Water and other non-hazardous waste fluids produced in association with oil-and-gas or non-oil-and-gas activities in Saskatchewan can be disposed into a subsurface pool through a disposal well in accordance with subsection 17(1)(k) of The Oil and Gas Conservation Act and The Oil and Gas Conservation Regulations, 2012.
A well licensee must apply to and receive authorization from the Ministry of Energy and Resources (the ministry) through the Integrated Resource Information System (IRIS) for a disposal well licence or reclassifying/recompleting an existing well to a disposal well.
Disposal wells are classified based on their disposal fluid type. Well completions related to disposal operations are:
- Disposal Well;
- Potash Waste Disposal Well;
- Waste Disposal Well; and
- Acid Gas Disposal Well
Requirements for Disposal Wells
Directive PNG008: Disposal and Injection Well Requirements sets out the requirements for the licensing and operation of disposal wells. The proposed disposal operations must be no impact to public safety and no adverse effects on the environment or hydrocarbon recovery in the surrounding area, including:
- The proposed disposal well must have sufficient wellbore integrity to ensure initial and ongoing containment of the disposal fluids in the interest of both hydrocarbon conservation and groundwater protection.
- The proposed disposal pool must be suitable for initial and ongoing containment of the disposal fluids in the interest of both hydrocarbon conservation and groundwater protection. If disposal is to occur into a hydrocarbon pool or an associated aquifer, it must be evident that it won't have a detrimental effect on the ultimate hydrocarbon recovery from the pool.
- The ministry considers the suitability of the waste fluids disposed into the proposed disposal pool through a disposal well based on the nature of the waste fluids, the characteristics of the disposal pool, the integrity of the well, and alternative waste management options. The waste fluids should be compatible with the disposal pool, i.e., the waste fluids should have similar chemical and physical qualities as reservoir fluids and it would not result in plugging and reduced permeability limiting the capacity of the well or damaging the reservoir. Compatibility can be evaluated through a fluid compatibility test. The test should be as detailed and as site specific as feasible. If available, actual fluids should be used for testing; alternatively, representative fluids from other wells in the same formation in the area can be used. If no testing is conducted, an alternative analysis indicating there is no or limited compatibility issues would occur should be provided by professional personnel.
- Only certain subsurface pools are considered suitable to receive specified waste fluids generated or processed from surface facilities.
- The proposed disposal well typically is not part of a project authorized by the ministry (e.g., Waterflood Project, Enhanced Oil Recovery (EOR) Project, Storage Project, etc.). Waste disposal wells associated with a Geothermal Project and acid gas disposal wells are authorized through an appropriate project application prior to a well licence submission or reclassification/recompletion.
Read the following Directives and Guidelines for additional regulatory requirements for a disposal well authorization application:
To apply to dispose fluids into subsurface pools:
- Have an Integrated Resource Information System (IRIS) account and the appropriate permissions assigned by your IRIS Security Administrator to submit an application.
- The applicant must have the rights to dispose fluids into the drainage unit/area in the proposed disposal pool(s). The drainage unit/area assigned to a disposal well is that which would be assigned to an oil producing well. Refer to Directive PNG006: Horizontal Oil Well Requirements and Guideline PNG021: Determining Drainage Units and Target Areas on how to determine the drainage unit/area. Refer to Directive PNG008 on the proof of the right to dispose. Please note that target area is not applied to disposal wells.
- If the proposed disposal pool is not within the common disposal pool, as defined in Directive PNG008, or if the disposal fluids are considered waste or substances other than produced salt water, the necessary consents from the offsetting mineral owners must be obtained, or the Public Notice process must be completed with objections resolved. Refer to Directive PNG009: Public Notice Requirements for the minimum notification area. It is the responsibility of the applicant to identify any potentially or directly affected parties outside of the minimum area and provide notification.
3. How to Apply
Disposal wells can be applied in IRIS through:
- A well licence application;
- As part of a recompletion/reclassification application;
- As part of a commingling application (if the well is not part of a project);
- As part of an acid gas disposal project application; or
- As part of a geothermal project application.
The following are processes for each application above.
Apply for a disposal well licence:
- Determine whether a prior authorization is required for the disposal wells.
- As outlined in Directive PNG008, the prior authorization is required before a well licence submission for:
- An acid gas disposal well as part of an acid gas disposal project;
- A waste disposal well as part of a geothermal project; or
- If the proposed disposal pool is a commingled pool.
