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So just-what-rule

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Mike Beck
Mike Beck

The regulatory landscape for oil and gas operations is changing. Regulations and directives issued by provincial bodies like the ERCB must now be followed, as they carry the force of law. Industry recommended practices (IRPs) on technical operating standards are still developed through the Drilling and Completions Committee, but regulators now give them greater consideration. Upcoming focus will likely remain on fracturing operations and developing standards to prevent inter-wellbore communication issues. Operators must stay informed of changing rules and ensure compliance, as ignorance will not excuse deviations from regulatory requirements.

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So, Just What Rule Should Iin 2012 Regulatory Changes Be Following? 2012 ICoTA Roundtable
The Regulatory Landscape is Changing The old way Federal/Provincial regulations: must be followed OHS rules: must be followed, in case of no rules must have some justification for what you are doing. EUB/ERCB: Guides on how to do things. ERCB only has jurisdiction over the leaseholder. IRPs: Best practices, in 1997 roughly 6 IRPs existed
The Regulatory Landscape is Changing Our lives today Federal/Provincial regulations: must be followed OHS rules: must be followed, in case of no rules must have some justification for what you are doing. IRP¨s/Guides/etc are considered ｀the right way¨ in the absence of anything else. Note ｀Accepted Practice¨ is not a defence, ｀Acceptable Practice¨ is. EUB/ERCB: Directives on what must be done. ERCB only has jurisdiction over the leaseholder but Directive is law. IRPs: Best practices, in 2011 approximately 24 IRPs exist or in draft form.
Who Issued IRP¨s? ? Drilling and Completions Committee (DACC)
Who Now Issues IRP¨s? ? Drilling and Completions Committee (DACC) Voting members ERCB Traditionally the ERCB and CAPP rotated the position of Chairman. Now Associate members each participating member group is eligible. This year Patrick Delaney of PSAC will be Chairman. ICoTA Manitoba Energy & Mines Sask Energy & Resources
What Do DACC do/What About Enform? DACC is responsible for the development of recommended technical operating practices for the upstream oil & gas industry in the areas of drilling, completions and servicing of wells. The primary focus for DACC will be to develop technical recommended practices, where the objectives include cost efficiencies, technical optimization, productivity, safety, and environmental performance. In developing IRPs, DACC will give priority to: Development of new IRPs. Review and revision of outdated IRPs at a maximum time span of 5 years, particularly where new technology requires new operating procedures. Providing general support to foster development of non-IRP industry operating practices that have current application to a limited number of stakeholders. The role of DACC is separate and distinct from that of Enform (who focus on worker safety).
Who Decides to Sanction IRPs? Governance decisions strive for consensus, but can proceed with a majority vote (e.g. Terms of Reference, Memorandum of Understanding and Funding). All other decisions (IRP and related decisions) shall be made by consensus. - Each member organization is limited to one vote. - All regular members must vote. - IRP decisions require both consensus at DACC and sanction by the associations (as outlined in DACC membership). - Associate members do not have a vote, but are encouraged to provide input on DACC decisions. - If consensus cannot be achieved, as outlined above, the matter may be arbitrated by an independent 3rd party. - If arbitration is not successful then the outcome is that there is no DACC decision - No decision at DACC does not preclude an individual association from proceeding to address an issue at their discretion (note that individual associations always have this prerogative). - The consensus decision process is not complete until the member associations have reviewed and sanctioned an IRP.
IRP¨s for 2012/2013 ? No new IRPs planned to date ? Each IRP has a 5 year review cycle ? DACC can choose to leave IRP as is if there is no indication of any issues with the current IRP ? Any IRP can be reconsidered should one of the DACC member organizations deem it necessary and get committee approval to do so ? Up for review 2013 ? ? ? IRP7: Standards for Wellsite Supervision of Drilling, Completion and Workovers IRP8: Pumping of Flammable Fluids IRP13: Slickline Operations
Any Changes to IRP21? ERCB always envisaged making Section 2: Recommended Coiled Tubing BOP Stack and Accumulator Specifications law by including extracts from it in a new Directive 37 ? Current status: Multi-stage horizontal fracturing a very high visibility issue, ERCB resources are focussed on fracturing Directive The changes to Directive 37 will happen at some point http://www.ercb.ca/regulations-and-directives/directives/directive037
Oil and Gas Conservation Act Alberta Regulation 151/1971 With amendments up to and including Alberta Regulation 121/2012 Note: There is now no doubt that Directives 36 and 37 are law.
