Alberta Notice of Landlord - Excel by yid44294

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          *Section 13.2 - Amend directive to require education about



          *Section 14.2.1 - Amend #4 to include notification of accidential


          *Section 14.2.8.1 - Amend #11 statement to include RHAs be given
          copy of air monitoring results
          *Section 14.2.8.2 - Amend statement to include RHAs on receiving
          information about the monitored HVP product



          *CHR's comments and criticisms are no different from those they
*The ERCBs policy decision to use 100 ppm for 60 minutes is
consistent with the advice given to the ERCB by AHW.
CHR seems to be concerned about population exposure to 100 ppm
3. Drilling into sour zones in two overlapping EPZs should not be permitted
Progress - Neil Merchant
1.   5.7 Plan Distribution:
Christine McCardle -
Enerplus
Calgary Health Region -
CHR
include topography to list of criteria.
Amend directive to require plan to reflect what is described in MEP.




Exercise Requirements (14.11) - amend directive to reflect new CSA Standard


Overlapping EPZs (14.14)- amend table 11 to require that RHA be notified.
Terry Dick - Transcanada
Comment

1) AHW agrees with Capital Health that it is reasonable for D-71 to identify the
process of ERP applications and reviews. It is suggested that the ERCB
outline the application process and what occurs after the pan is submitted to
them. This could be done via an appendix in the document or as a link within
the document so RHAs can familiarize themselves with the process.

2) AHW does not support Capital Health's request for a more comprehensive
risk and vulnerability assessments in relation to any sour gas operation. AHW
feels that the ERCBH2S software provides a sufficient risk management
process which adequately protects the public's health in the event of an
incident. In addition, ERCB policies around levels for voluntary and mandatory
evacuation provide additional public safety.

3) AHW will continue to work with the RHAs to ensure and improve
understanding of their roles during an ERP review process as well as during an
incident. Currently the Environmental Field Manual on Public Health and Oil &
Gas is being introduced to all RHAs which addresses many of these issues.
4) AHW is supportive of the following individual issues identifed by Capital
Health:
*Add definitions - licensee, MOH, RHA,
*Amend definition of a "public facility" to a "public place" in
accordance with the Public Health Act
*Add to the directive that a licensee is required to notify all

stakeholders when the plan is no longer need i.e. a mandatory recall notice
*Indicate or refer within the directive to other documents which
define the roles and responsibilities of the local municipality, ERCB, RHAs,
MOH specific duties as well as other agencies. Also, what occurs if one of
these agencies does not fulfill its role during an event.
*Section 4.3 - Table 4 needs to include that notification will go
to the landlord and the tenant of properties
*Section 5.8 - #16 - bullet 4 - amend statement to include that
the procedures used to provide information and update the media are done in
consultation with all stakeholders. This should be a coordinated message
between all parties (i.e. ERCB, AHW, RHA, AENV etc etc).
*Section 13.2 - Amend directive to require education about

emergency response procedures to take place annually to accomodate
changes in home ownership and/or land use development.
*Section 14.2.1 - Amend #4 to include notification of accidential
releases to local authority and RHA. Especially in circumstances where any
voluntary evacuation may occur.
*Section 14.2.8.1 - Amend #11 statement to include RHAs be given
copy of air monitoring results
*Section 14.2.8.2 - Amend statement to include RHAs on receiving
information about the monitored HVP product

Our response to the comments from Calgary Health Region can be
summarized in the following three points:
*CHR's comments and criticisms are no different from those they
have provided over the past 4 years. They present no new science or
arguments.
*The ERCBs policy decision to use 100 ppm for 60 minutes is
consistent with the advice given to the ERCB by AHW.
CHR seems to be concerned about population exposure to 100 ppm

for 60 minutes. However, this is not a scenario that would ever occur as there
are steps in place to limit exposure well before that level would be reached.

1) According to the ERCB, the health end-point is not only protective of
lethality, but also of unconsciousness. There is some merit to their criticism
that the methodology was arbitrary. The ERCB did a great deal of science and
came up with a health end point of 200 ppm for 60 minutes. When that was
presented to the Board, the Board decided to lower it to 100 ppm for 60
minutes. That is a policy choice of the ERCB Board. It does make the end point
even more conservative compared to what the science says is protective of
human lethality.
2) The 100 ppm for 60 min is not a significant departure and relaxation in
public safety as CHR states. The 100 ppm for 3 minutes referred to by CHR is
based on the old model for calculating EPZs which did not take into account a
number of factors. The new model (ERCBH2S) takes into account more inputs
that were not accounted for in the old model.
The USEPA AEGL method should not be used to calculate this endpoint
because of a fundamental flaw in the calculation of the uncertainty factor. The
AEGL method results in an effective uncertainly factor of over 20,000. This is a
continuing debate between AHW and CHR. However, AHW has the support of
Dr. Steve Hrudey and Dr. David Wilson regarding the faults of the AEGL
method.

3) The CHR claims that the effective uncertainty factor in the ERCB approach
is 6.6. However, they are applying the fundamental flaw of the AEGL approach
in that they have applied the n-value (3.5) to the uncertainty factor, which
results in the inflated uncertainty factors noted above.
4) A discussion of the health outcomes should a population be exposed to 100
ppm for 60 minutes is moot. Page 94 of Directive 71 states that approaching
10 ppm people will be advised whether to evacuate or shelter in place. This
means it is highly unlikely that anyone will be exposed to levels above 10 ppm
(tenfold below the health endpoint for calculating the EPZs). In addition, the
averaging time for the emergency evacuation guideline (the 10 ppm) is 3
minutes....significantly lower and more conservative than 60 minutes for the
calculation of the EPZs.

5) The graph is also moot. It must be repeated that these are not real exposure
scenarios. Again, the emergency evacuation guideline is 10 ppm.
The Hilderman et al. (2002) method of calculating toxic load was not rejected
at the EPA AEGL workshop in 2002.
At the 2004 public consultation, CHRs critique of the Hilderman et al.
approach was effectively refuted by Dr. David Wilson, one of the authors of the
Hilderman et al. approach.
6) The health endpoint presented in the ERCB document seems to be based
on appropriate science and a policy decision by the Board. There is no need to
adopt the health endpoints recommended by CHR.
7) No issues with this comment.

8) This comment is also OK and is similar to a comment made by Capital.
9) We disagree with this option. Once a level is set for voluntary evacuation, it
is no longer voluntary. In the current system (as outlined in section 4.2.1 of D-
71), a member of the public can evacuate should they feel they need to at any
concentration. This is a more conservative option from the point of view of
protecting public health.

1. The calculation of the EPZ perimeter must be based on an H2S end point of
10 ppm.
The criteria for calculating the EPZ perimeter appears to continue to be based
on an H2S exposure level of 100 ppm. This criteria is inadequate for the
protection of public health and safety, especially of sensitive individuals (e.g.
young children, seniors, pregnant women, persons with respiratory health
issues, persons susceptible to heart and stroke responses upon exposure to
toxic gas, people who have been previously exposed to H2S, etc.). An endpoint
of 10 ppm is already very high. It is the level of the exposure limit prescribed by
Occupational Health and Safety Regulations (Section 307(1)) and is meant to
be applied only to trained, screened, and tested healthy workers in an
occupational setting.




2. The regulations should include a minimum radius for all EPZs.

This is necessary to account for the risks associated with the activities that
occur at the well site, and to account for anomalous meteorological conditions.
                                     ‐                                 ‐

3. The ERCBH2S calculation of site specific EPZs must include site specific
topography as an input variable.                                    ‐

H2S gas is heavier than air, and will follow the general contours of low lying
topography under atmospheric pressures. The ERCBH2S model uses
thermodynamics, fluid dynamics, and atmospheric dispersion modeling to
determine possible dispersion scenarios, but is not required to include the
effects of topography. Topography is one of the main variables that will affect
dispersion, and must be included in order to provide a more accurate basis for
the calculation of the EPZ boundaries. The behavior of a sour gas release
along the Pembina River Valley on January 14th and 15th, 2007, reinforces the
importance that local topography may have in affecting the routing and limit
dispersion of both H2S and S02.


4. The criteria used to determine the perimeter of the Initial Isolation Zone (IIZ)
and the Protective Action Zone (PAZ) are absent from, and should be included,
in the Directive.
In the absence of specified criteria, determination of the boundaries of the IIZs
and PAZs will be left to the discretion of the operator. If the rationale for the
concept is to aid responders in protecting the public the delineation of IIZ
residences should not be recommended, but required. By not requiring proper
inclusion in the plan the result may lead to confusion and delay, and could
eliminate any value from the use of the concept. A minimum radius for the IIZ,
and a minimum width (angle) and downwind distance for the PAZ should be
specified, along with criteria to determine the size of these zones beyond the
minimum prescribed dimensions.
5. The entire IIZ and PAZ area must be included in the EPZ.

In the current draft, there is a possibility that the IIZ and PAZ may extend
beyond the perimeter of the EPZ (the PAZ extends beyond the EPZ perimeter
in Figure 2, page 47). However, operators are only required to consult with and
plan for the evacuation of residents within the EPZ. Therefore, there is a
possibility that people outside of the EPZ, who have not been consulted or
                                                 ‐
notified, will need to be evacuated. In this case the operator will have had no
opportunity to, or have been required to, pre plan for this operation.
6. The calculation criteria, evacuation criteria, evacuation priority and reasoning
for each of the IIZ, PAZ, EPZ and EAZ zones must be more clearly explained
in the Directive.

The information regarding IIZs, PAZs, EPZs and EAZs is not presented in a
clear and concise manner. We suggest that more information be provided and
that the information be presented and consolidated in one section of the Draft.
7. Multiple Pollutants must be quantified and considered in ERPs.