Note: An application for a disposal well licence is either a routine or non-routine application in IRIS depending on the type of well and the declarations made by the applicant. A non-routine application is triggered when:
- Well completion type as potash waste disposal well, waste disposal well, or acid gas disposal well;
- If the proposed disposal pool is a commingled pool; and/or
- Declarations not meeting routine application requirements.
Apply for reclassification or recompletion to a disposal well:
Reclassification and/or recompletion to a disposal well after the initial completion of the well must be applied for in IRIS, using the appropriate application process. Refer to Guideline PNG024: Reclassification and Recompletion and Apply to Reclassify and Complete a Well.
- Determine whether the disposal well is part of a project (i.e., acid gas disposal, or geothermal project).
- Complete the appropriate Reclassification or Recompletion Form and include necessary attachments:
- Reclassification Recompletion (as part of reservoir application) Form; or
- Reclassification Recompletion (standalone) Form
Note: A well licence application instead of reclassification/recompletion application must be made in IRIS, if:
- Re-enter an abandoned well;
- Deepen a non-abandoned well into another stratigraphic unit; or
- Change the trajectory of a non-abandoned well (e.g., from horizontal to vertical or vertical to horizontal).
Apply for commingled disposal (when the well is not part of a project):
If the disposal well is not part of a project and is used for commingled disposal, a commingling application must be made and authorized by the ministry before licensing or reclassifying/recompleting the well. To apply:
- Determine whether the proposed pool is a commingled pool and the well is not part of a project.
- Complete the Application to Commingle Disposal Form, and include all required attachments (see the "Form Instructions" tab of the application).
- Log in to IRIS and complete the appropriate application process for authorization and attach the required documents.
Apply for an acid gas disposal well as part of an acid gas disposal project:
An acid gas disposal project means a development that groups one or more wells for approval of the disposal of acid gas into a deep saline aquifer or depleted hydrocarbon pool in non-EOR operations. An acid gas disposal project application must be made and authorized by the ministry before licensing or reclassifying/recompleting an acid gas disposal well. A separate Reclassification/Recompletion application or Commingling application is not required that can be authorized as part of an acid gas project application. To apply for an acid gas disposal project:
- Complete the Application for Acid Gas Disposal Project Form and include all required attachments. If applicable, a separate well licence application must be submitted after receiving the project authorization. See the Form Instructions tab of the application.
- Complete the Public Notice Process if required.
- Obtain written consent to the project from all Freehold mineral owners within the drainage area of the proposed disposal well(s).
- Complete the Reclassification/Recompletion (as part of a reservoir application) Form with all the necessary attachments (as one document), if required. For more information, see Guideline PNG024.
- Confirm that all the information is complete and accurate, and forms are dated and signed. Ensure all required attachments are included:
- Application for Acid Gas Disposal Project Form and attachments.
- Well list
- Completed Public Notice Process package, documented objections and required consents as a separate document, if applicable.
- Reclassification/Recompletion (as part of a reservoir application) Form with all the necessary attachments.
- Third-party Engineering Report (Confidential)
- Seismic Data and Report (Confidential)
- Other supporting documents (if applicable)
If applicable, a separate well licence application must be submitted after receiving the project authorization.
Apply for a waste disposal well as part of a geothermal project:
A geothermal project means a development that geothermal fluids are produced from a water source well, the geothermal energy is recovered at surface as part of an industrial process for any purpose, and the cooling fluids are disposed into subsurface through a waste disposal well.
A geothermal project application must be made and authorized by the ministry before licensing or reclassifying/recompleting a waste disposal well as part of geothermal project. A separate Reclassification/Recompletion application or Commingling application is not required that can be authorized as part of a geothermal project application.
Please refer to Apply for a Geothermal Project for information on requirements and application process for a geothermal project.
If applicable, a separate well licence application must be submitted after receiving the project authorization.
5. Further Information
Disposal into Undisposed Crown Lands
If disposing fluids in undisposed Crown Lands, a Lease of Space Agreement must be executed with Crown on application in IRIS after the disposal well authorization. Refer to Non-Advertised Dispositions and Non-Advertised Dispositions Application for more information.
Disposal Wells within a Project
Disposal wells as part of a Project Authorization may be subject to additional reporting requirements, which are typically set as obligations on a project. Refer to the Project Obligations Training Module for more information how to fulfill project obligation process in IRIS.
Potash Waste Disposal Wells
If applicable, an obligation may be set for all potash waste disposal wells in the same site on a project, other than on each well, to submit documentation. Refer to the Project Obligations Training Module for more information how to fulfill project obligation process in IRIS.