appendix i: hangingstone demonstration project ... · appendix i: hangingstone demonstration...

JACOS Hangingstone Expansion Project Supplemental Submission Part 4 - Appendices Appendix I: Hangingstone Demonstration Project Environmental Compliance Manual February 2011

APPENDIX I

Hangingstone Demonstration Project Environmental Compliance Manual

JACOS Environmental Compliance Manual Section 1.0: Introduction Revision 1: June 2010

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1.0 Introduction 1.1 General JACOS is committed to preventing damage to the environment as a result of its operations. The combined efforts of operators, supervisors, managers and contractors will be needed to achieve this objective.

1.2 Limitations of Manual This manual is designed to provide JACOS employees and contractors with the basic information required to help ensure protection of the environment and reduce possible liabilities. The contents of this manual provide a basis upon which “due diligence” can be shown (see Section 2.0). This manual applies to JACOS’ Hangingstone Demonstration site only.

1.3 When in Doubt Sooner or later a situation will arise where this manual does not give explicit guidance. In such a situation always ask before acting. JACOS management actively encourages its employees and contractors to seek advice and if the situation is serious, to call head office personnel, even after hours. When in doubt call; individuals at your disposal with environmental compliance knowledge are: • Safety/Environmental Officer: - Glyn Jones Site: (780) 799-4009

Cell: (780) 713-9114 Home: (780) 714-3455

OR CALL CALGARY

• Regulatory Affairs Manager: - Enzo Pennacchioli Calg Off.: (403) 668-5155 Cell: (403) 813-1086 Home: (403) 235-3035 • Senior Environmental Coordinator: - Karen Cresine Calg Off.: (403) 213-8973

Home: (403) 252-6802

• Environmental Specialist: - Shelly Johnson Calg Off.: (403) 213-8971 Home: (403) 475-2877

• Senior Environmental Coordinator: - Jos Lussenburg Calg Off.: (403) 668-5226

Alt Off.: (403) 851-5140

JACOS Environmental Compliance Manual Section 1.0: Introduction Revision 1: June 2010

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Cell: (403) 875-3113 Home: (403) 932-0908 • Community Relations - Bill Rennie Calg Off.: (403) 668-5223 Coordinator: Cell: (403) 650-1762

Home: (403) 202-1210 • Calgary Reception: Main: (403) 264-9046

(they may be able to track down any of the above) The above contact list is not to be confused with an emergency response reporting list; instead it is a listing of people that may be able to clarify or advise further. The JACOS Emergency Response Chain of Command (JERCC) flow diagram is included for reference at the end of this section.

1.4 Manual Organization

In each section of the manual a brief explanation is provided as to why the particular environmental component is applicable and what the company’s consequent environmental expectations are. Users need to be aware that at the end of each section, only the most immediately relevant legislation and/or regulations have been referenced. These references should therefore not be considered as a comprehensive listing.

1.5 Manual Sections

Section 1.0 ............................................... Introduction Section 2.0 ............................................... Due Diligence Section 3.0 ............................................... Roles and Responsibilities Section 4.0 ............................................... Documentation & Reporting Section 5.0 ............................................... Land Use Section 6.0 ............................................... Waste & Chemical Storage Section 7.0 ............................................... Release - Spill Reporting Section 8.0 ............................................... Soil Monitoring Section 9.0 ............................................... Groundwater Monitoring Section 10.0 ............................................... Run-Off Control Section 11.0 ............................................... Water Source Wells Section 12.0 ............................................... Water Disposal Wells Section 13.0 ............................................... Pipelines Section 14.0 ............................................... Air Emissions Section 15.0 ............................................... Waste Disposal Section 16.0 ............................................... Noise Control Section 17.0 ............................................... Vegetation & Wildlife Control

Actions or Response, for eg:

-contain spill,-fight fire,-rescue

Toshi HirataOffice: 403-668-5156Cell: 403-818-0025

Home: 403-278-5910

Bill RennieOffice: 403-668-5223Cell: 403-650-1762

Home: 403-202-1210

JACOS EMERGENCY RESPONSE CHAIN OF COMMAND

Mano DehghaniOffice: 780-799-4001Cell: 780-916-4202

Home: 780-464-2963

Roy Marlatt (Procurement)Office: 780-799-4008Cell: 780-713-9211

Home: 780-791-4502Ray Mussell (Electrical)

Office: 780-799-4016Cell: 780-788-0111

Home: 780-939-2866Brian Howse (Maintenance)

Office: 780-799-4007Cell: 780-799-9945

Home: 780-791-5441Norm Trudeau (Construction)

Office: 780-799-4015Cell: 780-916-3150

INCIDENT

FIRST PERSON ON SCENE

Main Switchboard: 780-799-4000Control Room: 780-799-4019Emergency Site Phone: 780-715-9472Fax: 780-799-4010

PRESIDENT

EXECUTIVE VICE-PRESIDENT

Yukio KishigamiOffice: 403-668-5215Cell: 403-703-0046

Home: 403-244-9518

COMMUNITY RELATIONS & JOINT VENTURES

COMMUNITY NOTIFICATIONS

MEDIA

EMERGENCY RESOURCE TEAM

HANGINGSTONE SITE OFFICE

ON-SITE COMMANDER(SUPERINTENDENT)

EMERGENCY CO-ORDINATORS or ALTERNATES

Ernie FidderOffice: 780-799-4005Cell: 780-799-9946

Home: 780-791-9922Leo Lasaga

Office: 780-799-4005Cell: 780-799-9946

Home: 780-743-1880Glyn Jones (EH&S)

Office: 780-799-4009Cell: 780-713-9114

Home: 780-714-3455Jeff Faucher

Office: 780-799-4003Cell: 780-792-7364

Home: 780-942-2202

Enzo PennacchioliOffice: 403-668-5155Cell: 403-813-1086

Home: 403-235-3035

Jos Lussenburg (MICEP)Office: 403-668-5226Cell: 403-875-3113

Home: 403-932-0908Alt: 403-851-5140

ENVIRONMENT & REGULATORY

EMERGENCY SERVICES DIAL 911

UTILITY COMPANIES

SENIOR VICE-PRESIDENT

Brian HarschnitzOffice: 403-668-5443Cell: 403-803-0920

Home: 403-241-2582

OPERATION’S FOREMAN or ALTERNATE

TRANSPORTATION OF DANGEROUS GOODS (TDG)

For all Fire, Medical, or Police emergency services 911Fort McMurray Fire & Ambulance 780-799-5870Fort McMurray Hospital 780-799-6121Northern Lights Regional Health Centre 780-791-6161Fort McMurray R.C.M.P (info) 780-799-8850Poison Control Centre 1-800-332-1414Industrial Accidents 1-780-427-8848

ATCO Power 1-800-668-5506ATCO Gas 1-800-511-3447TransCanada Pipelines 1-888-982-7222

AREA Y OIL SPILL TEAM 1-866-541-8888

ALBERTA ENVIRONMENT 1-800-222-6514

ERCB (Bonnyville) 780-826-5352

R.C.M.P 911Dangerous Goods Control 780-422-9600

OTHER GOVERNING ASSOCIATIONS

Alberta Boiler Safety Association (ABSA) 780-437-9100Alberta Sustainable Resources Development (ASRD):

Fish & Wildlife 780-743-7200Forestry 780-743-7125Land 780-743-7120

Alberta Work Health & Safety (OH&S) 1-866-415-8690

OTHER RESOURCES

RMWB Emergency Operations Centre: 911Remedy Energy Services (Bob Dyck):

Office 403-226-0879Cell 403-651-0047Home 403-272-0703

Rickard Construction 780-791-2867Eveready / Trivax 780-743-0222Helicopters: STARS Ambulance (Site #9164) 1-888-888-4567

Canadian 403-743-4888Delta 1-800-665-3564Highland 780-791-0039Phoenix 403-799-0141Wood Buffalo 780-743-5588

Anzac:Violet 780-334-2298

Chipewyan Prairie First Nation: Chief Vern Janvier

Office 780-559-2259 Home 780-559-2477

Conklin: Wendy Tremblay 780-559-2235

Fort McMurray First Nation:Chief Albert Cree 780-334-2293

Janvier/Chard:Jules Nokohoo 780-559-2230

Fort McMurray Today Newspaper 780-743-8186Fort McMurray Mayor 780-743-7009

VICE-PRESIDENTFINANCE &

ADMINISTRATION

Bruce WatsonOffice: 403-668-5212Cell: 403-803-0920

Home: 403-241-2543

if needed

Emergency & Reporting Resources

Calgary Office403-264-9046

VICE-PRESIDENTTECHNICAL

Tony NakamuraOffice: 403-668-5151

VICE-PRESIDENTGEOSCIENCE

Shinichi TakahataOffice: 403-668-5201Cell: 403-993-3016

LAST UPDATED: NOVEMBER 24, 2009

JACOS Environmental Compliance Manual Section 2.0: Due Diligence Revision 1: June 2010

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2.0 Due Diligence 2.1 Why You Should Understand

No manual or guide can include sufficient information to prepare you for every eventuality. Besides understanding the fundamental principle of environmental protection as outlined in the company’s policy statement, it is also important to understand the concept of due diligence. By understanding the concept of due diligence, you will be able to respond correctly in the large majority of situations. Understanding the concept and applying it will also go a long way towards prevention. In so doing you will protect yourself, the officers and directors of the company, as well as the company. Simply put, due diligence is the only effective defence against current legislation which is complex, varied, and not always very explicit. The legal term applied to this type of legislation is that it is “discretionary”. Furthermore, under current legislation officers and directors of a company can be held personally liable unless they can demonstrate due diligence. 2.2 What is Due Diligence?

Due diligence is a legal term that has come into use when defending the actions taken in the course of conducting day to day operations or in response to a particular event. If on the balance of probabilities an individual and/or the company can be determined to have taken all reasonable care, the individual or company can claim to have been duly diligent. Alternately, due diligence has been defined as:

• “Taking all reasonable steps to prevent an (environmental) incident” • “Doing what any reasonable individual can be expected to do under the

circumstances.” • “Taking all reasonable care by establishing a proper system to prevent the

commission of an offense and by taking reasonable steps to ensure the effective operation of the system.”

The question then becomes what does reasonable mean? What is considered reasonable by one individual is considered unreasonable by another. To answer that, put yourself in the position of an unbiased industry outsider looking in on the situation you are faced with and then consider what he or she would find reasonable.

JACOS Environmental Compliance Manual Section 2.0: Due Diligence Revision 1: June 2010

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2.3 Why is Due Diligence Important?

Due diligence is a defence under law. Both Federal and Alberta environmental law specifically provide a defence for due diligence with respect to a prosecution under the respective statutes (i.e.: laws). If not specifically provided for under the statute, there is history of case law (i.e.: past judicial rulings) that allows one to make a defence of diligence in so called strict liability offences. Simplistically, strict liability offences are those that are prohibitive of (or, not in) the public interest and commonly include offences created under Occupational Health & Safety and Environmental legislation.

2.4 To Whom Does it Apply?

• Companies • Officers and Directors of a Company • Individuals, that is to say Employees and/or Contractors.

JACOS Environmental Compliance Manual Section 3.0: Documentation & Reporting Revision 1: June 2010

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3.0 Roles & Responsibilities

3.1 Why?

Environmental damage, when it occurs, is an outcome that had an underlying cause. As a result, each individual in the JACOS organization whether an employee or contractor, has a role to play and responsibilities to live up to if environmental incidents are to be prevented.

3.2 Scope

The roles and responsibilities set out below relate to the operations at the Hangingstone site.

3.3 Responsibilities

President

• Through leadership and direction demonstrate JACOS’ commitment to environmental stewardship.

• Report on environmental matters to JACOS’ Board of Directors

Vice Presidents

• Reinforce environmental management objectives throughout the company. • Understand the company’s larger environmental obligations under law. • Include environmental objectives in project and business planning. • Review environmental incidents and ensure follow-up actions are carried out.

Plant Superintendent

• Reinforce environmental management objectives at the plant site. • Understand the company’s environmental obligations under law. • Include environmental objectives in project and business planning. • Review environmental incidents and follow-up those incidents. • Ensure environmental compliance reports are submitted to government in a timely

fashion or as delegated. • Initiate environmental audits and inspections or as delegated. • Review action plans to correct deficiencies identified by environmental inspections and

audits. • Ensure environmental considerations are carried out as per design both during

turnarounds and in the construction of facilities. • Promote good relations with regulatory officials and local residents/stakeholders.


