Environmental Protection and Enhancement Act Approvals and Registrations Procedure Regulation Applications for Sour Gas Processing Plants and Heavy Oil Processing Plants A Guide to Content Environmental Sciences Division Issued August 1996 (Revised September 1999) www.gov.ab.ca/env/protenf/publications/appsourgas.pdf APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 1 INTRODUCTION The Activities Designation Regulation (Alberta Regulation 211/96) under the Environmental Protection and Enhancement Act (EPEA) requires that the defined types of plants obtain an approval for construction, operation, or reclamation. The purpose of this guide is to assist companies or their agents in preparing applications. EPEA was enacted in September, 1993 replaced nine former acts, including both the Clean Air Act and Clean Water Act. The procedures for obtaining approvals under EPEA are significantly different than under previous legislation (i.e. Clean Water Act and Clean Air Act). EPEA also has public notification, review and appeal provisions and requirements which must be complied with when seeking a new approval or an amendment/renewal for an energy facility. This guideline has been written to assist companies in preparing applications to construct or operate sour gas processing plants and heavy oil processing plants. CO-OPERATION WITH THE EUB Section 26(1) of the Oil and Gas Conservation Act requires the Alberta Energy & Utilities Board's (EUB) approval of any scheme for the processing of gas. Through agreement, the EUB acts as the "one-window" for applications for new projects when a Joint Notice is necessary or when an Environmental Impact Assessment (EIA) is required. When Joint Notice or EIA is not required, direct application to Alberta Environment (AENV) in advance of application to the EUB may be appropriate. This is to fulfill the need for public notice that is required under EPEA for certain non-routine applications. In all other circumstances beyond those specifically mentioned, the applications concerning environmental matters must be sent directly to AENV for review and approval under EPEA. Generally, the approval processes of both agencies proceed in parallel with co-ordination and integration to reduce the time to process the applications. For applications for renewal of the EPEA operating approval, applications are sent directly to AENV with no EUB involvement. The information requirements outlined in this guide relate only to EPEA approvals; however, an attempt has been made to make the application information requirements complementary to EUB information requirements. Operators may also be subject to requirements under the Water Act, Public Lands Act, or federal legislation. CONTACTS Where there is a Joint Notice or EIA requirement, applications should be submitted to: Alberta Energy & Utilities Board (EUB) 640 - 5th Avenue S.W. Calgary, Alberta T2P 3G4 Tel: (403) 297-8311 (Note: Five copies are required for AENV.) APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 2 For renewals of EPEA operating approvals or applications that only involve changes to EPEA approvals, four copies of all applications should be submitted to: Alberta Environment (AENV) Regulatory Approvals Centre Main Floor, 9820 - 106 Street Edmonton, Alberta T5K 2J6 Information regarding AENV approvals, approval requirements, and fee schedules can be obtained from the following contacts: Re: Application Guides: Regulatory Approvals Centre (RAC) (780) 427-6311 Re: General Air Quality Issues, General Wastewater/Groundwater/Soil Issues: Industrial Program Development Branch AENV Edmonton (780) 427-5883 Re: Site Specific Application Information Bow Region Northeast Boreal Region 201, Deerfoot Square 6th Flr, Oxbridge Place 2938 – 11 Street NE 9820 – 106 Street Calgary T2E 7L7 Edmonton T5K 2J6 Tel: (403) 297-7948 Tel: (780) 427-7617 Fax: (403) 297-5944 Fax: (780) 427-7824 Prairie Region Northern East Slopes Region 245, Provincial Bldg 107, Provincial Bldg 200 – 5 Avenue S 111 – 54 Street Lethbridge T1J 4L1 Edson T7E 1T2 Tel: (403) 381-5322 Tel: (780) 723-8395 Fax: (403) 382-4428 Fax: (780) 723-8386 Parkland Region Northwest Boreal Region 3rd Flr, Provincial Bldg 2nd Flr, Provincial Bldg 4920 – 51 Street 9621 – 96 Avenue Red Deer T4N 6K8 Peace River T8S 1T4 Tel: (780) 340-7744 Tel: (780) 624-6402 Fax: (780) 340-5022 Fax: (780) 624-6542 APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 3 APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 4 INFORMATION REQUIREMENTS General information requirements for energy facility applications under EPEA are outlined in Section 3(1) of the Approvals and Registrations Procedure Regulation (Alberta Regulation 113/93 with amendments up to and including Alberta Regulation 211/96). Some of the information required in the Regulation has been waived by the Director for Sour Gas Processing Plant applications. This guide outlines the type of information that is required to ensure a "complete" application whether it is a new plant, plant approval renewal, or amendment. Any questions on content should be directed to the appropriate AENV regional contacts. Note: Applications are public documents. Any sections of an application that the applicant wishes to be kept confidential should be identified and the reason for confidentiality given and justified. The Director makes the decision on requests for confidentiality with refusals subject to appeal. FORMAT To ensure compliance with the requirements of the Regulation, it is important that the required information is provided in the application. However, the format of the application is at the discretion of the applicant. Providing the information requested in this guide in the sequence noted will result in a "stand alone" application document that will meet the information requirements of the regulations and be readable by members of the general public. If the format is changed then the use of cross-references to the information requirements in the regulations is encouraged to improve the reviewability of the application. General information that has been prepared for the EUB such as their Application Common Page can be included as a cover page for the EPEA application. TIME REQUIRED TO OBTAIN APPROVAL One of the major components of EPEA is the requirement for mandatory Public Notification for any application, which is considered non-routine. Once an application is received, reviewed and declared complete (i.e. the application contains the information required as per Section 3(1) of the Approvals and Registration Procedure Regulation), then the applicant will be informed of the notification requirements and the suggested format of the public Notice of Application. The regulations require a minimum 30-day period