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WELL COMPLETION,

MAINTENANCE AND
ABANDONMENT
GUIDELINE
August | 2015
Version 1.17

Well Completion, Maintenance and Abandonment Guideline, Version 1.17


CONTENTS
MANUAL REVISIONS .............................................................................................. 1
SUMMARY OF REVISIONS...............................................................................................1
1 PREFACE .............................................................................................................. 2
1.1 PURPOSE ..........................................................................................................2
1.2 SCOPE ..............................................................................................................2
1.3 HOW TO USE THIS MANUAL.................................................................................3
1.4 ADDITIONAL GUIDANCE ......................................................................................3
1.4.1
Feedback ..............................................................................................4
1.4.2
Frequently Asked Questions .................................................................4
2 WELL EQUIPMENT ............................................................................................... 5
2.1
2.2
2.3
2.4
2.5
2.6
2.7

WELLHEADS ......................................................................................................5
TUBING ............................................................................................................5
PACKERS ...........................................................................................................5
SUBSURFACE SAFETY VALVES ................................................................................6
OIL WELLS ........................................................................................................6
FENCING ...........................................................................................................8
LEAK DETECTION ................................................................................................8

3 WELL SERVICING OPERATIONS .......................................................................... 10


3.1 WELL SERVICING OPERATIONS ............................................................................10
3.2 COMPLETIONS / WORKOVERS / MAINTENANCE .....................................................10
3.2.1
Shallow Fracturing .............................................................................10
3.2.2
Commingling ......................................................................................11
3.3 WELL SUSPENSION ...........................................................................................12
3.3.1
Definitions ..........................................................................................12
3.3.2
Observation Wells ..............................................................................12
3.3.3
Suspension Requirements ..................................................................13
3.3.4
Packer Testing ....................................................................................18
3.3.5
Long Term Inactive Wells ...................................................................18
3.3.6
Reactivating Suspended Wells ...........................................................18
3.3.7
Information / Reporting Requirements ..............................................18
3.4 CLASSIFICATION OF LOW AND MEDIUM RISK GAS WELLS .........................................20
3.5 WELL ABANDONMENT ......................................................................................21
4 WELL SERVICING EQUIPMENT AND PROCEDURES ............................................. 22
4.1 BLOWOUT PREVENTION.....................................................................................22
4.1.1
Well Servicing Blowout Prevention ....................................................22
4.1.2
BOP Equipment Classes ......................................................................22
4.1.3
General ..............................................................................................23
4.1.4
Accumulator systems .........................................................................23
4.1.5
Requirements Specific to Class A Systems..........................................24
4.1.5
Requirements Specific to Class B and C Systems ................................24
4.1.6
Line Requirements .............................................................................24
4.1.7
Stabbing Valve ...................................................................................25
4.1.8
Blowout Prevention Manifold ............................................................25
4.1.9
Testing of Blowout Prevention Equipment.........................................25
4.1.10
Special Sour Wells .........................................................................26
4.1.11
Slickline, Snubbing and Coil Tubing Operations ............................26

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Well Completion, Maintenance and Abandonment Guideline, Version 1.17


4.1.12
Hammer Unions ............................................................................26
4.1.13
Diagrams of Blowout Prevention Systems for Well Servicing .......27
4.2 PERSONNEL .....................................................................................................31
4.3 FIRE PRECAUTIONS AND EQUIPMENT SPACING .......................................................33
4.3.1
Engines ...............................................................................................33
4.3.2
Fuel ....................................................................................................33
4.3.3
Smoking .............................................................................................33
4.3.4
Recommended Spacing Distances......................................................34
4.3.5
Flare Stacks ........................................................................................35
4.3.6
Explosives ...........................................................................................35
4.4 INCIDENT REPORTING ........................................................................................35
4.5 CONCURRENT OPERATIONS ................................................................................35
5 ENVIRONMENTAL CONSIDERATIONS ................................................................ 36
5.1 SURFACE CASING VENT FLOWS ...........................................................................36
5.1.1
Definitions ..........................................................................................36
5.1.2
Checking for Surface Casing Vent Flows ............................................36
5.1.3
Testing and Reporting Surface Casing Vent Flows .............................37
5.1.4
Surface Casing Vent Flow Repairs ......................................................39
5.2 GAS MIGRATION ..............................................................................................40
5.2.1
Definitions ..........................................................................................40
5.3 CASING LEAKS AND FAILURES ..............................................................................42
5.4 NOISE ............................................................................................................42
5.5 FLARING AND VENTING......................................................................................42
5.6 FLUID STORAGE ...............................................................................................42
6 DATA SUBMISSION ............................................................................................ 43
6.1

COMPLETION / WORKOVER / ABANDONMENT REPORTS ..........................................43

7 COMPLIANCE ..................................................................................................... 46
OGAA ................................................................................................................46
Drilling and Production Regulation ..................................................................46
APPENDIX A: COMPLETION/WORKOVER REPORT GUIDELINES ............................ 47
APPENDIX B: WELL SUSPENSION/INSPECTION FORM INSTRUCTIONS .................. 51
Well Classification ............................................................................................51
Formations Open To The Wellbore...................................................................51
Pressure Monitoring and Pressure Tests ..........................................................52
Visual Inspection ..............................................................................................52
General .............................................................................................................53

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Manual Revisions
Summary of Revisions
The Well Completion, Maintenance and Abandonment Manual
has been revised based upon feedback to provide clarity in
terms of requirements and process. Structural changes by
section are highlighted below.
Applications received on or after the effective date will be
required to meet the revised application standards.
Effective Date

Section
Section 4

1-June-2014
Section 6

13-February-2015

Various

20-April-2015

Various

10-August-2015

Section
2.3

Description/Rationale
Updated s. 4.1.2 Class A & B hydrogen sulphide content samples
from 10 mol % or great to 1 mol % or greater (p. 23).
Updated s. 4.1.4 to include a rating of production casing (p.30).
Updated the submissions section to reflect the new Well Data
Requirements Submission Guideline (p. 46)
Updated to reflect the change in the water source approval process
and requirements for hydrogeological assessment and data
collection, monitoring, and data reporting.
For more information, refer to INDB 2015-03 on the Commissions
website.
This document has been updated to reflect the implementation of the
Commissions eSubmission Portal. Readers are encouraged to
review this document in full. Please see INDB 2015-06 and the
Commissions BTS webpage for more information.
Update reference for packer isolation test procedures to
Commissions Water Service Well Summary document.

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1 Preface
1.1

Purpose
This manual has been created to guide users through the BC
Oil and Gas Commission (the Commission) processes and
procedures. It also serves to highlight changes in process,
procedure, requirements and terminology resulting from the Oil
and Gas Activities Act (OGAA).
For users already familiar with the Commission application
process, this manual provides a quick reference highlighting the
steps required to complete specific tasks. For users less
familiar, this manual presents a complete overview of
Commission requirements and provides links to more detailed
material.
This manual is not intended to take the place of the applicable
legislation. The user is encouraged to read the full text of
legislation and each applicable regulation and seek direction
from Commission staff, if and when necessary, for clarification.

1.2

Scope
This manual focuses exclusively on requirements and
processes associated with the Commissions legislative
authorities and does not provide information on legal
responsibilities that the Commission does not regulate. It is the
responsibility of the applicant or permit holder to know and
uphold its other legal responsibilities. Examples of legal
responsibilities outside of this manual include obligations under
the Federal Fisheries Act, the Transportation Act, the Highway
Act, the Workers Compensation Act, and the Wildlife Act.

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1.3

How to Use This Manual


This manual is divided into sections which will take the user
through the various operational steps and regulatory
requirements related to well servicing activities, including
completions, workovers, maintenance and abandonments.
Section 2.0 Well Equipment explains regulatory requirements for well
equipment in the Drilling and Production Regulation.
Section 3.0 Well Servicing Operations outlines and explains the
requirements for well completions, workovers, maintenance,
suspension and abandonments.
Section 4.0 Well Servicing Equipment and Procedures outlines and
explains blowout prevention standards, personnel requirements
and fire precautions that permit holders must follow to comply
with the Drilling and Production Regulation.
Section 5.0 Environmental Considerations outlines and explains the
regulatory requirements for flaring, noise, fluid storage, casing
leaks, surface casing vent flows and gas migration.
Section 6.0 Data Submission outlines and explains the regulatory
requirements the operator must include in reports for the
completion, workover and abandonment of wells. Regulatory
requirements for reporting on well deliverability tests are also
included within this section.
Section 7.0 Compliance describes contravention of legislation and
regulation and administrative penalties.

