Archive

Requirements on Waste Transport by Pipeline and Waste Tracking
July 31, 2009


Variations in the quality of crude oil streams being received at refineries are impacting their operations. The Energy Resources Conservation Board (ERCB) reminds upstream petroleum licensees and approval holders of the requirements in Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry regarding the transport of oilfield wastes by pipeline.
Directive 058, Section 6: Wastes Banned from Disposal via Injection into Pipelines Systems, states the following:

  • Upstream oilfield wastes that can be separated from production streams and can be harmful to oil handlers must not be diluted by injection into pipelines.
  • Pipelines must not be thought of as a “mixing vessel” for waste dilution.
  • For safety, environmental, corrosion, operational, and economic reasons, the oilfield wastes identified in this subsection are banned from direct injection into any pipeline system. The rationale for this is based on non-hydrocarbon content, chemical composition, water content, solids content, and/or the availability of practical cost effective waste treatment methods.

Directive 058, Section 31: Waste Transport by Pipeline identifies the introduction of inappropriate oilfield wastes into crude oil pipelines as a waste management issue, as well as a crude quality issue, which must be addressed by the producers, pipeline licensees, and refinery companies together. It states that certain (listed) waste types may be injected into a pipeline system only if the following control conditions are met:

  • the waste has a usable hydrocarbon content and does not pose a downstream handling problem, and
  • specific agreements have been arranged between the waste producer, the pipeline licensee, and the refinery for which the specific waste volume is destined.

Adherence to the above conditions is an ERCB requirement and will be monitored as part of the ERCB oilfield waste management surveillance program. If the ERCB determines that wastes are being injected into pipeline systems in violation of the Sections 6 and 31 requirements, it will reconsider its policy to permit waste transport by pipeline as an oilfield waste management option.
The ERCB reminds industry of the addition of new wastes codes with the February 13, 2009, release of Directive 047: Waste Reporting Requirements for Oilfield Waste Management Facilities. The new waste codes were also set out in a March 26, 2009, announcement on the ERCB Web site www.ercb.ca . The new wastes codes are to be used for waste tracking and to be reported in the 2009 Annual Oilfield Waste Disposition Report. The ERCB has added “waste transport by pipeline” as a disposition type and requires industry to include information about oilfield wastes being managed by transport by pipeline in their Annual Oilfield Waste Disposition Reports.
For information on requirements regarding waste tracking and submission of the Annual Oilfield Disposition Report, refer to Section 9 of Directive 058 and to Directive 030: Digital Data Submission of the Annual Oilfield Waste Disposition Report.
Any inquiries related to this bulletin may be directed to Visser Consulting Ltd at sales@vcl.ab.ca or call 403.293.3797.

 

Updates to Storage Requirements for the Upstream Petroleum Industry—Discussion Document on Directive 055

July 30,2009

The Energy Resources Conservation Board (ERCB) is responsible to maintain and administer material storage requirements for the upstream petroleum industry. These requirements are set out in Directive 055: Storage Requirements for the Upstream Petroleum Industry.
Directive 055 was last revised in 2001. The ERCB is finding repeat noncompliances with some of the requirements in Directive 055 and has been responding to numerous queries from industry and consultants seeking clarification of some of the requirements.
A discussion document (Report 2009-A: Updates to Storage Requirements for the Upstream Petroleum Industry—Discussion Document on Directive 055) has been prepared to communicate potential updates and clarifications to Directive 055 in the following areas:

  • excluded material types and storage systems
  • alternative storage systems
  • permanent storage devices not requiring secondary containment
  • temporary storage
  • dike and tank integrity verification requirements for pre-1996 sites
  • dike size and capacity
  • schedule for repeat integrity testing of tanks
  • secondary containment for small aboveground storage tanks
  • use of open-topped, nonmetallic tanks with an internal volume less than 30 cubic metres (m3)
  • construction and installation factors for aboveground storage tanks with an internal volume =5 m3
  • weather protection for steel aboveground storage tanks with an internal volume =5 m3
  • design of double-walled aboveground storage tanks
  • monthly leak detection requirements for underground storage tanks
  • inspection, monitoring, and record keeping
  • on-site storage of small volumes of oilfield waste
  • revision of surface discharge criteria for collected surface run-on/run-off waters

