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Manual 001: Facility and

Well Site Inspections


Enforcement and Surveillance Branch
June 2014
AER Field Centres and Offices
24 hour Emergency Number

1-800-222-6514

Energy or Environmental Emergency

Complaints

AER Inquiries
1-855-297-8311

inquiries@aer.ca
AER Offices
Key Messages

Directive 019 is a key component to compliance


assurance

Manual 001 identifies the most common


noncompliances for well sites and facilities (oil, gas,
and waste management)

The AER responds to industry incidents, including


releases, fires, and complaints
Directive 019: Compliance Assurance

Risk assessments
Response to noncompliant events
Persistent Noncompliance Framework
Appeals
Voluntary Self Disclosure
Compliance performance information
Voluntary Self Disclosure

Proactive correction
No enforcement if conditions are met
Improved relationships
Improved public health and safety
Protection of the environment
Conservation of the resource
Regulatory confidence
Voluntary Self Disclosure

The licensee must


be the first party to contact the AER,
not fall under one of the circumstances,
where a self disclosure will not be accepted,
correct the noncompliance in a timely manner,
develop and implement a written action plan.
Inspection Selection Process (OSI)
Computer Generated

Operator Performance provincial basis


inspection record and complaints
Sensitivity
forest, agricultural, populated areas
Inherent Risk
sweet vs. sour, single vs. multi-well
As Part of a Facility Inspection, AER Looks
at
The inspection history of a company
Complaint and incident history
Production records on PETRINEX (previously,
Petroleum Registry of Alberta)
The Emergency Response Plan (ERP)
Manual 001

Manual 001 is available on the AER Web site at


www.aer.ca/Rules&Directives/Manuals

Manual 001 highlights the most prevalent oil


and gas noncompliances encountered during routine
surveillance
Manual 001
Gas Measurement

Gas must be measured by


meters (> 0.5 E3M3 per day), or
determined by an engineering estimate, and
volumes => 0.1 E3M3 must be reported to
PETRINEX
How Often Should Gas Meters be
Calibrated?
In the first month of operation
Following a service or repair
Semi-annually for royalty trigger points (gas plant
sales)
Annually for all others

*Tag or report must be attached*


How Often are you Required to do an
Internal Inspection on Gas Meters?
Semi-annually for royalty trigger points

Annually for all other meters


Inlet Gas Plant Measurement

Must have inlet separation

Must have continuous measurement for all fluids


(gas, hydrocarbon liquids, and water)
Fuel Gas Measurement
Calibration Tag

16
Temperature

Compliant Compliant

18
Inappropriate Temperature Measurement
Needle Valves

Noncompliant Compliant

20
Liquid Meter Proving Frequency

Annually for wellhead, group, and injection


Semi-annually for gas plant
Monthly for delivery point

*Tag or report must be attached*


Measurement

Compliant Noncompliant

22
Accounting (Sales) Meters Require

Full port valves (same size as sensing lines)


Sensing lines must be a minimum 1/2 tubing for a
meter run greater than or equal to 4 in diameter, or
A minimum 3/8 tubing for a meter run less than 4 in
diameter
Sales Meter
Meter Tag/Chart Information

25
Meter Installation

26
Produced Water Injection

27
Water Injection Meter
Meter Calibration

29
Gas Plant Inlet Measurement
Orifice Plate

31
Sensing Lines Must

Have separate valve manifolds for each measuring


device
Be suitably winterized
Be self-draining
Chart Recorder Winterized
Gas Measurement Metering

Minimum temperature Criteria or events


reading frequency
Continuous Sales/delivery points
and/or EFM devices
Daily > 16.9 103m3/d
Weekly 16.9 103m3/d

Daily Production (proration)


volume testing, non-routine
or emergency flaring and
venting
Oil and Emulsion Must be Measured by

Meters

Gauges, or

Weigh scales
Weigh Scale
Testing Requirements Oil Proration
S&W Analysis Requirements for Oil
Proration
Use a centrifuge for water cuts below 10 percent
Use a graduated cylinder and centrifuge for water cuts
10-80 percent
Use a graduated cylinder for water cuts above 80
percent
Petrinix Reporting

42
Petronix Reporting

43
Reporting

Must report volumes of flared/vented/incinerated gas


greater than or equal to 0.1 E3M3/month to PETRINEX

Operators must maintain a log of flaring, venting, and


incinerating events; and respond to public complaints
Petrinex Reporting

45
Petrinex Reporting

46
Spacing Requirements
Spacing Requirement

48
Spacing

50
Furnace
Ignition Source

56
Flare/Incinerator Stack
Design and Operation
Decision Making and Planning When Flaring
or Venting
If vented gas can support stable combustion, burn it

Conserve, if possible

Venting should be the last resort


Decision Tree Analysis
Decision Tree Analysis

*Document analysis*

Can venting or flaring be eliminated? If nowhy?

