Enhanced recovery (ER) techniques involve injecting fluid into a hydrocarbon reservoir to supplement or maintain reservoir energy (pressure), enhance the sweep efficiency of hydrocarbons to production wells, or alter the state of the reservoir fluids in order to enhance hydrocarbon flow. A Directive 065: Resources Applications for Oil and Gas Reservoirs application must be submitted in order to implement or amend an ER scheme in accordance with section 39(1)(a) of the Oil and Gas Conservation Act (OGCA). Additional approvals from the AER or other governmental agencies may also be required to implement an ER scheme.
All well locations to be used for ER injection purposes must be drilled before a Directive 065 ER application is submitted.
The following outlines the critical information the AER requires and the process the applicant must follow to get approval for a new ER scheme and subsequent amendments. It contains links to relevant application submission procedures and guidance documents.
The ER (new or amendment) application and the related Directive 051: Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements application must be submitted using the Digital Data Submission (DDS) system, which is available through “Systems & Tools” on the AER website, www.aer.ca.
Applications are registered using Integrated Application Registry (IAR), and all material related to an application is stored within this system.
All submissions made in relation to any application are held non-confidential by the AER and are accessible, upon request, by other interested parties.
Approval Process for Enhanced Recovery Application
All applications are published on the Public Notice of Application (PNoA) page on the AER website (www.aer.ca) to encourage public participation in the approval process.
Applications are initially reviewed for administrative completeness upon receipt at the AER. An application may be closed if significantly deficient of Directive 065 requirements. If an application is declared administratively complete, a technical review will be conducted to ensure that the application includes the following (supplemental information may be requested during the review period):
- Statements of concern (SOCs) filed by parties that may be directly and adversely affected by the proposed ER operations for which approval is sought are evaluated for relevance to the application. If relevant, an SOC may necessitate a public hearing to address the stated concerns before the application can be finalized. The relevance of the SOC is decided by the AER director of subsurface authorizations;
- Notification in accordance with Directive 065 guidelines. This includes notifying licensees of all wells, including abandoned wells that are in the applied-for approval area or wells that are within a quarter section outside (i.e., within a half mile) of the applied-for area. In the case of an ER amendment that includes proposed injectors, licensees of all wells will be notified, including licensees of abandoned wells within 800 metres of the proposed injector. In the case of an ER amendment that includes changes to voidage replacement ratio conditions, Approval holders of adjacent enhanced recovery schemes;
- The Crown has been sent a letter of indemnification as it pertains to the proposed injection activities, if into Freehold lands;
- The proposed injection fluids and their suitability for the objective of maximizing hydrocarbon recovery;
- The source of the injection fluids and sufficiency of the source;
- Application referral to AER Authorizations Subsurface (Geology), if required for answers to questions about reservoir rock type, quality, and continuity;
- The composition of the proposed injection fluids for acid gas or H2S content. If acid gas or H2S content is confirmed, the application may be referred to the AER Emergency Planning & Assessment Section to confirm that the proposed disposal operations comply with Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry,including that the operations have an up-to-date emergency response plan (ERP). Where acid gas or H2S content is less than 100 parts per million, the applicant may only be asked to confirm the existence of an up-to-date ERP;
- The proposed ER scheme area and the underlying drilling spacing unit in the area and formation;
- The applicant’s reservoir fluid volumetric estimates and the AER database estimates;
- The reservoir fluid PVT characterization, and comparison of the results with the PVT table provided by the applicant;
- Assessment of the reservoir pressure depletion trend from production initiation and the effect of fluid injection on this, if ER has already been implemented;
- The effect of reservoir energy depletion on production performance trends and the effect of fluid injection on this;
- The list of wells and their individual status in the pool and the list of wells that will be in or are in the proposed ER scheme area;
- The scheme holder’s record of compliance with approval conditions;
- A technical memorandum, with disposition recommendations, and the draft approval documents, prepared and presented for supervisory review.
Other application process and approval considerations:
- Directive 051 applications for the proposed injection wells can be submitted with the Directive 065 application or within a prescribed timeframe after the approval of the latter. Note that injection operations cannot begin into any wellbore until the AER has confirmed in writing that the wells meet Directive 051 requirements.
- The AER assesses the maximum wellhead injection pressure (MWHIP) for each proposed injection well usually based on the analysis of step-rate injectivity, or equivalent tests, which establish the formation fracture propagation pressure. If no injectivity test data is provided, MWHIP is assessed from the default table on the basis of the true vertical depth (TVD) of the perforation top of the proposed injection well interval. A scheme holder may also, through the application process, apply to have the MWHIP assessed based on 8 × TVD of the perforation top of the proposed injection well interval where the formation top is deeper than 400 metres. The AER reserves the right to revert to the default table if the base MWHIP of 8 × TVD is deemed to pose a risk to operations in an area or to the environment.
- Offset wellbores have been reviewed for potential high-risk hydraulic isolation deficiencies;
- The performance of the scheme in meeting the original hydrocarbon recovery estimates is assessed while considering an application to terminate a scheme.
- The reservoir engineering manager or the manager’s delegates make the final decision on the merits of any application and sign off on the approval.
- Applications that require a public hearing will only be finalized in accordance with the decision of the hearing panel.
- Application approvals can be appealed after disposition if the SOC is received from eligible parties. Eligibility for an SOC is based on the Responsible Energy Development Act. The filing requirements and process for a request for regulatory appeal, including form, content, and time limits, are set out in sections 30 through 33 of the Alberta Energy Regulator Rules of Practice.
The processing time for this application is 80 business days. This timeline is made up as follows: