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Bulletin 2009-25

July 30, 2009

The Energy Resources Conservation Board (ERCB) is responsible to maintain and administer material storage requirements for the upstream petroleum industry. These requirements are set out in Directive 055: Storage Requirements for the Upstream Petroleum Industry.

Directive 055 was last revised in 2001. The ERCB is finding repeat noncompliances with some of the requirements in Directive 055 and has been responding to numerous queries from industry and consultants seeking clarification of some of the requirements.

A discussion document (Report 2009-A: Updates to Storage Requirements for the Upstream Petroleum Industry—Discussion Document on Directive 055) has been prepared to communicate potential updates and clarifications to Directive 055 in the following areas:

• excluded material types and storage systems
  
• alternative storage systems
  
• permanent storage devices not requiring secondary containment
  
• temporary storage
  
• dike and tank integrity verification requirements for pre-1996 sites
  
• dike size and capacity
  
• schedule for repeat integrity testing of tanks
  
• secondary containment for small aboveground storage tanks
  
• use of open-topped, nonmetallic tanks with an internal volume less than 30 cubic metres (m3)
  
• construction and installation factors for aboveground storage tanks with an internal volume ≥5 m3
  
• weather protection for steel aboveground storage tanks with an internal volume ≥5 m3
  
• design of double-walled aboveground storage tanks
  
• monthly leak detection requirements for underground storage tanks
  
• inspection, monitoring, and record keeping
  
• on-site storage of small volumes of oilfield waste
  
• revision of surface discharge criteria for collected surface run-on/run-off waters

The ERCB consulted with Alberta Environment, Alberta Municipal Affairs, Canadian Association of Petroleum Producers, and Small Explorers and Producers Association of Canada during the development of this discussion document.

Report 2009-A: Updates to Storage Requirements for the Upstream Petroleum Industry—Discussion Document on Directive 055 is available for review on the ERCB Web site www.ercb.ca under Industry Zone : Rules Regulations Requirements : Directives : Directive 055. The ERCB invites comments on the discussion document. Feedback may be electronically submitted (by e-mail or e-mail with an attached Word file) to wasteops@ercb.ca, with the subject line “Directive 055 Discussion Document Feedback”; hard-copy feedback may be mailed to Susan Halla, ERCB Environment Group, 640 – 5 Avenue SW, Calgary, Alberta T2P 3G4.

The ERCB would appreciate that the responses be formatted to identify

• the specific section of the discussion document of issue, including the page on which it appears,
  
• what the issue is,
  
• possible solutions or recommendations, and
  
• rationale to support the solution or recommendation

Comments received will be taken into consideration when finalizing the updates and clarifications to Directive 055. Comments will be accepted until September 30, 2009.

<original signed by>

Dwayne Waisman, B.E.S., C.E.T.
Executive Manager
Field Surveillance and Operations Branch