ID 96-03: Oilfield Waste Management Requirements for the Upstream Petroleum Industry
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Release Date: November 22, 1996
This interim directive highlights the requirements for the appropriate management of oilfield waste and introduces the Alberta Energy and Utilities Board (EUB) Guide 58; Oilfield Waste Management Requirements for the Upstream Petroleum Industry. This document, which covers all aspects of the regulation of oilfield waste, applies to all oil and gas, oil sands, and oilfield waste management facilities under the jurisdiction of the EUB.
This interim directive as well as Guide 58, supersede the following EUB Informational Letters:
- IL 81-10 Disposal of Campsite and Wellsite Waste,
- IL 85-16 Storage, Handling, and Disposal of Oily Wastes,
- IL 93-8 Draft Recommended Oilfield Waste Management Requirements, and
- IL 95-4 Criteria for the Application of Oily Byproducts to Roads.
On 11 February 1994, the ERCB (now the EUB) initiated a public review of the draft report, Recommended Oilfield Waste Management Requirements, which was previously published in August 1993. A multi-stakeholder Steering Committee was established to identify areas of the document that required further work, based on the public review. As the review of each area was completed, either by a subcommittee or independently by the EUB, the sections were tabled with the Steering Committee for their endorsement and consolidation into Guide 58.
Highlights of the Oilfield Waste Management Requirements for the Petroleum Industry
Significant areas of Guide 58 are highlighted in the following paragraphs. It is in these areas where surveillance, compliance auditing, and enforcement will be focussed initially. The onus is placed on the waste generators and receivers to fully understand and comply with all requirements as listed and explained in Guide 58.
1. Waste Generator Responsibilities
The oilfield waste generator (i.e. EUB licensee and/or approval holder) is responsible for ensuring that the requirements within Guide 58 are followed, including:
- properly characterizing and classifying their oilfield wastes,
- utilizing appropriate treatment and disposal practices,
- understanding the capabilities and limitations of the methods selected for the treatment and/or disposal of their wastes,
- maintaining accurate and complete waste documentation and manifests,
- informing waste carriers and receivers of the properties of their oilfield wastes, and
- ensuring operational requirements have been satisfied and, if applicable, required approvals are in place for any on-site waste handling, treatment, and disposal method.
2. Waste Receiver Responsibilities
The oilfield waste receiver is responsible for ensuring that the requirements within Guide 58 are followed, including:
- ensuring required approvals are in place and operational requirements have been satisfied for all waste handling, treatment, and disposal methods offered,
- understanding the capabilities and limitations of their treatment and disposal methods/facilities and communicating these to waste generators,
- accepting only those wastes their facility is approved to receive,
- maintaining accurate and complete waste documentation and manifests,
- operating their facilities in compliance with licences and approvals, and
- upgrading their equipment and operating practices as necessary to comply with changes in regulatory requirements.
Wastes generated outside of Alberta resulting from the exploration and production of oil and gas and exhibit the properties that would classify the wastes as dangerous in accordance with Section 5.0 of Guide 58 may be imported into Alberta for purpose of treatment only. These wastes must be directed into the Alberta Special Waste Management System, which is under the jurisdiction of Alberta Environmental Protection (AEP).
Oilfield wastes that would be classified as non-dangerous in accordance with Section 5.0 of Guide 58 may be imported into Alberta for purpose of treatment and/or disposal. Licensees and/or approval holders of facilities under the jurisdiction of the EUB must obtain approval from the EUB to receive imported non-dangerous oilfield wastes.
4. Waste Characterization/Classification
The waste generator is responsible for properly characterizing and classifying each oilfield waste. This characterization is then used in assessing the appropriate handling, treatment, and disposal of that waste. The waste must be classified as either dangerous oilfield waste (DOW) or non-dangerous oilfield waste (non-DOW), in accordance with Section 5.0 of Guide 58.
Oilfield waste must not be mixed with any solid or liquid for the primary purpose of dilution to avoid any Alberta regulatory requirement.
