2100, 350 – 7 Avenue S.W.

Calgary, Alberta Canada T2P 3N9 Tel 403-267-1100 Fax 403-261-4622

1000, 275 Slater Street Ottawa, Ontario Canada K1P 5H9 Tel 613-288-2126 Fax 613- 236-4280

1004, 235 Water Street St. John’s, Newfoundland and Labrador Canada A1C 1B6 Tel 709-724-4200 Fax 709-724-4225

310, 1321 Blanshard Street Victoria, British Columbia Canada V8W 0B5 Tel 778-410-5000 Fax 778-410-5001

www.capp.ca communication@capp.ca

November 12, 2015

Dr. Ray Gosine

Chair, Hydraulic Fracturing Review Panel

c/o Office of Associate Vice-President (Research)

Bruneau Centre for Research and Innovation, IIC-3067

Memorial University of Newfoundland

St. John’s, NL A1C 5S7

Dear Mr. Gosine:

Thank you for meeting with CAPP on October 6, 2015. At that meeting, Panel members asked

several questions about hydraulic fracturing practices that were not addressed in our original

submission of May 29, 2015.

Attached please find additional information addressing those questions. If we can provide further

information please let me know.

Regards,

P Barnes

Manager, Atlantic Canada and Arctic

1

General Comment:

CAPP would like to emphasize that as part of continuous improvement for regulatory

frameworks and industry practices there are several well established working groups in Canada

that commonly include regulators, industry representatives, government and academics. These

parties have the direct experience and intimate knowledge of the hydraulic fracturing activities.

Industry associations, like Society of Petroleum Engineers (SPE), Canadian Society of

Unconventional Resources (CSUR) and Petroleum Technology Alliance of Canada (PTAC) and

others are acting as coordinators and facilitators of research projects. The Panel may wish to

contact these groups for further information.

Q1: Panel is looking for any additional regulation or industry best practices on long term

well bore integrity (monitoring or specific regulatory requirements in other Canadian

jurisdictions that address this)?

Long-term wellbore integrity must consider the entire life cycle of the well and the specific

processes a company follows, as well as specific regulations and best practices that play a role in

ensuring wellbore integrity. Long-term wellbore integrity issues are linked to the following:

initial planning/well design (e.g., material selection, fluid design, weight and grade of

casing and completion design),

well construction and drilling,

well operations (flow-testing and production history),

well monitoring,

well remediation,

potential well suspension; and ultimately,

well abandonment and decommissioning.

Examples of well design steps that can be taken to ensure integrity, include physical testing (rock

mechanics) and modeling to evaluate stress fields, hoop stresses and cement sheath integrity

across the full well life cycle. Regulatory frameworks address on-going well bore integrity

through monitoring of surface casing vent flows (SCVF), gas migration (GM), packer isolation

testing (PIT), and other such tools.

The type of well is an important factor related to wellbore integrity. Companies and regulators

have different expectations and requirements based on whether a well is designed for deep well

2

injection, sweet natural gas production, sour gas production, acid gas disposal or carbon capture

and storage, to name a few examples. For each well, there are many variables that affect the

practices undertaken and regulations being applied that are factors that could affect wellbore

integrity.

It is also important to remember that during their life cycle wells are inspected, maintained and

tested, regularly to ensure wellbore integrity. Therefore, the question of long-term wellbore

integrity must assess these phases in the life of any given well. But the fact is, well integrity

failures have generally decreased because learnings from earlier times have been incorporated

into new well design practices and regulations. Companies implement well integrity

management systems to ensure adherence to regulatory requirements, safety and environmental

protections, and long-term liability protection.

Of course wellbore integrity has gained heightened attention in the last few years but it has

always been a critical component of safe and responsible oil and gas development. Tables 1 and

2 provide a sample of regulatory measures in place in Alberta and British Columbia that govern

wellbore integrity. In addition, studies related to carbon-capture and storage (CCS) evaluated

long-term wellbore integrity issues in the past decade. An example of this type of work includes

a Society of Petroleum Engineers (SPE) Paper 106817 by Watson and Bachu entitled Factors

Affecting or Indicating Potential Wellbore Leakage (2007).

