Having a problem with your ERCB applications? The ERCB is now called the Alberta Energy Regulator (AER). Do you need a guideline for completing a petroleum development application? Take this list of criteria from Alberta, the centre of this industry for North America.
Since the AER, formerly called the Alberta Energy Resources Conservation Board (ERCB), published Directive 56, entitled Energy Development Applications and Schedules, you can find a complete list outlining steps for applying for a licence to build or use a new development in this sector. The choices normally include pipelines, facilities and wells. This and all other directives can be found on the Alberta AER website, aer.ca. See the current AER Directive 56 document at http://www.aer.ca/rules-and-regulations/directives/directive-056 .
This directive stems from the Oil and Gas Conservation Regulations (OGCR), which you can see on the Canadian Legal Information Institute website, canlii.org. That said, these two documents cover parts of the fundamentals only, and considerable expertise is required to make a credible application. The Board is prepared to help with other questions ERCB applications may require you to address, so look up AER Applications or AER Facilities Applications if you need assistance in this regard.
Generally speaking, prospective developers will do better once they demonstrate that they will follow the regulations precisely. Steps for continued success with the authority include obeying technical rulings and audit requirements as well as encouraging participant involvement and respecting input from regulators, the public (Métis and First Nations peoples, for instance), the industrial proponent, and possibly other groups. An ongoing commitment to the needs of all interest-groups involved is expected from each proponent, right through to the end of the life of the facility operations and beyond. Details are provided in Directive 56.
With that in mind, you can use AER Directive 56 as a guide for your AER Applications in addition to an overview of the relevant regulations overseeing the application procedure for licences. It regulates one component of the industry, while other AER directives exist for other parts of the operation, such as pipelines. It also informs the applicant what information to disclose, how to plan and implement a participant program, and how do handle conflicts and scheduling.Supplemental forms include these Schedules:
One component of the process for AER applications (ERCB applications) deals with how to handle the environment: the earth, air (throughout the whole depth of the atmosphere), land, water, organic and inorganic matter, organisms, and interdisciplinary issues involving multiple natural systems.
When assessing if the activity will change anything important, the government looks at public "safety, economic and property rights." They examine water, air and soil contamination, industrial noise, potential property damage and effects on animals. A development might require an emergency planning zone (EPZ) if pipelines are present. Sometimes the construction of new facilities, such as sour gas plants, is discouraged, especially if there are already facilities in the area. Sulphur recovery and injection is strongly encouraged whenever possible. See this Environmental Protection and Enhancement Act document for an example of AER- ERCB applications and content...Applications for Sour Gas Processing Plants and Heavy Oil Processing Plants: A Guide to Content. The document is at www.environment.gov.ab.ca/info/library/7269.pdf It comes from Alberta Environment and Parks, AEP.
AER- ERCB applications require an examination of nitrogen oxide (NOx) and sulphur dioxide (SO2) emissions, at the very least. Other substances may need examination on a case-by-case basis.
For SO2: How much gas is being burned on a continuous basis? AER Directive 60 goes into greater detail regarding venting, flaring and incineration. Conservation of flared stream gas is strongly preferred and must be considered for feasibility. Refer to both AER Directive 60, Section 7 and AEP documentation for correctly designing flare stacks with regard to ambient SO2 concentrations. SO2 dispersion modelling will most likely be required to meet AEP regulations.
I conduct this kind of modelling, full time. If this is what you need, please see this dispersion modelling description.
For NOx: The AER and Alberta Environment and Parks will both probably require dispersion modelling in accordance with the AEP Air Quality Model Guideline (AQMG) to ensure no exceedences of the Alberta Ambient Air Quality Objectives (AAAQO) are predicted. A facility emitting over 16 kilograms of NOx per hour needs an AEP Code of Practice for Compressor and Pumping Stations and Sweet Gas Processing Plants at www.qp.alberta.ca/documents/codes/COMPRESS.PDF - A facility emitting less than that will still need to design wisely, with stacks at least 20% taller than the building peak and dispersion modelling is still recommended even if not required.
The Province regularly tightens its performance-based emission limits, with new engines currently needing to emit less than 6 grams of NOx per kilowatt-hour. The Directive 56 gives rules for using temporary and third party NOx sources as well.
When one conducts modelling for ERCB applications for AER in Alberta, Directive 56 specifies that the report should include the emission parameters used in the model input. This list includes emission rates in mass per unit time, stack heights, diameters, exit velocities, temperatures, source locations and base elevations. The report shall also have predicted average and maximum concentrations and technical specifications including modelling receptors assigned a description of the meteorological and topographical data, a map of the area and the name and version of the model used.
What if modelling shows exceedences of the AAAQO? The AER can allow exceptions at times, but will want to know why they exist and why they are needed. Applicants need to show how the modelling was conducted by providing all the technical data listed in the previous paragraph and list the maximum predicted concentrations. The Board might then request additional information, including stack diagrams, heating values, statistical data representing how often the AAAQO might be breached and how the operator plans to control the situation (e.g., by using a flare management plan, future mitigations etc.) The process of negotiation can be really helpful in borderline cases, if undertaken thoughtfully.
For Benzene: AER Directive 39, entitled Revised Program to Reduce Benzene Emissions from Glycol Dehydrators provides details for concerned facilities. Check http://www.aer.ca/documents/directives/Directive039.pdf - It outlines additional data needed for submission.
For H2S: AER has defined setback distances, which provide the lowest distance allowed from one of these sites to residences and public areas. The distances depend on the amount of sulphur contained in the facility gas. These exist to ensure public safety. The board set four hazard levels (Level 1, Level 2 etc.), dependent on H2S release rates, the product of volume release and H2S concentration. You can use these to calculate setbacks in accordance with the danger associated with an accidental release. Essentially, if the company elects to place a new well among existing developments, it must follow all existing and new requirements in AER Directive 56, including setback and emergency planning zone (EPZ) regulations.
General Spacing Requirements: The Board specifies distance separation for water bodies, industrial storage tanks, roads, flaring equipment, exhaust pipes, compressors and other features. In addition to AER, the Board regulating ERCB applications, other provincial regulatory bodies may have their say on construction design as well.
The public can become very concerned when they detect odours. An energy facility with very low H2S content, 10 parts per million (ppm) or less in its gas will comply with these regulations by making sure no odours make it outside of their lease boundaries. The data in each of your ERCB applications need to show how you, as the responsible person, will be extra careful when transferring fluids among vessels and/or trucks. Facilities need greater care and diligence when handling gases with stronger H2S content. In many cases, the Board disallows any unburned discharge to the atmosphere. Intermediate H2S concentrations in inlet gas will result in a facility needing to conform to intermediate levels of handling regulations.
Public odours and public safety gives us the primary reasons the setbacks are needed and how the distances are determined. The person submitting ERCB applications to AER needs to spell out how this concern will be handled.
Calgary is in the heart of the Canadian petroleum industry and is home to the head office of Calvin Consulting Group Ltd. This small company specializes in energy-industry air emissions regulations and solutions, including specialty services such as:
Please call Barry J. Lough at Calvin Consulting Group Ltd. at 403-547-7557.
How can you complete your AER applications?
What technical requirements do you need to fulfill?
Have a look at this introduction and references.
Are you concerned about Air Pollution in your area?
Maybe modelling air pollution will get you the answers you need for this problem.
That's what I do full-time. Try it.
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