Draft Directive 080: Well Logging (June 2013) Stakeholder Feedback and AER Response

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1 Draft Directive 080: Well Logging (June 2013) Stakeholder Feedback and AER Response 1. Logging speed of 9 metres per minute (m/min) Logging speed 9 m/min: This is not clear whether this applies to MWD gamma ray or wireline logging. Clarify that the intent is MWD only. Current wireline logging speed is 18 m/min. Devon Canada Replaced all references to 9 m/min with the following general requirement: To ensure data integrity, all well log data acquired must be collected according to industry standards and the technically accepted logging rate published by the service provider. The literature indicates what the maximum logging rate can be (9 m/min). It does not explicitly state which logging service this applies to (resistivity, compressional sonic, gamma ray or neutron density). One assumes that it would only apply to the neutron density service. Having said this, we do not believe that logging rates should be explicitly stated in this directive because even at the present time (and for more than 15 years) newly designed equipment with advanced technology being used by certain (not all) service providers has been able, with proven results, to increase this rate for neutron density surveys. We would recommend that the verbiage normal logging rate of 9 m/min be replaced by the service provider s published technical excepted logging rate for the survey being acquired. 9 m/min for logging nuclear services is no longer normal and is a legacy value for those vendors who have re-designed the equipment to move away from this. As well the document should not explicitly state any processes or logging rates as they certainly will become antiquated very much sooner than will this standing directive. Husky Energy Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 1 of 13

2 Logging speed requirement of 9 m/min 1700 ft/hr. Set the logging speed requirement at industry standards for typical logging jobs. Suggest service companies provide their logging speeds for those tools which are required by regulations. 9 m/min is the typical rate for high resolution logging, which is rarely used, and is not necessary for good quality data. Typical logging speeds for the major logging providers are around 3600 ft/hr (18 m/min), which is double the regulatory requirement. Such an increase in rate could significantly impact logging time and lead to: - Unnecessary exposure of tools to open hole conditions - Hole deterioration due to prolonged exposure - Tools getting stuck due to differential sticking or bad hole conditions - Not being able to do multiple logging runs if hole conditions worsen due to prolonged exposure - Poor data quality due to tension pulls if the open hole is sticky Shell Canada 2. Logging of surface casing on multiwell pads At issue is how to define whether the vertical observation well is part of the same pad. For example, the pad of new wells may be located very close to, or on the site of, an older, perhaps abandoned, well that met the conditions. A proposed alternate wording that may reduce the number of waiver requests might be: Logging of the surface casing interval may be from a vertical observation well on the same pad or lease (groundwater evaluation well or passive seismic well or an existing well) if the following conditions are met: Nexen Energy ULC Added or surface facility lease to Logging of surface casing interval may be from a vertical observation wells (groundwater evaluation well or passive seismic well) on the same pad or surface facility lease if the following conditions are met: Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 2 of 13

3 Add the following wording after For all other wells on the pad, acquiring logs for the surface interval is not required. The existing wording is ambiguous and could be interpreted in different ways by different operators. Suggested supplemental wording removes that ambiguity. 3. Logging of observation wells The statement All non-licensed observation wells should be logged. Why is this requirement in this directive? How does AER manages these non-licensed observation wells? 4. Vertical and deviated wells vs. horizontal wells Vertical and Deviated Wells and Horizontal Wells More details around the designation of the wells covered in these two sections are required. There is also uncertainty as to whether these designations also apply to the different sections of the well (i.e., vertical/build/lateral sections). Providing greater details will encourage more consistent interpretation by operators making compliance and enforcement, if required, easier to obtain. Shell Canada Shell Canada Added the following under section 3.3.2, Multiwell Pad: For all other wells on the same pad, acquiring logs over the surface casing interval is not required. As indicated in section 1.4, the terms recommends, and should indicate recommended practices and are not subject to enforcement action. The AER recommends that licensees log all non-licensed observation wells. The well designation of vertical, deviated, or horizontal is specified by the licensee at the time of licensing or when submitting information through the Digital Data Submissions system. 5. Regulatory objectives Provide a listing of required petrophysical parameters within the directive either as a footnote or within the section directly. Not enough information has been provided in the draft directive to ensure consistent interpretation of petrophysical parameters. Shell Canada The AER has chosen not to provide a list of required petrophysical parameters in the directive because providing such a list may limit the approaches industry uses to obtain log data. The directive requires industry to gather and submit appropriate well log data to determine lithology, fluid, and porosity. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 3 of 13

