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

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

Department of Environment and Natural Resources Government of the Northwest Territories

Norman Wells, NT. June 12-13, 2014

Overview

• Aquatic Effects Monitoring Program (AEMP)
• Surveillance Network Program, Surface Water

Run-off

• Soil Treatment Facility and Groundwater Testing
• Spill Contingency and Response Planning
• Deposition of Contaminants to Land and Water

from Flaring

• Closure & Reclamation

ENR Intervention: S13L1-007 - June 12-13, 2014

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.”

3 ENR Intervention: S13L1-007- June 12-13, 2014

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….

4 ENR Intervention: S13L1-007- June 12-13, 2014

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

5 ENR Intervention: S13L1-007- June 12-13, 2014

Aquatic Effects Monitoring Program (AEMP)

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 insufficient to monitor HC’s

6 ENR Intervention: S13L1-007- June 12-13, 2014

7 ENR Intervention: S13L1-007- June 12-13, 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

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.

8 ENR Intervention: S13L1-007- June 12-13, 2014

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

9 ENR Intervention: S13L1-007- June 12-13, 2014

Spill Contingency & Response Planning

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

10 ENR Intervention: S13L1-007- June 12-13, 2014

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

11 ENR Intervention: S13L1-007- June 12-13, 2014

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

12 ENR Intervention: S13L1-007- June 12-13, 2014

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

13 ENR Intervention: S13L1-007- June 12-13, 2014

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

14 ENR Intervention: S13L1-007- June 12-13, 2014

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.

15 ENR Intervention: S13L1-007- June 12-13, 2014

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

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…..

Closure and Reclamation

18 ENR Intervention: S13L1-007- June 12-13, 2014

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

Thank you