manual 001: facility and well site inspections
TRANSCRIPT
Manual 001: Facility and
Well Site Inspections
Enforcement and Surveillance Branch
June 2014
24 hour Emergency Number
1-800-222-6514
Energy or Environmental Emergency
Complaints
AER Field Centres and Offices
• AER Offices
AER Inquiries
1-855-297-8311
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
reading frequency
Criteria or events
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 no…why?
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 Noncompliance’s
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
124
Double Walled Tank
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
Suppression
Noise 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
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
Waste Management
*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”
Spills and Fires Reporting
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
Surface Water
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 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)
Suspended Wells
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
Explosions
Fires
Pipeline hits and breaks
Spills
Landowner complaints
Incident Examples
What’s 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)