1 BALZAC SOUR GAS PROCESSING PLANT AND THE BALZAC SULPHUR PROCESSING PLANT (‘BALZAC GAS PLANT’) APPLICATION TO ALBERTA ENVIRONMENT FOR AMENDMENT OF APPROVAL NUMBER: 155-02-00 FOR DECOMMISSIONING, DISMANTLING, ABANDONMENT, REMEDIATION & RECLAMATION OF THE BALZAC GAS PLANT March 5, 2012
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
A. APPLICANT INFORMATION ..................................................................................................................... 8 B. LOCATION, CAPACITY AND SIZE OF THE ACTIVITY ................................................................................. 9
1. Legal Land Description .................................................................................................................... 9 2. Relation to nearest town, city, village, and residents/users of the land. ........................................... 9 3. Geographical description of the surrounding topography (including a topographical map) and
relation to nearby watercourses................................................................................................................. 9 4. Gas Processing Capacity (Raw), Hydrogen Sulphide Processing Capacity, Sulphur Inlet Rate. .... 9 5. Sulphur Production Capacity, Liquid Hydrocarbon Production, Sulphur Storage Status, Bitumen
Processing Capacity, Other. ...................................................................................................................... 9 6. Material Balance. ........................................................................................................................... 10 7. Descriptive size of the affected area, leased area, and/or plant site (Le., hectares), or ................. 10 8. Physical dimensions of the plant site including a plant site map (i.e., plot plan) and number of
employees working at the facility. ............................................................................................................ 10
C. THE NATURE OF THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE
AMENDMENT, ADDITION OR DELETION, AS THE CASE MAY BE: ............................................... 13
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 13 3.1 Describe the change(s). .................................................................................................................. 13
3.1.1 HISTORY OF THE PLANT ................................................................................................................. 13 3.1.2 CURRENT PHASE OF THE PROJECT .............................................................................................. 13 3.1.3 FACILITIES TO REMAIN IN OPERATION DURING THE DRR PROJECT PHASE ..................... 15 3.1.4 FACILITIES TO REMAIN IN OPERATION DURING THE DLR PROJECT PHASE ..................... 17
3.2 Describe the affect that the change(s) may have on the environment. ........................................... 20 3.3 Describe the affect that the change(s) may have on the Environment Control Systems. ................ 20 3.4 Describe the implications, which the change(s) may have on the current approval. ..................... 20 3.5 Describe when the changes will take place. ................................................................................... 23
D. WHERE THE APPLICATION REQUIRES AN APPROVAL FROM THE ALBERTA ENERGY
AND UTILITIES BOARD OR THE NATURAL RESOURCES CONSERVATION BOARD IN
RELATION TO THE ACTIVITY, THE DATE OF THE WRITTEN DECISION IN RESPECT OF
THE APPLICATION ...................................................................................................................................... 23
1. DATE OF ALBERTA ENERGY AND UTILITIES BOARD (EUB) APPROVAL............................................... 23 2. APPROVAL NUMBER ............................................................................................................................ 23
E. AN INDICATION OF WHETHER AN ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
REPORT HAS BEEN REQUIRED ............................................................................................................... 23
1. WAS AN EIA REQUIRED? ..................................................................................................................... 23
F. COPIES OF EXISTING APPROVALS THAT WERE ISSUED TO THE APPLICANT IN
RESPECT OF THE ACTIVITY UNDER THIS ACT OR A PREDECESSOR OF THIS ACT ............. 23
G. THE PROPOSED OR ACTUAL DATES FOR CONSTRUCTION COMMENCEMENT,
CONSTRUCTION COMPLETION, AND COMMENCEMENT OF OPERATION .............................. 24
3.1 PROVIDE ACTUAL DATE FOR ORIGINAL COMMENCEMENT OF OPERATION, IF KNOWN. .......................... 24 3.2 PROVIDE PROPOSED EFFECTIVE DATE FOR "ACTIVITY CHANGE" AND/OR AMENDMENT. ..................... 24
H. A LIST OF SUBSTANCES, THE SOURCES OF THE SUBSTANCES AND THE AMOUNT OF
EACH SUBSTANCE THAT WILL BE RELEASED INTO THE ENVIRONMENT AS A RESULT OF
3
THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE AMENDMENT, ADDITION OR
DELETION, AS THE CASE MAY BE, THE METHOD BY WHICH THE SUBSTANCES WILL BE
RELEASED AND THE STEPS TAKEN TO REDUCE THE AMOUNT OF THE SUBSTANCES
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 24 3.1 Provide a description of current substance releases. ..................................................................... 24 3.2 Describe the implications to the above description as a result of the Activity Change. ................. 24 3.3 Provide the final modified description that will result after the Activity Change is operational. .. 24
I. A SUMMARY OF THE ENVIRONMENTAL MONITORING INFORMATION GATHERED
DURING THE PREVIOUS APPROVAL PERIOD .................................................................................... 25
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 25 1. Only monitoring information on the affected parameters is required. ........................................... 25
J. A SUMMARY OF THE PERFORMANCE OF SUBSTANCE RELEASE CONTROL SYSTEMS
USED FOR THE ACTIVITY DURING THE PREVIOUS APPROVAL PERIOD: ................................ 25
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 25 3. Present the same information, as required above for Renewals, however, limit it to only those
environmental control systems affected by the Activity Change .............................................................. 25
K. THE JUSTIFICATION FOR THE RELEASE OF SUBSTANCES INTO THE ENVIRONMENT
AS A RESULT OF THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE AMENDMENT,
ADDITION OR DELETION, AS THE CASE MAY BE. ............................................................................ 25
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 25 2. Same as for new plants except the discussion should be limited to only those items which will be
affected by the Activity change. ................................................................................................................ 25
L. THE MEASURES THAT WILL BE IMPLEMENTED TO MINIMIZE THE AMOUNT OF
WASTE PRODUCED, INCLUDING A LIST OF THE WASTES THAT WILL OR MAY BE
PRODUCED, THE QUANTITIES AND THE METHOD OF FINAL DISPOSITION ........................... 26
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 26 3. Discuss the environmental aspects of the present approval which will be affected by the change(s).
26
M. ANY IMPACT, INCLUDING SURFACE DISTURBANCE, THAT MAY OR WILL RESULT
FROM THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE AMENDMENT, ADDITION
OR DELETION, AS THE CASE MAY BE .................................................................................................. 27
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 27 3.1 Limit discussion to the extent and nature of the surface disturbance which is proposed by
construction, other impacts should be identified in the other relevant areas of this application form such
as section (k). ........................................................................................................................................... 27 3.2 Describe the change to surface disturbance both temporary and permanent caused by the "Activity
N. CONFIRMATION THAT ANY EMERGENCY RESPONSE PLANS THAT ARE REQUIRED
TO BE FILED WITH THE LOCAL AUTHORITY OF THE MUNICIPALITY IN WHICH THE
ACTIVITY IS OR IS TO BE CARRIED ON OR WITH ALBERTA PUBLIC SAFETY SERVICES
HAVE BEEN SO FILED ................................................................................................................................ 28
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 28 4. Provide only if there is a change in plant status (i.e. convert from a sweet gas to a sour gas
processing plant) that necessitates a change. .......................................................................................... 28
4
O. CONFIRMATION THAT THERE ARE CONTINGENCY PLANS IN PLACE TO DEAL WITH
ANY UNEXPECTED SUDDEN OR GRADUAL RELEASES OF SUBSTANCES TO THE
P. THE CONSERVATION AND RECLAMATION PLAN FOR THE ACTIVITY ........................... 29
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 29 3.1 Describe any topsoil conservation plans for any areas affected by the change, if applicable. .......... 29 3.2 A plan to prevent, remove or treat areas of contamination to within established guidelines
(Environmental Sciences Division of AENV). .......................................................................................... 29
Q. A DESCRIPTION OF THE PUBLIC CONSULTATION UNDERTAKEN OR PROPOSED BY
THE APPLICANT. ......................................................................................................................................... 29
APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 29 3.1 Same as for New Plants ..................................................................................................................... 29
APPENDIX I – EXISTING AENV APPROVALS ....................................................................................... 32
APPENDIX II – PUBLIC CONSULTATION FACT SHEET .................................................................... 33
APPENDIX III – DECOMMISSIONING, REMEDIATION AND LAND RECLAMATION PLAN .... 34
APPENDIX IV – BALZAC POWER STATION MAPS ............................................................................. 35
APPENDIX V – PROPOSED 2012 GROUNDWATER MONITORING PROGRAM ............................ 36
Table 1. Company Information .............................................................................................. 8 Table 2. Approval Summary ................................................................................................ 23
Figure 1. Regional Aerial Photo of Location ....................................................................... 11
Figure 2. Aerial Photo of Balzac Gas Plant (2009) ............................................................. 12 Figure 3. Infrastructure Expected to Remain ....................................................................... 19
5
INTRODUCTION
The BALZAC SOUR GAS PROCESSING PLANT (FOR THE PROCESSING OF NATURAL
GAS) AND THE BALZAC SULPHUR PROCESSING PLANT (“Balzac Gas Plant”) are operated
by Nexen Inc. (“Nexen”) of Calgary, pursuant to approval No. 6457, issued by the Energy and
Utilities Board (hereafter referred to as the Energy Resources Conservation Board (“ERCB)) and
Alberta Environment (“AENV”) approval 155-02-00.
The Balzac Gas Plant ceased operations permanently on April 28th, 2011 (“Plant Closure”).
Therefore, Nexen is submitting this amendment application for approval to decommission,
dismantle, remediate and reclaim the Balzac Gas Plant (“Plant”).
This amendment application is being prepared in accordance with the Applications for Sour Gas
Processing Plants and Heavy Oil Processing Plants - A Guide to Content (AENV 1999).
The Balzac Gas Plant is located adjacent to the Calgary's city limits, in LSD 7-2-26-29 W4M. Other
nearby communities includes the towns of Balzac and Airdrie, Alberta.
The Balzac Gas Plant was a sour, natural gas processing plant that receives gas streams from
surrounding well sites and produce specification sales gas with the recovery of propane, butane,
condensate, and sulphur. The operation used conventional gas processing units with inlet separation,
gas compression, amine sweetening (hydrogen sulphide (H2S) and carbon dioxide (CO2) removal),
refrigeration/dehydration, condensate stabilization, sulphur recovery, and LPG fractionation.
Propane and butane were stored in horizontal pressure tanks in the tank farm and were loaded into
truck or rail car for delivery to markets. Condensate was stored in tankage and transferred to the
Pembina Pipeline system for delivery to refineries. Sales gas was sent to the Trans Canada
Transmission pipeline system, and liquid (molten) sulphur was processed into a sulphur granulation
product (prilled) and shipped by rail to Vancouver. Enersul operated and owns the sulphur
granulation facility.
The sulphur granulation process was discontinued after May 2011.
Approximately eighty-one producing gas wells (“Balzac Field”) supplied the raw natural gas
mixture to the plant for processing. Most of the gas produced from the wells is considered "sour"
meaning naturally-occurring H2S is present. H2S content varies from well to well and from different
formations. Within the Balzac field, H2S in the produced sour gas varies from 0.6% to 42%.
In the Balzac Field, all Crossfield and Elkton pipelines have been shut in and purged with Nitrogen.
Basal Quartz pipelines were pigged with fuel gas. All Crossfield wells have been blinded at the
wellhead. Elkton wells and Basal Quartz wells have been shut-in as per ERCB requirements.
The Plant has been shut down in a safe, controlled fashion, equipment and piping was
decontaminated and any sources of energy, such as steam and electricity, isolated and shut off as
required. The shutdown was managed by the Shutdown, Decommissioning and Salvage (“SDS”)
team comprised of a group of operations, maintenance, environmental and safety personnel from the
Plant, in addition to contractors familiar with the Plant and experienced to execute work in a safe,
6
efficient manner. Decommissioning activities to bring the Plant to a state of zero energy and make it
safe for demolition began in May, 2011 and finished December 2011.
Under Nexen’s current operating approval with Alberta Environment, Nexen is required to submit a
Decommissioning, Remediation and Land Reclamation Plan (“DLR”) amendment within six (6)
months of closure of the facility. Nexen submitted a draft amendment application dated September
12, 2011 which was reviewed by AENV with feedback provided. The current version of this
application incorporates changes to reflect the feedback from AENV. Approval of the DLR
amendment is expected in 2012.
7
ABBREVIATIONS
ABSA Alberta Boilers Safety Association
AENV Alberta Environment
AMD Air Monitoring Directive
BalCAP Balzac Community Advisory Panel
BGP Balzac Gas Plant
BPS Balzac Power Station
DLR Decommissioning, Remediation and Land Reclamation Plan
DRR Demolition, Remediation and Reclamation
EPEA Environmental Protection & Enhancement Act
ERCB Energy Resources Conservation Board
ERP Emergency Response Plan
SDS Shutdown, Decommissioning and Salvage
SHA Sulphur Handling Area
8
3 (1) An application must be made to the Director and must be accompanied by the following
information relative to the activity, the change in the activity or the proposed amendment,
addition or deletion of the term or condition:
A. Applicant Information
Table 1. Company Information
Company Name(s) Nexen Inc.
(Operator of Facility)
Head Office Address 801 – 7
th Avenue S.W.,
Calgary, Ab T2P 3P7
Plant Address Nexen Inc.
RR3, Site 17, Comp 16 Rockyview County, AB T4A 0P7
Contact Numbers
Head Office: P: 403-699-4000; F: 403-699-5800
Gas Plant Office: P: 403-226-3165 (General Inquiries)
Emergency: 403-226-0967
Application Due Date October 28, 2011
Contact Person for
Application
Mr. Todd Jorgensen-Nelson, C.E.T. Sr. Coordinator – HSE&SR
Balzac Gas Plant RR3, Site 17, Comp 16
Rockyview County, AB. T4A 0P7 Phone (403) 699-6978, Fax (403) 716-0691
Fugitive emissions from sulphur base pad, including AMD soils – measures sulphur deposition and
dust and potential fugitive for demolition and remediation and reclamation phases.
Surface water runoff and domestic wastewater as per current approvals.
3.2 Describe the implications to the above description as a result of the Activity
Change.
No change to the above description.
3.3 Provide the final modified description that will result after the Activity Change
is operational.
Upon successful Shut-down, decommissioning, dismantlement, and remediation the land will be
reclaimed to support equivalent land capability while considering end land use strategies that may be
applicable. As such, no substance releases will occur.
25
I. A summary of the environmental monitoring information gathered during the
previous approval period
Nexen has conducted numerous air quality, soils and groundwater investigations at the facility since
1990. Please refer to the Decommissioning, Remediation and Land Reclamation Plan (Appendix
III) which summarizes this information in detail.
Applications for Activity Change or an Amendment
1. Only monitoring information on the affected parameters is required.
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
J. A summary of the performance of substance release control systems used for
the activity during the previous approval period:
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
Applications for Activity Change or an Amendment
3. Present the same information, as required above for Renewals, however, limit it to
only those environmental control systems affected by the Activity Change
Not Applicable.
K. The justification for the release of substances into the environment as a result
of the activity, the change to the activity or the amendment, addition or
deletion, as the case may be.
Not Applicable.
Applications for Activity Change or an Amendment
2. Same as for new plants except the discussion should be limited to only those items
which will be affected by the Activity change.
Not Applicable.
26
L. The measures that will be implemented to minimize the amount of waste
produced, including a list of the wastes that will or may be produced, the
quantities and the method of final disposition
Applications for Activity Change or an Amendment
3. Discuss the environmental aspects of the present approval which will be affected by the
change(s).
Nexen is developing a Waste Management Plan to handle wastes associated with the various phases
of this Project.
Nexen Inc. (NEXEN) is committed to demonstrating continuous improvement in reducing the
generation of waste from its operations, beneficially reusing or recycling materials that might
otherwise end up in the waste stream. Nexen will properly store, handle, and dispose of those
wastes that remain in accordance with Provincial or Federal regulations.
Active waste minimization is forefront, when the proper waste handling techniques are employed.
NEXEN is committed to ensuring compliance with regulations, as well as ensuring protection of the
environment when dealing with its waste products.
NEXEN is also committed to properly training all personnel who handle wastes and those
responsible for their supervision.
To actively pursue these commitments, NEXEN is developing a Waste Management Plan to ensure
compliance with all associated environmental regulations. The plan will serve as a valuable tool for
the collection of data, providing guidance to employees, identification of future technology needs
and requirements, as well as reducing risk exposure, and identifying the company’s operating
procedures and standards.
The plan is being designed based on discussions with operations and environmental personnel from
NEXEN. Site visits to a representative sample of facilities may be conducted or third party audits
may be obtained and reviewed to ensure waste facility audits are in place and reviewed. The plan
will ensure regulatory compliance.
This waste management plan is comprised of the following components:
Identification
Characterization and classification
Handling
Storage
Treatment
Disposal
Manifesting
Tracking and record keeping
Reporting
27
The principles of waste minimization will be followed closely in the plan. This is both an
environmental consideration as well as an economical one. Recognizing opportunities to reduce
waste volumes as well as the elimination of certain wastes will enable NEXEN to ensure that it is
operating in an environmentally safe and responsible manner. This will reduce the liabilities
associated with the handling, storage and disposal of dangerous oilfield wastes (DOWs).
Nexen will continue to follow its Waste Management Plan during the transition into the demolition
phase.
Wastes expected to be handled include (list not exhaustive):
Domestic-type wastes (non-hazardous, "garbage")
Salvage metals, i.e. Iron, Copper, Tin, Steel
Construction waste (general building materials, e.g. concrete, plaster, wood, etc.)
Glass and ceramics
Asbestos-containing or contaminated materials (insulations, building materials, abatement
waste materials)
Asbestos-contaminated water (filtered)
Synthetic (non-asbestos) insulating materials
Lead-acid batteries
Mercury, liquid in instrumentation
Mercury lamp bulbs and tubs
PCB Transformer oil (potential)
PCB-containing lamp ballasts (potential)
Ozone-depleting refrigerants (HVAC units)
Other Dangerous Oilfield Wastes ("DOW"), e.g. residual chemicals or contaminated
materials as identified during demolition
M. Any impact, including surface disturbance, that may or will result from the
activity, the change to the activity or the amendment, addition or deletion, as
the case may be
Applications for Activity Change or an Amendment
3.1 Limit discussion to the extent and nature of the surface disturbance which is
proposed by construction, other impacts should be identified in the other
relevant areas of this application form such as section (k).
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
3.2 Describe the change to surface disturbance both temporary and permanent
caused by the "Activity Change".
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
28
N. Confirmation that any emergency response plans that are required to be filed
with the local authority of the municipality in which the activity is or is to be
carried on or with Alberta Public Safety Services have been so filed
Applications for Activity Change or an Amendment
4. Provide only if there is a change in plant status (i.e. convert from a sweet gas to a sour
gas processing plant) that necessitates a change.
The current version of the Nexen Inc. Balzac Complex Emergency Response Plan (ERP)
was formally approved by the ERCB on November 17, 2011. The plan meets the
requirements of ERCB Directive 71: Emergency Preparedness and Response Requirements
for the Petroleum Industry, 2008 Edition.
The Balzac Gas Plant ERP was updated and re-issued in October 19, 2011.
The approved Balzac Complex Emergency Response Plan is currently registered with the
ERCB (DDS #211) and distributed to all agencies listed below.
1. ERCB;
2. Alberta Health Services;
3. City of Calgary, including:
a. Airport Authority
b. Emergency Management Agency
c. Emergency Operations Centre.
4. Town of Airdrie;
5. County of Rocky View;
6. Town of Chestermere; and,
7. RCMP.
O. Confirmation that there are contingency plans in place to deal with any
unexpected sudden or gradual releases of substances to the environment
The Emergency Response Plan which is in place for the Balzac Gas Plant addresses the prevention
of and response to accidental spills, releases, or other abnormal occurrences which are foreseeable.
The Nexen Balzac Complex has an ERCB approved and up-to-date ERP. A number of plans and
procedures can be found within the ERP that deal with unexpected, sudden, or gradual releases of
substances to the environment. Generally, any major upset conditions at the facility and at all field
locations are covered by the ERP (e.g., gas releases, fires, explosions, spills, etc.). The Nexen
Balzac Complex also has a Spill Response Plan in place dated February 2007. This document also
references a number of policies, procedures, and action plans that are in place to deal with spills and
it identifies responsibilities at different levels within the company.
Regular visitations to residents and affected stakeholders within the ERP were conducted every two
years with approximately fifty-percent of all residents being contacted in person on an annual basis.
This process ensures for the accuracy of the response plan and helps to identify and address any
existing questions or concerns in the community. Going forward into 2012 resident visitations will
be conducted annually.
29
In 2002, the Nexen Balzac Gas Plant became the first Oil & Gas facility in the world verified
Responsible Care® In-Place.
Responsible Care® (RC) is a unique ethic developed within the chemicals industry that drives
continual improvement in health, safety, environmental and business performance, while openly and
transparently communicating with stakeholders about products and processes.
Critical to RC is an expectation for member companies to have a functioning, effective management
system in place and that it is structured to include all components of the Plan/Do/Check/Act cycle of
continual improvement.
Both the “ethic” and effectiveness of the management system is verified every three years by a team
of external industry experts and leaders within the community through a process of staff interviews,
document reviews and meetings with external stakeholders. The next verification for the Balzac Gas
Plant is scheduled for the fall of 2013.
P. The conservation and reclamation plan for the activity
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
Applications for Activity Change or an Amendment
3.1 Describe any topsoil conservation plans for any areas affected by the change, if
applicable.
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
3.2 A plan to prevent, remove or treat areas of contamination to within established
guidelines (Environmental Sciences Division of AENV).
Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).
Q. A description of the public consultation undertaken or proposed by the
applicant.
Applications for Activity Change or an Amendment
3.1 Same as for New Plants
At Nexen, public consultation is the conduit to actively involving the public and community in the
processes and decisions that may impact their lives or livelihood. Communities have a legitimate
right-to-know about our planned and on-going activities and to participate in decision-making for
30
issues that affect them. Nexen believes that in identifying shared concerns, we are better able to find
shared solutions or opportunities.
Nexen's commitment to ongoing and continued communication with area residents, neighbours,
stakeholders and business's is one way in which we conduct our activities and work with the
community to maintain an open, honest and transparent relationship. In 2002, the Nexen Balzac Gas
Plant became the first upstream Oil & Gas facility in the world to be verified in achieving the status
of Responsible Care®.
Responsible Care®, originally developed by the Chemical Industry Association of Canada (CIAC),
is a global, chemical industry initiative. It is a comprehensive performance improvement initiative
designed to address public concerns related to impacts associated with the chemical industry.