The ERCB consulted with Alberta Environment, Alberta Municipal Affairs, Canadian Association of Petroleum Producers, and Small Explorers and Producers Association of Canada during the development of this discussion document.
Report 2009-A: Updates to Storage Requirements for the Upstream Petroleum Industry—Discussion Document on Directive 055 is available for review on the ERCB Web site www.ercb.ca  under Industry Zone : Rules Regulations Requirements : Directives : Directive 055. The ERCB invites comments on the discussion document. Feedback may be electronically submitted (by e-mail or e-mail with an attached Word file) to wasteops@ercb.ca , with the subject line “Directive 055 Discussion Document Feedback”; hard-copy feedback may be mailed to Susan Halla, ERCB Environment Group, 640 – 5 Avenue SW, Calgary, Alberta T2P 3G4.

The ERCB would appreciate that the responses be formatted to identify:

  • the specific section of the discussion document of issue, including the page on which it appears,
  • what the issue is,
  • possible solutions or recommendations, and
  • rationale to support the solution or recommendation.

Comments received will be taken into consideration when finalizing the updates and clarifications to Directive 055. Comments will be accepted until September 30, 2009.


Dwayne Waisman, B.E.S., C.E.T.
Executive Manager
Field Surveillance and Operations Branch

Benzene Emissions Reporting Update (OGC IL 09-16)

May 14, 2009

Effective Date: Effective Immediately

Background: The Oil and Gas Commission Information Letter 07-03, dated January 15, 2007 required that the annual Benzene Dehydrator Inventory List be emailed to benzene.tat@capp.ca.  This email address is no longer supported by CAPP. All annual Benzene Dehydrator Inventory Lists are now to be submitted directly to the Commission.

Requirement: All annual Benzene Dehydrator Inventory Lists are now to be submitted directly to the Commission at OGCbenzene.inventory@gov.bc.ca. 

If you have any questions regarding the above, please contact Visser Consulting Ltd at sales@vcl.ab.ca or call 403.239.3797.

ERCB New Enhanced Production Audit Program (EPAP)

May 14, 2009

 

Introduction

The ERCB has introduced the Enhanced Production Audit Program (EPAP).  EPAP is a company’s way of determining the level of assurance (confidence) they have in the processes and procedures they use to ensure their measurement and production numbers are correct or accurate, thereby providing confidence in the reporting of these numbers into the Petroleum Registry.

The program allows companies the ability to identify areas where they are deficient and implement corrective actions.

Visser Consulting has developed a program that encompasses field inspections and production accounting audits that ensure a company has a measurement and reporting program that meets all of the ERCB requirements and also provides a competency assuredness for a sign off by senior company officers.

Legislation

ERCB Directive XXX Operator Declaration Regarding Measurement and Reporting Requirements

http://www.ercb.ca/docs/Documents/directives/DraftDirective_Declaration_Measurement_Reporting.pdf

The directive requires two senior company officials to sign a declaration stating their level of assurance regarding information they have supplied to the ERCB for measurement and reporting requirements.

Outline of Target Components

The ERCB has identified the following timeline for companies to develop their EPAP program.

  • Trial Declaration period August 2009 to July 2010
  • First Declaration period August 2010 to July 2011

All of the respective ERCB Directives governing measurement and Reporting are included in this program.

If you would like additional information or assistance in developing your program please contact us at sales@vcl.ab.ca.

The OH&S code has been updated

April 27, 2009

The Alberta Occupational Health and Safety (OHS) Code has been updated to keep workplace health and safety rules current and relevant.  Alberta employers have until July 1 to comply with the updates.

Updates to the OHS Code include the following:

  • new requirements for lift calculations, tag lines and personnel baskets;
  • healthcare requirements specific to patient/client/resident handling;
  • new requirements for medical sharps;
  • distinguishing between ‘confined’ and ‘restricted’ spaces for entry permit systems;
  • requirements applicable to respiratory protection against airborne bio-hazardous material;
  • mobile equipment requirements specifically for concrete pump trucks;
  • new, specific safety factors for rigging components; and
  • updates to better reflect current mining practices.