There is clear evidence that dangerous levels of other air pollutants beyond
H2S and SO2 are released during emergency venting and flaring incidents.
However, the Draft Directive remains focused on sour emissions, to the
exclusion any other well pollutants. Directive 71 should require operators to
quantify and plan for other toxic emissions (including, but not restricted to acid
gases, condensates, BTEX fraction, and carbon sulphides) in their ERPs.
8. H2S and SO2 exposure limits must be significantly reduced to reflect the
reality that other pollutants act synergistically alongside H2S and SO2 to
increase health effects at lower exposure levels.
Until accurate data is acquired to model the health effects of the other
pollutants the precautionary principle needs to be employed, and the interim
values for H2S and SO2 must be reduced to account for the effects of these
additional pollutants.
9. Volumes of condensate liquids (which convert to gas at standard pressure)
must be added to sour gas for calculating release rates for drilling and well
operating purposes, as well as for pipeline design, setback calculation, and
        ‐
EPZ calculation.
1. Non Resident Landowners that own land but do not reside within the
perimeter of the EPZ, and farmers who rent land but do not reside within the
EPZ, are directly affected and need to be included as full participants in the
consultation process for proposed development. PAPA Submission on
Directive 71 – January 31, 2008 Page 4 of 9
This is particularly important for farmers and ranchers who often spend a
greater portion of daylight hours on their land than in their residence.
Landowners who spend significant time on their land are at a higher risk than
residents in the case of a sour gas release because they are more difficult to
                                                 ‐ ‐
locate and evacuate. They are also less likely to be accessible by phone and
they are likely to have fewer viable sheltering in place options. The language
and requirements set out in Table 3 (page 19) and Table 4 (page 21) is
confusing and contradictory by first stating that “notification and consultation
with members of the public within the EPZ is required” and then indicating that
only certain members of the public have the right of notification and
consultation.
2. All members of the public within the EPZ must be afforded at least 72 hours
notice of the commencement of sour operations.
Many residents wish to be outside of the EPZ during sour operations for health
and safety reasons. To make alternate arrangements requires more than the
24 hours notice indicated in the Draft Directive.
PAPA has negotiated agreements with several operators in the Drayton Valley
area to provide at least 72 hours notice of sour operations commencement to
landowners. The ERCB should extend this existing commitment from operators
and incorporate it into Directive 71.
1. Full scale simulation exercises with full field mobilization must be required
                                              ‐
annually for each area system ERP.
The Draft Directive states that a major (full scale) exercise must be completed
once every three years for each system ERP. ERPs are not tested often
enough, especially considering the high rates of turnover in the industry, and in
the local municipal and regulatory agencies, and that large problems in the
enactment of the ERPs have been shown in actual emergency situations.
There are few other examples, when public or industrial safety is concerned,
where such a long lapse in practical field testing of a complex emergency
system is in existence.
2. ERPs must be „surprise‟ tested occasionally, without warning, and with
public involvement, to ensure that operator preparedness and response is
adequate.
                                             ‐
The testing regime proposed in the Draft Directive is inadequate to ensure
public safety. ERPs need to be tested in full scale exercises without advanced
    ‐
warning to adequately simulate a real emergency situation. Results from the
full scale simulations and surprise tests must be carefully evaluated by the
operator and the ERCB to improve emergency response.


3. An Administrative Exercise combined with a communication exercise must
be completed for every ERP.

The draft states that an administrative exercise combined with a
communication exercise must be held annually for each area ERP (except in a
year when a major exercise is held). The Administrative and Communications
exercise must be completed for every single ERP to ensure that the response
team has a proper understanding of the ERP, that all contacts are up to date
and correct and that sufficient resources and capacity are in place.
1. The ERPs should acknowledge and account for all other sour wells and
facilities already in place, as well as potential wells planned for a reasonable
period into the future.

2. Every ERP must contain a procedure for when a release is detected by or
reported to the operator, but appears to be from someone else‟s operations or
the cause is unknown. The procedure must contain steps to properly involve
and contact other area operators, the ERCB, and the public agencies, to
ensure an appropriate and coordinated response to the release.

3. Drilling into sour zones in two overlapping EPZs should not be permitted
The ERPs do not take into account or manage the overlapping emergency
response requirements and the potential impacts of multiple sour gas and oil
wells being drilled, as well as others simultaneously being serviced or in full
operation. For these reasons it is unsafe to allow for drilling into sour zones in
two overlapping EPZ to occur.
4. No resident should be included in the planning zone for more than three
wells for notification, drilling and completions, at any one time.

This recommendation addresses both hazard issues and the hassle to
landowners. There must be a maximum number of critical sour wells requiring
ERPs that a single resident can be subjected to (having to live with, and
participate in communication, consultation, awareness and readiness for
evacuation) at one time. Allowing a single resident to be in the planning zone
for more that three wells at once is highly stressful, potentially unsafe, and is
an unfair disturbance to the landowners‟ privacy and freedom. This is
particularly problematic in areas such as Drayton Valley, where there are plans
                                                                        ‐
to drill hundreds of sour wells in the next few years.
5. The ERCB needs to establish an easily accessible public clearing house and
information centre where residents can access information about sour
operations in their area.
    ‐
Information regarding the status of notification, approvals, site construction,
pre sour drilling, sour zone drilling, completions and active operations must be
included; as this information affects the various EPZs a resident may be in at
any point in time. This could be accomplished by maintaining a website with
this information, and having a telephone number that people who do not have
internet access can call to receive information.
1. More information must be included in Public Information Packages to ensure
that residents are aware of their rights as landowners, and about the project
that is being proposed. PAPA recommends that the following information be
required in all Public Information Packages:
a) An overview of the potential wells and facilities planned in the area for a
reasonable period into the future.
b) A description of the ERCB consultation and notification process explaining
the landowner rights to objection, representation, to have the safety of livestock
and pets addressed by the licensee and so on.
c) A description of the materials that the landowner has a right to request from
the company (ERP, drilling plan etc.)
2. The format of Public Information Packages needs to be standardized with
something like a required Table of Contents to assist members of the public
frequently subjected to the consultation process.
1. All ERPs must be drafted in a consistent logical format that ensures a high
standard of quality. All required items in the ERP must be included in a specific
order in a standard format, and bookmarked with labeled tabs.
The standardized format will help facilitate the use and navigation through
ERPs by the ERCB, public agencies, and by service personnel, as well as by
members of the public who are in the middle of a large number of EPZs. In the
event of an emergency, peoples‟ lives will depend on the ability of people to
access information quickly and to implement an ERP plan effectively and
efficiently.
2. All ERPs must contain a suitable number of assigned Rover Areas inside
both the EPZ and the EAZ.
The number of Rover Areas will depend on the size of the EPZ or EAZ, the
                                 ‐
population inside the zone, locations of sensitive individuals, topography, and
access and egress issues. Pre assigned Rover Areas are crucial for assisting
the involved government and safety PAPA Submission on Directive 71 –
January 31, 2008 Page 7 of 9
agencies in allocating required response actions, and for enabling a timely
response in the case of an emergency.
PAPA has successfully negotiated agreements with several operators in the
Drayton Valley area who have volunteered to include assigned Rover Areas in
their ERPs. The ERCB should extend this existing commitment from operators
and incorporate it into Directive 71.
3. Real person telephone callers, and not an automated system, must be used
to contact identified residents in the notification phase of any level of
emergency.

Automated telephone systems are a useful mechanism to provide notification
for some planned operations, however, they are not reliable enough to provide
notification to residents in an emergency, and cannot respond to questions
from those contacted. Real person telephone callers should be assigned
contacts in advance of sour operations, and asked to review their contact
information at ERP review meetings. An automated system may be used to
initiate notification as quickly as possible, but a personal caller must follow up
with each household. If a member of the public identifies in the initial
consultation phase that they do, or do not wish to be contacted by an
automated system or a personal caller this will of course be respected.
PAPA has negotiated agreements with several operators in the Drayton Valley
area who have volunteered to use real person telephone callers for notification
purposes. The ERCB should extend this existing commitment from operators
and incorporate it into Directive 71.                                           ‐
4. Legible information signs regarding drilling operations must be posted at
strategic access points on the perimeter of the EPZ, approximately seventy two
hours prior to commencing sour operations.

There are no current requirements for the posting of information signs on the
perimeter of EPZs for sour wells undergoing drilling operations. It is very
important that these signs be present to alert people passing through or
temporarily using an EPZ area that they are entering a sour production zone.
PAPA has negotiated agreements with several operators in the Drayton Valley
area who have volunteered to post sour drilling operations signs. The ERCB
should extend this existing commitment from operators and incorporate it into
Directive 71.
1. Early sour gas detection networks must be established in areas where there
are multiple sour gas well proposals.
There are no current requirements for area operators to provide an early
warning sour gas detection network in areas where there are multiple sour gas
well proposals. These systems are necessary to mitigate risks, and should be
applied on a provincial basis.
                                                            8
PAPA Submission on Directive 71 – January 31, 2008 Page ‐ of 9
Industry operators in the Drayton Valley area have committed to provide a
number of permanent monitors, and are working with a multi stakeholder
committee to establish and maintain a regional sour gas monitoring network.
The ERCB should extend this existing commitment from operators and
incorporate it into Directive 71.