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Plant Supervisors / Shift Foremen

• Ensure workers are properly qualified to perform their work. • Ensure property and equipment is maintained to acceptable standards. • Inspect facilities for environmental performance and housekeeping standards and

ensure records are kept to that effect. • Understand and implement the requirements set out in this manual. • Ensure that appropriate environmental training is given to workers and that records are

kept to that effect. • Observe operating practices for leaks, spills, improper waste management and other

signs of environmental damage. • Maintain control of contractors and their employees to ensure all work is performed in

compliance with company requirements and government regulations or as delegated. • Include regular contractors in your meetings with staff. • Review inspection/audit reports; respond and document the reported deficiencies. • Be familiar with regulatory requirements. • Communicate environmental information to staff or as delegated. • Be alert for signs of environmental damage such as stained ground or damaged

vegetation. • Ensure that wastes are handled, stored and disposed of in accordance with regulatory

requirements. • Be aware of the chemical composition of the chemical products, produced fluids,

gases and wastes with a view to knowing their environmental hazard potential. • Promote good relations with regulatory officials and local residents.

Plant Operators & Maintenance Personnel

• Operators/Maintenance Personnel are responsible for understanding the contents and

abiding by environmental requirements set out in this manual. • All Operators/Maintenance Personnel will take an active part in promoting

environmental awareness and compliance. • Practice good housekeeping in all aspects of daily work. • All environmental incidents and potential environmental hazards must be reported to a

shift foreman or supervisor. • Records, diaries and logbooks should be used regularly to keep track of both routine

and unusual events. • Operators/Maintenance Personnel can enhance the company's public reputation by

maintaining the facility's appearance and promoting good relations with local officials and residents.

• Spills should be cleaned up as they occur. • Operators/Maintenance Personnel should maintain and operate equipment in a

manner that will eliminate the potential for leaks, spills, fugitive emissions, noise and other forms of environmental impacts.

• Be familiar with the location and proper use of emergency and spill response equipment.


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• Monitor work of contractors to ensure compliance with environmental requirements. Contractors

• Contractors must be informed of and comply with JACOS’ environmental practices by

attending a compulsory site orientation prior to commencing work. • Contractors must be aware of JACOS’ requirements and all government regulations

that pertain to the work they are performing. • Contractors must have appropriate insurance and Workers' Compensation Board

coverage. • Ensure land entry authorizations have been obtained.

Technical, Engineering, and Managerial Support Staff (All Others)

• In accordance with the role being filled at site, know your responsibilities as set out

above. • Understand the company’s environmental obligations under law which at minimum

includes the contents of this manual. • Ensure environmental considerations are included in all project planning and in the

execution of the work once underway. • Recognize that regulatory approval may be required for any project work being

planned. If in doubt, screen projects with JACOS environmental resource staff. • Recognize that regulatory approvals, if required, take time. • As part of project planning, factor in the need for public consultation, and local

involvement such as contracting opportunities for stakeholder communities. • Ensure land entry authorizations have been obtained.

Environmental Coordinators and Health, Safety & Environmental Officer

• Reinforce environmental management objectives throughout the company by providing

awareness of policies, procedures and training • Identify environmental risks and promote environmental awareness. • Keep management and operations aware of emerging environmental issues and new

regulatory initiatives. • Seek employee - contractor feedback. • Periodically audit and update the environmental compliance program and manual. • Review incident reports and monitor follow-up actions. • Provide technical support to operations staff on environmental protection measures • Provide guidance and training to field staff in response to spills, and other

environmental requirements • Contribute to industry association activities. • Evaluate and recommend sources of safety and environmental training.


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3.4 Documentation

Elements of the above rely on proper documentation and reporting, i.e.: you must be in a position to prove you did it right, see Section 4.0 for details. Reference:

• CAPP Basic Environmental Program


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4.0 Documentation & Reporting 4.1 Why?

The company must not only be in a position to do it right but also to prove that they did it right.

4.2 Scope

Various pieces of environmental legislation stipulate the need to keep environmental records for periods that vary from 2 to 10 years. In addition, JACOS operating approvals either contain specific reporting requirements or these requirements are inherent in the approval.

4.3 Documentation Requirements

Site

• Copies of all of JACOS’ current operating approvals. • Copies of all monthly and annual reports to regulatory agencies. • Copies of all regulatory correspondence including electronic formats (i.e.: e-mail)

undertaken by site personnel. • Copies of any documentation as it relates to environmental monitoring - tracking -

training, e.g.: - laboratory analyses whether for gases, water or wastes, - relevant logs, - inspection reports - audit reports, - accident - incident (spill) reports - emergency situations - waste manifests (both for dangerous-hazardous and reportable wastes), - training records, e.g.: internal and external course attendance, manuals issued

to ........, when. • At minimum, an informal record of discussion should be kept as it relates to dealings

with any regulatory officials or local community complaints. • All of the above should be kept at site for a minimum of 2 years, and in dead storage

(e.g.: head office) for up to 10 years.

Head Office

• Copies of all of JACOS’ current operating approvals. • Copies of all monthly - annual reports to regulatory agencies. • Copies of all regulatory correspondence including electronic formats, i.e.: e-mail. • At minimum, an informal record of discussion should be kept as it relates to dealings

with any regulatory officials or local community complaints.


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• For remainder, discretionary dependant upon need. 4.4 Regulatory Correspondence All correspondence with regulatory agencies must be documented and approved by the Manager of Regulatory Affairs.

4.5 Regular Reporting Requirements

Inherent in JACOS’ various operating approvals is the requirement to submit various reports - performance tests either on a monthly or annual basis. These reporting requirements have been summarized in Table 4.1. Some of these reporting requirements are not strictly environmental: however, they do bear on equipment integrity and thus ultimately help minimize environmental risk.

Table 4.1: Summary of Reporting Requirements

Regulatory Requirement

Parameter Analyzed

Report Due Date Contents

AENV Approval # 1604-02-00, expires Jan 30, 2019 Source Air Monitoring

CPF Flare Gas SO2 (calculated daily in tonnes/day)

Monthly (on or before end of following month) Annual (on or before Mar. 15 of following yr)

CPF Produced Gas H2S, total HC's, LHV (lower heating value)

Monthly (on or before end of following month)

Manual Stack Survey (Steam Gen)

NO2 (must notify director 2 weeks prior to survey )

Monthly (on or before end of following month) Annual (on or before Mar. 15 of following yr)

Boiler and Heater Upgrading Study/Proposal

Sept. 30, 2010 Details of Plant 1 14.6 MW Steam Generators with cost estimate and proposal to replace these boilers with low NOx boilers

Ambient Air Monitoring


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Parameter Analyzed


Continuous Monitoring Station (one)

SO2, H2S, NO2, wind speed and direction (monitored for 6 months/year)

Monthly (on or before end of following month) Annual (on or before Mar. 15 of following year)

Summary of required parameters as per the Air Monitoring Directive

Static Exposure Stations (six)

total sulphation, H2S Monthly (on or before end of following month) Annual (on or before Mar. 15 of following year)

Water Reporting Industrial Wastewater (runoff)

volume, pH, oil & grease, chloride (grab sample prior to release and once/day during release)

Annual summary report (on or before Mar. 31 of following year)

Summary and evaluation of management of industrial wastewater and industrial runoff

Domestic Wastewater

volume of wastewater and sludge disposed

Annual summary report (on or before Mar. 31 of following year)

Groundwater Monitoring Proposal

Submitted on May 31, 2009

Annual Groundwater Report

As per proposal and approval requirements

Annual report due on or before Mar. 31 of following yr

Results from groundwater sampling program comparing chemical concentrations to Alberta Tier 1 Remediation Guidelines

Soils Reporting Soil Monitoring Program Proposal

Submitted on May 31, 2009. Next due Nov. 30, 2012.

Soil Monitoring Program Report

As per May 2009 proposal

Annually (on or before Mar. 31 of following year)

Results from soil sampling program comparing chemical concentrations to Alberta Tier 1 Remediation Guidelines

Conservation and Reclamation Report

as per Guide to the Preparation of Applications and Reports for Coal and Oil Sands Operations, AENV 1991

Annually (on or before Mar. 31 of following year)

Summary of land disturbance and C&R activities

Decommissioning and Land Reclamation Plan

6 Months prior to plant ceasing operations


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Parameter Analyzed


Water Act Approval # 00229371-01-00 expires Jan 29, 2014 (production wells SE 11-084-11W4) Monthly Water use Report: Monitoring Wells

water level (weekly measurement @ TW01-1, DQ05-5-50, DQ02-3, DQ05-4-100, DQ02-01)

Monthly, on or before the 20th day of each month following the month in which the data was collected

Summary of water levels

Monthly Water Use Report: Production Wells

H2O levels and volume in m3 of H2O diverted (weekly measurement @ production wells while diverting)

Monthly, on or before the 20th day of each month following the month in which the data was collected

Summary of consumption

Annual Water Use Report

Annually for: TDS, Hardness, Alkalinity, pH, Ca, Mg, Na, P, CO3, HCO3, SO4, Ch, N, Fe

Annual summary report on or before Feb. 28th of following yr to include all data collected as per 4.10 of approval

Canadian Environmental Protection Agency (CEPA) NPRI A per subsection 46

(1) Annually (on or before June 1 of following year)

Summary of priority substance releases to the environment

GHG A per subsection 46 (1)

Annually (on or before June 1 of following year)

Summary of GHG emissions

AENV Fugitive Emissions As per proposal

(completed annually) Annually Summary & evaluation of fugitive

emission sources as per the CCME Environmental Code of Practice for the Measurement and Control of Fugitive VOC Emissions from Equipment Leaks

Alberta SGER (Specified Gas Emitters Regulation)

calculated Annually (on or before Mar. 31 of following year)

Greenhouse gas emissions for the calendar year, intensity calculation, calculation of compliance fee

ERCB Secondary Containment Inspections

Visual for liquids in containment vessels

Results from visual leak inspections of above ground tanks requiring secondary containment, interstitial leak detection layers


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Parameter Analyzed


TK501 Secondary Containment Inspection

Daily inspections as per special approval

As requested Summary of inspection for leaks, spills, condition, and secondary containment

Annual Packer Test Wellhead pressure ≥ 1400 kPa for 15 minutes

Sept. 1 in same year as test

Results from tests on disposal wells WD-3 and WS2-23

Performance Presentation

Annually, as requested

Overview of operations' performance

Waste Disposition Report

As requested Summary of oilfield wastes (DOWs and trackable NDOWs) disposed of (what, where, and when)

Cathodic Protection Report

Part of the PIMP requirements

Annually Status of cathodic protection system and maintenance recommendations

In addition a Regulatory Reporting and Documentation Matrix is presented in Table 4.2 at the end of this section which shows the monitoring and reporting requirements, frequency, and people responsible for routine reporting.

4.6 Internal Reporting Requirements

Internal reporting requirements, as applicable, are specified in each section. 4.7 Quality Assurance

There are various quality control and accuracy requirements stipulated by the ERCB and AENV for data used in reports. These requirements are specified in various Acts, Regulations, and Directives. However, recently both AENV and the ERCB have introduced requirements to establish quality assurance, measurement and reporting programs. These programs consolidate most requirements into a single document that must be approved by the appropriate regulatory body (either by submission or by audit request). The purpose of these programs is to provide consistency with reporting practices amongst companies and to ensure minimum standards are met by everyone. The two key quality control documents for this facility are described below.

ERCB Measurement, Accounting & Reporting Plan (MARP) Mandatory for all thermal bitumen schemes, JACOS established a MARP in 2007. Its scope covers all production data reported to the Petroleum Registry. It outlines process measurement points, describes meter calibration/proving/verification processes, production accounting calculations and reporting procedures, including water balancing and produced gas recovery


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ratio calculations. The MARP is a controlled document, with copies both at the head and field offices. AENV Quality Assurance Program (QAP) This program outlines requirements for quality assurance and quality control associated with environmental monitoring and reporting activities to external agencies, in accordance with approval or regulatory conditions. It does not apply to process fluid analysis for internal monitoring purposes, although the principles of the QAP could equally apply. The QAP (in draft) is a controlled document, with copies both at the head and field offices. Contractor Services Analytical work conducted at accredited external laboratories is normally covered by the laboratory’s QA/QC program. However, it is our responsibility to ensure the laboratory’s programs are current and applicable. As stipulated in our AENV operating approval, we are to follow the standards, methods, and/ or criteria for the collection, preservation, storage, handling, and analysis of our media samples that are listed in JACOS’ Approval No. 1604-02-00, Section 2.3 Analytical Requirements (see Section 2.3.1 for specifics) and use laboratories which are ISO 17025 - General requirements for the competence of t esting and calibration la boratories - accredited when the analytical data is being reported to AENV. Maxxam Analytics and Exova conform to our approval conditions. Reference:

• JACOS Approvals - Licenses as referenced • CAPP Basic Environmental Program • JACOS Measurement, Accounting and Reporting Plan (MARP) • JACOS Quality Assurance Plan (QAP)


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Table 4.2: Regulatory Reporting & Documentation Matrix

Category Item Activity Who Daily * Monthly Semi-Annually Annually As

RequiredAG Tanks (single-wall) inspect-visual F xAG Tanks (double-wall) test-interstit F xPlant 2 BFW Tank (TK-501)* inspect-visual F xUG Tanks / Sumps. test-interstit F xRecycle Ponds test-interstit F xContainers inspect-visual F xFlare & PG Analysis sample F xVolumes record F xStatic/ Passive Monitors replace F xSO2 Emission check F xMonthly Air Report submit HO xB-520 NOx Survey sample F xFugitive Emissions survey F xGreenhouse Gas Emissions (SGER + federal) submit HO xAnnual Report submit HO xContinuous AAQ Monitoring submit HO x xLevels dip F xVolumes record F xMonthly Report submit HO xAnalysis sample F xAnnual Report submit HO xManifest fill out F xDomestic Waste record F xWaste Audit Report conduct HO xManifests for Brine fill out F xWH Pressures monitor F xAnnual Packer Tests conduct F xVolumes record F xPonds test F xCollected Surf. Water test F xAnnual Report (including domestic waste) submit HO xSpring Survey sample F xFall Survey sample F xAnnual Report submit HO xSurvey sample F xReport submit HO xAnnual Conservation & Reclamation Report submit HO xCathodic Protection report F xSurveillance conduct FVolume Balance check F xPIM Plan Audit conduct HO xOn-site/unrefined product or waste, ≥ 2m3 report F xOff-site/unrefined product or waste, any quantity report F xOn-site/refined product, quantity varies, ref. Chapter 7 report F xOff-site/refined product, any quantity report F xNational Pollutant Release Inventory (NPRI) submit HO x

"F" = field "HO" = head office

*

Groundwater

Pipelines

Releases

Note: In some cases, reporting may be daily but continuous measurements are required. For example, volumes are recorded continuously on DCS but reported as a daily total.