1.4

Additional Guidance
Guidance for submitting applications for wells within the
jurisdiction of the Commission is located in the Well Permit
Application Manual.
Guidance for well construction, drilling, reclamation and waste
management for wells within the jurisdiction of the Commission
is located in the Well Drilling and Waste Management manuals.
The Supplementary Information for Water Source Wells
document outlines additional requirements specific to water
source wells.
The glossary page on the Commission website provides a
comprehensive list of terms.

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Other navigational and illustrative elements used in the manual
include:
Hyperlinks: Hyperlinked items appear as blue, underlined text. Clicking on a
hyperlink takes the user directly to a document or location on a
webpage.
Sidebars: Sidebars highlight important information such as a change from
the old procedure, new information, or reminders and tips.
Figures: Figures illustrate a function or process to give the user a visual
representation of a large or complex item.
Tables: Tables organize information into columns and rows for quick
comparison.

1.4.1 Feedback
The Commission is committed to continuous improvement by
collecting information on the effectiveness of guidelines and
manuals. Clients and stakeholders wishing to comment on
Commission guidelines and manuals may send constructive
comments to OGC.Systems@bcogc.ca.

1.4.2 Frequently Asked Questions


A Frequently Asked Questions (FAQ) link is available on the
Commission OGAA website. The information provided is
categorized into topics which reflect the manuals for easy
reference.

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2 Well Equipment
The well equipment section outlines the regulatory requirements
for well equipment in the Drilling and Production Regulation.

2.1

Wellheads
[Section 17, Drilling and Production Regulation]
Wellheads are required to operate safely under the conditions
anticipated during the life of the well and the wellhead is not to
be subjected to excessive force.
Refer to Enform Publications Industry Recommended Practice
(IRP) Volume #5, (IRP 5 Minimum Wellhead Requirements)
for more information.

2.2

Tubing
[Section 16, Drilling and Production Regulation]
Tubing is required for the production of gas containing 5%
hydrogen sulphide (H2S) and for all injection and disposal
except for the injection of fresh water.

2.3

Packers
[Sections 16 and 39, Drilling and Production Regulation]
A production packer must be used for:
All injection and disposal except for the injection of fresh
water and
Wells containing gas with > 5% H2S, or if a numbered
highway or populated area is located within the emergency
planning zone for the well.
Populated area means a dwelling, school, picnic ground or
other place of public concourse.
Annual packer isolation testing is required for all wells where
installation of a production packer is required. If a packer test
fails, the permit holder must complete repairs without

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unreasonable1 delay.
Refer to the Commissions Water Service Well Summary
Information document Appendix D for recommended packer
testing procedures.
Please submit a PDF file of the report to
welldatamail@bcogc.ca with the naming convention
WANUM_PIT_YYYYMMMDD_OPTIONAL (example:
11122_PIT_2015JUN05_PASS). YYYYMMMDD is the date the
test was performed. The optional portion of the naming
convention may be any alphanumeric text up to 40 characters in
length. eSubmission of packer isolation tests reports is under
development and will be available soon.

2.4

Subsurface Safety Valves


[Section 39, Drilling and Production Regulation]
Subsurface safety valves are required for wells containing gas
with > 5% H2S if:
A major highway or populated area is located within the
emergency planning zone for the well
The well is located within 800 m of a populated area or 8
km of a town, city or village and
The well could produce > 30 000 m3 of gas per day
In general, the distance from a city, town or village should be
measured from the corporate limits. In cases where the
corporate limits do not reasonably correspond with the
boundaries of the community, the permit holder may take a
functional approach such as delineation of the extent of
developed areas.

2.5

Oil Wells
[Section 39, Drilling and Production Regulation]

In general, all repairs should be completed within 90 days. Reasonable


delays are acceptable in cases where access is seasonal and the delay does
not result in a risk to safety or the environment. Delays that extend past the
next seasonal access window are not reasonable (greater than one year).

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Oil wells completed after September 13, 2010 equipped with an
artificial lift, if the H2S content of the gas exceeds 100 ppm,
must install the following
An automatic shutdown on the stuffing box that will shut
down the pumping unit in the event of a stuffing box or
polish rod failure and
An automatic vibration shutdown system

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2.6

Fencing
[Section 39, Drilling and Production Regulation]
Permit holders of completed wells that:
Are located within 800 m of a populated area or
Have a populated area within the emergency planning zone
for the well
Fencing or other measures to prevent unauthorized access to
the well must be installed in these circumstances.
Fencing or other forms of access control must be proportional to
the potential for unauthorized access to the wellsite. Access
control may include fencing of the wellsite, or gating the access
road. If the well is located in an access-controlled area, no
additional measures may be required. For wells that are located
on private land, the method of access control should be
developed in consultation with the landowner.

2.7

Leak Detection
[Section 39, Drilling and Production Regulation]
All completed wells must be equipped with a system to detect
and control leaks as quickly as practicable.
The Commission expects that leak detection systems will be
proportional to the consequences that may result from a leak.
Leak detection may range from fully automated shutdown
systems to periodic inspections.
If an uncontrolled flow from a completed well could produce a
hydrogen sulphide concentration in atmosphere greater than
100 ppm at a distance of 50 metres from the well, the permit
holder must install and maintain:
An automated shutdown system and
A hydrogen sulphide detection, alarm and automated
shutdown system if the well is located within 1600 metres
of a populated area
For wells completed prior to October 4, 2010, H2S detection and
automated shutdown systems are not required until
January 1, 2012 and the permit holder may apply for an
exemption to the requirement.

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The following formula may be used to calculate the absolute
open flow rate of a well that will result in an H2S concentration in
atmosphere of 100 ppm at a point 50 metres from the well:
Wellhead AOF (103m3/day) = 147 000 / H2S (ppm)
or
Wellhead AOF (103m3/day) = 14.7 / H2S (mol %)

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Well Completion, Maintenance and Abandonment Guideline, Version 1.17

3 Well Servicing Operations


The well servicing operations section outlines and explains the
requirements for the reporting of servicing, suspension,
reactivation or abandonment of wells. It also outlines the
notification requirements for completions, workovers and
maintenance of wells.

3.1

Well Servicing Operations


[Section 39, Drilling and Production Regulation]
A permit holder must ensure that an adequate Emergency
Response Plan is in place before conducting well servicing
operations. For more information, contact the Commissions
Emergency Response and Safety Department.

3.2

Completions / Workovers / Maintenance


[Section 24, Drilling and Production Regulation]
A Notice of Operations must be submitted to the Commission at
least 24 hours prior to the start of all completion, workover or
abandonment operations. An approved Application to Alter is no
longer required for completion or workover operations.
All notifications must be submitted using the eSubmission
Portal. Refer to the eSubmission Portal User Guide for more
information.
See Section 6.1 for Completion/Workover Report submission
requirements.

3.2.1 Shallow Fracturing


[Section 21, Drilling and Production Regulation]
Fracturing operations conducted at a depth of 600 metres or
less must be approved in the well permit. Applications for
shallow fracturing operations should include:
The fracture program design including proposed pumping
rates, volumes, pressures, and fracturing fluids
Estimation of the maximum fracture propagation
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Assessment of groundwater resources in the area


Identification and depth of all wells within 200 metres of the
proposed shallow fracturing operations
Verification of cement integrity through available public data
of all wells under the Commissions jurisdiction within a 200
metre radius of the well to be fractured
Notification of water well owners within 200 metres of the
proposed fracturing operations
The depth of bedrock and
Assessment of the suitability of the candidate well for the
proposed fracturing operations including casing and
cement integrity

Refer to the Well Permit Application Manual for more


information on well permit applications and amendments.
3.2.2 Commingling
[Section 23, Drilling and Production Regulation]
All zones in a well must remain segregated unless permission
has been granted for commingled production. Permission may
be granted in an individual well permit or by a special project for
commingling under section 75 of OGAA. The Commission has
designated certain areas where commingling is authorized,
subject to certain conditions, including:
Deep basin
Plains and Northern Foothills
Outer Foothills
For more information, refer to the Commingling section within
the Commissions Reservoir Engineering Forms and Guidelines
page.
The Notification of Commingled Well Production form must be
submitted to the Commission within 30 days of the
commencement of commingled production.