With the new D71, ERCBH2S could give extremely small EPZs for slightly sour
wells. If these slightly sour wells with tiny EPZs were being drilled / worked over
and had an overlap with a larger Nisku EPZ would this count as overlapping
EPZs?
If a non-resident landowner inside the EPZ is to be notified, what form of
standing will they have?
For the 6 month “ERP Current” requirement, it makes sense when new
structures are built inside an EPZ. What about a renter moving in and another
renter moving out. Does the ERCB expect a company to track this type of thing
and update the ERP every 6 months?
For a local authority inside the PAZ but not in the EPZ, what form of standing
will the local authority have?
Can a Level One Emergency be called down by the company without any input
from the EUB, local authority or the local health region? Section 14.5.1 appears
to reflect this.

Flowchart Box 2 of Appendix 9 – Assessment and Ignition Criteria Flowchart
states that ignition must take place when “Although required, evacuation of the
response zones has not taken place”. Does the ERCB expect a company to
ignite if evacuation of the PAZ outside the EPZ has not taken place?
Page 20 Section 4.2 point 6) Personal consultations
The prescriptive reference to face-to-face consultation with the listed
government agencies and local authorities is difficult. We see the relevance of
site meetings in Non-Routine locations that include Critical wells however in all
cases has its challenges, primarily time and money spent.
• Today we consult with each of the agencies via telephone conference. Most
of the agencies will then forward their requirement/expectations and references
from their plans. In most properties such as locations where there are routine
operations, teleconference consultations are effective and quick.
• The definition of a face-to-face will extend the timeframe of ERP development
significantly. The prospect of getting all parties together at the same time is
unlikely resulting in multiple trips and coordination. Many community
responder folks in rural are volunteers or multi-taskers with other
responsibilities and are not easily accessible for telephone consultation, much
less face to face.
• Companies must develop Continuing Education Program for Public
Awareness is ambiguous by nature. What is appropriate, what about overlap
with other producers?
• The Licensee must conduct this program through personal consultation with
all identified individuals every 2 years.
There are many areas where multiple producers and plans will overload
stakeholders with efforts being redundant and inconsistent lending to public

Page 59 Section 14.6 Item 18) No requirement for annual ERP update.. The
definition of current, that reflects the latest possible "resident contact
information". Moving from annual updates to "when changes occur" on the
surface seems less prescriptive and more effective but here is the problem:

How do you know the currency of the Resident information without actually
talking to the resident? This could change the contact from Annual to Bi-
annual or more frequent to ensure compliance.This would be a non
compliance item in any jurisdiction where there are developments, industrial or
residential ongoing.Updates derived from normal consultations either triggered
by new project or by an annual date threshold will be more cost effective and
prudent than an idealistic approach on a less than idealistic process.

Page 21 Table 4 - Notification of Non-resident landowners and farmers renting
land within the EPZ. This is a major concern. The ability to get and maintain
information on non-resident landowners of land impacted by the EPZ is difficult
and costly the most likely source is through land titles and in majority of cases,
ineffective from a public safety perspective vs. cost vs. risk.
         The ongoing management of this information would require
        continual searches to determine changes. The sending of an
        informational package by registered mail is also expensive.

             The gathering and management of Non-resident data, provides
       little or no benefit with regards to the operational effectiveness an ERP
       or of a companies Emergency Preparedness and training.

          This added step also lends to more risk in gathering, processing
       and managing private and confidential data not necessarily needed.
Dissemination of information through Open houses and newspaper
advertisements could be used to inform landowners of the range of impact of
the EPZ. This would minimize the timeframes, impacts and costs of informing
the public.




1. The Draft speaks to the need for licenses to conduct a “risk-
assessment” on all facility river crossings, what tool if any is approved 
and what criteria if any will dictate a company to have further mitigation
in place over and above being a member of an Oil-Spill Co-Op?
2. What is the proposed implementation plan for D-71?
3. Will all existing approved ERP plans require re-assessment and
approval by the ERCB?
4. Section 8.2 describes the requirement for HVP modeling and
supporting documentation. Will the ERCB defining the proposed
(approved) model?
5.   What changes would trigger the need to remodel a P/L‟s EPZ (new 
wells, wells shut in)?
6. In section 14.13 how will a new licensee comply with a seven day
notification to residents within an EPZ of a change of ownership? It is
unlikely under current privacy laws that the former owner could pass
along confidential resident information?
7. Will nonresident landowners require notification every update, or is
it a one time notification and if so why if there has been no change to an
EPZ?
8. In section 14.6 the ERCB identifies that annual updates are no
longer required and attempts to define the requirements for companies
to maintain and keep their ERP “current”.  How is the ERCB going to 
interpret “the latest possible resident contact information” as current 
(two year update cycle)?
9. What criteria will dictate the need to "remodel" EPZ's, new well tie-ins, gas
composition changes (what would be considered a significant change), wells
shut in, revers P/L flow? Please provide clarity.

       Recommendation: Either rewrite the Emergency
       Management Act to exclude a municipalities responsibility
       within any Emergency Planning Zone or rewrite the
       proposed amended Directive 71 to recognize the
       municipalities responsibilities.
 Section 4.2 paragraph 4 states that an oil company is not
required to notify resident within an urban area but only has to
advise the Director of Municipal Emergency Management
however if it is an urban type of development in a rural area they
have to advise all residents. I cannot understand this exclusion
– are urban residents of less value that rural residents or are
you trying to hide something? Are we all not residents of the
Province of Alberta? Are you making it the responsibility of the
Director of Municipal Emergency Management to advise the
residents in the urban municipality of the drilling program, of the
oil companies plans for evacuation and to keep them updated as
the program proceeds? Is the oil company going to reimburse
the urban municipality of any time and costs of advising its
resident of the program? Recommendation: Remove any
differences between rural and urban residents.

 Section 4.2 paragraph 7 states that the Energy Resources
Conservation Board “may” provide mediation in the event the
municipality and the oil company cannot agree on the ERP.
This is too permissive. Section 11 of the Emergency
Management Act makes the municipality responsible. If they
cannot agree the Energy Resources Conservation Board MUST
provide mediation and if the municipality and the oil company
can no agree the license application should not be issued.
Recommendation: Rewrite Section 4.2 paragraph 7 to
require the board to provide mediation and if the oil
company and the municipality cannot agree require that the
license application be refused.
 Section 4.3 paragraph 10 requires the licensee must notify
residents of urban centres that they are within the EPZ, while
Section 4.2 paragraph 4 says that they don‟t need to notify
urban residents. Recommendation: Ensure that these two
paragraphs are consistent.

 Section 4.3.1 paragraph 14 requires the licensee to provide
a copy of their Public Information Package to the ERCB field
office so they can respond to questions. It is likely that the
municipality will receive questions as well but will not have any
information upon which they can respond to questions therefore
the municipality should receive a copy of the public information
package. Recommendation: Require the licensee to
provide a copy of any information provided to the public to
the municipality.
       Section 5.2.2 paragraph 4 requires the licensee to advise
      how the evacuation … will be accomplished. Oil companies do
      not have any authority to conduct an evacuation – they can
      request resident to leave but they have no authority to evacuate
      people. In fact a municipality cannot order evacuation unless a
      State of Local Emergency” has been declared by the elected
      officials. They have the option of declaring it or not.
      Recommendation: If an evacuation is to be conducted the
      municipality must be involved.

        Section 5.2.3 states “The local authority responsible for the
       area coordinates the evacuation response in the EAZ and
       beyond as per its Municipal Emergency Plan (MEP) with
       assistance from the licensee and with all available resources
       and manpower. This statement is incorrect; under the
       Emergency Management Act the municipality is responsible for
       all evacuation. Recommendation: Rewrite Directive 71 to
       recognize the municipal responsibility and require
       cooperation between the licensee and the municipality.
        Section 13.1 paragraph 1 and table 10. Although paragraph
       requires that local authorities are to be notified in situations
       included in Table 10 the Table only includes the public and not
       the local authority. Recommendation: Amend Table 10 to
       include local authority.
        Section 14.1 paragraph 3 does not require local authorities
       to be notified. Recommendation: Require the licensee to
       notify the local authority every time the public is notified of
       anything.
Section 14.2.1 paragraph 4 does not require notification of the local
authority unless the Emergency Planning Zone includes an urban area
but not a rural local authority. Recommendation: Require
notification of the local authority every time the public is notified
and, as recommended earlier; remove the distinction between
rural and urban municipalities
        Section 14.2.6.1 and Section 14.2.6.2 state that if the licensee
       does not agree to ignite the release the Energy Resources
       Conservation Board may make the decision. The way the
       document is written the licensee and the Energy Resources
       Conservation Board have authorities the local authority does not
       have. The Emergency Management Act places the
       responsibilities on the municipality. Municipalities must have all
       the authority necessary to manage the incident.
       Recommendation: Provide all authorities necessary to
       municipalities to manage any incident.
        Section 14.2.8.1 paragraph 11 requires the licensee to
       notify the Energy Resource Conservation Board and Alberta
       Environment and request the public of the levels to H2S and
       SO2 but not the municipality. Recommendation: Require the
       notification of the municipality whenever the public is
       notified.

Section 14.2.8 - Air Quality monitoring
I believe this section, as in the past, still seems to focus mostly on drilling &
sour wells and should be strengthened to better reflect air quality monitoring
requirements and aspects as related to facility / pipeline plans.
section 5.3 maps

- should trapper cabins not be identified
- do we not have to show industrial facilities within the EPZ
- although it may be implied, but should it not be requirement to include TWP
/ Rge grids
and lat / long markers
it should be a requirement that all ERP maps show a detail box indicating the
geographical location of the specific ERP area related to a larger map i.e.
where it is situated topographically in the real world.