Action by Provincial Regulators

The western provinces have a history of collaboration, exchange of knowledge and sharing of

case studies to continuously improve resource development practices. An example is the Western

Regulators Forum, where regulators, industry and other experts in British Columbia, Alberta and

Saskatchewan address issues like wellbore integrity. However, individual provinces are also

working on many other continuous improvement initiatives.

Alberta

The Alberta Energy Regulator (AER) has a variety of other activities in progress related to well

integrity, including:

Industry workshops related to well abandonment

Industry workshops related to emerging well integrity best practices in thermal operations. A

paper will be presented on this at the Banff SPE Symposium on Nov 23-25, 2015.

Ongoing communication with several research organizations (variety of topics)

Examining alternatives to cement for remedial well repairs

Communicating with industry on 1) fracturing issues, 2) quantifying well failure types, 3)

developing best practices (variety of issues), 4) updating AER Directives and FAQs, and 5)

emerging technology.

3

British Columbia

The BC Oil and Gas Commission (BCOGC) is actively working with operators monitoring and

assessing the causes of surface casing vent flows (SCVF) with the focus of continuous

improvement and knowledge sharing among operating companies. SCVF may be an indication

of wellbore integrity issues and there are reporting requirements, remediation procedures and

other actions designed to maintain wellbore integrity. The BCOGC also has statistics on the

number of wells with SCVF or ground migration (GM). It also evaluates the rate of leakage as

part of risk (safety and environmental) evaluation and management procedures.

In addition, the BCOGC expects routine tests for SCVF to be conducted at the time of well

suspension, during well servicing operations (that is, recompletions), and annually for a period of

five years if a positive SCVF has been identified. (See Well Completion, Maintenance and

Abandonment Guideline, Sept., 2015, p. 38). Non-serious SCVF must be repaired at the time of

well abandonment (p. 40).

Note: The BCOGC has not found any evidence of wellbore leakage as a result of cement

degradation. The BCOGC conducts several hundred abandoned well inspections every year and

has not found any evidence of failed abandonment plugs resulting in wellbore leakage over the

long-term. Leaks associated with abandoned wells result from SCVF or GM that were not

detected and adequately remediated at the time of well abandonment. Regulations have been

improved to require testing and repair prior to well abandonment.

To suspend a well the BCOGC requires the following:

A Well Suspension/Inspection Form must be submitted to the Commission’s Drilling and

Production Department within 30 days of suspension of a well and should be submitted by

email to OGCDrilling.Production@bcogc.ca. Records of suspensions and inspections must

be maintained on file until the time of well abandonment and must be provided to the

Commission on request. Inspection results may be recorded by filling out the applicable

sections of the OGC’s Well Suspension/Inspection Form.

To ensure long term integrity, inactive wells must be maintained, pressure tested, and

inspected on a schedule laid out on tables 3.1, 3.2, 3.3, and 3.4 in the Well Completion,

Maintenance and Abandonment Guideline (pages 14 to 17).

Wells must be abandoned in a manner that ensures the long-term integrity of the wellbore is

maintained in accordance with the AER Directive 20. See Well Completion, Maintenance

and Abandonment Guideline, Sept., 2015, p. 21.

For more information, see Well Completion, Maintenance and Abandonment Guideline,

Sept., 2015

4

Table 1 Sample of Alberta Energy Regulator’s Measures Governing Wellbore Integrity

REGULATION Relationship to Well Bore Integrity

AER Directive 008 Surface Casing Depth Requirements

AER Directive 009 Casing Cementing Minimum Requirements July 01, 1990

AER Directive 010 Minimum Casing Design Requirements

AER Directive 020 Well Abandonment

AER Directive 023 Oil Sands Project Applications

AER Directive 036 Drilling Blowout Prevention Requirements and Procedures

AER Directive 051 Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements

AER Directive 079 Surface Development in Proximity to Abandoned Wells

AER Directive 083 Hydraulic Fracturing – Subsurface Integrity

AER Interim Directive 2003-01:

