View PDF version

Informational Letter IL 99-2

28 May 1999

TO: All Oil and Oil Sands Operators

USE OF PRODUCED SAND IN ROAD CONSTRUCTION

EXECUTIVE SUMMARY

Significant volumes of reservoir (produced) sands are produced along with heavy oil in northeast Alberta. The EUB classifies this produced sand as "non-dangerous oilfield waste."

The heavy oil industry has been actively investigating a range of options for the safe re-use and/or disposal of this sand. Recently, using this sand in roadbed construction has become a significant disposal option.

A task force was formed to determine guidelines for produced sand use in roadbed construction. Participation of various stakeholders included environmental groups, the public, the heavy oil industry, waste processors, Alberta Transportation and Utilities, Alberta Environmental Protection, and the EUB. The attached IL is the result of extensive research and review by the task force. The recommendation that this practice be allowed is based on extensive and rigorous scientific research and opinion.

The EUB is prepared, under very restricted conditions (strict limits on contaminants for example), to allow this sand to be incorporated or encapsulated into roads during construction. The primary contaminants of concern are chlorides (salt) and hydrocarbon (oil). As such, two key restrictions are:

• the chloride concentration of sand encapsulated into roads must not exceed 3000 milligrams per kilogram, and
• the concentration of entrained crude oil in the sand cannot exceed five per cent.

Other conditions will also apply, including strict controls limiting contaminants such as free water, benzene, or heavy metals. In addition, the produced sand must not be contaminated by any sources of halogenated hydrocarbons, hazardous chemicals, refined or lube oils, drilling waste, flare pit sludge, or spill clean-up materials or any other deleterious materials. Requirements for storage and sampling of the produced sand are also set out.

Companies must follow a clearly defined application process that involves both the EUB and the local county or municipal district. The appropriate EUB Field Centre will issue an approval to use produced sand in road construction, should a tendered application meet all EUB requirements.

The EUB notes that, because of varying native soil properties and other geographical features, not all roads are suitable for using produced sand during construction. The Board expects the local county or municipal district accepting the produced sand and the oil company which generated the material to carefully evaluate site characteristics and ensure proper practices are adhered to.

Failure by a company to comply with the requirements of the new guidelines will result in EUB enforcement actions, which may include immediate suspension of the road project and immediate implementation of corrective action. Future approvals for using produced sand in road construction may also be withheld.

A key issue considered in formulating this guideline was who would be liable for any environmental contamination that might result from using produced sand in roadbed construction? Both the task force and Board sought legal advice on this question.

The understanding of the Board, based on that advice, is that there are four parties that could potentially be held liable for addressing any contamination. These parties are: owners and past owners of the produced sands, those in charge, management and control of the produced sands, directors and officers of the companies and successor companies that generated the produced sands, and owners and past owners of the roads.

These guidelines will be subject to review every two years, or as necessary.

1 INTRODUCTION

This Informational Letter outlines the EUB guideline for produced sand to be used as construction material in roads. The produced sands referred to in this document are limited to the solids (reservoir sand) recovered from heavy oil operations in north-east Alberta. This material contains small quantities of hydrocarbons and chlorides and may be used in road construction in accordance with this document.

This guideline, includes criteria, site restrictions, application requirements, audit, and enforcement expectations for produced sand generators.

As a companion to Part F Section 29.0 "Spreading of Oily By-Products to Roads" in Guide 58, Oilfield Waste Management Requirements for the Upstream Petroleum Industry, this guideline will be subject to regular review every two years or as required. Further, it will be added into Guide 58 in due course. Some of the terminology used in this guideline have been given specific definitions, as noted below, which are consistent with road construction practice but may not necessarily match other accepted definitions for those terms.

