Contamination Management Policy And Guidelines

The following contamination management policy and guidelines, listed in order of their application to the remediation process, should be used to

identify and manage releases,
assess contamination,
manage the risks of contamination, and
remediate releases and spills.

Many of these policy and guideline documents have been developed by Alberta Environment and Protected Areas.

Our Remediation and Remediation Regulation Administration pages describe our expectations for companies to safely and responsibly manage and clean up contamination. If we find that a company isn’t following the rules, we’ll take the appropriate compliance or enforcement action.

Manual 021: Contamination Management

Manual 021: Contamination Management relates to activities regulated by the AER and has been written for a target audience of industry and environmental practitioners. It contains

a summary of pre-existing requirements from across many relevant regulatory documents (some described below) and
advice on how to efficiently demonstrate to the AER that those requirements have been met.

Manual 021 has been structured to provide the following:

a summary of key concepts and regulatory requirements
a description of life cycle stages of a substance released to the environment affecting soil and groundwater
objectives for each stage (from initial discovery to closure) to demonstrate compliance

Examples are given in an appendix.

While the regulatory requirements described in Manual 021 apply to all activities regulated by the AER, the report and closure application submission process described in sections 7 through 11 is specific to oil and gas, in situ, and pipelines activities. Manual 021 does not set requirements or policy.

Contaminated Sites Policy Framework

The Government of Alberta's Contaminated Sites Policy Framework provides an overview of the provincial legislation for remediation and contaminated site management in Alberta and is designed to achieve three policy outcomes:

Pollution prevention: avoid impairment of, or damage to the environment, human health or safety, or property.
Health protection: take action on contaminated sites that is commensurate with risk to human health and the environment.
Productive use: encourage remediation and return of contaminated sites to productive use.

The Contaminated Sites Policy Framework sets out the following principles of contaminant management:

control the source of the contamination
conduct an environmental site assessment
assess risk
manage contamination
consider other factors in addition to risk

Environmental Site Assessment Standard

The Environmental Site Assessment Standard provides the minimum submission requirements for all site assessments and reporting at contaminated or potentially contaminated sites in Alberta.

Record of Site Condition

The AER Record of Site Condition (RoSC) is used to summarize the current known environmental condition of an assessed site so that major environmental parameters can be tracked. As per the Environmental Site Assessment Standard, an AER RoSC and its declarations must be included with all contamination management report submissions.

Further information on the AER Record of Site Condition is available on the Record of Site Condition webpage and in the OneStop Quick Reference Guides under the heading “Contamination Management.”

Alberta Tier 1 and Tier 2 Soil and Groundwater Remediation Guidelines

The Alberta Tier 1 Soil and Groundwater Remediation Guidelines contains general guidelines for remediating contamination on cultivated, residential, commercial, and industrial land. Alberta Tier 2 Soil and Groundwater Remediation Guidelines describes how to modify the Tier 1 guidelines using site-specific information.

Supplemental Guidance on Site-Specific Risk Assessments in Alberta

The Government of Alberta’s Supplemental Guidance on Site-specific Risk Assessments in Alberta provides additional clarification on the requirements and expectations for completing site-specific risk assessments (SSRAs) for contaminated sites in Alberta. SSRAs are one approach available under the Tier 2 guidelines for consideration of site-specific conditions. Use of the guidance provided by this document will facilitate regulatory review and acceptance of SSRAs.

Native Prairie Protocol

The Native Prairie Protocol helps to identify well sites on native grasslands where leaving salt contamination in place will not result in adverse effects to the ecosystem, which is very sensitive to disturbance. Sites that meet the conditions specified in the protocol can receive a reclamation certificate even though salt concentrations may exceed Alberta Tier 1 guidelines.

Subsoil Petroleum Hydrocarbon Guidelines for Remote Forested Sites in the Green Area

The Subsoil Petroleum Hydrocarbon Guidelines for Remote Forested Sites in the Green Area must be used at sites within the Green Area that

will not be affected by human disturbance, and
are being reclaimed to forested land use.

These guidelines specify when the ecological direct contact pathway for petroleum hydrocarbon fractions 1 to 4 may be eliminated (1.5 m for fine-grained soil; 3.0 m for coarse-grained soil).

Tier 2 Guidelines for Salinity: The Subsoil Salinity Tool

The Subsoil Salinity Tool is a software program for developing Alberta Tier 2 soil remediation guidelines for chloride-based salt contamination below the root zone, based on information provided by the user, including site location and soil and groundwater information. Soil within the root zone must be remediated to meet salinity guidelines in the Alberta Tier 1 Soil and Groundwater Remediation Guidelines.

Tool users who wish to develop Tier 2 guidelines for remediation or reclamation certification must successfully complete a three-day training course, including a comprehensive four-hour exam with an 80 per cent pass mark. For more information, see the Subsoil Salinity Guidelines Fact Sheet and Subsoil Salinity Tool Assessment Checklist.

Domestic-Use Aquifer Pathway

Under the Alberta Tier 1 Soil and Groundwater Remediation Guidelines, the protection of the domestic-use aquifer pathway must be included for all assessments. Under the Alberta Tier 2 Soil and Groundwater Remediation Guidelines, the applicant is able to reassess the domestic-use aquifer pathway and remove it if there is not a risk to human health or the environment at the location in question. Another option to remove this pathway from the assessment of risk is based on the lack of access to the groundwater resource within the municipal boundaries, provided the applicant can demonstrate that there is a municipal bylaw in place that prevents access to groundwater to install drinking water wells. This bylaw is deemed an administrative control that protects human health. The Guide to Excluding the Domestic Use Aquifer Based On Municipal Bylaws outlines the conditions that need to be met for exclusion based on municipal bylaw. It is intended to help parties ensure they are submitting sufficient information for the regulator to review and approve their applications.

Alberta Risk Management Plan Guide

The Alberta Risk Management Plan Guide outlines what a company must include in its risk management plan, which must be submitted when exposure control is being considered for managing contamination. Required components include a notification of affected third parties; a risk management plan commitment letter for the persons responsible; and a risk management plan completion checklist.

Alberta Exposure Control Guide

The Alberta Exposure Control Guide should be used to develop a plan to manage contamination and remove or mitigate an exposure pathway to a receptor. It can be used by companies when developing and assessing options for managing contamination through

administrative or institutional controls (e.g., restricting groundwater use, restricting site access); and
physical barriers (covering contaminated soil).

Soil Monitoring Directive

The Soil Monitoring Directive sets out the requirements for monitoring and managing soil contamination at EPEA-approved facilities. It describes how companies should

identify substance releases before they cause significant contamination of soil;
ensure that the source is controlled in timely manner to limit contamination being transferred from soil to air or water; and
ensure that the contamination is assessed, managed, and reported in a timely manner.

Waste Management Documents and Directives

Drilling Waste

Directive 050: Drilling Waste Management sets out our requirements for treating and disposing of drilling waste. Drilling waste can include mud and cuttings generated when a well is drilled (including oil sands exploration wells) or when directional drilling is used during pipeline construction.
For more information, see the following documents:

Oilfield Waste

To clean up contamination, a company might have to excavate or remove the contaminated soil and pump contaminated groundwater so that it can be treated or disposed of. Contaminated material that is treated or disposed of from the ground is considered oilfield waste. It must be disposed of according to the directives listed on our Waste Management page.