after a Notice of Application has been made to allow the public to submit "Statements of Concern". This notification period should be built into the project schedule, especially when a project may have serious time constraints. In general, the target is to issue all necessary approvals within 60-90 days from the time application is received but this time period will vary depending on the complexity of the application, public interest and concern, and completeness of the application. APPLICATION FEES Application fees are required for an initial approval, an approval amendment, or an approval renewal. This application fee is based on the plant's sulphur inlet rate (for sour gas processing plants) or the heavy oil processing capacity (for heavy oil processing plants). For more information on the fee schedule, please APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 5 contact the Regulatory Approvals Centre (RAC). CODE OF PRACTICE - COMPRESSOR AND PUMPING STATIONS AND SWEET GAS PROCESSING PLANTS As part of the Alberta Government's move to regulatory reform, approvals are not required for Compressor and Pumping Stations and Sweet Gas Processing Plants as defined in the Activities Designation Regulation. Environmental requirements are laid out in Code of Practice along with the registration form. To obtain a copy of the Code of Practice, please contact the Regulatory Approval Centre (RAC) or the Queen’s Printer. FACT SHEETS As part of this guide, various "fact sheets" will appear as Appendices to outline Department policy or procedures on technical matters. These will be updated as changes are made. USER INPUT Comments on this guide are welcomed. In this regard, please contact: Randy M. Dobko, Senior Engineer Industrial Program Development Branch, Alberta Environment, Edmonton (780) 427-6869 APPLICATION GUIDE Note: Information required as per Section 3(1) of the Approvals and Registrations Procedure Regulation is in a larger font. Specific information that must be provided by the applicant is in smaller font. 3 (1) An application must be made to the Director and must be accompanied by the following information relative to the activity, the change in the activity or the proposed amendment, addition or deletion of the term or condition: (a) The name and address of the applicant: New/Renewal/Change 1. Registered Company Name 2. Mailing Address of Head Office (in Alberta) 3. Mailing Address of Applicable Plant or Regional Office 4. Phone and Telecopier Numbers 5. Date 6. Name(s) of contact(s) for this application (specify primary contact and secondary contact, if any) 7. E-mail address for company contact Note: The EUB Application Common Page can be used to fulfil this information requirement. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 6 (b) The location, capacity and size of the activity to which the application relates: New/Renewal/Change Location: 1. Legal Land Description - LLD (i.e. LSD-Section-Township-Range-Meridian). Note: For heavy oil processing plants, include both central processing facilities and other lands that are applicable to land reclamation. 2. Relation to nearest town, city, village, and residents/users of the land. 3. Geographical description of the surrounding topography (including a topographical map) and relation to nearby watercourses. Capacity (stated design, nominal): 4. Gas Processing Capacity (Raw), Hydrogen Sulphide Processing Capacity, Sulphur Inlet Rate. 5. Sulphur Production Capacity, Liquid Hydrocarbon Production, Sulphur Storage Status, Bitumen Processing Capacity, Other. 6. Material Balance. Size: 7. Descriptive size of the affected area, leased area, and/or plant site (i.e. hectares), or 8. Physical dimensions of the plant site including a plant site map (i.e. plot plan) and number of employees working at the facility. (c) The nature of the activity, the change to the activity or the amendment, addition or deletion, as the case may be: New Plants 1.1 Classification of this facility under EPEA Activities Designation Regulation 211/96. 1.2 General Purpose, Products, By-products (i.e. Gas Compression and/or Processing, Sulphur production/storage, Condensate storage, etc.). 1.3 Major Unit Operations including a process flow diagram and description of the process. (i.e. Amine or Scavenger Sweetening (include type of sweetening agent used), Cooling Towers, Steam Boilers, Compression, Sulphur Prilling, etc.). 1.4 Major Environmental Control Operations including size and location of any pits/ponds, pond contents, pond liners (include type and thickness of each liner), landfills or other waste management facilities (i.e. sludge ponds), discharge details, engineering drawings for these structures (i.e. Runoff control, Overall Wastewater Disposal, Claus Sulphur Recovery, Sulphur Degassing, Sulphur Storage, Vapour Recovery, etc). As-built plans and liner details for ponds, landfills, and other waste management facilities will also be required. 1.5 For all underground and aboveground tanks, specify: (i) tank locations; (ii) type of service (i.e. produced water); (iii) capacity (in m3); (iv) material type; (v) type of corrosion protection; (vi) type of secondary containment; and (vii) method of leak detection; Note: Tabular presentation of data would be appropriate. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 7 For underground storage tanks, please specify: (i) Measures incorporated to prevent overfilling of tanks (i.e. Automatic shut-off devices, high level alarms); and (ii) summarize results of integrity testing and inspections. See Attachment E. 1.6 For any new above ground storage tanks, describe the leak detection system that will be incorporated between the base of the tank and the underlying liner. 1.7 Water Considerations (i) Source of potable water and a description of any water treatment system used (i.e. chlorination, filtration, softening, etc.). If groundwater wells are used, provide location and depths of wells, analytical data (before and after treatment), and copies of Water Act licences for those wells. Refer to Potable Water Regulation 122/93 with amendments up to an including Alberta Regulation 214/96. (ii) Sanitary Sewage Handling procedures. If a septic/holding tank is used, specify capacity and material type of the underground tank. In addition, specify what approved municipal facility the domestic wastewater or sludge is taken to for disposal. 1.8 Details on the reciprocating or turbine engines: (i) make and model number; (ii) rated power (kilowatts); (iii) exhaust stack diameter (metres); (iv) exhaust stack height above grade (metres); (v) exhaust gas temperature (°C); (vi) exhaust gas velocity (m/s); and (vii) emission rate of the oxides of nitrogen (grams of NOx)/(kW-hr); (viii) does the engine meet the low NOx emission requirement and by what method. Note: Tabular presentation of these data would be appropriate. 