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Directive 056: Frequently Asked Questions – Pipelines Technical

It appears that a blocked MSL area boundary may be misinterpreted as a single surface lease boundary. Consequently, any surface pipelines wholly contained within a blocked MSL that connect a well pad to a central processing plant might be erroneously considered exempt, as set out in Directive 056, Section 6.5.2.

The ERCB would like to clarify that the facility surface lease boundary described in both Directive 056, Section 6.5.2, and the Pipeline Regulation, Part 1, Section 3(3b), is not the same as the area boundary defining a blocked MSL issued by SRD. Rather, a facility surface lease boundary is specific to the lease boundary of each well pad, facility, or central processing plant.

In situ oil sands surface pipelines wholly contained within the boundary of a well pad, facility, or central processing plant and also located within a blocked MSL would not require a Directive 056 licence.

In situ oil sands surface pipelines that extend beyond the well pad, facility, or central processing plant lease boundary but are still within the blocked MSL area boundary require a Directive 056 pipeline application to be submitted and approved prior to construction. In such instances, the participant involvement requirements conducted under Directive 023: Guidelines Respecting an Application for a Commercial Crude Bitumen Recovery and Upgrading Project would satisfy the participant involvement requirements for the Directive 056 application.

Applicants are strongly encouraged to review existing in situ oil sands surface pipelines to ensure that they meet current Directive 056 licensing requirements. Any applicants that identify existing in situ oil sands surface pipelines that require licensing must submit to the Facilities Applications Audit Section a complete self-disclosure application, as set out in Process Clarification for Licensing Pipeline Amendments, Scenario 3.

Companies are reminded that licences for surface pipelines associated with oil sands mine approvals are not issued under Directive 056 unless the pipelines cross a public road or watercourse.  

Submit an application to ERCB Facilities Applications for any request for permanent bi-directional flow pipeline operations. Temporary bi-directional flow pipeline requests are currently submitted and reviewed by ERCB Pipeline Operations.

The ERCB needs to review and document all pipelines being licensed for permanent bi-directional flow before approval, whether the requests are for new pipelines or for amendments to existing lines. The applicant must file its application as nonroutine by filling out all applicable questions on Schedules 3, 3.1, and 3.2, including the following:

1)   Schedule 3: Pipeline Licence Application

Under Step 5: Licence Amendment Only, check “Other” and enter “Perm. Bi-directional.”

2)   Schedule 3.1: Segment/Installation Identification

Under Step 4: Pipe Location and Status, enter the “From” location and “To” location according to the project’s most common direction of flow.
 

3)   Schedule 3.2: Technical/Environmental Information

Under Step 2: Technical Considerations, check “No” for Question 3: The pipeline meets all current applicable CSA Z662 standards.

The following is the minimum supporting information applicants must submit with each application:

• A description of the proposed project and an explanation of the need for a permanent bi-directional flow pipeline.
• Confirmation that the requirements of CSA Z662 and the Pipeline Act are met.
• A description of the pipeline design and configuration, its suitability for the difference in pressure gradient to operate in both directions, and the suitability of the corrosion control for the bi-directional flow operation.
• A description of the tie-in compatibility for both flow directions (e.g., maximum operating pressures, substance, etc.).
• A description of the internal and external condition of the pipeline.
• A pipeline piping & instrumentation diagram.
• A pipeline right-of-way plan.
• A pipeline base map.

E NVIRONMENTAL REQUIREMENTS

If the proposed ROW crosses a water body as defined by the Water Act but not by the Code of Practice for Pipelines and Telecommunication Lines Crossing a Water Body , the applicant, before licensing, must contact Alberta Environment (AENV) to determine if Water Act approval is necessary. The Code of Practice defines a water body as having a defined bed and bank, whether or not water is continuously present, but does not include fish-bearing lakes.

If AENV determines that Water Act approval is not required, the applicant may proceed with an application submission. If AENV determines that Water Ac t approval is required, the applicant may still proceed with an application submission but must get Water Act approval prior to construction.

When filling out Schedule 3.2 – Step 6, Question 2:

YES     means that you will notify AENV as required by the Code of Practice or, if the Code of Practice does not apply, that you have consulted with AENV about the need for Water Act approval.

N/A      means that no water body crossing as defined by the Water Act is involved.