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3.3

Well Suspension
[Section 25, Drilling and Production Regulation]
3.3.1 Definitions
Activity means
(a) production, injection, or disposal of fluids,
(b) drilling, completion or workover operations and
(c) reservoir pressure observation.
Inactive Well means a well that has not been abandoned but
(a) has not been active for 12 consecutive months or
(b) if the well is classified as a special sour well or an acid
gas disposal well and has not been active for 6
consecutive months.
For active production, injection and disposal wells, the date of
last activity is defined as the first day of the month following the
last month for which production, injection and disposal volumes
were reported.
Observation wells are deemed to be active (see Observation
Wells section).
For drilling activity, including new wells and re-entries, the date
of last activity is defined as the rig release date.
For completion and workover activity, the date of last activity is
defined as the completion date.
A permit holder may apply to the Commission to declassify a
special sour well.

3.3.2 Observation Wells


Inactive wells offer good opportunities to monitor reservoir
behaviour, specifically, pool pressures over time. Tests of these
wells do not require shutting in producing wells to obtain
pressure information and can provide accurate sampling points.
Wells with an operational status of Observation must be tested
and a Reservoir Pressure Survey Test Report must be
submitted to the Commission Reservoir Engineering
Department at least once every two years.

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A well may be classified as Observation by submission of a


BC-11 form (Notice of Commencement or Suspension of
Operations) to the Ministry of Finance. A brief statement
indicating what the well will be used to monitor should be
included in the comments section.
Observation wells are treated as active and do not require
suspension unless declassified.
Observation wells will be declassified if pressure data is not
submitted within 12 months of its due date.
Upon declassification, observation wells will be reclassified
according to the well operation status (i.e. Gas Production)
that existed prior to their classification as observation wells
and will require suspension.
For observation wells that have been declassified, the date
of last activity is the due date of the last pressure test
survey report.

3.3.3 Suspension Requirements


All wells must be suspended within 60 days of attaining inactive
status in a manner that ensures the ongoing integrity of the well.
Any well may be suspended to a higher standard than the
minimum requirements described in Tables 1 to 4. Reporting
requirements are outlined in the Information and Reporting
Requirements section.
If all zones in a non-special sour well are abandoned and the
well has not yet been surface abandoned, the well shall be
categorized as Low Risk - All cased wells (no perforations or
open hole).
Permit holders may apply to the Commission Drilling and
Production Department for an extension of a deadline.
The following tables describe the Commissions minimum
requirements for each category.

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Table 3.1: General Requirements for All Inactive Wells


Wellheads

Unperforated wells may use a welded steel plate atop the production casing stub.
The plate must provide access to the wellbore for pressure measurement. All other
wells must use standard wellheads as described in IRP2 and IRP5 (draft).
There shall be no wellhead leaks.
Bullplugs or blind flanges with needle valves must be installed on all outlets except
the surface casing vent.
The surface casing vent valve must be open and the surface casing vent
unobstructed unless otherwise exempted by an official.

Wellhead
Maintenance

All valves must be chained and locked or valve handles must be removed.
The flowline must be disconnected from the wellhead.
Polish rod removal is not required to suspend low risk oil wells as long as the polish
rod remains connected to the pump jack.
Pressure testing of the wellhead sealing elements refers to the primary and
secondary seals only, as applicable. For wellheads that do not have adequate test
ports, pressure tests may be omitted and visual observation for leaks is acceptable.
An explanatory note must be included on the well suspension report.

Surface
Casing Vent
Flows

Lease
Maintenance

Visual
Inspection

Surface casing vent flows are to be managed and reported in accordance with
Commission requirements.

A sign stating the wells surface location, current permit holder, the current
permit holders emergency contact number and appropriate warning symbols
as defined in Section 17 of the Drilling and Production Regulation must be in
place.

An area of 10 metres radius around the wellhead must be maintained to


prevent brush from growing and causing a fire hazard.

Noxious weeds must be controlled.

A visual inspection of the lease and wellhead must be conducted at least yearly to
observe for wellhead integrity, noxious weeds and other hazards.
For wells with helicopter access, the visual inspection frequency is the pressure
testing / monitoring frequency.
Submit a BC-11 to the Ministry of Finance as outlined in Section 8.2.

A Suspension Report must be submitted to the Commission within 30 days of


the completion of suspension operations.

Records of inspections must be maintained on file and if requested, be made


available to the Commission for review.

Reporting

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Table 3.2: Requirements Specific to Inactive High Risk Wells

Well Types

Suspension Options

Type 1: Special sour wells2.


Type 2: Acid gas disposal wells.
Option A

Downhole
Requirements

Pressure Testing /
Monitoring / Servicing
Requirements
Pressure Testing /
Monitoring / Servicing
Frequency

Wellbore Fluid

Option B

Bridge plug or packer and


tubing plug.

Bridge plug capped with 8 m


lineal of cement.

Pressure test both tubing and


annulus to 7 MPa for 10
minutes.

Pressure test the casing to 7


MPa for 10 minutes.

Service and pressure test


wellhead sealing elements.

Service and pressure test


wellhead sealing elements
(if applicable).

At the time of suspension and


then annually.

At the time of suspension and


then every 5 years.

Wellbore must be filled with


non-saline water or corrosion
inhibited water. The upper
portion of the wellbore must
be protected from freezing.
Freeze protection may be
accomplished by the
placement of at least 2 m of a
suitable, non-freezing fluid at
surface.

Wellbore must be filled with nonsaline water or corrosion


inhibited water. The upper
portion of the wellbore must be
protected from freezing. Freeze
protection may be accomplished
by the placement of at least 2 m
of a suitable, non-freezing fluid at
surface.

If applicable, install a bridge plug or packer and tubing plug within 100
metres of the liner top on uncompleted special sour wells.

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Table 3.3: Requirements Specific to Inactive Medium Risk Wells

Well Types

Type 1: Medium risk gas wells (see Section 3.4).


Type 2: Non-flowing oil wells 50 mol/kmol H2S.
Type 3: Flowing oil wells3.
Type 4: All injection and disposal wells except for acid gas
disposal wells.
Type 6: Completed low risk wells that have been inactive or
suspended for at least 10 consecutive years.

Suspension
Options
Downhole /
Wellhead
Requirements

Option A (All types)

Option B (All types)

Option C (Type 6 Only)

Packer and tubing plug.

Bridge plug.

Dual master valves.

Pressure test both the


tubing and annulus to 7
MPa for 10 minutes.

Pressure test the


casing to 7 MPa for 10
minutes.

Read and record shut-in


tubing pressure (if
applicable) and shut-in
casing pressure.

Service and pressure


test wellhead sealing
elements.

Service and pressure


test wellhead sealing
elements.

Pressure Testing /
Monitoring /
Servicing
Frequency

At the time of
suspension and then
every 3 years.

At the time of
suspension and then
every 5 years.

At the time of suspension


and then annually.

Wellbore Fluid

Wellbore must be filled


with non-saline water or
corrosion inhibited
water. The upper
portion of the wellbore
must be protected from
freezing. Freeze
protection may be
accomplished by the
placement of at least 2

Wellbore must be filled


with non-saline water or
corrosion inhibited
water. The upper
portion of the wellbore
must be protected from
freezing. Freeze
protection may be
accomplished by the
placement of at least 2

None.

Pressure Testing /
Monitoring /
Servicing
Requirements

Service and pressure test


wellhead sealing
elements.

Flowing oil wells are oil wells with sufficient reservoir pressure to sustain
flow against atmospheric pressure without artificial lift. The flowing product is
a fluid.

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m of a suitable, nonfreezing fluid at surface.

m of a suitable, nonfreezing fluid at surface.

Table 3.4: Requirements Specific to Inactive Low Risk Wells

Well Types

Type 1: All non-special sour cased wells (no perforations or open


hole sections).
Type 2: Low risk gas wells (see Section 3.4).
Type 3: Water source wells.

Type 5: Non-flowing oil wells < 50 mol/kmol H2S.

Suspension
Options

Option A

Option B

(Types 2,3 and 5 only)

(Type 1 only)

Downhole
Requirements

None.

Pressure Testing
/ Monitoring /
Servicing
Requirements

Read and record shut-in tubing


Pressure test casing to 7 MPa for 10
pressure (if applicable) and shut-in
minutes.
casing pressure.
Service and pressure test wellhead
Service and pressure test
sealing elements (if applicable).
wellhead sealing elements.