Storage

Water Source

Waste

Water Disposal

Runoff

Air Emissions

Soils

JACOS Environmental Compliance Manual Section 5.0: Land Use Revision 1: June 2010

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5.0 Land Use 5.1 Why?

In areas of native vegetation, the use of land for industrial activity results in the removal or fragmentation of plant and animal habitat. This loss or fragmentation of habitat threatens biodiversity and ecosystem sustainability.

5.2 Scope

JACOS’ operations are located in the Green Area, which is an area that occupies most of northern Alberta and contains forested lands that cannot be used for agricultural development. Thus these areas are administered by the Waterways Office of the Land and Forest Division, Alberta Sustainable Resources Development (ASRD). JACOS’ use of land is governed by the terms and conditions set out in its AENV Operating Approval (Part 5), its Mineral Surface Lease (MSL) and AENV’s Code of Practice for Oil Production Sites. On the surrounding lands, much the same conditions will apply irrespective of whether the activity is on an actual land disposition held by JACOS or not; e.g.: Surface Materials Lease (SML), Pipeline Right of Ways (PLA), Licenses of Occupation (LOC), Miscellaneous Lease (MLL), and Borrow Pits.

5.3 General Land Use Principles

The basic principals underlying land use regulations are:

• to minimize impact by among other things, trying to minimize the footprint; • to avoid ecologically sensitive areas if possible, e.g.: wetlands, stream banks; • to conduct land disturbance activities in such a way that the area disturbed may be

readily reclaimed at a later date to an equivalent land use capability, i.e.: go in with the end in mind;

• to manage the disturbed lands in such a way that no additional impacts are caused, e.g.: controlling erosion, controlling weed infestations, stabilizing spoil piles through revegetation, etc; and

• to inform other occupants on the land of your presence.

5.4 Requirements

Regulatory Authorization

Direct approval must be obtained from the Waterways Office of the Land and Forest Division (ASRD) for any land disturbance activity. This includes making improvements to areas already disturbed and applies equally to areas on or off JACOS’ MSL or any other JACOS held surface dispositions (LOCs, PLAs, SMLs, etc.). Approval can range


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from as little as making a phone call to the Waterways Office to seeking an amendment for an existing surface land approval or applying for a new disposition.

JACOS Environmental Management must be notified of any planned land use activity as does JACOS’ Land Department.

Typical activities that require authorization among others are:

• widening of roads, • off pad ditch - runoff control improvements, • culvert installation off pad, • expanding the size of a pad, • re-opening a borrow pit, • any bush - brush slashing, • any disposal of woody debris/waste, • any revegetation activity, • any temporary land use activity, e.g.: campsites, temporary access, remote sumps -

pits, etc; • any disposal of drilling wastes unless to a pre-approved sump site, • any stockpiling of sub or topsoils, • any activity that requires the use of undisturbed (new) land, e.g.: new well pad, new

access road, new borrow pit, etc.

Specific Requirements What follows is an amalgamation of all that is contained in the three documents referenced (see Scope).

• All topsoil shall be salvaged from land to be disturbed. • Top soil shall be stockpiled as follows:

- topsoil shall be stockpiled separately from other materials, - stockpile foundations must be stable, - stockpiles shall be stabilized to control water and wind erosion, - stockpiles shall be accessible and retrievable, and - stockpiles shall be revegetated and controlled for weeds.

• Topsoil salvage operations shall be suspended immediately when: - wet (e.g.: break-up) or frozen (freeze-up) field conditions will result in the

degradation of topsoil quality, and - any other field conditions or operations occur that will result in the degradation

of topsoil quality, e.g.: rutting, high winds (loss of soil). • Drainage control measures will be used to minimize erosion and sedimentation on

disturbed land, e.g.: by practicing interim reclamation including topsoil replacement and re-seeding.

• All ditches and trenches discharging to the surrounding land or natural watercourses and water bodies will be stabilized in order to minimize erosion and sediment input.

• No debris or soil shall be deposited in or pushed through a watercourse/water body or


19

on the ice of a watercourse/water body. • Any (drilling) sumps - pits constructed will be in impermeable soils. • All merchantable timber will be salvaged. • The seed used for revegetation will be for native species and free of prohibited and

primary noxious weeds as approved by ASRD. • Existing clearings and trails are to be used wherever possible. • Leases will be maintained in a neat and clean condition.

External Notification

Either as a function of accessing an existing disposition or when applying for a new disposition, third party permissions or notifications are required. These permissions/notifications typically consist of:

• Proximity agreements • Crossing agreements • Road use agreements

In the cases where new dispositions are being obtained the Forest Management Agreement (FMA) holder needs to be notified and timber damage payments may or may not be required. Similarly, Consultative Notations also need to be made. All external notifications should be undertaken through JACOS’ Land Department.

Record Keeping & Internal Notification

A detailed record must be kept of each land disturbance and conservation, and reclamation activity undertaken at the Hangingstone site including any non-compliance with any of the above specific requirements. This means:

• what was done (or occurred), where, when, and how, • type and volume of materials used - removed, and • type and quantity of species planted or seed used

JACOS’ Operating Approval and MSL specify the need to submit an annual Conservation & Reclamation (C&R) Report or Land Use Report detailing as much. In that report which is prepared by JACOS Environmental Management, any additional disturbance must be rationalized, i.e.: were there alternatives, has every effort been made to utilize existing disturbances wherever possible, when necessary has any new disturbance been minimized etc.

Consequently, JACOS Environmental Management must be notified of any planned land use activity as does JACOS’ Land Department. Ultimately, Environmental Management will also be responsible for reclaiming the disturbance. If in the process of undertaking a land use activity, documentation is generated, regulatory or otherwise, it must also be submitted to Environmental Management. Documentation examples are:


20

• Environmental Field Reports; • Temporary Field Authorities (TFA’s) as issued by ASRD; • Reclamation Inspections as performed and documented by ASRD; • Destination and volumes of materials hauled, and placed; • As-built survey results, and • Applications for surface dispositions, seismic and drilling programs.

The actual process of amending an existing surface disposition or obtaining approval for a new surface disposition is handled by JACOS’ Land Department. Nevertheless, should either be required, Environmental Management still needs to be notified in advance.

JACOS Environmental Compliance Manual Section 6.0: Waste & Chemical Storage Revision 1: June 2010

21

6.0 Waste & Chemical Storage

6.1 Why? Contaminated site issues (soil and groundwater) arise equally from improper storage of products, wastes and chemicals, and spills of the same substances. Of equal importance are potential Health & Safety issues that can arise from the improper storage of substances.

6.2 Scope Requirements for the Hangingstone site are primarily dictated by the ERCB’s Directive 55 Storage Requirements for the Upstrea m Petroleum Industry and AENV Approval No. 1604-02-00. Also applicable are the Alberta Fire Code (Section 4.3) and the Waste Control Regulation under AEPEA. However, with a few exceptions Directive 55 incorporates the requirements set out in these other regulations.

6.3 General Principles Whether a substance requires secondary containment and the manner of containment is dictated by the following general principles.

• If the substance is a liquid then the liquid must meet the surface water discharge criteria (see below), else that liquid will likely require some form of secondary containment. In the case of a solid, the leachate or the water percolated over or through the solid, must meet the surface water discharge criteria. In the case of gas, the gas must be contained in a registered pressure vessel.

• The level of protection, i.e.: containment, required is a direct function of the nature of the substance (gas - liquid - solid) and the hazard - danger - toxicity potential of the substance.

• If a substance is toxic to a living organism, secondary contain it. All storage requirements are based on minimizing the potential for a substance to have an adverse effect on living organisms either in the short or long term.

6.4 Requirements At the Hangingstone site, other than for the exemptions - exceptions listed below, almost every substance requires some form of secondary containment whether a product, chemical or waste. As the facility was built after 1996, it was for the most part designed to meet the requirements of Directive 55 and new as of January 31, 2009, all domestic waste volumes are to be reported per our AENV operating approval. As a result, the requirements set out below relate primarily the need to know information related to operations or operational situations that may arise. Specific design requirements and sizing requirements for containment systems are contained in


22

Directive 55. Figures 6.1 and 6.2 show the locations of Plant 1 tanks and Plant 2 tanks, respectively.

Temporary Storage

Temporary is defined as being no more than three (3) months for the storage of materials produced, generated or used in specific operations at the facility. Typical activities requiring temporary storage of materials would be:

• turnaround or maintenance activities, • some construction operations, • spill containment and clean-up, • emergency or upset conditions, and • drilling, completions, and work over operations.

This does not mean that for temporary storage needs, the normal ERCB storage requirements no longer apply. JACOS is still expected to meet the intent of the ERCB’s requirements (e.g.: secondary containment) in order to minimize environmental impacts and ensure public safety. Contaminated materials or materials that have the potential to leach must not be stored directly on the ground, including the “boneyard”.

Volume Exemptions

• Above Ground Tanks:

− A tank or collection of tanks with a volume of < 5 m3 (5000 liters, 1100 Imp. gallons, 31.5 bbls) does not require secondary containment. These small tanks must be inspected visually monthly, have non-leaking fittings/nozzles/hoses, have preventative measures to avoid leaks and spills, and be either externally coated or made of a corrosion resistant material. Drip trays are recommended.

− Fuel tanks (gasoline, diesel) > 500 gallons (2275 liters) must be registered with the Petroleum Tank Management Association of Alberta (PTMA).

− Any tanks < 1 m3, which are portable, are considered to be containers. • Containers:

− A collection of containers with a combined volume of < 1 m3 at any site (1000 liters, 220 Imp. gallons, 5 bbls) does not require secondary containment.

− For large facilities that have collections of containers at more than one location within the facility, each of those locations is considered a site.


23

Exceptions

• Pressure Vessels: Pressure vessels registered with ABSA (Alberta Boilers Safety Association) do not

require secondary containment. • Water Tanks: Directive 55 states that if the water in a tank meets the Surface Discharge criteria, no

secondary containment is required. It should be noted that despite meeting surface discharge criteria for pH, chloride and

visible hydrocarbon sheen, if other chemical contamination is suspected (for example – organics) further testing must be done to confirm the water is not toxic or potentially harmful to the environment. Do not assume that simply meeting the above three criteria ensures the water is safe to discharge

• Sewage Tanks: No special monitoring or containment requirements. • Pop Tanks: Providing pop tanks are empty and inspected regularly, no secondary containment is

required. • Floor Drains: No secondary containment required providing they are infrequently used, are regularly

inspected to verify their integrity, are sufficiently sloped so that fluids do not accumulate, and are always maintained empty.

Most sumps, however, are considered underground storage systems and must have a

double wall.

Requirements for Above Ground Tanks e.g.: bitumen, slop oil, produced water, boiler feedwater (if it consists of recycled produced water or contains blowdown), glycol, boiler blowdown water, oil-water emulsions, caustic, acid - water and oil treatment chemical tanks.

• Secondary Containment:

All tanks ≥ 5 m3 must either be double-walled or be placed on an impervious compacted clay or synthetic liner and surrounded by an impervious dike sized as per


24

the Directive, where the dike capacity must be at least 100% the volume of the largest tank on the tank farm. There can be no uncontrolled opening through the dike. The dike must be maintained in good condition and the area encompassed kept free from grass, weeds, and other extraneous combustible material. Secondary containment for indoor above ground tanks must include an impervious containment floor and wall or curbing.

