Reference
Currently the Russian law on minerals does not make it possible to clearly qualify formation waters when extracting hydrocarbons from rock beds as included, or not included, in production waste.
In this regard, Government environmental control officials interpret formation water reinjection into the rock bed as disposal of waste produced during hydrocarbon extraction, which entails a payment for environmental pollution by a company conducting waste disposal.
Meanwhile, according to global and domestic experience, disposal of mineralised formation water in the rock bed after separation from hydrocarbons is used as a priority environmental measure aimed at reducing the negative effects of these waters on the environment and to support the technological process of hydrocarbon extraction from the subsoil.
Reinjection of formation waters into the rock bed is included in the project documentation for developing hydrocarbon fields, which is subject to relevant expert review and approval by authorised agencies.
The draft law extends the type of subsoil development “exploring and extracting minerals including using the waste of mining and relevant processing facilities” (Article 6 Clause 3 of the Russian Federation law On Minerals) with the words “disposal of formation waters and waters used by subsurface users for their own production and technological needs in the rock bed”.
The adoption of the draft law will make it possible to prevent the possibility of qualifying formation waters as production waste when extracting hydrocarbons. The adoption of the draft law will make it possible to simplify excessive administrative procedures and exclude any unsubstantiated extension of financial burdens on subsurface users conducting reinjection of formation waters in the bed rock as distinct from the activity concerned with treating production and consumption waste.
The draft law was debated and approved at the Russian Federation Government meeting on 7 November 2013.
