BALZAC THERMAL ELETRIC POWER PLANT

1

BALZAC SOUR GAS PROCESSING PLANT AND

THE BALZAC SULPHUR PROCESSING PLANT

(‘BALZAC GAS PLANT’)

APPLICATION TO

ALBERTA ENVIRONMENT

FOR

AMENDMENT OF

APPROVAL NUMBER: 155-02-00

FOR

DECOMMISSIONING, DISMANTLING, ABANDONMENT, REMEDIATION &

RECLAMATION OF THE BALZAC GAS PLANT

March 5, 2012

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INTRODUCTION ............................................................................................................................................. 5

3 (1) AN APPLICATION MUST BE MADE TO THE DIRECTOR AND MUST BE ACCOMPANIED

BY THE FOLLOWING INFORMATION RELATIVE TO THE ACTIVITY, THE CHANGE IN THE

ACTIVITY OR THE PROPOSED AMENDMENT, ADDITION OR DELETION OF THE TERM OR

CONDITION: .................................................................................................................................................... 8

A. APPLICANT INFORMATION ..................................................................................................................... 8 B. LOCATION, CAPACITY AND SIZE OF THE ACTIVITY ................................................................................. 9

1. Legal Land Description .................................................................................................................... 9 2. Relation to nearest town, city, village, and residents/users of the land. ........................................... 9 3. Geographical description of the surrounding topography (including a topographical map) and

relation to nearby watercourses................................................................................................................. 9 4. Gas Processing Capacity (Raw), Hydrogen Sulphide Processing Capacity, Sulphur Inlet Rate. .... 9 5. Sulphur Production Capacity, Liquid Hydrocarbon Production, Sulphur Storage Status, Bitumen

Processing Capacity, Other. ...................................................................................................................... 9 6. Material Balance. ........................................................................................................................... 10 7. Descriptive size of the affected area, leased area, and/or plant site (Le., hectares), or ................. 10 8. Physical dimensions of the plant site including a plant site map (i.e., plot plan) and number of

employees working at the facility. ............................................................................................................ 10

C. THE NATURE OF THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE

AMENDMENT, ADDITION OR DELETION, AS THE CASE MAY BE: ............................................... 13

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 13 3.1 Describe the change(s). .................................................................................................................. 13

3.1.1 HISTORY OF THE PLANT ................................................................................................................. 13 3.1.2 CURRENT PHASE OF THE PROJECT .............................................................................................. 13 3.1.3 FACILITIES TO REMAIN IN OPERATION DURING THE DRR PROJECT PHASE ..................... 15 3.1.4 FACILITIES TO REMAIN IN OPERATION DURING THE DLR PROJECT PHASE ..................... 17

3.2 Describe the affect that the change(s) may have on the environment. ........................................... 20 3.3 Describe the affect that the change(s) may have on the Environment Control Systems. ................ 20 3.4 Describe the implications, which the change(s) may have on the current approval. ..................... 20 3.5 Describe when the changes will take place. ................................................................................... 23

D. WHERE THE APPLICATION REQUIRES AN APPROVAL FROM THE ALBERTA ENERGY

AND UTILITIES BOARD OR THE NATURAL RESOURCES CONSERVATION BOARD IN

RELATION TO THE ACTIVITY, THE DATE OF THE WRITTEN DECISION IN RESPECT OF

THE APPLICATION ...................................................................................................................................... 23

1. DATE OF ALBERTA ENERGY AND UTILITIES BOARD (EUB) APPROVAL............................................... 23 2. APPROVAL NUMBER ............................................................................................................................ 23

E. AN INDICATION OF WHETHER AN ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

REPORT HAS BEEN REQUIRED ............................................................................................................... 23

1. WAS AN EIA REQUIRED? ..................................................................................................................... 23

F. COPIES OF EXISTING APPROVALS THAT WERE ISSUED TO THE APPLICANT IN

RESPECT OF THE ACTIVITY UNDER THIS ACT OR A PREDECESSOR OF THIS ACT ............. 23

G. THE PROPOSED OR ACTUAL DATES FOR CONSTRUCTION COMMENCEMENT,

CONSTRUCTION COMPLETION, AND COMMENCEMENT OF OPERATION .............................. 24

3.1 PROVIDE ACTUAL DATE FOR ORIGINAL COMMENCEMENT OF OPERATION, IF KNOWN. .......................... 24 3.2 PROVIDE PROPOSED EFFECTIVE DATE FOR "ACTIVITY CHANGE" AND/OR AMENDMENT. ..................... 24

H. A LIST OF SUBSTANCES, THE SOURCES OF THE SUBSTANCES AND THE AMOUNT OF

EACH SUBSTANCE THAT WILL BE RELEASED INTO THE ENVIRONMENT AS A RESULT OF

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THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE AMENDMENT, ADDITION OR

DELETION, AS THE CASE MAY BE, THE METHOD BY WHICH THE SUBSTANCES WILL BE

RELEASED AND THE STEPS TAKEN TO REDUCE THE AMOUNT OF THE SUBSTANCES

RELEASED. .................................................................................................................................................... 24

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 24 3.1 Provide a description of current substance releases. ..................................................................... 24 3.2 Describe the implications to the above description as a result of the Activity Change. ................. 24 3.3 Provide the final modified description that will result after the Activity Change is operational. .. 24

I. A SUMMARY OF THE ENVIRONMENTAL MONITORING INFORMATION GATHERED

DURING THE PREVIOUS APPROVAL PERIOD .................................................................................... 25

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 25 1. Only monitoring information on the affected parameters is required. ........................................... 25

J. A SUMMARY OF THE PERFORMANCE OF SUBSTANCE RELEASE CONTROL SYSTEMS

USED FOR THE ACTIVITY DURING THE PREVIOUS APPROVAL PERIOD: ................................ 25

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 25 3. Present the same information, as required above for Renewals, however, limit it to only those

environmental control systems affected by the Activity Change .............................................................. 25

K. THE JUSTIFICATION FOR THE RELEASE OF SUBSTANCES INTO THE ENVIRONMENT

AS A RESULT OF THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE AMENDMENT,

ADDITION OR DELETION, AS THE CASE MAY BE. ............................................................................ 25

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 25 2. Same as for new plants except the discussion should be limited to only those items which will be

affected by the Activity change. ................................................................................................................ 25

L. THE MEASURES THAT WILL BE IMPLEMENTED TO MINIMIZE THE AMOUNT OF

WASTE PRODUCED, INCLUDING A LIST OF THE WASTES THAT WILL OR MAY BE

PRODUCED, THE QUANTITIES AND THE METHOD OF FINAL DISPOSITION ........................... 26

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 26 3. Discuss the environmental aspects of the present approval which will be affected by the change(s).

26

M. ANY IMPACT, INCLUDING SURFACE DISTURBANCE, THAT MAY OR WILL RESULT

FROM THE ACTIVITY, THE CHANGE TO THE ACTIVITY OR THE AMENDMENT, ADDITION

OR DELETION, AS THE CASE MAY BE .................................................................................................. 27

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 27 3.1 Limit discussion to the extent and nature of the surface disturbance which is proposed by

construction, other impacts should be identified in the other relevant areas of this application form such

as section (k). ........................................................................................................................................... 27 3.2 Describe the change to surface disturbance both temporary and permanent caused by the "Activity

Change". .................................................................................................................................................. 27

N. CONFIRMATION THAT ANY EMERGENCY RESPONSE PLANS THAT ARE REQUIRED

TO BE FILED WITH THE LOCAL AUTHORITY OF THE MUNICIPALITY IN WHICH THE

ACTIVITY IS OR IS TO BE CARRIED ON OR WITH ALBERTA PUBLIC SAFETY SERVICES

HAVE BEEN SO FILED ................................................................................................................................ 28

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 28 4. Provide only if there is a change in plant status (i.e. convert from a sweet gas to a sour gas

processing plant) that necessitates a change. .......................................................................................... 28

4

O. CONFIRMATION THAT THERE ARE CONTINGENCY PLANS IN PLACE TO DEAL WITH

ANY UNEXPECTED SUDDEN OR GRADUAL RELEASES OF SUBSTANCES TO THE

ENVIRONMENT ............................................................................................................................................ 28

P. THE CONSERVATION AND RECLAMATION PLAN FOR THE ACTIVITY ........................... 29

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 29 3.1 Describe any topsoil conservation plans for any areas affected by the change, if applicable. .......... 29 3.2 A plan to prevent, remove or treat areas of contamination to within established guidelines

(Environmental Sciences Division of AENV). .......................................................................................... 29

Q. A DESCRIPTION OF THE PUBLIC CONSULTATION UNDERTAKEN OR PROPOSED BY

THE APPLICANT. ......................................................................................................................................... 29

APPLICATIONS FOR ACTIVITY CHANGE OR AN AMENDMENT ........................................................................ 29 3.1 Same as for New Plants ..................................................................................................................... 29

APPENDIX I – EXISTING AENV APPROVALS ....................................................................................... 32

APPENDIX II – PUBLIC CONSULTATION FACT SHEET .................................................................... 33

APPENDIX III – DECOMMISSIONING, REMEDIATION AND LAND RECLAMATION PLAN .... 34

APPENDIX IV – BALZAC POWER STATION MAPS ............................................................................. 35

APPENDIX V – PROPOSED 2012 GROUNDWATER MONITORING PROGRAM ............................ 36

Table 1. Company Information .............................................................................................. 8 Table 2. Approval Summary ................................................................................................ 23

Figure 1. Regional Aerial Photo of Location ....................................................................... 11

Figure 2. Aerial Photo of Balzac Gas Plant (2009) ............................................................. 12 Figure 3. Infrastructure Expected to Remain ....................................................................... 19

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INTRODUCTION

The BALZAC SOUR GAS PROCESSING PLANT (FOR THE PROCESSING OF NATURAL

GAS) AND THE BALZAC SULPHUR PROCESSING PLANT (“Balzac Gas Plant”) are operated

by Nexen Inc. (“Nexen”) of Calgary, pursuant to approval No. 6457, issued by the Energy and

Utilities Board (hereafter referred to as the Energy Resources Conservation Board (“ERCB)) and

Alberta Environment (“AENV”) approval 155-02-00.

The Balzac Gas Plant ceased operations permanently on April 28th, 2011 (“Plant Closure”).

Therefore, Nexen is submitting this amendment application for approval to decommission,

dismantle, remediate and reclaim the Balzac Gas Plant (“Plant”).

This amendment application is being prepared in accordance with the Applications for Sour Gas

Processing Plants and Heavy Oil Processing Plants - A Guide to Content (AENV 1999).

The Balzac Gas Plant is located adjacent to the Calgary's city limits, in LSD 7-2-26-29 W4M. Other

nearby communities includes the towns of Balzac and Airdrie, Alberta.

The Balzac Gas Plant was a sour, natural gas processing plant that receives gas streams from

surrounding well sites and produce specification sales gas with the recovery of propane, butane,

condensate, and sulphur. The operation used conventional gas processing units with inlet separation,

gas compression, amine sweetening (hydrogen sulphide (H2S) and carbon dioxide (CO2) removal),

refrigeration/dehydration, condensate stabilization, sulphur recovery, and LPG fractionation.

Propane and butane were stored in horizontal pressure tanks in the tank farm and were loaded into

truck or rail car for delivery to markets. Condensate was stored in tankage and transferred to the

Pembina Pipeline system for delivery to refineries. Sales gas was sent to the Trans Canada

Transmission pipeline system, and liquid (molten) sulphur was processed into a sulphur granulation

product (prilled) and shipped by rail to Vancouver. Enersul operated and owns the sulphur

granulation facility.

The sulphur granulation process was discontinued after May 2011.

Approximately eighty-one producing gas wells (“Balzac Field”) supplied the raw natural gas

mixture to the plant for processing. Most of the gas produced from the wells is considered "sour"

meaning naturally-occurring H2S is present. H2S content varies from well to well and from different

formations. Within the Balzac field, H2S in the produced sour gas varies from 0.6% to 42%.

In the Balzac Field, all Crossfield and Elkton pipelines have been shut in and purged with Nitrogen.

Basal Quartz pipelines were pigged with fuel gas. All Crossfield wells have been blinded at the

wellhead. Elkton wells and Basal Quartz wells have been shut-in as per ERCB requirements.

The Plant has been shut down in a safe, controlled fashion, equipment and piping was

decontaminated and any sources of energy, such as steam and electricity, isolated and shut off as

required. The shutdown was managed by the Shutdown, Decommissioning and Salvage (“SDS”)

team comprised of a group of operations, maintenance, environmental and safety personnel from the

Plant, in addition to contractors familiar with the Plant and experienced to execute work in a safe,

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efficient manner. Decommissioning activities to bring the Plant to a state of zero energy and make it

safe for demolition began in May, 2011 and finished December 2011.

Under Nexen’s current operating approval with Alberta Environment, Nexen is required to submit a

Decommissioning, Remediation and Land Reclamation Plan (“DLR”) amendment within six (6)

months of closure of the facility. Nexen submitted a draft amendment application dated September

12, 2011 which was reviewed by AENV with feedback provided. The current version of this

application incorporates changes to reflect the feedback from AENV. Approval of the DLR

amendment is expected in 2012.

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ABBREVIATIONS

ABSA Alberta Boilers Safety Association

AENV Alberta Environment

AMD Air Monitoring Directive

BalCAP Balzac Community Advisory Panel

BGP Balzac Gas Plant

BPS Balzac Power Station

DLR Decommissioning, Remediation and Land Reclamation Plan

DRR Demolition, Remediation and Reclamation

EPEA Environmental Protection & Enhancement Act

ERCB Energy Resources Conservation Board

ERP Emergency Response Plan

SDS Shutdown, Decommissioning and Salvage

SHA Sulphur Handling Area

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3 (1) An application must be made to the Director and must be accompanied by the following

information relative to the activity, the change in the activity or the proposed amendment,

addition or deletion of the term or condition:

A. Applicant Information

Table 1. Company Information

Company Name(s) Nexen Inc.

(Operator of Facility)

Head Office Address 801 – 7

th Avenue S.W.,

Calgary, Ab T2P 3P7

Plant Address Nexen Inc.

RR3, Site 17, Comp 16 Rockyview County, AB T4A 0P7

Contact Numbers

Head Office: P: 403-699-4000; F: 403-699-5800

Gas Plant Office: P: 403-226-3165 (General Inquiries)

Emergency: 403-226-0967

Application Due Date October 28, 2011

Contact Person for

Application

Mr. Todd Jorgensen-Nelson, C.E.T. Sr. Coordinator – HSE&SR

Balzac Gas Plant RR3, Site 17, Comp 16

Rockyview County, AB. T4A 0P7 Phone (403) 699-6978, Fax (403) 716-0691

[email protected]

Application Document

Completed by

Robert McCallum, P.Biol Environmental Coordinator

Technical & Operational Services

Signature Name / Title Date of Signature

Robert McCallum

TJN Stamp

Robert McCallum

Typewritten Text

Todd Jorgenson-Nelson Sr. Coordinator - HSE&SR

Robert McCallum

Typewritten Text

March 6, 2012

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B. Location, Capacity and size of the activity

1. Legal Land Description

07-02-026-29W4M

2. Relation to nearest town, city, village, and residents/users of the land.

The Balzac Gas Plant is located adjacent to Calgary's city limits, which are on

Township Road 260 and Range Road 291. Other nearby communities include the

town of Balzac which is located 4.8 km west and 2.4 km north of the Balzac Gas

Plant, and Airdrie which is approximately 7 km northwest of the Balzac Gas Plant.

There are approximately 222 residences included in the Balzac Gas Plant

Emergency Response Plan that include homeowners (acreage owners), businesses

and schools. (Figures 1, 2, 3)

3. Geographical description of the surrounding topography (including a

topographical map) and relation to nearby watercourses.

The Balzac Gas Plant is located on a rolling morainal plain within the Grassland

Natural Region of Alberta, where the dominant soils are Black Chernozems.

Generally, the topography is subdued with slopes ranging between 6% and 9%. The

local area has a few small seasonal, intermittent wetlands/sloughs, and McDonald

Lake, which is immediately to the west of the Balzac Gas Plant.

4. Gas Processing Capacity (Raw), Hydrogen Sulphide Processing Capacity, Sulphur

Inlet Rate.

Formerly: Raw gas processing capacity: 8,988 10

3m

3J/Day

Hydrogen sulphide processing capacity: 1,276 103m

3/D

Sulphur inlet rate: 1,000 tonnes/day

Currently :

Raw gas processing capacity: 0 103m

3J/Day

Hydrogen sulphide processing capacity: 0 103m

3/D

Sulphur inlet rate: 0 tonnes/day

5. Sulphur Production Capacity, Liquid Hydrocarbon Production, Sulphur Storage

Status, Bitumen Processing Capacity, Other.

Formerly:

Sulphur Production Capacity: 1,000 tonnes/day

Liquid Hydrocarbon Production Capacity (LPG Unit - LPG numbers are

based on 215,474 MSCFD inlet gas at 14.4 PSIA and 60°F):

Propane - 75,580 U.S. gallons/day

Butane - 54,739 U.S. gallons/day

Condensate - 58,976 U.S. gallons/day

------------------------------------------------------------

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Production at the Balzac Gas Plant in 2010 was as follows:

Sulphur production: 84,903 tonnes/year

Raw Gas production: 438,755 E3m

3

Sales Gas production: 267,293 E3m

3

Propane production: 16,053 m3

Butane production capacity: 12,507 m3

Condensate production: 22,263 m3

Current production volumes: 0 m3

Sulphur storage status - the East Sulphur Basepad and West Sulphur Basepad

currently contain approximately 40,000 tonnes of recoverable sulphur.

6. Material Balance.

Not Applicable

7. Descriptive size of the affected area, leased area, and/or plant site (Le., hectares),

or

See 8.

8. Physical dimensions of the plant site including a plant site map (i.e., plot plan) and

number of employees working at the facility.

Nexen, along with its partners, own Section 2-26-29-W4M. The Balzac Gas Plant

occupies approximately 426 hectares within that Section. As of January 1, 2011 the

Balzac Gas Plant employed 74 people.

Due to current cessation of plant operations:

Preliminary staffing for the start of 2012 is as follows:

Number of employees on site full time: 14

Calgary based employees, part time: 10

Calgary based employees, on-site part time: 10

Contract employees, full time on-site: 4

Contract employees, part time on-site: 2

Contract personnel: as needed and currently

unknown

Asbestos abatement personnel: 60-70 contract workers

from March to October

2012.

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Image Date = 14/09/2008

High Pressure Pipelines and Wells current to November 30, 2009 *** Low Pressure Pipelines current to November 1, 2005

Figure 1. Regional Aerial Photo of Power Station Location.

N

Compaq_Owner

Text Box

Balzac Gas Plant

Compaq_Owner

Text Box

City of Calgary International Airport

Compaq_Owner

Text Box

Highway 2

Compaq_Owner

Text Box

City of Calgary boundary

MCDONALD

LAKE

226-29-4

COOLING /BLOWDOWN

PLANTMAINTENANCE

INLETCOMPRESSION

/ SALES

CONDENSATE STORAGE AREA

LPG /CONDENSATE

LOADOUT

SULPHUR BLOCK / BASEPAD

SULPHURPLANT

OFFICE / CONTROL ROOM

PROCCESSAREA

LPGUNIT

POWERSTATION

SULPHUR VAT POND

SULPHURHANDLINGFACILITY

2-2 PITS /TREATMENT

AREA

HOLDINGPOND

SOUTHEASTPROCESS

POND

TURBODISCHARGEPIPE POND

APPROX.LOCATION OFBORROW PIT

SW DUGOUT

COOLINGPLANT

COOLINGPLANT

CAUSTIC PUMP HOUSE

POWERSTATION

SOUTHWESTQUADRANT

BONEYARD/ FIELD

MAINTENANCE 2

FIRE WATERRESERVOIR

SOUTHLANDFILL

EVAPORATIONPOND

SOUTHEASTQUADRANT

2-2WELLPAD

DRILLINGMUD SUMP

NORTHLANDFILL

RIPARIAN /SHORELINE

FIREWATERRESERVOIR

OPEN DRAINCOLLECTION

POND

0 10050Meters

servicesAuthor: L. TulissiGIS Analyst : M. JanickDept. : GIS Services

Date: March 3, 2011File No: A12327.mxd

NEXEN INC. 801-7th Ave S.W. Calgary, AB. Canada T2P 3P7T. 403.699.4000 www.nexeninc.com

BALZAC PLANT

Nexen Inc.Canadian Oil & Gas Division

Scale: 1:3,500

±

LegendPlant Dispositions

13

C. The nature of the activity, the change to the activity or the amendment,

addition or deletion, as the case may be:

Applications for Activity Change or an Amendment

3.1 Describe the change(s).

3.1.1 HISTORY OF THE PLANT

Construction of the Balzac gas plant began in April 1961. At the time, the plant was known as the

Petrogas plant, for Petrogas Processing Ltd., a separate company set up with numerous partners

including Canadian Occidental Petroleum (now Nexen). The Petrogas operating structure, which

had become inefficient, was collapsed in 1995 and reverted to a conventional joint venture system.

After eight short months of construction, first gas was processed in November 1961. Through the

’60s and ’70s the plant went through a series of expansions but depressed markets in the mid-’80s

forced a decommissioning of part of the plant. Over a 15-year period beginning in the 1980s, Nexen

tried five times to combine the production from sour gas plants owned by other companies. There

was renewed optimism in 2006 when Nexen undertook an ambitious strategy to license 15 new sour

gas wells and five new pipelines. Unfortunately, results from the first wells drilled were

disappointing and the project was cancelled. In 2010, the Plant was coming up to the 50th year of

operation, facing poor market prices, high repair costs and declining production from its wells, all

partners agreed to retire the Balzac Gas Plant in 2011.

In addition to declining production, urban encroachment was another factor considered when

determining the future of the plant. In 1961, Calgary’s population was 250,000. Today about 1.3

million people live in the Calgary area, and the Balzac gas plant is no longer isolated from the city.

Some of the gas wells are now in residential communities.

More than 3.5 trillion cubic feet of natural gas and millions of tons of sulphur have been processed

over the past 50 years. The plant and the gas fields – covering approximately 400 square kilometres

(154 square miles), with 300 kilometres (186 miles) of pipelines and 120 wells – have run safely and

efficiently since day one with an impeccable safety record.

The plant ceased operations permanently on April 28th, 2011. Nexen no longer processes sour

natural gas at the Balzac Gas Plant and is applying to AENV for approval to shutdown,

decommission, salvage, remediate, and ultimately reclaim the BGP.

3.1.2 CURRENT PHASE OF THE PROJECT

After the plant stopped producing gas in late April 2011, the abandonment process began in the

plant and field (May 2011). The Shutdown, Decommissioning and Salvage (“SDS”) phase of the

project (this means the Plant was prepared, cleaned and its various systems de‐energized) was

executed by the SDS team from May to December 2011. The SDS project dismantled, removed or

demolished only to the extent required by the work of shutdown and decommissioning as well as the

pursuit of any salvage opportunities that may arise while the SDS project is ongoing.

14

Items available for immediate disposition and salvage were identified and the removal process has

commenced and will continue into 2012.

In December 2011, the Project was turned over to the Demolition, Remediation and Reclamation

phase (“DRR”). This DRR phase will include demolition of the facilities, remediation of the soil

and ultimately reclamation of the site. Apart from wastes which were produced by the SDS

execution and other wastes which must be disposed of to make the Plant safe for dismantling and

demolition, most salvage and waste activities will be executed by the DRR project.

Disposition of select pieces of equipment under the SDS phase will occur as per Nexen’s EPEA

Approval Amendment No. 155-02-06, issued on July 28, 2011, which authorized the removal of

selected equipment as described in that application and approval.

Guidelines for how the various phases of the work will be executed, from planning to physical

removal and disposal, are currently being developed so that the various assets are removed and

disposed of in a safe, environmentally responsible and cost effective manner.

A preliminary list of BGP assets has been developed. A master asset list of all BGP assets includes

only the major equipment. Spare parts, inventory, tools, furniture, etc. are on separate lists. In order

to maximize asset value, offset future demolition/disposal costs and reduce the amount of waste sent

to landfills, a condensed list of assets and spare parts inventory deemed to be in good condition was

offered to interested parties for transfer or sale.

Where an asset did not/does not sell for reuse an attempt will be made to recycle the asset by selling

it for scrap. If the scrap value cannot be realized for an asset, it will be sent to a landfill. Scrap and

waste disposals will be recorded in a Nexen database.

The priority for asset disposition is:

Transfer/sell for reuse;

Sell for scrap / recycle;

Donate;

Landfill (this categorization will only be made after reasonable investigations into

options for recycling traditional waste streams. Nexen will investigate these options

as waste streams are further identified.

Any equipment leaving the site (working component, scrap or waste) will be documented and

appropriate updates will be made to internal tracking systems and the Alberta Boilers Safety

Association (“ABSA”) (where applicable).

Nexen has implemented contractual mechanisms to ensure that equipment (i.e. tanks) that previously

contained potentially hazardous materials/wastes were/are identified to buyers as a component of the

contract and documentation. Nexen will/has worked with reputable buyers to ensure safe and legal

transport and use of the disposed items, however once the equipment leaves the BGP, Nexen cannot

control 3rd

party buyer end use of the disposed equipment.

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3.1.3 FACILITIES TO REMAIN IN OPERATION DURING THE DRR

PROJECT PHASE

In order to maintain existing environmental controls, safety controls, and operational requirements

for infrastructure fundamental to the DRR project, the following facilities are to remain in operation

during the DRR project phase:

1. Diesel Fire Water Pumps (2 Pumps PM-18-35 & PM-18-1522.

2. Electric Fire Water Pump (18-1516-01).

3. Double Lined Flare Ponds (Open Drain Collection Ponds) – two compartments (38-2802 &

38-2803). Water from thes ponds is sent to an approved disposal well.

i. Flare Pond Pump (28-1520) - Pump associated with pond

4. Chemical Storage Tanks (2) (38-1909 & 38-1910) c/w containment.

5. Miscellaneous small pumps around the Plant for moving surface water.

6. Sulphur Handling Area (SHA) System – all water treated in sulphur basepad area - tank and

lined pond:

i. Lined Acid Water Containment Pond;

ii. Caustic Tank (SV-19-20);

iii. Weeping Tile Pump (PM-18-34);

iv. Pond Discharge Pumps (PM-18-32, PM 18-33);

v. Crusher Pump (PM-18-31);

vi. Sulphur Block Area Surface Runoff Collection Pond;

7. Groundwater Remediation System (LPG GW/Lean Oil Collection):

i. Wilden Air Operated Pump or equivalent; currently operated by portable gas-fired

operated compressor.

ii. Lean Oil Storage Tanks (SV-19-21, SV-19-22, SV-19-23, SV-19-11).

8. Blowdown Holding Ponds: Currently the blowdown holding ponds capture surface water

runoff that occurs as a result of precipitation in the immediate vicinity of the Blowdown

Ponds. During the DRR project phase, runoff will continue to be managed in accordance

with the current approval. The existing infrastructure used to manage surface water runoff

and diversions to the ponds will remain in place. However, all former inlet systems to the

blowdown ponds have been isolated. Only surface water from the immediate area around

the blowdown ponds will enter the blowdown ponds which is now classified as industrial

runoff (developed Area 2 and changed in approval 155-02-06 from Industrial Wastewater to

Industrial Runoff). Blowdown Ponds no longer used to store Process Wastewater. Water in

the blowdown ponds will continue to be sampled prior to release as per the amended AENV

approval 155-02-06.

9. Sub-station #8 complete with a diesel operated Emergency Generator (41-1804): required

to provide power to incinerator stacks for lights as per NAV Canada requirements, power to

16

the on-site abandonment and reclamation offices, shop & warehouse, in addition to the three

maintenance shacks. The single Emergency diesel generator to stay operational.

10. Pipelines:

i. Fuel Gas Pipeline to the Field (timeline for operation is currently undetermined);

ii. Disposal Water Pipeline to Disposal Well 10-36-25-01 W5M. (timeline for

operation dependent on Disposal Well operations);

iii. Water Supply line to the BGP;

iv. Fuel gas line, Water Supply and Water Disposal to and from the Balzac Power

Plant;

v. Firewater Lines located on the Plant site.

11. Cathodic protection on remaining pipelines;

12. All Building Foundations and/or Concrete Pads Used to Support Equipment: During the

salvage component of the SDS phase, equipment was/is being removed for sale. Some of

that equipment was/is situated on concrete support pads. During the DRR phase of the

project, remaining pieces of equipment, facilities, buildings, piping, etc… will be

demolished and removed. Following the demolition and removal of equipment, Nexen will

strive to leave all foundations and concrete pads in place until the remediation phase of the

DRR project begins. If concrete at surface is in the way of equipment removal then activities

may be undertaken to remove surface concrete for access purposes only. Subsurface

concrete associated with these specific projects would then be removed at a later date. Both

the Dismantling and Remediation processes require separate and unique management

techniques, which are easier to manage separately. Therefore, the intent is NOT to leave

foundations and pads in long term but to accomplish two things:

i. Avoid disturbance of underlying soils and materials that may have been potentially

affected by contamination. This will allow Nexen to fully determine appropriate

remediation processes at these numerous locations prior to disturbance of the

foundations and pads. This will allow Nexen to implement appropriate

management, safety and remediation protocols at that time.

ii. Avoid creation of open holes, pits or excavations that would then become

workplace hazards to personnel completing demolition components. Nexen has

completed a risk analysis and hazard assessment of the removal of the foundations

or concrete pads. It was determined that in order to reduce safety hazards on the

project site, minimizing disturbed ground or open excavations is desirable.

As a function of the safety/risk protocols, work permits will be issued for all work

completed by a contractors. The Work Permits are intended to ensure potentially

hazardous work is carried out under safe working conditions. The permit system is

a two-way arrangement and the responsibility for taking special precautions rests on

both the issuer and the receiver of the permit. Prior to starting work contractors are

expected to discuss work permit requirements with the Nexen representative. When

a work permit is issued from an area other than at the immediate work site an

agreement will be made between the two parties regarding who will be responsible

to perform the site hazard assessment prior to work starting and which hazard

assessment form will be used to document the assessment.

17

Non-Routine tasks shall also be subject to a Task Risk Assessment (TRA) and Task

Hazard Assessment (THA). In the case of non-routine tasks, the process takes place

immediately prior to starting the task. The process includes the following:

1. Perform a TRA using the Task Risk Assessment Form;

2. If the Task risk identified is MEDIUM or higher, perform a THA using the

Task Hazard Assessment form;

3. After completing the THA and identifying controls, re-assess the risk of the

task and note the residual risk; and,

4. If the residual risk is MEDIUM or HIGH, The Business Unit Manager, or

their designate, and the HSE Coordinator/Advisor must make the decision and

document whether to proceed or not proceed with the task.

13. Balzac Power Station and associated infrastructure captured under the Balzac Power Station

AEPEA Approval # 136858-00-00.

14. Nexen is currently evaluating the Disposal Well (ERCB - Approval 7079B) located at 10-

36-25-01 W5M. The well is currently shut-in until an analysis of well is completed. There is

a potential that the disposal well will continue to operate after it has met the ERCB’s

regulatory conditions. AENV will be updated accordingly.

15. Some tanks will be left on site for the possible storage of water during non-freezing time

frames. The decision on what tanks may stay is still being reviewed. Any and all tanks

that will be used at various locations (TBD) around the BGP site during upcoming

operations will meet ERCB D55 requirements/regulations.

3.1.4 FACILITIES TO REMAIN IN OPERATION DURING THE DLR

PROJECT PHASE

Following decommissioning and dismantlement, Nexen will implement a remediation and

reclamation management program. This program is referred to as the Decommissioning,

Remediation and Land Reclamation Plan (“DLR”) (The DLR Plan is provided in Appendix III).

The objectives of this Plan are:

To abandon in place below ground facilities such as pipelines that are no longer required as

per ERCB Pipeline regulations (AR 91/2005 PIPELINE REGULATION, Part 10);

To analyze and characterize the existing site conditions of the facility and its surroundings

with respect to potential contamination and remediation requirements;

To characterize and quantify any identified site contamination;

To develop a remedial action plan for the site; and,

To develop a surface reclamation plan for the site based upon project end land use scenarios

and expected requirements to meet equivalent land capability based upon end land use.

During the DLR phase of the Project, and following successful remediation and reclamation to an

approved end land use, the following infrastructure is expected to remain in place (FIGURE 3):

1. Balzac Power Station and associated infrastructure captured under the Balzac Power Station

AEPEA Approval # 136858-00-00.

http://www.ercb.ca/docs/requirements/actsregs/pl_reg_091_2005.pdf

18

2. Pipelines:

i. Fuel Gas Pipeline to the Field indeterminate;

ii. Disposal Water Pipeline to Disposal Well 10-36-25-01 W5M. (dependent on

Disposal Well operations);

iii. Water Supply line to the BGP (Balzac Gas Plant);

iv. Water Supply to the BPS (Balzac Power Station);

v. Water Disposal line from BPS (Balzac Power Station);

vi. Fuel gas line to the BPS (Balzac Power Station);

MCDONALD

LAKE

226-29-4

PipelineR/W (031

0629)

PipelineR/W (031 0391)

GasPipeline R/W (4609

JK)

Pipeline R/W(791

0816)

Gas Pipeline R/W(851

0253)

Gas TransmissionLine R/W(299 JK)


Oil PipelineR/W (754

JK)


PipelineR/W

(1547 JK)


PipelineR/W (101

2606)

Pipeline R/W(502 JK)




CanadianPacific Railway

(871 JK)

Pipeline R/W(081

5893)

PipelineR/W (081

3328)


0816)

PipelineR/W

(500 JK)

Pipeline R/W(500JK)

Gas PipelineR/W

Gas PipelineR/W

Admin Building

Power Station

FiberOptic Pipeline

(10m R/W)

FiberOptic Pipeline (10m

R/W)

Building

Pipeline R/W

PowerlineR/W

PowerlineR/W (9012327

UR/W)

Pipeline R/W

Well Site 2-2

PipelineR/W (931

2570)

0 100 200 30050Meters

±

LegendDisposition - Operator

Atco

Canadian Pacific Railway

City of Calgary

Fortis

Nexen

Pembina

Telus

services

Nexen Inc.


BalzacFigure 3

Existing InfrastructureExpected to Remain

Author: R. McCallumGIS Specialist: A. JackDept: GIS Services

Date: November 24, 2011Updated: February 6, 2012File No : CA13581.mxd

NAD 1983 UTM Zone 12NProjection: Transverse Mercator

Imagery provided by ValtusDate Collected: September 22, 2009VISTA Alberta UTM 12 0.3m 2009

Scale: 1:2,500

20

3.2 Describe the affect that the change(s) may have on the environment.

After plant closure Nexen will no longer be processing sour natural gas. Air emissions associated

with sour gas processing will be eliminated. Industrial wastewater and domestic wastewater

emissions will ultimately be eliminated. Upon successful dismantling, remediation and reclamation

at the Balzac Gas Plant, land use will be restored to the appropriate equivalent land capability or end

land use appropriate for that time.

3.3 Describe the affect that the change(s) may have on the Environment Control

Systems.

Environmental control systems for air emissions will no longer be required. Upon successful and

approved remediation and reclamation at the Plant, all environmental control systems (including

industrial wastewater and industrial runoff) will be eliminated.

3.4 Describe the implications, which the change(s) may have on the current

approval.

This application document is being submitted pursuant to Terms 5.1.1 to 5.3.2 of the current

approval 155-02-00.

The approval(s) will require amendment to remove all operational, monitoring and reporting

requirements associated with the Plant as follows:

AMENDMENTS REQUESTED AS A RESULT OF THIS APPLICATION

Nexen requests that the following monitoring/reporting clauses in the current approval (155-02-00)

be removed or amended as they apply specifically to an operating facility:

Terms 4.6.1 to 4.6.7 – Groundwater monitoring. As per this amendment a modified

Groundwater Monitoring Program is being proposed. (See Proposed 2012 Groundwater

Monitoring Program - Appendix V for further information). The rationale for this request is

that Nexen has collected a significant volume of data on groundwater characteristics since

1992. This existing data will allow Nexen to determine remediation options and methods

appropriate for plant decommissioning. Furthermore, Nexen believes that the intent of the

Groundwater monitoring program was/is to delineate impacts and understand groundwater

characteristics. Nexen is confident that this intent has been and will continue to be fulfilled.

In light of the Plant decommissioning, some monitoring wells are of lesser importance to

this aforementioned intent. It should be noted that during Plant decommissioning and

remediation of the area, several wells installed near facilities will be removed. These

monitoring wells will need to be properly abandoned. Nexen will of course continue to

monitor groundwater wells that are on the periphery of either the plant or areas undergoing

decommissioning or remediation but request an amendment to the groundwater monitoring

program.

21

Groundwater conditions at the Balzac Sour Gas Processing Plant (Plant) have been

documented in great detail through monitoring from 1992 to 2011. The main

findings of the groundwater monitoring include:

generally, natural groundwater quality in the Plant area is

of poor quality as indicated by high sulphate and total

dissolved solids (TDS) concentrations;

groundwater flow velocities outside of the process area are

low, in all three monitored groundwater zones, primarily

due to low hydraulic gradients;

groundwater quality, including in zones of contamination,

is relatively stable with small seasonal and annual

variability; and

inorganic and organic groundwater impacts related to Plant

operation identified within the process area, ponds and

adjacent areas are aerially stable and have not expanded

greatly over the monitoring period.

Considering the significant hydrogeological information available and the Plant

decommissioning, a major revision in the forthcoming groundwater monitoring

program is recommended. Proposed changes to the 2012 program include:

reduction in groundwater monitoring frequency;

reduction in the number of monitoring wells to be monitored;

reduction in analytical schedule; and

concentrating monitoring activities around the process area and

perimeter “C” wells.

The proposed groundwater monitoring program would include sampling once a year

in the spring, instead of spring and fall sampling, with the number of monitored

wells reduced. To address operational issues during the 19 year history of

groundwater monitoring, several monitoring wells were installed in relatively close

proximity to each other, often duplicating and/or confirming information obtained

from existing wells. These expansions to the monitoring network were required at

the time of installation. However, in view of the Plant decommissioning, some

monitoring wells are of lesser importance. It should be noted that during Plant

decommissioning and remediation of the area, several wells installed near facilities

will be removed. These monitoring wells should be properly abandoned.

Monitoring wells selected for continued monitoring should be sampled and tested as

follows:

laboratory analysis for benzene, toluene, ethylbenzene, xylenes

(BTEX) and petroleum hydrocarbon (PHC) fractions F1 and F2

and amines; and

field measured parameters including depth to groundwater

surface, temperature, electrical conductivity (EC) and pH. If

significant changes in EC and/or pH are measured as compared

to historical field measurements, a sample should be submitted

for routine potability analysis for the well in question.

Otherwise, laboratory testing for main ions and dissolved

metals should be discontinued.

22

Terms 4.7.1 to 4.7.5 – Soil monitoring. Conditions as outlined in amended approval 155-

02-05 regarding a date change for soil monitoring submission dates;

TERMS AND CONDITIONS EXPECTED TO REMAIN IN FORCE

Nexen expects the following conditions will remain in place during the demolition, remediation and

reclamation components of the Project:

Term 4.1.2: As amended in approval 155-02-06;

Term 4.1.19: As amended in approval 155-02-06;

Term 4.2.1: The approval holder shall not release any substances from the plant to the

surrounding watershed except as authorized;

Term 4.2.3 Industrial wastewater that is collected in the Double Lined Open Drain

Collection Pond shall only be disposed as follows:

(a) to an Alberta Energy and Utilities Board (EUB) approved disposal well; or,

(b) to an Alberta Energy and Utilities Board (EUB) approved Waste Processing

and Disposal Facility; or

(c) as otherwise authorized in writing by the Director.

Term 4.2.6: As amended in approval 155-02-06

Term 4.2.7: As amended in approval 155-02-06.

Term 4.2.8: As amended in approval 155-02-06.

Term 4.2.9: As amended in approval 155-02-06, including 4.2.9.1

Term 4.2.10: As amended in approval 155-02-06,





Term 4.4.1 All domestic wastewater shall be directed to a septic tank with subsequent

disposal to an approved municipal wastewater treatment system.

Terms 4.7.6 and 4.7.7 – Sampling standards to remain.

Terms 4.7.8 to 4.7.16 – Soil Management Program. Conditions as outlined in current

approval will be followed.

23

3.5 Describe when the changes will take place.

The plant ceased operations permanently on April 28th, 2011. Upon submission of this amendment

application, Nexen is hopeful that dismantling activities may commence in 2012. The exact date of

commencement will be dependent upon AENV review and approval timelines however general time

periods are as follows (Table 2):

Table 2. Approval Summary

Approval Number Application Number Original Effective Date Expiry Date of

Original Approval

155-02-00 008-155 October 31, 2005 September 30, 2015

155-02-01 014-155 September 17, 2007 September 30, 2015

155-02-02 015-155 February 29, 2008 September 30, 2015

155-02-03 017-155 July 23, 2010 September 30, 2015

155-02-04 016-155 January 14, 2011 September 30, 2015

155-02-05 Not Provided March 9, 2011 September 30, 2015

155-02-06 019-155 July 28, 2011 September 30, 2015

D. Where the application requires an approval from the Alberta Energy and

Utilities Board or the Natural Resources Conservation Board in relation to the

activity, the date of the written decision in respect of the application

1. Date of Alberta Energy and Utilities Board (EUB) Approval

The date of the ERCB Facility Licence for the Balzac Gas Plant is June 28, 2007.

2. Approval Number

Licence No. F3645.

E. An indication of whether an environmental impact assessment (EIA) report has

been required

1. Was an EIA required?

An Environmental Impact Assessment was not required for initial licensing of the facility.

F. Copies of existing approvals that were issued to the applicant in respect of the

activity under this Act or a predecessor of this Act

Refer to APPENDIX I – EXISTING AENV APPROVALS for copies of existing approvals.

24

G. The proposed or actual dates for construction commencement, construction

completion, and commencement of operation

3.1 Provide actual date for original commencement of operation, if known.

The construction of the Balzac Gas Plant began in April 1961. The first sales gas product was

delivered in November 1961.

3.2 Provide proposed effective date for "Activity Change" and/or

Amendment.

Nexen would like to request an effective date for the amendment as 6 months from submission date

of this application.

H. A list of substances, the sources of the substances and the amount of each

substance that will be released into the environment as a result of the activity,

the change to the activity or the amendment, addition or deletion, as the case

may be, the method by which the substances will be released and the steps

taken to reduce the amount of the substances released.


3.1 Provide a description of current substance releases.

As the Plant has ceased operations, currently there are no exhaust system releases except from:

diesel fired emergency generator exhaust stack; and,

two diesel fired firewater pump exhaust stacks.

Fugitive emissions from sulphur base pad, including AMD soils – measures sulphur deposition and

dust and potential fugitive for demolition and remediation and reclamation phases.

Surface water runoff and domestic wastewater as per current approvals.

3.2 Describe the implications to the above description as a result of the Activity

Change.

No change to the above description.

3.3 Provide the final modified description that will result after the Activity Change

is operational.

Upon successful Shut-down, decommissioning, dismantlement, and remediation the land will be

reclaimed to support equivalent land capability while considering end land use strategies that may be

applicable. As such, no substance releases will occur.

25

I. A summary of the environmental monitoring information gathered during the

previous approval period

Nexen has conducted numerous air quality, soils and groundwater investigations at the facility since

1990. Please refer to the Decommissioning, Remediation and Land Reclamation Plan (Appendix

III) which summarizes this information in detail.


1. Only monitoring information on the affected parameters is required.

Refer to Decommissioning, Remediation and Land Reclamation Plan (Appendix III).

J. A summary of the performance of substance release control systems used for

the activity during the previous approval period:



3. Present the same information, as required above for Renewals, however, limit it to

only those environmental control systems affected by the Activity Change

Not Applicable.

K. The justification for the release of substances into the environment as a result

of the activity, the change to the activity or the amendment, addition or

deletion, as the case may be.

Not Applicable.


2. Same as for new plants except the discussion should be limited to only those items

which will be affected by the Activity change.

Not Applicable.

26

L. The measures that will be implemented to minimize the amount of waste

produced, including a list of the wastes that will or may be produced, the

quantities and the method of final disposition


3. Discuss the environmental aspects of the present approval which will be affected by the

change(s).

Nexen is developing a Waste Management Plan to handle wastes associated with the various phases

of this Project.

Nexen Inc. (NEXEN) is committed to demonstrating continuous improvement in reducing the

generation of waste from its operations, beneficially reusing or recycling materials that might

otherwise end up in the waste stream. Nexen will properly store, handle, and dispose of those

wastes that remain in accordance with Provincial or Federal regulations.

Active waste minimization is forefront, when the proper waste handling techniques are employed.

NEXEN is committed to ensuring compliance with regulations, as well as ensuring protection of the

environment when dealing with its waste products.

NEXEN is also committed to properly training all personnel who handle wastes and those

responsible for their supervision.

To actively pursue these commitments, NEXEN is developing a Waste Management Plan to ensure

compliance with all associated environmental regulations. The plan will serve as a valuable tool for

the collection of data, providing guidance to employees, identification of future technology needs

and requirements, as well as reducing risk exposure, and identifying the company’s operating

procedures and standards.

The plan is being designed based on discussions with operations and environmental personnel from

NEXEN. Site visits to a representative sample of facilities may be conducted or third party audits

may be obtained and reviewed to ensure waste facility audits are in place and reviewed. The plan

will ensure regulatory compliance.

This waste management plan is comprised of the following components:

Identification

Characterization and classification

Handling

Storage

Treatment

Disposal

Manifesting

Tracking and record keeping

Reporting

27

The principles of waste minimization will be followed closely in the plan. This is both an

environmental consideration as well as an economical one. Recognizing opportunities to reduce

waste volumes as well as the elimination of certain wastes will enable NEXEN to ensure that it is

operating in an environmentally safe and responsible manner. This will reduce the liabilities

associated with the handling, storage and disposal of dangerous oilfield wastes (DOWs).

Nexen will continue to follow its Waste Management Plan during the transition into the demolition

phase.

Wastes expected to be handled include (list not exhaustive):

Domestic-type wastes (non-hazardous, "garbage")

Salvage metals, i.e. Iron, Copper, Tin, Steel

Construction waste (general building materials, e.g. concrete, plaster, wood, etc.)

Glass and ceramics

Asbestos-containing or contaminated materials (insulations, building materials, abatement

waste materials)

Asbestos-contaminated water (filtered)

Synthetic (non-asbestos) insulating materials

Lead-acid batteries

Mercury, liquid in instrumentation

Mercury lamp bulbs and tubs

PCB Transformer oil (potential)

PCB-containing lamp ballasts (potential)

Ozone-depleting refrigerants (HVAC units)

Other Dangerous Oilfield Wastes ("DOW"), e.g. residual chemicals or contaminated

materials as identified during demolition

M. Any impact, including surface disturbance, that may or will result from the

activity, the change to the activity or the amendment, addition or deletion, as

the case may be


3.1 Limit discussion to the extent and nature of the surface disturbance which is

proposed by construction, other impacts should be identified in the other

relevant areas of this application form such as section (k).


3.2 Describe the change to surface disturbance both temporary and permanent

caused by the "Activity Change".


28

N. Confirmation that any emergency response plans that are required to be filed

with the local authority of the municipality in which the activity is or is to be

carried on or with Alberta Public Safety Services have been so filed


4. Provide only if there is a change in plant status (i.e. convert from a sweet gas to a sour

gas processing plant) that necessitates a change.

The current version of the Nexen Inc. Balzac Complex Emergency Response Plan (ERP)

was formally approved by the ERCB on November 17, 2011. The plan meets the

requirements of ERCB Directive 71: Emergency Preparedness and Response Requirements

for the Petroleum Industry, 2008 Edition.

The Balzac Gas Plant ERP was updated and re-issued in October 19, 2011.

The approved Balzac Complex Emergency Response Plan is currently registered with the

ERCB (DDS #211) and distributed to all agencies listed below.

1. ERCB;

2. Alberta Health Services;

3. City of Calgary, including:

a. Airport Authority

b. Emergency Management Agency

c. Emergency Operations Centre.

4. Town of Airdrie;

5. County of Rocky View;

6. Town of Chestermere; and,

7. RCMP.

O. Confirmation that there are contingency plans in place to deal with any

unexpected sudden or gradual releases of substances to the environment

The Emergency Response Plan which is in place for the Balzac Gas Plant addresses the prevention

of and response to accidental spills, releases, or other abnormal occurrences which are foreseeable.

The Nexen Balzac Complex has an ERCB approved and up-to-date ERP. A number of plans and

procedures can be found within the ERP that deal with unexpected, sudden, or gradual releases of

substances to the environment. Generally, any major upset conditions at the facility and at all field

locations are covered by the ERP (e.g., gas releases, fires, explosions, spills, etc.). The Nexen

Balzac Complex also has a Spill Response Plan in place dated February 2007. This document also

references a number of policies, procedures, and action plans that are in place to deal with spills and

it identifies responsibilities at different levels within the company.

Regular visitations to residents and affected stakeholders within the ERP were conducted every two

years with approximately fifty-percent of all residents being contacted in person on an annual basis.

This process ensures for the accuracy of the response plan and helps to identify and address any

existing questions or concerns in the community. Going forward into 2012 resident visitations will

be conducted annually.

29

In 2002, the Nexen Balzac Gas Plant became the first Oil & Gas facility in the world verified

Responsible Care® In-Place.

Responsible Care® (RC) is a unique ethic developed within the chemicals industry that drives

continual improvement in health, safety, environmental and business performance, while openly and

transparently communicating with stakeholders about products and processes.

Critical to RC is an expectation for member companies to have a functioning, effective management

system in place and that it is structured to include all components of the Plan/Do/Check/Act cycle of

continual improvement.

Both the “ethic” and effectiveness of the management system is verified every three years by a team

of external industry experts and leaders within the community through a process of staff interviews,

document reviews and meetings with external stakeholders. The next verification for the Balzac Gas

Plant is scheduled for the fall of 2013.

P. The conservation and reclamation plan for the activity



3.1 Describe any topsoil conservation plans for any areas affected by the change, if

applicable.


3.2 A plan to prevent, remove or treat areas of contamination to within established

guidelines (Environmental Sciences Division of AENV).


Q. A description of the public consultation undertaken or proposed by the

applicant.


3.1 Same as for New Plants

At Nexen, public consultation is the conduit to actively involving the public and community in the

processes and decisions that may impact their lives or livelihood. Communities have a legitimate

right-to-know about our planned and on-going activities and to participate in decision-making for

30

issues that affect them. Nexen believes that in identifying shared concerns, we are better able to find

shared solutions or opportunities.