2 CHARACTERISTICS OF PRODUCED SAND

Based on the characteristics noted below, produced sand is typically classified as non-dangerous oilfield waste and therefore, is equivalent to waste classified as non-hazardous under the Alberta Environmental Protection and Enhancement Act, Waste Control Regulation. Produced sand typically found in north-east Alberta, generally falls within the ranges for the parameters¹ listed here:

flashpoint	greater than 61 degrees Celsius
total petroleum hydrocarbon	10 000 to 150 000 mg/kg (using Dean Stark Method)
chloride	200 to 30 000 mg/kg
sodium	150 to 20 000 mg/kg
trace metals	similar to soil background values
particle size	fine to very fine sand (250 to 62.5 microns)
pH	6 - 8

¹ Established from EUB and industry databases. Variances are the result of different reservoir conditions and operator production and storage practices.

Although the information indicates that within produced sand the concentrations of crude oil, sodium, and chloride can range drastically, the average concentrations typically found are around 3.5 per cent or 35 000 mg/kg oil, 2000 mg/kg sodium, and 3500 mg/kg chloride. Considering that 93 per cent or more of the components within heavy crude oil boil at a temperature greater than 225 C, the residual crude oil within the produced sand is of high molecular weight and therefore, monoaromatic hydrocarbons (benzene, toluene, ethylbenzene, and xylenes) occur at extremely low levels.

Although the pH of produced sand typically ranges from 6 to 8, the receiving road material would easily buffer a pH range between 4 and 9. Therefore, the requirement to measure the pH of the produced sand has been dropped from the criteria listed below.

Publications and scientific literature relating to road construction practices indicate that higher molecular weight hydrocarbons such as bitumens and asphaltenes are used as soil stabilizers in the preparation of road sub-bases and grades. The literature also indicates that the presence of sodium in clay material decreases the permeability of the admixed soils while chlorides provide additional stabilization and freezing point depression. Relating this information to the characteristics of produced sand, the Task Force deems that produced sand is an acceptable construction material for roads and poses minimal environmental and safety risks provided the criteria and requirements set out below are met.

3 CRITERIA

Produced sand generated during in situ oil sands and heavy oil production in north-eastern Alberta may be incorporated or encapsulated into roads during their construction provided the following criteria are met:

6 SITE CHARACTERISTICS AND RESTRICTIONS

As a result of native soil properties and other geographical features, not all roads will be suitable for the encapsulation or incorporation of produced sand during their construction. In addition to the produced sand meeting the criteria specified in Section 3.0, the following road site characteristics and restrictions provide added environmental protection against the potential migration of salt or hydrocarbon contained within the produced sand used in a road construction project.

It is the responsibility of the local authority (county/municipal district) and operator (generator of the produced sand) to ensure these site characteristics and restrictions are adhered to. It is also expected that roads having produced sand incorporated or encapsulated into them, must be constructed following acceptable engineering practices (current Alberta Transportation and Utilities Standard Specifications for Highway Construction). The local authority, by allowing produced sand to be used as a road construction material, must agree that it will be used in accordance with this document.

11 PRODUCED SAND (WASTE) TRACKING

Section 9.0 of EUB Guide 58, Oilfield Waste Management Requirements for the Upstream Petroleum Industry, requires oilfield waste generators to implement and maintain a waste tracking system for the oilfield wastes listed on Table 9.1, Reportable Oilfield Wastes. As produced sand is an oilfield waste that is listed on Table 9.1, it must be tracked from the point of initial generation to final disposition. A road that has been constructed with produced sand incorporated or encapsulated into it, would be considered a final disposition point for the produced sand. Therefore, the volumes of produced sand used in the road construction and the location of the road must be recorded in the tracking system.

All tracking systems must be effective and capable of displaying due diligence. At any time, the EUB may audit a generator's waste tracking system or request the generator to provide information pertinent to the waste tracking system. As well, generators must be able to summarize the tracking information into an oilfield waste disposition report. For further information on oilfield waste tracking and reporting please refer to Part C, Guide 58.

12 LIABILITY

Although the Task Force believes produced sand is an acceptable construction material for roads and poses minimal environmental and safety risks, a key issue considered was who would be liable for any environmental contamination that might result from the use of produced sands in road construction. While the final answer to such a question may ultimately reside with the Courts, the Task Force and the Board did obtain legal advice on the question. The understanding of the Board, based on the results of that review, is there are four general parties that could potentially be held liable for addressing any contamination that might occur. These are:

• owners and past owners of the produced sands,
  
  
• those in charge, management, and control of the produced sands,
  
  
• directors and officers of the companies and successor companies that generated the produced sands, and
  
  
• owners and past owners of the roads.

