Regulatory Intelligence
When does a single well battery need a facility licence?
Category:
Facilities Licensing
Research Basis
Archive Period
2015-2025
Records Reviewed
71
Primary Topics
D056; single well battery; facility licence; H2S; EDCT; incineration; Directive 060
Current Reference
AER Directive 056; AER Manual 012; AER Directive 060
Common Question
When does a single well battery need a facility licence?
Archive Findings
The answer depends on the stream and activity, not just that it is a single well battery. In the 2025 correspondence, AER said the example was not exempt because it produced oil with H2S greater than 0.01 mol/kmol and used an incinerator.
Across the folder, AER treated exemption as a fact-specific check: substance, H2S, processing or storage, flaring or incineration, and the EDCT result all mattered.
Engineering Insight
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Do the facility classification before telling operations the SWB can stay under the well licence. Keep the gas analysis, EDCT result, process description, and exemption/licence rationale in the file.
Current Guidance
Use Directive 056 and Manual 012 to confirm facility licensing or exemption. Check Directive 060 if flaring, venting, or incineration is involved.