1.9 A copy of the plot plan showing the exhaust stack locations and distance between each stack. 1.10 The peak height of the compressor building in metres. 1.11 Details on all natural gas fired heaters, treaters, boilers, and steam generators: (i) rated power (kilowatts); (ii) exhaust stack height (metres); (iii) exhaust stack diameter (metres); (iv) peak height of buildings (metres), if applicable; and (v) does the heater or boiler meet the low NOx emission requirement. Note: Tabular presentation of these data would be appropriate. 1.12 Details on any auxiliary or standby process equipment or other sources of emission. 1.13 Details on flare stacks: (i) height (metres); (ii) diameter (metres); and (iii) igniter. Note: Tabular presentation of these data would be appropriate. 1.14 Details on any active flare pit on site including: (i) under what condition is it used; (ii) type and/or present condition of liner; and (iii) how often it is used and what goes into the pit. Details on any inactive or former flare pits on site including: (i) size of flare pit; (ii) description of previous or planned remediation activities; and (iii) confirmatory soil and groundwater sample results (if applicable). APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 8 1.15 Description of any on site incineration of solid waste and any approvals received for the disposal practice. 1.16 Provide both a computer input and output run (using an acceptable program) for NO2 dispersion modelling to show maximum ground level concentration (MGLC) will not be exceeded (when all continuous point sources are in operation). 1.17 For a sour gas processing plant (continuous acid gas flaring or sulphur recovery process units with tail gas incinerators, acid gas reinjection plants) and heavy oil processing plants: (i) provide both a computer input and output run (using an acceptable program) for SO2 dispersion modelling (flaring) to show MGLC will not be exceeded (when all continuous point sources are in operation); and (ii) rates and composition of acid gas and fuel gas flared streams. 1.18 Emergency flaring scenario: (i) provide both a computer input and output run (using an acceptable program) for SO2 dispersion modelling to show MGLC and an explanation on how emergency flaring will be minimized; and (ii) rates and composition of flared streams (i.e. inlet stream, acid gas before sulphur recovery unit, acid gas after sulphur recovery unit, acid gas when reinjection is not occurring). Note: For 1.16, 1.17 and 1.18, refer to the Air Quality Model Guidelines (listed in References, pg 23). 1.19 Sulphur Storage Facilities (specify amounts stored and in what form, type and thickness of each liner used, how sulphur dusting is minimized, how runoff water is being handled, etc). 1.20 Describe how benzene emissions from glycol dehydrators are being controlled. 1.21 For heavy oil processing plants, volume of produced gas, concentration of H2S in produced gas and method of disposal. Renewal Applications 2.1 Same as for new plants. (Note: Tiered SO2 emission targets may be applied if plants are operating significantly below design sulphur inlet rates - see attached fact sheet.) Applications for Activity Change or an Amendment 3.1 Describe the change(s) (i.e. once through cooling water replaced with cooling towers, addition of a reciprocating engine to increase compression, etc.). 3.2 Describe the affect that the change(s) may have on the environment. 3.3 Describe the affect that the change(s) may have on the Environmental Control systems. 3.4 Describe the implications, which the change(s) may have on the current approval. 3.5 Describe when the changes will take place. (d) Where the application requires an approval from the Alberta Energy & Utilities Board or the Natural Resources Conservation Board in relation to the activity, the date of the written decision in respect of the application: APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 9 New/Renewal/Change Provide: 1. Date of EUB Approval (if approval has been issued - if no approval has been issued then indicate when an approval/decision is expected). 2. EUB Approval Number. (e) An indication of whether an environmental impact assessment (EIA) report has been required: New/Renewal/Change 1. Was an EIA required? 2. Was a report prepared? 3. Date of final submitted EIA report to AENV that was accepted by the Director. (f) Copies of existing approvals that were issued to the applicant in respect of the activity under this Act or a predecessor of this Act: New Plants 1. Not Applicable Renewal/Change 2. Attach copies of applicable existing approvals (i.e. if this is a renewal application, please include a copy of the previous approval which is due to expire as part of the application). (g) The proposed or actual dates for construction commencement, construction completion, and commencement of operation: New Plants 1. Provide proposed dates for the above. Renewal Applications 2. Provide actual date for original commencement of operation. Applications for Activity Change or an Amendment 3.1 Provide actual date for original commencement of operation. 3.2 Provide proposed effective date for "Activity Change" and/or Amendment. Note: If timing of an approval or amendment is crucial, please provide explanation. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 10 (h) A list of substances, the sources of the substances and the amount of each substance that will be released into the environment as a result of the activity, the change to the activity or the amendment, addition or deletion, as the case may be, the method by which the substances will be released and the steps taken to reduce the amount of the substances released: New Plants 1.1 A list and quantity of substances used in the production process in terms of a typical operating day. 1.2 Describe the water demand in terms of the sources, purpose (specific operation) and quantities. 1.3 Describe the sources of the substance(s) to be released to the environment. 1.4 Describe the amount of the substance(s) to be released to the environment. 1.5 Describe the methods of release. 1.6 Describe the pollution prevention and control measures that are part of plant design and operation including groundwater and soil protection measures (see attached fact sheets). 1.7 For all plants, determine the industrial runoff volume for the plant developed area. Refer to Attachment B for determination of industrial runoff drainage system design. 