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ARPEL Environmental Guide No. 14
Guidelines for Conducting Environmental Audits for the Petroleum Industry
August 25, 1997
Funding
This document has been exclusively prepared for the ARPEL Environmental Project Phase 2. The Project
was funded by the Canadian International Development Agency (CIDA) and co-managed by the
Environmental Services Association of Alberta (ESAA) and the Regional Association of Oil and Natural
Gas Companies in Latin America and the Caribbean (ARPEL).
Environmental Services Association of Alberta Regional Association of Oil and Natural Gas
#1710, 10303 Jasper Avenue Companies in Latin America and the Caribbean
Edmonton, Alberta T5J 3N6 Javier de Viana 2345
Tel: (780) 429-6363 CP 11200 Montevideo, URUGUAY
Fax: (780) 429-4249 Tel.: (598-2) 410-6993 – 410-7454
E-mail: info@esaa.org Fax: (598-2) 410-9207
E-mail: arpel@arpel.org.uy
Copyright
The copyright in this document or product, whether in print or electronically stored on a CD or diskette or
otherwise (the "Protected Work") is held by the Environmental Services Association of Alberta (ESAA).
The Regional Association of Oil and Natural Gas Companies in Latin America and the Caribbean (ARPEL)
has been granted a license to copy, distribute and reproduce this Protected Work on a cost-recovery and
non-commercial basis. This Protected Work shall not, in whole or in part, be copied, photocopied,
reproduced, translated or reproduced to any electronic means or machine-readable form without prior
consent in writing from ESAA. Any copy of this Protected Work made under such consent must include
this copyright notice.
Authors
These Guidelines have been prepared upon request of ARPEL and its Environment, Health and Safety
Committee by:
Western Oilfield Environmental Services
1100, 550 - 6th Avenue S.W.
Calgary, Alberta T2P 0S2
Tel.: (403) 266-3286
Fax: (403) 262-3430
E-mail: wci@cadvision.com
Consultants were assisted in detailed drafting and revision by the ARPEL Environmental Audits Working
Group.
Reviewers
Oldemar Ramirez RECOPE
Jayme de Seta Filho PETROBRAS
Enrique Escobar YPFB
Miguel Moyano ARPEL Executive Secretariat
Oscar González Environmental Services Association of Alberta
Disclaimer
Whilst every effort has been made to ensure the accuracy of the information contained in this publication,
neither ARPEL, nor any of its member, nor ESAA, nor any of its member companies, nor CIDA, nor the
consultants, will assume liability for any use made thereof.
Guidelines for Conducting Environmental Audits for the Petroleum Industry Operations
ABSTRACT
Preliminary activities have to be completed before the onsite inspection. This includes
setting up the scope of the audit, selecting representative facilities, scheduling/logistics
and documentation review. Phase I site assessment activities include a detailed
records review, interviewing and a facility/field inspection. The generated data is then
evaluated and a report is prepared. Phase II and III assessments are implemented if a
non-compliance situation is found after Phase I.
A set of specific Protocols and Guidelines are provided for different onshore and
offshore petroleum operations (i.e., Seismic, Drilling, Production, Pipeline,
Transportation and Terminals and Refinery activities). Specific instructions are
provided to conduct a site assessment in the areas of Environmental Planning, General
Operating Procedures, Spill Prevention, Emergency Response, Waste Management,
Abandonment and Reclamation.
INTRODUCTION
The Guidelines for Conducting Environmental Audits for the Petroleum Industry
Operations is a component of the Environmental Audits Project of the ARPEL
Environmental Program Phase 2. The document has been prepared to facilitate a
process of compliance with local and international regulations, compliance with
corporate policies and procedures and protection of the environment by ARPEL
member companies through the implementation of environmental audits. It contains
general information regarding the environmental auditing process as well as specific
Environmental Audit Guidelines for the ARPEL petroleum member companies.
Many Latin American countries have recently adopted laws and regulations for
environmental protection. Within these regulations, some countries are requiring that
routine environmental audits are conducted within the industry sector.
Chapter Title
This section describes the environmental audit process by activities and phases.
Some chapters include examples of checklists and interview questionnaires.
Chapter Title
This section contains specific audit guidelines for onshore and offshore petroleum
operations. Section III has the following chapters:
Chapter Title
Chapter 12 and 13 provide environmental audit guidelines for specific oil and gas
operations.
12.1 Seismic
12.2 Drilling
12.3 Production
Abandonment and
Reclamation Reclamation Plan; Site Dismantling; Closure
of Flare Pits; Tank Removal; Well
Abandonment; Decontamination; Soil
Remediation; Recontouring; Revegetation;
Reclamation Assessment.
Abandonment and
Reclamation Reclamation Plan; Site Dismantling; Tank
Removal; Road Abandonment; Risk
Management; Decontamination; Soil
Remediation; Recontouring; Revegetation;
Reclamation Assessment.
12.5 Refineries
Environmental Planning
and Administration Regulatory Environmental Authorizat ion;Personnel
Training; Environmental Concerns.
Spill Prevention
and Emergency Response Release/Spill Prevention; Spill/Release;
Contingency Plans; Emergency Response .
TABLE OF CONTENTS
LIST OF FIGURES
LIST OF TABLES
BIBLIOGRAPHY
SECTION I
• Review;
• Survey;
• Appraisal;
• Evaluation;
• Assessment; and,
• Inspection.
Operational Audit
The operational audit provides the management of a company with the corporation’s
record of compliance. The audit reviews the systems of internal management and
identifies existing or potential environmental, health and safety problem areas.
Transactional Audit
Typically, the Board of Directors or the executive of the company will request an
operational environmental audit to determine the status of the company, its facilities
and operations and personnel with respect to environmental issues. Management is
responsible for the completion of the audit and for reporting the findings to the Board.
It is essential that the audit team works with management to design the audit to meet
the objectives of the Board and to present a true status report of operations and
facilities with respect to regulatory agency requirements, corporate policy and
procedures compliance and acceptable industry practices within the available
infrastructure.
Audit support also includes allocation of sufficient funds to complete the work and a
commitment to provide funds for the work required to implement the recommendations
arising from the audit.
- Identify the need for additional testing to evaluate the scope, location, source
and nature of any releases or threat of releases of hazardous substances
affecting the property
- Environmental sampling and analysis.
As concerns grow for maintaining and improving the quality of the environment and
human health, organizations increasingly are turning their attention to the potential
impacts of their activities, processes, products and services. An organization can
develop and implement an Environmental Management System (EMS).
1. Corporate Support
In addition to the written environmental policy, an EMS must have written guidelines
which demonstrate how the organization intends the policy to be applied, and these
guidelines are most effective in the form of manuals.
The performance of personnel within job activities may be measured through the
success in reporting. The effectiveness of such reporting programs depends on a good
recording system for such issues as compliance permits, pollution control, waste
management and incidence accountability.
The final component of an EMS is the generation of regular reports which convey the
overall organization’s environmental status. These reports may include a list of all
environmental activities, environmental deficiencies and corresponding mitigating
actions, steps undertaken to ensure continual improvement and projected
environmental activities.
Audit criteria can be defined as laws, regulations, standards, policies, practices and
procedures against which the auditor compares collected evidence about the subject
matter to determine the degree of conformity.
External Standards
Internal Standards
• Corporate policies
• Corporate guidelines
• Corporate standards
• Industry association guidelines
• Facility guidelines
• Good industry practice
• Codes of practice
The responsibility for setting environmental policy rests with the organization’s top
management. The organization’s management is responsible for implementing the
policy and for providing input to the formulation and modification of the policy.
The issues addressed in the policy depend on the nature of the organization. In
addition to compliance with environmental regulations, the policy can state
commitments to:
• Minimize the environmental impacts of new developments through the use of the
integrated environmental management procedures and planning;
• The development of environmental performance evaluation procedures and
associated indicators;
• Embody life cycle thinking;
• Design products in such a way as to minimize their environmental impacts in
production, use and disposal;
• Prevent pollution, reduce waste and the consumption of resources and
commitment to recovery and recycling as opposed to disposal;
• Education and training; and
• Technology transfer.
The corporate environmental policies should state the company’s position with respect
to environmental regulations, management and stewardship. The corporate
environmental procedures should satisfy the requirements of all applicable laws,
regulatory agencies, industry standards and good environmental operating practice.
The organization should also ensure that contractors working at the site provide
evidence that they have the requisite knowledge and skills to perform the work in an
environmentally responsible manner or may provide training for contractor personnel.
The organization should train its employees or members, at all relevant levels, to be
aware of:
The organization should establish and maintain procedures to monitor and measure
the key characteristics of its processes that can have a significant impact on the
environment. This should include the recording of information to track performance
and conformance with the organization’s objectives and targets.
Companies must follow codes and standards for facility design, fabrication and
construction. Standard specifications describe manufacturing processes, chemical
and mechanical property requirements, test methods and requirements related to
specific procedures.
The organization should consider the different functions contributing to its significant
impacts when developing operational controls and procedures:
Operational Audits in the oil and gas industry can be subdivided into:
• Management Audits;
• Exploration Audits;
• Production Audits;
• Refinery Audits;
• Pipeline, Transportation and Terminals Audits;
• Waste Management Audits;
• Baseline Audits;
• Maintenance Audits; and,
• Special (Air Quality, Water Quality, Spill Response, Compliance, etc.) Audits.
Management audits are completed by verification and documentation and selected site
inspections to ground-proof the documents.
Exploration audits are conducted on seismic and drilling activities and must be
scheduled to coincide with the following programs:
Production audits usually examine, where possible, the entire production stream
beginning with the inlet to the facility and ending with the product in storage and/or
departing from the facility.
Refinery audits are conducted at petroleum refining facilities. They require detailed
review of process and installation drawings. Refinery audits can be sub-divided into:
Pipeline audits are primarily associated with maintenance and operations activities and
may include an operational audit component if terminals are a part of the pipeline
company.
Maintenance:
• Vegetation management;
• Erosion control;
• Right-of-way maintenance;
• Emission control; and,
• Land reclamation.
Operations:
• Awareness;
• Leak detection and spill prevention;
• Emergency response and spill cleanup;
• Risk management;
• Hazardous materials and waste management; and,
• Environmental monitoring.
Terminals:
• Waste management;
• Noise;
• Emission control; and,
• Ship/terminal safety operations.
Waste management audits are completed to determine that all materials are disposed
of in an acceptable manner prescribed by corporate procedures or regulations:
• Biological treatment;
• Deep well;
• Evaporation ponds;
• Incineration;
• Land treatment;
• Landfills; and,
• Reclaimers.
Storage and transportation of wastes are also a concern and are included in a waste
audit. Some regulations and guidelines in North America are:
Baseline audits are detailed and extensive. They focus on the company, operations,
site and facility designs. These audits include considerable historical information on:
Maintenance audits are completed after the baseline audits to ensure that
recommendations arising from the baseline audit have been implemented, are
repeated at regular intervals and focus on specific environmental issues with each
audit anticipating a higher standard than the last.
Special audits may include air pollution auditing, water pollution auditing, spill
response auditing, etc.
The following table shows definitions and applications of the different types of
environmental assessments.
Table 1
Types of Environmental Assessments
Definitions Applications
Environmental Impact Assessment
Evaluation of available information (nature of Assessments may determine the relative level
hazard, exposure pathways and receptors) to of risk so that priorities may be established
determine if adverse effects have occurred or for subsequent action.
may occur.
Determines the presence and extent of known
Phase I Site Assessment is typically a contaminants.
historical and operations review.
Table 1 (Continued)
Types of Environmental Assessments
Definitions Applications
Risk Assessment
Laboratory process to identify toxic Identifies toxic compounds that are not priority
compounds released from a site or facility. pollutants and may define new, regulated
The process combines chemical manipulation monitoring requirements.
of samples with toxicity testing and chemical
analyses. Establishes a toxicity level that is independent
of numerical criteria and may be used to
establish Tier 2 criteria for acceptable
remediation levels.
This type of assessment is conducted to Conducted at the time that the site or facility
determine what type of reclamation will be is being abandoned.
required to bring a site to a condition suitable
for release from rental, contractual and Determines what actions must be taken to
regulatory obligations. restore the site to baseline conditions.
SECTION II
Management should carefully select the environmental auditing team. Experience with
auditing and a knowledge of the type of facility and related processes are important
requirements. The current practice in auditing is for the audit to be conducted by either
employees of the organization from outside the work unit being audited or by
consultants. There are advocates for each method.
The selection of the appropriate audit team should place a strong emphasis on people
capable of providing the best professional judgement within the auditing process. It is
essential that auditors possess a strong command of the federal, provincial and local
regulations they will be dealing with on the audit.
• Design engineers;
• District or project supervisor;
• Area operator; and,
• Environmental/risk/safety professionals.
In small businesses, the auditing team may consist of the operations engineer and a
technician. In large businesses, the environmental managers may delegate the team’s
responsibility to regional environmental specialists, who then in turn will select a team.
A key to successful auditing is the budget and time allocated to the acquisition of
relevant information.
It is also important to find individuals whose expertise can assist the audit team leader
in developing an accurate picture of the status of the facility. In addition, these
individuals must have the time available to do their assigned task and a commitment to
see that it is completed in a timely fashion. Each team member must not only be
knowledgeable in his or her area of expertise, but must also be able to translate the
requirements of the regulations and operating procedures to the real world operations
of the facility. The team members must be impartial in their review of the status of the
facility or site. Managers or supervisors of an area may be team members, but may
not necessarily be team leaders. If the audit team member is such an individual,
negative or deficient areas within their own realm or responsibility must be objectively
reported. If this individual is too close to the situation to be impartial, another audit
team member or outside reviewer must be able to supply an objective assessment. In
any case, periodic audits by individuals completely independent of the audited facility
are advisable.
Outside consultants and specialists may serve as audit team members as long as they
are fully qualified with regard to the audit purpose and protocols. Consultants may be
requested to conduct the audit in its entirety.
Audit team leader responsibilities can be divided into those responsibilities which
correspond to the three types of audit activities: preliminary audit activities, site
assessment activities and analysis and reporting.
During the preliminary audit activities, the audit team leader is responsible for:
During the site assessment activities, the audit team leader is responsible for:
• Leading the startup meeting presentation;
• Serving as liaison between team and facility personnel to ensure all team members
are appropriately scheduled to meet with facility personnel;
• Soliciting feedback from each team member on the status of work accomplished
through the audit;
• Performing audit duties as determined by the audit plan;
• Documenting the rationale for changing the scope of the audit (if necessary);
• Understanding the context for and meaning of each finding reported by the team;
• Providing periodic feedback to facility personnel on the status of the audit and the
findings of the team;
• Leading the preparation of recommendations;
• Reviewing all scores and recommendations with key facility personnel prior to the
close-out meeting to ensure the accuracy of all findings;
• Leading presentation of close-out meeting discussion; and,
• Summarizing reporting schedule and format.
During the audit evaluation and preparation of reports, the audit team leader is
responsible for:
• Reviewing working papers and ratings to ensure that all topics were covered and
that all findings are supported by working paper notes;
• preparing the draft report;
• Distributing draft report for comments;
• incorporating comments where appropriate into the final report;
• Ensuring that there is an action plan submitted for comment by the facility (3-6
months after audit); and,
• Following up to ensure the action plan is being followed.
Responsibilities of the audit team members can also be divided into those relating to
the preliminary audit activities, site assessment activities and analysis and reporting.
During the preliminary audit activities, the audit team members are responsible for:
During site assessment activities, the audit team members are responsible for:
During the audit evaluation and preparation of reports, the audit team members are
responsible for:
• Reviewing the draft audit reports for wording changes, suggested input as
necessary, etc.
These activities are necessary to effectively prepare the audit team to efficiently
complete the work and minimize the time spent at the facility to meet the objectives of
the audit. Preliminary audit activities consist of the development of an audit plan. The
audit plan addresses technical, logistical and timing issues and background
information on the facility and the criteria to be used in evaluating the facility.
The environmental audit is comprised of investigation and review of corporate and field
records including engineering and administration files.
• Terms of Reference;
• Selecting Representative Facilities;
• Scheduling the Audit/Logistics;
• Documentation Requirements and Review; and,
• Preparation of Questions for Interviews.
- Management audit
- Exploration audit
- Production audit
- Other or combination of these
The method for selection of representative facilities for auditing can be based on the
size of the facility to be audited.
- Approximately 10-25% of all off-site facilities: well sites, flow lines, pigging
facilities, separators, storage tanks, injection wells, etc.
Plus:
6.2.3 Scheduling/Logistics
When scheduling the audit, the following five factors should be considered:
Prepare and send out the following document lists prior to the audit:
Document Checklist
This document should be sent prior to the audit and should be completed by the facility
staff.
• Administrative/Management;
• Water;
• Air; and,
• Waste Management.
A detailed review, scoring and comment entry should be completed by the audit team
during the audit.
Administrative/Management Data:
• Organizational structure;
• All environmental policies/procedures;
• All environmental reports;
• Minutes or notes of environmental meetings;
• Personnel training records;
• Complaint reports; and,
• Incident Reports.
Regulatory data:
• All federal, provincial and local licenses, permits, certificates, letters of approval,
etc.;
• All pertinent regulatory legislation;
• All correspondence documents with any regulatory agency;
Technical/Operational Types:
• Exploration; and,
• Production/Operations.
Exploration:
Production/Operation:
• Obtain and review site layouts, blueprints and all relevant process flow diagrams
from facility management. These drawings can include surface drainage, sewer
diagrams, tank, equipment and building locations, process flow charts, etc.
• Establish the presence of any major or unusual activities of the operation (eg.
special waste management facilities such as an incinerator) so that the audit team
can prepare appropriately. These activities have to be permitted.
Who to Interview?
• Interview people who have relevant responsibilities and who would be able to
provide the necessary information.
• Include a cross-section from:
- Field/plant management
- Operators
- Maintenance Personnel
- Adjacent Land Owners (optional)
- Chemical hazards/safety
- Waste management
- Emergency response
- Spill clean ups; and,
Many of the activities of the environmental assessment may be completed at the site.
If historical records or reports were noted as deficiencies at an earlier stage of the
audit, that information may be available at the site in written form or verbally, subject to
confirmation, during the site visit. The site assessment is an important component of
the audit process but it must be emphasized that the main purpose of the visit is to
confirm the information the audit team has generated concerning the site.
• Startup Meeting;
• Records Review;
• Interviewing;
• Facility/Field Inspection; and,
• Close Out Meeting.
• Facility manager
• Environmental/safety coordinator
• Instructions
• Agenda review
• Description of audit process - scoring if used.
Miscellaneous:
Existing policies and procedures must be reviewed. Where deficiencies exist, either as
a result of changing regulations or omissions, it should be noted and the matter
scheduled for field review and/or discussion during the interview process. Facilities
files provide design, construction and operational information. Communications with
regulatory agencies highlight incidents or confirm site status. Licenses, permits and
compliance reports note the operating characteristics and point out long term aspects.
Preventive maintenance programs, such as cathodic protection and chemical corrosion
control, indicate the operating problems and the company response to operational
requirements.
The review is generally completed at the main office. However, when information is
not available, site files are reviewed. If the information is still not available, the
deficiency is noted and the data is generated by site inspection. The information
required to complete the records review is presented in table 2.
• Is the facility/field operations complying with all terms and conditions of the permits,
licenses, etc.?;
• Note all deviations from the regulatory requirements;
• Make an ongoing list of these deviations;
• Confirm with facility/field personnel that a deviation actually exists; and,
• Modify list of deviations as necessary.
Table 2
Records Review Topic and Anticipated Source*
* FILES indicates the information required should be available in unit or well files.
F/FILES indicates the information required should be available in the operator unit or plant files
FIELD indicates required information by a site inspection and operator interview if possible.
6.3.3 Interviewing
Attempt to:
In addition:
The inspection is to confirm all the information that has been reviewed by the audit
team and to generate data concerning deficiencies in the records. The site tour
confirms:
• Documents/file review concerns;
• To actually see “the real thing” versus paper model/concept;
• Housekeeping practices;
• The inlet to outlet for process, storage, distribution; and,
• Areas of concern.
As a rule, the auditors should have a set of protocols specific to the activity or facility
they intend to audit. A checklist will reduce the confidentiality concern by acquiring
audit information specifically associated with an activity or a facility, and it will not
present other issues on paper. In the conduct of an audit, a specific audit checklist
should examine:
• Policy;
• Regulations; and,
• Facility Design and Operations.
When to tour:
Examples of field Inspection checklists are included in Chapter 11.0. Section III of
these guidelines contain specific audit protocols and guidelines for different types of
petroleum operations.
The audit team should meet with key facility personnel as a courtesy and:
The audit team must not discuss conclusions with facility personnel during the
meeting.
• Evaluating data;
• Scoring the Audit;
• Reaching Conclusions and Providing Recommendations; and,
• Reports and Follow-up.
After an exploration activity or petroleum facility has been audited, the audit team must
evaluate the results and identify areas and activities of high environmental
performance, as well as areas of concern and environmental liability. The auditor must
evaluate the findings obtained in the records review, site visit and interviews and
present such information so that the significance of the findings is understandable.
The auditor must:
6.4.2 Scoring
Types of scoring:
A- Acceptable
B- Needs minor improvement
C- Needs moderate improvement
D- Needs great improvement
F- Unacceptable
A- 80-100%
B- 66-79%
C- 50-65%
D- 31-49%
F- 0-30%
Challenge:
• Many descriptors
• Many explanations
• Difficult for Reporting
• Difficult to quantify
Benefits:
Protection of Confidentiality
In the situation where a consultant participates in or completes an audit for a client, the
client owns the audit documents, including the final report, and the consultant has no
authority or right to disclose any information concerning the audit, even the fact the
audit was performed, without directions from the client. Even though the consultant
may possess a copy of the report and certain documents, the consultant cannot
provide any information to anyone without written instructions. The audit documents in
the possession of the consultant do not exist. If the consultant does reveal information
concerning the company and the audit, the consulting firm may be liable for civil and
criminal legal proceedings.
The audit team is generally required to prepare a formal written report which should
follow a pre-arranged format or report guideline. The primary focus of an
environmental audit report is:
• To document all environmental audit findings and to identify related issues and
concerns; and,
There is no common report format for environmental auditing. The following section
describes the basic elements of a Phase I audit report.
Scope of work: States the scope of work of the audit and identifies the sites
or operations that were assessed.
Implementation: This is the basis of the report. The audit team must be able
to devise ways and means to deal with the concerns
identified by the audit. It benefits no one to present a
recommendation which cannot be implemented and
undermines the credibility of the audit with operational
personnel.
A technique which has been successful is to prepare parallel reports; the first dealing
with policies, procedures and management based on review, interviews and inspection
of facilities and operations. The report comments on the effectiveness of
environmental management and systems. The second report deals with operations
and compliance with regulations and policies and procedures and the physical status
of the facility or operation based on review, interviews and inspection. The report
comments on the compliance of operations and facilities and includes an inventory of
liabilities or deficiencies.
All findings resulting from the investigations must be included in the report. The report
should specify the dates to which all of the findings relate. Recommended headings
for this section of the report include:
Records review findings relate to all the information identified during the review of
existing policies and procedures, facility files, communication with regulatory agencies,
licenses, permits, compliance reports, etc. Section 6.3.2 contains more information
regarding records review.
Site visit findings relate to the information collected during the site visit. It is
recommended that the descriptions of the observations are presented separately for
each location (i.e., specific wellsite, battery, etc.). For each location, the auditor should
indicate the unsatisfactory observations with an explanation of the problems found.
Working papers and checklists should be included in the audit report. All notes taken
during the audit are called working papers. These working papers document the
information gathered and should include enough information to provide effective
reporting and follow-up.
Final Report
• It must meet the objectives set out in the scope of work and terms of reference.
• It must be concise and include the observations discussed and reviewed at all
close-out meetings.
• The conclusions must be supported by observations and not based on verbal
reports.
• Recommendations must be clear and concise and deal with the issues.
• Implementation procedures, with costs where applicable, must address all
recommendations.
• Finally, the audit team must review their performance in completing the work. They
must critically review the approach to the project, the cooperation of the personnel
they interacted with in the audit, the disruption which was caused to everyday
activity because of the audit and prepare recommendations to improve the
performance of the audit team in all aspects of the work from audit design,
historical review, inspections, interviews, discussions, conclusions and
recommendations and implementation schemes.
• The audit project manager must prepare an Executive Summary of the audit as a
preface to the audit report.
2.0 Introduction
6.0 Interviews
7.0 Findings
9.0 Conclusions
12.0 Appendices
Quality Assurance
The integrity of the audit is the responsibility of the audit team. Every fact must be
verified and every anomaly must be identified and investigated. If, during discussions
or interviews, claims are made that justify certain activities, those claims must be
noted and a follow up performed to confirm that the information is correct.
The simplest method of ensuring the accuracy of the audit report is to review the
findings with operating personnel with discussion of all aspects of the audit.
Supervisors, foremen and area managers should be included in the review. They
should be asked to provide documents to support statements or claims.
Audit Follow-up
It is important that the company is prepared to deal with the findings of the audit before
the audit is commissioned because when a deficiency or liability is reported, the
company has an obligation to rectify the situation as quickly as practicable to
demonstrate the due diligence on behalf of the company. The corrective action may
include aspects of environmental management from modifying policies, operating
procedures or personnel training.
The first step in implementing the audit recommendations is to develop an action plan.
In order to do this, it is necessary to determine the priority or rank of the various
recommendations contained in the audit. The action plan can then be designed to
ensure that high ranking recommendations (non-compliance) be given immediate
attention.
• Regulations;
• Internal policy;
• Professional practice;
• Public perception/local conditions;
• Major environmental hazards; and,
• Operating procedures.
Depending on the size of the audit, it may be necessary to further group the
recommendation into sub-categories so that they can be dealt with more easily. For
example, the different categories may be divided up according to the type of emission,
such as air, water, etc.
The method for assigning priority should be consistent with Best Management
Practices and address factors of interest to management. The recommendations may
be ranked in any of several ways. The following are the more common:
• Probability and severity of the potential hazard and the effect on human health and
the environment;
• The potential enforcement penalties associated with a finding;
• Authority establishing the requirement. Federal legislation is given higher priority
than provincial, and so on; and,
• Impact on public accountability.
The objective of the action plan is to review audit recommendations and implement
appropriate solutions. It provides the opportunity to target where the major concerns
exist and to allocate the resources and personnel to remediate the issue. In addition to
providing the time span for completing the project, it should clearly specify the roles
and responsibilities for executing the improvements. These recommendations, then,
become discrete programs within the organization’s environmental management
program.
It is also possible that some of the recommendations will not be executed. For
example, management may have further information and valid concerns and may not
agree with the findings of the audit. Also, the technology to implement the findings
may be prohibitive or is not yet available. Whatever the reason a recommendation is
not performed, it is important that the justification for this decision be documented.
A major part of the action plan involves scheduling time, resources and budgeting
funds to ensure that the recommendations are implemented. The schedule should
ensure that high priority recommendations are implemented quickly.
Documentation and reporting of the status of action plans are important components of
the environmental audit follow-up. Ongoing reports ensure that management is kept
aware of the degree of completion of action plans, and that all management groups are
kept involved with environmental commitment.
The documentation of action plan activities is also important from the use of this record
keeping for future audit planning, to legal back-up in the event of an environmental
incident. Proof of an initiative in solving non-compliance problems will act as an
element of due diligence if regulatory authorities investigate the incident.
Documentation acts as an element of security, showing that management has acted
positively to remediate environmental problems.
The key technical feature that distinguishes Phase I and Phase II investigations is the
use of quantitative sampling and analytical techniques in Phase II studies. However,
other important nontechnical differences also exist. Depending on the scope of issues
to be dealt with, a Phase II investigation may be much more expensive and time-
consuming than a Phase I assessment. Furthermore, Phase II assessments usually
require contributions from specialized environmental professionals. Unlike Phase I
assessments, the scope, duration, and cost of a Phase II investigation are highly
dependent upon factors such as the methods used; the size of the site; the number,
type, and identity of suspected contaminants; the level of confidence desired in
analytical results; and the environmental matrices (eg. air, surface water, ground water,
soil, plants, animals) to be sampled.
Initial Phase II assessments are necessary at properties where the information from
Phase I indicates that a hazardous materials release has occurred, resulting in
potential human health or environmental hazards. The principal objective of the Initial
Phase II assessment is to confirm whether a release has occurred by implementing a
limited program of collection and analysis of appropriate site samples. The key
characteristic of the Initial Phase II assessment is its limited scope; it is only intended
to confirm the occurrence of hazardous materials. Efforts to fully characterize the
release in terms of extent, magnitude and migration potential are beyond the scope of
the Initial Phase II assessment.
There are four principal components of an Initial Phase II assessment that must be
addressed prior to its implementation:
The sampling plan is the primary document that provides a detailed description of the
scope and nature of the Initial Phase II assessment sampling to be conducted. The
sampling plan clearly states the objectives to the sampling effort in terms of the types
of samples, the number of samples, the analytical parameters and the rationale for
why the sampling is required. Additionally, the sampling plan provides details
concerning methodologies of sample location and collection, preservation,
transportation, analysis, etc.
The scope of an Initial Phase II assessment is generally small enough so that the
required sampling plan components can usually be presented in a single document.
This contrasts with the sampling plan for an expanded Phase II assessment, which,
due to the greater scope of the effort, may require separately bound documents
dedicated to individual topics (i.e. Sampling and Analysis Plan, Quality Assurance and
Quality Control Plan, etc.)
A useful guideline for assessing the appropriate extent of the sampling is to recognize
that the extent of sampling should increase with increases in the availability of
evidence from the Phase I assessment indicative of potential human exposure to
hazardous materials.
If there is no knowledge of the type of hazardous materials that may be onsite, but
there is suspicion of their presence, indicator parameters such as total organic
halogens (TOX), total petroleum hydrocarbons (TPH), specific conductivity, pH, etc.
may be appropriate initial parameters. However, such parameters give only limited
information concerning the nature of contamination. Therefore, whenever possible, it is
preferred that specific analytical parameters be identified.
Format
The Sampling Plan is the central guide to follow to ensure successful implementation
of the Initial Phase II assessment. Therefore, it should present a concise synopsis of
the required sampling and associated procedures and analytical methods.
Table 3 summarizes the information that should be contained in the Sampling Plan.
Table 3
Synopsis of the Format/Content of the Initial
Phase II Assessment Sampling Plan
The plan should identify the number and type of quality assurance samples,
specifically the number of blanks, duplicates, or spikes that will be taken. The
specific QA/QC guidelines to be followed in this program are to be stipulated
by each Region.
Equipment Decontamination
The sampling plan should identify the reagents and any special procedures
associated with equipment decontamination.
Chain of Custody
All samples collected (including blanks and spikes) must be maintained under
chain-of-custody procedures. Chain-of-custody minimizes the potential for
damaging or closing samples before they are analyzed. Chain-of-custody
tracks the possession of a sample from the time of collection, through all
transfers of custody, to when it is received in the laboratory. In the laboratory,
internal laboratory chain-of-custody procedures take over. Investigators should
generally follow regional protocols for chain-of-custody procedures.
Field Operation
The sampling plan should discuss the sequence for conducting the field
activities.
Sampling Methodology
The sampling plan should include sampling methodology including tools and
collection methodology.
Table 3 (Continued)
Synopsis of the Format/Content of the Initial
Phase II Assessment Sampling Plan
Sampling Locations/Rationale
The sampling plan should discuss the technique and level of detection that will
be used to analyze each sample. This should also include a description of
potential false positives/negatives.
Sample Handling
The Sampling Plan must be reviewed to ensure that its principal objectives are met
and to eliminate contradictory information concerning scope and objectives. The
review process will also facilitate a summary of the resources necessary to implement
the Sampling Plan. If required resources exceed available resources, than the
Sampling Plan can possibly be revised to eliminate this conflict.
Prior to conducting sampling at the property, the following steps should be taken:
Prior to arriving at the property to be sampled, the sampling team must make sure that
they have the means to gain access to the property and that they are capable of
identifying the locations/media to be sampled. If sampling is to be conducted at
adjacent properties, appropriate arrangements will need to have been made to secure
permission and access.
A health and safety plan should be prepared prior to initiating sampling that addresses
the following issues:
The sampling plan should be carefully reviewed by the individuals who will be
conducting sampling at the property. This is especially important if the authors of the
sampling plan are not the same individuals who will be conducting the sampling.
Enough time should be allowed between the time of sampling plan review and
sampling to allow issues to be resolved that may surface during review of the sampling
plan.
During implementation of the sampling plan, site conditions may be discovered that
require deviations from the plan. In such circumstances, the nature of the condition
and the rationale for the deviation must be documented. Air quality monitoring should
also be conducted during sampling if the property poses the threat of inhalation
exposure to hazardous materials. The results of the air monitoring would be used to
assess the requirement for using personal protection equipment.
Photographs should be taken to document the conditions of the facility and procedures
followed during inspection of the facility. Types of pictures that should be taken
include:
The Sampling and Field Logbook is a very important document that facilitates
integrating the Initial Phase II assessment results into the Initial Phase II assessment
report. This report will provide the rationale for determining if an Expanded Phase II
assessment is advisable. A unique logbook should exist for each property. The
sequentially numbered pages of the logbook should only contain entries that are
tracked by date and time. Types of logbook entries should include:
Careful tracking of sample shipment and analysis should be provided to ensure that
the samples are analyzed for the appropriate parameters, that all samples sent to the
laboratory are actually received by the laboratory, and that the samples are analyzed
within the prescribed holding times. Depending on the type of analyses being
conducted, sample analysis may require several days to several weeks (sometimes
months for Expanded Phase II assessments). This time lag between sample collection
and receipt of the results must be considered when making projections of the amount
of time necessary to determine the disposition of a property.
Also whereas the purpose of the Initial Phase II assessment is to confirm the presence
or absence of hazardous materials, the objective of the Expanded Phase II assessment
is to characterize the contamination. Characterization refers to:
The Phase II assessment would evaluate the potential impacts, if any, of the property
on public health and environment by conducting an Endangerment Assessment. The
potential exposure of people and sensitive environmental systems would be estimated.
In assessing potential public health impacts, potential pathways and points of possible
human or environmental exposure should be characterized. Environmental
concentrations of significant constituents should be calculated at all exposure points
and compared to applicable standards and criteria.
There is an almost unlimited variety in the scope and complexity of Expanded Phase II
assessments; each one is determined on the basis of the existing data made available
by implementation of the Initial Phase II assessment. The best guideline for assessing
scope requirements for the Expanded Phase II assessment is verification that the
individuals involved with the interpretation of the Initial Phase II assessment results are
experienced with interpreting such results and that they have a working knowledge of
the environmental regulations concerning the occurrence of hazardous materials in the
environment.
Sampling Water
There are different types of waters that can be sampled, requiring different sampling
equipment, but most of the samples are treated similarly once they have been
collected. In the case of groundwater, the drilling of a well and the contaminants that
may be associated with the materials used in well construction are considered to be
part of the overall sampling program. The types of water that may be most commonly
sampled at contaminated sites include surface waters (rivers, lakes, artificial
impoundments, runoff, etc.), groundwaters and wastewaters.
Waters are usually very heterogeneous, making it difficult to obtain truly representative
samples. Solids with specific gravities only slightly greater than that of water are
usually inorganic. They will remain suspended in the flow, but will also form strata in
smoothly flowing channels. Oils and solids lighter than water (usually organic) will
float on, or near the surface. Some liquids, such as halogenated organic compounds,
are heavier than water and will sink to the bottom. The chemical composition of lakes
and ponds may also vary significantly depending on the season. The composition of
flowing waters, such as streams, depends on the flow and may also vary with the
depth.
• Do not include large nonhomogeneous particles, such as leaves and detritus, in the
sample;
• In flowing waters, place the sampling apparatus upstream to avoid contamination;
and,
• Collect a sufficient volume to permit replicate analyses and quality control testing.
For water quality sampling sites located on a homogeneous reach of a river or stream,
the collection of depth-integrated samples in a single vertical may be adequate. For
small streams, a grab sample taken at the centroid of flow is usually adequate. When
a single fixed intake point is used, it should be located at about 60% of the stream
depth in a area of maximum turbulence, and the intake velocity should be equal to or
greater than the average water velocity.
When sampling standing water, the sample should be taken from the downwind end of
the water body if possible.
A professional hydrogeologist or geologist will typically select the location for the
installation of piezometers and/or monitoring wells and supervise the installation of
these wells.
The material for well construction should be selected carefully. Cement used for
polyvinyl (PVC) pipe joints can leach into samples from wells; this can be prevented by
using threaded pipes. Equipment for monitoring wells should be constructed of
stainless steel of other inert materials.
Sampling devices and sample containers are always likely sources of contamination.
