Alberta Disposal Applications: Common Questions Before You Start

​

Disposal wells provide a safe and regulated method of permanently injecting approved waste fluids into suitable underground formations. They are an essential part of oil and gas operations, allowing produced water and other approved fluids to be managed while protecting groundwater resources, hydrocarbon reservoirs, and the environment.

​

Although the approval process may appear straightforward, successful applications require much more than completing regulatory forms. A strong application demonstrates that the selected disposal interval is geologically suitable, the wellbore is mechanically sound, injection operations can be conducted safely, and all applicable regulatory requirements have been addressed.

​

This guide provides an overview of Alberta disposal well applications, including approval types, technical requirements, common deficiencies, and practical considerations based on years of regulatory consulting experience.

​

Approval Types

​

Before preparing an application, the first step is determining exactly what approval is required. Different projects may follow different regulatory pathways depending on the proposed operation.

​

Common disposal projects include:

​

• New disposal schemes

• Adding a disposal well to an existing approved scheme

• Amending an existing disposal approval

• Converting an existing well to disposal service

• Changing the approved disposal interval

• Modifying approved operating conditions

 

Selecting the correct approval pathway early in the project helps avoid unnecessary revisions and regulatory delays.

​

Application Process

​

While every project is unique, most disposal applications follow a similar sequence.

​

Step 1 – Define the Project

​

Clearly identify the project objectives, proposed disposal well, disposal formation, fluid source, and expected operating conditions.

​

Step 2 – Collect Supporting Data

​

Gather the geological, engineering, wellbore, land, and operational information required to evaluate the project.

​

Step 3 – Complete Technical Evaluations

​

Review the suitability of the disposal interval, evaluate wellbore integrity, confirm operating pressures, and complete any required engineering or geological assessments.

​

Step 4 – Regulatory Review

​

Prepare the application package and complete any required stakeholder notification before submitting the application.

​

Step 5 – Regulator Review

​

The regulator reviews the application and may request clarification or additional technical information before issuing an approval.

​

Data Requirements

​

Successful disposal applications begin with complete and accurate information.

​

Typical information includes:

​

• Proposed disposal well UWI

• Existing approval number (if applicable)

• Disposal formation

• Top and base of the disposal interval

• Proposed perforation interval

• Fluid source

• Fluid composition

• Expected injection pressure

• Expected injection rate

• H₂S information

• Wellbore schematic

• Completion reports

• Casing and cementing records

• Historical logs and testing

• Land ownership

• Mineral ownership

• Offset operator information

 

Providing complete information early in the project allows technical evaluations to proceed efficiently and reduces the likelihood of regulator requests for additional information.

​

Geological Requirements

​

A disposal application should demonstrate that the proposed disposal interval is suitable for long-term injection.

Typical geological evaluations may include:

​

• Disposal formation characterization

• Reservoir continuity

• Reservoir quality

• Formation thickness

• Vertical containment

• Lateral containment

• Existing injection history

• Offset well review

• Pressure depletion or pressure support

• Structural considerations

• Fault evaluation (where applicable)

 

The level of geological support required depends on the complexity of the project and the characteristics of the proposed disposal interval.

​

Engineering Requirements

​

Engineering evaluations focus on demonstrating that the proposed operation can be conducted safely while maintaining long-term well integrity.

​

Typical engineering considerations include:

​

• Wellbore integrity

• Completion design

• Tubing configuration

• Packer design

• Injection pressure limits

• Injection rates

• Surface equipment

• Pressure monitoring

• Mechanical integrity

• Long-term surveillance requirements

 

Engineering assessments should clearly demonstrate that the well is suitable for the proposed operating conditions.

​

Regulatory Requirements

​

Disposal well applications must satisfy all applicable regulatory requirements.

 

Depending on the project, this may include:

• Directive 051 well requirements

• Wellbore integrity evaluations

• Cement Bond Logs

• Casing Inspection Logs

• Packer Isolation Tests

• Completion records

• Historical testing information

• Conversion requirements

• Existing approval conditions

 

The specific regulatory requirements depend on the well, proposed operation, and project scope.