Include costs and economics


Venting Requirements

For temporary, short-term venting


Gas must be sweet
Volume must not exceed 2.0 E3M3 and duration must
not exceed 24 hours (excluding the clean-out phase
for testing)
Notification requirements must be met
Solution Gas Conservation

Must conduct an economic evaluation on all flared


volumes > 900 m3 per day

Must conserve if volumes are > 900 m3 per day within


500 metres of a residence

Licensees of production facilities operating within


3 kilometres of each other must jointly consider
clustering when evaluating solution gas conservation
economics
Flare Spacing Requirements

Must be 50 metres from wells and storage tanks


Must be 25 metres from processing equipment
Solution Gas Conservation

There are limitations for non routine flaring at solution


gas conserving facilities.
Any outage (planned or emergency) > 4 hours
inlet must be reduced by 75%
no flaring of solution gas >10% H2S
residents within 500 metres must be notified
Various requirements for outages < 4 hours and
partial equipment outages.
Liquid Separation must be Equipped with

A visual level indicator


A high level shutdown or alarm

Noncompliant Compliant
Back Flash Prevention

Use flame arrestors between combustion points and


separators, or

Sufficient sweep gas to purge oxygen


Wind Guard/Flame Arrestor
No Flame Arrestor
Flare Ignition
1% H2S or higher, must have a pilot or auto igniter

Gas plants with 10ppm or more H2S requires a pilot


and an auto igniter
Pilot and Ignition Device

72
Flaring Limits: 6 Major Events in 6 Months

Below 1 billion m3/year (raw gas inlet volume)


vent/flare/incineration cannot exceed 0.5% of receipts
Above 1 billion m3/year (raw gas inlet volume)
vent/flare/incineration cannot exceed 0.2% of receipts

Plant Inlet Major Flaring Event


> 500 E3M3/d 100 E3M3
150 500 E3M3/d 20% of design daily inlet
< 150 E3M3/d 30 E3M3
Dispersion Modeling for Sour Gas Flaring

Dispersion modeling must be


conducted for the flaring or
incinerating of gas containing
>1% H2S, regardless of
volume
Well Test Notifications
Flare Pits

Noncompliant Compliant
Low Risk Noncompliance

79
Incinerator/Exposed Flame
Signs and Security
Licensee or operator name
24 hour emergency phone number
Surface location
Appropriate warning symbol
flammable, or
sour - if above 10ppm H2S
Signage Requirements

83
Primary Entrance

84
Noncompliant Signage
Well pad Signage

86
Fencing Requirements

Batteries >1% H2S


cattle type fence with a minimum of four strand barbed wire
and either a gate or cattle guard
Batteries >1% H2S within 800 metres of a dwelling or
public facility
2 metre high mesh fence with a locked gate when
unattended
Pumping unit within 800 metres of a public facility
2 metre high mesh fence with a locked gate when
unattended
Sour Battery

ncing
Fencing Requirements

89
Wellhead Protection
Wellheads are to be conspicuously marked or fenced
so they are visible in all seasons

Farm or other vehicles must not operate within a


3 metre radius of the wellhead
Surface Casing Vent

Compliant NonCompliant

97
Emergency Controls and Relief Systems

Oil PSVs must be tied into a pop tank

Vessels must have a high level and high pressure


shutdown and be tied into a flare if >1% H2S
PSV Lines

99
H2S > 1%: Separator Controls

102
Surface Containers (< 1m3)

A licensee can store


1m3 onsite without
secondary containment

Anything more has to be


stored on a barrel dock
or inside secondary
containment
Container Storage Requirements

104
Bulk Storage Tanks (1m3 - 5m3)

Licensee can store up to 5m3 on site in a single


walled tank without secondary containment

Anything more, the licensee must have secondary


containment

Do monthly inspections to verify the tanks integrity


Single-walled Aboveground Storage
Tanks > 5m3

A dike and liner required

Dike capacity should be able to hold 110%

Spill control devices at fluid transfer points

Pre-1996 tanks require a 5-year integrity test (if no


liner installed)
Noncompliant Compliant
High Risk Noncompliances

111
Oilfield Waste Storage
Aboveground Double-walled Storage
Tanks > 5m3
No dike or liner is required

Have measures in place to prevent overflow


(visible/audible alarm or a high level shutdown
*function tested monthly*)

Monitor the interstitial space monthly

Must have spill control devices on load lines


Aboveground Flare Knockout Tank

115
Underground Storage Tanks

Must be double walled (if installed after 2002)


interstitial space must be monitored monthly
Pre-2002 (single-walled) requires a 3-year integrity
test
Must have a level indicator or a high level alarm (to
prevent overfilling)
Steel tanks must have cathodic protection
Single Walled U/G Tank

