Professional Sign Off & Environmental Assurance

 

Professional Sign Off & Environmental Assurance

WITHIN THIS SECTION

Upstream Oil and Gas Reclamation & Remediation Program


Environmental Assurance

Professional sign off is required for all upstream oil and gas reclamation certificate work.

Operators have a 25 year liability for surface reclamation issues (topography, vegetation, soil texture, drainage, etc.) and lifetime liability for contamination.

Public notice of application will be provided in accordance with the Responsible Energy and Development Act. People who believe they may be directly and adversely affected may file a statement of concern with the AER within the time periods specified in the public notice.

Once a decision is made on a reclamation certificate application, a notice of that decision will be posted on the Public Notice of Decision tool

Landowners or occupants may file a request for regulatory appeal with the AER if they have concerns about the decision to issue a reclamation certificate.

Professional Sign Off

Since January 1, 2008, members of seven professional organizations must sign off on all land remediation and reclamation work on upstream oil and gas sites.

The AER does NOT provide professional signoff as part of the approval of the reclamation certificate. However, operators must provide professional signoff ‎for the work they complete and the information they submit in support of the reclamation certificate application. This professional signoff is another level of assurance (QA/QC) and also provides a means for the AER to report delinquent operators and or consultants to their respective professional organizations (e.g. Alberta Institute of Agrologists).

For all remediation and reclamation work completed after January 1, 2008, a designated professional must sign a Professional Declaration for Reclamation Certificate Applications form. The form must be signed after the following have been completed:

  • Phase 1 environmental site assessment
  • Compliance Option Checklists for Drilling Waste Disposal
  • Phase 2 environmental site assessments
  • remediation and confirmatory sampling
  • reclamation detailed site assessments

To approve on remediation and reclamation work, the professional must meet the following requirements:

  • The professional must be a member in good standing of one of the following seven professional organizations:
    • Alberta Institute of Agrologists
    • Alberta Society of Professional Biologists
    • Association of Professional Engineers and Geoscientists of Alberta
    • Association of Science and Engineering Technology Professionals of Alberta
    • Association of the Chemical Profession of Alberta
    • College of Alberta Professional Foresters
    • College of Alberta Professional Forest Technologists
  • The professional must carry professional liability insurance (errors and omissions) unless doing work on behalf of an employer

Sign off must include the professional's signature and either the registration or membership number or the stamp or seal of the professional organization.

Audits
The AER audits reclamation certified sites to verify compliance with legislation, requirements, criteria, guidelines, and policy.

Audits are separate from the complaint process. Sites are either randomly selected for audit or targeted for audit based on risk.

To ensure that all standards and guidelines have been met, the AER will audit at least 15 per cent of the sites that receive a reclamation certificate.

Desktop Audit
This type of audit ensures that the correct information was available to support reclamation certification.

Any risk factors identified may result in a more comprehensive desktop audit. This may include a review of the

  • Phase 1 environmental site assessment (ESA),
  • Phase 2 ESA,
  • Phase 3 ESA, or
  • detailed site assessment.

Based on the findings from the desktop audit, a certified site may be sent for a surface or subsurface field audit.

Surface Reclamation Field Audit
This type of audit includes a file review and site visit to assess whether the site is compliant.

The assessment includes

  • vegetation quality and quantity,
  • soil quality and quantity,
  • site topography and landscape,
  • evidence of remaining facilities,
  • visual indicators of contamination, and
  • any other parameters identified by the landowner or flagged by the desktop audit.

Subsurface Contamination Field Audit
This type of audit includes a complete file review and site visit to collect soil samples for lab analyses. At some sites, electromagnetic survey and groundwater sampling may also be included.

Cancelling Certifications
Certificates may be upheld or cancelled at any audit step. Reasons for cancellations may include

  • an incomplete or inaccurate application or one that contained inconsistent information,
  • a failure to assess the site for contamination where required, or
  • a failure to comply with the remediation guidelines or reclamation criteria and without adequate justification within the application.

Inspections and Compliance
AER inspectors in field centres throughout the province are responsible for ensuring that operators comply with legislation and other requirements. Inspectors work closely with landowners and industry to resolve concerns.

For more information on the AER’s compliance assurance program, visit the Compliance and Enforcement page.