​

Stakeholder Engagement

​

Many disposal applications require notification or consultation with potentially affected parties.

Depending on the project, stakeholder engagement may include:

​

• Offset operators

• Mineral owners

• Surface owners

• Indigenous consultation (where applicable)

• Regulatory notification requirements

 

Addressing stakeholder concerns early often results in a smoother review process and fewer delays.

​

Common Deficiencies

​

Many disposal applications are delayed because key technical information is incomplete or missing.

Some of the most common deficiencies include:

​

• Incomplete geological justification

• Missing formation tops or bases

• Missing perforation information

• Inadequate containment evaluation

• Missing wellbore integrity information

• Incomplete casing or cementing records

• Missing Directive 051 requirements

• Inadequate H₂S assessment

• Incomplete engineering justification

• Missing stakeholder documentation

• Late project changes after the application has been submitted

 

Completing a thorough technical review before submission significantly reduces the likelihood of regulator questions and application delays.

​

Frequently Asked Questions

​

How long does it take to obtain a disposal approval?

​

Approval timelines vary depending on project complexity, application completeness, stakeholder notification requirements, and regulator workload.

​

Can I add another well to an existing disposal scheme?

​

In many cases, yes. However, the regulator must be satisfied that the additional well is appropriate within the existing approval and that all technical requirements have been addressed.

​

Does every disposal application require stakeholder notification?

​

Not always. Notification requirements depend on the project type and applicable regulatory requirements.

​

Does H₂S affect a disposal application?

​

Yes. The presence of H₂S should be identified and appropriately addressed within the application, even where only trace concentrations are expected.

​

What information should I gather before starting?

​

Operators should have basic geological information, wellbore records, completion information, expected operating conditions, fluid characteristics, and available historical testing before beginning the application process.

​

What type of disposal approval do we need?

​

The approval type depends on the fluid being injected, the proposed disposal zone, the well configuration, and whether the project is a new scheme, an amendment, or an additional well to an existing scheme.

Common disposal applications include:

​

• Class II produced water or brine-equivalent disposal

• Class I waste disposal

• Class III acid gas disposal

• Class III CO₂ sequestration

• Class IV injection or disposal, where applicable

• Amendments to existing disposal approvals

• Adding a well to an existing disposal scheme

 

The disposal class should be confirmed early because the application requirements, notification requirements, logging requirements, and long-term monitoring obligations differ by class. Directive 051 classifies wells based on the characteristics and types of fluids being injected or disposed, and Directive 065 applies those classifications to disposal scheme applications.

​

What information should we gather before starting a disposal application?

​

At minimum, operators should gather:

• Proposed disposal well UWI

• Existing disposal approval number, if applicable

• Proposed disposal formation

• Top and base of the disposal zone

• Proposed perforation interval

• Disposal fluid type and class

• Expected injection rate

• Expected injection pressure

• Proposed MWHIP

• Wellbore schematic

• Casing and cementing records

• Completion reports

• Available logs and tests

• H₂S information

• Fluid composition

• Mineral rights information

• Offset well and offset operator information

• Land and stakeholder information

 

Directive 065 requires the application to describe the disposal scheme, including the well identifiers, disposal zone top and base, disposal perforations, disposal fluid class, anticipated daily disposal volumes, and production packer depth.

​

What geological information is required?

​

A disposal application should include enough geological information to show that the proposed disposal zone is suitable and that injected fluids will remain confined to the approved interval. Typical geological requirements include:

​

• Geological discussion of the proposed disposal zone, base, and caprock

• Structure map of the disposal zone

• Isopach map of the disposal zone

• Isopach map of the confinement strata

• Interpreted and annotated log cross-section or representative well logs

• Stratigraphic interpretation of the zones of interest

• Fluid interface interpretation, where applicable

• Discussion of continuity, thickness, lithology, and integrity

• Discussion of fractures or faults, where applicable

• Area review of offsetting wells

 

Directive 065 specifically identifies structure and isopach maps, an isopach map of the confinement strata, and an interpreted and annotated log cross-section or representative well logs as part of the containment requirements.

