Hydraulic fracturing in Alberta: ERCB draft directive

Limnos Environmental Ltd.

Recently, the ERCB has provided a draft directive proposed to govern hydraulic fracturing in unconventional oil and gas wells. New developments well drilling technology have allowed producers to drill one or more laterals horizontally along the producing zone. Because the producing zone is intersected over a surface area several orders of magnitude compared to a conventional well, oil and gas production is increased, meaning formerly uneconomic deposits in zones of low porosity and permeability are now viable and profitable. This type of drilling has become the norm in Alberta and throughout most of North America.

Hydraulic fracturing is used to increase both porosity and permeability in the laterals. A fluid is introduced and subjected to high pressure, which fractures the zone to be produced. Hydraulic fracturing has caused issues in certain types of wells, especially where the producing zone is near, or in potable groundwater. More significantly for Alberta, hydraulic fracturing requires the storage of large volumes of fluid on the drill site which may spill, causing environmental damage.

The ERCB has provided the draft directive here. The directive is presently open for feedback. The ERCB has also provided an animation describing drilling unconventional wells and hydraulic fracturing here.

An update for those in drilling waste managment in Alberta:

Manual 002: Drilling Waste Disposal Inspection has been released and is in effect January 1, 2013.  Directive 070: Drilling Waste Disposal Inspection Manual will be rescinded effective January 1, 2013.

What you should know about clubroot in Alberta: a guide for land owners and oil and gas operators: Limnos Environmental Ltd.

January 14, 2013

Clubroot is a serious soil-borne crop disease caused by Plasmidiophora brassicae. Important crops such as canola, mustard and cole crops are susceptible; and because the disease is soil borne it is difficult to control once it has been established in a field. Clubroot affects the root system of plants, manifesting as roots having a club-like appearance. Affected plants can be wilted, stunted, and yellowed, and may undergo premature ripening leading to lower quality and reduced yields.

Clubroot is not distributed equally throughout Alberta. Surveillance has been undertaken in Alberta since 2003, and a map detailing cumulative clubroot infestations can be found here. Detection of clubroot in Alberta is a relatively recent occurrence, with the first detection being in 2003 near Edmonton.

According to Swedish research, clubroot can persist in the soil for up to 20 years, so the best management practice is to prevent the spread of soil from one field to another. Proper sanitation requires 3 steps:

1.      Rough cleaning: Manual removal of soil using a hand scraper, wire brush or compressed air. This should remove 90% of the soil on the equipment.

2.      Fine cleaning:  Removal of remaining soil from pressure washing at 2000-3000 psi. A detergent may be used to help remove the soil. Steps 1 and 2 should remove 99% of the soil on the equipment.

3.      Disinfection: Disinfect the equipment using a 1-2% bleach solution. It is recommended that a herbicide sprayer is used. Disinfected areas should remain wet for approximately 20 minutes to ensure efficacy.

It is important for each stakeholder (i.e., landowner, oil and gas operator, oil and gas service provider) to assess the clubroot risk based on the area of the province and the type of work to be completed. It is important that best practices are developed and followed based on the exposure risk. Third party inspection of equipment is often recommended to ensure documentation of sanitation procedures and results. Limnos Environmental Ltd. has experience in developing clubroot management plans, and conducting inspections of equipment, including professional sign off (P.Ag.).

Drilling Waste Management Programs in Alberta, Limnos Environmental Ltd.:

If the life cycle of a typical well site in Alberta is considered, there are a number of activities that will contribute to the potential environmental liability of the site. Given that all sites are expected to be reclaimed to an equivalent land use at the end of their life, managing environmental liability is a significant issue confronting operators. Additionally, understanding environmental liability allows the operator to better plan anticipated expenditures and to more effectively manage acquisition and divestures as needed.

In spite of the above situation, many operators do not regard drilling waste management as an important consideration. In reality, drilling waste disposal can often be the largest source of environmental liability during the operation of a well site.

Operators that plan drilling waste management as an integral part of well site development and step away from ad hoc disposal practices will realize better compliance, reduced reclamation costs, and reduced environmental liability. ERCB Directive 050 in Alberta provides for a wide range of disposal options, but it is important to realize that the document may not provide the level of diligence required to ensure reclamation suitability.

We have provided operators both large and small with guidance on the development of drilling waste management plans, as well as third party auditing of well files to ensure compliance and to ascertain levels of environmental liability. These steps have proven to assist operators in lowering costs, ensuring compliance and understanding the environmental liability accrued on any site. We invite you to discuss your current drilling waste management plan with us and determine if Limnos Environmental Ltd. can help you achieve the goals of your program.

Indoor Air Quality, Limnos Environmental Ltd.:

Recently there has been a much greater focus on indoor air quality (IAQ) in both residential and commercial structures. Poor air quality can lead to a number of health concerns, such as bronchitis, allergenic symptoms, fatigue, and at the extreme mesothelioma. What makes diagnosing IAQ issues difficult is the number of variables that can contribute to poor air quality.

Generally IAQ can be split into poor IAQ due to mould, and poor IAQ arising from other factors. Mould issues are generally easiest to diagnose, as mould is quite visible in most cases with some destructive and intrusive testing. There are a number of approaches to correcting mould issues, but in general best practices would recommend that any mould bearing surface that is porous or semi-porous is removed and disposed of. Impervious surfaces can be cleaned.

Mould assessments should be conducted by a qualified professional, but most often:

• It is not recommended to treat mould with a fungicide, or other cleanser. Mould should be physically removed from the surface.
• Mould will grow wherever water intrusion is occurring. It is imperative that the source of moisture is located and sealed or mould regrowth is inevitable.
• Mould can cause mild to severe reactions in individuals, and exposure should be managed through the proper use of personal protective equipment (PPE).
• Air testing for mould is generally not needed if mould is visible. Mould should first be removed wherever it is present. The role of subsequent air testing is to confirm that levels of mould in the structure are comparable to background levels.

Finally, marihuana grow operations (MGO) often require disclosure and additional remediation steps depending on the jurisdiction where they are located. MGO often create severe mould growth and chemicals used as pesticides or fertilizers can cause significant secondary contamination issues. It is recommended that a qualified professional is consulted if an MGO is present or suspected.

Other air quality concerns are most often related to high concentrations of airborne contaminants or gases being present in the environment. These issues can create health concerns, which have a wide range of symptoms. If mould has been ruled out as a cause of poor IAQ, it is necessary to conduct air sampling for other potential causes such as elevated:

• Volatile organic compounds (VOC)
• Carbon monoxide and dioxide (CO and CO₂)
• Dust particles
• Temperature and humidity variability

Investigation of the above parameters is usually done by testing the air over a longer period of time (such as a 24 hour period). The IAQ professional then relates values for each of the above parameters to guidelines and standards that are applicable, and works to determine the source of any elevated parameter. For example, VOC’s often are emitted from newer building materials such as carpets, adhesives and paints.

Solutions to these IAQ problems related to the parameters are best conducted by a qualified IAQ professional. If you feel you may have an IAQ issue, please feel free to visit Limnos Environmental Ltd., where we would be happy to assist you.