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' ~ 1 <br /> <br />. - ~ • ~~~ <br /> <br /> <br />Minister of the Environment may request a public hearing, which may be <br />held by the Environmental Assessment Board. The procedure for wells <br />that dispose of brine produced by the creation of storage caverns in <br />salt is the same as for industrial waste wells, but there is no prohibi- <br />tation against the use of the Detroit River Group. In the case of wells <br />used to dispose of oilfield brines or secondary recovery wells, the <br />function of the MOE is limited to a review of the permit application. <br />MOE objections to any aspect of the application are transmitted to MNR, <br />Each agency applies the regulations it has developed to meet its statu- <br />tory obligations, approves applications that conform to the regulations, <br />and advises applicants of the conditions and obligations that accompany <br />the permit. Both agencies make available to applicants public data on <br />oil, gas, and water wells to assist them in preparing applications. <br />In general, pressure limits are not specified in the regulations <br />~ (0. Reg. 152 (MNR) or 0. Reg. 152 (MOE}} which instead adopt the more <br />flexible approach of investing in the Ministers the authority to set <br />pressure limits as necessary. At present, wells that dispose of fluids <br />'. to the Detroit River Group are required by the MOE to maintain a zero <br />gauge flowing pressure (atmospheric pressure) at the wellhead (gravity <br />drive only). The operators of these wells are required by MOE to record <br />each month a 24-hour static water level at least 10 feet (3 m) below the <br />base of fresh water. The MNR has now adopted the gravity-drive only <br />rule for new oilfield brine disposal wells. The MNR does not ordinarily <br />require the monthly shut-in test, but occasionally requests that this <br />test be performed. The fluid-level standards of MOE and MNR do not <br />consider the density of the fluid in the well. As noted elsewhere in <br />this report, the allowable maximum flowing wellhead pressure may be <br />slightly too high to provide a high degree of safety in high-risk areas. <br />The risks have been described in the previous chapter and_ are reviewed <br />below. <br />119 <br />