Pressure Testing
/ Monitoring /
Servicing
Frequency

At the time of suspension and


then every 5 years.

At the time of suspension and then every 5


years.

None.

Wellbore must be filled with non-saline


water or corrosion inhibited water. The
upper portion of the wellbore must be
protected from freezing. Freeze protection
may be accomplished by the placement of
at least 2 m of a suitable, non-freezing
fluid at surface.

Wellbore Fluid

None.

Non-flowing oil wells are oil wells without sufficient reservoir pressure to
sustain flow against atmospheric pressure without artificial lift. The flowing
product is a fluid. Removal of polish rods is not required to suspend low-risk
oil wells as long as the polish rod remains connected to the pump jack.

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3.3.4 Packer Testing
Wells that require installation and yearly testing of a production
packer are exempt from the testing requirements if the well is
suspended in accordance with the Drilling and Production
Regulation.
3.3.5 Long Term Inactive Wells
All completed low-risk wells must meet medium risk suspension
requirements after being suspended for 10 consecutive years.
For example, a completed low-risk well that last reports
production in December 2008 would be classed as inactive on
December 31, 2009 and the Operator would have 60 days to
suspend the well in accordance with low-risk suspension
requirements. If the well was still suspended on December 31,
2019, the Operator would have 60 days to suspend the well in
accordance with medium risk suspension requirements.
3.3.6 Reactivating Suspended Wells
The following are the procedures for the reactivation of a
suspended well:
All Wells:
Inspect, service and pressure test the wellhead
Inspect and service control systems and lease facilities
Report the reactivation through submission of a BC-11 form
to the Ministry of Finance
Medium and High-Risk Wells:
Pressure test the casing to 7 MPa for 10 minutes
(if applicable). If the test fails, investigate and repair the
problem
Pressure test the tubing (if present) to 7 MPa for 10
minutes. If the test fails, investigate and repair the problem
3.3.7 Information / Reporting Requirements
3.3.7.1 Oil and Gas Commission
Suspensions
A Well Suspension/Inspection Form must be submitted to the
Commission, Drilling and Production Department within 30 days
of suspension of a well.
The suspension report may be submitted as a paper copy or in
spreadsheet form.
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Reactivations
Submission of a reactivation report is not required.
Reactivations are identified by alternate means (i.e. spud date,
production reporting).
Inspections
Records of inspections must be provided to the Commission on
request.
Inspection results may be recorded by filling out the applicable
sections of the Well Suspension/Inspection Form or through the
permit holders internal database. If an internal inspections
database is used, it is the permit holders responsibility to
ensure that the required information is recorded.
3.3.7.2 Ministry of Finance
The form Notice of Commencement or Suspension of
Operations: BC-11 must be submitted to the Ministry of Finance
on or before the 20th day of the calendar month following the
calendar month in which the following operations occurred at a
well:
Testing operations at a well prior to its being tied in to a gas
gathering system
Initial commencement of production
Initial commencement of injection or disposal
Suspension of production
Suspension of injection or disposal
Resumption of production
Resumption of injection or disposal
A separate BC-11 is required for each well or completed zone
within a well. A single form may be completed if a well has both
a production and a service status in a production month, or if the
status changes more than once in a production month (for
example testing and producing)

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3.4

Classification of Low and Medium Risk Gas Wells


3.4.1 High Risk gas wells are gas wells that are classified as
special sour or are acid gas disposal wells.
3.4.2 Medium Risk gas wells are gas wells where the
maximum stabilized wellhead AOF exceeds the Maximum
Allowable Flowrate5 or 28 x 103 m3/day6 and are not classified
as high risk gas wells.
Maximum Allowable Flowrate (103m3/day) = 15 x 103 / H2S
Concentration (ppm)
3.4.3 Low Risk gas wells are gas wells that are not classified
as Medium or High Risk.
100000
MEDIUM
RISK

H2S (ppm)

10000

1000
535 ppm

100
LOW
RISK

10

10

28,000 m3/day

100

Flowrate (x 1000 m3/day)

This calculation (adopted from the AER Directive 13) determines the
maximum flowrate for a given H2S concentration that will result in a
maximum concentration of H2S at the lease boundary of 10 ppm. The lease
boundary is assumed to be 50 metres from the wellhead.
6
Maximum flowrate is adopted from the AER Directive 13 and is considered
to be surface killable based on fluid momentum theory.

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Figure 3.1: Classification of Low and Medium Risk Gas Wells (Adopted
from AER Directive 13).

3.5

Well Abandonment
[Section 26, Drilling and Production Regulation]
For drilling wells, notification is not required prior to conducting
open hole plugbacks or abandonments.
Drilling wells that are downhole, but not surface abandoned at
the time of rig release, are not considered abandoned. An
abandonment notification and abandonment report must be
submitted to the Commission at the time of surface
abandonment as outlined below for the well status to be
changed to abandoned.
Notification is required 7 days prior to conducting all other well
abandonments; however the notification requirement may be
waived on a case by case basis. An abandonment program
must be included with the notification.
Wells must be abandoned in a manner that ensures:
Adequate hydraulic isolation between porous zones
Fluids will not leak from the well
Excessive pressure will not build up in any portion of the
well
The long-term integrity of the wellbore is maintained
Permit holders are expected to conduct abandonments and
plugbacks in accordance with the AER Directive 20. If there is
any doubt about the adequacy of a plugging or abandonment
program, the permit holder should discuss their plans with the
Commission. Failure to adequately plug or abandon a well may
result in an order for remedial work.
Abandonment reports may be submitted using a
Completion/Workover Report Form.

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4 Well Servicing Equipment and Procedures


The well servicing equipment and procedures section outlines
and explains blowout prevention standards, personnel
requirements and fire precautions that permit holders must
follow to comply with the Drilling and Production Regulation.

4.1

Blowout Prevention
[Part 4, Division 2, Drilling and Production Regulation]
4.1.1 Well Servicing Blowout Prevention
The following section outlines blowout prevention standards that
a permit should follow to comply with the requirements of Part 4,
Division 2 of the Drilling and Production Regulation. It is the
responsibility of the permit holder to ensure that blowout
prevention equipment and procedures are adequate.
A permit holder may use alternate blowout prevention
equipment and techniques if they can demonstrate by means of
a detailed engineering analysis that the alternate equipment or
techniques are adequate as required by section 16(1) of the
Drilling and Production Regulation.
4.1.2 BOP Equipment Classes
For the purposes of well servicing, blowout prevention
equipment classes are as follows:
Class A equipment is required for a well where the minimum
pressure rating of the production casing flange is less than or
equal to 21 000 kilopascals (kPa) and the hydrogen sulphide
content in a representative sample of the gas is less than 1 mol
%;
Class B equipment is required for a well where the minimum
pressure rating of the production casing flange is:
a) greater than 21 000 kPa, or
b) less than or equal to 21 000 kPa and the hydrogen
sulphide content in a representative sample of the gas is
1 mol % or greater
Class C equipment is required for a special sour well.

