Directive 050: Drilling Waste Management
Purpose of this Directive
This directive sets out requirements for the treatment and disposal of drilling waste. It contains information on sampling requirements, analytical requirements and procedures, disposal criteria, and documentation related to drilling waste management and disposal.
It is designed to ensure that methods used to manage drilling waste are protective of the environment, sites used to manage drilling waste can be restored to equivalent land capability, and drilling waste management practices meet AER requirements and environmental outcomes.
Advanced Gel Chemical Drilling Wastes
Question 1: Are approvals for advanced gel chemical drilling wastes still required pursuant to Informational Letter 2001-3: Management of Drilling Wastes Associated with Advanced Gel Chemical Systems?
Answer 1: No. IL 2001-3 was rescinded with the publication of the 2012 edition of Directive 050. As of May 2, 2012, drilling wastes from advanced gel chemical mud systems must be managed following the requirements of the 2012 edition of Directive 050 (refer to Sections 1.1 and 1.5).
Question 2: What is an advanced gel chemical drilling waste?
Answer 2: It is a drilling waste resulting from a water-based drilling mud system in which a significant primary component such as a salt or polymer has been added to aid in the drilling program (refer to the definition in Appendix 7). Should there be any question as to whether a mud system is an advanced gel chemical system, handle it as one and follow the new requirements. Note that all requirements within the 2012 edition of Directive 050 are effective November 1, 2012.
Disclosure of Sites Used to Manage Drilling Wastes
Question 3: Regarding Section 1.5.2, is disclosure required for pits that have had the drilling wastes removed and managed by mix-bury-cover or landspreading, or is it just the active, open pits that require disclosure?
Answer 3: Refer to points 1(a) and 1(b) in the section. Disclosure is not required if
- the sump is on a remote site and the drilling waste was removed and managed appropriately prior to May 1, 2013, or
- as of May 1, 2013, the time period from first use of the remote site to manage drilling waste has not exceeded five years.
Note: If the five year duration has been exceeded, disclosure is still not required if the reclamation process for the site has been engaged or completed prior to May 1, 2013.
Disclosure is required if
- the sump is on a remote site and on May 1, 2013, it will have contained drilling wastes for a period exceeding 18 months, or
- as of May 1, 2013, the time period from the first use of the remote site to manage drilling waste (including storage) will have exceeded five years and the reclamation process for the site has not been engaged or completed.
Question 4: Do the disclosure requirements in Section 1.5.2 apply to only remote sites or any site used to manage drilling wastes?
Answer 4: The section only requires disclosure of remote sites. The intent is to obtain an inventory of remote sites that are outstanding respecting drilling waste management and to get the sites closed and reclaimed or if applicable, approved as an oilfield waste management facility.
Question 5: If a cleared site has been used consecutively for three to five years, with a new sump dug every fall followed by a spring mix-bury-cover of the drilling waste, would this site need to be disclosed by May 1, 2013 if the reclamation process has not been either started or completed by this time? Or is it possible to consider sump/mix-bury-cover as an independent site?
Answer 5: Disclosure pursuant to Section 1.5.2 is not required if the site has not been in use for longer than five years, provided there is not an open sump on it for which the drilling waste storage duration has exceeded 18 months from rig release of the first well that contributed drilling waste to the sump. While Section 6.2(8) sets out the timing for removal of drilling waste from a sump and physical a closure of the sump, the number of years that the site is being used for drilling waste storage/management also needs to be tracked as the site can only be used for five years.
Need for Directive 058 Approval of Sites Used to Manage Drilling Wastes
Question 6: If a drilling waste storage site is used for five years, does the licensee require ERCB approval for continued usage?
Answer 6: A site can be used for up to five years for drilling waste storage/management under the requirements of Directive 050. A site in use for longer than five years requires approval as an oilfield waste management facility pursuant to Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry; refer to the note under Section 6.6(23).
Drilling Waste and First Nations Land
Question 7: Have there been any discussions with IOGC related to management of drilling wastes and consent for First Nations Lands?
