number
assigned an approval of a scheme or operation
for the recovery of oil sands or crude bitumen
under Section 10 of the Oil Sands Conservation
Act.
Oilfield waste - An unwanted (by the generator)
substance or mixture of substances that results
from the construction, operation, or reclamation
of a well site, oil and gas battery, gas plant,
compressor station, crude oil terminal, pipeline,
gas gathering system, heavy oil site, oil sands
site, or related facility.
Operator - With respect to a well or facility, a
person who has control of or undertakes the day-
to-day operations and activities at a well or
facility or keeps records and submits production
reports for a well or facility to the EUB, whether
or not that person is also the licensee or approval
holder for the well or facility.
Perforation - The holes placed through the casing
and cement into the formation using a
perforating gun or by cutting the casing and
cement using sand-laden fluids to expose a
formation.
Permanent dwelling - A designation (also
referred to as dwelling or individual dwelling)
generally for any dwelling located on a quarter
section with eight or fewer permanent dwellings
outside the corporate boundaries of an urban
centre and not situated at a public facility. May
also apply to other locales frequented by people
over a 24-hour period, such as work sites and
places of business (or similar activities) or where
the evacuation situation appears complex.
Personal consultation – Visit(s) or telephone
conversation(s) by the applicant to a person
whose rights may be directly and adversely
affected by a decision on an application to:
• inform the party of the nature of the
proposed application,
• identify potential impacts,
• respond to questions and concerns,
• discuss options, alternatives, or mitigating
measures, and
• seek concurrence through collaborative
efforts.
Pipeline abandonment - The permanent
deactivation of a pipeline or part of a pipeline,
whether or not it is removed, as long as it is
physically separated.
Pipeline base map - The plan produced by the
EUB on a township or smaller areal basis that
shows pipelines currently licensed under the
Pipeline Act.
Pipeline break - A rupture in any part of a
pipeline.
Pipeline discontinuation - The temporary
deactivation of a pipeline or part of a pipeline
where the licence remains in effect and the
pipeline is not physically disconnected.
Pipeline leak - The escape of substance from a
pipeline.
Primary containment device - A device used to
physically contain materials produced,
generated, and used by the upstream petroleum
industry. Primary containment devices include,
but are not limited to, single walled tanks and
containers.
Process vessel - A heater, dehydrator, separator,
treater, or any vessel used in the processing or
treatment of produced gas or oil.
Proponent - Any person, company, or
government agency that proposes to undertake a
development.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000) • 5
Proportionate share - With respect to a working
interest participant, the percentage share equal to
the participant’s undivided interest in the well,
pipeline, or facility.
Proration plan - A system that has been set up to
share the demand for conventional light and
medium crude oil in an equitable manner among
all the oil pools in the province. Under the
proration plan, each well is assigned a maximum
volume of oil (allowable) that can be produced
in a given month.
Public facility - A public building such as a
hospital, rural school, or a major recreational
facility situated outside of an urban centre; for
the purposes of applying the requirements of
EUB Interim Directive (ID) 97-6, includes other
developments that the EUB, after consultation
with appropriate interested parties, may
designate as a public facility based on the
complexity of evacuation and taking into
consideration the number of people using the
facility and the frequency and duration of their
use.
Publication of notice - The service, circulation,
or advertising by the EUB, in accordance with
its rules of practice, of a notice stating that, in
the absence of objection by any person having a
bona fide interest in the matter, the EUB might
grant an application or take such other action in
a proceeding as the notice may specify.
Pumping station - A system of equipment
located at intervals along a main pipeline to
maintain flow to the terminal point.
Re-entry operations - The re-entry of an
abandoned wellbore by a company other than
the original licence holder, which necessitates
the issuement of a new well licence by the EUB.
Refer - A critical level on the EUB enforcement
ladder whereupon a company’s noncompliance
record will be considered by the EUB when
deciding to approve or deny future applications.
Regional group - Similar to a local interest
group, except with a broader area of concern and
with stakeholders from a larger cross-section of
society.
Resident - Any persons living within the
distances outlined in Schedule 1, Table 1.3:
Minimum Public Disclosure and Consultation
Requirements.
Resumption of drilling operations - Occurs when
the original holder of a licence re-enters an
existing wellbore, whether abandoned or not, for
the purpose of deepening, whipstocking,
recompleting (abandoned well only), or
horizontal recompletion.
Retrospective facility licensing - A temporary
EUB program to licence existing facilities that
would have required licensing if they were
constructed under current regulatory
requirements.
Right-of-way - The strip of land in which a legal
right of passage is granted over another person’s
property. This right can be acquired by means of
an easement or by a right of entry order.