Although the Nexen Balzac Gas Plant was the first upstream Oil and Gas facility to implement
Responsible Care®, Nexen's other Divisions have taken a leadership role in Responsible Care® with
In-place certification assigned in October of 2010.
In addition, Nexen was instrumental in the development and support of the Balzac Community
Advisory Panel (BalCAP). The mission (focus) of the Balzac Community Advisory Panel was to
provide a forum for open, honest and transparent communication, on-going dialogue and timely
discussion of issues related to existing and proposed development and operations in the Balzac and
surrounding area. However, due to Plant shutdown, BalCAP has now been disbanded as of 4th
Quarter of 2011 and consultation will conducted through open houses (see below).
Communications and consultation processes for the Nexen Balzac Complex are divided into three
basic categories, they are:
1. Annual and ongoing contacts;
2. Emergency response planning contacts; and,
3. Project and maintenance contacts.
Regular visitations to residents and affected stakeholders within the ERP were conducted every two
years with approximately fifty-percent of all residents being contacted in person on an annual basis.
This process ensures for the accuracy of the response plan and helps to identify and address any
existing questions or concerns in the community. Going forward into 2012 resident visitations will
be conducted annually.
Direct mail, local newspaper advertising, open houses, and visitations were also used to delineate
information regarding regular field maintenance upgrades, new drilling programs, and testing.
Abandonment and reclamation activities are also conducted in such a manner as to ensure that
residents living adjacent to these activities are informed of the schedule of activities and rationale
for the work.
Amendment Application: Consultation Activities
Following an administrative review of the Nexen Balzac Gas Plant amendment application by
Alberta Environment, Nexen's public involvement process will begin by advertising in the following
local and regional newspapers to advise interested parties of the amendment application and thirty-
day review process:
Calgary Herald;
31
Calgary Sun;
Airdrie City View; and,
Rocky View Weekly.
Stakeholder Notification:
In addition to the newspaper advertisement all the residents, businesses, local authorities within the
Balzac Complex & Gathering System Emergency Planning Zone (approximately 1500 contacts)
were mailed three editions of the Nexen Community Matters news publication since January 1st,
2011 and an invitation to attend our Open House held at the Balzac Community hall on October 18th
2011. Nexen is planning on another Open House in early 2012.
All information presented at the Open House is posted on the Nexen Balzac website
www.nexeninc.com/balzac
Comments and feedback to the amendment application will be collected through a variety of
mechanisms. Nexen has provided the phone numbers for the Plant Manager(s) and Social
Responsibility department, as well as an email address where queries and/or comments can be
forwarded. All comments received will be recorded, catalogued and available on request.
32
APPENDIX I – EXISTING AENV APPROVALS
APPROVAL
PROVINCE OF ALBERTA
ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACT R.S.A. 2000, c.E-12, as amended.
APPROVAL NO. 155-02-00 APPLICATION NO. 008-155 EFFECTIVE DATE: October 31, 2005 EXPIRY DATE: September 30, 2015 APPROVAL HOLDER: Nexen Inc.
ACTIVITY: CONSTRUCTION, OPERATION AND RECLAMATION OF THE BALZAC SOUR GAS PROCESSING PLANT FOR THE PROCESSING OF NATURAL GAS AND THE BALZAC SULPHUR PROCESSING PLANT. ……………………………………………………………………………………………… ……………………………………………………………………………………………… IS SUBJECT TO THE ATTACHED TERMS AND CONDITIONS. Designated Director under the Act Alan Pentney, P.Eng. Date Signed October 31, 2005
APPROVAL NO. 155-02-00 Page 1 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL PART 1: DEFINITIONS
SECTION 1.1: DEFINITIONS
1.1.1 All definitions from the Act and the regulations apply except where expressly defined in this approval.
1.1.2 In all PARTS of this approval:
(a) "Act" means the Environmental Protection and Enhancement Act, R.S.A. 2000, c.E-12, as amended;
(b) "air contaminant" means any solid, liquid or gas or combination of any of them in the atmosphere resulting directly or indirectly from the activities of man;
(c) "application" means the written submissions to the Director in respect of application number 008-155 and 010-155 and any subsequent applications for amendments of approval number155-02-00;
(d) "CEM" means continuous emissions monitor;
(e) "CEMS Code" means the Continuous Emission Monitoring System Code, Alberta Environment, 1998, as amended;
(f) "chemical" means any substance that is added or used as part of the treatment process;
(g) "commence operation" means to start up the plant, process unit or equipment for the first time with the introduction of feed material, electrical or thermal energy and the simultaneous production of products for which the plant, process unit or equipment was designed excluding predetermined period of commissioning or testing;
(h) "container" means any portable device in which a substance is kept, including but not limited to drums, barrels and pails which have a capacity greater than 18 litres but less than 210 litres;
(i) "day" means any sampling period of 24 consecutive hours unless otherwise specified;
(j) "decommissioning" means the dismantling and decontamination of a plant undertaken subsequent to the termination or abandonment of any activity or any part of any activity regulated under the Act;
(k) "decontamination" means the treatment or removal of substances from the plant and affected lands;
APPROVAL NO. 155-02-00 Page 2 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(l) "Director" means an employee of the Government of Alberta designated as a Director under the Act;
(m) "dismantling" means the removal of buildings, structures, process and pollution abatement equipment, vessels, storage facilities, material handling facilities, railways, roadways, pipelines and any other installations that are being or have been used or held for or in connection with the plant;
(n) "fugitive emissions" means emissions of substances to the atmosphere other than ozone depleting substances, originating from a plant source other than a flue, vent, or stack but does not include sources which may occur due to breaks or ruptures in process equipment;
(o) "industrial runoff" means precipitation that falls on or traverses the plant developed area;
(p) "industrial runoff control system" means the parts of the plant that collect, store or treat industrial runoff from the plant;
(q) "industrial wastewater" means the composite of liquid wastes and water-carried wastes, any portion of which results from any industrial process carried on at the plant;
(r) "industrial wastewater control system" means the parts of the plant that collect, store or treat industrial wastewater;
(s) “ISO 17025” means the international standard, developed and published by International Organization for Standardization (ISO), specifying the management and technical requirements for laboratories;
(t) "local environmental authority" means the Department of Environment, in the Province of Alberta, or the agency that has the equivalent responsibilities for any jurisdiction outside the Province;
(u) "manual stack survey" means a survey conducted in accordance with the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended;
(v) "monitoring system" means all equipment used for sampling, conditioning, analyzing or recording data in respect of any parameter listed or referred to in this approval including equipment used for continuous monitoring;
(w) "month" means calendar month;
(x) "net or lower heating value" means the quantity of heat evolved on complete combustion where the combustion products remain as vapour at 15°C;
APPROVAL NO. 155-02-00 Page 3 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(y) "plant” means all buildings, structures, process and pollution abatement equipment, vessels, storage facilities, material handling facilities, roadways, pipelines and other installations, and includes the land, located on East half of Section 2, Township 26, Range 29, West of the 4th Meridian, that is being or has been used or held for or in connection with the Balzac sour gas processing plant and sulphur processing plant;
(z) "plant developed area" means the areas of the plant used for the storage, treatment, processing, transport, or handling of raw material, intermediate product, by-product, finished product, process chemicals, or waste material;
(aa) "QA/QC" means quality assurance and quality control;
(bb) "quarter year" means a time period of three consecutive months designated as January, February, and March; or April, May, and June; or July, August, and September; or October, November, and December;
(cc) "representative grab sample" means a sample consisting of equal volume portions of water collected from at least four sites between 0.20-0.30 metres below the water surface within a pond;
(dd) "soil" means mineral or organic earthen materials that can, have, or are being altered by weathering, biological processes, or human activity;
(ee) "suitable quality" means topsoil having a good, fair or poor rating as described in the Soil Quality Criteria Relative to Disturbance and Reclamation, Alberta Agriculture March, 1987, as amended;
(ff) "tank" means a stationary device, designed to contain an accumulation of a substance, which is constructed primarily of non-earthen materials that provide structural support including wood, concrete, steel, and plastic;
(gg) "topsoil" means the uppermost layer of suitable quality soil, containing organic matter, ordinarily moved in tillage or its equivalent in uncultivated soils;
(hh) "volume estimate" means a technical evaluation based on the sources contributing to the release, including, but not limited to, pump capabilities, water meters, and batch release volumes;
(ii) "week" means any consecutive 7-day period unless otherwise specified.
PART 2: GENERAL
SECTION 2.1: GENERAL
APPROVAL NO. 155-02-00 Page 4 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 2.1.1 The approval holder shall immediately report to the Director by telephone any
contravention of the terms and conditions of this approval at 1-780-422-4505.
2.1.2 The approval holder shall submit a written report to the Director within 7 days of the reporting pursuant to 2.1.1.
2.1.3 The terms and conditions of this approval are severable. If any term or condition of this approval or the application of any term or condition is held invalid, the application of such term or condition to other circumstances and the remainder of this approval shall not be affected thereby.
2.1.4 The approval holder shall immediately notify the Director in writing if any of the following events occurs:
(a) the approval holder is served with a petition into bankruptcy;
(b) the approval holder files an assignment in bankruptcy or Notice of Intent to make a proposal;
(c) a receiver or receiver-manager is appointed;
(d) an application for protection from creditors is filed for the benefit of the approval holder under any creditor protection legislation; or
(e) any of the assets which are the subject matter of this approval are seized for any reason.
2.1.5 If the approval holder monitors for any substances or parameters which are the subject of operational limits as set out in this approval more frequently than is required and using procedures authorized in this approval, then the approval holder shall provide the results of such monitoring as an addendum to the reports required by this approval.
2.1.6 All abbreviations used in this approval follow those given in Standard Methods for the Examination of Water and Wastewater published jointly by the American Public Health Association, the American Water Works Association, and the Water Environment Federation, 1998, as amended, unless otherwise specified in this approval.
2.1.7 Environmental Protection and Enhancement Act Approval No. 155-01-00 (previously approved as 95-IND-072) is cancelled.
SECTION 2.2: RECORD KEEPING
APPROVAL NO. 155-02-00 Page 5 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 2.2.1 The approval holder shall record and retain all the following information in respect of
any sampling conducted or analyses performed in accordance with this approval for a minimum of ten years, unless otherwise authorized in writing by the Director:
(a) the place, date and time of sampling;
(b) the dates the analyses were performed;
(c) the analytical techniques, methods or procedures used in the analyses;
(d) the names of the persons who collected and analyzed each sample; and
(e) the results of the analyses.
SECTION 2.3: ANALYTICAL REQUIREMENTS
2.3.1 With respect to any sample required to be taken pursuant to this approval, the approval holder shall ensure that:
shall be conducted in accordance with the following unless otherwise authorized in
writing by the Director:
(i) for air monitoring:
(A) the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended;
(B) the Methods Manual for Chemical Analysis of Atmospheric Pollutants, Alberta Environment, 1993, as amended;
(C) the Air Monitoring Directive, Alberta Environment, 1989, as amended; and,
(D) the CEMS Code;
APPROVAL NO. 155-02-00 Page 6 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(ii) for industrial wastewater, industrial runoff, groundwater and domestic wastewater parameters:
(A) the Standard Methods for the Examination of Water and Wastewater, published jointly by the American Public Health Association, American Water Works Association, and the Water Environment Federation, 1998, as amended;
(iii) for soil samples:
(A) Soil Sampling and Methods of Analysis, Lewis Publishers, 1993, as amended;
(B) the Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, USEPA, SW-846; September 1986, as amended;
(C) the Soil Quality Criteria Relative to Disturbance and Reclamation, Alberta Agriculture, March 1987, as amended;
(D) the Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites – Volume I: Main Report, CCME EPC-NCS62E, 1993, as amended; and
(E) the Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites – Volume II: Analytical Method Summaries, CCME EPC-NCS66E, 1993, as amended;
2.3.2 The approval holder shall analyze all samples that are required to be obtained by this approval in a laboratory accredited pursuant to ISO 17025, as amended, for the specific parameter(s) to be analyzed, unless otherwise authorized in writing by the Director.
2.3.3 The approval holder shall comply with the terms and conditions of any written
authorization issued by the Director under 2.3.2. SECTION 2.4: OTHER 2.4.1 All industrial wastewater and process liquids contained in above and below ground
storage tanks, shall be contained in accordance with the Alberta Energy and Utilities Board (EUB) Guide G-55 "Storage Requirements for the Upstream Petroleum Industry", as amended.
2.4.2 All aboveground storage tanks containing liquid hydrocarbons or organic compounds
shall conform to the Environmental Guidelines for Controlling Emissions of Volatile
APPROVAL NO. 155-02-00 Page 7 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
Organic Compounds from Aboveground Storage Tanks, CCME-EPC-87-E, as amended.
PART 3: CONSTRUCTION
Not used at this time.
PART 4: OPERATIONS, LIMITS, MONITORING AND REPORTING
SECTION 4.1: AIR
OPERATIONS
4.1.1 The approval holder shall not emit any effluent streams to the atmosphere except as provided in this approval.
4.1.2 The approval holder shall only emit effluent streams to the atmosphere from the following sources:
(a) the East Sulphur recovery process unit incinerator stack;
(b) the two Emergency Flare Stacks (Low and High Pressure);
(c) the three 24,625 kW power boiler exhaust stacks;
(d) the 246 kW compressor engine exhaust stack;
(e) the 328 kW compressor engine exhaust stack;
(f) the two 410 kW compressor engine exhaust stacks;
(g) the four 1,790 kW compressor engine exhaust stacks (two stacks for each engine);
(h) the two 13,800 kW still reboiler exhaust stacks (one standby);
(i) the two 1,760 kW stabilizer reboiler exhaust stacks (one standby);
(j) the 3,250 kW sulfreen heater exhaust stack;
(k) the two 513 kW Salt Bath Heaters;
(l) the three Enersul GXM2 sulphur granulator units exhaust stacks;
(m) the natural gas fired emergency generator exhaust stack;
APPROVAL NO. 155-02-00 Page 8 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(n) the diesel emergency firewater pump exhaust stacks;
(o) the instrument air compressor engine stack;
(p) the space ventilation exhaust stacks as described in the application;
(q) the space heater exhaust vents as described in the application;
(r) the compressor starter gas vents as described in the application; and
(s) any other source authorized in writing by the Director or by an amendment to this approval.
4.1.3 The approval holder shall maintain the following stacks according to the minimum height requirements specified in TABLE 4.1-A and TABLE 4.1-B:
TABLE 4.1-A: STACK HEIGHTS
STACK MINIMUM HEIGHT ABOVE GRADE (metres)
High Pressure Emergency Flare Stack 61.6
Low Pressure Emergency Flare Stack 61.3
East Sulphur Recovery Process Unit Incinerator Stack 121.9
TABLE 4.1-B: STACK HEIGHTS
COMPRESSOR ENGINE RATED CAPACITY KILOWATTS (kW)
NUMBER OF ENGINES
MINIMUM HEIGHT ABOVE GRADE (metres)
246 1 18.4
328 1 18.4
410 2 18.2
1,790 4 16.25 4.1.4 The approval holder shall operate the emergency flare stacks in accordance with
4.1.9.
APPROVAL NO. 155-02-00 Page 9 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.1.5 Residue gas shall be added to the sour gas released to the emergency flare stacks
such that the net or lower heating value of the combined gas stream is not less than 12 MJ/m3 (at 101.325 kPa and 15°C), unless otherwise authorized in writing by the Director.
4.1.6 The approval holder shall ensure the combustion of all combustible gases released to the emergency flare stacks.
4.1.7 The approval holder shall equip and operate all emergency flare stacks with:
(a) a wind guard; and
(b) a continuously burning pilot light; and
(c) an electric, or equivalent, ignitor.
4.1.8 All plant pressure safety valves in sour gas service shall be connected to the flare system.
4.1.9 Except as provided for by the Director in writing, the approval holder shall not emit fugitive emissions or an air contaminant from any source not specified in 4.1.2 or an air contaminant from the emergency flare stacks that causes or may cause any of the following:
(a) the impairment, degradation or alteration of the quality of natural resources; or
(b) material discomfort, harm or adversely affect the well being or health of a person; or
(c) harm to property or to plant or animal life.
SULPHUR PROCESSING PLANT
4.1.10 Effective the earlier of April 30, 2006 or the commencement of full operation of the new Sulphur Handling Facility as described in application 010-155:
(a) sulphur shall only be processed by the new Sulphur Handling Facility consisting of the Enersul GXM2 sulphur granulator units;
(b) no sulphur shall be processed by the existing Sulphur Handling Facility consisting of the slater units.
4.1.11 The approval holder shall provide, to the Director by March 31, 2006, an amendment to the Decommissioning and Reclamation Plan for the Sulphur Handling Facility dated November 2004 that consists of an update of the schedule of activities to be undertaken as described in the Plan, unless otherwise authorized in writing by the Director.
APPROVAL NO. 155-02-00 Page 10 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.1.12 The approval holder shall implement the Decommissioning and Reclamation Plan as
amended, as referred to in 4.1.11, unless otherwise authorized in writing by the Director.
4.1.13 Effective the earlier of April 30, 2006 or the commencement of full operation of the new Sulphur Handling Facility as described in application 010-155, the approval holder shall not operate the existing Sulphur Handling Facility unless the approval holder has obtained an amendment permitting such operation.
LIMITS 4.1.14 Release of air contaminants shall not exceed the limits specified in TABLE 4.1-C.
TABLE 4.1-C: LIMITS
EMISSION SOURCE AIR CONTAMINANT/ PARAMETER LIMIT
2.33 tonnes per hour
40.0 tonnes per day Sulphur Dioxide
10,300 parts per million by volume for a one-hour
averaging period
East Sulphur Recovery Process Unit Incinerator Stack
Temperature a minimum of 465°C for a one-hour averaging period
Sulphur granulator units SHF_1 and 2 and 3 exhaust stacks
Total Particulate Matter 0.20 grams per kilogram of
effluent
MONITORING AND REPORTING 4.1.15 The approval holder shall monitor as specified in TABLE 4.1-D.
4.1.16 The approval holder shall report as specified in TABLE 4.1-D.
APPROVAL NO. 155-02-00 Page 11 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.1-D SOURCE MONITORING AND REPORTING
EMISSION SOURCE/ EFFLUENT STREAM
PARAMETER SAMPLING FREQUENCY
MONITORING METHOD
METHOD OF ANALYSIS
REPORTING FREQUENCY (one copy required)
REPORT TO
Sulphur Dioxide, Flow Rate,
and Temperature
Continuous CEM CEMS Code
Monthly, before the end
of the next month
East Sulphur Recovery Process Unit Incinerator Stack
Sulphur Dioxide Twice per year Manual Stack Survey
Alberta Stack Sampling
Code
Twice per year, each by the end of the Month after
the survey is done
Emergency Flare Stacks
Amount of Sulphur Dioxide released to the
atmosphere
Acid gas & residue or fuel gas released to
flare
Daily Measured or estimated
Mass Balance
Monthly, before the end
of the next month
Exhaust stacks of Sulphur granulator Units SHF_1, SRF 2 or SRF 3
Total Particulate Matter, PM2.5
Annual sampling of
one stack at a minimum, with
rotation so that each of the stacks shall be
surveyed at a minimum once
every three years
Manual Stack Survey
Alberta Stack Sampling
Code
Before the end of the Month
after the month in which the
survey is done
Director
4.1.17 The approval holder shall monitor for ambient levels of all parameters as specified in
TABLE 4.1-E.
4.1.18 The approval holder shall report as specified in TABLE 4.1-E.
APPROVAL NO. 155-02-00 Page 12 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.1-E: AMBIENT MONITORING AND REPORTING
PARAMETER TO BE ANALYSED OR MEASURED
NUMBER OF MONITORING SITES
FREQUENCY METHOD OF MONITORING
METHOD OF ANALYSIS OF MEASURE-MENT
REPORT FREQUENCY (one copy required)
REPORT TO
SO2, H2S, wind speed and direction
2 ambient air quality monitoring
stations
12 Months/year Continuous
Total Sulphation and Hydrogen Sulphide
13 exposure stations Monthly Exposure
Stations
Monthly, before the end of the
next month
Soil Testing in accordance with the Air Monitoring Directive
As authorized by the Director Annually Air Monitoring
Directive
Air Monitoring Directive
Annually
Director
4.1.19 An annual summary and evaluation report shall be submitted to the Director by March
15 of each year that contains for the previous year information related to plant operation, performance of air pollution control equipment and air contaminant emissions.
STUDIES 4.1.20 The approval holder shall submit a proposal to the Director by June 1, 2006 for
investigating the elevated ambient air H2S concentrations observed at the ambient air quality monitoring stations to the Director by June 1, 2006.
4.1.21 The proposal referred to in 4.1.20 shall include the following:
(a) site map showing the plant in relation to activities believed to contribute to elevated ambient air H2S concentrations;
(b) description and summary of dates of observed elevated ambient air H2S concentrations and wind speed and direction, observed plant activities and other possible factors related to elevated ambient air H2S concentrations;
(c) method to investigate sources of elevated ambient air H2S concentrations including additional monitoring based on historic events;
(d) possible means to mitigate or prevent elevate ambient air H2S concentrations; and,
APPROVAL NO. 155-02-00 Page 13 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(e) a schedule for implementing the investigation.
4.1.22 The approval holder shall implement the proposal referred to 4.1.20 as authorized in writing by the Director.
4.1.23 The approval holder shall submit a report summarizing the results of the investigation referred to in 4.1.20 and as authorized in writing by the Director by March 31, 2007.
SPECIAL REPORTING 4.1.24 The approval holder shall continuously measure or estimate and record on a daily
basis the average sulphur inlet rates in tonnes per day.
4.1.25 If the percentage of daily SO2 mass emission rates as reported in 4.1.26 are less than or equal to the values in Column 3 in TABLE 4.1-F for the applicable daily SO2 mass emission (Column 2, TABLE 4.1-F) based on the average daily sulphur inlet rates (Column 1, TABLE 4.1-F) at which the plant operated during the reporting period;
OR
If the percentage of hourly SO2 mass emission rates as reported in 4.1.26 are less than or equal to the values in Column 5 in TABLE 4.1-F for the applicable hourly SO2 mass emission (Column 4, TABLE 4.1-F) based on the average daily sulphur inlet rates (Column 1, TABLE 4.1-F) at which the plant operated during the reporting period;
then the following information shall be provided in the monthly report by the approval holder:
(a) a description of the events or circumstances that lead to higher cumulative mass emission readings; and
(b) an outline of the action taken to control the magnitude and/or duration of the event; and
(c) a description of any long-term measures or actions that are required to prevent or minimize such occurrences in the future and a schedule of implementation for these measures or actions.