4 6. Logging of vertical and deviated multiwell pads full logging required on first well on the pad or any well on the pad (2) stipulates 1st well on pad must have acceptable lithology, fluid, porosity log but (3) indicates that logged well must be equivalent to deepest zone penetrated on the pad. What if the deepest zone to be penetrated isn t drilled in the first well, but is planned for a later phase of the pad drilling? Specify that if a multipad well that will penetrate the deepest zone on the pad isn t the 1st well on the pad, then the 1st well on the pad can apply for a waiver to defer litho / fluid / poro logging until the deeper well is drilled. Maybe require that the deeper well be licensed in order to secure the logging waiver for the 1st well. This would eliminate the costly effort of having to run pipe-conveyed logging tools in the first well and a later deeper well on the same pad. The later logging of the deeper well would achieve the goal of the directive as described in 1.2 which is to ensure that there is logging coverage of the zones. Suncor Energy Changed For the first well on the pad to For at least one well on a multiwell pad, the licensee must take an acceptable log to determine the lithology, fluid, and porosity of the strata from the total depth of the well to the base of surface casing and record all pertinent data. Added: 2) Log coverage specified in (1) must be obtained over the full stratigraphic section penetrated by the wells on the pad (from the deepest formation to base of surface casing). Added: 3) If additional well(s) are drilled from a previously existing pad and penetrate deeper zone(s) that were not previously logged, additional well logs must be taken over these zones to determine the lithology, fluid, and porosity of the strata not previously logged. Added: The AER strongly recommends the licensee not leave the open-hole measurement of the lithology, fluid, and porosity to the last well on the pad due to the possibility of encountering unforeseeable technical/operational problems that could prevent acquiring these logs on the last well. To reduce the number of waiver applications, an alternate wording is suggested: For at least one well on a multiwell pad or lease, the licensee must For clarity in subsections (2), (3) and (4) of 3.3.2, it is suggested to replace all instances of total depth with Total Vertical Depth (TVD). Nexen Energy ULC Changed For the first well on the pad to For at least one well on a multiwell pad, the licensee must take an acceptable log to determine the lithology, fluid, and porosity of the strata from the total depth of the well to the base of surface casing and record all pertinent data. Nexen Energy ULC Added: 2) Log coverage specified in (1) must be obtained over the full stratigraphic section penetrated by the wells on the pad (from the deepest formation to base of surface casing). Added: 3) If additional well(s) are drilled from a previously existing pad and penetrate deeper zone(s) that were not previously logged, additional well logs must be taken over these zones to determine the lithology, fluid, and porosity of the strata not previously logged. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 4 of 13

5 For ) Add the following wording after pertinent data. For multiwell pads drilled using batch drilling the licensee must take an acceptable log, as above, on the most valuable well drilled. The practice of using a batch drilling process for multiwell pads has not been accommodated for in the existing wording. The suggested additions will provide clarity and direction to those operators using the batch process. In batch drilling all of the surface holes are drilled first, then the intermediate section on each hole and finally the horizontal section of each. The order of wells may not be sequential so the first to have the surface hole drilled may be the 3rd for the intermediate section and 2nd for the horizontal section. Provide a special provision which allows the operator to log the most valuable well instead of just the first one drilled, regardless of the use of batch drilling. Logging of the first well on the pad would not necessary mean logging the most valuable well. Being able to log the most valuable well would give the operator and AER the best possible information. Not drilling the most valuable well first could arise due to pad or well design, penetration depth, or other operations planned for the well (coring, micro seismic, production logging, etc.). Shell Canada Changed For the first well on the pad to For at least one well on a multiwell pad, the licensee must take an acceptable log to determine the lithology, fluid, and porosity of the strata from the total depth of the well to the base of surface casing and record all pertinent data. Added: 2) Log coverage specified in 1) must be obtained over the full stratigraphic section penetrated by the wells on the pad (from the deepest formation to base of surface casing). Added: 3) If additional well(s) are drilled from a previously existing pad and penetrate deeper zone(s) that were not previously logged, additional well logs must be taken over these zones to determine the lithology, fluid, and porosity of the strata not previously logged. Added: The AER strongly recommends the licensee not leave the open-hole measurement of the lithology, fluid and porosity to last well on the pad due to the possibility of encountering unforeseeable technical/operational problems that could prevent acquiring these logs on the last well. The total depth of the logged well must be equivalent to the total depth of the deepest zone penetrated by all wells on the pad. Shell suggests the AER indicate the outcome it hopes to achieve with the total depth criteria and allow the operator to determine which well on the pad would best serve the needs to the AER towards that outcome. The existing wording appears to be inconsistent with the requirement in section since the first well on the pad may not be the deepest drilled. If wells are completed in different zones then the deepest zone penetrated by all the wells may not actually be the deepest zone penetrated by a single well. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 5 of 13

