By mid-2013 Alberta is expected to enter the realm of having a Single Regulator for Oil and Gas. That Regulator will also capture Geophysical applications whereas in today`s world the Energy Resources Conservation Board (ERCB) handles all Oil and Gas applications except Geophysical. Geophysical applications fall under Environment and Sustainable Resource Development (ESRD).
There are some outstanding policy issues that we hope to have cleared up before the transfer is complete. These include Seismic on Lakes, Seismic in Riparian areas and appropriate structures for regulatory (or not) oversight.
We are currently challenged with some microseismic jobs being conducted today that require geophysical permits which are however being sold as not requiring such permits. Some of the questions that need to be asked:
- Definition –What is “Microseismic” and what is involved?
- Methodology to meet the different requirements for all the different types of microseismic. (i.e. Near and far offsets, types of energy required, surface or downhole receivers, if downhole are they new holes to be drilled with a plan for final cleanup and abandonment?).
- Time – too many of these projects show up with too tight of timelines to actually get an approval. We see many cases with less than a five day window to get the approval.
- Details – More questions about what is being done.
As a general rule of thumb a geophysical application (and subsequent permit) is required whenever any of the following occur:
- Any shot drilling occurs (whether on or off the lease site);
- Use of a surface source (such as a vibe) located off of the lease site or road to the site that the company has under a disposition;
- Use of receivers located off of the lease site or road to the site that the company has under a disposition;
- These also apply to initial test shots being used for set up and/or calibration of equipment.
Applications for a Vertical Seismic Profile (VSP) or Downhole Seismic Approval
Under the current legislation, any person conducting a vertical seismic profile must:
- Hold a valid exploration license issued under the Exploration Regulation, and
- Apply for an exploration approval under Section 23 of the Exploration Regulation
The only exception to the requirement specified in current legislation is when the activity associated with the vertical seismic profile is contained entirely within the well lease as issued by Energy Resources Conservation Board, or Surface Mineral Lease issued under the authority of the Public Lands Act. Only non-explosive surface or down well bore energy sources are permitted for an exception. If this is the case, then the activity is deemed to be associated with the well lease or Surface Mineral Lease and an exploration approval is not required.
Activities involving drilling of holes and/or use of explosive energy sources will still require an Approval. All other Parts of the Exploration Regulation 284/2006 still apply.
If any shot holes are drilled Exploration Directives such as those dealing with Shot Holes and Depths, Test Holes, Temporary and Permanent Abandonment of Shot Holes and a number of other more general Exploration Directives must be followed. The general Directives are required to be followed when any of the operation is located off of the lease. These documents can be found on the ESRD’s website or through links off the CAGC website (for Members).
A common issue is that sometimes companies doing MicroSeismic are dealing only with production and completion and not going through the geophysical groups so they are unaware of the actual requirements. In any case if the Oil Company has a Geophysical Operations Department I would encourage those within the company to seek the expertise of your own people to ensure you are meeting the requirements under the legislation. As well a number of MicroSeismic companies are CAGC members and others should be encouraged to consider membership if their operations brush into the requirement for geophysical applications and the subsequent permit for operation of the program.
Typically Industry moves faster than Government regulations. For example there exists a committee populated by the CAGC, CAPP Geo Operation types and the Alberta Government for definition of Modern (New) Technologies and how they should be (or not) regulated. These are often complex issues with things such as surface disturbance, timing, lifespan, repetitive, subsurface or surface, airborne, passive, footprint / intensity and program size needing to be considered. Check with your own Geophysical Department if this is relevant to your work. It is likely they sit on the committee.
From the Thursday Files
You don’t know what you don’t know.
– Unattributed (or attributed to many…)