​

Who needs to be notified for a disposal application?

​

Notification depends on the type of disposal application.

For disposal applications other than Class I waste disposal and acid gas disposal, the minimum notification list includes:

​

• Unit operator, if applicable

• Approval holder of the scheme, if applicable

• All well licensees, including licensees of abandoned wells

• Holders of Crown agreements or authorizations to sequester CO₂

• Geothermal lease holders

 

The notification area is generally a 1.6 km radius from the proposed disposal well where the proposed disposal zone is known to be present.

​

For Class I waste disposal, the minimum notification list is broader and includes both industry and public notification. Industry notification includes the unit operator, scheme approval holder, well licensees including abandoned wells, mineral lessees, mineral lessors, holders of Crown CO₂ sequestration agreements or authorizations, and geothermal lease holders. Public notification includes landowners and occupants. Directive 065 identifies a 1.6 km radius for the disposal zone and a 0.5 km radius from the proposed disposal well for landowners and occupants.

​

For acid gas disposal, notification includes the unit operator, scheme approval holder, all well licensees including abandoned wells, mineral lessees, mineral lessors, holders of Crown CO₂ sequestration agreements or authorizations, and geothermal lease holders. If injection is into a depleted hydrocarbon pool, the area is the AER-designated pool. If injection is into an aquifer, the area is generally a 1.6 km radius from the section containing the disposal well in the target zone.

​

What mineral rights or authorization is required?

​

The applicant must have the right or authorization to dispose into the proposed zone.

If the operator does not own or control the mineral rights for the proposed disposal zone, additional authorization is required. Directive 065 identifies the acceptable authorization by land type:

​

• Unleased Crown land: valid Crown authorization

• Crown land leased by another party: consent from the leaseholder or a valid Crown authorization

• Freehold lease land: consent from the freehold mineral holder

 

For CO₂ sequestration and acid gas disposal, the right to inject CO₂/acid gas into the proposed zone must be secured before the Directive 065 application is submitted.  For acid gas disposal, this involves submitting a small scale and remote sequestration tenure application to Alberta Energy.  

​

Is a Crown Mineral Activity authorization required?

​

Where the disposal rights are open Crown, a Crown Mineral Activity authorization should be confirmed before proceeding. For Class I, Class II, and Class IV disposal wells, this should be addressed as part of the land and authorization review before the Directive 065 application is submitted.

​

For Class III acid gas and CO₂ disposal projects, operators should confirm the required Alberta Energy and Minerals tenure or authorization before the D065 application. Directive 065 states that for a new acid gas scheme, or an amendment that increases cumulative fluid disposal volume with additional captured CO₂ volumes, tenure must be granted by Alberta Energy and Minerals. For CO₂ sequestration, the right to inject must be secured before application submission.

​

Do Class III acid gas and CO₂ disposal wells need Alberta Energy approval first?

​

Yes. For Class III acid gas and CO₂ disposal projects, confirm the required Alberta Energy and Minerals tenure, Crown agreement, or authorization before preparing the Directive 065 application.

For CO₂ sequestration, Directive 065 requires evidence that the applicant has the right to inject captured CO₂ into the proposed zone before the application is submitted. For acid gas schemes involving new captured CO₂ volumes, Directive 065 states that tenure must be granted by Alberta Energy and Minerals.

 

How close must the packer be to the disposal perforations?

​

As a practical application review item, the packer depth should be checked carefully against the shallowest disposal perforation.

​

For disposal wells, the packer is typically expected to be set no more than 15 metres above the shallowest disposal perforation, unless there is a clear technical reason for a greater separation. If a greater distance is proposed, the application should explain why the packer placement is appropriate and how containment and wellbore integrity will be maintained.

​

Directive 051 requires packers to be placed in accordance with the Oil and Gas Conservation Rules, and Directive 065 requires the disposal application to include the depth of the production packer.

​

How much cellar is acceptable below the disposal perforations?