Nexen's commitment to ongoing and continued communication with area residents, neighbours,

stakeholders and business's is one way in which we conduct our activities and work with the

community to maintain an open, honest and transparent relationship. In 2002, the Nexen Balzac Gas

Plant became the first upstream Oil & Gas facility in the world to be verified in achieving the status

of Responsible Care®.

Responsible Care®, originally developed by the Chemical Industry Association of Canada (CIAC),

is a global, chemical industry initiative. It is a comprehensive performance improvement initiative

designed to address public concerns related to impacts associated with the chemical industry.

Although the Nexen Balzac Gas Plant was the first upstream Oil and Gas facility to implement

Responsible Care®, Nexen's other Divisions have taken a leadership role in Responsible Care® with

In-place certification assigned in October of 2010.

In addition, Nexen was instrumental in the development and support of the Balzac Community

Advisory Panel (BalCAP). The mission (focus) of the Balzac Community Advisory Panel was to

provide a forum for open, honest and transparent communication, on-going dialogue and timely

discussion of issues related to existing and proposed development and operations in the Balzac and

surrounding area. However, due to Plant shutdown, BalCAP has now been disbanded as of 4th

Quarter of 2011 and consultation will conducted through open houses (see below).

Communications and consultation processes for the Nexen Balzac Complex are divided into three

basic categories, they are:

1. Annual and ongoing contacts;

2. Emergency response planning contacts; and,

3. Project and maintenance contacts.

Regular visitations to residents and affected stakeholders within the ERP were conducted every two

years with approximately fifty-percent of all residents being contacted in person on an annual basis.

This process ensures for the accuracy of the response plan and helps to identify and address any

existing questions or concerns in the community. Going forward into 2012 resident visitations will

be conducted annually.

Direct mail, local newspaper advertising, open houses, and visitations were also used to delineate

information regarding regular field maintenance upgrades, new drilling programs, and testing.

Abandonment and reclamation activities are also conducted in such a manner as to ensure that

residents living adjacent to these activities are informed of the schedule of activities and rationale

for the work.

Amendment Application: Consultation Activities

Following an administrative review of the Nexen Balzac Gas Plant amendment application by

Alberta Environment, Nexen's public involvement process will begin by advertising in the following

local and regional newspapers to advise interested parties of the amendment application and thirty-

day review process:

Calgary Herald;

31

Calgary Sun;

Airdrie City View; and,

Rocky View Weekly.

Stakeholder Notification:

In addition to the newspaper advertisement all the residents, businesses, local authorities within the

Balzac Complex & Gathering System Emergency Planning Zone (approximately 1500 contacts)

were mailed three editions of the Nexen Community Matters news publication since January 1st,

2011 and an invitation to attend our Open House held at the Balzac Community hall on October 18th

2011. Nexen is planning on another Open House in early 2012.

All information presented at the Open House is posted on the Nexen Balzac website

www.nexeninc.com/balzac

Comments and feedback to the amendment application will be collected through a variety of

mechanisms. Nexen has provided the phone numbers for the Plant Manager(s) and Social

Responsibility department, as well as an email address where queries and/or comments can be

forwarded. All comments received will be recorded, catalogued and available on request.

32

APPENDIX I – EXISTING AENV APPROVALS

APPROVAL

PROVINCE OF ALBERTA

ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACT R.S.A. 2000, c.E-12, as amended.

APPROVAL NO. 155-02-00 APPLICATION NO. 008-155 EFFECTIVE DATE: October 31, 2005 EXPIRY DATE: September 30, 2015 APPROVAL HOLDER: Nexen Inc.

ACTIVITY: CONSTRUCTION, OPERATION AND RECLAMATION OF THE BALZAC SOUR GAS PROCESSING PLANT FOR THE PROCESSING OF NATURAL GAS AND THE BALZAC SULPHUR PROCESSING PLANT. ……………………………………………………………………………………………… ……………………………………………………………………………………………… IS SUBJECT TO THE ATTACHED TERMS AND CONDITIONS. Designated Director under the Act Alan Pentney, P.Eng. Date Signed October 31, 2005

APPROVAL NO. 155-02-00 Page 1 of 31

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TERMS AND CONDITIONS ATTACHED TO APPROVAL PART 1: DEFINITIONS

SECTION 1.1: DEFINITIONS

1.1.1 All definitions from the Act and the regulations apply except where expressly defined in this approval.

1.1.2 In all PARTS of this approval:

(a) "Act" means the Environmental Protection and Enhancement Act, R.S.A. 2000, c.E-12, as amended;

(b) "air contaminant" means any solid, liquid or gas or combination of any of them in the atmosphere resulting directly or indirectly from the activities of man;

(c) "application" means the written submissions to the Director in respect of application number 008-155 and 010-155 and any subsequent applications for amendments of approval number155-02-00;

(d) "CEM" means continuous emissions monitor;

(e) "CEMS Code" means the Continuous Emission Monitoring System Code, Alberta Environment, 1998, as amended;

(f) "chemical" means any substance that is added or used as part of the treatment process;

(g) "commence operation" means to start up the plant, process unit or equipment for the first time with the introduction of feed material, electrical or thermal energy and the simultaneous production of products for which the plant, process unit or equipment was designed excluding predetermined period of commissioning or testing;

(h) "container" means any portable device in which a substance is kept, including but not limited to drums, barrels and pails which have a capacity greater than 18 litres but less than 210 litres;

(i) "day" means any sampling period of 24 consecutive hours unless otherwise specified;

(j) "decommissioning" means the dismantling and decontamination of a plant undertaken subsequent to the termination or abandonment of any activity or any part of any activity regulated under the Act;

(k) "decontamination" means the treatment or removal of substances from the plant and affected lands;


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TERMS AND CONDITIONS ATTACHED TO APPROVAL

(l) "Director" means an employee of the Government of Alberta designated as a Director under the Act;

(m) "dismantling" means the removal of buildings, structures, process and pollution abatement equipment, vessels, storage facilities, material handling facilities, railways, roadways, pipelines and any other installations that are being or have been used or held for or in connection with the plant;

(n) "fugitive emissions" means emissions of substances to the atmosphere other than ozone depleting substances, originating from a plant source other than a flue, vent, or stack but does not include sources which may occur due to breaks or ruptures in process equipment;

(o) "industrial runoff" means precipitation that falls on or traverses the plant developed area;

(p) "industrial runoff control system" means the parts of the plant that collect, store or treat industrial runoff from the plant;

(q) "industrial wastewater" means the composite of liquid wastes and water-carried wastes, any portion of which results from any industrial process carried on at the plant;

(r) "industrial wastewater control system" means the parts of the plant that collect, store or treat industrial wastewater;

(s) “ISO 17025” means the international standard, developed and published by International Organization for Standardization (ISO), specifying the management and technical requirements for laboratories;

(t) "local environmental authority" means the Department of Environment, in the Province of Alberta, or the agency that has the equivalent responsibilities for any jurisdiction outside the Province;

(u) "manual stack survey" means a survey conducted in accordance with the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended;

(v) "monitoring system" means all equipment used for sampling, conditioning, analyzing or recording data in respect of any parameter listed or referred to in this approval including equipment used for continuous monitoring;

(w) "month" means calendar month;

(x) "net or lower heating value" means the quantity of heat evolved on complete combustion where the combustion products remain as vapour at 15°C;


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(y) "plant” means all buildings, structures, process and pollution abatement equipment, vessels, storage facilities, material handling facilities, roadways, pipelines and other installations, and includes the land, located on East half of Section 2, Township 26, Range 29, West of the 4th Meridian, that is being or has been used or held for or in connection with the Balzac sour gas processing plant and sulphur processing plant;

(z) "plant developed area" means the areas of the plant used for the storage, treatment, processing, transport, or handling of raw material, intermediate product, by-product, finished product, process chemicals, or waste material;

(aa) "QA/QC" means quality assurance and quality control;

(bb) "quarter year" means a time period of three consecutive months designated as January, February, and March; or April, May, and June; or July, August, and September; or October, November, and December;

(cc) "representative grab sample" means a sample consisting of equal volume portions of water collected from at least four sites between 0.20-0.30 metres below the water surface within a pond;

(dd) "soil" means mineral or organic earthen materials that can, have, or are being altered by weathering, biological processes, or human activity;

(ee) "suitable quality" means topsoil having a good, fair or poor rating as described in the Soil Quality Criteria Relative to Disturbance and Reclamation, Alberta Agriculture March, 1987, as amended;

(ff) "tank" means a stationary device, designed to contain an accumulation of a substance, which is constructed primarily of non-earthen materials that provide structural support including wood, concrete, steel, and plastic;

(gg) "topsoil" means the uppermost layer of suitable quality soil, containing organic matter, ordinarily moved in tillage or its equivalent in uncultivated soils;

(hh) "volume estimate" means a technical evaluation based on the sources contributing to the release, including, but not limited to, pump capabilities, water meters, and batch release volumes;

(ii) "week" means any consecutive 7-day period unless otherwise specified.

PART 2: GENERAL

SECTION 2.1: GENERAL


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TERMS AND CONDITIONS ATTACHED TO APPROVAL 2.1.1 The approval holder shall immediately report to the Director by telephone any

contravention of the terms and conditions of this approval at 1-780-422-4505.

2.1.2 The approval holder shall submit a written report to the Director within 7 days of the reporting pursuant to 2.1.1.

2.1.3 The terms and conditions of this approval are severable. If any term or condition of this approval or the application of any term or condition is held invalid, the application of such term or condition to other circumstances and the remainder of this approval shall not be affected thereby.

2.1.4 The approval holder shall immediately notify the Director in writing if any of the following events occurs:

(a) the approval holder is served with a petition into bankruptcy;

(b) the approval holder files an assignment in bankruptcy or Notice of Intent to make a proposal;

(c) a receiver or receiver-manager is appointed;

(d) an application for protection from creditors is filed for the benefit of the approval holder under any creditor protection legislation; or

(e) any of the assets which are the subject matter of this approval are seized for any reason.

2.1.5 If the approval holder monitors for any substances or parameters which are the subject of operational limits as set out in this approval more frequently than is required and using procedures authorized in this approval, then the approval holder shall provide the results of such monitoring as an addendum to the reports required by this approval.

2.1.6 All abbreviations used in this approval follow those given in Standard Methods for the Examination of Water and Wastewater published jointly by the American Public Health Association, the American Water Works Association, and the Water Environment Federation, 1998, as amended, unless otherwise specified in this approval.

2.1.7 Environmental Protection and Enhancement Act Approval No. 155-01-00 (previously approved as 95-IND-072) is cancelled.

SECTION 2.2: RECORD KEEPING


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TERMS AND CONDITIONS ATTACHED TO APPROVAL 2.2.1 The approval holder shall record and retain all the following information in respect of

any sampling conducted or analyses performed in accordance with this approval for a minimum of ten years, unless otherwise authorized in writing by the Director:

(a) the place, date and time of sampling;

(b) the dates the analyses were performed;

(c) the analytical techniques, methods or procedures used in the analyses;

(d) the names of the persons who collected and analyzed each sample; and

(e) the results of the analyses.

SECTION 2.3: ANALYTICAL REQUIREMENTS

2.3.1 With respect to any sample required to be taken pursuant to this approval, the approval holder shall ensure that:

(a) collection; (b) preservation; (c) storage; (d) handling; and (e) analysis;

shall be conducted in accordance with the following unless otherwise authorized in

writing by the Director:

(i) for air monitoring:

(A) the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended;

(B) the Methods Manual for Chemical Analysis of Atmospheric Pollutants, Alberta Environment, 1993, as amended;

(C) the Air Monitoring Directive, Alberta Environment, 1989, as amended; and,

(D) the CEMS Code;


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(ii) for industrial wastewater, industrial runoff, groundwater and domestic wastewater parameters:

(A) the Standard Methods for the Examination of Water and Wastewater, published jointly by the American Public Health Association, American Water Works Association, and the Water Environment Federation, 1998, as amended;

(iii) for soil samples:

(A) Soil Sampling and Methods of Analysis, Lewis Publishers, 1993, as amended;

(B) the Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, USEPA, SW-846; September 1986, as amended;

(C) the Soil Quality Criteria Relative to Disturbance and Reclamation, Alberta Agriculture, March 1987, as amended;

(D) the Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites – Volume I: Main Report, CCME EPC-NCS62E, 1993, as amended; and

(E) the Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites – Volume II: Analytical Method Summaries, CCME EPC-NCS66E, 1993, as amended;

2.3.2 The approval holder shall analyze all samples that are required to be obtained by this approval in a laboratory accredited pursuant to ISO 17025, as amended, for the specific parameter(s) to be analyzed, unless otherwise authorized in writing by the Director.

2.3.3 The approval holder shall comply with the terms and conditions of any written

authorization issued by the Director under 2.3.2. SECTION 2.4: OTHER 2.4.1 All industrial wastewater and process liquids contained in above and below ground

storage tanks, shall be contained in accordance with the Alberta Energy and Utilities Board (EUB) Guide G-55 "Storage Requirements for the Upstream Petroleum Industry", as amended.

2.4.2 All aboveground storage tanks containing liquid hydrocarbons or organic compounds

shall conform to the Environmental Guidelines for Controlling Emissions of Volatile


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Organic Compounds from Aboveground Storage Tanks, CCME-EPC-87-E, as amended.

PART 3: CONSTRUCTION

Not used at this time.

PART 4: OPERATIONS, LIMITS, MONITORING AND REPORTING

SECTION 4.1: AIR

OPERATIONS

4.1.1 The approval holder shall not emit any effluent streams to the atmosphere except as provided in this approval.

4.1.2 The approval holder shall only emit effluent streams to the atmosphere from the following sources:

(a) the East Sulphur recovery process unit incinerator stack;

(b) the two Emergency Flare Stacks (Low and High Pressure);

(c) the three 24,625 kW power boiler exhaust stacks;

(d) the 246 kW compressor engine exhaust stack;

(e) the 328 kW compressor engine exhaust stack;

(f) the two 410 kW compressor engine exhaust stacks;

(g) the four 1,790 kW compressor engine exhaust stacks (two stacks for each engine);

(h) the two 13,800 kW still reboiler exhaust stacks (one standby);

(i) the two 1,760 kW stabilizer reboiler exhaust stacks (one standby);

(j) the 3,250 kW sulfreen heater exhaust stack;

(k) the two 513 kW Salt Bath Heaters;

(l) the three Enersul GXM2 sulphur granulator units exhaust stacks;

(m) the natural gas fired emergency generator exhaust stack;


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(n) the diesel emergency firewater pump exhaust stacks;

(o) the instrument air compressor engine stack;

(p) the space ventilation exhaust stacks as described in the application;

(q) the space heater exhaust vents as described in the application;

(r) the compressor starter gas vents as described in the application; and

(s) any other source authorized in writing by the Director or by an amendment to this approval.

4.1.3 The approval holder shall maintain the following stacks according to the minimum height requirements specified in TABLE 4.1-A and TABLE 4.1-B:

TABLE 4.1-A: STACK HEIGHTS

STACK MINIMUM HEIGHT ABOVE GRADE (metres)

High Pressure Emergency Flare Stack 61.6

Low Pressure Emergency Flare Stack 61.3

East Sulphur Recovery Process Unit Incinerator Stack 121.9

TABLE 4.1-B: STACK HEIGHTS

COMPRESSOR ENGINE RATED CAPACITY KILOWATTS (kW)

NUMBER OF ENGINES

MINIMUM HEIGHT ABOVE GRADE (metres)

246 1 18.4

328 1 18.4

410 2 18.2

1,790 4 16.25 4.1.4 The approval holder shall operate the emergency flare stacks in accordance with

4.1.9.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.1.5 Residue gas shall be added to the sour gas released to the emergency flare stacks

such that the net or lower heating value of the combined gas stream is not less than 12 MJ/m3 (at 101.325 kPa and 15°C), unless otherwise authorized in writing by the Director.

4.1.6 The approval holder shall ensure the combustion of all combustible gases released to the emergency flare stacks.

4.1.7 The approval holder shall equip and operate all emergency flare stacks with:

(a) a wind guard; and

(b) a continuously burning pilot light; and

(c) an electric, or equivalent, ignitor.

4.1.8 All plant pressure safety valves in sour gas service shall be connected to the flare system.

4.1.9 Except as provided for by the Director in writing, the approval holder shall not emit fugitive emissions or an air contaminant from any source not specified in 4.1.2 or an air contaminant from the emergency flare stacks that causes or may cause any of the following:

(a) the impairment, degradation or alteration of the quality of natural resources; or

(b) material discomfort, harm or adversely affect the well being or health of a person; or

(c) harm to property or to plant or animal life.

SULPHUR PROCESSING PLANT

4.1.10 Effective the earlier of April 30, 2006 or the commencement of full operation of the new Sulphur Handling Facility as described in application 010-155:

(a) sulphur shall only be processed by the new Sulphur Handling Facility consisting of the Enersul GXM2 sulphur granulator units;

(b) no sulphur shall be processed by the existing Sulphur Handling Facility consisting of the slater units.

4.1.11 The approval holder shall provide, to the Director by March 31, 2006, an amendment to the Decommissioning and Reclamation Plan for the Sulphur Handling Facility dated November 2004 that consists of an update of the schedule of activities to be undertaken as described in the Plan, unless otherwise authorized in writing by the Director.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.1.12 The approval holder shall implement the Decommissioning and Reclamation Plan as

amended, as referred to in 4.1.11, unless otherwise authorized in writing by the Director.

4.1.13 Effective the earlier of April 30, 2006 or the commencement of full operation of the new Sulphur Handling Facility as described in application 010-155, the approval holder shall not operate the existing Sulphur Handling Facility unless the approval holder has obtained an amendment permitting such operation.

LIMITS 4.1.14 Release of air contaminants shall not exceed the limits specified in TABLE 4.1-C.

TABLE 4.1-C: LIMITS

EMISSION SOURCE AIR CONTAMINANT/ PARAMETER LIMIT

2.33 tonnes per hour

40.0 tonnes per day Sulphur Dioxide

10,300 parts per million by volume for a one-hour

averaging period

East Sulphur Recovery Process Unit Incinerator Stack

Temperature a minimum of 465°C for a one-hour averaging period

Sulphur granulator units SHF_1 and 2 and 3 exhaust stacks

Total Particulate Matter 0.20 grams per kilogram of

effluent

MONITORING AND REPORTING 4.1.15 The approval holder shall monitor as specified in TABLE 4.1-D.

4.1.16 The approval holder shall report as specified in TABLE 4.1-D.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.1-D SOURCE MONITORING AND REPORTING

EMISSION SOURCE/ EFFLUENT STREAM

PARAMETER SAMPLING FREQUENCY

MONITORING METHOD

METHOD OF ANALYSIS

REPORTING FREQUENCY (one copy required)

REPORT TO

Sulphur Dioxide, Flow Rate,

and Temperature

Continuous CEM CEMS Code

Monthly, before the end

of the next month

East Sulphur Recovery Process Unit Incinerator Stack

Sulphur Dioxide Twice per year Manual Stack Survey

Alberta Stack Sampling

Code

Twice per year, each by the end of the Month after

the survey is done

Emergency Flare Stacks

Amount of Sulphur Dioxide released to the

atmosphere

Acid gas & residue or fuel gas released to

flare

Daily Measured or estimated

Mass Balance

Monthly, before the end

of the next month

Exhaust stacks of Sulphur granulator Units SHF_1, SRF 2 or SRF 3

Total Particulate Matter, PM2.5

Annual sampling of

one stack at a minimum, with

rotation so that each of the stacks shall be

surveyed at a minimum once

every three years

Manual Stack Survey

Alberta Stack Sampling

Code

Before the end of the Month

after the month in which the

survey is done

Director

4.1.17 The approval holder shall monitor for ambient levels of all parameters as specified in

TABLE 4.1-E.

4.1.18 The approval holder shall report as specified in TABLE 4.1-E.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.1-E: AMBIENT MONITORING AND REPORTING

PARAMETER TO BE ANALYSED OR MEASURED

NUMBER OF MONITORING SITES

FREQUENCY METHOD OF MONITORING

METHOD OF ANALYSIS OF MEASURE-MENT

REPORT FREQUENCY (one copy required)

REPORT TO

SO2, H2S, wind speed and direction

2 ambient air quality monitoring

stations

12 Months/year Continuous

Total Sulphation and Hydrogen Sulphide

13 exposure stations Monthly Exposure

Stations

Monthly, before the end of the

next month

Soil Testing in accordance with the Air Monitoring Directive

As authorized by the Director Annually Air Monitoring

Directive

Air Monitoring Directive

Annually

Director

4.1.19 An annual summary and evaluation report shall be submitted to the Director by March

15 of each year that contains for the previous year information related to plant operation, performance of air pollution control equipment and air contaminant emissions.

STUDIES 4.1.20 The approval holder shall submit a proposal to the Director by June 1, 2006 for

investigating the elevated ambient air H2S concentrations observed at the ambient air quality monitoring stations to the Director by June 1, 2006.

4.1.21 The proposal referred to in 4.1.20 shall include the following:

(a) site map showing the plant in relation to activities believed to contribute to elevated ambient air H2S concentrations;

(b) description and summary of dates of observed elevated ambient air H2S concentrations and wind speed and direction, observed plant activities and other possible factors related to elevated ambient air H2S concentrations;

(c) method to investigate sources of elevated ambient air H2S concentrations including additional monitoring based on historic events;

(d) possible means to mitigate or prevent elevate ambient air H2S concentrations; and,


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(e) a schedule for implementing the investigation.

4.1.22 The approval holder shall implement the proposal referred to 4.1.20 as authorized in writing by the Director.

4.1.23 The approval holder shall submit a report summarizing the results of the investigation referred to in 4.1.20 and as authorized in writing by the Director by March 31, 2007.

SPECIAL REPORTING 4.1.24 The approval holder shall continuously measure or estimate and record on a daily

basis the average sulphur inlet rates in tonnes per day.

4.1.25 If the percentage of daily SO2 mass emission rates as reported in 4.1.26 are less than or equal to the values in Column 3 in TABLE 4.1-F for the applicable daily SO2 mass emission (Column 2, TABLE 4.1-F) based on the average daily sulphur inlet rates (Column 1, TABLE 4.1-F) at which the plant operated during the reporting period;

OR

If the percentage of hourly SO2 mass emission rates as reported in 4.1.26 are less than or equal to the values in Column 5 in TABLE 4.1-F for the applicable hourly SO2 mass emission (Column 4, TABLE 4.1-F) based on the average daily sulphur inlet rates (Column 1, TABLE 4.1-F) at which the plant operated during the reporting period;

then the following information shall be provided in the monthly report by the approval holder:

(a) a description of the events or circumstances that lead to higher cumulative mass emission readings; and

(b) an outline of the action taken to control the magnitude and/or duration of the event; and

(c) a description of any long-term measures or actions that are required to prevent or minimize such occurrences in the future and a schedule of implementation for these measures or actions.


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TABLE 4.1-F: SO2 MASS EMISSION TIERS

COLUMN 1 COLUMN 2 COLUMN 3 COLUMN 4 COLUMN 5

PLANT DAILY AVERAGE SULPHUR INLET RATE

(TONNES/DAY)

DAILY SO2 MASS EMISSION (TONNES/DAY)

Sulphur Recovery Process Unit Incinerator Stack

% OF DAILY READINGS IN A MONTH THAT ARE TO BE LESS THAN THE DAILY MASS EMISSION VALUE IN COLUMN 2

HOURLY SO2 MASS EMISSION (TONNES/HOUR)

Sulphur Recovery Process Unit Incinerator Stack

% OF HOURLY READINGS IN A MONTH THAT ARE TO BE LESS THAN THE HOURLY MASS EMISSION VALUE IN COLUMN 4

0 – 300.0 12.0 90.0 0.70 90.0

300.1 – 700.0 28.0 93.3 1.63 95.0

700.1 – 975.0 39.0 96.7 2.28 98.0

4.1.26 The approval holder shall report the frequency distribution of both the hourly and daily mass emission rates of sulphur dioxide versus the monthly average daily sulphur inlet rate monthly.

4.1.27 The approval holder shall notify in writing the Director a minimum of two weeks prior to all stack surveys.

SECTION 4.2: INDUSTRIAL WASTEWATER

OPERATIONS

4.2.1 The approval holder shall not release any substances from the plant to the surrounding watershed except as authorized by this approval.

4.2.2 Industrial wastewater shall be managed as described in the application, unless otherwise authorized in writing by the Director.

4.2.3 Industrial wastewater that is collected in the Double Lined Open Drain Collection Pond shall only be disposed as follows:

(a) to an Alberta Energy and Utilities Board (EUB) approved disposal well; or

(b) to an Alberta Energy and Utilities Board (EUB) approved Waste Processing and Disposal Facility; or


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(c) as otherwise authorized in writing by the Director.

4.2.4 The approval holder shall only release the following industrial wastewater streams to the Blowdown Holding Ponds:

(a) Boiler blowdown; and,

(b) Cooling tower blowdown.

4.2.5 The approval holder shall only release industrial wastewater from the Blowdown Holding Ponds via pipeline to McDonald Lake, unless otherwise authorized in writing by the Director.

4.2.6 All industrial runoff from the plant developed area shall be directed to the Sulphur Block Area Surface Runoff Collection Pond.

4.2.7 The approval holder shall only release industrial runoff from the Sulphur Block Area Surface Runoff Collection Pond via pipeline to McDonald Lake, unless otherwise authorized in writing by the Director.

LIMITS

4.2.8 Releases from the Blowdown Holding Ponds shall not exceed the limits for the parameters specified in TABLE 4.2-A.

4.2.9 Releases from the Sulphur Block Area Surface Runoff Collection Pond shall not exceed the limits for the parameters specified in TABLE 4.2-A.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.2-A: LIMITS

PARAMETER LIMIT

Industrial Wastewater Released from the Blowdown Holding Ponds

PH 6.0 - 9.5 pH units

Floating solids Must not be present except in trace amounts

Visible foam Must not be present except in trace amounts

Oil or other substances Must not be present in amounts sufficient to create a visible film or sheen

Chemical Oxygen Demand 200 mg/L

Ammonia-Nitrogen 5 mg/L

Oil & Grease 5 mg/L

Total Suspended Solids 25 mg/L

Chlorine Residual 0.3 mg/L

Industrial Runoff Released from the Sulphur Block Area Surface Runoff Collection Pond pH 6 – 9.5 pH units

Oil & Grease No visible sheen

Chemical Oxygen Demand 50 mg/L

Ammonia-Nitrogen 5 mg/L

Total Suspended Solids 25 mg/L

Chloride 500 mg/L


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TERMS AND CONDITIONS ATTACHED TO APPROVAL MONITORING AND REPORTING 4.2.10 The approval holder shall monitor the Blowdown Holding Ponds, Industrial Runoff

Control System and McDonald Lake as required in TABLE 4.2-B unless otherwise authorized by the Director.

4.2.11 The approval holder shall report to the Director the results of monitoring the Blowdown Holding Pond, Industrial Runoff Control System and McDonald Lake as required in TABLE 4.2-B.

4.2.12 For the purpose of Table 4.2-B:

(a) sampling location A is defined as Blowdown Holding Ponds;

(b) sampling location B is defined as Sulphur Block Area Surface Runoff Collection Pond; and

(c) sampling location C is defined as McDonald Lake.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL TABLE 4.2-B: INDUSTRIAL WASTEWATER AND INDUSTRIAL RUNOFF CONTROL

SYSTEM MONITORING AND REPORTING

MONITORING REPORTING

PRIOR TO RELEASE

DURING RELEASE

Parameter, Test, Event, Study Proposal or

Reporting Requirement Frequency Frequency Sample Type Sampling

Location Monthly Annually

Flow (m3/d) Daily Estimate A, B

Ammonia-Nitrogen (mg/L)

Weekly Representative Grab A, B

Total Suspended Solids (mg/L)

Weekly Representative Grab A, B

pH Daily Representative Grab A, B

Floating Solids Daily Visual A

Visible Foam Daily Visual A

Oil and Grease Daily Visual B

Oil and Grease (mg/L) Weekly Representative Grab A

Chemical Oxygen Demand (mg/L) Weekly Representative

Grab A, B

Chloride (mg/L) Weekly Representative Grab B

Chlorine Residual (mg/L) Weekly Representative Grab A

Sulphate (mg/L) Weekly Representative Grab B

Total Phosphorus (mg/L) Weekly Representative Grab A

Conductivity (umhos) Weekly Representative Grab A

Monthly Industrial

Wastewater and Industrial

Runoff Report as per

4.2.13

(On or before the end of the month

following the month in which the

information was

collected)

Number of Copies

Required 1

Temperature, pH, total hardness, total alkalinity, carbonate, bicarbonate, chloride, sulphate, nitrite-nitrogen, nitrate-nitrogen, sodium, magnesium, potassium, total iron, oil & grease, chemical oxygen demand, conductivity, total dissolved solids, water level, BTEX and F1 Parameters

Once per year

Representative Grab C Not

required

Annual Industrial

Wastewater and

Industrial Runoff

Report as per 4.2.14 due March 15 of each

year

Number of Copies

Required 1


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TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.2.13 In addition to the monthly reporting in Table 4.2-B, the monthly Industrial Wastewater

and Industrial Runoff Report shall include, at a minimum, all of the following information:

(a) an assessment of the monitoring results relative to the limits in TABLE 4.2-A;

(b) the release from the Blowdown Holding Pond and the Industrial Runoff Pond to McDonald Lake for the parameters listed in TABLE 4.2-A in kilograms per day;

(c) the daily minimum, maximum and average pH recorded as per TABLE 4.2-B;

(d) an assessment of the performance of the Industrial Wastewater Control System, the Industrial Runoff Control System, pollution abatement equipment and monitoring equipment;

(e) a summary of contraventions reported pursuant to 2.1.1; and

(f) any other information as required in writing by the Director.

4.2.14 In addition to the annual reporting in Table 4.2-B, the Annual Industrial Wastewater and Industrial Runoff Report shall include, at a minimum, all of the following information:

(a) an overview of the operation and performance of the Industrial Wastewater and Industrial Runoff Control Systems and pollution abatement equipment;

(b) a tabulated summary of the monitoring results for the industrial wastewater and industrial runoff released to McDonald Lake including the minimum, maximum and average for all the parameters listed in Table 4.2-B for each month;

(c) an assessment of the monitoring results relative to the limits specified in Table 4.2-A including trend analysis and control charts;

(d) a summary of contraventions reported pursuant to 2.1.1; and

(e) any other information as required in writing by the Director.


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TERMS AND CONDITIONS ATTACHED TO APPROVAL SULPHUR MANAGEMENT

4.2.15 The approval shall not pour liquid sulphur to the sulphur storage blocks unless the following requirements are met:

(a) the pouring shall be conducted under the circumstances specified in the application or in the event of an emergency event; and,

(b) the approval holder shall notify the following parties at least 72 hours in advance of the commencement of the set up of pouring: (i) Alberta Environment, and (ii) all residents within a 3 km radius of the plant; and

(c) any other information as required in writing by the Director.

4.2.16 The approval holder shall ensure that sulphur spills are cleaned up as soon as possible after each spill event.

4.2.17 The approval holder shall submit to the Director by October 31, 2006 an Environmental Assessment for management of contaminated sulphur and materials contaminated with sulphur.

4.2.18 The Environmental Assessment for management of contaminated sulphur and materials contaminated with sulphur shall include, but is not limited to, the sulphur block and basepads, the slater units, the sulphur load-out area, the sulphur storage pad and sulphur soil pile. The Assessment shall include:

(a) an estimate of contaminated sulphur and material contaminated with sulphur;

(b) a schedule for removal and disposal of contaminated sulphur and materials contaminated with sulphur;

(c) an evaluation of the permeability of the areas where the contaminated sulphur and materials contaminated with sulphur are stored;

(d) recommendations for upgrading the storage area(s) with an impermeable surface based on the results from 4.2.18(c);

(e) recommendations for mitigating wind erosion of the storage area(s);

(f) recommendations for upgrading and lining the collection ditches and sump areas;

(g) material specification of proposed liners;

(h) schedule of planned activities; and

(i) any other information the Director requires.


………………….

TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.2.19 The approval holder shall correct any deficiencies in the Environmental Assessment

referred to in 4.2.18 as specified in writing by the Director.

4.2.20 The approval holder shall implement the Environmental Assessment recommendations referred to in 4.2.18 and as authorized in writing by the Director.

UPGRADES TO INDUSTRIAL RUNOFF CONTROL SYSTEM

4.2.21 The approval holder shall conduct an assessment of Industrial Runoff at the plant. The assessment shall have the following components:

(a) a brief description of the catchment areas;

(b) a description of the sampling program for collecting samples of industrial runoff from catchment areas in 2006 including a site plan showing the catchment areas and the locations of where the samples were taken;

(c) interpretation and tabulation of the analytical results including the laboratory analytical results;

(d) a determination of industrial runoff quantities at the plant and for each catchment area;

(e) a description of the risks of contaminating industrial runoff at each catchment area;

(f) an assessment of implementing Best Management Practices (BMPs) at the plant to mitigate industrial runoff at the plant including the possibility of diverting industrial runoff from specified portions of catchment areas and details on the receiving areas and potential impacts on these receiving areas.

(g) a plan and schedule for implementing BMPs at the plant.

4.2.22 The approval holder shall submit the Industrial Runoff Assessment referred to in 4.2.21 to the Director by December 1, 2006 unless otherwise authorized in writing by the Director.

4.2.23 The approval holder shall implement the plan referred to in 4.2.21(g) as authorized in writing by the Director.


………………….

TERMS AND CONDITIONS ATTACHED TO APPROVAL UPGRADES TO INDUSTRIAL WASTEWATER CONTROL SYSTEM

4.2.24 The approval holder shall submit a proposal to the Director by December 1, 2006 for upgrading the industrial wastewater control system. The proposal shall include, at a minimum, all of the following:

(a) identification of the chemicals of concern in the boiler blowdown and cooling tower blowdown based on treatment chemicals used for the boiler and cooling tower water systems;

(b) review of the monitoring results of the blowdown holding pond including a tabulated summary, graphs showing trends for monitoring data collected from 1995 to 2005;

(c) an assessment of the boiler and cooling tower water treatment systems to determine the optimum number of cycles to minimize treatment chemical usage and contaminants in the blowdown including Total Suspended Solids;

(d) an assessment of technology options for treating boiler blowdown and cooling tower blowdown including:

(i) the quality of treated wastewater that can be achieved for each technology option and feasibility of recycling this treated wastewater to the cooling water and boiler or other uses;

(ii) the estimated quantity and quality of the waste stream resulting from the treatment technology and possible disposal options; and

(iii) recommendations for the most effective treatment technology option for implementation at the plant; and

(iv) a schedule for this work to be done.

4.2.25 If the proposal referred to in 4.2.24 is found deficient by the Director, the approval holder shall correct all the deficiencies as outlined by the Director within 120 days of the deficiency letter.

4.2.26 The approval holder shall implement the recommendations referred to in 4.2.24(d)(iii) as authorized in writing by the Director.

SECTION 4.3: WASTE MANAGEMENT

OPERATIONS



………………….

TERMS AND CONDITIONS ATTACHED TO APPROVAL SECTION 4.4: DOMESTIC WASTEWATER

OPERATIONS

4.4.1 All domestic wastewater shall be directed to a septic tank with subsequent disposal to an approved municipal wastewater treatment system.

SECTION 4.5: WATERWORKS


SECTION 4.6: GROUNDWATER

4.6.1 The approval holder shall implement the Groundwater Monitoring Program for the plant as authorized in writing by the Director.

4.6.2 The samples extracted from the groundwater monitor wells shall be collected using scientifically acceptable purging, sampling and preservation procedures so that a representative groundwater sample is obtained.

4.6.3 All groundwater monitor wells shall be:

(a) protected from damage; and

(b) locked except when being sampled; unless otherwise authorized in writing by the Director.

4.6.4 If a representative groundwater sample cannot be collected because the groundwater monitor well is damaged or is no longer capable of producing a representative groundwater sample:

(a) the groundwater monitor well shall be cleaned, repaired or replaced; and

(b) a representative groundwater sample shall be collected and analyzed prior to the next scheduled sampling event; unless otherwise authorized in writing by the Director.

4.6.5 In addition to the sampling information recorded in 2.2.1, the approval holder shall record the following sampling information for all groundwater samples collected:

(a) a description of purging and sampling procedures;

(b) the static elevations, above sea level, of fluid phases in the groundwater monitor well prior to purging;

(c) the temperature of each sample at the time of sampling;


………………….


(d) the pH of each sample at the time of sampling; and

(e) the specific conductance of each sample at the time of sampling.

4.6.6 The approval holder shall compile an Annual Groundwater Monitoring Program Summary Report which shall include, at a minimum, all of the following information:

(a) a legal description of the plant and a map illustrating the plant boundaries;

(b) a topographic map of the plant;

(c) a description of the industrial activity and processes;

(d) a map showing the location of all surface and groundwater users, and, a listing describing surface water and water well use details, within at least a three kilometre radius of the plant;

(e) a general hydrogeological characterization of the region within a five kilometre radius of the plant;

(f) a detailed hydrogeological characterization of the plant;

(g) a geological cross-section(s) of the plant;

(h) a map of surface drainage patterns located within the plant;

(i) a map of groundwater monitor well locations and a description of the existing groundwater monitoring program for the plant;

(j) a summary of any changes to the groundwater monitoring program made since the last groundwater monitoring report;

(k) analytical data recorded as required in 4.6.1 and 4.6.5;

(l) a summary of fluid elevations recorded as required in 4.6.5(b) and an interpretation of changes in fluid elevations;

(m) an interpretation of groundwater flow patterns;

(n) an interpretation of the analytical results including the following:

(i) diagrams indicating the location of any contamination identified,

(ii) probable sources of contamination, and

(iii) the extent of contamination identified;


………………….


(o) a summary and interpretation of the data collected since the groundwater monitoring program began including:

(i) control charts which indicate trends in contaminant concentrations, and

(ii) the migration of contaminants;

(p) a description of the following:

(i) contaminated groundwater remediation techniques employed,

(ii) source elimination measures employed,

(iii) risk assessment studies undertaken, and

(iv) risk management studies undertaken;

(q) a sampling schedule for the following year;

(r) recommendations, as follows;

(i) for changes to the groundwater monitoring program to make it more effective; and

(ii) for remediation, risk assessment or risk management of contamination identified.

4.6.7 The approval holder shall submit two copies of the Annual Groundwater Monitoring Summary Report to the Director on or before April 14 of the year following the year in which the information on which the report is based was collected, unless otherwise authorized in writing by the Director.

SECTION 4.7: SOIL

MONITORING

4.7.1 The approval holder shall develop and document proposals for the Soil Monitoring Program in accordance with the Soil Monitoring Directive, Alberta Environment, May 1996, as amended.

4.7.2 The approval holder shall submit the Soil Monitoring Program proposals to the Director for authorization in writing according to the following schedule:

(a) for the first soil monitoring proposal, no later than May 1, 2006; and

(b) for the second soil monitoring proposal, no later than March 1, 2011; or


………………….


unless otherwise authorized in writing by the Director.

4.7.3 If the Soil Monitoring Program proposals are found deficient by the Director, the approval holder shall correct all the deficiencies as outlined by the Director within 120 days of the deficiency letter.

4.7.4 The approval holder shall implement the Soil Monitoring Program proposals as authorized in writing by the Director.

4.7.5 The approval holder shall implement QA/QC provisions in accordance with the CCME Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites, Volume I, Report CCME EPC-NCS62E, Winnipeg, Manitoba, December 1993, as amended.

STANDARDS

4.7.6 For sampling locations which meet the conditions in C.1 of the Soil Monitoring Directive, May 1996, as amended, the concentration of substances in soil shall be compared to values in the following:

(a) for petroleum hydrocarbons, Alberta Soil and Water Quality Guidelines for Hydrocarbons at Upstream Oil and Gas Facilities, Alberta Environment, 2001, as amended;

(b) for salt, Salt Contamination Assessment and Remediation Guidelines, Alberta Environment, 2001, as amended;

(c) for substances not included in 4.7.6 (a) or (b), Canadian Environmental Quality Guidelines, Canadian Council of Ministers of the Environment, PN1299, 1999, as amended, excluding values determined before 1997;

(d) for substances not found in 4.7.6 (a) to (c), for soil which will be remediated to an agricultural, residential, or parkland land use, Alberta Tier I Criteria for Contaminated Soil Assessment and Remediation, Alberta Environmental Protection, March 1994, as amended; and

(e) for substances not found in 4.7.6 (a) to (c), for soil which will be remediated to a commercial or industrial land use, the Interim Canadian Environmental Quality Criteria for Contaminated Sites, Canadian Council of Ministers of the Environment, EPC-CS34, September 1991, as amended.

4.7.7 For sampling locations which do not meet the conditions in C.1 of the Soil Monitoring Directive, May 1996, as amended, or if substances are present that are not listed in the standards referred to in 4.7.6 (a) to 4.7.6 (e), the concentrations of substances in soil shall be compared to values derived using methods in C.2 of the Soil Monitoring Directive.


………………….

TERMS AND CONDITIONS ATTACHED TO APPROVAL REPORTING

4.7.8 The approval holder shall submit two copies of each Soil Monitoring Program Report to the Director summarizing the data obtained from the soil monitoring referred to in 4.7.4 according to the following schedule:

(a) for the first soil monitoring report, no later than December 1, 2006; and

(b) for the second soil monitoring report, no later than October 1, 2011; or

unless otherwise authorized in writing by the Director.

4.7.9 The Soil Monitoring Program reports shall be as prescribed in the reporting requirements of the Soil Monitoring Directive, May 1996, as amended.

SOIL MANAGEMENT PROGRAM

4.7.10 If the Soil Monitoring Program, or any other soil monitoring, reveals that there are substances present in the soil at concentrations greater than the applicable concentrations in 4.7.6 or 4.7.7, the approval holder shall develop and document a Soil Management Program Proposal in accordance with the Guideline for Monitoring and Management of Soil Contamination Under EPEA Approvals, Chemicals Assessment and Management Division, May 1996, as amended, or as otherwise authorized in writing by the Director.

4.7.11 If required pursuant to 4.7.10, the approval holder shall submit a Soil Management Program Proposal to the Director within six months after the date that the Soil Monitoring Report referred to in 4.7.8 is due.

4.7.12 The Soil Management Program Proposal shall include, at a minimum, all of the following:

(a) steps to be taken to control sources of contamination;

(b) remediation objectives for substances identified by soil monitoring as exceeding the applicable maximum standards in 4.7.6 or 4.7.7;

(c) proposed steps for management of soil contamination; and

(d) a schedule for implementing the Soil Management Program.

4.7.13 If the Soil Management Program Proposal is found deficient by the Director, the approval holder shall correct all the deficiencies as outlined by the Director by the date specified in the deficiency letter.


………………….

TERMS AND CONDITIONS ATTACHED TO APPROVAL 4.7.14 The approval holder shall implement the Soil Management Program as authorized in

writing by the Director.

4.7.15 If the approval holder must implement a Soil Management Program pursuant to 4.7.14, the approval holder shall submit a written Soil Management Program Report to the Director on or before March 31 of each year, unless otherwise authorized in writing by the Director.

4.7.16 The Soil Management Program report shall include, at a minimum, all of the following information:

(a) a summary of actions taken under the Soil Management Program during the previous year;

(b) a description and interpretation of results obtained, including any soil testing, from the Soil Management Program; and

(c) events planned for the current year including any deviations from the program authorized in writing by the Director.

PART 5: RECLAMATION

SECTION 5.1: GENERAL

5.1.1 The approval holder shall apply for an amendment to this approval to reclaim the plant by submitting a Decommissioning and Land Reclamation Plan to the Director.

5.1.2 The Decommissioning and Land Reclamation Plan referred to in 5.1.1 shall be submitted within six months of the plant ceasing operation, except for repairs and maintenance, unless otherwise authorized in writing by the Director.

5.1.3 The approval holder shall implement the Decommissioning and Land Reclamation Plan as authorized by the Director.


………………….

TERMS AND CONDITIONS ATTACHED TO APPROVAL SECTION 5.2: DECOMMISSIONING

5.2.1 The approval holder shall develop and submit a plan for the Decommissioning phase to the Director which shall include, at a minimum, all of the following:

(a) a plan for dismantling the plant;

(b) a comprehensive study to determine the nature, degree and extent of contamination at the plant and affected lands;

(c) a plan to manage all wastes produced at the plant during operation and decommissioning;

(d) evaluation of remediation technologies proposed to be used at the plant and affected lands;

(e) a plan for decontamination of the plant and affected lands in accordance with the following:

(i) for petroleum hydrocarbons, Alberta Soil and Water Quality Guidelines for Hydrocarbons at Upstream Oil and Gas Facilities, Alberta Environment, 2001, as amended;

(ii) for salt, Salt Contamination Assessment and Remediation Guidelines, Alberta Environment, 2001, as amended;

(iii) for substances not included in 6.2.1 (e) (i) or 6.2.1 (e) (ii), Canadian Environmental Quality Guidelines, Canadian Council of Ministers of the Environment, PN1299, 1999, as amended, excluding values determined before 1997;

(iv) for substances not found in 6.2.1 (e) (i) to 6.2.1 (e) (iii), for soil which will be remediated to an agricultural, residential, or parkland land use, Alberta Tier I Criteria for Contaminated Soil Assessment and Remediation, Alberta Environmental Protection, March 1994, as amended;

(v) for substances not found in 6.2.1 (e) (i) to 6.2.1 (e) (iii), for soil which will be remediated to a commercial or industrial land use, the Interim Canadian Environmental Quality Criteria for Contaminated Sites, Canadian Council of Ministers of the Environment, EPC-CS34, September 1991, as amended;

(vi) for water, Canadian Water Quality Guidelines, CCREM, 1987, as amended; and


………………….


(vii) for soil or water, to contaminant levels in accordance with a risk assessment procedure accepted by the Director;

(f) confirmatory testing to indicate compliance with the remediation objectives; and

(g) a plan for maintaining and operating contaminant monitoring systems.

5.2.2 The approval holder shall implement the Decommissioning plan as authorized in writing by the Director.

5.2.3 All analytical protocols shall be in accordance with the Guidance Manual on Sampling, Analysis and Data Management for Contaminated Sites - Volume 1: Main Report, CCME EPC-NCS62E.

5.2.4 The approval holder shall submit an Annual Report to the Director by December 30 of each year until decommissioning is complete which shall include, at a minimum, all of the following:

(a) summary of decommissioning activities conducted during the reporting period;

(b) status of decommissioning;

(c) decommissioning activities planned for the following reporting period;

(d) summary and interpretation of monitoring data collected for the reporting period; and

(e) interpretation of monitoring data collected historically.

SECTION 5.3: LAND RECLAMATION

5.3.1 The approval holder shall develop and submit a plan for the Land Reclamation phase to the Director which shall include, at a minimum, all of the following:

(a) the final use of the reclaimed area and how equivalent land capability will be achieved;

(b) removal of infrastructure;

(c) restoration of drainage;

(d) soil replacement;

(e) erosion control;


………………….


(f) revegetation and conditioning of the plant including:

(i) species list, seed source and quality, seeding rates and methods;

(ii) fertilization rates and methods;

(iii) wildlife habitat plans where applicable; and

(g) reclamation sequence and schedule.

5.3.2 The approval holder shall implement the Land Reclamation plan as authorized in writing by the Director.

DATED October 31, 2005 DESIGNATED DIRECTOR UNDER THE ACT ALAN PENTNEY

AMENDING APPROVAL

PROVINCE OF ALBERTA

ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACTR.S.A. 2000, c.E-12, as amended.

155-02-01APPROVAL NO.

014-155APPLICATION NO.

September 17, 2007EFFECTIVE DATE:.

September 30, 2015EXPIRY DATE:

Nexen Inc.APPROVAL HOLDER

Pursuant to Division 2, of Part 2, of the Environmental Protection and Enhancement Act,R.S.A.2000, c.E-12, as amended, the approval for the following activity:

Balzac sour gas processing plant for the processing of natural gas and the Balzac sulphurprocessing plant.

is amended as per the attached terms and conditions.

Kevin WilkinsonDesignated Director under the Act

Kevin Wilkinson

September 17, 2007Date Signed

APPROVAL NO.155-02-01

……………………….


Environmental Protection and Enhancement Act Approval No. 155-02-00 is hereby amended asfollows:

1. The following is added after SECTION 4.1.2(s):

(t) the diesel emergency generator exhaust stack.

DATED September 17, 2007 Kevin Wilkinson DESIGNATED DIRECTOR UNDER THE ACT

AMENDING APPROVAL

PROVINCE OF ALBERTA

ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACTR.S.A. 2000, c.E-12, as amended.

155-02-02APPROVAL NO.

015-155APPLICATION NO.

February 29, 2008EFFECTIVE DATE:.

September 30, 2015EXPIRY DATE:

Nexen Inc.APPROVAL HOLDER

Pursuant to Division 2, of Part 2, of the Environmental Protection and Enhancement Act,R.S.A.2000, c.E-12, as amended, the approval for the following activity:

Balzac sour gas processing plant for the processing of natural gas and the Balzac sulphurprocessing plant.

is amended as per the attached terms and conditions.

Kevin WilkinsonDesignated Director under the Act

February 29, 2008Date Signed

APPROVAL NO.155-02-02……………………

….


Environmental Protection and Enhancement Act Approval No. 155-02-00 is hereby amended asfollows:

1. The following is added after SECTION 4.1.14:

4.1.14 (a) notwithstanding Table 4.1-C, for the period between March 17 to 21, 2008, or asotherwise authorized in writing by the Director, the temperature of the effluentstream released to the atmosphere shall not be less than the one-hour averageof 300 degrees celsius.

DATED February 29, 2008 Kevin Wilkinson DESIGNATED DIRECTOR UNDER THE ACT

33

APPENDIX II – PUBLIC CONSULTATION FACT SHEET

Social ResponsibilityHSE&SR Management System

Public ComplaintsPublic Complaints

Identifying and addressing “Public Complaints”

What is a public complaint?

Guiding Principle & Standard:At Nexen, we conduct our business with respect and care for people. From time to time, we receive complaints from our stakeholders and the general public. Our standard is to track, document and respond to any complaint, question, or query within five working days of its receipt.

At Nexen, we separate complaints into two basic categories; 'Reportable' and 'Non-Reportable'.

Reportable Complaint: A direct expression of concern made by a stakeholder or member of the public that relates to a topic or event associated with Nexen's operations and results in the business unit taking action to correct the problem or concern. In some instances, reportable events are also required to be reported to a regulator.

Non-Reportable Complaint or Comment:A direct or indirect expression of concern, an observation, or viewpoint

of an industry related activity(s) near Nexen's operations that may or may not result in a formal reply or further action by Nexen.