1.8 Spill Containment. Process areas such as dehydrator building, refrigeration building, new reciprocating or turbine compressors and amine skids require built in secondary containment for containment of spills. This is accomplished by constructing skids with a built in sub floor “bathtub” type structure or by sloping and sealing the floor and curbing the perimeter with a minimum 75 mm curb (including across doorways). For reciprocating or turbine compressor buildings, AENV will accept spill containment constructed around the specific areas of spills or leaks. Describe how this will be achieved for this gas plant. Liquid load out and off-loading areas require spill collection devices as a minimum around the hose connection point. This type of device will help ensure the protection of soil and groundwater quality and will lessen cleanup costs. For load-out areas that are very frequently used (i.e. daily or in sensitive areas) containment for truck tank overflow would be required. With respect to liquid off-loading or load-out areas, AENV is requesting that the spill collection devices include the following features: • A lid to keep rain, snow or other materials out of the spill collection device. This will help to prevent unnecessary contamination of rainwater and lessen the risk of the spill collection device overfilling with rainwater or other liquids. • The device should be elevated above the ground level in order to prevent rust and to allow for easy inspection of its integrity. • A device or method to recover any spilled liquids. Some spill collection devices have a built in suction tube that is used to recover any spilled liquid by transfer into the off- loading truck. Provide a list of all the load-out areas and a description or of how the above will be achieved. Renewal Applications 2.1 Same as for new plants. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 11 Applications for Activity Change or an Amendment 3.1 Provide a description of current substance releases. 3.2 Describe the implications to the above description as a result of the Activity Change. 3.3 Provide the final modified description that will result after the Activity Change is operational. (i) A summary of the environmental monitoring information gathered during the previous approval period: New Plants 1.1 Any baseline ambient environmental data that may have been collected at the site (for air, water, soils, etc.). 1.2 Baseline hydrogeologic characteristics and groundwater monitoring data (information requirements outlined in Attachment C). Renewal Applications 2.1 Describe the ambient monitoring requirements of the previous approval (i.e. EPEA 999-00-00), listing the parameters required and their frequency and sampling requirements. 2.2 Briefly describe the results of the environmental monitoring information compiled under the previous approval (use statements, tables, graphs, etc.) in summary form. 2.3 Hydrogeologic characteristics and groundwater monitoring data (information requirements outlined in Attachment C). 2.4 Summarize the results of any additional monitoring conducted at the site (groundwater remediation programs, industrial runoff, soil monitoring, etc.) Applications for Activity Change or an Amendment 3. Only monitoring information on the affected parameters is required. (j) A summary of the performance of substance release control systems used for the activity during the previous approval period: New Plants 1. Not Applicable. Renewal Applications 2.1 Relate the environmental control systems (source/in-plant control) performance to: (i) approval limits; (ii) activity guidelines; (iii) industrial performance; and (iv) ambient air quality guidelines. Note: Increase in sulphur recovery efficiency from 90% to 95%, only SO2 emission information would be required. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 12 2.2 Present monitoring data using tables, charts with simple statistics which will provide durations and frequencies of non-median events. 2.3 Describe present condition of pond liners, sulphur basepad liners, runoff collection ditches, waste storage areas, berms/dykes and other containment structures. 2.4 Briefly outline any operational incidents (i.e. shutdown period, power failure), that affected the performance of substance release control systems. Applications for Activity Change or an Amendment 3. Present the same information, as required above for Renewals, however, limit it to only those environmental control systems affected by the Activity Change. (k) The justification for the release of substances into the environment as a result of the activity, the change to the activity or the amendment, addition or deletion, as the case may be: New Plants 1. Discuss the application of process technology, management practices and current environmental control technology/control systems in the context of: (i) Alternate commercially available technologies available; (ii) Industry Guidelines and Standards; (iii) Similar typical environmental approvals (either locally or in other jurisdictions); (iv) Potential environmental impacts; (v) Unique situations due to plant location, size or capacity; and (vi) Ambient air quality guidelines or standards. Renewal Applications 2. Not Applicable. Applications for Activity Change or an Amendment 3. Same as for new plants except the discussion should be limited to only those items which will be affected by the Activity change. (l) The measures that will be implemented to minimize the amount of waste produced, including a list of the wastes that will or may be produced, the quantities and the method of final disposition of them: New Plants 1.1 Complete the Waste Management Summary (in Attachment A). 1.2 Describe any waste minimization measures to be implemented. Renewal Applications 2.1 Complete the Waste Management Summary (in Attachment A). 2.2 Describe any waste minimization measures implemented. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 13 Applications for Activity Change or an Amendment 3. Discuss the environmental aspects of the present approval which will be affected by the change(s). (m) Any impact, including surface disturbance, that may or will result from the activity, the change to the activity or the amendment addition or deletion, as the case may be: New Plants 1. Limit discussion to the extent and nature of the surface disturbance which is proposed by construction, other impacts should be identified in the other relevant areas of this application form such as section (k). Renewal Applications 2. Same as new plants. Applications for Activity Change or an Amendment 3.1 Same as new plants. 