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Bulletin 2008-45
December 10, 2008
Reminder: Oilfield Waste Being Sent Off Site for Management Must Go Only to Approved Waste Management Facilities
The Energy Resources Conservation Board (ERCB/Board) recently became aware of the existence of oilfield waste management facilities operating in the province without an approval. Oil and gas licensees, the generators of oilfield waste, are reminded that the documents listed below clearly identify that oilfield waste being sent off site for collection, storage, treatment, disposal, or recycling must be sent only to ERCB-approved or Alberta Environment (AENV)-approved waste management facilities:
- Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry
- Interim Directive (ID) 2000-03: Harmonization of Waste Management
- Interim Directive (ID) 2000-04: An Update to the Requirements for the Appropriate Management of Oilfield Wastes
The Memorandum of Understanding (MOU) Between the Alberta Energy and Utilities Board and Alberta Environment on Harmonization of Waste Management attached to ID 2000-03 outlines guiding principles that the then Alberta Energy and Utilities Board (now the ERCB) and AENV agreed on to harmonize requirements for the management of oilfield waste and non-oilfield wastes. The agreements include the division of regulatory responsibilities based on the type of waste management facility or activity.
Individuals and companies considering establishing a site to collect and manage oilfield waste should refer to the MOU attached to ID 2000-03 to determine the applicable regulatory agency: either the ERCB or AENV. Note that the ERCB derives its authority to approve oilfield waste management facilities from Section 39(1)(g) of the Oil and Gas Conservation Act , which states:
No scheme for the storage, treatment, processing or disposal of oilfield waste may be proceeded with unless the Board, by order, has approved the scheme on any terms and conditions that the Board prescribes.
In addition, licensees sending oilfield waste to landfills must meet the requirements set out in
ID 99-04: Deposition of Oilfield Waste into Landfills . Licensees found in noncompliance (i.e., sending oilfield waste to unapproved facilities or to a facility where its approval does not authorize the receipt of waste in question or the management activity/service being offered) are subject to the ERCB enforcement process set out in Directive 019: ERCB Compliance Assurance—Enforcement , which could include being responsible for remedial measures should the use of the unapproved facility result in environmental damage.
Any inquiries related to this bulletin may be directed to the ERCB Waste and Storage Section by telephone at 403-297-2034 or to the ERCB Customer Service Centre at 403-297-8311 or by e-mail at Inquiries@ercb.ca .
<original signed by>
D. K. Boyler, P.Eng.
Executive Manager
Compliance, Environment, and Operations Branch