All public complaints are entered into the Lotus Notes LEHS database by the field staff member that received the complaint or by a designate within the regional office. Information to be provided in an LEHS entry must include:

date and time of event, hlocation and/or nearest facility, and hdetails of the complaint. h

Where applicable, the regional social responsibility lead/representative will then add this information including contact information into Nexen's Stakeholder database (Praxis).

The area operations superintendent or supervisor initiates the investigation with the local HSE&SR practitioner providing support and technical guidance as required.

How does Nexen track public complaints?

Who investigates public complaints?

What are examples of public complaints?

A landowner smells something (a hpetroleum odour) on their property and calls Nexen to report the concern,A local fisherman writes a letter to hNexen to express concerns that offshore activity is affecting fishing in the area,A resident calls upset about finding hsediment in their well water and believes it is from a nearby Nexen drilling operation,A farmer informs a contractor on a hNexen lease that they believe their horse (livestock) was injured during recent drilling or mobilization activity,A Nexen field office receives a hnoise complaint from a local landowner where drilling activities are currently underway,A concerned citizen contacts the hlocal authority about Nexen activities in an area that they consider environmentally sensitive, the authority contacts Nexen to seek clarity of the issue.

Element 4 of the HSE&SR Management System:

4.3.1 Ongoing Community EngagementAll divisions will establish and maintain ongoing community engagement programs to support Nexen's long-term social license to operate.

This engagement will typically include: involving the community in decision-making processes for operational hchanges, expansions or abandonment activities that may affect them; taking proactive measures to ensure communities are aware of hongoing Nexen activities; providing a vehicle for members of the public to express questions, hconcerns and complaints regarding our operations.

All divisions will record notable public complaints, comments and inquiries in the Nexen LEHS database, respond to them in a timely manner, and document the response.

July 2011 S13735

Version Dec 8, 2011

Balzac A&R Team

Public Concern 12 Step Response Procedure

1. Call Centre directs Public Concern from a citizen or interested party to the On Call Responder.

2. On Call Responder will complete a Public Concern form while in conversation with caller (see attached).

3. On Call Responder will verify with caller if, after investigation a call back is required.

4. On Call Responder investigates the concern and if required, takes necessary action.

5. On Call Responder will document on the Public Concern form actions taken.

6. If required, the On Call Responder will follow up with the original caller advising them of our findings and or action taken.

7. On Call Responder will classify the concern as “reportable” or “non-reportable”. All reportable concerns require an email notification to the appropriate contacts identified on the Public Concern form.

8. The On Call Responder will enter the Public Concern into the Lotus Notes LEHS database, and attach the Public Concern form to the event in the attachments section. Once attached the document must be retained in a secure environment or shredded.

9. A&R Team Lead will conduct a review of the LEHS event report within 5 days for accuracy and technical content. If necessary, the A&R Team Lead will correct and/or add action items and discuss revisions with On Call Responder.

10. A&R HSE Advisor(s) will conduct a review of the LEHS event report within 10 days for accuracy and technical content from an HSE perspective. If necessary, the A&R HSE Advisor(s) will correct and/or add action items and discuss revisions with A&R Team Lead.

11. A&R Managers (Plant or Field) will conduct a review and/or amend the LEHS event within 15 days and if there are no outstanding issues and all actions items are closed move event to “Final”.

12. On receipt of event in Lotus Notes the Social Responsibility Lead will enter information into stakeholder database (Praxis) at their discretion.

Balzac A&R

Last Edit Dec 8, 2011

PUBLIC CONCERN FORM CALL INFORMATION

DATE and TIME: INFORMATION RECORDED BY: NAME: PHONE NUMBER: LOCATION: CONCERNS:

Follow-up call requested? Yes No ODOUR COMPLAINT: YES NO If Yes, complete section below. Can you describe the direction the odour is coming from: NW NE SW SE When did the odour first appear? How long did the odour last? Is the odour still occurring? Yes No

Can you please describe the smell: Faint Moderate Strong Very Strong

INVESTIGATION SECTION Comments from Nexen Representative after Investigation: Nexen Sites Checked for Odour:

Is this event : Reportable Non- Reportable

FOLLOW UP SECTION Follow-up Call Completed by (Name): Follow up Call Details Time: Same day or Date:

Additional Comments: Attach separately as 2nd Page If this is a REPORTABLE PUBLIC CONCERN issue an email notification to:

FIELD MANAGER PLANT MANAGER A&R TEAM LEAD A&R HSE ADVISOR(s) SOCIAL RESPONSIBILITY COORDINATOR

Entered into Lotus Notes: Yes No Date Entered: Attached Concern form to Event: Yes No LEHS #:

34

APPENDIX III – DECOMMISSIONING, REMEDIATION AND LAND

RECLAMATION PLAN

BALZAC GAS PLANT

DECOMMISSIONING

REMEDIATION

&

LAND RECLAMATION

PLAN

SUBMITTED BY:

NEXEN INC.

801 – 7th

Avenue S.W.

Calgary, Ab

T2P 3P7

March 5, 2012

BALZAC GAS PLANT

DECOMMISSIONING, REMEDIATION & LAND RECLAMATION PLAN 2012

1

Table of Contents INTRODUCTION .............................................................................................................. 5

1. Shutdown, Decommissioning and Salvage ................................................................. 6

2. Dismantling and Demolition of Facility ..................................................................... 9

a. Hazardous Materials Removal ............................................................................... 10

b. Demolition of Equipment, Vessels, Tanks and Piping .......................................... 10

c. Demolition of Buildings and Structures ................................................................ 11

d. Processing of Demolition Recyclables .................................................................. 11

e. Transportation of Materials .................................................................................... 12

f. Site Cleanup ........................................................................................................... 12

g. Noise Control ......................................................................................................... 12

h. Dust Control ........................................................................................................... 12

3. REMEDIATION AND RECLAMATION PLAN .................................................... 13

3.1 Remediation Action Plan (“RAP”) .................................................................... 13

3.2 Reclamation Plan ................................................................................................ 13

4. FACILITY BACKGROUND ................................................................................... 14

5. REGULATORY CRITERIA .................................................................................... 15

6. SITE CHARACTERISTICS AS DETERMINED FROM PAST ASSESSMENTS

ON THE BGP ................................................................................................................... 16

6.1 Regional Characteristics ..................................................................................... 16

6.2 Geology .............................................................................................................. 16

6.3 Soils .................................................................................................................... 17

6.4 Hydrogeology ..................................................................................................... 18

6.4.1 Regional Hydrogeology .............................................................................. 18

6.4.2 Present Groundwater Use ........................................................................... 18

6.4.3 Local Groundwater Conditions ................................................................... 19

6.5 Industrial and Surface Water .............................................................................. 20

6.5.1 Catchment Areas – Balzac Gas Plant .......................................................... 21

6.5.2 Catchment Areas – Surrounding Lands ...................................................... 25

6.6 Surrounding Land Use ....................................................................................... 27

7 REMEDIAL CHARACTERIZATION .................................................................... 30

7.1 Previous Investigations and Remedial Programs ............................................... 30

8 CURRENT STATE OF PROPERTY ....................................................................... 69

BALZAC GAS PLANT


2

8.1 Primary Sources of Contamination .................................................................... 71

8.2 Summary of COPCs ........................................................................................... 73

8.3 Soil Conditions ................................................................................................... 76

8.3.1 Contaminants of Potential Concern in Soil ................................................. 77

8.4 Groundwater Conditions .................................................................................... 81

8.4.1 COPCs in Groundwater .............................................................................. 81

8.5 Surface Water Conditions .................................................................................. 85

8.5.1 McDonald Lake .......................................................................................... 87

8.6 Secondary Sources of Contamination ................................................................ 88

8.6.1 Free Phase Hydrocarbon Liquids ................................................................ 88

8.7 Data Gaps ........................................................................................................... 89

8.7.1 Background Data ........................................................................................ 89

8.7.2 Bedrock Flow Mechanism .......................................................................... 89

8.7.3 Geographical and Temporal Data Coverage ............................................... 89

8.7.4 Survey Data ................................................................................................. 92

8.7.5 McDonald Lake .......................................................................................... 92

9 REMEDIAL OPTIONS ............................................................................................ 92

9.1 Determination of End Land Use & Remediation Criteria .................................. 93

10 REMEDIATION PLAN ........................................................................................... 95

10.1 General ............................................................................................................ 95

10.2 Sulphur Handling Facility .............................................................................. 97

10.3 McDonald Lake .............................................................................................. 97

10.4 Noise Management ......................................................................................... 97

10.5 Industrial Runoff Management ....................................................................... 97

10.6 Monitoring Programs ...................................................................................... 98

11 RECLAMATION PLAN .......................................................................................... 99

12 HEALTH & SAFETY PROGRAM .......................................................................... 99

13 COMPLAINT RESPONSE .................................................................................... 100

14 REPORTING .......................................................................................................... 101

Appendix I –Slater Demolition Plan ............................................................................... 102

Appendix II – Waste Management Plan ......................................................................... 103

Appendix III – List of Environmental Reporting Completed for the BGP ..................... 104

BALZAC GAS PLANT


3

TABLES

Table 1. AEPEA Approvals Applicable to BGP ............................................................... 5

Table 2. Equipment Changes on BGP – 2006* ................................................................. 6 Table 3. Equipment Changes on BGP – 2009 ................................................................... 7 Table 4. Summary of catchment area sizes, current land use, and confirmation of Plant

runoff contribution. ........................................................................................................... 23 Table 5. Previous Environmental Investigations by Liability Sub-Unit and Year. ......... 67

Table 6. Liability Sub-Units (“LSU”) .............................................................................. 69 Table 7. Summary of Potential Environmental Issues ..................................................... 71

Table 8. Summary of COPCs in Soil & Groundwater ..................................................... 74 Table 9. COPCs in Soils .................................................................................................. 79

Table 10. Summary of COPCs in Soils ........................................................................... 80 Table 11. Detailed Summary of COPCs in Groundwater by LSU .................................. 82 Table 12. COPCs in Groundwater by LSU ...................................................................... 84

Table 13. COPC in Surface Water Bodies ....................................................................... 86

FIGURES

Figure 1. Catchment Areas within the BGP ..................................................................... 24

Figure 2. Catchment Areas Surrounding BGP ................................................................. 26 Figure 3. Balzac East Area Zoning Map .......................................................................... 29 Figure 4. Complete or Assessed Programs ...................................................................... 68

Figure 5. Liability Sub-Units ........................................................................................... 70 Figure 6. COPC by LSU .................................................................................................. 75 Figure 7. Existing Infrastructure Expected to Remain ..................................................... 94

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ABBREVIATIONS

ACM Asbestos Containing Material AENV Alberta Environment

AEPEA Alberta Environmental Protection and Enhancement Act

AO Aesthetic Objective

BEASP Balzac East Area Structure Plan

BGP Balzac Gas Plant

BPS Balzac Power Station

CAPP Canadian Association of Petroleum Producers

CCME Canadian Councils of Minister of the Environment

COPC Contaminants of Potential Concern

CPW Cathodic Protection Wells

DEA Diethanolamine

DLR Decommissioning, Remediation and Land Reclamation Plan

DRR Demolition, Remediation and Reclamation

ERCB Energy Resources Conservation Board

ERP Emergency Response Plan

GCDWQ Guidelines for Canadian Drinking Water Quality

KVSR KVSR is a brand name compressor LBP Lead Based Paint

LNAPL Light Non-Aqueous Phase Liquid LPG Liquified Petroleum Gas

LSU Liability Sub-Unit

MAC Maximum Acceptable Concentration

MBGS Metres Below Ground Surface

PAH Poly Aromatic Hydrocarbons

PCB Polychlorinated Biphenyl RAP Remedial Action Plan

SDS Shutdown, Decommissioning and Salvage

SMP Soil Monitoring Program

SSLA Site Specific Liability Assessment

SSRA Site Specific Risk Assessment

TDS Total Dissolved Solids

UST Underground Storage Tank

VOC Volatile Organic Compounds

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INTRODUCTION The Balzac Sour Gas Processing Plant (for the processing of natural gas) and the Balzac Sulphur

Processing Plant (herein referred to as the Balzac Gas Plant) are operated by Nexen Inc.

(“Nexen”) of Calgary, Alberta, pursuant to approval No. 6457, issued by the Energy and Utilities

Board (hereafter referred to as the Energy Resources Conservation Board (“ERCB”) and Alberta

Environment (“AENV”) approvals (listed below).

The Balzac Gas Plant (“BGP”) ceased operations permanently on April 28th, 2011 (“Plant

Closure”). Therefore, Nexen is submitting this amendment application for approval to

decommission, dismantle, remediate and reclaim the Balzac Gas Plant (“BGP”).

As part of the overall retirement program, the following undertakings will be completed:

1. Shutdown, Decommissioning and Salvage – All production processes at the BGP are

ceased, equipment on-site is purged of fluids and gas, equipment is inspected and made

safe for eventual demolition equipment is tagged as such, and equipment that can be sold,

reused, or recycled is handled and removed as required or approved;

2. Dismantling and Demolition – asbestos abatement activities are completed then all

equipment is taken apart and taken down for disposal at an approved facility (i.e. landfill,

recycler);

3. Remediation (Management plan is implemented to determine which lands have been, or

require assessment for potential contaminants, and processes are implemented to safely

excavate, remove and dispose of contaminated materials) and Reclamation Plan (site is

restored to an equivalent land capability appropriate with a yet to be determined end land

use).

These undertakings are extremely complex, technical and detailed in scope and execution

requirements. Many processes that form the basis for the undertakings noted above require

specific management, tracking, and outcomes that are too detailed or outside the scope of this

document. These undertakings will therefore be completed in accordance with the general

outline provided in this Decommissioning and Land Reclamation Plan, or updated versions

thereof.

This Plan will be submitted to Alberta Environment in accordance with the following approvals:

Table 1. AEPEA Approvals Applicable to BGP

Approval Number Application Number Effective Date Expiry Date of

Original Approval

155-02-00 008-155 October 31, 2005 September 30, 2015

155-02-01 014-155 September 17, 2007 September 30, 2015

155-02-02 015-155 February 29, 2008 September 30, 2015

155-02-03 017-155 July 23, 2010 September 30, 2015

155-02-04 016-155 January 14, 2011 September 30, 2015

155-02-05 Not Provided March 9, 2011 September 30, 2015

155-02-06 019-155 July 28, 2011 September 30, 2015

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1. Shutdown, Decommissioning and Salvage

The following summarizes previously reported Decommissioning activities:

2006

Nexen upgraded the sulphur handling facilities at the Balzac Gas Plant. The sulphur slaters which

have operated since the1970's were taken out of service in April 2006 and the new sulphur

handling facilities (GX Units) were put into full scale operation. During 2006, some of the

sulphur slating facilities were decommissioned and removed. See the equipment list in Table 2

below for the status of the slater decommissioning and removal.

Table 2. Equipment Changes on BGP – 2006*

DESCRIPTION QUANTITY NOTES* SCHEDULE

SLATER BELTS 6 Item # 4 3rd Quarter 2006 - Removed

SLATER FRAMES 6 Item # 4 3rd Quarter 2006 - Removed

SLATER MOTORS 6 Item # 4 3rd Quarter 2006 - Removed

SLATER FANS 24 Item # 4 3rd Quarter 2006 - Removed

SLATER DRIVES 6 Item # 4 3rd Quarter 2006 - Removed

SLATER BUILDING 1 Item # 5 3rd Quarter 2006 - Removed

ELECTRICAL WIRING LOT 3rd Quarter 2006 - Removed

ELECTRICAL STARTERS 7 3rd Quarter 2006 - Removed

WATER COOLER 1 Item # 9 3rd Quarter 2006 - Removed

COLLECTOR CONVEYOR 1 Item # 13 3rd Quarter 2006 - Removed

*The information provided in this table (specifically the Notes column) refers to the demolition map provided in

Appendix I of this document.

2007

Nexen started removing the sulphur contaminated soil pile which was located on the Plant site

south of the current west sulphur basepad. during October 2007 in two phases. Phase I of the

project started on October 31, 2007 and finished November 23, 2007.Approximately 27,396

metric tonnes of sulphur contaminated soil was removed from the plant site and hauled to an

approved landfill in Phase 1 of this project. Phase 2 of this project was completed in 2008.

2008

Nexen started removing the sulphur contaminated soil pile (Phase 2) and sulphur impacted

underlying soils which were located on the Plant site (south of current west sulphur basepad)

during the first quarter of 2008. Approximately 58,234 metric tonnes of sulphur contaminated soil

was removed from the plant site and hauled to an approved landfill. (Phase 2)

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Nexen removed sulphur contaminated material (Topsoil Stockpile) which was located adjacent to

the Enersul Sulphur Storage Pile in 2008. Approximately 15,086 metric tonnes of sulphur

contaminated soil was removed from this area in 2008 and disposed of at an approved landfill.

Nexen also removed 3,093 metric tonnes of hydrocarbon contaminated soil from the Unknown

Sump which was located adjacent to the Plant Flare Area in 2008. This contaminated material

was removed from this area in 2008 and disposed of at an approved landfill.

2009

Nexen removed the sulphur contaminated material which was located on the site of the removed

Enersul Slating Area in 2009. Approximately 29,138 metric tonnes of sulphur contaminated soil

was removed from the Enersul Slater Area in 2009 and disposed of at a landfill.

Delays were encountered as the result of finding subsurface asbestos contaminated material

which necessitated halting further work to develop a detailed safety and environmental plan

before going ahead with this part of the project. Nexen has decided to include this project in the

overall plant wide hazard assessment. Enersul sump area (located adjacent to the sulphur storage

pad) construction was also delayed due to a change in design plans for sump. As the area is now

shutdown this too will be included in the overall plant wide hazard assessment.

Table 3 summarizes the equipment removed or changed in 2009.

Table 3. Equipment Changes on BGP – 2009

DESCRIPTION QUANTITY NOTES SCHEDULE

WATER TANK 1 Item # 11 3rd Quarter 2009 - Removed

WATER PUMP 2 Item #10 3rd Quarter 2009 - Removed

WATER PUMP BUILDING 1 Item # 10 3rd Quarter 2009 - Removed

SHOP 1 Item # 6 3rd Quarter 2009 - Removed

SEPTIC TANK 1 Item # 7 3rd Quarter 2009 - Removed

FUELS & OIL STORAGE 1 Item # 8 3rd Quarter 2009 - Removed

SITE OFFICE &

CHANGEROOMS 1 Item#12

3rd Quarter 2009 - Removed

STORAGE BLDG. 1 Item # 35 3rd Quarter 2009 - Removed

2010

Nexen planned and executed the removal of the West Cooling Tower in 2010. A pre-demolition

sampling and testing program was conducted on materials slated for demolition and removal.

The following pieces of equipment were removed:

1. West Cooling Water Tower - 3 Banks were removed complete with piping, trays inside the

tower and fans and motors were all demolished and disposed of. The basin/sump was left

intact.

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2. West Cooling Water Deluge Building and all piping attached to the building was demolished

and disposed of.

3. West Cooling Tower Sand Filter (Tank) and associated piping, sand, etc. was removed and

disposed of. The foundation was left intact.

2011

As part of the overall retirement program, shutdown, decommissioning and salvage (SDS)

activities have already been initiated to shut down and clean the plant. The Plant was in the SDS

phase of the Project from June to December of 2011. The Plant has been prepared, cleaned and

its various systems de‐energized. Items available for immediate disposition and salvage have

been identified, and the Plant was turned over to the Demolition, Remediation and Reclamation

project (“DRR”) as of December 15, 2011, which will demolish the facilities, remediate the soil

and ultimately reclaim the site. Prior to demolition, outstanding hazards will addressed including

the large scale abatement project for 2012.

Disposition of select pieces of equipment is occurring as per Nexen’s submission to AENV on

April 6, 2011, entitled “Licence Amendment Application – Asset Disposition & Select Monitoring

and Reporting Changes” and subsequent submissions and as per Amendment Approval # 155-02-

06. In order to maximize asset value, offset future demolition/disposal costs and reduce the

amount of waste sent to landfills, a condensed list of assets deemed to be in good condition was

offered to interested parties for transfer or sale.

Where an asset does not sell for reuse, an attempt will be made to recycle the asset by selling it

for scrap. If the scrap value cannot be realized for an asset, it will be sent to an approved landfill.

The priority for asset disposition is:

Transfer/sell for reuse;

Sell for scrap / recycle;

Donate;

Landfill (this categorization will only be made after reasonable investigations

into options for recycling traditional waste streams. Nexen will investigate these

options as waste streams are further identified.

A preliminary list of BGP assets has been developed. This list will become a master asset list of

all BGP assets: major equipment, spare parts, instrumentation, electrical equipment, furniture, etc.

Sub-lists will be generated from this master list and distributed to partners, potential buyers,

regulators and others as required. Scrap and waste disposals will also be recorded in the database,

although waste streams will be tracked in the overall Waste Tracking database as well.

Any equipment leaving the site (working component, scrap or waste) will be documented and

appropriate updates will be made to internal tracking systems and the Alberta Boilers Safety

Association (“ABSA”) (where applicable).

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The SDS project has dismantled and demolished only to the extent required by the work of

shutdown and decommissioning as well as the pursuit of any salvage opportunities that arose

while the SDS project was ongoing. Apart from wastes which were produced by the SDS

execution and other wastes which must be disposed of to make the Plant safe for dismantling and

demolition, most salvage and waste activities will be executed by the DRR project.

Waste management will be protective of human health and the environment by controlling and

minimizing exposure to hazardous materials. The intent is to minimize the volume of waste

delivered to registered disposal facilities by minimizing waste generation and maximizing the re-

use and recycling of material.

Groundwater wells that are not of potential interest to future monitoring or study will be

decommissioned. Prior to decommissioning any wells, Nexen will obtain agreement to do so from

AENV. Monitoring wells that are a key part of the Site’s monitoring program will be replaced if

there is a need for their decommissioning during remediation or construction.

2. Dismantling and Demolition of Facility

The demolition of the Balzac gas plant is tentatively planned for execution in 2013. The

objective will be to bring the plant site down to grade by demolishing all structures

elevated above the level of the building slab. This would include any raised perimeter

grade beams or pedestals for columns / equipment that are located outside or inside the

buildings. All resulting debris and recyclable materials will be removed from the site as

it is accumulated.

A SDS Health Safety & Environment (HSE) plan is developed based on the Nexen Inc.

(Nexen) Canadian Oil and Gas, the BGP HSE Management Systems (SMS), as well as

applicable regulations and they will be adhered to as the minimum requirement. In

addition, contractors task specific procedures will also be utilized providing they meet or

exceed Nexen’s expectations. Any concerns or questions regarding the expectations

referenced in this plan shall be brought forward to a Nexen supervisor and/or the site

Safety and Environmental Advisors for resolution.

All Nexen management, supervisory and contractor staff will be expected to be familiar

with this plan. Nexen is the Prime Contractor for the SDS Project. Any non-compliance

to the requirements identified in this HSE plan may result in corrective action up to and

including dismissal.

All applicable government rules, regulations or restrictions, Federal or Provincial or

local, in effect must be met or exceeded.

Activities that will be conducted on site include:

removal of any remaining hazardous materials

demolition of applicable equipment, tanks, vessels and piping

demolition of applicable buildings and structures

processing of demolition recycling and debris

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transportation and offsite disposal of recyclables and demolition debris to

approved waste sites

final site cleanup

a. Hazardous Materials Removal

All remaining hazardous materials that were identified in a comprehensive site survey

will be abated prior to building demolition. These hazardous materials may include but

are not limited to:

Domestic-type wastes (non-hazardous, "garbage")

Salvage metals, i.e. Iron, Copper, Tin, Steel

Construction waste (general building materials, e.g. concrete, plaster, wood, etc.)

Glass and ceramics

Asbestos-containing or contaminated materials (insulations, building materials,

abatement waste materials) (ACM)

Asbestos-contaminated water (filtered)

Synthetic (non-asbestos) insulating materials

Lead-acid batteries

Mercury, liquid in instrumentation

Mercury lamp bulbs and tubs

PCB Transformer oil (potential)

PCB-containing lamp ballasts (potential)

Ozone-depleting refrigerants (HVAC units)

Other Dangerous Oilfield Wastes ("DOW"), e.g. residual chemicals or

contaminated materials as identified during demolition

Lead Based Paint (LBP)

Oil / Liquid containing devices

Bird and Rodent Excrement

Handling, transportation and disposal of regulated equipment, building accessories and

generated wastes shall be in accordance with applicable laws and regulation. All wastes

will be accurately recorded and tracked as per current site procedures.

b. Demolition of Equipment, Vessels, Tanks and Piping

All equipment, vessels, tanks and piping not identified as remaining on site will be

demolished / removed and segregated. Equipment, materials and methods for demolition

will be provided by the site demolition contractor and verified by Nexen prior to

executing the work. It will be ensured that any adjacent structures (i.e. buildings,

pipelines, etc.) that are not scheduled for demolition will be adequately protected.

Removal of residual liquids / materials, decontamination and removal of all items shall be

performed in a way that prevents uncontrolled discharge of fluids and maximizes material

/ liquid recovery.

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Nexen will ensure that all Alberta Boiler Safety Association (ABSA) disposition

guidelines are followed for any registered pressure vessels.

c. Demolition of Buildings and Structures

All buildings and structures that have not been identified as remaining on site will be

demolished / removed and segregated. The at-grade portion of the building

foundations will stay in place while all other above grade concrete foundation

components will be removed. All Building Foundations and/or Concrete Pads Used

to Support Equipment: During the salvage component of the SDS phase, equipment

was/is being removed for sale. Some of that equipment was/is situated on concrete

support pads. During the DRR phase of the project, remaining pieces of equipment,

facilities, buildings, piping, etc… will be demolished and removed. Following the

demolition and removal of equipment, if warranted Nexen will leave all foundations

and concrete pads in place until the remediation phase of the project begins. If

concrete at surface is in the way of equipment removal then activities may be

undertaken to remove surface concrete for access purposes only. Subsurface concrete

associated with these specific projects would then be removed at a later date. Both

the Dismantling and Remediation processes require separate and unique management

techniques, which are easier to manage separately. Therefore, the intent is NOT to

leave foundations and pads in long term but to accomplish two things:

i. Avoid creation of open holes, pits or excavations that would then become

workplace hazards to personnel completing demolition components. Nexen has

completed a risk analysis and hazard assessment of the removal of the

foundations or concrete pads. It was determined that in order to reduce safety

hazards on the project site, minimizing disturbed ground or open excavations is

desirable; and,

ii. Avoid disturbance of underlying soils and materials that may have been

potentially affected by contamination. This will allow Nexen to fully determine

appropriate remediation processes at these numerous locations prior to

disturbance of the foundations and pads. This will allow Nexen to implement

appropriate management, safety and remediation protocols at that time.

Equipment, materials and methods for demolition will be provided by the site demolition

contractor and verified by Nexen prior to executing the work. It will be ensured that any

adjacent structures (i.e. buildings, pipelines, etc.) that are not scheduled for demolition

will be adequately protected.

d. Processing of Demolition Recyclables

Processing of steel and other materials will occur on site to make them suitable for

transport to scrap or material recycling facilities. Processed materials will be transported

off-site on a regular basis to avoid large accumulations.

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e. Transportation of Materials

All demolition wastes, both hazardous and non-hazardous, and recyclables will be

transported in accordance to all applicable laws and regulations. This includes, but is not

limited to, The Transportation of Dangerous Goods Act and any local road use

agreements and restrictions. Furthermore, Nexen will manage transportation and waste

management as per the Waste Management Plan provided in Appendix II.

f. Site Cleanup

At the completion of demolition, the site will be free of all demolition materials,

equipment and temporary facilities. Building foundations that are left in place with

trenches, sumps and pits will be backfilled to slab-on-grade or equivalent at Nexen’s

discretion. The site will be graded to ensure that adequate surface drainage is in place.

g. Noise Control

Nexen will follow existing regulations for noise control to reduce effects of noise on

nearby residents and workers. Nexen will comply with the requirements of:

Municipal District of Rockyview No. 44 Bylaw No. C-5772-2003 (aka “Noise

Control Bylaw”);

Occupational Health and Safety Act, Occupational Health and Safety Code 2009.

Approved (recommended CSA Class A or CSA Grade 4) hearing protection

devices must be worn at all times where noise levels exceed 85 DBA. These

areas will usually be marked with signage stating that hearing protection is

required;

Environmental Noise impacts shall be minimized as much as possible.

Reasonable mitigation measures will be taken to reduce noise impacts on the

public, domestic animals or wildlife during operation activities that might cause

adverse noise impacts.

h. Dust Control

When workers are or may be exposed to airborne contaminants or a mixture of airborne

contaminants in concentrations exceeding the occupational exposure limits defined in

OHS regulations for specific province of work, to atmospheres with an oxygen

concentration of less than 19.5% by volume, and/or to other airborne contaminants such

as dusts, hazardous and noxious fumes, rodent infested work areas, etc., the appropriate

respiratory protective equipment must be worn.

Nexen will implement appropriate dust suppression measures on roads, work areas, or

transportation and loading routes as on BGP roads. Further dust control MAY be

required on the existing county road located on the east boundary of the BGP, from the

BGP to Highway ?, located north of the BGP. The decision to control dust will be made

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at the field level and will depend upon site conditions, level of activity, and worker health

and safety.

3. REMEDIATION AND RECLAMATION PLAN This Decommissioning and Reclamation Plan describes general methodologies that will be

implemented to remediate and reclaim the Balzac Gas Plant. The scope of this plan is as follows:

3.1 Remediation Action Plan (“RAP”) The objective of the RAP will be to identify and appropriately manage and remediate

contaminants of concern at the BGP. The RAP is currently under development and includes:

Site Characterization and Background Characterization;

Summary of Previous Assessments and Site Characterizations;

Proposed Remediation Criteria; and,

Remediation Plan for soil, groundwater and sediment;

Management of surface water

The RAP consists of the following components:

1. Facility Background;

2. Regulatory Criteria;

3. Site Characterization;

4. Remedial Characterization;

5. Current State of Property;

6. Remedial Options;

7. Remediation Plan;

8. Health and Safety Program; and,

9. Complaint Resolution System.

Due to the extensive amount of information collected at the BGP since the 1960s, the complex

nature of the infrastructure, and a myriad of unknowns, in order to effectively determine the most

appropriate RAP, Nexen anticipates a 2-3 year timeframe for appropriate development.

Therefore the RAP will be submitted to AENV with the renewal application in 2015. The RAP

will be under constant review and may change prior to the initiation of on-site activities and/or

completion of the overall program at the BGP.

3.2 Reclamation Plan

Following successful remediation at the BGP, reclamation activities will be conducted to meet

regulatory requirements for end land use that may exist at that time and to ensure topsoil

management, drainage restoration, erosion control and re-vegetation are effective.

Each aspect will be discussed in the following sections.

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4. FACILITY BACKGROUND

The Balzac Gas Plant is located adjacent to the Calgary's city limits, in LSD 7-2-26-29 W4M.

Other nearby communities includes the towns of Balzac and Airdrie, Alberta.

The Balzac Gas Plant was a sour, natural gas processing plant that received gas streams from

surrounding well sites and produced specification sales gas with the recovery of propane, butane,

condensate, and sulphur. The operation used conventional gas processing units with inlet

separation, gas compression, amine sweetening (hydrogen sulphide (H2S) and carbon dioxide

(CO2) removal), refrigeration/dehydration, condensate stabilization, sulphur recovery, and LPG

fractionation.

Propane and butane were stored in horizontal pressure tanks in the tank farm and were loaded into

truck or rail car for delivery to markets. Condensate was stored in tankage and transferred to the

Pembina Pipeline system for delivery to refineries. Sales gas was sent to the Trans Canada

Transmission pipeline system, and liquid (molten) sulphur was processed into a sulphur

granulation product (prilled) and shipped by rail to Vancouver. Enersul operated and owned the

sulphur granulation facility. The sulphur granulation process was discontinued after May 2011.

Approximately eighty-one producing gas wells (“Balzac Field”) supplied the raw natural gas

mixture to the plant for processing. Most of the gas produced from the wells is considered "sour"

meaning naturally-occurring H2S is present. H2S content varies from well to well and from

different formations. Within the Balzac field, H2S in the produced sour gas varies from 0.6% to

42%.

In the Balzac Field, all Crossfield and Elkton pipelines have been shut in and purged with

Nitrogen. Basal Quartz pipelines were pigged with fuel gas. All Crossfield wells have been

blinded at the wellhead. Elkton wells and Basal Quartz wells have been shut-in as per ERCB

requirements.

The Plant has been shut down in a safe, controlled fashion, equipment and piping was

decontaminated and any sources of energy, such as steam and electricity, isolated and shut off as

required. The shutdown was managed by the Shutdown, Decommissioning and Salvage (“SDS”)

team comprised of a group of operations, maintenance, environmental and safety personnel from

the Plant, in addition to contractors familiar with the Plant and experienced to execute work in a

safe, efficient manner. Decommissioning activities to bring the Plant to a state of zero energy and

make it safe for demolition began May 31st and will continue for the remainder of the year.

Under Nexen’s current operating approval with Alberta Environment, Nexen is required to submit

a Decommissioning and Land Reclamation (“DLR”) amendment within six (6) months of closure

of the facility. Approval of the DLR amendment is expected in 2012.

The Balzac Power Station (BPS) is located near the northern extent of the BGP property, but

within the BGP boundaries, on the shores of McDonald Lake. The BPS operates under a separate

AEPEA Approval (Approval #: 136858-00-00). The power plant generates 105 MW of

electricity to meet power demands of southern Alberta, Calgary specifically. The plant consumes

BALZAC GAS PLANT


15

826 MMBtu (HHV)/h of natural gas and 3,000 m3/d of water. Approximately 100 to 300 m

3/d of

process wastewater is produced from plant operations. The Power Station consists of:

Two (2) GE LM-6000 PC E-Sprint gas turbines

Two (2) once-through steam generators (OTSG)

One (1) Dresser-Rand steam turbine

Steam and condensate distribution;

Cooling water system;

Glycol heating system;

Make-up water treatment system;

Boiler feed water polisher system; and

Instrument air system.

This power station will remain active during decommissioning of the Gas and Sulphur Plants and

remediation and reclamation of the larger property parcel. There is no current plan to

decommission this power station. There is also associated infrastructure (pipelines carrying gas

and water) running to and from the BPS that travel above grade across the larger property that

will remain in place after decommissioning of the Gas Plant. This infrastructure has been

considered during the development of this remedial plan.

5. REGULATORY CRITERIA

As discussed in subsequent sections, appropriate remediation criteria have been selected and are

protective of human health and ecological receptors. Through the use of generic remediation

criteria as may be deemed appropriate, and the use of site specific remedial guidelines and/or risk

assessment where possible, this RAP will be implemented in a manner that is protective of human

health and the environment, such that these lands will be returned to safe, and productive end land

use.

There are four options available to Nexen for remediation of the BGP. Each of these options is

discussed in greater detail in the Tier I and Tier II Soil and Groundwater Remediation Guidelines

(December 2010). These options include:

1. Remediation (insitu or exsitu) of soil, groundwater, surface water, and sediment to the

AENV Tier I guidelines (or the CCME environmental quality guideline for parameters

not included in the AENV guidelines).

2. Remediation (insitu or exsitu) of soil, groundwater, surface water, and sediment to AENV

Tier II site specific guidelines which would be developed for the BGP site for each

Contaminant of Concern (COC). Tier II site specific guidelines would be established

through pathway exclusion and/or parameter adjustment in consultation with AENV.

3. Completion of a Tier II Site Specific Risk Assessment (SSRA), possibly allowing for

soils, groundwater, surface water and/or sediment to remain in place. Remediation,

where necessary (insitu or exsitu), would be completed to the Tier II site specific

BALZAC GAS PLANT


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guidelines. This option will almost always require a monitoring plan until stable end

points are demonstrated.

4. Exposure Control and Long Term Risk Management (Human Health) and Ecological

Risk Assessment (Ecological Health and McDonald Lake).

Options 1 to 3 allow for full regulatory closure under the Alberta Environment Environmental

Site Assessment Program (Record of Site Condition). Regulatory closure would allow Nexen to

divest of the property in the future. Option 4 does not allow for regulatory closure. It is fully

protective of human and ecological health, with a management plan/exposure control plan in

place. This option would allow Nexen to redevelop and/or lease the property in the future.

Risk assessment activities will ensure that no long term risk is present to the aquatic environment

from remediation activities and surface run off or groundwater inputs from the BGP.

6. SITE CHARACTERISTICS AS DETERMINED FROM PAST

ASSESSMENTS ON THE BGP

This section outlines the regional characteristics, site specific geological, hydrogeological, soils,

surface water and groundwater characteristics of the property and surrounding areas, and

surrounding land use.1

6.1 Regional Characteristics

The Site is located within the Alberta Plain, a sub-region within the Interior Plains physiographic

region of Canada. The plains are characterized by gently rolling landscape with flat-topped hills.

Creek and river valleys are generally broad and deep, representing mature drainage features. The

regional terrain generally slopes from west to east, with a moderate elevation change from

approximately 1,092 metres above sea level (masl) near the Balzac facility, to roughly 1,070 masl,

near Twin Lakes 7 km to the east.

6.2 Geology

Bedrock encountered below the site is the Upper Porcupine Hills Formation, which consists of

dark to very dark grey, fractured and weathered, calcareous siltstone, very fine-grained sandstone,

and claystone. To date, the maximum depth of exploration into the bedrock on-site is 95 metres

below ground surface (mbgs). Regionally, the thickness of the Porcupine Hills Formation is

about 450 m, thinning towards the east.

Surficial deposits, approximately 2 to 11 metres thick, overlay the bedrock. Beneath much of the

Plant site, these deposits have been disturbed as a result of original site grading during

construction of the plant in the late 1950’s. This is evident from the 0.6 to 1.8 m thick layer of fill

in the process area. Native surficial deposits cover the remainder of the site and consist of a

1 References for Section 6.0 Site Characterization were taken from consultant reports listed in Section 7.1

of this report.

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blanket of calcareous, low to medium plastic, sandy silt (Balzac Formation) overlying a silty clay

till (Lochend Formation), containing thin, silty sand lenses ranging from 0.1 to 1.3 m thick. These

Quaternary deposits vary in thickness from 3.0 to 6.7 m at the site. The majority of till appears to

be oxidized, as evidenced by brown colouration and the abundance of iron oxide staining.

However, the lower 1.0 to 1.5 m becomes dark grey to mottled grey-brown in colour, indicating

the presence of a relatively thin transition zone from oxidized to unoxidized till.

During field work in support of the 2006 Site Management Plan, a unit of black organic silty clay

to clayey silt approximately 0.3 to 2.2 m thick was encountered in boreholes covering a large

portion of the southeast part of the Site. Field observations suggest that these sediments were

deposited in a lacustrine environment. Initial results of an investigation into the effects of acid

conditions beneath the west sulphur basepad indicate that this organic layer possesses significant

buffering capacity.

Little topographic gradient can be seen across the Site and hence surface water often ponds onsite

without mechanical pumping.

At the site, there are three distinct water-bearing zones identified in the groundwater monitoring

network. The three zones are defined as follows: Weathered Till Horizon or A-series,

Till/Bedrock Contact or B series, and Bedrock or C-series. Depths of the A-series piezometers do

not exceed 5.1 mbgs. Generally, the A-series wells are completed in silty sand or sandy-silt clay

till. The till is typically moist or saturated and mottling is common. Sub-angular pebbles and

cobbles of various lithologies are prevalent throughout the till across the site. Gypsum crystals are

evident within the till at some piezometers.

The B-series piezometers range from 4.3 to 8.4 mbgs and are screened such that they intersect the

weathered till just at the bedrock contact. They include a very minor portion of the upper bedrock

within the screen. Beneath the till, a very fine, grey sandstone or siltstone is apparent. This unit is

very hard and dry. The sandstone or siltstone alternates with a shale unit to a maximum depth of

28.3 mbgs. The shale is hard, dark grey, brittle and breaks into blocky, angular fragments.

Groundwater flows within the highly fractured shale unit and the depth to groundwater increases

with distance from the lake.

Depths of the C-series monitoring wells vary from 4.1 to 28.3 mbgs.

6.3 Soils The soils of the Site have been mapped as a complex of poorly drained saline Humic Gleysols,

well drained Black Chernozems, and well to imperfectly drained Solodized Solonetz. These soil

types have formed on a thin discontinuous layer of lacustrine sediments overlying till. This till

was deposited in a lower-lying groundwater discharge area divided by occasional well-drained

knolls. All soil types have a black surface horizon (Ah) of varying thickness and texture and high

organic matter content. The light coloured sub soils (Csak) generally contain free lime and

soluble salts.

The majority of the soils sampled near the Site are the Balzac series, which is a saline-carbonate

Rego Humic Gleysol. Balzac soil is poorly drained, and forms where saline groundwater is

permanently maintained near the soil surface. This soil type is associated with groundwater

BALZAC GAS PLANT


18

discharge and shallow water table areas. Based on the soil survey information and investigative

observations made to date, surface mineral soils of the subject area are saline and calcareous, and

possess a high buffering capacity.

6.4 Hydrogeology During operations, Nexen has completed numerous assessments of groundwater at the BGP

resulting in significant understanding of the regional and local hydrogeology of the area.

6.4.1 Regional Hydrogeology

Porcupine Hills Formation has the potential to contain major aquifer intervals in the area.

Regional groundwater flow in the deeper bedrock is towards the east-southeast. Potential well

yields have been found to range from less than 0.075 L/s to more than 37.5 L/s. In the vicinity of

the plant (5 km radius), groundwater yields range from 0.04 to 11.4 L/s, based on AENV water

well records. Groundwater in the Porcupine Hills Formation is dominantly sodium-bicarbonate

and sodium-bicarbonate-sulphate types exhibiting total dissolved solids (TDS) of approximately

1,500 mg/L. In general, the water quality would be considered poor, based on sulphate and TDS

values in excess of the aesthetic objective (AO) for drinking water quality, with both AO values

set at 500 mg/L.

As previously noted the Quaternary deposits in the area are relatively thin (2 to 11 m) and have

little potential for groundwater resource development, based on their low hydraulic conductivity

and poor water quality. Water produced from the tills commonly has a very high mineralization,

usually associated with sodium and sulphate. Due to the elevated sulphur content in local till

deposits, concentrations of naturally occurring sulphate in groundwater may typically be in excess

of the current Health Canada (2006) AO guideline.

6.4.2 Present Groundwater Use

All water well records within a 5 km radius of the Balzac Sour Gas Plant were reviewed in 2006.

Relevant information was obtained from the AENV Water Well database. A total of 354 water

wells records were obtained from the database search. The state of wells within the area of

interest and their locations were not field verified. The majority of the wells were installed from

1939 to 2001. Well completion depths range from approximately 10 to 137 mbgs, with the

majority of wells being completed within 60 m of the ground surface.

Groundwater use in the study area was as follows:

Domestic use: Approximately 80% ;

Mixed use (domestic, livestock, irrigation): Approximately 4% ;

Livestock watering use: Approximately 10%;

Industrial use: Approximately 1%; and,

Other/Unknown use: Approximately 5%.

BALZAC GAS PLANT


19

6.4.3 Local Groundwater Conditions

Regional water quality surveys have been conducted on a voluntary basis by Nexen at locations

surrounding the BGP since 1967. These surveys were conducted annually from 1967 to 1976, and

biennially thereafter, last occurring in 2007. The 2007 monitoring program included 15 domestic

supply wells and 2 stock wells. Surface water samples were collected from 2 dugouts and

McDonald Lake. In addition, one industrial injection well was sampled.

The 2007 groundwater quality results were generally consistent with previous programs. The

main findings of that study are summarized below.

Indicator Parameters

Groundwater in the region is generally a sodium-bicarbonate-sulphate type. Many of the domestic

supply wells sampled have natural concentrations of sodium, sulphate, turbidity, and TDS that

exceed the respective aesthetic objectives as defined in the Guidelines for Canadian Drinking

Water Quality (GCDWQ).

Significant variations in the main ion concentrations of the water sampled from McDonald Lake

have been documented over the years. Concentrating effects from evaporation and periodic

dilution from major runoff events are believed to be the cause. The presence of surface salts

around the edges of McDonald Lake supports the hypothesis of excessive evaporation as a

controlling mechanism. Chloride concentrations on the west side of the lake opposite the Plant

facility have been found to range from 375 mg/L to 1,750 mg/L depending on time of sampling.

Similar variations in ion concentrations are observed in samples from other surface water bodies

in the area.

McDonald Lake and the Southwest Dugout are potentially accessible for livestock watering. The

2004 Regional Groundwater Monitoring Program indicated that the sulphate concentrations in

samples from McDonald Lake and the SW dugout within the Plant boundary exceeded the

Canadian Council of Ministers of the Environment (CCME) (1999) livestock guideline of 1,000

mg/L.

Dissolved Hydrocarbons

Water samples were analyzed for benzene, toluene, ethylbenzene, and xylenes (BTEX), and

petroleum hydrocarbon fraction 1 (PHC F1). Hydrocarbons were not detected in any of the

domestic or stock wells tested with the exception of a single well which reported a toluene

concentration of 0.0012 mg/L in November 2004. A confirmatory sample and a duplicate were

taken at this location in December 2004 and the results were both below the analytical method

detection limit (<0.0004 mg/L). The November 2004 result was not confirmed and was likely due

to laboratory error.

Total Metals

The 2004 analytical schedule was updated to include total metals analysis instead of dissolved

metals analysis. Total metals analysis should be performed when sampling from developed water

wells or surface water bodies, including residential water wells. All reported concentrations of

total metals were below the respective Guidelines for Canadian Drinking Water Quality

BALZAC GAS PLANT


20

“(GCDWQ”) criteria with the exception of total iron and manganese, which may be a result of

natural conditions, and total arsenic at McDonald Lake. Historically, elevated arsenic

concentrations in excess of the Health Canada (2006) Maximum Acceptable Concentration

(MAC) have been reported at well 821. In 2002 and 2004, the arsenic level reported at well 821

remained below the respective MAC of 0.025 mg/L. In 2002, dissolved arsenic concentrations

above the GCDWQ guideline were measured in the Dugout southwest of the Plant (sample 004)

and in McDonald Lake. In 2004, the total arsenic concentration reported at McDonald Lake

(0.0977 mg/L) exceeded the Health Canada (2006) MAC.

At the BGP, arsenic is not a chemical used, or created, as a result of operating processes.

Furthermore, sampling procedures and findings in groundwater assessments lead Nexen to

believe that arsenic levels previously identified, represent background/natural conditions in

McDonald Lake.

Biological Parameters

Total coliforms were below the Maximum Allowable Concentration (‘MAC’) of 10 mpn/100 mL

at all residential wells sampled and fecal coliforms were not detected in any residential wells. All

surface water samples analyzed in 2004 indicated the presence of total coliforms in excess of 10

mpn/100 mL. Fecal coliforms were detected at location 883 (Nexen Slough). The surface water

bacteriological results are consistent with the use of the water bodies by livestock and/or

waterfowl.

6.5 Industrial and Surface Water A Industrial Runoff Management Report was prepared in 2003 for Nexen by Westhoff

Engineering Resources, Inc. (Westhoff, 2003). Westhoff (2003) was a component of the Plant

license renewal application as submitted to Alberta Environment in August, 2003. It described

findings of a site assessment, a review of historical water releases into McDonald Lake, and the

industrial surface runoff drainage system including an assessment of site catchment areas, site

drainage infrastructure, and the locations where surface runoff is released to McDonald Lake.

Westhoff (2003) also assessed industrial runoff quantity through modelling and a separate water

balance analysis of McDonald Lake. The following description of catchment areas is based

largely on the Westhoff (2003) report with confirmation completed during site visits by Worley

Parsons Komex.

Generally, runoff of the Plant is collected in surface ditches and ponds. Much of the south end of

the Plant is self-contained in the sense that runoff stays on site through infiltration and/or

evaporation.

Runoff from the north end is fed via a series of pumps through a water treatment system,

collected in the Sulphur Block Area Surface Runoff Collection Pond and tested before it is

released to McDonald Lake. Runoff from the Plant is released to McDonald Lake in a controlled

manner and only after it has met the release limits of the Approval.

The most important surface drainage feature near the site is McDonald Lake located on the

western edge of the BGP. No streams, creeks, or natural watercourses enter or leave the lake, and

therefore, it is assumed that the lake is a discharge point. Overland drainage from adjacent

BALZAC GAS PLANT


21

agricultural and pastureland is also known to accumulate in the Lake. Surface runoff occurs

mainly during the spring snowmelt, or immediately following periods of heavy precipitation.

Historical aerial photos indicate that in the past, McDonald Lake has dried.

A report on assessing Industrial Runoff was prepared by Worley Parsons per operating approval

requirements and it was submitted to Alberta Environment in 2006. The purpose of the report was

to review runoff management at the Plant and evaluate current practices to determine what

improvements could be made to positively impact the site and the watershed downstream of the

plant. Worley Parsons Komex Report: Balzac Gas Plant – 2006 industrial Runoff Assessment - File No. C25531806

6.5.1 Catchment Areas – Balzac Gas Plant

Currently there are a total of eight catchment areas across the BGP Site as shown in Figure 1.

Generally, runoff of the Plant is collected in surface ditches and ponds. Much of the south end of

the Plant is self-contained in the sense that runoff stays on site through infiltration and/or

evaporation. Runoff from the north end is fed via a series of pumps through a water treatment

system, collected in the Sulphur Block Area Surface Runoff Collection Pond and tested before it

is released to McDonald Lake. Runoff from the Plant is released to McDonald Lake in a

controlled manner and only after it has met the release limits of the Approvals.

Catchment Area A – Process Area and Sulphur Storage Area

Catchment area A contains two sub-catchment areas: the Sulphur Storage Area (A -1) and the

Process Area (A -2). Surface runoff from the Process Area is naturally conveyed to the S.E.

Runoff Pond located between the railway spur line and the Firewater Pond. From there runoff

flows northward along a drainage ditch towards the S.W. Crusher Pump Station. Runoff from

portions of the Sulphur Storage Area is also collected at the S.W. Crusher Pump Station via small

culverts under the rail line. This surface runoff is then pumped into a High Density Polyethylene

(HDPE) lined swale and commingled with runoff water from the remainder of the Sulphur Storage

Area. In the HDPE lined swale, this water flows by gravity to the single lined HDPE Containment

Pond.

A Crusher Pump Station is in place because generally surface grades do not permit the flow of

surface runoff from the S.E. Runoff Pond and the majority of the Sulphur Storage Area to the

Acid Water Containment Pond. The runoff water is collected in the Acid Water Containment

Pond treated with caustic to neutralize pH and then pumped to the Sulphur Block Area Surface

Runoff Collection Pond. The water in the Sulphur Block Area Surface Runoff Collection Pond is

analyzed for parameters as identified in the approval and released to McDonald Lake, provided

that it meets the release limits.

