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Bulletin 2008-33

July 9, 2008

Revised Edition of Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry (July 2008) Issued

The July 2008 revised edition of Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry is now available on the Energy Resources Conservation Board (ERCB) Web site www.ercb.ca  and replaces the April 2008 edition. Changes to the April 2008 edition of Directive 071 have been made as result of stakeholder feedback and are highlighted in Appendix 10 of the directive.

The ERCB had applied a three-month phase-in period from April 8, 2008, to July 2, 2008, for compliance with new requirements. All requirements are now fully in place and noncompliances are subject to enforcement action, in accordance with Directive 019: ERCB Compliance Assurance—Enforcement.

ERP Application Approval
The July 2008 revised edition of Directive 071 introduces a new emergency response plan (ERP) application process that includes preapproval (routine and nonroutine review) and postapproval audit. An important part of the application process is to accurately and fully complete the ERP Application Form in Appendix 2 of Directive 071. The form is now electronically available on the ERCB Web site, but note that a paper copy of the form and the ERP must be submitted to the ERCB for the ERP application to proceed. The ERCB goal is to eventually introduce electronic submission, but no timeline for this has been set.

Temporary Exemptions
Bulletin 2008-15 sets out provisions for temporary exemption for existing sour production facility ERPs. These exemptions remain in effect subject to the terms described in Bulletin 2008-15.

All exempt sour production facility ERPs must continue to comply with all applicable requirements in the 2005 edition of Directive 071. This includes submission of annual updates to the ERCB.

Associated noncompliances will also be addressed in accordance with the 2005 edition of Directive 071 and other ERCB directives and their associated compliance categories, as previously done.

ERCBH2S Version 1.19 – Computer Model for Calculating Emergency Planning Zones
Major incidents involving sour gas are rare occurrences in Alberta due to rigorous standards and safeguards required for sour operations. Although this is the case, requirements are in place to ensure that licensees plan and are capable of responding to incidents when they occur. In ensuring an appropriate level of planning, preparedness and response capability, it’s important to properly characterize the hazard and the distance to where initial and priority response actions would occur by the licensee. Licensees are also required to consider in its ERPs actions coordinated with other responders wherever public safety threats may occur including beyond the initial area of priority response.

The ERCB requires calculation of an emergency planning zone (EPZ) that represents the starting point for licensees to pre-plan its first response actions. Through the initial planning phase and through the public involvement process the calculated EPZ may be modified to account for site-specific features which may also trigger a site-specific emergency response plan (ERP) if surface development occurs within the EPZ. As part of the ERP Application process the ERCB may further direct a licensee to modify its EPZ and change the ERP prior to approval being granted and before operations can commence.

In April 2008, the ERCB required licensees to calculate Emergency Planning Zones (EPZ) for sour operations using a new state-of-the-art computer model. The ERCBH2S model is a complex program that uses thermodynamics and dispersion modelling to predict hazard distances if an incident were to occur. ERCBH2S is a powerful tool in that it allows and encourages hazard mitigation options to be assessed with the result of more representative EPZs being reflected within an ERP. In practical terms this means that during an incident less sour gas is released.

To ensure that EPZs and the actual ERP is representative, the ERCB from time-to-time will modify ERCBH2S to ensure it is kept current. In keeping with this objective, the ERCB has now released ERCBH2S version 1.19 for use in ERP applications. Changes during the initial implementation of ERCBH2S (version 1.16) were expected as the model was applied industry-wide. All known issues identified are now believed to have been addressed and no further changes are anticipated at this time. Changes are documented in the change log that is part of the download package on the ERCB Website. Licensees are required to consult or notify impacted parties to explain why planning zones have changed.

EPZs calculated using a previous version and already submitted in an ERP application to the ERCB may still be valid. Emergency Planning and Assessment (EPA) staff will contact licensees if they are required to recalculate EPZs as result of a version change. A list of changes in version 1.19 is included with the new version of ERCBH2S. Note that ERP applications currently before the ERCB and subject to hearing may require additional actions. Changes will be at the discretion of the Board panel assigned to the hearing.

Existing Sour Production Facility EPZ Calculations Using ERCBH2S
Existing sour production facility ERPs may be temporarily exempt from the Directive 071 July 2008 edition requirements, as set out in Bulletin 2008-15. However, licensees are required to recalculate EPZs associated with these facilities and submit the information in Comma Separated Value (CSV) format by December 31, 2008, by e-mail to Directive71@ercb.ca. This is to allow the ERCB, along with industry, to assess the EPZ information submitted and determine the implications of the changes. This will be considered in development of a full implementation plan that will be provided by July 2, 2009, for updating existing facility ERPs.

• Licensees are not required to calculate every well and pipeline EPZ within a facility ERP. Licensees are required to submit calculations for a sample that is representative of the licensees’ entire operations. The licensee is expected to provide a justification to defend the sample provided. The licensee should also include a discussion of the impacts the potential change in EPZ size would have on the rewrite of its ERPs.
• Licensees should begin considering using mitigation options in EPZ calculations, such as procedural and engineering changes as well as applying operating conditions (with appropriate margins) instead of licensed values to prepare for full implementation.

Frequently Asked Questions (FAQs)
The FAQs previously published on the ERCB Web site have been expanded to address stakeholder input received through the EPA Helpline at 403-297-2625, the EPAssessment@erc.ca mailbox, and Directive 071 rollout sessions conducted in Calgary, Edmonton, Red Deer, and Grande Prairie. Licensees are encouraged to refer to this document and the ERCBH2S User Guide prior to contacting EPA.
If a question has not been addressed, please submit it by e-mail to EPAssessment@ercb.ca to ensure efficiency and consistency in response.

Comments and suggestions for future changes to Directive 071 should continue to be sent to Directive71@ercb.ca.

<original signed by>

Dwayne Waisman
Executive Manager
Public Safety / Field Surveillance Branch