   1. 2.1.2 (5) Communications Plan: Under this section, a licensee
   developing a Corporate ERP must include measures for contacting and
   maintaining emergency communications with government agencies and
   members of the public. Unlike 4.1 (Table 3), there is no existing
   requirement to contact or consult with the local authority in the
   development of these plans. Consequently, there are situations where
   Corporate ERP‟s covering our municipality and our residents have been
   developed where we have not been consulted to ensure these measures
   are correct and will work in an emergency. We therefore request:
           a. That the local authority be consulted in the development of
           Corporate ERP‟s (as per site-specific ERP‟s)
           b. That the Licensee be required to provide a copy of the
           Corporate ERP on request of the local authority (as per site-specific
           ERP‟s)
         c. Where Corporate ERP‟s exist and the Licensee does not have
         evidence of local authority consultation - satisfactory to the ERCB –
         in the development of the Corporate ERP that the ERCB require
         this consultation to occur within 1 year of the implementation of the
         new Directive 71.
1. 5.7 Plan Distribution:
         a. According to Section 5.7, site-specific drilling/completion ERP‟s
         must be distributed within 5 business days of receiving written
         approval.
         b. According to Section 5.7, 7.3.3., 8.3.3 and 9.3.2 all other ERP‟s
         and supplements (e.g. sour operations, HVP pipeline) must be
         distributed within 30 days.
         c.    [Please note that according to part B of Table 1, Section 14
         has been changed to 30 days. No reference to this exists in
         Section 14.]
It is our view that the timing requirement is not as important as it is to
ensure that parties expected to response (e.g. Local
Authorities/Emergency Services/RCMP) should be provided with their copy
of the ERP sufficiently prior to the commencement of potentially hazardous
operations (e.g. penetration of shallow sour zones, start-up of a new HVP
or sour pipeline tie-in, etc.). As presently worded, we would be required to
provide a written request aligned with this philosophy at the consultation
stage.
1. 14.2.5 Notification and Evacuation outside of the EPZ: This
section currently reads “the local authority responsible for the area
coordinates the evacuation response in the EAZ and beyond per its
Municipal Emergency Plan with assistance from the licensee and with all
available resources and manpower.”

As noted in our letter of January, 2007, the ERCB does not have
jurisdiction or authority over municipalities. We are concerned when the
ERCB applies directive language to local authorities such as “coordinates
the evacuation response” and “ all available resources and manpower”.
While we may in fact strive for these goals in responding, the response is
subject to many factors for which binding language could leave industry
with unfulfilled expectations to the possible detriment of the public. We
would request a re-wording.

1. 14.2.8.1 (11) Air Quality Monitoring – Sour Gas Release: The
licensee is expected to provide monitoring results to Alberta Environment,
the ERCB and on request to the public. We would request that the local
authority (emergency services) be provided with the data on an equal
footing to AENV and ERCB. Emergency Services may require immediate
access to this information due to our overall mandate for public protection
during an emergency. See also 14.2.8.2.

1. Resident Consultations: The requirements for resident consultations
and associated work (groundproofing and mapping updates) could be
improved. For example, the present wording of the document leaves it
unclear whether consultation with our residents by licensees can be spread
over two years. A table clearly explaining this entire topic would be helpful.
1. Section 2: Corporate Level ERP’s: The addition of a requirement for
the licensee to make corrections to Corporate ERP‟s brought to their
attention by plan holders (e.g. Local Authorities, RHA‟s, etc.) similar to
Section 14.7 (site-specific ERP‟s) would be useful. From our perspective
regarding both Corporate and Site-specific ERP‟s, if these requests are
substantive (e.g. incorrect emergency contact information, responsibilities
listings, or surface developments) then the licensee should amend the ERP
immediately. Other types can wait for the next update. This request is
based on our experience with requesting revisions.

1. 3.2.5 Facilities: The calculated Emergency Planning Zones (EPZ‟s)
for facilities in this guide remains the same as the EPZ for the facility‟s
largest pipeline. Our view is that this does not safely reflect facility „upset‟
or containment failure scenarios, where the facility releases the H2S
entrained in the process units, as well as the drained volume of all inlet
pipelines from their last line block valve into the facility. Incidents of this
nature have occurred in Alberta (including where the flare stack has failed)
and suggest that a facility-specific EPZ reflective of this scenario is
required to adequately protect the public.

1. 5.2.2 Evacuation and/or Sheltering Within the EPZ: Under item 6,
the CAPP best practice Shelter-in-Place document has been downgraded
to a recommended practice from the mandatory inclusion required by the
previous draft of D-71. Strathcona County supported the previous
inclusion, as it required consistent instructions on shelter-in-place to be
provided to our residents by industry in wording that had the agreement of
the Medical Officers of Health, the EUB, and the majority of upstream
petroleum developers in this province. Additionally Strathcona County had
been aligning and utilizing this wording in alignment with the requirements
of our own Land Use Bylaw. We request reversion to the requirements of
the previous draft.
1. 7.3.1 Newly Added Well/Pipeline Tie-ins, Facilities and Operating
Areas: This section requires the licensee to conduct a public involvement
program for all new members of the public, as defined in Section 4.3.
While local authorities are captured indirectly by the definition of “public”,
without being specifically referenced in Section 4.3, there is a strong
possibility of being overlooked during consultation. Providing clarity would
reflect our need to be aware and comment on these from an emergency
response perspective, and would be more reflective of our own
experiences with such situations. Additionally, it puts the County at a
potential disadvantage if we are not aware of the same information our
residents would be when they call us with their concerns. This comment
also applies to 7.3.4 (11).

1. 12.3 Response Zones: RCMP are mentioned twice in this paragraph.
I would suggest that this say police, as there are a number of non-RCMP
police services in the province, including in jurisdictions where sour gas
wells/pipelines/facilities are present (e.g. NE Calgary).
1. 13.1 (1) Table 10, Cancellation of ERP: Plan holders should be
notified of an ERP cancellation, in addition to the residents of the EPZ as
noted in this table. Written notification would be preferred.
    1. 14.6 ERP Updates – Current Plans: We are not convinced that
    dropping the requirement for annual updates will be sufficiently off-set by
    spot-checks with the assessment program. Our experience has been with
    many current ERP‟s not being updated for periods over one year or more.
1. 14.11 (23) Exercise Requirements: The licensee must invite the local
authority to participate/observe at major exercises, and must provide the ERCB
with 30 days notice. If the licensee knows of their exercise 30 days in
advance, we would appreciate the same courtesy of notification. Presuming
that the ERCB is sincere about having local authority participation, the same
reasons why the ERCB requires 30 days advance notice are the same ones
behind our request.


) Page 20 Section 4.2 point 6) Personal consultation with Local Authorities and:

   The prescriptive reference to face-to-face consultation with the listed
government agencies and local authorities. Today we consult with each of the
agencies via telephone conference and face-to-face when needed or
requested. Most of the agencies will then forward their
requirement/expectations and references from their MEP. We document the
coordination forward on to the local authority for acceptance.In most properties
such as location that are routine operations, Teleconference consultations are
effective and quick. The definition of a face-to-face will extend the timeframe
of ERP development significantly.. as the prospect of getting all parties
together at the same time is unlikely resulting in multiple trips and
coordination. I see the relevance of site meetings in Non-Routine locations
that include Critical wells etc. The timelines to coordinate face-to face
meetings, especially with groups who do not see the need or have the time, will
extend the overall time to prepare an ERP beyond acceptable timeframes.

 Recommendation: Reword the requirement to state the Licensee must
coordinate with the Local Authorities and others as listed to confirm and
coordinate roles and responsibilities. Dropping the prescriptive reference to
Face-to-Face. This would allow both the licensee and the coordinating local
authorities to determine the most effective method of achieving your goal.
2) Page 21 Table 4 - Notification of Non-resident landowners and farmers
renting land within the EPZ.

   This is a major concern.. The ability to get and maintain information on non-
resident landowners of land impacted by the EPZ is difficult and costly the
most likely source is through land titles. The ongoing management of this
information would require continual searches to determine changes. the
sending of an informational package by registered mail is also expensive. The
gathering and management of Non-resident data, provides little or no benefit
with regards to the operational effectiveness an ERP or of a companies
Emergency Preparedness and training, which are the core principles of
Directive 071. As written this places a higher priority and is more prescriptive
than the requirement of notifying the public residing in a Municipality that is
within the EPZ.
Recommendation: Dissemination of information through Open houses and
newspaper advertisements could be used to inform landowners of the range of
impact of the EPZ. The Add could reference the LSD's impacted by the EPZ
and allow the public, with concerns, to contact the Licensee to request further
information. These would achieve your objective and minimize the timeframes,
impacts and costs of informing the public.
3) Page 59 Section 14.6 Item 18) No requirement for annual ERP update.. The
definition of current, that reflects the latest possible "resident contact
information". Moving from annual updates to "when changes occur" on the
service seems on the surface less prescriptive and more effective. The
problem is, how do you know the currency of the Resident information without
actually talking to the resident. This could change the contact from Annual
to every 6 months to ensure compliance. The in many cases the public is not
happy receiving multiple contacts (from different companies) annually and
would be even further annoyed if contacted every 6 months. The general
approach and objective of the 6 months review process is ok but I believe the
contacting of the residents is not manageable in areas with large numbers of
residents.

Recommendation: Through regular field truthing the Licensee is required to
document changes to the resident impacts and update information as
determined. Resident Contact information is to be updated and kept current
with contact to be made at a minimum, annually.

