Miles Tindal, Millenium EMS Solutions Ltd.
There are a large number of oil & gas sites with salts in soil that exceed one or more generic guideline values. The nature of generic guidelines is that, by definition, they do not uniquely consider site specific conditions and therefore may indicate the potential for an adverse effect when in actuality there is no such potential. Undertaking remedial activities where no potential for adverse effect exists will result in a negative net environmental benefit. Resources (equipment, consultants, money, landfill space, time, etc.) allocated to remediation with no benefit to environmental protection could be used to address more significant environmental problems or to increase the number of sites reclaimed. The benefit of generic guidelines is that they are easily administered with clear remedial endpoints.
Given the concerns noted above with applying generic guidelines to salt sites, an alternative method of managing these sites needs to be found. The alternative method should be efficient (cost, timely) and science-based. Such a process for characterizing and risk assessing salt sites would enable timely, economic regulatory closure and would significantly reduce “net negative” environmental benefit. This would be beneficial to landowners, regulators, the public and industry. Petroleum Technology Alliance Canada has initiated a project to look for solutions to these issues for all relevant exposure pathways and land uses. The current document reports specifically on issues relating to the ecological direct contact exposure pathway (growth and reproduction of plants and soil invertebrates) in native grasslands areas of Alberta.
Salt-Affected Wellsite Closure Project – Best Practices Document
Salt-Affected Wellsite Closure Project – Scientific Rationale Document – Final June 2016
Native Prairie Protocol Presentation – November 30, 2018
Report Salt-Affected Wellsite Closure Project
Salix PTAC MixedGrass Wetland Species – November 2018
Sulphate Borehole Profiles and Site Examples
2018 Native Prairie Protocol – Final Report 2018
2019 Event Presentation – May 2, 2019