APPROVAL NO. 155-02-00 Page 14 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
TABLE 4.1-F: SO2 MASS EMISSION TIERS
COLUMN 1 COLUMN 2 COLUMN 3 COLUMN 4 COLUMN 5
PLANT DAILY AVERAGE SULPHUR INLET RATE
(TONNES/DAY)
DAILY SO2 MASS EMISSION (TONNES/DAY)
Sulphur Recovery Process Unit Incinerator Stack
% OF DAILY READINGS IN A MONTH THAT ARE TO BE LESS THAN THE DAILY MASS EMISSION VALUE IN COLUMN 2
HOURLY SO2 MASS EMISSION (TONNES/HOUR)
Sulphur Recovery Process Unit Incinerator Stack
% OF HOURLY READINGS IN A MONTH THAT ARE TO BE LESS THAN THE HOURLY MASS EMISSION VALUE IN COLUMN 4
0 – 300.0 12.0 90.0 0.70 90.0
300.1 – 700.0 28.0 93.3 1.63 95.0
700.1 – 975.0 39.0 96.7 2.28 98.0
4.1.26 The approval holder shall report the frequency distribution of both the hourly and daily mass emission rates of sulphur dioxide versus the monthly average daily sulphur inlet rate monthly.
4.1.27 The approval holder shall notify in writing the Director a minimum of two weeks prior to all stack surveys.
SECTION 4.2: INDUSTRIAL WASTEWATER
OPERATIONS
4.2.1 The approval holder shall not release any substances from the plant to the surrounding watershed except as authorized by this approval.
4.2.2 Industrial wastewater shall be managed as described in the application, unless otherwise authorized in writing by the Director.
4.2.3 Industrial wastewater that is collected in the Double Lined Open Drain Collection Pond shall only be disposed as follows:
(a) to an Alberta Energy and Utilities Board (EUB) approved disposal well; or
(b) to an Alberta Energy and Utilities Board (EUB) approved Waste Processing and Disposal Facility; or
APPROVAL NO. 155-02-00 Page 15 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(c) as otherwise authorized in writing by the Director.
4.2.4 The approval holder shall only release the following industrial wastewater streams to the Blowdown Holding Ponds:
(a) Boiler blowdown; and,
(b) Cooling tower blowdown.
4.2.5 The approval holder shall only release industrial wastewater from the Blowdown Holding Ponds via pipeline to McDonald Lake, unless otherwise authorized in writing by the Director.
4.2.6 All industrial runoff from the plant developed area shall be directed to the Sulphur Block Area Surface Runoff Collection Pond.
4.2.7 The approval holder shall only release industrial runoff from the Sulphur Block Area Surface Runoff Collection Pond via pipeline to McDonald Lake, unless otherwise authorized in writing by the Director.
LIMITS
4.2.8 Releases from the Blowdown Holding Ponds shall not exceed the limits for the parameters specified in TABLE 4.2-A.
4.2.9 Releases from the Sulphur Block Area Surface Runoff Collection Pond shall not exceed the limits for the parameters specified in TABLE 4.2-A.
APPROVAL NO. 155-02-00 Page 16 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.2-A: LIMITS
PARAMETER LIMIT
Industrial Wastewater Released from the Blowdown Holding Ponds
PH 6.0 - 9.5 pH units
Floating solids Must not be present except in trace amounts
Visible foam Must not be present except in trace amounts
Oil or other substances Must not be present in amounts sufficient to create a visible film or sheen
Chemical Oxygen Demand 200 mg/L
Ammonia-Nitrogen 5 mg/L
Oil & Grease 5 mg/L
Total Suspended Solids 25 mg/L
Chlorine Residual 0.3 mg/L
Industrial Runoff Released from the Sulphur Block Area Surface Runoff Collection Pond pH 6 – 9.5 pH units
Oil & Grease No visible sheen
Chemical Oxygen Demand 50 mg/L
Ammonia-Nitrogen 5 mg/L
Total Suspended Solids 25 mg/L
Chloride 500 mg/L
APPROVAL NO. 155-02-00 Page 17 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL MONITORING AND REPORTING 4.2.10 The approval holder shall monitor the Blowdown Holding Ponds, Industrial Runoff
Control System and McDonald Lake as required in TABLE 4.2-B unless otherwise authorized by the Director.
4.2.11 The approval holder shall report to the Director the results of monitoring the Blowdown Holding Pond, Industrial Runoff Control System and McDonald Lake as required in TABLE 4.2-B.
4.2.12 For the purpose of Table 4.2-B:
(a) sampling location A is defined as Blowdown Holding Ponds;
(b) sampling location B is defined as Sulphur Block Area Surface Runoff Collection Pond; and
(c) sampling location C is defined as McDonald Lake.
APPROVAL NO. 155-02-00 Page 18 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.2-B: INDUSTRIAL WASTEWATER AND INDUSTRIAL RUNOFF CONTROL
SYSTEM MONITORING AND REPORTING
MONITORING REPORTING
PRIOR TO RELEASE
DURING RELEASE
Parameter, Test, Event, Study Proposal or
Reporting Requirement Frequency Frequency Sample Type Sampling
Location Monthly Annually
Flow (m3/d) Daily Estimate A, B
Ammonia-Nitrogen (mg/L)
Weekly Representative Grab A, B
Total Suspended Solids (mg/L)
Weekly Representative Grab A, B
pH Daily Representative Grab A, B
Floating Solids Daily Visual A
Visible Foam Daily Visual A
Oil and Grease Daily Visual B
Oil and Grease (mg/L) Weekly Representative Grab A
Chemical Oxygen Demand (mg/L) Weekly Representative
Grab A, B
Chloride (mg/L) Weekly Representative Grab B
Chlorine Residual (mg/L) Weekly Representative Grab A
Sulphate (mg/L) Weekly Representative Grab B
Total Phosphorus (mg/L) Weekly Representative Grab A
Conductivity (umhos) Weekly Representative Grab A
Monthly Industrial
Wastewater and Industrial
Runoff Report as per
4.2.13
(On or before the end of the month
following the month in which the
information was
collected)
Number of Copies
Required 1
Temperature, pH, total hardness, total alkalinity, carbonate, bicarbonate, chloride, sulphate, nitrite-nitrogen, nitrate-nitrogen, sodium, magnesium, potassium, total iron, oil & grease, chemical oxygen demand, conductivity, total dissolved solids, water level, BTEX and F1 Parameters
Once per year
Representative Grab C Not
required
Annual Industrial
Wastewater and
Industrial Runoff
Report as per 4.2.14 due March 15 of each
year
Number of Copies
Required 1
APPROVAL NO. 155-02-00 Page 19 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.2.13 In addition to the monthly reporting in Table 4.2-B, the monthly Industrial Wastewater
and Industrial Runoff Report shall include, at a minimum, all of the following information:
(a) an assessment of the monitoring results relative to the limits in TABLE 4.2-A;
(b) the release from the Blowdown Holding Pond and the Industrial Runoff Pond to McDonald Lake for the parameters listed in TABLE 4.2-A in kilograms per day;
(c) the daily minimum, maximum and average pH recorded as per TABLE 4.2-B;
(d) an assessment of the performance of the Industrial Wastewater Control System, the Industrial Runoff Control System, pollution abatement equipment and monitoring equipment;
(e) a summary of contraventions reported pursuant to 2.1.1; and
(f) any other information as required in writing by the Director.
4.2.14 In addition to the annual reporting in Table 4.2-B, the Annual Industrial Wastewater and Industrial Runoff Report shall include, at a minimum, all of the following information:
(a) an overview of the operation and performance of the Industrial Wastewater and Industrial Runoff Control Systems and pollution abatement equipment;
(b) a tabulated summary of the monitoring results for the industrial wastewater and industrial runoff released to McDonald Lake including the minimum, maximum and average for all the parameters listed in Table 4.2-B for each month;
(c) an assessment of the monitoring results relative to the limits specified in Table 4.2-A including trend analysis and control charts;
(d) a summary of contraventions reported pursuant to 2.1.1; and
(e) any other information as required in writing by the Director.
APPROVAL NO. 155-02-00 Page 20 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL SULPHUR MANAGEMENT
4.2.15 The approval shall not pour liquid sulphur to the sulphur storage blocks unless the following requirements are met:
(a) the pouring shall be conducted under the circumstances specified in the application or in the event of an emergency event; and,
(b) the approval holder shall notify the following parties at least 72 hours in advance of the commencement of the set up of pouring: (i) Alberta Environment, and (ii) all residents within a 3 km radius of the plant; and
(c) any other information as required in writing by the Director.
4.2.16 The approval holder shall ensure that sulphur spills are cleaned up as soon as possible after each spill event.
4.2.17 The approval holder shall submit to the Director by October 31, 2006 an Environmental Assessment for management of contaminated sulphur and materials contaminated with sulphur.
4.2.18 The Environmental Assessment for management of contaminated sulphur and materials contaminated with sulphur shall include, but is not limited to, the sulphur block and basepads, the slater units, the sulphur load-out area, the sulphur storage pad and sulphur soil pile. The Assessment shall include:
(a) an estimate of contaminated sulphur and material contaminated with sulphur;
(b) a schedule for removal and disposal of contaminated sulphur and materials contaminated with sulphur;
(c) an evaluation of the permeability of the areas where the contaminated sulphur and materials contaminated with sulphur are stored;
(d) recommendations for upgrading the storage area(s) with an impermeable surface based on the results from 4.2.18(c);
(e) recommendations for mitigating wind erosion of the storage area(s);
(f) recommendations for upgrading and lining the collection ditches and sump areas;
(g) material specification of proposed liners;
(h) schedule of planned activities; and
(i) any other information the Director requires.
APPROVAL NO. 155-02-00 Page 21 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.2.19 The approval holder shall correct any deficiencies in the Environmental Assessment
referred to in 4.2.18 as specified in writing by the Director.
4.2.20 The approval holder shall implement the Environmental Assessment recommendations referred to in 4.2.18 and as authorized in writing by the Director.
UPGRADES TO INDUSTRIAL RUNOFF CONTROL SYSTEM
4.2.21 The approval holder shall conduct an assessment of Industrial Runoff at the plant. The assessment shall have the following components:
(a) a brief description of the catchment areas;
(b) a description of the sampling program for collecting samples of industrial runoff from catchment areas in 2006 including a site plan showing the catchment areas and the locations of where the samples were taken;
(c) interpretation and tabulation of the analytical results including the laboratory analytical results;
(d) a determination of industrial runoff quantities at the plant and for each catchment area;
(e) a description of the risks of contaminating industrial runoff at each catchment area;
(f) an assessment of implementing Best Management Practices (BMPs) at the plant to mitigate industrial runoff at the plant including the possibility of diverting industrial runoff from specified portions of catchment areas and details on the receiving areas and potential impacts on these receiving areas.
(g) a plan and schedule for implementing BMPs at the plant.
4.2.22 The approval holder shall submit the Industrial Runoff Assessment referred to in 4.2.21 to the Director by December 1, 2006 unless otherwise authorized in writing by the Director.
4.2.23 The approval holder shall implement the plan referred to in 4.2.21(g) as authorized in writing by the Director.
APPROVAL NO. 155-02-00 Page 22 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL UPGRADES TO INDUSTRIAL WASTEWATER CONTROL SYSTEM
4.2.24 The approval holder shall submit a proposal to the Director by December 1, 2006 for upgrading the industrial wastewater control system. The proposal shall include, at a minimum, all of the following:
(a) identification of the chemicals of concern in the boiler blowdown and cooling tower blowdown based on treatment chemicals used for the boiler and cooling tower water systems;
(b) review of the monitoring results of the blowdown holding pond including a tabulated summary, graphs showing trends for monitoring data collected from 1995 to 2005;
(c) an assessment of the boiler and cooling tower water treatment systems to determine the optimum number of cycles to minimize treatment chemical usage and contaminants in the blowdown including Total Suspended Solids;
(d) an assessment of technology options for treating boiler blowdown and cooling tower blowdown including:
(i) the quality of treated wastewater that can be achieved for each technology option and feasibility of recycling this treated wastewater to the cooling water and boiler or other uses;
(ii) the estimated quantity and quality of the waste stream resulting from the treatment technology and possible disposal options; and
(iii) recommendations for the most effective treatment technology option for implementation at the plant; and
(iv) a schedule for this work to be done.
4.2.25 If the proposal referred to in 4.2.24 is found deficient by the Director, the approval holder shall correct all the deficiencies as outlined by the Director within 120 days of the deficiency letter.
4.2.26 The approval holder shall implement the recommendations referred to in 4.2.24(d)(iii) as authorized in writing by the Director.
SECTION 4.3: WASTE MANAGEMENT
OPERATIONS
Not used at this time.
APPROVAL NO. 155-02-00 Page 23 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL SECTION 4.4: DOMESTIC WASTEWATER
OPERATIONS
4.4.1 All domestic wastewater shall be directed to a septic tank with subsequent disposal to an approved municipal wastewater treatment system.
SECTION 4.5: WATERWORKS
Not used at this time.
SECTION 4.6: GROUNDWATER
4.6.1 The approval holder shall implement the Groundwater Monitoring Program for the plant as authorized in writing by the Director.
4.6.2 The samples extracted from the groundwater monitor wells shall be collected using scientifically acceptable purging, sampling and preservation procedures so that a representative groundwater sample is obtained.
4.6.3 All groundwater monitor wells shall be:
(a) protected from damage; and
(b) locked except when being sampled; unless otherwise authorized in writing by the Director.
4.6.4 If a representative groundwater sample cannot be collected because the groundwater monitor well is damaged or is no longer capable of producing a representative groundwater sample:
(a) the groundwater monitor well shall be cleaned, repaired or replaced; and
(b) a representative groundwater sample shall be collected and analyzed prior to the next scheduled sampling event; unless otherwise authorized in writing by the Director.
4.6.5 In addition to the sampling information recorded in 2.2.1, the approval holder shall record the following sampling information for all groundwater samples collected:
(a) a description of purging and sampling procedures;
(b) the static elevations, above sea level, of fluid phases in the groundwater monitor well prior to purging;
(c) the temperature of each sample at the time of sampling;
APPROVAL NO. 155-02-00 Page 24 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(d) the pH of each sample at the time of sampling; and
(e) the specific conductance of each sample at the time of sampling.
4.6.6 The approval holder shall compile an Annual Groundwater Monitoring Program Summary Report which shall include, at a minimum, all of the following information:
(a) a legal description of the plant and a map illustrating the plant boundaries;
(b) a topographic map of the plant;
(c) a description of the industrial activity and processes;
(d) a map showing the location of all surface and groundwater users, and, a listing describing surface water and water well use details, within at least a three kilometre radius of the plant;
(e) a general hydrogeological characterization of the region within a five kilometre radius of the plant;
(f) a detailed hydrogeological characterization of the plant;
(g) a geological cross-section(s) of the plant;
(h) a map of surface drainage patterns located within the plant;
(i) a map of groundwater monitor well locations and a description of the existing groundwater monitoring program for the plant;
(j) a summary of any changes to the groundwater monitoring program made since the last groundwater monitoring report;
(k) analytical data recorded as required in 4.6.1 and 4.6.5;
(l) a summary of fluid elevations recorded as required in 4.6.5(b) and an interpretation of changes in fluid elevations;
(m) an interpretation of groundwater flow patterns;
(n) an interpretation of the analytical results including the following:
(i) diagrams indicating the location of any contamination identified,
(ii) probable sources of contamination, and
(iii) the extent of contamination identified;
APPROVAL NO. 155-02-00 Page 25 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(o) a summary and interpretation of the data collected since the groundwater monitoring program began including:
(i) control charts which indicate trends in contaminant concentrations, and
(i) for changes to the groundwater monitoring program to make it more effective; and
(ii) for remediation, risk assessment or risk management of contamination identified.
4.6.7 The approval holder shall submit two copies of the Annual Groundwater Monitoring Summary Report to the Director on or before April 14 of the year following the year in which the information on which the report is based was collected, unless otherwise authorized in writing by the Director.
SECTION 4.7: SOIL
MONITORING
4.7.1 The approval holder shall develop and document proposals for the Soil Monitoring Program in accordance with the Soil Monitoring Directive, Alberta Environment, May 1996, as amended.
4.7.2 The approval holder shall submit the Soil Monitoring Program proposals to the Director for authorization in writing according to the following schedule:
(a) for the first soil monitoring proposal, no later than May 1, 2006; and
(b) for the second soil monitoring proposal, no later than March 1, 2011; or
APPROVAL NO. 155-02-00 Page 26 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
unless otherwise authorized in writing by the Director.
4.7.3 If the Soil Monitoring Program proposals are found deficient by the Director, the approval holder shall correct all the deficiencies as outlined by the Director within 120 days of the deficiency letter.
4.7.4 The approval holder shall implement the Soil Monitoring Program proposals as authorized in writing by the Director.
4.7.5 The approval holder shall implement QA/QC provisions in accordance with the CCME Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites, Volume I, Report CCME EPC-NCS62E, Winnipeg, Manitoba, December 1993, as amended.
STANDARDS
4.7.6 For sampling locations which meet the conditions in C.1 of the Soil Monitoring Directive, May 1996, as amended, the concentration of substances in soil shall be compared to values in the following:
(a) for petroleum hydrocarbons, Alberta Soil and Water Quality Guidelines for Hydrocarbons at Upstream Oil and Gas Facilities, Alberta Environment, 2001, as amended;
(b) for salt, Salt Contamination Assessment and Remediation Guidelines, Alberta Environment, 2001, as amended;
(c) for substances not included in 4.7.6 (a) or (b), Canadian Environmental Quality Guidelines, Canadian Council of Ministers of the Environment, PN1299, 1999, as amended, excluding values determined before 1997;
(d) for substances not found in 4.7.6 (a) to (c), for soil which will be remediated to an agricultural, residential, or parkland land use, Alberta Tier I Criteria for Contaminated Soil Assessment and Remediation, Alberta Environmental Protection, March 1994, as amended; and
(e) for substances not found in 4.7.6 (a) to (c), for soil which will be remediated to a commercial or industrial land use, the Interim Canadian Environmental Quality Criteria for Contaminated Sites, Canadian Council of Ministers of the Environment, EPC-CS34, September 1991, as amended.
4.7.7 For sampling locations which do not meet the conditions in C.1 of the Soil Monitoring Directive, May 1996, as amended, or if substances are present that are not listed in the standards referred to in 4.7.6 (a) to 4.7.6 (e), the concentrations of substances in soil shall be compared to values derived using methods in C.2 of the Soil Monitoring Directive.
APPROVAL NO. 155-02-00 Page 27 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL REPORTING
4.7.8 The approval holder shall submit two copies of each Soil Monitoring Program Report to the Director summarizing the data obtained from the soil monitoring referred to in 4.7.4 according to the following schedule:
(a) for the first soil monitoring report, no later than December 1, 2006; and
(b) for the second soil monitoring report, no later than October 1, 2011; or
unless otherwise authorized in writing by the Director.
4.7.9 The Soil Monitoring Program reports shall be as prescribed in the reporting requirements of the Soil Monitoring Directive, May 1996, as amended.
SOIL MANAGEMENT PROGRAM
4.7.10 If the Soil Monitoring Program, or any other soil monitoring, reveals that there are substances present in the soil at concentrations greater than the applicable concentrations in 4.7.6 or 4.7.7, the approval holder shall develop and document a Soil Management Program Proposal in accordance with the Guideline for Monitoring and Management of Soil Contamination Under EPEA Approvals, Chemicals Assessment and Management Division, May 1996, as amended, or as otherwise authorized in writing by the Director.
4.7.11 If required pursuant to 4.7.10, the approval holder shall submit a Soil Management Program Proposal to the Director within six months after the date that the Soil Monitoring Report referred to in 4.7.8 is due.
4.7.12 The Soil Management Program Proposal shall include, at a minimum, all of the following:
(a) steps to be taken to control sources of contamination;
(b) remediation objectives for substances identified by soil monitoring as exceeding the applicable maximum standards in 4.7.6 or 4.7.7;
(c) proposed steps for management of soil contamination; and
(d) a schedule for implementing the Soil Management Program.
4.7.13 If the Soil Management Program Proposal is found deficient by the Director, the approval holder shall correct all the deficiencies as outlined by the Director by the date specified in the deficiency letter.
APPROVAL NO. 155-02-00 Page 28 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.7.14 The approval holder shall implement the Soil Management Program as authorized in
writing by the Director.
4.7.15 If the approval holder must implement a Soil Management Program pursuant to 4.7.14, the approval holder shall submit a written Soil Management Program Report to the Director on or before March 31 of each year, unless otherwise authorized in writing by the Director.
4.7.16 The Soil Management Program report shall include, at a minimum, all of the following information:
(a) a summary of actions taken under the Soil Management Program during the previous year;
(b) a description and interpretation of results obtained, including any soil testing, from the Soil Management Program; and
(c) events planned for the current year including any deviations from the program authorized in writing by the Director.
PART 5: RECLAMATION
SECTION 5.1: GENERAL
5.1.1 The approval holder shall apply for an amendment to this approval to reclaim the plant by submitting a Decommissioning and Land Reclamation Plan to the Director.
5.1.2 The Decommissioning and Land Reclamation Plan referred to in 5.1.1 shall be submitted within six months of the plant ceasing operation, except for repairs and maintenance, unless otherwise authorized in writing by the Director.
5.1.3 The approval holder shall implement the Decommissioning and Land Reclamation Plan as authorized by the Director.
APPROVAL NO. 155-02-00 Page 29 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL SECTION 5.2: DECOMMISSIONING
5.2.1 The approval holder shall develop and submit a plan for the Decommissioning phase to the Director which shall include, at a minimum, all of the following:
(a) a plan for dismantling the plant;
(b) a comprehensive study to determine the nature, degree and extent of contamination at the plant and affected lands;
(c) a plan to manage all wastes produced at the plant during operation and decommissioning;
(d) evaluation of remediation technologies proposed to be used at the plant and affected lands;
(e) a plan for decontamination of the plant and affected lands in accordance with the following:
(i) for petroleum hydrocarbons, Alberta Soil and Water Quality Guidelines for Hydrocarbons at Upstream Oil and Gas Facilities, Alberta Environment, 2001, as amended;
(ii) for salt, Salt Contamination Assessment and Remediation Guidelines, Alberta Environment, 2001, as amended;
(iii) for substances not included in 6.2.1 (e) (i) or 6.2.1 (e) (ii), Canadian Environmental Quality Guidelines, Canadian Council of Ministers of the Environment, PN1299, 1999, as amended, excluding values determined before 1997;
(iv) for substances not found in 6.2.1 (e) (i) to 6.2.1 (e) (iii), for soil which will be remediated to an agricultural, residential, or parkland land use, Alberta Tier I Criteria for Contaminated Soil Assessment and Remediation, Alberta Environmental Protection, March 1994, as amended;
(v) for substances not found in 6.2.1 (e) (i) to 6.2.1 (e) (iii), for soil which will be remediated to a commercial or industrial land use, the Interim Canadian Environmental Quality Criteria for Contaminated Sites, Canadian Council of Ministers of the Environment, EPC-CS34, September 1991, as amended;
(vi) for water, Canadian Water Quality Guidelines, CCREM, 1987, as amended; and
APPROVAL NO. 155-02-00 Page 30 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(vii) for soil or water, to contaminant levels in accordance with a risk assessment procedure accepted by the Director;
(f) confirmatory testing to indicate compliance with the remediation objectives; and
(g) a plan for maintaining and operating contaminant monitoring systems.