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4.1.3 General
At all times during well servicing, the well must be under control,
adequate blowout prevention equipment must be installed and
must be able to shut off flow from the well regardless of the type
or diameter of tools or equipment in the well.
The blowout prevention equipment must have a pressure rating
equal to or greater than the pressure rating of the production
casing flange or the formation pressure, whichever is the lesser.
Hydraulic ram type blowout preventers which are not equipped
with an automatic ram locking device must have hand wheels
available.
An accurate pressure gauge to determine the well annulus
pressure during a well shut-in must be either installed or readily
accessible for installation.
A service rig used at the well site must have an operable horn
on the drilling control panel for sounding alerts.
A sour service separator and flare system, including appropriate
manifolding, must be used to process sour well effluent.
The well control system must be adequately illuminated.
4.1.4 Accumulator systems
All blowout preventers must be hydraulically operated and
connected to an accumulator system.
The accumulator system must be installed and operated in
accordance with the manufacturer's specifications. The system
must be:
a) 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 must be
of steel construction unless completely sheathed with
adequate fire resistant sleeving
b) Capable of providing, without recharging, fluid of
sufficient volume and pressure to effect full closure of all
preventers, and to retain a pressure of 8 400 kPa on the
accumulator system
c) Recharged by a pressure controlled pump capable of
recovering the accumulator pressure drop resulting from
full closure of all preventers within 5 minutes
d) Capable of closing any ram type preventer within 30
seconds
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e) Capable of closing the annular preventer within 60
seconds
f) Equipped with readily accessible fittings and gauges to
determine the pre-charge pressure
g) Equipped with a check valve between the accumulator
recharge pump and the accumulator and
h) Connected to a nitrogen supply capable of closing all
blowout preventers installed on the well
The accumulator nitrogen supply must:
a) Be capable of providing sufficient volume and pressure to
fully close all preventers and to retain a minimum
pressure of 8 400 kPa, and
b) Have a gauge installed, or readily available for
installation, to determine the pressure of each nitrogen
container
4.1.5 Requirements Specific to Class A Systems
Class A blowout prevention system
a) May utilize the rig hydraulic system to recharge the
accumulator and
b) Must have operating controls for each preventer in a
readily accessible location near the operator's position
and an additional set of controls located a minimum of
7 meters from the well
4.1.5 Requirements Specific to Class B and C Systems
Class B and Class C blowout prevention system must 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
b) An additional set of controls in a readily accessible
location near the operator's position and
c) Working spools with flanged outlets
4.1.6 Line Requirements
The following requirements do not apply to snubbing units and
service rigs completing rod jobs.
A blowout prevention system must have two lines, one for
bleeding off pressure and one for killing the well, which must:
a) Be either steel or flexible sheathed hose to provide
adequate fire resistant rating

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b) Be valved and have a working pressure equal to or
greater than that required for the blowout prevention
equipment
c) Have one line connected to the rig pump and one line
connected to the tank
d) Have one line connected to an outlet below the blowout
preventers and the necessary equipment to readily
connect the second line to the tubing
e) Be at least 50 mm nominal diameter and
f) Be securely tied down
4.1.7 Stabbing Valve
A full opening ball valve (stabbing valve) which can be attached
to the tubing or other pipe in the well must:
a) Be ready for use and located in a readily accessible
location on the service rig
b) Be maintained in the open position
c) Have an internal diameter equal to or greater than the
smallest restriction inside the tubing or casing and
d) Be kept clean and ice free
4.1.8 Blowout Prevention Manifold
The blowout prevention system must include a manifold that:
a) Consists of an arrangement of valves and steel lines that
have a working pressure greater than or equal to that of
the blowout prevention system installed on the well
b) Contains a check valve to prevent flow from well to rig
pump
c) Contains a pressure relief valve upstream of the check
valve
d) Is equipped with an accurate pressure gauge which shall
be either installed or readily accessible for installation
4.1.9 Testing of Blowout Prevention Equipment
Before commencing servicing operations at a well, a 10-minute
pressure test must be conducted on:
a) Each ram preventer to 1400 kPa, prior to the tests
described in (b) and (c)
b) Each ram preventer, the full opening safety valve and the
connection between the stack and the wellhead, tested to
the wellhead pressure rating or the formation pressure,
whichever is less

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c) Each annular preventer to 7000 kilopascals or the
formation pressure, whichever is less
Note: For an annular type blowout preventer, all mechanical and
pressure tests required under subsection (c) must be conducted
with pipe in the blowout preventer.
All blowout prevention equipment, except for shear rams on
special sour wells, must be mechanically tested daily, if
operationally safe to do so; any equipment found defective must
be made serviceable before operations are resumed.
All tests must be reported in the servicing log book and in the
case of a pressure test, the report must state the blowout
preventer tested, the test duration and the test pressure
observed at the start and finish of each test.
At least once every three years, all blowout preventers must be
shop serviced and shop tested to their working pressure and the
test data and the maintenance performed must be recorded and
made available to an official on request.
4.1.10 Special Sour Wells
Refer to Enform Publications Industry Recommended Practice
(IRP) #2: Completing and Servicing Critical Sour Wells for
detailed information.
4.1.11 Slickline, Snubbing and Coil Tubing Operations
Refer to Enform IRP#13: Slickline Operations
Refer to Enform IRP#15: Snubbing Operations
Refer to Enform IRP#21: Coil Tubing Operations (Draft)
4.1.12 Hammer Unions
Hammer unions should not be used in the manifold shack or
under the rig substructure

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4.1.13 Diagrams of Blowout Prevention Systems for Well


Servicing

Figure 4.A Equipment Symbols

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Figure 4.B

BOP Class A Pressure Rating and Component Placement


Notes: 1. Pressure rating of preventers is equal to or
greater than the production casing flange rating or
the formation pressure, whichever is the lesser.
2. 50 mm lines throughout
3. The positioning of the tubing and blind rams may
be interchanged.
4. Spool may have threaded side outlet (and valve) if
wellhead has threaded fittings.
5. A flanged BOP port (and valve) below the lowest
set of rams may replace spool (valve may be
threaded if wellhead has threaded fittings).

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Rating of production casing flange is greater than 21 000 kPa or
rating of production casing flange is less than or equal to 21 000
kPa and the H2S content of the gas is equal to or greater than
10 MOLES per KILOMOLE.

Figure 4.C

BOP Class B Pressure Rating and Component Placement


Notes: 1. Pressure rating of preventers is equal to or greater
than the production casing flange rating or the
formation pressure, whichever is the lesser.
2. 50 mm lines throughout
3. The positioning of the tubing and blind rams may
be interchanged.
4. Spool may have threaded side outlet (and valve) if
wellhead has threaded fittings.
5. A flanged blowout preventer port (and valve)
below the lowest set of rams may replace spool
(valve may be threaded if wellhead has threaded
fittings.)

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Figure 4.D

BOP Class C Wellhead Configuration

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Figure 4.E

4.2

BOP Class C Optional Wellhead Configuration

Personnel
[Section 13, Drilling and Production Regulation]
The permit holder must ensure that there are a sufficient
number of trained and competent individuals to carry out all well
operations safely and without causing pollution.
The following people must possess a valid Well Service Blowout
Prevention Certificate, issued by Enform:
The driller on tour
The rig manager (tool push) and
The permit holders representative

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If gas containing H2S is expected, every crew member must be


trained in H2S safety.
Blowout prevention drills should be performed by each rig crew
every 7 days or once per well, whichever is more frequent.
Blowout prevention drills should be recorded in the servicing log
book.
Evidence of the qualifications of any person referred to in this
section must be made available to an official on request.
The rig crew must have an adequate understanding of, and be
able to operate, the blowout prevention equipment and, when
requested by an official and if it is safe to do so, the contractor
or rig crew must:
Test the operation and effectiveness of the blowout
prevention equipment and
Perform a blowout prevention drill in accordance with the
Well Control Procedure placard issued by the Canadian
Association of Oilwell Drilling Contractors or as outlined by
the Enform Blowout Prevention Manual
Refer to Enform IRP#7 Standards for Wellsite Supervision of
Drilling, Completions and Workovers for more information.

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4.3

Fire Precautions and Equipment Spacing


[Sections 45 and 47, Drilling and Production Regulation]
4.3.1 Engines
Permit holders must ensure that, if engines are located at a
wellsite, suitable safeguards are installed and tested to prevent
a fire or explosion in the event of a release of flammable liquids
or ignitable vapours.
For engines located within 25 metres of a well, petroleum
storage tank or other unprotected source of ignitable vapours,
the Commission recommends that:
The engine exhaust pipe is insulated or cooled to prevent
ignition in the event that flammable material contacts the
exhaust pipe
The exhaust pipe is directed away from the well or source
of ignitable vapours and
The exhaust manifold is sufficiently shielded to prevent
contact with flammable materials
For diesel engines located within 25 metres of a well, the
Commission recommends that one of the following devices be
installed:
A positive air shutoff valve, equipped with a readily
accessible control
A system for injecting inert gas into the engines cylinders,
equipped with a readily accessible control or
A suitable duct so that air for the engine is obtained at least
25 metres from the well
Permit holders must also ensure compliance with the
requirements in Section 23.8 of the Occupational Health and
Safety Regulation.
4.3.2 Fuel
Gasoline or liquid fuel, except for fuel in tanks that are
connected to operating equipment, must not be stored within 25
metres of a well and drainage must be away from the wellhead.
4.3.3 Smoking
Smoking is prohibited within 25 metres of a well.