Catchment Area B – Firewater Pond

Catchment area B is a 0.50 ha self-contained retention area for the storage of fire water with no

structural connections to the adjacent catchment areas. This pond is filled with water supplied by

the City of Calgary to provide a fire suppression contingency for the Plant.

BALZAC GAS PLANT


22

Catchment Area C – Sulphur Handling Facility and Surrounding Area

Catchment area C is a triangle shaped area between the Sulphur Storage Area and Range Road

291with local Plant roads on the north and the S.E. Quadrant (catchment area E) on the south.

Surface runoff from the Sulphur Handling Facility itself is collected and conveyed via two

culverts to the Acid Water Containment Pond where it is treated with caustic to neutralize pH and

pumped to the Sulphur Block Area Surface Runoff Collection Pond. A portion of runoff

generated from this catchment is drained to a Low-Lying Area west of Range Road 291.

Catchment Area C-C – Plant Entranceway and Surrounding Area

Catchment area C-C is a triangle shaped area between the Sulphur Storage Area and Range Road

291 and Plant entranceway. Surface runoff from the Plant Entranceway flows to McDonald Lake.

Catchment Area D – Sulphur Block Area Surface Runoff Collection Pond

This area includes the runoff collection pond for water that is pumped and treated from catchment

areas A and C. This pond acts as a holding cell while water is analyzed before being released to

McDonald Lake.

Catchment Area E – S.E. Quadrant

This area consists of two wetland areas located between the railway tracks and Range Road 291.

Surface runoff from the northern portion of the S.E. Quadrant is self-contained in that area.

Surface runoff in the southern portion of the S.E. Quadrant at times of high water flows south of

the Plant off of Nexen property to a slough south of the Plant, then makes its way north back onto

the Plant and drains via a ditch system to McDonald Lake.

Catchment Area F – Abandoned Evaporation Pond

Surface runoff in this catchment area F is self-contained within the catchment and drains into the

Abandoned Evaporation Pond where the water evaporates or infiltrates.

Catchment Area G – Auxiliary Facilities

This area contained several auxiliary facilities including a filter cake disposal pond, a chemical

pond, a double-lined open drain collection pond and a hydrocarbon burn pit. Surface runoff from

this catchment area is directed via ditches and overland drainage to a low area known as the

Abandoned Holding Pond. The Abandoned Holding Pond is located in the northeast portion of

the catchment area and across the road from the Abandoned Evaporation Pond. Runoff collected

in catchment area G evaporates or infiltrates in this area.

Catchment Area H – Blowdown Ponds

The wastewater from the cooling tower blowdowns and the treated wastewater from the Plant

boilers were piped to the two Blowdown Ponds. Surface runoff generated in the immediate

catchment area previously made up only a small portion of the water contained in the two

BALZAC GAS PLANT


23

blowdown ponds. This water (formerly blowdown water), which has been changed from

industrial wastewater to industrial runoff water per amended approval 155-02-06, is analyzed

before it is released to McDonald Lake via a pipeline, hoses or piping.

Table 4. Summary of catchment area sizes, current land use, and confirmation of Plant

runoff contribution.

Catchment Area Area (ha) Land Use Contribution to Runoff

A-1 14.0 Sulphur Storage Area Yes

A-2 19.5 Process Area Yes

B 0.5 Firewater Pond No

C 8.25 Sulphur Handling Facility and

Surrounding Area Yes

C-C .75 Plant Entranceway and

Surrounding Area No

D 1.0 Sulphur Block Area Surface

Runoff Collection Pond Yes

E 6.6 S.E. Quadrant No

F 19.4 Abandoned Evaporation Pond No

G 13.5 Auxiliary Facilities No

H 0.4 Blowdown Ponds No

Catchment area characteristics are based on information provided in Westhoff (2003).

Robert McCallum

Text Box

Catchment Areas in BGP

Robert McCallum

Text Box

Figure 1

BALZAC GAS PLANT


25

Nexen has attempted to determine how the reclamation of the BGP will potentially affect

McDonald Lake water levels. The original Westhoff Report (2003) indicated that a 1:10 year

storm would result in approximately 23,400 m3 of surface runoff from the BGP. A 1:100 year

storm was estimated to result in 37,165m3 of surface runoff from the 8 catchment areas into

McDonald Lake. Further analysis indicated that McDonald Lake had adequate capacity to handle

surface runoff volumes. Since the 2003 licence application, however, other inputs into McDonald

Lake have occurred from other areas including new local developments and these volumes into

McDonald Lake have not been studied by Nexen.

The final input of surface water into McDonald Lake from a successfully reclaimed BGP will

depend on final land use at the time of reclamation certification, in addition to surrounding land

use. Currently surrounding the lake there are numerous other developments that result in

unmonitored discharges of surface flow into the lake. As Nexen has no knowledge of those

surrounding surface water inputs, the overall effect of reclamation at the BGP cannot be

determined at this time.

6.5.2 Catchment Areas – Surrounding Lands

Currently there are a total of 11 catchment areas located on lands surrounding the BGP. (FIGURE

2) Generally, runoff from these surrounding lands is collected in surface ditches and ponds before

it is released to McDonald Lake. As far as Nexen can determine, runoff from these surrounding

lands are not released into McDonald Lake in a controlled or monitored manner. Nexen cannot

confirm if release limits are being monitored within these surrounding catchment areas.

!

!

! !

!

!

!

!

!

!

!!

!

!

!

Existing Catchment A619ha

Existing Catchment B1500ha

Catchment A

Catchment BCatchment C

Catchment D

Catchment E

Catchment F Catchment G

Catchment HCatchment I

Cell 'A'

Cell 'B'

Ham EastConceptual

Scheme

Wagon WheelIndustrial Park

ConceptualScheme

High PlainsIndustrial Park

ConceptualScheme

RosemontConceptual

Scheme

Walton Development & Management NE

Residual Area

MunicipalCampus

CrossIron Mills

Racing /

Entertain

ment

Centre

Nose Cree

k

Business

Park

Points North

Business Park

Prodev Ltd.PartnershipConceptual

Scheme

SR

36-025-01-W5

02-026-29-W4

13-026-29-W4

07-026-28-W4

16-026-29-W4

09-026-29-W4

03-026-29-W4

14-026-29-W4

36-025-29-W4

12-026-01-W5

34-025-29-W4

11-026-29-W4

01-026-01-W5

15-026-29-W4

35-025-29-W4

01-026-29-W4

31-025-28-W4

18-026-28-W4

13-026-01-W5

06-026-28-W4

19-026-28-W4

33-025-29-W4

10-026-29-W4

Legend! Storm Water Pond

BuildingsDevelopedStorm Water PondCatchementsConceptual Scheme Outline

±

services

Author: S. DurhamGIS Analyst : M. JanickDept. : GIS Services

Date: September 2, 2011File No: A13256.mxd


BALZAC CATCHEMENTS026-29-W4M


Scale: 1:25,000

0 500250Meters

SR Balzac Plant

Robert McCallum

Text Box

Figure 2. Balzac Catchment Areas

BALZAC GAS PLANT


27

6.6 Surrounding Land Use The Site and land directly to the west, north and east is located within Rocky View County. Land

directly to the south of the Site is located within the city limits of Calgary. Currently, surrounding

land use to the north and to the west of the Site is primarily agricultural, while land use to the

south and to the east of the Site is industrial and agricultural.

A Land Use District map from the City of Calgary Planning, Development & Assessment

indicates the land directly south of the Site is situated in zoning of S-FUD. The following is a

description of the zoning classification:

S-FUD – Special Purpose – Future Urban Development District. The purpose of this

district is intended to:

be applied to lands that are awaiting urban development and utility servicing;

protect lands for future urban forms of development;

provide for a limited range of temporary uses that can be easily be removed when

land is re-designated to allow for urban forms of development; and

accommodate extensive agricultural uses prior to development to urban uses

(City of Calgary 2008).

A land use map from the Rocky View County indicates the Site is designated as NRI and

surrounding land use is PS, I-IA, NRI, B-2, DC-94 and DC99. The following is a description of

these zoning classifications:

NRI – Natural Resources Industrial District. The purpose of the district is to provide

development of industrial uses related to non-renewable natural resource extraction and

processing;

PS – Public Services District. The purpose of the district is to provide for the development

of Institutional, Educational and Recreational uses. This can include a residential dwelling;

I-IA – Industrial Activity. The purpose of the district is to provide for a range of industrial

activity, including agricultural, industrial and commercial;

B-2 – The purpose of the district is to provide for a wide range of business and associated

uses, which are compatible with each other and do not adversely affect surrounding land

use. Uses include agricultural, industrial and commercial; and

DC – Direct Control District. The purpose of the district is to provide for developments that

due to unique characteristics, unusual site constraints or innovative ideas require specific

regulations unavailable in other land use districts. All land use applications shall be

evaluated by the Rocky View Council to establish appropriate development standards

(Rocky View County 2011).

BALZAC GAS PLANT


28

A Balzac East Area Structure Plan (BEASP) from the Rocky View Department of Planning and

Development indicates land to the west of the Site will be primarily a commercial/light industrial

area. Land to the north and east of the Site is also considered appropriate for industrial and

business development (Municipal District of Rocky View 2008). (FIGURE 2)

The catchment area map provided in Figures 1 and 2 also shows future development scenarios for

the lands surrounding the BGP. The Figure shows 5 different Industrial Park development

schemes surrounding the BGP.

Nexen has had preliminary discussions with the Municipal District of Rockyview #44 regarding

existing surrounding, and potential future land uses immediately adjacent to the BGP. The reality

is that at the time of final reclamation, surrounding zoning may have changed. But given the

current state of zoning, the existing industrial uses to the north and south, and the development of

a warehouse directly east of the BGP, Nexen anticipates that zoning will continue to remain

“heavy industrial”. However Nexen will continue to review end land use and zoning with the

MD of Rockyview on an as needed basis as adjacent zoning changes. AENV will be updated

following these meetings.

NRI

AH

DC118R-1

R-2

R

RF

AH

NRI

NRI

AH F

R-1

R-2

F

R-2

R-2

AHB-

4

AHR

-2

F

R-3

R-2

DC30

R-2

NRI

R-2

F

R-2

R-1

B-2 R

-1

R-1

F

R-3

B-2

R-1

FDC109

DC99

DC99

DC99

DC99

DC99

DC99

DC117

DC94

DC109

DC99

C

RF

DC72

R-2

DC125

R-1

DC

31

DC

128

F

AH

DC131B-2

PS

DC131PS

I-IA

2

ST566

LAND USE MAP No.

DATE: Mar 31, 2011

TWP. 26-29-W4M

ROCKY VIEW COUNTY

ALL LANDS ARE DESIGNATED RF UNLESS NOTED OTHERWISE

Part FIVE of the BYLAW No. C-4841-97

64-SOUTH

McDonald Lake Existing Balzac Gas Plant

Robert McCallum

Text Box

Figure 3. Balzac East Area Zoning Map

BALZAC GAS PLANT


30

7 REMEDIAL CHARACTERIZATION This section provides a detailed discussion by year of previous site assessment studies and

remedial activities that have been completed at the BGP.

7.1 Previous Investigations and Remedial Programs Nexen has conducted numerous air quality, soils and groundwater investigations at the facility

since 1990. This following summarizes information previously gathered (from the date of last

operating approval), and unless otherwise indicated, AENV has already been provided copies.

AIR QUALITY

1. Annual Air Quality Reports. 2003 to 2010. Each report summarizes annual air quality

data collected for ambient H2S and SO2, NOx emissions, sulphur block activity and

sulphur handling facility operations, in addition to an annual evaluation of QAP and

CEMS operations at the Plant. As air quality emissions, testing, results and exceedences

are specific from year to year, and not applicable to the SDS and DRR project due to the

shutdown of the BGP, no further summary is warranted.

WATER QUALITY

1. Annual Water Quality Reports. 2003 to 2010. Each report summarizes annual water

quality data collected. The following data is included in the annual water report:

a. Sources of Fresh Water and Chemical Treatment;

b. Sources of Wastewater;

c. Wastewater Disposal and Treatment;

d. Site Plan Showing Water Handling Facilities;

e. Changes or Modifications;

f. Controlled Releases;

g. Water Quality Survey of McDonald Lake;

h. Industrial Landfills on site;

i. Industrial Runoff Water and Industrial Wastewater is also summarized.

AMD SOILS

1. Annual AMD Soil Monitoring Reports. Assessment of the Effects of Elemental Sulphur

Handling on Soils. 2003 to 2010. The objective of this soil monitoring program was to

monitor soils in the vicinity of the sulphur storage and handling facilities to assess any

impacts resulting from the deposition of elemental sulphur dust. As the effects of

elemental sulphur on surrounding soils were monitored over time, the most recent results

(2010) are the most relevant. They are as follows: Of 50 soil monitoring network sites,

22 sites exceeded the AMD guideline for total sulphur, 9 sites exceed the AMD guideline

for pH. The limestone requirement calculations indicated that 9 sites required limestone

addition to counteract potential and active acidity resulting from the oxidation of sulphur.

BALZAC GAS PLANT


31

Although sites indicated a lime requirement, none of the sites were limed because the pH

values were either not acidic, or were only slightly acidic.

Finally, most of the sample locations were located east of the BGP. At the time of this

application, most of the surface soils on those lands have been, or are in the process of,

being removed to allow for the construction of a warehouse facility.

SOILS

1. 2006 Soil Monitoring Program. Balzac Sour Gas Plant. Worley Parsons. Report

C25531803. 30 November 2006. The program was designed to meet the terms and

conditions for soil monitoring in Section 4.7.1 through 4.7.9 of the AEPEA Approval

No.155-02-00. In total 58 sampling locations were proposed for the soil monitoring

program at the Balzac Sour Gas Plant only 51 of which were drilled. Please refer to the

Tables 7 – 12 in this document which outline known Contaminants of Potential Concern

(“COPC”) by area.

2. 2006 Soils Management Plan. Worley Parsons - Report No. C25531901. Issued to

Alberta Environment May 31, 2007. This report, subsequent to the completion of the soil

monitoring program, a soil management plan must be submitted to Alberta Environment

within six months of the soil monitoring report. Please refer to Figures 5 & 6 and Tables

8-13 in this document which outline known Contaminants of Potential and Liability

Subunits.

3. 2007 Soil Management Activities Program at Balzac Sour Gas Plant. Worley Parsons.

Report C25532002.

4. March 28, 2008.In 2006, sampling locations were selected to characterize the soil north

of the sulphur/soil stockpiles within the northern and southern stockpiles, and at the base

between the stockpiles. Based on the analytical results and field observations, it was

determined that excavation and off-site disposal of the soil from the sulphur/soil

stockpiles was required. As scheduled, the work began in fall 2007. From October 31 to

December 4, 2007, material from the sulphur-impacted stockpiles was removed from the

Site and hauled to the CCS Energy Services Ltd. (CCS) Landfill located at Rocky

Mountain House, Alberta. Nexen, who is responsible for the overall management of the

Site, supervised and directed the hauling of impacted soil. The following is a summary of

the extent of the sulphur/soil pile removal completed up to December 4, 2007:

Initial sulphur/soil stockpile volume = 23,292 m3 (plus approximately 400 m3 of

waste sulphur; as surveyed)

Volume hauled to CCS Landfill = 16,305 m3 (plus approximately 400 m3 of waste

sulphur)

Remaining sulphur/soil stockpile volume = 6,987 m3 (approximate)

Mass received by CCS Landfill = 27,396 tonnes

Bulk Density of material hauled = 1.64 tonne/m3 (calculated)

The remaining material from the sulphur/soil stockpiles was removed when work

resumed in 2008. The soil north of the stockpiles to a depth of at least 2.0 metres below

ground surface (mbgs) and the soil underlying the stockpiles and to the south of the

BALZAC GAS PLANT


32

stockpiles to a depth of at least 0.15 mbgs also required excavation and off site disposal.

Excavation work began in 2008.


Report C25532105. March 27, 2009. On January 21, 2008, work in the sulphur/soil

stockpiles area resumed. Impacted soil underneath and adjacent to the piles underwent

excavation. Removal of the remaining material from the sulphur/soil stockpile (11,459

tonnes) was completed in 2008. In total 38,855 tonnes of impacted soil was landfilled

from the stockpiles. In addition to the removal of the stockpiles, it was determined that

sulphur-impacted soil underlying and adjacent to the stockpiles required excavation and

off Site disposal. Excavation of sulphur-impacted soils was conducted in January to

March 2008 under the direction of a Nexen representative. An additional 46,775 tonnes

of sulphur-impacted soil was hauled from the excavation to the landfill. The excavation

was generally sloped from the south to the north, and soil was excavated to depths

ranging from 0.1 to 3.0 metres below ground surface (mbgs). Physical constraints to the

north (road), east (road), south (pipeline and railway) and west (railway and power poles)

prohibited further excavation; therefore, characterization sampling of the walls and

ditches was conducted. All final confirmatory base samples reported elemental sulphur

below the AENV Tier 1 (2007) guideline (500 mg/kg) and total sulphur content below

the Alberta Environmental Protection (AEP) (1996b) guideline (4% total sulphur). The

AENV Tier 1 (2007) guidelines were also used as remedial endpoints for hydrocarbon

and metals analyses.

The following is a summary of the 2008 activities:

Estimated in situ volume excavated = 22,000 m3

2007 mass received by CCS Landfill = 27,396 tonnes

2008 mass received by CCS Landfill = 58,234 tonnes (inclusive of 11,459

tonnes remaining from stockpile)

Total Sulphur/soil stockpile removal mass received by CCS Landfill =

85,630 tonnes (2007 & 2008 activities).

The excavation was backfilled in April 2008 and topsoil was placed and seeded

in October 2008. The results of the sulphur/soil stockpile removal and excavation

of underlying soil are discussed in WorleyParsons (2009b).

Previously Unknown Sump Excavation: A soil investigation was conducted in

2006 to characterize and delineate the facility-related impacts within the previously

unknown sump area. Based on the results of the 2006 investigation, excavation and both

off Site disposal and on Site treatment of the soil was selected as the remedial strategy.

Excavation activities were conducted under the direction of a Nexen representative from

October 2008 until December 2008. Off Site disposal of heavily impacted material took

place from November 28 to December 2, 2008. Approximately 3,039 tonnes of soil was

hauled off Site to BFI Landfill Calgary. Excavation sampling (November 20 to 22, 2008

and December 4 to 5, 2008) and groundwater sampling events were completed. Soil

sample results were compared to the AENV Tier 1 (2008) guidelines for detailed salinity,

benzene, toluene, ethylbenzene and xylenes (BTEX), petroleum hydrocarbon (PHC)

fractions F1 through F4, polycyclic aromatic hydrocarbons (PAH) and glycols analyses.

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Results indicated impacts above guidelines remaining within areas of the excavation;

therefore additional delineation and excavation activities were recommended for 2009.

The following is a summary of 2008 activities:

Estimated in situ volume excavated = 6,000 m3

2008 mass received by BFI Landfill Calgary = 3,039 tonnes

Enersul Stockpile Removal: In 2006, sulphur and salinity impacts were

identified at sampling locations (S06-71 and S06-75) within the suspected topsoil

stockpile at the Enersul area. Off Site disposal of impacted material was recommended.

As scheduled, the work was conducted in November 2008. Under the direction of a

Nexen representative, the stockpiles and impacted soil underlying and adjacent to the

stockpiles was transported off Site.


Estimated ex situ volume = 8,000 m3

2008 mass received by BFI Landfill Calgary = 15,086 tonnes

On November 28, 2008 soil samples (0.0 to 0.15 mbgs) were obtained from the base area

underlying and adjacent to the stockpiles. Elemental sulphur and total sulphur impacts

were reported above the applicable guidelines at select sampling locations. Test pitting

was conducted to determine the vertical extent of sulphur impacts to soil on January 16,

2009. Elemental sulphur impacts were identified from surface to 0.6 mbgs.


Report C25522109. March 30, 2010.

Sulphur Handling Facility

A soil investigation was conducted in 2006 to characterize and delineate the

facility-related impacts within the sulphur handling facility (WorleyParsons

Komex 2006a). The following findings of the 2006 investigation pertain to 2009

activities on Site:

i. sampling locations S06-60, S06-73 and S06-74 were investigated to

characterize the sediment in the drainage ditch adjacent to the sulphur

pad and loadout. Elemental and total sulphur impacts were confirmed in

the drainage ditch. Elevated electrical conductivity (EC), depressed pH

values and elevated salinity parameters at S06-73 and S06-74 indicated

significant sulphur-related impacts. Excavation and off Site disposal of

soil was recommended. After remediation of the drainage ditch, it was

recommended that an impermeable liner be utilized to prevent possible

future impacts to this area. An Industrial Runoff Assessment

recommended the reconstruction and remediation of ditches in the

Sulphur Handling Facility Area;

ii. at S06-63, located adjacent to the underground rail tank car, pH,

elemental and total sulphur impacts were confirmed by analytical results

and field observations. Excavation and off Site disposal of soil was

recommended;

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iii. significant hydrocarbon impacts were not identified at S06-64, located

near the former fuel tanks, as hydrocarbon parameters were below

guidelines. No remedial action was recommended; and

iv. soil underneath the old slating units (S06-65) and at the Enersul poured

sulphur pad (S06-66and -67) was characterized. Based on field

observations and laboratory analyses, sulphur impacts were identified

including elevated EC values, acidic pH and elevated elemental/total

sulphur concentrations. Excavation and off Site disposal of soil was

recommended, with potential for in situ remediation for soil at depths

below 1.0.

In 2009, upgrading of the surface water drainage ditch system in the sulphur handling

facility commenced. In conjunction with this program, impacted soil was excavated from

the drainage system, the underground rail car (Enersul Water Tank), the old slating units

and poured sulphur pad within the sulphur handling facility. Soil excavation, disposal

and backfilling activities took place under the direction of a Nexen representative from

August to December 2009. Excavation continued until impacts were not visible and

analytical results were reported below applicable guidelines unless the excavation was

restricted by infrastructure in the area. Soil sample results were compared to the AENV

Tier 1 (2009) guidelines for sulphur, detailed salinity, benzene, toluene, ethylbenzene and

xylenes (BTEX), petroleum hydrocarbon (PHC) fractions F1 through F4, polycyclic

aromatic hydrocarbons (PAH), metals and volatile organic compounds (VOCs). Soil

sample results were also compared to AENVs Guidelines for the Remediation and

Disposal of Sulphur Contaminated Solid Wastes (AEP 1996b) to determine the remedial

requirements for total sulphur.

Approximately 29,100 tonnes of soil was excavated and disposed of at the BFI Calgary

Landfill. During the excavation, the fuel tanks located near S06-64 were moved to the

south side of the maintenance building near soil monitoring location S06-70. Analytical

results of excavation confirmatory soil samples indicate soil concentrations of sulphur,

hydrocarbons and salinity remain above guidelines in areas of the excavation restricted

by infrastructure. The excavation was backfilled with fill imported from an off Site

location and a significant portion of the drainage ditch system was paved with asphalt.


2009 soil received by BFI Landfill Calgary = 29,100 metric tonnes.

DEA UST in the Process Area

The DEA UST is used as the collection point for many of the DEA pumps within the gas

plant’s process area. The tank was single walled and was scheduled for replacement with

a double walled tank.

Excavation and installation of the new tank was conducted under the direction of a Nexen

representative. Installation of the new tank along with a groundwater collection system

was completed on September 3 and 4, 2009. The new tank was installed parallel and

immediately south of the old tank.

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Soil excavated from the new tank area was placed into four 15 m3 bins for disposal.

Characterization sampling was conducted on the four walls and the base of the excavation

and groundwater samples were collected from the excavation. Soil sample results were

compared to the AENV Tier 1 (AENV 2009) guidelines for detailed salinity, BTEX, PHC

F1-F4, metals and amines. Groundwater sample results were compared to AENV Tier 1

(AENV 2009) guidelines for BTEX, PHC F1 – F2, routine potability, dissolved metals

and amines. A soil hydrocarbon concentration was reported above AENV Tier 1

guideline. Inorganic and hydrocarbon parameter concentrations from the groundwater

samples were reported above Tier 1 guidelines.

Unknown Sump Excavation

A soil investigation was conducted in 2006 to characterize and delineate the facility-

related impacts within the unknown sump area. Results of the program indicated

hydrocarbon odour and staining was present in the upper 2-3 m. Analytical results

indicated the presence of hydrocarbons and chloride. Excavation and both off Site

disposal and on Site treatment of the soil was recommended.

Excavation activities were conducted under the direction of a Nexen representative from

October 2008 until March 2009. Off Site disposal of heavily impacted material took place

from November 28 to December 2, 2008. Approximately 3,039 tonnes of soil was

disposed of off Site at BFI Landfill Calgary in 2008. Soil sample results were compared

to the AENV Tier 1 (AENV 2009) guidelines for detailed salinity, BTEX, PHC F1-F4,

PAH and glycols analyses. Results indicated impacts above guidelines remaining within

areas of the excavation.

On January 4, 2009, remedial activities within the unknown sump area resumed. Three

delineation trenches were excavated out from the south and west walls of the excavation.

Based on the results of the trenching, further excavation of the base and the west and

south walls was conducted. All confirmatory samples from the base and walls of the

excavation met AENV Tier 1 (AENV 2009) guidelines, with the exception of select

sampling locations along the eastern wall. Additional excavation along the eastern wall

and further to the east was not possible due to physical constraints (roadway and

pipeline). Partial backfill of the excavation occurred during 2009. Assessment of an in

situ groundwater extraction system along the eastern wall of the excavation is under

review.

Sulphur Base Pad Assessment

A soil investigation was conducted in 2006 to characterize and delineate the facility

related impacts within the sulphur handling facility. Varying depths of sulphur were

drilled through to attain ground surface in the west and east sulphur pads. Soil elemental

sulphur concentrations exceeded the applicable AENV guideline and elevated EC values

above established background data were reported.

The objective of the 2009 sulphur base pad assessment was to quantify the amount of

possible recoverable sulphur on the base pads, and the extent of impacts to soil

underlying the sulphur. Soil sample results were compared to the AENV Tier 1 (AENV

2009) guidelines for sulphur and salinity parameters. Soil sample results were also

compared to AENVs Guidelines for the Remediation and Disposal of Sulphur

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Contaminated Solid Wastes (AEP 1996b) to determine the remedial requirements for

total sulphur.

In total, 10 environmental boreholes were advanced across the west sulphur base pad.

Soil elemental sulphur impacts above the AENV Tier 1 (2009) guideline were identified

to an average depth of 0.6 metres below ground surface (mbgs) across the west sulphur

base pad. A total of 23 environmental boreholes were advanced within the east base pad

area. Nine locations were located on the existing east sulphur base pad. The additional 14

boreholes were located south of the existing sulphur block and base pad, where the base

pad had been previously excavated. Elemental sulphur impacts above the AENV Tier 1

(2009) guideline were identified to an average depth of 0.65 mbgs in soil underlying the

current base pad area. Impacts above the AENV Tier 1 (2009) guidelines were identified

to an average depth of 0.6 mbgs in the excavated portion. The estimated total volume of

impacted soil under both the east and west sulphur base pad areas is approximately

40,700 m3.


March 11, 2011. During 2010, on Site treatment and backfilling of soils from the

unknown sump excavation continued. All confirmatory samples from the base and walls

of the excavation met Tier 1 (AENV 2010) industrial, fine-grained surface soil

hydrocarbon guidelines, with the exception of select sampling locations along the eastern

wall. Additional excavation along the eastern wall and further to the east was not possible

due to physical constraints (roadway and pipeline). Approximately 3,039 tonnes of soil

was disposed of, off Site at BFI Landfill Calgary. The remainder of hydrocarbon-

impacted soil was stockpiled on Site for treatment and backfilling into the excavation

During 2010, approximately 700 m3 of soil was treated to meet Tier 1 (AENV 2010)

guidelines for hydrocarbon parameters and backfilled into the excavation. A portion of

excavated material requires further treatment.

Unknown Sump Excavation

During 2010, on Site treatment and backfilling of soils from the unknown sump

excavation continued. In 2008 and 2009, the excavation of the unknown sump was

completed. All confirmatory samples from the base and walls of the excavation meet Tier

1 (AENV 2010) industrial, fine-grained surface soil hydrocarbon guidelines, with the

exception of select sampling locations along the eastern wall. Additional excavation

along the eastern wall and further to the east was not possible due to physical constraints

(roadway and pipeline). Partial backfill of the excavation occurred during 2009. Design

and commissioning of an in situ groundwater extraction system along the eastern wall of

the excavation was considered; however, with the anticipated Site closure, a strategy for

managing/remediating residual hydrocarbon impacts will be assessed during the DRR

process. Approximately 3,039 tonnes of soil was disposed of, off Site at BFI Landfill

Calgary. The remainder of hydrocarbon-impacted soil was stockpiled on Site for

treatment and backfilling into the excavation. During 2010, approximately 700 m3 of

soil was treated to meet Tier 1 (AENV 2010) guidelines for hydrocarbon parameters and

backfilled into the excavation. A portion of excavated material requires further treatment.

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LIQUIFIED PETROLEUM GAS (LPG) UNIT NEAR PROPANE/BUTANE BULLETS

1. Delineation of Free Product Contamination in LPG Recovery Area – 1999, Komex

Report KI-2553-10-5 dated May 9, 1999. Conductivity probes were used in delineation of

plume.

2. Remediation Options Analysis - LPG Recovery Area, Komex Report KI-2553-11-02

(Draft) dated May 1999.

3. Installation and 1999 Performance Review - LPG Recovery Area, Komex Report

C2553-1106 dated March 2000.

4. 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area,

Komex Report C2553-1212 dated October 2001.

5. Proposed Expansion of Free Product Recovery System - LPG Recovery Area, Komex

Report C25531205 dated June 2000.

6. 2001 Performance Report Free Phase Recovery - LPG Recovery Area, Komex Report

C2553-1303 dated July 2002.

7. 2002 Performance Report - LPG Recovery Area, Komex Report C2553-1407 dated

March 19, 2003.

8. 2003/2004 Performance Report LPG Recovery Area, Komex Report C25531605 dated

July 27, 2005

9. 2005-2008 Performance Report Lean Oil Remediation System, Worley Parsons Report

C25532004 (Draft)

10. 2009-2010 Performance Report Lean Oil Remediation System, Worley Parsons Report

C25532104 (Draft)

Summary

In 1998, an Integrated Soil and Groundwater Investigation was conducted and confirmed the

presence of free phase hydrocarbons as light non-aqueous phase liquids (LNAPL) in the

Liquefied Petroleum Gas (LPG) Recovery Area. Further follow-up investigations delineated

an area of approximately 2,700 m2 with free phase hydrocarbons. Historically, free phase

hydrocarbon liquids have been noted in monitoring wells installed within the till, till/bedrock

and bedrock of the LPG plume. Field observations (sheen and hydrocarbon odour) and

elevated hydrocarbon groundwater concentrations indicate free phase hydrocarbon liquids

may have been present during monitoring events where measurable products was not

reported.

Several remediation options were review and a three phased in-situ approach was selected.

The three phased system is collectively referred to as the Lean Oil Remediation System. The

BALZAC GAS PLANT


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objective of the Lean Oil Remediation System were free phase hydrocarbon containment and

plume mass recovery with treatment/disposal. The system includes the following:

Phase 1: product recovery trench;

Phase 2: free phase hydrocarbon extraction and dissolved phase hydrocarbon

treatment system using trench and gate technology; and,

Phase 3: vertical recovery wells for free phase hydrocarbon extraction.

Details regarding site conditions and the installation of Phases 1, 2 and 3 and system

monitoring are summarized as follows:

In 2002, Komex proposed Phase 3 of the remediation system, which consisted of a

product skimmer pump rotated between multiple vertical wells within the LPG area

lean oil plume . The skimmer pump concept was chosen so only free product would

be removed, thereby, eliminating the need for water disposal. Three wells (LPG-2,

LPG·3 and LPG-4) were installed in areas where groundwater monitoring

demonstrated the greatest thickness of free product.

Through 2003 to 2004, a TR 515 FAP. Plus™ Skimmer System was installed and

rotated between the three vertical wells on a regular basis. Recovered fluids were

stored in two 45-gallon drums. The drums were placed within Overpac barrels for

secondary containment.

In 2005, free phase hydrocarbon product was detected at LPG-2 (1.5 cm) and LPG-3

(up to 14.7 cm). Sheen was observed at LPG-4. On April 19, 2005, the TR 515

FAP. PlusH" Skimmer System pump (skimmer pump) was installed at LPG-3. The

2005 results indicated successful removal of free hydrocarbon product from the

groundwater, which was then added to the Plant's Open Drain Collection Pond for

deep well disposal. The pump was disconnected on October 12, 2005.

In 2006, two new extraction wells, LPG-5 and LPG-6, were added to the system in

2006 with the intention of recovering more product. Free phase hydrocarbon

product was detected at LPG-3 (up to 36 cm), LPG-5 (up to 1 cm) and LPG-6 (up to

3 ern), Sheen was observed at the other Phase 3 extraction wells. The Skimmer

System pump was re-installed at LPG-3 in 2006; however, due to operational

constraints, the pump was not operated and no free product was recovered.

In 2007, the skimmer pump could not be installed due to damage to the pump and

missing parts. The Phase 3 remediation system was not operated in 2007. Three six

inch remediation wells were installed around the CHD system within the LPG

Recovery Area.

In 2008, hydrocarbon free product was detected at LPG-3 and LPG-5. Hydrocarbon

sheen was observed at the other Phase 3 extraction wells in 2008. A new skimmer

pump was installed and hydrocarbon free product was successfully removed from

LPG-3. Product levels were non-detectable at well LPG-3 after the skimmer pump

was disconnected. On July 23, 2008, samples from the three wells were submitted

for routine potability and dissolved hydrocarbons analyses. In the three culverts,

iron, manganese and TDS concentrations were reported above the applicable AENV

Tier 1 (2008) guidelines (Table 1). The concentrations of chloride, sulphate , TDS

and sodium reported at the CHD culverts were lower than concentrations reported

within the upper-water bearing zone in the area. Measureable thickness of free

phase hydrocarbons were not measured in the culverts in 2008.

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In 2009 and 2010 no recordable free phase hydrocarbons were detected in the Phase

1 tank indicating free phase hydrocarbons were not captured within the Phase 1

system. Analytical results from the Phase 1 tank indicate the system is effective in

removing dissolved phase hydrocarbons from the sub surface. No measurable free

phase hydrocarbon product was observed within the Phase 2 system however,

dissolved hydrocarbon concentrations have consistently been reduced to below

analytical detection limits following treatment from sparging system. Phase 3 of the

lean oil remediation system includes removal of product from extraction wells and

culverts. Free product was removed in 2009 and 2010 via a skimmer pump, bailing

and vacuum truck.

GROUNDWATER

1. 2003 Groundwater Monitoring Report. Balzac Gas Plant. Komex International Ltd.

Report No. C25531502. Issued to Alberta Environment April 2004;




Report No. C25531701.. Issued to Alberta Environment April 2006;

4. 2006 Groundwater Monitoring Report. Balzac Sour Gas Plant. Worley Parsons Komex


5. 2007 Groundwater Monitoring Report. Balzac Gas Plant. Worley Parsons Komex.

Report No. C25531903.. Issued to Alberta Environment April 2008;

6. 2008 Groundwater Monitoring Report. Balzac Gas Plant. Worley Parsons.


7. 2009 Groundwater Monitoring Report. Balzac Gas Plant. Worley Parsons.

Report No. C25532103. Issued to Alberta Environment April 2010

8. 2010 Groundwater Monitoring Program. Balzac Sour Gas Plant. Worley Parsons.

Report No. C25532202. Issued to Alberta Environment April 11, 2011.

The scope of work for the annual reports included:

a. Review of the study area including physiography, topography, drainage,

hydrogeology and groundwater usage (5 km radius around plant site);

b. Assessment of local surface water flow and groundwater flow conditions at the

Site (lateral and vertical);

c. Collection of groundwater and surface water samples for assessment of quality;

d. Review of laboratory analytical results and comparison with historical data to

determine the present status of known or suspected contaminant situations; and

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e. Preparation of a groundwater monitoring summary report detailing program

results.

As testing and results are specific from year to year, only the most recent data is summarized:

a) Since September 1992, biannual monitoring of water quality at the Balzac Sour Gas Plant

has been completed by WorleyParsons (formerlyWorleyParsons Komex & Komex

International Ltd.);

b) The Site is underlain by approximately 3.0 to 6.7 m of calcareous sandy silt till and silty

clay till containing sand lenses ranging from 0.1 to 1.3 m thick. An interval of black

organic silty clay to clayey silt approximately 0.3 to 2.2 m thick has been encountered

beneath a large portion of the southeast portion of the Site. The bedrock is grey, fractured

and weathered calcareous siltstone to mudstone.

c) Groundwater flow velocities using geometric mean hydraulic conductivity values for the

upper (A-series), lower (B-series), and bedrock (C-series) water-bearing intervals were

estimated to be 2.2 m/year, 0.5 m/year and 0.5 m/year, respectively.

d) Groundwater flow within the upper and lower water-bearing intervals (till and

till/bedrock respectively) is variable. However, mounding beneath the Process area has

resulted in a radial flow pattern outward from this area. South of the main Process area,

flow in the upper groundwater-bearing zone is dominantly to the west towards McDonald

Lake. Lateral flow in the lower water-bearing zone is west toward McDonald Lake but

also west towards the Flare area. Lateral flow in the bedrock was north/northwest towards

McDonald Lake.

e) Vertical flow conditions do not appear to be completely spatially related, with a small

majority of sites having a downward gradient. Nested locations closest to the lake

exhibited upward gradients year-round, as expected for a groundwater recharged lake.

The potential for off Site migration of impacted groundwater is considered low due to the

hydraulic properties of the sediment and bedrock, existing groundwater flow directions

and prevalent hydraulic gradients.

f) The most significant chloride impacts occur in the Flare area, Former Process Ponds, and

the Evaporation Pond area. The most significant dissolved hydrocarbon impacts occur in

the Flare and Former Process Ponds area, Plant Process area and the LPG Recovery area.

g) Of the contaminants identified to date, chloride appears to have the greatest potential of

reaching McDonald Lake. Considering the age of the facility (49 years), and the

estimated groundwater flow velocities in the weathered till (2.2 m/year), total potential

lateral migration of this inorganic constituent is on the order of 100 m, assuming an

immediate release following plant commissioning. It is possible that chloride from the

Flare area has approached the shoreline. In contrast to chloride, dissolved hydrocarbons

measured down-gradient of the Flare area would have a much lower chance of reaching

McDonald Lake given their tendency to attenuate by natural means (i.e. adsorption and

biodegradation).

h) Dissolved phase hydrocarbon analyses revealed concentrations of some BTEX, PHC F1

and/or PHC F2 constituents exceeding AENV (2009) guidelines at a number of Flare and

Former Process Ponds area piezometer locations. The continued presence of significant

dissolved hydrocarbon concentrations, chloride and/or DEA indicates contaminants have

migrated laterally and somewhat vertically in this area.

i) DEA detections were reported at piezometers within the Flare and Former Process Ponds

area. These detections are generally consistent with historical concentrations, with the

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exception of piezometers where laboratory MDLs have been historically high.

Piezometers in the Flare and Former Process Ponds area are reporting increased

frequency of detectable concentrations and raised detection limits for amine parameters.

j) During 2008 excavation activities at the Unknown Sump piezometer 03-36A was

destroyed.

k) Within the Process area at piezometer 92-9A, ethylbenzene was reported exceeding

guidelines in 2009. Benzene was detected below guidelines. The occurrence of benzene

and ethylbenzene has been consistent since October 2002. At 06-47A, located west of the

KVSR Compressor Buildings, benzene, ethylbenzene, and PHC F2 impacts were reported

exceeding AENV (2009) guidelines in 2009.

l) Piezometer 06-49A (near the glycol storage tank) reported benzene, ethylbenzene, PHC

F1 and PHC F2 concentrations all exceeding AENV (2009) guidelines. At the LP Surge

Culvert, benzene and ethylbenzene concentrations were reported exceeding AENV

(2009) guidelines.

m) Measurable product thickness was not detected in 98-24A/B/C, located within the LPG

Recovery area. Very high dissolved phase hydrocarbon concentrations, though showing a

decrease compared to historical values, were reported at 98-24A. Increased values of

benzene, PHC F1 and PHC F2 at 98-24B were reported exceeding AENV (2009)

guidelines. 98-24C reported benzene, ethylbenzene and PHC F2 exceedances in 2009.

n) In the LPG Recovery Area, measurable thickness of free phase hydrocarbons was

measured, followed by the installation of a passive skimmer at this location. No

measurable thickness of product was detected in the fall 2008, or spring/fall 2009

sampling events. Dissolved hydrocarbon concentrations remained above guidelines,

however concentrations decreased from spring 2008 levels.

o) Piezometers 98-26A/C, MW-8A and MW-10A (east side of Sulphur Block) may be

monitoring inorganic impact from an up-gradient location onto the Site.

p) Concentrations of chloride, hydrocarbons, selected metals and/or amines may indicate

groundwater quality impacts at various locations.

Groundwater conditions at the Balzac Sour Gas Processing Plant (Plant) have been documented

in great detail through monitoring from 1992 to 2011. The main findings of the groundwater

monitoring include:

generally, natural groundwater quality in the Plant area is of poor quality as

indicated by high sulphate and total dissolved solids (TDS) concentrations;

groundwater flow velocities outside of the process area are low, in all three

monitored groundwater zones, primarily due to low hydraulic gradients;

groundwater quality, including in zones of contamination, is relatively stable

with small seasonal and annual variability; and

inorganic and organic groundwater impacts related to Plant operation

identified within the process area, ponds and adjacent areas are aerially stable

and have not expanded greatly over the monitoring period.

Considering the significant hydrogeological information available and the Plant

decommissioning, a major revision in the forthcoming groundwater monitoring program is

recommended. Proposed changes to the 2012 program include:


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concentrating monitoring activities around the process area and perimeter “C”

wells.

The proposed groundwater monitoring program would include sampling once a year in the spring,

instead of spring and fall sampling, with the number of monitored wells reduced. To address

operational issues during the 19 year history of groundwater monitoring, several monitoring wells

were installed in relatively close proximity to each other, often duplicating and/or confirming

information obtained from existing wells. These expansions to the monitoring network were

required at the time of installation. However, in view of the Plant decommissioning, some

monitoring wells are of lesser importance. It should be noted that during Plant decommissioning

and remediation of the area, several wells installed near facilities will be removed. These

monitoring wells should be properly abandoned.

Monitoring wells selected for continued monitoring should be sampled and tested as follows:

laboratory analysis for benzene, toluene, ethylbenzene, xylenes (BTEX) and

petroleum hydrocarbon (PHC) fractions F1 and F2 and amines; and

field measured parameters including depth to groundwater surface,

temperature, electrical conductivity (EC) and pH. If significant changes in EC

and/or pH are measured as compared to historical field measurements, a

sample should be submitted for routine potability analysis for the well in

question. Otherwise, laboratory testing for main ions and dissolved metals

should be discontinued.

STORMWATER MANAGEMENT

1. Balzac Gas Plant. Stormwater Management Report. Westhoff Engineering Resources

Inc. July 2003. The report was completed in support of a licence renewal application to

AENV in support of the information requested in “Attachment B –Industrial Runoff and

Surface Runoff Drainage System”. A composite drainage plan and catchment area plan

was developed, dividing the BGP into 9 10 Catchment areas. Westoff Engineering Resources Inc. Balzac Gas Plant Stormwater Management Report – WER 102-74

McDONALD LAKE

1. Sediment Sampling in McDonald Lake to Assess the Potential for Natural Hydrogen

Sulphide Generation. Matrix Solutions Inc. January 29, 2009. The objective of the

program was to assess the potential hydrogen sulphide generation from sediments in

McDonald Lake to determine if natural conditions from the lake could potentially

produce hydrogen sulphide and contribute to exceedances found at Nexen’s ambient

monitoring stations. It was concluded that “McDonald Lake appears to have the

ecological conditions conducive for sulphate reduction and the generation of hydrogen

sulphide at certain times of the year.” This was completed to try to understand the H2S

exceedances that were received at the ambient monitoring trailers during the year.

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SULPHUR HANDLING FACILITIES

1. Decommissioning and Reclamation Plan – Sulphur Handling Facility. Worley Parsons

Komex. Report No. C25531604. Issued to Alberta Environment March 2006.

The primary objective of the D&R Plan was to satisfy the specific requirements of

Amending Approval (155-01-05) and Current Approval (155-02-00) with respect to

decommisioning and reclamation of the former Sulphur Handling Facility.

2. 2006 Environmental Assessment for Management of Contaminated Sulphur And

Materials Contaminated with Sulphur. WorleyParsons Komex. Report No. C25531803.

Issued to Alberta Environment November 28, 2006

The primary objective of the assessment was to address the terms and conditions for

Sulphur Management in Sections 4.2.15 through 4.2.20 of the current operating approval

(155-02-00). This environmental assessment included the following areas:

the sulphur block

sulphur basepad;

the slater units;

the sulphur load-out area; and,

the sulphur soil pile(s).

The results of this assessment program assisted in defining remedial requirements during

remedial activities completed from 2007 to 2009 in liability subunits 18 and 25 (see

Figure 5) and the assessment will also assist in future remedial programs.

Additionally, this assessment partially addresses the regulatory requirement for a Soil

Monitoring Program (SMP) at the site. (See 2006 Soil Monitoring Program. Balzac Sour

Gas Plant. Worley Parsons. Report C25531803. November 30, 2006)

3. Confirmatory Soil Sampling Summary Balzac Plant Ditch Excavation. WorleyParsons

Report No. C25532106 – March 23, 2011. Approximately 29,000 tonnes of sulphur-

impacted soil was excavated and hauled to the BFI Canada Inc. Calgary landfill.

Exceedances of Tier 1 and/or the sulphur remediation guidelines were left in place in

many areas of the excavation. These exceedances will be re-evaluated and removed at a

future date.

4. Sulphur Pit Construction. Balzac Sour Gas Plant. WorleyParsons. Report No.

C25531902. Report still in Draft. May 9th, 2011. Approximately 3,950 m3 (in situ) of

soil was excavated during the sulphur pit excavation. Analytical results indicate

hydrocarbon and sulphur impacts remain in the excavation wall and base. Sulphur

analytical results confirmed sulphur impacts above the Tier 1 Guideline in the suspected

sulphur-impacted stockpile. Hydrocarbon results were reported below Tier 1 Guidelines

from the suspected hydrocarbon-impacted stockpile. Elevated EC and SAR results from

excavation and stockpile samples were within Site background concentrations.

5. Sulphur Pile Closure Sampling. Balzac Sour Gas Plant. Worley Parsons. Report No.

C25532001. April 11, 2011. The 2006 Soils Management Plan (Worley Parsons -

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Report No. C25531901) was issued to Alberta Environment May 31, 2007. The Soil

Management Plan included recommendations for work in the sulphur/soil stockpile area,

located south of the west sulphur block/basepad area. The recommendations included the

excavation and off site disposal of soil from the sulphur/soil stockpiles and soil adjacent

to and underlying the stockpiles. Excavation and off Site removal of the sulphur/soil

stockpile and underlying soil was conducted from October 2007 to April 2008. In total,

85,630 tonnes of impacted soil was sent to a Class II landfill in Rocky Mountain House,

Alberta. The excavation proceeded until elemental sulphur concentrations were below

500 mg/kg and total sulphur was below 4% or further excavation was restricted. The

excavation had some constraints in certain areas as pipelines, railways and roads were

encountered. Backfill material and topsoil was brought in to bring area up to grade and

seeding activities were completed to support plant growth.

6. Topsoil Stockpile Removal Sulphur Handling Facility. Balzac Sour Gas Plant. Worley

Parsons. Report C25532007. May 9th, 2011. Excavation and off Site removal of the soil

stockpile and underlying and adjacent material took place from November 12 to 26, 2008.

Excavated soil was transported to BFI Landfill south of Calgary. The mass received by

the landfill from the excavation activities was 15,086 tonnes. Analytical results indicate

sulphur impacts remain in the base pad of the former stockpile. One test pit indicated

sulphur impacts exceeding Tier 1 Guidelines extend to 0.6 mbgs . Elevated EC results

from base pad and test pit samples were reported within Site background concentrations.

OTHER

1. Condensate Loading Area (CLA) Excavation, Balzac Sour Gas Plant. Worley Parsons.

Report C25531211. Draft May 4th, 2011.

In 1999, Nexen retained Komex International to conduct a soil and groundwater

investigation designed to assess the extent of hydrocarbon impact and sulphur impact at

the Condensate Loading Area (Truck Loading). Excavation activities were conducted

from October 13 to October 31, 2000. The following activities were undertaken:

Removal of 2,500 m3 of sulphur-impacted surface soils to the sulphur

storage area.

Excavation of approximately 1,000 m3 of heavily hydrocarbon-impacted

soil and disposal at a Class II landfill.

Excavation of approximately 1,000 m3

of moderate levels of

hydrocarbon impact for soil treatment in 2001 at the Plant South landfill

location.

Excavation of approximately 2,900 m3 of soil with low level

hydrocarbon impact for treatment in 2001 at a treatment pad adjacent to

the excavation.

The excavation had some constraints in certain areas as underground firewater structures

and railways. It was determined that some impact remained due to these constraints.

Remedial guidelines have changed since this work was conducted and further assessment

requirements will be reviewed as part of the overall Plant remediation assessment

activities.

2. Unknown Sump Excavation. 02-26-29W4M, Alberta. Worley Parsons. Report

C25531802. January 30, 2009. Remedial excavation activities were conducted from

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October 2008 to December 2008. Delineation trenching activities were completed in

January 2009. In addition, groundwater that collected at the base of the excavation was

sampled six times. Approximately 6000 m3 (in situ) of the soil has been excavated. At

various locations throughout the excavation, samples failed Alberta Tier I (2008)

guidelines for BTEX, PHC F1-F4 and PAH parameters. There are remaining impacts

along the eastern wall, however further excavation was stopped due to the presence of the

roadway and underground pipelines. Further impacts were identified on the southern and

western walls. In addition, several base sampling locations failed applicable guidelines.

Further recommendations for the sump are as follows:

Excavation of the majority of the western portion of the base of the current

excavation to a depth of 4.5 mbgs;

Further excavation to the west and south to a depth of at least 4 mbgs. The

western and southern walls of the excavation should be pulled back to

remove further soils; and

Continued pumping of groundwater during excavation and sampling

activities.

