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 • 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 ENR Intervention: S13L1-007, 2014 2
Mandate and Authority “Protect and enhance environmental quality in the North” 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 ENR Intervention: S13L1-007, 2014 3
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. ENR Intervention: S13L1-007, 2014 4
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 overlap • A coordinated and consistent approach to environmental protection between various agencies within the operational area is required ENR Intervention: S13L1-007, 2014 5
Closure and Reclamation 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 of all SL&WB and NEB regulated sites/activities/facilities/structures • Cont….. ENR Intervention: S13L1-007, 2014 6
Closure and Reclamation 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 ENR Intervention: S13L1-007, 2014 7
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 operational 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
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 9
Aquatic Effects Monitoring Program (AEMP) 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.” ENR Intervention: S13L1-007, 2014 10
Aquatic Effects Monitoring Program (AEMP) • 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…. ENR Intervention: S13L1-007, 2014 11
Aquatic Effects Monitoring Program (AEMP) 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 ENR Intervention: S13L1-007, 2014 12
Spill Contingency & Response Planning 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 6 th , 2014 ENR Intervention: S13L1-007, 2014 13
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. ENR Intervention: S13L1-007, 2014 14
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 ENR Intervention: S13L1-007, 2014 15
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 operations • Information of waste to air should be placed on the SL&WB public registry • Ensure transparency and public accountability ENR Intervention: S13L1-007, 2014 16
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 ENR Intervention: S13L1-007, 2014 17
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 ENR Intervention: S13L1-007, 2014 18
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 ENR Intervention: S13L1-007, 2014 19
Thank you ENR Intervention: S13L1-007, 2014 20
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