IRP24 Fracture Simulation The introduction of multi-stage fracturing to the oil and gas industry increased hydraulic fracturing activity throughout the Western Canadian Sedimentary Basin (WCSB). Horizontal wells now have lateral sections that can extend up to and beyond two kilometers often encompassing multiple offset wells in proximity of the fracture stimulation operation. The result is increased inter-wellbore communication.
IRP24 Fracture Simulation IRP 24 is an interim Industry Recommended Practice (IRP) for the WCSB that industry C along with regulators C collaboratively developed to address inter-wellbore communication concerns. It is a risk-based IRP structured around a hazard management process and a Hazard Register that logs industry-known hazard scenarios related to inter-wellbore communication from hydraulic fracturing. The IRP document and supporting Hazard Register offers a process and mechanism for Operators to identify and document suitable controls for Hazard Register scenarios at the planning stages to be carried through at execution.
IRP24 Fracture Simulation IRP 24 follows a hazard management process to determine: ? ? ? ? ? ? ? ? ? A Fracture Planning Zone (FPZ); Identified Offset Wells (IOW); Special Consideration wells (SCs); IOW well integrity and risk assessment; IOW well control plan; Pre-planning notification to affected Operators; IOW wellsite procedures; Program execution; and Reporting to jurisdictional regulatory bodies.
IRP24 Fracture Simulation The section on inter-wellbore communication should be released soon. Due to the high profile nature of this topic the consultation period end November 15, 2012. http://enform.ca/safety_resources/publications/PublicationDetails.aspx?a=29&type=irp If there are no comments then it is assumed that everything is good to go. It may include having well control devices on adjacent wells. Could test equipment be required on some wells too? There have been inter-wellbore communication issues (>20)
What Changes Are Coming? Much focus on crane use in BC Need operator at controls when holding a suspended load Safety concerns C putting people in harms way Competency of operator Boom Truck Operator certification. The Alberta Advanced Education Wellhead Boom Truck Operator certification is also accepted by the Saskatchewan Apprenticeship and Trade Certification Commission for wellhead operations in Saskatchewan. Enform's Wellhead Boom Truck Operator training certificate is endorsed by WorkSafeBC for wellhead operations in British Columbia; however, operators must register with the British Columbia Association of Crane Safety (BCACS) before they can work in British Columbia. Boom truck vs crane >45 tons considered a mobile crane. For information on Registered Apprentices : http://www.tradesecrets.gov.ab.ca/index.html?page=working_in_alberta/working_in_trade.asp
What Changes Are Coming? All IRPs were reviewed against a specific acceptance criteria regarding what should constitute an IRP. After review these IRPs were branded Enform IRPs but will be converted to Guidelines: - Volume #11 - Dangerous Tree Control - Volume #12 - Hand Signals for Directing Vehicles - Volume #17 - Ground Disturbance and Damage Prevention - Volume #18 - Fire and Explosion Hazard Management - Volume #23 - Lease Lighting Standards Lunch and Learn - Enform CALGARY - Tuesday, Oct 30, 2012, 2:00 - 1:30 pm Breakfast session - Petroleum Club CALGARY - Friday, Nov 2, 2012, 7:30 - 9:00 am Lunch and Learn - Enform, NISKU - Tuesday, Nov 13, 2012, 12:00 - 1:30 pm Go to Enform Website: http://www.enform.ca/safety_resources/publications/Default.aspx?type=guidelines
Summary ? Likely that all regulatory focus will be on Fracturing in the short term ? ERCB Directives 36 and 37 are the regulations that need to be met in Alberta ? Be familiar with Directive 37 ? If you deviate from a requirement C have a written justification before you do it
Summary ? The regulatory landscape seems to be changing, we all need to pay attention to ensure valid and timely input ? Provincial OHS groups not ｀approving¨ IRPs anymore ? Remember regulation is just like marriage C ignorance is not an excuse!