Note: this is an update or interim report – this remediation is not complete

Further remediation activities will be reviewed as part of the overall Plant remediation

assessment activities.

3. Remediation Status Report. 01-08-027-27W4M/06-23-027W4M. Worley Parsons.

Report C25532006. May 9th, 2011 (In Draft). Treatment activities began in July 2002.

A total of approximately 7,700 m3 of excavated soil from 01-08-027-27 W4M (4,100 m

3)

and 06-23-027-27 W4M (3,600 m3) as well as excess drilling mud from well re-entry

activities at the Plant, was treated at the Plant from 2002 to 2009. The material was

initially land surface treated in the Temporary Treatment Area (“TTA”) next to the 02-

02-026-29 W4M well site, and piled in the backfill area adjacent to the 02-02-026-29

W4M well site once remediation guidelines at the time of sampling were met. Some

samples collected from 2002-2004 exceed current Tier 1 Guidelines for benzene and

potentially PHC F2; however, concentrations were within applicable guidelines at the

time of sampling. Salinity parameters were reported within Tier 1 Guidelines and/or

background soil values. Untreated soil was moved to the Temporary Surface Land

Treatment Area (“SLTA”) within the Plant in 2008, land surface treated, and piled at the

north end of the SLTA once Tier 1 Guidelines were met. Treated soil hydrocarbon

concentrations in analyzed samples were below Tier 1 Guidelines and thus, these treated

soils were suitable to be used as backfill/contouring material. However, given the

presence of elevated chlorides, soils should remain at the Plant and not transported back

to their original well site locations. The berms surrounding the TTA were removed in

2009.

4. Confirmatory Soil Sampling Summary. Balzac Plant Ditch Excavation. Worley Parsons.

Report C25532106. March 23, 2011. A soil investigation was conducted in 2006 to

characterize and delineate the facility related impacts within the sulphur handling facility.

The following findings of the 2006 investigation pertain to 2009 activities on Site:

• sampling locations were investigated to characterize the sediment in the drainage

ditch adjacent to the sulphur pad and loadout. Elemental and total sulphur

impacts were confirmed in the drainage ditch. Elevated electrical conductivity

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(EC), depressed pH values and elevated salinity parameters indicated significant

sulphur-related impacts. Excavation and off Site disposal of soil was

recommended. After remediation of the drainage ditch, it was recommended that

an impermeable liner be used to prevent possible future impacts to this area. An

Industrial Runoff Assessment recommended the reconstruction and remediation

of ditches in the Sulphur Handling Facility Area.

• at locations adjacent to the underground rail tank car, pH, elemental and total

sulphur impacts were confirmed by analytical results and field observations.

Excavation and off Site disposal of soil was recommended

• soil underneath the old slating units and at the Enersul Area poured sulphur was

characterized. Based on field observations and laboratory analyses, sulphur

impacts were identified including elevated EC values, acidic pH and elevated

elemental/total sulphur concentrations. Excavation and off Site disposal of soil

was recommended, with potential for in situ remediation for soil at depths below

1.0 m.

Approximately 29,000 tonnes of sulphur-impacted soil was excavated from the Site and

hauled to the BFI Canada Inc. Calgary landfill. Exceedances of Tier 1 and/or the sulphur

remediation guidelines were left in place in many areas of the excavation. These

exceedances will be reviewed as part of the overall Plant remediation assessment

activities. As recommended the surface water collection system (ditches) in the Enersul

Area was upgraded. A summary of this work includes:

Upgrades and extensions to the existing surface collection system to

improve conveyance and increase capacity to accommodate runoff.

Reconstruction clay lined and asphalt lined ditches

Removal, replacement and disposal of sulphur impacted soils below

new ditches with clean imported fill.

Installation of a low density polyethylene (LDPE) liner below all new

asphalt ditches to provide secondary containment.

5. 2009 DEA UST Removal and Replacement - Letter Report. Worley Parsons. Report

C25532107. May 10, 2011. Approximately 50 m3 (in situ) of impacted soil was

excavated from the new DEA UST. The excavation did not extend beyond the

dimensions of the new DEA tank. Soil samples were collected from the base and walls of

the excavation for characterization of the soil to establish baseline data. Excavation wall

and base soil sampling and analysis indicated the soil met the Tier 1 Guidelines for all

parameters with the exception of EC at four of the five sample locations and PHC F2 at a

single sample location. EC results reported above the Tier 1 Guideline were within

previously established Site background concentrations. Groundwater sampling during

three events indicated there are exceedances above Tier 1 Guidelines. Some parameters

fluctuate between exceeding and not exceeding parameter guidelines. These results are

consistent with groundwater conditions analyzed at nearby monitoring wells. Due to the

planned decommissioning of the Site, the new DEA UST was never put into operation.

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SUMMARY OF ENVIRONMENTAL STUDIES AT THE PLANT, BY YEAR

The following briefly summarizes the different environmental studies and/or remediation projects

that have been tracked on the BGP since 1989. The information below is provided to demonstrate

to the reader what projects have been implemented and completed, where the projects are located

on the BGP, and why the individual projects were required. All the studies and their conclusions

(which are too numerous to list succinctly) create the basis of information Nexen used to

determine the current state of the property, as summarized in Section 8 – Current State of the

Property.

1989 Activities: A hydrogeological assessment at the Balzac facility was completed. This

program involved the installation and sampling of 11 monitoring wells. Two additional wells

were installed at well sites 11-01-26-29 W4M (MW-12B) east of the plant, and 11-12-26-29

W4M (MW-13B) to the northeast. The purpose of this program was to assess groundwater quality

at these on-site and off-site locations.

1991 Activities: Completion of a follow-up assessment of hydrogeological conditions, and to

address special conditions outlined in the License to Operate. This included a review of reports

prepared by UMA Engineering Ltd., published hydrogeological maps and reports, and water well

records.

1992 Activities: a major upgrade of the groundwater monitoring network was completed. This

program included the installation of 18 additional observation wells across the plant site,

providing more comprehensive monitoring coverage. Prior to this, a geophysical reconnaissance

of the area was completed. Terrain conductivity and magnetometer surveys were conducted near

the buried south landfills, south of the main process area, and down gradient of North and South

Cooling Tower Blowdown Ponds.

Terrain Conductivity and Magnetometer Survey – Petrogas Processing Plant

A geophysical survey of the Blowdown Pond Area and Landfill Area Sulphur Block Storage Area

was conducted. The survey was conducted to better assess potential soil and groundwater

contamination issues. This program is the precursor to starting detailed soil and groundwater

investigations at the Balzac Plant. Komex Report: Terrain Conductivity and Magnetometer Survey at the Petrogas Processing Plant, Balzac Alberta A92-2553-2

1993 Activities: four additional monitoring wells (93-15A/C and 93-16A/C) were installed on

the west side of McDonald Lake. The purpose of these wells was to further define local

background conditions. The piezometers were installed in nested configurations, including one

shallow and one deep, to assess vertical flow conditions at each location.

1994 Activities: a geophysical survey was completed in the vicinity of the sulphur block storage

area. Subsequently, in July 1994, bedrock monitoring wells (94-17C, 94-18C, and 94-19C) were

installed at the plant site to assess groundwater flow conditions and water quality in the deeper

water-bearing horizons. Later in 1994, a geophysical investigation was conducted south of the

main process area to assess the extent of potential subsurface impact associated with a number of

former waste water and surface runoff ponds. This study was followed up in March 1995 with a

soil and sludge sampling program in the Evaporation Pond, Holding Pond, Hydrocarbon Burn Pit,

Chemical Pond, and Filter Cake Pond.

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A stable isotope investigation of soil and groundwater in and around the plant ponds, sulphur

storage, and sulphur loading areas was also completed. The purpose of this investigation was to

determine the source of anomalous groundwater sulphate concentrations at the Balzac site (i.e.,

natural versus industrial).

Upgrade of Runoff Water Control around Sulphur Block Area

This project consisted of installing lined ditches around the sulphur block and sulphur basepad

and construction of a lined acidic water collection pond and secondary containment for caustic

treating facilities. This was in response to AENV concerns on the handling of acidic runoff water

in Sulphur Block Area. An activity change application was submitted to Alberta Environment and

approved. The work stretched over a two-year period (1994-1995). Petrogas Report Entitled: Activity Change – Upgrade of Runoff Water Control around Sulphur Block Area – Central File 001-20

Stable Isotope Study

A Stable Isotope investigation of soils, groundwater and vegetation was conducted in 1994 in

various plant ponds and the Sulphur Storage Area. The purpose of the investigation was to

determine the source of anomalous groundwater sulphate conditions (industrial vs. natural). The

report suggested a low degree of industrial impact from plant operations was evident. Komex Report: Stable Isotope Study at the Petrogas Processing Facility KI94-2553-5

Terrain Conductivity Survey – Petrogas Processing Plant

In 1994 a Geophysical survey of the Sulphur Block Storage Area was conducted. The survey was

conducted to better assess potential soil and groundwater contamination issues. The objective of

the program was to delineate in a plan view shallow inorganic soil and/or groundwater

contamination. This program was the precursor to starting detailed soil and groundwater

investigations at the Balzac Plant. Komex Report: Terrain Conductivity Survey at the Petrogas Processing Plant, Balzac Alberta A94-2553-6

1995 Activities: a piezometer (95-20A) was installed south of piezometer nest 92-8A/B.

Temporary piezometers 96-21A and 96-22A were subsequently installed in 1996 down gradient

of the North and South Cooling Tower Blowdown Ponds.

1995 Geophysical Program and Limited Soil Sampling Investigation This program was conducted to fulfill plant operating licence requirements. The survey was

conducted to better assess potential soil and groundwater contamination issues. The geophysical

program covered the entire south end of the Plant. This geophysical program, in conjunction with

the two previous geophysical investigations (1992 &1994), covered the majority of the Balzac

Plant Site. Komex Report: 1995 Geophysical Program and Limited Soil Sampling Investigation – Petrogas Processing Ltd. KI95-2553-6

1996 Activities: the first soil monitoring program (SMP) was conducted at the Site. Subsequent

to submission of the monitoring program report to AENV, a management plan was developed to

address identified soil contaminant issues over time. It was followed by a Remedial Program

Work Plan.

Effects of Acid Conditions on Element Distribution beneath a Sulphur Basepad

A CAPP research project entitled “Effects of Acid Conditions on Element Distribution beneath a

Sulphur Basepad” was completed in 1996. (West sulphur basepad) The program consisted of

installing two groundwater wells and the collection of six soil samples from different locations

BALZAC GAS PLANT


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under the basepad. Results indicated that the pH in the soils immediately under the west sulphur

basepad had not been impacted in the 35 years of operation. Komex Report: Effects of Acid Conditions on Element Distribution Beneath a Sulphur Basepad KI96-4374

Study of Soil, Sludge and Groundwater Conditions around the Blowdown Ponds

This report was submitted to fulfill a plant operating licence requirement regarding the plant

blowdown ponds. The program was to address the integrity of the liner material in the blowdown

ponds and determine if the ponds posed a risk to soils and groundwater and options to upgrade the

ponds if necessary. The report concluded that it did not appear that shallow groundwater had been

adversely impacted from the blowdown ponds. Komex Report: Study of Soil, Sludge and Groundwater Conditions Around the Blowdown Ponds at the Balzac Gas Plant 2553-7-2

1996 Soil Monitoring Program

The 1996 soil monitoring program was conducted to fulfill a condition in the plant operating

licence. The soil monitoring program consisted of the following activities:

Soil sample collection at 19 locations around the facility and one background location.

Sample analysis for parameters as specified in the plant operating approval.

Data summary and presentation, incorporating previous investigations.

The report summarized the nature of impact at specific locations. Komex Report: 1996 Soil Monitoring Program – Balzac Gas Plant – Canadian Occidental Petroleum Ltd. KI96-2553-7-3-6

1997 and 1998 Activities: Initiation of clean-up at the Hydrocarbon Burn Pit, the Filter Cake

Pond, the Chemical Pond, and the Drilling Mud Pit.

In 1998 an integrated soil and groundwater investigation program was completed. The

investigation targeted areas where additional groundwater monitoring was required (e.g.

installation of a bedrock piezometer near the flare area) and locations at which further soil quality

characterization was warranted. Twelve piezometers were installed as part of this program. This

program identified a number of previously unknown issues, including: free hydrocarbon product

contamination in the LPG recovery area and soil contamination in two former flare pits southwest

of the bone yard.

Remediation of soil adjacent to the southeast Process Pond commenced. This area had previously

been contaminated by a release from the Plains Midstream (Federated Pipelines/Anderson were

operators of this pipeline in or around 1998) condensate pipeline, which passes through the area.

Monitoring well 98-29A was installed in the upper water bearing zone to monitor success of the

remediation program. This well is not considered part of the current Nexen monitoring network.

A 5 year Environment Management Plan (EMP) for the Plant was developed. The Management

Plan for the Plant was updated in 2000. Since that time, many of the recommended activities in

the Plan have been implemented and additional site assessments completed. In view of the

progress made, and new information obtained, a revised EMP, extending to 2005, was developed

in 2001.

Soil Quality Adjacent to the Sulphur Contaminated Soil Pile

A study was undertaken in 1997 to determine if there were any impacts due to storing sulphur-

contaminated soil at the Balzac Gas Plant. The sulphur soil pile was generated in 1995 when

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remediation activities around the sulphur block and basepad during the Sulphur Block Runoff

ditches and pond construction. The report indicated that acidic impact beneath the basepad had

been limited to the upper 0.3 meters of the soil profile. The lack of acidic impact suggested that

adequate soil buffering capacity is present in the existing soils after 33 years of operation. Komex Report: Soil Quality Adjacent to the Sulphur Contaminated Soil Pile at the Balzac Gas Plant – 2553-8-2

Remediation of the Hydrocarbon Burn Pit, Filter Cake Pond, Chemical Pond and Ditches

Remediation plans for the on-site Hydrocarbon Burn Pit and ditches, Filter Cake Pond, Chemical

Pond were developed in 1997. The remediation of the Hydrocarbon Burn Pit and ditches began

late in 1997. Heavily contaminated sludge was removed and disposed of at a Class II landfill.

Hydrocarbon contaminated soils were assessed and a decision to spread and land treat the soils

was decided on. These activities were implemented to reduce contaminant levels to below Alberta

Tier I guidelines in the vicinity of the pit and ditches.

The remediation of the Filter Cake Pond and Chemical Pond began in 1998 along with the

completion of the Hydrocarbon Burn Pit and ditch remediation. Again some heavily contaminated

sludge was removed and disposed of at a Class II landfill. The less contaminated sludge was land

spread and land farmed in place. Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2

Remediation of the Drilling Mud Pit The remediation of an old Drilling Mud Pit located on the plant site was also completed during

1998. Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2

Slop Tank Remediation – Flare Area

During the 1997 upgrade of the plant’s Flare Area, contaminated soil was encountered. During

this upgrade it was decided to remediate the footprint of the new installation. The area was

excavated to a depth of approximately 2.5 meters. The contaminated material was deemed land

treatable and this contaminated material was incorporated into existing land treatment activities

from the Hydrocarbon Burn Pit and ditches, Chemical Pond and Filter Cake Pond. Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2

Screening Level Human Health and Ecological Risk Assessment

During 1998, a “Screening Level Human Health and Ecological Risk Assessment” was initiated.

The risk assessment was developed to look at three specific areas of the plant: S.E. Process Area

Runoff Pond, Holding Pond, Evaporation Pond, and it looked at McDonald Lake to a lesser

extent.

In general the assessment found that there would be no unacceptable risks to human health in an

industrial or parkland setting. The ecological risk assessment indicated that there are ecological

risks associated with certain identified chemicals of concern. The next steps included actions to

try and minimize ecological risks. Komex Report: Screening Level Human Health and Ecological Risk Assessment (Ponds) Wascana Energy - Balzac Gas Plant - KI 98-

4683

North Flare Pit and South Flare Pit Investigations

Contamination was identified in the vicinity of Wellsite 2-2-26 (located on Plant Property) during

the 1998 Integrated Soil and Groundwater Program. Based on this Program a delineation

program was initiated in 1999.

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1998 Integrated Soil & Groundwater Investigation Program

This 1998 Integrated Soil and Groundwater Program were conducted to supplement the 1996 Soil

Monitoring Program and in turn help fulfill plant operating licence requirements.

Correspondence with Alberta Environment and Alberta Energy and Utilities Board and an audit

conducted by both parties identified the need for additional soil and groundwater monitoring. The

additional sampling brought forth some specific areas of concern, some of which are being

addressed in various remediation and investigation programs now being conducted at the plant. Komex Report: 1998 Integrated Soil and Groundwater Investigation Program - Wascana Energy Inc. KI-2553-9 T01/T02

Lean Oil Collection System – LPG

During the 1998 Integrated Soil and Groundwater Program, the presence of free product (Lean

Oil) was discovered. A delineation program was developed and implemented in October 1998.

The scope of work consisted of the following:

To identify the extent of the free product in the LPG Area;

To establish the approximate thickness of the free product in the LPG Area; and,

To collect data to support the development of remedial options. Komex Report: Delineation of Free Product Contamination in the LPG Recovery Area – Balzac Gas Plant KI-2553-10-5

1999 Activities: the Former 2-2 North and South Flare Pits were remediated. During this

remediation, approximately 4600 m3 of impacted soil and sludge was excavated; 1100 m

3 was

treated at a thermal desorption unit and later backfilled into the excavations; and 3500 m3 was

spread in a designated on-site treatment area and later backfilled into the excavations.

A soil and groundwater investigation program was undertaken to better delineate known

contaminant situations in the Condensate Loading Area and the Flare Area. The investigation

involved drilling twelve test holes to delineate previously identified hydrocarbon contamination

in soil. Temporary mini-piezometers were installed in four of the test holes to evaluate potential

groundwater impacts. Subsequent remedial work was conducted that included excavation in

2000, and in 2001, the treatment of approximately 4,000 m3 of impacted soils. A lean oil plume,

with an estimated volume of 81 m3 and extending over an approximate area of 3,100 m

2, was

delineated beneath and down gradient of the LPG Recovery Area of the Plant. In 1999, the first

of a three-phase remediation plan was implemented to begin recovery of the mobile free product.

Phase I consisted of a free product recovery trench that was installed within the plume core, in an

open area immediately south of the LPG Recovery facilities. An additional well (LPG-1) was

installed in the LPG Area in August 1999 and has been used to recover additional free product.

Delineation and Remediation of North Flare Pit near Well site 2-2-26 Remediation plans for the on-site 2-2 North Flare Pit were completed in the spring of 1999 and

remediation began in the fall of 1999. The 2-2 North Flare Pit was used to collect a variety of

waste materials from the plant in the early to mid-years of the plant. Approximately 700 m3 of

heavily contaminated sludge was removed from the North Flare Pit and sent for treatment at a

thermal desorption unit (incinerate soil to remove contaminants). In addition to this process

approximately 3,500 m3 of lightly contaminated soil was spread in a designated on-site treatment

cell and treatment was initiated in 1999 and completed in 2000. The first thing that was initiated

was a treatability study to determine if the contaminated soil could be land treated. After the

studies it was decided to use thermal desorption (incinerate) to decontaminate the more heavily

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contaminated sludge. These treated soils were then returned to the Gas Plant for use as fill

material. Komex Report: Soil and Sludge Remediation Program of Flare Pits at Wellsite 2-2 C25531204

Delineation and Remediation of South Flare Pit near Well site 2-2-26

Remediation plans for the Well site 2-2-26 South Flare Pit were completed in the spring of 1999

and remediation began in the fall of 1999. Approximately 420 m3 of heavily contaminated sludge

was removed from the South Flare Pit and sent for treatment at a thermal desorption unit

(incinerate soil to remove contaminants). Komex Report: Soil and Sludge Remediation Program of Flare Pits at Well site 2-2 C25531204


During the 1998 Integrated Soil and Groundwater Program the presence of free product (Lean

Oil) was discovered. In 1999 a Remedial Options Analysis was proposed to address this

contaminant concern. The analysis looked at the following groundwater remediation issues:

1. Understand (characterize) the problem at the site;

2. Assess the risks posed by the problem;

3. Set remedial goals for the site;

4. Review and select the most appropriate remedial options;

5. Pilot scale test(s) of selected remediation option or options;

6. Implement the optimal remediation program at the site; and,

7. Monitor results, modify systems. *Komex Report: Remediation Options Analysis LPG Recovery Area – Balzac Gas Plant KI2553-11-02 (Draft)

The Lean Oil Collection System Remediation program was installed in 1999 after free product

was discovered in the groundwater during the 1998 Integrated Soil and Groundwater

Investigation Program. Trenches and Collection Points were installed to collect free product (lean

oil) from the groundwater in the LPG unit. Komex Report: Installation and 1999 Performance Review LPG Recovery Area Free Phase Recovery System C25531106

2000 Activities: Phase II of the remediation included installation of a trench and gate system

between the two sets of LPG Storage Tanks down gradient of the free product plume. Continuous

operation of Phase II began in May 2001. The system was designed to direct groundwater flow

through the permeable collection trench and into a product separation gate, which traps floating

hydrocarbon. In 2001, only free product sheen was detected in the product separation gate,

therefore no free product removal was required. Analytical results for groundwater samples have

been collected since 2001. Benzene and total xylenes concentrations above the respective AENV

guidelines have been detected in the Phase II product separation gate system. However,

concentrations exiting the system through the re-infiltration gallery are below analytical method

detection limits.

A plant-wide program of UST removals was conducted in the summer of 2000. A total of four

tanks were removed, and impacted soils were delineated, and excavated where possible.

North and South Blowdown Pond Clean-up

Due to deteriorating water quality in North and South Blowdown Ponds a sludge sampling

program was conducted in 2000. The sampling discovered some contaminants and natural

elements (organic) in the sludge. The North Blowdown pond sludge contained some heavy end

hydrocarbons (unknown source) and this material was sent to a landfill. The South Blowdown

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53

contained a substantial amount of organic matter which may have contributed to an ammonia

nitrogen issue in the water. This sludge was removed from the South Blowdown Pond and added

to the land treatment activities with the added organic matter aiding in the remediation process.

Underground Petroleum Storage Tank Investigation

To facilitate construction of the Balzac Power Station an environmental investigation was

conducted in the fall of 2000. During the investigation phase hydrocarbon impact was discovered.

A program was immediately set up to delineate and formulate a remediation plan to address the

contamination. Three former underground tanks (diesel/gasoline) were located in the vicinity of

this planned construction. Approximately 3600 m3 of hydrocarbon contaminated soil was

removed to a temporary bio-treatment cell. Land treatment of this impacted soil was undertaken

and completed in 2001. Komex Report: Balzac Parking Lot – Underground Petroleum Storage Tank Investigation – File No. 25531208

Condensate Loading Area Remediation

The delineation phase of this project began in 1999 with approximately 12 soil borehole locations

and 4 temporary mini piezometers (groundwater well) being installed. The contamination plume

was mapped and a remediation plan developed. The Condensate Loading Area remediation began

in 2000. The plan was to first excavate approximately a one-meter lift of sulphur contaminated

soil and stockpile on Sulphur Contaminated Soil Pile. Once the program began it was determined

that all the condensate loading facilities would be removed to ensure a full clean-up of the area.

This resulted in the removal of the loading structure and underground facilities in the immediate

area of the loading facility. Approximately 1000 m3 of soil was removed to the Temporary Land

Treatment Cell located on the Plant Site. Approximately 3000 m3 of soil was treated in place at

the Condensate Loading Area. The soil contained light end hydrocarbons and it was successfully

remediated during the 2001 season. The material was deemed clean per Alberta Tier I guidelines

and a portion (1000 m3) was stockpiled adjacent to the South Balzac Landfill.

Komex Report: Balzac Gas Plant – Delineation of the Flare Area and Condensate Loading Area – File No. C25531104 Draft

Komex Report: Balzac Gas Plant – Condensate Loading Area Remediation – File No. 25531211 Draft

Underground Tank Removals

Four underground tanks/sumps located on the Plant were removed in 2000. Remediation activities

were undertaken on 3 of the 4 tanks/sumps removed. The tanks were as follows: KVSR Oil

Sump, RDS Sales Gas Oil Tank, L.P. Surge Rerun Sump and Site ‘G’ Compressor Drain Tank

(contamination not present). These underground tanks/sumps were replaced with aboveground

facilities. The contaminated soil was removed and tested to determine suitable disposal or

treatment options. The KVSR Oil Sump and RDS Sales Gas Oil Tank contained heavy end

hydrocarbons and off-site disposal was undertaken. The L.P. Surge Rerun Sump contaminated

material (900 m3) contained lighter end hydrocarbons and an on-site treatment cell was

constructed to treat this material. Komex Report: Balzac Gas Plant – Underground Tank Removals – File No. C-2553-1206

Land Treatment Activities

Land treatment activities began in 2000 to deal with contaminated soils from various remediation

projects. The table below summarizes this information. These soils were tested extensively during

the remediation process and on completion in 2001. Activities occurred at a temporary land

treatment location within the BGP. Komex Report: Balzac Gas Plant – Landtreatment Activities – File No. C-2553-1211

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Soil Source Contaminated Soil/Sludge Contaminant Main Parking Lot 3600 m

3 Diesel/Gasoline

LP Surge Rerun 900 m3 Condensate

Condensate Loading 4000 m3 Condensate

KVSR Storage Tank 300 m3 To BFI Lube Oil

South Blowdown Pond 1000 m3 Not Contaminated

Sulphur Contaminated Soil Bench Scale Studies

In 2000, soil samples were sent to laboratory to begin a series of studies to determine a suitable

method for extracting elemental sulphur from soil. The bench scale study looked at separating

sulphur/soil by three different methods of gravity concentration. Heavy media separation was

determined to work the most effectively.


The Lean Oil Collection System was expanded in 2000. A trench and gate system was installed

late in 2000. The trench and gate system provided complete hydraulic containment of the free

product plume and treat the dissolved phase. This was the second phase of the system which was

initially installed in 1999. Komex Report: 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area Free Phase Recovery System

C25531212

After review of the Lean Oil Collection System operations had taken place, another report was

generated entitled “Proposed Expansion of the Free Product Recovery System LPG Recovery

Area – Balzac Gas Plant”. The scope of this report was as follows:

Proposed Phase II Expansion;

Proposed Phase III Expansion; and,

Continued Operation of Phase I operations. Komex Report: Proposed Expansion of the Free Product Recovery System LPG Recovery Area – Balzac Gas Plant C25531205

2001 Activities: The parking lot area was designated for construction of a portion of the Balzac

Power Station. Three USTs containing diesel and gasoline located north of the Plant parking lot

were removed in 1994, and soil quality delineation and remediation programs were implemented

in 2000 to ensure that the site was suitable for Balzac Power Station construction.

During 2001, construction of the new Balzac Power Station was completed in the northeast corner

of the Plant site. This required the installation of a new fuel gas pipeline north of the condensate

storage tanks, and a freshwater pipeline along the north-south access road. Both of these

installations uncovered previously unknown environmental impacts on the property. Condensate

impact was encountered along the fuel gas pipeline path, and a previously unidentified landfill

east of the Evaporation Pond was discovered along the planned route of the water pipeline.

In November 2001, a full characterization and delineation of the North and South Landfills was

completed. Additionally, the planned pathway for the freshwater pipeline necessitated the

removal of two aboveground methanol storage tanks. A remedial excavation and soil treatment

program was conducted on the underlying methanol impacted soils.

A Risk Assessment of the three former process ponds was initiated in 1998 and updated in 2001.

The Evaporation, Holding, and Southeast process ponds were sampled and evaluated for their

BALZAC GAS PLANT


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potential to adversely impact aquatic life due to salinity or metals. In December 2002, removal of

the surficial sediment layer from the Southeast Process pond was completed.

In December 2001, a piezometer replacement program was conducted. Three piezometers (01-

33A, 01-34A, and 01-35A) were drilled to replace MW-2A, 92-10A, and MW-7A, respectively;

the first two were removed to allow for construction of the Balzac Power Station. A further

piezometer (98-26A) was abandoned and re-drilled.

Balzac Gas Plant – North and South Landfill Characterization Program

The objective of this program was to characterize the contents of two former landfill sites located

on the Balzac Gas Plant property. The landfills had been previously identified and a preliminary

characterization program had been completed. The objective of the program was collect enough

information to develop a remediation plan.

The North Landfill contained filters, wood, crushed drums, catalyst, asbestos, tires, tubes from

reboilers, small amounts of sulphur and hydrocarbon contamination. The approximate volume of

the North Landfill was 9000 m3.

The South Landfill contains 5 separate cells which were in operation from 1967 to 1984. Again

the South Landfill site contains general plant refuse including: filters, pipes, timbers, catalyst,

small amounts of sulphur and hydrocarbon contamination. The approximate volume of the South

Landfill is 8000 m3.

Komex Report: Balzac Gas Plant – North and South Landfill Characterization Program – File No. 25531309 Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9

T01/T02 (Page 50 and Photos Section)

Sulphur Contaminated Soil Remediation Technology

To further progress the sulphur bench scale testing that had begun in 2000, a temporary Field

Pilot Project was implemented in the fall of 2001. The pilot ran for approximately six weeks. The

purpose of the pilot was to collect data to assess whether this technology was suitable to remove

elemental sulphur from soil. The pilot plant operated as planned. Process Research Associates Ltd. Report: Project No. 00-05207

Land Treatment Activities

Land treatment activities continued through 2001 and they were completed in the fall of 2001.

These activities dealt with contaminated soils from various remediation projects as outlined in the

2000 Land Treatment Activities. Two areas were set aside for land treatment activities –

Condensate Loading Area and over the South Landfill Area. Komex Report: Balzac Gas Plant – Land treatment Activities – File No. C-2553-1211

Methanol Tank Investigation/Remediation – LPG Unit

Remediation work had begun in this general area in 2001. The Field Methanol Tank was removed

in 2001. During the investigation phase approximately 1000 m3 of methanol impacted soil was

discovered and the impacted soil was segregated into the same land treatment area as the

Condensate Loading Area material. The remediation of the methanol area was combined with the

Condensate Loading Area Remediation and both were completed in the fall of 2001. Komex Report: Balzac Gas Plant – Methanol Storage Tank Investigation - File No. 25531306

Field Inhibitor Tank Investigation/Remediation – LPG Unit

Remediation work had begun in this general area (Condensate Loading Area) in 2001.

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The inhibitor tank and sump were also removed in the fall of 2001. The inhibitor tank remediation

activities were transferred to 2002 as the soil was determined to have heavier end contaminants

and this required landfill acceptance. Komex Report: Balzac Gas Plant – Inhibitor Tank Remediation – File No. 25531408


The Lean Oil Collection System was run throughout 2001. Komex Report: 2001 Performance Report - Free Phase Recovery - LPG Recovery Area C25531303

Hydrocarbon Monitoring Results Waterline Installation – Balzac Power Station

During the construction of the water supply line to the Balzac Power Station, a previously

unknown landfill was discovered. The landfill was delineated - see above “Balzac Gas Plant –

North and South Landfill Characterization Program”. Komex Report: Hydrocarbon Monitoring Results Waterline Installation C25531307

Hydrocarbon Monitoring Results Fuel Gas Line Installation – Balzac Power Station

During the construction of the fuel gas supply line from the Balzac Gas Plant to the Balzac Power

Station two pockets of contaminated soil was encountered. The line intersected an area of known

contamination “Lean Oil Collection System – LPG” and another area that was addressed in 2004

activities “L.P. Surge Review – Remediation Plan”. Komex Report: Hydrocarbon Monitoring Results Fuel Gas Line Installation C25531307

Arsenic Detections in the S.W. Dugout

A report was issued in 2001 on the elevated arsenic values in the S.W. dugout. It was

recommended that further sampling be conducted on the dugout which was done approximately

every two to three weeks during the summer 2001. Arsenic values were below Canadian

Livestock Watering Guidelines for the first part of the year and again in the fall the arsenic values

went above the guidelines. The resident was notified immediately. They removed cattle upon

verbal discussions. Komex Report: Arsenic Detection’s in S.W. Dugout – Review and Recommendations C25531302

2002 Activities: In April 2002, a soil quality investigation was conducted around the main

electrical sub-station during plant turnaround. Trace amounts of PCBs (polychlorinated

biphenyls) and above AENV criteria heavy-end hydrocarbons were noted. Due to the complexity

of overhead and underground utilities, complete soil remediation is not an option until Plant

closure.

During August 2002, the field inhibitor storage tank and sump, located south of the LPG bullets,

were removed. Approximately 300 m3 of the surrounding impacted soil was excavated and

disposed of at the BFI landfill in Calgary.


The Lean Oil Collection System was operated throughout 2002. Trenches and Collection Points

were installed three years ago to collect free product (lean oil) from the groundwater in the LPG

unit. An air-operated pump collected the lean oil/groundwater and it was pumped to a 400 Bbl.

tank SV 19-23 located in the LPG.

The second phase of the system was installed in December of 2000 and it continued to run

throughout 2002. This phase consisted of a trench and gate collection system which should cut-

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off the flow of lean oil and any minor contaminants in the groundwater. One culvert (between

tank #5 and #6) acted as a collection point and one culvert (under tank #7) had a continuous

supply of air injected into the culvert. (N.B. This remediation system was featured in a

“Remediation Technologies Symposium” entitled “In-Situ Containment & Treatment of a Free

Phase Hydrocarbon Plume Beneath Plant Infrastructure” in Banff, October 2002. The paper was

presented by Mike Brewster of Komex International Ltd.) Komex Report: Installation and 1999 Performance Review LPG Recovery Area Free Phase Recovery System Komex Report: 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area Free Phase Recovery System

C25531212 Komex Report: 2001 Performance Report - Free Phase Recovery - LPG Recovery Area C25531303

Field Inhibitor Tank Remediation – LPG Unit

Remediation work had begun in this general area (Condensate Loading Area) in 2001. The

inhibitor tank and sump were also removed in the fall of 2001. The inhibitor tank remediation was

completed in the summer of 2002. Remediation consisted of removing contaminated soil for

testing to determine remediation options. The inhibitor contained some heavy end contaminates

that were not amenable to land treatment. The contaminated soil was temporarily stored just plant

south of the propane/butane truck loading area. The testing determined that off-site disposal was

the suitable disposal option. The contaminated soil was sent to the BFI landfill. Komex Report: Balzac Gas Plant – Inhibitor Tank Remediation – File No. 25531408

Sulphur Vat Pond Sludge (South of Wellsite 2-2)

Sludge from the Sulphur Vat Pond was evaluated and excavated and stored until 2003. (See

below)

Temporary Land Treatment Area (Adjacent to 2-2-26)

Contaminated soils from two pipeline failures (1-8-27 & 16-3-25) and a flare knockout

underground tank failure remediation project (6-23-27) were brought to the plant for land

treatment. The soils were treated throughout the summer and fall of 2002. The contamination

was condensate based and it was shown to be quickly treated using heavy equipment (tractor with

rotovator and lift removal with a dozer). Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006. (In

Draft).

PCB Soil/Debris Disposal from new Electrical Substation Revamp at Turnaround During the 2002 turnaround, low level PCB’s were discovered in the soil and some concrete

during a new substation upgrade. The concrete pads that housed the old transformer and capacitor

were removed; testing confirmed low level PCB’s were present on some of the concrete pads. A

new grounding grid was required around the new substation. To facilitate the grid installation a

trench was required. Soils around the substation were tested and low levels of PCB’s were

discovered in some areas.

The majority of the samples contained non-detect levels of PCB’s. The soil was transferred to soil

bins and off-site disposal was arranged. Komex Report: Balzac Gas Plant – PCB Soil Sampling and Delineation – File No. C25531403

Arsenic Detection’s in the S.W. Dugout

The recommended further sampling program continued through the summer 2002. Arsenic

values were below Canadian Livestock Watering Guidelines for the first part of the year and

again in the fall the arsenic values went above the guidelines. Resident notification again was

undertaken.

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2003 Activities: Phase III of the remediation system was designed to remove free product from

multiple vertical wells within the LPG area lean oil plum. Three new extraction wells (LPG-2,

LPG-3, and LPG-4) were installed. A Skimmer System was installed and rotated between the

three vertical wells on a regular basis throughout 2003 and 2004, removing the entire free product

thickness from wells LPG-2 and LPG-4.

Piezometers 92-12A, 98-24A, and 93-15C were replaced in June 2003.

In response to questions raised by AENV in a letter dated November 26, 2002, Komex issued an

‘Environmental Summary Update’ for the Balzac Gas Plant in June 2003, updating environmental

work completed and planned in the 5-year EMP. After review, AENV requested a further update

of more recent remedial work conducted in 2003/2004 (AENV letter dated March 3, 2004),

specifically including areas associated with the Sulphur Handling Facility. An ‘Environmental

Summary Update” was issued to address these requests, and update requirements of Section 5.3.2

of the Approval (AENV Approval No. 155-01-08). A ‘2005 Environmental Summary Update’

was prepared in July 2005, after a meeting and site tour was conducted with AENV.

A Flare area delineation program involving both soils and groundwater was conducted in

November 2003 as a continuation of the program initiated in September 1999. The purpose of the

program was to determine the lateral extent of the impact between the Flare area and McDonald

Lake. The program involved 14 soil sampling boreholes and the installation of seven piezometers;

one piezometer nest (03-39A/B) and five single piezometers (03-36A, 03-37A, 03-38A, 03-40A,

and 03-41A.

Remediation and reclamation of the North Landfill cell was completed in December 2003. In

addition, one down gradient piezometer was added to the Plant monitoring network (04-42A).

North Landfill Remediation

The North Landfill remediation was completed in 2003 except for topsoil dressing and seeding

which occurred in 2004. The area that the North Landfill was situated in was characterized and

delineated in environmental reports as listed below. Komex Report: Balzac Gas Plant – North and South Landfill Characterization Program – File No. 25531309

Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9

T01/T02 (Page 50 and Photos Section) Komex Report: Balzac Gas Plant – North Landfill Closure Report - File No. 25531505

Sulphur Vat Pond Sludge (South of Wellsite 2-2-26)

Approximately 6,926 tonnes of sludge from the Sulphur Vat Pond was sent to the BFI landfill in

2003. This material was removed from the Sulphur Vat Pond in 2002 and it was then evaluated

and stored temporarily over old Balzac South Landfill until a disposal option could be

determined.

Expand LPG Recovery System and Investigate Groundwater Treatment

Three additional collection points (perforated wells) for capturing contaminated groundwater

were completed in 2003 (Phase III work). The option of treating contaminated groundwater and

releasing it back to environment was assessed. Komex Report: Balzac Gas Plant – 2002 Performance Report – Free Phase Recovery System LPG Recovery Area Balzac Gas Plant –

File No. C25531407 – Draft Report

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Flare Area Review – and Remediation Plan and/or Risk Assessment

The existing groundwater contaminant situation was reviewed and an expanded assessment

program was developed. The expanded assessment program included an extensive soil

investigation and groundwater monitoring network that were completed in November 2003 to

help develop a monitoring and remediation plan. Komex Report: Balzac Gas Plant – Delineation of the Flare Area and Condensate Loading Areas – File No. C25531104 – Draft

Report

Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504

Waste Storage Area (Adjacent to 2-2-26)

Contaminated soils from two pipeline failures (1-8-27 & 16-3-25) and a flare knockout

underground tank failure remediation project (6-23-27) were brought to the plant for land

treatment in 2001. The contamination was condensate based and it was shown to be quickly

treated using heavy equipment. The area is a waste storage pad approved to store waste but its

not a Land Treatment Area (LTA). The area is a double lined collection area approved by ERCB

for containment. Waste is then hauled off quarterly/annually depending on volumes Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006. (In Draft).

Environmental Assessment of Soils for Proposed Sulphur Forming Facilities

AMEC Environmental conducted a subsurface soil assessment in an area designated for the

construction of a new sulphur forming facility. Completed – AMEC Earth and Environmental Ltd. February 2003 – CE02621

2004 Activities: In December 2004, Nexen submitted a Decommissioning and Reclamation plan

to AENV designed to remove the existing sulphur area slating units and replace them with three

enclosed GXM2 sulphur granulator units. Remediation and reclamation planning was an integral

component of the plan. In March 2006, the plan was updated and resubmitted to AENV.

Updated Risk Assessment (3 Ponds)

The Updated Risk Assessment Report was completed during 2004. Komex Report: Balzac Gas Plant – Updated Risk Assessment – C25531301 June 2004

Sulphur Handling Area - Demolition & Remediation Plan for Enersul Slating Facilities

A Decommissioning and Reclamation plan was developed for the Sulphur Handling Area. This

plan was submitted to Alberta Environment per Approval Number 155-01-05.

The Approval (155-01-05) required the following items to be submitted by December 1, 2004 in

regards to the Sulphur Handing Area:

Industrial Runoff Control System Upgrade. (5.4.1)

Decommissioning Plan (6.2.1)

Land Reclamation Plan (6.3.1) Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan – Sulphur Handling Facility - File No. C25531604

LPG Recovery System

The Phase III groundwater collection system continued to operate. To ensure Nexen is operating

within our remediation objectives, the LPG Recovery System was re-evaluated. Monitoring of the

LPG Recovery System continued. Komex Report: Balzac Gas Plant – 2003/2004 Performance Report – Lean Oil Remediation System – LPG Recovery Area – File No.

C25531605

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Flare Area Review – and Remediation Plan

Komex issued a Flare Area Review – and Remediation Plan report in December 2004. Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504

2005 Activities: the Skimmer System installed in 2003 successfully recovered additional free

product. Two deep cathodic protection wells (CPW) were installed at the Plant.

Flare Area Remediation

The draft Flare Area Investigation Report was finalized. Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504

LPG Recovery System – On-going

Nexen continued to pump contaminated groundwater and to monitor the LPG Recovery System.

In 2005, two collection wells were added under the LPG Bullets as part of the Phase III

groundwater collection system (skimming portion). Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No.

C25532004 (Draft)

Topsoil from 6-33-25 Reclamation

During Field A & R activities at wellsite 6-33-25, clean topsoil (2500 m3) was discovered and

brought to the plant for storage adjacent to the South landfill Area.

Alberta Environment Summary Update

AENV formally requested an update of recent remedial work conducted or planned for 2004/

2005/2006. Nexen conducted a tour for AENV officials (soils & groundwater experts) at the Plant

to discuss specific contaminate issues to support the reports and work that has been conducted at

the facility over numerous years. Komex Report: Balzac Gas Plant – 2005 Environmental Summary Update- File No. C25531700

2006 Activities: As part of the LPG Recovery System two new vertical extraction wells (LPG-5

and LPG-6) were added to expand Phase III of the remediation system.

In April 2006, a soil investigation was conducted in a pit area (Unknown Sump), situated west of

the holding pond in the Flare Area. Exploratory trenching was completed to investigate chloride

and hydrocarbon facility-related impacts. The investigation identified an approximate total in-situ

volume of 6,300 m3 of impacted materials. The boundaries of the excavation all met Tier I

guidelines with the exception of soils along the eastern wall of the excavation, where physical

constraints (roadway and pipeline) limited excavation in this direction. Assessment of an insitu

groundwater extraction system along the eastern wall of the excavation is under review.

A Site Specific Liability Assessment (SSLA) was completed (as required in support of the

Alberta Energy and Utilities Board (EUB) Large Facility Liability Management Program as

detailed in Directives 001 and 024). As a part of this Assessment, site-specific environmental

costs for reclamation and for soil and groundwater quality issues at the Site were estimated.

As a part of the 2006 Environmental Assessment for Management of Contaminated Sulphur and

Materials Contaminated with Sulphur, 34 boreholes were advanced throughout the Sulphur

Handling and Sulphur Block/Basepad Areas of the Plant. As outlined in the D&R Plan for the

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Sulphur Handling Facility, the results of the assessment program were used to define remedial

requirements for soil impacted by sulphur.

The 2006 Soil Monitoring Program involved the sampling of 49 boreholes throughout the Site, in

addition to two background boreholes/piezometers. The most significant chloride and/or

hydrocarbon impacts to soil were observed in the Evaporation Pond, Flare and Formation Water

Handling, and Process Areas. In addition, sulphur impacts in soil were identified in the

Cooling/Blowdown, Plant Maintenance and Sulphur Plant Areas.

As a result of these programs seven new single piezometers (06-43A through 06-49A) were

installed across the Site. Piezometer 93-15A was also re-drilled as it had been damaged by frost-

jacking.

Soil Monitoring Program – Plant Overall

The Soil Monitoring Program was completed throughout the Plant Site per Plant Operating

Approval with Alberta Environment in the fall of 2006. Worley Parsons Komex Report: Balzac Gas Plant – 2006 Soil Monitoring Program - File No. C25531803

Environmental Assessment for the Management of Contaminated Sulphur and Materials

Contaminated with Sulphur

This assessment program was an operating approval requirement. Included in the assessment was

assessment at the following locations:

the sulphur block

sulphur basepad

the slater units

sulphur load out areas

the sulphur soil piles Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur

and Materials Contaminated with Sulphur - File No. C25531803

Decommissioning and Reclamation Plan Sulphur Handling Facility

This report was issued to Alberta Environment (Mar. 2006) as per operating approval conditions.

The D&R Plan was approved by Alberta Environment in June 2006. Removal of the Enersul

Slating Facilities was completed (see below). Future work looked at Industrial Runoff and Site

Reclamation in the Sulphur Handling Area. Worley Parsons Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan Sulphur Handling Facility

- File No. C25531604

Sulphur Contaminated Infrastructure - Enersul Slating Facilities

The D&R plan was submitted to Alberta Environment in December 2004. Demolition of Enersul

surface sulphur slating facilities began July 2006. The Enersul Slater building was removed and

water tanks, belts, power, etc. were either disconnected or removed. Alberta Environment

required dust control measures had to be undertaken during the removal of the slater building.

Remediation of the Slater Area and upgrading (removing sulphur contaminated sediment from

ditches and installing lined ditches) was completed in 2009.

Unknown Sump Area Assessment - Flare Area

Assessment was completed on area of contamination based on previous flare area soils and

groundwater investigations.

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Worley Parsons Komex Report: Balzac Gas Plant – 2006 Soil Investigation in Unknown Pit Area - File No. C25531802

2006 Industrial Runoff Assessment

This assessment was a licence requirement as per current operating approval (155-02-00) with

Alberta Environment. The purpose of the report was to review runoff management at the Plant

and evaluate current practices to determine what improvements could be made to positively

impact the site and the watershed downstream of the plant. Worley Parsons Komex Report: Balzac Gas Plant – 2006 industrial Runoff Assessment - File No. C25531806

Flare Area Remediation Follow-up

Nexen continued to monitor this area to ensure impacts have been minimized and review how

effective remediation activities have been. Overall soils management program conducted in the

fall of 2006 added some piezometers and soil borehole locations.


Nexen continued to monitor the LPG Recovery. The lean oil collection system (collection of lean

oil which is situated on top of the groundwater table) in the LPG Unit was run throughout the

2006 season (early spring - April to late fall – October). The system was functioning as designed

with minor levels of BTEX showing up in the primary collection system and no BTEX levels in

the aerated discharge point (Trench and Gate System). As well the Phase III lean oil collection

system was run during 2006. The one skimmer pump (pumps only lean oil product) was

transported to various wells throughout the collection season. Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No. C25532004 (Draft)

EUB Directive 001 Site Specific Liability Assessment

The A&R Group in Calgary started the Directive 001 study in conjunction with a consultant and

Plant input. Nexen conducted this EUB compliant study to perform an overall site assessment of

the Plant with all collected data to date.

2007 Activities:

Soil Monitoring Management Plan

Subsequent to the completion of the 2006 Soil Monitoring Program, the soil management plan

was submitted to Alberta Environment within six months of the Soil Monitoring Program that

was conducted in 2006 per Plant Operating Approval with Alberta Environment. Worley Parsons Komex Report: Balzac Gas Plant – Soil Management Plan - File No. C25531901

Sulphur Contaminated Soil Pile Disposal - Phase I

Phase I removal of sulphur contaminated sulphur/soil storage pile located on the plant site began

in the fall of 2007 and continued with Phase II in the first quarter of 2008. Phase I saw 27,395.95

tonnes (16,305 m3) of sulphur contaminated soil pile removed to CCS Rocky Mountain House. Worley Parsons Report: Balzac Gas Plant – Sulphur Soil Pile Closure Sampling - File No. C25532001

EUB Directive 001 Site Specific Liability Assessment

A report was issued to the EUB on 001 Liability Assessment as per the Large Facility Liability

Management Program per EUB’s Guide 024. Worley Parsons Komex Report: Balzac Gas Plant – Directive 001 Site Specific Liability Assessment - File No. C25531801

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LPG Recovery System

Nexen continued to pump contaminated groundwater and to monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No.

C25532004 (In Draft)

New Underground Sulphur Pit Construction

Soils were assessed during the construction of the new underground sulphur pit. Some soil was

sulphur contaminated and segregation and delineation activities were conducted during the

preparation for construction. Some sulphur contaminated soil was removed and placed on the

Sulphur Contaminated Soil Pile (see above). Approximately 3,950 m3 of soil was excavated

during the sulphur pit excavation. Analytical results indicate hydrocarbon and sulphur impacts

remained in the excavation wall and base. Worley Parsons Report: Balzac Gas Plant – Sulphur Pit Construction - File No. 25531902 (In Draft)

2008 Activities:

Sulphur Contaminated Soil Pile Disposal – Phase II

Phase II removal of sulphur contaminated sulphur/soil storage pile located on the plant site began

in the Jan 2008 and was completed April 2008. Phase II saw 58,234 tonnes (~32,352 m3) of

sulphur contaminated soil pile removed to CCS Rocky Mountain House. Worley Parsons Report: Balzac Gas Plant – Sulphur Soil Pile Closure Sampling - File No. C25532001

Suspected Topsoil StockPile Disposal

During the 2006 Soil Monitoring Program (SMP), sulphur and salinity impacts were identified

within a soil stockpile (previously referred to as “suspected topsoil stockpile”) in the sulphur

handling facility area.

Excavation and off site removal of the soil stockpile and underlying and adjacent material took

place from November 12 to 26, 2008. Excavated material was transported to BFI Landfill south

of Calgary. The volume received by the landfill was 15,086 tonnes. Worley Parsons: Sulphur Impacted Soil Stockpile Removal in Sulphur Handling Facility at Balzac Sour Gas Plant. File No. C25532007. (In Draft)

Sulphur Contaminated Soil Remediation - Enersul Slating Facilities

Started remediation program based on Sulphur Area Decommissioning and Reclamation Plan

conducted in 2004 and Environmental Assessment for the Management of Contaminated Sulphur

and Materials Contaminated with Sulphur conducted in 2006. The purpose of the report was to

assess areas of the Plant with sulphur contamination issues and provide the following: estimated

volumes of contaminated material, schedule for removal, evaluation of the permeability of the

area storing sulphur, upgrading of ditches, schedule of activities, etc. Worley Parson Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan – Sulphur Handling Facility - File No.

