Surface Development Clarification
The distance required to the nearest "surface development" provides the EUB with an indication as to whether a site specific ERP is required. Please note that the distance has no bearing on the Directive 056 participant involvement requirements.

Surface Development Definition
The following definition replaces the previous "distance to nearest occupied dwelling" in Schedule 4, Step 10 of the Guide 56 (October 2000) (now Directive 056). The change in text was required to coincide with the new "surface development" definition set out in Guide 71: Emergency Response Planning (now Directive 071). The definition in Appendix 3 of Directive 056 (October 2003) quotes Directive 071, stating that a surface development is:

An occupied permanent or part-time dwelling, a publicly used facility, including a campground, a place of business, and any other surface development where the public may gather.

Place of Business
A "place of business" with respect to oil and gas developments will include the nearest off-lease building that is manned by staff or where people may work or gather on a regular basis. An example of a nearest off-lease place of business would be a field office located at a compressor station in the adjacent section where people may gather on a regular basis. A compressor, pipeline, or wellhead without a manned building would not be considered a place of business.

Please do not record the distance to the nearest well, facility, or pipeline as the distance to the nearest "surface development" unless there is a building on the lease or right-of-way where people may gather on a regular basis.

Distance to Nearest Surface Development
In order to answer the question "Distance to nearest surface development" on Schedule 2, 3 (pipeline installations only), or 4 the applicant must locate the distance to the nearest surface development from either:

• the well centre
• edge of pipeline right-of-way, or
• the edge of the facility lease

Survey Plan or Plot Plan
The survey plan or plot plan must meet all Directive 056 requirements and should reflect the distance to the nearest:

• dwelling whether occupied part time or fulltime (e.g.; house, seasonal cottage, trapper's cabin),
• publicly used facility (e.g.; church, community centre, campground, curling rink),
• place of business (as described above), or
• other surface development where the public may gather

Remote or Undeveloped Areas
The distance to the nearest surface development is used to determine if a site specific ERP is required. In remote or undeveloped areas, the applicant must initially search to the distance of the emergency awareness zone  (EAZ) (two times the  size of the emergency planning zone  EPZ ) for any surface developments. If there is no surface development within the EAZ, the applicant may record a distance to the nearest town, village, or urban centre. Where there is no EPZ the search should encompass at least 1.5 km. The applicant may then choose to use 1.5 km as the distance to the nearest surface development. This process is to be used only in remote or undeveloped areas for the purpose of a Directive 056 licence application.

Surface Development and Surface Improvement
The term "surface development" should not be confused with the definition for "surface improvement". Please refer to Directive 056, Appendix 3 for a definition of "surface improvement".

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For AENV guidance when siting an upstream oil and gas site on private land, please refer to R&R/03-2 "Siting an Upstream Oil and Gas Site in an Environmentally Sensitive Area on Private Land", can be viewed at AENV website located at: http://environment.gov.ab.ca/info/library/5940.pdf

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No person shall construct a pipeline or any part of a pipeline or undertake any operations preparatory or incidental to the construction of a pipeline unless the person is the holder of a licence or unless the person is acting pursuant to a direction of the Board under section 33 authorizing the person to do so

Section 6 (1) prohibits any preparatory or incidental operations, on private or public lands, prior to receiving a pipeline licence from the EUB. However, Section 6(2) of the Pipeline Act allows for access to the lands, prior to issuance of a licence, to make surveys and for negotiation purposes. Therefore, a company may not do any preparatory work prior to receiving pipeline licence approval from the EUB. The exception to this would be by direction of the Board under section 33 of the Pipeline Act and to conduct surveying of the pipeline right-of-way for the purpose of a pipeline licence application.

The EUB Reference Tool for Sour Service Conversion of Existing Carbon Steel Pipelines document compiles the current CSA sour service requirements in a comprehensive manner and highlights certain requirements already contained in Directive 056: Energy Development Applications and Schedules. The document is located on the EUB website at http://www.ercb.ca

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When an application to the EUB for a Category C or D surface pipeline is required, the applicant must include documentation to support the design, safety, and need for the pipeline, as described below. Be sure to refer to Directive 056 and the current Directive 056 Errata, Section 6.9.10: Surface Pipelines and Step 7: Technical Considerations for all details.

Design Considerations
Design requirements for surface pipelines are described in Section 21 of the Pipeline Regulation, which states:

21    (1) A licensee of an existing pipeline, well or facility who intends to install a surface pipeline for temporary service shall do so in accordance with the requirements set out in this section and in Directive 56.

(2) A licensee shall install

(a) a form of pressure-relieving device if any possibility of a pressure increase above the allowable maximum operating pressure exists due to a rise in ambient air temperature or solar heating,
(b) a system to allow for adequate expansion or contraction due to temperature change,
(c) temperature monitoring equipment if the pipeline material has temperature limitations,
(d) suitable restraints to adequately control lateral or vertical movement, and
(e) any other safety or operational systems the Board considers appropriate.

(3) A licensee shall bury the pipeline at all road and trail crossings and shall install pipeline warning signs at the point of pipeline entry and exit of each crossing.

(4) A licensee shall take additional precautions, including adding extra pipeline warning signs or providing other warnings to indicate the presence of a surface line, when

(a) equipment may be working in the vicinity of the pipeline,
(b) off road vehicular traffic may endanger the pipeline, or
(c) any conditions may obscure or endanger the pipeline.

In addition to the above, the applicant must provide

• a detailed explanation of the pipeline design that includes consideration of the downstream pipeline effects and compatibility with connecting pipelines, and
• information on the corrosion control, monitoring program, and mitigation measures for the proposed surface pipeline, which includes assessing any impacts that adding and later removing the flow will have on the flow regimen of the connecting pipelines.

Safety Considerations
The applicant is required to provide a description of the measures that will be taken to protect the pipeline from third-party damage.

Need
The applicant is required to provide a discussion regarding the need for the surface pipeline, whether permanent or temporary.

Please keep in mind that the EUB's Operations Group, Pipeline Section, will review the application and supporting documentation; therefore, the applicant should allow for review time when making a surface pipeline application.

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.

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• and the Directive 056 participant involvement program was not completed prior to April 8, 2008, you are required to ensure that the new EPZ based on the requirements of the April 2008 edition of Directive 071 has been reflected in the project-specific information package and that the radius of personal consultation and confirmation of nonobjection for category C, D, and E wells is based on the new EPZ prior to submitting a Directive 056 application; or
   
• if the Directive 056 participant involvement program was completed prior to April 8, 2008, based on EPZ calculations from the 2005 edition of Directive 071 , you will be required to renotify residents in accordance with Table 3 of the 2008 edition of Directive 071 prior to the submission of your Directive 056 application. This means that if the EPZ increased, notification of residents within the expanded portion of the EPZ is required, or if the EPZ is smaller, notification of residents who are no longer in the EPZ is required. Enforcement action will not be applied to applications processed during the Directive 071 (April 2008) transition period, April 8 to July 2, 2008, for noncompliance issues related to Directive 056 EPZ requirements

For applications currently before the Board in a hearing process, the decision to require the applicant to recalculate the EPZ using ERCBH2S and rewrite its plan in accordance with the requirements in the April 2008 edition of Directive 071 will be at the discretion of the Board and considered on a case-by-case basis.

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• enter the outside diameter, wall thickness, material (MAT.), type, grade, and joints of the existing pipe,
• enter the maximum operating pressure (MOP) of the proposed liner,
• do not fill in the stress level (i.e., should be left blank), and
• enter an ‘L’ in the internal protection (IP) box to indicate that a free-standing liner is being installed.

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