Bulletin 2011-11: Invitation for Feedback on Draft Revision of Directive 050: Drilling Waste Management
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Invitation for Feedback on Draft Revision of Directive 050: Drilling Waste Management
Apr 18, 2011
The Energy Resources Conservation Board (ERCB) is responsible for maintaining and administering oilfield waste management requirements for the upstream petroleum industry. Requirements for the management of drilling waste are set out in Directive 050, which was last updated in 1996. Since 1996 there have been significant advancements in drilling mud formulations, waste management options, and in soil quality and reclamation guidelines. An update to the 1996 edition of Directive 050 is required to clarify requirements, strengthen standards, streamline processes, and gather information to support surveillance.
In September 2007, the ERCB published a draft revision of Directive 050 and invited feedback on it. Thirty seven responses were received from a range of stakeholders (e.g., oil and gas industry, environmental consulting companies, laboratories, and public interest groups). To better understand and assess the comments on current soil, environmental, and analytical sciences, and on regulatory requirements, the ERCB held meetings and corresponded with representatives of industry and environmental associations and of federal and provincial government agencies. The ERCB, in consultation with Alberta Environment and Alberta Sustainable Resource Development, has considered all comments and has revised the 2007 draft edition (refer to Attachment 1: Summary of Revisions Made to 2007 Draft Rewrite of Directive 050).
The ERCB is inviting stakeholders to review the 2011 draft revision of Directive 050 and provide feedback.
As this is the second round of consultation, feedback received on items that have previously been assessed may receive limited consideration unless new information is put forth.
The draft revision is available for review on the ERCB website at www.ercb.ca under Industry Zone : Rules, Regulations, Requirements : Directives. Paper copies of the draft revision are available from ERCB Information Services, Suite 1000, 250 – 5 Street SW; telephone: 403-297-8311; fax: 403-297-7040; e-mail: firstname.lastname@example.org.
Feedback can be electronically submitted (by e-mail with an attached Word or Excel file) to email@example.com with the subject line “Draft Directive 050 Feedback.”
The ERCB would appreciate that the responses be formatted to identify:
- the section of the directive that is of issue, including the page on which it appears,
- what the issue is,
- possible solutions or recommendations, and
- the rationale to support the solution or recommendation.
Comments will be accepted until June 20, 2011.
All feedback received will be reviewed for the purposes noted in the bulletin and to finalize the directive noted above. All of the comments, feedback, and information collected, used, and disclosed through this consultation will form part of the public record and are subject to the Alberta Freedom of Information and Protection of Privacy Act. The ERCB may use the contact information you provide for follow-up communication related to your feedback.
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Attachment 1: Summary of Revisions Made to 2007 Draft Rewrite of Directive 050
Below summarizes the key revisions made to the draft rewrite of Directive 050:
- The number of samples required to assess receiving soils, and when necessary, the soil/waste mix, has been reduced.
- The disclosure requirements have been revised to focus on remote sites that pose a higher risk, and the disclosure period has been extended from six months to one year. Forms have been developed that will allow industry to electronically submit this information.
- Reference to the Petroleum Services Association of Canada list of toxicity assessment data for fluid additive/mud products has been removed. Licensees will be required to have information to substantiate that additives/products were used in concentrations below the toxicity threshold for luminescent bacteria or will be required to test the drilling waste for toxicity.
- Procedures to assess a “generic drilling mud system” have been added for situations in which a multi-well program will be drilled with a predetermined mud system. The results can be used to evaluate potential disposal options; provisions have been included to monitor changes in the mud system during the drilling program. The procedure should alleviate controversy surrounding
- individual compound toxicity testing not accounting for synergistic effects, and
- varying metal content of base compounds used for drilling additives/products creating challenges to determine metal concentrations in drilling wastes.
- The soil testing requirements for sump suitability has retained Atterberg Limits, as it provides information respecting suitable clays for containment purposes and has increased the fines content from 30% to 50% to align with Alberta Environment’s criteria for fine grain soils. The need for sump site assessment to be overseen by a professional has been changed to a qualified person based on relevant work experience and educational background.
- Additional changes include
- with the exception of biodegradation sites, changing the maximum slope for sites receiving drilling waste from 3% back to 5% with emphasis on no pooling or migration of wastes; slope requirement has been removed from the pump-off disposal method;
- clarifying disposal options for drilling wastes generated during pipeline operations;
- clarifying cement return management options, including the need to obtain landowner consent when a cement return pit exceeds an area of 4 m2, limiting cement return pits to a maximum area of 100 m2, and requiring disclosure of the cement return pits during the reclamation certification process;
- adding quality assurance/quality control requirements for field analysis programs;
- developing two post-disposal notification forms for the management of drilling wastes—one for wastes generated from wells and a second for wastes generated from pipelines, to be submitted electronically;
- clarifying requirements for managing drilling wastes that contain radioactive isotopes; and
- adding requirements to allow re-mixing of pre-1993 drilling waste disposals under specific circumstances.