Imperial Oil Resources Ltd. Type A Water Licence Hearing S13L1-007 - - PowerPoint PPT Presentation

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Imperial Oil Resources Ltd. Type A Water Licence Hearing S13L1-007 - - PowerPoint PPT Presentation

Jul 06, 2023 285 likes •494 views

Imperial Oil Resources Ltd. Type A Water Licence Hearing S13L1-007 Norman Wells, NT. 2014 Department of Environment and Natural Resources Government of Northwest Territories ENR Intervention: S13L1-007, 2014 1 Overview Mandate

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SLIDE 1

Imperial Oil Resources Ltd. Type A Water Licence Hearing S13L1-007

Department of Environment and Natural Resources Government of Northwest Territories

Norman Wells, NT. 2014

1 ENR Intervention: S13L1-007, 2014

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SLIDE 2

Overview

  • Mandate
  • Closure & Reclamation
  • Surveillance Network Program, Surface Water

Run-off

  • Aquatic Effects Monitoring Program (AEMP)
  • Spill Contingency and Response Planning
  • Soil Treatment Facility and Groundwater Testing
  • Deposition of Contaminants to Land and Water

from Flaring

2 ENR Intervention: S13L1-007, 2014

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SLIDE 3

Mandate and Authority

GNWT authority to manage waste derived from:

  • Environmental Protection Act (EPA) and
  • Wildlife Act

GNWT subscribes to the following principles:

  • Ensure equivalent level of environmental protection

throughout the territory

  • Keep Clean Areas Clean
  • No environmental liabilities for future generations

“Protect and enhance environmental quality in the North”

3 ENR Intervention: S13L1-007, 2014

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SLIDE 4

Closure and Reclamation

  • IORL describes SLWB & NEB as primary jurisdictions
  • Norman Wells proven area located primarily on Block

Land Transfers (essentially Commissioner’s/Community Lands)

  • ENR has jurisdiction for final clearance (certificate of

remediation) for closure activities on Commissioner’s/Community Lands

  • Compliance with NWT EPA and Environmental Guideline for

Contaminated Site Remediation, November 2003 (CSR Guideline) required

  • ENR supports IORL stated Phase I, II, and III

Environmental Site Assessment approach

  • References National Guidelines for Decommissioning Industrial

Sites (CCME 1991) for closure and reclamation activities.

  • This approach is consistent with ENR’s CSR Guideline.

4 ENR Intervention: S13L1-007, 2014

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SLIDE 5

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Closure and Reclamation

  • Unclear:
  • Whether current WL term includes suspension of

Norman Wells oil/gas activities

  • What sites/facilities included in closure and

reclamation fall under jurisdictions of the SL&WB, those of NEB

  • Aspects of the mandates of GNWT, SL&WB, and NEB
  • verlap
  • A coordinated and consistent approach to

environmental protection between various agencies within the operational area is required

ENR Intervention: S13L1-007, 2014

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SLIDE 6

Recommendations:

i. ENR concurs with the establishment of a Closure and Reclamation Working Group, in place throughout term of WL ii. Licensee submit within one year of WL, an Interim Closure and Reclamation Plan which includes:

  • Expected closure date
  • Record of all sites reclaimed to date
  • Timelines for progressive reclamation through to closure
  • f all SL&WB and NEB regulated

sites/activities/facilities/structures

  • Cont…..

6

Closure and Reclamation

ENR Intervention: S13L1-007, 2014

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SLIDE 7

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Recommendations ii) continued:

  • Annual review with necessary revisions to reflect

changes in operations, technology, or additional updates to previous year’s activities

  • Revisions submitted for approval*
  • Applicable clean-up criterion should be determined in

Closure and Reclamation Working Group

  • A Groundwater Modelling and Monitoring Program to

support progressive reclamation activities developed

Closure and Reclamation

ENR Intervention: S13L1-007, 2014

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SLIDE 8

Surveillance Network Program, Surface Water Run-off

  • Schedule 3 of draft WL differentiates between

Category A and Category B locations

  • These categories are used to determine potential

Surveillance Network Program (SNP) locations

  • Category “B” require physical testing for

contaminants, while Category “A” do not

  • Locations of Schedule 3 facilities all within the
  • perational area, all potential sources of

contaminant release

  • Visible oil sheen test in Category “A” not modern

practice and sufficient to monitor HC’s

8 ENR Intervention: S13L1-007, 2014

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SLIDE 9

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Surveillance Network Program, Surface Water Run-off

Recommendations:

SNP updated to ensure :

  • All Surface Water Runoff Facilities are considered

the same and tested according to Category “B”

  • That all bunkers (both mainland and on islands) are

included as SNP stations

  • ENR concurs with recommendations by AANDC for

Effluent Quality Criteria (EQC) for total petroleum hydrocarbons and SNPs

ENR Intervention: S13L1-007, 2014

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SLIDE 10

Aquatic Effects Monitoring Program (AEMP):

  • “…a monitoring program designed to determine

the short and long term effects in the Receiving Environment resulting from project activities; to evaluate the accuracy of impact predictions; to assess the effectiveness of planned impact mitigation measures; and to identify additional impact mitigation measures to reduce or eliminate environmental effects.”

