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Bulletin 2009-26

July 31, 2009

Requirements on Waste Transport by Pipeline and Waste Tracking

Variations in the quality of crude oil streams being received at refineries are impacting their operations. The Energy Resources Conservation Board (ERCB) reminds upstream petroleum licensees and approval holders of the requirements in Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry regarding the transport of oilfield wastes by pipeline. 
Directive 058, Section 6: Wastes Banned from Disposal via Injection into Pipelines Systems, states the following:

• Upstream oilfield wastes that can be separated from production streams and can be harmful to oil handlers must not be diluted by injection into pipelines.
• Pipelines must not be thought of as a “mixing vessel” for waste dilution.
• For safety, environmental, corrosion, operational, and economic reasons, the oilfield wastes identified in this subsection are banned from direct injection into any pipeline system. The rationale for this is based on non-hydrocarbon content, chemical composition, water content, solids content, and/or the availability of practical cost effective waste treatment methods.

Directive 058, Section 31: Waste Transport by Pipeline, identifies the introduction of inappropriate oilfield wastes into crude oil pipelines as a waste management issue, as well as a crude quality issue, which must be addressed by the producers, pipeline licensees, and refinery companies together. It states that certain (listed) waste types may be injected into a pipeline system only if the following control conditions are met:

• the waste has a usable hydrocarbon content and does not pose a downstream handling problem, and
• specific agreements have been arranged between the waste producer, the pipeline licensee, and the refinery for which the specific waste volume is destined.

Adherence to the above conditions is an ERCB requirement and will be monitored as part of the ERCB oilfield waste management surveillance program. If the ERCB determines that wastes are being injected into pipeline systems in violation of the Sections 6 and 31 requirements, it will reconsider its policy to permit waste transport by pipeline as an oilfield waste management option.

The ERCB reminds industry of the addition of new wastes codes with the February 13, 2009, release of Directive 047: Waste Reporting Requirements for Oilfield Waste Management Facilities. The new waste codes were also set out in a March 26, 2009, announcement on the ERCB Web site www.ercb.ca. The new wastes codes are to be used for waste tracking and to be reported in the 2009 Annual Oilfield Waste Disposition Report. The ERCB has added “waste transport by pipeline” as a disposition type and requires industry to include information about oilfield wastes being managed by transport by pipeline in their Annual Oilfield Waste Disposition Reports.

For information on requirements regarding waste tracking and submission of the Annual Oilfield Disposition Report, refer to Section 9 of Directive 058 and to Directive 030: Digital Data Submission of the Annual Oilfield Waste Disposition Report.

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 Services Contact Centre by e-mail at Inquiries@ercb.ca.

<original signed by>

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