4) Page 62 Section 14.13 "Sale of Property" The timelines required to develop
the Consultative Program, Gather information on assets purchased and
implement the public Consultation / involvement programs as prescribed will
not allow companies the ability to meet the stated requirement of developing an
ERP within 60 days of of change of Ownership. This will effectively force
companies into noncompliance at the start, even if they follow all the
prescriptive requirements as they will simply run out of time.
5) Page 69 Appendix 1 "Noncompliance Events". Part A and Part B. There
are many duplications of events within each part. Also the points are not
always clear as to the specific meaning. Ie. First point in "Part B : Failure to
have a copy of the Corporate-Level ERP at a location capable of initiating first
response actions." Section 11.1 Requirements states the same thing but does
not provide clarity on what is meant by "location capable of initiating first
response actions." Is this the field location and are the Operators defined as
the first responders? I think this is the case, but an individual could interpret
this as their EOC where they would initiate response and direct actions from
there as opposed to the field. If there is documented Non-Compliance events
they need to be clear without any subjective assessments as to the meaning of
the criteria.
2. The organization of the directive in to two parts Planning and Response
although seemingly a good process from a theoretical perspective does make
it more cumbersome in the development of an operating plan. One example is
with respect to evacuation, in the planning section it tells you who you have to
evacuate, then deep in the response section it tells you when/how to evacuate.
Thus when preparing a working plan and say defining a Rovers duties you
have to search out the info from two parts. It would be easier if once a subject
is introduced all aspects were covered. This would eliminate more duplication
in the document, as there is usually an introduction each time with similar
information in it, and repetitive statements like using the decision matrix as well
as some of the technical operational requirements being repeated. Sections 2
and 11, 3 and 12, 4 and 13, 5 and 14, 6 and 15, 10 and 16 could be combined
shortening the document considerably. This would make the document a lot
more user friendly.

       3. Is it the intent that the whole CAPP shelter in place document be
       included in the Public Information Package, or are we ok with
       abbreviated versions of key steps that we have now.

4. To allow for the most Current Emergency Response Plan to be distributed to
agencies (Health Regions, Municipalities, RCMP, etc) other than the ERCB,
why not leave the time frame open so that they are distributed 5 days (where
possible) prior to commencing operations. Due to rig schedule changes,
delays, etc many times we have to prepare update supplements 2 - 3 times
after the plan has been approved and before operations start. This would
minimize the administrative burden in the system.



       5. Is it the intent that we use the ERCB First Call Form verbatim in the
       process, or can we use a similar form we are already using that has all
       that information and even some more?

       7. The addition of the two extra zones has not added anything to the
       way we conduct public safety. I only have a fear of having to explain all
       of this to the public when we have big problems communicating what
       happens in the current Emergency Planning Zone and Emergency
       awareness Zone. We operate in this manner now. Also by reading the
       directive regarding the Emergency Planning Zone, Emergency
       Awareness Zone, IIZ, and PAZ, a person could interpret that you do not
       have to evacuate the whole Emergency Planning Zone. Is this true?
       By following the Directive as written, I don't have to evacuate the whole
       Emergency Planning Zone until the wind changes. Then it is too late
       and I will expose the public to H2S or SO2. Am I missing something, or
       should there be a positive statement put in there that after the IIZ and
       PAZ are evacuated you immediately begin the remainder of the
       Emergency Planning Zone?
       8. What level of detail is expected that we collect on public facilities in
       the Emergency awareness Zone? Is it just identification, or phone
       contact, or personal contact, and how much information is expected to
       be collected around contact info and other procedures for managing the
       Emergency awareness Zone?
       9. With respect to face to face contact with local agencies, does it have
       to be face to face in all instances? For instance if there are multiple
       wells in an area, and f2f is done on the first well, do you have to do it on
       all others, or will phone contact suffice.
       10. Page 21 Table 4 Column 1 row 3, Should have oil and gas
       operators with manned facilities. Column 2, row 3, should have oil and
       gas operators with wellhead only. Column 2 row 4, This should be put
       in D56. Column 1 row 5, how do we consult an open picnic ground? In
       past we have treated them and monitored them as transients and
       would be managed this way in the event of an emergency. We do
       identify the location on maps and they are part of daily rover
       observations. I this still OK?
       12. With respect to competency to ignite a well or pipeline except HVP,
       is proof that a person has participated in structured ignition exercises
       including deploying equipment and rescue equipment sufficient to be
       assigned the task of ignition/ignition supervisor?
       13. Section 5.7 Should have distribution changed to 5 days before
       commencing operations instead of 5 days after approval.


        14. Section 5.8 With respect to inclusion of a communications
        flowchart, what is the expectation? Can a combined
        command/communications chart work?
15. Section 7.1 Just a general question, why not keep track of these wells
within the well and pipeline tables, so that in the chance that something did
happen, the information is readily available

Section 14.6 - Current Plan

      The current wording in this section reads that there is a requirement to
continually update the ERP plan for 5 elements. The exception ConocoPhillips
has in this regard is that

-resident updates would never be complete in our opinion.
-current within 6 months from what date? Would this be the approval date of
the original ERP moving ahead from there or today's date?

CPC Position
      The concept of evergreen plans has always been accepted as good
practice. If new facilities are being added or information about residents or
public facilities becomes known we have endeavored to update the plan. It is
our opinion that new residents even though they may not be in the current
version of the plan would still be cared for in the similar sense of a transient.
No contact of a household or public facility would be recorded and rovers sent
to investigate the reason.
Section 3.2.1 Sour Gas Wells

      What is the expectation in regards to existing producing/suspended wells
and calculating their release rates? Will it be the expectation to redo all the
release rates as some of the current rates may be based on the 3 x max
production rate procedure? In the situations where current static gradients or
reservoir information is not available is there an alternative acceptable method
for calculating release rates.

1. Section 14.2.8.1 is very confusing and does not adequately state what
the air monitoring requirements are for producing pipeline systems and
facilities. The way the section has been written it appears to only apply
to sour wells.
2..When acquiring a property from another licensee can resident data
(i.e. confidential information) be transferred? If not as I suspect, then
how should a company implement the notification requirements
outlined in the first paragraph of Section 14.13.
1. Section 3.3 in Directive 071 is too vague and should be better
defined. Later in Sections 8.2 and 9.2 a requirement is described to
include HVP modelling supporting documentation. The ERCB should
be defining what HVP modelling supporting documentation will be
accepted, especially when in Section 3.3 there have been no modelling
requirements stipulated.
1. Section 3.2.2 requires that EPZs be calculated for non-flowing wells,
why? The EPZ values are going to be very small for non-flowing wells
producing fluids containing less than 1% H2S but more than the 100
ppm H2S. It will take considerable resources to complete the EPZ
evaluations for all non-flowing wells and will not necessarily provide
any useful information, at least from a public protection standpoint.
Would it be acceptable to look at the worst case scenario in any given
field area containing multiple non-flowing wells and then apply the
results of the assessment to all of the wells in that field area? This
would be conservative and would reduce the burden on companies to
conduct modelling on all wells.
1. Why are face-to-face meetings with local authorities required? This
may make sense for ERP‟s where there are significant potential impacts 
to the public, but what about the majority of ERPs which only
encompass 10 or fewer residents. There is a high likelihood that most
local authorities will not have the time or patience to meet multiple
companies as they try to implement these new requirements. Will the
ERCB accept reasons for not meeting with local authorities face-to-
face? What if the local authority feels it is unnecessary?
2. Section 4.3.1 Public Information Package


a. Part 12) states that the licensee should provide a reasonable amount of time
having regard for the specific circumstances...
i. Can you please quantify “a reasonable amount of time”.

b. Part 13) states that the licensee should provide specific information upon
request for any well, pipeline or facility that is in the public information package.
i. Please change “specific” to “all publicly available”. Industry should not be
obligated to provide classified information to the public.


Section 5.2.3 and section 14.2.5... "The local authority responsible for the area
coordinates the evacuation response in the EAZ and beyond as per its Municipal
Emergency Plan (MEP) with assistance from the licensee and with all available
resources and manpower."

There are issues with this:
a) ERCB has no legislation to enforce this requirement.
b) If you place responsibility for emergency response on the local authority then you
must also give them complete power to prevent development once it exceeds their
ability to respond.

c) this does not match up with the final sentence: "Evacuation of the area outside the
EPZ is a coordinated response through a licensee‟s ERP and the response framework in 
the local authority MEP."

UNLESS... by 'coordinates' you mean 'monitors the efforts of industry and ensures the
safety of their residents" but I don't think that's what you mean.


It is true, however, that: "If the licensee does not have the resources to manage an
evacuation in an area affected by a release, the local authority responsible for the area
will coordinate the evacuation response as per its Municipal Emergency Plan (MEP)
with assistance from the licensee and with all available resources and manpower"
the response framework in the local authority MEP."
should be:
"The Petroleum Industry Incident Support Plan will also be activated by the
government for level 2 and level 3 incidents to provide support to the incident
response. Notification mechanisms outlined in the MEP response framework will be
used to notify residents outside the EPZ, as per negotiations conducted during
notification and consultation. Evacuation of the area outside the EPZ is a coordinated
response through a licensee‟s ERP and the response framework in the local authority 
MEP."
Footnote 14:
"has to issue an order for a Local State of Emergency before mandatory evacuation can
occur" should be "has to declare a State of Local Emergency before mandatory
evacuation can occur"
1. The health end-points proposed to define the EPZ are not
protective of human lethality, and have not been developed
following peer reviewed published protocols. The curve was then
„set at 100 ppm for 60 minutes.  There is no evidence that this health 
end-point is protective of human health for lethality. In this respect,
the health end-points must be regarded as arbitrary. The approach
should establish a point of departure following the published
methods for risk assessment.