• Leak and Integrity Testing: Leak detection at the Hangingstone facility will consist of monthly visual inspection of

tanks and tank containment area liners for evidence of damage or leakage. One exception is the Plant 2 BFW Tank (TK-501), which must be visually inspected and results recorded daily. This condition of an ERCB approval for alternate storage design is outlined in a letter dated July 20, 2008. Leak detection from the site as a whole is monitoring through groundwater monitoring.

• Weather Protection: For above ground storage tanks ensure an exterior protective coating is maintained in

good condition.

Requirements for Containers e.g.: chemical totes

• General: A container is considered a portable aboveground storage device that does not exceed

1 m3 in capacity. • Secondary Containment:

All containers or a collection of containers with a total combined volume of ≥ 1 m3 (i.e.: five or more 45 gallon drums) requires secondary containment.

− Secondary containment systems (e.g.: pads-floors, dikes, curbs or collection trays) must be impervious to and will not react with the substance being stored.

− Curbs must have a minimum height of 15 cm, a capacity greater than the largest container or a capacity > 10% of the total volume contained; whichever is greater.

• Leak Detection and Weather Protection:

Leak detection is not required, other than visual inspection. For weather protection, provide a building, cover or coating (i.e.: paint) that will protect the integrity of the


25

containers.

• Empty Containers:

Typically, a chemical or product residual remains within a container upon emptying. In combination, many empty containers can still contain a substantial volume of the chemical or product. Thus, the above requirements may still apply. For example, with a 5% residual, twenty (20) 1 m3 totes in combination would necessitate secondary containment.

Requirements for Underground Tanks (including sumps & drains) e.g.: HLS sump at Plant 2, all building sumps

• General:

With the exception of double walled tanks with interstitial leak detection, as of January 1, 2002 the use of underground tanks is now prohibited. That is, the use of single-walled underground tanks where a synthetic liner or natural impermeable soil conditions are used for secondary containment has been discontinued as an option.

• Secondary Containment:

All underground tanks, regardless of size, must be double-walled. General construction factors are as follows:

- tanks and associated piping must be tested for integrity prior to placing in

service - steel tanks must have an external coating and cathodic protection - transfer lines and hoses must be compatible with material being stored and

have leak-proof connections - spill control devices must be used around hose connections - measures to prevent overfilling of tanks, such as automatic shutoff devices,

high-level alarms, etc., must be in place • Leak Detection:

Underground double-walled tanks must have interstitial leak detection which must be monitored monthly. Methods can consist of pressure monitoring, vacuum monitoring, electronic monitoring, vapour detection, manual sampling, or an equivalent method.

Requirements for Solids Bulk Pads

e.g.: lime storage quonset


26

• Primary Containment:

A compacted clay or synthetic liner, concrete or asphalt base pad with a slope directed to a catchment device (e.g.: sump) that allows for the collection of precipitation and leachate. The pad must have a continuous curb 15 cm in height on at least three sides. Materials must be stockpiled in a way that prevents them from tumbling over the curbs. Where leachate may potentially be generated, concrete or asphalt are considered good working surfaces but are not considered adequate for primary containment. In those cases, the pad must have:

- a compacted clay or synthetic liner under the working surface (primary containment device)

- a leachate containment system above the primary containment device

• Leak Detection:

A leak detection system under the concrete or asphalt pad is required if the stored materials may potentially generate leachate.

• Weather Protection:

Some form of cover is strongly recommended if a substance is at all leachable.

Discharge of Run-Off from within Containment Areas

Surface run-off water collected within secondary containment systems of a site, such as the diked area of a tank farm or within the surface water collection system (i.e. runoff pond), can be released in a controlled manner to the environment after it is tested and meets the following criteria. Under no circumstances can the run-off water be release into or near a water body (a dry creek bed is considered a water body).

- chloride content: maximum 500 ppm (mg/l), - pH of between 6.0 to 9.0, - no visible oil or hydrocarbon sheen, and - no other chemical contamination.

However, if there is any evidence or suspicion that the run-off water from within a containment area could be contaminated (ex. organics), do not release the water. If possible, the water should be recycled to the process. If that cannot be done, more detailed laboratory analysis is necessary to determine if the water can be released. For example, if organics are suspected, a Microtox® test should be done to determine the toxicity of the water. Other analyses may be required if different contaminants are suspected. If it cannot be concluded whether or not the water is suitable for surface discharge, it should be sent to an approved facility for treatment or disposal.


27

Withdrawal of Tanks from Service

• Temporary Withdrawal ≤ 180 days:

- isolate tank - empty tank (or measure and record fluid level in tank and repeat on a monthly

basis) - maintain cathodic protection if applicable - maintain monthly leak detection (if any fluid level is maintained)

• Temporary Withdrawal > 180 days:

- empty tank and ensure all vapours are removed - isolate tank and clearly indicate that it is empty - maintain cathodic protection if applicable - if tank is reactivated after one (1) year or more from being withdrawn from

service, verify the integrity prior to reactivation, then appropriately label the tank

• Permanent Withdrawal:

- aboveground tanks must be emptied and should be removed from the active part of the facility, and relocated to an appropriate storage area or disposed offsite

- after being emptied, underground tanks should also be removed if it doesn’t compromise the operation

- if not removed immediately, the underground tank must be isolated and removed when the facility is decommissioned

- once the tank is removed the surrounding soil should be checked for contamination and appropriately dealt with

Inspection, Monitoring, and Record Keeping

• Keep a record of when you tested and inspected tanks as per the above for a

minimum of five (5) years and preferably for the life of the tank. • Keep records of abnormal circumstances found during monthly visual tank inspections

or interstitial tests on double-walled tanks, as well as any corrective action taken, for five (5) years and preferably for the life of the tank.

• Same as above for interstitial leak detection on ponds or bulk pads where it applies. • Keep any run-off water testing and release records for ten (10) years. • Retain groundwater monitoring records for a minimum of five (5) years but preferably

for the lifetime of the site. • Keep copies of all required approvals, licenses and permits on site. • Maintain the names of all persons who conducted the inspection and monitoring

programs. • Also see Section 4.0, Documentation & Reporting.


28

Reference:

• ERCB Directive 55: Storage Requirements for the Upstream Petroleum Industry • Alberta Fire Code • AEPEA Waste Control Regulation

FIGURE 6.1PLANT 1 TANKS

RUN OFFLOADING PLATFORM

ELE

CT

POND

SLUDGEPOND

FEEDWATERTANK

BOILER

BLOWDOWNTANK

BOILER

FIGURE 6.2PLANT 2 TANKS

JACOS Environmental Compliance Manual Section 7.0: Release & Spill Reporting Revision 1: June 2010

29

7.0 Release and Spill Reporting 7.1 Why?

Failure to report a spill (an uncontrolled release) to the ERCB and AENV could lead to significant fines, penalties or charges. Furthermore, JACOS is also required to undertake soil monitoring programs and bi-annual groundwater monitoring, both of which are a means of detecting spills.

7.2 Scope

Spills are the uncontrolled release of a substance to air, soil or water (surface water body and groundwater). Included but often overlooked, are slow leaks and the release of gases in a manner that is not approved as an emission source. Responsibility for spills resides with both the ERCB (Table 7.1) and AENV (Table 7.2) dependent upon the substance. In general, spills are reported by regulatory agency as follows:

• ERCB: Spills of unrefined products on or off MSL, OSE or LOC lease boundary (see tables for reportable quantities), i.e.: those substances produced at an upstream oil and gas facility including wastes, as well as all pipeline breaks on or off lease.

• AENV: Spills of refined products (e.g.: fuels, lubricants, solvents, chemicals) and

those substances specifically controlled under an AENV approval, including air emissions and all unrefined spills off lease (see tables for quantities and classes and contact Environmental Coordinator if unsure).

• RCMP: If a Dangerous Good (see TDG or Transportation of Dangerous Good classification below) is released while still in transit to the site. This includes loading and offloading at the site. • Transport Canada: If a Dangerous Good (see TDG or Transportation of Dangerous

Good classification below) is released while still in transit to the site. This includes loading and offloading at the site. NOTE: AENV and/ or RCMP will act on behalf of Transport Canada and forward them this information, so a separate call is not needed to Transport Canada; HOWEVER, a separate report is required to Transport Canada (see reporting below).

If the spill constitutes an emergency, procedures for the response provided in the corporate and site-specific Emergency Response Plans (ERP) should be followed. Both of these documents are a requirement of the ERCB under Directive 71 Em ergency Preparedness and Response Requirements for the P etroleum Industry. Information provided in the ERPs will also assist in identifying the reporting requirements for an emergency situation.


30

7.3 General Principles

• Any release that “has caused, is causing or may cause an adverse effect” must be reported. Adverse effect is defined as “impairment of or damage to the environment, human health or safety or property”.

• In general, the toxicity of a substance, i.e.: its hazard potential or adverse effect potential, dictates the quantity at which a release becomes a reportable incident. This includes any process water spills on site, which must be treated with the same care and attention as any other process fluids on site.

• If in doubt, report. The consequences of not reporting are far more serious than discovering on further investigation that it was a non reportable incident.

7.4 Requirements

At the Hangingstone site, with few exceptions, the majority of substances spilled dependent upon volume, are reportable. Spills must be brought under control as soon as they are discovered. Clean-up of the spill should be started immediately and be completed without delay; contaminated soils must not be left on the ground surface, call environmental coordinator for assistance.

Table 7.1: ERCB Reportable Quantities by Substance

Substance Reportable Quantity

On lease: unrefined produced products and wastes,e.g.: - bitumen, - slop oil, - produced water, - process boiler blow down water, - any oil-water emulsions, - WCR & hot lime sludge (de-watered or not),

- produced sand, and - crystallizer salt

• on lease meaning: facility - well pads

any release > 2 m3 (2000 liters, 440 Imp. gallons, 12 bbls)

Off lease: produced products and wastes, as above • off lease meaning: undisturbed land and while in

transport

any release in any quantity

Pipeline Break (water source, water disposal, fuel gas)

any release, (any quantity)

Exception: in accordance with condition in ERCB letter dated July 30, 2008, any spill regardless of volume from the Plant 2 BFW Tank (TK-501) must be reported to the ERCB Waste & Storage Section in writing within 5 days.


31

Table 7.2: AENV Reportable Quantities by Substance

Substance Reportable Quantity Class 2.1 and 2.2 (compressed gas) > 100 liters Class 2.3 and 2.4 (poisonous and corrosive gas)

Any amount

Class 3 (flammable liquids) > 200 liters Class 4 (flammable solids) > 25 kilograms Class 5.1 (oxidizer) > 50 kilograms or 50 liters Class 5.2 (organic peroxide) > 1 kilogram or 1 liter Class 6.1 (poisonous substance) > 5 kilograms or 5 liters Class 6.2 (infectious substance) Any amount Class 8 (corrosive substance) > 5 kilograms or 5 liters Class 9.1 (substance having sufficient hazard to regulate)

> 50 kilograms

Class 9.2 (environmental hazard) > 1 kilogram

Chemicals by TDG

Classification (check

Material Safety Data

Sheet, MSDS)

Class 9.3 (dangerous waste) > 5 kilograms or 5 liters Uncombusted Flare Gas (flame out) All

Air Emissions

When emissions approval limits are exceeded or when an air contaminant is released from a non-approved point source. This includes odour issues due to flaring or venting, and/ or black smoke.

Approval exceedance and/ or there are possible adverse effect (see 7.3)

Diesel > 200 liters Gasoline > 200 liters Lubricant (if new, i.e.: unused) > 200 liters Solvents (e.g.: corrosion inhibitors) > 200 liters Glycols

> 200 liters

Used oil (spent lubricating oil and undrained lube oil filters)

> 5 kilograms or 5 liters

Wastes other than those under the ERCB listing

as per TDG, see Section 13, cheat sheets

Examples

Containers & Scrap Metal if to a water course and possibility of an adverse effect

Note: If not on the above listings, do not assume it is not reportable, seek advice.


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Initial Reporting

Reportable means at the first available opportunity i.e. (within 1 hour), not when it is convenient and the emergency/ incident is over If in doubt as to which agency is responsible, call both. If there is any immediate danger to any individuals (trappers) or groups (work crew) in the vicinity of the plant site, notify these people as soon as possible.

When reporting have the following information ready:

• the chemical and physical characteristics of the substance released, use MSDS if

applicable • the estimated quantity, • the receiving media, i.e.: air, land, water, • the time and location of the release, and • the risk to the environment, e.g.: were you able to contain it, if not where did it go?

You are expected to follow the reporting order outlined below meaning that if the first contact in the sequence can not be contacted, skip to the next and so on. In the unlikely event you are unable to reach any of the listed company contacts then you will need to report the release yourself to the regulatory agencies. If that occurs, keep a record of conversation. You will be issued with a reference number, make note of it.