(1) Isolation Packer Testing, Reporting, and Repair Requirements; (2) Surface Casing Venting Flow/Gas Migration Testing, Reporting, and Repair Requirements; (3) Casing Failure Reporting and Repair Requirements

Table 2 Sample of Industry Association Guidelines and Events Governing Wellbore Integrity

GUIDELINE or EVENT

Relationship to Well Bore Integrity

Enform IRP#3 In Situ Heavy Oil Operations

Enform IRP#5 Minimum Wellhead Requirements

Enform IRP #01 Critical Sour Drilling

Enform IRP#24 Hydraulic Fracturing

Enform IRP#25 Primary and Remedial Cementing (currently under review) -- Current timeline will have it for industry review in January, 2016. The review has significant operator and regulator representation

CSA Z625 Well Design, scheduled for publication in 2016. Will contain enhanced casing and cementing requirements for new wells

Society of Petroleum Engineers (SPE)

Technical events on wellbore issues: SPE Thermal Well Design & Integrity Symposium, Nov. 23-25,

2015 SPE Thermal Well Design & Integrity Workshop, Nov. 18-20, 2014

PTAC Sponsored a new project compiling information on Surface Casing Vent Flow and Gas Migration; this is an example of how new information will inform industry’s and regulators’ ongoing efforts relating to wellbore integrity

5

Saskatchewan

For drilling, Saskatchewan has regulations and requirements for well casing and surface casing

specifications and also requires cementing all casing strings. For new wells, companies must

determine if they have serious SCVF or GM problems prior to completing a well. If serious, they

must contact the Ministry for repair or monitoring programs. Companies are also required to test

for SCVF and GM at the time of abandonment.

Saskatchewan requires companies to complete regular pressure tests on water injection and

disposal wells, and to report failures to the ministry. Throughout the life of wells, Saskatchewan

requires companies to conduct casing integrity records (e.g. pressure tests, bond logs, noise logs,

temperature logs, etc.) when wells are abandoned, recompleted or reclassified to other uses, and

to submit the failures to the Ministry accompanied with appropriate repair programs. There is

also a requirement for casing integrity inspection on cavern wells and gas storage wells.

There are regulatory requirements for well abandonment (Oil and Gas Conservation Regulations

OGCR; sections 44 through 48) and the Ministry conducts inspections at well sites for SCVF and

gas migration.

6

Q2: Panel is wondering about chemical disclosures and proprietary disclosure exemptions

and related legislation?

The Hazardous Material Information Review Act (HMIRA) does allow for a “Claim for

exemption by Supplier”. Please see Review of Confidential Business Information, Section 11)

11.(1) Any supplier who is required, either directly or indirectly, pursuant to the provisions

of the Hazardous Products Act, to disclose [...] may, if the supplier considers such

information to be confidential business information, claim an exemption from the

requirement to disclose that information by filing with the Chief Screening Officer a claim

for exemption in accordance with this section.

For any ingredient that is subject to a claim for exemption through Hazardous Material

Information Review Act (HMIRA), the registry number must be provided in the comments.

Furthermore, the generic name of the ingredient must also be provided, where possible.

Otherwise, the ingredient may be listed as ‘Undisclosed’.

If the subject of the claim is solely for the chemical identity of one or more ingredients, then the

CAS number(s) is/are left blank for each ingredient subject to a claim, but the maximum

concentration within the additive is provided, along with the maximum concentration within the

fracture fluid for each ingredient.

If the subject of the claim is to protect both the chemical identity and the concentration of one or

more ingredients, then the CAS number(s) is/are left blank along with the concentration(s) within

the additive for each ingredient subject to a claim. If possible, concentration of the ingredient

within the fracture fluid can also be provided, but may also be left blank.

The FracFocus.ca website has additional information related to chemical disclosure.

7

Q3: Induced seismicity – what is new or in progress on this topic in western Canada?

There are many studies and/or initiatives that have improved the technical understanding of

induced seismicity resulting from both hydraulic fracturing and deep well injection and an

understanding of practices for risk assessment and mitigation. This has led to mitigation and

monitoring procedures being adopted by regulators and increased collaboration and sharing

among industry operators. The BCOGC and the AER (the regulators) have enacted several

procedures and monitoring requirements.