5.2.2 The approval holder shall implement the Decommissioning plan as authorized in writing by the Director.
5.2.3 All analytical protocols shall be in accordance with the Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites - Volume 1: Main Report, CCME EPC-NCS62E.
5.2.4 The approval holder shall submit an Annual Report to the Director by December 30 of each year until decommissioning is complete which shall include, at a minimum, all of the following:
(a) summary of decommissioning activities conducted during the reporting period;
(b) status of decommissioning;
(c) decommissioning activities planned for the following reporting period;
(d) summary and interpretation of monitoring data collected for the reporting period; and
(e) interpretation of monitoring data collected historically.
SECTION 5.3: LAND RECLAMATION
5.3.1 The approval holder shall develop and submit a plan for the Land Reclamation phase to the Director which shall include, at a minimum, all of the following:
(a) the final use of the reclaimed area and how equivalent land capability will be achieved;
(b) removal of infrastructure;
(c) restoration of drainage;
(d) soil replacement;
(e) erosion control;
APPROVAL NO. 155-02-00 Page 31 of 31
………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
(f) revegetation and conditioning of the plant including:
(i) species list, seed source and quality, seeding rates and methods;
(ii) fertilization rates and methods;
(iii) wildlife habitat plans where applicable; and
(g) reclamation sequence and schedule.
5.3.2 The approval holder shall implement the Land Reclamation plan as authorized in writing by the Director.
DATED October 31, 2005 DESIGNATED DIRECTOR UNDER THE ACT ALAN PENTNEY
AMENDING APPROVAL
PROVINCE OF ALBERTA
ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACTR.S.A. 2000, c.E-12, as amended.
155-02-01APPROVAL NO.
014-155APPLICATION NO.
September 17, 2007EFFECTIVE DATE:.
September 30, 2015EXPIRY DATE:
Nexen Inc.APPROVAL HOLDER
Pursuant to Division 2, of Part 2, of the Environmental Protection and Enhancement Act,R.S.A.2000, c.E-12, as amended, the approval for the following activity:
Balzac sour gas processing plant for the processing of natural gas and the Balzac sulphurprocessing plant.
is amended as per the attached terms and conditions.
Kevin WilkinsonDesignated Director under the Act
Kevin Wilkinson
September 17, 2007Date Signed
APPROVAL NO.155-02-01
……………………….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
Environmental Protection and Enhancement Act Approval No. 155-02-00 is hereby amended asfollows:
1. The following is added after SECTION 4.1.2(s):
(t) the diesel emergency generator exhaust stack.
DATED September 17, 2007 Kevin Wilkinson DESIGNATED DIRECTOR UNDER THE ACT
AMENDING APPROVAL
PROVINCE OF ALBERTA
ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACTR.S.A. 2000, c.E-12, as amended.
155-02-02APPROVAL NO.
015-155APPLICATION NO.
February 29, 2008EFFECTIVE DATE:.
September 30, 2015EXPIRY DATE:
Nexen Inc.APPROVAL HOLDER
Pursuant to Division 2, of Part 2, of the Environmental Protection and Enhancement Act,R.S.A.2000, c.E-12, as amended, the approval for the following activity:
Balzac sour gas processing plant for the processing of natural gas and the Balzac sulphurprocessing plant.
is amended as per the attached terms and conditions.
Kevin WilkinsonDesignated Director under the Act
February 29, 2008Date Signed
APPROVAL NO.155-02-02……………………
….
TERMS AND CONDITIONS ATTACHED TO APPROVAL
Environmental Protection and Enhancement Act Approval No. 155-02-00 is hereby amended asfollows:
1. The following is added after SECTION 4.1.14:
4.1.14 (a) notwithstanding Table 4.1-C, for the period between March 17 to 21, 2008, or asotherwise authorized in writing by the Director, the temperature of the effluentstream released to the atmosphere shall not be less than the one-hour averageof 300 degrees celsius.
DATED February 29, 2008 Kevin Wilkinson DESIGNATED DIRECTOR UNDER THE ACT
33
APPENDIX II – PUBLIC CONSULTATION FACT SHEET
Social ResponsibilityHSE&SR Management System
Public ComplaintsPublic Complaints
Identifying and addressing “Public Complaints”
What is a public complaint?
Guiding Principle & Standard:At Nexen, we conduct our business with respect and care for people. From time to time, we receive complaints from our stakeholders and the general public. Our standard is to track, document and respond to any complaint, question, or query within five working days of its receipt.
At Nexen, we separate complaints into two basic categories; 'Reportable' and 'Non-Reportable'.
Reportable Complaint: A direct expression of concern made by a stakeholder or member of the public that relates to a topic or event associated with Nexen's operations and results in the business unit taking action to correct the problem or concern. In some instances, reportable events are also required to be reported to a regulator.
Non-Reportable Complaint or Comment:A direct or indirect expression of concern, an observation, or viewpoint
of an industry related activity(s) near Nexen's operations that may or may not result in a formal reply or further action by Nexen.
All public complaints are entered into the Lotus Notes LEHS database by the field staff member that received the complaint or by a designate within the regional office. Information to be provided in an LEHS entry must include:
date and time of event, hlocation and/or nearest facility, and hdetails of the complaint. h
Where applicable, the regional social responsibility lead/representative will then add this information including contact information into Nexen's Stakeholder database (Praxis).
The area operations superintendent or supervisor initiates the investigation with the local HSE&SR practitioner providing support and technical guidance as required.
How does Nexen track public complaints?
Who investigates public complaints?
What are examples of public complaints?
A landowner smells something (a hpetroleum odour) on their property and calls Nexen to report the concern,A local fisherman writes a letter to hNexen to express concerns that offshore activity is affecting fishing in the area,A resident calls upset about finding hsediment in their well water and believes it is from a nearby Nexen drilling operation,A farmer informs a contractor on a hNexen lease that they believe their horse (livestock) was injured during recent drilling or mobilization activity,A Nexen field office receives a hnoise complaint from a local landowner where drilling activities are currently underway,A concerned citizen contacts the hlocal authority about Nexen activities in an area that they consider environmentally sensitive, the authority contacts Nexen to seek clarity of the issue.
Element 4 of the HSE&SR Management System:
4.3.1 Ongoing Community EngagementAll divisions will establish and maintain ongoing community engagement programs to support Nexen's long-term social license to operate.
This engagement will typically include: involving the community in decision-making processes for operational hchanges, expansions or abandonment activities that may affect them; taking proactive measures to ensure communities are aware of hongoing Nexen activities; providing a vehicle for members of the public to express questions, hconcerns and complaints regarding our operations.
All divisions will record notable public complaints, comments and inquiries in the Nexen LEHS database, respond to them in a timely manner, and document the response.
July 2011 S13735
Version Dec 8, 2011
Balzac A&R Team
Public Concern 12 Step Response Procedure
1. Call Centre directs Public Concern from a citizen or interested party to the On Call Responder.
2. On Call Responder will complete a Public Concern form while in conversation with caller (see attached).
3. On Call Responder will verify with caller if, after investigation a call back is required.
4. On Call Responder investigates the concern and if required, takes necessary action.
5. On Call Responder will document on the Public Concern form actions taken.
6. If required, the On Call Responder will follow up with the original caller advising them of our findings and or action taken.
7. On Call Responder will classify the concern as “reportable” or “non-reportable”. All reportable concerns require an email notification to the appropriate contacts identified on the Public Concern form.
8. The On Call Responder will enter the Public Concern into the Lotus Notes LEHS database, and attach the Public Concern form to the event in the attachments section. Once attached the document must be retained in a secure environment or shredded.
9. A&R Team Lead will conduct a review of the LEHS event report within 5 days for accuracy and technical content. If necessary, the A&R Team Lead will correct and/or add action items and discuss revisions with On Call Responder.
10. A&R HSE Advisor(s) will conduct a review of the LEHS event report within 10 days for accuracy and technical content from an HSE perspective. If necessary, the A&R HSE Advisor(s) will correct and/or add action items and discuss revisions with A&R Team Lead.
11. A&R Managers (Plant or Field) will conduct a review and/or amend the LEHS event within 15 days and if there are no outstanding issues and all actions items are closed move event to “Final”.
12. On receipt of event in Lotus Notes the Social Responsibility Lead will enter information into stakeholder database (Praxis) at their discretion.
Balzac A&R
Last Edit Dec 8, 2011
PUBLIC CONCERN FORM CALL INFORMATION
DATE and TIME: INFORMATION RECORDED BY: NAME: PHONE NUMBER: LOCATION: CONCERNS:
Follow-up call requested? Yes No ODOUR COMPLAINT: YES NO If Yes, complete section below. Can you describe the direction the odour is coming from: NW NE SW SE When did the odour first appear? How long did the odour last? Is the odour still occurring? Yes No
Can you please describe the smell: Faint Moderate Strong Very Strong
INVESTIGATION SECTION Comments from Nexen Representative after Investigation: Nexen Sites Checked for Odour:
Is this event : Reportable Non- Reportable
FOLLOW UP SECTION Follow-up Call Completed by (Name): Follow up Call Details Time: Same day or Date:
Additional Comments: Attach separately as 2nd Page If this is a REPORTABLE PUBLIC CONCERN issue an email notification to:
FIELD MANAGER PLANT MANAGER A&R TEAM LEAD A&R HSE ADVISOR(s) SOCIAL RESPONSIBILITY COORDINATOR
Entered into Lotus Notes: Yes No Date Entered: Attached Concern form to Event: Yes No LEHS #:
34
APPENDIX III – DECOMMISSIONING, REMEDIATION AND LAND
RECLAMATION PLAN
BALZAC GAS PLANT
DECOMMISSIONING
REMEDIATION
&
LAND RECLAMATION
PLAN
SUBMITTED BY:
NEXEN INC.
801 – 7th
Avenue S.W.
Calgary, Ab
T2P 3P7
March 5, 2012
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
1
Table of Contents INTRODUCTION .............................................................................................................. 5
1. Shutdown, Decommissioning and Salvage ................................................................. 6
2. Dismantling and Demolition of Facility ..................................................................... 9
a. Hazardous Materials Removal ............................................................................... 10
b. Demolition of Equipment, Vessels, Tanks and Piping .......................................... 10
c. Demolition of Buildings and Structures ................................................................ 11
d. Processing of Demolition Recyclables .................................................................. 11
e. Transportation of Materials .................................................................................... 12
f. Site Cleanup ........................................................................................................... 12
g. Noise Control ......................................................................................................... 12
h. Dust Control ........................................................................................................... 12
3. REMEDIATION AND RECLAMATION PLAN .................................................... 13
3.1 Remediation Action Plan (“RAP”) .................................................................... 13
3.2 Reclamation Plan ................................................................................................ 13
Appendix I –Slater Demolition Plan ............................................................................... 102
Appendix II – Waste Management Plan ......................................................................... 103
Appendix III – List of Environmental Reporting Completed for the BGP ..................... 104
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
3
TABLES
Table 1. AEPEA Approvals Applicable to BGP ............................................................... 5
Table 2. Equipment Changes on BGP – 2006* ................................................................. 6 Table 3. Equipment Changes on BGP – 2009 ................................................................... 7 Table 4. Summary of catchment area sizes, current land use, and confirmation of Plant
runoff contribution. ........................................................................................................... 23 Table 5. Previous Environmental Investigations by Liability Sub-Unit and Year. ......... 67
Table 8. Summary of COPCs in Soil & Groundwater ..................................................... 74 Table 9. COPCs in Soils .................................................................................................. 79
Table 10. Summary of COPCs in Soils ........................................................................... 80 Table 11. Detailed Summary of COPCs in Groundwater by LSU .................................. 82 Table 12. COPCs in Groundwater by LSU ...................................................................... 84
Table 13. COPC in Surface Water Bodies ....................................................................... 86
FIGURES
Figure 1. Catchment Areas within the BGP ..................................................................... 24
Figure 2. Catchment Areas Surrounding BGP ................................................................. 26 Figure 3. Balzac East Area Zoning Map .......................................................................... 29 Figure 4. Complete or Assessed Programs ...................................................................... 68
F1 and PHC F2 concentrations all exceeding AENV (2009) guidelines. At the LP Surge
Culvert, benzene and ethylbenzene concentrations were reported exceeding AENV
(2009) guidelines.
m) Measurable product thickness was not detected in 98-24A/B/C, located within the LPG
Recovery area. Very high dissolved phase hydrocarbon concentrations, though showing a
decrease compared to historical values, were reported at 98-24A. Increased values of
benzene, PHC F1 and PHC F2 at 98-24B were reported exceeding AENV (2009)
guidelines. 98-24C reported benzene, ethylbenzene and PHC F2 exceedances in 2009.
n) In the LPG Recovery Area, measurable thickness of free phase hydrocarbons was
measured, followed by the installation of a passive skimmer at this location. No
measurable thickness of product was detected in the fall 2008, or spring/fall 2009
sampling events. Dissolved hydrocarbon concentrations remained above guidelines,
however concentrations decreased from spring 2008 levels.
o) Piezometers 98-26A/C, MW-8A and MW-10A (east side of Sulphur Block) may be
monitoring inorganic impact from an up-gradient location onto the Site.
p) Concentrations of chloride, hydrocarbons, selected metals and/or amines may indicate
groundwater quality impacts at various locations.
Groundwater conditions at the Balzac Sour Gas Processing Plant (Plant) have been documented
in great detail through monitoring from 1992 to 2011. The main findings of the groundwater
monitoring include:
generally, natural groundwater quality in the Plant area is of poor quality as
indicated by high sulphate and total dissolved solids (TDS) concentrations;
groundwater flow velocities outside of the process area are low, in all three
monitored groundwater zones, primarily due to low hydraulic gradients;
groundwater quality, including in zones of contamination, is relatively stable
with small seasonal and annual variability; and
inorganic and organic groundwater impacts related to Plant operation
identified within the process area, ponds and adjacent areas are aerially stable
and have not expanded greatly over the monitoring period.
Considering the significant hydrogeological information available and the Plant
decommissioning, a major revision in the forthcoming groundwater monitoring program is
recommended. Proposed changes to the 2012 program include:
reduction in groundwater monitoring frequency;
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
42
reduction in the number of monitoring wells to be monitored;
reduction in analytical schedule; and
concentrating monitoring activities around the process area and perimeter “C”
wells.
The proposed groundwater monitoring program would include sampling once a year in the spring,
instead of spring and fall sampling, with the number of monitored wells reduced. To address
operational issues during the 19 year history of groundwater monitoring, several monitoring wells
were installed in relatively close proximity to each other, often duplicating and/or confirming
information obtained from existing wells. These expansions to the monitoring network were
required at the time of installation. However, in view of the Plant decommissioning, some
monitoring wells are of lesser importance. It should be noted that during Plant decommissioning
and remediation of the area, several wells installed near facilities will be removed. These
monitoring wells should be properly abandoned.
Monitoring wells selected for continued monitoring should be sampled and tested as follows:
laboratory analysis for benzene, toluene, ethylbenzene, xylenes (BTEX) and
petroleum hydrocarbon (PHC) fractions F1 and F2 and amines; and
field measured parameters including depth to groundwater surface,
temperature, electrical conductivity (EC) and pH. If significant changes in EC
and/or pH are measured as compared to historical field measurements, a
sample should be submitted for routine potability analysis for the well in
question. Otherwise, laboratory testing for main ions and dissolved metals
should be discontinued.
STORMWATER MANAGEMENT
1. Balzac Gas Plant. Stormwater Management Report. Westhoff Engineering Resources
Inc. July 2003. The report was completed in support of a licence renewal application to
AENV in support of the information requested in “Attachment B –Industrial Runoff and
Surface Runoff Drainage System”. A composite drainage plan and catchment area plan
was developed, dividing the BGP into 9 10 Catchment areas. Westoff Engineering Resources Inc. Balzac Gas Plant Stormwater Management Report – WER 102-74
McDONALD LAKE
1. Sediment Sampling in McDonald Lake to Assess the Potential for Natural Hydrogen
Sulphide Generation. Matrix Solutions Inc. January 29, 2009. The objective of the
program was to assess the potential hydrogen sulphide generation from sediments in
McDonald Lake to determine if natural conditions from the lake could potentially
produce hydrogen sulphide and contribute to exceedances found at Nexen’s ambient
monitoring stations. It was concluded that “McDonald Lake appears to have the
ecological conditions conducive for sulphate reduction and the generation of hydrogen
sulphide at certain times of the year.” This was completed to try to understand the H2S
exceedances that were received at the ambient monitoring trailers during the year.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
43
SULPHUR HANDLING FACILITIES
1. Decommissioning and Reclamation Plan – Sulphur Handling Facility. Worley Parsons
Komex. Report No. C25531604. Issued to Alberta Environment March 2006.
The primary objective of the D&R Plan was to satisfy the specific requirements of
Amending Approval (155-01-05) and Current Approval (155-02-00) with respect to
decommisioning and reclamation of the former Sulphur Handling Facility.
2. 2006 Environmental Assessment for Management of Contaminated Sulphur And
Materials Contaminated with Sulphur. WorleyParsons Komex. Report No. C25531803.
Issued to Alberta Environment November 28, 2006
The primary objective of the assessment was to address the terms and conditions for
Sulphur Management in Sections 4.2.15 through 4.2.20 of the current operating approval
(155-02-00). This environmental assessment included the following areas:
the sulphur block
sulphur basepad;
the slater units;
the sulphur load-out area; and,
the sulphur soil pile(s).
The results of this assessment program assisted in defining remedial requirements during
remedial activities completed from 2007 to 2009 in liability subunits 18 and 25 (see
Figure 5) and the assessment will also assist in future remedial programs.
Additionally, this assessment partially addresses the regulatory requirement for a Soil
Monitoring Program (SMP) at the site. (See 2006 Soil Monitoring Program. Balzac Sour
Gas Plant. Worley Parsons. Report C25531803. November 30, 2006)
Report C25532106. March 23, 2011. A soil investigation was conducted in 2006 to
characterize and delineate the facility related impacts within the sulphur handling facility.
The following findings of the 2006 investigation pertain to 2009 activities on Site:
• sampling locations were investigated to characterize the sediment in the drainage
ditch adjacent to the sulphur pad and loadout. Elemental and total sulphur
impacts were confirmed in the drainage ditch. Elevated electrical conductivity
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
46
(EC), depressed pH values and elevated salinity parameters indicated significant
sulphur-related impacts. Excavation and off Site disposal of soil was
recommended. After remediation of the drainage ditch, it was recommended that
an impermeable liner be used to prevent possible future impacts to this area. An
Industrial Runoff Assessment recommended the reconstruction and remediation
of ditches in the Sulphur Handling Facility Area.
• at locations adjacent to the underground rail tank car, pH, elemental and total
sulphur impacts were confirmed by analytical results and field observations.
Excavation and off Site disposal of soil was recommended
• soil underneath the old slating units and at the Enersul Area poured sulphur was
characterized. Based on field observations and laboratory analyses, sulphur
impacts were identified including elevated EC values, acidic pH and elevated
elemental/total sulphur concentrations. Excavation and off Site disposal of soil
was recommended, with potential for in situ remediation for soil at depths below
1.0 m.
Approximately 29,000 tonnes of sulphur-impacted soil was excavated from the Site and
hauled to the BFI Canada Inc. Calgary landfill. Exceedances of Tier 1 and/or the sulphur
remediation guidelines were left in place in many areas of the excavation. These
exceedances will be reviewed as part of the overall Plant remediation assessment
activities. As recommended the surface water collection system (ditches) in the Enersul
Area was upgraded. A summary of this work includes:
Upgrades and extensions to the existing surface collection system to
improve conveyance and increase capacity to accommodate runoff.
Reconstruction clay lined and asphalt lined ditches
Removal, replacement and disposal of sulphur impacted soils below
new ditches with clean imported fill.
Installation of a low density polyethylene (LDPE) liner below all new
asphalt ditches to provide secondary containment.
5. 2009 DEA UST Removal and Replacement - Letter Report. Worley Parsons. Report
C25532107. May 10, 2011. Approximately 50 m3 (in situ) of impacted soil was
excavated from the new DEA UST. The excavation did not extend beyond the
dimensions of the new DEA tank. Soil samples were collected from the base and walls of
the excavation for characterization of the soil to establish baseline data. Excavation wall
and base soil sampling and analysis indicated the soil met the Tier 1 Guidelines for all
parameters with the exception of EC at four of the five sample locations and PHC F2 at a
single sample location. EC results reported above the Tier 1 Guideline were within
previously established Site background concentrations. Groundwater sampling during
three events indicated there are exceedances above Tier 1 Guidelines. Some parameters
fluctuate between exceeding and not exceeding parameter guidelines. These results are
consistent with groundwater conditions analyzed at nearby monitoring wells. Due to the
planned decommissioning of the Site, the new DEA UST was never put into operation.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
47
SUMMARY OF ENVIRONMENTAL STUDIES AT THE PLANT, BY YEAR
The following briefly summarizes the different environmental studies and/or remediation projects
that have been tracked on the BGP since 1989. The information below is provided to demonstrate
to the reader what projects have been implemented and completed, where the projects are located
on the BGP, and why the individual projects were required. All the studies and their conclusions
(which are too numerous to list succinctly) create the basis of information Nexen used to
determine the current state of the property, as summarized in Section 8 – Current State of the
Property.
1989 Activities: A hydrogeological assessment at the Balzac facility was completed. This
program involved the installation and sampling of 11 monitoring wells. Two additional wells
were installed at well sites 11-01-26-29 W4M (MW-12B) east of the plant, and 11-12-26-29
W4M (MW-13B) to the northeast. The purpose of this program was to assess groundwater quality
at these on-site and off-site locations.
1991 Activities: Completion of a follow-up assessment of hydrogeological conditions, and to
address special conditions outlined in the License to Operate. This included a review of reports
prepared by UMA Engineering Ltd., published hydrogeological maps and reports, and water well
records.
1992 Activities: a major upgrade of the groundwater monitoring network was completed. This
program included the installation of 18 additional observation wells across the plant site,
providing more comprehensive monitoring coverage. Prior to this, a geophysical reconnaissance
of the area was completed. Terrain conductivity and magnetometer surveys were conducted near
the buried south landfills, south of the main process area, and down gradient of North and South
Cooling Tower Blowdown Ponds.