1. Safety/Environmental Officer: Glyn Jones Site: (780) 799-4009

Cell: (780) 713-9114 Home: (780) 714-3455

↓ 2. On duty Shift Supervisor: As applicable Site: (780) 799-4019

↓

3. Regulatory Affairs Manager: Enzo Pennacchioli Calgary: (403) 668-5155 Cell: (403) 813-1086 Home: (403) 235-3035

4. Sr. Environmental Coordinator: Jos Lussenburg Calgary: (403) 668-5226 Cell: (403) 875-3113

Home: (403) 932-0908 ↓

5. ERCB, Bonnyville: (780) 826-5352 (24 hour) AND

AENV: (780) 422-4505 (Pollution Control Division, PCD) or 1 (800) 222-6514 (24 hour)

RCMP, Ft. McMurray (780) 799-8850


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Report at the FIRST AVAILABLE OPPORTUNITY and indicate you are still investigating if necessary. If less serious than first thought, make a follow-up call and inform accordingly. The regulatory on-call person is usually quite helpful.

7.5 Follow Up Reporting & Record Keeping

• ERCB: A verbal report must be followed up with the completion of an ERCB spill report form, the ERCB staff member who took the call will e-mail the

company representative that they spoke to the form, it will have a reference number called an “FIS” number on it. The form must be sent by e-mail to the local field office within 7 days. If final clean up (confirmatory samples are required for off site spills) is not achieved within the 7 day time frame, a closure report must also be sent once it is achieved. All written reports will be sent by the Environmental/Regulatory group in Calgary.

• AENV: A verbal report to AENV industry spill reporting Line (1-780-422-4505 or

[email protected]) must be followed up with a written report within 7 days (Table 7-3 shows an example) If final clean up (confirmatory samples are required for off site spills) is not achieved within the 7 day time frame, a closure report must also be sent once it is achieved. All written reports will be sent by the Environmental/Regulatory group in Calgary. The required content of the report is appended to this section as an example. If the incident proves to be a non reportable, AENV may waive that requirement

• RCMP: A verbal report made to the RCMP under TDG legislation must be

followed up within 30 days with a written report to Transport Canada, an e-mailed copy of the AENV report usually suffices. AENV will also take the verbal report on behalf of Transport Canada.

Reference:

• ERCB IL 98-1 • AEPEA Release Reporting Regulation • ERCB Directive 71: Emergency Pre paredness and Respon se Require ments for the

Petroleum Industry

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Table 7.3: Example Spill Report

Japan Canada Oil Sands Ltd. Hangingstone Facility

Land Description: 16-27-84-11-W4 AEPEA Approval # 1604-02-00

ERCB Scheme Approval # 8788G

Release Report, Alberta Environment Reference # xxxxxx 3 Information Item (as per AEPEA

Release Reporting Regulation)

(a) date and time of release June 29, 2009, at approximately 15:30

(b) location of the point of release Plant 1 Sales Oil Cooler

(c) duration of the release and release rate

Leak occurred at approximately 15:30 and continued for approximately 15 minutes until the process exchanger was drained and depressured.

(d) composition of release

(i) concentration Main constituent of the release was boiler blowdown which is typically high in pH (10.5-11), alkalinity (800-1200ppm), total dissolved solids (5000-7000ppm), and organics. There was also trace amounts of oil residue in the fluid.

(ii) total weight quantity of amount released

Volume of fluid released was estimated at 1m3. The total amount of contaminated gravel recovered was estimated to be 5m3.

(e) circumstances leading to release Seal failure on exchanger E-406B. The exchanger is a registered pressure vessel and is not within secondary containment.

(f) steps, procedures, taken to minimize, control or stop the release

Shell and tube sales oil exchangers E-406N and E-406B operate in series and are used to cool sales oil below 100˚C prior to storage in sales oil tanks. The exchangers have been equipped with an external wash system using boiler blowdown as the cleansing agent, where the exchangers are removed from service for cleaning. The leak occurred towards the end of a cleaning cycle. An operator started a circulation

35

3 Information Item (as per AEPEA Release Reporting Regulation)

pump to recirculate boiler blowdown from a storage tank through the exchange system to flush any remaining solids from the exchanger. It appears that starting the pump caused a sudden increase in pressure and a surge of flow through the exchanger, resulting in a seal failure on E-406B. The circulation pump was immediately shutdown and the exchanger was depressured and drained to a process tank. Sawdust was spread over the contaminated area to absorb the fluid. Approximately 5m3 of affected gravel and sawdust was recovered and placed in a solid waste bin. The material is consistent with previously recovered contaminated soils and was disposed of to a third party landfill accordingly.

(g) steps, procedures taken to prevent similar releases

The exchanger bundle cover was removed and the damaged seal was replaced with an original equipment manufacturer spare. The exchanger was reassembled and leak tested prior to restoring to service. The exchanger, which has been in service for over 4 years, is a registered pressure vessel with common, suitable seal materials and as such, re-occurrence is not expected. Notwithstanding, JACOS will continue to explore improved seal materials and, if an improvement is found, will replace the existing seal at the earliest opportunity.

(h) any other information required by the Director

JACOS Environmental Compliance Manual Section 8.0: Soil Monitoring Revision 1: June 2010

36

8.0 Soil Monitoring 8.1 Why?

Soil monitoring is the first line of defense in monitoring for spills - leaks at an industrial site for the products and wastes produced, and the chemicals used. A release (spill) that impacts soil is no different than a release to a surface water body as the spilled substance will eventually leach into the groundwater table, i.e.: it is a reportable incident.

8.2 Scope

JACOS is required by its AENV Approval, to monitor the soil on and around both Plant sites and as they are brought on line, producing well head pads. This involves the submission of a monitoring plan every 5 years which on approval is followed by a sampling program. The results of the sampling programs in turn dictate whether a soil management plan is required. For the Hangingstone facility such a management plan is in effect. Typically the management plan entails further delineation as required, the clean-up of any contamination, changes to equipment if determined to be the cause and changes to the work practices/procedures that may have contributed to the contamination. Soil management plan activities are reported annually to AENV.


• The cost of remediation is far greater than avoiding the problem in the first place

through good operating practices. • The cumulative effect of small drips and slow leaks over time is no different than a one

time spill event. • The parameters that make up the analysis suite reflect the products and wastes

produced, and the chemicals used at the site. This means that even relatively small quantities or accumulations of substances when spilled on bare ground, will likely be detected sooner or later.

8.4 Requirements

• Ensure that the integrity of secondary containment systems is maintained at all times,

e.g.: - keep run-off drainage valves/openings closed, - avoid the use of heavy equipment inside containment areas or on dykes, and - do not drive stakes, drill or auger holes inside containment areas.

• Repair leaking flanges and valves as soon as practically possible. Even minor drips and small leaks can amount to substantial volumes over time.

JACOS Environmental Compliance Manual Section 8.0: Soil Monitoring Revision 1: June 2010

37

• If there is any suspicion that a tank or pond may be leaking, bring it to the attention of the plant supervisor or manager.

• Clean-up spills promptly and if absorbed into the ground, remove the contaminated soil immediately.

• Avoid cleaning and maintenance activities on bare ground that involve the use of chemicals/solvents where inadvertent spillage is likely.

• Do not store product, wastes or chemicals, even temporarily, on bare ground without fully understanding their hazard potential and thus the storage requirements as per Section 6.0 of this Manual.

8.5 Monitoring Network

The locations of the points sampled and analyzed to date are shown on Figure 8.1 and 8.2. + Reference:

• AENV Approval 1604-02-00, Section 4.7

LEGEND

FUEL GAS &UTILITIES

PONDS

FLARE

OIL TREATING

TANK FARM&

TRUCK LOADING

FUEL TANK

OFFICE &WAREHOUSE

WATER STORAGE FORSTEAM GENERATION

STEAM GENERATION

BOILER FEEDWATER TREATMENT

TANK FARM

LIME SLUDGESTORAGE

2003-2005 SOIL SAMPLING LOCATIONS WITHPARAMETERS EXCEEDING REGULATORY GUIDELINES

PLANT 1

pHBoron

BoronCresols

pHECBoron

pH

ECSAR

ECpH

ECpH

ECpH

ToluenePHC-F2

PHC-F3

EC

pH

PHC F2

PHC F3

SAR

KOMEX INTERNATIONAL LTD.ENVIRONMENT AND WATER RESOURCES

johnsons

Text Box

8.1

johnsons

Rectangle

LEGEND

OIL TREATING

STEAMGENERATION

WATER RECYCLE

RUNOFFPOND

SLUDGE POND

TANK FARM&

TRUCK LOADOUTOFFICE/ADMIN/VEHICLE

MAINTENANCE

WATER DEOILING

FLARE & UTILITIES

GLYCOL TREATING &COOLING SYSTEMS

2003-2005 SOIL SAMPLING LOCATIONS WITHPARAMETERS EXCEEDING REGULATORY

GUIDELINES PLANT 2

pHCresols

EC

EC

ECSAR

EC

pHEC

ECSAR

ECSAR

EC

ECSAR

pH

pH

EC

SAR

KOMEX INTERNATIONAL LTD.ENVIRONMENT AND WATER RESOURCES

johnsons

Text Box

8.2

johnsons

Rectangle

JACOS Environmental Compliance Manual Section 9.0: Groundwater Monitoring Revision 1: June 2010

38

9.0 Groundwater Monitoring 9.1 Why?

Groundwater (GW) monitoring is the last line of defense in monitoring for spills - leaks at an industrial site for the products and wastes produced, and the chemicals used. A release (spill) that impacts groundwater quality is no different than a release to a surface water body, i.e.: it is a reportable incident.

9.2 Scope

JACOS is required as per its AENV Approval, to monitor groundwater quality in and around both Plant sites and as they are brought on line, producing well head pads as well. This involves the installation of monitoring wells and sampling these wells twice per year, in the spring and fall. The sampling analysis results need to be submitted as part of the annual report to AENV.


• The cost of remediating a contaminated groundwater problem is far greater than

avoiding the problem in the first place through good operating practices. • The cumulative effect of small drips and slow leaks over time is no different than a one

time spill event. • The parameters that make up the analysis suite reflect the products and wastes

produced, and the chemicals used at the site. This means that even relatively small quantities or accumulations of substances when spilled on bare ground, will likely be detected sooner or later.

9.4 Requirements

• Ensure that the integrity of secondary containment systems is maintained at all times,

e.g.: - keep run-off drainage valves/openings closed, - avoid the use of heavy equipment inside containment areas or on dykes, and - do not drive stakes, drill or auger holes inside containment areas.

• Repair leaking flanges and valves as soon as practically possible. Even minor drips and small leaks can amount to several litres over a 24 hour period.

• If there is any suspicion that a tank or pond may be leaking, bring it to the attention of the plant supervisor or manager.

• Clean-up spills promptly and if absorbed into the ground, remove the contaminated soil as well.

• Avoid activities in the immediate vicinity of groundwater monitoring wells. They are expensive to replace, if accidentally damaged or destroyed.

JACOS Environmental Compliance Manual Section 9.0: Groundwater Monitoring Revision 1: June 2010

39

• Monitoring wells have a protective outer steel casing with a cap that should be locked. If found unlocked, report immediately to your supervisor. Do not handle the inside 2" plastic standpipe. Even a small amount of a substance (e.g.: oil) on your hands or gloves could contaminate the entire well.

9.5 Monitoring Network

JACOS currently has 10 nested pairs of GW monitoring wells for a total of 33 wells. At each location the “A” well monitors the deeper depth (around 10 meters) and the “B” well monitors the shallower depth (around 2 meters). The location of the wells is shown on Figure 9.1.

9.6 Reporting & Record Keeping

JACOS must submit an Annual Groundwater Monitoring Report by March 31 of the following year to AENV. All GW related records must be kept on file for 10 years. Reference:

• AENV Approval 1604-02-00, Section 4.6

LEGEND

FIGURE 9.1GROUNDWATER COMPLIANCEMONITORING WELLS

GROUNDWATER WELLMONITORED

AFIG 3

GEOLOGICCROSS SECTION

A'FIG 3

PROPOSED 2010MONITORING WELL

JACOS Environmental Compliance Manual Section 10.0: Run-Off Control Revision 1: June 2010

40

10.0 Run-Off Control

10.1 Why? Run-off from rainfall has the potential to become contaminated as a result of the operations conducted at an industrial site.

10.2 Scope As per current AENV standards, run-off at both the Plant 1 and 2 facility sites is routed to lined run-off collection ponds (see Figure 10.1). Both collection ponds have been sized to accommodate the 1 in 25 year 24 hour maximum rainfall event. As specified in JACOS’ AENV Approval, prior to controlled release, these collected waters must be tested.


• The presence of an industrial site will not adversely affect surface water quality around the site.

• Run off water from an industrial site should not cause erosion when it is discharged.