On October 6, 2015, the University of Calgary hosted a multi-stakeholder workshop to discuss

improvement to the Traffic Light Protocol, a commonly used seismicity mitigation tool (and

currently regulated in the Fox Creek area of Alberta). The Canadian Society of Unconventional

Resources (CSUR) is holding an Induced Seismicity Workshop in Calgary on Nov. 19, 2015.

This event will highlight many of the research initiatives underway.

Provincial Activities

British Columbia

Regulatory Changes

On August 6, 2015, the BCOGC announced it had approved amendments to the Drilling and

Production Regulation that would, among other things, regulate the reporting requirements of

permit holders relating to seismic events. New permit conditions are as follows:

(1) During fracturing or disposal operations on a well, the well permit holder must

immediately report to the commission any seismic event within a 3 km radius of the drilling

pad that is recorded by the well permit holder or reported to the well permit holder by any

source available, if

(a) the seismic event has a magnitude of 4.0 or greater, or

(b) a ground motion is felt on the surface by any individual within the 3 km radius.

(2) If a well is identified by the well permit holder or the commission as being responsible for

a seismic event that has a magnitude of 4 0 or greater, the well permit holder must suspend

fracturing and disposal operations on the well immediately.

(3) Fracturing and disposal operations suspended under subsection (2) may continue once

the well permit holder has implemented operational changes satisfactory to the commission

to reduce or eliminate the initiation of additional induced seismic events.

Monitoring and Reporting Activity

The province created the BC Seismic Research Consortium, which is comprised of four project

partners: Geoscience BC, the Canadian Association of Petroleum Producers (CAPP), Natural

Resources Canada (NRCan) and the BC Oil and Gas Commission (BCOGC). The Consortium

was formed on July 1, 2012 in response to recommendations set forth in the BCOGC report

Investigation of Observed Seismicity in the Horn River Basin. In August 2013, six, three-

component seismographs were installed in northeast B.C. to complement two existing Canadian

National Seismic Network stations and better understand seismic activity created from natural

gas operations. The consortium has a five-year mandate to collect and analyze the seismic data.

Other actions as a result of this consortium include:

8

In November 2014, the BCOGC and NRCan added two more seismographs to the

network.

The BCOGC and Geoscience BC hosted a Northeastern BC Induced Seismicity

workshop on Nov. 19, 2014. This brought industry and government experts together to

share knowledge and practices related to induced seismicity

Deployment of eight new seismic stations.

These eight new seismic stations in northeast BC have significantly increased the detection

capability of the regional network (NE BC seismic consortium). See Final Report for Year 2 of

the Induced Seismicity Monitoring Project Report here.

Education is also important. The new BCOGC office in Fort St. John has a “Seismic Monitoring

in the Fort St. John Region” display with real-time seismograph images from the local station.

This exhibit has been very effective in demonstrating that the regulator (OGC) and associated

experts are monitoring induced seismic events in Northeast BC, and that there are defined

procedures in place to modify activities, if required.

In select areas of Northeast BC, companies have established more than 12 dense seismic arrays

in order to accurately detect and locate induced events. They voluntary submit reports to the

BCOGC for any events they detect greater than magnitude 1.5.

Alberta:

Regulatory Changes

AER is working with other Government of Alberta agencies to understand the risk of induced

seismicity and sharing learnings regarding sensitivities and potential triggers of induced seismic

events. Some recent work in the area includes:

In August 2014, AER started a project to develop the capacity for the collection and

analysis of information collected from induced seismic events, Induced Seismicity

Data Aggregation Project. AER is now in phase II of this project, which includes

integrated holistic analysis of internally collected data with data collected from

operators. This project’s goal is to develop a system to intake information regarding

induced seismic events, understand their cause, and pass this information on to

develop appropriate actions by Government.

In February of 2015 the AER created Subsurface Order #2 (SO#2). SO#2 outlines a

traffic light protocol for the Fox Creek area, specific to hydraulic fracturing

operations within the Duvernay Formation.

