Current Regulations Affecting Well and Pipeline Abandonment in Alberta
also involve the removal of a pipeline. Directive 056 states that a partial pipeline removal does not involve the taking out of any crossings, whereas a complete removal also includes crossings. For a partial pipeline removal, a licence amendment application must be submitted to the Board, and removal work can begin only once approval is granted. Landowner notification is required. A complete pipeline removal is considered non-routine, so there are additional notification requirements to occupants within 500m and urban authorities within 1,500m.
Re-starting the Use of a Pipeline
Applications to re-start an abandoned pipeline are considered non-routine by the Board and will be subjected to added scrutiny and notification requirements within 500m and 1,500m for urban authorities. With respect to re-starting a discontinued pipeline, an applicant will have to obtain a licence from the Board before the commencement of restarting activities. n all cases, an applicant seeking the re-start of a pipeline will have to show that cathodic protection was maintained, there is external/internal coating integrity and any sour service requirements are met.26
The Pipeline Regulation directs that applicants follow the Board’s rules as outlined in Directive 056 to restart a discontinued or abandoned pipeline.25
Liability – A Common Issue to Both Wells and Pipelines The licensee and working interest participant in both wells and pipelines are responsible for the costs associated with abandonment and reclamation. In some cases, a licensee or working interest participant defaults on its obligations to abandon and reclaim facilities
and the costs associated with this work. To deal with these circumstances, the Alberta Oil and Gas Orphan Abandonment and Reclamation Association (OWA),27
a non-profit society, administers an
Increased well and pipeline activity guarantees that abandonment, suspension and discontinuance operations will also continue to expand.
orphan fund, which is funded by industry through a levy. To minimise the risk to the orphan fund, the Board also administers a licence liability rating (LLR) programme. The LLR programme assesses a licensee’s ability to pay for future abandonment and reclamation of its facilities, and compares a licensee’s deemed assets with its liabilities on a monthly basis. Details related to the LLR programme can be found in Board Directive 006: Licensee Liability Rating Program and Licence Transfer Process.28
Directive 006 also speaks to the transfer of wells and pipelines, and in particular the transfer of abandoned facilities.
Conclusion
The increasing number of wells that have been inactive for longer than one year will only make suspension and abandonment a more pressing issue for licence holders. In 2004, the ERCB estimated that there were
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