Part 2. Injection permits

Part 2 applies to wells and projects subject to a permit to inject issued under section 11 of the Oil, Gas and Salt Resources Act. Section 11 permits are required for the purposes of injecting substances into a geological formation in connection with projects set out in that section of the act, including projects for enhancing oil or gas recovery. A section 11 permit is not required for routine well stimulation.

2.1 Application requirements

Injection permit applications shall be made in writing and accompanied by a report containing the following:

  1. scaled plan of the lands underlain by the formation that will be the subject of the proposed injection showing:
    1. geographic lots and concessions of the area and the boundary of the area proposed to be injected or affected by the injection,
    2. the location and status of all wells including the proposed injection and production wells, and
    3. the boundaries of any designated gas storage areas within 1.6 kilometres from the boundaries shown under (i);
  2. a feasibility study that addresses the engineering and geological aspects of the project including,
    1. a site plan of surface facilities including wells, pipelines, storage tanks and other production facilities,
    2. geological and structural maps illustrating the extent of the formation or pool to be injected,
    3. an isopach map of the of the injection formation,
    4. representative geological cross sections of the injection formation that show the fluid contacts,
    5. the production and pressure history of the pool,
    6. a tabulation of reservoir parameters,
    7. a determination of the oil and gas in-place, remaining reserves under existing production practice and the incremental reserves under the proposed injection practice and recovery factors,
    8. a forecast of fluid volumes proposed to be injected, produced and re-injected and corresponding gas-oil and water-oil ratios and comparison to existing ratios,
    9. descriptions and results of preliminary injectivity tests,
    10. schematics of well completions for all wells proposed to be used or converted to injection,
    11. the location of any observation wells,
    12. a construction schedule including anticipated start-up date; and
  3. an evaluation of the compatibility of the proposed injection fluid with the fluids and rock type of the injection formation including,
    1. a description and chemical composition of all fluids,
    2. the source and treatment of injection fluids, and
    3. analyses of fluid-fluid and fluid-rock reactions.

2.1.1 Application fee

The application fee shall be in the form of a money order, cash, cheque or pre-authorized debit from an account or credit card, or credit or debit card payable to the Minister of Finance, and submitted with the Injection permit application.

2.1.2 Incomplete applications

Incomplete applications will not be processed until missing information is provided.

2.2 Injection well design

Operators shall design injection wells to:

  1. permanently isolate and protect all potable water formations from contamination;
  2. prevent the migration of the injected fluid from the target formation to other existing and potential hydrocarbon bearing formations;
  3. prevent the migration of fluids between permeable formations; and
  4. ensure that the injection fluids do not enter formations other than the injection formation.

2.3 Injection well/project construction, operation & maintenance

The operator shall construct, operate and maintain an injection well in a manner that provides for:

  1. all injection of fluid to be conducted through tubing:
  2. the annular space between the tubing and production casing to be isolated from the injection zone by a packer or some other acceptable method;
  3. all fresh water zones to be isolated with casing and cement:
  4. the surface and production casings to be cemented to surface except when intermediate casing(s) is used;
  5. when intermediate casing is used, the surface casing and the intermediate casing shall be cemented to the surface and the production casing shall be cemented to surface inside the intermediate casing;
  6. all wellhead components to be rated to 110 percent of the maximum operating pressure; and
  7. ensure that the injection fluids are compatible with the injection formation such that precipitates or clay mobilization or other adverse chemical reactions are minimized.

2.4 Existing well conversions

Conversion of an existing well for use an injection well may be made if the:

  1. well is less than 20 years old*;
  2. well’s condition and construction meets the requirements of section 2.2; and
  3. operator conducts additional pressure tests, casing evaluation logs and cement evaluation logs to demonstrate the mechanical integrity of the well.

*Note: Departures from the age limitation in (a) will not be accepted.