Report Recommendations and Response
RECOMMENDATION
B.C. should adopt the Natural Resources
Defense Council recommendations for fracking
wastewater disposal wells. B.C. disposal wells
should be required to meet the U.S.
Environmental Protection Agency’s guidelines
for Class I hazardous waste wells.
Summary of Best Practices Rules: B.C. should
require operators to reduce, reuse, and
recycle wastewater; minimize their use of
chemical additives; create “project-specific
water-management plans”; and refrain from
using water sources that are already
experiencing stress.
RESPONSE
 The U.S. does not require its own oil and
gas industry to meet this standard.
 B.C. disposal well requirements have
become very rigorous.
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Summary of Best Practices Rules: B.C. should
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conduct a strategic environmental assessment
to assess the cumulative impacts of fracking
and disposal well activities in northeastern B.C.
B.C. must consider the cumulative impacts of
fracking and injection activity to ensure
improperly sited wells do not cause
earthquakes, and to reduce the chances of a
changing underground environment opening
up new pathways for wastewater to make its
way to the surface. See the Environmental Law
Centre’s report on the need for a Strategic
Environmental Assessment of the proposed
new Liquefied Natural Gas industry at
www.elc.uvic.ca.
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B.C. is already doing this – industry is
actively encouraged to reduce its
freshwater use and to recycle where
possible.
B.C. also restricts the use of water for
hydraulic fracturing during times of
drought.
Industry is utilizing integrated water
management plans, recognized as a highly
important development consideration,
examples - water flow lines for both
delivery and flowback that reduces
trucking, stated goals to re-use 100 per
cent of flowback water, use of city of
Dawson Creek wastewater.
The industry Montney Water Group proactively shares flowback water for recycle
use by other companies, reducing disposal.
B.C. has looked at projections for
increased industry activity and has
determined there are adequate water
supplies and disposal capacity being
developed.
B.C. has done significant research on
induced seismicity and has made
improvements to increase the number of
seismic monitoring stations, and has
requirements to shut down operations if
such activity reaches a certain threshold.
RECOMMENDATION
Summary of Best Practices Rules: B.C. should
require operators to carry out a site-specific
risk assessment that examines underground
and surface in a sufficient radius around the
well, taking into account an appropriate
timeframe. Operators should be required to
submit this information as part of the
permitting application. If there is a chance the
well will allow fluids to migrate to the surface
or induce seismicity, permitting authorities
should be required to refuse the permit.
Summary of Best Practices Rules: B.C. should
require operators to ensure best practice in
well design and construction, systematically
verify the integrity of the well and quality of
the seal, and have this integrity testing
evaluated by an independent, qualified third
party.
Summary of Best Practices Rules: B.C. should
require comprehensive baseline testing of
surface and
groundwater, soil, and seismic activity near
the well prior to operation; this monitoring
should continue to take place throughout the
life of the well.
Summary of Best Practices Rules: B.C. should
ensure a robust monitoring and compliance
regime exists, along with adequate emergency
response plans. An appropriate way for B.C. to
ensure robust monitoring and compliance
efforts for disposal wells would be to give
affected First Nations and other affected
communities adequate resources to hire staff
to conduct baseline testing; provide
monitoring and compliance services
throughout the lifetime of the well to ensure
wastewater does not adversely impact the
environment or public health; and develop, in
conjunction with industry, adequate
emergency response plans and procedures
that give First Nations and other affected
communities adequate notice of spills and
leaks.
RESPONSE
 B.C. already has such requirements and
the Commission does refuse permits that
don’t meet our strict regulatory
requirements.
 Wells within a minimum of a 5km radius
from a disposal well are examined for
adequate integrity as part of the review
process.
 Detailed geologic mapping and analysis of
the disposal and overlying formations is
part of the application and review process,
to ensure competent storage.
 The risk of induced seismicity is part of the
application review process.
 B.C. does this and the information is
verified by certified professional engineers
and geologists, first by the company
making the application and operating the
well, then independently at the
Commission.
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B.C. does monitor a disposal well
throughout its active life.
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B.C. has a robust monitoring and
compliance regime. This includes a team
of almost 20 inspectors who carry out
more than 4,000 inspections annually.
Emergency Response Plans are required
for all oil and gas operations in the
province.
The Commission has a program in place
with First Nations to work alongside our
staff.
Communities are contacted anytime there
is a spill or leak through the Commission’s
24/7 emergency response system.
Disposal well approvals include a
requirement for continuous wellbore
pressure measurement and recording, the
first indicator if there is a potential of loss
of injection containment, which requires
the well to be immediately shut-in.
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