Questions? Wow, I was pretty sure we were still in Alberta!

More Related Content

So just-what-rule

  • 1. So, Just What Rule Should Iin 2012 Regulatory Changes Be Following? 2012 ICoTA Roundtable
  • 2. The Regulatory Landscape is Changing The old way Federal/Provincial regulations: must be followed OHS rules: must be followed, in case of no rules must have some justification for what you are doing. EUB/ERCB: Guides on how to do things. ERCB only has jurisdiction over the leaseholder. IRPs: Best practices, in 1997 roughly 6 IRPs existed
  • 3. The Regulatory Landscape is Changing Our lives today Federal/Provincial regulations: must be followed OHS rules: must be followed, in case of no rules must have some justification for what you are doing. IRP¨s/Guides/etc are considered ｀the right way¨ in the absence of anything else. Note ｀Accepted Practice¨ is not a defence, ｀Acceptable Practice¨ is. EUB/ERCB: Directives on what must be done. ERCB only has jurisdiction over the leaseholder but Directive is law. IRPs: Best practices, in 2011 approximately 24 IRPs exist or in draft form.
  • 4. Who Issued IRP¨s? ? Drilling and Completions Committee (DACC)
  • 5. Who Now Issues IRP¨s? ? Drilling and Completions Committee (DACC) Voting members ERCB Traditionally the ERCB and CAPP rotated the position of Chairman. Now Associate members each participating member group is eligible. This year Patrick Delaney of PSAC will be Chairman. ICoTA Manitoba Energy & Mines Sask Energy & Resources
  • 6. What Do DACC do/What About Enform? DACC is responsible for the development of recommended technical operating practices for the upstream oil & gas industry in the areas of drilling, completions and servicing of wells. The primary focus for DACC will be to develop technical recommended practices, where the objectives include cost efficiencies, technical optimization, productivity, safety, and environmental performance. In developing IRPs, DACC will give priority to: Development of new IRPs. Review and revision of outdated IRPs at a maximum time span of 5 years, particularly where new technology requires new operating procedures. Providing general support to foster development of non-IRP industry operating practices that have current application to a limited number of stakeholders. The role of DACC is separate and distinct from that of Enform (who focus on worker safety).
  • 7. Who Decides to Sanction IRPs? Governance decisions strive for consensus, but can proceed with a majority vote (e.g. Terms of Reference, Memorandum of Understanding and Funding). All other decisions (IRP and related decisions) shall be made by consensus. - Each member organization is limited to one vote. - All regular members must vote. - IRP decisions require both consensus at DACC and sanction by the associations (as outlined in DACC membership). - Associate members do not have a vote, but are encouraged to provide input on DACC decisions. - If consensus cannot be achieved, as outlined above, the matter may be arbitrated by an independent 3rd party. - If arbitration is not successful then the outcome is that there is no DACC decision - No decision at DACC does not preclude an individual association from proceeding to address an issue at their discretion (note that individual associations always have this prerogative). - The consensus decision process is not complete until the member associations have reviewed and sanctioned an IRP.
  • 8. IRP¨s for 2012/2013 ? No new IRPs planned to date ? Each IRP has a 5 year review cycle ? DACC can choose to leave IRP as is if there is no indication of any issues with the current IRP ? Any IRP can be reconsidered should one of the DACC member organizations deem it necessary and get committee approval to do so ? Up for review 2013 ? ? ? IRP7: Standards for Wellsite Supervision of Drilling, Completion and Workovers IRP8: Pumping of Flammable Fluids IRP13: Slickline Operations
  • 9. Any Changes to IRP21? ERCB always envisaged making Section 2: Recommended Coiled Tubing BOP Stack and Accumulator Specifications law by including extracts from it in a new Directive 37 ? Current status: Multi-stage horizontal fracturing a very high visibility issue, ERCB resources are focussed on fracturing Directive The changes to Directive 37 will happen at some point http://www.ercb.ca/regulations-and-directives/directives/directive037
  • 10. Oil and Gas Conservation Act Alberta Regulation 151/1971 With amendments up to and including Alberta Regulation 121/2012 Note: There is now no doubt that Directives 36 and 37 are law.