Terrain Conductivity and Magnetometer Survey – Petrogas Processing Plant
A geophysical survey of the Blowdown Pond Area and Landfill Area Sulphur Block Storage Area
was conducted. The survey was conducted to better assess potential soil and groundwater
contamination issues. This program is the precursor to starting detailed soil and groundwater
investigations at the Balzac Plant. Komex Report: Terrain Conductivity and Magnetometer Survey at the Petrogas Processing Plant, Balzac Alberta A92-2553-2
1993 Activities: four additional monitoring wells (93-15A/C and 93-16A/C) were installed on
the west side of McDonald Lake. The purpose of these wells was to further define local
background conditions. The piezometers were installed in nested configurations, including one
shallow and one deep, to assess vertical flow conditions at each location.
1994 Activities: a geophysical survey was completed in the vicinity of the sulphur block storage
area. Subsequently, in July 1994, bedrock monitoring wells (94-17C, 94-18C, and 94-19C) were
installed at the plant site to assess groundwater flow conditions and water quality in the deeper
water-bearing horizons. Later in 1994, a geophysical investigation was conducted south of the
main process area to assess the extent of potential subsurface impact associated with a number of
former waste water and surface runoff ponds. This study was followed up in March 1995 with a
soil and sludge sampling program in the Evaporation Pond, Holding Pond, Hydrocarbon Burn Pit,
Chemical Pond, and Filter Cake Pond.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
48
A stable isotope investigation of soil and groundwater in and around the plant ponds, sulphur
storage, and sulphur loading areas was also completed. The purpose of this investigation was to
determine the source of anomalous groundwater sulphate concentrations at the Balzac site (i.e.,
natural versus industrial).
Upgrade of Runoff Water Control around Sulphur Block Area
This project consisted of installing lined ditches around the sulphur block and sulphur basepad
and construction of a lined acidic water collection pond and secondary containment for caustic
treating facilities. This was in response to AENV concerns on the handling of acidic runoff water
in Sulphur Block Area. An activity change application was submitted to Alberta Environment and
approved. The work stretched over a two-year period (1994-1995). Petrogas Report Entitled: Activity Change – Upgrade of Runoff Water Control around Sulphur Block Area – Central File 001-20
Stable Isotope Study
A Stable Isotope investigation of soils, groundwater and vegetation was conducted in 1994 in
various plant ponds and the Sulphur Storage Area. The purpose of the investigation was to
determine the source of anomalous groundwater sulphate conditions (industrial vs. natural). The
report suggested a low degree of industrial impact from plant operations was evident. Komex Report: Stable Isotope Study at the Petrogas Processing Facility KI94-2553-5
In 1994 a Geophysical survey of the Sulphur Block Storage Area was conducted. The survey was
conducted to better assess potential soil and groundwater contamination issues. The objective of
the program was to delineate in a plan view shallow inorganic soil and/or groundwater
contamination. This program was the precursor to starting detailed soil and groundwater
investigations at the Balzac Plant. Komex Report: Terrain Conductivity Survey at the Petrogas Processing Plant, Balzac Alberta A94-2553-6
1995 Activities: a piezometer (95-20A) was installed south of piezometer nest 92-8A/B.
Temporary piezometers 96-21A and 96-22A were subsequently installed in 1996 down gradient
of the North and South Cooling Tower Blowdown Ponds.
1995 Geophysical Program and Limited Soil Sampling Investigation This program was conducted to fulfill plant operating licence requirements. The survey was
conducted to better assess potential soil and groundwater contamination issues. The geophysical
program covered the entire south end of the Plant. This geophysical program, in conjunction with
the two previous geophysical investigations (1992 &1994), covered the majority of the Balzac
Plant Site. Komex Report: 1995 Geophysical Program and Limited Soil Sampling Investigation – Petrogas Processing Ltd. KI95-2553-6
1996 Activities: the first soil monitoring program (SMP) was conducted at the Site. Subsequent
to submission of the monitoring program report to AENV, a management plan was developed to
address identified soil contaminant issues over time. It was followed by a Remedial Program
Work Plan.
Effects of Acid Conditions on Element Distribution beneath a Sulphur Basepad
A CAPP research project entitled “Effects of Acid Conditions on Element Distribution beneath a
Sulphur Basepad” was completed in 1996. (West sulphur basepad) The program consisted of
installing two groundwater wells and the collection of six soil samples from different locations
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
49
under the basepad. Results indicated that the pH in the soils immediately under the west sulphur
basepad had not been impacted in the 35 years of operation. Komex Report: Effects of Acid Conditions on Element Distribution Beneath a Sulphur Basepad KI96-4374
Study of Soil, Sludge and Groundwater Conditions around the Blowdown Ponds
This report was submitted to fulfill a plant operating licence requirement regarding the plant
blowdown ponds. The program was to address the integrity of the liner material in the blowdown
ponds and determine if the ponds posed a risk to soils and groundwater and options to upgrade the
ponds if necessary. The report concluded that it did not appear that shallow groundwater had been
adversely impacted from the blowdown ponds. Komex Report: Study of Soil, Sludge and Groundwater Conditions Around the Blowdown Ponds at the Balzac Gas Plant 2553-7-2
1996 Soil Monitoring Program
The 1996 soil monitoring program was conducted to fulfill a condition in the plant operating
licence. The soil monitoring program consisted of the following activities:
Soil sample collection at 19 locations around the facility and one background location.
Sample analysis for parameters as specified in the plant operating approval.
Data summary and presentation, incorporating previous investigations.
The report summarized the nature of impact at specific locations. Komex Report: 1996 Soil Monitoring Program – Balzac Gas Plant – Canadian Occidental Petroleum Ltd. KI96-2553-7-3-6
1997 and 1998 Activities: Initiation of clean-up at the Hydrocarbon Burn Pit, the Filter Cake
Pond, the Chemical Pond, and the Drilling Mud Pit.
In 1998 an integrated soil and groundwater investigation program was completed. The
investigation targeted areas where additional groundwater monitoring was required (e.g.
installation of a bedrock piezometer near the flare area) and locations at which further soil quality
characterization was warranted. Twelve piezometers were installed as part of this program. This
program identified a number of previously unknown issues, including: free hydrocarbon product
contamination in the LPG recovery area and soil contamination in two former flare pits southwest
of the bone yard.
Remediation of soil adjacent to the southeast Process Pond commenced. This area had previously
been contaminated by a release from the Plains Midstream (Federated Pipelines/Anderson were
operators of this pipeline in or around 1998) condensate pipeline, which passes through the area.
Monitoring well 98-29A was installed in the upper water bearing zone to monitor success of the
remediation program. This well is not considered part of the current Nexen monitoring network.
A 5 year Environment Management Plan (EMP) for the Plant was developed. The Management
Plan for the Plant was updated in 2000. Since that time, many of the recommended activities in
the Plan have been implemented and additional site assessments completed. In view of the
progress made, and new information obtained, a revised EMP, extending to 2005, was developed
in 2001.
Soil Quality Adjacent to the Sulphur Contaminated Soil Pile
A study was undertaken in 1997 to determine if there were any impacts due to storing sulphur-
contaminated soil at the Balzac Gas Plant. The sulphur soil pile was generated in 1995 when
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
50
remediation activities around the sulphur block and basepad during the Sulphur Block Runoff
ditches and pond construction. The report indicated that acidic impact beneath the basepad had
been limited to the upper 0.3 meters of the soil profile. The lack of acidic impact suggested that
adequate soil buffering capacity is present in the existing soils after 33 years of operation. Komex Report: Soil Quality Adjacent to the Sulphur Contaminated Soil Pile at the Balzac Gas Plant – 2553-8-2
Remediation of the Hydrocarbon Burn Pit, Filter Cake Pond, Chemical Pond and Ditches
Remediation plans for the on-site Hydrocarbon Burn Pit and ditches, Filter Cake Pond, Chemical
Pond were developed in 1997. The remediation of the Hydrocarbon Burn Pit and ditches began
late in 1997. Heavily contaminated sludge was removed and disposed of at a Class II landfill.
Hydrocarbon contaminated soils were assessed and a decision to spread and land treat the soils
was decided on. These activities were implemented to reduce contaminant levels to below Alberta
Tier I guidelines in the vicinity of the pit and ditches.
The remediation of the Filter Cake Pond and Chemical Pond began in 1998 along with the
completion of the Hydrocarbon Burn Pit and ditch remediation. Again some heavily contaminated
sludge was removed and disposed of at a Class II landfill. The less contaminated sludge was land
spread and land farmed in place. Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2
Remediation of the Drilling Mud Pit The remediation of an old Drilling Mud Pit located on the plant site was also completed during
1998. Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2
Slop Tank Remediation – Flare Area
During the 1997 upgrade of the plant’s Flare Area, contaminated soil was encountered. During
this upgrade it was decided to remediate the footprint of the new installation. The area was
excavated to a depth of approximately 2.5 meters. The contaminated material was deemed land
treatable and this contaminated material was incorporated into existing land treatment activities
from the Hydrocarbon Burn Pit and ditches, Chemical Pond and Filter Cake Pond. Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2
Screening Level Human Health and Ecological Risk Assessment
During 1998, a “Screening Level Human Health and Ecological Risk Assessment” was initiated.
The risk assessment was developed to look at three specific areas of the plant: S.E. Process Area
Runoff Pond, Holding Pond, Evaporation Pond, and it looked at McDonald Lake to a lesser
extent.
In general the assessment found that there would be no unacceptable risks to human health in an
industrial or parkland setting. The ecological risk assessment indicated that there are ecological
risks associated with certain identified chemicals of concern. The next steps included actions to
try and minimize ecological risks. Komex Report: Screening Level Human Health and Ecological Risk Assessment (Ponds) Wascana Energy - Balzac Gas Plant - KI 98-
4683
North Flare Pit and South Flare Pit Investigations
Contamination was identified in the vicinity of Wellsite 2-2-26 (located on Plant Property) during
the 1998 Integrated Soil and Groundwater Program. Based on this Program a delineation
program was initiated in 1999.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
51
1998 Integrated Soil & Groundwater Investigation Program
This 1998 Integrated Soil and Groundwater Program were conducted to supplement the 1996 Soil
Monitoring Program and in turn help fulfill plant operating licence requirements.
Correspondence with Alberta Environment and Alberta Energy and Utilities Board and an audit
conducted by both parties identified the need for additional soil and groundwater monitoring. The
additional sampling brought forth some specific areas of concern, some of which are being
addressed in various remediation and investigation programs now being conducted at the plant. Komex Report: 1998 Integrated Soil and Groundwater Investigation Program - Wascana Energy Inc. KI-2553-9 T01/T02
Lean Oil Collection System – LPG
During the 1998 Integrated Soil and Groundwater Program, the presence of free product (Lean
Oil) was discovered. A delineation program was developed and implemented in October 1998.
The scope of work consisted of the following:
To identify the extent of the free product in the LPG Area;
To establish the approximate thickness of the free product in the LPG Area; and,
To collect data to support the development of remedial options. Komex Report: Delineation of Free Product Contamination in the LPG Recovery Area – Balzac Gas Plant KI-2553-10-5
1999 Activities: the Former 2-2 North and South Flare Pits were remediated. During this
remediation, approximately 4600 m3 of impacted soil and sludge was excavated; 1100 m
3 was
treated at a thermal desorption unit and later backfilled into the excavations; and 3500 m3 was
spread in a designated on-site treatment area and later backfilled into the excavations.
A soil and groundwater investigation program was undertaken to better delineate known
contaminant situations in the Condensate Loading Area and the Flare Area. The investigation
involved drilling twelve test holes to delineate previously identified hydrocarbon contamination
in soil. Temporary mini-piezometers were installed in four of the test holes to evaluate potential
groundwater impacts. Subsequent remedial work was conducted that included excavation in
2000, and in 2001, the treatment of approximately 4,000 m3 of impacted soils. A lean oil plume,
with an estimated volume of 81 m3 and extending over an approximate area of 3,100 m
2, was
delineated beneath and down gradient of the LPG Recovery Area of the Plant. In 1999, the first
of a three-phase remediation plan was implemented to begin recovery of the mobile free product.
Phase I consisted of a free product recovery trench that was installed within the plume core, in an
open area immediately south of the LPG Recovery facilities. An additional well (LPG-1) was
installed in the LPG Area in August 1999 and has been used to recover additional free product.
Delineation and Remediation of North Flare Pit near Well site 2-2-26 Remediation plans for the on-site 2-2 North Flare Pit were completed in the spring of 1999 and
remediation began in the fall of 1999. The 2-2 North Flare Pit was used to collect a variety of
waste materials from the plant in the early to mid-years of the plant. Approximately 700 m3 of
heavily contaminated sludge was removed from the North Flare Pit and sent for treatment at a
thermal desorption unit (incinerate soil to remove contaminants). In addition to this process
approximately 3,500 m3 of lightly contaminated soil was spread in a designated on-site treatment
cell and treatment was initiated in 1999 and completed in 2000. The first thing that was initiated
was a treatability study to determine if the contaminated soil could be land treated. After the
studies it was decided to use thermal desorption (incinerate) to decontaminate the more heavily
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
52
contaminated sludge. These treated soils were then returned to the Gas Plant for use as fill
material. Komex Report: Soil and Sludge Remediation Program of Flare Pits at Wellsite 2-2 C25531204
Delineation and Remediation of South Flare Pit near Well site 2-2-26
Remediation plans for the Well site 2-2-26 South Flare Pit were completed in the spring of 1999
and remediation began in the fall of 1999. Approximately 420 m3 of heavily contaminated sludge
was removed from the South Flare Pit and sent for treatment at a thermal desorption unit
(incinerate soil to remove contaminants). Komex Report: Soil and Sludge Remediation Program of Flare Pits at Well site 2-2 C25531204
Lean Oil Collection System – LPG
During the 1998 Integrated Soil and Groundwater Program the presence of free product (Lean
Oil) was discovered. In 1999 a Remedial Options Analysis was proposed to address this
contaminant concern. The analysis looked at the following groundwater remediation issues:
1. Understand (characterize) the problem at the site;
2. Assess the risks posed by the problem;
3. Set remedial goals for the site;
4. Review and select the most appropriate remedial options;
5. Pilot scale test(s) of selected remediation option or options;
6. Implement the optimal remediation program at the site; and,
7. Monitor results, modify systems. *Komex Report: Remediation Options Analysis LPG Recovery Area – Balzac Gas Plant KI2553-11-02 (Draft)
The Lean Oil Collection System Remediation program was installed in 1999 after free product
was discovered in the groundwater during the 1998 Integrated Soil and Groundwater
Investigation Program. Trenches and Collection Points were installed to collect free product (lean
oil) from the groundwater in the LPG unit. Komex Report: Installation and 1999 Performance Review LPG Recovery Area Free Phase Recovery System C25531106
2000 Activities: Phase II of the remediation included installation of a trench and gate system
between the two sets of LPG Storage Tanks down gradient of the free product plume. Continuous
operation of Phase II began in May 2001. The system was designed to direct groundwater flow
through the permeable collection trench and into a product separation gate, which traps floating
hydrocarbon. In 2001, only free product sheen was detected in the product separation gate,
therefore no free product removal was required. Analytical results for groundwater samples have
been collected since 2001. Benzene and total xylenes concentrations above the respective AENV
guidelines have been detected in the Phase II product separation gate system. However,
concentrations exiting the system through the re-infiltration gallery are below analytical method
detection limits.
A plant-wide program of UST removals was conducted in the summer of 2000. A total of four
tanks were removed, and impacted soils were delineated, and excavated where possible.
North and South Blowdown Pond Clean-up
Due to deteriorating water quality in North and South Blowdown Ponds a sludge sampling
program was conducted in 2000. The sampling discovered some contaminants and natural
elements (organic) in the sludge. The North Blowdown pond sludge contained some heavy end
hydrocarbons (unknown source) and this material was sent to a landfill. The South Blowdown
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
53
contained a substantial amount of organic matter which may have contributed to an ammonia
nitrogen issue in the water. This sludge was removed from the South Blowdown Pond and added
to the land treatment activities with the added organic matter aiding in the remediation process.
Underground Petroleum Storage Tank Investigation
To facilitate construction of the Balzac Power Station an environmental investigation was
conducted in the fall of 2000. During the investigation phase hydrocarbon impact was discovered.
A program was immediately set up to delineate and formulate a remediation plan to address the
contamination. Three former underground tanks (diesel/gasoline) were located in the vicinity of
this planned construction. Approximately 3600 m3 of hydrocarbon contaminated soil was
removed to a temporary bio-treatment cell. Land treatment of this impacted soil was undertaken
and completed in 2001. Komex Report: Balzac Parking Lot – Underground Petroleum Storage Tank Investigation – File No. 25531208
Condensate Loading Area Remediation
The delineation phase of this project began in 1999 with approximately 12 soil borehole locations
and 4 temporary mini piezometers (groundwater well) being installed. The contamination plume
was mapped and a remediation plan developed. The Condensate Loading Area remediation began
in 2000. The plan was to first excavate approximately a one-meter lift of sulphur contaminated
soil and stockpile on Sulphur Contaminated Soil Pile. Once the program began it was determined
that all the condensate loading facilities would be removed to ensure a full clean-up of the area.
This resulted in the removal of the loading structure and underground facilities in the immediate
area of the loading facility. Approximately 1000 m3 of soil was removed to the Temporary Land
Treatment Cell located on the Plant Site. Approximately 3000 m3 of soil was treated in place at
the Condensate Loading Area. The soil contained light end hydrocarbons and it was successfully
remediated during the 2001 season. The material was deemed clean per Alberta Tier I guidelines
and a portion (1000 m3) was stockpiled adjacent to the South Balzac Landfill.
Komex Report: Balzac Gas Plant – Delineation of the Flare Area and Condensate Loading Area – File No. C25531104 Draft
Komex Report: Balzac Gas Plant – Condensate Loading Area Remediation – File No. 25531211 Draft
Underground Tank Removals
Four underground tanks/sumps located on the Plant were removed in 2000. Remediation activities
were undertaken on 3 of the 4 tanks/sumps removed. The tanks were as follows: KVSR Oil
Sump, RDS Sales Gas Oil Tank, L.P. Surge Rerun Sump and Site ‘G’ Compressor Drain Tank
(contamination not present). These underground tanks/sumps were replaced with aboveground
facilities. The contaminated soil was removed and tested to determine suitable disposal or
treatment options. The KVSR Oil Sump and RDS Sales Gas Oil Tank contained heavy end
hydrocarbons and off-site disposal was undertaken. The L.P. Surge Rerun Sump contaminated
material (900 m3) contained lighter end hydrocarbons and an on-site treatment cell was
constructed to treat this material. Komex Report: Balzac Gas Plant – Underground Tank Removals – File No. C-2553-1206
Land Treatment Activities
Land treatment activities began in 2000 to deal with contaminated soils from various remediation
projects. The table below summarizes this information. These soils were tested extensively during
the remediation process and on completion in 2001. Activities occurred at a temporary land
treatment location within the BGP. Komex Report: Balzac Gas Plant – Landtreatment Activities – File No. C-2553-1211
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
54
Soil Source Contaminated Soil/Sludge Contaminant Main Parking Lot 3600 m
3 Diesel/Gasoline
LP Surge Rerun 900 m3 Condensate
Condensate Loading 4000 m3 Condensate
KVSR Storage Tank 300 m3 To BFI Lube Oil
South Blowdown Pond 1000 m3 Not Contaminated
Sulphur Contaminated Soil Bench Scale Studies
In 2000, soil samples were sent to laboratory to begin a series of studies to determine a suitable
method for extracting elemental sulphur from soil. The bench scale study looked at separating
sulphur/soil by three different methods of gravity concentration. Heavy media separation was
determined to work the most effectively.
Lean Oil Collection System – LPG
The Lean Oil Collection System was expanded in 2000. A trench and gate system was installed
late in 2000. The trench and gate system provided complete hydraulic containment of the free
product plume and treat the dissolved phase. This was the second phase of the system which was
initially installed in 1999. Komex Report: 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area Free Phase Recovery System
C25531212
After review of the Lean Oil Collection System operations had taken place, another report was
generated entitled “Proposed Expansion of the Free Product Recovery System LPG Recovery
Area – Balzac Gas Plant”. The scope of this report was as follows:
Proposed Phase II Expansion;
Proposed Phase III Expansion; and,
Continued Operation of Phase I operations. Komex Report: Proposed Expansion of the Free Product Recovery System LPG Recovery Area – Balzac Gas Plant C25531205
2001 Activities: The parking lot area was designated for construction of a portion of the Balzac
Power Station. Three USTs containing diesel and gasoline located north of the Plant parking lot
were removed in 1994, and soil quality delineation and remediation programs were implemented
in 2000 to ensure that the site was suitable for Balzac Power Station construction.
During 2001, construction of the new Balzac Power Station was completed in the northeast corner
of the Plant site. This required the installation of a new fuel gas pipeline north of the condensate
storage tanks, and a freshwater pipeline along the north-south access road. Both of these
installations uncovered previously unknown environmental impacts on the property. Condensate
impact was encountered along the fuel gas pipeline path, and a previously unidentified landfill
east of the Evaporation Pond was discovered along the planned route of the water pipeline.
In November 2001, a full characterization and delineation of the North and South Landfills was
completed. Additionally, the planned pathway for the freshwater pipeline necessitated the
removal of two aboveground methanol storage tanks. A remedial excavation and soil treatment
program was conducted on the underlying methanol impacted soils.
A Risk Assessment of the three former process ponds was initiated in 1998 and updated in 2001.
The Evaporation, Holding, and Southeast process ponds were sampled and evaluated for their
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
55
potential to adversely impact aquatic life due to salinity or metals. In December 2002, removal of
the surficial sediment layer from the Southeast Process pond was completed.
In December 2001, a piezometer replacement program was conducted. Three piezometers (01-
33A, 01-34A, and 01-35A) were drilled to replace MW-2A, 92-10A, and MW-7A, respectively;
the first two were removed to allow for construction of the Balzac Power Station. A further
piezometer (98-26A) was abandoned and re-drilled.
Balzac Gas Plant – North and South Landfill Characterization Program
The objective of this program was to characterize the contents of two former landfill sites located
on the Balzac Gas Plant property. The landfills had been previously identified and a preliminary
characterization program had been completed. The objective of the program was collect enough
information to develop a remediation plan.
The North Landfill contained filters, wood, crushed drums, catalyst, asbestos, tires, tubes from
reboilers, small amounts of sulphur and hydrocarbon contamination. The approximate volume of
the North Landfill was 9000 m3.