Answer 7: The ERCB did consult with Indian Oil and Gas Canada, and the results of the discussions related to consent for management of drilling waste on First Nations Lands and reclamation of the sites are set out in Sections 1.6 and 1.7.
Drilling Waste Analysis and Related Soil Endpoints
Question 8: What are the drilling waste and soil nitrogen testing requirements, as there is some confusion between ammonia and ammonium?
Answer 8: The third footnote on Table 3.1 identifies nitrogen as being total mineral nitrogen and includes ammonia-nitrogen, nitrate-nitrogen, and nitrite-nitrogen. Respecting the ammonia-nitrogen testing requirement, some parts of Directive 050 print out the chemical formula for the ammonium-nitrogen form (NH4-N), but not the ammonia-nitrogen form (NH3-N). While ammonium and nitrate are the forms of nitrogen that plants take up from soil, many forms of nitrogen exist in soil, and the forms easily change from one to another. In addition, standard reference methods typically target both the ammonium and ammonia species by converting them to one form and analyzing both species as one and reporting the results as total ammonia-nitrogen or total N. Therefore, to meet the ammonia-nitrogen testing requirements, test for total ammonia-nitrogen (NH3 + NH4+).
Question 9: If a drilling waste contains amines, do the nitrogen testing requirements need to be expanded to include amines?
Answer 9: No. Continue to test for total mineral nitrogen, but ensure all other requirements for the disposal method being used are followed including toxicity testing.
Question 10: Can the hydrocarbon and metal concentrations set out in Tables 3.3 and 3.5 be recalculated and expressed as dry weight numbers?
Answer 10: Yes. Both tables have been expanded to express the concentrations in both dry weight and wet weight numbers. The expanded tables are located at the end of the FAQ.
Question 11: Are the units for dry bulk density in footnote 1 of Table 3.5 mistaken?
Answer 11: Yes. The dry bulk density should be 1.54 Mg/m3, which is megagram per cubic metre and not milligram (mg) per cubic metre. To avoid confusion and to be consistent with the units used for dry bulk density in other sections of Directive 050, updates to the table will present dry bulk density as 1540 kg/m3.
Question 12: Is a horizontal gas well considered a hydrocarbon flag?
Answer 12: It is not identified as one in the definition of hydrocarbon flags (refer to Appendix 7). However, the drilling waste from a horizontal gas well needs to be checked for the identified hydrocarbon flags before ruling out the presence of hydrocarbons.
Question 13: If a drilling waste disposal area did not meet the required soil endpoints, but the licensee remedied the issue, can the same area of land be used again for drilling waste disposal?
Answer 13: It depends on the drilling waste disposal method being used. Section 13.3(12)(a) and Section 14.3(14)(a) do not allow mix-bury-cover or landspreading of drilling waste on an area of land that has been previously used for drilling waste disposal.
The landspray, landspray-while-drilling, disposal onto forested Public Lands, and pump-off disposal methods can be used on areas of land that previously received drilling wastes using these methods, provided the licensee has landowner consent and the receiving soil does not exceed the initial soil salinity criteria and the maximum allowable changes from background (initial) soil conditions as set out in Table 3.1. In addition, the soil hydrocarbon and metal endpoints set out in Tables 3.2 and 3.4 can not be exceeded.
Question 14: Is a licensee required to demonstrate compliance with all soil endpoint criteria even when testing the drilling waste for all of the parameters was not required, or is compliance assumed on the premise that the soil endpoint criteria is met due to the absence or low concentration of the parameter(s) in the drilling waste?
Answer 14: Compliance would involve being able to demonstrate that testing the drilling waste for the parameter (e.g., metals, hydrocarbons, or nitrogen) was not required and hence, the need to test the soil of the disposal area for the endpoint parameter was not required. Should there be compliance issues, licensees may be required to test the soil for any or all of the endpoint parameters and conduct further work, as necessary, in the event of finding soil endpoint exceedances. In addition, should a landowner have a concern with a disposal area, the licensee responsible may be required to conduct work to assess whether the concern is related to the disposal event (e.g., a drilling waste disposal requirement was overlooked or not met) and implement remedial measures if necessary.
