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The
use of rings that store any kind of liquid or oilfield waste other than
water or inert solids must now be approved by the ERCB.
ERCB Bulletin
Bulletin 2011-10
April 18
Use of C-Rings for Storage Systems in the Upstream Petroleum Industry
Alberta’s oil and gas industry is applying or adapting new
technology and practices to initiate production from unconventional oil
and gas resources and to improve recovery from mature reservoirs. The
Energy Resources Conservation Board (ERCB) supports these innovative and
flexible approaches, provided that they do not compromise public safety
and environmental protection.
The ERCB has become aware that certain operators have been
using c-rings to store large volumes of fluids associated with hydraulic
fracturing operations. C-rings consist of a synthetically lined corrugated
steel ring system. The liner covers the area within the steel ring,
extends up the wall of the steel ring, and is keyed onto the outside of
the wall. The ERCB recognizes that c-rings have been used in other
jurisdictions as an alternative to maintaining large numbers of
conventional tanks to store fluids on site and that c-rings may assist in
addressing surface footprints and managing water and waste.
Section 8.030 of the
Oil and Gas
Conservation Regulations requires materials that are used, produced,
or generated at a well site or facility, other than fresh water or inert
solids, to be stored in accordance with ERCB
Directive 055:
Storage Requirements for the Upstream Petroleum Industry. Currently,
c-rings are not classified as tanks and are not an approved storage system
under
Directive 055. Hence,
operators that propose to use c-rings to store fluids other than fresh
water or inert solids must first obtain ERCB approval to do so.
Upon reviewing an application, the ERCB may approve the use of c-rings
under
Directive 055 if the applicant can demonstrate that the level of
environmental protection and site safety provided by the proposed system
is at least equivalent to that set out in
Directive 055.
ERCB staff have already been in direct contact with a few companies,
asking for such supporting information.
The ERCB requests industry’s cooperation in identifying
and disclosing where they are using c-rings in their operations. The ERCB
also requests that industry assist the ERCB in its assessment and analysis
of the use of c-rings as a fluid storage alternative. In that regard, the
ERCB requests operators to disclose the following information:
- Each surface land location on which one or more c-rings are located
and the license number of any associated well or facility, as well as the
name of the licensee and contact information.
- A description of the use and design of the system, including date of
installation, dimensions, capacity, and construction materials, along with
the proximity of each c-ring to other equipment on the site and offset
land features.
- A description of any mitigative measures implemented by the operator
to enhance worker and/or public safety and environmental and wildlife (e.g,
migratory birds) protection.
- A description of the materials being stored in each c-ring, including
the chemical compositions of the materials.
- A description of the operational objectives and benefits the operator
expects to achieve through the use of c-rings as compared to standard
Directive
055 storage systems.
Operators currently using c-rings without written ERCB
approval and who are not currently in communication with ERCB staff
regarding this issue must disclose and e-mail the requested information in
a Word file to
Directive_055-StorageApps@ercb.ca by
June 20, 2011.
C-rings that are not disclosed and that are found through inspections,
audits, or other means will be subject to ERCB enforcement pursuant to
Directive
019: Compliance Assurance.
This bulletin
serves as notice to all ERCB licensees and prospective licensees that
effective immediately c-rings are not permitted for storage of fluids
without prior ERCB approval.
ERCB staff will review all applications received for the
use of c-rings. ERCB staff also intend to examine
Directive 055
to determine whether changes are required.
Directive 055 is available on the ERCB Web site
www.ercb.ca under Industry Zone : Rules,
Regulations, and Requirements : Directives. Printed copies of the
directive may be purchased from ERCB Information Services, 10 Floor, 250 –
5 Street SW, Calgary, Alberta; telephone: 403-297-8311; fax: 403-297-7040;
e-mail: infoservices@ercb.ca.
Stephen Smith
Executive Manager
Applications
Branch
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