The South Landfill contains 5 separate cells which were in operation from 1967 to 1984. Again
the South Landfill site contains general plant refuse including: filters, pipes, timbers, catalyst,
small amounts of sulphur and hydrocarbon contamination. The approximate volume of the South
Landfill is 8000 m3.
Komex Report: Balzac Gas Plant – North and South Landfill Characterization Program – File No. 25531309 Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9
T01/T02 (Page 50 and Photos Section)
Sulphur Contaminated Soil Remediation Technology
To further progress the sulphur bench scale testing that had begun in 2000, a temporary Field
Pilot Project was implemented in the fall of 2001. The pilot ran for approximately six weeks. The
purpose of the pilot was to collect data to assess whether this technology was suitable to remove
elemental sulphur from soil. The pilot plant operated as planned. Process Research Associates Ltd. Report: Project No. 00-05207
Land Treatment Activities
Land treatment activities continued through 2001 and they were completed in the fall of 2001.
These activities dealt with contaminated soils from various remediation projects as outlined in the
2000 Land Treatment Activities. Two areas were set aside for land treatment activities –
Condensate Loading Area and over the South Landfill Area. Komex Report: Balzac Gas Plant – Land treatment Activities – File No. C-2553-1211
Methanol Tank Investigation/Remediation – LPG Unit
Remediation work had begun in this general area in 2001. The Field Methanol Tank was removed
in 2001. During the investigation phase approximately 1000 m3 of methanol impacted soil was
discovered and the impacted soil was segregated into the same land treatment area as the
Condensate Loading Area material. The remediation of the methanol area was combined with the
Condensate Loading Area Remediation and both were completed in the fall of 2001. Komex Report: Balzac Gas Plant – Methanol Storage Tank Investigation - File No. 25531306
Field Inhibitor Tank Investigation/Remediation – LPG Unit
Remediation work had begun in this general area (Condensate Loading Area) in 2001.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
56
The inhibitor tank and sump were also removed in the fall of 2001. The inhibitor tank remediation
activities were transferred to 2002 as the soil was determined to have heavier end contaminants
and this required landfill acceptance. Komex Report: Balzac Gas Plant – Inhibitor Tank Remediation – File No. 25531408
Lean Oil Collection System – LPG
The Lean Oil Collection System was run throughout 2001. Komex Report: 2001 Performance Report - Free Phase Recovery - LPG Recovery Area C25531303
Hydrocarbon Monitoring Results Waterline Installation – Balzac Power Station
During the construction of the water supply line to the Balzac Power Station, a previously
unknown landfill was discovered. The landfill was delineated - see above “Balzac Gas Plant –
North and South Landfill Characterization Program”. Komex Report: Hydrocarbon Monitoring Results Waterline Installation C25531307
Hydrocarbon Monitoring Results Fuel Gas Line Installation – Balzac Power Station
During the construction of the fuel gas supply line from the Balzac Gas Plant to the Balzac Power
Station two pockets of contaminated soil was encountered. The line intersected an area of known
contamination “Lean Oil Collection System – LPG” and another area that was addressed in 2004
activities “L.P. Surge Review – Remediation Plan”. Komex Report: Hydrocarbon Monitoring Results Fuel Gas Line Installation C25531307
Arsenic Detections in the S.W. Dugout
A report was issued in 2001 on the elevated arsenic values in the S.W. dugout. It was
recommended that further sampling be conducted on the dugout which was done approximately
every two to three weeks during the summer 2001. Arsenic values were below Canadian
Livestock Watering Guidelines for the first part of the year and again in the fall the arsenic values
went above the guidelines. The resident was notified immediately. They removed cattle upon
verbal discussions. Komex Report: Arsenic Detection’s in S.W. Dugout – Review and Recommendations C25531302
2002 Activities: In April 2002, a soil quality investigation was conducted around the main
electrical sub-station during plant turnaround. Trace amounts of PCBs (polychlorinated
biphenyls) and above AENV criteria heavy-end hydrocarbons were noted. Due to the complexity
of overhead and underground utilities, complete soil remediation is not an option until Plant
closure.
During August 2002, the field inhibitor storage tank and sump, located south of the LPG bullets,
were removed. Approximately 300 m3 of the surrounding impacted soil was excavated and
disposed of at the BFI landfill in Calgary.
Lean Oil Collection System – LPG
The Lean Oil Collection System was operated throughout 2002. Trenches and Collection Points
were installed three years ago to collect free product (lean oil) from the groundwater in the LPG
unit. An air-operated pump collected the lean oil/groundwater and it was pumped to a 400 Bbl.
tank SV 19-23 located in the LPG.
The second phase of the system was installed in December of 2000 and it continued to run
throughout 2002. This phase consisted of a trench and gate collection system which should cut-
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
57
off the flow of lean oil and any minor contaminants in the groundwater. One culvert (between
tank #5 and #6) acted as a collection point and one culvert (under tank #7) had a continuous
supply of air injected into the culvert. (N.B. This remediation system was featured in a
“Remediation Technologies Symposium” entitled “In-Situ Containment & Treatment of a Free
Phase Hydrocarbon Plume Beneath Plant Infrastructure” in Banff, October 2002. The paper was
presented by Mike Brewster of Komex International Ltd.) Komex Report: Installation and 1999 Performance Review LPG Recovery Area Free Phase Recovery System Komex Report: 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area Free Phase Recovery System
Remediation work had begun in this general area (Condensate Loading Area) in 2001. The
inhibitor tank and sump were also removed in the fall of 2001. The inhibitor tank remediation was
completed in the summer of 2002. Remediation consisted of removing contaminated soil for
testing to determine remediation options. The inhibitor contained some heavy end contaminates
that were not amenable to land treatment. The contaminated soil was temporarily stored just plant
south of the propane/butane truck loading area. The testing determined that off-site disposal was
the suitable disposal option. The contaminated soil was sent to the BFI landfill. Komex Report: Balzac Gas Plant – Inhibitor Tank Remediation – File No. 25531408
Sulphur Vat Pond Sludge (South of Wellsite 2-2)
Sludge from the Sulphur Vat Pond was evaluated and excavated and stored until 2003. (See
below)
Temporary Land Treatment Area (Adjacent to 2-2-26)
Contaminated soils from two pipeline failures (1-8-27 & 16-3-25) and a flare knockout
underground tank failure remediation project (6-23-27) were brought to the plant for land
treatment. The soils were treated throughout the summer and fall of 2002. The contamination
was condensate based and it was shown to be quickly treated using heavy equipment (tractor with
rotovator and lift removal with a dozer). Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006. (In
Draft).
PCB Soil/Debris Disposal from new Electrical Substation Revamp at Turnaround During the 2002 turnaround, low level PCB’s were discovered in the soil and some concrete
during a new substation upgrade. The concrete pads that housed the old transformer and capacitor
were removed; testing confirmed low level PCB’s were present on some of the concrete pads. A
new grounding grid was required around the new substation. To facilitate the grid installation a
trench was required. Soils around the substation were tested and low levels of PCB’s were
discovered in some areas.
The majority of the samples contained non-detect levels of PCB’s. The soil was transferred to soil
bins and off-site disposal was arranged. Komex Report: Balzac Gas Plant – PCB Soil Sampling and Delineation – File No. C25531403
Arsenic Detection’s in the S.W. Dugout
The recommended further sampling program continued through the summer 2002. Arsenic
values were below Canadian Livestock Watering Guidelines for the first part of the year and
again in the fall the arsenic values went above the guidelines. Resident notification again was
undertaken.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
58
2003 Activities: Phase III of the remediation system was designed to remove free product from
multiple vertical wells within the LPG area lean oil plum. Three new extraction wells (LPG-2,
LPG-3, and LPG-4) were installed. A Skimmer System was installed and rotated between the
three vertical wells on a regular basis throughout 2003 and 2004, removing the entire free product
thickness from wells LPG-2 and LPG-4.
Piezometers 92-12A, 98-24A, and 93-15C were replaced in June 2003.
In response to questions raised by AENV in a letter dated November 26, 2002, Komex issued an
‘Environmental Summary Update’ for the Balzac Gas Plant in June 2003, updating environmental
work completed and planned in the 5-year EMP. After review, AENV requested a further update
of more recent remedial work conducted in 2003/2004 (AENV letter dated March 3, 2004),
specifically including areas associated with the Sulphur Handling Facility. An ‘Environmental
Summary Update” was issued to address these requests, and update requirements of Section 5.3.2
of the Approval (AENV Approval No. 155-01-08). A ‘2005 Environmental Summary Update’
was prepared in July 2005, after a meeting and site tour was conducted with AENV.
A Flare area delineation program involving both soils and groundwater was conducted in
November 2003 as a continuation of the program initiated in September 1999. The purpose of the
program was to determine the lateral extent of the impact between the Flare area and McDonald
Lake. The program involved 14 soil sampling boreholes and the installation of seven piezometers;
one piezometer nest (03-39A/B) and five single piezometers (03-36A, 03-37A, 03-38A, 03-40A,
and 03-41A.
Remediation and reclamation of the North Landfill cell was completed in December 2003. In
addition, one down gradient piezometer was added to the Plant monitoring network (04-42A).
North Landfill Remediation
The North Landfill remediation was completed in 2003 except for topsoil dressing and seeding
which occurred in 2004. The area that the North Landfill was situated in was characterized and
delineated in environmental reports as listed below. Komex Report: Balzac Gas Plant – North and South Landfill Characterization Program – File No. 25531309
Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9
T01/T02 (Page 50 and Photos Section) Komex Report: Balzac Gas Plant – North Landfill Closure Report - File No. 25531505
Sulphur Vat Pond Sludge (South of Wellsite 2-2-26)
Approximately 6,926 tonnes of sludge from the Sulphur Vat Pond was sent to the BFI landfill in
2003. This material was removed from the Sulphur Vat Pond in 2002 and it was then evaluated
and stored temporarily over old Balzac South Landfill until a disposal option could be
determined.
Expand LPG Recovery System and Investigate Groundwater Treatment
Three additional collection points (perforated wells) for capturing contaminated groundwater
were completed in 2003 (Phase III work). The option of treating contaminated groundwater and
releasing it back to environment was assessed. Komex Report: Balzac Gas Plant – 2002 Performance Report – Free Phase Recovery System LPG Recovery Area Balzac Gas Plant –
File No. C25531407 – Draft Report
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
59
Flare Area Review – and Remediation Plan and/or Risk Assessment
The existing groundwater contaminant situation was reviewed and an expanded assessment
program was developed. The expanded assessment program included an extensive soil
investigation and groundwater monitoring network that were completed in November 2003 to
help develop a monitoring and remediation plan. Komex Report: Balzac Gas Plant – Delineation of the Flare Area and Condensate Loading Areas – File No. C25531104 – Draft
Report
Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504
Waste Storage Area (Adjacent to 2-2-26)
Contaminated soils from two pipeline failures (1-8-27 & 16-3-25) and a flare knockout
underground tank failure remediation project (6-23-27) were brought to the plant for land
treatment in 2001. The contamination was condensate based and it was shown to be quickly
treated using heavy equipment. The area is a waste storage pad approved to store waste but its
not a Land Treatment Area (LTA). The area is a double lined collection area approved by ERCB
for containment. Waste is then hauled off quarterly/annually depending on volumes Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006. (In Draft).
Environmental Assessment of Soils for Proposed Sulphur Forming Facilities
AMEC Environmental conducted a subsurface soil assessment in an area designated for the
construction of a new sulphur forming facility. Completed – AMEC Earth and Environmental Ltd. February 2003 – CE02621
2004 Activities: In December 2004, Nexen submitted a Decommissioning and Reclamation plan
to AENV designed to remove the existing sulphur area slating units and replace them with three
enclosed GXM2 sulphur granulator units. Remediation and reclamation planning was an integral
component of the plan. In March 2006, the plan was updated and resubmitted to AENV.
Updated Risk Assessment (3 Ponds)
The Updated Risk Assessment Report was completed during 2004. Komex Report: Balzac Gas Plant – Updated Risk Assessment – C25531301 June 2004
Sulphur Handling Area - Demolition & Remediation Plan for Enersul Slating Facilities
A Decommissioning and Reclamation plan was developed for the Sulphur Handling Area. This
plan was submitted to Alberta Environment per Approval Number 155-01-05.
The Approval (155-01-05) required the following items to be submitted by December 1, 2004 in
regards to the Sulphur Handing Area:
Industrial Runoff Control System Upgrade. (5.4.1)
Decommissioning Plan (6.2.1)
Land Reclamation Plan (6.3.1) Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan – Sulphur Handling Facility - File No. C25531604
LPG Recovery System
The Phase III groundwater collection system continued to operate. To ensure Nexen is operating
within our remediation objectives, the LPG Recovery System was re-evaluated. Monitoring of the
LPG Recovery System continued. Komex Report: Balzac Gas Plant – 2003/2004 Performance Report – Lean Oil Remediation System – LPG Recovery Area – File No.
C25531605
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
60
Flare Area Review – and Remediation Plan
Komex issued a Flare Area Review – and Remediation Plan report in December 2004. Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504
2005 Activities: the Skimmer System installed in 2003 successfully recovered additional free
product. Two deep cathodic protection wells (CPW) were installed at the Plant.
Flare Area Remediation
The draft Flare Area Investigation Report was finalized. Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504
LPG Recovery System – On-going
Nexen continued to pump contaminated groundwater and to monitor the LPG Recovery System.
In 2005, two collection wells were added under the LPG Bullets as part of the Phase III
groundwater collection system (skimming portion). Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No.
C25532004 (Draft)
Topsoil from 6-33-25 Reclamation
During Field A & R activities at wellsite 6-33-25, clean topsoil (2500 m3) was discovered and
brought to the plant for storage adjacent to the South landfill Area.
Alberta Environment Summary Update
AENV formally requested an update of recent remedial work conducted or planned for 2004/
2005/2006. Nexen conducted a tour for AENV officials (soils & groundwater experts) at the Plant
to discuss specific contaminate issues to support the reports and work that has been conducted at
the facility over numerous years. Komex Report: Balzac Gas Plant – 2005 Environmental Summary Update- File No. C25531700
2006 Activities: As part of the LPG Recovery System two new vertical extraction wells (LPG-5
and LPG-6) were added to expand Phase III of the remediation system.
In April 2006, a soil investigation was conducted in a pit area (Unknown Sump), situated west of
the holding pond in the Flare Area. Exploratory trenching was completed to investigate chloride
and hydrocarbon facility-related impacts. The investigation identified an approximate total in-situ
volume of 6,300 m3 of impacted materials. The boundaries of the excavation all met Tier I
guidelines with the exception of soils along the eastern wall of the excavation, where physical
constraints (roadway and pipeline) limited excavation in this direction. Assessment of an insitu
groundwater extraction system along the eastern wall of the excavation is under review.
A Site Specific Liability Assessment (SSLA) was completed (as required in support of the
Alberta Energy and Utilities Board (EUB) Large Facility Liability Management Program as
detailed in Directives 001 and 024). As a part of this Assessment, site-specific environmental
costs for reclamation and for soil and groundwater quality issues at the Site were estimated.
As a part of the 2006 Environmental Assessment for Management of Contaminated Sulphur and
Materials Contaminated with Sulphur, 34 boreholes were advanced throughout the Sulphur
Handling and Sulphur Block/Basepad Areas of the Plant. As outlined in the D&R Plan for the
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
61
Sulphur Handling Facility, the results of the assessment program were used to define remedial
requirements for soil impacted by sulphur.
The 2006 Soil Monitoring Program involved the sampling of 49 boreholes throughout the Site, in
addition to two background boreholes/piezometers. The most significant chloride and/or
hydrocarbon impacts to soil were observed in the Evaporation Pond, Flare and Formation Water
Handling, and Process Areas. In addition, sulphur impacts in soil were identified in the
Cooling/Blowdown, Plant Maintenance and Sulphur Plant Areas.
As a result of these programs seven new single piezometers (06-43A through 06-49A) were
installed across the Site. Piezometer 93-15A was also re-drilled as it had been damaged by frost-
jacking.
Soil Monitoring Program – Plant Overall
The Soil Monitoring Program was completed throughout the Plant Site per Plant Operating
Approval with Alberta Environment in the fall of 2006. Worley Parsons Komex Report: Balzac Gas Plant – 2006 Soil Monitoring Program - File No. C25531803
Environmental Assessment for the Management of Contaminated Sulphur and Materials
Contaminated with Sulphur
This assessment program was an operating approval requirement. Included in the assessment was
assessment at the following locations:
the sulphur block
sulphur basepad
the slater units
sulphur load out areas
the sulphur soil piles Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur
and Materials Contaminated with Sulphur - File No. C25531803
Decommissioning and Reclamation Plan Sulphur Handling Facility
This report was issued to Alberta Environment (Mar. 2006) as per operating approval conditions.
The D&R Plan was approved by Alberta Environment in June 2006. Removal of the Enersul
Slating Facilities was completed (see below). Future work looked at Industrial Runoff and Site
Reclamation in the Sulphur Handling Area. Worley Parsons Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan Sulphur Handling Facility
The D&R plan was submitted to Alberta Environment in December 2004. Demolition of Enersul
surface sulphur slating facilities began July 2006. The Enersul Slater building was removed and
water tanks, belts, power, etc. were either disconnected or removed. Alberta Environment
required dust control measures had to be undertaken during the removal of the slater building.
Remediation of the Slater Area and upgrading (removing sulphur contaminated sediment from
ditches and installing lined ditches) was completed in 2009.
Unknown Sump Area Assessment - Flare Area
Assessment was completed on area of contamination based on previous flare area soils and
groundwater investigations.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
62
Worley Parsons Komex Report: Balzac Gas Plant – 2006 Soil Investigation in Unknown Pit Area - File No. C25531802
2006 Industrial Runoff Assessment
This assessment was a licence requirement as per current operating approval (155-02-00) with
Alberta Environment. The purpose of the report was to review runoff management at the Plant
and evaluate current practices to determine what improvements could be made to positively
impact the site and the watershed downstream of the plant. Worley Parsons Komex Report: Balzac Gas Plant – 2006 industrial Runoff Assessment - File No. C25531806
Flare Area Remediation Follow-up
Nexen continued to monitor this area to ensure impacts have been minimized and review how
effective remediation activities have been. Overall soils management program conducted in the
fall of 2006 added some piezometers and soil borehole locations.
LPG Recovery System – On-going
Nexen continued to monitor the LPG Recovery. The lean oil collection system (collection of lean
oil which is situated on top of the groundwater table) in the LPG Unit was run throughout the
2006 season (early spring - April to late fall – October). The system was functioning as designed
with minor levels of BTEX showing up in the primary collection system and no BTEX levels in
the aerated discharge point (Trench and Gate System). As well the Phase III lean oil collection
system was run during 2006. The one skimmer pump (pumps only lean oil product) was
transported to various wells throughout the collection season. Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No. C25532004 (Draft)
EUB Directive 001 Site Specific Liability Assessment
The A&R Group in Calgary started the Directive 001 study in conjunction with a consultant and
Plant input. Nexen conducted this EUB compliant study to perform an overall site assessment of
the Plant with all collected data to date.
2007 Activities:
Soil Monitoring Management Plan
Subsequent to the completion of the 2006 Soil Monitoring Program, the soil management plan
was submitted to Alberta Environment within six months of the Soil Monitoring Program that
was conducted in 2006 per Plant Operating Approval with Alberta Environment. Worley Parsons Komex Report: Balzac Gas Plant – Soil Management Plan - File No. C25531901
Sulphur Contaminated Soil Pile Disposal - Phase I
Phase I removal of sulphur contaminated sulphur/soil storage pile located on the plant site began
in the fall of 2007 and continued with Phase II in the first quarter of 2008. Phase I saw 27,395.95
tonnes (16,305 m3) of sulphur contaminated soil pile removed to CCS Rocky Mountain House. Worley Parsons Report: Balzac Gas Plant – Sulphur Soil Pile Closure Sampling - File No. C25532001
EUB Directive 001 Site Specific Liability Assessment
A report was issued to the EUB on 001 Liability Assessment as per the Large Facility Liability
Management Program per EUB’s Guide 024. Worley Parsons Komex Report: Balzac Gas Plant – Directive 001 Site Specific Liability Assessment - File No. C25531801
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
63
LPG Recovery System
Nexen continued to pump contaminated groundwater and to monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No.
C25532004 (In Draft)
New Underground Sulphur Pit Construction
Soils were assessed during the construction of the new underground sulphur pit. Some soil was
sulphur contaminated and segregation and delineation activities were conducted during the
preparation for construction. Some sulphur contaminated soil was removed and placed on the
Sulphur Contaminated Soil Pile (see above). Approximately 3,950 m3 of soil was excavated
during the sulphur pit excavation. Analytical results indicate hydrocarbon and sulphur impacts
remained in the excavation wall and base. Worley Parsons Report: Balzac Gas Plant – Sulphur Pit Construction - File No. 25531902 (In Draft)
2008 Activities:
Sulphur Contaminated Soil Pile Disposal – Phase II
Phase II removal of sulphur contaminated sulphur/soil storage pile located on the plant site began
in the Jan 2008 and was completed April 2008. Phase II saw 58,234 tonnes (~32,352 m3) of
During the 2006 Soil Monitoring Program (SMP), sulphur and salinity impacts were identified
within a soil stockpile (previously referred to as “suspected topsoil stockpile”) in the sulphur
handling facility area.
Excavation and off site removal of the soil stockpile and underlying and adjacent material took
place from November 12 to 26, 2008. Excavated material was transported to BFI Landfill south
of Calgary. The volume received by the landfill was 15,086 tonnes. Worley Parsons: Sulphur Impacted Soil Stockpile Removal in Sulphur Handling Facility at Balzac Sour Gas Plant. File No. C25532007. (In Draft)
Started remediation program based on Sulphur Area Decommissioning and Reclamation Plan
conducted in 2004 and Environmental Assessment for the Management of Contaminated Sulphur
and Materials Contaminated with Sulphur conducted in 2006. The purpose of the report was to
assess areas of the Plant with sulphur contamination issues and provide the following: estimated
volumes of contaminated material, schedule for removal, evaluation of the permeability of the
area storing sulphur, upgrading of ditches, schedule of activities, etc. Worley Parson Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan – Sulphur Handling Facility - File No.
C25531604
Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur and Materials Contaminated with Sulphur - File No. C25531803
Nexen continued to pump contaminated groundwater and to monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No. C25532004 (Draft)
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
64
Unknown Pit Remediation - Flare Area
Remediation of a previously unknown pit in the flare area began in 2008 and continued in 2009.