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4.3.4 Recommended Spacing Distances


Permit holders must ensure that appropriate spacing is
maintained between potential sources of flammable liquids or
ignitable vapours and ignition sources. All fires must be
sufficiently safeguarded and all vessels and equipment from
which ignitable vapours may issue must be safely vented.

PRODUCED FLAMMABLE
LIQUIDS CRUDE OIL &
CONDENSATE TANKS

OTHER SOURCES OF IGNITABLE


VAPOURS

SEPARATOR

FLAME TYPE EQUIPMENT

PRODUCED FLAMMABLE LIQUIDS


CRUDE OIL & CONDENSATE TANKS

50

PRODUCED WATER TANK

50

BOILER, STEAM GENERATING


EQUIPMENT, TEG*

WELLHEAD
FLARE OR INCINERATOR
BOILER, STEAM
GENERATING EQUIPMENT,
TEG*
PRODUCED WATER TANK
OTHER SOURCES OF
IGNITABLE VAPOURS
SEPARATOR
FLAME TYPE EQUIPMENT

FLARE OR INCINERATOR

WELLHEAD

It is the responsibility of the permit holder to maintain sufficient


equipment spacing.

25
NS

NS
25

NS
25

NS
25

25*
25

50
50

25

25

25

25

25

NS

NS

25*

NS

NS

25*

NS
NS**
25*

25

NS

NS

25

25

NS

25

25

NS

NS
25*

25
25

25
25

NS
25*

NS
25*

25*

25*
T

50

50

25

NS

NS

NS**

25*

All distances are in metres (m).


* 25 m without flame arrestors, not specified with flame arrestors.
** Separator cannot be in the same dyke.
T Treaters should be at least 5 m (shell to shell) from other treaters.
Note:
a) Boilers etc. Includes steam generating equipment, electric generators and TEG units.

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b) Other sources of ignitable vapours include compressors.
c) Flame type equipment includes: treaters, reboilers and line heaters.
d) All electrical installations must conform to the Canadian Electrical Code.
Table 4.1 Recommended Spacing Distances

Flares and incinerators must be located at least 80 metres from


any public road, utility, building, installation, works, place of
public concourse or reservation for national defence.
4.3.5 Flare Stacks
A sufficient area beneath and around flare stacks must be
cleared of flammable materials and vegetation.
The recommended blackened area beneath a flare stack is 1.5
times the stack height.
The Commission recognizes that a lesser area may be justified
depending on the circumstances. It is the responsibility of the
permit holder to maintain a sufficient area, given the location
and the conditions under which flaring will or may occur.
4.3.6 Explosives
Explosives must be stored in properly constructed magazines
and be located a minimum of 150 metres from any well
servicing operation.

4.4

Incident Reporting
Spills and well control incidents must be reported to the
Provincial Emergency Program (PEP) at 1-800-663-3456, and
the Commission at (250) 794-5200
Spills must be reported in accordance with the Spill Reporting
Regulation.

4.5

Concurrent Operations
A concurrent operations plan is required for completions
operations on any well that is located within 25 metres of
another well.

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5 Environmental Considerations
The environmental considerations section outlines and explains
the regulatory requirements for testing, repairing and reporting
environmental impacts: surface case venting flows, gas
migration, casing leaks and failures, noise, flaring and venting,
fluid storage and spills.

5.1

Surface Casing Vent Flows


[Section 41, Drilling and Production Regulation]
5.1.1 Definitions
Surface Casing Vent Flow (SCVF) means the flow of gas
and/or liquid from the surface casing/casing annulus.
Serious Surface Casing Vent Flow means
A vent flows with hydrogen sulphide (H2S) present
A vent flow with a stabilized gas flow rate equal to or
greater than 300 cubic metres per day (m3/d)
A vent flow with a surface casing vent stabilized shut-in
pressure greater than

o one half the formation leak-off pressure at the surface


casing shoe or
o 11 kPa/m times the surface casing setting depth
A hydrocarbon liquid (oil) vent flow
A vent flow due to wellhead seal failures or casing failure
A water vent flow if the water contains substances that
could cause soil or groundwater contamination
A vent flow where any usable water zone in not covered by
cemented casing or
Any other vent flow that constitutes a fire, public safety, or
environmental hazard

5.1.2 Checking for Surface Casing Vent Flows


Testing for evidence of a surface casing vent flow must be
conducted:
During initial completion of the well
As routine maintenance throughout the life of the well
During the abandonment of the well
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The Commission expects routine tests for surface casing vent


flows to be conducted at the time of well suspension, during well
servicing operations (that is, recompletions) and annually for a
period of five years if a positive surface casing vent flows has
been identified.
A 10-minute bubble test is adequate to test for the presence of a
surface casing vent flow. The recommended procedure is as
follows:
Bubble Test Equipment:
1) A container of water (from 500 ml to 1L)
2) Pipe fittings, small hose (minimum 6mm), or other
equipment necessary to direct gas flow from vent
downward in the water container
Bubble Test Procedure:
1) Ensure that there are no gas leaks at fittings and welds;
2) Ensure there is no H2S present;
3) Ensure all valves in the vent line are open;
4) If necessary, connect test fittings to the vent so gas flow
can be directed into the container of water.
5) Immerse vent or hose a maximum of 2.5 cm below the
water surface;
6) Observe for 10 minutes. Note any gas flow (i.e. bubbles)
which must be recorded as a positive vent flow;
7) Record observations.
5.1.3 Testing and Reporting Surface Casing Vent Flows
Serious surface casing vent flows present a safety or
environmental hazard and must be reported to the Commission
as soon as possible.
The Commission recommends that permit holders report
surface casing vent flows that are non-serious -those that do not
present an immediate safety or environmental hazard. This may
be accomplished by submitting via email to
OGCDrilling.Production@bcogc.ca a Surface Casing Flow
Gas Migration Information Form or an industry report form . Test

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results for non-serious surface casing vent flows must be
maintained on file and provided to the Commission on request.
A permit holder should perform annual surface casing vent flow
tests on all non-serious surface casing vent flow for a minimum
of five years. The permit holder may select appropriate yearly
testing measures, however, the Commission may order specific
test measures for surface casing vent flows of particular
concern. If there is no change in the flow rate or shut in
pressure after five years of testing, or if the vent dies out, no
further testing is expected. If a non-serious vent flow becomes
serious, the permit holder must notify the Commission as soon
as possible.
Recommended surface casing vent flow test procedures are as
follows:
5.1.3.1 Measuring Flowrate
Once a positive vent flow is detected, the flow rate and
stabilized shut in pressures must be recorded. To measure
venting gas volumes, a positive displacement gas meter, turbine
meter or an orifice well tester may be used. Equipment selection
should be based on previous observations indicating what flow
rate and pressure range can be expected. A positive
displacement meter will be necessary to measure low volumes
accurately. An orifice well tester, with proper orifice plate, may
provide satisfactory measurements if the 24 hour shut in
pressure is 200 kPa or greater and builds quickly.
Install and use the equipment according to manufacturers
instructions and
1) Do not exceed the pressure/volume range of the
equipment
2) Ensure that there are no leaks
5.1.3.2 Measuring Buildup Pressure
To determine the maximum shut-in surface casing pressure the
following method can be used.
Pressure Buildup Required Equipment:
Pressure gauge or single pen static pressure recorder with
24 hour chart or
Dead weight pressure gauge or
Electronic pressure recorder
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A pressure relief valve, calibrated to release the pressure if it


has built to its maximum allowable surface pressure, should be
installed on the surface casing vent while measuring the build
up pressure. If it is anticipated that the maximum allowable shut
in pressure will be exceeded, a suitable recording device must
be used in order to capture the rise and decline of pressure (i.e.
electronic recorder).
Pressure Buildup Testing Procedure:
1) Install pressure recorder and pressure relief valve.
2) Ensure that there are no gas leaks at fittings and welds.
3) If a chart is used, note the chart reading 24 hours later. If
pressure has not stabilized, it may be necessary to change
the chart in order to cover a longer time period in order to
achieve a maximum shut-in pressure.
4) Monitor the readings to determine when a stabilized
maximum pressure is obtained and record this value.