On the basis of the above, the Board believes that landowners whose property abuts onto roads incorporating/encapsulating produced sand should not, provided that they do not also fall into one of the above categories, face any liability or bear any subsequent responsibility for clean up to either their land or water, in the unlikely event that contamination might arise from the use of produced sand as road construction material.

[Original signed by]

J. D. Dilay, P.Eng.
Board Member

Attachments

APPENDIX 1: Recommended Practices of Sampling Protocol for Roadbed Construction

1 SAMPLE COLLECTION

1.1 Core Sampling Method

A representative sample must be obtained from each sand storage facility whose contents are to be used in the incorporation/encapsulation project in questions. The preferred method is to collect a composite sample made up of sub-samples collected from a grid pattern spaced evenly across the storage facility. The full depth of the produced sand is to be sampled if possible, or every 1.5 – 2.5 m interval.

As a rough guide to sampling intensity for pits less than 500 square m in area, a inimum of 5 sub-samples should be taken. For pits greater than 500 square m in area, a minimum of 9 sub-samples should be taken. The sub-samples should be mixed together into 1 composite sample.

Sub-samples should be collected using Shelby Tubes or hollow metal or PVC tubes 50 - 75 mm in diameter and sufficient length, or with sufficient extensions, to sample the full depth of the produced sand.

Prior to sampling a sand storage facility, the core sampler should be thoroughly cleaned to avoid cross contamination of the samples. This can be done using a steam cleaner or a three-stage process like the following example: The first stage cleaning should be done with an oil solvent, such as varsol and a wire brush and clean rag pull-through. The second stage should be done by rinsing with acetone or hexanol, until a clean cloth can be pulled through. Finally, a distilled water rinse should be used to remove any residue from the sampler.

NOTE: For produced sand stockpiles of a height greater than 2.5 m, sampling is required every 1.5 – 2.5 m interval.

1.2 Backhoe Method

An alternate method for taking the samples is to collect representative samples using a backhoe. Sub samples should be collected using a grid pattern similar to that described for core sampling. The full depth of the produced sand should be included in the subsample as much as possible.

It is not practical to wash the backhoe bucket in a similar fashion to that described for core sampling. Therefore, in order to ensure that the sub-samples do not become contaminated by mixing with previously sampled materials, enough of the material contained in each bucket must be sliced away using a clean spade or trowel so that a subsample slice or representative grab sample can be taken away from the sides of the bucket. Prior to sampling the pit, or tank, the sampling tool must be cleaned using the three stage wash similar to the one described for core sampling.

2 SAMPLE HANDLING

Sub-samples from the field containers (usually 20 L high density polyethylene pail) should be taken following the protocol below:

• visually examine the sample,
  
  
• combine sub-samples in a field container and mix thoroughly to form a composite sample,
  
  
• take sample from field container and place in a clean (1 L) glass jar with a Teflon-lined lid.

The sample jar must be immediately labelled with a unique identification number and the sample identification sheet must be filled in. The jar must be properly labelled to comply with WHMIS requirements.

A copy of the sample sheet, including the Produced Sand Characterization for Road Incorporation/Encapsulation Data Sheet, must be sent with the sample to the laboratory.

Due to the complexity and precision in this analytical program, operators are requested to use a major laboratory qualified to analyze produced sand samples specific to the needs of produced sand characterization.

Note: The above sample collection and handling methodologies were developed jointly by industry, government and chemical laboratories using accepted industry standards modified for unique heavy oil operations. Any proposed alternate sampling method must provide a level of protection which, in the EUB's opinion, is equal to or greater than these requirements and must receive EUB approval

APPENDIX 2: Produced Sand Characterization For Road Incorporation/Encapsulation Data Sheet

Appendix 2 Produced Sand Characterization For Road Incorporation / Encapsulation Data Sheet Laboratory Name: ___________________ Lab Sample Number: _______________ Date Received:_______________ Field Sample Number: _________________ Date Analyzed: _____________

Sample Information

Operator:

Source: (i.e. ecology pit, desand tank etc.)