Remediation continued in 2010 however remediation on hold pending overall strategy
development. Further remediation activities will be reviewed as part of the overall Plant
remediation assessment activities. Worley Parsons Report: Balzac Gas Plant – 2006 Soil Investigation in Unknown Pit Area - File No. C25531802
Industrial Runoff Upgrades
Based on the 2006 Industrial Runoff Assessment the upgrades in the Enersul Area were
commenced in conjunction with the Sulphur Soil Remediation of the Enersul Facilities. Worley Parsons Komex Report: Balzac Gas Plant – 2006 Industrial Runoff Assessment - File No. C25531806
Land Treatment Activities Pipeline Failure 7-15-25 Nov 2007
Land and treatment activities on the soils brought from the 7-15-25 pipeline failure that occurred
December 2007 were completed in September 2008. The soils were treated and then stockpiled
beside the treatment area. Worley Parsons Komex Report: Balzac Gas Field – Pipeline Release Remediation Program at 7-15-25-28 W4M Wellsite - File No.
C50920500
Land Treatment Activities Pipeline Failure 1-8-27 & 6-23 KO Drum Removal
A total of approximately 7,700m3 of excavated soils from 01-08-027-27 W4M (4, 100m
3) and 06-
23-027-27 W4M (3,600m3 ), as well as excess drilling mud from re-entry activities at the BGP,
was treated from 2002 to 2009. The material was initially land surface treated in the TTA next to
the 02-02-026-29 W4M well site, and then stockpiled in an area adjacent to the well site once
remediation guidelines at the time of sampling were met.
Untreated soil was moved within the Plant in 2008, land surface treated, and piled once Tier 1
Guidelines were met. Treated soil hydrocarbon concentrations in analysed samples were below
Tier I guidelines. Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006.
(Draft).
2009 Activities: a sulphur base pad assessment was completed to quantify the amount of possible
recoverable sulphur on the base pads, and the extent of impacts to soil underlying the sulphur. A
total of 23 boreholes were advanced within the east base pad area. Elemental sulphur impacts
above the AENV Tier I guideline were identified to an average depth of 0.65 mbgs in soil
underlying the current base pad.
In 2009, upgrading of the surface water drainage ditch system in the sulphur handling facility
commenced. Impacted soil was also excavated from the drainage system, the underground rail
car, the old slating units and poured sulphur pad within the sulphur handling facility.
The current groundwater monitoring network comprises of 68 piezometers, three culverts and 13
surface water sampling locations. Seasonal groundwater monitoring (fall and spring) was
completed in 2009. The most significant chloride impacted groundwater was present during
these monitoring events in the Flare Area, the Former Process Ponds, and the Evaporation Pond.
The most significant hydrocarbon impacts in groundwater were present in the Flare Area, the
Former Process Ponds, the Plant Recovery area and the LPG Recovery Area.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
Complete remediation program that was started in 2008 along with Industrial Runoff Upgrades in
the Enersul Area. Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan – Sulphur Handling Facility - File No. C25531604 Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur
and Materials Contaminated with Sulphur - File No. C25531803
Sulphur Contaminated Soil Remediation - Sulphur Block and Sulphur Basepad
Continue to develop a plan for basepad reclamation and sulphur block/basepad reclamation.
South Landfill Remediation
The South Landfill remediation was originally planned for 2009 but not competed. Remediation
of this landfill is on hold pending overall strategy development. The area that the landfills are
situated on was characterized and delineated in environmental reports as listed below. Komex Report: Balzac Gas Plant – North and South Landfill Characterisation Program – File No. 25531309
Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9 T01/T02
Conducted minor clean-up activities of sulphur and soil just outside the fence near Plant weigh
scale.
LPG Recovery System – On-going
Continued to pump contaminated groundwater and monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2009-201 Performance Report Lean Oil Remediation System - File No.
C25532104 (Draft)
Unknown Pit Remediation - Flare Area
Remediation of a previously unknown pit in the flare area began in 2008 and continued in 2009. Worley Parsons Report: Balzac Gas Plant – Unknown Sump Excavation Update - File No. C25531802
Began the excavation and removal of soil impacts related to sulphur production. Collected
confirmatory samples in conjunction with this ditch upgrade work. Remedial excavation work
was carried out from August – December 2009. Approximately 29,000 tonnes of sulphur-
impacted soil was excavated and hauled to the BFI Canada Inc. Calgary landfill. Worley Parsons Report: Confirmatory Soil Sampling Summary, Balzac Plant Ditch Excavation – File No.C25532106, 23-March-
2011.
Worley Parsons: Interim As-Built Drawings of Surface Water Collection Ditches Constructed During 2009 at the Balzac Gas Plant -. Report C25532005. December 23, 2009.
DEA UST Removal and Replacement
In 2009 the DEA UST was pressure tested and failed. Since the reason for failure could not be
determined, Nexen implemented replacement plans for the UST. On Sept. 3-4, 2009, the
excavation and installation of a new tank occurred. During excavation soil and groundwater
sampling was conducted and a groundwater extraction system was installed. Approximately
50m3 of impacted soil was excavated from the new DEA UST. Wall and base soil sampling
indicated soil met Tier 1 Guidelines for all parameters except EC at four of the five sample
locations and PHC F2 at a single sample location. Worley Parsons-2009 DEA UST Removal and Replacement - Letter Report. Report C25532107. May 10, 2011. DRAFT
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
66
2010 Activities:
Unknown Pit Remediation - Flare Area
Remediation of a previously unknown pit in the flare area began in 2008 and continued in 2009.
In 2010, approximately 700 m3 of soil from the Unknown Sump was treated.
LPG Recovery System – On-going
Continued to pump contaminated groundwater and monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2009-201 Performance Report Lean Oil Remediation System - File No.
C25532104 (Draft)
2011 Activities:
No update as plant shutdown was being planned.
The figure on the following page provides a cursory outline of past remediation programs.
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description 1989 1991 1992 1993 1994
General Various Locations of the Site
Hydrogeological assessment, installation and sampling of 11 monitoring wells (UMA,
1989)
Assessment of hydrogeological conditions (Piteau, 1992a)
Upgrade of the groundwater monitoring network, installation of 18 observation wells (Piteau 1993a). Geophysical surveys conducted near
the buried south landfills, south of the main Process Area, and down gradient of North and South Cooling Tower Blowdown Ponds (Piteau
1992b).
Piezometers installed on the west side of McDonald Lake (93-15A (R)/C (R) and 93-16A/C) to further
define local background conditions (Komex 1995a). Groundwater monitoring program (Piteau 1993b/c)
Geophysical investigation south of the main Process area to assess the extent of potential subsurface impact associated with a number of former wastewater and surface runoff
ponds (Komex 1995b). Stable isotope investigation in and around the plant ponds, sulphur storage and sulphur loading areas (Komex 1995c). Groundwater monitoring program
(Komex 1995a)
1 Southwest Quadrant
2 South Landfill Install 94-17C bedrock piezometer (Komex 1995b).
18 Sulphur Block/Basepad Geophysical survey in the vicinity of the Sulphur Block storage area (Komex 1994). Install 94-18C bedrock piezometer (Komex 1995b).
19 Sulphur Plant
20 Office Control/Room
21 Process Area
1 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description 1989 1991 1992 1993 1994
22 LPG Unit
23 Power Station Three underground storage tanks containing diesel and gasoline in parking lot were removed (Komex 2000g and 2000h).
24 Sulphur Vat Pond
25 Sulphur Handling Facility
2 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
General Various Locations of the Site
1 Southwest Quadrant
2 South Landfill
3 2-2 Pits/ Treatment Area
4 Evaporation Pond
5 Southeast Quadrant
6 North Landfill
7 Drilling Mud Sump
8 Boneyard/Field Maintenance
9 Flare & Formation Water Handling Area
10 Riparian/Shoreline11 Firewater Reservoir
12 Southeast Process Pond
13 Cooling/Blowdown
14 Plant Maintenance
15 Inlet Compression/Sales
16 Condensate Storage Area
17 LPG/Condensate Loadout
18 Sulphur Block/Basepad
19 Sulphur Plant
20 Office Control/Room
21 Process Area
1995 1996 1997 1998 1999
Groundwater monitoring program (Komex 1996) Groundwater monitoring program (Komex 1997a). First soil monitoring program (Komex 1997b).
Groundwater monitoring program (Komex 1998a). Soil management plan (Komex 1997c) and remedial program work plan
(Komex 1997d).
Groundwater monitoring program (Komex 1999a). Integrated soil and groundwater investigation, twelve piezometers were installed (Komex
1998b). A 5 year environment management plan for the Site developed (Komex 1998d).
Groundwater monitoring program (Komex 2000a).
Soil monitoring program (Komex 1997b).
Identified soil contamination in two former flare pits southwest of the boneyard (Komex 1998b)
Former 2-2 North and South Flare Pits were remediated. Approximately 4600 m3
excavated (Komex 2000c).
Soil sampling program (Komex 1995b) Integrated soil and groundwater investigation (Komex 1998b).
Soil and sludge sampling program (Komex 1995b) Remediation program of the Drilling Mud Pit, soils treated with lime (Komex 1999c).
Soil monitoring program (Komex 1997b). Integrated soil and groundwater investigation (Komex 1998b).
Soil and sludge sampling program (Komex 1995b). Temporary piezometer (95‑20A) installed south of piezometer nest 92‑8A/B
(Komex 1996). Soil monitoring program (Komex 1997b).
Remediation program of the Hydrocarbon Burn Pit (Komex 1999c). Approximately 1600
m3 of accessible soil excavated next to LP flare knockout drum (Komex 1998b).
Remediation programs of the Hydrocarbon Burn Pit (2850 m3 excavated) , the Filter Cake Pond (1400 m3 excavated), the Chemical Pond (2250 m3
excavated) and Slop Tank (excavated 850 m3) (Komex 1999c). Integrated soil and groundwater investigation (Komex 1998b).
Soil and groundwater investigation to delineate known contaminant situations
(Komex 2000d).
Soil monitoring program (Komex 1997b).
Remediation of soil adjacent to the southeast Process Pond. Excavation of 2200 m3. Area was contaminated by a release from a Anderson Exploration Ltd. condensate pipeline. Piezometer 98-29A was installed (Komex 1999d).
Integrated soil and groundwater investigation (Komex 1998b).
Temporary piezometers (96‑21A and 96‑22A) installed down‑gradient of the North and South Cooling Tower Blowdown
Ponds (Komex 1997a).Integrated soil and groundwater investigation (Komex 1998b).
Soil monitoring program (Komex 1997b). Integrated soil and groundwater investigation (Komex 1998b).
Soil monitoring program (Komex 1997b).
Soil monitoring program (Komex 1997b). Integrated soil and groundwater investigation (Komex 1998b). Soil and groundwater investigation to
delineate known contaminant situations in Condensate Loading Area (Komex 2000d).
Soil monitoring program (Komex 1997b). Investigation to determine potential impact to shallow soil (Komex 1997e)
Soil monitoring program (Komex 1997b).
Soil monitoring program (Komex 1997b). Integrated soil and groundwater investigation (Komex 1998b).
3 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
22 LPG Unit
23 Power Station
24 Sulphur Vat Pond
25 Sulphur Handling Facility
1995 1996 1997 1998 1999
Soil monitoring program (Komex 1997b). Identified free phase hydrocarbon product contamination in the LPG
Recovery area (Komex 1998c). Integrated soil and groundwater investigation (Komex 1998b).
Three phase remediation plan implemented. Phase I consisted of a free product recovery
trench and recovery well (Komex 2000e).
Soil monitoring program (Komex 1997b).
Soil monitoring program (Komex 1997b).
4 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
General Various Locations of the Site
1 Southwest Quadrant
2 South Landfill
3 2-2 Pits/ Treatment Area
4 Evaporation Pond
5 Southeast Quadrant
6 North Landfill
7 Drilling Mud Sump
8 Boneyard/Field Maintenance
9 Flare & Formation Water Handling Area
10 Riparian/Shoreline11 Firewater Reservoir
12 Southeast Process Pond
13 Cooling/Blowdown
14 Plant Maintenance
15 Inlet Compression/Sales
16 Condensate Storage Area
17 LPG/Condensate Loadout
18 Sulphur Block/Basepad
19 Sulphur Plant
20 Office Control/Room
21 Process Area
2000 2001 2002 2003
Groundwater monitoring program (Komex 2001a). Update of thee nvironmental management plan for the
Site(Komex 2000b)
Groundwater monitoring program (Komex 2002a). Revised environmental management plan, extending to 2005
(Komex 2001c). Piezometer replacement program (Komex 2003e).
Groundwater monitoring program (Komex 2003a).
Groundwater monitoring program (Komex 2004a). Environmental Summary Update issued for the Site, updating
environmental work completed and planned in the 5‑year environmental management plan (Komex 2003g). Piezometer
replacement as recommended (Komex 2003a).
Ex-situ remediation of hydrocarbon impacted soils from Main Parking Lot, LPG Surge Tank and Condensate Loading Area (Komex 2003b). Characterization and delineation of South
Landfill (Komex 2002c).
A risk assessment of the Evaporation pond initiated in 1998 and updated in 2001. Pond sampled and evaluated for potential to
adversely impact aquatic life due to salinity or metals (Komex 2002d).
Landfill east of the Evaporation Pond discovered along the planned route of the water pipeline (2001d and 2001e).
Characterization and delineation of the North Landfill (Komex 2002c)
Remediation and reclamation of the North Landfill, approximately 8700 m3 excavated (Komex 2004e).
A risk assessment of the Holding pond initiated in 1998 and updated in 2001. Pond sampled and evaluated for potential to
adversely impact aquatic life due to salinity or metals (Komex 2002d).
Delineation program involving both soils and groundwater. The program involved 14 soil sampling boreholes and the
installation of seven piezometers (Komex 2004d).
A risk assessment of the Southeast pond initiated in 1998 and updated in 2001. Pond sampled and evaluated for potential to
adversely impact aquatic life due to salinity or metals (Komex 2002d).
Removal of the surficial sediment layer from the Southeast Process Pond (Komex 2005c)
Sludge layer removed from ponds. North Pond reconstructed with a compacted clay liner (Komex, 2005c)
KVSR sump tank removed, approximately 340 m3
impacted soils excavated where possible (Komex 2003d)
Condensate impact encountered along the fuel gas pipeline path (2001d and 2001e).
Remediation program of condensate loading area, hydrocarbon (4900 m3) and sulphur (2500 m3) impacted
soils excavated (WorleyParsons 2011f).
Removal of two above ground methanol storage tanks, excavation (1000 m3) and soil treatment program conducted on
the underlying methanol impacted soils (Komex 2002b)
Field inhibitor storage tank and sump removed. Impacted soil excavated (345 m3) and disposed
of at the BFI landfill (Komex 2003f).
Soil quality investigation around the main electrical sub-station, trace amounts of
polychlorinated biphenyls (PCBs) and heavy‑end hydrocarbons noted. Approximately 5900 kg of
soil excavated (Komex 2004b).
RDS Sump Tank Excavation (Komex 2003d).
5 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
22 LPG Unit
23 Power Station
24 Sulphur Vat Pond
25 Sulphur Handling Facility
2000 2001 2002 2003
Phase II of the remediation plan, which included installation of a trench and gate system down‑gradient of
the free product plume (Komex 2001f). LP Surge excavation approximately 900 m3 raw condensate/waste
oil impacted soils excavated (Komex 2003d).
Free phase recovery system performance (Komex 2003c)
Phase III of the remediation system was initiated, system designed to remove free product from multiple vertical wells
within the LPG area lean oil plume (Komex 2005b).
Soil quality delineation and remediation programs were implemented to ensure that the Site was suitable for Power Station construction. Approximately 4000 m3
excavated (Komex 2000g and 2000h).
Soil assessment to document pre-development soil conditions (AMEC 2003).
6 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
General Various Locations of the Site
1 Southwest Quadrant
2 South Landfill
3 2-2 Pits/ Treatment Area
4 Evaporation Pond
5 Southeast Quadrant
6 North Landfill
7 Drilling Mud Sump
8 Boneyard/Field Maintenance
9 Flare & Formation Water Handling Area
10 Riparian/Shoreline11 Firewater Reservoir
12 Southeast Process Pond
13 Cooling/Blowdown
14 Plant Maintenance
15 Inlet Compression/Sales
16 Condensate Storage Area
17 LPG/Condensate Loadout
18 Sulphur Block/Basepad
19 Sulphur Plant
20 Office Control/Room
21 Process Area
2004 2005 2006 2007 2008
Groundwater monitoring program (Komex 2005a). Environmental Summary Update issued to address Alberta Environment requests
(Komex 2004c). Decommissioning and reclamation plan submitted to Alberta Environment for removal and replacement of the sulphur area
slating units (Komex 2004f).
Groundwater monitoring program (WorleyParsons Komex 2006a). 2005 Environmental Summary
Update prepared, after a meeting and Site tour with Alberta Environment (Komex 2005c).
Groundwater monitoring program (WorleyParsons Komex 2007a). Soil monitoring program and install of seven piezometers
(WorleyParsons Komex 2006c and 2006d). Decommissioning and reclamation plan updated and resubmitted to Alberta Environment
Groundwater monitoring program (WorleyParsons Komex 2008a). Soil Management Plan developed (WorleyParsons Komex 2007b). Soil management activities summary (WorleyParsons Komex 2008c)
Groundwater monitoring program (WorleyParsons 2009a). Soil management activities summary
(WorleyParsons 2009d)
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Soil investigation in the Unknown Sump (pit) area (WorleyParsons 2009f). Soil monitoring program (WorleyParsons
Komex 2006d).
Excavation of the Unknown Sump, portion of the impacted material sent off Site for disposal,
remaining material stockpiled on Site for treatment (WorleyParsons 2011b)
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Soil monitoring program (WorleyParsons Komex 2006d).
Baseline assessment of soil and groundwater conditions in the vicinity of Sulphur Handling Facility (AMEC 2004) Soil monitoring program (WorleyParsons Komex 2006c).
Removal and off Site disposal of the sulphur/soil stockpiles located southwest of the existing Sulphur
Block (WorleyParsons 2009c).
Soil monitoring program (WorleyParsons Komex 2006c).Construction of a new sulphur pit, impacted soil (3950 m3) excavated (WorleyParsons 2011c).
Soil monitoring program (WorleyParsons Komex 2006d). Installed two vertical remediation Stabilizer Culverts down‑gradient of the stabilizer towers.
7 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
22 LPG Unit
23 Power Station
24 Sulphur Vat Pond
25 Sulphur Handling Facility
2004 2005 2006 2007 2008
Soil monitoring program (WorleyParsons Komex 2006d).Installed three remediation culverts around the CHD system in the LPG area, which are included in the
operation of the LPG remediation system.
Soil monitoring program (WorleyParsons Komex 2006d).
Baseline assessment of soil and groundwater conditions in the vicinity of Sulphur Handling Facility (AMEC 2004) Soil monitoring program (WorleyParsons Komex 2006c).
Suspected topsoil stockpiles removed from Site and sent for off Site disposal Impacted soil underlying and adjacent to the stockpile was also
removed from Site (WorleyParsons 2011e).
Notes Indicates Assessment WorkIndicates Remediation Work
8 of 10 10/11/2011 12:13 PM
TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR
LSU Description
General Various Locations of the Site
1 Southwest Quadrant
2 South Landfill
3 2-2 Pits/ Treatment Area
4 Evaporation Pond
5 Southeast Quadrant
6 North Landfill
7 Drilling Mud Sump
8 Boneyard/Field Maintenance
9 Flare & Formation Water Handling Area
10 Riparian/Shoreline11 Firewater Reservoir
12 Southeast Process Pond
13 Cooling/Blowdown
14 Plant Maintenance
15 Inlet Compression/Sales
16 Condensate Storage Area
17 LPG/Condensate Loadout
18 Sulphur Block/Basepad
19 Sulphur Plant
20 Office Control/Room
21 Process Area
2009 2010
Groundwater monitoring program (WorleyParsons 2010a). Soil management activities summary
(WorleyParsons 2010b)
Groundwater monitoring program (WorleyParsons 2011a). Soil
CONTAMINATED SOILS FOR LANDTRT. 2000 & 2001 KOMEX REPORT
C2553-1206 RERUN SUMPSALES GAS OIL SUMP ELKTON KVSR
OIL SUMP SITE 'G' SUMP FURTHERDELINEATION COMPLETED IN
2006 ON: TRIM SUMP, BULK SUMP
UNDERGROUND STORAGE TANKS REMOVAL- UPGRADE EXCAVATE CONTAMINATED SOILSFOR LAND TRT. 2000 & 2001 KOMEXREPORT C2553-1206 RERUN SUMPSALES GAS OIL SUMP ELKTONKVSR OIL SUMP SITE 'G'SUMP FURTHER DELINEATION COMPLETED IN2006 ON: TRIM SUMP, BULK SUMP
HOLDING POND RISK ASSESSMENT-1998
KOMEX REPORT KI-98-4683KOMEX REPORT C25531301
2-2 PIT NORTH REMEDIATED 1999-2000 OFFSITE TREATMENT OF SLUDGE - THERMAL DESORPTION LAND TREATMENT FOR REMAINING SOILS COMPLETED 2000KOMEX REPORT C25521103KOMEX REPORT C25531204
FILTER CAKE POND REMEDIATED 1998OFFSITE DISPOSAL OF SLUDGES
LAND SURFACE TREATMENT OF REMAINING SOILS KOMEX REPORT KI-2553-10-2
NEW CONSTRUCTION IN FLARE AREA APPROX. 850m .EXCAVATED (1997) AND LAND SURFACE TREATMENT WITH OTHER PIT/POND MATERIAL (1998)
KOMEX REPORT KI-2553-10-02
CHEMICAL POND REMEDIATED 1998OFFSITE DISPOSAL OF SLUDGES
LAND SURFACE TREATMENT OF REMAINING SOILS KOMEX REPORT KI-2553-10-2
2-2 PIT SOUTH REMEDIATED 1999-2000 OFFSITE TREATMENT OF SLUDGE-THERMAL DESORPTION
LAND TREATMENT FOR REMAINING SOILS KOMEX REPORT C25521103 & C25531204
-INHIBITOR TANK & METHANOL TANK REMOVED 2001 UPGRADED CONTAINMENT & STORAGE FOR BOTH TANKS NOW LOCATED IN FIELD BONEYARD. -METHANOL TANK REMEDIATION - 2001 KOMEX REPORT 25531306 -INHIBITOR TANK REMEDIATION COMPLETED 2002.KOMEX REPORT 25531408NEW FACILITIES - DOUBLE WALLED TANKSFIELD BONEYARD
CONDENSATE LOADING AREA DELINEATION COMPLETE IN 1999
EXCAVATION 2000 SULPHUR CONTAMINATED SOILS TO PILE.