6 For the first well on a multiwell pad, the licensee must take an acceptable log to determine the lithology, fluid, and porosity of the strata from the total depth of the well to the base of surface casing and record all pertinent data. Would this still be required if there is an existing vertical well with logs? Pennwest If the pre-existing vertical well is fully logged (has an acceptable well log to determine lithology, fluid, and porosity) and is on the same pad, no additional logs to determine lithology, fluid and porosity would be required. For multiwell pads in which one or more vertical/deviated wells and one or more horizontal wells are drilled, the vertical/deviated wells on the pad are subject to section 4.3. All horizontal wells on the pad are subject to section 5.3. For additional information, see the section on waivers as well as the figures at the end of the directive. 7. Horizontal wells clarification needed Clarification required. Horizontal Wells: Does this mean that for all horizontal wells, regardless of Lahee designation or pool designation, no other logging services are required for the horizontal, build and vertical sections? If so, then no open hole logging waiver will be required if conditions outlined in section 4 are satisfied? In section 4.3, include (3) Horizontal wells do not require services and measurements as outlined in section 3.3.3, except for those stated in sections 4.3(1) and 4.3.(2). Provide an unambiguous statement as to when, or if, an open waiver is required for any section of the well being drilled. Husky Energy Logging waivers will not be required if the minimum requirements in section 5.3 are met. Added (drilled from single well pads and multiwell pads), regardless of Lahee to For all horizontal wells, (drilled from single well pads and multiwell pads), regardless of Lahee, the licensee must, at a minimum, take an acceptable well log to measure the gamma ray of the strata from the total depth of the well to the base of surface casing. Sample diagrams (figures) provided at the end of the directive. 8. Substitution of acceptable well log types The well licence may not be available 30 days prior to planned well logging operations. Remove must in second paragraph. Many wells do not have 30 days between the licence application, the licence approval, and the logging operations beginning. Devon Canada Changed from 30 days in advance to the following: To ensure the application is reviewed before planned commencement of the logging program, the application must be submitted 30 days in advance or as soon as a well licence is obtained, which ever occurs later. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 6 of 13

7 9. Waivers If there is already a pre-existing well in the same section as the proposed multi-well pad and this well penetrates the deepest zone targeted by the multi-well pad and this pre-existing well has acceptable litho / fluid / poro logging, then there shouldn t be a need for any well on the multi-well pad to have the required litho/fluid/poro logging. Modify the directive to allow for waivers of the required logging if a pre-existing well meets the criteria described in The purpose of the directive is to ensure adequate log evaluation coverage exists as described in 1.2. If this can be achieved through preexisting well control, then the multi-well pad logging seems redundant. Retain the ability to apply for logging waivers, if the well was not the first one on a section, from the previous directive. Suncor Energy Shell Canada Added a section to address waivers based on pre-existing offset well log data (section 6.2). In the oil sands, we obtain waivers to log the horizontal wells on the pads due to the large number of fully logged core holes and observation wells in close proximity to the pads. It would be preferred to indicate that the presence of a logged well close to the pad would meet the requirements of this section, however it may be difficult to clearly define how close that well must be. Suggested wording may be: For at least one well on a multiwell pad or lease, the licensee must take an acceptable log to determine the lithology, fluid, and porosity of the strata from the total depth of the well to the base of surface casing and record all pertinent data. The logged well may be from another well on the same pad or lease (evaluation well or passive seismic well or an existing well). Nexen Energy ULC Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 7 of 13

8 Waiver may be granted as a result of unplanned technical or operational event that inhibits logging. Since these events are unplanned it is often not possible to determine when this might happen and timeliness of response on a waiver is critical to safely concluding the operations. How can it be ensured that a quick response of a logging waiver request is achieved? Specify the protocol that can be used to get a decision on a waiver that is timely in order to deal with unplanned events. Safe operations at a well site often require quick decisions and any significant delays in a response could jeopardize such operations. I noticed that there is no reference made to the rule of thumb we ve been working under, that if a modern set of offset logs exist in the same section that covers the same intervals, then an open hole waiver may be granted (Dev NC).Will this still be the case, or does this change? Suncor Energy Husky Energy Added a section to address waivers based on technical or operational circumstances (section 6.1). Added a section to address waivers based on pre-existing offset well log data (section 6.2) Will logging waivers for horizontal wells still be required? Harvest Energy No, logging waivers will not be required for horizontal wells if the minimum requirements in section 4.3 are met. 10. Reporting of well logs acquired Currently the 'WellLogSummaryReport' is fairly detailed; certain information is technical and long to fill out. Example # 5 Well TVD will be challenging for analysts to identify. As well 'Log Top Depth' and 'Md/Tvd' and Logging Run No' will be difficult for analysts to fill out, if enforced this would entail the vendors or geologists to fill out due to some technical information required. Could some of the information be waived or optional? What is the benefit of requiring this extent of technical information as it will be directly on the log once received? address is not included. Provide address for form submission. Devon Canada The AER requires a record of all well logs acquired at the well to ensure that all logs taken are submitted to the AER. The information in the log summary report is necessary to cross check for compliance with the requirements. Removed well TD, well TVD, and log start run date from the well log summary report. Well log summary reports are to be submitted on CD or DVD, similar to the submission for raster and LAS well logs. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 8 of 13