Question 15: Is the flashpoint in the note under requirement 3 in Section 17.2 correct?
Answer 15: No. The flashpoint should be 60.5°C as set out in the Waste Control Regulation and not 61.5°C.
Drilling Waste Storage / Sump Construction
Question 16: Regarding C-rings for surface mud, can a 12 mil liner be used instead of a 30 mil liner or would it depend on the nature of the waste being stored?
Answer 16: The ERCB uses the term “aboveground synthetically-lined wall storage system” (AWSS) to address storage systems sometimes referred to as “C-rings.” Note that the ERCB only allows AWSSs to be used to store cement returns and water-based hydraulic fracturing fluids and flowback fluids. For storage of cement returns, Section 7 of the 2012 edition of Directive 050 allows the liner of the AWSS to be 12 mil. Refer to Directive 055 – Addendum 2011-10-11 for more information about the use of AWSSs.
Question 17: For existing sumps, when do the new requirements of the 2012 Directive 050 take effect?
Answer 17: Sumps that are in use prior to November 1, 2012, must meet the 1996 edition of Directive 050, which requires sumps to be closed within 12 months of rig release. These sumps can continue to be used for the remainder of 12 month duration allowed under the 1996 edition of Directive 050. As of November 1, 2012, any new sump or a sump that is being reused will need to meet the 2012 edition of Directive 050 (refer to Section 6.6 for requirements for reuse of a sump).
Question 18: Do all storage systems have to be closed by the end of 18 months?
Answer 18: Yes, for any storage systems put in use following the 2012 edition of Directive 050; closed means that the storage system must be emptied of drilling waste and physically closed within 18 months of rig release of the first well that contributed drilling waste to it. For storage systems in use following the 1996 edition of Directive 050 (prior to November 1, 2012) the closure must occur within 12 months.
Question 19: Is it possible to demonstrate that soils are suitable for sump construction using permeability testing as opposed to testing for plasticity index (PI) and liquid limits (LL)?
Answer 19: No. Section 6.3(10)(b) sets out the soil testing requirements to determine suitable soil characteristics for sump construction and includes testing for fines and clay content in addition to PI and LL.
Question 20: If a sump is closed within 18 months but does not meet post disposal endpoints, what must a licensee do?
Answer 20: The licensee must remedy the situation. Section 6.2(8)(b) identifies that physical closure of a drilling waste storage system (e.g., sump) includes removal of the drilling waste, decontaminating (if needed) the area beneath and surrounding the sump, and backfilling/contouring the area. The objective is to close the sump in a manner that will allow the site to be restored to equivalent capability. Exceedances found after sump closure could be the result of
- breach of sump containment and failure to decontaminate the area beneath and around the sump,
- not having removed all of the drilling waste prior to backfilling/contouring area, or
- in the case of managing the drilling waste using MBC in the area of the sump, inappropriate mixing or use of inappropriate mix ratios.
Licensees must handle the situation as an exceedance of soil endpoints and follow the notification procedure set out in Section 3.5. (The notification must include a plan to remedy the exceedance, which is a noncompliance event.)
Question 21: Can multiple licensees deposit drilling waste into one sump, conduct mix-bury-cover (MBC) disposals on one site, or use one remote site to store/manage drilling wastes?
Answer 21: No. Section 6.4 states that multiple wells contributing drilling waste to a storage system/sump must have the same licensee. If the storage is occurring on a remote site, the licensee must have a written agreement with the landowner for the site, and the remote site must be tied back to the licence of the well that first contributed drilling waste to the sump/storage system. MBC disposal of drilling waste can only occur on the generating well site or a remote site on which the drilling waste is stored (refer to Section 13).
Question 22: What is an acceptable containment system for cement returns being classified for landfill disposal? Would a three sided shale bin be acceptable?
Answer 22: Requirements for containment of cement returns are set out in Section 7.2(1)(a) and (b); requirement (b) allows for use of aboveground portable rigid structures that will adequately contain the cement returns and prevent release into the environment. Depending on the fluid content of the cement returns, a three sided shale bin may not meet this requirement.