Contaminant leaching from sampling devices and containers is very complex and
requires serious attention. Table 4 shows the types of contaminants caused by
materials used in sampling devises and well construction monitoring.
Table 4
Potential Contaminants from Sampling
Devises and Well Casings
There are two general types of samples: grab samples and composite samples. Grab
samples are single samples collected at a specific spot. Composite samples are
derived by combining portions of multiple samples.
Variability arises from the heterogeneity of soils, the size and distribution of the
sampling populations, and the bias of the sampling and analysis methods. Because
soil samples are heterogeneous, it is best to select as large a test sample as practical
for preparation. An extract or digested solution will be more homogeneous and provide
more reproducible aliquots than a smaller portion of the sample.
Composite samples may help overcome the lack of homogeneity over time or in the
distribution of chemical species. At the same time, compositing may dilute peak
values of concern. Therefore, if peak concentrations of analytes are important,
compositing should be supplemented with grab samples taken at sites and times
where higher values are suspected.
The success and reliability of a site characterization program is contingent upon the
proper analytical parameters being run on the soil samples. If the analytical
parameters are not sufficient to identify and characterize the complete contamination
There are several steps that must be taken when determining which analytical
parameters must be requested to complete a site characterization program. These
steps are:
2. The area that the sample(s) was collected from must be identified.
5. The analytical request must be made. Ensure that the control sample is
adequately tested to determine the background levels of contaminants that may
be present as a result of neighbouring operations.
Small, relatively simple operations tend to have easily identified contaminant streams.
For example, an oil well with no water or sand cut which requires no downhole support
chemicals will have only one contaminant stream: crude oil. However on large
integrated facilities, or on small facilities which have had support operations completed
on them, there will be many contaminant streams.
Consider the oil well discussed above. Obviously, the oil well had to be drilled, which
resulted in the generation of drilling wastes. Depending upon the handling of the
drilling waste, it may be present on the site as a contaminant. Also assume that the
well has been frac'ed in order to improve production. If the frac fluid was blown back
onto the site, the fluid may be present as a contaminant in the soil. An examination of
the operating history quickly changes a "simple' site into one with several potential
contamination streams.
Larger facilities, such as gas sweetening facilities, or large integrated facilities, such as
batteries with treating operations and gas processing, will have an even larger number
of contaminate streams.
The following table can be utilized to assist in the identification of the contamination
streams normally associated with various facilities and operations. It must be stressed
that this table does not address all possible operations or all potential contaminant
streams possible for any given facility or operation. The experience and expertise of
the site assessor must be utilized in determining all of the potential contaminant
streams.
Table 5
Potential Contaminants of Operations/Facilities
• Crude oil with a high content of sodium chloride. (This includes emulsions of crude
oil and produced water with high sodium chloride content);
• Glycol used to scavenge produced water (in those cases where the produced water
has a high content of sodium chloride); and,
• Used lubricants, in particular engine oils. These lubricants often contain high
contents of heavy metals, in addition to the petroleum hydrocarbons.
All contaminant streams must be closely assessed in order to ensure that there are not
multiple contaminants present in that stream. In many cases a simple examination of
the process which generates or contains the stream is sufficient to determine whether
or not multiple contaminants exist. However, in other cases it is necessary to utilize
analytical process to determine the presence or absence of multiple contaminants.
Analytical Parameters
The following table can be used to assist in the identification of the analytical
parameters that should be requested for environmental samples. It must be stressed
that this chart should only be used to assist in the selection of analytical parameters.
The final analytical request must be based on the assessors' knowledge of the
individual facility (i.e. its operations, its history, its potential waste streams, and any
other unique factors).
Code/Analysis Code/Analysis
Table 6
Analytical Parameters
Crude Oils, Hydraulic Fluids O&G, C60, Met, Sal O&G, C60, Met, Sal
Waste Petroleum Products O&G, BTEX, C60, Met, PCB, O&G, Met, Tox
PCP, EOX
Condensate THE, BTEX, O&G, Sal THE, BTEX, O&G, Sal
Tank Bottoms (Crude Oil C60, O&G, Met, Sal O&G, Met, Sal, Tox
Storage)
Frac Fluid/Blowdown NO3, Gm, Sal, Tox NO3, Sal, Tox
Drilling Wastes (Muds, Fluids, O&G, Met, Sal O&G, Met, Sal
Cuttings)
Pit Fluids N/A O&G, Met, Sal, Tox
(Flare/Evaporation/Storage)
Pit Sediments EOX, Met, O&G, PAH, PCP, N/A
PCB, Sal, THE
Glycols BTEX, Met, Sal, Tox BTEX, Met, Sal, Tox
Downhole Support Chemicals BTEX, Met, Sal, Tox BTEX, Met, Sal, Tox
Creosotes, Tars C60, EOX, Met, PAH, PCB, O&G, EOX, PAH, PCB, PCP
PCP
Herbicides Hb, Gm, Tox Hb, Tox
Analytical procedures will often provide erroneous or misleading results, even though
the procedure has been completed in strict accordance to recognized and approved
laboratory protocol. The reasons for these erroneous or misleading results are
numerous, and include:
• There is naturally occurring material in the sample matrix which will interfere with
the analytical procedure, obscuring the results. For example, if a standard
hydrocarbon analysis is conducted on a soil with a high organic matter content,
some of the natural soil organic matter will be identified as hydrocarbon. This can
lead to the analytical results being misinterpreted as showing a higher percentage
of petroleum hydrocarbons being present in the sample; and,
• There are multiple contaminants present in the soil, and one or more of those
contaminants interfere with the analytical procedure. For example, a soil with a
high sodium chloride content may show high extractable organo-halogen content, a
result of the chloride interfering with the procedure and showing higher EOX
content that is truly present.
A result that shows a higher content, or the presence of a contaminant which is truely
not present is known as a false positive. The opposite, a result that denies the
presence or shows a lower content of a contaminant than is truly present is known as
a false negative.
- Surface features
- Contaminant source investigation
- Meteorological investigations
- Geological investigations
- Soil investigations
- Groundwater and surface water
investigations
- Human population surveys
- Ecological investigations
- Surface features
- Meteorology
- Surface water hydrology
- Geology
- Soils
- Hydrogeology
- Demography and land use
- Ecology
General Approach
The general approach for conducting a phase III evaluation of possible remedial
options and for identifying remedial alternatives can be divided into two parts:
The first part consists of a two-stage screening process to narrow the range of
remedial alternatives to be evaluated in the second part. The approach to performing
each part of a remedial alternatives analysis is described below.
The initial phase would involve the development of a comprehensive list of general
remedial actions to be considered. Data from the Phase I and II assessments would
be reviewed to identify general categories of response actions. The remedial
alternatives considered at this stage should consist of general actions that broadly
define the nature of the required response. By eliminating inapplicable responses at
this stage, the universe of potential remedial actions to be considered in the following
steps is substantially reduced, and the emphasis can be placed on alternatives with
greater potential applicability to property problems under consideration.
Performance Standards
A key factor in the first phase of remedial alternatives analysis for the property is the
establishment of appropriate performance standards or cleanup criteria. The
development of appropriate performance standards or cleanup criteria for the property
provides a firm basis for the evaluations of remedial alternatives. Suggested
performance standards should, where possible, be formulated and presented in the
form of target levels (i.e. concentrations) for specific contaminants (where such levels
are available) and/or goals for contamination control (i.e. prevention of further
contaminant migration).
Property-specific factors affecting risks to public health and the environment (such as
the nature and extent of actual and projected containment migration, dispersion, and
attenuation effects on contaminant levels at downstream locations, human and biotic
populations, and systems at risk ) should also be evaluated in developing a cleanup
criteria.
The next step in Part 1 of the remedial alternatives analysis should consist of a
preliminary screening process to further narrow the range of alternatives requiring
detailed analysis. Lists of specific remedial technologies included in the general
technologies should be combined to develop alternatives required to mitigate any
property problems identified.
be noted that a “no action” (no further study or remediation) alternative should be
included in the detailed analysis.
Part 2 requires the development and detailed specification of conceptual designs of the
remaining remedial alternatives. The detailed analysis should include: detailed cost
estimation, including distribution of costs over time; evaluation in terms of engineering
implementation of constructability; an assessment of each alternative in terms of the
extent to which it is expected to effectively mitigate and minimize damage to and
provide adequate protection of public health, welfare, and the environment; and
analyze any adverse environmental impacts, methods of mitigating these impacts, and
costs of mitigation. To meet these requirements, detailed technical, economic,
environmental, legal/regulatory, and public health evaluations should be conducted.
The potential impacts, if any, of each remedial alternative on public health and the
environment would be evaluated in detail and would assess potential exposure of
people and sensitive environmental systems, potential exposure pathways, and
populations at risk. Environmental concentrations of the “indicator chemical” identified
by the Phase II assessment should be estimated at all exposure points and compared
to applicable standards and criteria.
The results of the detailed analyses should be summarized in a tabular format that
compares cost, health risks, environmental impacts, performance, technical reliability
and other important factors; this table will facilitate the selection of a preferred
alternative. The alternative selected should be the lowest cost alternative that is
technologically feasible and reliable and which effectively mitigates and minimizes
damage to and provides adequate protection of public health, welfare or the
environment.
• Biological Technologies;
• Thermal Technologies;
• Physical Technologies;
• Chemical Technologies; and,
• Encapsulation Technologies.
Biological Technologies
Micro-organisms such as bacteria are used to remove contaminants from media (soil,
sludge or water). Generally used on organic contaminants to reduce them to
components such as carbon dioxide and water. Some micro-organisms incorporate
inorganic contaminants into cellular material.
Thermal Technologies
As the term implies, heat is used. Contaminants are either volatilized and later
recovered, or burned to breakdown or recombine organic components.
Physical Technologies
Physical separation processes, such as adsorption, stripping, extraction, etc. are used
for both organics and inorganics.
Chemical Technologies
Encapsulation Technologies
Chemicals are immobilized and prevented from migrating. The process can be done in
situ or in processing equipment (in tank). Technologies include vitrification,
solidification and asphalt incorporation.
Remediation Criteria
Remediation criteria are the target levels and/or allowable levels of a substance
allowed in a matrix. These criteria determine whether or not a site is considered to be
contaminated. There are two general types of remediation criteria: numerical criteria
(also known as regulatory criteria), and risk based criteria.
Numerical Criteria
Numerical criteria are the most common form of remediation criteria. These numerical
limits for contaminants in soil, water and air are developed by regulatory agencies (or,
in some cases, other organizations) to regulate contaminated materials and sites in
order to protect, maintain and improve the environmental quality at those sites. These
criteria are general, and are developed by taking into account the effect of the
contaminant on both human and environmental health or through very generic risk
assessments. For these reasons, numerical criteria are not acceptable in all
situations.
Some numerical criteria are broken into categories based upon land-use. For
example, different criteria may be applied to land used for agricultural, residential, or
industrial purposes. The criteria for a particular contaminant on industrial land may be
much higher than that for residential land. These sliding criteria are based partially on
risk, again showing how numerical criteria are derived from risk based studies and
data.
Numerical criteria are often further divided into Assessment Criteria and Remediation
Criteria. Assessment Criteria are utilized during Initial Phase II Site Assessments in
order to determine if an Expanded Phase II Site Assessment is required. If substances
are identified during the initial Phase II Site Assessment at or above the Assessment
Criteria values, then an Expanded Phase II Site Assessment should be implemented.
Assessment criteria are developed by referencing the "typical" or "representative"
background levels of substances in the environment. The theory behind this
developmental procedure is that if a substance is present above its "normal"
background level, it is likely a non-natural occurrence. However, it must be recognized
that the background levels of various substances will vary from site to site, not too
mention the variance between areas with varying surface geologies, and these generic
assessment criteria can be misleading.
Remediation Criteria are used as target levels. That is, once the substance identified
as a contaminant reaches a level less than the value identified as a Remediation
Criteria (whether it is through the institution of a remedial program, or through more
detailed sampling and assessment), the material should no longer be considered
contaminated.
The risk-based criteria must be developed using credible and accepted scientific
practices and principles. Finally, risk-based criteria are not acceptable in all cases, nor
are they always acceptable to regulatory agencies. When-ever risk-based criteria are
going to be developed and/or utilized, the regulatory agencies should be consulted.
The process required to develop risk based criteria is complex and variable. It is fully
explained in risk assessment and risk management resources, and is beyond the
scope of this manual.
Criteria are best utilized to assist in the development of both site management plans
and in the development of remediation objectives. The remediation criteria are utilized
as a threshold value. Those sites which have had uncontrolled releases of
substances, and now exceed the concentration listed in the remediation criteria, are
identified as sites which require management. Those sites which do not have
substances exceeding the "threshold" values do not require additional management.
• the use of existing remediation criteria as remediation target levels saves both time
and money, allowing a faster design and implementation of a remediation program
and,
• the existing regulatory framework may not have any numerical remediation criteria;
• the organization may want to eliminate the need to conduct risk assessments and
develop site specific risk based criteria on large remediation projects or site
management schemes; and,
• the organization may be active in more than one regulatory jurisdiction, and may
wish to adopt one set of numerical criteria acceptable to all jurisdictions in order to
ease environmental operations.
The development of internal remediation criteria is best done in the following manner:
a) Identify the existing numerical remediation criteria and regulatory criteria (as well
as any draft or interim guidelines) for all of the regulatory jurisdictions in which
the organization has operations (or plans to have operations).
b) Compare the criteria, selecting the most stringent criteria for each category.
Record these values.
c) Collect site specific risk based criteria generated during previous remediation
and risk assessment programs completed for/by the organization. Record all
values, and note the site sensitivity.
e) Compare all recorded values, selecting those which are the most stringent.
Caution must be taken when selecting criteria values generated for site specific
risk based criteria. Often, these criteria will be exceptionally stringent,
particularly in those areas where receptors are both sensitive and in close
proximity. The adoption of this list of numerical criteria generated through this
process will result in the organization operating to a remediation criteria equal to
or better than the requirements of any regulatory jurisdiction within which they
operate.
It should be noted that this internal numerical remediation criteria list must be
assessed each time any of the regulatory jurisdictions within which the organization
operates adopts a new set of regulatory criteria. This will ensure that the internal
remediation criteria do not result in the organization’s operations becoming non-
compliance.
Example Criteria
The following table provides an example of remediation criteria that have been
generated by referencing numerical remediation criteria from Canada. The criteria
which have been referenced are: "Interim Canadian Environmental Quality Criteria for
Contaminated Sites" and the "Alberta Tier I Criteria for Contaminated Soil Assessment
and Remediation".
Table 7
Remediation Criteria for Contaminated Sites
Note: All values in µg/g dry weight or µg/L unless otherwise stated.
CONTRACTOR/CONSULTANT AGREEMENTS
COOMPLIANCE REPORTS
(NOTE DEFICIENCIES)
MONITORING SCHEDULE
(WEEKLY, MONTHLY,
ANNUALLY?)
SURFACE WATER MONITORING
(RECORDS KEPT?)
ON-SITE GROUNDWATER MONITORING
WATER WEl.LS WITHIN 1 Km
ARE WATER WELLS MONITORED
WASTE MANAGEMENT
MSDS/WHMIS MATERIAL ON-SITE MSDS/WHMIS MATERIAL COMPLETE
HEAD OFFICE
FIELD FACILITY
WASTE REGULATIONS TDG
WHMIS
MSDS
PUBLIC HEALTH
OTHER
NOTE DEFICIENCIES
HAZARDOUS WASTE/DANGEROUS
GOODS INVENTORY (COMPLETE?)
(TYPE, VOLUME,. LOCATION, SOURCE)
SHIPPING RECORDS
(COMPLETE?) RECORDS LOCATION
RISK ANALYSIS
CATHODJC PROTECTION CATHODIC TYPE
NON-DESTRUCTIVE TESTING
SPILL RECLAMATION
COMMENTS
• Administration/management;
• Air;
• Water;
• Safe work permits;
• Waste;
• Operations/process control/maintenance;
• Laboratory; and,
• Emergency response.
ENVIRONMENTAL AUDIT
101 Policicles
102 Responsibilities/Training
Utilizing the information generated by the records, files review program and biophysical
descriptions, each facility and well site is inspected to determine the environmental
status and impact. Examples of inspection forms are included in this chapter.
Additional information about Field Inspection Checklists is included in Chapter 6.0.
WELLSITE CHECKLIST
ENVIRONMENTAL PARAMETERS
COMPANY _________________ FILE #: ________________ INSPECTOR(S) ________________
OPERATOR _________________ FIELD: __________________ DATE: ________________
ALTA: LSD ______ SECT _____ TWP _____ R _____ W _______M
BC: MAP ______ UNIT _____ SHEET _____ ZONE____CENTIZONE____SUBUNIT____
SITE STATUS:
SHUT IN _______PRODUCING _______ SUSPENDED _______ ABANDONED_______
IN USE _______UNCONFIRMED _______D&A _______NOT DRILLED_______
CAPPED (STANDING CASED) _______
POWERED BY:
PROPANE____NAT GAS____ELECTRIC ____CASING GAS____ OTHER____
ENVIRONMENTAL PARAMETERS
TANK BERMS ADEQUATE: (IF YES HOLDS 1.5 TIMES VOLUME OF LARGEST TANK IN BERM)
YES / NO
WELLSITE CHECKLIST
ENVIRONMENTAL PARAMETERS
FLUID IN PIT: WATER/ OIL/ BOTH/ NOTHING
SUBSIDENCE: YES / NO
COMPACTION: YES / NO
IS TOPSOIL STOCKPILED?YES / NO LOCATION: ___________________
LIVESTOCK CONCERNS: ___________________
SPILL LOCATION:
ACCESS ROAD/ ON LEASE/ OFF LEASE/ PIPELINE ROW/ OTHER
WELLSITE CHECKLIST
ENVIRONMENTAL PARAMETERS
EROSION:
CONTROLS IN PLACE:YES/ NO TYPE __________________
COMMENTS:
WATER QUALITY:
NO. OF DOMESTIC WATER WELLS WITHIN 1 Km_______________
PROXIMITY OF WATER WELLS TO SITE _______________M
PROXIMITY OF WATERCOURSE/WATERBODY _______________M
NAME/TYPE: ______________________________________________
IS SURFACE WATER AFFECTED? YES / NO
IS SURFACE WATER THREATENED? YES / NO
AIR QUAL(TY:
AIR QUALITY AUTHORIZATIONS ON SITE? YES / NO
WIND SOCK VISIBLE: YES / NO
EXCESSIVE NOISE: YES / NO
NOISE SOURCE: _____________________________________________
ODOUR: YES / NO SOURCE: ________________________
BIOPHYSICAL ASPECTS:
ADJACENT TOPOGRAPHY
LEVEU GENTL Y ROLLING/ STEEPLY ROLLING/ MOUNTAINOUS
VEGETATION ON SITE:
% BARE ON WORKING AREA______________
% BARE ON PERIMETER AREA_____________
VEGETATION TYPE (WEEDS, CONDITION,ETC.):
______________________________________________ .1 i
WELLSITE CHECKLIST
ENVIRONMENTAL PARAMETERS
VEGETATION CONTROL:
NONE/ CHEMICAL/ MECHANICAL ADEQUATE?: YES / NO
CHEMICALS USED (IF KNOWN):
___________________________________________________________
WASTE CONTROL:
WASTE NAME WASTE VOLUME STORAGE LOCATION DISPOSAL METHOD
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
HOUSEKEEPING:
GOOD ________ AVERAGE ___________ POOR _____________
RECLAMATION:
___________________________________________________________________________
(STANDARD RECLAMATION, NO OBSERVABLE EXTRA LIABILITIES)
COMPLIANCE:
___________________________________________________________________________
(REMEDIA TION CAN BE DEFERRED UNTIL FINAL ABANDONMEN.T)
NON-
COMPLIANCE:__________________________________________________________________________
(REMEDIATION CAN NOT BE DEFERRED UNTIL FINAL ABANDONMENT)
PHOTO LOG:
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
WELLSITE CHECKLIST
ENVIRONMENTAL PARAMETERS
SITE DIAGRAM:
LEGEND:
slope direction
.fencing
COMPRESSOR SITE
TANK CONTENTS
SECTION III
ENVIRONMENTAL AUDIT
PROTOCOLS AND GUIDELINES
The following elements are common to all physical assessments and inspections:
Prior to any field inspection, all related operational activities and facility
processes must be identified and understood.
Verification activities confirm that regulations and policies are being adhered to,
identify gaps in common policies and standards and confirm that management
control systems are in place.
It is important to understand how the facility design works and what operations
are required to maintain facility processes. An initial activity is to verify facility
design by physically walking through the process from the start where raw
product enters to the end of the facility where produced products such as oil or
gas leaves.
Facility operations require many types of materials to complete oil and gas
processing activities. The audit program should utilize material balancing
studies to determine all feedstock, product and effluent streams are accounted
for.
The site walkover confirms all the information generated. It is important that a
complete assessment be undertaken of the facility site. This assessment
should involve walking around the boundary site and a detailed walk within the
site area to observe any potential or existing environmental problems.
CHAPTER 12.0
12.1 Seismic
12.2 Drilling
12.3 Production
12.5 Refineries
12.1 Seismic
Environmental Planning
Waste Management
SEISMIC
ENVIRONMENTAL PLANNING
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any exploration program. Special conditions and restrictions shall
be reviewed and enforced.
Audit Guideline:
• Review the project records to ensure that all required permits, licenses and
regulatory authorizations were obtained prior to the start of any field operations and
make sure that all information in writing is available on site. Record permit/license
numbers and verify information in the field.
• Review records to verify that consent of the landowner or land occupant has also
been obtained prior to any work. Look for field report sheets on
landowner/occupant contacts.
• Verify through interviews that the project supervisor is aware of any restrictions and
environmental concerns and has provided this information to the contractor. Verify
that those restrictions are enforced with the contractor and personnel, and that the
local government has been contacted about the project prior to the operations start.
• Identify if regulatory personnel will be inspecting the seismic work and attempt to
coordinate the site visit and meet with the government person in the field.
SEISMIC
ENVIRONMENTAL PLANNING
Audit Protocol:
The planning of seismic operations shall be undertaken in a manner that will anticipate
problems and minimize the effects of the operations.
Audit Guideline:
• Inspect site to verify that environmental concerns were considered during the
planning of the seismic operations. These concerns may include loss of timber,
effect on forage and crops, effect on wildlife, water pollution, erosion potential on
slopes, access and fence crossing requirements.
• Review records and indicate if there are any water quality monitoring programs.
Record any information available if such programs have been implemented.
• Verify that environmental concerns were considered during the planning of access
roads. Existing roads should be used as much as possible to minimize
unnecessary road construction and encroachment on the adjacent land. To
minimize the need for deep cuts, the planner should avoid steep gradients and
identify the areas for detours. Access road location should minimize disturbance to
watercourses and sensitive areas. Clearing widths should be kept to a minimum.
Changes to natural conditions should be minimized while attaining maximum
erosion control.
• Verify through interviews that the work crew has been instructed to stay on
designated trails to avoid trampling of crops.
• Verify that the base camp and existing fly camp were built according to the
recommended waste water regulations.
• Verify that landowners have been contacted prior to any explosive detonations so
that livestock is moved away from shot points. Seismic work can impact upon
livestock sensory systems. It may also be disturbing for livestock to be in the area
when large work crews are in the field.
• Verify that work crews have been instructed to avoid harassment of wildlife.
• Verify that attempts have been made to schedule project activities to avoid the time
periods when high water levels occur in marshes. Walking across marsh areas
can disturb the habitat provided by the marsh. Spawning periods of fish in rivers,
streams and creeks should be taken into consideration to avoid disturbance during
critical periods. Efforts must be made to avoid damage to spawning beds at all
water crossings.
• Identify if limitations of seasonal weather and the parameters for halting work in the
event of serious environmental damage have been considered (i.e. wet weather
causing erosion or extreme dry weather and a high fire risk).
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
The initial entry onto a program should be reviewed to determine issues of concern
depending on vegetative cover, land use, terrain and habitat. This may impact the type
and amount of survey required to ensure efficient establishment of seismic right-of-
way.
Audit Guideline:
• Determine the method of line cutting and maintaining the proper bearing. In
situations where timber avoidance line cutting is employed, a line of sight may be
required. If the line can be cut “on the face” without pre surveying the line, ensure
items of concern are identified and flagged on the ground for the lead cat (i.e., road
crossings, stream crossings, steep slopes requiring detours). Programs should be
ground truthed prior to construction or cutting of seismic lines to evaluate access,
confirm existing lines and consider the placement of new cut lines in relation to
existing lines.
• Verify that the opportunity to utilize and maximize existing clearing as access or
seismic line is undertaken.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Topsoil shall be salvaged from all graded and disturbed areas. Topsoil shall be used
for specific land surface restoration and revegetation.
Audit Guideline:
• Inspect site to verify that topsoil is selectively removed from the disturbed area and
conserved.
• Where ever possible topsoil should be stockpiled at the top of a slope and not at
the bottom to facilitate easy replacement.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates in place. Verify that
access control is in place for environmentally sensitive areas.
Access controls may be enhanced with doglegs on seismic lines where they
intersect existing public access road or trails. This effectively screens the new cut
line from general viewing and awareness.
Rollback of debris on the first 90 meters of new cut seismic line may effectively
restrict or control unauthorized use of the line in conjunction with the dogleg or
deflection cut.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect access roads near high sensitive areas. Fences or post signing should be
used to limit the use of access roads in sensitive areas.
• Inspect access roads to detect any drainage problems. All access roads should be
maintained to allow proper drainage and to prevent erosion. This includes clean-
out ditches, culverts and erosion control structures.
• Inspect access roads for proper construction of ditches to control runoff water.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction,
seismic lines or placement of a bridge or culvert for continual crossing use. Measures
shall be taken to reduce the impact of exploration activities on water quality.
Audit Guideline:
• Inspect stream crossings for signs of pollution and sediment problems. Sediments
entering streams are a major pollutant and have significant effects on the survival,
reproduction and growth of fish.
• If work crews cross rivers and water bodies in boats, erosion of stream banks can
occur during the loading of work crews into boats. Verify that steep slopes are
avoided for passenger loading areas. Clearing of vegetation on stream banks must
be avoided.
• Inspect stream crossings to verify that no more than one crossing has been
constructed at the intersection of a seismic line and any stream. Inspect that debris
and material is pulled back at a crossing rather than pushed through the stream.
Wood and soil materials should not be placed into any waters.
• Inspect stream crossing to verify that the number of vehicular movements across a
stream is kept to a minimum. Existing bridges should be used whenever they are
available. Work crews should cross rivers and water bodies in boats if bridges are
not available.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect site for any signs of disturbance to drainage patterns. The consequences of
inadequate drainage are extensive and include ponding, flooding, washouts and
inundation of vegetation . Disturbance to drainage patterns can be minimized if
equipment is hand carried within the project area.
• Verify through interviews that work crews have been instructed not to place any
materials in drainages.
• Inspect any bridges that are constructed as required to cross drainage channels to
minimize disturbance of surface runoff.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect site to verify that any particular restrictions regarding clearing operations
have been enforced.
• Inspect site to verify that all necessary precautions were taken to minimize soil
erosion and to avoid pollution of waters and waterways.
• Review records to verify that a recording procedure is in place for all sold and
transported timber.
• Verify that after clearing, timber is removed and put to some beneficial use or is
disposed of by sale, wherever it is possible.
• Ensure salvaged timber is located in areas suitable for recovery and in a manner to
facilitate economical removal.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect access routes and vehicle use to verify that damage to the soil is being
prevented. Look for ruts from large tires or tracked equipment.
• Inspect site to verify that any interference with the normal drainage of water from
land, where such interference has been caused by the operations, has been
remedied or removed.
• Verify that efforts are made to avoid disturbance of the top duff layer during the line
cutting operation. Areas of the seismic line which have been stripped should be
noted for prompt erosion control measures.
• Inspect areas of steep slopes for damage by vehicular traffic. Detours around steep
slopes should be encouraged with hand cut 4 foot wide line of sight cut over the
slopes to facilitate the laying of geophones.
• Verify that a corridor of trees is preserved between the clearings and the river to
prevent erosion of the river bank.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Through interviews, determine if personnel are familiar with the proper handling of
explosives. Verify that safety measures taken when transporting explosives are
appropriate. Explosives carried to the work area must be stored in a separate,
enclosed, locked compartment. Detonators and explosives shall be separated by at
least 15 cm of solid lumber when transported. For helicopter transportation,
detonators shall be stored inside an aluminum locked container.
• Verify safety measures for handling explosives. Persons loading explosives must
wear safety hats equipped with ear protection. Verify that the detonators were
connected in series circuit along the short array.
• Inspect the site where explosives have been detonated. Where a charge is
detonated in the vicinity of a water well, care should be taken to avoid damage to
the well. Check that drill sites are at a sufficient distance from water wells.
• Inspect shot holes. Shot holes found to be flowing when drilled should not be
loaded or shot. All flowing shot holes should be filled to permanently or effectively
stop the flow. Any swamp or marsh area in a topographically low area should be
considered a potential flowing zone. Shot holes must be plugged and filled to the
original contour before progressing to the next shot hole, or as soon as conditions
permit.
• Verify that shot holes are abandoned properly. The following guidelines are
suggested:
• Inspect seismic drilling operations near water bodies. Use of explosives must be
limited within permanent, fish bearing and freshwater water bodies.
• Verify if any water wells have been sampled and analyzed prior to and following
detonation of explosives to ensure water quality and quantity are not disturbed.
Seismic work can disturb groundwater aquifers during the detonation of explosives
if such aquifers are close to the shot hole.
• Verify that all cratered shot points are backfilled and levelled to as near original
contours as possible.
• Verify that warning signs regarding the use of radio-telephones and other electronic
equipment are posted in conjunction with the “shooting” of the program.
• Verify that all shot points are labelled with the appropriate information to relocate
the point at a later date (for drilling) or in the event of an environmental problem
(flowing hole).
• Verify that all shot points located near electric transmission lines have been
skipped.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
It is typical for seismic activity to be the first industrial activity in remote locations or in
areas not frequented by regular traffic. As a result, the potential for serious and hard to
control fire situations is not uncommon. Seismic programs must be sensitive to the
seasonal potential for ignition and wildfire starts. Fuel sources such as grass are very
easy to ignite and prone to rapid spread.
Audit Guideline:
• Determine the level of fire hazard to the seismic operation. Factors to consider is
fuel type and ease of ignition due to fuel moisture and size.
• If open fires are needed, verify that precautions are taken to ensure extinguishment.
• Verify that the method of line cutting and debris windrow is addressed to avoid
wicking a fire. Wicking is referred to the effect of a wildfire following or wicking
along a debris windrow and dramatically increasing a fire front. Alternate piling of
the windrows on the side of the line at 400 meter intervals effectively breaks the
continuity of fuel and restricts the spread potential.
SEISMIC
GENERAL OPERATING PROCEDURES
Audit Protocol:
Depending on the type of terrain, vegetative cover, existing activities and concerns of
other land users, the seismic program may require adjustments to accommodate as
many concerns as is practical or possible.
Audit Guideline:
• Inspect site for any disturbance to agricultural productivity due to trampling of crops,
removal of plantation trees and plants and inconvenience of farming activities.
• In agricultural areas, inspect site for attempts made to avoid disturbance of fields
that are nearing harvests.
• Inspect fence crossings to ensure satisfactory repairs have been made. Where
ever possible existing gates should be utilized to avoid unnecessary damage to
landowner fences.
• Inspect location of camp. Camp and facilities must be located so as not to impede
with local land users.
SEISMIC
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Audit Guideline:
• Check for signs of spills onsite. Record location and size of any spills. Provide a
sketch of the spill area if possible. Indicate the type of spills observed (type of
contaminant, soil contamination, water contamination, etc.)
• Inspect fuel storage areas and equipment. Fuel tanks are preferable to bladders,
and welded steel tanks are preferable to bolted ones. Inspect tank dykes and verify
that they are of adequate size to contain any spills and have impermeable sides
and bases. Other guidelines for fuel storage facilities include:
- Stationary fuel storage facilities should not placed within the annual flood plain
of a water course or closer than the locally recommended distance to a water
body.
- Stationary fuel storage should be located above the high water mark of any lake
or stream.
- Stationary fuel storage should be on flat, stable terrain or in natural depressions
separated from water bodies.
- Stationary fuel storage areas should be free of other combustible material to
isolate potential fires.
• Verify that fuel storage areas are clearly marked to ensure that they are not
damaged by moving vehicles. The markers should be visible under adverse
weather conditions. Check that “No Smoking” signs are posted.
• Through interviews, verify that all personnel are familiar with proper fuel handling
procedures.
• Verify if fuel transfer operations are performed in a manner that prevents spills.
Review records to verify if there is any reporting process in place to record
occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgable of such process.
• Verify that all personnel are aware that oil changes or other oil related repairs are to
be completed without random dumping of oil and oil filters. Any such operation
should only be completed with an emergency spill kit close at hand.
SEISMIC
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Seismic operations shall have a spill contingency plan. All personnel shall be familiar
with the contingency plan.
Audit Guideline:
• Verify the existence of an appropriate spill contingency plan. Record and analyze
the particular spill prevention and response methods to make sure they are
appropriate. Tools and materials should be available to clean up any spills or drips.
Equipment should include absorbent material, shovels an plastic bags
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite.
SEISMIC
WASTE MANAGEMENT
Audit Protocol:
Wastes shall be properly stored and handled. Waste includes all flagging, stakes and
other debris not normally found within the area of operations.
Audit Guideline:
• Inspect waste storage areas. Verify that proper storage procedures are
implemented.
• Inspect waste storage areas for proper signage and access control. Verify that
measures are taken to prevent access by the public, wildlife or livestock.
• Inspect and verify that putrescible wastes that attract scavengers are placed in
suitable containers that have tight-fitting lids. This type of refuse should be picked
up and hauled to the disposal site every day. Other non-putrescible refuse should
be picked up as required.
• Verify that plastic, organic and metallic garbage has been collected along seismic
lines and transported to a proper disposal place.
SEISMIC
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Inspect distances of subsurface disposal facilities (septic tanks, leach pits) from
any sources of water supply and natural water bodies.
• If the septic tanks are used, verify that they provide a 24-hr retention period for the
raw sewage and an equal volume for sludge storage.
• Verify that pump-out and hauling operations are carried out in a manner that does
not expose the driver or people in the area where the tanks are emptied to any
health hazard. Every effort should be taken to avoid any spillage when holding
tanks are emptied or when the truck contents are discharged into the treatment
facility.
SEISMIC
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Verify that waste materials are separated and proper disposal methods of camp
solid and liquid wastes are used.
• Verify that proper procedures are in place for the transportation, disposal and
storage of hazardous wastes. Hazardous materials should not be incinerated.
Non-combustible garbage should be properly sent to an authorized disposal facility,
if available, according to local regulations. In the absence of such facilities, waste
should be buried at least one meter below the surface.
• Inspect site to verify method used for sewage disposal. Septic tanks are
acceptable systems for sewage disposal.
• Verify how often the seismic camp is moved. Seismic camps should be moved as
often as practical to minimize the amount of garbage and waste to be disposed at
any one location.
SEISMIC
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
• Inspect site to verify that proper cleanup operations have been implemented.
• Verify that all timber and debris not disposed of after the campsites were cleared
has been salvaged or removed. All buildings, trailers, machinery, equipment,
materials, litter and storage containers must be removed from the area. Temporary
access roads from the highway to the campsites must be removed. Abandoned
equipment should either be hauled out of the area or buried in a landfill site.
• Ensure all sites which require rollback as access control have been treated after
debris cleanup and seeding.
SEISMIC
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
a) If the roads have been temporarily abandoned, the following are required:
- Cuts and fills must be recontoured to natural conditions where slope and
materials make this practical.
- Erosion control measures such as diversion berms and cross-ditches must
be installed as required.
- Rollback windrowed debris for erosion control to provide microsites for
vegetation.
- All watercourse crossings must be removed and creek banks stabilized if
necessary.
- Disturbed areas must be revegetated using a suitable seed mix.
SEISMIC
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
• Inspect the site to verify that recontouring of the land was implemented as required
to pre-disturbance conditions. As soon as possible, the seismic lines should be
contoured to their original condition.
• Inspect the seismic lines to determine what type of reclamation has been done.
• Inspect shot holes locations. Disturbed ground surface area must be restored to
original condition and reclaimed to prevent erosion. Shot holes must be plugged
during abandonment.
SEISMIC
ABANDONMENT AND RECLAMATION
Audit Protocol:
Upon completion of seismic operations and the removal of camps and all related
facilities, a revegetation program shall be implemented to restore the disturbed area to
a productive capability similar to or better than the pre-disturbed condition.
Audit Guideline:
• Inspect site to verify that proper revegetation procedures have been implemented.