3.2 Describe the change to surface disturbance both temporary and permanent caused by the "Activity Change". (n) Confirmation that any emergency response plans that are required to be filed with the local authority of the municipality in which the activity is or is to be carried on or with Alberta Public Safety Services have been so filed: New Plants 1. Emergency Response plans related to the disaster plans prepared in accordance with the requirements of the EUB. Provide the following information: (i) statement of confirmation; and (ii) agencies to which the plan has been submitted (i.e. Municipalities, EUB). Renewal Applications 2. Same as new plants. Applications for Activity Change or an Amendment 3. Provide only if there is a change in plant status (i.e. convert from a sweet gas to a sour gas processing plant) that necessitates a change. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 14 (o) Confirmation that there are contingency plans in place to deal with any unexpected sudden or gradual releases of substances to the environment; Environmental contingency plans are descriptive procedures to deal with abnormal occurrences which have the potential of negatively affecting expected environmental performance. These occurrences need not be environmental emergencies, result in adverse impacts or even result in contravention of approval limitations; but rather may be occurrences which potentially result in significant variations to the normal environmental expectations described in applications for approvals. (p) The conservation and reclamation plan for the activity; New Plants 1.1 Aesthetics - Discuss the potential impact of the project on landscape aesthetics and outline the plans to minimize such impact. 1.2 Topsoil Conservation: (i) The quality and quantity of topsoil to be utilized after construction for landscaping and reclamation purposes. (ii) The quality and quantity of topsoil to be saved and stored for the purpose of reclamation of the site after decommissioning and abandonment of the plant. (iii) Areas where topsoil is to be salvaged should be indicated along with general total volumes. (iv) Discuss the storage of topsoil either for present use such as improving berming or landscaping, or for future use after the life of the plant. 1.3 Discuss conceptual plant decommissioning process, including plant abandonment and reclamation. Renewal Applications 2.1 Describe any conservation activities, if any, which were practised during construction. 2.2 Answer questions 1.2 and 1.3 under new plants. 2.3 Describe reclamation status of previously used flare pits, landfills, process wastewater ponds, burn pits, and sulphur blocks. Applications for Activity Change or an Amendment 3.1 Describe any topsoil conservation plans for any areas affected by the change, if applicable. 3.2 A plan to prevent, remove or treat areas of contamination to within established guidelines (Environmental Sciences Division of AENV). (q) A description of the public consultation undertaken or proposed by the applicant; New Plants 1.1 Describe any proposed or conducted public involvement process. 1.2 Briefly describe the target audiences, frequency, type and purpose for the public involvement and any environmental concerns identified in the review and how those concerns were addressed. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 15 1.3 Please provide names of newspapers for advertising the application/approval. The newspapers should encompass all private citizens that may be directly affected by the activity. For citizens isolated from newspapers, please recommend how notification can best be provided. Renewal Applications 2. Same as new plants. Applications for Activity Change or an Amendment 3. Same as new plants. Note: As a matter of policy, the Director has deemed that all new plants, approval renewals changes to activities will be considered non-routine, unless there are extenuating circumstances which must be described in the application. (r) Information required under any other regulation under the Act to be submitted as part of or in support of the application: (s) Any other information required by the Director, including information that is addressed in a standard or guideline in respect of the activity that is published or adopted by the Department. (Note: The applicant should contact the Department to determine what, if any, information might be required under this Section.) Other Sections of the Regulation that are relevant to the application/approval process are as follows: 3(2) The Director may waive any of the requirements of subsection (1)(a) to (q) if the Director is satisfied that a requirement is not relevant to a particular application or that it is appropriate for other reasons to waive the requirement. 4(1) The Director shall not review an application for the purpose of making a decision until it is a complete application. 4(2) Where the application is not complete, the Director shall notify the applicant in writing and request the information necessary to make the application complete. 4(3) Where the information is not supplied by the applicant within a reasonable time, the Director may reject the application and shall forthwith advise the applicant in writing of that fact. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 16 ATTACHMENT A FOR GAS PLANTS COMPLETE APPLICATION REQUIREMENTS Please complete the following chart (indicate NE where a particular waste is never encountered). ESTIMATED STORAGE METHOD AND PRECISE DISPOSAL METHOD AND WASTE AMOUNT LOCATION(S) LOCATION(S) LIQUID surface runoff water boiler blowdown water cooling water blowdown steam condensate water treatment wastewater vessel drains produced water floor wash equipment wash vent/flare liquids filter backwash sanitary sewage engine oil compressor lube oil laboratory wastes amine glycol methanol other sweeteners other chemicals heat medium other turnaround wastes Other SLUDGES tank bottoms APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 17 ESTIMATED STORAGE METHOD AND PRECISE DISPOSAL METHOD AND WASTE AMOUNT LOCATION(S) LOCATION(S) reclaimer bottoms pond bottoms septic tank cooling tower API separator diatomaceous earth other SOLID domestic garbage carbon filters sock filters cartridge filters construction material catalyst desiccant iron sponge or other spill debris drums (> 20 L) capacitors ion exchange resin asbestos incinerator ash other OTHER waste received from off-site drum wash pond skimming pigging waste APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 18 ESTIMATED STORAGE METHOD AND PRECISE DISPOSAL METHOD AND WASTE AMOUNT LOCATION(S) LOCATION(S) dirty sulphur sulphur contaminated soil sulphur remelt waste transformer oil contaminated soil Other APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 19 ATTACHMENT B INDUSTRIAL RUNOFF AND SURFACE RUNOFF DRAINAGE SYSTEM 1. Topographic map(s) shall be submitted, showing the following: a) plant site with major facilities, b) any off-site areas contributing storm water runoff to the site surface drainage system, c) facilities provided for the collection, segregation, treatment and discharge of storm water runoff from the various areas of the site and off-site, and d) facilities to prevent or minimize runoff originating from off the site from flowing across the plant developed area. Note: The topographic map(s) should identify any proposed contour changes to the natural topography. 