Protocol requires operators to monitor seismic activity during hydraulic fracturing

operations and react to the protocol as specified. AGS monitors and reports all

seismic activity in the SO#2 area on the AER website

9

On October 6th

, 2015 a group of regulators, academics, and industry met to discuss

the effectiveness of the Traffic Light Protocol and looked at ways to improve it.

Monitoring and Reporting Activity

The Alberta Geological Survey (AGS) continues to deploy stations, and monitor earthquakes to

better understand the tectonic setting of the Western Canada Sedimentary Basin and the

influences from petroleum operations. Some recent activity includes:

The AGS has recently installed a new seismic network: the Regional Alberta

Observatory for Earthquake Studies Network (RAVEN), which continuously

monitors earthquakes throughout the province [Schultz and Stern, 2015]. This data is

also made publically available through IRIS (http://ds.iris.edu/mda/RV).

The AGS performs meta-analysis on the incoming waveform and catalogue data to

better understand the performance of the routinely analyzed events, and to make

suggestions for future improvements and deployments of RAVEN stations [Schultz et

al., 2015b].

The AGS has previously characterized seismicity known as the Brazeau cluster in the

Cordel field. Their findings were that the seismicity in this location, dating from the

90s until present, was most likely (>99.7% confidence) the result of nearby waste-

water disposal operations [Schultz et al., 2014].

Furthermore, a study by the AGS found that earthquakes in southern Alberta, near the

town of Cardston, were most likely (>99.7% confidence) due to fracturing stimulation

of the Exshaw formation. The increase of pore-pressure during stimulation was

purported to have reactivated a Late Cretaceous extensional fault [Schultz et al.,

2015c].

Yukon

Yukon Geological Survey is installing seismographs in collaboration with Northeast BC Seismic

Consortium starting in 2015.

Northwest Territories

Four seismic (earthquake) monitoring stations were installed surrounding Norman Wells to

monitor seismic activity in the oil and gas leases in the Central Mackenzie Valley. Information

on the frequency, intensity and location of earthquakes in the valley is being collected and can be

found at http://www.nwtgeoscience.ca/project/summary/seismic-monitoring-central-mackenzie-

valley

For the Northwest Territory seismic project overview:

http://csegrecorder.com/articles/view/preparing-to-monitor-and-distinguish-natural-and-induced-

seismicity

Please see Appendix A for a list of References and a list of Academic Experts working on

induced seismicity in Western Canada.

10

11

Q4: Financial securities/liabilities -- are there BC and AB models for long term liability

protection?

British Columbia

There are many safe guards in oil and gas activities to protect the taxpayers from long-term

environmental impact costs. These include the “polluter pays principle.” In addition, security

deposits are assigned to individual companies based on risk-based systems that consider closure

obligations and a company’s ability to pay. Other programs in place include:

The Certificate of Restoration (COR) system is designed to avoid longer-term

environmental issues.

Orphan Site Reclamation Fund (OSRF) – covers the rare occurrences where a permit

holder for an existing site is insolvent or cannot be identified. These sites can be

designated by the BCOGC as Orphan Sites. The Fund then covers the cost to

remediate these Orphan Sites. The OSRF is a levy on oil and gas production paid by

industry that protects taxpayers from paying for restoration liability.

The BCOGC has various risk management systems, including a legacy site review

process. This allows it to put some rare sites into the orphan status (if necessary), and

thereby allocating funds to remediate a site. The BCOGC does not have any long-

term liability fund per se. It believes that its risk management systems and processes

outlined above are adequate.

In BC, a person who contravenes the Drilling and Production Regulation (as specified

in the Administrative Penalties Regulation, Section 5) may be liable to an

administrative penalty ranging from $2,000 to $500,000. Please see Well

Completion, Maintenance and Abandonment Guideline, Sept., 2015, p. 47.

Security payment schedule is defined in the Oil and Gas Act, Fee, Levy and Security

Regulation, Part 5.