Seismic lines should be reseeded and fertilized if necessary. The area should be
revegetated with grasses, shrubs and trees native to the area.
• Inspect that species selected are consistent with the planned use of the area
(commercial forest, recreation area, grazing or wildlife habitat, etc.).
• Verify that the seed mixture is fast growing, self-sustaining and that it requires little
or no maintenance.
• Verify that all steep slopes are treated and any areas which have been stripped of
the surface duff layer receive prompt attention.
• If the site has had time for vegetation, record the success achieved after
revegetation and if more work is required.
12.2 Drilling
Environmental Planning
Waste Management
DRILLING
ENVIRONMENTAL PLANNING
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any exploration program. Special conditions and restrictions shall
be reviewed and enforced.
Audit Guideline:
• Meet with the drilling manager or project supervisor to review the project records to
ensure that all required wellsite construction and drilling permits, licenses and
regulatory authorizations were obtained prior to the start of any field operations.
Check the files to make sure that all information in writing is available and has been
provided to all field supervisors on site. Record permit/license numbers and
contractors specifications and verify information in the field.
• Review records to verify that consent of the landowner or land occupant has also
been obtained prior to any work. Look for field report sheets on
landowner/occupant contacts. Check with the project supervisor that field reports
have been reviewed.
• Verify through interviews that the project supervisor is aware of any restrictions and
environmental concerns and has provided this information to the contractor. Verify
that those restrictions are enforced with the contractor and personnel. Check all
written conditions provided to the contractor.
• Identify if regulatory personnel will be inspecting the drilling work and attempt to
coordinate the site visit and meet with the government person in the field.
DRILLING
ENVIRONMENTAL PLANNING
Audit Protocol:
The planning of drilling operations shall be undertaken in a manner that will anticipate
problems and minimize the effects of the operations to the adjacent environment.
Audit Guideline:
• Verify that environmental concerns were considered during the selection of the
drilling site. For example:
a) Determine the drainage pattern around the drilling site. The site should be
selected so that spills can be easily contained and where natural drainage
moves away from the site. This guideline also applies for staging areas,
camps, fuel dumps and storage areas.
c) Verify that the location of campsites and access roads are planned based on
minimized environmental impacts.
d) Verify that the wellsite does not conflict with local land use restrictions (i.e.,
airports, proximity to dwellings, etc.).
e) Verify that the access road and wellsite does not create possible
environmental effects on marshes, river beds, fractured formations, springs,
etc.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates. Verify that access
control is in place to protect environmentally sensitive areas.
• Check the success of access control and determine if further control methods are
required.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction or
placement of a bridge or culvert for continual crossing use. Measures shall be taken to
reduce the impact of exploration activities on water quality.
Audit Guideline:
• Verify that the protection of streams due to sedimentation contamination has been
taken into consideration in the plans, designs and construction of an access road.
Inspect stream crossings for signs of pollution and sediment problems.
• Inspect stream crossing to verify that the number of vehicular movements across a
stream is kept to a minimum. Existing bridges should be used whenever they are
available.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
All construction activities shall employ cutting and clearing methods which will result in
the least environmental damage and least forest or grassland growth removed.
Audit Guideline:
• Inspect the wellsite to verify that any particular restrictions regarding clearing
operations have been enforced.
• Verify that areas outside the wellsite requiring environmental protection measures
were identified to minimize disturbance to the environment as a result of cutting and
clearing operations.
• Inspect site to verify that all necessary precautions were taken to minimize soil
erosion and to avoid pollution of waters and waterways.
• Review records to verify that a recording procedure is in place for all sold and
transported timber.
• Verify that after clearing, timber is removed and put to some beneficial use by the
company or is disposed of by sale to a lumber company.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Topsoil shall be salvaged from all graded and disturbed areas. Topsoil shall be used
for specific land surface restoration and revegetation.
Audit Guideline:
• Verify, prior to going to the field, if construction specifications provide guidelines for
topsoil removal, storage and replacement.
• Inspect site to verify that topsoil is selectively removed from the disturbed area and
conserved.
• Inspect the topsoil storage area to determine if the topsoil has been placed in a
location secure from contamination and erosion. Topsoil must be protected from
loss by wind or water erosion. Depending on the period of time the lease will
remain in a disturbed state or the time of year, a vegetative cover may be required
on the topsoil salvage piles.
• Ensure the placement of topsoil salvage piles are located to facilitate replacement
over the disturbed area. Avoid burial or over the edge locations.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Erosion control measures shall be implemented during the construction of the access
road and wellsite and during drilling operations.
Audit Guideline:
• Inspect the access road and wellsite to look for signs of erosion problems,
sedimentation of streams, suffocation due to siltation of vegetation or reduction in
watershed capacity caused by the removal of trees, shrubs and other vegetation,
disturbance of land surface, or any other cause resulting from the operations.
Select the most difficult terrain for an initial inspection.
• Verify during the inspection that any interference with the normal drainage of water
from land, where such interference has been caused by the operations, has been
remedied or removed.
• Check for signs of serious erosion as a result of any large cuts on sloping land. To
prevent erosion on unstable slopes and to prevent sediment from these slopes
entering streams, controls to water runoff should be built. Controls that could be
used include replanting with shrubs and grass, debris installed on the slope, bales
of straw, rocks bigger than 100 mm mesh size, sacks of sand, logs thicker than 100
mm diameter, and trees and stumps imbedded in the slope to reduce mud slides.
Indicate if there is any need for stabilizing structures like gabions, contour
trenching, berms, terraces or equalizer dams.
• Inspect all areas which have water released to surrounding countryside from
diversion ditches, cross culverts, etc. for the presence of heavy silt loading to the
vegetation. Excessive siltation will smother grasses and the roots of shrubs and
trees causing mortality.
• Inspect soil stability around bridges and culverts to determine if any erosion has
started.
• Verify if all drainage channels, related construction of bridges and erosion controls
have taken high flood conditions into consideration.
• Verify that wind erosion has also been taken into consideration, especially on land
high in sand content.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect the access road and wellsite for any signs of disturbance to drainage
patterns. The consequences of inadequate drainage are extensive and include
ponding, flooding, washouts and inundation of vegetation .
• Verify through interviews that work crews have been instructed not to place any
materials in drainages.
• Inspect the wellsite for internal drainage control to contain potential wellsite
pollutants on the site.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Audit Guideline:
• Inspect access roads near high sensitive areas. Check gates, fences and wellsite
identification signs to limit access or identify environmental concerns.
• Inspect access roads to detect any drainage problems. All access roads should be
maintained to allow proper drainage and to prevent erosion. This includes clean-
out ditches, culverts and erosion control structures.
• Inspect access roads for proper construction of ditches to control runoff water.
• Inspect borrow pits required for fill situations. Grade construction should be
planned in advance to reduce the area of disturbance. Borrow pits should be
screened from the access road, take advantage of suitable borrow material,
landscaped to blend with the surrounding terrain, and revegetated to encourage
assimilation back into the pre-disturbance environment.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Drilling operations shall protect groundwater sources by placing surface casing through
freshwater horizons.
Audit Guideline:
• Check any freshwater wells onsite. Water wells should be located and cased to
prevent any contamination during drilling operations.
• Inspect surface and production casings to verify that they are cemented to the
surface by the pump-and-plug, displacement or other approved method, to a depth
sufficient to protect all freshwater and to ensure against blowouts or uncontrolled
flows.
• Verify that loss of drilling fluid to freshwater aquifers is avoided. Interview personnel
to verify precautions taken during all drilling operations to prevent casing ruptures.
• Verify that producing wells have appropriate tubulars designed to maintain well
control and prevent possible contamination of freshwater aquifers.
• Inspect site for construction and maintenance of berms and/or ditches to prevent
contamination of surface freshwater. Berming should include the access to the
well site, particularly if access is on the low side of the lease.
• Inspect pumps and engines location when freshwater lake or pond is used as a
water supply. Pumps and engines should be located so as to prevent any
hydrocarbon leaks form contaminating the water source.
• Verify that no pits for containing mud, oil, water and other fluids associated with the
well are constructed closer than 100m to the normal high water mark of a body of
water or permanent stream.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Accidental well blowout during drilling operations can result in extensive damage to the
environment. Blowout prevention measures should be in place prior to the start of any
drilling operations
Audit Guideline:
• Prior to a field inspection, verify if blowout prevention procedures are practised and
if there are any written guidelines. Verify if there is any pollution risk assessment
due to spillage of crude oil, including anticipated reservoir characteristics, shallow
nature and blowout potential studies.
• Contact the drilling supervisor on the wellsite and inspect the blowout prevention
equipment.
• Verify if there are any scheduled or unscheduled blowout prevention drills to ensure
drilling crews and service people know their proper places and job assignments fro
an emergency blowout condition.
• Check if there has been the construction of at least a 1 m high berm on the well site
around facilities which could result in the escape of deleterious material.
DRILLING
GENERAL OPERATING PROCEDURES
DRILL 12.0 Flaring During Completion and Testing of Gas and Oil Wells
Audit Protocol:
Audit Guideline:
• Inspect flare pits to make sure that no produced fluids, trash or other foreign
materials have entered the flare pit. Inspect the equipment onsite to make sure that
there is no possibility for produced fluids to enter the pit. Inspect the land adjacent
to the flare pit to identify areas of contamination as a result of pit overflow or
excessive flaring. Inspect the walls of the pit and adjacent land for vegetation
control and potential use of soil sterilants. Inspect the security of the pit to prevent
people or livestock from entering the pit area. Inspect location of flare pit so that
prevailing winds will reduce fire hazards and smoke nuisance. Ensure there is
sufficient clearing between the flare pit/stack and standing timber, as a fire
prevention precaution. Preferably, flare pits must be located at least 50m from the
well head.
• Verify that the separated fluid is piped and stored in a closed, dyked tank. After the
completion of testing, the liquid must be disposed of appropriately. Inspect dykes.
• Inspect site for presence of separators in cases where liquid production may be
expected. Verify that the contents of the well are passed through a separator to
separate the gaseous and liquid components.
• If a flare stack is used, inspect the stack and adjacent land to see if liquids have
sprayed off the stack. Inspect flare stack operations. The separated liquids should
not be discharged to a flare stack and burned. Free liquids can escape up the flare
stack to pollute the land.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Every effort shall be made to avoid spills and contain any accidentally spilled drilling
fluids or chemicals. When sump pit overflows, hydraulic oil or fuels and saltwater is
spilled, immediate steps to contain and clean up the oil or salt water shall be taken.
Audit Guideline:
• Meet with the drilling supervisor and verify that a Spill Contingency Plan or
Emergency Response Plan is on site which identifies appropriate measures to
contain spills. Released produced water and hydrocarbon releases can be
contained using booms, absorbent material or soil berms or trenches as necessary.
Free produced water and hydrocarbons can be recovered using pumps or vacuum
trucks. The area of the spilled produced water should be flushed with a calcium
amendment prior to the application of any fresh water, recovering excess fluid. The
area of spilled hydrocarbons should be flushed with water and surfactant in order to
free and recover additional hydrocarbons.
• Inspect the size of the drilling sump pits, dykes and berms constructed to contain
and permit the recovery of any drilling or spilled fluid.
• Verify that any spilled drilling fluid is contained and transferred to the sump.
• Inspect the wellsite area to determine the direction a spill would flow should one
occur. Check to see that a containment system is in place to contain and remove
the spill material.
• If any spills have occurred, verify that cleanup programs were undertaken.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
Equipment must be maintained at all times to prevent hydraulic oil and fuel leakage.
Oil spill materials should be utilized for cleanups and spill control drains should be
directed to special runoff holding pits on tanks.
Audit Guideline:
• Inspect the drilling rig for special hydraulic oil, fuel and chemical containment
system, spill control and cleanup materials.
• Inspect desanders, desilters and mud cleaners. Record any overflows or leaks.
• Verify that proper measures are taken if emergency or problems with the drilling
program result in a “foreign drilling fluid” being introduced to the system ( i.e.,
contamination of a fresh water gel mud system with diesel fuel due to “stuck in the
hole” problems). Compatibility or segregation with the drilling sump depending on
recycle requirements or disposal options must be used.
• Verify that only drilling additives of chemically known composition is used in the
drilling mud systems. Chemicals and materials should be clearly marked, neatly
stacked and easily accessible.
DRILLING
GENERAL OPERATING PROCEDURES
Audit Protocol:
The impact of drilling operations’ noise on local residents and workers shall be
minimized.
Audit Guideline:
• If houses are adjacent to the wellsite, verify that discussions regarding noise
potential impacts were held with nearby residents during the planning stage. Verify
that adjustments were made to meet the concerns and needs of the residents.
Adequate public notification and discussion can prevent noise complaints after the
operation starts.
• Identify if there have been public complaints and verify that complaints (if any) have
been responded to. If the noise level is higher than acceptable limits, verify that
measures have been taken to meet or better the acceptable limits. If complaints
have been received, verify that noise monitoring of the wellsite is being done.
• Prior to field inspection, verify that noise control programs are in place. Identify if
the rig has noise reduction mufflers.
• Inspect all motor systems to determine that mufflers are in place and are reducing
noise.
DRILLING
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Proper fuel, oil and chemical handling measures shall be taken to prevent the
occurrence of spills.
Audit Guideline:
• Through interviews, verify that all personnel are familiar with fuel and chemical
handling procedures.
• Inspect fuel storage areas and equipment. Fuel tanks are preferable to bladders,
and welded steel tanks are preferable to bolted ones. Inspect tank dykes and verify
that they are of adequate size to contain any spills and have impermeable sides
and bases.
• Verify that fuel storage areas are clearly marked to ensure that they are not
damaged by moving vehicles. The markers should be visible under adverse
weather conditions. Check that “No Smoking” signs are posted.
• Verify if fuel and chemical transfer operations are performed in a manner that
prevents spills. Review records to verify if there is any reporting process in place to
record occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgable of such process.
• Check for signs of spills onsite. Record location and size of any spills. Provide a
sketch of the spill area if possible. Indicate the type of spills observed (type of
contaminant, soil contamination, water contamination, etc.)
DRILLING
SPILL PREVENTION AND EMERGENCY RESPONSE
DRILL 17.0 Emergency Response for Well Drilling, Completion or Testing of Sour
Gas Wells
Audit protocol:
Drilling operations of sour gas wells shall have an Emergency Response Plan to
protect the public, employees, the environment and property should an emergency
occur.
Audit Guideline:
a) Emergency Response Plans are required for any well where the potential
3
H2S release rate is greater than 0.01m /s.
c) A normal plan is required where there are many more residences in the
emergency planning zone than the reduced plan.
d) A special plan is required where there are large numbers of people in the
emergency planning zone. The special plans go beyond the level of detail
required for a normal plan.
• Review the contents of the Emergency Response Plan. The plan should include:
a) Summary
- Location.
- Size of the emergency planning zone.
- Dates for potential hazard.
- Company contact.
- Local regulatory agency office.
b) Emergency Definition
- Outline of circumstances causing a sour gas release and action to be
taken.
- Stages of alert and action plan.
- Responsibilities of company personnel.
- Responsibilities of government personnel.
e) Evacuation Procedures
- Evacuation criteria.
- Evacuation plan.
- Road blocks.
- Evacuation centre.
- Communications.
- Monitoring.
- Evacuation notification.
d) Ignition criteria
- Description of procedures to be followed by well site personnel to ignite
an uncontrolled flow.
e) Post-emergency procedures
h) Contact information
I) Maps
• Verify through inspection that all material and equipment specified in the
Emergency Response Plan are available onsite.
DRILLING
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Drilling operations shall have a spill contingency plan. All personnel shall be familiar
with the contingency plan.
Audit Guideline:
• Interview personnel to verify the level of knowledge of such plan and level of related
experience.
• Verify through inspection that all material and equipment specified in the
contingency plan are available onsite. Material and equipment should contain the
following: spill absorbent material, small containment barrels and small pumps,
hoses and suction nozzles.
• If there has been a spill, inspect the area to verify proper cleanup operations and
reporting procedures were undertaken.
• Identify areas of risk due to spill and ensure provisions to handle the situation (i.e.,
if the wellsite is on a slope above a fish bearing river, etc.).
• Inspect the drilling fluid containment pits to asses pit sizes. Through site interviews
and inspection, determine that pit volumes take into consideration extra fluid due to
rain fall or emergency dumping situations. Verify if a contingency plan exists to
transfer fluid to prevent overflows.
DRILLING
WASTE MANAGEMENT
Audit Protocol:
Where feasible, work camp or drilling site wastewater shall be hauled or discharged to
an approved municipal wastewater treatment system. No effluent shall be discharged
unless it meets minimum requirements of existing local regulations.
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
sewage disposal facilities have been identified and provided as guidelines for
implementation in the field. Verify camp and wellsite specifications for housing
personnel.
• Inspect distances of subsurface disposal facilities (septic tanks, leach pits) from
any sources of water supply and natural water bodies.
• If the septic tanks are used, verify that they provide a 24-hr retention period for the
raw sewage and an equal volume for sludge storage.
• If leach pits are constructed verify that they have two compartments connected in
series. The first cell should settle out solids and the second cell should be used for
percolation.
• Verify that pump-out and hauling operations are carried out in a manner that does
not expose the driver or people in the area where the tanks are emptied to any
health hazard. Every effort should be taken to avoid any spillage when holding
tanks are emptied or when the truck contents are discharged into the treatment
facility.
DRILLING
WASTE MANAGEMENT
Audit Protocol:
All waste material must be properly identified and handled according to hazardous and
nonhazardous waste handling regulatory requirements. Solid wastes generated by
drilling operations shall be disposed of in an acceptable manner to prevent pollution of
the environment.
Audit Guideline:
• Verify prior to the field inspection, the required regulatory procedures to properly
dispose of all types of solid wastes generated either from drilling operations or
typical wellsite activities.
• Verify that there is a reporting policy established regarding type and quantities of
waste.
• Verify that drilling site is kept free of trash and litter. All trash, litter and garbage
must be placed in metal or plastic containers and disposed of properly.
• Verify that rig wastes such as engine oil, waste oil, grease, etc. are accumulated in
appropriate containers for disposal.
• Verify that wastewater utilized in cleaning the rig, tools and equipment is collected
in reserve or storage pits and separated from the sump pits.
• Inspect site area for disposal methods of general solid wastes. Such wastes
include rags, waste paper, paper cartons, scrap metal, plastic wastes and rubber
wastes. Industrial landfilling and incineration are the most commonly used
methods for disposal of solid wastes. Incineration is followed by burial of the
incinerated residue. Combustible wastes should be incinerated daily. Materials
suitable for recycling should be stored separately and recycled accordingly.
a) On well sites, any residue may be compacted and buried in sump pits
provided a minimum of 1m of mineral soil covers the debris and the natural
ground contours are maintained.
b) On roads where deep fills are required in the grade, residue may be
compacted and buried provided that a minimum of 1m covers the residue
and the natural ground contours are maintained.
• Inspect garbage disposal sites. Garbage disposal sites should be used for small,
non-toxic, non-perishable refuse and incinerator residues. Holes or pits should be
located above the expected high water level. A minimum distance from the bank of
a water body of 45 m is required. Consider and evaluate the potential of wildlife
intrusions to the garbage disposal sites or attraction to the location.
DRILLING
WASTE MANAGEMENT
Audit Protocol:
Drilling fluid material is to be contained at all times in such a manner that no soil,
surface water or underground source of water is or may be polluted.
Audit Guideline:
The ARPEL document “Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes” can be used as a guide for the auditor in the conduct of
audits in this area.
• Verify from regulatory permit approvals if specific guidelines are required for sump
construction
• Onsite, inspect the sump system. The size of the drilling sumps must be adequate
for the anticipated volumes of the drilling fluids and should include 1m of freeboard,
depending on the expected variables in the drilling program. The drilling sump
should be excavated from an impervious, undisturbed subsoil and should be
shaped to allow maximum reuse of clear water for mud make-up. The sump
should be located on the high side of the lease, and as far away from water bodies
as possible, and the excavated material stockpiled in a location which will facilitate
backfilling.
• Where the soil is such that an on-site sump is not possible, verify that all fluids are
tanked on-site and trucked to an approved disposal site.
• Inspect any rain runoff diversion ditches. Depending on surrounding contours and
the sensitivity of the area, rain runoff diversion ditches may be required around the
lease. Containment berms are recommended on the low side of the lease.
• Inspect the security of the sump. Where applicable, fences or other structures
should be installed to prevent wildlife, people, and livestock from entering the
sump.
• If sumps are constructed in permeable soil material, inspect and verify the sumps
are sealed by an acceptable clay or synthetic liner of other approved material to
prevent leakage.
• Verify that well work over and completion wastes are isolated from the main sump
on completion of well drilling operations.
DRILLING
WASTE MANAGEMENT
Audit Protocol:
Disposal of drilling fluids and solids must be completed within acceptable procedures
which do not result in pollution to the environment.
Audit Guideline:
The ARPEL document “Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes” can be used as a guide concerning waste disposal
methods.
• Verify the approved method for disposal of drilling fluids. The main concern with
drilling fluids is ensuring proper segregation so that handling and disposal can be
undertaken effectively with little environmental impact. The waste drilling fluids
should be stored in a main sump.
• Verify if oil based materials are utilized in the drilling fluid and inspect the method of
disposal of oily wastes. A concrete lined pit, metal tank or impervious lined pit
must be used. Earthen structures should not be permitted.
• Verify that lubricating oil, diesel fuel and other hydrocarbons are not added to the
main sump. Unused chemicals and/or other completion fluids must not be added
to the main sump unless prior approval has been obtained from the drilling
supervisor responsible for the sump disposal program.
• Verify that rig wash detergents are not used where KCl drilling fluids are in use or
where they may be mixed with oils. Detergents will emulsify and disperse KCl
fluids and oils into small droplets that are more readily absorbed by flora and fauna
and are more difficult to treat for disposal. In general, rig wash fluids should be
separated from the drilling fluids.
• Verify that all flammable solid waste material is burned in an approved incinerator
or burn pit, or removed to an approved disposal site.
• Verify by inspection, the proper use of the sump. The sump is not a garbage pit.
All solid waste materials that will not incinerate must be collected and stored for
removal from the site. These materials include:
• In addition, verify that the sump is not used to collect solid wastes which could not
be incinerated on their own such as cardboard, wooden boxed and rags. Wire
cable and wire rope should be cut in lengths and bundled for ease of handling.
Burial of any of the above items is detrimental to the environment and a hindrance
to further construction on the site.
DRILLING
WASTE MANAGEMENT
Audit Protocol:
Drilling fluid wastes are defined as either hazardous or nonhazardous waste material.
Proper storage and disposal for each type of waste material is required.
Audit Guideline:
The ARPEL document “Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes” can be used as a guide concerning waste disposal
methods.
• Verify from regulatory permit approvals that appropriate disposal options for the
sump fluids are implemented. Preferred practices include:
Disposal of fluid on the lease is permitted if the total disposal volume is less than
3
1000 m and there is little or no chance of migration. On-lease disposal is done by
squeezing or by evaporation.
b) KCl Fluids:
KCl fluids should be segregated from other fluids used in the drilling program.
Solids can be disposed of as in item “a” but the solid disposal is not as simple as
above. Squeezing/burial is discouraged by some of the regulatory agencies.
Review existing regulations regarding this practice. Salt levels in solids may need
to be reduced through washing the solids prior to disposal. Where saturated KCl
muds are used to drill through evaporite (salt) formations, the fluids and cuttings
must be segregated from other drilling fluids and wastes. The fluids should be
stored in lined sumps and then disposed of through deep well injection.
The cuttings are transferred to a lined sump or steel tank. Free oil is collected and
reused in the active mud system. At the completion of the well, the cuttings are
spread on the lease and allowed to dry. After an initial drying period, the cuttings
are worked into the disturbed surface soil layer and returned to the sump. Fertilizer
addition may be necessary to promote degradation. Where oil-based or invert
muds are used to drill through evaporite (salt) formations, the fluids and cuttings
must be segregated from other drilling fluids and wastes. The fluids should be
stored in lined sumps and then disposed of through deep well disposal.
• Verify that proper disposal procedures are followed by site contract with the drilling
foremen. Review any analytical information.
• Inspect all drilling waste containment sites and assess waste disposal programs.
Verify that fluid sampling and analysis programs are following acceptable regulatory
standards.
• Inspect location of injection lines for deep well disposal. They should be located
downstream (flow of the aquifer) of ponds, lakes, crops and dwellings. Deep well
injection can be used to dispose of liquid wastes, particularly saltwater (produced
water), glycols and drilling workover or completion liquid wastes. However, some
regulatory agencies do not consider deep well injection as the best applicable
technology. Emphasis is now being placed on water reuse systems for produced
waters.
DRILLING
WASTE MANAGEMENT
Audit Protocol:
During well completions or workovers, a variety of fluids may be circulated through the
well to fracture the formation and otherwise maintain or improve fluid flow to the well
bore. These fluids are returned back to tanks on the surface. The fluids which
accumulate in the tanks at the well site shall be disposed of in an acceptable manner.
Audit Guideline:
The ARPEL document “Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes” can be used as a guide concerning waste disposal
methods.
b) Oil and oil/water emulsions: run fluid through a production treater to salvage
the oil and dispose of water down hole.
d) Acid water: neutralize with slaked lime and dispose of down hole.
• Inspect well service operations and verify that waste completion fluids, especially
frac acids, are not discharged to the drilling sump. This would make drilling fluid
disposal more difficult.
• Inspect the service operations and check for signs of leaks and spills. Verify that
spill control is practised and any spills are cleaned up.
DRILLING
ABANDONMENT AND RECLAMATION
Audit Protocol:
The well casing and wellsite shall be abandoned to a condition where there exists no
present or potential environmental pollutants.
Audit Guideline:
• Verify through record review that abandonment approvals have been obtained from
related regulatory agency.
• Verify that abandonment procedures have been developed. The preferred practices
include:
b) Any known productive oil and gas zones must be isolated and migration of
fluids in or out of these zones prevented.
c) The open hole must be isolated from the cased hole by a cement plug of a
retainer-cement plug combination placed in the deepest casing string which
extends to the surface.
d) All annulus spaces that are open to formations and that extend to the surface
must be plugged.
e) A surface cement plug must be placed below the ground surface in the
smallest casing string which extends to the surface.
g) Before the drill rig is moved away from the drill site, a tag indicating the
company name and drill hole location must be placed within 10m from the
actual drill hole.
• Verify that an abandoned well has a cement plug extending from a depth of at least
200 metres to surface, unless that interval is covered by casing which is cemented
over the interval.
DRILLING
ABANDONMENT AND RECLAMATION
Audit Protocol:
Rig dismantling, disposing of waste materials, site recontouring and restoring the soil
profile and revegetation shall be undertaken to prevent environmental damage and
revegetate all disturbed areas.
Audit Guideline:
• Inspect abandonment activities and verify that upon completion of the well, rig
components are neatly stacked alongside the drilling site and/or right-of-way or on
other approved sites.
• Inspect the site to verify that all holes are properly tagged, filled or plugged. Cellars
should be filled or provided with a suitable cover.
• Inspect the flare pits for proper closure. Check that no produced fluids have been
allowed to enter the flare pit. If contaminants are present, sampling must be
undertaken to assess if special cleanup work is required.
• Verify that surface wood roads and riprap utilized on the drilling site are dismantled.
Lumber, scraps, nails and debris should be removed from the surface.
• Verify that the sump pit area is appropriately backfilled and restored using the
originally excavated material. The soil should be restored to original or better
condition. The covering fill should be built up above the general site level to allow
for subsequent settlement of the fill material. Impermeable pit lining material
should be removed. If backfilling and final cleanup is not feasible (e.g. due to wet
conditions), the pit should be fenced to ensure the protection of livestock and
wildlife.
• During the site inspection, verify that after cleanup operations are completed, the
site is recontoured utilizing subsoil material. Final surface restoration should be
undertaken utilizing topsoil and organic material.
• Verify that slash from the preliminary clearing operation is chopped or shredded,
and spread over the wellsite surface to act as a mulch fostering revegetation.
• Verify that all sites contaminated by spills and other chemical disturbances have
been decontaminated.
• Inspect stream crossings to verify that all culverts have been removed. Verify that
stream banks have been recontoured to original contour. Stabilized log cribbings
may sometimes be left.
DRILLING
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
• Inspect the site to verify that recontouring of the land was implemented as required
to pre-disturbance conditions. Disturbed ground surface area must be restored to
original condition and reclaimed to prevent erosion.
• Inspect the site with the drilling supervisor to determine if all the work has been
performed.
DRILLING
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
• Ensure that steps have been taken to re-establish a suitable or required vegetative
cover depending on the well permit or the surrounding land use. The wellsite may
have to be inspected at a later date to assess the success of the revegetation
program.
• Inspect that species selected are consistent with the planned use of the area
(commercial forest, recreation area, grazing or wildlife habitat, etc.)
• Verify that the seed mixture is fast growing, self-sustaining and that it requires little
or no maintenance.
• If the site has had time for vegetation growth, record the success achieved after
revegetation and if more work is required.
12.3 Production
- Processing
Waste Management
PRODUCTION
ENVIRONMENTAL PLANNING AND ADMINISTRATION
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained for the planning,
design, construction and operation of any oil and gas production facility. Special
conditions and restrictions shall be reviewed and enforced.
Audit Guideline:
• Review the project records to ensure that all required permits, licenses and
regulatory authorizations were obtained for oil and gas production facilities and
make sure that all information in writing is available on site. Record permit/license
numbers and verify this information is in the field.
• Verify through interviews that facility operators are aware of any restrictions and
environmental concerns for the operation of the facility. This is particularly
important for sour gas facilities.
PRODUCTION
ENVIRONMENTAL PLANNING AND ADMINISTRATION
Audit Protocol:
All facilities operating personnel shall be trained and aware of the environmental
impacts of their operations. They should understand the necessity for environmental
planning and protection measures.
Audit Guideline:
• Verify that all personnel have taken environmental training in their field of
operations and are clear on how to implement and use their training correctly. This
should include, but not be limited to, emergency response/spill containment
training, waste management, current regulatory requirements and best operating
procedures.
• Verify if there is a system in place for all personnel to update their training yearly as
required.
• Inspect the facility technical reference library to identify that environmental training
manuals and reference programs are available.
• Verify through consultation with senior personnel that funds are made available
annually for environmental training.
PRODUCTION
ENVIRONMENTAL PLANNING AND ADMINISTRATION
Audit Protocol:
The engineering design and site planning of any production facilities shall be
undertaken in a manner that will anticipate potential environmental problems and
provide the design and operating procedures to minimize the impacts of the operations
on the environment.
Audit Guideline:
• Verify that environmental concerns were considered during the selection of the
facility site. For example:
a) The site should be selected so spills can be easily contained and cleanup
vehicles can have ready access. This guideline also applies for staging
areas, camps, fuel dumps and storage areas. The site selection process
should also minimize impact to natural runoff patterns and should prevent
soil erosion and surface water contamination.
e) Present and future land use restrictions (i.e., airports, proximity to dwellings,
etc.) should be considered prior to making a final site decision.
water, spilled oil and grease, from affecting habitat vegetation and water
quality.
PRODUCTION
GENERAL SITE INFORMATION
Audit Protocol:
At the start of the audit all general information on site list shall be verified. Site
information should correspond to all engineering and design drawings and plans. All
modifications or amendments to any facility or production operations should be found
in all drawings and plans showing the date of change. All modifications associated
with environmental protection should be recorded.
Audit Guideline:
• Verify type of site (i.e., disposal, oil, gas, injection, water, etc.).
• Verify site status (i.e., shut in, producing, suspended, abandoned, in use, drilled
and abandoned, etc.).
• Record all equipment and its condition on site (i.e., pumpjacks, pits, tanks, dikes,
berms, sheds, etc.).
• Record soil quality, erosion controls, condition of top soil stockpiled and adjacent
wild life habitats and species.
• Verify the nearness of surface water bodies and water wells to facilities.
• Undertake a general inspection of the site to verify engineering and design plans
are current. Record any changes in the facility which do not correspond to existing
plans or drawings.
PRODUCTION
GENERAL OPERATING PROCEDURES
Wellsite and Flowlines
Utilization of surface casing is a standard practice to protect ground water from oil and
gas production. Surface casing should be vented to monitor for leaking production
casing and prevent dangerous gas pressure buildup.
Audit Protocol:
Audit Guideline:
• Inspect surface casing vents and verify that proper operating procedures are in
place. The vents should be opened at all times, unless a problem has been
identified or the well is in a special area. When a vent flow has been identified, the
pressure must be determined after the surface casing vent has been shut-in for 24
hours. Local regulations may require that the gas flow rate be measured annually.
• If the well is sour, verify that proper safety and environmental rules are followed
when working around open casing vents.
• Verify that surface casing vent flows are properly detected and there is a proper
procedure to limit the release of methane (CH4) and carbon dioxide (CO2) (sources
that contribute to greenhouse gases).
PRODUCTION
GENERAL OPERATING PROCEDURES
Wellsite and Flowlines
Audit Protocol:
Audit Guideline:
• Verify that pipelines are pigged regularly to ensure a pipeline does not become
plugged with solids. Inspect records which indicate type and schedule for pipeline
maintenance.
• Verify that pipelines are designed and constructed to allow for different types of
pigging operations.
• Inspect pigging stations where pigs are released or captured within a pipeline
system. Verify that waste containment is undertaken to trap and store waste
material. Verify these areas are properly labelled and the waste properly disposed
of.
PRODUCTION
GENERAL OPERATING PROCEDURES
Wellsite and Flowlines
Audit Protocol:
Audit Guideline:
• Inspect pumpjacks. Check for signs of spills around the well head. New soil
around the wellhead may cover up old spills.
• Identify if a mechanical automotive system shut down system exists at the wellhead
which shuts the well down if there has been an oil or gas release (low or high
pressure shut off switches).
• Verify that spill containment equipment is available and that operators are familiar
with the Spill Contingency Plan and Emergency Response Plans. (See Spill
Prevention and Emergency Response section).
PRODUCTION
GENERAL OPERATING PROCEDURES
Wellsite and Flowlines
Audit Protocol:
Valves shall be maintained in order to prevent spills. The operation and maintenance
of wellheads shall be carried out so that impact to the environment is minimized.
Audit Guideline:
• Verify that Inspection of all valves are regularly undertaken. Verify that valves are
secured on shut in or suspended wells and monitored regularly for leaks.
• Inspect wellheads for signs of leaks. If there are any leaks, record the type (i.e., oil,
gas, chemical, water, etc).
• Inspect injection well locations. Pressure of disposal must be monitored. Look for
signs of spills.
• Inspect location of injection lines for deep well disposal. They should be located
downstream (flow of the aquifer) of ponds, lakes, crops and dwellings. Produced
water injection wells are susceptible to corrosion, therefore leaks along the pipeline
right-of-way are always a possibility and must be monitored. Record method of
detecting leaks in pipelines.
• If supplemental water is being used in the injection system, verify that the water
source well(s) are inspected and that the producing zone is not potable and that the
producing zone is not in communication with a potable water zone.
PRODUCTION
GENERAL OPERATING PROCEDURES
Wellsite and Flowlines
Audit Protocol:
All production lines shall be maintained properly to reduce the potential of pipeline
failure and resulting pollution to the environment.
Audit Guideline:
• Ensure all lines are marked and maintained and that records are checked before
any excavations are started. Spill containment equipment should be on hand
before any excavations begin.
• Check for saltwater or oil spill along right-of-way, erosion control, slash disposal
and vegetation control.
• Verify that procedures exist which ensure the proper marking and protection of
buried or surface pipelines such as site security and anti-corrosion programs.
• Verify that trained personnel and spill containment equipment is available should a
pipeline break occur.
• Verify that the engineering design and operations of a pipeline utilizes emergency
valve shut-off and leak detection programs and procedures.
• Inspect portions of the production line systems for such items as placement of shut-
off valves, marked facilities, erosion control, vegetation management and spill
cleanup.
PRODUCTION
GENERAL OPERATING PROCEDURES
Wellsite and Flowlines
Audit Protocol:
Well blow-down procedures shall be carried out so that impact to the environment is
minimized.
Audit Guideline:
• Verify that when well production casing is purged of fluids, sediments or waxes
proper waste containment procedures are followed. Local regulations may not
allow earthen structure used for storage of produced fluids. Tanks or other
containment must be used to contain the fluids. Some regulations may allow the
use of centralized blow-down pits provided they are equipped with an impervious
liner, leak detection and groundwater monitoring.
• Inspect wellsites in which wells have been purged. Identify the containment
procedures and verify if waste control was both undertaken and effective.
Document any spills.
• Verify through inspection that engineering designs take into consideration valve
controls at the wellhead to prevent pressure failure during these procedures and
shut-off systems are in place should storage facilities be unable to store related
waste volumes.