5.1.4 Surface Casing Vent Flow Repairs


5.1.4.1 Non Serious Repair
Remedial repair may be deferred until well abandonment for
non-serious surface casing vent flows.
In an effort to minimize the amount of venting from a nonserious surface casing vent flow, the permit holder may consider
the installation of a burst plate or pressure safety valve (PSV).
The permit holder must obtain an exemption to section 18(9)(a)
of the Drilling and Production Regulation to allow the installation
of a burst plate or pressure safety valve.
Non-serious surface casing vent flows must be repaired at the
time of well abandonment.
5.1.4.2 Serious Repair
The permit holder of a well determined to have a serious
surface casing vent flow should contact the Commission as
soon as possible to discuss repair or management
requirements.
5.1.4.3 Surface Casing Vent Flow Production

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If the permit holder wishes to explore the option of producing the
surface casing vent flow, an application must be made to the
Drilling and Production Department to obtain an exemption to
section 18(9)(a) of the Drilling and Production Regulation.
Requests will be considered if:
The source depth and formation of origin has been clearly
identified
The permit holder owns the mineral rights to produce the
source formation
The cemented portion of the surface casing or the next
casing string covers the deepest known usable
groundwater and
The flow has been analyzed and determined to be sweet (0
percent H2S)
The Commission may rescind the approval to produce from the
surface casing vent and may require the surface casing vent
flow to be repaired at any time if the Commission determines a
safety or environmental hazard exists.

5.2

Gas Migration
[Section 41, Drilling and Production Regulation]
5.2.1 Definitions
Gas Migration (GM) means a flow of gas that is detectable at
the surface outside of the outermost casing string (often referred
to as external migration or seepage).
Serious Gas Migration means gas migration that
1) Contains hydrogen sulphide
2) Creates a fire or public safety hazard or
3) May cause off-lease environmental damage (such as,
groundwater contamination).
A permit holder must report, via email to
OGCDrilling.Production@bcogc.ca, all occurrences of gas
migration to the Commission as soon as possible.
The permit holder is not required to test for gas migration unless
there is visible evidence that it is occurring. Upon initial
discovery of gas migration, a gas sample should be collected to
identify the source of the gas. Recommended gas migration
testing procedures are as follows:

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5.2.1.1 Gas Migration Testing
Once gas migration is visible, the Commission requires that
testing be carried out to identify the source of the gas. Testing
must be done in frost free months only and periods immediately
after a rainfall must be avoided. If less than full scale readings
are obtained, the soil horizon must be examined to ensure that
readings are not the result of contaminated solids due to spills
of diesel fuel, solvents, oil, etc. If contaminated soils are
suspected, the soil must be excavated and removed. Retesting
is then required. Instrumentation must be calibrated regularly
and checked daily when in use.
Select sample testing points as follows:
Two within 30 cm of wellbore on opposite sides
At two metre intervals outward from the wellbore every 90
(a cross with the wellbore at centre) to a distance of six
metres and
At any points within 75 metres of the wellbore where there
is apparent vegetation stress
Required Equipment:
Bar or auger (64 mm or less in diameter) capable of
penetrating a minimum of 50 cm
Calibrated monitor or other instrument capable of detecting
hydrocarbon at one percent lower explosive limit (LEL)
Equipment or material to seal the hole at surface while soil
gases are being evacuated from the soil through the
instrument
Test Procedure:
1) Perform instrument check (for example,calibration, voltage,
zero)
2) Insert auger or make a bar hole a minimum of 50 cm deep
3) Isolate the hole from atmospheric contaminations
4) Insert hose, wand, or other equipment a minimum of 30 cm
into hole, maintaining a seal at surface to prevent
atmospheric gas and soil gas mixing
5) Withdraw soil gas sample. The volume, rate, etc., will
depend on the instrumentation being used. Ensure that a
sufficient sample is removed to purge lines and
instrumentation
6) Record observations

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7) Purge instrument and lines

5.3

Casing Leaks and Failures


[Section 18, Drilling and Production Regulation]
A permit holder must notify the Commission of any casing leak
or casing failure as soon as possible. The leak or failure must
be repaired within a reasonable time frame, giving consideration
to the accessibility of the site and the seriousness of the leak or
failure.

5.4

Noise
[Section 40, Drilling and Production Regulation]
A permit holder must ensure that well operations do not cause
excessive noise. Permit holders should work with area residents
to minimize noise impacts when undertaking completions
activities near populated areas.
The B.C. Noise Control Guideline (OGC IL 09-09) contains
information regarding acceptable noise levels and noise
assessment techniques.

5.5

Flaring and Venting


Refer to the Flaring and Venting Reduction Guideline for
detailed guidance.

5.6

Fluid Storage
[Section 50, Drilling and Production Regulation]
Secondary containment of tanks associated with completions
operations is generally not required. For extended, unmanned
flowback operations that require a facility permit, secondary
containment in accordance with the National Fire Protection
Agencys Flammable and Combustible Liquids Code (NFPA 30)
is required.
Fracturing fluid returns must be stored in accordance with the
Commissions Information Letter on the storage of fluid returns
from hydraulic fracturing operations (OGC IL 09-07).

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6 Data Submission
General
All data must be submitted to the Commission.
For compete submission requirements, please refer to the Well
Data Submission Requirements Manual.
This section provides instructions on Completion, Workover and
Abandonment Reports.

6.1

Completion / Workover / Abandonment Reports


[Sections 26 and 36, Drilling and Production Regulation]
One pdf copy of the Completion / Workover / Abandonment
Report (CW Report) must be emailed to welldatamail@bcogc.ca
within 30 days of the end of main operations (do not include
flow/clean-up). Incomplete reports will not be accepted and will
be returned to sender.
Appendix A specifies which operations require a
Completion/Workover Report and which operations do not.
Refer to the Notice of Operations and Completion Workover
Report Reference Guide for more information.
6.1.1 Completion / Workover / Abandonment form Cover
Page
Check the appropriate box for type of report (Completion,
Workover, Abandonment, Other). The report must include: Well
Name, Well Permit #, Bottom hole location, 16 character Unique
Well Identifier (UWI), Start and Finish dates of the daily reports
included, Intervals worked (Open Hole interval, perforation
intervals or location of frac ports) and the geological formation
name. Incomplete reports will not be accepted and will be
returned.

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6.1.1.1 Reason for work


State the purpose of the operation (such as, initial completion;
to increase productivity; to shut-off water flow, re-entry,
recompletion, zonal abandonment, surface abandonment, etc.)
6.1.1.2 Required Attachments to the Completion /
Workover Report
Required attachments include:
Chronological Summary - either on this form if a short
summary, or on separate enclosed page, list the major
events in this completion report by date, such as
perforations or frac port openings, stimulation operations,
setting temporary or permanent plugs/zonal
abandonments, milling operations, type of production
string installed and flowing operations.
Detailed completion/workover daily reports.
Downhole schematic diagram.
6.1.1.3 Example Chronological Short Summary:
2010/11/10 Perf Bluesky 971.2973.4 mKB
2010/11/13 Frac: Pump 1.5 m3 15% HCL acid. Pump 10 m3
Fracsol, 10 tonnes of 20/40 mesh sand. Formation breakdown
@ 21,000 kPa
2010/11/16 Flowed gas 3.720 103m3/d @ 2200 kPa. Water
production 2.1 m3/hr.
2010/11/21 Bluesky uneconomic. Set bridge plug at 969 mKB
w/ 8 lineal m cement on top. Pressure tested BP.
6.1.1.4 Completion Type
Indicate what kind of completion was done (such as, Open Hole
well, Single if one zone capable of producing, Dual or Multi if 2
or more zones capable of producing separately, Commingled if
two or more formations producing together).
6.1.1.5 Completion Activity
Indicate all operations performed within this completion report.
6.1.1.6 Stimulation Type
State which stimulation type achieved breakdown or well flow.
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If Acid Stimulation, state the acid volume pumped in the
stimulation in cubic meters (m3) and the maximum pressure
used in the acid stimulation in kilopascals (kPa).
If Hydraulic Fracturing conducted, submit fracture data file
electronically via the eSubmission Portal. Please refer to
Hydraulic Fracture CSV How-To Guide.
6.1.1.7 Flow Summary (for each formation)
If applicable, indicate the hydrogen sulphide (H2S) percent, oil
rate, water rate, choke size or API gravity.
6.1.1.8 Flow Rate
Indicate the final gas flow rate in 103m3/day.
6.1.1.9 Flow Pressure
Indicate the final flow pressure in kPa.
6.1.1.10 Flow Date
Indicate the final flow date.
6.1.1.11 Radioactive Material
Indicate if radioactive material was used in the workover (such
as frac sand). If so, attach documentation explaining the method
of disposal or, if buried on site, attach sketch of location
showing burial location and indicate depth of burial and volume
of material.
6.1.1.12 Result of Work Done
State the outcome of the operation (such as, successful
completion of the Montney; well on production; productivity
increased; water flow successfully shut-off; well successfully
suspended) For the above example, the result would be,
Bluesky tested and suspended with BP.