C25531604

Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur and Materials Contaminated with Sulphur - File No. C25531803

Worley Parsons Komex Report: Balzac Gas Plant – Confirmatory Soil Sampling – Balzac Plant Ditch Excavation - File No.

C25532106

LPG Recovery System

Nexen continued to pump contaminated groundwater and to monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No. C25532004 (Draft)

BALZAC GAS PLANT


64

Unknown Pit Remediation - Flare Area

Remediation of a previously unknown pit in the flare area began in 2008 and continued in 2009.

Remediation continued in 2010 however remediation on hold pending overall strategy

development. Further remediation activities will be reviewed as part of the overall Plant

remediation assessment activities. Worley Parsons Report: Balzac Gas Plant – 2006 Soil Investigation in Unknown Pit Area - File No. C25531802

Industrial Runoff Upgrades

Based on the 2006 Industrial Runoff Assessment the upgrades in the Enersul Area were

commenced in conjunction with the Sulphur Soil Remediation of the Enersul Facilities. Worley Parsons Komex Report: Balzac Gas Plant – 2006 Industrial Runoff Assessment - File No. C25531806

Land Treatment Activities Pipeline Failure 7-15-25 Nov 2007

Land and treatment activities on the soils brought from the 7-15-25 pipeline failure that occurred

December 2007 were completed in September 2008. The soils were treated and then stockpiled

beside the treatment area. Worley Parsons Komex Report: Balzac Gas Field – Pipeline Release Remediation Program at 7-15-25-28 W4M Wellsite - File No.

C50920500

Land Treatment Activities Pipeline Failure 1-8-27 & 6-23 KO Drum Removal

A total of approximately 7,700m3 of excavated soils from 01-08-027-27 W4M (4, 100m

3) and 06-

23-027-27 W4M (3,600m3 ), as well as excess drilling mud from re-entry activities at the BGP,

was treated from 2002 to 2009. The material was initially land surface treated in the TTA next to

the 02-02-026-29 W4M well site, and then stockpiled in an area adjacent to the well site once

remediation guidelines at the time of sampling were met.

Untreated soil was moved within the Plant in 2008, land surface treated, and piled once Tier 1

Guidelines were met. Treated soil hydrocarbon concentrations in analysed samples were below

Tier I guidelines. Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006.

(Draft).

2009 Activities: a sulphur base pad assessment was completed to quantify the amount of possible

recoverable sulphur on the base pads, and the extent of impacts to soil underlying the sulphur. A

total of 23 boreholes were advanced within the east base pad area. Elemental sulphur impacts

above the AENV Tier I guideline were identified to an average depth of 0.65 mbgs in soil

underlying the current base pad.

In 2009, upgrading of the surface water drainage ditch system in the sulphur handling facility

commenced. Impacted soil was also excavated from the drainage system, the underground rail

car, the old slating units and poured sulphur pad within the sulphur handling facility.

The current groundwater monitoring network comprises of 68 piezometers, three culverts and 13

surface water sampling locations. Seasonal groundwater monitoring (fall and spring) was

completed in 2009. The most significant chloride impacted groundwater was present during

these monitoring events in the Flare Area, the Former Process Ponds, and the Evaporation Pond.

The most significant hydrocarbon impacts in groundwater were present in the Flare Area, the

Former Process Ponds, the Plant Recovery area and the LPG Recovery Area.

BALZAC GAS PLANT


65

Sulphur Contaminated Soil Remediation - Enersul Slating Facilities

Complete remediation program that was started in 2008 along with Industrial Runoff Upgrades in

the Enersul Area. Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan – Sulphur Handling Facility - File No. C25531604 Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur

and Materials Contaminated with Sulphur - File No. C25531803

Worley Parsons Komex Report: Balzac Gas Plant – Topsoil Stockpile Removal - File No. C25532007 DRAFT Worley Parsons Komex Report: Balzac Gas Plant – Sulphur Ditch Assessment - File No. C25532106

Sulphur Contaminated Soil Remediation - Sulphur Block and Sulphur Basepad

Continue to develop a plan for basepad reclamation and sulphur block/basepad reclamation.

South Landfill Remediation

The South Landfill remediation was originally planned for 2009 but not competed. Remediation

of this landfill is on hold pending overall strategy development. The area that the landfills are

situated on was characterized and delineated in environmental reports as listed below. Komex Report: Balzac Gas Plant – North and South Landfill Characterisation Program – File No. 25531309

Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9 T01/T02

Sulphur Contaminated Soil Remediation – Weigh Scale

Conducted minor clean-up activities of sulphur and soil just outside the fence near Plant weigh

scale.


Continued to pump contaminated groundwater and monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2009-201 Performance Report Lean Oil Remediation System - File No.

C25532104 (Draft)


Remediation of a previously unknown pit in the flare area began in 2008 and continued in 2009. Worley Parsons Report: Balzac Gas Plant – Unknown Sump Excavation Update - File No. C25531802

Confirmatory Soil Sampling Summary, Balzac Plant Ditch Excavation

Began the excavation and removal of soil impacts related to sulphur production. Collected

confirmatory samples in conjunction with this ditch upgrade work. Remedial excavation work

was carried out from August – December 2009. Approximately 29,000 tonnes of sulphur-

impacted soil was excavated and hauled to the BFI Canada Inc. Calgary landfill. Worley Parsons Report: Confirmatory Soil Sampling Summary, Balzac Plant Ditch Excavation – File No.C25532106, 23-March-

2011.

Worley Parsons: Interim As-Built Drawings of Surface Water Collection Ditches Constructed During 2009 at the Balzac Gas Plant -. Report C25532005. December 23, 2009.

DEA UST Removal and Replacement

In 2009 the DEA UST was pressure tested and failed. Since the reason for failure could not be

determined, Nexen implemented replacement plans for the UST. On Sept. 3-4, 2009, the

excavation and installation of a new tank occurred. During excavation soil and groundwater

sampling was conducted and a groundwater extraction system was installed. Approximately

50m3 of impacted soil was excavated from the new DEA UST. Wall and base soil sampling

indicated soil met Tier 1 Guidelines for all parameters except EC at four of the five sample

locations and PHC F2 at a single sample location. Worley Parsons-2009 DEA UST Removal and Replacement - Letter Report. Report C25532107. May 10, 2011. DRAFT

BALZAC GAS PLANT


66

2010 Activities:


Remediation of a previously unknown pit in the flare area began in 2008 and continued in 2009.

In 2010, approximately 700 m3 of soil from the Unknown Sump was treated.


Continued to pump contaminated groundwater and monitor the LPG Recovery System. Worley Parsons Komex Report: Balzac Gas Plant – 2009-201 Performance Report Lean Oil Remediation System - File No.

C25532104 (Draft)

2011 Activities:

No update as plant shutdown was being planned.

The figure on the following page provides a cursory outline of past remediation programs.

TABLE 5.PREVIOUS ENVIRONMENTAL INVESTIGATIONS BY LOCATION AND YEAR

LSU Description 1989 1991 1992 1993 1994

General Various Locations of the Site

Hydrogeological assessment, installation and sampling of 11 monitoring wells (UMA,

1989)

Assessment of hydrogeological conditions (Piteau, 1992a)

Upgrade of the groundwater monitoring network, installation of 18 observation wells (Piteau 1993a). Geophysical surveys conducted near

the buried south landfills, south of the main Process Area, and down gradient of North and South Cooling Tower Blowdown Ponds (Piteau

1992b).

Piezometers installed on the west side of McDonald Lake (93-15A (R)/C (R) and 93-16A/C) to further

define local background conditions (Komex 1995a). Groundwater monitoring program (Piteau 1993b/c)

Geophysical investigation south of the main Process area to assess the extent of potential subsurface impact associated with a number of former wastewater and surface runoff

ponds (Komex 1995b). Stable isotope investigation in and around the plant ponds, sulphur storage and sulphur loading areas (Komex 1995c). Groundwater monitoring program

(Komex 1995a)

1 Southwest Quadrant

2 South Landfill Install 94-17C bedrock piezometer (Komex 1995b).

3 2-2 Pits/ Treatment Area

4 Evaporation Pond

5 Southeast Quadrant Install 94-19C bedrock piezometer (Komex 1995b).

6 North Landfill

7 Drilling Mud Sump

8 Boneyard/Field Maintenance

9 Flare & Formation Water Handling Area

10 Riparian/Shoreline11 Firewater Reservoir

12 Southeast Process Pond

13 Cooling/Blowdown

14 Plant Maintenance

15 Inlet Compression/Sales

16 Condensate Storage Area

17 LPG/Condensate Loadout

18 Sulphur Block/Basepad Geophysical survey in the vicinity of the Sulphur Block storage area (Komex 1994). Install 94-18C bedrock piezometer (Komex 1995b).

19 Sulphur Plant

20 Office Control/Room

21 Process Area

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LSU Description 1989 1991 1992 1993 1994

22 LPG Unit

23 Power Station Three underground storage tanks containing diesel and gasoline in parking lot were removed (Komex 2000g and 2000h).

24 Sulphur Vat Pond

25 Sulphur Handling Facility

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LSU Description



2 South Landfill


4 Evaporation Pond

5 Southeast Quadrant

6 North Landfill

7 Drilling Mud Sump





13 Cooling/Blowdown





18 Sulphur Block/Basepad

19 Sulphur Plant


21 Process Area

1995 1996 1997 1998 1999

Groundwater monitoring program (Komex 1996) Groundwater monitoring program (Komex 1997a). First soil monitoring program (Komex 1997b).

Groundwater monitoring program (Komex 1998a). Soil management plan (Komex 1997c) and remedial program work plan

(Komex 1997d).

Groundwater monitoring program (Komex 1999a). Integrated soil and groundwater investigation, twelve piezometers were installed (Komex

1998b). A 5 year environment management plan for the Site developed (Komex 1998d).

Groundwater monitoring program (Komex 2000a).

Soil monitoring program (Komex 1997b).

Identified soil contamination in two former flare pits southwest of the boneyard (Komex 1998b)

Former 2-2 North and South Flare Pits were remediated. Approximately 4600 m3

excavated (Komex 2000c).

Soil sampling program (Komex 1995b) Integrated soil and groundwater investigation (Komex 1998b).

Soil and sludge sampling program (Komex 1995b) Remediation program of the Drilling Mud Pit, soils treated with lime (Komex 1999c).

Soil monitoring program (Komex 1997b). Integrated soil and groundwater investigation (Komex 1998b).

Soil and sludge sampling program (Komex 1995b). Temporary piezometer (95‑20A) installed south of piezometer nest 92‑8A/B

(Komex 1996). Soil monitoring program (Komex 1997b).

Remediation program of the Hydrocarbon Burn Pit (Komex 1999c). Approximately 1600

m3 of accessible soil excavated next to LP flare knockout drum (Komex 1998b).

Remediation programs of the Hydrocarbon Burn Pit (2850 m3 excavated) , the Filter Cake Pond (1400 m3 excavated), the Chemical Pond (2250 m3

excavated) and Slop Tank (excavated 850 m3) (Komex 1999c). Integrated soil and groundwater investigation (Komex 1998b).

Soil and groundwater investigation to delineate known contaminant situations

(Komex 2000d).


Remediation of soil adjacent to the southeast Process Pond. Excavation of 2200 m3. Area was contaminated by a release from a Anderson Exploration Ltd. condensate pipeline. Piezometer 98-29A was installed (Komex 1999d).

Integrated soil and groundwater investigation (Komex 1998b).

Temporary piezometers (96‑21A and 96‑22A) installed down‑gradient of the North and South Cooling Tower Blowdown

Ponds (Komex 1997a).Integrated soil and groundwater investigation (Komex 1998b).



Soil monitoring program (Komex 1997b). Integrated soil and groundwater investigation (Komex 1998b). Soil and groundwater investigation to

delineate known contaminant situations in Condensate Loading Area (Komex 2000d).

Soil monitoring program (Komex 1997b). Investigation to determine potential impact to shallow soil (Komex 1997e)



3 of 10 10/11/2011 12:13 PM


LSU Description

22 LPG Unit

23 Power Station

24 Sulphur Vat Pond


1995 1996 1997 1998 1999

Soil monitoring program (Komex 1997b). Identified free phase hydrocarbon product contamination in the LPG

Recovery area (Komex 1998c). Integrated soil and groundwater investigation (Komex 1998b).

Three phase remediation plan implemented. Phase I consisted of a free product recovery

trench and recovery well (Komex 2000e).



4 of 10 10/11/2011 12:13 PM


LSU Description



2 South Landfill


4 Evaporation Pond


6 North Landfill

7 Drilling Mud Sump





13 Cooling/Blowdown






19 Sulphur Plant


21 Process Area

2000 2001 2002 2003

Groundwater monitoring program (Komex 2001a). Update of thee nvironmental management plan for the

Site(Komex 2000b)

Groundwater monitoring program (Komex 2002a). Revised environmental management plan, extending to 2005

(Komex 2001c). Piezometer replacement program (Komex 2003e).

Groundwater monitoring program (Komex 2003a).

Groundwater monitoring program (Komex 2004a). Environmental Summary Update issued for the Site, updating

environmental work completed and planned in the 5‑year environmental management plan (Komex 2003g). Piezometer

replacement as recommended (Komex 2003a).

Ex-situ remediation of hydrocarbon impacted soils from Main Parking Lot, LPG Surge Tank and Condensate Loading Area (Komex 2003b). Characterization and delineation of South

Landfill (Komex 2002c).

A risk assessment of the Evaporation pond initiated in 1998 and updated in 2001. Pond sampled and evaluated for potential to

adversely impact aquatic life due to salinity or metals (Komex 2002d).

Landfill east of the Evaporation Pond discovered along the planned route of the water pipeline (2001d and 2001e).

Characterization and delineation of the North Landfill (Komex 2002c)

Remediation and reclamation of the North Landfill, approximately 8700 m3 excavated (Komex 2004e).

A risk assessment of the Holding pond initiated in 1998 and updated in 2001. Pond sampled and evaluated for potential to


Delineation program involving both soils and groundwater. The program involved 14 soil sampling boreholes and the

installation of seven piezometers (Komex 2004d).

A risk assessment of the Southeast pond initiated in 1998 and updated in 2001. Pond sampled and evaluated for potential to


Removal of the surficial sediment layer from the Southeast Process Pond (Komex 2005c)

Sludge layer removed from ponds. North Pond reconstructed with a compacted clay liner (Komex, 2005c)

KVSR sump tank removed, approximately 340 m3

impacted soils excavated where possible (Komex 2003d)

Condensate impact encountered along the fuel gas pipeline path (2001d and 2001e).

Remediation program of condensate loading area, hydrocarbon (4900 m3) and sulphur (2500 m3) impacted

soils excavated (WorleyParsons 2011f).

Removal of two above ground methanol storage tanks, excavation (1000 m3) and soil treatment program conducted on

the underlying methanol impacted soils (Komex 2002b)

Field inhibitor storage tank and sump removed. Impacted soil excavated (345 m3) and disposed

of at the BFI landfill (Komex 2003f).

Soil quality investigation around the main electrical sub-station, trace amounts of

polychlorinated biphenyls (PCBs) and heavy‑end hydrocarbons noted. Approximately 5900 kg of

soil excavated (Komex 2004b).

RDS Sump Tank Excavation (Komex 2003d).

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LSU Description

22 LPG Unit

23 Power Station

24 Sulphur Vat Pond


2000 2001 2002 2003

Phase II of the remediation plan, which included installation of a trench and gate system down‑gradient of

the free product plume (Komex 2001f). LP Surge excavation approximately 900 m3 raw condensate/waste

oil impacted soils excavated (Komex 2003d).

Free phase recovery system performance (Komex 2003c)

Phase III of the remediation system was initiated, system designed to remove free product from multiple vertical wells

within the LPG area lean oil plume (Komex 2005b).

Soil quality delineation and remediation programs were implemented to ensure that the Site was suitable for Power Station construction. Approximately 4000 m3

excavated (Komex 2000g and 2000h).

Soil assessment to document pre-development soil conditions (AMEC 2003).

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LSU Description



2 South Landfill


4 Evaporation Pond


6 North Landfill

7 Drilling Mud Sump





13 Cooling/Blowdown






19 Sulphur Plant


21 Process Area

2004 2005 2006 2007 2008

Groundwater monitoring program (Komex 2005a). Environmental Summary Update issued to address Alberta Environment requests

(Komex 2004c). Decommissioning and reclamation plan submitted to Alberta Environment for removal and replacement of the sulphur area

slating units (Komex 2004f).

Groundwater monitoring program (WorleyParsons Komex 2006a). 2005 Environmental Summary

Update prepared, after a meeting and Site tour with Alberta Environment (Komex 2005c).

Groundwater monitoring program (WorleyParsons Komex 2007a). Soil monitoring program and install of seven piezometers

(WorleyParsons Komex 2006c and 2006d). Decommissioning and reclamation plan updated and resubmitted to Alberta Environment

(WorleyParsons Komex 2006b). Phase 1 Environmental Site Assessment (WorleyParsons Komex 2006e).

Groundwater monitoring program (WorleyParsons Komex 2008a). Soil Management Plan developed (WorleyParsons Komex 2007b). Soil management activities summary (WorleyParsons Komex 2008c)

Groundwater monitoring program (WorleyParsons 2009a). Soil management activities summary

(WorleyParsons 2009d)

Soil monitoring program (WorleyParsons Komex 2006d).



Soil investigation in the Unknown Sump (pit) area (WorleyParsons 2009f). Soil monitoring program (WorleyParsons

Komex 2006d).

Excavation of the Unknown Sump, portion of the impacted material sent off Site for disposal,

remaining material stockpiled on Site for treatment (WorleyParsons 2011b)







Baseline assessment of soil and groundwater conditions in the vicinity of Sulphur Handling Facility (AMEC 2004) Soil monitoring program (WorleyParsons Komex 2006c).

Removal and off Site disposal of the sulphur/soil stockpiles located southwest of the existing Sulphur

Block (WorleyParsons 2009c).

Soil monitoring program (WorleyParsons Komex 2006c).Construction of a new sulphur pit, impacted soil (3950 m3) excavated (WorleyParsons 2011c).

Soil monitoring program (WorleyParsons Komex 2006d). Installed two vertical remediation Stabilizer Culverts down‑gradient of the stabilizer towers.

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LSU Description

22 LPG Unit

23 Power Station

24 Sulphur Vat Pond


2004 2005 2006 2007 2008

Soil monitoring program (WorleyParsons Komex 2006d).Installed three remediation culverts around the CHD system in the LPG area, which are included in the

operation of the LPG remediation system.


Baseline assessment of soil and groundwater conditions in the vicinity of Sulphur Handling Facility (AMEC 2004) Soil monitoring program (WorleyParsons Komex 2006c).

Suspected topsoil stockpiles removed from Site and sent for off Site disposal Impacted soil underlying and adjacent to the stockpile was also

removed from Site (WorleyParsons 2011e).

Notes Indicates Assessment WorkIndicates Remediation Work

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LSU Description



2 South Landfill


4 Evaporation Pond


6 North Landfill

7 Drilling Mud Sump





13 Cooling/Blowdown






19 Sulphur Plant


21 Process Area

2009 2010

Groundwater monitoring program (WorleyParsons 2010a). Soil management activities summary

(WorleyParsons 2010b)

Groundwater monitoring program (WorleyParsons 2011a). Soil

management activities summary (WorleyParsons 2011d).

Environmental assessment of the east and west sulphur base pads (WorleyParsons 2009e).

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LSU Description

22 LPG Unit

23 Power Station

24 Sulphur Vat Pond


2009 2010

Upgrading of the surface water drainage ditch system, impacted soil was excavated (29000

tonnes) within the drainage system and within the sulphur handling facility. Impacted soil was sent off

Site for disposal (WorleyParsons 2010c).

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CONDENSATE SPILL-FEDERATED/ANDERSONREMEDIATION 1998.

REPORT TO ANDERSON NOV 1999KOMEX REPORT C47480100

UNDERGROUND STORAGE TANKS REMOVAL -UPGRADE EXCAVATE CONTAMINATED SOILS

FOR LAND TRT. 2000 & 2001 KOMEXREPORT C2553-1206 RERUN SUMP

SALES GAS OIL SUMP ELKTONKVSR OIL SUMP SITE 'G' SUMP FURTHER

DELINEATION COMPLETED IN2006 ON: TRIM SUMP, BULK SUMP

UNDERGROUND STORAGE TANKSREMOVAL - UPGRADE EXCAVATE

CONTAMINATED SOILS FOR LANDTRT. 2000 & 2001 KOMEX REPORT

C2553-1206 RERUN SUMPSALES GAS OIL SUMP ELKTON KVSR

OIL SUMP SITE 'G' SUMP FURTHERDELINEATION COMPLETED IN

2006 ON: TRIM SUMP, BULK SUMP

UNDERGROUND STORAGE TANKS REMOVAL- UPGRADE EXCAVATE CONTAMINATED SOILSFOR LAND TRT. 2000 & 2001 KOMEXREPORT C2553-1206 RERUN SUMPSALES GAS OIL SUMP ELKTONKVSR OIL SUMP SITE 'G'SUMP FURTHER DELINEATION COMPLETED IN2006 ON: TRIM SUMP, BULK SUMP

HOLDING POND RISK ASSESSMENT-1998

KOMEX REPORT KI-98-4683KOMEX REPORT C25531301

2-2 PIT NORTH REMEDIATED 1999-2000 OFFSITE TREATMENT OF SLUDGE - THERMAL DESORPTION LAND TREATMENT FOR REMAINING SOILS COMPLETED 2000KOMEX REPORT C25521103KOMEX REPORT C25531204

FILTER CAKE POND REMEDIATED 1998OFFSITE DISPOSAL OF SLUDGES

LAND SURFACE TREATMENT OF REMAINING SOILS KOMEX REPORT KI-2553-10-2

NEW CONSTRUCTION IN FLARE AREA APPROX. 850m .EXCAVATED (1997) AND LAND SURFACE TREATMENT WITH OTHER PIT/POND MATERIAL (1998)

KOMEX REPORT KI-2553-10-02

CHEMICAL POND REMEDIATED 1998OFFSITE DISPOSAL OF SLUDGES

LAND SURFACE TREATMENT OF REMAINING SOILS KOMEX REPORT KI-2553-10-2

2-2 PIT SOUTH REMEDIATED 1999-2000 OFFSITE TREATMENT OF SLUDGE-THERMAL DESORPTION

LAND TREATMENT FOR REMAINING SOILS KOMEX REPORT C25521103 & C25531204

-INHIBITOR TANK & METHANOL TANK REMOVED 2001 UPGRADED CONTAINMENT & STORAGE FOR BOTH TANKS NOW LOCATED IN FIELD BONEYARD. -METHANOL TANK REMEDIATION - 2001 KOMEX REPORT 25531306 -INHIBITOR TANK REMEDIATION COMPLETED 2002.KOMEX REPORT 25531408NEW FACILITIES - DOUBLE WALLED TANKSFIELD BONEYARD

BALZAC PARKING LOTUNDERGROUND PETROLEUM TANK INVESTIGATIONREMEDIATION SEPT/OCT 2000 KOMEX REPORT 25531208

CONDENSATE LOADING AREA DELINEATION COMPLETE IN 1999

EXCAVATION 2000 SULPHUR CONTAMINATED SOILS TO PILE.

KOMEX REPORT C2553-1211 & C25531104

REMOVAL OF SOIL TO FACILITATE CONSTRUCTION OF NEW

SULPHUR PIT - 2007 WPK REPORT 25531902

HYDROCARBON BURN PIT & DITCHES REMEDIATED 1997-1998 OFFSITE DISPOSAL OF SLUDGES LAND SURFACE TREATMENT OF REMAINING SOILS LAND TREATMENT OF DITCHES KOMEX REPORT KI-2553-10-2

LPG RECOVERY AREA-LEAN OIL COLLECTION REMEDIATION ACTIVITIES *DELINEATION OF FREE PRODUCT CONTAMINATION IN LPG RECOVERY AREA-BALZAC GAS PLANT-1999 KOMEX REPORT KI-2553-10-05 *PHASE 1-RECOVERY TRENCH - 1999 KOMEX REPORT C-2553-1106 *DELINEATION OF FREE PRODUCT CONTAMINATION IN CLA AND FLARE AREA-MAY 1999 KOMEX REPORT KI-2553-1104 *PHASE 2-TRENCH & GATE COLLECTION SYSTEM-2000 KOMEX REPORT C-2553-1212 TRENCH & GATE COLLECTION SYSTEM 2001 KOMEX REPORT C-2553-1303 *PHASE 3-2003 EXPAND LPG RECOVERY SYSTEM KOMEX REPORT C-2553-1503 *REMEDIATION OPTIONS ANALYSIS-LPG RECOVER AREA KOMEX REPOT 2553-1102 *PROPOSED EXPANSION OF FREE PRODUCT RECOVERY SYSTEM KOMEX REPORT 2553-1206 *2003-2004 PERFORMANCE REPORT-LEAN OIL REMEDIATION SYSTEM - LPG RECOVERY AREA KOMEX REPORT 2553-1605 *2005 PERFORMANCE REPORT LEAN OIL - REMEDIATION SYSTEM KOMEX REPORT 2553-1702

DRILLING MUD SUMP REMEDIATED 1998 CALCIUM AMENDMENTKOMEX REPORT KI-2553-10-2

TEMPORARY LAND TREATMENT AREA SOILS STORAGE (CLEAN)PARKING LOT SOILS ~3600m3 LP SURGE SOILS ~900m3CONDENSATE LOADING SOILS ~1000m3SOUTH BLOWDOWN POND SLUDGE/SOIL ~1000m3COMPLETED FALL 2001 KOMEX REPORT C2553-1211

EVAPORATION POND RISK ASSESSMENT - 1998 KOMEX REPORT KI98-4683KOMEX REPORT C25531301

SOUTHEAST PROCESS AREA RUNOFF PONDRISK ASSESSMENT - 1998

KOMEX REPORT KI-98-4683 KOMEX REPORT C25531301

SEDIMENT REMOVAL 2002/2003

ENVIRONMENTALSOILS ASSESSMENTFOR NEW SULPHURFORMING FACILITY- 2003 AMEC AMECREPORT: CE02621

PHASE 1 / 11 ENVIRO. SITE ASSESSMENT PROPOSED BALZAC POWER STATION. JACQUES WHITFORD REPORT: ABC50167-9

WATERLINE INSTALLATIONHYDROCARBON RESULTS - 2001KOMEX REPORT C2553-1307

- SOIL QUAILITY ADJACENT TO SULPHUR CONTAMINATED SOIL PILE - 1997 KOMEX REPORT 2553-8-2 - SULPHUR CONTAMINATED SOIL PILE EVALUATE COST EFFECTIVE DISPOSAL OPTIONS BENCH TESTING CONDUCTED 2000 - SULPHUR SOIL PILE RESAMPLED AS PART OF "2006 ENVIROMENTAL ASSESS FOR MGM OF CONTAMINATED SULPHUR" WPK REPORT 25531803 KOMEX REPORT KI-2553-1104 - SULPHUR PILE REMOVAL TO LANDFILL PHASE 1 - STARTED OCT. 2007 SULPHUR SOIL REMOVED 16,305m3 (27,394 tonnes) - PHASE 2 - STARTED JAN. 2008 SULPHUR SOIL REMOVED 29,171m3 (58,234 tonnes) SULPHUR SOIL REMEDIATION WPK REPORT 25532001 REPORT PENDING

NORTH LANDFILL AREACHARACTERIZATION PROGRAM

COMPLETED 2001 KOMEX REPORT C25531309 &

KI-2553-9REMEDIATION COMPLETED 2003-2004

CLOSURE SAMPLING REPORT KOMEX REPORT C25531505

UPGRADE RUNOFF WATER CONTROLAROUND SULPHUR BLOCK AREA 1994-1995

PETROGAS REPORT: C. FILE 001-02

SOIL ASSESSMENT & GROUNDWATERBASE-LINE DATA

AMEC PROPOSAL & REPORT CE2004/173

SOIL MONITORING (AMD)1988-PRESENT

MATRIX SOLUTIONS/JIM LORE & ASSOC. LIMING PROGRAMS

1990, 1992, 1995, 2004

SULPHUR CONTAMINATED SOIL REMEDIATION TECH - 2001PROCESS RESEARCH ASSOC. REPORT PROJECT 00-05207

FUEL GAS INSTALLATIONHYDROCARBON MONITORING RESULTS - 2001 KOMEX REPORT C25531307

ARSENIC DETECTIONS IN SW DUGOUT KOMEX REPORT 2553-1302CONTINUE TO MONITOR

BONEYARD: RESAMPLED 2006KOMEX REPORT C25531901

FLARE AREA DELINEATION OF CONTAMINATION IN FLARE AREA & CLA KOMEXE REPORT 25531104 - 2000 2003 SOILS & GROUNDWATER INVESTIGATION IN THE FLARE AREA - BALZAC GAS PLANT KOMEX REPORT 2551504

SOUTH BLOWDOWNPOND SLUDGE REMOVAL NOV.2000

SULPHER RECOVERY AREARESAMPLED 2006 2006SOIL MGM PLAN WPKREPORT C25531901

PCB REMOVALSUBSTATION #6-2000 & 2002

NORTH BLOWNDOWNPOND SLUDGE REMOVAL & DISPOSAL SEPT.2000

STUDY OF SOIL, SLUDGE AND GROUNDWATER AROUND TEH BLOWDOWN PONDS KOMEX REPORT 2553-7-2

CONDENSATE STORAGE TANK/ LP SURGE FURTHER DELINEATION COMPLETE

2006 SOIL MGM PLANWPK REPORT C25531901

REMOVAL OF PCB CONTAMINATED SOIL IN ELECTRICAL SUBSTATION GROUND GRID-2002 (PARTIAL) PCB REMOVAL CAPAC. BANK MAIN SUBSTATION - 2002

SULPHUR AREA DECOMMISSIONING& RECLAIMATION PLAN - PROPOSALKOMEX C25531604

EFFECTS OF ACID CONITIONS ON ELEMENT DISTRIBUTION BENEATH A SULPHUR BASEPAD KOMEX REPORT K1964374 - 1996

SOUTH LANDFILL AREA (5 CELLS) CHARACTERIZATION PROGRAM COMPLETED 2001 KOMEX REPORT C25531309 7 KI-2553-9

0 100 200 30050Meters

Author: R. McCallumGIS Analyst : M. JanickDept.: GIS Services

Date: June 10, 2011File No: A12780.mxd


Figure 4.COMPLETE OR

ASSESSED PROGRAMS


Scale:1:2,500

services

LegendComplete or Assessed Programs

DEA UST REMOVALWP REPORT C25532107 - DRAFT

CONFIRMATORY SOIL SAMPLINGSUMMARY

WP Report C25532106

SULPHUR IMPACTED SOIL STOCKPILE REMOVALWP REPORT C25532007-DRAFT

SULPHUR BASE PAD ASSESSMENTWP 25532102, 2009

SULPHUR PILE CLOSURE REPORT

DRAFT

UNKNOWN SUMP SOIL INVESTIGATIONWP REPORT C25531802SOIL REMEDIATIONWP REPORT PENDING

LAND TREATMENT FOR PIPELINE FAILURE01-08-27-27W4 & 06-23-027-27W4WP REPORT C25532006 - DRAFTWP REPORT C25531409 - PENDING

WP REPORT C25531403 - DRAFT

BALZAC GAS PLANT


69

8 CURRENT STATE OF PROPERTY

This section outlines the current known state of soil, groundwater and surface water based upon

completed investigative and remedial projects to date at the BGP. The BGP has been divided into

the following Liability Sub-Units:

Table 6. Liability Sub-Units (“LSU”)

Liability Subunit(s)

1. Southwest Quadrant 2. South Landfill 3. 2-2 Pits/Treatment Area

4. Evaporation Pond 5. Southeast Quadrant 6. North Landfill

7. Drilling Mud Sump 8. Boneyard/Field Maintenance 9. Flare & Formation Water

Handling Area

10. Riparian/Shoreline 11. Firewater Reservoir 12. Southeast Process Pond

13. Cooling/Blowdown 14. Plant Maintenance 15. Inlet Compression/Sales

16. Condensate Storage Area 17. LPG/Condensate Loadout 18. Sulphur Block/Basepad

19. Sulphur Plant 20. Office/Control Room 21. Process Area

22. LPG Unit 23. Balzac Power Station 24. Sulphur Vat Pond

25. Sulphur Handling Facility Entire Site

Robert McCallum

Text Box

5

BALZAC GAS PLANT


71

8.1 Primary Sources of Contamination Potential sources of contamination and location within the Site are summarized in the following

table.

Table 7. Summary of Potential Environmental Issues

LSU LSU

Reference

Source Issue

Entire Site Deep wells Potential cross-contamination due to improper

abandonment

South Landfill 2 Former landfill Impacts associated with former landfill

Evaporation Pond 4 Evaporation pond Impacts associated with surface water and sediments

Land treatment area Treatment of hydrocarbon and condensate-impacted

soils

Boneyard/Field

Maintenance

8 AST area Hydrocarbon impacts associated with bulk storage of

fluids

Spills/leaks Impacts associated with spills and leaks

Flare & Formation

Water Handling Area

9

Unknown Sump area Impacts associated with a former buried sump

Holding pond Impacts associated with sediments and surface water

Pits and ponds Impacts associated with former burn pit and chemical

pond

Collection pond,

tanks, equipment,

spills, leaks

Impacts associated with equipment, tankage, and plant

processes in area

Sludge Impacts associated with sediments

Pond water Impacts associated with surface water

Chemical spill Impacts associated with catalyst spill

Cooling/Blowdown 13 Blowdown Pond Impacts associated with unlined blowdown pond

Plant Maintenance 14 Former sulphur pit Potential migration from the former sulphur pit

Former storage docks Potential impacts associated with former storage docks

BALZAC GAS PLANT


72

LSU LSU

Reference

Source Issue

Inlet Compression/

Sales

15 KSVR Compressors Faulty floor drains/hydrocarbon staining

Site ‘G’ Comp.

Building

Minor hydrocarbon staining/potential tank leakage

RDS Sales Gas Area Potential drips/leaks from chemicals stored at the pad

and associated with the drain

Diethanolamine

(DEA) coolers

Impacts associated with historical cleaning practices of

the bundles from the DEA coolers

Former tankage Potential drips/leaks from former oil sump and

separator sump

Condensate Storage

Area

16 Condensate Storage

Tanks

Drips/leaks from condensate storage tanks and spills in

general area

Bundle wash area Impacts associated with bundle washing

Sulphur Block/

Basepad

18 Sulphur Blocks –

East and West

Unlined sulphur blocks

Sulphur Soil Piles Stockpiles of sulphur-impacted soil

Sulphur Block carry-

over

Surface soil impacts

Sulphur Plant 19 Spills, leaks, tanks Impacts associated with tankage, drainage system, and

truck loading

Sulphur Pit Impacts associated with sulphur pit

Office/Control Room 20 Transformers/

Electrical Substation

Drips/leaks from Polychlorinated Biphenyls (PCB)-

containing equipment

Process Area 21 Treater Building Impacts associated with equipment and processes in

and north of Treater building

DEA Storage Area Impacts associated with equipment and processes in the

DEA storage area

Stabilizer Towers Impacts associated with equipment and processes in the

Stab towers area

Salt Bath Heaters Impacts associated with historical spills at the Salt bath

heaters

BALZAC GAS PLANT


73

LSU LSU

Reference

Source Issue

LPG Unit 22 Lean oil plume Lean oil plume

Sulphur Vat Pond 24 Sulphur Vat Pond Impacts associated with sediment and surface water in

pond

Sulphur Handling

Facility

25 Sulphur Handling

Facility

Impacts in the load out, sulphur pile, and former slating

facilities

Sulphur Handling

Facility

Surface soil impacts

Sulphur Handling

Facility

Impacts associated with facility buildings and former

sulphur pad area

Sterilants were identified as likely having been used on Site for vegetation control in the past.

Current vegetation control includes non-persistent herbicides.

Asbestos insulation and presence of naturally occurring radioactive material (NORMS) have also

previously been identified on the Site

8.2 Summary of COPCs A summary of identified COPCs in soil and groundwater identified in LSUs of the Site is

provided in Table 8 (below). Groundwater COPCs identified in the table are based on analytical

data from monitoring wells installed within a LSU. Some parameters have recorded

concentrations above guidelines in background locations and therefore elevated concentrations

within the Site may not necessarily be attributable to facility-related impacts. A detailed analysis

of background conditions is required to confirm and or disregard select COPCs.

Table 8. Contaminants of Potential Concern in Soil and Groundwater

LSU Description Petroleum Hydrocarbons

Free Phase Hydrocarbon

LiquidsPAHs VOCs Metals Glycols Amines Methanol Sulphur PCBs Debris Catalyst Salinity Indicators

/ Nitrogen


2 South Landfill S S W S S S W

3 2-2 Pits/ Treatment Area W W

4 Evaporation Pond S S W S W


6 North Landfill W W

7 Drilling Mud Sump

8 Boneyard/Field Maintenance S S W S S W

9 Flare & Formation Water Handling Area S W W S S W S W S W S S W

10 Riparian/Shoreline

11 Firewater Reservoir

12 Southeast Process Pond S S

13 Cooling/Blowdown S W S S W

14 Plant Maintenance S S S

15 Inlet Compression/Sales S W S W S S S W

16 Condensate Storage Area S S S S

17 LPG/Condensate Loadout S S W S S W

18 Sulphur Block/Basepad S W S S W

19 Sulphur Plant S S S S W

20 Office Control/Room S

21 Process Area S W W S W S W S S S W

22 LPG Unit S W W S W S W

23 Power Station

24 Sulphur Vat Pond W S W

25 Sulphur Handling Facility S S S S W S S WLSU = Liability Subunit S = Soil W = Groundwater PAHs = Polycyclic Aromatic Hydrocarbons VOCs = Volatile Organic Compounds

Notes: PCBs = Polychlorinated Biphenyls Salinity = pH, electrical conductance, major ions Indicators/Nitrogen = major ions, nitrate, nitrite, ammonia

Contaminants of Potential Concern

Robert McCallum

Text Box

6

BALZAC GAS PLANT


76

8.3 Soil Conditions

Soil conditions across the property are reasonably understood, with assessment activities having

taking place in most areas over the past ten years. Full delineation of identified soil

contamination has not been completed in most cases due to the presence of infrastructure, lack of

activity within the area, or areas that were deemed to be low risk in the past. With the exception

of the south landfill and the sulphur block/basepad, where delineation efforts have been

completed, and remedial volumes are reasonably understood.

Most point sources of soil contamination are understood across the property, with the exception

of the following locations, where assessment has not yet been completed or has been limited due

to the presence of existing infrastructure that prevented sampling:

Flare/Formation Water Handling Area: various impacts to soil (hydrocarbon, salinity,

alcohol, glycol, PAH, VOCs, amines and metals) at various selected locations. Detailed

assessment as to the extent of each of these contaminants has not been undertaken to date

due to congestion of infrastructure and underground utilities;

Flare/Formation Water Handling Area (unknown sump): soil excavation has been

completed in this area, but was limited along the eastern extent by the presence of

pipelines. Assessment was not feasible under the pipelines at the time of remediation;

Southeast Process Pond: a partial remediation was completed on the southeast process

pond in 2002, but assessment is still required to confirm and better understand salinity

impacts to soil and sediment;

Inlet Compression/Sales: soil impacts (hydrocarbon and boron) were not fully assessed

due to the presence of Building #3-#4 (KVSR);

Process Area: suspected hydrocarbon impacts at the DEA UST. The presence of the UST

has limited assessment to date;

Process Area: general remediation of soil impacts (arsenic, barium, boron, molybdedum,

and hydrocarbon) is not currently possible due to facility operations. The extent of these

soil impacts is not known; and,

Sulphur Handling Facility: sulphur impacted soils around current GXM2 building.

Building is limiting further assessment and delineation.

Numerous other areas across the property have identified soil contamination and delineation is

required to fully characterize the extents of the plume. This assessment work will be completed

in the coming years in order to finalize remedial planning for an appropriate end land use once

equipment and infrastructure has been removed. As this occurs, the remedial plan will be

revisited and revised as necessary.

Sulphur Base Pads

Still marketable sulphur remaining and Nexen is working on a marketing strategy to remove this

material through 2012-2014. This will allow Nexen to attempt to reduce remediation and

disposal options for this material during the remediation time frames.

BALZAC GAS PLANT


77

8.3.1 Contaminants of Potential Concern in Soil

Several soil, groundwater and surface water environmental investigations have been completed at

the Site. Soil, surface water and groundwater monitoring locations are shown on Figure 6. Based

on findings of the investigations, remedial activities have also been implemented during operation

of the Site. Significant environmental investigations and remedial work since 1989 has been

summarized.

The Plant has been subdivided into component areas and processes and were termed "Liability

Subunits" (LSUs). For the purpose of this report, the LSUs are used to associate areas of concern

(AOC) and COPC with locations of the Site.

A listing of the LSUs for the Site and a plot plan showing the physical location and size of each

LSU are provided in Tables 5, 8, 9, 10 and 11 and Figure 5, respectively. In addition, one non-

traditional LSU was used. This LSU was termed the "Entire Site" and was used for issues or

findings that applied to the Site as a whole (i.e. groundwater impacts underlying several LSUs) or

for concerns/activities that cannot readily be assigned to a specific component area or process.

This LSU is not depicted on the accompanying figures, as it is conceptual in nature.

Previously identified background locations are located in the southwest (LSU 1), southeast (LSU

5) and on the west end of McDonald Lake in areas believed to be undisturbed by Site activities.

Analytical data from these background locations were used in evaluation of COPCs associated

with the Site. Parameters that were identified as COPCs in soil include:

hydrocarbons;

polycyclic aromatic hydrocarbons (PAHs);

volatile organic compounds (VOCs);

metals;

glycols;

amines;

methanol;

salinity (pH, electrical conductivity [EC], major ions);

sulphur; and,

PCBs.

Soil data indicate background sodium adsorption ratios (SAR) in topsoil and subsoil are generally

in the unsuitable category. SAR concentrations reported across the Site are generally consistent

with background conditions, as such, SAR was excluded as a COPC for the Site. EC

concentrations in topsoil and subsoil background samples range from good to unsuitable category

ratings, the variance is likely due to varying concentrations of sulphate in the soil. Background

soil data is limited and, based on the variation observed, it is possible that background

concentrations of sulphate may be higher than currently reported. Therefore, EC concentrations

BALZAC GAS PLANT


78

across the Site, exceeding currently reported background concentrations may not necessarily be

attributable to historical activities, depending on the ions influencing the EC concentration.

Elevated EC concentrations in some areas of the Site may be attributable to naturally occurring

sulphate concentrations that were not captured in available background soil data. Further

background soil data of the area is required to confirm.

The Balzac Power Station (LSU 23) and 2-2 well site (LSU 3) have been included in subdivision

of the Site as they are functionally attached to the Site. However, the Balzac Power Station

operates under a separate license or approval from the BGP under AEPEA Approval # 136858-

00-00. The 2-2 well site also operates under a separate ERCB well licence # 0022533.

LSU Description AOC Source Issue COPC Type Above Tier 1 - 2010 Parkland/ Residential Above Background

Background (S06-1)

Entire Site 1 Deep cathodic wells

Potential cross-contamination due to improper abandonment Hydrocarbons, salts Potential

1 Southwest Quadrant (S96-19- Background)

2 South Landfill 2 Former landfill Impacts associated with former landfill

Hydrocarbons, salts, metals, debris, catalyst Proven

3 2-2 Pits/ Treatment Area Not Included in Assessment

4 Evaporation Pond 3 Evaporation pond

Impacts associated with surface water and sediments Salts, metals Contingent chloride, sulphate, Cobalt, lead, zinc

4 Land treatment area

Treatment of hydrocarbon and condensate-impacted soils Hydrocarbons Proven

5 Southeast Quadrant (95-1, S06-2 -Background)6 North Landfill7 Drilling Mud Sump

8 Boneyard/Field Maintenance 5 AST area Hydrocarbon impacts associated with bulk storage of fluids Hydrocarbons Proven Molybedum & Cobalt molybdenum, cobalt, Chloride, mdea

6 Spills/ leaks Impacts associated with spills and leaks

Hydrocarbons, salts, amines Potential

9 Flare & Formation Water Handling Area 7 Unknown pit area

Impacts associated with a former buried sump Hydrocarbons, salts Proven

8 Holding pond Impacts associated with sediments and surface water Salts, metals Proven

9 Pits and ponds Impacts associated with former burn pit, chemical pond and ditches

Hydrocarbons, waste oil, disposal water,

aminesProven

10

Collection pond, tanks, equipment, spills, leaks

Impacts associated with equipment, tankage, and plant processes in area

Hydrocarbons, salts (biocide) Proven

10.1 Sludge Impacts associated with sediments Hydrocarbons, metals, salts Potential

10.2 Pond Water Impacts associated with surface water

Hydrocarbons, metals, salts Proven

11 Chemical spill Impacts associated with catalyst spill Catalyst Proven

EC, Boron, BTEX, TEH, TPH, F1-F4, PAHs -

Fluoranthene, Fluorene, Naphthalene,

Phenanthrene, Pyrene

Chloride, Sulphate, Cadmium, Lead, Berylium, Molybedum, Cobalt. Verification sampling of metals

removal from Ponds was not completed several metals exceeded 95-7 Burn Pit, 95-9 Filter Cake Pond, 95-10

Chemical Pond). PAHs - Acenaphthene, benzo(e)pyrene, 2-methylnaphthalene, benzo(ghi)perylene,

benzon(a)anthracene, chrysene. VOC - 1,2,4-Trimethybenzene, 1,3,5-Trimethylbenzene.

Phase 1/ Liability Assesment Soils Tables - Based on SMP data and limited projects as noted

EC, Boron

Robert McCallum

Text Box

Table 9. Contaminants of Potential Concern (COPCs) in Soil



12 Southeast Process Pond EC, pH, Molybdenum chloride, sulphate, boron, cadmiuim, copper, lead

13 Cooling/Blowdown 12 Blowdown pond Impacts associated with unlined blowdown pond Salts, metals Potential Elemetal Sulphur,

molybdenum Total sulphur, chloride, chromium

14 Plant Maintenance 14 Former sulphur pit

Potential migration from the former sulphur pit

Waste oil, elemental sulphur Potential Elemetal Sulphur Total sulphur, molybdenum, TEH

15 Former storage docks

Potential impacts associated with former storage docks Hydrocarbons, metals Potential

15 Inlet Compression/Sales 16 KSVR Compressor

Faulty floor drains/ hydrocarbon staining Hydrocarbons, glycol Proven

17 Site G Building Minor hydrocarbon staining/ potential tank leakage Hydrocarbons Potential

18 RDS sales gas area

Potential drips/ leaks from chemicals stored at the pad and associated with

the drainHydrocarbons Proven

19 DEA coolersImpacts associated with historical cleaning practices of the bundles

from the DEA coolersAmine Potential

20 Former tankage Potential drips/ leaks from former oil sump and separator sump Hydrocarbons Potential

16 Condensate Storage Area 21 Condensate storage tanks

Drips/ leaks from condensate storage tanks and spills in general area

Hydrocarbons, condensate Proven

22 Bundle wash area

Impacts associated with bundle washing Salts, metals, amines Potential

17 LPG/Condensate Loadout EC, Benzene & Ethylbenzene

Sulphate, Sulphur Potential, xylenes, PAHS - not analyzed during excavation, inibitor tank removal included PAH

exceedanes of characterization but below DL for confirmatory

18 Sulphur Block/Basepad 23 Sulphur blocks – east and west Unlined sulphur blocks Elemental sulphur Proven EC, pH, elemental Sulphur,

Molybdenum, Sulphate, Total Sulphur,

24 Sulphur soil piles Stockpiles of sulphur-impacted soil Elemental sulphur Proven Boron S06-87, Selenium S06-93, Hydrocarbon detection

S06-95

25 Sulphur block carry-over Surface soil impacts Elemental sulphur Proven


EC, boron, molybdenum, BEX, F1-F2

chloride, sulphate, chromium,copper, lead, zinc, toluene, PHC F3, F4

EC, arsenic, boron, molybdenum, BTEX, PHC

F1-F3sulphate, chromium, nickel, zinc, thalium, PHC F4

Robert McCallum

Text Box



19 Sulphur Plant 13 Spills, leaks, tanks

Impacts associated with tankage, drainage system, and truck loading

Metals, elemental sulphur Proven

26 Sulphur pit Impacts associated with sulphur pit Elemental sulphur Potential

20 Office Control/Room 27Transformers/

electrical substation

Drips/ leaks from PCB-containing equipment PCBs Proven

21 Process Area 28 Treater buildingImpacts associated with equipment

and processes in and north of Treater building

Hydrocarbon, glycol, lube oil Proven

29 DEA storage area

Impacts associated with equipment and processes in the DEA storage

areaAmines Proven

30 Stabilizer towers

Impacts associated with equipment and processes in the Stab towers

area

Hydrocarbons, salts, glycols Proven

31 Salt bath heaters

Impacts associated with historical spills at the Salt bath heaters Salts Potential

21 Process Area

Phase 1 Indicates Methonal Spilled to

ground in 2001 -150 Liters

22 LPG Unit 32 Lean oil plume Lean oil plume Hydrocarbons Proven

EC (adjacent to LPG Loadout), hexavalent chromium, selenium, thallium, BTEX, F1

Sulphate, boron

23 Power Station Not Included in Assessment

24 Sulphur Vat Pond 33 Sulphur vat pond

Impacts associated with sediment and surface water in pond Sulphate, salts Potential EC Sulphate, Total Sulphur, Xylenes

25 Sulphur Handling Facility 34Sulphur Handling Facility

Impacts in the load out, sulphur pile, and former slating facilities

Hydrocarbons, elemental sulphur Proven

35Sulphur Handling Facility

Surface soil impacts Elemental sulphur Proven

36Sulphur Handling Facility

Impacts associated with facility buildings and former sulphur pad

areaElemental sulphur Proven


lead, mercury, chromium, TEH, F3, F4

EC, pH, elemental Sulphur, PAHs (Fluorene,

Naphthalene, Phenanthrene, Pyrene), Chromium, PHC F2, F3

Sulphate, Total Sulphur, Chromium, PAHs (2-Methylnaphthalene, benzo(b&j)fluoranthene, chrysene),

Arsenic, Copper, Vanadium, Zinc, Molybdenum & Barium, Tetrachlorethene, Ethylbenzene, Xylenes, F1, Boron

excavated

EC, Elemental Sulphur, mercury, molybdenum,

thalium, selenum,

Total Sulphur, sulphate, boron, chromium, copper, lead, zinc, F1, F2

Boron, molybdenum, BTEX, DEA, MDEA

Robert McCallum

Text Box


Table 10. Summary of COPCs in Soils

Soils COPC BTEX, F1-F4 PAHs VOCs Metals Glycols Amines Salinity Sulphur PCBs Debris CatalystLSU Description

Background Entire Site

1 Southwest Quadrant 2 South Landfill X X X X X3 2-2 Pits/ Treatment Area4 Evaporation Pond X X X5 Southeast Quadrant 6 North Landfill7 Drilling Mud Sump8 Boneyard/Field Maintenance X X X X9 Flare & Formation Water Handling Area X X X X X X X10 Riparian/Shoreline11 Firewater Reservoir12 Southeast Process Pond X X13 Cooling/Blowdown X X X14 Plant Maintenance X X X15 Inlet Compression/Sales X X X X16 Condensate Storage Area X X X X17 LPG/Condensate Loadout X X X X18 Sulphur Block/Basepad X X X19 Sulphur Plant X X X X20 Office Control/Room X21 Process Area X X X X X22 LPG Unit X X X23 Power Station No Assessment24 Sulphur Vat Pond X25 Sulphur Handling Facility X X X X X X

Salinty - includes EC, pH, chloride, sulphate

BALZAC GAS PLANT


81

8.4 Groundwater Conditions

UMA conducted a hydrogeological assessment in 1989: installing the initial 11 groundwater

wells. Piteau Engineering (Komex) took over the management of the groundwater monitoring

network in 1992. The groundwater monitoring program has evolved from 1989 to the current

program (2011) with slight analytical modifications taking place over the last 22 years with

approval from Alberta Environment.