• Inspect flare knock-out tanks. They must be adequately sized and emergency
measures must be in place to shut a well down (e.g., high level shut down alarms).
PRODUCTION
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Pressure vessels shall be designed, operated and maintained such that impact to the
environment is minimized.
Audit Guideline:
• During the inspection, check for signs of spills. If there are any spills, record type
and location. Pressure relief valves, rupture disks or burst plates that are installed
on a separator, treater or other pressure vessel which receives production from a
well, must be connected by suitable piping to an open tank. They must also be
connected to the flare stack to ensure complete oxidation of all gaseous
substances prior to their discharge to the atmosphere. Other methods to prevent oil
spills are acceptable if they provide equivalent or better protection than the venting
of relief devices to an open tank.
• Verify that building drains are not to ground and all drains go to tanks for
appropriate disposal. Verify the methods of monitoring these tanks for failure.
PRODUCTION
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Dehydration units in gas plants, well sites and batteries shall be used and maintained
so that impact to the environment is minimized.
Audit Guideline:
• During the inspection, check for signs of improper gas leakage or spills. If there are
any spills, record type and location. Exhaust gases from dehydration units must be
vented out of the building. If a flare is in use at the site, then the exhaust gas
should be piped into the flare system. Water vapours off the reboiler should be
collected in a tank and disposed of properly.
PRODUCTION
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Audit Guideline:
• Prior to the field inspection, review plant licenses for emission rates. Determine if
rates are exceeded.
• Verify that the required number of stack surveys are completed each year.
• Verify if any soil/air monitoring is completed (see Soil Monitoring and Air Quality
Monitoring).
• Verify that sulphur is transported safely and dust control measures are in place.
• Inspect sulphur storage areas. Verify that proper storage procedures are followed
and identify if sulphur depositions are impacting on adjacent water quality or
vegetation.
PRODUCTION
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Audit Guideline:
PRODUCTION
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
The operation of aboveground and underground tanks shall be carried out in a manner
which does not cause damage to the environment. Tank operations include all work
which is done in conjunction with tanks. Examples are gauging, disposing of tank
bottoms, loading and unloading of tanks and emergency containment.
Audit Guideline:
a) Except in special areas, the volume contained by the dike must contain a
volume 10% greater than the tank if there is only one tank. If there is more
than one tank, the dyke must contain 100% of the largest tank plus 10% of
the aggregate volume of all tanks. Special areas may require a greater
secondary containment volume and are site specific.
d) Any other system that provides the same level of protection as those listed
above.
• Verify that a leak detection system is used for underground storage tanks. Inspect
this system. This can include:
PRODUCTION
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
Tanks and distribution lines shall be located such that they cannot be easily damaged
by moving equipment. Design techniques must be employed to prevent pressure
eruptions and reduce fire hazards.
Audit Guideline:
• See flowlines.
PRODUCTION
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
Oil and gas products shall be stored and labelled properly. All storage and loading
facilities and operations shall have equipment and procedures in place to prevent
spillage or reduce impacts to the environment as a result of a spill.
Audit Guideline:
• Verify the engineering designs and operating procedures, provide tank storage
integrity and that all loading facilities are designed to prevent or reduce accidental
discharge.
• Verify that all storage areas have proper spill containment and spill recovery
systems such as berms, spill drains, spill recovery collection tanks and oil recovery
technology.
• Inspect the storage and loading area for good housekeeping and spill cleanup.
Identify and inspect all central and collection systems. Determine the effectiveness
of such systems.
PRODUCTION
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
The handling, storage and use of chemicals in production operations shall be done
such that impact to the environment is minimized. These chemicals include treatment
chemicals (demulsifiers, friction reducers, surfactants and pad breakers) and corrosion
control chemicals (corrosion inhibitors, biocides, oxygen scavengers and scale
inhibitors). Hazardous materials shall also be handled properly. Chemical and
hazardous materials shall be stored and labelled properly.
Audit Guideline:
• Record chemical type and volume for each storage location. Verify that chemicals
are segregated appropriately.
• Verify methods for injection of treatment chemicals into the line at wellhead
operations and pipeline facilities. When this method is continued on a permanent
basis, it should be achieved by direct injection into the system from bulk tank (e.g.,
45 gallon drum). This method also applies to odorizing chemicals injected into
product pipelines at compressor stations.
• Inspect storage areas. Verify that all chemicals and hazardous materials are stored
safely and labelled properly. To store the chemicals, the following
recommendations are suggested:
b) All tanks should be fitted with an external gauge to monitor content level.
The tank must be externally vented if located in a building.
f) When wall mounted drums (45 gallon) are used as bulk tanks, the refilling
process should be carried out using a barrel transfer pump. The barrel pump
construction should be suitable for use with the specific chemical. Barrel
pumps and both containers involved in the transfer should be grounded.
• Inspect chemical metering pumps. These pumps are essential to control chemical
usage. The following recommendations are suggested:
b) All chemical lines should be colour coded and/or labelled at both ends.
• Verify use of Material Safety Data Sheets. Safety data sheets on each chemical
should be displayed where the chemicals are used. First aid kits should also be
available at all locations where chemicals are handled.
PRODUCTION
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
All hydrocarbon release points shall be piped into a vapour recovery unit.
Audit Guideline:
• Verify from engineering drawings the utilization and placement of vapour recovery
units.
• Verify through inspection and record reviews that vapours are incinerated.
PRODUCTION
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
Trucks, tanks and trailers shall be properly maintained. Operators should have proper
training in transportation safety and emergency response to accidental spillage.
Audit Guideline:
• Verify that policy and procedure are in place related to environmental protection.
Review procedures associated with the proper loading and transportation of oil and
gas products. Determine if all drivers are trained in emergency response
procedures.
• Verify and review vehicle and tank trailer service logs to identify schedules and
procedures undertaken to maintain equipment integrity, therefore further reducing
the potential for spills due to equipment failure.
• Verify that noise control policy is in place and all trucks undertake noise control
monitor.
• Verify that facility personnel are in continuos attendance when trucks are loading.
Determine if there is an appropriate drainage system in case of a spill.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Verify that construction guidelines are in place and guidelines pertain to protection
of the environment. Verify that any road maintenance programs do not utilize
harmful chemical negotiation management programs.
• Inspect general conditions of roads. The road surface should be compatible with
heavy loads. Sides of roads should be revegetated and the growth should be
controlled in order to maintain good visibility. Signs should be used to control
speed. Dust should be controlled.
• Inspect roads to detect any drainage problems. All access roads should be
maintained to allow proper drainage and to prevent erosion. Culverts should be
built as needed and maintained. All signs of erosion should be noted and the
cause repaired immediately.
• Inspect access roads near highly sensitive areas. Fences and signs should be
used to limit the use of access roads in sensitive areas.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates. Verify that access
control is in place for environmentally sensitive areas.
• Check the success of access control and determine if further control methods are
required.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Berms shall be used to contain surface runoff from oil wells, tank storage and
production facilities in order to minimize/eliminate a pollution release from going off-
site to contaminate the adjacent environment.
Audit Guideline:
• Verify that berm containment system has a surface water collection disposal
process. Verify that such a system is monitored to allow for water runoff but is
operated in a closed capacity to hold containments
• Verify that berms are inspected and maintained. There should not be any breaches
in the berms. If a release has occurred, the berms should be cleaned and repaired
as needed.
• Inspect berm areas. Identify proper berm design and placement, any berm failure
or breaches, or any permeable material which allows seepage.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction or
placement of a bridge or culvert for continual crossing use. Measures shall be taken to
reduce the impact of production operation activities on water quality.
Audit Guideline:
• Verify that the protection of streams due to sedimentation contamination has been
taken into consideration in the plans, designs and construction of an access road.
Inspect bridge crossings for signs of pollution and sediment problems.
• Inspect open stream crossing to verify that the number of vehicular movements
across a stream is kept to a minimum. Existing bridges should be used whenever
they are available.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
All sites shall be maintained properly and kept neat, clean and safe. Housekeeping
refers to the general maintenance of a site with respect to acceptable operating
practices, upkeep maintenance and overall orderliness of the grounds, buildings and
equipment.
Audit Guideline:
• Inspect site to verify that site is kept neat, tidy and free from litter. Trash should be
continuously collected and disposed of at an approved facility. (See Waste
Management section).
• Verify that all chemicals are properly labelled, stored, handled and disposed of.
(See Product Storage and Loading section)
• Verify that waste disposal is carried out such that it does not attract wildlife.
• Verify that clearly legible signs are posted as needed and maintained. Fences and
gates should be constructed as needed and maintained.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Regulations may restrict the storage of produced fluids or other foreign materials in an
earthen pit. Produced fluids, garbage or other foreign materials entering the flare pit
shall be removed immediately.
Audit Guideline:
• Inspect flare pits to make sure that no produced fluids, trash or other foreign
materials have entered the flare pit. If produced fluids are present, they must be
removed immediately.
• Inspect the equipment on site to ensure that there is no possibility for produced
fluids to enter the pit.
• Inspect the land adjacent to the flare pit to identify areas of contamination as a
result of pit overflow or excessive flaring.
• Inspect the walls of the pit and adjacent land for vegetation control (particularly use
of soil sterilants).
• Inspect the security of the pit to prevent people, livestock or wildlife from entering
the pit area.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The operation of flare stacks shall be done to minimize impact to the environment.
Audit Guideline:
• Inspect the location of flare stacks. They should be located away from trees, but
downwind of buildings and oil storage tanks. Verify that special restrictions in
forested areas are followed.
• Inspect stacks and adjacent land to see if liquids have sprayed off the stack.
Inspect flare stack operations. The separated liquids should not be discharged to a
flare stack and burned. Free liquids can escape up the flare stack to pollute the
land.
• Verify and inspect associated liquid removal vessels within the flare stack system.
Determine if an overflow shut down system is in place and if this system is working.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Verify that there is a Spill Contingency Plan and Emergency Response Plan that
clearly outline measures to be taken during a release of produced water. (See Spill
Prevention and Emergency Response section). A produced water release should
be responded to in the following manner:
a) Identify and control the source of the release; make repairs when safe to do
so.
c) Contain the released produced water using absorbent material or soil berms
or trenches as necessary.
f) The area of the spill should be flushed with a calcium amendment prior to
the application of any fresh water, recovering the excess fluid.
• Verify that any produced water spills have been properly decontaminated.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Verify that there is a Spill Contingency Plan and Emergency Response Plan that
clearly outline measures to be taken during a release of hydrocarbons. (see Spill
Prevention and Emergency Response section). A hydrocarbon release should be
responded to in the following manner:
a) Identify and control the source of the release; make repairs when safe to do
so.
f) Using water and surfactant, flush contaminated soil in order to free and
recover additional hydrocarbons.
• Check for signs of spills onsite. Record location and size of any spills. Provide a
sketch of the spill area if possible. Indicate the type of spills observed (type of
contaminant, soil contamination, water contamination, etc.)
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Verify that operations and maintenance personnel have guidelines to the proper
storage and disposal of waste materials as a result of site maintenance.
• Verify and inspect that hazardous materials utilized during maintenance operations
are properly handled and that hazardous waste material is properly recorded, stored
and disposed of (see Waste Management section).
• Verify that surface and underground storage tanks are monitored for leaks or
overflows (see Product Storage and Loading section).
• Verify that fences are in good conditions and gates are locked.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The impact of production operations’ noise on local residents and workers shall be
minimized.
Audit Guideline:
• If houses are adjacent to the facility, verify that discussions regarding the potential
impacts of noise were held with nearby residents during the design phase of the
facility. Verify that adjustments were made to meet the concerns and needs of the
residents. Adequate public notification and discussion can prevent noise
complaints before the operation starts. An ambient sound survey to measure
existing sound levels may be needed to assist the design.
• Make note of any public complaints (if any), response provided, and, if the noise
level is higher than acceptable limits, verify that measures have been taken to meet
or better the acceptable limits. If complaints have been received, verify that noise
monitoring of the wellsite is being done.
• Inspect wellsite to ensure that facilities are designed to ensure appropriate noise
levels.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The facility shall have proper drainage systems. Changes in natural conditions should
be minimized to prevent altering natural drainage patterns. Any normal interference
with the normal drainage of water from land, where such interference has been caused
by the operation, shall be removed or remedied as soon as possible.
Audit Guideline:
• Inspect site for internal drainage control to contain potential pollutants on the site.
• Inspect any contaminated areas and verify that surface drainage in those areas is
segregated from other areas of surface runoff. The contained fluids should be
stored for treatment and/or evaporation.
• Inspect bermed storage areas. Drainage from those areas should be contained to
prevent leakage of a spilled product from entering into the drainage discharge.
• Verify that all proper erosion control measures are being used.
• Inspect site for any signs of disturbance to drainage patterns. The consequences of
inadequate drainage are extensive and include ponding, flooding, washouts and
inundation of vegetation.
• Culverts and drainage ditches must be constructed as needed around the plant site
to prevent contamination of surface waters and groundwater.
• Verify through interviews that work crews have been instructed not to place any
materials in drainages.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Surface water shall be monitored after spills, after controlled acceptable releases and
as required to monitor water quality near operating sites. Existing local regulations
should be followed. A certified laboratory shall perform the analysis.
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
surface water monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including surface water monitoring
reports and verify compliance.
• Indicate if the facility has a surface water sampling monitoring program. Surface
water sampling and monitoring are site specific.
• Inspect surface water control and release structures. Identify if these structures are
shut to prevent accidental release runoff water.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Soil sampling and monitoring require proper sampling protocols and a certified
laboratory to perform the analysis. Record keeping is essential, particularly of
sampling locations (to ensure the same locations are sampled during a monitoring
program).
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
soil sampling and monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including soil sampling and monitoring
reports and verify compliance.
• Indicate if the facility has a soil sampling monitoring program. Soil sampling and
monitoring are site specific activities in order to assess soil quality. These activities
may be completed to track the progress of a decontamination program, to
determine the extent of a spill and develop remediation programs. Soil monitoring
may be undertaken at any time of a facility’s life, from pre-disturbance, during
operations or during reclamation.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
groundwater monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including water quality reports and verify
compliance.
• Indicate if the facility has any groundwater monitoring systems. Inspect monitoring
well sites and locations. Groundwater monitoring is a site specific issue. Wells
should be installed hydraulically up gradient and down gradient of a potential
contaminant. These wells will be used to determine the depth and direction of
groundwater flow. Monitoring wells must be set in an area that will not interfere
with everyday operations, however, they must be set in order to collect the proper
information.
• Verify that monitoring wells are equipped with a lock in order to prevent
unauthorized entry.
• Verify that only trained personnel or consultants sample the monitoring wells.
Groundwater monitoring is site specific; however, for predisturbance assessments,
it is recommended that the following components be sampled: pH, electrical
conductivity, major ions, total metals and dissolved organic carbon.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The discharge of water to the environment shall be minimized. A water release may
occur by opening a berm drain, by overflowing a berm, or by pumping water to the
surrounding land.
Audit Guideline:
• Verify that any water released to the environment meets existing regulations. When
discharging water, a field analysis must be done. Field determination may be done
using an appropriate pH meter and Quan Tabs for the chloride determination. Any
visible hydrocarbon sheen requires that the fluid be disposed of via an appropriate
oil field waste disposal facility. The following criteria are recommended:
If the discharged water does not meet the above criteria, the fluid must be disposed
of at an approved oil field waste disposal facility or treated and then discharged on
or off lease with the approval of existing regulatory agencies and the landowner
(private land) or public land manager (public lands).
• Verify that any water discharged is not allowed to flow directly into rivers, creeks or
any other permanent body of water.
• Verify that a proper documentation and reporting procedure exists for water
discharges to the environment. Records must include the parameters listed above
as well as an estimation of the volumes of water disposed.
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Gaseous emissions in oil production batteries or gas plants shall be controlled and
minimized.
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
gaseous emissions have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including air quality reports and verify
compliance.
• Determine if any measures are taken to minimize gaseous emissions occurring on-
site. The main air quality parameters of concern are SO2, H2S and NOx. Ozone,
carbon monoxide, carbon dioxide, hydrocarbons and ammonia are also a concern.
Ways to reduce gaseous emissions may include:
PRODUCTION
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Air quality monitoring is required at some locations of the facility to comply with
existing regulations or when due to resident or landowner concerns. Long term
emissions can have an adverse impact on soil and water.
Audit Guideline:
• Prior to the field inspection, review records including air quality emission reports
and verify compliance.
• Verify that air quality monitoring systems are onsite as required (e.g. facilities
where sour gas is processed, etc.). Two types of air monitoring systems may be
undertaken: ambient monitoring and total sulphation/H2S.
• Inspect air quality monitoring equipment. Air quality sampling is done with many
different pieces of equipment including mobile trailers, stationary trailers and
“birdhouses”. Verify that sampling equipment is in working order and correctly
calibrated.
• Through interviews, verify that operators are familiar with the station so that if there
is an upset, they can fix/modify it and it is not down for an extended period of time.
Operators must be familiar with sampling procedures and sampling locations.
• At sour locations, verify that stack surveys are completed, if existing regulations
require them.
PRODUCTION
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Audit Guideline:
• Inspect fuel storage areas and equipment. Fuel tanks are preferable to bladders,
and welded steel tanks are preferable to bolted ones. Inspect tank dykes and verify
that they are of adequate size to contain any spills and have impermeable sides
and bases. (See section Product Storage and Loading section)
• Verify that fuel storage areas are clearly marked to ensure that they are not
damaged by moving vehicles. The markers should be visible under adverse
weather conditions. Check that “No Smoking” signs are posted and followed.
• Through interviews, verify that all personnel are familiar with fuel handling
procedures.
• Verify if fuel transfer operations are performed in a manner that prevents spills.
Review records to verify if there is any reporting process in place to record
occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgable of such process.
• Verify the utilization of API oil skimmer systems. Review engineering designs and
identify any modifications. Verify if water analysis is undertaken at water discharge
points.
• Inspect all API oil skimmer units to determine the effectiveness of oil recovery.
Review water analysis to assess the success of these systems. Record any spills
or evidence of hydrocarbons in the water discharge streams.
PRODUCTION
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Audit Guideline:
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite. Determine locations, types and quantities of
spill control materials available onsite. These may include: sorbent materials, oil
retention booms, sand bags or temporary curbing devices, recovery pumps and
collection hoses, recovery tank trucks and protective equipment.
• Verify that release drills are held. Release drills should be held at least once a
year. All operating personnel should be required to attend. The sites chosen for
the drill should include topography which is representative of the conditions most
likely to be faced in the event of a release.
• Review any past incident reports. If there have been any releases in the past, a
review should be undertaken to review the causes of the release and to provide
recommendations as to how such a release can be avoided in the future. The
review should include an assessment of the contingency plan and the response as
well, assessing whether there should be any improvements made to the plan or the
training provided.
PRODUCTION
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Production facilities shall have an Emergency Response Plan to protect the public,
employees, the environment and property should an emergency occur. It is necessary
to provide all employees with a systematic presentation of communication practices
and procedures to be followed in an emergency.
Audit Guideline:
• If the facility is located near residential areas, verify that discussions with local
residents were held when preparing the Emergency Response Plan.
• Interview personnel to verify the level of knowledge of such plan. All employees
should be familiar with the Emergency Response Plan for their work area. They
should also be familiar with the location of emergency equipment and have
participated in mock exercises, held at least once a year.
a) Regulatory Information
b) Scope of the Emergency Plan
c) Local public involvement
d) Contents of the Emergency Procedure Plan:
• Verify through inspection that all material and equipment specified in the
Emergency Response Plan is available onsite.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Production facilities shall have a Waste Management Plan to ensure each facility
knows what wastes it produces and how to handle and dispose of those wastes
properly.
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility. Review the plan
and see if the wastes the facility produces match the wastes discussed in the plan.
Review the waste disposal methods recommended in the plan and verify if they are
being followed. Review the training schedules for waste management; when
talking to the operators, determine how well the management plan is taught/how
familiar they are with the plan/how practical it is. Verify that a waste manifest
procedure is in place and is being used properly. Review trucking routes for waste
disposal.
• Inspect all waste handling containers and verify the waste has been sorted and
allocated to the correct container. Verify that the container is the correct type for
the waste.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
All waste material shall be properly identified and handled according to hazardous and
nonhazardous waste handling regulatory requirements. General solid wastes
generated by operations shall be disposed of in an acceptable manner to prevent
pollution to the environment.
Audit Guideline:
• Verify prior to the field inspection, the required regulatory procedures to properly
dispose of all types of solid wastes generated.
• Verify that all sites and rights-of-way are kept free of trash and litter. All trash, litter
and garbage must be placed in metal or plastic containers and disposed of
properly.
• Inspect site area for disposal methods of general solid wastes. Such wastes
include rags, waste paper, paper cartons, scrap metal, plastic wastes and rubber
wastes. Industrial landfilling and incineration are the most commonly used
methods for disposal of solid wastes. Incineration is followed by burial of the
incinerated residue. Combustible wastes should be incinerated daily. Materials
suitable for recycling should be stored separately and recycled accordingly.
• Inspect garbage disposal sites. Garbage disposal sites should be used for small,
non-toxic, non-perishable refuse and incinerator residues. Holes or pits should be
located above the expected high water level. A minimum distance from the bank of
a water body of 45 m is required. Consider and evaluate the potential of wildlife
intrusions to the garbage disposal sites or attraction to the location. Verify that pits
are lined.
• Verify that fuel barrels or other containers are not left on the site or along the rights-
of-way.
• Verify that the incinerator(s) is inspected and tested at least yearly to ensure
optimum efficiency.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Indicate if there is any specific code of practice for worksites where asbestos
containing materials and man-made vitreous fibres are present.
• Verify that standard work procedures are in place for working with asbestos
containing materials and man-made vitreous fibres. These measures may include
refraining from smoking, eating or drinking while working with insulation products,
showering, not taking clothes contaminated with fibrous insulation out of specific
areas, following special cleaning procedures for work clothes, wearing the required
safety clothing, posting appropriate signage and using appropriate handling
methods.
• Verify that asbestos containing materials are held in restricted zones or transported
immediately to its final disposal site.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
sewage disposal facilities have been identified and provided as guidelines for
implementation in the field.
• If there are any subsurface disposal facilities (septic tanks, leach pits), inspect
distances from any sources of water supply and natural water bodies. Verify that
pump-out and hauling operations are carried out in a manner that does not expose
the driver or people in the area where the tanks are emptied to any health hazard.
Every effort should be taken to avoid any spillage when holding tanks are emptied
or when the truck contents are discharged into the treatment facility.
• Verify that the flow through the effluent treatment system is carefully controlled.
Oveloading the system hydraulically reduces the effectiveness of pollutant removal.
Also, a sudden shock will upset the biological balance and performance will drop.
The shock can be either an increase in pollutants or an influx of unusual pollutants.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
If sewage lagoons are used, they shall be designed properly to ensure that effluents do
not contaminate ground or surface water or soil and do not present a health hazard.
Audit Guideline:
• Inspect sewage lagoons onsite used to treat sewage/effluent. The following criteria
are recommended:
e) Must be fenced.
• Verify that lagoon is properly built, effluent is not released before full retention time
and there are no leaks.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility where recycling is
implemented.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
All water usage shall be assessed for the potential of recycling or reuse. Water usage
shall be minimized by employing the basic principles of water conservation through
reduction of the volume of water used, effective recycling, and maximizing reuse.
Emphasis should be placed on concentrating waste materials in limited volumes of
water.
Audit Guideline:
• Verify if there is an appropriate recycling and reuse system in place for waste
water. This system may include assessment of potential recycling and reuse
methods upon waste identification, determination of preferred methods of recycling
water and identification of alternatives. Waters identified for recycling should be
properly stored and clearly identified.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
The disposal of oil based waste materials shall be done in an acceptable manner.
These materials include waste oil sludge, treater hay and oil spill debris.
Audit Guideline:
• Verify that waste oil sludge is disposed of properly. Oily waste may originate from:
a) Tank bottoms and treater sludge from conventional production.
b) Sand and waste oils from heavy oil production.
c) Pigging wax from line cleaning.
d) Solvents.
e) Lube oil.
• Inspect site for the provision of tanks at all facilities to ensure temporary storage for
waste oils until they can be properly and safely disposed. Disposal bins equipped
with steam tracing lines may be used to temporarily store pigging wax. The bin can
be transported to a reclaiming facility where it is steamed prior to dumping the
residue into a reclamation tank.
Acceptable disposal options (not a permanent solution but generally safe) are:
a) Application on Roads: tank bottoms, treater sludge and waste oil from heavy
oil operations may be applied to roads, subject to approval of appropriate
authorities.
b) Incineration: waste oils can be disposed of by incineration. However, poor
combustion may cause objectionable smoke or odours.
• Verify that treater hay is disposed of properly. Treater hay results from conventional
treaters that use a filtering medium to enhance impurity removal. The filter material
is called treater hay.
The following disposal methods are acceptable if the preferred options are not
available:
a) The hay may be disposed of into flare pits and burned in conjunction with
periodic flaring (subject to regulatory approval). If the hay is adequately
cleaned prior to burning, it may not create smoke problems when burning.
b) Transport in sealed containers to nearby reclaimers equipped with cleaning
facilities and incinerators.
• Verify that oil spill debris is disposed of properly. In the past, most spills were
controlled on site and burned as quickly as possible. However, due to the emission
of unsightly black smoke and the hazard of ash and carbon fallout, regulatory
bodies are often reluctant to give permission to burn unless there are no other
options. The hazards of forest and/or ground fires must also be considered prior to
burning. The heat generated by burning will destroy underground roots and soil
microbiology, making the re-establishment of vegetation much more difficult.
The preferred reclamation option is: After as much oil as possible has been picked
up, the preferred reclamation procedure is to help the residual oil to degrade by
natural microbial action. This can often be enhanced by using fertilizers and
agricultural practice. See Reclamation/Remediation.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Verify that wastes resulting from natural gas processing are disposed of properly.
The following methods are preferred:
c) Disposal of spent iron sponge: it can be either regenerated with air to form
elemental sulphur or it can be removed and disposed.
f) Disposal of desiccants: since molecular sieves are alkaline and often quite
clean from the regeneration process, they can safely be disposed in properly
constructed landfills at the plant site. Contaminated molecular sieves should
not be landfilled. They must be stored in drums or on the plant site. Since
the quantity is often not very large, this is not a problem for most plants.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Filters shall be disposed of and changed in an acceptable manner. There are many
types of filters used in the petroleum industry. They include glycol filters, lube oil filters,
domestic water filters, amine and sulfinol filters, etc. Eventually these filters become
clogged and must be replaced. Since filter media will be saturated with the material
being filtered, care must be taken when disposing of them.
Audit Guideline:
Immediately after use, filters should be stored in a container equipped with screens
to permit fluids to drain. Filters should always be drained prior to disposal and the
entrained liquids can be disposed of at approved disposal wells (see section on
Injection and Disposal Wells). To properly drain a filter, it must be stored in the
screened container for a minimum of three days at room temperature. Entrained
fluids must be kept segregated for recycling or disposal. It must be determined
through sampling if the filter is a dangerous oilfield waste. Examples of filters that
may be a dangerous oilfield waste are: glycol filters, leachate and entrained liquids,
air pollution control filters, sulphinol filters, lub oil filters, methanol filters, gas filters
and produced or process water filters.
If a screened on-site container is not available for drainage, a barrel with a fitted
screen may be used. The filters should be enclosed in separate plastic bags,
sealed in a drum and buried at an industrial landfill site.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
The operation and maintenance of disposal wells shall be carried out so that impact to
the environment is minimized.
Audit Guideline:
• Determine if there is a standard procedure in place to detect any releases from the
disposal system.
• Inspect disposal well locations. Pressure of disposal must be monitored. Look for
signs of spills.
• Inspect location of disposal lines for deep well disposal. They should be located
downstream (flow of the aquifer) of ponds, lakes, crops and dwellings. Produced
water disposal wells are susceptible to corrosion, therefore leaks along the pipeline
right-of-way are always a possibility and must be monitored. Record method of
detecting leaks in pipelines.
• Verify that the disposal zone is at a depth not less than 600 metres.
PRODUCTION
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Verify that appropriate precautions are taken when handling sulphur. Personnel
should take measures to alleviate or mitigate the following major issues:
c) Sulphur spills when pouring molten sulphur into tank cars for transportation
or onto sulphur blocks for storage.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
A Reclamation Plan shall be used for returning the land to its former land use
capability.
Audit Guideline:
The reclamation plan will take into account whether it is part of a live site which is
being reclaimed or whether the entire site is being abandoned. This can
significantly alter the procedures used.
The plan should identify all capital salvage items, outline the salvage program,
identify disposal options for items which cannot be reused, identify any
contamination issues and how they are to be dealt with and specify the steps for
the restoration of the site (or the portion being restored).
The plan is based on the Site Assessment (Phase I, Phase II if necessary). The
data from the assessment is then evaluated and the necessary procedures are
specified in order of priority. The plan should include a cost estimate, inventory
control, service contracts, equipment and material handling procedures,
environmental protection measures, safety measures, schedule and priorities and
cost control.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
The physical removal of all buildings, facilities, structures and improvements - above
and below ground - shall be done in an acceptable manner.
Audit Guideline:
• Inspect sites being decommissioned or reclaimed. Verify that all equipment and
structures are removed appropriately. Some items, including access roads, gates
or pads, may be left on site if the landowner and reclamation officer are in
agreement or if the landowner agrees and it does not interfere with the reclamation
of the site.
• Verify that all liquids and sludges from vessels/tanks/lines are removed for
disposal.
• Check for asbestos insulation. It is not possible to visually discern this, a lab test is
required. Asbestos containing materials must be removed by especially trained
crews and double bagged for disposal. See Asbestos
• Verify that after all liquid has been removed from the vessels, flowlines, and tanks,
and that all equipment from the site is removed. Ensure any residual fluids which
remain are collected for disposal.
• Verify that cement pads and other inert materials are broken up and are buried on
site with a minimum cover of 1 m of compacted fill or it can be hauled out. Power
lines, power poles, gas lines, telephone lines, and equipment require removal by a
utility company.
• Verify that gravel is salvaged as much as possible for use elsewhere. Gravel
should not be removed until all heavy traffic is finished in order to prevent
reclamation problems.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
Flare pits shall be closed in an acceptable manner in order to ensure no harm is done
to the surrounding land and water.
Audit Guideline:
• If there are fluids in the pit, verify that a composite sample of the fluids is taken. All
precautions must be taken, particularly if the site is still in use. Verify that all
applicable safety procedures are followed.
• Verify that proper methods are used for treatment and disposal of contaminated
material.
• Verify that the soil in the pit was sampled and analyzed to determine if
contaminants are present. If analysis indicates contaminants are not present, then
the pit may be backfilled. If contaminants are present, then decontamination must
be completed. Verify that sampling of the flare pit was undertaken without fluids in
the pit.
• Inspect flare pits planned for closure. If feasible also inspect flare pits in which
closure activities are underway.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
When sites are being decommissioned or abandoned, the removal of underground and
aboveground storage tanks shall be done with minimum impact to the environment.
Audit Guideline:
• Verify that tanks are removed properly. The following procedure is recommended:
All residual liquid must be removed from the tank. A bull plug must be placed in all
tanks openings.
All piping must be exposed and disconnected. All fluid must be removed from the
tank prior to the start of any excavation. Tanks should be purged or inerted prior to
the start of excavation. Purge means to remove the explosive vapours and inert
means to remove the oxygen from the tank.
• Verify that any contamination resulting from the removal of the tanks has been
assessed by a qualified environmental consultant. Soil samples should be
collected.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
The well casing and wellsite shall be abandoned to a condition where there exists no
present or potential environmental pollutants.
Audit Guideline:
• Verify through record review that abandonment approvals have been obtained from
related regulatory agency.
b) Isolate any known productive oil and gas zones and prevent migration of
fluids in or out of these zones.
c) Isolate the open hole from the cased hole by a cement plug or a retainer-
cement plug combination placed in the deepest casing string which extends
to the surface.
d) Plug all annulus spaces that are open to formations and that extend to the
surface.
e) Place a surface cement plug below the ground surface in the smallest
casing string which extends to the surface.
• Verify that an abandoned well has a cement plug extending from a depth of at least
200 metres to surface, unless that interval is covered by casing which is cemented
over the interval.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
All sites being reclaimed shall have any contaminated soil removed or remediated
before recontouring and revegetation.
Audit Guideline:
• Verify that all sites contaminated by spills and other chemical disturbances have
been decontaminated. Inspect site being decontaminated. The site may require
restricted access, such as fencing to protect people and animals.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
Reconstructed soils should be able to produce to the former land capability. Soil shall
be returned to similar conditions as preconstruction/operations. The soil layers on site
should be within 50% of their predisturbance depths (topsoil and subsoil). The topsoil
must be in the same texture class as adjacent land. Approximately 20% of the site
may drop one soil quality class.
Audit Guideline:
• Verify that at least four control sites were examined to a depth of 50 cm in order to
identify what soil conditions should be for the site.
• Determine if soil amendments were used or are needed in order to return the soil to
predisturbance conditions. Verify that the amendments recommended were based
on laboratory analysis of the soil on site. Verify what amendments were used
(manure, straw, tree bark mulch, peat, artificial fertilizer) and determine if they were
consistent with both the predisturbance soil conditions and the laboratory analysis.
• Verify that the soil after remediation is the same texture class, same pH, same
aggregate size and strength, same quantity of gravel and rocks and same organic
matter content as the control sites.
• Ensure that the site has been decompacted and that the soil process restriction
parameters are nonrestrictive as compared to the control. Process restriction
parameters are water permeability, vertical root elongation and soil aeration. No
soil layer should have greater density than before.
• Verify that surface soils have been salvaged and replaced on site.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
All sites being decommissioned, reclaimed or portions of “live” sites not required for
operations, shall be restored to a capability equal or better than the surrounding current
land use. This includes restoring the original drainage patterns and ensuring that the
site does not hold water.
Audit Guideline:
• Verify that culvert and creek crossings are removed and banks are recontoured
back to original contour (stabilized log cribbing may sometimes be left).
• Verify that creation of steep slopes is minimized (<3H:1V on clay soils, <5H:1V on
silt soils).
• Verify that runoff is spread over a large area to minimize runoff water velocities.
Water should be drained in a sheet instead of channels on slight to moderate
slopes.
• Verify that berms and diversion ditches are used to move water into vegetated
areas on steep slopes to reduce erosion. Angle across face of slop should be < 30
degrees. There should be no more erosion gullies than on adjacent land.
• Verify that soil is replaced according to the soil profile - horizons A and B should not
be mixed. Subsoil should be replaced with proper compaction.
• Look for ponding, silt deposition and gully erosion. Altered drainage must not
adversely impact adjacent properties.
• Verify that all surface soils are salvaged and replaced onsite.
• Verify that erosion control measures are used as required including berms,
crimping, mulching, manuring, netting and bale placement.
• Verify any rocks were buried more than 150 cm below grade.
• Ensure microsites are created for enhancing growth of vegetation - site should not
be smooth.
• Inspect sumps and pits locations for signs of settlement. Sumps and pits which are
backfilled will settle - mound 50-100 cm to compensate.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
All sites being decommissioned or reclaimed and all disturbed areas at “live locations”
shall be revegetated to prevent erosion, soil degradation and return site to its former
land use.
Audit Guideline:
• Inspect site to verify that proper revegetation procedures have been implemented.
Disturbed areas should be revegetated with grasses, shrubs and trees native to the
area.
• Inspect that species selected are consistent with the planned use of the area
(commercial forest, recreation area, grazing or wildlife habitat, etc.)
• Verify that the seed mixture is fast growing, self-sustaining and that it requires little
or no maintenance.
• Verify the density of growth: overly dense or too little plant growth will require further
work. Determine the method of seeding, time of year of seeding and seeding rates
and compare with the success of the revegetation on site.
• Verify if fertilizers were used and if so what kind. Determine if the quantity and type
is appropriate for the site and climate.
• Verify that the recontouring was appropriate for the vegetation growth (see
Recontouring) i.e., decompaction, microsites, no erosion or ponding.
• Verify fences have been used where necessary to protect new growth.
• If the site has had time for revegetation growth, inspect and record the success
achieved after revegetation and if more work is required.
PRODUCTION
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
• Verify that all equipment was properly removed and that the site has been
completely dismantled.
• Verify that flare pits are closed in an acceptable manner (see Closure of Flare Pits).
• Verify that access roads, borrow pits,etc., have all been removed.
• Verify that all decontamination procedures were performed properly and that the
site is decontaminated (soil and water).
• Verify that the soil profiles on site are within acceptable limits to matching the soil
profiles of the off-site controls.
• Verify that the vegetation is, after at least one full growing season, growing well,
with appropriate plant density, cover, plant type and height. Also verify that the
species composition is appropriate for the site and that the vegetation is healthy.