The Liability Management Rating (LMR) program has been developed by the

BCOGC to assist in the determination of security deposits for permit holders under

Section 30 of the Oil and Gas Activities Act. Please contact Mike Janzen at

Mike.Janzen@bcogc.ca or (250) 419-4464 for more detailed information. See also:

o The documentation on the Liability Management Rating

o The 2013/14 Liability Management Rating Summary report on the OGC website.

12

Alberta

The Alberta Energy Regulator (AER) works collaboratively with government and industry

stakeholders to develop and implement appropriate liability management programs for all energy

sectors regulated by the AER. The AER recognizes its responsibility to Albertans to protect the

public from significant potential environmental issues and costs associated with abandonment

and decommissioning of those sites that have been involved in petroleum resource recovery by

ensuring licensees and owners are responsible for proper abandonment and decommissioning.

The AER Liability Management website describes in detail their programs and processes

including the Orphan Levy, Licensee Liability Rating (LLR) Program Management Plan,

Directive 024 Large Facility Liability Management Program (LFP), Directive 068 Security

Deposit Requirements, Directive 001 Site-Specific Liability Assessments (SLA), and Directive

075 Oilfield Waste Liability (OWL) Program. These materials clearly demonstrate that the

liability risks to the public are carefully considered across the spectrum of activities conducted

during oil and gas operations in Alberta.

13

Q5: Air quality – the Panel is wondering about a new report recently released from BC?

In terms of a new report, yes the BCOGC is preparing a new report that will put air quality in the

broader context for northeast BC. This will assist the public to better understand the role of

flaring and other activities in the larger air quality picture. The public release for this new report

is expected at the end of November, 2015.

The BCOGC has a web-page on Air Quality where it indicates it monitors air quality from oil

and gas activities in order to protect public safety and conserve the environment. It also actively

participates in the Northeast Air Monitoring Project (see next bullet). In addition the BCOGC

publishes an annual flaring summary, the most recent being for 2013.

The North East Air Monitoring Project was announced in June 2012 as a partnership between the

provincial government, the BCOGC and the oil and gas industry operating in the northeast. The

final report for this project was released on Jan. 31, 2014.

As part of The North East Air Monitoring Project, there is a dynamic map-based viewer that

shows real-time air quality data for northeast BC.

The BCOGC acquired an Air Monitoring Environmental Laboratory (CAMEL). This is used by

the BCOGC to determine potential sources of airborne contaminants within communities that do

not have fixed monitoring stations. CAMEL contains a suite of sensory equipment to measure

air pollutants as low as parts per billion (ppb) concentrations and can be deployed to

communities concerned about air pollution due to oil and gas activity.

In terms of air quality, Northern Health also works closely with the Ministries of Environment

and Health, and various other agencies on matters relating to air quality in northeast BC.

From the BCOGC website page the various elements of Air Quality are summarized in the table

below.

14

Q6: Panel has asked if our industry or any government agencies elsewhere are working

together on any non-regulated performance programs. They also asked about WHMIS.

Regarding Non-regulated Performance Programs for Unconventional Activities:

The Center for Sustainable Shale Development (CSSD) in Pennsylvania has developed 15 initial

performance standards for operators that are protective of air quality, water resources and

climate. These standards represent consensus on what is achievable and protective of human

health and the environment. As these standards are put into practice, CSSD will learn from these

adaptations and is committed to revise standards as appropriate.

On its website, CSSD outlines the standards as follows:

Air & Climate Performance Standards

Limitations on Flaring

Use of Green Completions

Reduced Engine Emissions

Emissions Controls on Storage Tanks

Surface & Ground Water Performance Standards

Maximizing Water Recycling

Development of Groundwater Protection Plan

Closed Loop Drilling

Well Casing Design

Groundwater Monitoring

Wastewater Disposal

Impoundment Integrity

Reduced Toxicity Fracturing Fluid

The CSSD also offers a certificate program. Certification is based on the Center’s 15 initial

performance standards that were developed to reflect leading industry practices. Companies can

seek certifications in Air & Climate, Water & Waste, or both, concurrently.

Regarding WHMIS:

The Hazardous Products Act lays out how and when WHMIS is required. For hazardous

products it is mandatory. Suppliers, employers and workers have obligations under WHMIS to

15

ensure the safe use of products. Employers must ensure appropriate control measures are in place

to protect the health and safety of workers.