Question 23: What is the effective date for the requirements in Section 7: Management of Cement Returns, including the landowner consent requirement?
Answer 23: November 1, 2012. However, note that Section 2.1 of Directive 055 – Addendum 2011-10-11 has been replaced by Section 7.2(1)(a) of Directive 050 respecting use of aboveground synthetically lined wall storage systems (AWSSs) for containment of cement returns. When using AWSSs, licensees can follow either Directive 55 – Addendum 2011-10-11 or Directive 050 requirements up to November 1, 2012; after November 1, 2012, Directive 050 requirements must be followed.
Water Body and Drilling Waste Management
Question 24: What is the complete definition of a water body?
Answer 24: Definitions for Directive 050 terms, including one for a water body, can be found in Appendix 7. This definition is consistent with that in Directive 056: Energy Development Applications and Schedules.
Question 25: Does the ERCB consider muskeg to be a water body?
Answer 25: It is identified in the definition of water body (refer to Appendix 7).
Question 26: Are drilling waste disposals permitted on well pads constructed overtop of muskeg in situations where the berm soils and receiving soils meet the required conditions?
Answer 26: No. In addition to needing to adhere to the water body setback, information from ESRD identifies that most pads are about 2 m thick, and at abandonment time, the clay pad must be removed (clay is to either be reused or replaced into the borrow pit). ESRD preference is to avoid any potential to compromise the clay and to not allow drilling disposal on the pads.
Question 27: Are earthen berm storage systems required to meet the 100 m setback from an offsite water body?
Answer 27: Yes. Earthen berm storage systems are subject to the general drilling waste storage requirements set out in Section 6.2; requirement 6.2(5) addresses setback distances. Hence, the setback requirements set out in Section 6.5(19) (which is missing the 100 m setback from a water body) are redundant and will be removed in the next update to Directive 050.
Drilling Wastes from Pipelines
Question 28: Can multiple licensees use one parcel of land for storage or MBC disposal of drilling waste from a pipeline construction project?
Answer 28: No, if storage or MBC of the drilling waste is occurring on a site remote from the pipeline right-of-way (ROW), the licensee must have a written agreement with the landowner for the remote site, and the remote site must be tied back to licence and line number of the pipeline that generated the drilling waste. In addition, the licensee is obligated to reclaim the remote site. Multiple remote sites could be located on a parcel of land with one licensee being responsible for one remote site.
Note that MBC of the drilling waste can also occur on the pipeline ROW provided the surface of the pipeline ROW is disturbed (top soil removed, ROW is under construction, or has been disturbed for pipeline work) and the drilling waste is generated from the construction of the pipeline associated with the ROW (refer to Section 8).
Landspray and Landspray-While-Drilling (LWD)
Question 29: For landspray and LWD, what is meant by “prepare the disposal area so that the drilling waste is applied to the surface of disposal area and not onto snow accumulation?”
Answer 29: There have been situations where drilling waste has migrated from the disposal area as a result of it being applied to snow accumulation. Complete removal of all snow is not expected; a reasonable approach to prepare the site to prevent migration of the drilling waste should be used (e.g., remove snow until sufficient vegetation or stubble is visible to aid with retention of the drilling waste on the disposal area).
Disposal onto Forested Public Lands (DFPL)
Question 30: For the DFPL method, does not the requirement to blade 10 to 15 cm of surface soil contradict with the term “minimum ground disturbance (MGD)?”
Answer 30: Yes. The ERCB has discussed this with ESRD and ESRD has clarified that blading of soil should not be done in MGD areas. Therefore, licensees are not to follow requirement 3(a) under Section 11.2.
Question 31: Regarding the DFPL method, does requirement 12 within Section 11.3 contradict requirement 11 (c), (d), and (e)?
Answer 31: No. Requirement 11 allows DFPL to be conducted in a manner similar to LWD (e.g., opportunity to conduct sumpless drilling), but with higher drilling waste application rates. Should there be any hydrocarbon, metal, or toxicity issues, requirement 12 allows DFPL to continue to be a viable disposal method provided the waste is stored, sampled, and tested and the results comply with the direction set out in requirement 12.