9 The trigger for the timing requirement, associated with reporting for multiwell pads, was not indicated. Add the following text to section 6.1: In the case of multiwall pads, the 30 day reporting requirement commences at the release of the rig from the pad. The existing wording in the directive could be interpreted as having the 30 days starts with rig release from the well or the pad. The suggested wording provides clarification for multiwell pads as well as consideration for operators using a batch drilling process. Is the summary report required to be submitted prior to the log submissions or with the log submission? Shell Canada Added under section 7.2, In the case of multiwell pads, the one-month time period starts on the date the rig was released from the pad. Both are acceptable. 11. Submission of well logs (section 6.3) I strongly suggest the Board make it a requirement for licensee s to submit any and all logs run in any type of wellbore, vertical, deviated, or horizontal whereby the logging information is available and readily accessible. Licensees may not be required but instead choose to run logs such as geological striplogs, open-hole logs, casedhole logs etcetera and this data although not a requirement may be of importance to other operators and assist in the geological understanding of a formation. Please consider this in the draft directive. TriOil Resources Ltd. Moved the requirement The licensee must submit to the AER a copy of all the well log data acquired at the well, as stipulated in the OGCR, section from the reporting and submission of well logs section to the general requirements section at the beginning of the directive. Added This requirement pertains to any and all logs acquired at the well, regardless of whether or not the acquired logs were required to be taken. This includes open-hole logs, cased-hole logs, mud logs, strip logs, lithology logs, hydrocarbon logs, rate-of-penetration measurements, mud-gas detector readings, and cuttings descriptions. 12. Submission file format TIFF and PDF TIFF or PDF file type for logs. (The TIFF requirement has been generated by wireline companies for multiple years but directional companies providing only gamma logs have never done this. If the purpose for this change is to reduce paper format data submissions what is the difference between a PDF and TIFF as both contain the imaged data? This just adds additional costs for directional companies as we have to find/purchase software that will make a TIFF file.) Mostar Directional Technologies Inc. Added under the submission of well logs and summary reports section, PDF file format for raster logs. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 9 of 13

10 We provide only gamma logs and normally we provide a LAS and PDF of the log. I converted the PDF to TIFF and it results in multiple pages to make up the image log. I m not sure if we can make one TIFF file for the entire log. Will this be acceptable? Why can we not stay with a PDF file format (attached) of the log since it is still digital? Why is the TIF format required over PDF? PDF is still easier to view. Mostar Directional Technologies Inc. Mostar Directional Technologies Inc Raster logs may be submitted in TIFF or PDF. Why wouldn t the AER accept PDF files of the well log in the CD? Accept PDFs and TIFFs for strip logs. The program PowerSuite/Powerlog by Trivision Geosystems at this point in time does not produce TIFF files for the striplog. The only way to do this is to download a free PDF to TIFF convert, print the striplog in PDF format and convert it to a TIFF. The issue with this is the convertor program only creates pages in 8½ x 11 and cannot produce a continuous page as stated in the directive and also to load into geoscout. Any software program is expensive to purchase and time consuming to learn it, these well site geologists will just wait for a new update to come out rather than switching to Wellsight Systems where it can create continuous TIFF. It will more than likely take a fair amount of time for Trivision to develop the update to allow for the creation of a TIFF directly from the program in a continuous format. In the meantime, there is no way possible that I have come across talking to many individuals, to produce a continuous striplog in PowerSuite/Powerlog. Trilogy Energy Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 10 of 13