Impacts to groundwater have also been assessed over the past ten years, with 68 piezometers

across the property: 48 completed in the weathered till horizon (A-series); 9 at the till/bedrock

contact (B-series); and 11 in the bedrock strata (C-series). The most recent sampling event was

completed in 2011, with groundwater samples (67), culvert samples (3) and surface water bodies

samples (12) collected and analysed.

8.4.1 COPCs in Groundwater

Previously identified groundwater monitoring locations in the southeast (LSU 5) and on the west

end of McDonald Lake are believed to represent background quality for the Site on the basis they

are located up-gradient. Background locations have been identified in the weathered till horizon

(A-series) and bedrock (C-series). Background concentrations for a number of parameters exceed

their respective AENV Tier 1 guidelines (AENV 2010a), indicating naturally elevated

concentrations. Groundwater parameters exceeding generic guidelines were only considered

COPCs if concentrations were also generally exceeded reported background concentrations.

Parameters with no guidelines were considered COPCs if concentrations generally exceeded

background concentrations. Parameters that were identified as COPCs in groundwater include:

hydrocarbons;

VOCs;

metals;

glycols;

amines;

indicators (major ions); and

nitrogen parameters.

A number of metals in particular aluminum, antimony, cadmium, chromium, lead, selenium,

silver, thallium, tin, titanium and zinc record concentrations that are generally consistent with

background concentrations and therefore are not considered to be COPCs; however, a more

detailed statistical analysis of background is required to confirm this conclusion, such a study

may also identify other metals and indicator parameters that should not be considered COPCs

based on their background concentrations and associations with other parameters. Concentrations

of nitrate and sulphate (included as nitrogen parameters and indicators, respectively) vary

considerably in background locations and sometimes exceed guidelines. Therefore, it is possible

that elevated concentrations of sulphate and nitrate at the Site may not necessarily represent

facility-related impact.

Table 11. Detailed Summary of COPCs in Groundwater by LSU

MW GW ReportWell Associated with

LSU Description AOC Source Issue COPC Type

Background

Entire Site 1 Deep cathodic wellsPotential cross-contamination due to improper abandonment

Hydrocarbons, salts Potential



Hydrocarbons, salts, metals, debris, catalyst Proven 92-1A, MW-9A/B, 94-17C Buried Landfill Cells

3 2-2 Pits/ Treatment Area Not Included in Assessment 92-2A, 92-3A/B, MW-4A MW-4A - Evaporation Pond

4 Evaporation Pond 3 Evaporation pondImpacts associated

with surface water and sediments

Salts, metals Contingent 92-5A, MW-3A

5 Southeast Quadrant MW11A, 06-44A & 94-19C (Background locations)

6 North Landfill 04-42A

7 Drilling Mud Sump 92-14A

8 Boneyard/Field Maintenance 5 AST areaHydrocarbon impacts associated with bulk

storage of fluidsHydrocarbons Proven 92-4A

Phase 1/ Liability Assesment

93-15A/C, 93-16A/C, 94-19C, MW-11A, 06-43A, 06-

44A







9 Flare & Formation Water Hand 7 Unknown pit areaImpacts associated with a former buried

sumpHydrocarbons, salts Proven

92-6A, 92-7A, 92-8A/B, 99-30A/C, 99-31A, 99-32A, 01-35A, 03-36A, 03-37A, 03-38A, 03-39A/B, 03-

40A, 03-41A, 06-45A, 06-46A, MW-5A, 98-8C

92-7A - Burn Pit, 92-6A & 06-46A - Chemical Pond, MW-5A -

Filter Cake Pond, 06-45A - Holding Pond

10 Riparian/Shoreline11 Firewater Reservoir12 Southeast Process Pond

13 Cooling/Blowdown 12 Blowdown pondImpacts associated

with unlined blowdown pond

Salts, metals Potential 96-22A, Process Area

14 Plant Maintenance 14 Former sulphur pitPotential migration

from the former sulphur pit

Waste oil, elemental sulphur Potential

15 Inlet Compression/Sales 16 KSVR Compressor Faulty floor drains/ hydrocarbon staining Hydrocarbons, glycol Proven 92-9A, 98-25A/B , 06-47A Process Area

20 Former tankagePotential drips/ leaks from former oil sump and separator sump

Hydrocarbons Potential


Drips/ leaks from condensate storage tanks and spills in

general area


22 Bundle wash area Impacts associated with bundle washing Salts, metals, amines Potential





17 LPG/Condensate Loadout 92-12A/B, 98-23A/B 92-12 - Sulphur Block, 98-23 - Process Area

18 Sulphur Block/Basepad 23 Sulphur blocks – east and west Unlined sulphur blocks Elemental sulphur Proven 92-26A, MW-1A, MW-8A,

MW-10A, 94-18C, 98-26C


Impacts associated with tankage, drainage

system, and truck loading

Metals, elemental sulphur Proven 92-11A/B Process Area

20 Office Control/Room 27 Transformers/ electrical substation


21 Process Area 28 Treater building

Impacts associated with equipment and

processes in and north of Treater building

Hydrocarbon, glycol, lube oil Proven 01-34A, 06-48A, 06-49A,

Stab Culvert 1/2 06-48A - LPG Recovery

22 LPG Unit 32 Lean oil plume Lean oil plume Hydrocarbons Proven 98-24A/B/C, LPG Surge Culvert MW-1A - Sulphur Block

23 Power Station Not Included in Assessment

24 Sulphur Vat Pond 33 Sulphur vat pondImpacts associated with sediment and

surface water in pondSulphate, salts Potential 92-13A

25 Sulphur Handling Facility 34 Sulphur Handling Facility

Impacts in the load out, sulphur pile, and

former slating facilities

Hydrocarbons, elemental sulphur Proven 01-33A Sulphur Block

Notes PAH analysis not completed.Metals - compared results to background 95th percentile - considered above Tier 1 Guideline of background if at least two samples exceeded guideline or background (included manganese, iron)Indicators/Nitrogen - exceeding background - generally above the highest background concentration (chloride, sodium,sulphate, TDS, nitrite, nitrate, ammonia)Organics - exceeding background - above detection limit


LSU Description A unit B unit C unit A unit B unit C unit

Background

Entire Site


2 South LandfillCl, SO4, Fe, Mn, TDS, Na, Fluoride, NO2, Al, Cd, Cr, Cu, Se, U, Zn

SO4, TDS, Fluoride, Na, Mn, NH3 (only 1994

measurement), As, Cd, Cr, Cu, Se, Zn

pH (high), TDS, Na, Fluoride, NH3 (Only

2001) As, Cd

Cl, SO4, Fe, Mn, TDS, Na, No2, Al, Cr, Cu, Mo, Ni

Cl, SO4,TDS, Na, As, Cr, Cu, Ni, Zn Fluoride, As

3 2-2 Pits/ Treatment AreaCl, SO4,Mn, TDS, Na,

NH3 (only 1994) Fluoride, Phenols

SO4, TDS, Fluoride, Na, Mn Cl, SO4, Mn, TDS, Na, SO4, TDS, Na, Mn

4 Evaporation PondCl, SO4,Mn, TDS, Na,

Fluoride, NH3 (only 1994) Cr, U,

Cl, Mn, Cr, B, Mo,


6 North LandfillCl, SO4,Fe, Mn, TDS,

Na, As, Cd, Cr, Cu, Se, U, Zn

Cl, SO4, Fe, Mn, TDS, Na, As, Co, Cu, U, Zn

7 Drilling Mud Sump SO4, Mn, TDS, Na, Fluoride


S04, Fe, Mn,TDS, Na, Fluoride, NO2/NO3, NH3 9only 1994) Sb, As, Cd,

Cr, Cu, Se, U, Zn

Cl, Fe, Na, Fluoride, NO2/NO3, Sb, As, Cd, Cu,

Mo, Se, U

Groundwater Tables Groundwater Tables - Based on GW Monitoring ReportsAbove Tier 1 - 2010 Parkland/ Residential Above Background

SO4, TDS, Fluoride, Na, NO3, NH3 (only 1994), Mn, Cd, Cr, Cu, Se, U,

Zn

No selected well assume same as A unit

SO4, TDS, Fluoride, Na, NO3, Mn, Cd, Se




One Benzene detection in 2006 at DL

9 Flare & Formation Water Hand

Cl, SO4, Fe, Mn, TDS, Na, Fluoride, NO2, NO3,

NH3 (wells & pond & burn pit culvert), BTEX,

F1, F2, MEA, DEA, Phenols, VOCs - (1,2 -

Dichoroethane, Tetrachloroethene), Al - (08 measurements only),

Sb, As, B, Ba, Cd, Cr, Cu, Ni, Se, Ag, U, Zn

pH (high), Cl, SO4, Fe, Mn, TDS, Na, Fluoride, NO2, BTEX, F1, DEA, Sb, As, Cd, Cr, Cu, Se,

Zn

Cl, S04, Fe, Mn, TDS, Na, DEA, As, Cu, Se,

Zn

Cl, Fe, Mn, NO2, NH3 (pond & burn pit culvert), BTEX, F1, F2, VOCs - (Chloromethane, 1-1 Dichloroethane, 1,2 -

Dichoroethane, , 1,2,4 Trimethylbenzene, 1,3,5-

Trimethylbenzene), MDEA, Sb, As, B, Ba, Cr, Cu, Mo,

Ni, Se, U

Cl, SO4, Fe, TDS, Na, NO2, Sb, As, Cu, Se,

BTEX, F1

Cl, S04, Fe, Mn, TDS, Na, Benzene, As, Cu, Zn

10 Riparian/Shoreline11 Firewater Reservoir12 Southeast Process Pond

13 Cooling/Blowdown SO4, Mn, TDS, Na, Cd, Ni, U Cl, SO4, TDS, Na, Ni, U


15 Inlet Compression/Sales Cl, SO4, Fe, Mn, TDS, Na SO4, Mn, TDS, Na, Cl, Fe Cl, Mn, TDS

BTEX, F2, As, Cd, Se, Ni, Phenols, NH3

F1, As, B, Ni, Zn, BTEX, F1, F2





17 LPG/Condensate LoadoutSO4, Fe, Mn, TDS, Na, Fluoride, As, Cd, Cr, Cu,

Se, Ag, Zn

SO4, Fe, Mn, TDS, Na, Fluoride, As, Cd, Cu, Se,

Zn

Cl, SO4, Fe, Mn, TDS, As, Cu, Ag, Zn

SO4, Fe, Mn, TDS, Na, Fluoride, As, Zn

18 Sulphur Block/BasepadSO4, Fe, Mn, TDS, Na,

Fluoride, NO3, Cd, Se, U, Cr, Ag, U, Zn

SO4, Mn, TDS, Fluoride, Na, NO2/NO3, Cl, SO4, Fe, Ag, U Cl, S04, Mn TDS, Na,

19 Sulphur Plant Cl, SO4, TDS, Na, Fluoride, NO2/NO3

SO4, Mn, TDS, Na, Fluoride, Cl, NO2/ NO3 Cl,


21 Process Area

ph (low), SO4, Fe, Mn, TDS, Na, NO2, BTEX,

F1, F2, Glycols (ethylene, diethylene), Al, Sb, As, Ba, Cd, Cu, Ni, Se, Zn

(Stab culvert)

Cl, Fe, Mn, NO2, Al, Sb, As, Ba, Ni, Mo, Zn (Stab culvert), BTEX, F1, F2,

Glycols

22 LPG UnitSO4, Fe, Mn, TDS, Na, Fluoride, NH3 (surge

culvert), BTEX, F1, F2,

TDS (only Cl and TDS measured), BTEX, F1, F2

TDS, SO4, Fe, Mn, Na, BTEX, F1, F2 Cl, Fe, BTEX, F1, F2 Cl, TDS Cl, TDS, SO4, Fe, Mn,

Na, BTEX, F1, F2

23 Power Station

24 Sulphur Vat Pond SO4, Mn, TDS, Na, Fluoride Cl, Mn

25 Sulphur Handling Facility SO4, Fe, Mn, TDS, Na, Al, Cd, Cr, Cu, Se, U , Zn Cl, Fe, Al, B

Notes PAH analysis not completed.Metals - compared results to background 95th percentile - considered above Tier 1 Guideline of background if at least two samples exceeded guideline or background (included manganese, iron)Indicators/Nitrogen - exceeding background - generally above the highest background concentration (chloride, sodium,sulphate, TDS, nitrite, nitrate, ammonia)Organics - exceeding background - above detection limit

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Chloride in groundwater has been identified in the Flare Area, Former Process Ponds and the

Evaporation Pond. The most groundwater report (2010) shows that chloride is present above

AENV Tier I guidelines in the upper water-bearing zone across the Evaporation Pond area, and

the Flare and Formation Water Handling Area. Elevated chloride concentrations (but not above

Tier I guidelines) are also present across the majority of the property in the upper water-bearing

zone.

In the lower water-bearing zone, the chloride plume is more limited to the Flare and Formation

Water Handling Area (above AENV Tier I guidelines). There is also elevated concentrations of

chloride present across the Process Area and the Sulphur Plant. Finally, in the bedrock zone,

there is a smaller plume of chloride that exceeds the AENV Tier I guidelines, located in the Flare

and Formation Water Handling Area (near McDonald Lake). A few additional isolated areas

across the property also show elevated chloride levels in groundwater in bedrock.

Based on assessment to date, chloride appears to have the greatest potential for reaching

McDonald Lake. Considering the age of the BGP and the estimated groundwater flow velocities

in the weathered till (~2.2m/year), total potential lateral migration of this inorganic constituent is

approximately 100 metres, assuming an immediate release following plant commissioning. It is

possible that chloride from the Flare Area has approached the shoreline of McDonald Lake. No

assessment of McDonald Lake has been completed to date to confirm whether chloride impacted

groundwater is discharging into the Lake.

In the upper water-bearing zone, there were more than ten (10) occurrences of elevated

concentrations of benzene above the Tier I guidelines during the 2010 groundwater monitoring

event. No specific plume boundaries have been defined at this time. In the lower water-bearing

zone, there were only a few locations with elevated concentrations of benzene reported, and only

one location was reported in the bedrock zone.

There is a plume of hydrocarbons in the LPG Recovery Area that has shown in the past (2008) to

have measurable thickness of free phase hydrocarbons. There is an operational remediation

system in place in this area to remove free phased product, when identified. Elevated

concentrations of dissolved phase hydrocarbons and benzene and ethylbenzene are also present in

this area.

Table 12. COPCs in Groundwater by LSU

GW COPCs BTEX, F1-F2 VOCs Phenols Metals Glycols Amines Indicators NitrogenLSU Description

Background (S06-1)Entire Site

1 Southwest Quadrant 2 South Landfill X X X3 2-2 Pits/ Treatment Area X X X4 Evaporation Pond X X X5 Southeast Quadrant (Background)6 North Landfill X X7 Drilling Mud Sump X8 Boneyard/Field Maintenance X X X9 Flare & Formation Water Handling Area X X X X X X X10 Riparian/Shoreline11 Firewater Reservoir12 Southeast Process Pond13 Cooling/Blowdown X X14 Plant Maintenance15 Inlet Compression/Sales X X X X16 Condensate Storage Area17 LPG/Condensate Loadout X X18 Sulphur Block/Basepad X X19 Sulphur Plant X X20 Office Control/Room21 Process Area X X X X X22 LPG Unit X X X X23 Power Station24 Sulphur Vat Pond X X25 Sulphur Handling Facility X X

Indicators/Nitrogen - exceeding background - generally above the highest background concentration (chloride, sodium,sulphate, TDS, nitrite, nitrate, ammonia)Glycols - MEA, DEA, MDEA,Metals - includes Iron, Manganese, ....Phenols - likely from organic decay - excluded

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8.5 Surface Water Conditions

Little topographic gradient can be seen across the Site, although the Process area in the northwest

is slightly elevated with respect to the rest of the Site. Surface water often ponds on Site and is

controlled by mechanical pumping.

Currently there are seven open water surface collection areas on the BGP:

Open Drain Collection Ponds

Fire Water Reservoir

North Blowdown Pond

South Blowdown Pond

Sulphur Block Runoff Pond

Sulphur Vat Treated Water Pond

McDonald Lake.

The most important surface drainage feature near the Site is McDonald Lake located on the

western edge of the Process area. No streams enter or leave the lake, and therefore, it is assumed

that the lake is groundwater fed. Overland drainage from adjacent agricultural and pastureland is

also known to accumulate in this depression. Surface runoff occurs mainly during the spring

snowmelt, or immediately following periods of heavy precipitation. Water levels within

MacDonald Lake vary, at the time of writing, the water levels in MacDonald Lake are unusually

high and have partially flooded some areas in the west of the Site.

Table 13. COPC in Surface Water Bodies

Surface Water Pond Groundwater TablesSurface Water Surface Water Guidelines


Background McDonald Lake

Entire Site 1 Deep cathodic wells

Potential cross-contamination due to improper abandonment

Hydrocarbons, salts Potential



Hydrocarbons, salts, metals, debris, catalyst Proven

3 2-2 Pits/ Treatment Area Not Included in Assessment

4 Evaporation Pond 3 Evaporation pond

Impacts associated with surface water and

sedimentsSalts, metals Contingent

5 Southeast Quadrant 6 North Landfill7 Drilling Mud Sump

8 Boneyard/Field Maintenance 5 AST areaHydrocarbon impacts associated with bulk

storage of fluidsHydrocarbons Proven



pH (high), chloride, SO4, Fe, Mn, TDS, NA, Ammonia, Al, Ar, Cd, Cu, Se, Zn






9 Flare & Formation Water Ha 7 Unknown pit area

Impacts associated with a former buried

sumpHydrocarbons, salts Proven Open Drain Collection

Ponds Chloride, SO4, TDS, NH3, BTEX, F1

10 Riparian/Shoreline11 Firewater Reservoir Fire Water Reservoir12 Southeast Process Pond

13 Cooling/Blowdown 12 Blowdown pondImpacts associated

with unlined blowdown pond

Salts, metals Potential North Blowdown Pond SO4, TDS, NH3

South Blowdown Pond SO4, TDS, NH3

14 Plant Maintenance 14 Former sulphur pit

Potential migration from the former

sulphur pit

Waste oil, elemental sulphur Potential

15 Inlet Compression/Sales 16 KSVR Compressor

Faulty floor drains/ hydrocarbon staining Hydrocarbons, glycol Proven

20 Former tankagePotential drips/ leaks from former oil sump and separator sump

Hydrocarbons Potential


Drips/ leaks from condensate storage tanks and spills in

general area


22 Bundle wash area

Impacts associated with bundle washing Salts, metals, amines Potential

17 LPG/Condensate Loadout Sulphur Block Runoff Pond pH (low), sulphate, TDS, NH3

18 Sulphur Block/Basepad 23 Sulphur blocks – east and west Unlined sulphur blocks Elemental sulphur Proven


Impacts associated with tankage, drainage

system, and truck loading

Metals, elemental sulphur Proven





20 Office Control/Room 27Transformers/

electrical substation


21 Process Area 28 Treater building

Impacts associated with equipment and

processes in and north of Treater building

Hydrocarbon, glycol, lube oil Proven

22 LPG Unit 32 Lean oil plume Lean oil plume Hydrocarbons Proven23 Power Station Not Included in Assessment

24 Sulphur Vat Pond 33 Sulphur vat pond

Impacts associated with sediment and

surface water in pondSulphate, salts Potential Sulphur Vat Treated

Water Pond SO4, TDS, NH3

25 Sulphur Handling Facility 34 Sulphur Handling Facility

Impacts in the load out, sulphur pile, and

former slating facilities

Hydrocarbons, elemental sulphur Proven

Notes Oragnics - exceeding background - above detection limit

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8.5.1 McDonald Lake

McDonald Lake is considered a stagnant water body, and as such may tend to concentrate

inorganic groundwater contaminants through evaporation. Currently McDonald Lake supports a

limited aquatic community of saline-adapted plants. No fish species are known to occupy the

lake.

A significant decrease in routine indicator parameters (EC, chloride, sulphate, sodium and TDS)

was observed at McDonald Lake in October 2005 following significant precipitation that June.

Since then, levels have generally stabilized.

The measured chloride concentrations in spring and fall 2009 were 310 and 450 mg/L,

respectively. The laboratory-reported pH in McDonald Lake was reported within surface water

guidelines (8.67, spring and 8.33, fall). Chloride, sulphate, iron (fall only), manganese (fall only),

TDS and sodium exceeded the respective surface water guidelines in 2009.

All hydrocarbon parameters remained below laboratory MDLs in 2009. In October 2009,

dissolved arsenic and cadmium concentrations exceeded the applicable surface water guidelines.

Dissolved antimony, chromium, lead, selenium, silver and zinc were reported below laboratory

MDLs; however, the MDLs exceeded guidelines. All other metal parameters were below surface

water guidelines.

Amines have been analyzed at McDonald Lake since 2003. Historically, MEA, DEA and MDEA

were reported below laboratory MDLs. In November 2008, a single instance detectable MEA

concentration was reported. The lake was re-sampled on December 11, 2008, and again in

October 2009. Results reported values below laboratory MDLs; however, detection limits were

raised (<10 mg/L in 2008 and <5 mg/L in 2009).

Elevated chloride, TDS, sulphate and sodium concentrations have been historically reported at

McDonald Lake. Historic dissolved arsenic concentrations exceeded the applicable surface water

guidelines. Metals concentrations were generally reported within historical ranges. The

Government of Alberta, Agriculture & Rural Development indicates that “groundwater in gray-

coloured clay-rich aquitards with low oxygen levels in southern Alberta sometimes contain

naturally-occurring arsenic at levels that exceed the drinking-water guideline.”

(http://www1.agric.gov.ab.ca/$department/deptdocs.nsf/all/irr4452, November 2011).

McDonald Lake, which is a saline slough, has elevated salt concentrations in the surface water

and sediment, likely due to the natural evaporative process. Dissolved salts in the waters of

McDonald Lake are a sodium sulphate type, which is typical for an evaporative slough. Organic

compounds are assumed to naturally degrade over time.

http://www1.agric.gov.ab.ca/$department/deptdocs.nsf/all/irr4452

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8.6 Secondary Sources of Contamination Assessment and remediation work indicate that activities at the Site have impacted soil,

groundwater and potentially soil vapour. COPCs at the Site were identified on the basis of the

following:

comparison of previous analytical data, from environmental assessment and

remediation work, with generic guidelines;

comparison of analytical data with previously established background conditions;

and,

anecdotal evidence or professional judgement with similar facilities and/or

operations.

8.6.1 Free Phase Hydrocarbon Liquids

A plume of free phase hydrocarbon product was detected during the 1998 soil and groundwater

investigation as a light non-aqueous phase liquid (LNAPL: Komex 1998b), immediately

down-gradient of the LPG Recovery area (LSU 22). Subsequent investigation programs were

undertaken to delineate the extent of free product in the LPG Recovery area and remediate the

impact.

A three phased remedial approach for free phase hydrocarbon containment and plume mass

recovery was implemented. The remediation approach included the following:

Phase 1: installation of a product recovery trench;

Phase 2: installation of a free phase hydrocarbon extraction and dissolved phase

hydrocarbon treatment system using trench and gate technology; and

Phase 3: installation of vertical recovery wells for free phase hydrocarbon extraction

using an in situ skimmer pump.

To date, approximately 12 m

3 of free phase hydrocarbon liquids have been removed from the

LPG recovery area. As of fall 2010 hydrocarbon liquids continue to be measured in recovery

wells and monitoring well 98-24A installed within the till groundwater unit of the LPG area.

Measurable free phase hydrocarbon liquids have been noted in monitoring wells installed within

the till/bedrock (98-24B: 1998-1999) and bedrock (98-24C:1998, 1999, 2002 and 2007) of the

LPG plume. Field observations (sheen and hydrocarbon odour) and elevated hydrocarbon

groundwater concentrations reported at 98-24B and 98-24C indicate free phase hydrocarbon

liquids may have been present during monitoring events where measurable product was not

reported. Free phase hydrocarbon liquids have also been noted in the surge culvert of the LPG

area.

North of the LPG Unit, free phase hydrocarbon liquids have been measured in the Process area

(LSU 21) at 06-48A (2006-2010). In the Flare and Formation Water Handling area (LSU 9), free

phase hydrocarbon liquids were measured at 99-32A in 2000. Field observations (sheen and

hydrocarbon odour) and elevated hydrocarbon groundwater concentrations reported in 99-32A

BALZAC GAS PLANT


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and other select wells in the Flare and Formation Water Handling area (2000–2010), Process area

(2006-2010) and Inlet Compression/Sales (LSU 15: 2006-2010) may also indicate the presence of

free phase hydrocarbon liquids in the vicinity of the wells.

8.7 Data Gaps A review of historical information for the Site has identified gaps in available data for the Site.

8.7.1 Background Data

Limited background soil data for the Site is available. Four sampling locations located in the

southwest (LSU 1), southeast (LSU 5) and on the west end of McDonald Lake have been

identified as background locations. Additional analytical data of the surrounding area and Site is

necessary to evaluate natural salinity and inorganic parameters.

Groundwater monitoring locations in the southeast (LSU 5) of the Site and on the west end of

McDonald Lake are believed to represent background quality for the Site on the basis they are

located up-gradient. Several indicator and metal parameters have been historically reported above

Tier 1 guidelines (AENV 2010a) in background monitoring locations and likely indicate these

parameters are naturally elevated in the area of the Site. Due to variations in background

concentrations, select parameters at the Site exceeding available background data may not

necessarily represent an impact associated with Site activities. Further collection and statistical

analysis of background data is required to confirm natural groundwater quality.

8.7.2 Bedrock Flow Mechanism

Limited information on fracture flow mechanisms within bedrock beneath the Site is available.

The upper surface, till/bedrock contact, is likely highly weathered and is likely to act as an

equivalent porous media. Deeper bedrock is likely dominated by fracture flow.

Impacts have been identified within the bedrock zone of the Site, including free phase

hydrocarbon product in the bedrock of the LPG Unit (LSU 22); however, the relationship

between the free product and deeper fracture flow has not been established. Further information

regarding fracture density, orientation, and flow rates are required for a site-specific risk

assessment to determine if fracture flow is a dominant migration pathway at the Site.

8.7.3 Geographical and Temporal Data Coverage

Overall there is reasonably good areal coverage of intrusive and or excavation data across the

Site. However, once remedial objectives for the Site have been established, further investigation

may be required of previous remedial excavations and/or delineation of impacts. Areas with

limited data or requiring further evaluation include the following:

Previously excavated areas. Excavation limits and treatment of excavated soil were

typically guided by assessment criteria current at the time the excavation was

completed as a source removal program. Since completion of an excavation, clean

backfilled soil may have been impacted by broader scale contamination in the soil

and groundwater surrounding the excavated area. Excavation soil quality, including

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backfill should be verified to confirm if the soils meet remedial objectives for the

Site; and,

Soil underlying process buildings. Previous intrusive investigations have not

included assessment beneath process buildings.

Limited or no analytical data is available for some parameters identified as COPCs at the Site.

These parameters include:

PAHs in groundwater. Previous detections of PAH parameters in soil have been

identified in LSUs 9, 17 and 25. PAHs have not been analyzed in groundwater

across the Site;

Methanol is a process chemical used at the Site and a methanol spill in the Process

area was previously identified in the Phase 1 ESA. Limited analytical data for

methanol in soil is available for the Site;

NORM Surveys have been completed in 2011 at the Balzac Gas Plant. A typical

source of NORM in the oil and gas industry is radon gas decay products, including

Lead-210 (NORMCAM 2006). (Naturally occurring radionuclides (``NORMs``)

are present at varying concentrations in the Earth’s crust and can be concentrated

and enhanced by processes associated with the recovery of oil and gas.

Radioactive materials such as Uranium and Thorium were incorporated in the

Earth’s crust when it was formed; these normally exist at trace (parts per million –

ppm) concentrations in rock formations. Decay of these unstable radioactive

elements produces other radionuclides that, under certain conditions (dependent

upon pressure, temperature, acidity etc) in the subsurface environment are mobile

and can be transported from the reservoir to the surface with the oil & gas

products being recovered. During the production process, NORM flows with the

oil, gas and water mixture and accumulates in scale, sludge and scrapings. It can

also form a thin film on the interior surfaces of gas processing equipment and

vessels. The level of NORM accumulation can vary substantially from one facility

to another depending on geological formation, operational and other factors. To

determine whether or not a facility has NORM contamination, NORM survey,

sampling and analysis needs to be conducted There are various national and

international regulations and guidelines on radiation protection in general and

NORM in particular. These are not specific to the oil & gas industry and there are

variations in the methods of control adopted.)

Historical surveys have been referenced and utilized to support the 2011 surveys.

2011 surveys where completed at various phases of the plant shutdown and

decommissioning stages. Surveys were initially executed in April and then again in

May, June, July, August and September. This method of survey allowed for the

identification of potential NORM in various operating conditions and confirmed

previous surveys as being accurate.

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o The initial 2011 survey was completed in April while the plant was still in

operation. This allowed the personnel to determine possible NORM

locations before any equipment or piping was opened and exposed to

atmosphere. Once this survey was completed areas that detected NORM

where opened with extreme care and caution. A third party company with

NORM expertise was present and did all NORM testing (NORMCAN – A

CCS Company). If NORM was detected the equipment/piping was

immediately closed, sealed and labeled. All testing was recorded and is

still maintained for future reference. Once all possible NORM

contaminated equipment and piping was tested it was re-tested to verify if

there were detections from the previous survey. This re-testing method was

executed monthly until the end of September. Any equipment or piping

that still detected NORM was sealed and labeled as NORM containing. If

piping was loose it was segregated, sealed and labeled. This piping was

located in a central location that has been isolated and clearly labeled as

NORM containing.

o Future NORM surveys will be executed prior to any exposure, handling or

movement of NORM containing materials. Routine checks on all stored

NORM-contaminated equipment will be undertaken to ensure that the

integrity of the protective measures is adequate. Detailed and verifiable

records will be maintained of all stored NORM contaminated equipment.

o Any NORM containing equipment that was sold was decontaminated prior

to the sale and prior to the removal from site. NORMCAN and CSC

completed the decontamination and all water was then taken to the

NORMCAN approved disposal site in Standard, Alberta. This equipment

included four (4) horizontal vessels or bullets used to store propane and

butane. There is currently an ongoing search for buyers that are willing to

purchase the four NORM contaminated propane bullets. If a buyer is

willing to accept the units in the declared state, the bullets would be

transferred from one contaminated propane process to another

contaminated propane process and therefore no attempt would be made to

decontaminate them. If a buyer for contaminated bullets cannot be found,

or if decontamination is attempted but unsuccessful, worse-case scenario is

that these contaminated units would have to be released to a landfill.

NORM surveying of the soil will be completed to confirm if further

analytical testing of soil is required. In some cases of NORMS remediation

involves the systematic removal of NORM contamination from the area in a

controlled manner, with the contaminated soil/material becoming part of the

NORM waste stream,

Sterilants were identified as likely used on Site in the past; however soil analytical

data for sterilants is not available.

Hydrocarbon product laboratory analysis. A hydrocarbon breakdown analysis of

the free product measured in the LPG Unit (LSU 22) was completed in 1998.

Additional analysis of the LNAPL should be conducted to evaluate how the

product has weathered since initial assessment in 1998.

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8.7.4 Survey Data

An orthographic aerial photo and survey of the Site has been completed and is used to establish

topographic features of the Site. The existing survey data will be compiled to support this and

further surveying may occur if deemed necessary.

8.7.5 McDonald Lake

Annual data of water levels within McDonald Lake is available; however additional data on

seasonal fluctuations of the lake may be obtained.

9 REMEDIAL OPTIONS

Once the decommissioning, dismantling, and removal of the majority of the infrastructure has

taken place across the property, more detailed delineation assessments will be initiated. The

general plan and criteria to be used for remediation of soils, groundwater, surface water, and

possibly sediment are described in this section.

There are four options available to Nexen for remediation of the BGP. Each of these options is

discussed in greater detail in the Tier I and Tier II Soil and Groundwater Remediation Guidelines

(AENV, December 2010). These options include:

1. Remediation (insitu or exsitu) of soil, groundwater, surface water, and sediment to

the AENV Tier I guidelines (or the CCME environmental quality guideline for

parameters not included in the AENV guidelines).

2. Remediation (insitu or exsitu) of soil, groundwater, surface water, and sediment to

AENV Tier II site specific guidelines which would be developed for the BGP site for

each COPC. Tier II site specific guidelines would be established through pathway

exclusion and/or parameter adjustment in consultation with AENV.

3. Completion of a Tier II Site Specific Risk Assessment (SSRA), possibly allowing for

soils, groundwater, surface water and/or sediment to remain in place. Remediation,

where necessary (insitu or exsitu), would be completed to the Tier II site specific

guidelines. This option will almost always require a monitoring plan until stable end

points are demonstrated.

4. Exposure Control and Long Term Risk Management (Human Health) and Ecological

Risk Assessment (Ecological Health and McDonald Lake).

Options 1 to 3 allow for full regulatory closure under the Alberta Environment Environmental

Site Assessment Program (Record of Site Condition). Regulatory closure would allow Nexen to

divest of the property in the future. Option 4 does not allow for regulatory closure. It is fully

protective of human and ecological health, with a management plan/exposure control plan in

place. This option would allow Nexen to redevelop and/or lease the property in the future.

BALZAC GAS PLANT


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9.1 Determination of End Land Use & Remediation Criteria

In order to determine the best final option for remediation at the Balzac Gas Plant, several steps

are required to be completed. These steps will allow for full understanding of the contaminant

picture across the property, in turn allowing a detailed analysis for each of the options outlined

above. This is a phased approach that CANNOT be completed until demolition is complete and

as each phase of demolition and testing occurs, the information will be used to support future and

final site remediation.

End land use is a key component in the larger process of decommissioning the BGP and is also a

key component in determining the appropriate route forward for remediation. End land use will,

in part, determine acceptable remedial options. However, what remedial options are practical,

cost effective, and reasonable will also have an impact on choices associated with end land use at

the property. In other words, end land use and remedial options need to be reviewed together in

order to find the correct balance and the best route forward for Nexen, the property, the

surrounding properties, and community. This process has begun at Nexen, but before it can be

fully completed, certain assessment and exploration steps are still required at the BGP.

End land use will be determined as a function of surrounding land use at the time the BGP is

going through the remediation and reclamation processes. Current land use plans provided in the

following Balzac East Area Structure Plan figure clearly demonstrate a surrounding land use

zoned, or to be zoned, as industrial. Therefore, at this time, end land use for the BGP is expected

to be industrial. End land use will be determined as a function of municipal development plans

for the area and the landowner(s).

The Balzac Power Station (BPS) will remain active during decommissioning of the BGP and

remediation and reclamation of the larger property parcel. There is no current plan to

decommission the BPS. There is associated infrastructure (pipelines carrying gas, firewater,

water disposal and water supply; above ground electrical transmission lines – see figure on

following pages) running to and from the BPS that travel above grade across the larger property

that will remain in place after decommissioning of the Gas Plant. (FIGURE 6) This

infrastructure has been considered during the development of the remedial plan, as impacted soils

and groundwater are known to be present under or around this infrastructure. Some excavation

might be possible and completed as part of remedial objectives, but the majority of the impacts

located under this infrastructure is expected to be managed in place through risk assessment and

exposure control methods.

Given the large size of the property, and the impacts that have been already identified across the

property, it is very likely that remediation to Tier I guideline criteria will not be the most cost

effective and practical choice for Nexen.

MCDONALD

LAKE

226-29-4

PipelineR/W (031

0629)



JK)

Pipeline R/W(791

0816)

Gas Pipeline R/W(851

0253)



Oil PipelineR/W (754

JK)


PipelineR/W

(1547 JK)


PipelineR/W (101

2606)





CanadianPacific Railway

(871 JK)

Pipeline R/W(081

5893)

PipelineR/W (081

3328)


0816)

PipelineR/W

(500 JK)

Pipeline R/W(500JK)

Gas PipelineR/W

Gas PipelineR/W

Admin Building

Power Station

FiberOptic Pipeline

(10m R/W)

FiberOptic Pipeline (10m

R/W)

Building

Pipeline R/W

PowerlineR/W

PowerlineR/W (9012327

UR/W)

Pipeline R/W

Well Site 2-2

PipelineR/W (931

2570)

0 100 200 30050Meters

±

LegendDisposition - Operator

Atco


City of Calgary

Fortis

Nexen

Pembina

Telus

services

Nexen Inc.


BalzacFigure 3



Date: November 24, 2011Updated: February 6, 2012File No : CA13581.mxd

NAD 1983 UTM Zone 12NProjection: Transverse Mercator

Imagery provided by ValtusDate Collected: September 22, 2009VISTA Alberta UTM 12 0.3m 2009

Scale: 1:2,500

144th Avenue

2 W

ire O

/H P

ow

er L

ine

Twp. 26

Twp. 25

S.W.1/4 Sec.2-26-29-4

McDonald Lake

Cha in L ink

GATE

NEX

EN

MA

RKE

TIN

G R

/W P

LAN 031 0391

Gat e

N.E.1/4 Sec.2-26-29-4

TE L E M E T R Y C A B L E F R O M T C P L

Gat eGat e

Drain

age C

ourse

MW04-2

MW04-4

MW04-3

MW04-1

Win

d Fe

nce

Of fi ce & M CC

P.P.

L.P.

Sulp

hur

Win

d Fe

nce

Cul

vert

P.P. P.P.

Bu ild ing

En tra nce Se curit y Bu ild ing

WEST SU LPHU R BLOC K PAD

8" WA

STE

WA

TER

FR

OM

BP

S

NEXEN 8" H

DPE WASTE

WATER F

RO

M B

PS

EXPO

CR

ETE

FLARE AREA SEE DETAIL 'C' (AS-BUILT NOT MAINTAINED LAST REVISION MAR. 2010)

NEXEN SALES P/LCROSSING(FORMERLY AGTL)SEE DETAIL 'A'

JUNCTION 11SEE DWG.BLZ-H11-A-001-A

JUNCTION 2SEE DWG.BLZ-H02-A-001-A

FIRE WATER PONDSEE DETAIL 'B'

JUNCTION 1ASEE DETAIL 'F'

LPG AREASEE DETAIL 'D' (AS-BUILT NOT MAINTAINED LAST REVISION MAR. 2010)

JUNCTION 2ASEE DWG.BLZ-H02-A-001-A

JUNCTION 15ASEE DWG.BLZ-H15A-A-001-A

BALZAC POWER STATIONSEE DWG.BLZ-P200-A-011-A

BALZAC GAS PLANT SEE DRAWING CONTROL

Airdrie Modelers Aircraft Society

RANCHER'S BEEF FACILITY

CALGARY ENERGY CENTER (ENMAX)

NEXEN BALZAC COMPLEX ENTRANCE

LP F lareKO B ldg .

LPFW Fl ash Ta nk B ldg.

Fla re A re a Sw itchge ar Bu ild ing

Fla re Heater Treater B ld g.

Fla re Pond Pu m p B ldg.

Wash Ba y

CP Po st

CP Po st

CP Po st

CP Po st

CP Po st

2" F/G TO J11 & 2-2-26

2" GLYCOL (ABND)

8" S ELKTON S/G FROM J12

2" GLYCOL (ABND)

2" GLYCOL (ABND)3" S/G FROM 10-35-25 (ABND)2" GLYCOL (ABND)

2" F/G FR

OM

2-2-26 CU

LVERT

6" S/G (ABN

D)

2" F/G FR

OM

J1A

2" GLYC

OL (ABN

D)

NEXEN 22" SALES TO TCPL

2" F

/G R

ISE

R

C/W

VA

LVE

BLI

ND

GLYCOL JUMPOVER DETAILWITHIN WEST DITCHNOT TO SCALE

4" L

.P. X

FLD

S/G

FR

OM

11-

36-2

58"

L.P

. XFL

D S

/G F

RO

M 1

1-36

-25

( AB

ND

)6"

FR

ES

H W

ATE

R F

RO

M C

ITY

OF

CAL

GA

RY

2" FRESH

ENERSULFACILITY

CAUTION:Buried Fibre Optic Cable

TELEMETRY CABLE FROM TCPL

22" SALES GAS TO TCPL

TELEMETRY CABLE FROM TCPLNEXEN 22" SALES GAS TO TCPL

Gat e

Gat e

Gate

Gat e

Gate

Gat e

Ab ove groun d Waste Oi l Ta nk Ab ove grou nd

Waste Oi l Se tt li ng Tank

Wel ding Te nt

Si te "G "Com pre sso rBu ild ing

Cool er

Se para to r

LPG Tru ck Load ing Do ck Bu ild ing

LPG Lo adin g MC C Build ing

Transform e rGat e

Ab ove groun d Lean Oil Ta nk

Bu ried

Cabl es (3

)

Transform e r

#9 Sub-stat ionSw itch Gea r Bu ild ing

Sa les G asCom pre sso rMa in Discon nect

Culvert withBu ried P ip es unde r Ro ad

8" STE

EL FIR

E W

ATE

R

6" STE

EL FIRE W

ATER

6" FIR

E WATER

8" FIRE WATER (ABND)


6" F

IRE W

ATER

6" FIRE WATER

6" FIRE WATER

6" F

IRE W

ATER L

INE

Ab and oned C abl es

6" FIRE WATER

P.P.

Nexen Si gn

P.P.

P.P.

Gat e

Te lus JB

Te lus JB

JB

JBJB

Vi deoCam era

2" FIRE WATER

Ab and oned Cabl es

Ho H

2H

3

H1

Ba lzac Po wer S tati on Cool er

FW V

FWV

FWV

FW V

FW V

Vi deoCam era

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

Vi deoCam era

Vi deoCam era

Te lus Pe destal

Te lus Pe destal

Telus Pedestal

Te lus Pe destal

Te lus Pe destal

FW V

FW V

FW V

6" HDPE FIRE WATER

8" HDPE FIRE WATER

6" ST EEL FIRE WATER

8" S

T EEL FI

RE WATE

R

2" Waterli ne Dead En dedU/G

En ersul Su lph ur

Form i ng Bu ild ing

Su lph ur Fil te r

Water Pi pe Riser

2" HD

PE

Water Lin

e

Wee pingTil e Riser

Su lph ur Conve yor

Liqu id Su lph ur Cool er

Stea

m

Con

den

sate

Build

ing

A/G P i pe &

El ect rical

Riser Fla nge

Transformer Pole

Disconnect Panel

Elec. Panel

P.P.

P.P.

P.P.

P.P. P.P.P.P.P.P.P.P.P.P.P.P.

P.P.

P.P.P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.P.P.

P.P. P.P.

P.P.

P.P.

P.P.P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.P.P.

P.P.

P.P.

P.P.

P.P.

Se rvice Hatch

P.P.

P.P.

P.P.

Ele ctr ica l Pa ne l

El ect rical Pa nel

El ec. Bo x

RTU

W/H JEFF LAKE 2-2

Telem

e try C

able

(Ab n'd

)

NEXEN 8" STEEL WASTE

WATER FROM BPS

3" N

EX

EN

DIS

PO

SA

L T

O 1

0-36

-25-

1 W

5

EAST

FE

NC

E

SEE

DE

TAIL

'E'

TELEMET RY C ABLE T O T CPL

TELEMET RY C

ABLE T O T CPL

FIELD OPS OFFICE & YARD

Door Gua rd Po sts

A/G

Pip

e &

A/G

Cab

le T

ray

Riser

Te lus Pe destal

Old Bu rnPi t Sum p

Old Chem i calPi t Sum p

CP Po st

Telu

s Pe

dest

al

A/G P

i pe Rack li quid

sulph

ur l ine

A/G P i pe Rack li quid su lph ur l ine

A/G P

i pe Rack li quid

sulph

ur l ine

A/G Pipe Rack liquid sulphur line

A/G

Pi p

e R

ack

liqu

id s

ulph

ur li

ne

Liqu id Su lph ur Load ing Stai rway

VAT Pum

p

Building

VAT Po nd

Caust ic Stora ge Ta nk

Se pt ic Ta nk

Win d Fen ce

Su lph ur Hopp er

Eye W ash Stat io n

Ba lzac Gas P la nt Water Pum p Stat io n

Cat Walk

Retain

ing W

all

Ma n Hole

KO Drum

Se curit y Sta.

Ski m Po nd

A/G P i pe Rack li quid su lph ur l ine

Ven t Pi pes

Man Gate

Man Gate

Te lus Pe destal

Te lus Pe destal

Inlet

Bu ild

i ng

Win d Fe nce


2" FIRE WATER

EAST SU LPHU R BLOC K PAD

RAN

GE

RO

AD

291

01 -33A

92-9A

98-25 B

98-25 A

01-35 A

99-32 A

99-30 A99-30 C

92-6A92-8B92-8A

92-8C

99-31 A

92-7A

MW -3A

92-14 A

92-3A

92 -3B

M W 8A

94 -18C

M W -10A

M W 5A

M W 11A

92 -5A

92 -2A

M W 4A

94 -17C

92 -1A

M W 9A M W 9B

92-4A

06-45 A

06-46 A

03-41 A

03-40 A

04-42 A

MW -1A

03-38 A

P2

P1

RG1

98-2

4 C98-2

4 B

98-2

4 A

No.19

No.18

Mi chig anBu ild ing

92-13 A

liquid sul phur li ne A/G

Pi pe R

ack

No.17

No.9

No.10

No.6

No.16

No.3

No.12

No.11

Bu ild ing

Bu ild ing

JU NCT ION 2 C ELLAR

Fire Water

Reservo ir

Pu mp Build ing

El ect rical F ire Water Pum p Bu ild ing

Diese l Fi re Water Pum p Bu ild ing

Bu ild ing

Me te rBu ild ing

Sw itch Gea r Bu ild ing

So uth Depro p. Cond . Buil din g

Gas Cool er Bu ild ing

Sa lesBu ild ing

#5 Su b-S tat ion Sw itch Gea r Bu ild ing

Crushe r Pu m p Bu ild ing

Gara ge

Ener

sul O

ff ice

NEXEN PLAN 59 LK

NEXEN PLAN 502 JK

PEMBINA PLAN 754 JK

NEXEN MARKETING R/W PLAN 031 0629

NEXE

N M

ARKE

TING

R/W

PLA

N 03

1 06

29

CANADIAN PACIFIC RAILWAY PLAN 871 JK

NEXEN PLAN 502 JK


NEXE

N MAR

KETI

NG R

/W P

LAN 0

31 0

391

NEXEN PLAN 4965 JK

NEXEN PLAN 502 JK

NORTH CANADIAN PLAN 851 0253

HOME OIL PLAN 821 0555NEXEN PLAN 4957 JK(NO PIPE IN R/W)

NEX

EN

PLA

N 0

31 0

174

NEXEN PLAN 4965 JK

NEXEN PLAN 931 2570

NEXEN PLAN 502 JK

NEX

EN

PLA

N 6

86 J

K

NEXEN

PLAN 1547 JK

ATCO PLAN 851 0253

PIPE LINE R/W 500 JK

NEX

EN

PLA

N 4

53 L

K

NEXEN PLA

N 500 J

K

ATC

O P

LAN

791

081

6

ACCESS TO ELKTON WELL10-35-25-29 W4M

ATC

O P

LAN

851

025

3

NEX

EN

PLA

N 0

61 2

620

NEX

EN

PLA

N 9

21 0

545

68th

STR

EE

T N

.E.

NEX

EN

PLA

N 5

02 J

K

UNDEVELOPED 144th AVENUE N.E. UNDEVELOPED 144th AVENUE N.E.

