Current Regulations Affecting Well and Pipeline Abandonment in Alberta
For wells that fall into the low-risk category, Directive 013 mandates no downhole requirements since these wells are not considered to pose a significant risk while suspended. With respect to medium-risk wells, there are three options with respect to the downhole requirements: first, a packer and a tubing plug can be used; second, a bridge plug can be relied on; and finally, if the well in question is a cavern service well, Directive 013 has specialised options. With regard to high-risk wells, either a packer and a tubing plug or a bridge plug capped with 8m of lineal cement must be used. The licensee must report the uspension results to the Board within 30 days after completion of suspension operations.
To reactivate a suspended well, the well must be inspected and serviced, and the wellhead must be pressure-tested. The control systems and lease facilities of the well must also be serviced and inspected. A well attains active status only after it has operated for a minimum of 360 hours per month for three consecutive months.
Regulatory Overview of Pipeline Discontinuance and Abandonment
The Pipeline Act and its regulation is the governing legislation for all pipelines in Alberta, with a few exceptions. The Pipeline Act does not apply to pipelines situated wholly within the property of a refinery or other plant, a pipeline for which there is in force a certificate or order from the NEB, a pipeline transmitting gas or oil for use as fuel wholly within the property of a consumer or a boiler, pressure vessel or pressure piping system within the meaning of the definitions under the Safety Codes Act. The Pipeline Act has a regulation, the Pipeline Regulation, Part 10 of which speaks to the expectations of what is to occur during discontinuance or abandonment. The Pipeline Act defines pipeline abandonment as “the permanent deactivation of a pipeline or part of a pipeline in the manner prescribed by the regulations, whether or not the pipeline or part of the pipeline is removed.”16
temporary deactivation of a pipeline or part of a pipeline.”17
Section 23 states that a licensee shall discontinue or abandon a pipeline when directed by the Board or required by the regulations. Section 23 goes on to say that the Board may order that a pipeline be discontinued or abandoned where it considers that it is necessary to
If abandonment of a pipeline is pursued, the licensee must meet requirements that are specified for pipeline discontinuance, as well as permanently plugging or capping the pipeline and removing cathodic protection from the pipeline.
do so to protect the public or the environment. Finally, Section 23 also confirms that discontinuation or abandonment of a pipeline must be carried out in accordance with the regulations.18
If a pipeline has not had active flowing service within the previous 12 months, the Pipeline 56
Regulation requires that the licensee discontinue, abandon or return the pipeline to active flowing service. A licensee is further required to notify the Board in accordance with the requirements of Directive 056 within 90 days of the completion of any discontinuance or abandonment operations.19
It is also important to be aware that
notification to the Board of discontinuance or abandonment operations does not relieve the licensee from further discontinuance or abandonment operations with respect to the same pipeline that may become necessary, as determined by the Board.20
The Pipeline Regulation also specifies that if a pipeline, or part of a pipeline, cannot be physically isolated or disconnected from an operating facility or another pipeline through discontinuance or abandonment
The licensee and working interest participant in both wells and pipelines are responsible for the costs associated with
abandonment and reclamation.
procedures, the pipeline cannot be discontinued or abandoned but must be maintained as an operating pipeline.21
specifics as to the operations that must be performed as part of discontinuance procedures, including purging the pipeline and protecting it with both internal and external control measures.22
The Pipeline Regulation provides The Pipeline The Act defines discontinuation as, “the
Regulation sets out the circumstances in which a licensee must pursue abandonment of a pipeline. These circumstances include where the licensee has ceased to be resident in Alberta and has not appointed a registered agent, where the licensee’s corporation is struck, where other infrastructure associated with the pipeline such as a well or facility has been abandoned, where the pipeline was not discontinued in accordance with requirements and where the Board orders abandonment.23
If abandonment of a pipeline is pursued, the licensee must meet requirements that are specified for pipeline discontinuance, as well as permanently plugging or capping the pipeline and removing cathodic protection from the pipeline.24
pipeline or part of the pipeline as part of abandonment, an application must be submitted to the Board under Directive 056.
Board Directives with Respect to Pipeline Discontinuance and Abandonment
Board directives form only a small part of the regulatory regime for pipelines, unlike for wells. Directive 056: Energy Development Applications and Schedules sets out the requirements and procedures for the construction and operation of any energy development in the Province of Alberta. Directive 056 defines discontinuation as the temporary deactivation of a pipeline or part of a pipeline. If a pipeline is being abandoned, Directive 056 requires that the licence amendment application be filed 90 days after completion of work so as to advise the Board of the abandonment. The licensee must also notify potentially directly and adversely affected parties along the pipeline right of way and those affected by setbacks before any abandonment procedures. A part of abandonment operations may
EXPLORATION & PRODUCTION – VOLUME 9 ISSUE 2
If the licensee intends to remove the
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