The AER will accept the feedback on the proposed changes until September 16, 2024.
The proposed changes are for the “Unit 4 Disposal / Storage” for all types of disposal activities (Class I-IV disposal, gas storage and sequestration schemes).
Below is the summary of the proposed changes:
1. Notification requirements in tables 1 and 3 have been expanded as follows:
CO2 Sequestration:
All Disposal Applications (Class I, II, III, IV, Acid Gas):
- Holders of Crown agreements or authorizations to sequester CO2
- Geothermal Lease Holders
2. The two-step application process now applies to all enhanced recovery, disposal,
gas storage, and sequestration schemes.
3. The following updates have been made to 4.1.5 Additional Requirements for
Class III Disposal:
- Include a site-specific risk assessment that will allow for risk management throughout the life of the scheme. The assessment should include potential hazards including geological containment, groundwater protection, offset wellbores, and induced seismicity. This should be carried out in accordance with CSA Z741-12 or its successor, or equivalent standard (e.g. ISO 27914-2017(E), EU Directive 2009/31/EC).
- Include reservoir models and results from simulations predicting the extent of the disposal fluid plume.
- If the risk assessment is medium to high, or if the projected fluid plume extent at the end of disposal project exceeds 1.6 km around the disposal interval, include a monitoring program with the baseline conditions.
- Include monitoring program if there is a subsurface risk to the geological containment of the disposal formation.
- Include a groundwater monitoring program if there is a risk to the groundwater.
- Include a surface casing vent flow (SCVF / gas migration) plan that satisfies Directive 87 requirements for wellbore locations within the area of influence of the acid gas plume.
- More in-depth offsetting wells review with wellbore risk assessment (Directive 20 level A abandonment standards).
- Requirements for Annual Progress Reports.
4. The following updates have been made to 4.1.6 Additional Application
Requirements for CO2 Sequestration:
- If the predicted fluid plume at the end of the project life exceeds 2.5 km around the sequestration well or if the geological containment risk assessment is medium to high, the applicant must execute and maintain a dynamic simulation model.
- Additional reporting: monthly reports to the AER via Petrinex on the density of the injection fluid stream (see 4.1.7).
5. The following has been added to the Appendix P “MMV Principles and
Objectives for CO2 Sequestration Projects”:
- If the geological containment risk assessment was medium to high and the reservoir is depleted, develop models and include simulation results tracking the fluid and pressure plumes.
- For the particular area of concern include assessment of wells in the projected pressure plume area that may present fluid crossflow risk.
6. Requirements around induced seismicity for all fluid disposal activities have been
added in section 4.1.8 Induced Seismicity Potentially Related to Disposal
Wells:
- If the AER determines that the disposal well is to be “seismogenic”, the following needs to be submitted through D065 application: a seismic risk assessment and monitoring, mitigation and response (MMR) plan.
- All applications for new fluid disposal wells and applications to amend the operating conditions of an existing fluid disposal well must include an induced seismic hazard assessment. A seismic risk assessment and an MMR plan are also required if the seismic hazard assessment shows that the area is prone to induced seismic events.
- The induced seismic hazard assessment must be conducted within 10 km radius around the disposal well. At a minimum, the seismic hazard assessment must use public earthquake catalogues (e.g. Alberta Geological Survey Earthquake Dashboard, Earthquakes Canada). The identification and assessment of an induced seismic hazard is a continuous process that the disposal scheme approval holders are expected to manage for the life of the disposal operation.
- If any infrastructure falls within a 10 km radius of the disposal well, the applicant or the scheme approval holder must engage the owners of the infrastructure and affected landowners when developing the MMR plan.
- The MMR plan must be authenticated by a qualified professional (e.g. APEGA member).
- If the MMR plan is required, the disposal approval holder must employ a real-time seismic monitoring array within the operating area, that contains minimum of: a seismometer network and accelerometer within 10 km radius from the disposal well.
- Seismic monitoring data acquired from any seismometer network must be submitted to the AER and the Incorporated Research Institution for Seismology.
Please contact us if you would like to discuss these changes with respect to your operations or would like us to assist you with the application process.