1. The new health end-point of 100 ppm for 60 minutes represents
a significant departure and relaxation in public safety from the
historical ERCB (1979) and ERCB (1990 health end- points. In the
past, the emergency planning zone was based on a single health end-
point of 100 ppm H2S for 3 minutes. There has been no evidence
present that the traditional health end-point was too conservative; in
fact, this health end-point is the same as that recently developed by
the US EPA (2002), i.e., 100 ppm at 3 minutes. The US EPA (2002)
AEGL was peer reviewed; including scientists in the United States,
Alberta, Alberta petroleum industry representatives, and the
American Petroleum Institute in North Carolina in 2000. Further the
EPA approach follows the peer reviewed process for establishing
uncertainty factors. This illustrates the un-conservative and arbitrary
value of the new proposal of 100 ppm H2S for 60 minutes.

1. The EUB health end-points have been defined by an unorthodox
and it appears arbitrary method of developing uncertainty factors.
The uncertainty factors are not conservative, nor have they been peer
reviewed. The proposal claims to have used an uncertainty factor of
759. An uncertainty factor of 20 was applied to the LC50 to
approximate a human LC50 line. An additional uncertainty factor of
15, (now a total of 300), was applied to approximate a point of no
unconsciousness effects.  The curve was then „set at 100 ppm for 60 
minutes‟ which means the total uncertainty from the animal LC50 
line is 759. There is no evidence presented that the values used to
derive the 759 are conservative or provide the protection they claim.
To compare with other published approaches, the 759 fold
uncertainty factor is actually (759)1/3.5 = 6.6. The uncertainty factor
is much less than those used by other regulatory jurisdictions. For
example, the US EPA (2002) recommended an uncertainty factor for
H2S of 10 in development of the acute exposure guideline levels.
4. The ERCB report claims: “the EUB EPZ results in zero chance of lethality”
(Zelensky and Zelt 2006, p. ii, and p. 49). This is not supported by the
scientific evidence, and in fact, the EUB proposed health end-point can result
in lethality for short exposure times. The proposed health end-points for ~1
second or breath is 1050 ppm H2S. The toxicological wisdom dating back over
100 years argues that this level of exposure is rapidly fatal. Lehmann (1892),
Baynes (1981) and Rogers (ERCB 1990b) in the ERCB toxicology review of
H2S stated that 1000 ppm H2S is rapidly lethal. Heustis (1966) reported the
immediate death of 5 workers at 1000 ppm H2S. Similarly, Prouza (1970)
document immediate lethality in one man at 1000 ppm H2S. The lowest
observed immediate lethality in an experimental setting we have identified is
400 ppm H2S; 1 of 1 pigs died within 1 second (O'Donoghue 1960). The EPA
(2002) commented: “vapour concentrations on the order of 500 – 1000 ppm or
more are usually fatal within minutes (Ahlborg 1951, API 1948, Reiffenstein et
al. 1992)” (EPA 2002, p. 2). Thus in contrast to the ERCB report claims, the
health end-point is not protective of human lethality, and in fact, human lethality
will likely result at the proposed health end-points for the EPZ.


   1. The Calgary Health Region (CHR) recommends that the ERCB
   adopt either the US EPA (2002) AEGL or the Brown and Strickland
   (2002) health end-points to define the EPZ. Either of these
   approaches can be used in the EUB dispersion model and both have
   been peer reviewed.
   1. The CHR recommends that section 5.2.3 notification and
   evacuation outside the EPZ, clearly indicate the role of regional
   health authorities in evacuation as per the Alberta Public Health Act
   (section 52.2).
   1.

   The CHR recommends the use of voluntary evacuation guidelines
   for H2S and SO2. The CHR has developed a protocol for this, and
   recommend the ERCB adopt this protocol.

- under principle points provided (i.e. 1-3) there is no requirement for follow-
up by the ERCB.

- Risk and Vulnerability Assessments be conducted prior to activities taking
place that are based on CSA Standard, since Assessment Matrix is referenced
once an incident has occurred (i.e. proactive instead of reactive)

- under 5) point # 2 replace “recommends” with “Must” , so that a 
communications flow chart be included in ERP
Emergency Awareness Zone (3.4)
provide clarification what is done if local authority does not have these
provisions built into their plan?
- What about authorities/role of MOH?
- Initial Isolation Zone (IIZ)
- replace residences to include all types of public facilities/places to reflect
similar risks at these types of facilities/places.
- Remove this definition as it is not understood why the ERCB would allow a
well/project to be located in such close proximity to the public place and to
create such a situation (i.e. risk to public health)?

- replace definition of “public facility” to “public place” as described in the 
Public Health Act to encompass all types of public locations/gathering places.
If definition will not be changed to amend the current definition to include” 
add or require special assistance”. First preferred.
- How to Prepare for the Notification and Consultation Program (4.2)



- under 6) change requirement that face to face has to occur during public
consultation to be required when first draft of the ERP has been completed.
This gives commenting body the opportunity to see the whole picture of what
is being proposed in writing not verbal (i.e. changes to plans may happen
between public consultation and draft stage).
under 6) where it indicates under section 11 of EMA, the Public Health Act
needs to be added (i.e. 29(4)).

under 7) it needs to be clear as to how the agreements are made (i.e in
writing).
Table 4 needs to include that notification will go the landlord and the tenant.
Some landlords live out of province or country. It also needs to include other
types of premises/places used by the public (e.g. B&B).
under 9) include requirement for consultation with the director of emergency
preparedness takes place (e.g. RHA).

under 10) please provide clarification if residents of urban areas are to be
advised or if the office of emergency preparedness is to be advised?
Public Information Package (4.3.1) recommend that a common terminology
be used to explain information (e.g. % vs. ppm).
under 13) include information as to what is too occur in acute exposure
situations (high level - short term).
Capital Health requests that further discussion with the Office of Emergency
Preparedness take place regarding the direct contacting or consulting with
directors of health centres. Prevent unnecessary confusion/panic from taking
place.
Information Required from the Public Involvement Program (4.4) - under 15)
include public places (Public Health Act definition).
Notification and Evacuation Outside the EPZ (5.2.3) - under 7) confirm that
local authorities know of and understand this change of requirement/added
responsibilities. Also advise why the upstream plan is activated when local
authority plan is also activated?

Air Quality Monitoring (5.2.6) - amend directive to require that dispersion
modeling be undertaken to assist in achieving the outcomes described/desired.
Hard to achieve these outcomes without some type of science taking place.
Also to include the placing of monitors at strategic locations determined by
modeling and personal experience of individual who is interpreting,
developing modeling program (it is assumed that the person developing and
interpreting modeling program has qualified credentials).
include topography to list of criteria.
Mutual Aid Understandings (5.5)- amend directive to require that written
agreements be in place, otherwise there is no guarantee that resources required
to respond to the incident will be available.

Plan Distribution (5.7)- amend directive to require that a process of retrieving
or removing inactive ERPs from locations plan distributed be required.
Communications Plan (5.8) - amend directive to require that consultation with
local authority and local RHA be undertaken to ensure consistent message
given. Amend information in directive to indicate a timeframe for when or
how soon a message has to be given.

Responsibilities of Personnel (5.9) - amend directive to include government
agencies and RHA. Amend directive to indicate what format plan will follow
(e.g. ICS) so all responders are aware of response format used.

6.0) Sour Under Balanced Drilling Operations (6.5) amend directive to require
that underbalanced drilling must not take place at locations where there are
public facilities/places within the EPZ, EAZ, urban development, urban
density development or close to unrestricted country development. Should
also be a requirement to increase the safety precautions on-site and adjacent
areas (i.e. risk assessment and consequence management plan be required)
7.0) ERP Submission Requirements (7.1)Table 6- ERP shall be required for a
sour pipeline located in close proximity to a public facility/place instead of
populated area being indicated, or list types of developments (e.g. urban
development).
10.0) Spill Cooperative Response Plans- provide clarification if “wells” means 
water wells or gas or oil wells. If “wells” means water wells the local RHA 
needs to be participate in activities. Amend directive to request that local
RHA participate in exercises.
11) Corporate-Level Plans-Communication Plans (11.1.2)- amend directive to
require licensee to contact agencies. Also to confirm if local RHA is part or
indicated in the Upstream Plan. Amend directive to require that participation
of local RHA and Authority be included in media releases issued. Also that
spokepersons should be Local Authority or RHA.

Downgrading Emergency Levels (11.1.2.1)-amend directive to indicate that
the MOH has jurisdiction to determine if an emergency is downgraded under
the Public Health Act.


Incident Management Centre (11.1.3)-amend directive to be clear as to what
ERP takes precedence, the local authority or the company plan.
12) Emergency Planning and Response Zone- Emergency Planning Zone
(EPZ) (12.1) Figure 2 - why is protective action zone based solely on wind
direction and not include other influencing factors (e.g. topography, weather
conditions). What happens if no wind present?

Initial Isolation Zone (12.3.1)- amend directive to include other public
facilities/places (e.g. foster homes, B&B). Ques: Not sure why this zone is
being implemented? Why not relocate or locate project to a location that will
not put public at these potential risks, as outlined in the IIZ definition?

Protective Action Zone (12.3.2)- amend directive to require that calculation of
PAZ includes other influencing factors (e.g. topography, weather conditions,
etc.).
Amend directive to require that written understandings be required that clearly
outline each agencies roles and responsibilities/activities during a response, so
as to provide a unified coordinated response.

13) Public and Local Authority Involvement in Emergency Preparedness and
Response -Table 10 - amend table to include the following: more advance
notification be given to public (i.e. > 24 hrs) prior to drilling, completion or
work over activities taking place, so as to give those with special
needs/situations time to make appropriate arrangements. Suggest two weeks.