Any bare areas or noxious weeds should be noted.
• Verify that any soil amendments are appropriate for the site and applied correctly.
• Verify that the drainage patterns, contours and slope are appropriate, that there is
no debris on site, that the landscape is stable and that surface rocks match
adjacent land.
• Verify that after operations are completed, the site is restored, as far as practical, to
a condition compatible with existing land use, and that the land capability is equal
to or better than predisturbance conditions.
This section applies to pipelines, tank farms and marine terminal operations.
Some topics may be relevant to each of these facilities or just one or two.
- Operations
- Product Storage
Waste Management
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any pipeline, transportation and marine terminals construction and
operations program. Special conditions and restrictions shall be reviewed and
enforced.
Audit Guideline:
• Meet with the project supervisor to review the project records to ensure that all
required construction permits, licenses and regulatory authorizations were obtained
prior to the start of any field operations. Check the files to make sure that all
information in writing is available and has been provided to all field supervisors on
site. Record permit/license numbers and contractors specifications and verify
information in the field.
• Review records to verify that consent of the landowner or land occupant has also
been obtained prior to any work. Look for field report sheets on
landowner/occupant contacts. Check with the project supervisor that field reports
have been reviewed.
• Identify if regulatory personnel will be inspecting the work and attempt to coordinate
the site visit and meet with the government person in the field.
• At marine terminals, there is very tight scheduling, and the terminals know well in
advance which vessels will arrive. Most terminals have requirements that vessels
must meet if they are to call at a particular terminal. Review any particular vessel
requirements related to length, draft, equipment (inert gas systems, crude oil
washing systems, segregated ballast, double hulls/double bottoms) and previous
accident or spill response. Verify that these issues are enforced during the terminal
operations.
Audit Protocol:
All facilities operating personnel shall be trained and aware of the environmental
impacts of their operations. They should understand the necessity for environmental
planning and protection measures.
Audit Guideline:
• Verify that all personnel have taken environmental training in their field of
operations and are clear on how to implement and use their training correctly. This
should include, but not be limited to, emergency response/spill containment
training, waste management, current regulatory requirements and best operating
procedures.
• Verify if there is a system in place for all personnel to update their training yearly or
as required.
• Inspect the facility technical reference library to identify that environmental training
manuals and reference programs are available.
• Verify through consultation with senior personnel that funds are made available
annually for environmental training.
Audit Protocol:
The planning and engineering design of pipelines, transportation and marine terminals
facilities shall be undertaken in a manner that will anticipate potential environmental
problems and minimize the impacts of the operations on the environment.
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding environmental concerns during the planning stage of
pipelines.
• Inspect site to verify that environmental concerns were considered during the
planning of the operations. These concerns may include loss of timber, effect on
forage and crops, effect on wildlife, effect on marine ecosystems, water pollution,
erosion potential on slopes, access, fence crossing requirements, scheduling of
construction, disruption of tides and damage to shorelines, etc.
• Review records to verify that all relevant operations and safety manuals and
abandonment procedures manuals are available on site.
• Verify that environmental concerns were considered during the planning of access
roads. Existing roads should be used as much as possible to minimize
unnecessary road construction and encroachment on the adjacent land. To
minimize the need for deep cuts, the planner should avoid steep gradients and
identify the areas for detours. Access road location should minimize disturbance to
watercourses and sensitive areas. Clearing widths should be kept to a minimum.
Changes to natural conditions should be minimized while attaining maximum
erosion control.
• Verify through interviews that work crew has been instructed to avoid trampling of
crops.
• Verify that work crews have been instructed to avoid harassment of wildlife.
• Verify that attempts have been made to schedule project activities to avoid the time
periods when high water levels occur in marshes. Walking across marsh areas
can disturb the habitat provided by the marsh. Spawning periods of fish in rivers,
streams and creeks should be taken into consideration to avoid disturbance during
critical periods. Efforts must be made to avoid damage to spawning beds at all
water crossings.
• Identify if limitations of seasonal weather and the parameters for halting work in the
event of serious environmental damage have been considered (i.e. wet weather
causing erosion or extreme dry weather and a high fire risk).
Audit Protocol:
At the start of the audit all general information on site list shall be verified. Site
information should correspond to all engineering and design drawings and plans. All
modifications or amendments to any facility or operations should be found in all
drawings and plans showing the date of change. All modifications associated with
environmental protection should be recorded.
Audit Guideline:
• Verify type of site (i.e., pipelines, tank farm, marine terminals, etc.).
• Record all equipment and its condition on site (i.e., tanks, pits, dikes, berms,
sheds, etc.).
• Record soil quality, erosion controls, condition of top soil stockpiled and adjacent
wild life habitats and species.
• Verify the nearness of surface water bodies and water wells to facilities.
• Undertake a general inspection of the site to verify engineering and design plans
are current. Record any changes in the facility which do not correspond to existing
plans or drawings.
Audit Protocol:
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding surveying of pipelines.
• Inspect flagged right-of-way and check that field sensitive areas are avoided.
• Verify that surveyors carry out their duties in an environmentally responsible manner
and they are aware of particularly sensitive areas.
Audit Protocol:
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding cutting, clearing and timber salvage.
• Inspect site to verify that any particular restrictions regarding clearing operations
have been taken into consideration.
• Inspect site to verify that all necessary precautions were taken to minimize soil
erosion and to avoid pollution of waters and waterways. Siltation can be avoided by
use of fibrous materials in drainage areas.
• Verify that all stream and river approaches and slopes with potentially unstable
banks are hand cleared to a distance of 100m from the high-water mark or to the
top of the slope, where the slope is greater than 3:1.
• Review records to verify that a recording procedure is in place for all sold and
transported timber.
• Verify that after clearing, timber is removed and put to some beneficial use or is
disposed of by sale.
• Ensure salvaged timber is located in areas suitable for recovery and in a manner to
facilitate economical removal.
Audit Protocol:
Topsoil shall be salvaged from all graded and disturbed areas. Topsoil shall be used
for specific land surface restoration and revegetation.
Audit Guideline:
• Inspect site to verify that topsoil is selectively removed from the disturbed area and
conserved.
• Where ever possible topsoil should be stockpiled at the top of a slope and not at
the bottom to facilitate easy replacement. Retaining walls can be used to hold soil
on slopes or away from creeks.
Audit Protocol:
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding grading procedures.
• Verify that grade changes requiring excessive cuts and fills are minimized. Grading
should be done only as necessary to provide an adequate surface for construction
equipment and to allow overbends and sags.
• Verify that grading is done away from watercourses to reduce the risk of material
entering a watercourse. Fill material should not be placed in a watercourse during
grading.
Audit Protocol:
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding trenching procedures.
• Verify that trenching in areas with a high water table is delayed until just prior to
lowering-in to prevent the trench from sloughing.
• Verify that proper safety measures are taken during trenching operations. No
person should enter a trench at any time. Shoring at tie in areas is recommended
where soil is loose or sandy. All trenching should be fenced if it is to be left open
overnight.
Audit Protocol:
Audit Guideline:
• Verify that appropriate gaps are left in pipe joints to permit vehicular access or
movement of livestock to watering and feeding areas. Within wildlife habitat areas,
gaps should be left for wildlife movement.
• Verify that spent welding rods are not left on the ground or in the trench. Verify that
proper techniques are used in high fire hazard areas (i.e. welding must be shut
down during high winds and water trucks should be available).
Audit Protocol:
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding backfilling procedures.
• Verify that the length of open trenches is minimized by backfilling immediately after
lowering-in.
• Verify that subsoil is backfilled prior to replacing topsoil. Topsoil should not be
used for padding the pipe. Backfill material should be kept free of wood, skids,
garbage and other construction debris.
Audit Protocol:
Audit Guideline:
• Determine if safe and proper procedures are used for testing operations. Post
warning signs may advise the public of danger. No one should be near lines when
testing.
• Verify that there are sufficient workers and equipment available on site to repair any
rupture, leak or erosion in the event of a test failure.
• Verify that alternatives to natural water bodies are used as a source of hydrostatic
test water. Test pumps should be isolated from water bodies with an impermeable
lined dyke or depression to prevent spills of fuel or lubricants from entering a water
body. Water returned to natural water bodies should be of sufficient quality to avoid
any serious pollution problems.
• Verify that pipelines are dewatered in a manner which prevents soil erosion and
damage to the beds and banks of water bodies.
• Verify that all methanol and ethylene glycol is recovered in tankage. Contamination
to natural water bodies must not be allowed.
Audit Protocol:
Audit Guideline:
• Verify that proper safety procedures are used for fire control. Restrictions on
smoking and ensuring vehicles carry fire fighting equipment during high fire hazard
periods are recommended. The following equipment and measures are suggested:
Audit Protocol:
Depending on the type of terrain, vegetative cover, existing activities and concerns of
other land users, the pipelines program may require adjustments to accommodate as
many concerns as is practical or possible.
Audit Guideline:
• Inspect site for any disturbance to agricultural productivity due to trampling of crops,
removal of plantation trees and plants, inconvenience of farming activities.
• In agricultural areas, inspect site for attempts made to avoid disturbance of fields
that are nearing harvests.
Audit Protocol:
Distribution lines shall be located such that they cannot be easily damaged by moving
equipment. Design techniques must be employed to prevent pressure eruptions and
reduce fire hazards.
Audit Guideline:
• Verify that procedures exist which ensure the proper marking and protection of
distribution lines such as site security and anti-corrosion programs.
• Ensure all lines are marked and maintained and that records are checked before
any excavations are started. Spill containment equipment should be on hand
before any excavations begin.
• Check for saltwater or oil spill along right-of-way, erosion control, slash disposal
and vegetation control.
• Verify that trained personnel and spill containment equipment is available should a
pipeline break occur.
• Verify that the engineering design and operations of a pipeline utilizes emergency
valve shut-off and leak detection programs and procedures.
• Inspect portions of the distribution line systems for such items as placement of
shut-off valves, marked facilities, erosion control, vegetation management and spill
cleanup.
There are at least three distinct types of terminals: those that are primarily used for
export, those that are primarily used for import and those that are designed for
transshipment. Most marine terminals are located at tide water; some are designed to
have ships berth at the dock and offload to tanks on shore; others have an offshore
buoy where vessels discharge their cargoes which move via marine pipelines to a
shore based tank farm. Some terminals are located offshore, but only a limited
number exists. Most crude oil is processed at or near the production site; the vast
majority of crude oil delivered to marine terminals is sales specification with a
minimum of sediment and water.
Audit Protocol:
Accidents frequently occur during the last phases of approach and docking or during
transfer operations. Operations at marine terminals shall be undertaken in a manner
that would minimize impacts to the environment. All equipment and infrastructure have
to be well maintained to prevent any pollution incidents.
Audit Guideline:
• Verify that charts, maps and other written or graphic information are well
maintained; verify that they are current and regular depth and obstruction surveys
are conducted where draft limitations are a concern.
• Pilots are used in some ports and at some terminals. Verify that the relationship
between the Master of the tanker and the Pilot is clear, and that the Pilot’s
credentials are relevant to the location and vessel being berthed.
• Verify that the condition of the dock, mooring lines, fenders, buoys,
connectors/fittings and hoses is acceptable. These issues are important for the
prevention of polluting incidents (also see Spill Prevention and Emergency
Response). Verify that adequate lighting is available for nighttime operations.
• Verify that fire-fighting equipment on-board and on the dock is maintained in a high
state of readiness.
Audit Protocol:
Crude oil transfer and shipping to terminals shall be conducted so that environmental
disturbance is minimized. Pipeline, truck and ocean tankers transfer operations shall
have environmental control systems such as electronic fluid control, gauges, lock out
valves, low pressure shut in valves, emergency shut down systems, etc.
Audit Guideline:
• Verify that all crude oil transfers are monitored by personnel at either end of the
connection. Ensure that appropriate emergency shutdown systems are available
and in working condition. Ensure that communication systems connecting the
discharge and receiving facilities are working and that adequate secondary systems
are available and function properly.
• Verify through interview and inspection of records that all components of the
loading/transfer system receive regular inspection and maintenance. Inspect logs
at the facility and tankers for an indication of problems during crude oil transfer and
their resolution. Pay particular attention to reports of emergency disconnects and
any release of oil.
• Check condition of transfer hoses, pumps and any pressure testing procedures.
Review incident history of transfer hoses. At ship terminals, close attendance
during bunkering of the vessel with the pollution control equipment is
recommended.
• Verify vehicle and tank trailer service logs to identify schedules and procedures
undertaken to maintain equipment integrity. Verify that drivers have proper training
in transportation safety and emergency response to accidental spillage.
Audit Protocol:
Valves shall be maintained in order to prevent spills and minimize any impact to the
environment.
Audit Guideline:
• Verify that inspection of all valves are regularly undertaken. Verify that valves are
secured and monitored regularly for leaks.
• Inspect valves for signs of leaks. If there are any leaks, record the type (i.e., oil,
gas, chemical, water, etc).
Audit Protocol:
Audit Guideline:
Audit Protocol:
The operation of aboveground and underground tanks shall be carried out in a manner
which does not cause damage to the environment. Tank operations include all work
which is done in conjunction with tanks. Examples are gauging, disposing of tank
bottoms, loading and unloading of tanks and emergency containment.
Audit Guideline:
a) Except in special areas, the volume contained by the dike must contain a
volume 10% greater than the tank if there is only one tank. If there is more
than one tank, the dyke must contain 100% of the largest tank plus 10% of
the aggregate volume of all tanks. Special areas may require a greater
secondary containment volume and are site specific.
d) Any other system that provides the same level of protection as those listed
above.
• Verify that a leak detection system is used for underground storage tanks. Inspect
this system. This can include:
Audit Protocol:
Oil and gas products shall be stored and labelled properly. All storage, loading
facilities and operations shall have equipment and procedures in place to prevent
spillage or reduce impacts to the environment as a result of a spill.
Audit Guideline:
• Verify that engineering designs, operating procedures, tank storage and loading
facilities are designed to prevent or reduce accidental discharge.
• Verify that all storage areas have proper spill containment and spill recovery
systems such as berms, spill drains, spill recovery collection tanks and oil recovery
technology.
• Inspect the storage and loading area for good housekeeping and spill cleanup.
Identify and inspect all central and collection systems. Determine the effectiveness
of such systems.
Audit Protocol:
The handling, storage and use of chemicals in pipeline operations shall be done such
that impact to the environment is minimized. Hazardous materials shall also be
handled properly. Chemical and hazardous materials shall be stored and labelled
properly.
Audit Guideline:
• Record chemical type and volume for each storage location. Verify that chemicals
are segregated appropriately.
• Inspect storage areas. Verify that all chemicals and hazardous materials are stored
safely and labelled properly. To store the chemicals, the following
recommendations are suggested:
b) All tanks should be fitted with an external gauge to monitor content level.
The tank must be externally vented if located in a building.
f) When wall mounted drums (45 gallon) are used as bulk tanks, the refilling
process should be carried out using a barrel transfer pump. The barrel pump
construction should be suitable for use with the specific chemical. Barrel
pumps and both containers involved in the transfer should be grounded.
• Inspect chemical metering pumps. These pumps are essential to control chemical
usage. The following recommendations are suggested:
b) All chemical lines should be colour coded and/or labelled at both ends.
• Verify use of Material Safety Data Sheets. Safety data sheets on each chemical
should be displayed where the chemicals are used. First aid kits should also be
available at all locations where chemicals are handled.
Audit Protocol:
All hydrocarbon release points shall be piped into a vapour recovery unit.
Audit Guideline:
• Verify from engineering drawings the utilization and placement of vapour recovery
units.
• Verify through inspection and record reviews that vapours are incinerated.
Audit Protocol:
Audit Guideline:
• Inspect access roads to detect any drainage problems. All access roads should be
maintained to allow proper drainage and to prevent erosion. This includes clean-
out ditches, culverts and erosion control structures.
• Inspect access roads near high sensitive areas. Fences or post signing should be
used to limit the use of access roads in sensitive areas.
• Inspect access roads for proper construction of ditches to control runoff water.
• Verify that movements of ground vehicles are strictly limited to designated access
roads, ancillary sites (compressor stations, construction camps, equipment yards,
etc.) and right-of-way boundaries.
• Verify that regularly used roads are bored to minimize disturbance to local users.
Verify that signs are posted to warn road users of the construction.
Audit Protocol:
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates to keep people and
wildlife away from the right-of-way. Verify that access control is in place for
environmentally sensitive areas.
• Check the success of access control and determine if further control methods are
required.
Audit Protocol:
Berms shall be used to contain surface runoff from tank storage and pipeline operation
facilities in order to minimize/eliminate a pollution release from going off-site to
contaminate the adjacent environment.
Audit Guideline:
• Verify that berm containment system has a surface water collection disposal
process. Verify that such a system is monitored to allow for water runoff but is
operated in a closed capacity to hold containments
• Verify that berms are inspected and maintained. There should not be any breaches
in the berms. If a release has occurred, the berms should be cleaned and repaired
as needed.
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction,
pipeline construction or placement of a bridge or culvert for continual crossing use.
Measures shall be taken to reduce the impact of pipelines activities on water quality.
Water damage to improper bridges can result in environmental/safety hazard.
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding stream crossings.
• Inspect stream crossings for signs of pollution and sediment problems. Sediments
entering streams are a major pollutant and have significant effects on the survival,
reproduction and growth of fish.
• Inspect that debris and material is pulled back at a crossing rather than pushed
through the stream. Logs and soil materials should not be placed into any waters.
• Inspect stream crossing to verify that the number of vehicular movements across a
stream is kept to a minimum. Existing bridges should be used whenever they are
available.
• Verify that pipeline crossings placed in streams are not buoyant or becoming
exposed due to channel migration and stream bank erosion.
Audit Protocol:
All sites shall be maintained properly and kept neat, clean and safe. Housekeeping
refers to the general maintenance of a site with respect to acceptable operating
practices, upkeep maintenance and overall orderliness of the grounds, buildings and
equipment.
Audit Guideline:
• Inspect site to verify that site is kept neat, tidy and free from litter. Trash should be
continuously collected and disposed of at an approved facility. (See Waste
Management section).
• Verify that all chemicals are properly labelled, stored, handled and disposed of.
(See Product Storage and Loading section)
• Verify that waste disposal is carried out such that it does not attract wildlife.
• Verify that clearly legible signs are posted as needed and maintained. Fences and
gates should be constructed as needed and maintained in working order.
Audit Protocol:
The operation of flare stacks shall be done to minimize impact to the environment.
Audit Guideline:
• Inspect the location of flare stacks. They should be located away from trees, but
downwind of buildings and oil storage tanks. Verify that special restrictions in
forested areas are followed.
• Inspect stacks and adjacent land to see if liquids have sprayed off the stack.
Inspect flare stack operations. The separated liquids should not be discharged to a
flare stack and burned. Free liquids can escape up the flare stack to pollute the
land.
• Verify and inspect associated liquid removal vessels within the flare stack system.
Determine if an overflow shut down system is in place and if this system is working.
• Verify that stack height and distance form facility meets regulations.
Audit Protocol:
Audit Guideline:
• Verify that there is a Spill Contingency Plan and/or an Emergency Response Plan
that clearly outline measures to be taken during a release of produced water. (See
Spill Prevention and Emergency Response section). A produced water release
should be responded to in the following manner:
a) Identify and control the source of the release; make repairs when safe to do
so.
c) Contain the released produced water using bell holes, soil berms or
interception trenches as necessary.
f) The area of the spill should be flushed with a calcium amendment prior to
the application of any fresh water, recovering the excess fluid.
• Verify that any produced water release has been properly documented and
decontaminated.
Audit Protocol:
Audit Guideline:
• Verify that there is a Spill Contingency Plan and Emergency Response Plan that
clearly outline measures to be taken during a release of hydrocarbons. (see Spill
Prevention and Emergency Response section). A hydrocarbon release should be
responded to in the following manner:
a) Identify and control the source of the release; make repairs when safe to do
so.
f) Using water and surfactant, flush contaminated soil in order to free and
recover additional hydrocarbons.
• Check for signs of spills onsite. Record location and size of any spills. Provide a
sketch of the spill area if possible. Indicate the type of spills observed (type of
contaminant, soil contamination, water contamination, etc.)
Audit Protocol:
Audit Guideline:
• Verify that operations and maintenance personnel have guidelines to the proper
storage and disposal of waste materials as a result of site maintenance.
• Verify and inspect that hazardous materials utilized during maintenance operations
are properly handled and that hazardous waste material is properly recorded, stored
and disposed of (see Waste Management section).
• Verify that surface and underground storage tanks are monitored for leaks or
overflows (see Product Storage section).
• Verify that fences are in good conditions and gates are locked.
Audit Protocol:
Audit Guideline:
• If houses are adjacent to the facility, verify that discussions regarding the potential
impacts of noise were held with nearby residents during the design phase of the
facility. Verify that adjustments were made to meet the concerns and needs of the
residents. Adequate public notification and discussion can prevent noise
complaints before the operation starts. An ambient sound survey to measure
existing sound levels may be needed to assist the design.
• Make note of any public complaints (if any), response provided, and, if the noise
level is higher than acceptable limits, verify that measures have been taken to meet
or better the acceptable limits. If complaints have been received, verify that noise
monitoring of the site is being done.
• Verify that any noise issues at marine terminals are dealt with appropriately. The
offloading operations can involve the generation of noise on a continuous basis for
12 hours or more.
Audit Protocol:
The facility shall have proper drainage systems. Changes in natural conditions should
be minimized to prevent altering natural drainage patterns. Any normal interference
with the normal drainage of water from land, where such interference has been caused
by the operation, shall be removed or remedied as soon as possible. Proper erosion
control measures should be taken.
Audit Guideline:
• Inspect site for internal drainage control to contain potential pollutants on the site.
• Inspect any contaminated areas and verify that surface drainage in those areas is
segregated from other areas of surface runoff. The contained fluids should be
stored for treatment and/or evaporation.
• Inspect bermed storage areas. Drainage from those areas should be contained to
prevent leakage of a spilled product from entering into the drainage discharge.
• Inspect site for any signs of disturbance to drainage patterns. The consequences of
inadequate drainage are extensive and include ponding, flooding, washouts and
inundation of vegetation.
• Culverts and drainage ditches must be constructed as needed around the plant site
to prevent contamination of surface waters and groundwater.
• Verify through interviews that work crews have been instructed not to place any
materials in drainages.
• Verify that all proper erosion control measures are being used.
• Inspect the site and check for signs of erosion problems, sedimentation of streams
or reduction in watershed capacity caused by the removal of trees, shrubs and
other vegetation, disturbance of land surface, or any other cause resulting from the
operations. Verify if any methods are used for erosion control of exposed soils.
Water spraying and/or soil tackifier is sometimes needed to minimize soil loss due
to wind erosion. If dust is a problem near residences, the site should be sprayed
with freshwater. In general, methods of erosion control can include diversion
berms, rip rap, matting, fibres, etc.
• Inspect access routes and vehicle use to verify that damage to the soil is being
prevented. Look for ruts from large tires or tracked equipment.
Audit Protocol:
Surface water shall be monitored after spills, after controlled acceptable releases and
as required to monitor water quality near operating sites. Existing local regulations
should be followed. A certified laboratory shall perform the analysis.
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
surface water monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including surface water monitoring
reports and verify compliance.
• Indicate if the facility has a surface water sampling monitoring program. Surface
water sampling and monitoring are site specific.
• Inspect surface water control and release structures. Identify if these structures are
shut to prevent accidental release runoff water.
Audit Protocol:
Soil sampling and monitoring require proper sampling protocols and a certified
laboratory to perform the analysis. Record keeping is essential, particularly of
sampling locations (to ensure the same locations are sampled during a monitoring
program).
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
soil sampling and monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including soil sampling and monitoring
reports and verify compliance.
• Indicate if the facility has a soil sampling monitoring program. Soil sampling and
monitoring are site specific activities in order to assess soil quality. These activities
may be completed to track the progress of a decontamination program, to
determine the extent of a spill and develop remediation programs. Soil monitoring
may be undertaken at any time of a facility’s life, from pre-disturbance, during
operations or during reclamation.
Audit Protocol:
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
groundwater monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including water quality reports and verify
compliance.
• Indicate if the facility has any groundwater monitoring systems. Inspect monitoring
well sites and locations. Groundwater monitoring is a site specific issue. Wells
should be installed hydraulically up gradient and down gradient of a potential
contaminant. These wells will be used to determine the depth and direction of
groundwater flow. Monitoring wells must be set in an area that will not interfere
with everyday operations, however, they must be set in order to collect the proper
information.
• Verify that monitoring wells are equipped with a lock in order to prevent
unauthorized entry.
• Verify that only trained personnel or consultants sample the monitoring wells.
Groundwater monitoring is site specific; however, for predisturbance assessments,
it is recommended that the following components be sampled: pH, electrical
conductivity, major ions, total metals and dissolved organic carbon.
Audit Protocol:
The discharge of water to the environment shall be minimized. A water release may
occur by opening a berm drain, by overflowing a berm, or by pumping water to the
surrounding land.
Audit Guideline:
• Verify that any water released to the environment meets existing regulations. When
discharging water, a field analysis must be done. Field determination may be done
using an appropriate pH meter and Quan Tabs for the chloride determination. Any
visible hydrocarbon sheen requires that the fluid be disposed of via an appropriate
oil field waste disposal facility. The following criteria are recommended:
If the discharged water does not meet the above criteria, the fluid must be disposed
of at an approved oilfield waste disposal facility or treated and then discharged on
or off lease with the approval of existing regulatory agencies and the landowner
(private land) or public land manager (public lands).
• Verify that any water discharged is not allowed to flow directly into rivers, creeks or
any other permanent body of water.
• Verify that a proper documentation and reporting procedure exists for water
discharges to the environment. Records must include the parameters listed above
as well as an estimation of the volumes of water disposed.
Audit Protocol:
Emissions from pipelines shall be controlled and minimized. This applies to all gas
pipelines and gas transmission lines (process marketable gas).
Audit Guideline:
• Verify that there is an Emergency Response Plan that clearly outlines measures to
be taken during a gas release. A gas release should be responded to in the
following manner:
Audit Protocol:
Air quality monitoring is required at some locations of the facility to comply with
existing regulations or when due to resident or landowner concerns. Long term
emissions can have an adverse impact on soil and water.
Audit Guideline:
• Prior to the field inspection, review records including air quality emission reports
and verify compliance.
• Verify that air quality monitoring systems are onsite as required (e.g. facilities
where sour gas is processed, etc.). Two types of air monitoring systems may be
undertaken: ambient monitoring and total sulphation/H2S.
• Inspect air quality monitoring equipment. Air quality sampling is done with many
different pieces of equipment including mobile trailers, stationary trailers and
“birdhouses”. Verify that sampling equipment is in working order and correctly
calibrated.
• Through interviews, verify that operators are familiar with the station so that if there
is an upset, they can fix/modify it and it is not down for an extended period of time.
Operators must be familiar with sampling procedures and sampling locations.
• At sour locations, verify that stack surveys are completed, if existing regulations
require them.
Audit Protocol:
Audit Guideline:
• Inspect fuel storage areas and equipment. Fuel tanks are preferable to bladders,
and welded steel tanks are preferable to bolted ones. Inspect tank dykes and verify
that they are of adequate size to contain any spills and have impermeable sides
and bases.
• Verify that fuel storage areas are clearly marked to ensure that they are not
damaged by moving vehicles. The markers should be visible under adverse
weather conditions. Check that “No Smoking” signs are posted and followed.
• Through interviews, verify that all personnel are familiar with fuel handling
procedures.
• Verify if fuel transfer operations are performed in a manner that prevents spills.
Review records to verify if there is any reporting process in place to record
occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgable of such process.
• Transfer operations at marine terminals can result in large spills and loading
efficiency can be affected by oceanographic and meteorological conditions. Verify
that operations are supported by reliable weather forecasting services that can be
used to plan loading/unloading operations at ship terminals. Verify that personnel
are trained to operate properly under unfavorable conditions where tankers may not
be able to connect to the loading system or may have to disconnect to ride out a
storm.
• Verify that tankers have segregated ballast systems that eliminate the problems
associated with the transfer and treatment of oily ballast water.
• If vessels do not have segregated ballast, as the tanker takes on oil, the ballast
must be offloaded (dumping dirty ballast at sea is illegal by international convention
MARPOL). The ballast water must be treated and disposed. Determine how the
ballast water was treated.
Audit Protocol:
Audit Guideline:
• Verify that ships transferring oil to terminals have a contingency plan that
guarantees an effective response. The plan must be developed with the specific
configuration /size of the terminal, local weather, currents and environmental
sensitivities in mind. The regulators (in many cases involving marine officials for
the Navy/Coast Guard) should be involved in the contingency plan, as should the
P&I Clubs/ITOPF (Protection and Indemnity/International Tanker Owners Pollution
Federation). Generally, if the spill takes place from the vessel before it has
connected to the terminal systems or after if leaves, it is the vessel responsibility to
deal with the spill.
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite. Determine locations, types and quantities of
spill control materials available onsite. These may include: sorbent materials, oil
retention booms, skimmers, sand bags or temporary curbing devices, recovery
pumps and collection hoses, recovery tank trucks and protective equipment.
During the construction of pipelines, all fuel and service vehicles should carry a
minimum of 10kg of suitable commercial sorbent material for use on small fuel or
oil spills. Mobile construction equipment should not be serviced or refuelled within
100m of watercourses to prevent water pollution.
• Verify that release drills are held. Release drills should be held at least once a
year. All operating personnel should be required to attend. The sites chosen for
the drill should include topography which is representative of the conditions most
likely to be faced in the event of a release.
• Review any past incident reports. If there have been any releases in the past, a
review should be undertaken to review the causes of the release and to provide
recommendations as to how such a release can be avoided in the future. The
review should include an assessment of the contingency plan and the response as
well, assessing whether there should be any improvements made to the plan or the
training provided.
Audit Protocol:
Audit Guideline:
• If the facility is located near residential areas, verify that discussions with local
residents were held when preparing the Emergency Response Plan.
• Interview personnel to verify the level of knowledge of such plan. All employees
should be familiar with the Emergency Response Plan for their work area. They
should also be familiar with the location of emergency equipment and have
participated in mock exercises, held at least once a year.
a) Regulatory Information
b) Scope of the Emergency Plan
c) Local public involvement
d) Contents of the Emergency Procedure Plan:
• Verify through inspection that all material and equipment specified in the
Emergency Response Plan is available onsite.
Audit Protocol:
Pipeline, transportation and marine terminal facilities shall have a Waste Management
Plan to ensure each facility knows what wastes it produces and how to handle and
dispose of those wastes properly.
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility. Review the plan
and see if the wastes the facility produces match the wastes discussed in the plan.
Review the waste disposal methods recommended in the plan and verify if they are
being followed. Review the training schedules for waste management; when
talking to the operators, determine how well the management plan is taught/how
familiar they are with the plan/how practical it is. Verify that a waste manifest
procedure is in place and is being used properly. Review trucking routes for waste
disposal.
• Inspect all waste handling containers and verify the waste has been sorted and
allocated to the correct container. Verify that the container is the correct type for
the waste.
Audit Protocol:
All waste material shall be properly identified and handled according to hazardous and
nonhazardous waste handling regulatory requirements. General solid wastes
generated by operations shall be disposed of in an acceptable manner to prevent
pollution to the environment.
Audit Guideline:
• Verify prior to the field inspection, the required regulatory procedures to properly
dispose of all types of solid wastes generated.
• Verify that all sites and rights-of-way are kept free of trash and litter. All trash, litter
and garbage must be placed in metal or plastic containers and disposed of
properly.
During construction of pipelines, verify that receptacles are provided for proper disposal
of welding rods. Whenever land is cleared by a linear development, debris disposal
is a major concern. Debris disposal is the total or partial disposal of all unsaleable
timber, brush, roots and other debris on the right-of-way. It is done to reduce fire
hazards and improve aesthetics. A common disposal method is Rollback of debris.
Rollback is the practice of spreading debris from clearing back over the line after
the completion of the construction program. It is restricted to debris less than 15
cm in diameter, and the debris should be compacted. Whenever a linear
disturbance crosses a road, total disposal should be completed for a distance of 90
m from either side of the road’s centre line. The most common method of total
disposal is burning, with the residue hauled down the line and spread out of sight in
the residual trees. Burial of burned debris is discouraged.
• Inspect site area for disposal methods of general solid wastes. Such wastes
include rags, waste paper, paper cartons, scrap metal, plastic wastes and rubber
wastes. Industrial landfilling and incineration are the most commonly used
methods for disposal of solid wastes. Incineration is followed by burial of the
incinerated residue. Combustible wastes should be incinerated daily. Materials
suitable for recycling should be stored separately and recycled accordingly. During
construction, waste materials such as pipe coating, spent welding rods, containers,
cans, lunch wrappings, used engine oil and other garbage arising from normal
pipeline activities should be collected daily by each crew and disposed of in an
approved manner.
• Inspect garbage disposal sites. Garbage disposal sites should be used for small,
non-toxic, non-perishable refuse and incinerator residues. Holes or pits should be
located above the expected high water level. A minimum distance from the bank of
a water body of 45 m is required. Consider and evaluate the potential of wildlife
intrusions to the garbage disposal sites or attraction to the location. Verify that pits
are lined.
• Verify that fuel barrels or other containers are not left on the site or along the rights-
of-way.
• Verify that the incinerator(s) is inspected and tested at least yearly to ensure
optimum efficiency.
• At marine terminals, verify that wastes are not dumped into the ocean.
Audit Protocol:
Audit Guideline:
• Indicate if there is any specific code of practice for worksites where asbestos
containing materials and man-made vitreous fibres are present.
• Verify that standard work procedures are in place for working with asbestos
containing materials and man-made vitreous fibres. These measures may include
refraining from smoking, eating or drinking while working with insulation products,
showering, not taking clothes contaminated with fibrous insulation out of specific
areas, following special cleaning procedures for work clothes, wearing the required
safety clothing, posting appropriate signage and using appropriate handling
methods.
• Verify that asbestos containing materials are held in restricted zones or transported
immediately to its final disposal site.
Audit Protocol:
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
sewage disposal facilities have been identified and provided as guidelines for
implementation in the field.
• If there are any subsurface disposal facilities (septic tanks, leach pits), inspect
distances from any sources of water supply and natural water bodies. Verify that
pump-out and hauling operations are carried out in a manner that does not expose
the driver or people in the area where the tanks are emptied to any health hazard.
Every effort should be taken to avoid any spillage when holding tanks are emptied
or when the truck contents are discharged into the treatment facility.
• Verify that the flow through the effluent treatment system is carefully controlled.
Overloading the system hydraulically reduces the effectiveness of pollutant removal.
Also, a sudden shock will upset the biological balance and performance will drop.
The shock can be either an increase in pollutants or an influx of unusual pollutants.
Audit Protocol:
If sewage lagoons are used, they shall be designed properly to ensure that effluents do
not contaminate ground or surface water or soil and do not present a health hazard.
Audit Guideline:
• Inspect sewage lagoons onsite used to treat sewage/effluent. The following criteria
are recommended:
• Verify that lagoon is properly built, effluent is not released before full retention time
and there are no leaks.
WASTE MANAGEMENT
Audit Protocol:
Pipelines, transportation and marine terminal facilities shall have an effective approach
to waste management. Recycling is a key component to conserving resources and
reducing wastes. Recycling assists by either reducing or eliminating the quantity of
waste which requires disposal, thereby reducing potential contamination to the
environment. The Waste Management Plan should contain recycling information.
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility where recycling is
implemented.
Audit Protocol:
All water usage shall be assessed for the potential of recycling or reuse. Water usage
shall be minimized by employing the basic principles of water conservation through
reduction of the volume of water used, effective recycling, and maximizing reuse.
Emphasis should be placed on concentrating waste materials in limited volumes of
water.
Audit Guideline:
• Verify if there is an appropriate recycling and reuse system in place for waste
water. This system may include assessment of potential recycling and reuse
methods upon waste identification, determination of preferred methods of recycling
water and identification of alternatives. Waters identified for recycling should be
properly stored and clearly identified.
Audit Protocol:
The disposal of oil based waste materials shall be done in an acceptable manner.
These materials include waste oil sludge, treater hay and oil spill debris.
Audit Guideline:
• Verify that waste oil sludge is disposed of properly. Oily waste may originate from:
a) Tank bottoms and treater sludge from conventional production.
b) Sand and waste oils from heavy oil production.
c) Pigging wax from line cleaning.
d) Solvents.
e) Lube oil.
• Inspect site for the provision of tanks at all facilities to ensure temporary storage for
waste oils until they can be properly and safely disposed. Disposal bins equipped
with steam tracing lines may be used to temporarily store pigging wax. The bin can
be transported to a reclaiming facility where it is steamed prior to dumping the
residue into a reclamation tank.