2. Describe the storm runoff according to the following: a) runoff volume from a one-in-ten year storm of 24-hour duration, based on the applicable rainfall data for the area (m3), and b) peak runoff from a one-in-ten year storm at point of discharge to a treatment facility (m3/s). Note: The Rational Formula can be used to estimate the runoff flow (please show calculations). Rainfall data is available from Environment Canada. Rational Formula: Q = CIA where Q = runoff flow (m3/s) C = rainfall coefficient (see Tables 1 and 2 for a guide) I = rainfall intensity (m/s) A = contributing area (m2) 3. Describe the storm water facilities according to the following: a) design (volume, lining, etc.) of storm water treatment or retention facilities (attach drawings), b) safety factors used in sizing the above facility, c) procedures used to minimize the contamination of storm water, and d) describe the route of surface runoff released from the site and its receiving environment. 4. Indicate the location of the nearest watercourses and describe the route of travel of any releases of industrial runoff/surface runoff from the site. The following information should be noted: APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 20 a) With respect to surface runoff management, Alberta Environment now requires that new gas plants will incorporate one of the following surface runoff management plans into the design and operation of the facility. Note that if the plant is in proximity to drainage courses/ravines that lead to a watercourse, a full runoff containment pond will be required. The operator shall take into account the site topography, soil permeability, rainfall statistics, concerns of adjacent land owners, proximity to nearby water courses, and potential sources of contamination at the site when choosing which management plant to implement. b) The operator shall control surface runoff from the plant developed area using ditching or berms so that industrial runoff is only released from the site at points where there are facilities or site features for the containment facilities include culverts with valves or small pits for the containment and recovery of any spills. The site shall be graded to minimize erosion and flooding. c) The operator shall install and operate an industrial runoff pond, for collection of surface runoff from the plant-developed area. The pond shall have, at minimum, a clay liner or re- compaction of in-situ clay with a hydraulic conductivity no greater than 1 x 10-7 cm/s. The pond shall be designed to manage the rainfall resulting from a 1 in 10 year 24-hour rainfall. The pond management shall incorporate facilities or procedures to separate floatables such as oil. For the gas plant or heavy oil processing plant describe in detail the method that will be used and the rationale for the method that has been chosen. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 21 Table 1: Runoff Coefficients for Urban Areas RUNOFF DESCRIPTION OF AREA COEFFICIENT (C) Flat, residential (about 30% of area impervious) 0.40 Moderately steep, residential (about 50% of area impervious) 0.65 Moderately steep, built up (about 70% of area impervious) 0.80 Table 2: Deductions from Unity to Obtain the Runoff Coefficient for Rural Areas DEDUCTION FROM TYPE OF AREA UNITY Topography Flat land (average slopes of 1 ft. to 3 ft. per mi.) 0.30 ) Rolling land (average slopes of 15 ft. to 20 ft. per mi.) 0.20 ) a Hilly land (average slopes of 150 ft. to 250 ft. per mi.) 0.10 ) Soil Tight impervious clay 0.10 ) Medium combinations of clay and loam 0.20 ) b Open sandy loam 0.40 ) Cover 0.10 ) Cultivated lands 0.20 ) d Woodland Notes: The value of C for rural areas is obtained by subtracting the sum of the three factors (topography, soil and cover) from unity, that is: C = 1 - (a + b + d) Additional information can be obtained from Gray, M. 1970. Handbook on the principles of hydrology. Water Information Centre, Inc. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 22 ATTACHMENT C HYDROGEOLOGIC AND GROUNDWATER MONITORING Groundwater Monitoring Programs for the plant shall include, but is not limited to, the following information: (a) a hydrogeologic description and interpretation of the plant; (b) a map and description of surface water drainage patterns for the plant; (c) a lithologic description and maps, including cross-sections, of the surficial and the upper bedrock geologic materials at the plant; (d) maps showing depth to water table, patterns of groundwater movement and hydraulic gradients at the plant; (e) the hydraulic conductivity of all surficial and bedrock materials at the plant; (f) a map showing the location of existing and additional proposed groundwater monitor wells at the plant; (g) lithologs of all boreholes drilled at the plant; (h) construction details of existing groundwater monitor wells; (i) a rationale for proposed groundwater monitor well locations and proposed completion depths of those wells; (j) a description of groundwater monitor well development protocols; (k) a list of parameters to be monitored and the monitoring frequency for each groundwater monitor well or group of groundwater monitor wells at the plant; (l) a description of the groundwater sampling and analytical QA/QC procedures; (m) details of a groundwater response plan specifying actions to be taken should contaminants be identified through the Groundwater Monitoring Program; and (n) any other information relevant to groundwater quality at the plant. NOTE: This information is not required if the approval holder has submitted a similar report within the last ten years. When an existing system is upgraded, the new data obtained from the system upgrade can be included with their next annual report. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 23 ATTACHMENT D APPLICATION FOR APPROVAL OF A LANDFILL SECTION ONE: GENERAL INFORMATION 1.1 Date of application. 1.2 Name, address and phone number of applicant. 1.3 Name, address and phone number of owner/operator. 1.4 Legal land description of disposal site. 1.5 Current land use and zoning. 1.6 Indicate whether application is for; (a) an approval to construct, or (b) an approval to operate. 1.7 Provide a summary of the project. 