11 13. Submission of Well Logs CD or DVD label Las disc contact information required to be listed, the contact name, phone number and address would not be optimal for industry to list personal information on corporate data. A generic address, company switchboard phone number and name of department would be more suitable in order to avoid personal information listed on the las. Can the required information on the CD label be put on the CD pocket/protective case? The CD or DVD must be labelled with ICD Data Collection, licensee name, contact name, and contact phone number or address. Licensees may use a department or group name, phone number, and address in place of a specific individual. Yes, but the CD must also be labelled with the appropriate contact information in case the CD becomes separated from the case. 14. File naming convention Naming requiring 'WL' incorporated there is no value for industry to incorporate in their naming convention could this be removed to allow the naming convention to be shorter? Can the AER change the (/01) to the valid event sequence (ie /02) for both TIFF and LAS file name examples in the finalized version of this directive? The WL naming convention is to assist the AER in distinguishing well log files from such files as the log summary reports and core analyses received by the AER. Examples provided have been changed to replace the invalid /01 event sequence with a valid /02 event sequence. Note that these examples are for demonstration purposes only. The example of the file naming UWI has an event sequence of 01. This is not an acceptable event sequence. Follow a real example as UWI are currently assigned. This is explained in the FAQ, but it would be better to follow current UWI standard. Change example to follow current UWI standards. The naming convention for LAS and TIFF well log files UWI (20 expanded with dashes) will not match the UWI (16 compressed) in the header of the LAS files. Have the file name and the header follow the LAS 2.0 standard (16 compressed). Follows a single standard well adopted in the industry and removes 4 digits from the file name. For example, W402. Devon Canada Devon Canada AER s file naming convention applies to both TIFF and LAS logs, and our system is designed to support the file name as defined in the directive. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 11 of 13

12 A reference number will difficult to track down as numerous log errors come in for separate logs or come in as batch log errors for multiple logs at a time. Resubmission of the logs would indicate it is revised, could the electronic logs be printed with 'REVISED' on the header to indicate the revised logs rather then incorporating a reference number for every log revised. Cenovus Energy Inc, Added section to address revised well logs. If a resubmission is requested in response to a letter of noncompliance received from the AER, a reference number will be provided in the letter and that reference number needs to be included in the file name to ensure proper processing. If a licensee initiates the resubmission of a log, the file name needs to include revised to ensure proper processing 15. General questions After the well log directive is enforced will paper copies no longer be required to be submitted? Is there a plan for AER to accept electronic logs via the DDS system or ? If so, what is the timeframe for implementing that? Our group feels that submitting logs via the DDS system or is a more efficient way than the CD. When the directive comes in effect, what would be the submission process for logs conducted prior to the directive implementation date? Is the new directive going to be a go forward process? Do older logs submissions have to follow the new process? As per Bulletin : Well Log Submission Requirements, once the well logging directive is in effect, all well logs must be submitted in electronic format, and the AER will no longer accept paper well log submissions. At this time, all well log files must be submitted on CD or DVD. The AER has no set timeframe to implementing a more direct electronic submission method. The licensee will be notified that well logs in paper format are no longer acceptable. The licensee will be requested to resubmit the log as per the requirements in the well logging directive. The submitted paper well log will be destroyed. If the well log is not resubmitted in electronic format on CD or DVD within 30 days of being notified, a Notice of Low Risk Noncompliance will be issued to the licensee. In this draft directive, the AER didn't mention the deadline for cased-hole log submission. What is the timeline for a company to have the cased-hole log submitted? Cased-hole logs are considered to be additional logs and are subject to the OGCR, section (1)(c), which states within one month of the run date, submit to the Regulator any additional logs, including flow meter logs and related analysis, taken at the well after the original logging operation. Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 12 of 13

13 Sounds like you are suggesting one fully logged well/pad for a pad-drilled project. Does this become one fully logged vert or dir strat per pad for a horizontal project? Harvest Energy For horizontal wells, the AER does not require one fully logged vertical or directional stratigraphic well per pad. The licensee determines the most appropriate well orientation for all wells on the pad. For multiwell pads on which one or more vertical/deviated wells and one or more horizontal wells are drilled, the vertical/deviated wells on the pad are subject to section 4.3 of the directive. All horizontal wells on the pad are subject to section 5.3 of the directive. See the figures in the directive. Also, appears you will be requesting GR surface csg. seat TD for horizontal wells. We currently run GR from kick off point to TD and cased-hole GR-Neutron freefall point to surface. I assume that will qualify? Harvest Energy Yes, that would qualify. Beside TIFF and LAS, can we have other files on the CD? I.e. HLG file (supporting documents for the LAS file). If service companies provide additional files to support the logs, our group will have to remove those extra files and re-burn the CD for the submission. This process will create lots of extra work. You may submit additional files; however, the AER will only manage the data that have been submitted as requested. Other data on the CD will not be accepted as formal submissions to the AER (e.g.,directional survey). Draft Directive 080 (June 2013) Stakeholder Feedback and AER Response 13 of 13