  • 11. IRP24 Fracture Simulation The introduction of multi-stage fracturing to the oil and gas industry increased hydraulic fracturing activity throughout the Western Canadian Sedimentary Basin (WCSB). Horizontal wells now have lateral sections that can extend up to and beyond two kilometers often encompassing multiple offset wells in proximity of the fracture stimulation operation. The result is increased inter-wellbore communication.
  • 12. IRP24 Fracture Simulation IRP 24 is an interim Industry Recommended Practice (IRP) for the WCSB that industry C along with regulators C collaboratively developed to address inter-wellbore communication concerns. It is a risk-based IRP structured around a hazard management process and a Hazard Register that logs industry-known hazard scenarios related to inter-wellbore communication from hydraulic fracturing. The IRP document and supporting Hazard Register offers a process and mechanism for Operators to identify and document suitable controls for Hazard Register scenarios at the planning stages to be carried through at execution.
  • 13. IRP24 Fracture Simulation IRP 24 follows a hazard management process to determine: ? ? ? ? ? ? ? ? ? A Fracture Planning Zone (FPZ); Identified Offset Wells (IOW); Special Consideration wells (SCs); IOW well integrity and risk assessment; IOW well control plan; Pre-planning notification to affected Operators; IOW wellsite procedures; Program execution; and Reporting to jurisdictional regulatory bodies.
  • 14. IRP24 Fracture Simulation The section on inter-wellbore communication should be released soon. Due to the high profile nature of this topic the consultation period end November 15, 2012. http://enform.ca/safety_resources/publications/PublicationDetails.aspx?a=29&type=irp If there are no comments then it is assumed that everything is good to go. It may include having well control devices on adjacent wells. Could test equipment be required on some wells too? There have been inter-wellbore communication issues (>20)
  • 15. What Changes Are Coming? Much focus on crane use in BC Need operator at controls when holding a suspended load Safety concerns C putting people in harms way Competency of operator Boom Truck Operator certification. The Alberta Advanced Education Wellhead Boom Truck Operator certification is also accepted by the Saskatchewan Apprenticeship and Trade Certification Commission for wellhead operations in Saskatchewan. Enform's Wellhead Boom Truck Operator training certificate is endorsed by WorkSafeBC for wellhead operations in British Columbia; however, operators must register with the British Columbia Association of Crane Safety (BCACS) before they can work in British Columbia. Boom truck vs crane >45 tons considered a mobile crane. For information on Registered Apprentices : http://www.tradesecrets.gov.ab.ca/index.html?page=working_in_alberta/working_in_trade.asp
  • 16. What Changes Are Coming? All IRPs were reviewed against a specific acceptance criteria regarding what should constitute an IRP. After review these IRPs were branded Enform IRPs but will be converted to Guidelines: - Volume #11 - Dangerous Tree Control - Volume #12 - Hand Signals for Directing Vehicles - Volume #17 - Ground Disturbance and Damage Prevention - Volume #18 - Fire and Explosion Hazard Management - Volume #23 - Lease Lighting Standards Lunch and Learn - Enform CALGARY - Tuesday, Oct 30, 2012, 2:00 - 1:30 pm Breakfast session - Petroleum Club CALGARY - Friday, Nov 2, 2012, 7:30 - 9:00 am Lunch and Learn - Enform, NISKU - Tuesday, Nov 13, 2012, 12:00 - 1:30 pm Go to Enform Website: http://www.enform.ca/safety_resources/publications/Default.aspx?type=guidelines
  • 17. Summary ? Likely that all regulatory focus will be on Fracturing in the short term ? ERCB Directives 36 and 37 are the regulations that need to be met in Alberta ? Be familiar with Directive 37 ? If you deviate from a requirement C have a written justification before you do it
  • 18. Summary ? The regulatory landscape seems to be changing, we all need to pay attention to ensure valid and timely input ? Provincial OHS groups not ｀approving¨ IRPs anymore ? Remember regulation is just like marriage C ignorance is not an excuse!
  • 19. Questions? Wow, I was pretty sure we were still in Alberta!