Amend directive to require a company to provide a complete updated ERP
when ownership of a location/project takes place, so as to prevent confusion
of what plan to be used during an incident.
Continuing Education Program for Public Awareness of Emergency Response
Procedures (13.2)
Amend directive to require that education to take place annually to
accommodate changes to home ownership and/or land use development (i.e.
new subdivisions).
Amend directive to address situations where individual resides in an urban
populated area and may be affected by oil and gas activities
Public Protection Measures (14.2)- amend directive to require that risk and
vulnerability assessments be carried out prior to drilling and completion
operations taking place, and that a consequence management plan be
developed. Also these assessments be re-assessed prior to any maintenance
work being carried out that is taking place > than one year after the initial
assessments were conducted.

Notification During an Accidental Release (14.2.1) - amend 4) to include
Local Authority and RHA. Amend 5) to require the licensee to provide
appropriate public protection measures, since that is this office‟s 
understanding of what this directive is aimed at achieving (i.e public safety).

Provide clarification if IIZ and PAZ are not already pre-determined. If so, why
does decision tree indicate they be determined (i.e. Appendix 8a)?
Recommend this decision tree be re-evaluated to ensure effectiveness.


Amend directive to require plan to reflect what is described in MEP.
Evacuation and/or Sheltering Indoors (14.2.2)- amend plan to indicate that the
re-occupying of evacuated areas is the responsibility of the MOH to determine
when safe to re-enter (Public Health Act).
Amend directive to require licensee to continuously assess and act on the need
to expand evacuation area (from should). RHA is to be involved in this
decision making process.
Amend directive to indicate that MOH also has the authority to issue a state
of emergency (Public Health Act).
Amend figure 4 flowchart to include: when RHA is advised of situation- how
will they detect conc. of substance, at notify public step in IIZ box. Public
should not be put in that situation anytime (imminent risk)- amend step that
enquires if ignition criteria has been met. What if criteria has not been met (no
next step).
Plan Maintenance (14.7)- amend directive to require licensee or designated
body responsible for contacting parties that have copies of plans, so as to
ensure all inactive/outdated plans are removed from circulation (i.e.
documentation control).


Exercise Requirements (14.11) - amend directive to reflect new CSA Standard
Sale of Property (14.13) - amend directive to indicate that RHA should be
consulted or new ERP forwarded to RHA.
Overlapping EPZs (14.14)- amend table 11 to require that RHA be notified.
Additional Conditions to ERP Approval (15.4) - provide clarification as to
what if well is drilled, suspended and completions occur at a later date?
Appendix 1 Noncompliance Events Part A – Planning Requirements 
Noncompliance Events- amend directive to ensure those activities and/or
conditions that do not protect public health and/or safety be considered an
offense requiring immediate action (i.e. high consequence action required).
There appears to be several non-compliance events that are considered “low” 
that based on this office‟s understanding of the purpose of Directive 71 and 
how information is described in main body of Directive 71 should be
considered “high” (i.e. ensure safety and wellbeing of public and 
environment).

Amend directive in a manner that would provide those agencies requested to
comment on the proposed ERPs an opportunity to provide comments prior to
any consideration or final approval of a plan takes place by the ERCB (i.e.
window period to provide comments from commenting bodies that would
allow the ERCB to make an informed decision on the proposed plan).
Amend directive to require that licensee have a means in the ERP to account
for members of public that have been requested to evacuate and no reception
centre is activated (i.e. see point that indicates failure to open reception centre
as being a low consequence).




The requirement to have (face to face) discussions rather than having the
option to discuss the plan over the phone with the Local Authorities – Director
of Emergency Management, Medical officer of Health and Director of
Environmental health is going to significantly increase the time to prepare and
receive approval for an ERP. In addition the costs will increase and in most
case in won‟t add any value to the existing process. Currently when a Local
Authority or Medical officer requests a meeting with an operator to discuss
roles and responsibilities etc companies ensure that occurs. Making it
mandatory isn‟t necessary and there are many Local Authorities and Medical
officers that are very knowledgeable about their roles and responsibilities and
don‟t want or require face to face meeting. Face to face meeting should only be
required should they be requested by a particular government agency.
I don‟t believe Section 12 adds any value to Directive 71. The reference and
information on the PAZ and the IIZ was taken from CSA Z731-03. PAZ and IIZ
should be used for emergencies when the Emergency Planning Zone can not
be determined or is unknown and when the hazardous substance is unknown
or the concentration can not be determined. In the case of the oil and gas
industry they will be using the ERCB H2S models where the hazard and the
concentration is know in order to calculate the EPZ. In addition, the number of
people in the EPZ is also known and on critical sour wells air monitoring
equipment is readily available. Adding IIZ and PAZ into an already complex
document will only lead to confusion to everyone involved in the event a
company has to implement its ERP.




Should this read “Emergency Operation Centres”?

Several references are made to the licensee and municipal Emergency
Operation Centres which is the proper terminology for these centres. For
consistency, I recommend that all references to an emergency operation
centre remain with this commonly accepted terminology (used in both the
private and public sector)
I‟m confused by the following statement…..



“If the licensee or local authority decides not to set up an EOC, the licensee
must inform the local EUB field Centre of this decision and provide reasons in
support of it.”

I don‟t understand why industry would be explaining and justifying to the board
why a local municipality did not establish their EOC. It should not be the
licensees accountability to justify the actions of a third party where there is no
control (No control - no accountability). Industry is required to justify their
actions to the regulator. Industry should not be required to justify the actions of
municipalities to the Board.

Concern with requirement to notify "non-resident landowners and farmers
renting land
Concern with requirement for evaluating resident contact and mapping
information every 6 months


submitted 36 pages of comments. Responses addressed in their Excel
spreadsheet.
Response




This is an internal process and doesn‟t belong in the Directive.




Agree




General Comment




Already in Directive for site-specific sour well ERPS




Done

In areas with large populations an annual program would be very
difficult for a licensee to accomplish. Once every two years should
be sufficient.


Done

Done

Done
agree




General statement




General statement




General statement




General statement




agree




Agree
Statement of support
D071 will acknowledge the role of the RHA WRT evacuation as per
the Public Health Act (section 5252)




Agree

The ERCB believes that the current endpoint is appropriate for use
in the model.




General Statement. No response required.
Meteorological conditions are already accounted for in the model. A
minimum radius for an EPZ has nothing to do with the risks
associated with activities that occur at a wellsite. Risks at a wellsite
are mitigated by using trained professionals and proper safety
procedures.




The model results are actually more conservative, meaning that the
EPZ is larger if we don't use site sspecific topography as an input.




The IIZ is determined from the ERCBH2S model. Methodology for
determining the approximate size of the PAZ immediately folllowing
an incident is outlined in D071. The licensee will use its monitoring
equipment to determine the actual size of the EPZ.
The IIZ is calculated from the ERCBH2S model and would never
extend beyond the EPZ boundary. The PAZ is a response zone
which starts at the boundary of the IIZ and will extend outwards
towards the EPZ boundary during the course of the incident. Under
certain types of meteorological conditions the PAZ could extend
beyond the EPZ and the licensee would work with the local
authority to ensure public protection.


The ERCB will take your comments under consideration.




Previously answered

Your comment should be directed at Alberta Health and Wellness
rather than the ERCB.




The release rate (wells) or volume (pipelines) for EPZ calculations
is based on the maximum amount of hydrogen sulphide
released.Condensate does not contain hydrogen sulphide and
therefore has no impact on the size of the EPZ.
The ERCB feels that 24 hours is an appropriate period of time for
notice of commencement of sour operations.




Exercise requirements are currently under review and will be
included in the next revision to this directive.




The ERCB uses its Emergency Response Assessment Program,
field inspections and observations from exercises to ensure that
licensee preparedness and response is adequate.




There is no requirement for licensees to exercise their site-specific
sour well ERPs. There is a requirement for every sour operations
ERP to carry out an adminiistrative exercise annually.
The ERCB addressed this question with your organization during
the last stakeholder consultation.




Previously answered




Previously answered




Beyond the scope of this directive




Being considered
Previously answered




Previously answered




Previously answered




Previously answered




Previously answered
Previously answered




It would count as a overlapping EPZ

D071 does not deal with standing



This section has been revised to reflect stakeholder concerns

D071 does not deal with standing
Paragraph has been changed. At any level the company must
consult with the ERCB to change the level or stand down the
incident.



It would provided that any of the criteria in the Assessment and
Ignition Flowchart were met.
Section has been changed to reflect your concerns.




Section has been revised to reflect stakeholder concerns




This issue will be presented to the Board for a decision.
The risk assessment may be conducted in any manner the
company choses. Being a member of a cooperative enhances a
companies ability to deal with a spill into moving water. Further
mitigation to prevent a spill involves an appropriate maintenance
program on the pipeline and devices to limit the amount of liquid
spill by shutting down the pipeline when a break occurs.
Plan will be announced by a Bulletin.
Yes and there will be a phased in approach to deal with the
hundreds of ERPs.


Not at the current time. The onus is on the licensee to ensure that
the HVP model reflects current methodology
Any change to the pipelines licensed conditions should be modelled
to determine if the EPZ has changed.


The new licensee must have access to the old ERP and can use
the resident information to send out notification of change of
ownership


The issue off non landowner notification will be presented to the
Board for a decision.




The ERCB will be assessing a company's plan management
system to determine if their process keeps plans "current"



Same as question 5.




The ERCB recognizes the municipalities responsibilities
Urban residents are notified that they are within the EPZ by a
different process then those in a rural area. Notification is done
through a combination of newpaper advertisements, email-outs,
and open houses.




Section 4.2.(4) says the the licensee does not have to identify
each individual residence with the urban centre. Section 4.3(10)
talks about notification. The two paragraphs are talking about
different issues.
Statement has been removed.



The statement above the table reads "The licensee must carry out
public and local authority notification and consultation for
situations outlined in Table 10.