1.8 Duration of the project. SECTION TWO: GEOGRAPHICAL FEATURES 2.1 Provide scale diagrams of the industrial landfill site and surrounding area. These diagrams shall include: (a) topography of the area; (b) landfill boundaries, buffer zones, and land use of the area; and (c) location of all water bodies and water supply wells within a 500 m radius of the site. SECTION THREE: GEOLOGICAL CHARACTERISTICS 3.1 The description of the surficial and bedrock geology shall include: (a) classification, hydraulic conductivity, and liquid absorption capacity of the soil; and (b) lithologic description and hydraulic characteristics of the geologic formations to a depth of at least 15 m below ground surface. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 24 SECTION FOUR: HYDROGEOLOGICAL CHARACTERISTICS 4.1 The following information shall be included in the description of the local hydrogeology: (a) water table level; (b) groundwater flow directions and rates; (c) background quality of groundwater in the upper water-bearing strata within the expected zone of influence; and (d) present groundwater uses which could be affected. SECTION FIVE: DESIGN CONSIDERATIONS 5.1 Provide a description of types, characteristics and quantities of waste as well as details on the industrial landfill design including the following: (a) production rate of each waste stream; (b) physical and chemical characteristics of each waste stream; (c) description of disposal methods; (d) detailed landfill design; (e) physical and chemical properties of liners, and intermediate or final covers; and (f) potential of materials described in (e) to retard movement and/or provide neutralization of waste components. SECTION SIX: MONITORING SYSTEM 6.1 Provide a full description of the groundwater monitoring system for the industrial landfill including the following: (a) the proposed number and location of groundwater observation wells (as a minimum, one well hydraulically upgradient of the site and two wells downgradient are required); and (b) details on the completion of observation wells (depth, screening interval, construction material, casing and annular seals). SECTION SEVEN: CLOSURE AND RECLAMATION 7.1 Provide a discussion regarding closure procedures, reclamation of the site, and the planned end use of the land. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 25 SECTION EIGHT: LOCAL AUTHORITY APPROVAL 8.1 Provide a copy of development permit, if applicable. SECTION NINE: ADDITIONAL INFORMATION 9.1 This application is submitted in accordance with the Alberta Environmental Protection and Enhancement Act. 9.2 An application for an Approval shall not be deemed to be complete until all the information, documents and authorizations referenced in the application form have been received. (Date) (Signature) (Title of Signature) NOTE: The application MUST be signed by the owner or his agent. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 26 ATTACHMENT E STORAGE TANKS Size of Tank Fugitive Emission Maximum True Control Description of Contents Vapour Type of Identification No. Dia. Vol. Type of Tank (Vapour Recovery Others Tank Stored Pressure of - Vents (m) (m3) System) Contents Yes No APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 27 REFERENCES Canadian Council of Resource and Canadian Water Quality Guidelines, March, 1987 Environment Ministers Canadian Council of Ministers of the § National Emission Guidelines for Stationary Combustion Environment Turbines, December, 1992 – “CCME-EPC/AITG-49E § National Emission Guidelines for Commercial/Industrial Boilers and Heaters, March 1998 – PN1286 Environment Canada Atmospheric Rainfall Frequency Atlas for Canada, 1985 Environment Service Health and Welfare Canada Guidelines for Canadian Drinking Water Quality, 1989 Alberta Environment § Air Quality Model Guidelines, April 1999 § Emergency/Process Upset Flaring Management: Modelling Guidance Alberta Environment Code of Practice - Compressor and Pumping Stations and Sweet Gas Plant Processing Plants Environment Canada Standard Methods for the Examination of Water and Wastewater published jointly by the American Public Health Association, American Water Works Association, and the Water Environment Federation (latest edition). Canadian Society of Soil Science Manual on Soil Sampling and Methods of Analysis, published by the Canadian Society of Soil Science. USEPA Test Methods for Evaluating Solid Waste, USEPA SW-846 ID 99-6 EUB Guide-60: Upstream Petroleum Industry Flaring Requirements IL 84-11 Approval, Monitoring, and Control of Sulphur Storage Sites IL 86-2 Criteria for the Exemption of Sweet Gas Processing Plants from Approval Requirements Under the Clean Air and the Clean Water Act IL 88-5 Application for Approval of Natural-Gas-Driven Compressors IL 88-13 Sulphur Recovery Guidelines - Gas Processing Operations GB 92-4 Requirements for Sulphur Storage Facilities CAPP § Best Management Practices for the Control of Benzene Emissions from Glycol Dehydrators, November 1997 § Managing Human Exposure to Benzene in the Upstream Oil & Gas Industry – November 1997 APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 28 FACT SHEET - TIERED SO2 EMISSION TARGETS FOR SOUR GAS PLANTS Alberta Environment, in cooperation with CAPP and certain CAPP members, has developed a new approval approach related to SO2 emissions from sour gas plants. This new approach was developed specifically for plants that are operating significantly below design inlet sulphur rates. The purpose of this new approach is to establish SO2 emission "targets" that better reflect the actual operating conditions of facilities. The new approach makes the Environmental Protection and Enhancement Act approvals more defensible from an environmental protection standpoint and provides companies with "operational" SO2 emission targets that reflect good operation. The new approach can be summarized as follows: ! for facilities operating at less than approximately 75%-60% of their design inlet sulphur rate, tiered SO2 emission targets are established ! the number of tiers and the range for each tier depends on the size of the facility with larger facilities having more tiers (normal range is from 3 to 8 tiers) ! a tier is an inlet sulphur range e.g. 100 to 200 tonnes/day of sulphur ! for each tier a daily and hourly SO2 emission target is established along with a frequency of achievement goal for this target (the frequency of achievement goal is based on hourly and daily measured SO2 emissions) ! if the achievement goal is not met then the company must explain why it wasn't met and, if necessary, outline the actions that will be taken to ensure that the goal is achieved in the future ! non-achievement of the goal is not an offence but if the company does not undertake the necessary follow-up then this is an offence ! the compliance limit for SO2 emissions remains the hourly and/or