​

The cellar below the disposal zone perforations should also be reviewed carefully.

As a practical rule, the cellar below the disposal perforations is typically expected to be no more than 15 metres, unless there is a good technical reason for a greater interval. If a longer cellar is proposed, the application should explain why it is necessary and demonstrate that it does not create an unacceptable containment, isolation, or wellbore integrity concern.

​

This should be reviewed alongside the wellbore schematic, casing details, cementing records, perforation interval, and Directive 051 logging requirements.

​

How long must the initial packer isolation test be?

​

The initial packer isolation test is 15 minutes, not 10 minutes.

​

For well classes I through III, Directive 051 requires an initial pressure test of the casing or tubing-casing annulus to a minimum pressure of 7000 kPa for 15 minutes before starting injection or disposal operations. The initial packer isolation test is considered successful when the required pressure is applied and maintained for at least 15 minutes, with variations not exceeding 3% of the applied pressure.

​

What if the Directive 051 work is not complete before the D065 approval?

​

Directive 065 allows for the possibility that a disposal approval may be issued before the Directive 051 information is complete, but the approval will contain a clause requiring the Directive 051 information to be submitted within three months of the approval date.

​

If the Directive 051 requirements are not submitted within the required timeframe, or an approved extension is not obtained, the AER may rescind the approval or the portion of the approval relating to the subject wells.

​

What additional requirements apply to Class III acid gas disposal?

​

Class III acid gas disposal applications require significantly more support than a typical Class II produced water disposal application.

​

Additional items may include:

​

• Site-specific risk assessment

• Geological containment assessment

• Groundwater protection assessment

• Offset wellbore review

• Induced seismicity assessment

• Upper and lower confining interval discussion

• Isopach maps of confining intervals

• Interpreted and annotated cross-section showing continuity and extent of confining intervals

• Fault mapping and containment discussion

• Above-zone monitoring intervals, if required

• SCVF / gas migration plan for applicable wellbores

• Wellbore risk assessment within the projected plume area

• Acid gas fluid properties

• Phase behaviour discussion

• Migration analysis

• Annual progress reporting

 

Directive 065 requires Class III disposal applications to include a site-specific risk assessment addressing hazards such as geological containment, groundwater protection, offset wellbores, and induced seismicity.

​

Is compositional analysis required for injected acid gas?

​

Yes. For acid gas disposal, Directive 065 identifies annual reporting requirements that include:

• Compositional analysis of the injected acid gas

• Mole fraction of H₂S

• Mole fraction of CO₂

• Density of the injected acid gas

• Volume of acid gas injected at standard conditions

• Volume of acid gas injected at reservoir conditions

• Wellhead injection pressure

 

This information should be anticipated early in the project because the acid gas composition affects risk assessment, plume behaviour, phase behaviour, containment, and reporting.

​

What additional requirements apply to CO₂ sequestration disposal?

​

CO₂ sequestration projects require additional technical and tenure support beyond a typical Class II produced water disposal application. Directive 065 requires CO₂ sequestration scheme applications to address:

​

• Storage capacity

• Containment

• Injectivity

• CO₂ plume prediction

• Maximum injection fluid area

• Site-specific risk assessment

• Baseline monitoring conditions

• Remediation strategies in case of loss of containment

• Demonstration that the plume will not interfere with existing use of the underground formation

 

For small-scale and remote sequestration projects where the plume does not exceed 2.5 km around the sequestration well, or where the containment risk assessment is low, Directive 065 states that the applicant is not required to execute or maintain a dynamic simulation model.​​

​

Related Technical Tools

​

• H₂S Release Rate Adjustment Calculator

• Step Rate Test Analyzer (MWHIP)

• Reservoir Analysis Toolkit

• Voidage Replacement Ratio Calculator

 

Need Assistance?

​

Whether you're planning a new disposal scheme, adding a well to an existing approval, converting a well to disposal service, or responding to regulator questions, Benoit Regulatory can assist throughout the project—from initial planning and technical evaluations to regulatory submission and approval.