The ERCB will contact the local authority after it has been
contacted by the licensee.




The local auhtority and the RHA have been included in the
notification list.
Your comment has been referred to the Alberta Emergency
Management Agency.




Change has been made.




Good comment. We will be expanding the section to reflect pipeline
and facility monitoring requirements.

Trapper cabins should be identified if they are a permanent or part
time residence.
They must be shown on the map as per Table 4
The ERCB would not accept a map if the township and range and
lat/long coordinates were not included.



Interesting comment. I'll pick it up with the EPA Section




A corporate-level ERP covers the entire range of company
operations and extends beyond a single local authority. In some
cases it extends beyond the province and outside the country. The
ERCB will be studying the issue of corporate-level ERPs in the next
revision to this Directive
This section has been revised to reflect your comment.




This section has been revised to reflect your comment.




If the local authority has representation at the EOC it will be
provided with the data as will the ERCB and AENV.



Section 13.1 has nothing to do with updating the ERP. It is a
program specifically designed to review public protection measures
with residents within the EPZ.
Good point. We will reference the requirement in the corporate-
level section.




We understand that this does occur however feel that the largest
fvolume release from a pipeline enetering the facility provides an
appropriate EPZ.




Many companies indicated that their shelter-in-place documents
were equivalent or better than the CAPP document. Companies
can use the CAPP document or their own provided that the
instructions are equivalent to the CAPP document.




Section will be revised to provide clarity




Good point. Change will be made.


General comment
Good point. Change will be made.




Section has been revised to reflect your comment.
Item is going to the Board for a decision




Section has been revised to reflect your comments.




Appendix is not finished and will be revised prior to publication.
We had considered constructing the Directive in the manner that
you had suggested however the decision was made to split it into
two parts. Unfortunately it does add some repetition to the
document; however, planners should be intimately familiar with both
parts of the Directive
The CAPP shelter in place document is an example of the type of
instructions that must be included in the public information
package. Your company's shelter-in-place document will also meet
the requirements of D071.




Good comment. We will incorporate that suggestion in the
Directive.

The ERCB first call form is an example of the type of form thatcould
be used to gather information during an incident. A company may
use any type of form to gather information during an incident.




There is no need to evacuate the entire EPZ during an incident if
the wind is blowing in a constant direction. During that time the IIZ
and the PAZ will have been evacuated and the rest of the public in
the EPZ will have been notified and instructed to shelter if they
smell a sour gas odour. If the wind shifts, which is common in
Alberta, the licensee will have to focus on monitoring and
evacuating in a new PAZ; however by that time ignition criteria may
have been met and the well would be ignited.
Your company needs to determine the locations of public facilities
(ideally to GPS) the location and place it on the ERP map.
Discussions with the local authority should include management of
the EAZ and existing contact information



Section has been changed to reflect our comments.



Recommendation has been accepted for column 1, row 3 and
column 2, row 3. Please advise why you feel that column 2, row 4
should be placed in D056. You must consult with the owner of a
picnic area; however, if it is an open area (no owner) then
consultation is not required and the picnic area should be handed
similar to the way transients are handled.

The requirement to have an ignition team that has been certified in
sour well ignition is not a regulatory requirement but rather an
ERCB expectation. What you are suggesting would be acceptable.

See question 4

The ERCB did not establish any particular format or required
content for the communications flowchart and only recommended
that companies include it in the ERP. A combined
command/communications chart would probably work.




Section has been revised to reflect your comments
The ERCB's expectation is that all release rates will be based on
AOF's or calculated release rates based on static gradients or
reservoir pressures. If none of these are available then the ERCB
should be consulted to see if another method would be acceptable




Section has been revised to reflect your comments.



The new licensee will have access to the old licensee's ERP and
can use the resident information to send out the notification.




The ERCB feels that it is adequate




Given the ease of using ERCBH2S and the ability to use a batch
file, it was decided that an EPZ will have to be calculated for each
well.




Section has been revised to reflect your comments.
The statement "a reasonable amount of time" is not a regulatory
requirement. We would suggest that you provide at least 3 to 4
days for persons to review the public information and submit any
questions or concerns.




We have decided to change the word "specific" to "non-
confidential".'




As per our meeting the wording has been changed in this section.




Change has been made



Footnote 14 - change has been made.
General statement and answered in previous stakeholder
feedback.




General statement and answered in previous stakeholder
feedback.




General statement and answered in previous stakeholder
feedback.
Not accepted




Accepted. Chan ge has been made




See AHW comments

The work carried out by the EPA section is the follow to the three
principles.




A communications chart is nice to have but is not required if the
licensee provides all the details associated with communications.



That part of section 3.4 has been removed.
It is not a regulatory requirement to draw these locations on an ERP
map therefore the use of resident ,locations is acceptable.


Well locations from resident locations are subject to the ERCB's
setback requirements.




Change in definition will be considered




The licensee needs to know the roles and responsibilities of the
local authority and other government agencies prior to carrying out
its consultation with members of the public.

Added to the section

These agreements are often concluded over the phone. We ask
that the licensee include a summary of the agreements in the ERP.
Bread and Breakfast are businesses and would be notified and
consulted. The landlord (owner) is notified and the tenant is notified
and consulted. Table 4 already covers those scenarios.
That consultation takes place before the licensee carries out its PI
Program.
Residents of urban centres are notified that they are within the EPZ
through a combination of appropriate notifications. The Director of
Emergency Management is consulted.

When dealing with the public common terminology should be used.
that would be covered under the description of the potential health
impacts




General Comment

This will be taken into consideration.
This section has been modified to address stakeholder concerns.
The Petroleum Industry Incident Support Plan is activated at a
Level 2 or above and is used to provide support to the licensee and
local authority if required.




This would be difficult because the dispersion modelling would have
to be specific to the topography of the location and somehow have
to incorporate the meteorological conditions at the time of the
release.
topography is covered under elevation features


Because of liability concerns licensees have informed the ERCB
that they will not sign a written mutual aid agreement



Holders of plans are notified when the ERP is no longer required.




That is already referenced in the response portion of the Directive

This section is for the licensee to identify the roles and
responsibilities of its personnel and responders. Although the
ERCB supports ICS it does not make it mandatory that this system
be used.




This requirement was aimed primarily at residents within the EPZ
however we could add public facilities to the requirement.




Public facilities are covered under surface development




Wells would mean oil, gas and water disposal wells
The Directive states that the licensee must contact the LA,
RCMP/Police and local RHA if the release goes off site. The local
authority or RHA canu se their own spokesperson for media
releases if they so desire.

The licensee consults with the ERCB when it wishes to downgrade
or stand-down an emergency and the ERCB confers with other
applicable agencies to ensure that the decision is appropriate.
The Emergency Management Act gives the Local Authority
jurisdiction over any company ERP; however, the ERCB has
jurisdiction over its licensees and requires them to prepare an ERP
which assists the LA in handling the emergency.



If there is no wind the plume will mainly remain around the release
point i.e., the IIZ.


If you don't identify the zone then you will not know where sheltering
is not recommended in the event of a continous H2S release.
Setbacks determine where oil and gas development can be
located.
If you use the ERCBH2S model to calculate the PAZ all of the other
influenciing factors are accounted for. When you're out in the field
and miles away from a computer the ERCB suggests that you could
use the methodology in Figure 3.


We ask the licensee to include a summary of the agreed to roles
and responsibilties in its ERP.




Twenty-four hours is a reasonable period of time.

That would mean having a company prepare an ERP for another
companies property before the sales agreement was ratified. The
ERCB believes that the current process rotects public safety.




The ERCB believes that a two year period is appropriate.
That scenario is already dealt with in the Directive.




What you ask is beyond the scope of this Directive




Changes have been made to the Directive.




Not sure what is being asked here.
As we understand, the MEP for each local authority is tailor made
for that individual LA. How could the ERCB amend D071 to reflect
what is in their plans?



That is your responsibility and not the ERCBs



Change has been made.

Change has been made.


We have placed the RHA with the Director of Emergency
management. The public will detect the H2S by its odour. If ignition
criteria have not been met you go back to the b ox where you
started from.
The licencee notifies plan holders when site-specific plans aer no
longer in effect. Sour operations plans have no such mechanism.
The ERCB will be exploring the use of electronically submitted
plans in the future which will allow outdated plans to be easily
removed from circulation.

To the best of our knowledge CSA 1600 has not been published
and we do not believe that it was intended to replace CSA Z-731

An new ERP would be forwarded to the RHA.
Unsure as to why the RHA would want to be notified?
The well must be completed within one year if the licensee is using
a drilling and completion sour well ERP. If not the company has to
submit a new completions ERP.




That is the way that we differentiated between high and low risk.




It would be extremely difficult to have two separate agencies
reviewing ERPs.



The licensee must open a reception centre if they have asked
members of the public to evacuate. See section 14.9




This section has been revised to reflect stakeholder concerns on
the requirement for face-to-face consultation
Most comments from industry on using these two terms have been
positive with companies indicating that we have just formalized
what they already do in an emergency. The concept of an IIZ and
PAZ was taken from CSA Z-731 however in the case of a sour gas
release the IIZ has real meaning. It provides responders with
information as to where sustained sheltering is not a viable option.




We decided to leave it as a genetric term "Incident Management
System" rather than using "Emergency Operations Centre". I
discussed this with CAPP this morning and they didn't have any
problem leaving it as is.


The statement that you referenced "If the licensee or local authority
decides not to set up an EOC, the licensee must inform the local
field centre of this decision and provide reasons in support of it."
was removed from this version of D071. You probably saw it in the
previous version.




Question already addressed

Section has been revised to reflect stakeholder concerns

								
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