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Informational Letter IL 94-6

24 March 1994

TO: All Oil and Gas Operators

DISCHARGE OF PRODUCED LIQUIDS TO EARTHEN STRUCTURES
NOTICE OF INTENTION TO AMEND EXISTING REGULATIONS

As of 31 December 1996, oil and gas operators will no longer be permitted to place or store produced liquids into earthen pits or structures. Produced fluids are considered to include crude bitumen, liquid hydrocarbons, process chemicals, and water produced from oil wells, gas wells, and associated batteries and other similar facilities regulated by the ERCB. To accomplish this, the ERCB intends to amend sections 8.010, 8.020, and 8.040 of the Oil and Gas Conservation Regulations (Appendix A).

These changes are intended to help ensure that oil and gas developments do not result in contaminated soils or groundwater. Pits and other earthen structures containing produced liquids are found to present a significant risk of such contamination. Operators who discover such contamination in the course of meeting these regulations must modify their existing facilities to prevent ongoing contamination and to initiate remediation appropriate to the level of environmental risk.

For a description of current acceptable approaches to the storage and disposal of produced fluids, operators should refer to ERCB Informational Letter IL 93-8 and the ERCB's 1993 draft "Recommended Oilfield Waste Management Requirements". Earthen structures, if properly designed, will continue to be acceptable for purposes such as fire-walls, run-on and run-off control, and emergency containment (eg. tank dyking).

Flare pits will also continue to be acceptable, provided that there is virtually no probability of produced liquids entering the pit. This can be accomplished through both good design (eg. flare knock-outs, oversized separators) and good operating practices. Because of the inherent risk of contamination, the Board would expect operators to consider various alternatives before selecting a flare pit.

It should be noted that the amended regulations will not apply to:

• oil and gas facilities where produced liquid storage is approved by Alberta Environmental Protection,
• drilling sumps (see ID 93-1 and Guide G-50 for these requirements), and
• shallow gas wells in southeastern Alberta (see IL 93-10 for these locations and associated requirements).

Should oil and gas operators continue to have concerns or questions as to how and when the Board intends to enforce these amended regulations, they are encouraged to contact the ERCB's Environment Protection Department at 297-3185 at their earliest convenience.

[Original signed by]

B. F. Bietz, Ph.D., P.Biol.
Board Member

Attachment

APPENDIX A
INTENDED AMENDMENTS TO THE
OIL AND GAS CONSERVATION REGULATIONS

Effective 31 December 1996, the Energy Resources Conservation Board will amend the Oil and Gas Conservation Regulations as follows:

Oil and Gas Conservation Amendment Regulation

• The Oil and Gas Conservation Regulations (Alberta Regulation 151/71) are amended by this Regulation.
• Section 8.010 is repealed and the following is substituted:
  8.010
  • Earthen structures or excavations shall not be used as receptacles for crude bitumen-liquid hydrocarbon, process chemicals, or water produced from a well or associated facility either by design or normal operating practice without the written approval of the Board.
• Section 8.020 is repealed. Amendments to section 8.010 now make this section redundant.
• Section 8.040 is repealed and the following is substituted:
  8.040
  1. The licensee of a well or the operator of a battery or processing plant or associated facility shall store and dispose of all water produced from a well in a matter satisfactory to the Board.
  2. No water produced from a well shall be discharged into an earthen structure or excavation either by design or normal operating practice without the written approval of the Board.
  3. All water produced to a battery, or produced at a well not connected to a battery, or produced at a processing plant, shall be disposed of in accordance with a scheme approved by the Board pursuant to section 26 of the Act.