Acceptable disposal options (not a permanent solution but generally safe) are:
a) Application on Roads: tank bottoms, treater sludge and waste oil from heavy
oil operations may be applied to roads, subject to approval of appropriate
authorities.
b) Incineration: waste oils can be disposed of by incineration. However, poor
combustion may cause objectionable smoke or odours.
• Verify that treater hay is disposed of properly. Treater hay results from conventional
treaters that use a filtering medium to enhance impurity removal. The filter material
is called treater hay.
The following disposal methods are acceptable if the preferred options are not
available:
a) The hay may be disposed of into flare pits and burned in conjunction with
periodic flaring (subject to regulatory approval). If the hay is adequately
cleaned prior to burning, it may not create smoke problems when burning.
b) Transport in sealed containers to nearby reclaimers equipped with cleaning
facilities and incinerators.
• Verify that oil spill debris is disposed of properly. In the past, most spills were
controlled on site and burned as quickly as possible. However, due to the emission
of unsightly black smoke and the hazard of ash and carbon fallout, regulatory
bodies are often reluctant to give permission to burn unless there are no other
options. The hazards of forest and/or ground fires must also be considered prior to
burning. The heat generated by burning will destroy underground roots and soil
microbiology, making the re-establishment of vegetation much more difficult.
The preferred reclamation option is: After as much oil as possible has been picked
up, the preferred reclamation procedure is to help the residual oil to degrade by
natural microbial action. This can often be enhanced by using fertilizers and
agricultural practice. See Reclamation/Remediation.
Audit Protocol:
Filters shall be disposed of and changed in an acceptable manner. There are many
types of filters used in the petroleum industry. They include glycol filters, lube oil filters,
domestic water filters, amine and sulfinol filters, etc. Eventually these filters become
clogged and must be replaced. Since filter media will be saturated with the material
being filtered, care must be taken when disposing of them.
Audit Guideline:
Immediately after use, filters should be stored in a container equipped with screens
to permit fluids to drain. Filters should always be drained prior to disposal and the
entrained liquids can be disposed of at approved disposal wells (see section on
Injection and Disposal Wells). To properly drain a filter, it must be stored in the
screened container for a minimum of three days at room temperature. Entrained
fluids must be kept segregated for recycling or disposal. It must be determined
through sampling if the filter is a dangerous oilfield waste. Examples of filters that
may be a dangerous oilfield waste are: glycol filters, leachate and entrained liquids,
air pollution control filters, sulphinol filters, lub oil filters, methanol filters, gas filters
and produced or process water filters.
If a screened on-site container is not available for drainage, a barrel with a fitted
screen may be used. The filters should be enclosed in separate plastic bags,
sealed in a drum and buried at an industrial landfill site.
Audit Protocol:
A Reclamation Plan shall be used for returning the land to its former land use
capability.
Audit Guideline:
The reclamation plan will take into account whether it is part of a live site which is
being reclaimed or whether the entire site is being abandoned. This can
significantly alter the procedures used.
The plan should identify all capital salvage items, outline the salvage program,
identify disposal options for items which cannot be reused, identify any
contamination issues and how they are to be dealt with and specify the steps for
the restoration of the site (or the portion being restored).
The plan is based on the Site Assessment (Phase I, Phase II if necessary). The
data from the assessment is then evaluated and the necessary procedures are
specified in order of priority. The plan should include a cost estimate, inventory
control, service contracts, equipment and material handling procedures,
environmental protection measures, safety measures, schedule and priorities and
cost control.
- site dismantling
- closure of flare pits
- removal of tanks
- decontamination
- soil remediation
- recontouring
- revegetation
- assessment of reclamation success
Audit Protocol:
The physical removal of all buildings, facilities, structures and improvements - above
and below ground - shall be done in an acceptable manner.
Audit Guideline:
• Inspect sites being decommissioned or reclaimed. Verify that all equipment and
structures are removed appropriately. Some items, including access roads, gates
or pads, may be left on site if the landowner and regulators are in agreement or if
the landowner agrees and it does not interfere with the reclamation of the site.
• After the construction of pipeline, verify that watercourse crossing structures and
survey stakes are removed, fences and gates are repaired or replaced, topsoil is
prepared for seeding and the right-of-way is reseeded. Verify that all timber and
debris not disposed of has been salvaged or removed. All buildings, trailers,
machinery, equipment, materials, litter and storage containers must be removed
from the area. Temporary access roads must be removed. Abandoned equipment
should either be hauled out of the area or buried in a landfill site.
• Verify that all liquids and sludges from vessels/tanks/lines are removed for
disposal.
• Check for asbestos insulation. It is not possible to visually discern this, a lab test is
required. Asbestos containing materials must be removed by especially trained
crews and double bagged for disposal. See Asbestos
• Verify that after all liquid has been removed from the vessels, distribution lines and
tanks, and that all equipment from the site is removed. Ensure any residual fluids
which remain are collected for disposal.
• Verify that cement pads and other inert materials are broken up and are buried on
site with a minimum cover of 1 m of compacted fill or it can be hauled out. Power
lines, power poles, gas lines, telephone lines, and equipment require removal by a
utility company.
• Verify that gravel is salvaged as much as possible for use elsewhere. Gravel
should not be removed until all heavy traffic is finished in order to prevent
reclamation problems.
Audit Protocol:
When sites are being decommissioned or abandoned, the removal of underground and
aboveground storage tanks shall be done with minimum impact to the environment.
Audit Guideline:
• Verify that tanks are removed properly. The following procedure is recommended:
All residual liquid must be removed from the tank. A bull plug must be placed in all
tanks openings.
All piping must be exposed and disconnected. All fluid must be removed from the
tank prior to the start of any excavation. Tanks should be purged or inerted prior to
the start of excavation. Purge means to remove the explosive vapours and inert
means to remove the oxygen from the tank.
• Verify that any contamination resulting from the removal of the tanks has been
assessed by a qualified environmental consultant. Soil samples should be
collected.
Audit Protocol:
Audit Guideline:
a) If the roads have been temporarily abandoned, the following are required:
- Cuts and fills must be recontoured to natural conditions where slope and
materials make this practical.
- Erosion control measures such as diversion berms and cross-ditches must
be installed as required.
- Rollback windrowed debris for erosion control to provide microsites for
vegetation.
- All watercourse crossings must be removed and creek banks stabilized if
necessary.
- Disturbed areas must be revegetated using a suitable seed mix.
Audit Protocol:
Audit Guideline:
This type of approach has the following advantages: decisions are made based on
reducing the risk of adverse human or environmental impacts to acceptable levels; it
offers a rational and consistent process for selecting appropriate remediation criteria
and options; it allows limited resources to focus on remediating the sites with the
greatest risk; it assures that both the approach taken to remediation and the extent of
remediation is the most cost-effective; and, it assures that environmental audit
activities are directed towards collecting only the information necessary to make
informed decisions.
Audit Protocol:
All sites being reclaimed shall have any contaminated soil removed or remediated
before recontouring and revegetation.
Audit Guideline:
• Verify that all sites contaminated by spills and other chemical disturbances have
been decontaminated. Inspect site being decontaminated. The site may require
restricted access, such as fencing to protect people and animals.
Audit Protocol:
Reconstructed soils should be able to produce to the former land capability. Soil shall
be returned to similar conditions as preconstruction/operations. The soil layers on site
should be within 50% of their predisturbance depths (topsoil and subsoil). The topsoil
must be in the same texture class as adjacent land. Approximately 20% of the site
may drop one soil quality class.
Audit Guideline:
• Verify that at least four control sites were examined to a depth of 50 cm in order to
identify what soil conditions should be for the site.
• Determine if soil amendments were used or are needed in order to return the soil to
predisturbance conditions. Verify that the amendments recommended were based
on laboratory analysis of the soil on site. Verify what amendments were used
(manure, straw, tree bark mulch, peat, artificial fertilizer) and determine if they were
consistent with both the predisturbance soil conditions and the laboratory analysis.
• Verify that the soil after remediation is the same texture class, same pH, same
aggregate size and strength, same quantity of gravel and rocks and same organic
matter content as the control sites.
• Ensure that the site has been decompacted and that the soil process restriction
parameters are nonrestrictive as compared to the control. Process restriction
parameters are water permeability, vertical root elongation and soil aeration. No
soil layer should have greater density than before.
• Verify that surface soils have been salvaged and replaced on site.
Audit Protocol:
All sites being decommissioned, reclaimed or portions of “live” sites not required for
operations, shall be restored to a capability equal or better than the surrounding current
land use. This includes restoring the original drainage patterns and ensuring that the
site does not hold water.
Audit Guideline:
• Verify that culvert and creek crossings are removed and banks are recontoured
back to original contour (stabilized log cribbing may sometimes be left).
• Verify that creation of steep slopes is minimized (<3H:1V on clay soils, <5H:1V on
silt soils).
• Verify that runoff is spread over a large area to minimize runoff water velocities.
Water should be drained in a sheet instead of channels on slight to moderate
slopes.
• Verify that berms and diversion ditches are used to move water into vegetated
areas on steep slopes to reduce erosion. Angle across face of slop should be < 30
degrees. There should be no more erosion gullies than on adjacent land.
• Verify that soil is replaced according to the soil profile - horizons A and B should not
be mixed. Subsoil should be replaced with proper compaction.
• Look for ponding, silt deposition and gully erosion. Altered drainage must not
adversely impact adjacent properties.
• Verify that all surface soils are salvaged and replaced onsite.
• Verify that erosion control measures are used as required including berms,
crimping, mulching, manuring, netting and bale placement.
• Verify any rocks were buried more than 150 cm below grade.
• Ensure microsites are created for enhancing growth of vegetation - site should not
be smooth.
• Inspect sumps and pits locations for signs of settlement. Sumps and pits which are
backfilled will settle - mound 50-100 cm to compensate.
Audit Protocol:
All sites being decommissioned or reclaimed and all disturbed areas at “live locations”
shall be revegetated to prevent erosion, soil degradation and return site to its former
land use.
Audit Guideline:
• Inspect site to verify that proper revegetation procedures have been implemented.
Disturbed areas should be revegetated with grasses, shrubs and trees native to the
area. Inspect that species selected are consistent with the planned use of the area
(commercial forest, recreation area, grazing or wildlife habitat, etc.)
• Verify that the seed mixture is fast growing, self-sustaining and that it requires little
or no maintenance.
• Verify the density of growth: overly dense or too little plant growth will require further
work. Determine the method of seeding, time of year of seeding and seeding rates
and compare with the success of the revegetation on site.
• Verify if fertilizers were used and if so what kind. Determine if the quantity and type
is appropriate for the site and climate.
• Verify that the recontouring was appropriate for the vegetation growth (see
Recontouring) i.e., decompaction, microsites, no erosion or ponding.
• Verify fences have been used where necessary to protect new growth.
• If the site has had time for revegetation growth, inspect and record the success
achieved after revegetation and if more work is required.
Audit Protocol:
Audit Guideline:
• Verify that all equipment was properly removed and that the site has been
completely dismantled.
• Verify that access roads, borrow pits,etc., have all been removed.
• Verify that all decontamination procedures were performed properly and that the
site is decontaminated (soil and water).
• Verify that the soil profiles on site are within acceptable limits to matching the soil
profiles of the off-site controls.
• Verify that the vegetation is, after at least one full growing season, growing well,
with appropriate plant density, cover, plant type and height. Also verify that the
species composition is appropriate for the site and that the vegetation is healthy.
Any bare areas or noxious weeds should be noted.
• Verify that the drainage patterns, contours and slope are appropriate, that there is
no debris on site, that the landscape is stable and that surface rocks match
adjacent land.
Verify that after operations are completed, the site is restored, as far as practical, to a
condition compatible with existing land use, and that the land capability is equal to or
better than predisturbance conditions.
12.5 Refineries
- Processing
6.0 Processing
7.0 Filter Vessels and Treaters
8.0 Sulphur Recovery
9.0 Cathodic Protection
Waste Management
In general, the following ARPEL documents can be used as guides in the conduct of
audits of petroleum refineries:
Guidelines for the Reduction and Control of Gaseous Emissions from Petroleum
Refineries;
Guidelines for the Management of Petroleum Refinery liquid Wastes;
Guidelines for the Management of Petroleum Refinery Solid Wastes; and,
Guidelines for Decommissioning and Surface Land Reclamation at Petroleum
Production and Refining Facilities.
REFINERIES
ENVIRONMENTAL PLANNING AND ADMINISTRATION
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained for the planning,
design, construction and operation of any refining facility. Special conditions and
restrictions shall be reviewed and enforced.
Audit Guideline:
• Review the project records to ensure that all required permits, licenses and
regulatory authorizations were obtained for refining facilities and make sure that all
information in writing is available on site. Record permit/license numbers and verify
this information is in the field.
• Verify through interviews that facility operators are aware of any restrictions and
environmental concerns for the operation of the facility.
REFINERIES
ENVIRONMENTAL PLANNING AND ADMINISTRATION
Audit Protocol:
All facilities operating personnel shall be trained and aware of the environmental
impacts of their operations. They should understand the necessity for environmental
planning and protection measures.
Audit Guideline:
• Verify that all personnel have taken environmental training in their field of
operations and are clear on how to implement and use their training correctly. This
should include, but not be limited to, emergency response/spill containment
training, waste management, current regulatory requirements and best operating
procedures.
• Verify if there is a system in place for all personnel to update their training yearly as
required.
• Inspect the facility technical reference library to identify that environmental training
manuals and reference programs are available.
• Verify through consultation with senior personnel that funds are made available
annually for environmental training.
REFINERIES
ENVIRONMENTAL PLANNING AND ADMINISTRATION
Audit Protocol:
The engineering design and site planning of any refining facilities shall be undertaken
in a manner that will anticipate potential environmental problems and provide the
design and operating procedures to minimize the impacts of the operations on the
environment.
Audit Guideline:
• Verify that environmental concerns were considered during the selection of the
facility site. For example:
a) The site should be selected so spills can be easily contained and cleanup
vehicles can have ready access. This guideline also applies for staging
areas, fuel dumps and storage areas. The site selection process should also
minimize impact to natural runoff patterns and should prevent soil erosion
and surface water contamination.
e) Present and future land use restrictions (i.e., airports, proximity to dwellings,
etc.) should be considered prior to making a final site decision.
REFINERIES
PRELIMINARY AUDIT ACTIVITIES
Audit Protocol:
Prior to the field inspection, the auditor shall be become familiar with the process and
installation drawings of the refinery facility.
Audit Guideline:
• Prior to the field inspection, review process and installation drawings to become
familiar with the specific refinery facility. Make sure that historical as well as
current drawings are studied.
REFINERIES
GENERAL SITE INFORMATION
Audit Protocol:
At the start of the audit all general information on site list shall be verified. Site
information should correspond to all engineering and design drawings and plans. All
modifications or amendments to any facility should be found in all drawings and plans
showing the date of change. All modifications associated with environmental
protection should be recorded.
Audit Guideline:
• Record all equipment and its condition on site (i.e., pits, tanks, dikes, berms,
sheds, etc.).
• Record soil quality, erosion controls, condition of top soil stockpiled and adjacent
wild life habitats and species.
• Verify the nearness of surface water bodies and water wells to facilities.
• Undertake a general inspection of the site to verify engineering and design plans
are current. Record any changes in the facility which do not correspond to existing
plans or drawings.
REFINERIES
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
All processing equipment shall be designed, operated and maintained in a manner that
prevents pollution to the environment. Typical refinery activities produce fuel products,
lubricants, sulphur, heavy useable hydrocarbons and processing wastes. Processing
of crude oil generally commences with an oil distillation facility which separates oil into
gasoline, kerosene, fuel oils and reduced crude oil, and sometimes reformer charge
stock, jet fuel or gas oil. Desulphurization is a second facility process from oil
distillation which recovers sulphur. Vacuum distillation is a third typical process which
processes lubricants, waxes, greases, coke and asphalt.
Audit Guideline:
A typical approach to audit a refinery is to break refinery processes into the following
three basic processes:
a) Primary Distillation.
c) Secondary Distillation.
• For each of these units, undertake an audit based on unit operations, unit pollution
control design (air, water, soil), material balancing, liquid/solid recovery systems,
waste storage and reduction, waste disposal and emergency response procedures.
• For each vessel and processing structure, verify use of emergency shutdown
systems, maintenance of valves and presence of leaks.
REFINERIES
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Filter vessels and treaters, associated with the oil recovery mechanisms on surface
water retention ponds and open top separation tanks, shall be designed, operated and
maintained such that impact to the environment is minimized.
Audit Guideline:
• During the inspection, check for signs of spills. If there are any spills, record type
and location. Pressure relief valves, rupture disks or burst plates that are installed
on filter vessels or treaters must be connected by suitable piping to an open pop or
release tank. Other methods to prevent oil spills are acceptable if they provide
equivalent or better protection than the venting of relief devices to an open pop or
release tank.
• Verify that process area drains are not to ground and all drains go to either recovery
tanks or impermeable and/or lined retention pond for appropriate disposal. Verify
methods of monitoring these tanks for failure.
• Verify that wastes (filters, hay sections, sludge, scale, etc.) are properly transported
and disposed of.
REFINERIES
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Audit Guideline:
• Prior to the field inspection, review plant licenses for emission rates. Determine if
rates are exceeded.
• Verify that the required number of stack surveys are completed each year.
• Verify if any soil/air monitoring is completed (see Soil Monitoring and Air Quality
Monitoring).
• Verify that sulphur is transported safely and dust control measures are in place.
• Inspect sulphur storage areas. Verify that proper storage procedures are followed
and identify if sulphur depositions are impacting on adjacent water quality or
vegetation.
REFINERIES
GENERAL OPERATING PROCEDURES
Processing
Audit Protocol:
Audit Guideline:
REFINERIES
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
Pipeline, truck and rail car bulk receipt of raw and produced products shall have
environmental control systems in place (such as emergency shut down systems,
gauges, lock out valves, etc.) to effectively store, handle and transfer product in an
environmentally safe manner. Loading and unloading procedures shall be performed
in a manner that prevents pollution to the environment. Tanks, trucks and trailers shall
be properly maintained. Operators should have proper training in transportation safety
and environmental protection.
Audit Guideline:
• Verify that facility personnel are in continuous attendance when trucks are loading
and unloading. If the unloading area does not flow into a catchment basin or into a
treatment facility designed to handle spills, a quick drainage system holding at least
the maximum capacity of one tank/tank car compartment should be used.
• Verify that interlock warning lights are used in loading and unloading areas to
prevent the departure of trucks before lines are disconnected.
• Inspect the loading areas to assess general housekeeping, control and cleanup of
leaks and assess transfer operations which are in progress.
REFINERIES
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
The operation of aboveground and underground tanks shall be carried out in a manner
which does not cause damage to the environment. Tank operations include all work
which is done in conjunction with tanks. Examples are gauging, disposing of tank
bottoms, loading and unloading of tanks and emergency containment.
Audit Guideline:
a) Except in special areas, the volume contained by the dike must contain a
volume 10% greater than the tank if there is only one tank. If there is more
than one tank, the dyke must contain 100% of the largest tank plus 10% of
the aggregate volume of all tanks. Special areas may require a greater
secondary containment volume and are site specific.
d) Any other system that provides the same level of protection as those listed
above.
• Verify that a leak detection system is used for underground storage tanks. Inspect
this system. This can include:
REFINERIES
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
Tanks and distribution lines shall be located such that they cannot be easily damaged
by moving equipment. Design techniques must be employed to prevent pressure
eruptions and reduce fire hazards.
Audit Guideline:
• Verify that procedures exist which ensure the proper marking and protection of
buried or surface pipelines such as site security and anti-corrosion programs.
• Ensure all lines are marked and maintained and that records are checked before
any excavations are started. Spill containment equipment should be on hand
before any excavations begin.
• Check for spills along right-of-way, erosion control, slash disposal and vegetation
control.
• Verify that the engineering design and operations of a pipeline utilizes emergency
valve shut-off and leak detection programs and procedures.
• Inspect pipeline systems for such items as placement of shut-off valves, marked
facilities, erosion control, vegetation management and spill cleanup.
REFINERIES
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
Oil and gas products shall be stored and labelled properly. All storage and loading
facilities and operations shall have equipment and procedures in place to prevent
spillage or reduce impacts to the environment as a result of a spill.
Audit Guideline:
• Verify the engineering designs and operating procedures, provide tank storage
integrity and that all loading facilities are designed to prevent or reduce accidental
discharge.
• Verify that all storage areas have proper spill containment and spill recovery
systems such as berms, spill drains, spill recovery collection tanks and oil recovery
technology.
• Inspect the storage and loading area for good housekeeping and spill cleanup.
Identify and inspect all central and collection systems. Determine the effectiveness
of such systems.
REFINERIES
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
All hydrocarbon release points shall be piped into a vapour recovery unit.
Audit Guideline:
• Verify from engineering drawings the utilization and placement of vapour recovery
units.
• Verify through inspection and record reviews that vapours are incinerated.
REFINERIES
GENERAL OPERATING PROCEDURES
Product Storage and Loading
Audit Protocol:
The handling, storage and use of chemicals in refining operations shall be done such
that impact to the environment is minimized. Hazardous materials shall also be
handled properly. Chemical and hazardous materials shall be stored and labelled
properly.
Audit Guideline:
• Record chemical type and volume for each storage location. Verify that chemicals
are segregated appropriately.
• Inspect storage areas. Verify that all chemicals and hazardous materials are stored
safely and labelled properly. To store the chemicals, the following
recommendations are suggested:
b) All tanks should be fitted with an external gauge to monitor content level.
The tank must be externally vented if located in a building.
f) When wall mounted drums (45 gallon) are used as bulk tanks, the refilling
process should be carried out using a barrel transfer pump. The barrel pump
construction should be suitable for use with the specific chemical. Barrel
pumps and both containers involved in the transfer should be grounded.
• Verify use of Material Safety Data Sheets. Safety data sheets on each chemical
should be displayed where the chemicals are used. First aid kits should also be
available at all locations where chemicals are handled.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Verify that operations and maintenance personnel have guidelines to the proper
storage and disposal of waste materials as a result of site maintenance.
• Verify and inspect that hazardous materials utilized during maintenance operations
are properly handled and that hazardous waste material is properly recorded, stored
and disposed of.
• Verify that surface and underground storage tanks are monitored for leaks or
overflows.
• Verify that fences are in good conditions and gates are locked.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
New construction:
Audit Guideline:
New construction:
• Verify that construction guidelines are in place and pertain to protection of the
environment.
• Verify that culverts of the right size are adequately placed along the road to handle
water volume.
• After a road has been constructed, verify that sides of roads are revegetated.
• Verify that any road maintenance programs do not utilize harmful chemical
management programs.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Access control is usually not an issue with respect to refineries; however, access
control shall be implemented for safety and to minimize additional disturbances to the
environment where local population, livestock and wildlife encroachment become a
problem at an unfenced refinery.
Audit Guideline:
• Check the success of access control and determine if further control methods are
required.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Perimeter berms are seldom if ever used at refineries. On occasion they may be
strategically installed along a low section of the refinery site’s natural topography to
contain or divert (using interception ditches or swails) surface runoff in order to
minimize/eliminate a pollution release from going off-site to contaminate the adjacent
environment.
Audit Guideline:
• Verify use of berms and inspect berm areas. Identify proper berm design and
placement. Berms should be constructed from an impermeable material. They
should be of a design and size to contain amounts of rainfall established by
meteorological statistics for the area.
• Verify that the berm containment system has interception ditches or swails to divert
surface runoff to an industrial runoff or surface retention pond for disposal.
• Verify that berms are inspected and maintained. There should not be any breaches
in the berms. If a release has occurred, the berms should be cleaned and repaired
as needed.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
All sites shall be maintained properly and kept neat, clean and safe. Housekeeping
refers to the general maintenance of a site with respect to acceptable operating
practices, upkeep maintenance and overall orderliness of the grounds, buildings and
equipment.
Audit Guideline:
• Inspect site to verify that site is kept neat, tidy and free from litter. Trash should be
continuously collected and disposed of at an approved facility. (See Waste
Management section).
• Verify that all chemicals are properly labelled, stored, handled and disposed of.
(See Product Storage and Loading section)
• Verify that waste disposal is carried out such that it does not attract wildlife.
• Verify that clearly legible signs are posted as needed and maintained. Fences and
gates should be constructed as needed and maintained.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The operation of flare stacks shall be done to minimize impact to the environment.
Audit Guideline:
• Inspect the location of flare stacks. They should be located away from trees, but
downwind of buildings and oil storage tanks. Verify that special restrictions in
forested areas are followed.
• Inspect stacks and adjacent land to see if liquids have sprayed off the stack.
Inspect flare stack operations. The separated liquids should not be discharged to a
flare stack and burned. Free liquids can escape up the flare stack to pollute the
land.
• Verify and inspect associated liquid removal vessels within the flare stack system.
Determine if an overflow shut down system is in place and if this system is working.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Verify that there is a Spill Contingency Plan and Emergency Response Plan that
clearly outline measures to be taken during a release of hydrocarbons. (see Spill
Prevention and Emergency Response section). A hydrocarbon release should be
responded to in the following manner:
a) Identify and control the source of the release; make repairs when safe to do
so.
f) Using water and surfactant, flush contaminated soil in order to free and
recover additional hydrocarbons.
• Check for signs of spills onsite. Record location and size of any spills. Provide a
sketch of the spill area if possible. Indicate the type of spills observed (type of
contaminant, soil contamination, water contamination, etc.)
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The impact of refining operations’ noise on local residents and workers shall be
minimized.
Audit Guideline:
• If houses are adjacent to the facility, verify that discussions regarding the potential
impacts of noise were held with nearby residents during the design phase of the
facility. Verify that adjustments were made to meet the concerns and needs of the
residents. Adequate public notification and discussion can prevent noise
complaints before the operation starts. An ambient sound survey to measure
existing sound levels may be needed to assist the design.
• Make note of any public complaints (if any), response provided, and, if the noise
level is higher than acceptable limits, verify that measures have been taken to meet
or better the acceptable limits. If complaints have been received, verify that noise
monitoring of the wellsite is being done.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The facility shall have proper drainage systems. Changes in natural conditions should
be minimized to prevent altering natural drainage patterns. Any normal interference
with the normal drainage of water from land, where such interference has been caused
by the operation, shall be removed or remedied as soon as possible.
Audit Guideline:
• Inspect site for internal drainage control to contain potential pollutants on the site.
• Inspect any contaminated areas and verify that surface drainage in those areas is
segregated from other areas of surface runoff. The contained fluids should be
stored for treatment and/or evaporation.
• Inspect bermed storage areas. Drainage from those areas should be contained to
prevent leakage of a spilled product from entering into the drainage discharge.
• Verify that all proper erosion control measures are being used.
• Inspect site for any signs of disturbance to drainage patterns. The consequences of
inadequate drainage are extensive and include ponding, flooding, washouts and
inundation of vegetation.
• Culverts and drainage ditches must be constructed as needed around the plant site
to prevent contamination of surface waters and groundwater.
• Verify through interviews that work crews have been instructed not to place any
materials in drainages.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Ponds shall be used to collect surface runoff, process liquids (potentially oily water)
and industrial wastewater to obtain and analyze representative grab samples of the
liquid in each pond for concentrations of contaminates before releasing, treating or
disposing.
Audit Guideline:
• Verify that pond and associated equipment design is in compliance with API
procedures and regulations or any other acceptable standards.
• Verify that ponds are constructed from a recompacted bentonite or in-situ clay with
-7
a hydraulic conductivity no greater than 1x10 centimetres per second or such other
impermeable material. Otherwise, ponds must have an impermeable liner or be
constructed of cement.
• Verify that ponds are situated to match the natural drainage of the site topography
and graded to minimize erosion and flooding.
• Verify that ponds are designed to control the rainfall established from
meteorological statistics for that area.
• Verify that separate ponds are used for each type of fluid stream collected (i.e., oily
water pond, surface runoff pond, etc.). Measures should be taken to avoid cross-
contamination between ponds.
• Verify that pond levels are monitored and pumped off routinely to ensure no
overflow occurs.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Surface water shall be monitored after spills, after controlled acceptable releases and
as required to monitor water quality near operating sites. Existing local regulations
should be followed. A certified laboratory shall perform the analysis.
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
surface water monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including surface water monitoring
reports and verify compliance.
• Indicate if the facility has a surface water sampling monitoring program. Surface
water sampling and monitoring are site specific.
• Inspect surface water control and release structures. Identify if these structures are
shut to prevent accidental release runoff water.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Soil sampling and monitoring require proper sampling protocols and a certified
laboratory to perform the analysis. Record keeping is essential, particularly of
sampling locations (to ensure the same locations are sampled during a monitoring
program).
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
soil sampling and monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including soil sampling and monitoring
reports and verify compliance.
• Indicate if the facility has a soil sampling monitoring program. Soil sampling and
monitoring are site specific activities in order to assess soil quality. These activities
may be completed to track the progress of a decontamination program, to
determine the extent of a spill and develop remediation programs. Soil monitoring
may be undertaken at any time of a facility’s life, from pre-disturbance, during
operations or during reclamation.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
groundwater monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including water quality reports and verify
compliance.
• Indicate if the facility has any groundwater monitoring systems. Inspect monitoring
well sites and locations. Groundwater monitoring is a site specific issue. Wells
should be installed hydraulically up gradient and down gradient of a potential
contaminant. These wells will be used to determine the depth and direction of
groundwater flow. Monitoring wells must be set in an area that will not interfere
with everyday operations, however, they must be set in order to collect the proper
information.
• Verify that monitoring wells are equipped with a lock in order to prevent
unauthorized entry.
• Verify that only trained personnel or consultants sample the monitoring wells.
Groundwater monitoring is site specific; however, for predisturbance assessments,
it is recommended that the following components be sampled: pH, electrical
conductivity, major ions, total metals and dissolved organic carbon.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
The discharge of water to the environment shall be minimized. A water release may
occur by opening a berm drain, by overflowing a berm, or by pumping water to the
surrounding land.
Audit Guideline:
• Verify that any water released to the environment meets existing regulations. When
discharging water, a field analysis must be done. Field determination may be done
using an appropriate pH meter and Quan Tabs for the chloride determination. Any
visible hydrocarbon sheen requires that the fluid be disposed of via an appropriate
oil field waste disposal facility. The following criteria are recommended:
If the discharged water does not meet the above criteria, the fluid must be disposed
of at an approved oil field waste disposal facility or treated and then discharged on
or off lease with the approval of existing regulatory agencies and the landowner
(private land) or public land manager (public lands).
• Verify that any water discharged is not allowed to flow directly into rivers, creeks or
any other permanent body of water.
• Verify that a proper documentation and reporting procedure exists for water
discharges to the environment. Records must include the parameters listed above
as well as an estimation of the volumes of water disposed.
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
gaseous emissions have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including air quality reports and verify
compliance.
• Determine if any measures are taken to minimize gaseous emissions occurring on-
site. The main air quality parameters of concern are SO2, H2S and NOx. Ozone,
carbon monoxide, carbon dioxide, hydrocarbons and ammonia are also a concern.
Ways to reduce gaseous emissions may include:
•
a) Increasing efficiency per unit of energy produced
b) Reducing sources of emission in all operations
c) Air quality monitoring, reporting and tracking systems (measured quantities
of emissions, reports, etc.)
REFINERIES
GENERAL OPERATING PROCEDURES
General Environmental Concerns
Audit Protocol:
Air quality monitoring is required at some locations of the facility to comply with
existing regulations or when due to resident or landowner concerns. Long term
emissions can have an adverse impact on soil and water.
Audit Guideline:
• Prior to the field inspection, review records including air quality emission reports
and verify compliance.
• Verify that air quality monitoring systems are onsite as required (e.g. facilities
where sour gas is processed, etc.). Two types of air monitoring systems may be
undertaken: ambient monitoring and total sulphation/H2S.
• Inspect air quality monitoring equipment. Air quality sampling is done with many
different pieces of equipment including mobile trailers, stationary trailers and
“birdhouses”. Verify that sampling equipment is in working order and correctly
calibrated.
• Through interviews, verify that operators are familiar with the station so that if there
is an upset, they can fix/modify it and it is not down for an extended period of time.
Operators must be familiar with sampling procedures and sampling locations.
• At sour locations, verify that stack surveys are completed, if existing regulations
require them.
REFINERIES
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Audit Guideline:
• Inspect fuel storage areas and equipment. Fuel tanks are preferable to bladders,
and welded steel tanks are preferable to bolted ones. Inspect tank dykes and verify
that they are of adequate size to contain any spills and have impermeable sides
and bases. (See Product Storage and Loading section)
• Verify that fuel storage areas are clearly marked to ensure that they are not
damaged by moving vehicles. The markers should be visible under adverse
weather conditions. Check that “No Smoking” signs are posted and followed.
• Through interviews, verify that all personnel are familiar with fuel handling
procedures.
• Verify if fuel transfer operations are performed in a manner that prevents spills.
Review records to verify if there is any reporting process in place to record
occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgable of such process.
• Verify the utilization of API oil skimmer systems. Review engineering designs and
identify any modifications. Verify if water analysis is undertaken at water discharge
points.
• Inspect all API oil skimmer units to determine the effectiveness of oil recovery.
Review water analysis to assess the success of these systems. Record any spills
or evidence of hydrocarbons in the water discharge streams.
REFINERIES
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Refining facilities shall have a spill/release contingency plan. All personnel shall be
familiar with the contingency plan
Audit Guideline:
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite. Determine locations, types and quantities of
spill control materials available onsite. These may include: sorbent materials, oil
retention booms, sand bags or temporary curbing devices, recovery pumps and
collection hoses, recovery tank trucks and protective equipment.
• Verify that release drills are held. Release drills should be held at least once a
year. All operating personnel should be required to attend. The sites chosen for
the drill should include topography which is representative of the conditions most
likely to be faced in the event of a release.
• Review any past incident reports. If there have been any releases in the past, a
review should be undertaken to review the causes of the release and to provide
recommendations as to how such a release can be avoided in the future. The
review should include an assessment of the contingency plan and the response as
well, assessing whether there should be any improvements made to the plan or the
training provided.
REFINERIES
SPILL PREVENTION AND EMERGENCY RESPONSE
Audit Protocol:
Refining facilities shall have an Emergency Response Plan to protect the public,
employees, the environment and property should an emergency occur. It is necessary
to provide all employees with a systematic presentation of communication practices
and procedures to be followed in an emergency.
Audit Guideline:
• If the facility is located near residential areas, verify that discussions with local
residents were held when preparing the Emergency Response Plan.
• Interview personnel to verify the level of knowledge of such plan. All employees
should be familiar with the Emergency Response Plan for their work area. They
should also be familiar with the location of emergency equipment and have
participated in mock exercises, held at least once a year.
a) Regulatory Information
b) Scope of the Emergency Plan
c) Local public involvement
d) Contents of the Emergency Procedure Plan:
- Ignition procedures.
- Control procedures to take control or shut-in the release.
- Responsibilities of company personnel.
- Responsibilities of government agencies.
- Media relations to give personnel direction when dealing with the
news media.
- Post-emergency procedures.
- Procedures to update the plan on an annual basis.
- Emergency contact lists.
- Overall site plan.
• Verify through inspection that all material and equipment specified in the
Emergency Response Plan is available onsite.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
The ARPEL documents “Guidelines for the Management of Petroleum Refinery Liquid
Wastes” and “Guidelines for the Management of Refinery Solid Wastes” can be used
as guides in the conduct of audits regarding waste disposal methods.
• Verify that wastes are disposed of properly. The following disposal guidelines for
refinery wastes are recommended:
Process Units
Utility Plant
Miscellaneous
• Maintenance wastes:
• Laboratory Wastes
Non-aqueous, non-hazardous: to
an enclosed and vented holding tank for pump out and
reprocessing.
Hazardous chemicals: to a
segregated vented holding tank
for suitable treatment
depending upon chemical
composition.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Proper handling and storage of toxic substances shall be performed to minimize harm
to people and the environment.
Audit Guideline:
• Review records and verify that current occupational benzene and other toxic
substances exposures have been adequately evaluated to determine compliance
with existing local regulations. Determine if there are any benzene exposure
monitoring survey reports.
• Verify through interviews that personnel are aware of the dangers of hazardous
substances and materials. Verify that proper handling procedures are used and
personal protective equipment is available.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Verify that the flow through the effluent treatment system is carefully controlled.
Overloading the system hydraulically reduces the effectiveness of pollutant removal.
Also, a sudden shock will upset the biological balance and performance will drop.
The shock can be either an increase in pollutants or an influx of unusual pollutants.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Refinery plants shall comply with monitoring requirements according to existing local
regulations.
