|Authors:||Duncan Kenyon, Nikki Way, Andrew Read, Barend Dronkers, Benjamin Israel, Binnu Jeyakumar, Nina Lothian|
|Publish Date:||October 2016|
|PDF Download:||[Landowners' Guide] [Landowners' Primer]|
|Pipelines and Other Infrastructure|
Oil and Gas Operational Impacts,
Conservation and Reclamation
|Abandonment and Reclamation|
|Compensation, Rights, and Hearings|
Water is required for all oil and gas operations. Water is used in drilling muds, and is also commonly injected into oil or gas wells to enhance production through water-flood or hydraulic fracture operations. Any operation that plans on using water must receive approval from the AER for their proposed source.
Two separate issues need to be considered with respect to water wells: the effect that water wells drilled by an oil and gas company can have on groundwater, and the impacts that may be caused by oil and gas wells.
Historically, companies have drilled water wells to get water for drilling muds, but in some areas water is also used for “waterflood” operations, where it is injected into an older reservoir to enhance oil recovery. Hydraulic fracturing water use for extracting oil and gas has also exponentially grown (see About Hydraulic Fracturing for more on hydraulic fracturing). While a properly constructed oil and gas water well should not allow pollutants to reach groundwater, these wells may draw from aquifers needed to supply water for domestic and agricultural operations.
Water wells can only be drilled by someone who has a current approval from Alberta Environment and Parks to drill water wells; they must follow the construction standards set out in the Water Regulations under the Water Act. A company must apply for and receive a well licence from the AER only if a water well is drilled deeper than 150 metres. Before a company withdraws water from a water well for drilling operations they must apply for a temporary diversion licence. Companies must obtain a term licence under the Water Act prior to any large-scale or long-term diversions of non- saline groundwater (see Water Act).
Many landowners ask the company to pay for the testing of their water well when they negotiate a lease agreement. This is to ensure that there is a baseline study against which to compare any future changes in well water quality that might result from oil- and gas-related operations. You should ensure that the laboratory carrying out the tests is accredited by the Canadian Association of Environmental Analytical Laboratories (see Laboratories). Be sure to ask for a copy of the test results and keep it for future reference.
The test should be thorough and cover both water volume and water quality. A basic flow test should involve pumping a well at a constant rate for at least 60 minutes, although in some cases, pumping for 120 minutes or for a day or more may be necessary. While the pumping rate is maintained, the water levels should be recorded in the well to measure the draw down. The well should then be allowed to recover for the same length of time that it was pumped, and again the depth should be measured to calculate the recovery rate of the well. In situations where the top of the well is inaccessible, it may not be possible to calculate the draw down and recovery rate, but the well should still be pumped to determine the yield. Alberta Agriculture has a great resource regarding water wells and how to determine yield.
A routine water quality test measures about ten parameters, including total dissolved solids, total hardness, alkalinity, pH, chlorides, sulphates, nitrates and nitrites, and sodium. You should ask for the test to include total extractable hydrocarbons, to establish that there are no hydrocarbons in the water before drilling starts. A test for metals, including arsenic, cadmium, copper, lead, manganese, and zinc, may also be a good idea. A test for gas content may be advisable if there is a risk of gas migration from an oil and gas operation, such as shallow coalbed methane or hydraulic fracturing operations. You can ask the company to pay for these tests, and negotiate it as a condition in your surface access lease.
If a company is unwilling to pay for a routine water quality test by an independent company before it constructs an oil or gas well, you may want to ask the AER to facilitate your negotiations. While the water is being tested, you may also want to get a test done for total fecal coliforms, as these organisms can cause acute illness. However, a company may not want to pay for this part of a test, as it does not relate directly to oil and gas activities. You may want to contact the local health unit regarding bacterial tests as many health units in Alberta will cover all or part of testing costs for routine and bacterial analyses of domestic water wells.
|A water test that includes the testing according to the Canadian Drinking Water Quality Guidelines as well as comprehensive parameters frequently required for drinking water approvals can cost up to $2000.|
Health Canada sets standards for the acceptable level of substances in drinking water.
Water well drillers submit their drilling reports to the Alberta government and this information is stored in the publicly available Alberta Water Well Information Database. Chemical analysis data after 1986 is not stored on the database; you must contact the landowner if the land is not your own.
The Alberta Energy Regulator is responsible for concerns that relate to water well contamination if thought to be caused by oil and gas activity (see Figure 6). If it finds that oil or gas industry activity could have caused the contamination, they will investigate. If you have a complaint about a water well that may be affected by the oil and gas industry or groundwater contamination, you should call the AER’s Energy and Environmental 24-hr Response line at 1-800-222-6514.
If you suspect your well has been contaminated by hydrocarbons from oil or that gas may have leaked into the groundwater, you should get your well tested by an independent laboratory (you can find a directory of private laboratories in Laboratories). All tests that were conducted before the oil or gas well was drilled should be repeated and, in addition to the test for total extractable hydrocarbons, you should also request a BTEX test (for benzene, toluene, ethylbenzene and xylenes). If you find gas in your well, a carbon isotope of each gas detected may help identify the source. You may want to negotiate with the company to arrange for them to pay for the costs of testing the well. If you need help, contact the Farmers’ Advocate Office and inquire about their Water Well Restoration or Replacement Program (see Farmers’ Advocate Office).