KOMEX REPORT C2553-1211 & C25531104
REMOVAL OF SOIL TO FACILITATE CONSTRUCTION OF NEW
SULPHUR PIT - 2007 WPK REPORT 25531902
HYDROCARBON BURN PIT & DITCHES REMEDIATED 1997-1998 OFFSITE DISPOSAL OF SLUDGES LAND SURFACE TREATMENT OF REMAINING SOILS LAND TREATMENT OF DITCHES KOMEX REPORT KI-2553-10-2
LPG RECOVERY AREA-LEAN OIL COLLECTION REMEDIATION ACTIVITIES *DELINEATION OF FREE PRODUCT CONTAMINATION IN LPG RECOVERY AREA-BALZAC GAS PLANT-1999 KOMEX REPORT KI-2553-10-05 *PHASE 1-RECOVERY TRENCH - 1999 KOMEX REPORT C-2553-1106 *DELINEATION OF FREE PRODUCT CONTAMINATION IN CLA AND FLARE AREA-MAY 1999 KOMEX REPORT KI-2553-1104 *PHASE 2-TRENCH & GATE COLLECTION SYSTEM-2000 KOMEX REPORT C-2553-1212 TRENCH & GATE COLLECTION SYSTEM 2001 KOMEX REPORT C-2553-1303 *PHASE 3-2003 EXPAND LPG RECOVERY SYSTEM KOMEX REPORT C-2553-1503 *REMEDIATION OPTIONS ANALYSIS-LPG RECOVER AREA KOMEX REPOT 2553-1102 *PROPOSED EXPANSION OF FREE PRODUCT RECOVERY SYSTEM KOMEX REPORT 2553-1206 *2003-2004 PERFORMANCE REPORT-LEAN OIL REMEDIATION SYSTEM - LPG RECOVERY AREA KOMEX REPORT 2553-1605 *2005 PERFORMANCE REPORT LEAN OIL - REMEDIATION SYSTEM KOMEX REPORT 2553-1702
FUEL GAS INSTALLATIONHYDROCARBON MONITORING RESULTS - 2001 KOMEX REPORT C25531307
ARSENIC DETECTIONS IN SW DUGOUT KOMEX REPORT 2553-1302CONTINUE TO MONITOR
BONEYARD: RESAMPLED 2006KOMEX REPORT C25531901
FLARE AREA DELINEATION OF CONTAMINATION IN FLARE AREA & CLA KOMEXE REPORT 25531104 - 2000 2003 SOILS & GROUNDWATER INVESTIGATION IN THE FLARE AREA - BALZAC GAS PLANT KOMEX REPORT 2551504
SOUTH BLOWDOWNPOND SLUDGE REMOVAL NOV.2000
SULPHER RECOVERY AREARESAMPLED 2006 2006SOIL MGM PLAN WPKREPORT C25531901
PCB REMOVALSUBSTATION #6-2000 & 2002
NORTH BLOWNDOWNPOND SLUDGE REMOVAL & DISPOSAL SEPT.2000
STUDY OF SOIL, SLUDGE AND GROUNDWATER AROUND TEH BLOWDOWN PONDS KOMEX REPORT 2553-7-2
CONDENSATE STORAGE TANK/ LP SURGE FURTHER DELINEATION COMPLETE
2006 SOIL MGM PLANWPK REPORT C25531901
REMOVAL OF PCB CONTAMINATED SOIL IN ELECTRICAL SUBSTATION GROUND GRID-2002 (PARTIAL) PCB REMOVAL CAPAC. BANK MAIN SUBSTATION - 2002
SULPHUR AREA DECOMMISSIONING& RECLAIMATION PLAN - PROPOSALKOMEX C25531604
EFFECTS OF ACID CONITIONS ON ELEMENT DISTRIBUTION BENEATH A SULPHUR BASEPAD KOMEX REPORT K1964374 - 1996
SOUTH LANDFILL AREA (5 CELLS) CHARACTERIZATION PROGRAM COMPLETED 2001 KOMEX REPORT C25531309 7 KI-2553-9
0 100 200 30050Meters
Author: R. McCallumGIS Analyst : M. JanickDept.: GIS Services
Date: June 10, 2011File No: A12780.mxd
NEXEN INC. 801-7th Ave S.W. Calgary, AB. Canada T2P 3P7T. 403.699.4000 www.nexeninc.com
9 Flare & Formation Water Handling Area S W W S S W S W S W S S W
10 Riparian/Shoreline
11 Firewater Reservoir
12 Southeast Process Pond S S
13 Cooling/Blowdown S W S S W
14 Plant Maintenance S S S
15 Inlet Compression/Sales S W S W S S S W
16 Condensate Storage Area S S S S
17 LPG/Condensate Loadout S S W S S W
18 Sulphur Block/Basepad S W S S W
19 Sulphur Plant S S S S W
20 Office Control/Room S
21 Process Area S W W S W S W S S S W
22 LPG Unit S W W S W S W
23 Power Station
24 Sulphur Vat Pond W S W
25 Sulphur Handling Facility S S S S W S S WLSU = Liability Subunit S = Soil W = Groundwater PAHs = Polycyclic Aromatic Hydrocarbons VOCs = Volatile Organic Compounds
Notes: PCBs = Polychlorinated Biphenyls Salinity = pH, electrical conductance, major ions Indicators/Nitrogen = major ions, nitrate, nitrite, ammonia
Contaminants of Potential Concern
Robert McCallum
Text Box
6
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
76
8.3 Soil Conditions
Soil conditions across the property are reasonably understood, with assessment activities having
taking place in most areas over the past ten years. Full delineation of identified soil
contamination has not been completed in most cases due to the presence of infrastructure, lack of
activity within the area, or areas that were deemed to be low risk in the past. With the exception
of the south landfill and the sulphur block/basepad, where delineation efforts have been
completed, and remedial volumes are reasonably understood.
Most point sources of soil contamination are understood across the property, with the exception
of the following locations, where assessment has not yet been completed or has been limited due
to the presence of existing infrastructure that prevented sampling:
Flare/Formation Water Handling Area: various impacts to soil (hydrocarbon, salinity,
alcohol, glycol, PAH, VOCs, amines and metals) at various selected locations. Detailed
assessment as to the extent of each of these contaminants has not been undertaken to date
due to congestion of infrastructure and underground utilities;
Flare/Formation Water Handling Area (unknown sump): soil excavation has been
completed in this area, but was limited along the eastern extent by the presence of
pipelines. Assessment was not feasible under the pipelines at the time of remediation;
Southeast Process Pond: a partial remediation was completed on the southeast process
pond in 2002, but assessment is still required to confirm and better understand salinity
impacts to soil and sediment;
Inlet Compression/Sales: soil impacts (hydrocarbon and boron) were not fully assessed
due to the presence of Building #3-#4 (KVSR);
Process Area: suspected hydrocarbon impacts at the DEA UST. The presence of the UST
has limited assessment to date;
Process Area: general remediation of soil impacts (arsenic, barium, boron, molybdedum,
and hydrocarbon) is not currently possible due to facility operations. The extent of these
soil impacts is not known; and,
Sulphur Handling Facility: sulphur impacted soils around current GXM2 building.
Building is limiting further assessment and delineation.
Numerous other areas across the property have identified soil contamination and delineation is
required to fully characterize the extents of the plume. This assessment work will be completed
in the coming years in order to finalize remedial planning for an appropriate end land use once
equipment and infrastructure has been removed. As this occurs, the remedial plan will be
revisited and revised as necessary.
Sulphur Base Pads
Still marketable sulphur remaining and Nexen is working on a marketing strategy to remove this
material through 2012-2014. This will allow Nexen to attempt to reduce remediation and
disposal options for this material during the remediation time frames.
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
77
8.3.1 Contaminants of Potential Concern in Soil
Several soil, groundwater and surface water environmental investigations have been completed at
the Site. Soil, surface water and groundwater monitoring locations are shown on Figure 6. Based
on findings of the investigations, remedial activities have also been implemented during operation
of the Site. Significant environmental investigations and remedial work since 1989 has been
summarized.
The Plant has been subdivided into component areas and processes and were termed "Liability
Subunits" (LSUs). For the purpose of this report, the LSUs are used to associate areas of concern
(AOC) and COPC with locations of the Site.
A listing of the LSUs for the Site and a plot plan showing the physical location and size of each
LSU are provided in Tables 5, 8, 9, 10 and 11 and Figure 5, respectively. In addition, one non-
traditional LSU was used. This LSU was termed the "Entire Site" and was used for issues or
findings that applied to the Site as a whole (i.e. groundwater impacts underlying several LSUs) or
for concerns/activities that cannot readily be assigned to a specific component area or process.
This LSU is not depicted on the accompanying figures, as it is conceptual in nature.
Previously identified background locations are located in the southwest (LSU 1), southeast (LSU
5) and on the west end of McDonald Lake in areas believed to be undisturbed by Site activities.
Analytical data from these background locations were used in evaluation of COPCs associated
with the Site. Parameters that were identified as COPCs in soil include:
hydrocarbons;
polycyclic aromatic hydrocarbons (PAHs);
volatile organic compounds (VOCs);
metals;
glycols;
amines;
methanol;
salinity (pH, electrical conductivity [EC], major ions);
sulphur; and,
PCBs.
Soil data indicate background sodium adsorption ratios (SAR) in topsoil and subsoil are generally
in the unsuitable category. SAR concentrations reported across the Site are generally consistent
with background conditions, as such, SAR was excluded as a COPC for the Site. EC
concentrations in topsoil and subsoil background samples range from good to unsuitable category
ratings, the variance is likely due to varying concentrations of sulphate in the soil. Background
soil data is limited and, based on the variation observed, it is possible that background
concentrations of sulphate may be higher than currently reported. Therefore, EC concentrations
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
78
across the Site, exceeding currently reported background concentrations may not necessarily be
attributable to historical activities, depending on the ions influencing the EC concentration.
Elevated EC concentrations in some areas of the Site may be attributable to naturally occurring
sulphate concentrations that were not captured in available background soil data. Further
background soil data of the area is required to confirm.
The Balzac Power Station (LSU 23) and 2-2 well site (LSU 3) have been included in subdivision
of the Site as they are functionally attached to the Site. However, the Balzac Power Station
operates under a separate license or approval from the BGP under AEPEA Approval # 136858-
00-00. The 2-2 well site also operates under a separate ERCB well licence # 0022533.
1 Southwest Quadrant 2 South Landfill X X X X X3 2-2 Pits/ Treatment Area4 Evaporation Pond X X X5 Southeast Quadrant 6 North Landfill7 Drilling Mud Sump8 Boneyard/Field Maintenance X X X X9 Flare & Formation Water Handling Area X X X X X X X10 Riparian/Shoreline11 Firewater Reservoir12 Southeast Process Pond X X13 Cooling/Blowdown X X X14 Plant Maintenance X X X15 Inlet Compression/Sales X X X X16 Condensate Storage Area X X X X17 LPG/Condensate Loadout X X X X18 Sulphur Block/Basepad X X X19 Sulphur Plant X X X X20 Office Control/Room X21 Process Area X X X X X22 LPG Unit X X X23 Power Station No Assessment24 Sulphur Vat Pond X25 Sulphur Handling Facility X X X X X X
Salinty - includes EC, pH, chloride, sulphate
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
81
8.4 Groundwater Conditions
UMA conducted a hydrogeological assessment in 1989: installing the initial 11 groundwater
wells. Piteau Engineering (Komex) took over the management of the groundwater monitoring
network in 1992. The groundwater monitoring program has evolved from 1989 to the current
program (2011) with slight analytical modifications taking place over the last 22 years with
approval from Alberta Environment.
Impacts to groundwater have also been assessed over the past ten years, with 68 piezometers
across the property: 48 completed in the weathered till horizon (A-series); 9 at the till/bedrock
contact (B-series); and 11 in the bedrock strata (C-series). The most recent sampling event was
completed in 2011, with groundwater samples (67), culvert samples (3) and surface water bodies
samples (12) collected and analysed.
8.4.1 COPCs in Groundwater
Previously identified groundwater monitoring locations in the southeast (LSU 5) and on the west
end of McDonald Lake are believed to represent background quality for the Site on the basis they
are located up-gradient. Background locations have been identified in the weathered till horizon
(A-series) and bedrock (C-series). Background concentrations for a number of parameters exceed
Notes PAH analysis not completed.Metals - compared results to background 95th percentile - considered above Tier 1 Guideline of background if at least two samples exceeded guideline or background (included manganese, iron)Indicators/Nitrogen - exceeding background - generally above the highest background concentration (chloride, sodium,sulphate, TDS, nitrite, nitrate, ammonia)Organics - exceeding background - above detection limit
Table 11. Detailed Summary of COPCs in Groundwater by LSU
LSU Description A unit B unit C unit A unit B unit C unit
Background
Entire Site
1 Southwest Quadrant
2 South LandfillCl, SO4, Fe, Mn, TDS, Na, Fluoride, NO2, Al, Cd, Cr, Cu, Se, U, Zn
25 Sulphur Handling Facility SO4, Fe, Mn, TDS, Na, Al, Cd, Cr, Cu, Se, U , Zn Cl, Fe, Al, B
Notes PAH analysis not completed.Metals - compared results to background 95th percentile - considered above Tier 1 Guideline of background if at least two samples exceeded guideline or background (included manganese, iron)Indicators/Nitrogen - exceeding background - generally above the highest background concentration (chloride, sodium,sulphate, TDS, nitrite, nitrate, ammonia)Organics - exceeding background - above detection limit
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
83
Chloride in groundwater has been identified in the Flare Area, Former Process Ponds and the
Evaporation Pond. The most groundwater report (2010) shows that chloride is present above
AENV Tier I guidelines in the upper water-bearing zone across the Evaporation Pond area, and
the Flare and Formation Water Handling Area. Elevated chloride concentrations (but not above
Tier I guidelines) are also present across the majority of the property in the upper water-bearing
zone.
In the lower water-bearing zone, the chloride plume is more limited to the Flare and Formation
Water Handling Area (above AENV Tier I guidelines). There is also elevated concentrations of
chloride present across the Process Area and the Sulphur Plant. Finally, in the bedrock zone,
there is a smaller plume of chloride that exceeds the AENV Tier I guidelines, located in the Flare
and Formation Water Handling Area (near McDonald Lake). A few additional isolated areas
across the property also show elevated chloride levels in groundwater in bedrock.
Based on assessment to date, chloride appears to have the greatest potential for reaching
McDonald Lake. Considering the age of the BGP and the estimated groundwater flow velocities
in the weathered till (~2.2m/year), total potential lateral migration of this inorganic constituent is
approximately 100 metres, assuming an immediate release following plant commissioning. It is
possible that chloride from the Flare Area has approached the shoreline of McDonald Lake. No
assessment of McDonald Lake has been completed to date to confirm whether chloride impacted
groundwater is discharging into the Lake.
In the upper water-bearing zone, there were more than ten (10) occurrences of elevated
concentrations of benzene above the Tier I guidelines during the 2010 groundwater monitoring
event. No specific plume boundaries have been defined at this time. In the lower water-bearing
zone, there were only a few locations with elevated concentrations of benzene reported, and only
one location was reported in the bedrock zone.
There is a plume of hydrocarbons in the LPG Recovery Area that has shown in the past (2008) to
have measurable thickness of free phase hydrocarbons. There is an operational remediation
system in place in this area to remove free phased product, when identified. Elevated
concentrations of dissolved phase hydrocarbons and benzene and ethylbenzene are also present in
1 Southwest Quadrant 2 South Landfill X X X3 2-2 Pits/ Treatment Area X X X4 Evaporation Pond X X X5 Southeast Quadrant (Background)6 North Landfill X X7 Drilling Mud Sump X8 Boneyard/Field Maintenance X X X9 Flare & Formation Water Handling Area X X X X X X X10 Riparian/Shoreline11 Firewater Reservoir12 Southeast Process Pond13 Cooling/Blowdown X X14 Plant Maintenance15 Inlet Compression/Sales X X X X16 Condensate Storage Area17 LPG/Condensate Loadout X X18 Sulphur Block/Basepad X X19 Sulphur Plant X X20 Office Control/Room21 Process Area X X X X X22 LPG Unit X X X X23 Power Station24 Sulphur Vat Pond X X25 Sulphur Handling Facility X X
Indicators/Nitrogen - exceeding background - generally above the highest background concentration (chloride, sodium,sulphate, TDS, nitrite, nitrate, ammonia)Glycols - MEA, DEA, MDEA,Metals - includes Iron, Manganese, ....Phenols - likely from organic decay - excluded
BALZAC GAS PLANT
DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012
85
8.5 Surface Water Conditions
Little topographic gradient can be seen across the Site, although the Process area in the northwest
is slightly elevated with respect to the rest of the Site. Surface water often ponds on Site and is
controlled by mechanical pumping.
Currently there are seven open water surface collection areas on the BGP:
Open Drain Collection Ponds
Fire Water Reservoir
North Blowdown Pond
South Blowdown Pond
Sulphur Block Runoff Pond
Sulphur Vat Treated Water Pond
McDonald Lake.
The most important surface drainage feature near the Site is McDonald Lake located on the
western edge of the Process area. No streams enter or leave the lake, and therefore, it is assumed
that the lake is groundwater fed. Overland drainage from adjacent agricultural and pastureland is
also known to accumulate in this depression. Surface runoff occurs mainly during the spring
snowmelt, or immediately following periods of heavy precipitation. Water levels within
MacDonald Lake vary, at the time of writing, the water levels in MacDonald Lake are unusually
high and have partially flooded some areas in the west of the Site.
Table 13. COPC in Surface Water Bodies
Surface Water Pond Groundwater TablesSurface Water Surface Water Guidelines
LSU Description AOC Source Issue COPC Type
Background McDonald Lake
Entire Site 1 Deep cathodic wells
Potential cross-contamination due to improper abandonment
Hydrocarbons, salts Potential
1 Southwest Quadrant
2 South Landfill 2 Former landfill Impacts associated with former landfill
High Pressure Pipelines and Wells current to November 30, 2009 *** Low Pressure Pipelines current to November 1, 2005ROCKY VIEW
FIgure 3. Aerial Photo of existing Thermal Electric Power Plant & Balzac Gas Plant
N
Compaq_Owner
Text Box
Electric Thermal Power Plant
Compaq_Owner
Text Box
Cooling Towers
Compaq_Owner
Polygonal Line
Compaq_Owner
Polygonal Line
Compaq_Owner
Text Box
Aerial photo of the Electric Thermal Power Plant. The power plant which is the primary component of this application document is outlined in yellow. All other infrastructure visible in the photo is associated with the Balzac Gas Plant, and is not a component of this application document.
36
APPENDIX V – PROPOSED 2012 GROUNDWATER MONITORING PROGRAM
J:\2553\25532300\25532306\3.0_Communication\3.6_Letters_Memos_Other\Proposed Changes to 2012 GW\C25532306-CA-LTR GW 2012 Changes-Rev0.doc
14 December 2011 Proj. No.: C25532306 File Loc.: Calgary
Nexen Inc. P.O. Box 239 Balzac, AB T0M 0E0
Attention: Todd Jorgensen-Nelson
Dear Mr. Jorgensen-Nelson:
RE: PROPOSED 2012 GROUNDWATER MONITORING PROGRAM AT BALZAC SOUR GAS PLANT
Groundwater conditions at the Balzac Sour Gas Processing Plant (Plant) have been documented in great detail through monitoring from 1992 to 2011. The main findings of the groundwater monitoring include:
generally, natural groundwater quality in the Plant area is of poor quality as indicated by high sulphate and total dissolved solids (TDS) concentrations;
groundwater flow velocities outside of the process area are low, in all three monitored groundwater zones, primarily due to low hydraulic gradients;
groundwater quality, including in zones of contamination, is relatively stable with small seasonal and annual variability; and
inorganic and organic groundwater impacts related to Plant operation identified within the process area, ponds and adjacent areas are aerially stable and have not expanded greatly over the monitoring period.
Considering the significant hydrogeological information available and the anticipated Plant decommissioning, a major revision in the forthcoming groundwater monitoring program is recommended. Proposed changes to the 2012 program include:
reduction in groundwater monitoring frequency;
reduction in the number of monitoring wells to be monitored;
reduction in analytical schedule; and
concentrating monitoring activities around the process area and perimeter “C” wells.
C25532306-CA-LTR GW 2012 Changes-Rev0.doc Page 2 of 2 14 December 2011
The proposed groundwater monitoring program would include sampling once a year in the spring, instead of spring and fall sampling, with the number of monitored wells reduced. To address operational issues during the 19 year history of groundwater monitoring, several monitoring wells were installed in relatively close proximity to each other, often duplicating and/or confirming information obtained from existing wells. These expansions to the monitoring network were required at the time of installation. However, in view of the Plant decommissioning, some monitoring wells are of lesser importance. It should be noted that during Plant decommissioning and remediation of the area, several wells installed near facilities will be removed. These monitoring wells should be properly abandoned.
Monitoring wells selected for continued monitoring should be sampled according to WorleyParsons’ preferred operating procedures. Reduction in laboratory analysis is also recommended. Testing at select monitoring locations should include:
laboratory analysis for benzene, toluene, ethylbenzene, xylenes (BTEX) and petroleum hydrocarbon (PHC) fractions F1 and F2 and amines; and
field measured parameters including depth to groundwater surface, temperature, electrical conductivity (EC) and pH. If significant changes in EC and/or pH are measured as compared to historical field measurements, a sample should be submitted for routine potability analysis for the well in question. Otherwise, laboratory testing for main ions and dissolved metals should be discontinued.
Based on the information noted above, a recommended analytical schedule is provided on Table 1.
It is WorleyParsons recommendation that Nexen submits proposed changes to the groundwater program to Alberta Environment (AENV) for approval. We trust that the proposed changes meet AENV requirements as well as Nexen’s long-term commitment to environmental protection.
Regards,
Steve Hardy, B.A.Sc., P. Eng. Dr. Tad Dabrowski, P.Eng. Staff Environmental Engineer Technical Director, Hydrogeology
Prairie Business Unit Infrastructure & Environment WorleyParsons Canada Services Ltd.
Table 1 2012 Schedule of Analyses
PROJECT NO.: C25532306
Monitoring Station
Fiel
d Pa
ram
eter
s
BTE
X/F1
ATF
1F2
Am
ine
GPW
WR
2
92-3A X92-3B X92-4A X92-8A X X X92-8B X X X98-8C X X X92-11A X92-11B X92-12A X92-12B X92-13A X92-14A X93-15A X93-15C X X94-17C X X94-18C X X94-19C X X96-22A X98-24A X X98-24B X X98-24C X X98-26A X98-26C X X98-28C X01-33A X01-34A X X03-37A X03-38A X X04-42A X06-44A X06-45A XMW-1A XMW-4A XMW-8A XMW-9A XMW-9B XMW-10A X