10.4 Requirements

• Ensure the ponds levels are maintained in such a manner that the run-off from a rainfall event can be accommodated, i.e.: do not maintain the ponds full. Prior to freeze-up pond levels should be low in anticipation of the spring run-off.

• Prior to release, a grab sample from the respective run-off pond will be collected and submitted to an accredited laboratory for testing of the Surface Discharge Criteria, which are:

− chloride content: < 500 ppm (mg/l), − pH of between 6.0 to 9.0, − no visible oil or hydrocarbon sheen, and − no other chemical contamination.

If, in the interval between sampling and receipt of results a major rainfall event occurs necessitating over boarding, a new sample will be obtained and tested on site for the Surface Discharge Criteria prior to release. A duplicate sample must then be submitted for offsite laboratory analysis for verification.

• All pond discharge events, (over boarding or recycle to the process) will be recorded, i.e.: date, time, duration, testing results and total volume released. Note: in cases where the pond water is recycled to the process, laboratory test results are not


41

required. • Over boarding will occur in a controlled manner such that no erosion occurs either at the discharge point nor down slope on the receiving lands (also see Section 5, Land Use). • Ensure that the run-off waters collected within secondary containment systems do not

contaminate the main run-off collection pond (see Section 7, Storage). If there is any reasonable doubt as to the quality of the water collected within a secondary containment system, test prior to it being routed to the run-off collection pond.

• Consideration should be given to re-using the collected run-off as process make up water, particularly if the water quality exceeds the parameters specified under the Surface Discharge Criteria.

Exception: Well Pad 6 was soil cemented in order to improve trafficability. A consequence of soil cementing is that an impermeable surface is created. This results in:

• greater volumes of run-off as rainfall is not absorbed in the soil, and • an increased risk that any materials spilled on the pad will be incorporated in the

run-off water Furthermore, the nature of soil cementing is such that the properties of native soil used for pad construction are altered by the chemical additives used in the cementing process. As such, when all of these factors are taken in combination, more comprehensive testing of the run-off water originating from Pad 6 is advisable. The scope of the analysis must include:

• Routine potability (analytical code: RCAP-P) • Chemical Oxygen Demand (analytical code: COD) • Microtox IC50 (analytical code: MTOX) • Oil and Grease (analytical code: OGIR)

10.5 Best Management Practice Aside from the run-off ponds which are specifically controlled as per JACOS’ operating approval there is also an internal standard. The internal standard or best management practice requires that where any other accumulation of run-off water occurs and there is a need to overboard the water; they too will be tested for the Surface Discharge Criteria on site.

10.6 Record Keeping Maintain a record of all over boarding events, as specified above, whether from licensed runoff ponds or any other runoff accumulations on site for a period of 10 years. JACOS is required to


42

submit an annual wastewater and runoff report for all licensed runoff ponds to AENV. References:

• AENV Approval 1604-02-00, Section 4.2 • Mineral Surface Lease 972290 • ERCB Directive 55: Storage Requirements for the Upstream Petroleum Industry

WELLPAD 2

PO

ND

PLANT 1

WELLPAD 1

PLANT 2

WELLPAD 3

WELLPAD 5

WELLPAD 6

PIPERACK

POND

OVERBOARD

OVERBOARD

FIGURE 10.1RUN-OFF POND RELEASE POINTS

JACOS Environmental Compliance Manual Section 11.0: Source Wells Revision 1: June 2010

43

11.0 Source Wells 11.1 Why?

JACOS’ supply of raw water comes from groundwater reservoirs. In the immediate area around the Hangingstone site, these groundwater reservoirs are scarce. Managing this resource is critical to ensuring a sustainable supply.

11.2 Scope

Use of a ground or surface water resource is controlled under the Water Act administered by the Water Management Branch of AENV. Under the Act, JACOS has temporary licenses to divert water from two wells, designated DQ02-2 and DQ06-7 (DQ = Deep Quaternary), the location of which is shown on Figure 11.1. The licenses specify among other things, how much water JACOS may divert and a requirement to report annual water use and reservoir health.


• Reservoir production can not exceed reservoir recharge else long term supply will be

compromised. • The higher the rate a well bore is produced at; the shorter its service life will be.

11.4 Requirements

• Table 11.1 outlines the maximum allowable water diversion from each well on an

annual basis, what that translates to on an average daily basis, and the maximum that can be pumped based on the installed equipment.

Table 11.1: JACOS Licensed Water Source Wells

JACOS Designator LSD

Annual Licenced Water Allocation1

(maximum)

Average Daily Allocation

DQ02-2

DQ06-7

DQ02-2 + DQ06-7 (in combination)

SE-11-84-11W4 438,000 m3/year 1,200 m3/day

1 the allocation is for the interval or reservoir being pumped not the individual well, i.e.: JACOS may produce 438,000 m3/ year from the specified interval using either of the two wells individually or a combination of the two wells. The maximum daily allocation is 1,350 m3/ day for each well if only one is in operation or in combination if both are in operation.


44

• Each water source well must be equipped with a totalizer type volume meter. Meter readings will be taken monthly.

• Water level readings from within a well must be taken while the pump is operating. These readings will be taken monthly when a well is operational and must include the time and date the reading was taken.

• JACOS is required to submit an annual return summarizing total consumption, monthly consumption and monthly water levels within the wells.

11.5 Recommended Operating Practices

• Wells DQ02-2 and DQ06-7 should be produced concurrently while on high rates.

While on low rates (< 600 m3/day), production should be alternated between the two wells on a weekly basis. From a long term reservoir management perspective, sustained lower volume production is always preferable to cyclic high volume production.

• Pumps should never be set within the screened interval of the well. Doing so will increase the risk of fouling - plugging of the screens and can also result in pump failure due to overheating caused by no water flow past the motor which is located at the very bottom of the pump assembly, i.e.: below pump suction. The well screen intervals are shown in Table 11-2.

Table 11-2: JACOS Water Source Well Completions

SCREEN PLACEMENT PUMP SETTING

Top Bottom Interval

Initial Water Level

Drop Pipe

Top of Pump to Suction

Well Cap to GL Pump Suction

WELL

(m Below Ground)

(m Below Ground) (m)

(m Below Ground) (m) (m) (m)

(m Below Ground)

DQ02-2 64.6 82.9 18.3 26.3 55.95 1.61 0.6 57.56

DQ06-7 70.9 86.5 15.6 25.9 65.4 1.61 1.0 67.01

• In the immediate vicinity of the two production wells (DQ02-2 and DQ06-7) are three observation wells or monitoring wells (DQ02-3, DQ05-5-50, and DQ06-8). These wells monitor the aquifer (interval being produced) as well as water bearing zones above and below the aquifer. In addition, there are also three far field monitoring wells (DQ05-4-100, DQ02-1, and TW01-1). All these wells contain level loggers, the data from which is used for regulatory reporting. These wells should only be accessed by qualified personnel.


45

11.6 Reporting & Record Keeping

• JACOS must file an Annual Water Use Report with AENV by February 28th of the

following year in which the data was collected. • Monthly volume records and well level records must be kept on file for 10 years, while

annual Water Use reports must be kept for a minimum of 5 years. Reference:

• Water Resources Act, Section 27 • AENV Licence to Divert Water, File No. 60460/ Licence No. 00229371-01-00

JACOS WD5

JACOS WD 41-23

JACOS WD3

JACOS WD2-23

HIGHWAY 63

TW9

TW8TW7

JACOS WS2-23

JACOS WD2 2-23

DQ02-2

MS

L 97

2290

DQ06-7

123

121110

131415

242322

34 35 36

25

36

2627

34 35 36

DQ05-4TW9

TW8TW7

6.1 KM TO

DISPOSAL P

/L ROW

DQ02-2DQ06-7

DQ05-4

FIGURE 11.1WATER SOURCE LAYOUT

JACOS Environmental Compliance Manual Section 12.0: Disposal Wells Revision 1: June 2010

46

12.0 Disposal Wells 12.1 Why?

Despite the extensive use of water recycle technology, JACOS still has a requirement to dispose of small volumes of blowdown and crystallizer brine. As such, JACOS has two remaining disposal wells where blowdown is disposed, while crystallizer brine is trucked offsite for third-party disposal.

12.2 Scope

Requirements for the injection of fluids into wells for disposal are dictated by the ERCB’s Directive 51, Injection a nd Disposal Wells - W ell Classif ications, Completions, Lo gging and Testing Requirements. Packer testing and reporting requirements are contained in the ERCB’s IL 94 -18 and Directive 51. JACOS’ two disposal wells are licensed as Class Ib disposal wells with the ERCB. The wells are located some 3 km SSE as shown on Figure 12.1. They are connected to the plant site by means of a 4 inch pipeline.


• Ensuring through well completion design, limiting injection pressures and annual

packer testing that no contamination of shallower aquifers (groundwater resources) will occur.

• JACOS’ disposal reservoir(s) is of limited extent meaning that the volume of water that can be injected in the short term is also limited.

• Concentrated boiler blow down is high in salinity, alkalinity and organics. As such, it is corrosive, toxic and an environmental hazard. It should therefore be treated with due care and attention.

12.4 Requirements

• Table 12.1 below outlines the maximum allowable injection pressure by well, the

maximum injection capacity (volume) by well and the recommended (sustainable) injection capacity.

JACOS Environmental Compliance Manual Section 12.0: Disposal Wells Revision 1: June 2010

47

Table 12.1: JACOS Licensed Disposal Wells

LSD

JACOS Designator

Max. Injection Pressure (kPa)

15-14-84-11W4

WD3

2500 2-23-84-11W4

WS2-23

2250

• Wells WS2-23 and WD3 are thought to have been completed into the same water

sands reservoir. This reservoir is known to be of limited extent. Therefore the rapid injection of large volumes of waste water should be avoided to prevent the reservoir from becoming over pressured, i.e.: unable to take water or only at significantly reduced rates.

• Each well is fitted with a totalizer type volume meter. Readings are taken monthly and recorded.

• With the establishment of JACOS’ Pipeline Int egrity Manage ment Pla n (see Section 13), a risk assessment was conducted on the disposal pipeline. An alarm will sound when there is a discrepancy in flow to warn of a potential leak.

• The following can not be injected into any disposal well: - sewage, used lubricating oils, spent solvents,

- diesel invert drilling muds, and - water that meets surface discharge criteria or is able to be readily treated to

meet discharge criteria (technically and economically). • Waste water from third parties (i.e.: other producers) will not be disposed of in JACOS

disposal wells. • Waste liquids are not permitted to be injected into a formation above its fracture

pressure (use third column in table as guide). • Annual packer tests are to be performed on all wells. The packer test results must be

submitted to JACOS head office for electronic submission to the ERCB on or before September 1 of each year.

• Disposal wells WD4 and WD5 have been abandoned.

12.5 Record Keeping

Volume records and packer tests will be maintained on file for a minimum of 2 years by

law; however, JACOS policy is that records should be retained for 10 years. References:

• ERCB IL 94-2 & Directive 51: Injection and Disposal Wells - Well Classifications, Completions, Logging and Testing Requirements

• ERCB IL 94 -18: Isolation Packer Tests, Testing and Reporting Requirement

14

23

WD5

WS2-23

WD3

WD4

13

24

RO

AD

ALL

OW

AN

CE

JACOS P/L ROW AND ACCESS ROAD

PCI PCEJ2-23

WD2-23

WD2 2-23

JACO

S P/L AND

ACC

ESS RO

AD

131415

242322

252627

MS

L 97

2290

WD5

WS2-23

WD3

PLANT 2

PLANT 1

WD4

FIGURE 12.1DISPOSAL WELLS

DISPOSAL PIPELINEACTIVE

DISPOSAL PIPELINEABANDONED

DISPOSAL WELLACTIVE

DISPOSAL WELLABANDONED

JACOS Environmental Compliance Manual Section 13.0: Pipelines Revision 1: June 2010

48

13.0 Pipelines 13.1 Why?

The construction, operation, abandonment, and eventual reclamation of a pipeline can generate a number of environmental concerns, including impacts to soil, vegetation, landscape, surface and groundwater, fish habitat (e.g.: buried pipelines crossings are below creeks), air, and land use.

13.2 Scope In Alberta, most activities related to oil and gas pipelines are administered by the ERCB. In addition, Alberta Environment regulates conservation and reclamation activities related to pipelines. The design, construction, operation, and abandonment of oil and gas pipelines in Alberta are regulated by:

- the Pipeline Act and Regulations - CSA Z662 (for design, construction and testing standards) - ERCB Directive 41 – Pipeline Integrity Management Plans - ERCB Directive 66 – Inspection Requirements and Procedures for Pipelines

All oil and gas pipelines in Alberta must be licensed by the ERCB. Also mandatory is the registration of all oil and gas pipelines with Alberta One Call.