Surface water can also be used to supply the necessary water at an oil and gas operation. Surface water is collected by water trucks and transported to the development site. Due to the intermittent supply, surface water is not suited for continuous operations. Instead, surface water tends to be used for drilling muds, well testing, and hydraulic fracturing where water is only required for a temporary period.
If surface water is proposed to be used, the operational requirements to withdraw the water will be stipulated in an operator’s water licence. It is standard for these licences to require use of a fish screen in water courses or bodies that are known to contain fish populations, and to limit withdrawals from watercourses to 10% of the instantaneous flow rate. These requirements ensure that fish populations and the aquatic ecosystem are not significantly affected by withdrawal of the water. If a company is observed withdrawing water from a waterbody or watercourse on your property, they are required to show you their licence upon request. If you believe water licence requirements are being contravened, you should notify the AER and provide any supporting evidence.
Coalbed methane (CBM) is an unconventional natural gas formed in coal seams, also known as natural gas in coal or natural gas from coal. Coal seams can be found across the southern half of Alberta.
If a coal formation contains water, it will be necessary to remove some of the water to reduce the pressure and allow the gas to be released. In some coal seams in central Alberta (for example, those in the Horseshoe Canyon formation) the coal is “dry” and no dewatering is necessary; however, deep coal formations (such as those in the Mannville group) usually contain saline groundwater. This water will usually be pumped out and piped to a central injection well, where it will be re-injected deep underground, in the same way that saline water from a conventional natural gas well is re-injected. If the saline zone is close below the non-saline zone, a company should not produce any gas from the non-saline zone, since this could result in the mixing of water of different qualities.
It is mandatory for an operator of a coalbed methane well to conduct baseline water testing for a new well or complete or recomplete wells if the wells are shallow and above the base of groundwater protection (BGWP). Since these are being drilled into shallow non-saline aquifers and these aquifers require dewatering to release the gas, their operations have the potential to impact the flow to other water wells.
|A conventional gas or oil well will sometimes produce saline water, and the quantity will probably increase as the well ages. This water is pumped out with the oil or gas, separated and injected back deep underground. If a CBM well contains water, it will need dewatering at the start of operations so that the gas can be released.|
You should get your water wells tested prior to any CBM development in a shallow, non- saline aquifer in the vicinity of your water well. The AER requires that developers offer to test all active water wells within a minimum 600-metre radius of a proposed CBM well prior to drilling or recompleting the well. Companies are required to provide detailed reports before the AER will consider an application for the diversion of groundwater. This is because dewatering of the coal seams could lower the water level in domestic wells, if the coal is near the surface or there is hydraulic connectivity with shallow aquifers. This data will provide a baseline against which to measure any future changes.
If, after drilling, a company finds they need to divert non-saline water from the coal seam, they must submit a technical report to the AER together with their application. The technical report must include detailed information about the hydrogeology, aquifers and water wells. The AER administers Alberta Environment and Parks water standards that require a company to test water wells for gas and, if gas is detected, to test for the carbon isotopes of each gas. This will help identify the source of any gas and serve as a baseline, in case the CBM development leads to any gas migration in the future. The Alberta Energy Regulator also publishes a public notice about the proposed water withdrawal and must respond to any statements of concern from the public. The Regulator is required to consider all statements from those who are directly and adversely affected, before they decide whether to authorize the diversion of water from the aquifer.
If a CBM well is drilled into a non-saline aquifer, you should ask about plans to dewater the coal seams, any potential impacts on groundwater, and how the water will be handled.
While saline water must be re-injected deep underground, there may be different ways of handling non-saline water. If the Alberta Energy Regulator issues a licence or approval for diversion of non-saline aquifers, it will indicate how the water must be handled. Even water that is defined as non-saline must be managed carefully, since the level of salts may be sufficient to damage soils and crops. Depending on the level of salts, non-saline water — that may still contain more than the standards of dissolved salts for potable water — may be used for watering livestock. Whether the water is suitable for irrigation will depend not only on the salt content and the crops grown, but also on the sodium adsorption ratio of the receiving soil. Alternatively, the water may be discharged or re-injected into a compatible aquifer underground. Since the quality of the water may change during the dewatering process, regular testing of the salinity level should be requested.
|While guidelines are designed to prevent damage to a non-saline aquifer, it is still advisable to ensure that a company will provide an alternate water supply should your water well be adversely affected by CBM drilling. You should include a clause in your surface lease agreement to this effect.|
Licences issued by the Alberta Energy Regulator for groundwater diversions typically include “investigation and mitigation” requirements that may include alternative water supply arrangements if needed. You typically would need to provide a written complaint to the Alberta Energy Regulator to initiate an investigation.