Question 32: Section 13 does not specify a soil texture requirement for MBC. Is it possible to conduct MBC disposals in soils that do not meet the soil characteristics for sump construction?
Answer 32: Yes, provided all requirements within Section 13 are met. Note that there are hydrocarbon and nitrogen soil endpoints specified for coarse and fine soils. Remember MBC is limited to occur on the well site that generated the drilling waste, a pipeline-right-of way that has a disturbed surface (provided the drilling waste is from construction of the associated pipeline), and a remote drilling waste storage site (provided the drilling waste is stored at the remote site).
Question 33: Is there a one metre maximum waste disposal onto land for landspreading?
Answer 33: The maximum drilling waste application rate for the landspreading disposal method is 1000 m3/ha or an applied thickness of 10 cm. The drilling waste is spread on the shallow subsoil of the lease and incorporated into the subsoil to a maximum depth profile of 1 m (refer to Section 14).
Question 34: When submitting a drilling waste remix notification, is it possible to use calculations to show that the 3:1 remix will meet the required endpoints, or can only 3:1 predictive lab mixes be used?
Answer 34: Section 20 requires predictive lab mixes to be used to determine the soil-to-waste mix ratio that will meet the soil endpoints set out in Tables 3.1, 3.2, and 3.4. Note that it identifies that the mix ratio must not exceed 3 parts soil to 1 part drilling waste.
Notification of Drilling Waste Disposal
Question 35: Is notification to the ERCB required prior to disposal of drilling waste, or is the notification now only required after disposal?
Answer 35: ERCB Directive 045 eliminated the paper notifications and introduced the requirement to electronically submit predisposal information through the ERCB Digital Data Submission (DDS) system, Field Surveillance Inspection System (FIS) Drilling Activity Notification Form. This requirement has been retained in the 2012 edition of Directive 050. In addition, the 2012 edition introduced the requirement to electronically submit postdisposal information (refer to Section 21.3 and 21.4).
Question 1:What are drilling wastes?
Answer 1: All spent drilling fluids and cuttings or solid materials carried to surface from oil and gas wells and directional holes are considered drilling wastes.
Question 2:What are drilling fluids?
Answer 2: Drilling fluids (or “muds”) are used when drilling oil and gas wells and during directional underground boring activities for pipeline construction. They are pumped down the drill string and circulated back to surface carrying the “cuttings,” which are drilled-up subsurface rock and sediments.
The three types of drilling fluids systems are water based, oil based, and gas based (air, for example). Drilling fluid systems that use Directive 050 land application methods as a disposal option typically use fresh water and allow the natural clays from the drill cuttings to form a viscous fluid known as “mud.” Other additives are used to ensure efficient, productive, and safe drilling operations, and include, among others, clay, calcium nitrate, wood fibre, lubricants, iron oxides, and calcium carbonates.
Question 3: What are cement returns?
Answer 3: Cement is used to set the well casings, the excess cement that flows back to surface is called cement returns. Cement returns are commonly placed in an earthen pit on the well site, allowed to harden, and then covered with one metre of subsoil. Directive 050 requires well licensees to obtain landowner consent when the pit size exceeds four square metres. This consent can be part of either the surface lease or right-of-entry agreement for the well site or an independent agreement.
Landowner agreements to bury cement returns are intended to prevent conflicts in future land development plans. Cement returns can also be sent to an approved landfill once hardened at the well site.
Question 4: How is drilling waste disposed of?
Answer 4: Drilling waste can be disposed of either by using the land application methods that are set out in Directive 050 or sending it to an approved waste management facility. The principle behind land application is to allow the soil’s natural capacity to assimilate waste in a manner that preserves soil conditions. The objective is to ensure that the waste benefits the soil quality or, at a minimum, that contaminant concentrations fall within provincial soil quality guidelines.
Landspreading and mix-bury-cover are land application methods where drilling waste is mixed with subsoils and covered. These disposal options are limited to well sites, pipeline right-of-ways, or a stand-alone (remote) site that is associated with a well or pipeline.