On February 11, 2015, the Government of Canada published Part II of the Hazardous Products

Regulations (HPR), which, in addition to the amendments made to the Hazardous Products Act

under the Economic Action Plan 2014 Act, No.1, modified the Workplace Hazardous Materials

Information System (WHMIS) in 1988 to incorporate the Globally Harmonized System of

Classification and Labelling of Chemicals (GHS) for workplace chemicals. This modified

WHMIS is referred to as WHMIS 2015. The Controlled Products Regulations (CPR) and the

Ingredient Disclosure List have been repealed.

While WHMIS 2015 includes new harmonized criteria for hazard classification and requirements

for labels and safety data sheets (SDS), the roles and responsibilities for suppliers, employers and

workers have not changed.

Regarding the Trend Toward Greener Chemicals:

Exploration and production companies and the associated service companies are working hard to

identify and use additives (chemicals) with the least risk and impact to health and environment.

They are also setting up tracking systems for enhancing future reporting on the overall toxicity of

their chemical mixtures. In the United States, companies are collaborating with the American

Chemical Society’s Green Chemistry Institute to advance green chemistry in hydraulic

fracturing.

Many companies continue to seek greener chemicals for hydraulic fracturing and to disclose

more information of these issues. Various company websites have varying degrees of

information about their chemical selection and toxicity ranking system processes. Some of these

have been published as professional papers:

https://www.onepetro.org/conference-paper/SPE-159690-MS

https://www.onepetro.org/conference-paper/SPE-147534-MS

https://www.onepetro.org/conference-paper/SPE-152068-MS

Enform’s Controlling Chemical Hazards (CCH) in the Oil and Gas Industry: Program

Development Guideline

This project is designed to raise awareness of chemical hazards and the role and

responsibilities of workers in controlling these hazards. Enform’s project consists of four

items: guideline, worker flip guide, guidance sheets, and exposure control plan template.

16

Q7: Public health responsibilities – The Panel was wondering about ISO certification of

operations?

ISO certification related to public health in the oil and gas sector seems limited, although there

are many documents and guidelines related to worker health and safety. The following materials

can be applied in many ways to the issue of public health:

The International Association of Oil & Gas Producers (IPIECA) has a Booklet entitled

Managing Health for Field Operations in Oil and Gas Activities- this is mostly focused on

workplace health

The American Petroleum Institute http://www.api.org/~/media/Files/Policy/Safety/14-

Industry-commitment-to-onshore-safety.pdf - this is mostly focused on workplace safety

Worksafe BC Occupational disease hazards in the oil and gas industry – bulletin. This

covers worker safety standards regarding exposure control plans (ECP) whenever workers

may be overexposed to chemical hazards, including hydrogen sulfide (H2S), drilling fluids,

silica, noise, diesel exhaust, confined spaces and mercury.

Health Performance Indicators, A guide for the Oil and Gas Industry. (UK) International

Petroleum Industry Environmental Conservation Association (IPIECA). This covers

community and workforce.

Alberta Oil and Gas Industry Emergency Preparedness and Response (2015). Alberta Health

Services Alberta Health Services (AHS) and Environmental Public Health (EPH) roles and

responsibilities in public health emergency preparedness and response to the oil and gas

industry are outlined in this document.

Canadian Ambient Air Quality Standards. These are health-based air quality objectives for

pollutant concentrations in outdoor air. Under the Air Quality Management System,

Environment Canada and Health Canada established air quality standards for fine particulate

matter and ground-level ozone, two pollutants of concern to human health and the major

components of smog. These standards are more stringent and more comprehensive than the

previous Canada-wide standards for these pollutants. Furthermore, the Canadian Ambient Air

Quality standards lower the short-term limits and introduce new limits for long-term

exposure for fine particulate matter.

Canadian Environmental Quality Guidelines provide science-based goals for the quality of

aquatic and terrestrial ecosystems.