Pit Location : LSD __ __ __ __W M

Proposed Volume:

Pit Name_________________________________

Road Location: from LSD __ __ __ __W M to LSD __ __ __ __W M

Total Petroleum Hydrocarbons (Dean Stark Soxhlet Extraction Method)

1:9 Water Extraction Method

Particle Size Distribution Soil Sampling Methods of Analysis Hydrometer or pipette method – (Carter) (Encapsulation Only)

Oil Concentration: (< 5 %)

%

Chloride/Cl: (<3,000mg/kg)

mg/kg

Total Metals (US EPA 3050 or 3051 (SW 846))

.

Concentration

.

Concentration

.

Concentration

% Silt (< 30 %)

Cadmium/Cd (<1.4)

mg/kg

Nickel/Ni (<150)

mg/kg

Lead/Pb (<70)

mg/kg

% Clay

Mercury/Hg (<6.6)

mg/kg

Zinc/Zn (<200)

mg/kg

Copper/Cu (<63)

mg/kg

% Sand

Total BTEX (EPA Method 8240 or 8020)

Flashpoint (Pensky- Martens Closed Tester ASTM D93-80)

.

Concentration

.

Concentration

(>61OC)

°C

Benzene (<0.5 mg/kg)

mg/kg

Toluene (<0.8 mg/kg)

mg/kg

Ethylbenzene (<1.2 mg/kg)

mg/kg

Xylene (<1.0 mg/kg)

mg/kg

.

The undersigned hereby certifies that the information is accurate and in accordance with the requirements of Section 3.

Signed: ___________________ (Laboratory Representative) _____________________ (Operator Representative)

1. Produced sand sample must not contain halogenated hydrocarbons, hazardous chemicals, refined or lube oil, flare pit sludge, or deleterious substances such as filters, rags, vegetation, and other debris including significant volumes of contaminated agricultural soils.
2. Information must be available that verifies the crude oil from which the produced sands are recovered has a density greater than 920 kg/m³.

APPENDIX 3: Application / Approval for Road Incorporation/Encapsulation

Please indicate with an (x) which type of submission		EUB File #
Initial Application or		EUB Signature :
Final Submission (incorporation/encapsulation completed)		EUB Approval Date :

General Information
Operator Name: _____________________________________________ _________
Local Authority (County/MD): ___________________________________________________
Engineering firm responsible for design of road: _____________________________________
Contractor building the road: ____________________________________________________
Is written consent from Local Authority (MD/County) as per Section 6.0 and 7.2 attached? (Yes/No) ________

Sand Information
Storage Facility location: LSD:_____________________ Pit Number/Name:______________________
Produced sand only: (Yes/No) ________ Proposed volume for this road: ________ m;
Proposed dates of incorporation/encapsulation: From: __________________To: _________________

Sand Sampling/Analysis Information
How was sampling done? (Core/Backhoe method) _________________ Sampling depth: _________m
Date of analysis: _____________ Are initial analysis attached? (Yes/No) _______
Oil content: ________ % by volume Chloride Concentration: ______ mg/k Silt _____ % (For encapsulation only)
Are more analyses required? (1 sample every 1.5 – 2.5 metres depth of stockpile) (Yes/No) _______
If yes date sampled: Date of analysis:
Are additional analyses attached: (Yes/No) _______

Consultation Information
Have all directly adjacent landowner/residents been notified? (Yes/No) ________

Road Information
Road location: From: LSD: _________________W__M To: LSD:__________________W__M
Has Engineering assessment been done? (Yes/No)______ Background Soils Properties: EC _____dS/m
Plasticity Index: ______% Liquid limit: _____% Clay Fraction _____% Are initial analyses attached? (Yes/No)________

Final Submission:
Was cell/trucks unloading sample analysed? (Yes/No) _______
Is cell/trucks unloading information attached? (Yes/No) ______ Actual amount of sand incorporated: _______ m³

Produced Sand Owner/Representative

Name: ____________________ Signature:____________________ Date:_______________

(print name)

NOTE:	By signing this form as a representative of the operator, I agree to follow the requirements for the use of produced sand in road construction, including adherence to Section 6.0 Road Site Characteristics and Restrictions.
APPLICATION:	For EUB approval, a copy of this sheet and the following must be submitted: written consent from MD/County, a copy of the initial analyses, and notification list.
FINAL SUBMISSION:	Please submit this sheet to Local Authority and EUB with all supporting documents, extra analyses, etc.

