View PDF version

Informational Letter IL 96-04

18 March 1996

TO: All Oil and Gas Operators

EUB POLICY UPDATE AND CLARIFICATION ON THE USE OF EARTHEN PITS

Informational Letter 94-6 Discharge of Produced Liquids to Earthen Structures; Notice of Intention to Amend Existing Regulations was issued to help ensure that oil and gas developments do not result in contaminated soils or groundwater. The EUB has revisited IL 94-6 and intends, based on discussions with industry and government, to make the following changes and clarifications.

Flaring to Earthen Pits

Because the security of earthen flare pits is particularly difficult to ensure with regard to illegal dumping and disposal of waste fluids, they present a significant risk of contamination. Consequently, flaring to earthen pits will be prohibited at all new facilities constructed after 1 July 1996. Companies are encouraged to investigate appropriate alternatives to earthen pits for flaring purposes.

At existing facilities, flaring to earthen pits will be acceptable, consistent with IL 94-6, provided that there is virtually no potential for produced liquids to enter the pit. In order for these existing flare pits to be acceptable, appropriate flow shut-off and emergency containment devices shall be installed, such as high level/high pressure shutdown devices, flare knock-out drums, and wellhead ESDs, and no evidence of produced fluids shall exist in the pit.

Where proper equipment is installed, upsets to the pit should occur rarely, if at all. If an upset occurs and produced fluids enter the pit, it shall be reported to the EUB and cleaned up immediately. A review should then be undertaken to assess why the upset occurred, whether additional equipment is needed, or if the pit should be eliminated. Consecutive or continuous releases to the pit will result in enforcement action.

Storage of Fluids in Earthen Pits

The following is intended to clarify IL 94-6 and prevent misinterpretation with regard to the presence of produced fluids in earthen pits. IL 94-6 will remain unchanged with regard to the presence of produced fluids in earthen pits or structures, and the intended changes to the regulations. All produced fluids found in unlined earthen pits must be removed and properly disposed of by 31 December 1996. The EUB believes that, for the most part, time extensions beyond this deadline will not be necessary. The Board will, however, consider special requests where an operator has developed and implemented a plan, but has been unable to meet the deadline because of unforseen circumstances. Requests for time extensions or other questions regarding the elimination of storage of fluids into earthen pits will be handled by the Board's Facilities Division, and may require on-site inspections by EUB staff.

In southeastern Alberta, companies that are using centralized pits for storage of blowdown fluids will be subject to the primary containment, secondary containment, and leak detection requirements as outlined in Guide G-55 Storage Requirements for the Upstream Petroleum Industry. Companies that intend to receive and/or store third party fluids must make formal application to the Facilities Division of the EUB.

Consequences of Non-Compliance

If, as a result of a complaint, or upon inspection by EUB staff, there is found to be evidence of produced fluids in any unlined earthen pit, the following enforcement action will take place:

• Facility shut-down will result and retrofitting the facility with equipment such as emergency shut-down devices on well heads, high level/high pressure shut-down devices on separators and tanks, flare stacks, pop tanks, appropriately sized flare knock-outs, and any other devices or modifications, to the satisfaction of EUB staff.
• The facility will remain shut down until produced fluids are removed from the pit and the above modifications have been completed.
• For suspended pits, the associated facility will be shut down until all produced fluids are removed from the pit, to the satisfaction of EUB staff.
• Where the pit is causing an adverse environmental effect, the EUB will notify the Contaminated Sites Branch of Alberta Environmental Protection (AEP), who may follow-up with the operator and take appropriate enforcement action.

The Board would strongly encourage each company to review its own facilities and initiate the appropriate equipment adjustments and pit remediation as soon as possible. Should a company discover problems in meeting the intent of IL 94-6, it must contact the EUB immediately. Companies which fail to meet the requirements of IL 94-6 due to lack of action or planning should not expect to receive an exemption from the above enforcement policy.

Reclamation of Earthen Pits

As per IL 96-3 Suspension and Reclamation of Upstream Oil and Gas Facilities, remediation and decontamination of soil and groundwater for all earthen pits on both active and inactive sites will now be handled by AEP. This includes the timing of any earthen pit remediation programs. As a result, IL 94-15 Assessment and Remediation of Earthen Pits; Land Treatment of Material on Lease is no longer in effect and will be rescinded.

For any inquiries, please contact the EUB's Facilities Division at 297-3726.

[Original signed by]

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