13.3 General Principles Land use due to pipeline activities follow the same principles outlined in Section 5.0, Land Use, of this manual. That is, impacts must be minimized by trying to minimize footprint, where possible avoid ecologically sensitive areas and conduct activities in a way that may be readily reclaimed later. The pipeline must be designed, constructed and operated in a manner that will protect its integrity. The primary goals of which are to:

• Control access to minimize industrial and recreational traffic; • properly operate and maintain the pipeline to reduce the potential for spills, leaks, and

the resulting environmental damage and health impacts; • maintain right-of-way to ensure vegetative cover is established and prevent the growth

of noxious weeds; • ensure spill prevention/mitigation measures are in place to minimize environmental

impacts should a spill occur;

JACOS Environmental Compliance Manual Section 13.0: Pipelines Revision 1: June 2010

49

• ensure a release reporting system is in place to properly report leaks/spills if they occur (see Section 7.0, Release – Spill Reporting, of this manual).

13.4 Requirements

In accordance with ERCB Directive 041, JACOS has established a Pipeline Integrit y Management Program to ensure the principles outlined in Section 13.3 are facilitated. JACOS’ Pipeline Integrity Management Program contains the following main elements:

• corporate policies • record keeping • competency and training • change management • failures and release reporting • hazard identification and control • risk assessment • hazard control and risk reduction • program planning • inspection, testing, patrol, and monitoring requirements • risk mitigation and repair

The Pipeline Integrity Management Progra m is a controlled document, copies of which are stored both at head office and the field office. References:

• ERCB Directive 41: Adoption of CSA Z662-03, Annex N, as Mandatory • ERCB Directive 66: Requirements and Procedures for Pipelines • JACOS Pipeline Integrity Management Program • CAPP Environmental Operating Practices for the Upstream Petroleum Industry,

Alberta Operations, Pipelines Volume

JACOS Environmental Compliance Manual Section 14.0: Air Emissions Revision 1: June 2010

50

14.0 Air Emissions

14.1 Why? Control and monitoring of air emissions are necessary to protect the health and safety of employees, to avoid nuisance odours, and to minimize environmental impact.

14.2 Scope JACOS’ operating approval from Alberta Environment stipulates operating and monitoring requirements as it relates to air emissions. Also applicable are the Alberta Ambient Air Quality Objectives which set maximum ground level concentrations for a number of compounds, notably nitrous oxides (NOX), sulphur dioxide (SO2) and hydrogen sulphide (H2S), among others. In JACOS’ AENV approval, SO2 emission limits are specified as is the requirement to passively monitor ambient air quality around the facility. The results of this passive air quality monitoring in turn can be equated to the criteria specified in the Alberta Ambient Air Quality Objectives (AAAQO). AENV Approval 1604-02-00 also stipulates that continuous ambient air quality monitoring is to occur on-site for six months of every year and is to include active monitoring of H2S, NO2, SO2, wind speed, and wind direction. JACOS is required to submit both monthly and annual air quality monitoring reports to AENV. The ERCB’s Directive 60 - Upstream Petroleum Industry F laring, Inciner ating and Venting Requirem ents sets out requirements to ensure efficient combustion of flare gas and minimum produced (solution) gas conservation ratios. 14.3 General Principles

• Air emissions once leaving a point source disperse into the atmosphere, however, dispersion equates to emission dilution not emission elimination.

• The earth’s atmosphere is a closed system. The various compounds that make up releases to atmosphere, i.e.: emissions, may change over time but they do not disappear.

• The release of un-combusted gas to the environment (venting or fugitive emissions) is many times more harmful than when incinerated.

14.4 Requirements

JACOS AENV Approval

• JACOS may emit air emissions from the following continuous (Table 14-1, Figure 14-1) and intermittent (Table 14-2, Figure 14-2) sources:


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Table 14-1: Continuous Emission Sources

Stack Description Tag # Height Above Grade

Plant 1 14.6 MW OTSG stack B-201A 12.0 14.6 MW OTSG stack B-201B 12.0 2.34 MW glycol heater stack H-701 9.0 879 kW fuel gas line heater stack H-702 12.0 low pressure flare stack FS-702 20.0 high pressure flare stack FS-701N 26.0 Plant 2 52.7 MW OTSG stack B-510 30.0 52.7 MW OTSG stack B-520 30.0 14.6 MW OTSG stack B-540 30.0 2.93 MW glycol heater stack H-755 9.0 low pressure flare stack FL-804 18.3 high pressure flare stack FL-801 18.3

Table 14-2: Intermittent Emission Sources

Source Description Tag # Height Above Grade

Plant 1 Emergency Diesel Generator G-702 8.2 Plant 2 Emergency Diesel Generator EG-920 4.9 Plant 2 Emergency Diesel Generator EG-925 3.7 Pad 4 Emergency Diesel Generator G-701 6.1 Phase 1 Wellhead Pop Tank TK-301N Phase 2 Wellhead Pop Tank TK-141 Phase 3 I & J Wellhead Pop Tank TK-157 Phase 3 Wellhead Pop Tank TK-167 Phase 4 Wellhead Pop Tank TK-185 Phase 5 Wellhead Pop Tank TK-180 all space ventilation exhaust stacks all space heater exhaust vents


52

Releasing air emissions - contaminants from sources other than those specified above is not permitted. An air contaminant is defined as a substance that has caused, is causing or may cause an adverse effect (see Section 7.3). In the event that there is a need to release an air contaminant as a result of a maintenance or turnaround activity, written permission from AENV must be obtained and the ERCB needs to be notified in advance.

• JACOS shall operate the facility in such a manner that fugitive emissions are managed, e.g.: repair valve and flange leaks promptly. A fugitive leak detection and correction program is in place for the facility. Details are discussed later in the section.

• Flares shall be equipped with a wind guard and a continuously burning pilot light, and an electric (or equivalent) igniter. Full design requirements are specified in Directive 60.

• JACOS shall ensure the combustion of all gases released to flare. Should a flame-out occur where the flare does not re-ignite immediately, such an event must be reported (see Section 7.4). Should re-ignition of the flare fail after several attempts, the plant must be shut down when it is safe to do so. The release of uncombusted gas from a flare is considered an uncontrolled release to the air.

• All plant pressure and safety valves in sour service shall be connected to the flare systems with the exception of the wellhead separator pop tank PSVs. Permission for this exception was granted under a special application. A detailed record must be kept of any known releases from these PSVs (when, where duration, estimated volume and composition.

• JACOS must calculate, based on monthly produced, purge and fuel gas analyses, its daily emissions of SO2 in tonnes per day. These results must be submitted in a monthly report to AENV. Currently, JACOS is limited to emitting 1.63 tonnes (1,630 kg) of SO2 per day (combined Plant 1 and Plant 2).

Monitoring & Reporting

• JACOS must maintain six (6) static exposure air quality monitoring stations around the

site. These stations as shown on Figure 14-3, measure total sulphation and hydrogen sulphide levels passively (that is, there is no mechanism for drawing or collecting air samples). The elements must be changed on the last day of every month and be submitted as soon as possible for analysis. The results must be reported to AENV in the monthly air reports by the end of the following month. The monitoring stations may not be moved without prior authorization from AENV.

• Beginning in 2010, JACOS is to monitor the ambient air quality continuously for six (6) months per year. Parameters of interest are H2S, NO2, SO2, wind direction, and wind speed.

• JACOS must submit a monthly report to AENV on or before the end of the month following the reporting month.

• JACOS must submit an annual report to AENV on or before March 15 in the year following the reporting year.

• As a best management practice JACOS has recently started reporting flare gas volumes and estimated daily SO2 emissions in the daily reports as a means of flagging potential limit violations or abnormally high flare rates before they become a real issue.


53

Monitoring & Reporting Responsibilities

• Plant Personnel:

- change the elements in the all static air quality monitoring stations on the last day of the month,

- submit the exposed elements to a laboratory for analysis as soon as practically possible,

- ensure that the monthly analysis results are forwarded to the individual responsible for monthly report preparation, i.e.: head office., and

- check the daily report numbers for correctness, investigate abnormal flaring/SO2 emission rates and contact head office is a problem is suspected

• Head Office Personnel:

− review daily reports to ensure the flaring and emission numbers are reported

correctly and follow up on any abnormal or unusual numbers, − prepare and submit monthly report to AENV, and − prepare and submit annual report to AENV.

Air Quality Guidelines

In the absence of real time or active air quality monitoring, knowledge as to whether these criteria have been exceeded will likely come after the fact. Nevertheless, plant personnel should be aware that the following concentrations (one hour averages) may not be exceeded at ground level:

- SO2: 0.17 ppmv (parts per million by volume), - NOX: 0.21 ppmv, - H2S: 0.010 ppmv.

The AAAQO specify limits for a number of other air contaminants. A complete listing is contained at the end of this section.

ERCB Directive 60:

Directive 60 provides regulatory requirements and guidelines for flaring, incinerating, venting, and produced gas conservation. The contents of the Directive include solution gas management practices, performance and design requirements for flares, venting and fugitive emissions management, sulphur recovery requirements, measurement and reporting requirements, compliance and enforcement.

Some specifics are:

− conserving facilities (such as Hangingstone) must be designed for a 95%

produced gas conservation (recovery ratio) with a minimum operating level of


54

90% − gas recovery ratio = ((total produced gas - flared produced gas)/total produced

gas)*100 − notification requirements and guidelines for gas recovery equipment planned

and unplanned outages > 4 hours; Calgary office must be notified for PGR and/or VRU outages (in advance for planned outages and as soon as possible for unplanned ones)

− the net (or lower) heating value of gas directed to the flare (including makeup gas) must be ≥ 20 MJ/m3

− there must not be routing smoke emissions from a flare − more detailed flare stack design criteria are contained in Directive 60

14.5 Fugitive Emissions Fugitive emissions are unintentional releases of gas resulting from process. Sources that may have fugitive emissions include valves, pump seals, PSVs, compressor seals, flanges, connectors, tank hatches/PVRVs, etc. Since uncombusted gases are a greater risk to health, safety and the environment, all attempts must be made to minimize them. JACOS’ Phase 3 AENV approval amendment stipulated the requirement to have a fugitive emission program. In 2009, an updated Fugitive Em issions Leak Detection and Correction Program was approved by AENV, which describes JACOS’ continuation of the Plant Specific Leak Rate Screening Value Correlation Equations method for leak detection. As required by the conditions of the approval, it conforms to the CCME (Canadian Council of Ministers of the Environment) Environmental Code of Practice for the Mea surement a nd Control of Fugitive VOC (volatile organic compounds) Em issions f rom Equipment Leaks . The CCME guideline specifies how fugitive emissions must be measured, emission rates calculated, data reported, and what are the maximum leak percentage criteria. A company specializing in fugitive emission surveys conducts an annual survey and reports leak rates to JACOS, who in turn submits the report to AENV along with recommendations if necessary. Maintenance personnel are informed about the surveys so that they may be available to attempt leak repairs on the spot. Leaks that require shutdowns are noted and should be fixed at the next turnaround. The following leak criteria have been set by the CCME (Table 14-3). The actual leak percentage rates for each equipment type must be below the criteria to be in compliance with approval conditions.


55

Table 14-3: CCME Maximum Leak Percentage Criteria For Equipment Types

Equipment Type CCME Leak % Criteria

Valves 2 Pump Seals 10 PSVs 2 Compressor Seals 10 Flanges 2 Connectors 2

14.6 Greenhouse Gases Greenhouse gases (GHG) are components of the atmosphere that contribute to atmospheric warming. The most common GHGs are water vapour, carbon dioxide, methane and nitrous oxides. Present in much smaller quantities are chlorofluorocarbons (CFCs), hydrofluorocarbons (HFCs), and sulphur hexafluoride. Every greenhouse gas has a global warming potential (GWP), which is a measure of the warming effect of that gas relative to carbon dioxide. Table 14-4 compares the GWPs of the most common GHGs and sulphur hexafluoride. The table illustrates the importance of controlling fugitive methane emissions because every tonne of uncombusted methane released to the atmosphere is equivalent to 21 tonnes of CO2.

Table 14-4: Global Warming Potential (GWP) Factors

Greenhouse Gas Global

Warming Potential

(GWP) carbon dioxide (CO2) 1 methane (CH4) 21 nitrous oxide (N2O) 310 sulphur hexafluoride (SF6) 23,900

In 2007 the Alberta Government established the first greenhouse gas legislation in Canada. The Specified Gas Emitters Regulation (SGER), which went into effect July 1, 2007, stipulates who is subject to the regulation, the facility’s baseline year, the estimating and reporting standards, reduction targets, and the compliance options. The regulation applies to industrial facilities that emit ≥ 100,000 tonnes of CO2-e GHGs per


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year. The reduction targets are intensity based. Currently, the reduction target for established facilities is 12% below baseline year intensity. The compliance options include: meeting the target intensity, purchasing performance credits from another Alberta facility, purchasing offsets from an Alberta based project, or purchasing credits from the Alberta Government at $15/tonne CO2 above the target. The penalty for non-compliance is $200/tonne CO2-e.