5. Manifesting and Tracking
With only a few exceptions, dangerous oilfield wastes generated in Alberta and transported on public roads within Alberta must be manifested. The EUB Alberta Oilfield Waste Manifest must accompany Alberta generated, dangerous oilfield wastes that are being transported to another site in Alberta (refer to Section 8.2 of Guide 58 for applicable exemptions).
Dangerous oilfield wastes moving across provincial boundaries or federal boundaries must be transported in compliance with the Transportation of Dangerous Goods Act and Regulation (TDG). This includes usage of the federal TDG manifest as opposed to the EUB waste manifest.
The waste generator is responsible for reconciling any discrepancies associated with the manifest that accompanies a shipment of dangerous oilfield waste.
Oilfield waste generators must implement a waste tracking system for dangerous oilfield wastes and for reportable oilfield wastes, as identified in Table 9.1 of Guide 58. Information that must be tracked includes:
- point of waste generation/consolidation,
- waste type,
- waste quantity generated, and
- treatment/disposal methods.
At any time, the EUB may audit a generator's waste tracking system or request the generator to provide information pertinent to the waste tracking system.
Each year selected waste generators (licensees and/or approval holders of wells or other facilities) will be required to submit an oilfield waste disposition report for the previous calendar year. The report must summarize the information obtained through the waste tracking system.
6. Oilfield Waste Management Facilities
An oilfield waste management facility may consist of one or more of the following components:
- waste storage area/facility,
- waste transfer station,
- waste processing facility,
- surface facility associated with a waste disposal well,
- waste disposal well (Class Ia or Ib),
- cavern (used for the disposal of waste),
- biodegradation facility, and
- thermal treatment facility.
Applicants must obtain written approval from the EUB to construct and operate all stand- alone oilfield waste management facilities. Refer to Part D of Guide 58 for details regarding whether approval or notification is required to integrate a specific waste management component into an existing EUB approved oil and gas or oil sands facility.
All licensees and/or approval holders of oilfield waste management facilities must comply with the requirements specified in Part D of Guide 58 for siting, safety, waste characterization, environmental impact assessment, design and operation, site assessment and groundwater protection, record keeping, and closure.
Financial security will be required for EUB approved fixed thermal treatment facilities (except for small batch feed and campsite incinerators), all EUB approved landfills, and all stand-alone oilfield waste management facilities.
(a) Waste Storage Area/Facility and Waste Transfer Station
Waste storage areas are defined as sites on existing EUB approved oil and gas or oil sands facilities used for the purpose of collecting oilfield wastes or oily wastes from one or more of a company's facilities. The licensee and/or approval holder of the facility where the storage area is located must be the same as that of the facilities from where the collected wastes were generated.
A stand-alone facility, which has been constructed for the purpose of collecting and storing oilfield wastes until volumes are sufficient for economic transfer to treatment and disposal facilities, is considered either a storage facility or a transfer station. The licensee and/or approval holder of a storage facility must be the same as that of the facilities from which the wastes are collected (i.e. first party receiver). A waste transfer station can receive wastes generated by various companies (i.e. third party receiver), as well as from various sites owned by a single company.
(b) Surface Facilities Associated With Waste Disposal Wells
The deep well disposal of oilfield waste fluids involves regulatory requirements for both the disposal well and the surface facility that is associated with the disposal well. The surface facility associated with a waste disposal well requires approval when:
- the disposal well is a stand-alone Class Ia or Ib well, or
- the surface facilities associated with the well are not covered in a new application or by an existing EUB facility approval.
(c) Waste Processing Facilities
A waste processing facility typically consists of a system of surface equipment designed for the treatment of oilfield waste material received from any oil and gas or oil sands operation. Some oilfield waste processing facilities are designed specifically for the recovery of crude oil, while others are designed to reduce volumes, alter chemical characteristics, and/or remove dangerous components prior to final disposal. Caverns which accept crude oil laden wastes for the purpose of crude oil recovery, also require approval as a waste processing facility.
Waste processing facilities accepting only wastes generated within the upstream petroleum industry only require approval from the EUB.