Landspray, landspray-while-drilling, and pump-off are topsoil application methods where waste is sprayed from vacuum trucks or pumps and hoses and typically occur on fields (cultivated or vegetated) off site from the well site.
The following are descriptions of the different drilling waste management methods that are set out under Directive 050:
Water-based drilling wastes can be stored in sumps (which are earthen excavations), lined sumps, or in temporary open-topped tanks. To protect soil and groundwater quality,
sumps can only be constructed on sites that meet the criteria for sump construction (see Section 6 of Directive 050). Hydrocarbon-based drilling wastes must only be stored in tanks.
Drilling waste is spread over an area of the lease, incorporated into the shallow subsoil, and covered with topsoils. Testing of the wastes prior to disposal is required to determine the size of the spread area needed. The incorporation technique must provide a mix ratio of one part drilling waste to at least three parts subsoil.
Often drilling waste is stored in an earthen excavation called a sump. In the mix-bury-cover disposal option drilling waste stored in a sump is stabilized by mixing it with subsoil at a ratio of at least three parts subsoil to one part waste. Waste testing determines the ratio of mixing required. The drilling waste and soil mixture is then buried and covered with at least one metre of clean subsoil.
Slurried water-based drilling waste or the fluid portion separated from the drilling waste
is sprayed at predetermined application rates onto fields (cultivated or vegetated/grassland) using vacuum trucks or similar equipment. The wastes may or may not be incorporated into the topsoil. If a licensee has arranged for the landowner to incorporate the drilling waste into a field, it is important that it be done in the time indicated to avoid any potential adverse effects on the land. The area of land and application rate used are calculated based on the characteristics of the drilling waste and whether it is being incorporated into the topsoil of the field.
- Landspray-While-Drilling (LWD)
LWD is similar to landspray but is limited to nontoxic drilling fluid systems. As a result, LWD has reduced testing requirements. LWD is done during or immediately after drilling operations. Disposal of drilling wastes containing hydrocarbons is not allowed by this method.
This method is limited to clear liquids that have separated from the water-based drilling waste within the drilling waste storage system. The clear liquids are pumped onto soils on the surface of fields or vegetated lands and are not incorporated. Testing the waste determines the rate of application and ensures that disposal criteria are met.
- Disposal onto Forested Public Lands (DFPL)
DFPL is similar to both landspray and LWD, but as it involves higher application rates it is limited to application on provincial Crown land.
Biodegradation involves reducing organic compounds in drilling waste through microbial processes and is most commonly used to manage drilling wastes
contaminated with formation hydrocarbons or hydrocarbon-based drilling wastes. It can also be used to manage drilling wastes that contain other organics (e.g.
starches, alcohols, and formates).
The most common biodegradation techniques are land treatment and treatment within a contained system. Land treatment involves applying drilling waste to subsoil and incorporating it in so that the inherent soil processes biodegrade, transform, and assimilate the waste. Treatment in a contained system is where the drilling waste is biodegraded in an impermeable cell or on an impermeable barrier. Following the breakdown of organic compounds, the drilling waste is removed from the contained system and managed by either another land application method or sent to an approved waste management facility for further treatment or disposal.
- Thermal Treatment
Thermal treatment involves heating waste in a chamber to a predetermined temperature to vapourize the organics. Once complete, vapours are captured on an adsorbent media or routed to another chamber where they are either condensed back to a liquid and captured or heated to a higher temperature and destroyed.
Thermal treatment can effectively reduce the concentration of hydrocarbons or other organic compounds in drilling waste. Mobile thermal treatment units brought to a well site or a remote site associated with a well to treat drilling waste must be approved by or registered with Alberta Environment and Water.
Question 5: Can all drilling wastes be applied to land for disposal?
Answer 5: No. Only wastes that meet Directive 050 criteria can use land application methods. In addition, Directive 050 prohibits hydrocarbon-based drilling wastes to be disposed of via landspray, landspray-while-drilling, and pump-off.
Question 6: Are all soil types appropriate for land application of drilling wastes?