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7 Compliance
OGAA
A person found by the Courts, to have contravened the Oil
and Gas Activities Act may be subject to a fine not
exceeding the amount specified in Section 86 of the act. A
person found by the Commission, to have contravened
OGAA may be liable to an administrative penalty not
exceeding the amount specified in the Administrative
Penalties Regulation.
Drilling and Production Regulation
A person who contravenes the Drilling and Production
Regulation (as specified in the Administrative Penalties
Regulation, Section 5) may be liable to an administrative
penalty ranging from $2,000 to $500,000.

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Appendix A: Completion/Workover Report Guidelines


A Notice of Operation including an uploaded program is required to be submitted
for initial completions, completions, workovers and abandonments. Examples are
shown below. A Completion / Workover Report is required to be submitted for
these operations.
Completion Operations
All cased or open hole operations using both service and drilling rigs
Perforating
Notching of tubing
Fracturing
Stimulation
Acidization (squeeze, fracturing operations)
Re-perforating an existing zone, tubing scale cleanout, hydrate removal
Milling, abrasion jetting (casing, tubing)
Bare foot completions
Testing, Monitoring and Logging
DFIT (diagnostic fracture injection test), or Mini-Frac test
o Injectivity tests
Logging for re-entry which includes removal of cement plugs
Remedial
Surface casing vent flow / gas migration - repair
Cement squeeze, cement plugs
o
o
o
o

Casing
patch or repair
installation of liner
removal or replacement

Suspension
Plugging or suspension of a zone
Installation of:
o
o
o
o
o

bridge plugs (any type)


cement retainers, cement plugs
tubing plugs
packers
wireline retrievable plug

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Wellhead

o installation of dual master valve and seals for purpose of suspension


Inhibiting wellbore for purpose of suspension

Abandonment
All downhole work performed during abandonment operations
Surface cut and cap of a well
Re-Entry
All completion re-entry work (Completion re-entry is the re-entry of any
abandoned well where no additional drilling is to occur).
For any workover performed in preparation for a drilling re-entry that is
finished prior to and is not to be reported as part of the drilling re-entry (ie:
drilling out of or setting of cement plugs, abandonment of hole, recovery or
setting of bridge plugs, logging, casing extensions, etc.)
Bottom Hole Equipment
Installation, removal or exchange for:
Artificial lifts (includes all forms of bottom hole pumping methods)

o downhole pumps
o plunger lift
o gas lift
o electrical submersible pumps (ESPs)
o bumper springs
Sub-surface safety valves - except for inspection and repair purposes

Change of:
Flapper valve for injection wells
Sliding sleeve - shifting for commingling of producing zones
Tubing
Depth change
Size change
Installation or removal - e.g.,velocity strings, endless tubing
A Notice of Operation is required to be submitted for the maintenance operations
listed below. A Completion / Workover Report is not required for these
operations:
Testing, Monitoring and Logging
Surface casing vent flow (SCVF) rate and buildup pressure
Packer isolation testing

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Pressure testing tubing or casing


Microseismic observation
Production logging
Swabbing
Gauge ring and junk basket runs

Suspension and Plugging


Inspection of suspension work
Bottom Hole Equipment
Artificial lift systems repair

o plunger lift
o gas lift
o pumpjack
o including all forms of pumping methods
Slickline work running or removing

o running recorders
o pressure gradient tests
Downhole choke installation or removal
Rod replacement or repair, polish rod
Packers - removal, repair and re-installation

Wellbore Integrity
Cleaning
Acidization (wash or pickling operation)
Scale
Coil tubing cleanout
Nitrogen / CO2
Blow downs
Well clean-up
Chemical injection for perforation wash
Methanol injection
Wax removal
Sulphur removal
Corrosion inhibitor
Swabbing of any type of tubing
Circulating for clean out of wellbore
Tubing
Fishing, chemical cutters
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Hole in tubing repair


Replacement or changing (same size)
Back pressure valves, installation or removal

Wellhead
Master valves and seals installation, changes, testing or repair
Primary and secondary seal testing
Surface casing vent assembly installation or repair
Burst plate or vent plate installation or repair
Well head valves maintenance (greasing)
For more information on operations not listed in this table, please contact:
Drilling and Production, Engineering Division, OGCDrilling.Production@bcogc.ca
or
Trudy Clark, (250)794-5258.

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Appendix B: Well Suspension/Inspection Form


Instructions
A Well Suspension/Inspection Form must be submitted to the Commissions
Drilling and Production Department within 30 days of suspension of a well and
should be submitted by email to OGCDrilling.Production@bcogc.ca. Records of
suspensions and inspections must be maintained on file until the time of well
abandonment and must be provided to the Commission on request. Inspection
results may be recorded by filling out the applicable sections of the OGCs Well
Suspension/Inspection Form.
Please note: Incomplete reports will not be accepted.
General
Required for all suspensions and inspections.
Well Name: Enter the full well name (for example, OIL CORP TOMMY B-092I/092-G-09)
WA#: Enter the well authorization number (for example, 12345)
Permit Holder: Enter the name of the licensed operator (for example, Oil
Corporation Ltd.)
Date: Enter the date that suspension operations or the inspection were
completed
Site Access: Enter the method of site access (for example, All Weather Road,
Dry Summer Road, Frozen Winter Road, Air, ATV Access, Walk-In Access Only,
Etc.)

Well Classification
Required at time of suspension. Not required for suspended well inspections.
Risk: Select the well classification: High, Medium or Low risk, as applicable,
defined in Section 3.3.
Well Type: Select the well type: 1-6, as applicable, defined in Section 3.3.
Suspension Option: Select the suspension option: A, B or C used for
suspension, defined in Section 3.3.

Formations Open To The Wellbore


Required at time of suspension. Not required for suspended well inspections.
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Include the formation name, associated H2S (%) and CO2 (%) and formation
interval (top and bottom locations in mKB). For formations with multiple
perforations, enter the upper and lower interval of the combined perforations, not
each individual interval.
Example:
FORMATION

H2S (%)

CO2 (%)

INTERVAL
(mKB)

Baldonnel

0.0

2.14

1238.7 -1249.7

Pressure Monitoring and Pressure Tests


Required at time of suspension and when pressure monitoring/testing is required.
Not required for visual inspections.
The correct Shut-In Tubing Pressure (SITP) and Shut-In Casing Pressure (SICP)
must be recorded in the appropriate category under this section. If there is no
tubing or casing installed in the well, this should be stated clearly in the
Comments section. All pressure test results should be recorded as Pass, Fail or
N/A. A wellhead pressure test is required for all well types. If a wellhead pressure
test is reported as Fail or N/A, an explanation, in the form of supporting
documentation, will be required with the report submission. Casing and tubing
pressure tests are required for applicable wells, as defined in Section 3.3. All
pressures should be recorded in kPa, if applicable.

Visual Inspection
Required for all suspensions and inspections.
Select yes or no, as applicable:
1. No indicates that there is no evidence of leaks from the wellhead,
including any attached fittings and valves and no evidence of significant
corrosion.
2. Yes indicates the wellhead meets the requirements for Wellheads and
Wellhead Maintenance in Table 3.1.
3. Yes indicates the surface casing vent is properly installed and the
surface casing vent is open and unobstructed. Indicate in the comments
section if the surface casing vent is obstructed for the purpose of
managing a vent flow (i.e., a burst plate is installed).
4. No indicates there is no evidence of a surface casing vent flow.
5. Yes indicates a barricade has been installed around the wellhead.
Requirements for a barricade are site-specific.

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6. Yes indicates a lease sign, meeting the requirements of Section 15(1) of
the Drilling and Production Regulation, has been installed.
7. Yes indicates noxious weeds are not present on the lease, nor the lease
access road.
8. Yes indicates brush piles are not present on the lease or the lease
access road.
9. No indicates there are no open sumps on the lease.

General
Required for all suspensions and inspections.
Comments: Provide any useful comments, for example, additional suspension
detail.
Name, Phone, Email, Cell: Provide the contact information of the person
responsible for the report.

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