Audit Guideline:
• Verify that the facility complies with monitoring requirements. Regulations may
require that a number of pollutants be monitored to demonstrate that the effluent
treatment system is being operated consistently.
Daily monitoring:
- Ammonia-nitrogen
- Organic carbon
- Oil and grease
- Sulphides
- Volatile aromatics (benzene, toluene, xylenes, ethylbenzene)
- Zinc and chromium
Monthly:
- aromatic hydrocarbons
- chlorinated volatiles
- acids
- metals
- cyanide
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Refinery plants shall use proper laboratory analytical methodology according to existing
local regulations.
Audit Guideline:
• Verify that proper laboratory analytical procedures are used and comply with
existing local regulations.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Refining facilities shall have a Waste Management Plan to ensure each facility knows
what wastes it produces and how to handle and dispose of those wastes properly.
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility. Review the plan
and see if the wastes the facility produces match the wastes discussed in the plan.
Review the waste disposal methods recommended in the plan and verify if they are
being followed. Review the training schedules for waste management; when
talking to the operators, determine how well the management plan is taught/how
familiar they are with the plan/how practical it is. Verify that a waste manifest
procedure is in place and is being used properly. Review trucking routes for waste
disposal.
• Inspect all waste handling containers and verify the waste has been sorted and
allocated to the correct container. Verify that the container is the correct type for
the waste.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
All waste material shall be properly identified and handled according to hazardous and
nonhazardous waste handling regulatory requirements. General solid wastes
generated by operations shall be disposed of in an acceptable manner to prevent
pollution to the environment.
Audit Guideline:
• Verify prior to the field inspection, the required regulatory procedures to properly
dispose of all types of solid wastes generated.
• Verify that all sites and rights-of-way are kept free of trash and litter. All trash, litter
and garbage must be placed in metal or plastic containers and disposed of
properly.
• Inspect site area for disposal methods of general solid wastes. Such wastes
include rags, waste paper, paper cartons, scrap metal, plastic wastes and rubber
wastes. Industrial landfilling and incineration are the most commonly used
methods for disposal of solid wastes. Incineration is followed by burial of the
incinerated residue. Combustible wastes should be incinerated daily. Materials
suitable for recycling should be stored separately and recycled accordingly.
• Inspect garbage disposal sites. Garbage disposal sites should be used for small,
non-toxic, non-perishable refuse and incinerator residues. Holes or pits should be
located above the expected high water level. A minimum distance from the bank of
a water body of 45 m is required. Consider and evaluate the potential of wildlife
intrusions to the garbage disposal sites or attraction to the location. Verify that pits
are lined.
• Verify that fuel barrels or other containers are not left on the site or along the rights-
of-way.
• Verify that the incinerator(s) is inspected and tested at least yearly to ensure
optimum efficiency.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Indicate if there is any specific code of practice for worksites where asbestos
containing materials and man-made vitreous fibres are present.
• Verify that standard work procedures are in place for working with asbestos
containing materials and man-made vitreous fibres. These measures may include
refraining from smoking, eating or drinking while working with insulation products,
showering, not taking clothes contaminated with fibrous insulation out of specific
areas, following special cleaning procedures for work clothes, wearing the required
safety clothing, posting appropriate signage and using appropriate handling
methods.
• Verify that asbestos containing materials are held in restricted zones or transported
immediately to its final disposal site.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
If sewage lagoons are used, they shall be designed properly to ensure that effluents do
not contaminate ground or surface water or soil and do not present a health hazard.
Audit Guideline:
• Inspect sewage lagoons onsite used to treat sewage/effluent. The following criteria
are recommended:
• Verify that lagoon is properly built, effluent is not released before full retention time
and there are no leaks.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility where recycling is
implemented.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
All water usage shall be assessed for the potential of recycling or reuse. Water usage
shall be minimized by employing the basic principles of water conservation through
reduction of the volume of water used, effective recycling, and maximizing reuse.
Emphasis should be placed on concentrating waste materials in limited volumes of
water.
Audit Guideline:
• Verify if there is an appropriate recycling and reuse system in place for waste
water. This system may include assessment of potential recycling and reuse
methods upon waste identification, determination of preferred methods of recycling
water and identification of alternatives. Waters identified for recycling should be
properly stored and clearly identified.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
The disposal of oil based waste materials shall be done in an acceptable manner.
These materials include waste oil sludge, treater hay and oil spill debris.
Audit Guideline:
• Verify that waste oil sludge is disposed of properly. Oily waste may originate from:
• Inspect site for the provision of tanks at all facilities to ensure temporary storage for
waste oils until they can be properly and safely disposed. Disposal bins equipped
with steam tracing lines may be used to temporarily store pigging wax. The bin can
be transported to a reclaiming facility where it is steamed prior to dumping the
residue into a reclamation tank.
a) Recycle : Whenever possible, waste oil should be recycled back into the
production system. Light wax, lube oil and treated slop oil can be pumped
into the crude oil pipeline in a controlled manner.
b) Waste Oil Reclaimers: Waste oil which cannot be recycled within the
operating company’s facilities should be sent to an approved waste
processing and disposal facility. Pigging wax and solvents that cannot be
recycled at company facilities must be sent to a reclaimer.
c) Land Treatment of Sludges: Land treatment is the controlled addition of oily
wastes into natural soil.
Acceptable disposal options (not a permanent solution but generally safe) are:
a) Application on Roads: tank bottoms, treater sludge and waste oil from heavy
oil operations may be applied to roads, subject to approval of appropriate
authorities.
b) Incineration: waste oils can be disposed of by incineration. However, poor
combustion may cause objectionable smoke or odours.
• Verify that treater hay is disposed of properly. Treater hay results from conventional
treaters that use a filtering medium to enhance impurity removal. The filter material
is called treater hay.
The following disposal methods are acceptable if the preferred options are not
available:
a) The hay may be disposed of into flare pits and burned in conjunction with
periodic flaring (subject to regulatory approval). If the hay is adequately
cleaned prior to burning, it may not create smoke problems when burning.
b) Transport in sealed containers to nearby reclaimers equipped with cleaning
facilities and incinerators.
• Verify that oil spill debris is disposed of properly. In the past, most spills were
controlled on site and burned as quickly as possible. However, due to the emission
of unsightly black smoke and the hazard of ash and carbon fallout, regulatory
bodies are often reluctant to give permission to burn unless there are no other
options. The hazards of forest and/or ground fires must also be considered prior to
burning. The heat generated by burning will destroy underground roots and soil
microbiology, making the re-establishment of vegetation much more difficult.
The preferred reclamation option is: after as much oil as possible has been picked
up, the preferred reclamation procedure is to help the residual oil to degrade by
natural microbial action. This can often be enhanced by using fertilizers and
agricultural practice. See Reclamation/Remediation.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Filters shall be disposed of and changed in an acceptable manner. There are many
types of filters used in the petroleum industry. They include glycol filters, lube oil filters,
domestic water filters, amine and sulfinol filters, etc. Eventually these filters become
clogged and must be replaced. Since filter media will be saturated with the material
being filtered, care must be taken when disposing of them.
Audit Guideline:
Immediately after use, filters should be stored in a container equipped with screens
to permit fluids to drain. Filters should always be drained prior to disposal and the
entrained liquids can be disposed of at approved disposal wells. To properly drain
a filter, it must be stored in the screened container for a minimum of three days at
room temperature. Entrained fluids must be kept segregated for recycling or
disposal. It must be determined through sampling if the filter is a dangerous oilfield
waste. Examples of filters that may be a dangerous oilfield waste are: glycol filters,
leachate and entrained liquids, air pollution control filters, sulphinol filters, lub oil
filters, methanol filters, gas filters and produced or process water filters.
If a screened on-site container is not available for drainage, a barrel with a fitted
screen may be used. The filters should be enclosed in separate plastic bags,
sealed in a drum and buried at an industrial landfill site.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
The operation and maintenance of disposal wells shall be carried out so that impact to
the environment is minimized.
Audit Guideline:
• Determine if there is a standard procedure in place to detect any releases from the
disposal system.
• Inspect disposal well locations. Pressure of disposal must be monitored. Look for
signs of spills.
• Inspect location of disposal lines for deep well disposal. They should be located
downstream (flow of the aquifer) of ponds, lakes, crops and dwellings. Produced
water disposal wells are susceptible to corrosion, therefore leaks along the pipeline
right-of-way are always a possibility and must be monitored. Record method of
detecting leaks in pipelines.
• Verify that the disposal zone is at a depth not less than 600 metres.
REFINERIES
WASTE MANAGEMENT
Audit Protocol:
Audit Guideline:
• Verify that appropriate precautions are taken when handling sulphur. Personnel
should take measures to alleviate or mitigate the following major issues:
c) Sulphur spills when pouring molten sulphur into tank cars for transportation
or onto sulphur blocks for storage.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
A Reclamation Plan shall be used for returning the land to its former land use
capability.
Audit Guideline:
The reclamation plan will take into account whether it is part of a live site which is
being reclaimed or whether the entire site is being abandoned. This can
significantly alter the procedures used.
The plan should identify all capital salvage items, outline the salvage program,
identify disposal options for items which cannot be reused, identify any
contamination issues and how they are to be dealt with and specify the steps for
the restoration of the site (or the portion being restored).
The plan is based on the Site Assessment (Phase I, Phase II if necessary). The
data from the assessment is then evaluated and the necessary procedures are
specified in order of priority. The plan should include a cost estimate, inventory
control, service contracts, equipment and material handling procedures,
environmental protection measures, safety measures, schedule and priorities and
cost control.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
The physical removal of all buildings, facilities, structures and improvements - above
and below ground - shall be done in an acceptable manner.
Audit Guideline:
• Inspect sites being decommissioned or reclaimed. Verify that all equipment and
structures are removed appropriately. Some items, including access roads, gates
or pads, may be left on site if the landowner and reclamation officer are in
agreement or if the landowner agrees and it does not interfere with the reclamation
of the site.
• Verify that all liquids and sludges from vessels/tanks/lines are removed for
disposal.
• Check for asbestos insulation. It is not possible to visually discern this, a lab test is
required. Asbestos containing materials must be removed by especially trained
crews and double bagged for disposal. See Asbestos
• Verify that after all liquid has been removed from the vessels, flowlines, and tanks,
and that all equipment from the site is removed. Ensure any residual fluids which
remain are collected for disposal.
• Verify that cement pads and other inert materials are broken up and are buried on
site with a minimum cover of 1 m of compacted fill or it can be hauled out. Power
lines, power poles, gas lines, telephone lines, and equipment require removal by a
utility company.
• Verify that gravel is salvaged as much as possible for use elsewhere. Gravel
should not be removed until all heavy traffic is finished in order to prevent
reclamation problems.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
When sites are being decommissioned or abandoned, the removal of underground and
aboveground storage tanks shall be done with minimum impact to the environment.
Audit Guideline:
• Verify that tanks are removed properly. The following procedure is recommended:
All residual liquid must be removed from the tank. A bull plug must be placed in all
tanks openings.
All piping must be exposed and disconnected. All fluid must be removed from the
tank prior to the start of any excavation. Tanks should be purged or inerted prior to
the start of excavation. Purge means to remove the explosive vapours and inert
means to remove the oxygen from the tank.
• Verify that any contamination resulting from the removal of the tanks has been
assessed by a qualified environmental consultant. Soil samples should be
collected.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
All sites being reclaimed shall have any contaminated soil removed or remediated
before recontouring and revegetation.
Audit Guideline:
• Verify that all sites contaminated by spills and other chemical disturbances have
been decontaminated. Inspect site being decontaminated. The site may require
restricted access, such as fencing to protect people and animals.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
Reconstructed soils should be able to produce to the former land capability. Soil shall
be returned to similar conditions as preconstruction/operations. The soil layers on site
should be within 50% of their predisturbance depths (topsoil and subsoil). The topsoil
must be in the same texture class as adjacent land. Approximately 20% of the site
may drop one soil quality class.
Audit Guideline:
• Verify that at least four control sites were examined to a depth of 50 cm in order to
identify what soil conditions should be for the site.
• Determine if soil amendments were used or are needed in order to return the soil to
predisturbance conditions. Verify that the amendments recommended were based
on laboratory analysis of the soil on site. Verify what amendments were used
(manure, straw, tree bark mulch, peat, artificial fertilizer) and determine if they were
consistent with both the predisturbance soil conditions and the laboratory analysis.
• Verify that the soil after remediation is the same texture class, same pH, same
aggregate size and strength, same quantity of gravel and rocks and same organic
matter content as the control sites.
• Ensure that the site has been decompacted and that the soil process restriction
parameters are nonrestrictive as compared to the control. Process restriction
parameters are water permeability, vertical root elongation and soil aeration. No
soil layer should have greater density than before.
• Verify that surface soils have been salvaged and replaced on site.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
All refinery sites being decommissioned and reclaimed shall be restored to a capability
equal or better than the surrounding current land use. This includes restoring the
original drainage patterns and ensuring that the site does not hold water.
Audit Guideline:
• Confirm that any culverts that were installed on access roads have been removed.
• Verify that runoff is spread over a large area to minimize runoff water velocities.
Water should be drained in a sheet instead of channels on slight to moderate
slopes.
• Verify that soil is replaced according to the soil profile - horizons A and B should not
be mixed. Subsoil should be replaced with proper compaction.
• Verify that all surface soils are salvaged and replaced onsite.
• Verify that erosion control measures are used as required including berms,
crimping, mulching, manuring, netting and bale placement.
• Verify any rocks were buried more than 150 cm below grade.
• Verify that all earthen pits and ponds have contaminates removed and properly
disposed of before being backfilled.
• Inspect buried earthen pit and pond locations for signs of settlement. Earthen pits
and ponds which are backfilled will settle - mound 50-100 cm to compensate.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
All sites being decommissioned or reclaimed and all disturbed areas at “live locations”
shall be revegetated to prevent erosion, soil degradation and return site to its former
land use.
Audit Guideline:
• Inspect site to verify that proper revegetation procedures have been implemented.
Disturbed areas should be revegetated with grasses, shrubs and trees native to the
area.
• Inspect that species selected are consistent with the planned use of the area
(commercial forest, recreation area, grazing or wildlife habitat, etc.)
• Verify that the seed mixture is fast growing, self-sustaining and that it requires little
or no maintenance.
• Verify the density of growth: overly dense or too little plant growth will require further
work. Determine the method of seeding, time of year of seeding and seeding rates
and compare with the success of the revegetation on site.
• Verify if fertilizers were used and if so what kind. Determine if the quantity and type
is appropriate for the site and climate.
• Verify that the recontouring was appropriate for the vegetation growth (see
Recontouring) i.e., decompaction, microsites, no erosion or ponding.
• Verify fences have been used where necessary to protect new growth.
• If the site has had time for revegetation growth, inspect and record the success
achieved after revegetation and if more work is required.
REFINERIES
ABANDONMENT AND RECLAMATION
Audit Protocol:
Audit Guideline:
• Verify that all equipment was properly removed and that the site has been
completely dismantled.
• Verify that access roads, borrow pits,etc., have all been removed.
• Verify that all decontamination procedures were performed properly and that the
site is decontaminated (soil and water).
• Verify that the soil profiles on site are within acceptable limits to matching the soil
profiles of the off-site controls.
• Verify that the vegetation is, after at least one full growing season, growing well,
with appropriate plant density, cover, plant type and height. Also verify that the
species composition is appropriate for the site and that the vegetation is healthy.
Any bare areas or noxious weeds should be noted.
• Verify that any soil amendments are appropriate for the site and applied correctly.
• Verify that the drainage patterns, contours and slope are appropriate, that there is
no debris on site, that the landscape is stable and that surface rocks match
adjacent land.
• Verify that after operations are completed, the site is restored, as far as practical, to
a condition compatible with existing land use, and that the land capability is equal
to or better than predisturbance conditions.
CHAPTER 13.0
13.1 Seismic
13.2 Drilling
13.3 Production
Auditing offshore facilities is somewhat more difficult that shore-based facilities as the
impacts for the operations on the surrounding environment are largely impossible to
detect or evaluate by visual means. Most discharges are below the surface and some
at considerable depth below the surface. In fact, most discharge depths are modelled
to a depth where they will not resurface.
13.1 Seismic
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any exploration program. Special conditions and restrictions shall
be reviewed and followed.
Audit Guideline:
• Audits of this activity are most effective if conducted towards the end of the program
and before demobilization. If regulatory personnel will be inspecting the exploration
work, attempt to coordinate that site visit with the commencement or termination of
the audit.
• Review the project records to ensure that all required permits, licenses and
regulatory authorizations were obtained prior to the start of any exploration
activities. Record permit/license numbers and verify information in the field.
• Verify through interviews that the supervisory personnel are aware of any
restrictions etc. and has provided this information to the contractor. Verify that
those restrictions are enforced with the contractor and personnel, and that the local
government has been contacted about the project prior to the operations start.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Audit Guideline:
• Verify that environmental concerns (i.e., recognized habitats for marine mammals,
minimizing acoustic disturbance to small cetaceans, effects of energy sources,
recording cables and anchoring on coral reefs etc. ) were incorporated during the
planning stage of the operations.
• If the operations have taken place, or are taking place, in near-shore areas, review
project records and determine if an assessment of the environmental resources in
near-shore operating areas was undertaken.
• Assess if steps have been taken to use the least hazardous solvents or other
hazardous materials.
• Verify that the base camp and existing fly camp were built according to the
recommended wastewater regulations.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Audit Guideline:
Educating the general public during the planning stage can minimize misperceptions
about the nature of the activity and potential impacts. Those not in the industry are not
always familiar with the operational constraints, time scales and commercial pressures
of the exploration and production industry. Local customs, traditions and religious
beliefs should be considered when planning and conducting operations.
Communication with area users can improve relations between all parties involved.
Operators should be aware that liaison with the fishing industry requires a proactive
approach for the development of a harmonious working relationship..
• Verify if any consultation and liaison has been undertaken with the local
communities/groups, the fishing industry, environmental groups and other external
parties. Determine to what extent the issues raised by these groups, during
planning and operations, have been incorporated into planning and operations or
otherwise resolved.
• Verify that if navigation aids have to be placed onshore to support marine seismic
vessels, local authorities are consulted in advance.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Audit Guideline:
• Verify if the lowest possible energy levels are used to achieve the objectives of the
survey.
• Verify if personnel are trained to take appropriate action if marine mammals move
into the area of operation.
• Verify that reasonable efforts were made to retrieve equipment lost overboard as
soon as possible after the loss occurs. Determine if the loss was reported to the
appropriate regulatory agency.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Where seismic operations are conducted in intertidal areas special precautions shall
be taken as dictated by the sensitivity of the area.
Audit Guideline:
Tidal marshes, mud flats and mangroves can be damaged through changes in salinity,
vegetation and erosion resulting from geophysical operations.
• Verify that care was taken when using vibroseis vehicles, water tenders and other
equipment to prevent undue interference with habitats, amenities and commercial
interests.
• Verify that the use of drilling mud on the foreshore for drilling shot holes for
explosive charges, has been discussed with, and approved by, relevant
authorities.
• Verify that inspection programs were in place and used to ensure that no debris is
left on the shore.
• Verify that the proper authorities were notified if a suspected archeological sites
were encountered.
OFFSHORE EXPLORATION
SEISMIC
Audit Protocol:
The survey vessel and auxiliary craft shall operate according to local regulations and in
a manner that minimizes impacts on the environment.
Audit Guideline:
• Inspect vessels and, if possible, observe routine operations to determine if care has
been taken to minimize the possibility of spills and other unacceptable discharges
of fuels, oils and solvents.
• Where vessels are operating in near-shore or inter-tidal areas, verify that operating
procedures include instructions respecting speed, routes etc. that are designed to
reduce the potential for erosion, contact with marine mammals and commercial or
subsistence fisheries.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Measures shall be taken to prevent the occurrence of chronic and accidental spills.
Audit Guideline:
• Verify that drip trays or other containment system is placed under equipment
containing fuel and/or lubricating oil and cable oil and that the fluids collected are
directed to sumps or separators where they are collected for transport to an
approved disposal site.
• Verify that procedures for refuelling operations are posted and, if possible, observe
fuel transfer operation.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Seismic operations shall have a spill contingency plan. All personnel shall be familiar
with the contingency plan.
Audit Guideline:
• Verify that response equipment is appropriate for the products that could be spilled.
• Verify that personnel are trained in the use of the clean-up equipment and any
personal protective equipment.
• Verify that adequate supplies of sorbent materials are available at locations where
spills could be expected to occur.
• Verify that reporting procedures are posted, and that if a spill did take place, were
the appropriate reports filed.
• Where a spill has taken place, verify that sorbents and other clean-up wastes were
disposed of in accordance with regulations and the contingency plan.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Audit Guideline:
• Inspect storage areas. Verify that storage procedures comply with those specified
by the manufacturer.
• Verify that safety information provided by the manufacturer is available to the crew.
• Verify that a tracking system exists that records purchases, usage, storage, spills
and disposal. If manufacturers package is damaged ensure products are
transferred to appropriate containers, marked accordingly and the transfer noted in
the records.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Disposal of wastes shall be carried out in a manner that does not impair environmental
quality.
Audit Guideline:
• Verify that a waste management plan exists and that waste are handled
accordingly.
• Where no plan exists, verify that hazardous wastes are segregated from domestic
and other benign wastes.
• Verify that hazardous material wastes are handled in accordance with the
manufacturers directions and/or local regulation.
OFFSHORE OPERATIONS
SEISMIC
Audit Protocol:
Audit Guideline:
• Inspect the area and all shorebased facilities to verify that proper cleanup
operations have been implemented. Pay particular attention to shorelines and
coastal waterways. An understanding of local tidal currents will assist in locating
any floating wastes that have come to shore.
• Ensure that any wastes sent to local facilities have been properly transported and
that disposal has not caused any problems.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any drilling program. Special conditions and restrictions shall be
reviewed and enforced.
Audit Guideline:
Drilling programs may be limited to a single well, a multiple well program or be part of
a larger field development. Therefore, the drilling may take place within a few months
or over several years. Audits on single well programs are most effective if conducted
towards the end of the well particularly if the well is to be tested. Audits on multi-well
programs can be conducted after the first well and again towards the end of the
program if more than one visit is possible. If only one visit is possible plan the audit for
the latter stages of the program. In the context of a multi-well program reports of
environmental or operational problems associated with drilling could be the trigger for
an audit. Where simultaneous drilling and production operations are planned it may
make sense from logistic and impact assessment perspectives to conduct an audit of
both operations during the same trip.
• Review the records to ensure that all required permits, licenses and regulatory
authorizations were obtained prior to the start of any drilling activities. Record
permit/license numbers and verify information in the field.
• Verify through interviews that the supervisory personnel are aware of any
restrictions etc. and has provided this information to the contractor. Verify, through
interview, documentation and discussions with the regulators, that those
restrictions were followed by the contractor and personnel.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Audit Guideline:
• Drilling programs, even multi-well and programs associated with field development,
occupy relatively small portions of the ocean. Well planned and well run programs
should have little effect on the marine environment and are generally compatible
with other marine activities such as shipping and fishing. Operations in
shallow/near-shore waters tend to have greater potential for environmental impacts.
The E&P Forum has developed operating guidelines for operations near mangroves
and coral reefs that were prepared to promote consideration and conservation of
the environment during drilling and production operations. Verify that local
authorities, experts and/or agencies were contacted for information early in the
planning process.
• Verify that environmental concerns (i.e., recognized habitats for marine mammals,
seabird populations, migration routes etc.) were incorporated during the planning
stage of the operations. If the operations have taken place, or are taking place, in
near-shore areas, review project records and determine if an assessment of the
environmental resources in near-shore operating areas was undertaken.
• Existing commercial and recreational activities are generally compatible with drilling
operations. If the operations have taken place, or are taking place, in near-shore
areas, verify that attempts have been made to schedule operations to avoid the time
periods of high commercial/subsistence fishing and significant recreational
activities.
• Assess to what extent steps have been taken to use the least toxic mud systems
and reduce the use of other hazardous materials.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
During drilling operations, stakeholders such as other marine users, local communities
and coastal business owners shall be consulted as appropriate.
Audit Guideline:
Educating the general public during the planning stage can minimize mispercetions
about the nature of the activity and potential impacts. Those not in the industry are not
always familiar with the operational constraints, time scales and commercial pressures
of the exploration and production industry. Local customs, traditions and religious
beliefs should be considered when planning and conducting operations.
Communication with area users can improve relations between all parties involved.
Operators should be aware that liaison with the fishing industry requires a proactive
approach for the development of a harmonious working relationship.
• Verify if any consultation and liaison has been undertaken with the local
communities/groups, the fishing industry, environmental groups and other external
parties. Determine to what extent the issues raised by these groups, during
planning and operations, have been incorporated into planning and operations or
otherwise resolved.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Audit Guideline:
Environmental impacts from drilling programs are primarily associated with large oil
spills from a loss of well control and the discharges of drilling mud and cuttings. The
drilling program is dictated by a number of factors including the type of well being
drilled (exploration, delineation, development, high angle, horizontal, etc.) and
anticipated hole conditions. Most of these systems have very low toxicities and can be
discharged in all but the most shallow waters with negligible effect. Oil-based muds
(OBM’s) however cannot be discharged directly to the seabed or water column as even
the low toxicity systems may leave sheens and could result in tainting of fish or
accumulations of hydrocarbons in the sediments below and adjacent to the drilling site.
Where OBM’s are used the bulk muds cannot be dumped when changing systems and
the cuttings from these portions of the hole must be treated prior to discharge.
Generally cuttings can be left where they fall as they are dispersed over time.
However, depending upon local seabed topography and in locations where sediments
accumulate and dredging is required to maintain navigation channels, it may be
reasonable to return cuttings to shore or remove to a dispersing area. However, there is
a high safety and pollution risk in transferring large quantities of cuttings from offshore
platforms and drilling rigs to the shore. It may be necessary in rare cases to disperse
cuttings some distance away form the rig by means of flexible hoses. Grinding and re-
injection into other rock strata, and the return to land of cuttings for disposal has been
considered but it is seen as having only limited application. and there is a lack of
suitable onshore facilities and sites for disposal of the large amounts of oiled cuttings
that can be produced annually.
ARPEL has prepared a guideline for the Treatment and Disposal of Exploration and
Production Drilling Wastes. Part II of that document deals with offshore operations.
• Prior to the field inspection, verify the required regulatory procedures to properly
dispose of drilling fluids and solid wastes.
• Where OBM’s have been used verify through inspection of records and interview,
that the cuttings washing equipment was maintained on a regular basis and that
discharges were within specified limits.
• Where OBM’s have been used, verify through inspection of records and interviews
that there was no dumping of used or unused mud. Verify with rig and shore-based
personnel that mud was shipped to shore, received at shore and treated/disposed
according to procedures and local regulations.
• Verify that well control systems were tested in accordance with procedures and that
all identified problems were corrected prior to commencing or resuming drilling
operations.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Stand-by and re-supply vessels shall operate according to existing local regulations
and in a manner that would minimize impact to the environment.
Audit Guideline:
• Inspect vessels and, if possible, observe routine operations to determine if care has
been taken to minimize the possibility of spills and other unacceptable discharges
of fuels, oils and bulk products.
• Where vessels are operating in near-shore or inter-tidal areas, verify that operating
procedures include instructions respecting speed, routes etc. that are designed to
reduce the potential for erosion, contact with marine mammals and commercial or
subsistence fisheries.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Measures shall be taken to prevent the occurrence of chronic and accidental spills.
Audit Guideline:
• Through interviews, verify that all personnel are familiar with fuel and chemical
handling procedures. Instructions for the monitoring of these activities should be
built into the drilling program or other suitable well-specific document.
• Verify if fuel and chemical transfer operations are performed in a manner that
prevents spills. Review records to verify if there is any reporting process in place to
record occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgeable of such process.
• Verify that regular inspections are performed to detect any leaks or spills.
• Check condition of transfer hoses and any pressure testing procedures. Review
incident history of transfer hoses.
• Close attendance during bunkering of the vessel with the pollution control
equipment is recommended.
• Check that “No Smoking” signs are posted in fuel storage areas. Verify that these
areas are clearly marked. Inspect chemical storage areas. Bagged material
should be properly stored in weather protected areas. Chemical barrels should be
protected so that leaks and spills can be contained.
• Verify that procedures are in place regarding oil well testing. Personnel should
maintain a watch for oil on the sea surface. The pollution control vessel should be
in close attendance at this time in order to be able to take immediate action on any
liquids escaping the flare boom and entering the water.
• Verify if there is any pollution risk assessment due to spillage of crude oil, including
anticipated reservoir characteristic studies and shallow nature and blowout
potential studies.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Drilling operations shall have a spill contingency plan that adequately addresses the
spill risks posed by the operations. All personnel shall be familiar with the contingency
plan and capable of fulfilling their roles in that plan.
Audit Guideline:
ARPEL has spent considerable effort in preparing guidance documents that describe
in detail the preparation of contingency plans and spill response options. These
documents can be used a guide for the auditor in the conduct of audits of this area.
• Verify the existence of a Spill Contingency Plan. Verify that local authorities,
including resource managers for fish and wildlife, were contacted in the preparation
of the contingency plan.
• Review contents of the Spill Contingency Plan. Record and analyze the particular
spill prevention and cleanup methods to make sure they are appropriate for the
location and risks posed by the operations. The essential elements of the plan are:
• Interview personnel to verify the level of knowledge of such plan and level of related
experience.
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite.
• In near-shore areas and sensitive areas, verify that particular attention has been
paid to predicting the effects of local weather and hydrogeography on the
movement of spilled oil. Verify the provision of adequate means of tracking and
surveillance of spilled oil.
• Verify that appropriate arrangements for oil pollution containment and recovery are
provided. The standby vessel can be provider dual purpose rescue and pollution
control duties for short periods of time near the drilling unit; however, the safety and
rescue roles should never be compromised.
OFFSHORE OPERATIONS
DRILLING
Audit protocol:
Drilling operations shall have a spill response capability commensurate with the size
and type of spills associated with those operations.
Audit Guideline:
• Inspect stand-by/ pollution control vessels. Verify that type of vessel is adequate for
the exploration area. Verify that all necessary equipment is available. The vessel
should have a set of operating procedures and well-specific instructions.
• Verify that clear instructions are given on the use of dispersants. Inspect and verify
type, efficiency and approval status of the dispersant stock. The vessel should
deploy and test equipment at regular intervals to ensure it is in a continual state of
readiness. The vessel should be in close proximity to the rig during transfer of fuel,
well testing or at any time when there is considered to be an increased risk of an oil
release.
• Verify that communications systems and reporting networks are tested on a regular
basis.
• If there has been a spill, inspect the area to verify proper cleanup operations and
reporting procedures were undertaken.
• Verify that collected oil and spill response wastes are properly stored and that
disposal is in accordance with the contingency plan and local regulations.
• Verify that monitoring of potential spills effects has been carried out. The level of
monitoring should reflect the size or seriousness 0f the spill.
• Determine how damage claims were handled/settled, and verify that all such
matters have been resolved.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Audit Guideline:
• Inspect storage areas. Verify that storage procedures comply with those specified
by the manufacturer.
• Verify that safety information provided by the manufacturer is available to the crew.
• Verify that hazardous material wastes are handled in accordance with the
manufacturers directions and/or local regulation.
• Verify that a tracking system exists that records purchases, usage, storage, spills
and disposal. If manufacturers package is damaged ensure products are
transferred to appropriate containers, marked accordingly and the transfer noted in
the records.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Disposal of wastes shall be carried out in a manner that does not impair environmental
quality.
Audit Guideline:
• Prior to the field inspection, verify the required regulatory procedures to properly
dispose of all types of solid wastes generated.
• Verify that a waste management plan exists and that waste are handled
accordingly. The plan should contain as a minimum, a reporting policy and a
description of disposal methods.
• Where no plan exists, verify that hazardous wastes are segregated from domestic
and other benign wastes.
• Verify that suitable and sufficient receptacles are provided for the collection and
storage of refuse. All such receptacles should be kept in a clean condition and
good repair.
• Verify that hazardous material wastes are handled in accordance with the
manufacturers directions and/or local regulation.
• Verify that wastes packaged for shipment to shore are properly prepared and
marked.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Audit Guideline:
• Prior to the field inspection, verify the required regulatory procedures for wastewater
discharges.
• Verify that operations comply with existing local regulations. For blocks outside the
three mile limit, the normal (maceration to 6mm) offshore discharge requirements
should apply. Within three miles of the shore and in other controlled waters,
consent may be required from the appropriate authorities to discharge any
wastewater. The consents may carry conditions on rate of discharge and effluent
composition.
• Verify that proper procedures for the treatment and disposal of oily water are in
place and being followed.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Discharges shall be monitored regularly to ensure that good operating practices are
followed.
Audit Guideline:
• Verify discharges are sampled and analyzed regularly. Inspect records for variance
from sampling schedule.
• Inspect analysis results for values that exceed regulatory or other standards.
OFFSHORE OPERATIONS
DRILLING
Audit Protocol:
Suspended and abandoned wells shall be left in a condition that do not pose a risk of
pollution or interference with other marine activities.
Audit Guideline:
• Verify that proper procedures are in place to ensure the seabed is clear of any
debris after the operation is complete. A seabed clearance report can be used to
demonstrate the presence or absence of seabed protrusions.
• Verify that all platforms and subsea structures are removed properly. In choosing
the best abandonment and decommissioning option, consideration should be given
to the relative benefits of the decommissioning versus allowing the materials to
remain in place.
• Verify that there are no obstacles left on the seabed that will be an impediment to
commercial or subsistence fishing interests.
13.3 PRODUCTION
13.3 PRODUCTION
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any oil and gas production activities. Special conditions and
restrictions shall be reviewed and followed.
Audit Guideline:
• Review the records to ensure that all required permits, licenses and regulatory
authorizations are current. Record permit/license numbers and verify information in
the field.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
Once installed, production facilities tend to be in place for many years. The impact of
operations over years can be cumulative. It is important to ensure that operations
strive for continuous improvement in an effort to reduce the potential for unacceptable
impacts. Monitoring programs are an essential component of the management of
these facilities. Audits should be scheduled on a regular basis; the schedule can vary
from facility to facility depending upon performance and relative risk. As a minimum
offshore facilities should be audited every 3 years. Impact from offshore production
facilities are primarily associated with large oil spills and produced water.
• For first audits, verify that environmental concerns (i.e., recognized habitats for
marine mammals, seabird populations, migration routes etc.) were incorporated
during the planning stage of the operations. If the operations have taken place, or
are taking place, in near-shore areas, review project records and determine if an
assessment of the environmental resources in near-shore operating areas was
undertaken.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
The Operators of oil and gas production facilities shall consult with stakeholders such
as other marine users, local communities and coastal business owners shall be
consulted as appropriate.
Audit Guideline:
Educating the general public during the planning stage can minimize misperceptions
about the nature of the activity and potential impacts. Those not in the industry are not
always familiar with the operational constraints, time scales and commercial pressures
of the exploration and production industry. Local customs, traditions and religious
beliefs should be considered when planning and conducting operations.
Communication with area users can improve relations between all parties involved.
Operators should be aware that liaison with the fishing industry requires a proactive
approach for the development of a harmonious working relationship..
• Verify if any consultation and liaison has been undertaken with the local
communities/groups, the fishing industry, environmental groups and other external
parties. Determine to what extent the issues raised by these groups, during
planning and operations, have been incorporated into planning and operations or
otherwise resolved.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
• Verify that operations are supported by reliable weather forecasting services that
can be used to plan production and loading operations.
• Verify that the work plans and activities of the maintenance, process operations and
well performance groups all contain environmental responsibilities.
• Verify through interview the extent to which these personnel understand the
environmental impacts that could result from accidents arising from their activities.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
• Verify through inspection of reports and interview that the schedule for testing,
inspecting and maintaining valves and wellheads has been followed.
• Ensure that unacceptable test results or reports have been properly addressed and
remedial action assigned on a priority that matches the risk posed by the situation.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Flare stacks shall be maintained to reduce the generation of smoke, soot and liquids.
Audit Guideline:
Flaring is generally associated with well testing which may or may not be conducted
from the production facility. Flaring is one method of disposing of unwanted gas
separated from the oil; recompression and reinjection of the gas for gas conservation
or enhanced recovery is a more acceptable option. Flaring should be kept to a
minimum; records of flaring events including the duration and reason for flaring should
be maintained.
• Inspect flare boom and adjacent areas for signs of staining from spray off the stack.
Check logs for times and duration of flaring, correlate with reports of sheen on the
water.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Crude oil transfer and subsequent shipping to onshore storage or market shall be
conducted so that environmental disturbance is minimized.
