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AER Bulletin 2019-35 – Application for an Aboveground Reusable Bladder Within a Structural Frame

Companies may apply to use alternative storage devices to those set out in Directive 055: Storage Requirements for the Upstream Petroleum Industry to store produced water and other fluids at a well site. Most storage devices meet the requirements either in Directive 055 or in the addendum to the directive.

However, there is a new type of storage device—an aboveground reusable bladder within a structural frame—that does not currently exist in either regulatory document. Under section 8.030(3) of the Oil and Gas Conservation Rules, we can approve such a device if it provides the same level of environmental protection as those under Directive 055.


We have therefore updated the Checklist for Alternative Storage Applications (attached)(previously referred to as guidelines). We’ve added Part D that sets out suggested information to include in an application for an aboveground reusable bladder within a structural frame.

The updated checklist is available on www.aer.ca under Regulating Development > Application Processes > Alternative Storage and from the Directive 055 and Directive 055 (Addendum) landing pages.

If you have any questions about this bulletin, send an email to Directive055@aer.ca.