14.7 Record Keeping All records relating to air quality shall be maintained on file for 10 years. References:

• ERCB Directive 60: Upstream Petroleum Industry Flaring, Incinerating, and Venting • AENV Approval 1604-02-00, Section 4.1 • Alberta Air Monitoring Directive


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58


59


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FIGURE 14.1PLANT 1 STACKS

RUN OFFLOADING PLATFORM

ELE

CT

POND

SLUDGEPOND

NEW SCRUBBER STACKNEW OTSG STACK

HEATERGLYCOL

EMERGENCY GENERATORS

OTSG STACKOTSG STACK

FIGURE 14.2PLANT 2 STACKS

WELLPAD 2

PLANT 1

WELLPAD 1

PLANT 2

WELLPAD 3

WELLPAD 5

WELLPAD 6

PIPERACK

FIGURE 14.3STATIC AMBIENT AIRMONITORING STATIONS

JACOS Environmental Compliance Manual Section 15.0: Waste Disposal Revision 1: June 2010

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15.0 Waste Disposal 15.1 Why?

Many wastes are hazardous and toxic. When wastes are shipped offsite for disposal, the generator of that waste remains responsible for the waste until it is properly disposed of. This includes being able to track the waste while in transport and ensuring it has arrived at an approved waste receiver. Furthermore, the generator must be in a position to prove it.

15.2 Scope

• As an upstream oil and gas producer in Alberta, JACOS must comply with the

requirements set out in the ERCB’s Directive 58. • Federal and provincial Transportation of Dangerous Goods (TDG) requirements also

apply. However, if the ERCB requirements are met, then so are TDG requirements, within the boundaries of Alberta.

15.3 General Requirements

The ERCB’s Directive 58 is long (222 pages) and complex in its message. This summary captures the following key requirements that upstream O&G producers are now obliged to observe and administer.

• What constitutes “waste” has been defined and classified into ninety seven (97) types some of which are dangerous (DOWs: dangerous oilfield wastes) and some are not (NDOWs: non dangerous oilfield wastes), and some of which are reportable and some not. A list of these classifications and their newly assigned codes is attached.

• Waste generators are required to reduce volumes of waste to a minimum by the recognized strategies of “Reduce, Reuse, Recycle, and Recover”, and to deal with what remains appropriately.

• Generators are required to “characterize” this waste into “Dangerous” and “Other”. Until disposed of, wastes must be stored separately and contained properly. If a site or facility is being used to stockpile wastes from surrounding sites, the ERCB will now need to be notified of their existence and dependent upon scale, these sites may require formal approval.

• Disposal must be to properly licensed receivers. • The storage and movement of wastes must be backed by a record keeping system of

manifests, specifically:

− As the generator of potentially dangerous wastes that are to be transported on public roads, you are required to prepare manifests.

− Because there is also a requirement to track “Reportable NDOWs”, these also need to be manifested.


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− Generators must now use the ERCB wastes codes. − Generators must also reconcile their records with those of the receiver, i.e.:

discrepancies must be accounted for within 60 days, and if serious, must be reported immediately.

− The reconciled originals of the manifest must be sent into the ERCB within 60 days.

− Companies must retain these records for a minimum of two (2) years. − Companies must be prepared to submit on request, an annual waste

disposition report in the format required by the ERCB.

• There are additional requirements in the Directive as it relates to:

− the type of waste streams that may be injected into sales pipeline systems, i.e.: most are banned,

− the stockpiling of your own wastes at a central site (waste storage facility, as above),

− waste storage and transfer stations, i.e.: a facility where third party wastes are received,

− waste processing facilities, typically where for the secondary recovery of crude oil from emulsions, processes are used such as retention - gravity separation - heat application,

− the surface facilities associated with Class 1a or 1b disposal wells1, − the operation of an oilfield landfill, only applicable if a producer operates their

own landfill, − minimum design and operating requirements for sites where the bio-

remediation of waste is occurring, e.g.: biopiles - land farms, and − incinerators that process more than 10 tonnes of waste per month.

The intent of this regulatory process is to ensure that wastes are properly handled. Oil Gas producers must not only be in a position to do it right but also to prove that they did right.

15.4 Specific Requirements

Plant Operators / Drilling, Completions, Workover Consultants • Before disposal can be considered, the waste must be characterized then

classified as DOW or NDOW as per the ERCB requirements. Operators are responsible for knowing the quantity and type of waste generated on-site, getting wastes characterized, then classifying the wastes so that the waste is sent to the

1 wells specifically licensed for the disposal of various dangerous/toxic waste streams as well as produced water. Note: JACOS= concentrated boiler blow down stream must go to a Class Ib well and not a Class II well which are for conventional produced water only.


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appropriate disposal facility. • Be present and personally complete an ERCB manifest form when either Dangerous

Oilfield Wastes (DOWs) or reportable Non-Dangerous Oilfield Wastes (reportable NDOWs) are being shipped from a site for which the Operator is responsible as per Table 15-1 (cheat sheet). Delegating this responsibility to transporters/receivers is not acceptable unless it is with the specific approval of JACOS Management.

• Follow the steps set out for the JACOS Operator on Figure 15-1 (Waste Disposal Decision Process) and Figure 15-2 (Waste Manifesting flow diagram).

• On receiving copies 1 and 2 (white & yellow) back from the receiver, ensure the receiver has filled in the “Handling Code” (see back of ERCB manifest for explanation). If necessary, call the receiver to get that information because if the waste goes to a transfer station (Code: 2), JACOS head office will need to obtain a final disposition report from the receiver.

• Ensure that any discrepancies that arise between the point of shipment and the point of receipt are reconciled when shipping a DOW, i.e.: determine the reason for the discrepancy. If the discrepancy is serious, for example, if a quantity of waste appears to have been lost somewhere during transport, then report immediately to the JACOS Supervisor to whom you normally report. If unable to contact this individual then go down the contact list provided in Section 1.3 until you reach someone. For reportable NDOWs (those requiring manifests, as per cheat sheets), the same applies except with a 72 hour reporting requirement.

• Ensure that no wastes are transported or shipped directly to a location across provincial or international boundaries from the Hangingstone site. If in doubt, consult the Plant Superintendent or his designate.

• Ensure that only approved waste transporters and receivers are used. • If a non routine waste or new waste stream requires shipping, contact Senior

Environmental Coordinator at head office, phone: (403) 668-5226, and he/she will assist you.

Plant Superintendent, or Designate

• Ensure the steps set out for JACOS Head Office, Calgary on Figures 15-1 and 15-2

(flow diagrams), Waste Manifesting Process, are followed. • Provide advice and guidance to operations personnel regarding the interpretation of

waste disposal regulations OR refer to Senior Environmental Coordinator (403) 668-5226 or Regulatory Affairs Manager (403) 668-5155.

• Audit waste handling and disposal operations and procedures formally or in the course of performing day to day duties.

Other JACOS Employees/Contractors

In the course of performing projects, take into account waste handling considerations

and ensure that the procedure as outlined for JACOS Operators is followed when wastes need to be disposed of.

See the Example of Waste Manifest Tracking at the end of this Section


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15.5 Record Keeping

• Maintain a copy (blue or photocopy) of all manifests at site for a minimum of 2 years. • Ensure the white copy (original) is sent to the ERCB directly (if a DOW) or that it is

sent by way of Calgary Head Office for forwarding to the ERCB. • Forward all yellow copies to Calgary Head Office for data entry. • Maintain copies of any laboratory analysis utilized to characterize a waste at site for a

minimum of 2 years.

References:

• ERCB Directive 58: Oilfield Waste Manage ment Require ments for the Upstrea m Oil and Gas Industry

• ERCB ID 96-03


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Table 15-1: ERCB Waste Codes


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Example of Waste Manifest Tracking

JACOS Environmental Compliance Manual Section 16.0: Noise Control Revision 1: June 2010

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16.0 Noise Control 16.1 Why?

Noise pollution can have a serious impact on the health of employees and the well being of nearby seasonal residents (trappers).

16.2 Scope

JACOS’ requirements are dictated by the ERCB’s Noise Control Directive 38 where the emphasis is on environmental noise (i.e.: minimizing noise impacts on surrounding residents). Due to the Hangingstone site’s relative isolation, the number of affected individuals is few. Nevertheless, the ERCB’s noise requirements still apply.


Noise from industrial facilities must be controlled to levels that are acceptable to receptors in the vicinity. This doesn’t necessarily mean that noise must be eliminated but it does mean that noise levels coming from the facility must not adversely impact indoor noise levels for nearby residents. Best practices should be incorporated to manage noise levels from the facility. This may include taking regular fence line measurements to determine if there are any significant changes in noise levels from the facility and planning activities that generate higher than normal noise levels during the day.

16.4 Requirements

• The ERCB Directive 38 – Noise Control specifies that in the absence of permanent

dwellings, maximum permissible noise levels at 1500 meters from a facility must not exceed 50 dBA during the day and 40 dBA during the night time period.

• Sound propagation modelling results indicate that during light wind conditions the predicted downwind combined Plant 1 and 2 facility sound level is 36 dBA at 1500 meters, while the predicted facility sound levels with the average ambient noise is 39 dBA at 1500 meters. Thus under normal operating conditions noise levels should not be a factor for individuals. However, non routine activities such as construction or maintenance activities could impact noise levels negatively.

Thus potential noise impacts stemming from non routine activities need to be identified at the planning stage so that stakeholders may be notified and regulatory approval may be sought, i.e.: JACOS’ Stakeholder and Community Relations Coordinator and Environmental Coordinator need to be informed.

JACOS Environmental Compliance Manual Section 16.0: Noise Control Revision 1: June 2010

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16.5 Record Keeping

Consultation and measurement records will be maintained on file for 2 years. References:

• ERCB Directive 38: Noise Control

JACOS Environmental Compliance Manual Section 17.0 Section 17.0: Vegetation & Wildlife Control Revision 1: June 2010

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17.0 Vegetation and Wildlife Control 17.1 Why?

Vegetation

When a non native species is introduced into an ecosystem that is not adapted to it, the non native species can become invasive, i.e.: there are no natural checks and balances on the new species. This in turn can result in the crowding out of native species with a consequent loss in biodiversity.

Herbicides are toxic to more than just the target species. Inappropriate use is not only a human health and safety concern but also a concern to any other living entities.

The bare ground areas typical on facility sites also lend themselves to both natural re-vegetation by early successional species and noxious weeds. This vegetation may need to be controlled to reduce fire hazards and to make maintenance activities easier.

Wildlife

Personnel encounters with wildlife are inevitable at a facility located in the middle the boreal forest. Similarly, with the availability of shelter, warmth and possibly food, wildlife pests become probable at some point in time. Knowing the best preventative measures and knowing how to respond in the event of an encounter, are important.

Similar to herbicides, pesticides are also toxic to more than just the target species. Inappropriate use is not only a human health and safety concern but also a concern to non target species.

17.2 Scope

In Alberta there are regulations controlling the use and application of pesticides and herbicides as a function of type and quantity. Similarly there are also regulations governing wildlife management.


Vegetation

• The introduction and spread of non native plant species must be avoided. • Improper or excessive use of sterilants and herbicides represents a human health risk

as well as an environmental risk. • Excessive vegetation in amongst process facilities represents a fire hazard and can


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interfere with maintenance practices. Wildlife

• Responding to nuisance wildlife or dealing with trapped, maimed or injured wildlife

should be left to professionals. • Improper or excessive use of pesticides represents a human health risk as well as a

risk to animals. • Poor housekeeping attracts nuisance animals.

17.4 Requirements

• Vegetation control will be undertaken by qualified contractors, certified by the province as licensed Pesticide Applicators (Industrial Class).

• Employees and contractors must ensure that vehicles and equipment working on JACOS surface dispositions are free of mud and other debris which may serve as a seed carrier.

• The Fish and Wildlife division of ASRD will be contacted in the event wildlife becomes a nuisance. ASRD will also be contacted if trapped or injured wildlife are encountered within the facility area.

• Any caribou sighting no matter where will be reported to JACOS’ Safety and Environment Officer.

• In support of JACOS’ health, safety, and environmental policies, JACOS’ management would like to make the following clear.

- The carrying and use of firearms by all employees on all JACOS surface land

dispositions is prohibited, and - Hunting and fishing by employees is prohibited on all JACOS surface land

dispositions, as is the use of these lands to access non-JACOS lands for these purposes.

17.5 Record Keeping

• Vegetation control activities will be reported to JACOS’ Safety and Environment Officer.

• Wildlife sightings in the general facilities area will be reported to JACOS’ Safety and Environment Officer.

• Any caribou sighting whether within the fence line or outside the fence line will be reported to JACOS’ Safety and Environment Officer for transmittal to ASRD.


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References:

• AEPEA Pesticide Ministerial Regulation • Weed Control Act • Wildlife Act

appendix i: hangingstone demonstration project ... · appendix i: hangingstone demonstration...

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