The 2009 OHS Code can be found online at: http://employment.alberta.ca/whs-ohs

Copies of the 2009 OHS Code can be purchased from the Queen’s Printer at 780-427-4952 (dial 310-0000 for toll-free access) or online at: www.qp.alberta.ca Shipping will begin in late May.

Click here to have a Visser representative contact you.

Wildfire Act & Regulation Within BC

April 23, 2009

Companies carrying out industrial activities within 300m of forest and grass lands are affected by this Legislation and should become familiar with the Act and Regulation in order to achieve due diligence.

The Regulation requires that companies must ensure that they have sufficient fire-fighting tools available if there is a fire risk, regardless of the time of year.  It also no longer details the type, number and specification of tools, pumps and other firefighting equipment to be used; but rather states that sufficient firefighting tools and fire suppression systems are a requirement.

For more information you can click here for the CAGC “Information Release” or send us an email and have a Visser representative contact you.

New ERCB Directive 073

December 17, 2008

The Energy Resources Conservation Board (ERCB) announces the release of Directive 073: Requirements for Inspection and Compliance of Oil Sands Mining and Processing Plant Operations in the Oil Sands Mining Area.The directive codifies existing ERCB requirements and presents procedures for inspection and compliance of oil sands mining and processing plant operations in the oil sands mining area. The directive also includes new requirements for oil sands mining and processing plant operations. It will aid staff in carrying out detailed inspections of oil sands mining and processing plant operations in a consistent manner, as well as inform industry personnel about what is required to achieve a satisfactory ERCB inspection.

The requirements in Directive 073 are effective December 17, 2008. A six-month phase-in period for this directive will take place before the new requirements face enforcement measures. This will allow operators and ERCB staff to assess the applicability of the risk-ranked items in Appendix 1 associated with the new requirements. If there are any discrepancies with the risk ranking, changes can be made during this timeframe. If a noncompliance issue is identified regarding existing requirements, the ERCB will take enforcement measures as appropriate on a case-by-case basis. However, enforcement will not be issued on new requirements during the phase-in period.

Directive 073 is available on the ERCB Web site www.ercb.ca under Industry Zone : Rules, Regulations, Requirements : Directives. Questions and answers, updates, and further details on the inspection and compliance requirements and procedures will be posted on the Web site as available.

Click here for the full News release.

Click here to have a Visser representative contact you.

ERCB Plans to crack down on Oil and Gas companies that are not in compliance with the Fugitive Emission program

Highlights of the planned enforcement program are as follows:

  • ERCB and CAPP will be meeting in June to discuss the BMP.  Whether housed in BMP or within Directive 060 itself, the new legislation will be clear and will outline specific aspects of a fully managed Fugitive Emission Program.  This will include a concise breakdown on enforcement.
  • Companies (Visser included) will be asked by ERCB to contribute to reporting criteria – a standard will be set regarding reporting, testing, training etc
  • Directive 060 will be rewritten this year.
  • Fugitive Emission Plan must be in place and implemented by Jan 1, 2010.  Companies have had 3 years to get a Fugitive Emission program started and running.  The ERCB will not accept a written plan without proof that testing has been completed.
  • 1st year of enforcement based on
  • have sites been tested?
  • does the company have an outlined plan?
  • ALL active, shut in, and inactive facilities must be checked
  • ERCB currently has 3 cameras for testing, and are looking into buying a 4th.
  • There are roughly 1100 companies in AB.  If the ERCB audits one facility per company, they will audit at least 660 of the companies by 2010
  • 300-350 facilities will be audited this year.
  • 600-700 facilities to be audited next year (based on 3 cameras)
  • Smaller companies will be targeted as well as companies with previous low/high risk non-compliances/ complaints.
  • Frequency of inspections to be determined by statistics in the field – leaks vs non leaks in all components

Top