Audit Guideline:
• Verify that all crude oil transfers are monitored by personnel at either end of the
connection. Ensure that appropriate emergency shutdown systems are available
and in working condition. Ensure that communication systems connection the
discharge and receiving facilities are working and that adequate secondary systems
are available and working.
• Verify that pollution control equipment is available onsite and that there are
procedures posted respecting the priorities for spill response. Where dispersant
use has received prior approval, determine is spray systems are active during
transfer operations.
• Verify that all vessels loading at the facility have segregated ballast. Where they do
not, determine how the ballast water was treated.
• Verify that there is a clearly assigned responsibility for spills originating from the
tankers calling at the production facility for spills where they are not connected to
the loading system. Each vessel should have a contingency plan that guarantees
an effective response will be mounted in a reasonable time. Response may be
coordinated between the ship owner, production facility and the destination terminal
dependent upon the location of the spill.
• Verify through interview and inspection of records that all components of the
loading system receive regular inspection and maintenance. Inspect logs of the
production facility and tankers for an indication of problems during crude oil transfer
and their resolution. Pay particular attention to reports of emergency disconnects
and any release of oil.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Stand-by and re-supply vessels shall operate according to existing local regulations
and in a manner that would minimize impact to the environment.
Audit Guideline:
• Inspect vessels and, if possible, observe routine operations to determine if care has
been taken to minimize the possibility of spills and other unacceptable discharges
of fuels, oils and bulk products.
• Where vessels are operating in near-shore or inter-tidal areas, verify that operating
procedures include instructions respecting speed, routes etc. that are designed to
reduce the potential for erosion, contact with marine mammals and commercial or
subsistence fisheries.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Measures shall be taken to prevent the occurrence of chronic and accidental spills.
Audit Guideline:
• Through interviews, verify that all personnel are familiar with fuel and chemical
handling procedures. Instructions for the monitoring of these activities should be
built into the operations manuals or other suitable facility-specific document.
• Verify if fuel and chemical transfer operations are performed in a manner that
prevents spills. Review records to verify if there is any reporting process in place to
record occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgeable of such process.
• Verify that regular inspections are performed to detect any leaks or spills.
• Check condition of transfer hoses and any pressure testing procedures. Review
incident history of transfer hoses. Close attendance during bunkering of the vessel
with the pollution control equipment is recommended.
• Check that “No Smoking” signs are posted in fuel storage areas. Verify that these
areas are clearly marked.
• Verify that procedures are in place regarding all testing of subsea systems.
Personnel should maintain a watch for oil on the sea surface. The pollution control
vessel should be in close attendance at this time in order to be able to take
immediate action on any liquids escaping the flare boom and entering the water.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Production facilities shall have a spill contingency plan that adequately addresses the
spill risks posed by the operations. All personnel shall be familiar with the contingency
plan and capable of fulfilling their roles in that plan.
Audit Guideline:
ARPEL has spent considerable effort in preparing guidance documents that describe
in detail the preparation of contingency plans and spill response options. These
documents can be used a guide for the auditor in the conduct of audits of this area.
• Verify the existence of a Spill Contingency Plan. Verify that local authorities,
including resource managers for fish and wildlife, were contacted in the preparation
of the contingency plan.
• Review contents of the Spill Contingency Plan. Record and analyze the particular
spill prevention and cleanup methods to make sure they are appropriate for the
location and risks posed by the operations. The essential elements of the plan are:
• Interview personnel to verify the level of knowledge of such plan and level of related
experience.
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite.
• In near-shore areas and sensitive areas, verify that particular attention has been
paid to predicting the effects of local weather and hydrogeography on the
movement of spilled oil. Verify the provision of adequate means of tracking and
surveillance of spilled oil.
• Verify that appropriate arrangements for oil pollution containment and recovery are
provided. The standby vessel can be provider dual purpose rescue and pollution
control duties for short periods of time near the drilling unit; however, the safety and
rescue roles should never be compromised.
OFFSHORE OPERATIONS
PRODUCTION
Audit protocol:
Production facilities shall have a spill response capability commensurate with the size
and type of spills associated with those operations.
Audit Guideline:
• Inspect stand-by/ pollution control vessels. Verify that type of vessel is adequate for
the conditions within the field. Verify that all necessary equipment is available. The
vessel should have a set of operating procedures and facility-specific instructions.
• Verify that clear instructions are given on the use of dispersants. Inspect and verify
type, efficiency and approval status of the dispersant stock.
• The vessel should deploy and test equipment at regular intervals to ensure it is in a
continual state of readiness. The vessel should be in close proximity to the rig
during transfer of fuel, testing of subsea components or at any time when there is
considered to be an increased risk of an oil release.
• Verify that communications systems and reporting networks are tested on a regular
basis.
• If there has been a spill, inspect the area to verify proper cleanup operations and
reporting procedures were undertaken.
• Verify that collected oil and spill response wastes are properly stored and that
disposal is in accordance with the contingency plan and local regulations.
• Verify that monitoring of potential spills effects has been carried out. The level of
monitoring should reflect the size or seriousness 0f the spill.
• Determine how damage claims were handled/settled, and verify that all such
matters have been resolved.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
• Inspect storage areas. Verify that storage procedures comply with those specified
by the manufacturer.
• Verify that safety information provided by the manufacturer is available to the crew.
• Verify that hazardous material wastes are handled in accordance with the
manufacturers directions and/or local regulation.
• Verify that a tracking system exists that records purchases, usage, storage, spills
and disposal. If manufacturers package is damaged ensure products are
transferred to appropriate containers, marked accordingly and the transfer noted in
the records.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Disposal of wastes shall be carried out in a manner that does not impair environmental
quality.
Audit Guideline:
• Prior to the field inspection, verify the required regulatory procedures to properly
dispose of all types of solid wastes generated.
• Verify that a waste management plan exists and that waste are handled
accordingly. The plan should contain as a minimum, a reporting policy and a
description of disposal methods for effluent streams such as produced water and
other wastes such as filters and sludges.
• Where no plan exists, verify that hazardous wastes are segregated from domestic
and other benign wastes.
• Verify that suitable and sufficient receptacles are provided for the collection and
storage of refuse. All such receptacles should be kept in a clean condition and
good repair.
• Verify that hazardous material wastes are handled in accordance with the
manufacturers directions and/or local regulation.
• Verify that wastes packaged for shipment to shore are properly prepared and
marked.
• Verify that clinical waste is stored, labelled and disposed in the manner described
in the waste management plan. “Sharps” should be collected in approved
containers.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
• Prior to the field inspection, verify the required regulatory procedures for wastewater
discharges.
• Verify that operations comply with existing local regulations. For blocks outside the
three mile limit, the normal (maceration to 6mm) offshore discharge requirements
should apply. Within three miles of the shore and in other controlled waters,
consent may be required from the appropriate authorities to discharge any
wastewater. The consents may carry conditions on rate of discharge and effluent
composition.
• Verify that proper procedures for the treatment and disposal of oily water are in
place and being followed.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Discharges shall be monitored regularly to ensure that good operating practices are
followed.
Audit Guideline:
• Verify discharges are sampled and analyzed regularly. Inspect records for variance
from sampling schedule.
• Inspect analysis results for values that exceed regulatory or other standards.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
Produced water management has been the subject of several recent international
conferences. The proceedings of these sessions will provide the auditor with
additional material with which to evaluate the management of this waste stream.
The volumes of produced water vary from field to field but generally tend to increase as
the field matures. Produced water may actually be surface water that has been treated
and injected into the reservoir (waterflood) or waters of geologic age which tend to be
of much higher salinity and contain a wider range of potential contaminants including
radioactive isotopes. produced water is warmer than the receiving seawater and may
tend to rise or remain neutrally buoyant for a short distance from the facility.
• Many regulations set an upper limit that represents an average concentration over a
fixed period of time, suggesting that it is important to have a sampling program that
allows operations personnel to detect when non-compliance is imminent. Verify
that a regular sampling program is in place that matches the compliance
requirements. Verify that appropriate responses, including notification of regulatory
agencies where necessary, to imminent or actual non-compliance incidents have
been made.
• Verify that environmental effects monitoring has been conducted on a regular basis
as a means of detecting changes in the biological and chemical environments in
the vicinity of the production facilities.
• Verify that where changes have been detected, the matter has been investigated,
mitigated or otherwise resolved.
OFFSHORE OPERATIONS
PRODUCTION
Audit Protocol:
Audit Guideline:
A discussion paper “Decommissioning offshore Oil and Gas Installations; Finding the
right Balance” has recently been prepared by the international oil and natural gas
exploration and production industry. This document and the proceedings of several
international symposiums will provide the auditor with the scope and perspective to
evaluate decommissioning and abandonment plans and operations. The UK Offshore
Operators Association has prepared “An Assessment of the Environmental Impacts of
Decommissioning Options for Oil and Gas Installations in the North Sea” which may
also provide the auditor with additional scope and perspective.
• Verify that proper procedures are in place to ensure the seabed is clear of any
debris after the operation is complete. A seabed clearance report can be used to
demonstrate the presence or absence of seabed protrusions.
• Verify that all platforms and subsea structures are removed properly. In choosing
the best abandonment and decommissioning option, consideration should be given
to the relative benefits of the decommissioning versus allowing the materials to
remain in place.
• Verify that there are no obstacles left on the seabed that will be an impediment to
commercial or subsistence fishing interests.
BIBLIOGRAPHY
BIBLIOGRAPHY
Alberta Environmental Protection. 1994. Tier I Soil Criteria for Contaminated Soil
Assessment and Remediation.
American Society for Testing and Materials (ASTM). 1993. ASTM Standard Practice
for Environmental Site Assessments. Phase I Environmental Site Assessment
Process. ASTM Designation: E 1527-93. Philadelphia, US.
ARPEL Documents: Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes; Guidelines for the Management of Petroleum Refinery
Solid Wastes; Guidelines for Decommissioning and Surface Land Reclamation at
Petroleum Production and Refining Facilities; Guidelines for the Environmental
Management of the Design, Construction, Operation and Maintenance of Hydrocarbon
Pipelines; Guidelines for Control and Mitigation of Environmental Effects of
Deforestation and Erosion and Guidelines for the Management of Petroleum Refinery
Liquid Wastes.
Center for Training and Understanding (CTU) and the Environmental Business
Association (TEBA). 1991. The Environmental Audit for Real Estate and Property
Transfer. Matawan, US.
The International Offshore Oil and Natural Gas Exploration and Production Industry.
Decommissioning Offshore Oil and Gas Installations: Finding the Right Balance.
London, England.
United States Environmental Protection Agency (EPA). 1989. Generic Protocol for
Environmental Audits at Federal Facilities. Washington, D.C.
American Society for Testing and Materials (ASTM). 1986. Inorganic Analytical
Methods Performance and Quality Control Considerations, fifth volume. C. L. Perket
(ed.), STP 925. Philadelphia, Pennsylvania.
American Society for Testing and Materials (ASTM). 1992. Annual Book of ASTM
Standards. Volume 04.08. Philadelphia, Pennsylvania.
American Society for Testing and Materials. 1986. Volatile Organic Analytical
Methods Performance and Quality Control Considerations. Fifth Volume. STP 925,.
Philadelphia, Pennsylvania.
Kane, M. (ed.). 1987. Manual of Sampling and Analytical Methods for Petroleum
Hydrocarbons in Groundwater and Soil. API Publication No. 4449. American
Petroleum Institute. Washington, D.C.
United States Environmental Protection Agency (EPA). 1977. Procedures Manual for
Groundwater Monitoring at Solid Waste Disposal Facilities. EPA/530/SW-611.
Washington, D.C.
United States Environmental Protection Agency (EPA). 1988. Office of Solid Waste
and Emergency Response. Superfund Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA. EPA OSWER. Washington,
D.C.
United States Environmental Protection Agency (EPA). 1986. Test Methods for
Evaluating Solid Wastes. SW-846.
United States Environmental Protection Agency (EPA). 40 CFR. Part 141 and 40 CFR.
Part 136.
United States Environmental Protection Agency (EPA). 1979. Methods for Chemical
Analysis of Water and Wastes. EMSL. EPA - 600/4 - 79 - 020. Cincinnati, OH 45268.
GLOSSARY
ABANDON: To cease efforts to produce oil and gas from a well, and to plug a depleted formation and
salvage all material and equipment.
ABSORPTION: The passage of one substance into or through another; to soak up.
ACIDIZING: The treatment of formations with hydrochloric or other type acids in order to increase
production or injection.
AIR POLLUTANT: Any substance in air which could cause, if in high enough concentration, harm man,
other animals, vegetation or material. Pollutants may include any natural or artificial composition of
matter capable of being airborne. They may be in the form of solid particles, liquid droplets, gases or in
combinations of these forms.
AIR POLLUTION: The presence of contaminant or pollutant substances in the air that do not disperse
properly and interfere with human health or welfare, or produce other harmful environmental effects.
ANNULAR SPACE: The space around a pipe (casing or tubing) suspended in a wellbore is often termed
the ANNULUS, and its outer wall may be either the wall of the borehole or the casing.
ASBESTOS: A mineral fibre that can pollute air or water and cause cancer or asbestosis when inhaled.
This material has been banned and its use severely restricted.
ATMOSPHERIC EMISSIONS: Residual discharges of emissions to the air (usually expressed in pounds
or kilograms per unit output) following emission control devices. Includes point sources such as stacks
and vents as well as area sources such as storage piles.
AUDIT: A systematic check of relevant aspects of an operation. Audits may include energy, wastes or a
full environmental audit of all matters that influence environmental performance.
AUDIT CONCLUSION: Professional judgement or opinion expressed by an auditor about the subject
matter of the audit, based on and limited to reasoning the auditor has applied to audit findings.
AUDIT CRITERIA: Policies, practices, procedures or requirements against which the auditor compares
collected audit evidence about the subject matter.
AUDIT FINDINGS: Results of the evaluation of the collected audit evidence compared against the agreed
audit criteria.
AUDIT TEAM: Group of auditors, or a single auditor, designated to perform a given audit: the audit team
may also include technical experts and auditors-in-training.
BENTONITE: A naturally occurring clay, which is often a major constituent of drilling muds.
BIOLOGICAL TREATMENT: A treatment technology that uses bacteria to consume waste. This
treatment breaks down organic materials.
BLOWOUT PREVENTER (BOP): The equipment installed at the wellhead for the purpose of controlling
pressures in the annular space between the casing and drill pipe during drilling.
BRINE: Water that has a large quantity of salt, especially sodium chloride, dissolved in it. Salt water.
BUFFER STRIPS: Strips of grass or other erosion-resisting vegetation between or below cultivated
strips or fields.
CASING STRING: The pipe run in a well, for example: surface string, intermediate string, production
string, etc.
CATALYST: A substance which alters the velocity of a chemical reaction without itself being altered.
CELLAR: A hole dug, usually before digging a deep well, to allow working space for the
casinghead equipment.
CLEANUP: Actions taken to deal with a release or threat of release of a hazardous substance that could
affect humans and/or the environment. The term “cleanup” is sometimes used interchangeably with the
terms remedial action, removal action, response action or corrective action.
CLOSED IN: A well capable of producing oil or gas, but temporarily shut in.
COMPOSITE SAMPLE: A sample which is made up of material combined from two or more samples. It is
a common practice to use composite samples made from samples taken from across an area. Sample is
seen to be a representative sample.
COMPOSTING: A waste management option. The biodegradation of organic solid wastes. A waste
management option involving the controlled biological decomposition of organic materials into a relatively
stable humus-like product that can be handled, stored, and/or applied to the land without adversely
affecting the environment.
CONDENSATE: Hydrocarbons which are in the gaseous state under reservoir conditions but which
become liquid either in passage up the hole or in the surface equipment.
CONSERVATION: Protection of the soil against physical loss by erosion or against chemical
deterioration; that is, excessive loss of fertility by either natural or artificial means.
CONTAMINATION: The presence in soil, water, groundwater, air or structures of a material which may
adversely affect human health or the natural environment.
CONTINGENCY PLAN: A document setting out an organized, planned, and coordinated course of action
to be followed in case of fire, explosion, or other accident that releases toxic chemicals, hazardous
wastes, or radio-active materials which threaten human health or the environment.
COOLING TOWER: A large structure in which atmospheric air is circulated to cool water by evaporation.
CORRECTIVE ACTION: Action taken to eliminate the causes of an existing nonconformity, defect or
other undesirable situation in order to prevent recurrence.
CRUDE OIL: A mixture of hydrocarbons that exists in the liquid phase in the underground reservoir and
remains liquid at atmospheric pressure after passing through surface separating facilities.
CUT OIL: Oil that contains water, usually in the form of a emulsion. Also called wet oil.
DANGEROUS SUBSTANCE: Substances that, when accidentally released, and in such a quantity as
may result in serious harm to life, property or the environment.
DECOMMISSIONING: The remediation of a mine or industrial site once the operations on the site have
come to an end or closed.
DECOMPOSITION: The breakdown of matter by bacteria and fungi. Changes the chemical makeup and
physical appearance of materials.
DISPOSAL: Final placement or destruction of toxic, radioactive or other wastes; surplus or banned
pesticides or other chemicals; polluted soils; and drums containing hazardous materials from removal
actions or accidental releases.
DISPOSAL FACILITY: A plant or structure used for the destruction, removal and disposal of waste
materials.
DREDGING: Removal of mud from the bottom of water bodies using a scooping machine. This disturbs
the ecosystem and causes silting that can kill aquatic life. Dredging of contaminated muds can expose
aquatic life to heavy metals and other toxins.
DRILL STRING: Lengths of steel tubing roughly 10 meters long screwed together to form a pipe
connecting the drill bit to the drilling rig. The string is rotated to drill the hole and also serves as a conduit
for drilling mud.
DYKE: A low wall that can act as a barrier to prevent a spill from spreading. (Also referred to as a
BERM)
ECOLOGY: The relationship of living things to one another and their environment or the study of such
relationships.
ECOSYSTEM: The interacting system of a biological community and its nonliving environmental
surroundings.
EFFLUENT WASTE WATER: Treated or untreated water flowing out of a treatment plant, sewer or
industrial outfall. Generally refers to wastes discharged into surface waters.
ELECTRICAL CONDUCTIVITY (EC): Environmental context refers to the method to determine the
salinity level of a soil or water sample. As the concentrations of salt increase in a solution, so does the
electrical conductivity.
EMERGENCY PLAN: A written detailed program of action to minimize the effects of an abnormal event
requiring prompt actions beyond normal procedures to protect human life, minimize injury, optimize loss
control and to reduce physical asset and environmental exposure.
EMISSION: Pollution discharged into the atmosphere from smokestacks, other vents, and surface areas
of commercial or industrial facilities.
EMULSION: A mixture of crude oil and formation water. Generally requires time and heat, chemicals
(called demulsifiers or emulsion breakers) or electricity to separate the water from the oil.
ENHANCED OIL RECOVERY: A process whereby oil is recovered other than by the natural pressure in
a reservoir, using secondary or tertiary recovery methods.
ENTRAINED GAS: Gas suspended in bubbles in a stream of liquid such as water or oil.
ENTRAINED LIQUIDS: Mist-size liquid droplets occurring in a gas stream. Special design separators,
with a mist extractor, are used to remove the liquid from the gas stream.
ENVIRONMENT: Surroundings in which an organization operates, including air, water, land, natural
resources, flora, fauna, humans, and their interrelation.
ENVIRONMENTAL IMPACT: Any change to the environment, whether adverse or beneficial, wholly or
partially resulting from an organization’s activities, products or services.
ENVIRONMENTAL MANAGEMENT SYSTEM: That part of the overall management system which
includes organizational structure, planning activities, responsibilities, practices, procedures, processes
and resources for developing, implementing, achieving, reviewing and maintaining the environmental
policy.
ENVIRONMENTAL POLICY: Statement by the organization of its intentions and principles in relation to
its overall environmental performance which provides a framework for action and for the setting of its
environmental objectives and targets.
EROSION: The wearing away of land surface by wind or water. Erosion occurs naturally from weather
or run-off but can be intensified by land-clearing practices.
EXPLORATION DRILLING: Drilling carried out to determine whether hydrocarbons are present in a
particular area or geological structure.
FIELD FACILITY: An installation designed for one or more specific field processing units--scrubbers,
absorbers, drip points, compressors, single or multiple stage separation units, low temperature
separators, and other types of separation and recovery equipment.
FLARING: Burning of gas extracted from an oil and gas reservoir which is not worth commercial
production.
FLOCCULATION: The process by which clumps of solids in water or sewage are made to increase in
size by biological or chemical action so that they can be separated from the water.
FLOW LINE: The surface pipe through which oil travels from the well to the field processing facility.
FLOW STRING: The string of casing or tubing through which fluids from a well flow to the surface.
FLOWING WELL: A well that produces without the means of an artificial lift.
FLUID: A substance that flows. Both liquids and gases are fluids. In common oilfield usage, the term
fluid refers to liquids.
FLUID INJECTION: Injection of gases or liquids into a reservoir to force oil toward and into producing
wells.
FRACTIONATOR: A cylindrical refining vessel where liquid feedstocks are separated into various
components or fractions (e.g., distillation).
FRACTURING: Application of hydraulic pressure to the reservoir formation to create fractures through
which oil or gas may move to the wellbore.
FUGITIVE EMISSIONS: Emissions from valves or leaks in process equipment of material storage areas
that are difficult to measure and do not flow through pollution control devices. They escape.
GAS PROCESSING PLANT: A facility designed to achieve the recovery of natural gas liquids from the
stream of natural gas which may or may not have been processed through lease separators and field
facilities. Also, to control the quality of the natural gas to be marked.
GATHERING LINES: The flow lines which run from several wells to a central lease or plant facility.
GEOLOGY: The scientific study of the origin, history and structure of the earth as recorded in rocks. A
person trained in geology is a GEOLOGIST. A Petroleum Geologist is primarily concerned with
sedimentary rocks where most of the world’s oil has been found.
GEOPHONES: The detectors used in seismic surveys to pick up sound waves reflected from sub-
surface strata.
GROUND WATER: The supply of fresh water found beneath the earth’s surface (usually in aquifers)
which is often used for supplying wells and springs. Because ground water is a major source of drinking
water, there is growing concern over areas where leaching agricultural or industrial pollutants or
substances from leaking underground storage tanks are contaminating ground water.
HALOGEN: Any of a group of five chemically related nonmetallic elements that includes bromine,
fluorine, chlorine, iodine and astatine.
HAZARD: A condition with the potential for causing an undesirable consequence. For a chemical for
instance, it is the potential the substance has for causing adverse effects at various levels of exposure.
A situation with a potential for human injury, damage to property, damage to the environment or some
combination of these.
HAZARDOUS MATERIAL: A material which may, upon exposure, constitute an identifiable risk to human
health or the natural environment. Hazardous material criteria are established in consultation with the
appropriate regulatory authorities.
HAZARDOUS WASTE: Any waste containing significant quantities of a substance which may present
danger to the life or health of living organisms when released into the environment or safety of humans or
equipment in disposal plants in incorrectly handled. Hazardous properties include toxic, carcinogenic,
HYDROGEOLOGY: The geology of ground water with particular emphasis on the chemistry and
movement of water.
HYDROLOGY: The science dealing with properties, distributions and circulation of water.
IMPACT: A change to the environment and the associated consequences for both humans and other
ecosystem components caused directly by the activities of product or service development and
production. Impacts include secondary and tertiary consequences with direct upstream links to primary
changes to environmental systems.
INCINERATION: Burning of certain types of solid, liquid or gaseous materials. A treatment technology
involving destruction of waste by controlled burning at high temperatures. e.g. Burning sludge to
remove the water and reduce the remaining residues to a safe, nonburnable ash which can be disposed
of safely on land, in some waters or in underground locations.
INJECTED GAS: High pressure gas injected into a formation to maintain or restore reservoir pressure
or otherwise enhance recovery.
INJECTION PUMP: A pump that injects chemicals into a flow-line system for the purpose of treating
emulsions or corrosion, or injects the ground for disposal or to enhance recovery.
INJECTION WELL: A well used to inject gas or water into an oil/gas reservoir rock in order to maintain
reservoir pressure during the secondary recovery process.
IN-SITU REMEDIATION: Remediation that can be done on site through advanced technology such as
soil cleaning.
KNOCK OUT: A kind of tank or vessel used to separate water from oil.
LANDFILL: A controlled site for disposal of wastes for land,run in accordance with safety and
environmental requirements laid down by a regulatory authority.
LAND TREATMENT: The controlled application of industrial wastes to the soil surface and the
incorporation of the waste into the upper soil zone in such a manner that, by using the natural capacity of
the soil system, the waste constituents are physically, chemically or biologically degraded, assimilated
and immobilized within the treatment zone.
LAYING DOWN TUBING: Pulling tubing, pipe or rods from the well and laying it on a pipe rack.
LEACHATE: A liquid that results from water collecting contaminants as it trickles through wastes,
agricultural pesticides or fertilizers. Leaching, particularly from landfills, may result in hazardous
substances entering surface water, ground water or the soil.
LEASE: A legal document that conveys to an operator the right to drill for oil and gas. The tract of land,
on which a lease has been obtained, where the producing wells and production equipment are located.
MANIFEST: A certificate or trip-ticket, usually comprising multiple copies, which accompanies a load of
transported waste so as to verify that it has reached its intended destination.
MATERIAL SAFETY DATA SHEET (MSDS): A compilation of information required on the identity of
hazardous chemical, health and physical hazards, exposure limits and precautions.
MIGRATION: The movement of oil from the area in which it has formed to a reservoir rock where it can
accumulate.
MINIMIZATION: Actions to avoid, reduce or in other ways diminish the hazards of waste at their source.
Recycling is, strictly speaking, not a minimization technique but is often included in such programs for
practical reasons.
MUD: The liquid that is circulated through the wellbore during rotary drilling and workover operations.
NATURAL GAS: A mixture of hydrocarbons and varying quantities of nonhydrocarbons that exists either
in the gaseous phase or in solution with crude oil in natural underground reservoirs.
NITRATE: A compound containing nitrogen which can exist in the atmosphere or as a dissolved gas in
water and which can have harmful effects on humans and animals. Nitrates in water can cause severe
illness in infants and cows.
OIL & GAS SEPARATOR: An item of production equipment used to separate the liquid components of
the well stream from the gaseous components.
OIL WELL: A well completed for the production of crude oil from at least one oil zone or reservoir.
PARAFFIN: Heavier paraffin-base hydrocarbons often form a waxlike substance called paraffin.
Paraffin may accumulate on the walls of tubing, flow lines and other production equipment, thus
restricting the flow of well fluids to the extent that it must be removed.
PERMEABILITY (of a reservoir rock): The ability of a rock to transmit fluid through the pore spaces - A
key influence on the rate of flow, movement and drainage of the fluid. There is no necessary relation
between porosity and permeability. A rock may be highly porous and yet impermeable if there is no
communication between pores.
PETROLEUM: Oil or gas obtained from the rocks of the earth by drilling down into a reservoir rock and
piping them to the surface.
PHASE 1 ENVIRONMENTAL SITE ASSESSMENT (ESA): The systematic process, as prescribed by the
standard, by which an assessor seeks to determine whether a particular property is or may be subject to
contamination. It does not involve the investigative procedures of sampling, analyzing and measuring
unless enhancements are agreed upon between the client and assessor. The term environmental audit
should not be used to describe a Phase 1 Environmental Site Assessment. As well, a Phase 1 ESA may
include a review of previously preformed environmental audits.
Phase I: A qualitative Environmental Site Assessment which does not involve any physical testing but is
based on historical and regulatory reviews as well as a visual inspection of the property.
Phase II: An Environmental Site Assessment which involves sampling and laboratory to determine the
extent, if any, of environmental contamination of the property.
Phase III: An Environmental Site Assessment which concentrates on the remedial actions necessary to
eliminate or minimize the environmental contamination and degradation of property,
PIG: A device inserted in a pipeline for the purpose of sweeping the line clean of water, rust or other
foreign matter. (Also known as GO DEVIL)
PITS, PONDS, or LAGOONS: Man made or natural depressions in a ground surface that are likely to
hold liquids or sludge containing hazardous substances or petroleum products. The likelihood of such
liquids or sludge being present is determined by evidence of factors associated with the pit, pond, or
lagoon, including, but not limited to, discolored water, distressed vegetation, or the presence of an
obvious wastewater discharge.
POLLUTANT: Generally, any substance introduced into the environment that adversely affects the
usefulness of a resource.
POROSITY (of a reservoir rock): The percentage that the volume of the pore space bares to the total
bulk volume. The pore space determines the amount of space available for storage of fluids.
POTABLE WATER: Water that is safe for drinking and cooking.
PRESSURE-RELIEF VALVE: A valve that opens at a preset pressure to relieve excessive pressures
within a vessel or line.
PRE-TREATMENT: Initial treatment of waste materials to make them safe to handle, or precondition
them for subsequent processing or disposal.
PREVENTION OF POLLUTION: Use of processes, practices, materials, or products that avoid, reduce
or control pollution, which may include recycling, treatment, process changes, control mechanisms,
efficient use of resources and material substitution.
PRIMARY TREATMENT: First steps in waste water treatment; screens and sedimentation tanks are
used to remove most material that floats or will settle. Primary treatment results in the removal of about
30 percent of carbonaceous biochemical oxygen demand from domestic sewage.
PRODUCTION: The yield of an oil or gas well. Also that branch of the petroleum industry that has to do
with bringing the well fluids to the surface and separating them, and with storing, gaging and otherwise
preparing the product for the pipeline.
PRODUCTION CASING: The last string of casing set in a well; the casing string set to the top or
through the producing formation and inside of which is usually suspending tubing string.
PRODUCTION PLATFORM: An offshore structure providing a central processing and disposition point
for fluids produced from wells on adjacent
PRODUCING and WELL PLATFORMS. The treated oil and gas is moved to shore through submarine
pipelines. Produced water is generally disposed of within the field.
QUALITY ASSURANCE: All the planned and systematic activities implemented within the quality system
and demonstrated as needed to provide adequate confidence that an entity will fulfil requirements for
quality.
QUALITY CONTROL: A system which measures the extent to which an audit is conducted according to
the objectives and scope of the audit, and the principles and practices contained in this standard.
Operational techniques and activities that are used to fulfil requirements for quality.
RAW MATERIALS: The total inputs for a subsystem including all material present in the product and
material found in losses due to emissions, scrap and off-spec products, and no-emission losses such as
moisture during a drying step.
RECYCLE: The process of reusing an item by converting it to another state or by reclaiming valuable
resources for another use.
RECYCLING: The retrieval of materials or products for re-use in their original form, or for re-processing
into products of similar composition.
RELEASE: Includes discharge, spray, inject, inoculate, abandon, deposit, spill, leak, seep, pour, emit,
empty, throw, dump, place and exhaust.
REMEDIAL ACTION: The actual construction or implementation phase of a Superfund site cleanup that
follows remedial design.
RESERVOIR: A subsurface porous and permeable rock body that contains oil and/or gas. Any natural
or artificial holding area used to store, regulate or control water.
REUSE: Using an item again for its original purpose of for a new purpose rather than throwing it away
without any treatment or modification.
RIG: The derrick, drawworks and attendant surface equipment of a drilling operation.
RISK ASSESSMENT: The qualitative and quantitative evaluation performed in an effort to define the
risk posed to human health and/or the environment by the presence or potential presence and/or use of
specific pollutants.
SALTWATER DISPOSAL: The method and system for the disposal of salt water produced with crude
oil. A typical system is composed of collection centers and disposal wells of which treated salt water is
injected into a suitable formation.
SCRUBBER: A vessel through which gas is passed to remove liquid and foreign matter.
SECONDARY CONTAINMENT: Refers to an area which is used to contain a spill or leak in case a
container ruptures or breaks. Storage tanks, under and aboveground, are often surrounded by
secondary containment.
SECONDARY TREATMENT: The second step to most public owned waste treatment systems in which
bacteria consume the organic parts of the waste. It is accomplished by bringing together waste, bacteria
and oxygen in trickling filters or in the activated sludge process. This treatment removes floating and
settleable solids and about 90 percent of the oxygen-demanding substances and suspended solids.
Disinfection is the final stage of secondary treatment.
SEISMIC SURVEY: A technique for determining the detailed structure of the rocks underlying a
particular area by passing acoustic shock waves into the strata and measuring the reflected signals.
SEPARATOR: A pressure vessel used for the purpose of separating gas from crude oil and water.
SHALE SHAKER: A vibrating or rotating screen which removes the coarse drill cuttings from the drilling
mud prior to recirculation.
SHOT HOLE SEISMIC METHOD: Seismic survey which uses a small explosion down a shallow
borehole to produce shock waves.
SHUT IN: To close valves on a well so that it stops producing; said of a well on which the valves are
closed.
SITE RECONNAISSANCE: Includes, but is not limited to, the site visit done in connection with such a
Phase I ESA.
SOLID WASTE: Any garbage, refuse, trash, dry sludge or material that is discarded or abandoned and
is intended for disposal. Technically, solid waste also refers to liquids and gases in containers.
SOUR CRUDE OIL (Sour Crude): An oil containing free sulfur or other sulfur compounds whose total
sulphur content is in excess of one percent.
SPACING: Distance between wells producing from the same reservoir (usually expressed in terms of
acres, e.g. 10 acre spacing)
STUFFING BOX: A packing gland; a chamber or “box” to hold packing material around a moving pump
rod, valve stem or wireline to prevent the escape of gas or liquids.
SURFACE CASING: The first string of casing to be set in a well. Its principal purpose is to protect fresh
water sands.
SURFACE WATER: All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams,
impoundments, seas, estuaries, etc.) And all springs, wells, or other collectors which are directly
influenced by surface water.
SUSPENDED SOLIDS: Small particles of solid pollutants that float on the surface of, or are suspended
in sewage or other liquids. The resist removal by conventional means.
SUSTAINABLE DEVELOPMENT: Development that meets the needs of the present without
compromising the ability of future generations to meet their own needs.
TERTIARY TREATMENT: Advanced cleaning of waste water that goes beyond the secondary or
biological stage. It removes nutrients such as phosphorus and nitrogen and most suspended solids.
THRESHOLD LIMIT VALUE (TLV): Represents the air concentrations of chemical substances to which
it is believed that workers may be exposed daily without adverse effects.
TOTAL SUSPENDED SOLIDS (TSS): A measure of the suspended solids in waste water effluent or
water bodies determined by using tests for “total suspended non-filterable solids”
TRAP (Geologic): An arrangement of rock strata or structures that halts the migration of oil and gas and
causes them to accumulate.
UNDERGROUND STORAGE TANK (UST): A tank located all or partially underground that is designed to
hold gasoline or other petroleum products or chemical solutions.
VAPOR RECOVERY UNIT: A facility for collecting stock or storage tank vapors to prevent their loss to
the atmosphere.
VENT: A connection in a vessel, line, or pump tp permit the escape of air or gas.
WATER FLOODING: One method of enhanced recovery in which water is injected into an oil reservoir
to force additional oil out of the reservoir rock and into the well bores of producing wells.
WATER WELL: A well drilled to obtain a fresh water supply to support drilling and production operations
or to obtain a water supply to be used in connection with an enhanced recovery program.
WASTE MINIMIZATION: Involves any technique, process or activity which either avoids, eliminates or
reduces waste at its source, usually within, but not limited to, the confines of the production unit, or
allows reuse or recycling of the waste for benign purposes. This is a technique for creating commercial
advantages while achieving compliance. All emissions to air, water and soil as well as energy
consumption should be considered as part of a waste minimization program.
WATER TABLE: The upper surface of ground water of regulated pollutants (usually expressed in
kilograms per unit output) after existing treatment processes.
WASTEWATER: Water that is or has been used in an industrial or manufacturing process. Water that
conveys or has conveyed sewage. Water that is directly related to manufacturing, processing, or raw
materials storage areas at an industrial plant. Wastewater does not include water originating on or
passing through or adjacent to a site, such as stormwater flows, that has not been used in industrial or
manufacturing processed, has not been combined with sewage, or is not directly related to
manufacturing, processing, or raw materials storage areas at an industrial plant.
WORKOVER: A process by which a completed production well is subsequently re-entered and any
necessary cleaning, repair and maintenance work done.
WORKING PAPERS: Written documentation of the work performed during an audit, including the
procedures followed, observations made, discussions held, and the conclusions reached by the auditor.
It is our mission to generate and carry out activities that will lead to the creation of
a more favorable environment for the development of the oil and natural gas
industry in Latin America and the Caribbean, by promoting:
Vision
Objectives
* To take care of the oil and natural gas industry’s public image.
Regional Association of Oil and Natural Gas Companies in Latin America and the Caribbean
Javier de Viana 2345 – CP 11200 Montevideo – URUGUAY
Phone: (598 2) 400 6993* Fax (598 2) 400 9207*
E-mail: arpel@arpel.org.uy
Internet web site: http://www.arpel.org