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Aquatic Effects Monitoring Program (AEMP)

ENR Intervention: S13L1-007, 2014

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SLIDE 11
  • ENR supports formation of AEMP Working

Group to review and advise its development

  • ENR is currently working with Sahtu

communities to:

  • identify water-related community concerns
  • prioritize these concerns
  • identify research questions
  • conduct a Community-based Water Quality

Monitoring Program hence….

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Aquatic Effects Monitoring Program (AEMP)

ENR Intervention: S13L1-007, 2014

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SLIDE 12

Recommendations/Commitments:

  • ENR concurs with an AEMP Working Group

being established, and commits to active membership

  • ENR commits to engage Sahtu communities to

assemble a list of water-related concerns/research questions and assemble sample data to aid development of an AEMP

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Aquatic Effects Monitoring Program (AEMP)

ENR Intervention: S13L1-007, 2014

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SLIDE 13

ENR requested in its intervention an update to the plan and recommended:

  • To resubmit the Spill Contingency and Response

Plan to include missing pages 33-35, the location of supplies, and clarify that the NT/NU Spill Line is not a lead agency, but the reporting mechanism.

IORL staff subsequently addressed these issues in an updated Section 18, submitted March 6th, 2014

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Spill Contingency & Response Planning

ENR Intervention: S13L1-007, 2014

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SLIDE 14

Soil Treatment Facility and Groundwater Testing

IORL states the following:

  • Soil Treatment Facility on site
  • Perimeter groundwater monitoring on annual basis
  • Sampling is typically conducted in August

ENR concern: Groundwater sampling in August alone may not monitor when groundwater table at its highest, i.e. during freshet in spring/early summer

Recommendation:

  • Update the groundwater sampling regime to demonstrate it is

monitoring groundwater throughout seasonal fluctuations in the groundwater table.

14 ENR Intervention: S13L1-007, 2014

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Deposition of Contaminants to Land & Water from Flaring

  • Historical/current activities result in emissions of

waste products via air from flaring, fugitive emissions, process emissions, and/or other releases

  • Sampling and/or detection systems not in place
  • Historically documentation lacking, including:

– quantification of contaminants – assessment of fate – mitigative measures

15 ENR Intervention: S13L1-007, 2014

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Deposition of Contaminants to Land & Water from Flaring

  • Regulatory control of oil/gas facilities under the

National Energy Board (NEB)

  • NEB regulatory authorizations expire Dec 2014
  • SL&WB process only open/public process for these
  • perations
  • Information of waste to air should be placed on

the SL&WB public registry

  • Ensure transparency and public accountability

16 ENR Intervention: S13L1-007, 2014

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Deposition of Contaminants to Land & Water from Flaring

  • At the Jan 2014 Technical Session ENR & EC tabled

concerns regarding air emissions

  • During follow up teleconference, IORL agreed to

course of action (per email)

  • ENR would like to ensure that this information is

public and is posted to the public registry, and included for consideration in pending NEB authorizations

17 ENR Intervention: S13L1-007, 2014

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SLIDE 18

Deposition of Contaminants to Land & Water from Flaring

Recommendations:

  • Quantify and assess all sources of emissions on-site,

including but not limited to fugitive emissions, process emissions, etc.

  • Develop the following information and provide it in the

Environmental Protection Plan:

– Flare log requirement – Overview of purposes (e.g., safety) and components of flaring – Explanation of variability in flaring practices – Discussion of the projects/operational changes – Options with associated challenges / constraints

18 ENR Intervention: S13L1-007, 2014

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SLIDE 19

Deposition of Contaminants to Land & Water from Flaring

Recommendations cont:

  • Build more detail into flare chart and summary included

in the NEB annual report and consider presenting flaring on an intensity basis

  • IORL provide the report annually to SL&WB registry to

ensure availability and demonstrate they are addressing public concerns about flaring

19 ENR Intervention: S13L1-007, 2014

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SLIDE 20

Thank you

20 ENR Intervention: S13L1-007, 2014