daily limit based on the design inlet sulphur rate and the EUB sulphur recovery limit. This approach is being implemented as existing operating approvals are renewed. Alberta Environment believes that establishing operating SO2 emission targets for plants operating well below design sulphur inlet rates provides a clear demonstration to the public that the Department and industry are committed to minimizing SO2 emissions and also shows a commitment to continuous environmental improvement. If you would like more detailed information on the tiered SO2 emission targets, please contact: Randy M. Dobko, P. Eng. Senior Engineer Industrial Program Development Branch Environmental Sciences Division 4th Floor, Oxbridge Place 9820 - 106 Street Edmonton, Alberta T5K 2J6 Tel: (780) 427-6869 APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 29 FACT SHEET - GROUNDWATER MONITORING Rationale for Groundwater Monitoring Requirements Groundwater monitoring and reporting requirements are included with approvals issued to industrial facilities that have a recognized potential to contaminate the local groundwater system. Their primary objectives are to identify, evaluate, and ensure the effective mitigation of substances that adversely effect groundwater quality. The approval requirements are intended to be flexible and to adjust to changing site conditions, management practices, risk reduction efforts, remediation programs and past operating practices at each facility. Gas processing facilities have a wide spectrum of processes and activities that could contribute to groundwater contamination. Major contaminants currently recognized includes free hydrocarbon products (predominantly condensates), dissolved organics (predominantly organics of the C6-C30 range), major ions, metals, amines, glycols, and various other chemicals used in gas sweetening or general plant operation and maintenance activities. Groundwater monitoring at these facilities focuses on pits, ponds, landfills, sulphur blocks, sewage lagoons and chemical processing and handling areas where leaks, spills or other releases of contaminants could occur. The program targets contaminants that are likely to create an adverse impact on the groundwater system immediately adjacent to the gas processing facility. Where contamination has or is suspected to include deeper aquifers, these zones are also included in the facility's monitoring program. Groundwater Monitoring Program The groundwater monitoring program is designed to include the following key functions: $ identification of all potential contaminant sources; $ characterization of the local hydrogeologic system; $ development and implementation of a monitor well network and a sampling program; $ data interpretation and annual reporting; and $ as necessary, development and implementation of a groundwater management plan. When the groundwater monitoring program identifies contaminants of concern at concentrations exceeding acceptable background levels, a groundwater management plan will be required. This plan is expected to include details on actions that will be taken to remove the source of contamination, treat or contain the contaminated groundwater, and a schedule for implementation and reporting on the progress and effectiveness of these actions. Remediation objectives may be based on national criteria or on site specific, risk-based objectives developed by the facility operators in conjunction with Alberta Environment. If more detailed information is required, please contact the Industrial Program Development Branch at (780) 427-5883. APPLICATIONS FOR SOUR GAS AND HEAVY OIL PROCESSING PLANTS - A GUIDE TO CONTENT PAGE 30 FACT SHEET - SOIL MONITORING Rationale The main objective of soil monitoring is to assess, prevent, and mitigate contamination by substances with the potential to exert an adverse effect on soil and interconnected media. As such, soil monitoring targets contaminants that: are toxic, mobile, or exert adverse effects on soil properties. Soil monitoring is directed primarily to the assessment of contaminants that have been released to the soil surface. However, where soil contamination is known or suspected to originate from subsurface sources such as underground tanks or pipes, an assessment will be required. The soil monitoring program was developed to address the problem of contamination of the soil resource at high risk, approved facilities. Such facilities include many sour gas plants, particularly those which recover sulphur. In addition, soil sampling may be required to establish baseline conditions for significant expansions or new plants. Facilities or portions of facilities may be exempted from soil monitoring requirements where the risk of soil contamination is minimal because of the kind of operation, or because engineered controls are in place to protect soil. Soil Monitoring Program Soil monitoring comprises the following general steps submitting a soil monitoring proposal; executing the soil monitoring plan as authorized by the Director; and interpreting and reporting the results of the soil monitoring. Soil Management Program In cases where soil monitoring reveals contamination in excess of limits specified in the approval, a soil management program will be needed. A management program consists of submitting a proposal, implementing the plan as authorized, and providing periodic progress reports. The program addresses the following, as necessary: 1. source control to stop on-going contaminant releases; 2. further assessment and delineation of the contaminated area; 3. adoption of remediation objectives as authorized by the Director; 4. choice of appropriate treatment, containment, or disposal technologies; and 5. confirmatory sampling to verify removal of contaminants to target levels. Remediation objectives are based on generic guidelines or a site-specific risk assessment. Generic guidelines are numerical concentration limits that are set or accepted by Alberta Environment. Risk-based objectives are developed by the proponent for a specific site using risk assessment procedures. When applying or developing remediation objectives, land use is a fundamental consideration. Remediation objectives should be discussed with Regional Staff prior to program implementation. Current Status Soil monitoring is being phased in as existing approvals are renewed. Details on soil monitoring and remediation are provided in the approval clauses, and the documents: "Soil Monitoring Directive", and "Guideline for Monitoring and Management of Soil Contamination Under EPEA Approvals". For further information, please contact Regional Staff or the Industrial Program Development Branch at (780) 427-5883.
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