Same production system - For the purposes of
oilfield waste management, an interconnected
system of upstream production facilities (e.g.,
wells, pipelines, batteries). An oil/gas
production site receiving oilfield wastes for on-
site management or storage must be within the
same interconnected system of upstream
production facilities as the oil/gas production
site from which the oilfield wastes originated.
Both the receiving and the originating site must
have the same licensee or approval holder.
Satellite or satellite battery - A small group of
surface equipment (not including storage tanks)
located between a number of wells and the main
battery that is intended to separate and measure
the production from each well, after which the
fluids are recombined and piped to the main
battery for treating and storage or delivery.
Separation or setback distance - The minimum
required distance between a well, sour pipeline
or other sour facility, permanent flaring facility,
or tank dyke and land-use development such as
surface improvement, permanent dwelling,
unrestricted country development, urban centre
or public facility.
6 • EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000)
Solution gas - Volatile hydrocarbons that are
dissolved in solution with produced oil or
bitumen.
Sour gas (H2S) - Raw natural gas that contains
quantities of hydrogen sulphide (H2S), carbon
dioxide (CO2), and other sulphide-based
compounds.
Sour well - Any oil or gas well expected to
encounter sour gas-bearing formations during
drilling or any oil or gas well capable of
producing sour gas.
Sour gas level classification - A designation to
stipulate different separation or setback
distances for sour wells, pipelines, and facilities
for land-use and public safety purposes, as
described in ID 81-3 and ID 97-6.
Stock tank vapours - The small volume of
dissolved gas present in the oil storage tanks that
may be released from the tanks.
Storage facility - A facility dedicated to the
storage of materials produced, generated, and
used by the upstream petroleum industry in
containers and/or tanks, including all land and
associated structures.
Sulphur emissions - The release of sulphur-
containing compounds, including SO2, H2S, and
total reduced sulphur compounds (i.e.,
mercaptans). Sulphur emissions from flare
stacks are expected to be primarily in the form
of SO2, with small amounts of other compounds.
Surface improvement - A railway, pipeline or
other right-of-way, road allowance, surveyed
roadway, canal, dwelling, industrial plant,
aircraft runway or taxiway, building used for
military purposes, permanent farm buildings,
school, or church.
Suspended well - A well at which no significant
production or injection operations have occurred
during the past 12 months.
Suspension - The temporary cessation of
operations at a well, pipeline, or facility in the
manner prescribed by the regulations; includes
any measures required to ensure that the well,
pipeline, or facility is left in a safe and secure
condition.
Tank - A device designed to contain materials
produced, generated, and used by the upstream
petroleum industry that is constructed of
impervious materials, such as concrete, plastic,
fibreglass-reinforced plastic, or steel that
provide structural support.
Tank farm - A system or arrangement of tanks or
other surface equipment associated with the
operation of a pipeline and that may include
measurement equipment and line heaters, but
does not include separation equipment or storage
vessels at a battery approved under the Oil and
Gas Conservation Act.
Unrestricted country development - Any
collection of permanent dwellings situated
outside of an urban centre and having more than
eight permanent dwellings per quarter section;
for the purpose of applying the requirements of
ID 97-6: Sour Well Licensing and Drilling
Requirements, includes any similar development
that the EUB might so designate.
Urban authority - The administrator of a city,
town, new town, village, summer village, or
hamlet with not fewer than 50 separate
buildings, each of which must be an occupied
dwelling, or other incorporated centres.
Waste material - Water, rubbish, debris, drilling
fluids, oil, oily waste, sand tailings, or other
products from a well, oil sands operation, tank,
pipeline, or other production installation.
EUB Guide 56: Energy Development Application Guide, Volume 2 / Appendix 10 (October 2000) • 7
Waste processing facility - A system or
arrangement of tanks or other surface equipment
receiving waste material for processing and
disposition from any gas, oilfield, or oil sands
operations.
Water body - The bed and shore of a river,
stream, lake, creek, lagoon, swamp, marsh,
slough, or other natural body of water or a canal,
drainage ditch, reservoir dugout, or other man-
made surface feature, whether it contains or
conveys water continuously, intermittently, or
seasonally.
Well spacing - The normal drilling spacing unit
for a gas well is one section (1 well per 256
hectares) and for an oil well is one quarter
section (4 wells per 256 hectares).
Working interest participant - A person who
owns a beneficial or legal undivided interest in a
well or facility under agreements that pertain to
the ownership of that well or facility.
Workovers or well servicing - Work performed
on a well after its initial completion to repair
downhole equipment or to increase production
rates.