Answer 6: No. Not all soils can receive drilling wastes. Directive 050 sets out salinity ranges for soils that can receive drilling wastes. Licensees must sample and test soil from the fields or sites where they plan to apply drilling waste. Directive 050 also identifies limits that the soil must not exceed after a drilling waste application. These limits are designed to protect the environment and are based on Alberta Environment and Water’s soil quality guidelines. To ensure compliance, licensees must test the drilling waste to determine the amount that may be applied to an area of land. In some situations, licensees are also required to sample the soil after the drilling waste is applied to verify that the disposal has met Directive 050 requirements.
Question 7: How often can drilling waste be applied to one area of land?
Answer 7: An area of land must only be subject to drilling waste disposal a maximum of twice per year: once during frozen-soil conditions (winter season) and once again during unfrozen-soil conditions (summer season).
Question 8:When is landowner consent required for disposal of drilling wastes?
Answer 8: Any application of drilling waste to land in areas outside of a well site, pipeline right-of-way, or remote site associated with a well or pipeline requires landowner consent. This consent must also be obtained to take soil samples when determining if soil conditions are appropriate for drilling waste disposal.
Landowners are not obligated to consent to these activities. Licensees have the option to send the drilling waste to approved waste management facilities or manage it on the well site, pipeline right-of-way, or remote site associated with the well or pipeline.
Question 9:Are licensees required to contact landowners before disposal operations begin?
Answer 9: Once consent has been given, licensees are not required by Directive 050 to contact landowners prior to commencing disposal operations. However, landowners can make this a condition of their consent.
Question 10: What drilling waste management activities are allowed on a remote site?
Answer 10: Directive 050 allows wastes to be stored, biodegraded, or disposed of on remote sites. Licensees must have a written surface lease or right-of-entry agreement with landowners to develop remote sites to manage drilling wastes.
As a landowner, if you wish to restrict certain drilling waste management methods or impose conditions beyond the requirements set out in Directive 050, these details must be part of the surface lease or right-of-entry agreement.
Question 11:What if a licensee or company doesn’t comply with requirements?
Answer 11: The ERCB sets out the requirements for drilling waste management in Alberta and is the government agency that has jurisdiction to ensure that industry adheres to the requirements. If noncompliance events are identified, the ERCB will require that the licensee address the problem.
Question 12: Who is responsible for proper drilling waste disposal?
Answer 12: While environmental consultants or service contractors working for the licensee may approach landowners regarding drilling waste disposals, the proper management of drilling waste is the responsibility of the well or pipeline licensee.
Landowners with concerns about drilling waste disposal operations should discuss them with the licensee first. If unsatisfied with the licensee’s response, landowners can contact the ERCB for assistance.
Common Questions and Considerations for Licensees and Landowners Contemplating Directive 050 Land Application Methods
The following is a list of questions and considerations landowners and licensees might want to consider during negotiations around proposals to use the land application methods in Directive 050.
- What type of drilling fluid is used at the well site?
- What type of drilling waste disposal is proposed in the licensee’s disposal plan?
- How much surface area will be needed for drilling waste disposals occurring off the well site?
- Are there any constraints or restrictions on relocating the disposal site if I’m not happy with the proposed location?
- When will the disposal operation start and finish?
- Will agreement and recommendations on waste disposal be confirmed in writing?
- How will the issue of compensation be handled?
- How will licensees agree to accommodate farming or agricultural conditions and schedules in their drilling waste disposal plans?
- Disposal operations can occur on a 24-hour basis. Therefore, discuss traffic routes that would limit noise and disturbances, safety, and soil compaction.
- Protect vegetation against repeat applications or winter disposal.
- Protect livestock.
- Ensure that the disposal area is 100 metres from a water body (including dugouts) or 50 metres from a water well; has a slope of less than five per cent in summer and three percent in winter and is free of features that would lead to pooling, erosion, or migration of the drilling waste; and is not within 10 metres of ditches or property lines.
- Protection against the spread of club root disease.
- Drilling waste disposal may have an effect on organic farm certification.
- Drilling waste may potentially contain radioactive tracers.