Class I Fluid Disposal

Timeline

Our estimated processing time for this application is 75 business days. See our timeline spreadsheet for updates.

Purpose of the Application

We classify disposal wells based on their injection fluid type. Our classification system is described in Directive 051: Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements.

Companies must apply to use an approved Class I disposal well. Class I fluids include

• Class Ia fluids: nonoil field wastes, and
• Class Ib fluids: specific common oilfield wastes or a mixture of oilfield and nonoil field wastes.

With our approval, companies can dispose of Class I fluids in underground formations or depleted hydrocarbon pools for reasons other than enhanced recovery or gas storage. There must be no impact to public safety and no adverse effects on the environment in the surrounding area.

Process Checklist

Before Applying

To be approved, Class I fluid disposal applications must meet our technical and safety requirements in the following documents:

• Directive 051: Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements
• Directive 056: Energy Development Applications and Schedules 
• Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry 
• Directive 065: Resources Applications for Oil and Gas Reservoirs
• Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry
• Oil and Gas Conservation Act, section 39(1)(c), (d)

Wells used for fluid disposal do not have to be drilled before submitting a Class I fluid disposal application. If the fluid disposal well has not yet been drilled, an optional two-step application process may be used in which the fluid disposal application under Directive 065 must be accompanied with an application for a well licence under Directive 056, either by submitting the applications at the same time or by submitting the Directive 065 application after the Directive 056 application has been submitted or approved. 

In the first step of the optional process, we will review the Directive 056 application, if not already approved, and the Directive 065 application to confirm that they meet our requirements. If the applications meet our requirements and we issue a well licence, we will issue a provisional Directive 065 approval for the disposal project that is subject to certain conditions. One of the conditions will require the operator to submit penetration data for the candidate fluid disposal well under a separate Directive 065 application. In the second step of the process, we will review the well penetration data to confirm the geological interpretation of the target formation and its suitability for fluid disposal. Once we have confirmed the formation’s suitability, we will issue the final Directive 065 approval. If this process is not used, the regular fluid disposal application process under Directive 065 must be used, which requires the candidate fluid disposal well to be drilled before application.
 

Submit an Application

Companies must submit Class I fluid disposal applications through our Digital Data Submission (DDS) system. Our detailed checklist document can be referenced to ensure that applications are complete. We will register each application and assign it a reference number.

By submitting an application, the company accepts that all materials related to the application are no longer confidential.

Review Process

1. We share all applications on our Public Notice of Application page to notify the public of applications that have been filed with the AER.
2. Anyone who believes that they may be directly and adversely affected by an application can file a statement of concern (SOC). If we receive an SOC, it may take us longer to process the application.
3. We will assign the application to a subject matter expert for initial review. If information is missing (i.e., the application is not complete), we will close the application. Otherwise, we will proceed with a full technical review. In our review, we look at our requirements, including
   • whether the applied-for well or facility site falls within an area covered by the Lower Athabasca Regional Plan or the South Saskatchewan Regional Plan. If so, our review will be more stringent;
   • whether the applicant holds mineral rights to the proposed disposal zone, or the requisite disposal consent has been secured from the current mineral rights holder;
   • whether the proposed disposal fluids contains acid gases or H₂S (to comply with Directive 071);
   • whether the wellbore integrity of the proposed disposal well is suitable for the proposed operation (to comply with Directive 051);
   • whether the receipt and injection of Class I fluids is permitted (to comply with Directive 058);
   • whether the proposed maximum wellhead injection pressure is appropriate for the operation. The safety factor on the estimate of the formation fracture propagation pressure must be applied at the sand face (bottom hole) for all disposal wells;
   • whether the Crown has been sent a letter of indemnification as it pertains to the proposed disposal activities, if on Freehold lands;
   • whether depleted hydrocarbon pools or their associated aquifers are the disposal zone. If so, the reservoir pressure history of the pool should be included in the application. The maximum operating pressure (maximum average reservoir pressure) must not exceed the initial pressure of the pool; and
   • whether the application has fulfilled notification requirements in Directive 065, specifically the following:
     • Landowners and occupants within a 0.5 km radius from the proposed disposal well have been notified.
     • Licensees of all wells (including abandoned wells) within a 1.6 km radius have been notified. This is a minimum requirement and could expand depending on the estimated fluid and pressure plume areas of influence.
4. We may request additional information (through a supplemental information request) to complete our technical review.
5. We will decide to approve, close, or deny the application. If we close it, the applicant may reapply without prejudice.
6. We will provide the applicant with a link to the letter with our decision, which is accessible through the Integrated Application Registry. We will also share our decision on our Publication of Decision page.