The Federal-Provincial-Territorial Committee on Drinking Water establishes the Guidelines

for Canadian Drinking Water Quality specifically for contaminants that meet all of the

following criteria:

17

o Exposure to the contaminant could lead to adverse health effects in humans;

o The contaminant is frequently detected or could be expected to be found in a large

number of drinking water supplies throughout Canada; and

o The contaminant is detected, or could be expected to be detected, in drinking water at

a level that is of possible human health significance.

The CSA Group has Z1001, Occupational Health and Safety Training, based on the

foundation established by Z1000 Occupational Health and Safety Management. These

materials are designed for workers and workplace health and safety, rather than the public.

The International Financial Corporation has Performance Standard 4 Community Health,

Safety, and Security. This document outlines high-level expectations for public health.

18

APPENDIX A: Associated with Q3: Induced Seismicity

Alberta References:

Baranova, V., Mustaqeem, A., and Bell, S. (1999). A model for induced seismicity caused by

hydrocarbon production in the Western Canada Sedimentary Basin. Canadian Journal of Earth

Sciences, 36(1), 47-64, doi: 10.1139/e98-080.

Schultz, R., Stern, V., and Gu, Y. J. (2014). An investigation of seismicity clustered near the

Cordel Field, west central Alberta, and its relation to a nearby disposal well. Journal of

Geophysical Research: Solid Earth, 119(4), 3410-3423, doi: 10.1002/2013JB010836.

Schultz, R., Stern, V., Novakovic, M., Atkinson, G., and Gu, Y.J. (2015a). Hydraulic fracturing

and the Crooked Lake Sequences: Insights gleaned from regional seismic networks, Geophysical

Research Letters, 42, 2750-2578, doi: 10.1002/2015GL063455

Schultz, R., Stern, V., Novakovic, M., Atkinson, G., and Gu, Y.J. (2015b). Hydraulic fracturing

and the Crooked Lake Sequences: Insights gleaned from regional seismic networks, Geophysical

Research Letters, 42, doi: 10.1002/2015GL063455

Schultz, R., Mei, S., Pană, D., Stern, V., Gu, Y.J., Kim, A., and Eaton, D. (2015c). The Cardston

Earthquake Swarm and Hydraulic Fracturing of the Exshaw Formation (Alberta Bakken play),

Bulletin of the Seismological Society of America, 105(6), doi: 10.1785/0120150131.

Schultz, R., and Stern, V. (2015). The Regional Alberta Observatory for Earthquake Studies

Network (RAVEN), CSEG Recorder, 40(8), 34-37.

Stern, V.H., R.J. Schultz, L. Shen, Y.J. Gu, D.W. Eaton (2013), Alberta Earthquake Catalogue,

Version 1.0: September 2006 through December 2010, Alberta Geological Survey Open File

Report, 2013-15, 36 pp.

Wetmiller, R. J. (1986). Earthquakes near Rocky Mountain House, Alberta, and their relationship

to gas production facilities, Can. J. Earth Sci. 23, 172–181, doi: 10.1139/e86-020.

Some of the Academic Experts working on induced seismicity in Western Canada:

Dr. Honn Kao – Natural Resources Canada lead for induced seismicity in Canada.

Dr. Ali Mahani, Geoscience BC contract seismologist – working on induced seismicity in

NEBC.

Dr Marc Bustin and Dr. Amanda Bustin, University of British Columbia -- incorporating

hydro-geomechanics and a variety of monitoring into a traffic light system.

Dave Eaton, University of Calgary -- NSERC/Chevron Industrial Research Chair in

Microseismic System Dynamics at the University. He also runs the Microseismic

Industry Consortium.

Dr. Gail Atkinson, University of Western Ontario -- ground motion expert, Professor &

NSERC/TransAlta/Nanometrics Industrial Research Chair in Hazards from Induced

Seismicity.

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Dr. Jeff Gu – University of Alberta - doing some work on induced seismicity.

Dr. Mirko van der Bann – University of Alberta - doing some work on induced

seismicity, part of the Microseismic Industry Consortium.

Original Submission from CAPP

http://nlhfrp.ca/wp-content/uploads/2015/01/Letter-from-CAPP1.pdf