Who to Notify for Disposal Activities

Overview

Notification is an important part of many disposal applications. Before an application is submitted, the operator should understand who may need to be notified, what disposal activity is being proposed, and whether the notification radius or affected parties change based on the type of disposal fluid.

This guide summarizes the notification considerations shown in the disposal application training video and provides a practical framework for reviewing notification requirements before submitting a Directive 065 application.

When This Process Applies

This process applies when preparing a disposal application, including produced water, saline water, waste gas, acid gas, or other disposal activities that require regulatory approval. Notification requirements may vary depending on the fluid type, disposal zone, offsetting interests, and whether a depleted hydrocarbon pool or aquifer is involved.

Operators should begin by confirming the type of disposal activity and the disposal fluid class. In the training example, produced water and saline water are identified as Class II disposal fluids, gas disposal without H2S or CO2 is identified separately, and potable water is treated differently. The fluid type helps determine the relevant notification category and the parties that may need to be contacted.

Reviewing Directive 065 Requirements

Directive 065 includes notification requirements for different disposal scenarios. The required parties may include the unit operator, approval holder of a scheme, all well licensees including abandoned wells, all mineral lessors, all mineral lessees, and potentially landowners or occupants depending on the scenario.

The notification radius can also vary. For some disposal activities, notification may be based on a radius from the proposed disposal well where the disposal zone is known to be present. For other activities, such as certain acid gas disposal scenarios, notification may be tied to a depleted hydrocarbon pool or to a specific radius from the second section containing the disposal well.

Practical Review Steps

Start by identifying the disposal fluid and disposal interval. Confirm the proposed disposal zone, well location, and whether the application involves an aquifer, a depleted hydrocarbon pool, or another reservoir context. Then review the applicable Directive 065 notification table and identify the parties listed for that application type.

For horizontal wells, consider the wellbore path and the relevant spacing or area of influence. Notification should be reviewed in the context of the actual proposed well and disposal zone rather than relying only on a surface location.

Key Considerations

Do not assume notification requirements are the same for every disposal application. The required parties and radius can change depending on the application type. Operators should document how the notification list was developed and retain records of the parties notified.

Need Assistance?

Benoit Regulatory assists operators with disposal applications, Directive 065 notification reviews, offset assessments, application preparation, and regulatory submissions. If you need help confirming notification requirements for a disposal project, our team can support the review and application process.

Final Review

Before submitting, complete a final review of the notification matrix, mapped area, well list, mineral interest review, and any land or occupant considerations. The application file should clearly show why each party was included or excluded. This helps support the application if the regulator asks how the notification list was developed.