(d) Oilfield Landfills
Oilfield landfills are:
- operated by an oil and gas company for the purpose of disposing oilfield wastes produced from their own operations,
- operated as part of an oilfield waste management facility for the purpose of disposing residual wastes resulting from their treatment process, or
- operated by an independent company for the purpose of disposing third party waste generated by the upstream petroleum industry.
Construction or expansion of all oilfield landfills, including those to be integrated into an existing EUB approved production facility, requires EUB approval.
The disposal of any liquid oilfield waste into any landfill is prohibited.
Only EUB approved Class Ia or Ib landfills, or AEP regulated landfills which are approved to accept hazardous waste, shall receive dangerous oilfield wastes.
Generators wishing to dispose oilfield wastes into AEP regulated landfills must properly characterize their wastes and ensure the landfill in question is appropriately designed (as outlined in Section 15.0 of Guide 58) and is approved to accept wastes exhibiting the properties of the oilfield waste in question.
Land treatment is limited to those situations where non-refined hydrocarbon (i.e. crude oil or condensate) contaminated soils resulting from leaks/spills, and non- refined hydrocarbon contaminated pit/pond sludges, are land treated in a single application on the site on which they were generated. These production sites must be active.
Licensees and/or approval holders must document their land treatment activities to verify that the protocol outlined in Section 16.0 of Guide 58 has been met, must retain this information until a reclamation certificate for the site has been issued, and must make this information available to AEP or EUB staff upon request.
Biocell or biopile techniques can be used to biologically degrade oilfield wastes in a contained and controlled system. Once the biodegradation process is complete the material must be removed from the system and forwarded for further treatment or disposal, or be returned to the originating site to be used as fill material if it meets acceptable criteria.
Companies wishing to integrate a permanent biodegradation system into an existing EUB approved facility must apply to amend the facility approval to include the biodegradation system.
(f) Thermal Treatment
Small batch feed incinerators, which do not burn more than 10 tonnes of oilfield waste per month, and campsite incinerators, which have a burning capacity of less than 90.7 kg/hr and are used to dispose of only kitchen waste, do not require approval from the EUB, provided the criteria in Sections 17.3 and 17.4 of Guide 58 are met.
All other fixed thermal treatment facilities operating at oil and gas, oil sands, or oilfield waste management facilities require approval to construct and operate from the EUB.
Non-dangerous oilfield waste may be incinerated at AEP regulated incinerators that are approved for the incineration of non-hazardous or hazardous wastes. The incinerator must also be approved to accept third party wastes.
Dangerous oilfield waste may be incinerated at AEP regulated incinerators that are approved for the incineration of hazardous wastes. The incinerator must also be approved to accept third party wastes.
Implementation of Guide 58
The following outlines the effective dates for various sections of Guide 58; Oilfield Waste Management Requirements for the Upstream Petroleum Industry:
- All new oil and gas, oil sands, and oilfield waste management facilities constructed after 30 November 1996 must meet the design and operational requirements within Guide 58.
- All oilfield waste management facilities constructed after 30 November 1996 must meet the financial security requirements within Guide 58 by 1 June 1997.
- All oilfield waste management facilities which were constructed and operating prior to 30 November 1996, must meet the financial security requirements within Guide 58 by 1 May 1998.
- All oilfield waste manifesting requirements become effective 1 June 1997.
- Surveillance, compliance auditing, and enforcement of Guide 58 begins 1 June 1997.
- All waste tracking requirements become effective 1 June 1997.
- The first annual oilfield waste disposition report must be submitted 28 February 1998 for the period 1 July 1997 to 31 December 1997. Those oil and gas companies (waste generators) selected to submit the report will be notified by 15 January 1998.
EUB Guide 58 is available from EUB Information Services at 297-8190 or at the main floor of the Energy Resources Building, 640 - 5 Avenue SW, Calgary, Alberta, T2P 3G4.
<original signed by>
Brian F. Bietz
Alberta Energy and Utilities Board