We will take a look at what these mean and how to implement a strategy for compliance and some of the tools you may find helpful to get there.
In Alberta, Directive 017 Section 8, there are specific rules for where and how to sample and when to report hydrocarbon liquids as liquid or a gas equivalent volume (GEV). Table 8.3 in Section 8.4 Directive 017 gives a comprehensive list of sampling frequencies for all upstream oil and gas operations for gas and condensate analysis (to see Table 8.3, click here). In Section 8.4, there are listed exceptions to the sampling frequency if the stream meets some specific conditions or the operator can apply to the AER for special approval.
Note: Crude oil/bitumen analysis is not covered in Section 8 of Directive 017, but is required in Section 14 to sample and analyze for density and water cut.
From Directive 017, sampling frequencies are defined as follows:
Initial – an analysis is required within the first six months of operation only, with no subsequent updates required
Monthly – an analysis is required at least once per calendar month
Quarterly – an analysis is required at least once per calendar quarter
Semiannually – an analysis is required at least once every two calendar quarters
Annually – an analysis is required at least once every four calendar quarters
Biennially – an analysis is required at least once every eight calendar quarters
Calendar quarters are January to March, April to June, July to September, and October to December
The timing in Table 8.3 of Directive 017 has built in flexibility so that the operator has a window of one calendar quarter to complete the sampling and analysis for each stream unless it is initial or monthly. For example, for an annual frequency, if the last sample was taken in July 2014, the operator has to take another sample by the end of September 2015 (end of the calendar quarter).
New gas and liquid samples must be taken for all new wells and measurement points by the end of the month following the first month of production.
If the AER inspector or auditor found that the sampling and analysis frequency wasn’t followed, or the analysis wasn’t used or updated within the allowed time frame, then they can assign non-compliance events in accordance with Directive 019 for each occasion.
In addition to a non-compliance event recorded with the AER, if the latest analysis wasn’t used or an incorrect analysis was used in the accounting system, the following may happen:
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