APPENDIX 4: On-Site Incorporation/Encapsulation Check Sheet

APPENDIX 4
* Submit to MD or County and retain on file			EUB File Number: ____________
ON-SITE INCORPORATION/ENCAPSULATION CHECK SHEET
	Yes	No	Remarks
Please submit this sheet to Local Authority and EUB with all supporting documents, extra analyses, etc.	.	.	.
Do you have a copy of the EUB Approval?	.	.	.
Is resample required due to depth of stockpile?	.	.	.
Is the produced sand segregated from slop oil / spill clean up material?	.	.	.
Has the sampled sand been re-stacked / segregated from daily inventory?	.	.	.
Have Truck/Loader/Vac truck Personnel been informed?	.	.	.
Is the sampled sand being hauled?	.	.	.
Has truck inspection been done? (No sand loss)	.	.	.
Is there a Designated Truck Route ?	.	.	.
Has Notification of Affected Parties been Conducted?	.	.	.
Is the sand being applied to the proper depth and location for cells?	.	.	.
Is the sand being incorporated at a 1:3 ratio and at the proper location	.	.	.
Are truckloads being sampled?	.	.	.

Produced Sand Owner/Representative Name:_____________________ Date:______________

(print name)

Signature:________________________________

APPENDIX 5: Daily Road Information Check Sheet for Cells

APPENDIX 5

* Submit to MD or County and retain on file

DAILY ROAD INFORMATION CHECK SHEET FOR CELLS

ROAD INFORMATION

SOILS CONDITIONS REMARKS

DATE

COMMENTS / REMARKS

Survey Pin Numbers

Sand Delivery Composite per cell

Weather (eg. 16°C, Cloudy)

Area of Cell              (m 2 )

Total Vol. per cell           (m 3)

Total cover (depth)

Road Information

Sand Lens Yes/No

.

* If cell is closed due to rain, record actions taken. The cell maybe covered and continue when weather permits.

From

To

Sample / Comments

Before

During

After

.

.

.

New

Re-built

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

• Additional items may include: as built plans submitted to MD/County

APPENDIX 6: Engineering & As-Built Plans

This section outlines the plan requirements industry must consider to incorporate or encapsulate produced sand into a statutory roads.

Required Engineering Plans

The mosaic plan/profile shall be prepared prior to construction and shall contain the following:

• Profile of existing road surface or natural ground at centre line.
• Profile of natural ground at each edge of the right-of-way.
• Elevation of the design grade line and proposed ditch bottoms.
• Elevation and location of proposed drainage structures.
• Drainage plan for the area (0.8 km on either side of the road).
• Typical cross-sections of proposed road.
• Location and elevation of bench marks used for the survey and design.
• Land locations on plan view.
• Location and size of any water bodies including sloughs, ponds, dugouts, lakes, creeks, rivers, streams, and coulees into which surface drainage from the project could enter.
• Existing and proposed right-of-way drafted on plan view.
• Location of residences and any known water wells in the area.
• Mass haul diagram.
• Sections of road where produced sand will be placed indicating depth and width.
• Bore hole test results.
• Depth of water table encountered in test holes.

As-Built Plans

Upon completion of road construction, three copies of a signed and stamped engineering report documenting compliance with soil properties and the as-built plan/profile shall be prepared for the operator, County/Municipal District and the EUB. It should also contain the following information:

• The location, width and depth of the produced sand incorporated or encapsulated into the road sub-grade.
• The total amount of produced sand in tonnes incorporated or encapsulated into the road sub-grade.