117
U/G Tank Not In Service

118
Flare Knockout Tank

119
5 Year Integrity Test

122
Double Walled Tank
High Level Shutdown

123
Double Walled Tank

124
High Level Shutdown

Double Walled Tank

125
Secondary Containment

127
Secondary Containment
Noncompliant Compliant
High Risk
Biopile/Excavated Contaminated Soil
Withdrawing a Tank from Service

Remove all fluids and keep it empty

All lines leading to the tank must be disconnected

Tag the tank Out Of Service


Compressor Installation

75kW and larger requires a


licence

Temporary compressor (less


than 21 days), AER approval
is not required

Must have landowner and


surrounding residents
consent
Emergency Response Plan (ERP)
Requirements
A licensee must have a corporate ERP

A licensee may be required to have a site specific


ERP based on requirements under Directive 071:
Emergency Preparedness and Response
Requirements for the Petroleum Industry

Contact AER when activating the ERP to confirm


the emergency level and convey the specifics of the
incident
Questions the AER May Ask

Is there a site-specific emergency response plan


(ERP) where required?

Is safety equipment that is specified in the ERP


installed/available?

Is a copy of the ERP readily available onsite?


More Questions the AER May Ask

Is the ERP up to date?

When was the last ERP exercise held? Were the


details documented?

Is the licensee/operator onsite representative familiar


with the ERP?

Does the licensee/operator communicate regularly


with residents in the emergency planning zone (EPZ)?
Emissions

H2S emissions/odours not allowed off lease


No H2S emissions/odours allowed during
transportation of sour fluids
Noise Complaints

No Noise Noise Suppression


Suppression

140
Benzene Emissions

Dehydrator Engineering and Operations Sheet


(DEOS) must be posted on site

DEOS must be revised annually or upon change in


status

Residents within 750 metres must be notified


Benzene Emissions Limits
Benzene Emissions Limits
Benzene Control Systems

Ways to reduce benzene emissions


incinerators
flares
condensers

*Note: the best control to reduce benzene emissions


is by operating the glycol dehydrator efficiently so the
glycol circulation rate is as low as feasible.
Noise Control and Common Noise Sources

Compressors

Pump jacks

Drilling and servicing operations


Waste Management

Keep the site in a clean condition


*No Staining*

Waste must be stored properly

Waste must be shipped to approved facilities

Waste tracking system (manifesting) must be


maintained
Spills and Fires Reporting

*Control and clean up spills immediately*

Notify the AER if identified as


> 2m3 on lease
off lease
any release from pipelines
on site and of a size that may cause, is causing or has
caused an adverse effect

Notify the landowner of all off lease spills


Surface Water

Release criteria for surface water


chloride content < 500mg/L maximum
pH between 6.0 and 9.0
no visible hydrocarbon sheen
no chemical contamination
flow not allowed directly into any watercourse
landowner consent obtained and documented
Injection Wells

Must have continuous measurement at the wellhead


(including acid gas injection wells)

Must not exceed maximum injection rates (as


specified in the injection well approval)
Emergency Controls and Relief Systems

Surface casing vent is required


Flowing well >5% H2S requires 2 master valves
Pumping well >1% H2S, capable of flow, requires an
hydraulic rod and environmental Blow Out Preventer
(BOP)
Flowing well >1% H2S requires surface shutoff valve
A Well is Determined Suspended When

There has not been any volumetric activity in a


12 month period
Critical sour and acid gas wells that have not had any
volumetric activity in a 6 month period
A licensee must evaluate the risk using AER Directive
013: Suspension Requirements for Wells, table 1,
that outlines all inactive well requirements
TABLE 1: SUSPENSION
REQUIREMENTS
Suspended Wells

Suspended wells must be inspected (1-5 years


depending on the type of well)
All outlets must be bull plugged or blinded
Valves must be chained and locked; or the valve
handles removed
*Note: a low risk well becomes a medium risk well
after 10 years of being in suspension (see down hole
requirements)
Abandonment
Critical Sour Wells

Requires a physical barrier that is clearly visible


around the well
Requires 2 master valves
If capable of flow to atmosphere, the well requires
a subsurface safety valve
Wellhead working pressure must not be less than
the bottom hole pressure
Requires a site specific ERP
If well is on rod pump, the well must have an
environmental BOP on top of the stuffing box
Surface Casing Vent Flow/Gas Migration

Any surface casing vent flow or gas migration must be


reported and repaired (if serious)
Isolation Packer

Packer isolation tests are required on


water injection/disposal wells
acid gas injection wells
wells >5% H2S

Packer isolation tests must be conducted annually and


reported to the AER
Casing Failures
Incident Examples

Explosions
Fires
Pipeline hits and breaks
Spills
Landowner complaints
Whats New

Manual 001 presentations for external stakeholder


access can be found at:
www.aer.ca/Compliance&Enforcement/education

New edition of Directive 039 (effective January 2013)

Revisions to Directive 017 (effective May 2013)

New Directive 083: Hydraulic Fracturing Subsurface


Integrity (effective May 2013)

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