TRANSALTA PARCEL 'A' PLAN 811 1282

NEXEN PLAN 851 1017

TRANSCANADA PIPELINE METER STATION

ATCO PLAN 791 0816

ATCO METER STATIONPLAN 791 0816

TRANSALTA PARCEL 'B' PLAN 811 1282

GO

VER

NM

EN

T R

OA

D A

LLO

WA

NC

E

PON D

Drain

age C

ourse

Drain age Co urse

O/H

Cab

le

Bu ried Power Cab le

3-Cab les2-C

ab les

2-Cab les

En d of

Win ch

Burie

d P

ower

Cab

les

El ec. Pa nel

Burie

d

P ow

e r

Cab

le

El ect rical Pa nel

El ect rical Riser

El ect rical Ju nct ion

Win ch

U/G

Cab

le

Lina log Laun cher

2" F

uel G

a s

VENT RISERS ON8" WASTE WATER FROM BPS

TEST POST

TEST POST

Lina log Laun cher

VEN T RISER SON 8" WASTE WAT ER PL

Bu ried P i pe & C able

2" D

ISPO

SAL TO

11-1

3-25

-29

W.4

M. (

ABND)

NEXEN 12" BQ S /G FR OM J80C

VEN T RISERS O N

8" WASTE WATER F RO M

BAL ZAC PO WER STATIO N

3" A

/ G L

VP

LI N

E T

O P

LAIN

S

2" F / G ( A B N D )

NEXEN 22" SALES GAS TO T CPL

2" GLYCO L (ABN D)8" S ELKT ON S /G F RO M J12

2" GLYCO L (ABN D)2" F/G TO J11

SU RG E 6" S /G TO J13" FIBER GLASS (ABND)2" FIBER GLASS (ABND)

2" G

lyco

l3"

Pi p

e2"

Gly

col

2" Pi pe

Unkno wn P ipe

Unkno wn P ipe

2" Pi pe

14" S /G FR

OM J39

3" F/G TO J39

Bu ried Re co very D it ch

10" F

/G T

O BPS

10" F

/G T

O BPS

NEXEN 6" S

/G F

ROM

2-2

-26 T

O U/G

TIE

-IN @

J1A

6" K

AL

IST

O S

/G F

RO

M J

11

Unk

now

n P

ipe

Unk

now

n P

ipe

s (2

)

Unk

now

n P

ipe

3" PL A IN S M IDST REAM (D ISCO NT INUED)

8" PL A IN S M IDST REAM

3" PL A IN S M IDST REAM P IPELINE (DISC ON TINUED )

8" PL A IN S M IDST REAM P IPELINE

8" PL A IN S M IDST REAM P /L

CIT Y OF C ALGAR Y 18 " PL ASTIC WATERL IN E

2 ATC O P IPEL INES

1 ATCO PIPELINE

NEXEN 8" S/G (ABND)

CIT Y OF C ALGAR Y 18 " PL ASTIC WATERL IN E

PLAIN

S 3" (A

BND)

PL A INS 3" (ABND

)

2 A /G LINES (ABND)

3" A /G LVP L IN E T O PLA INS

NE

XE

N 2

2" S

ALE

S T

O T

CP

L

3" A /G LVP L INE TO PLAINS

10" F

/G T

O BPS

Burie

d P

i pe

& C

able

6" E E

LKT

ON

10"/

12"

FLA

RE

LIN

E10

"/12

" F

LAR

E L

INE

Bu riedConcre te

Vau lt

2" F

/G T

O J

11

& 2-

2-2

6

An ode Bed

Anod

e B

ed

Cathod ic Cabl e

Anod

e Bed

Cathod ic Cabl e

Concre te Enca sed Con dui t

Concre te Enca sed Con dui t

Guard

Rail

Gua rd R

ail

Concre

te E

ncased C

ondui t

8" FRE

SH

WAT

ER

TO

BP

S

6" FIR

E WATER

LPG Pum pCont rol Swi tch

SURG

E TANK

BUTA

NE TANK

BUTA

NE TANK

BUTA

NE TANK

BUTA

NE TANK

PROPANE T

ANK

PROPANE T

ANK

PROPANE T

ANK

PROPANE T

ANK

7000BBL

7000BBL

Pe rfo rated

Culve rt

Pe rfo rated

Culve rt

Si dewa lk

Perfo

rate

d

Culve rt

Perfo

rate

d

Culve rt

Burie

d Re co

very

Ditc

h

Bu ried

Recovery

Ditch

<STE

ELHDPE

>

Elec. C

ont rol

Pa nel

A/G

Pi p

e Rac

k / C

able

Tra

y

A/G P i pe Rack / C able T ray

A/G P i pe Rack / C

able T ray

A/G P ip e Rack / Cab le Tray

W1

W2

W3

8" WA

STE

WA

TER

FR

OM

BP

S

8" FRE

SH

WAT

ER

TO

BP

S

CP Po st

CP Po st

CP Po st

CP Po st

CP Po st

CP Po st

CP Po st

CP Po st

3 Wir e O

/H P

owe

r

Cabl e

Tra

y



A/G P i pe Rack / C able T ray (5 )

TELEMET RY CABLE T O T CPL

Oil

Se

ttlin

g Ta

nk

Ta nks

Ta nks

3" W AT E R D I S P O S A L TO 10 - 36 - 2 5

Elec. Pedestal

A/G

Cab

l e T

ray

A/G

Pi p

e Rac

k

A/G

Cab

l e T

ray

Cattle Guard

Bridge

P.P.

P.P.

BERM

Concrete Vault (Suspended)

PON D

10" BURIED PVC DRAIN LINE

Ma nho le

Ma nho le

6" FIRE WATER LINE

Wood Retaining Wall

Wood Retaining Wall

Woo

d Re

taini

ng W

all

Transformer

Plas

tic P

ipe

Aban

don

ed C

abl e

s

Aban

don

ed C

abl e

s

Aban

done

d C

abl

es

8" F

RE

SH

WAT

ER

TO

BPS

P.P.P.P.

P.P.

P.P.

P.P.

P.P.P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.P.P.

P.P.P.P.

P.P.P.P. P.P. P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

P.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

L.P.

Railcar Sulphur

Loading Building

EnersulStand Pipe

EVAPORATION POND NOT IN SERVICE

RAN

GE

RO

AD

291

G

OV

ER

NM

EN

T R

OA

D A

LLO

WA

NC

E

2" FIRE

WATE

R

A/G P

i pe Rack

3" PLAINS (ABND)

BONEYARD

Gate

8" STEEL FIRE W

ATER

6" STEEL FIRE W

ATER

Cat

hod

ic C

abl e

6" F W V

6" F W V

Bu ried Re co very D itch

Airdrie Modelers Helipad

Airdrie Modelers Airstrip




8" W A S TE W A TE R F R O M

BA L Z A C P O W E R S TA T I O N

P.P.

P.P.

P.P.

P.P.

L.P.

L.P.

L.P.

L.P.

P.P.

EAST

FE

NC

E

SEE

DE

TAIL

'E'

AGTL PLAN 299 JK

P.P.

L.P.

8" HDPE FIRE WATER

6" HDPE FIRE WATER

VAT PUMP D ISCHARGE LINE

(PVC) <CONFIRMED>

DRAINVALVE

VAT

PUM

P D

ISCH

ARG

E LI

NE

(PVC

) <UN

CONF

IRM

ED>

COMPLEX ENTRANCE SEE DETAIL 'H'

HP.Fla reStack

LP.Fla reStack

3" Dispo sal PL and Vent Riser

3" L

.P. S

UR

GE

(A

BND

)

2" F

OR

MAT

ION

WAT

ER

FRO

M IN

LE

T S

EPA

RA

TO

RS

FILTER CAKE DRAIN (ABND)

2" F/G (ABND)

24" C

OOLI

NG W

ATER (A

BND)

24" C

OOLI

NG W

ATER (A

BND)

2 A /G Pi pes

Zap ata Riser & ESD Va lve

4" C

LOSED H

C DRAIN

FR

OM IN

LET

SEPARAT

OR B

UILD

ING

4" C

LOSED H

C DRAIN

TO

L.P

. SURG

E DRUM

CITY OF CALGARY R/W PLAN 901 2327

FORTIS R/W PLAN 081 3328

FORTIS R/W PLAN 081 5893

2 26-29-4

LIFT STATION SITE PLAN 071 0376

R/W PLAN 071 1197

NEXEN

MAR

KETING

R/W

PLAN 031 0629

Buried Power Cable

Su lph ur Crushe r/Lo ade r



No.20

Pu m p Bu ild ing

6" STE

EL FIR

E W

ATE

R

Transformer P.P.

F/WRiser

2" FIRE

WATE

R

UgP

2" FIRE

WATE

R

(ABN

D)

NEXEN 8" HDPE WAST E WAT ER F RO M BPS

Asp hal t Pa d

Low G

rade Gravel R

oad

Asp

hal t

Sw

ale

Asp hal t Swal e

Asp

hal t

Sw

ale

Pave

d P

lan

t Acc

ess

8" N. ELKTON S/G TO BGP

6" FRESH WATER TO BGP

2" F/G FROM BGP

2" GLYCOL (ABND)

2" FORMATION WATER (ABND)

8" L.P. XFLD S/G TO PLANT (SUSP)

2" GLYCOL FROM BGP

6" E. ELKTON S/G FROM 11-01-26

2" GLYCOL FROM J15

10" L.P. XFLD S/G FROM J32

2" FLASH GAS (ABND)

2

NORTH DITCH

SEPARATE DITCHSOUTH DITCH

SEPARATE DITCH

S.E.1/4 Sec.2-26-29-4

WELLSITE 2-2-26-29-W.4M. SEE DWG. BLZ-W120-A-001-A

NORTH DITCH

SEPARATE DITCH

SOUTH DITCH

(OLD AGTL R/W)

SEPARATE DITCH

3" WATER DISPOSAL TO 10-36-25

2" FIBER GLASS (ABND)

3" FIBER GLASS (ABND)

SURGE 6" S/G TO J1

2" F/G TO J11

2" GLYCOL (ABND)


2" GLYCOL (ABND)

2" F/G (ABND)

8" WASTE WATER FROM BALZAC POWER STATION

TELEMETRY CABLE FROM TCPL

NEXEN ��SEPARATE DITCH

NORTH D

ITCH

SEPARAT

E DITC

HSOUTH

DIT

CH

3" WAT

ER DIS

POSAL TO 10

-36-25

2" FIB

ER GLA

SS (ABND)

3" FIB

ER GLA

SS (ABND)

SURGE 6" S

/G TO

J1

2" F/G

TO J1

1

2" GLY

COL (ABND)

8" S E

LKTO

N S/G

FROM J1

2

2" GLY

COL (ABND)

2" F/G

(ABND)

8" WASTE W

ATER FROM B

ALZAC P

OWER S

TATIO

N

SEPARAT

E DITC

H

8" W ELKTO

N (ABND)

8" W E

LKTON (A

BND)

6" E ELKTON S/G

F ROM

11-1 -26

16" P IPE (ABND)

16" P IPE (ABND)

16" P IPE (ABN D)

Culvert withU/G IsolationValves

2" F/G TO ENERSUL FROM J15

Pu m ps

Pu m ps

FROM J2WATER

16" P IPE (ABND)

NEXEN 6" S

/G F

ROM

2-2

-26

2" G

LYC

OL

FRO

M B

GP

2" F

/G F

RO

M J

158"

N. E

LKTO

N S

/G F

RO

M J

15

2" F

RE

SH

WAT

ER

TO

EN

ER

SU

L2"

GLY

CO

L (A

BN

D)

2" G

LYC

OL

TO J

15

6" L

.P. X

FLD

S/G

FR

OM

J32

2" G

LYC

OL

FRO

M J

15

10" L

.P. X

FLD

S/G

FR

OM

J32

abovegroun d

8" N. ELKTON S/G TO BGP

6" FRESH WATER TO BGP

2" F/G FROM BGP

2" GLYCOL (ABND)

2" FORMATION WATER (ABND)

8" L.P. XFLD S/G TO PLANT (SUSP)

2" GLYCOL FROM BGP 2" GLYCOL TO J15

GLYCOL JUMPOVER DETAILWITHIN NORTH DITCHNOT TO SCALE

Fue l Ga sHead er

P.P. P.P.P.P.P.P.P.P.P.P.P.P.

06-43A

93-15A93-15C

93-16A

93-16C

NEXEN 4" L.P. XFLD S/G FROM 11-36-25-29W4M

6" KAL IS

T O S/G

FROM

J11

2" H

DPE

U/G

WAT

ER L

INE

<CON

FIR

MED

>

2" H

DPE

U/G

WAT

ER L

INE

<UNC

ONFI

RM

ED>

Culvert

ENERSUL SULPHUR STORAGE AREA

BPS WASTE WATER CONCRETE VAULT

ATCO METER SITE EXTENSION

P.P.

P.P.P.P.

P.P.

P.P.P.P.

P.P.

P.P.P.P.

P.P.

P.P.P.P.

P.P.

P.P.P.P.

P.P.

P.P.P.P.

P.P.

P.P.P.P.

ATCO PIPELINES

ATCO METER SITE EXTENSION ATC

O PLAN

4609 JK

Anod

e B

ed

Cathod ic Cabl e

Cathod

ic Cabl e

Cat

hod

ic C

abl e

Cat

hod

ic C

abl e

An ode Bed

An ode Bed

Rect if ierAn

ode B

edAn

ode B

ed

Anod

e B

ed03-39 A

03-39 B


2" HDPE Water Line

Po rta ble Em e rgen cySh owe r

Dra

ina g

e D

itch

to M

cDon

ald

Lake

1 ATC O P IPEL INE

P.P.

MCDONALD

LAKE

PipelineR/W (031

0629)


GasPipeline R/W

(4609 JK)

Pipeline R/W(791 0816)

Gas PipelineR/W (851 0253)

Gas TransmissionLine R/W (299 JK)

PipelineR/W (791

0816)

Oil PipelineR/W (754 JK)

Pipeline R/W(031 0174)

PipelineR/W

(1547 JK)

Gas TransmissionLine R/W (686 JK)

PipelineR/W (101

2606)

PipelineR/W

(502 JK)

PipelineR/W (061

2620)

PipelineR/W (921

0545)

PipelineR/W (821

0555)

CanadianPacific Railway (871

JK)

PipelineR/W (081

5893)


Gas Pipeline R/W(791 0816)

PipelineR/W

(500 JK)


GasPipeline R/W

GasPipeline

R/W

Admin Building

PowerStation

Fiber OpticPipeline

(10m R/W)

Fiber Optic Pipeline(10m R/W)

Building

Pipeline R/W

PowerlineR/W

PowerlineR/W (9012327 UR/W)

Pipeline R/W

WellSite2-2

PipelineR/W (931

2570)

0 100 200 30050Meters

±CONTINUOUS, 190, 25

TEL, 210, 25

CONTINUOUS, 90, 25

CONTINUOUS, 142, 25

DASH_5-1, 24, 25

DASH_5-1, 94, 25

PIPE-B, 10, 25

POWER, 190, 25

CABLE-ABD, 210, 25

CONTINUOUS, 50, 25

ANCHOR, 190, 25

ROAD-G, 90, 25

DASH_1-1, 142, 25

CONTINUOUS, 24, 25

CONTINUOUS, 94, 25

PIPE-B, 4, 25

ROAD-G, 10, 25

CONTINUOUS, 110, 25

CONTINUOUS, 252, 25

CONTINUOUS, 101, 25

CONTINUOUS, 36, 25

CONTINUOUS, 31, 25

CONTINUOUS, 140, 25

CONTINUOUS, 251, 25

WATER, 10, 25

CONTINUOUS, 141, 25

CABLE-OH, 190, 25

CONTINUOUS, 253, 25

TRACK, 7, 25

CONTINUOUS, 230, 25

CONTINUOUS, 221, 25

CONTINUOUS, 112, 25

CONTINUOUS, 121, 25

DASH_1-1, 7, 25

DASH_5-1, 160, 25

Q-LINE, 7, 25

POWER, 181, 25

DASH_1-1, 10, 25

CONTINUOUS, 6, 25

DASH_5-1, 240, 25

CONTINUOUS, 51, 25

CONTINUOUS, 193, 25

BLZ-F004-B-020-B.DWG MultiPatch<all other values>

Cad Renderer

CONTINUOUS, 7, 25

CONTINUOUS, 96, 25

CONTINUOUS, 91, 25

CONTINUOUS, 242, 25

CONTINUOUS, 241, 25

CONTINUOUS, 132, 25

CONTINUOUS, 131, 25

CONTINUOUS, 10, 25

CONTINUOUS, 20, 25

CONTINUOUS, 210, 25

CONTINUOUS, 211, 25

CABLE-B, 211, 25

CONTINUOUS, 130, 25

CONTINUOUS, 2, 25

CONTINUOUS, 1, 25

CONTINUOUS, 11, 25

ANODE, 220, 25

CONTINUOUS, 254, 25

CONTINUOUS, 4, 25

CABLE-B, 210, 25

CONTINUOUS, 5, 25

PIPE-B, 90, 25

CONTINUOUS, 160, 25

CONTINUOUS, 34, 25

CONTINUOUS, 170, 25

FENCE, 150, 25

CONTINUOUS, 150, 25

CONTINUOUS, 190, 25

TEL, 210, 25

CONTINUOUS, 90, 25

CONTINUOUS, 142, 25

DASH_5-1, 24, 25

DASH_5-1, 94, 25

PIPE-B, 10, 25

POWER, 190, 25

CABLE-ABD, 210, 25

CONTINUOUS, 50, 25

ANCHOR, 190, 25

ROAD-G, 90, 25

DASH_1-1, 142, 25

CONTINUOUS, 24, 25

CONTINUOUS, 94, 25

PIPE-B, 4, 25

ROAD-G, 10, 25

CONTINUOUS, 110, 25

CONTINUOUS, 252, 25

CONTINUOUS, 101, 25

CONTINUOUS, 36, 25

CONTINUOUS, 31, 25

CONTINUOUS, 140, 25

CONTINUOUS, 251, 25

WATER, 10, 25

CONTINUOUS, 141, 25

CABLE-OH, 190, 25

CONTINUOUS, 253, 25

TRACK, 7, 25

CONTINUOUS, 230, 25

CONTINUOUS, 221, 25

CONTINUOUS, 112, 25

CONTINUOUS, 121, 25

DASH_1-1, 7, 25

DASH_5-1, 160, 25

Q-LINE, 7, 25

POWER, 181, 25

DASH_1-1, 10, 25

CONTINUOUS, 6, 25

DASH_5-1, 240, 25

CONTINUOUS, 51, 25

CONTINUOUS, 193, 25

Disposition - Operator

Atco


City of Calgary

Fortis

Nexen

Pembina

Telus

services

Nexen Inc.


BalzacFigure 3



Date: November 24, 2011Updated: File No : CA13581.mxd

Scale: 1:2,500NAD 1983 UTM Zone 12N

Projection: Transverse Mercator

BALZAC GAS PLANT


95

The following steps are required to better understand the characteristics at the BGP, allowing for

remedial options to be compared, end land use to be further explored and discussed, and

ultimately, a detailed remedial plan to emerge. This is a phased approach that CANNOT be

completed until demolition is complete and as each phase of demolition and testing occurs, the

information will be used to support future and final site remediation:

1. Completion of an environmental site assessment for the BGP as a whole to ensure that all

areas of possible contamination across the property have been identified and assessed.

Finalize the list of unknowns/areas for investigation due to infrastructure limitations or

operations (Gap Analysis) and complete Phase II activities to determine if contamination

is present in these areas.

2. Develop a remedial action plan to determine and/or establish specific guidelines for each

Contaminant of Concern (as required for soil, groundwater, surface water and sediment).

Once these above steps have been completed, soil, groundwater, surface water and sediment

plumes will be understood. Confirmation of the specific details and methodologies of the

remedial plan can be completed at that time, in conjunction with final end land use planning.

10 REMEDIATION PLAN

10.1 General Options analyses for remediation planning have been conducted since decommissioning and

remediation at the Balzac Gas Plant was first contemplated. The following remedial strategy has

been developed to allow safe, effective, and efficient remediation and subsequent redevelopment

of the land. The following bullets summarize the tasks involved in the overall program, which

includes a remediation communication plan.

A remediation execution plan will be developed defining the areas requiring remediation,

the technical approach(es) that will be used, environmental monitoring and occupational

health and safety precautions to be undertaken. The execution plan will also define

requirements for confirmatory sampling for verification that remedial objectives have

been achieved.

All buildings and other surface and subsurface infrastructure, that are no longer required

will be demolished and waste materials either recycled or legally disposed.

Soil and soil stockpiles that are currently present within the boundaries of the BGP will

likely be remediated as follows:

o Soil will be excavated as needed, and processed to achieve volume reduction.

o Soils with organic contaminants above the Tier II guidelines established for the

site will be remediated in-situ wherever possible. If in-situ remedial options are

BALZAC GAS PLANT


96

not available for a certain contaminant, or not cost effective, ex-situ remediation

(still on site) will be considered (biopiles, etc). As possible, all organic

contamination will be dealt with on site.

o Inorganic contaminants in soil will be removed from site if necessary and may be

taken to a registered landfill facility as per the Nexen BGP Waste Management

Plan. Other options will be to stockpile in a specific area and risk manage

(perhaps in conjunction with the areas used by the operating Power Station and

associated pipelines).

o Further and more detailed remedial options will be established once further

assessment work and land use planning has been completed for the BGP.

Processed soil may be reused to establish development grades across the property,

consistent with tested contaminant characteristics and as verified by an appropriate

testing program.

Excess soil or other material that cannot or will not be reused to meet development grades

will be legally disposed off-site at an approved landfill facility. This includes debris,

hazardous waste, soil that does not meet geotechnical requirements for Site

redevelopment, and salvaged crushed rock.

Dust and noise management and mitigation are activities integral to remedial operations.

Monitoring measures will be implemented to verify that acceptable noise and air quality

is maintained during remediation activities.

Industrial water runoff will be controlled during remediation to prevent its contamination

by travelling over or through impacted materials. If needed, accumulations will be

removed from contaminated areas and treated as required, prior to release or disposal.

Groundwater remediation may include, but will not be limited to, the following:

o The existing groundwater remediation system present in the LPG area will

continue to be operated, both to recover NAPL (none was observed in 2009) and

dissolved phased contamination present in the groundwater. Groundwater

monitoring activities will also continue.

o Based on the results of site assessment and RAP, appropriate plans will be

implemented to best remediate and reduce risk to receptors. Receptors and risk

pathways will be evaluated to ensure no risk is present to human receptors, the

general environment and/or McDonald Lake. Ecological risk assessment

techniques will be utilized whenever possible to quantify actual risk to receptors.

BALZAC GAS PLANT


97

10.2 Sulphur Handling Facility As operations at the BGP have terminated, Nexen has assumed responsibility for the sulphur

handling facilities. As the approval holder Nexen has sole responsibility for the management and

control of the sulphur handling facility and the sulphur handling facility will be managed

consistent with the remainder of the gas plant.

A comprehensive assessment program will be undertaken to determine the nature, degree and

extent of contamination associated with the Sulphur Handling Facility. Decontamination of areas

directly associated with the sulphur slating plant and maintenance buildings, etc. will be the

overall responsibility of Nexen.

10.3 McDonald Lake

As per the Amending Approval 155-02-06, Nexen will continue to monitor McDonald Lake for

parameters outlined in Table 4.2-B of that approval. Annual reporting of findings will continue.

In addition to approved releases and influences from the BGP, McDonald Lake is known to

receive surface water inputs from industrial lands located south of the BGP, through surface water

drainage, and from the industrial park, located on the north-west shore of the lake. The industrial

park on the northwest shore of the lake includes a surface water retention pond, located directly

on the shore of the lake, which releases into the Lake. Furthermore, surface water drainage from

this same industrial park also influences McDonald Lake.

In addition, there is clear release of other users into McDonald Lake. It is Nexen`s understanding

that these other releases are not monitored or reported to AENV. Nexen would look to AENV to

develop a McDonald Lake monitoring strategy that would incorporate all Industrial influences to

ensure they are managed, monitored, and information pooled from all users to determine how all

contributors have affected/are effecting McDonald Lake.

10.4 Noise Management Noise assessment and mitigation will be addressed by complying with the Site's Health and

Safety Plan. The project will conduct noise-generating operations only within the standard

construction hours of 7:00 AM to 7:00 PM on weekdays and 8:30 AM to 7:00 PM on Saturdays

as per the Municipal District of Rockyview No. 44 Bylaw No. C-5772-2003 (aka “Noise Control

Bylaw”).

Noise will be monitored as required through established monitoring programs that may be

deemed appropriate at the time.

10.5 Industrial Runoff Management Industrial runoff control systems will continue as per the existing AEPEA approvals.

BALZAC GAS PLANT


98

Industrial water run-off will be controlled during remediation to prevent its contamination by

manipulating site grade (e.g. berm or channelling) to redirect potential run-off around the areas to

be remediated or in the process thereof. Industrial water control measures will be available and

will be installed as required and will be optimized as appropriate. These may include the use of

the existing catchment areas, or alterations to the catchment areas mentioned in Section 6.5, to

best manage surface water on the BGP.

Stockpiles of contaminated soils will be placed with proper grading to control Industrial water.

All stockpiles with contaminated soil (processed and unprocessed) will be located in a dedicated

areas a central location to minimize the risk of run-off of contaminants.

Industrial wastewater that accumulates around stockpiles or in excavation areas and requires

removal will be transported and/or pumped to a designated area. This captured water may be

treated using bag filters and activated carbon or disposed at an approved facility. The treated

water will only be reused for dust control in areas or on materials requiring or undergoing

remediation. No Industrial water will be discharged to McDonald Lake without appropriate

testing to ensure acceptable conditions.

10.6 Monitoring Programs

All of Nexen’s monitoring programs will be implemented in accordance with a Site Specific

Health and Safety Plan that will account for all of the physical and chemical hazards that may be

present. The health and safety program will be consistent with the following primary goals: no

accidents, no harm to people and no damage to the environment. The Health and Safety Plan has

been developed in accordance with all Provincial Occupation Health & Safety requirements and

regulations.

Nexen uses a defined Hazard Assessment process to identify any potential hazards. In the event a

hazard is identified (i.e. airborne contaminants) Nexen will conduct baseline surveys to determine

the likelihood of potential problems/exceedances. If the baseline survey identifies the hazard is

present in quantities of concern (50% of the Occupational Exposure Limit) Nexen will develop a

specific plan to eliminate/reduce, control and monitor exposure to the hazard. For example, while

operating and during SDS Nexen had specific monitoring plans for Noise, Asbestos, Benzene,

SO2, H2S, CO and Hydrocarbons.

During the course of the remedial program at the BGP, appropriate monitoring will take place to

ensure the workers and the public are not exposed to air borne contaminants or noise in excess of

regulations or guidelines in place at the time. These monitoring programs may include sampling

to ensure worker occupational exposure limits are not exceeded, organic air sampling, and/or

particulate sampling to ensure compliance with the Occupational Health and Safety Act,

Occupational Health and Safety Code 2009, or any updated versions thereof.

As per the requirements outlined in the existing AEPEA approval 155-02-00, and subsequent

amendments, soils will be sampled once in-situ or ex-situ remediation is complete, to document

soil conditions and ensure acceptable risk an all groundwater will be sampled prior to release.

BALZAC GAS PLANT


99

11 RECLAMATION PLAN The determination of a successful outcome of reclamation at the BGP will be dependent upon the

end land use agreed to by Nexen, working interest partners, and regulatory agencies (including

municipal bodies) and the regulatory criteria in effect at the time.

The exact date of reclamation commencement is currently unknown due to the unknown and long

timelines associated with decommissioning, dismantling, and remediation at the BGP. The goal

therefore is to briefly identify measures that could be used to achieve “equivalent land capability”

that may be similar to surrounding land use conditions that may exist at the time of reclamation.

As this could very well be 10 years or more in the future, it is strictly conceptual in nature.

Preparation of the reclamation plan will eventually be guided by the engineering drawings and

site grading plan for the determined end land use. The engineering plans should guide the amount

of soil salvage or replacement required, the location for soil storage and/or replacement, re-

contouring, drainage restoration, and post closure conditions that result in specific reclamation

requirements being met on the site.

The final goal will be to achieve the following:

Erosion control and site stability;

Return of the proposed disturbances to land capability that is equivalent to or consistent

with the approved end land use or uses;

Re-vegetation of all disturbed areas to the targeted end land use or uses;

Control of noxious and restricted weeds;

Development of a self-sustaining landscape; and,

Reclamation certification.

As industry best management practices will likely evolve, Nexen will incorporate such

developments in the plan for successful realization of the end land use objectives.

12 HEALTH & SAFETY PROGRAM The management of Nexen is dedicated to the safety of personnel as well as those Nexen works

with. Nexen’s goal is to provide a safe work environment through a trained employee or

contractor who is safety oriented. Nexen’s mission is to not only provide a job that is done well

but is done safely.

To that end, the remediation plan will be implemented in accordance with a Site Specific Health

and Safety Plan that will account for all of the physical and chemical hazards that may be present.

The health and safety program will be consistent with the following primary goals: no accidents,

no harm to people and no damage to the environment.

At a minimum, the Site Specific Health and Safety Program will incorporate the following:

Air Monitoring;

Noise Monitoring;

BALZAC GAS PLANT


100

Decontamination Procedures;

Emergency Response Procedures;

Ground Disturbance;

Confined Space Entry;

Respirator Use Code of Practice; and

Management of Change.

The Health and Safety Program will also include the following:

adequate training of all owner, contractor and technical personnel;

initial safety orientation prior to commencing Site work;

daily tailgate meeting to reemphasize and identify potential hazards or health concerns;

testing and identification of underground hazards prior to excavating or intrusive

investigation;

selection of appropriate personal protective equipment for each activity;

recognition of emergency situations and appropriate response;

implementation of procedures for handling of contaminated soils and water;

noise and air quality monitoring; and

safety audits.

Both of the above noted Programs ensure that Nexen maintains compliance with Occupational

Health and Safety Requirements.

In 2002, the Nexen Balzac Gas Plant became the first Oil & Gas facility in the world verified

Responsible Care® In-Place.

Responsible Care® (RC) is a unique ethic developed within the chemicals industry that drives

continual improvement in health, safety, environmental and business performance, while openly

and transparently communicating with stakeholders about products and processes.

Critical to RC is an expectation for member companies to have a functioning, effective

management system in place and that it is structured to include all components of the

Plan/Do/Check/Act cycle of continual improvement.

Both the “ethic” and effectiveness of the management system is verified every three years by a

team of external industry experts and leaders within the community through a process of staff

interviews, document reviews and meetings with external stakeholders. The next verification for

the Balzac Gas Plant is scheduled for the fall of 2013.

13 COMPLAINT RESPONSE Nexen has a procedure for receiving, recording, investigating, resolving and reporting public

inquiry or non-compliance events which may occur. One of the key outcomes of the process is to

ensure there are steps taken so that Nexen can learn from our experiences and maintain diligence

in its ongoing operations.

BALZAC GAS PLANT


101

These include:

Record enquiries, comments and complaints;

Develop, manage and record responses to enquiries, comments and complaints;

Support data collection and reporting requirements;

Support communication, liaison and notification activities;

Record communication, consultation and liaison activities;

Assist the project team in managing issues;

Nexen will handle all comments and complaints concerning the Project in a timely and prudent

fashion.

14 REPORTING Further assessment activities and delineation activities are required to determine all sources of

contamination on the property and fully define the edges of each of the contaminant plumes.

Once these assessment activities are completed, assessment reports will be completed, and the

remedial plans will be updated with more specifics relating to excavation, remedial opportunities

and risk assessment choices. This updated plan will be provided to AENV as per the conditions

of the current approval, Section 5.2.4 of Approval 155-02-00.

Reporting to AENV will update progress on the decommissioning and land reclamation as the

project commences proceeds and more details are known on aspects of the remediation and

reclamation methods, expected outcomes, and end land uses are determined.

BALZAC GAS PLANT


102

Appendix I –Slater Demolition Plan

BALZAC GAS PLANT


103

Appendix II – Waste Management Plan

Nexen Canada Ltd Waste Management Plan

Balzac Gas Plant 1.0: INTRODUCTION Table of Contents

1.0 INTRODUCTION

2.0 MANAGEMENT

2.1 Identification

2.2 Characterization and Classification

2.3 Handling

2.4 Treatment

2.5 Disposal

2.6 Tracking

2.7 Record Keeping

3.0 WASTE MANIFESTING

3.1 Manifest completion

3.2 EUB Handling Codes

3.3 Other Manifests

3.4 Alberta Waste Management Table

4.0 MINIMIZATION

4.1 Eliminate

4.2 Reduce

4.3 Reuse

4.4 Recycle

4.5 Recover

5.0 STORAGE REQUIREMENTS

6.0 LIST OF ALL WASTE RECEIVERS IN ALBERTA

7.0 LIST OF ALL LANDFILLS IN ALBERTA

8.0 SPILLS REPROTABLE TO GOVERNMENT

9.0 COMPANY FACILITY CODES

10.0 WASTE AUDIT REPORTS

11.0 RECYCLING


Balzac Gas Plant 1.0: INTRODUCTION

Introduction

The Oilfield Waste Management Requirements for the Upstream Petroleum

Industry (EUB Guide G-58) publication was published in December 1996 by the

AEUB. It is the standard for proper management of upstream oilfield wastes.

The operations staffs are responsible for managing day-to-day waste issues. The

facility design engineer is responsible for ensuring that waste from a process is

minimized. The Environmental Analyst is responsible for working with field and

technical staff to ensure all related regulations are complied with.

Objective

Nexen Canada Ltd. (NEXEN) is committed to demonstrating continuous

improvement in reducing the generation of waste from its operations, beneficially

reusing or recycling materials that might otherwise end up in the waste stream. It

also strives to properly store, handle, and dispose of those wastes that remain.

Active waste minimization is forefront, when the proper waste handling

techniques are employed. NEXEN is committed to ensuring compliance with

regulations, as well as ensuring protection of the environment when dealing with

its waste products.

NEXEN is also committed to properly training all personnel who handle wastes

and those responsible for their supervision.

To actively pursue these commitments, NEXEN has developed this Waste

Management Plan to ensure compliance with all associated environmental

regulations. This plan will serve as a valuable tool for the collection of data,

providing guidance to employees, identification of future technology needs and

requirements, as well as reducing risk exposure, and identifying the company’s

operating procedures and standards. In creating this Corporate-wide Waste

Management Plan, NEXEN has endeavored to meet the requirements of the

strictest province’s regulations, and enforce them company wide.

Scope

This plan is applicable to all EUB regulated segments of the company. This plan

will be the corporate guide for all of its facilities. The corporate waste

management plan will be the basis for the waste management philosophy of the

company, and will ensure consistency throughout. In areas outside of Alberta, the

site-specific plans for each facility will have to reflect the regulatory requirements

of the province in which the facility is operating. It is the intention of NEXEN to

establish and utilize the best management practices where available.


Balzac Gas Plant 1.0: INTRODUCTION

Plan Description

The plan is based on discussions with operations and environmental personnel

from NEXEN. Site visits to a representative sample of facilities were conducted,

for the purpose of conduction waste audits. The plan will ensure regulatory

compliances and will meet or exceed the requirements of the EUB’s waste

management requirements as outlined in Guide G-58.

This waste management plan is comprised of the following components:

Identification

Characterization and classification

Handling

Storage

Treatment

Disposal

Manifesting

Tracking and record keeping

Reporting

Site specific plans for field offices

The principles of waste minimization are followed closely in this plan. This is

both an environmental consideration as well as an economical one. Recognizing

opportunities to reduce waste volumes as well as the elimination of certain wastes

will enable NEXEN to ensure that it is operating in an environmentally safe and

responsible manner. This will reduce the liabilities associated with the handling,

storage and disposal of dangerous oilfield wastes (DOWs).

Waste Minimization will be addressed in Section 4.0.


Balzac Gas Plant 2.1: IDENTIFICATION

A. INTRODUCTION

This section will describe the wastes specific to the individual facilities. These

specific wastes will be outlined in the site-specific individual facilities and are

found in the appendices. The wastes will include both Dangerous Oilfield Wastes

(DOWs) and non-Dangerous Oilfield Wastes (non-DOWs).

B. PURPOSE AND SCOPE

A waste is an unwanted substance or a mixture of unwanted substances that result

from the construction, operation or reclamation of an oilfield facility. The waste

streams need to be identified and documented in order to prepare a management

plan. From this list, specific techniques will be developed in order to ensure

compliance to corporate and regulatory requirements.

C. PROCEDURES

1. A waste audit is an evaluation of all steps of the operation to determine where

waste is created. A waste audit is performed to identify all waste sources and

streams. This audit is a physical inspection, reviewing operating procedures,

disposal records and documentation. The criteria on which the audits are

performed are base industry standards. Copies of facility audits should be

retained on-site.

2. Waste Audits may be performed by company employees or by third-party

auditors utilizing the same format for all facilities. An audit report should be

produced for each facility. Copies of these reports should be maintained at the

facilities as well as at the corporate office.


Balzac Gas Plant 2.2: CHARCTERIZATION AND CLASSIFICATION

A. INTRODUCTION

This section assesses the properties of the waste to determine its waste type. All

wastes will be classified as a Dangerous Oilfield Waste (DOW) or a non-

Dangerous Oilfield Waste (non-DOW).


Under the requirements of EUB G-58, all wastes require assessment as to its

physical, toxicological and chemical characteristics. These properties will

determine the waste’s classification. All wastes and waste streams must be

classified.

These classifications will be used for manifesting, tracking, record keeping,

storage, disposal and transportation requirements.

This will ensure compliance with the Alberta waste regulations.

C. PROCEDURES

1. Identify the waste or waste stream [See Section 2.1: Identification]

2. Determine physical, toxicological or chemical properties using analytical

techniques. These techniques are detailed in Section B of Guide G-58.

3. Alternatively, the waste name may be referenced in either the CAPP Waste

Management Handbook, or Guide G-58.

4. Classify the waste as a DOW or a non-DOW. Company personnel should

document theses waste names, characteristics and classification for reference.

There are a number of properties that will be used to classify a waste as DOW. These

properties are derived form the TDG regulations and are outlined as follows:

Flammability – flash point less than 61°C

Spontaneous combustion – auto ignition

Waste incompatibility

Toxic – oral, dermal, or inhalation

Corrosivity – pH less than 2.5 and over 12.5

Leachate toxicity – Alberta Tier 1 Metals / BTEX

PCB content – over 50mg/kg


Balzac Gas Plant 2.2: CHARCTERIZATION AND CLASSIFICATION

As can be seen, it is imperative to know the characterization of a waste before it can be

classified. All wastes have to be classified as a DOW or a non-DOW. Once a material

has been classifies, certain requirements must be met, such as:

A DOW must be manifested and a non-DOW does not

A DOW will require TDG placarding and a non-DOW does not

All DOWs and non-DOWs have to be tracked

Etc.


Balzac Gas Plant 2.3: HANDLING

A. INTRODUCTION

This section details the procedures necessary for proper waste handling.


Waste handling is an issue that field personnel require training for. Knowing how

to correctly handle DOWs involves safety issues.

It is important to know the properties of the wastes being handled. Waste

segregation should be employed to ensure that DOWs and non-DOWs are not

commingled. This is done for two reasons: the first safety. The safety

procedures should be consulted to ensure that the correct clothing and safety

equipment is used. The MSDS sheets should also be consulted. This is especially

true when dealing with chemicals or flammable material.

The second reason wastes should not be commingled is for economic

considerations. As DOWs are usually more expensive to dispose, it is important

not to increase their volume. Any wastes that are in contact with a DOW will

have to be classified as a DOW. This will increase the disposal volume as well as

the cost.

The proper storage of waste is another important handling consideration. This

issue is dealt with in Section 5.0: Storage.

C. PROCEDURES

1. Identify (Section 2.1 Identification).

2. Characterization and Classification (Section 2.2 Characterization and

Classification).

3. Consult Material Safety Data Sheets (MSDS) for proper handling and safety

procedures (where applicable).

4. Consult EUB – Guide G-58.

5. Consult Alberta Environmental Protection (AEP) – Waste Handlers Guide.

6. Consult CAPP – Waste Management Guidelines.

Transportation

Comply with the transportation requirements as detailed in the Transportation of

Dangerous Goods Regulations (TDGR).


Balzac Gas Plant 2.4 TREATMENT

A. INTRODUCTION

This section details the procedures followed in on-site and off-site waste

treatment prior to, or in place of disposal.


Treatment of wastes is undertaken for several reasons. The first reason is the

reduction of the waste volume. By reducing the volume of waste required for

disposal thereby reducing the cost. Secondly, some DOWs may be treated so as

to change its classification to a non-DOW, resulting in saving in disposal costs.

Lastly, treatment may be used as an alternative to, or in conjunction with disposal.

C. PROCEDURES



Classification).





6. Investigate industry recognized treatment alternatives, such as:

On – site treatment:

Treating spill sites instead of removing material

Land farming flare pit material

Draining fluids from filters before disposal

Neutralizing acids or caustics

Filtering oils and glycol for reuse

Off – site treatment:

Removing liquids from sludge to reduce volumes

Reclaiming oil from sludge prior to disposal at a waste plant

Cleaning and re-using crank case oil by a third party

Cleaning filter mediums such as charcoal and re-using

Recovering gold and silver from tower trays for reuse

On-site treatments, apart from land farming and bioremediation, are not required

to be included in the EUB Annual Report. Any treatment that can re-use a waste

or can reduce a volume is usually cost effective.

Facilities should carefully consider all alternatives before deciding on an option.

Some wastes that are small in volume may not be cost effective to treat.


Balzac Gas Plant 2.4 TREATMENT

All treatment programs should be well documented and initiated after discussion

with the appropriate governing agencies.


Balzac Gas Plant 2.5 DISPOSAL

A. INTRODUCTION

This Section defines waste disposal requirements as stipulated in Guide G-58.


To ensure compliance to regulations, proper disposal procedures need to be

defined for all wastes identified by Section 2.1.

There are rules in Guide G-58 that stipulate where a waste must be disposed of.

Theses are based on the type, and classification of waste. It is imperative that the

company personnel are familiar with the regulations. The incorrect disposal of

wastes could result in fines, both for the company and the individual. Jail terms

may also result if it can be shown that a willful act took place.

C. PROCEDURES



Classification).





6. Verify transporter compliance to TDG regulations.

7. Select proper disposal options from site-specific waste management plan or

Guide 58.

Waste disposal options include but are not limited to:

Landfills (municipal, industrial, and oilfield)

Thermal treatment

Swan Hill waste treatment facility

Deep well disposal

Waste management facilities

Biodegradation

On-site disposal (small volume incinerators, etc.)

Cavern disposal

Recyclers

Out of province or country facilities

Verify the conditions and approvals as listed on the waste receiver’s license to

ensure the correct disposal option has been chosen. It is the waste generators

responsibility to confirm the receiver’s license conditions. Conducting audits of

the transporters and waste receivers is one method of ensuring that compliance is

met.


Balzac Gas Plant 2.5 DISPOSAL

Audits may be performed by company personnel or by a third-party auditor.

Audit reports should be maintained at the field offices. An industry-standard

format should be utilized in conducting these audits.

Audit reports should be maintained for a minimum of two years or until the

contractor’s subsequent audit.


Balzac Gas Plant 2.6 TRACKING

A. INTRODUCTION

This policy defines the Tracking and Record Keeping requirements as they

pertain to proper waste management.


Guide G-58: Section C clearly defines the requirements for generators of oilfield

wastes in Alberta. An integral component of proper waste management is the use

of documentation. This documentation refers to a system by which the handling,

movement, treatment and disposal of wastes are monitored by the waste

generator.

Generators will be required to complete EUB Waste Manifests for all DOWs

transported and disposed within the province. Out of province disposal will

require separate TDG manifests as do wastes destined for the Sawn Hills Waste

Treatment Facility.

Generators are also required to implement an electronic tracking system that

ensures that the quantities, and characteristics of all those specified wastes, both

DOW and non-DOW as well as their final treatment methods are known and

documented.

An accurate record-keeping system is necessary to fulfill these requirements.

C PROCEDURES

Manifesting

1. Identify (Section 2.1: Identification)

2. Characterization and Classification (Section 2.2: Characterization and

Classification)

3. Consult EUB – Guide G-58

4. Refer to Section 3.0: Manifesting

5. Refer to Site specific Waste Management Plan

Once the manifests are returned from the receiver, ensure that Pages 1 and 2 are

filled out completely. Return page 1 to the EUB in Calgary and attach copy 2 to

copy 5 and place into a waste-tracking file.

Table 9.1 – Oilfield Waste Management Requirements for the Upstream Oil and Gas

Industry

Reportable Oilfield Wastes

All DOWs must be included in the annual oilfield waste disposition report. Additionally,

the following oilfield wastes that may or may not be dangerous, must be included in the



report. Non-DOW that are not included in this list, but are specified in the Waste

Management Table, Section 7.4 of Appendix 7.0 are exempted from the waste disposition

report unless they are determined to be dangerous.

This list is only for the annual oilfield waste disposition report requirements. It is not

intended to be used for the classifying of oilfield wastes.

Absorbents

Activated Carbon

Asbestos

Boiler blowdown water

Catalyst (non sulphur)

Catalyst (sulphur)

All Contaminated Debris and Soils

Crude oil Condensate Emulsions (Residuals after treatment)

Desiccant

Filters (media) water treatment

Filters – air pollution control

Filters – lube oil

Frac Sand (radioactive and non-radioactive)

Glycol Solutions (no heavy metals)

Hydraulic and Transmission Oils

Incinerator Ash (if incinerator material is reportable)

Ion Exchange Resin

Ion Exchange Resin Regenerant Liquids

Lubricating Oil

Pigging Waste

Contaminated solids less than 50ppm Polychlorinated Biphenyls (PCBs)

Produced Sand

Sludges þ (flare pit, hydrocarbon, lime, process, and Sulphur)

Sweetening Agents þ (solids and liquids)

Treater Hay

Wash fluids (organic)

Water-Process (with organic chemicals)

Water-Process (neutralized solutions with heavy metals)

Water-Produced (if contaminants are present which make the solution a DOW)

Well Workover Fluids

Wood – chemically treated/cooling tower

Unlisted wastes (if they present a risk to the environment or the public)

Waste Tracking Sheet Requirements

The operator is required to track waste disposal information for all wastes

produced on the lease. This includes all wastes produced by drilling and servicing

contractors – such as: lube oil, glycol, filters, rags, absorbents, etc. The CAODC and

CAPP have agreed that the contractors will ensure proper disposal of all wastes that they



create on the lease. However the AEUB requires that the waste disposal information be

recorded and tracked by the operator. The operator is defined as the “Waste Generator”

for all wastes created in the development of operation of their properties or facilities.

Therefore, the drilling and servicing companies must provide the Operator or Operator’s

representative (Consultant) with the waste disposal details when wastes are disposed.



Facility Name:___________________________________________ Location: ___________________________

Reporting Dae: _______________________, 20____

Manifest

Number

Date

Shipped

Waste Name

[Waste Code]

Class

[D or N]

Volume

(units)

Transporter

Reciever


Balzac Gas Plant 2.7 RECORD KEEPING

A. INTRODUCTION

This policy defines the Record Keeping requirements as they pertain to proper

waste management.


Guide G-58: Section C clearly defines the requirements for generators of oilfield

wastes in Alberta. An integral component of proper waste management is the use

of documentation. This documentation refers to a system by which the handling,

movement, treatment and disposal of wastes are monitored by the waste

generator.

Generators will be required to complete EUB Waste Manifests for all DOWs

transported and disposes within the province. Out of province disposal will

require separate TDG manifests as do wastes destined for the Swan Hills Waste

Treatment Facility.

An accurate record-keeping system is necessary to fulfill these requirements.

C. PROCEDURES

Record Keeping

Waste generators are required to maintain an accurate electronic and physical

record of all DOWs and non-DOWs produced and disposed. These records are

maintained on a facility-by-facility basis, as well as at the corporate level.

The record keeping system must contain at least the following information:

1. Waste Tracking System

company operator code (EUB)

facility code (EUB)

point of waste generation / disposition

point of waste consolidation

waste (EUB Guide G-58: Appendix 7.0)

total quantity disposed (units: m³ or tones)

waste receiver information (company name, facility code, location, etc.)

disposal methods employed (such as: waste processing facility, disposal

wells, landfills, biodegradation facility, thermal treatment, used oil

recycler, recycling facility, Swan Hills Waste Treatment Facility, small

volume incineration, on-site biodegradation, road spreading, on-site burial

or other disposal methods)

Discrepancy reconciliation

Waste Reports (monthly, quarterly, annual, etc.)

2. Copies of the EUB manifests.



3. Employee training records

4. Waste receiver licenses and approvals

5. Waste minimization initiatives

6. Documentation of on-site treatment

7. Copies of transporter TDG certification

8. Contractor (i.e. waste receivers, transporters, waste brokers, etc.) audit /

inspection reports if completed

9. Copies of third-party waste agreements (Hazco, RB Williams, etc.)

Facilities are required to maintain these records on an individual basis. These records

must be kept for a minimum of 2 year. This will be the responsibility of the Facility

foreman or supervisor. It will be the responsibility of the environmental analyst to

prepare the quarterly, semi-annual, and the annual report.



Waste Inventory

When a waste bin, container or tank is being used an inventory should be kept for

each. This may be achieved by completing the attached Tank Inspection Sheet.

A separate line should be completed for each bin, container or tank.

Heading Description

Company Name Name of Operator/Waste Generator.

Date Date of Inspection – when worksheet is completed.

Location LSD of lease.

Contents Contents of the bin or compartment.

Fill Level Estimate the level of material in the bin.

Capacity Total capacity of the tank, bin or compartment – may be

obtained from bin supplier.

Cont. Condition Are there holes, cracks, etc. In the bin – walk around

physically inspect the bin, containers, etc.

Berm. Condition Are there holes, cracks, etc. in the berm – walk around to

physically inspect berm.

Comments Any additional comments regarding the storage containers.

Inspector Initials Initials of the person who completed the inspection.



Facility Name & Location: ___________________________________________

Date Tank

No.

Contents Fill Level Capacity Container

Condition

Berm

Condition

Comments Inspec.

Initials

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break

E ¼ ½ ¾ F Good

Leak

Good

Break


Balzac Gas Plant 3.0 MANIFESTING

A. INTRODUCTION

This Section defines the manifesting requirements as set by the EUB.


Contained Within the EUB Oilfield Waste Management Requirements for the

Upstream Petroleum Industry is the requirement for manifesting wastes

transported within Alberta. These manifests apply to waste generated, transported

and disposed within Alberta. This manifest will meet the TDG Requirement in

these instances.

All Dangerous Oilfield Waste transported from generator to receiver within

Alberta will be manifested using this new manifest. Non-DOWs do not have to

be manifested. These manifests are available from the EUB.

C. PROCEDURES

The waste manifest form you use is shown as an example on the next page. This

form conforms to Federal and Provincial regulations requiring manifesting.

MANIFEST Distribution

Step Action

1. GENERATOR completes part A.

2. TRANSPORTER completes part B.

3. GENERATOR detaches and retains page 5.

4. TRANSPORTER carries pagers 1,2,3 and 4 with shipment and

delivers them to receiver.

5. RECEIVER completes part C, noting any discrepancies, then gives

page 4 to Transporter, returns pages 1 & 2 to Generator within 30

days of the shipping date and retains page 3.

6. GENERATOR completes part D and submits completed page 1 to

EUB’s Environment Protection Department within 60 days of

shipment date. GENERATOR attaches page 2 to page 5 and files.

GENERATOR investigates any discrepancies noted by receiver and

takes corrective action.



EUB Manifest Preparation

The following table describes the fields in the EUB Alberta Oilfield Waste

Manifest. Part A – Generator (Consignor)

Field .

Company Name

Operator Code

Business Address

Source Location

Intended Receiver

N or D

Shipping Name

Waste Code

TDG/PIN and Classification

Packing Group

Alberta Permit Number

Quantity Shipped

Units

Oil/Water/Solid %

Description .

Name of the waste generating company.

AEUB assigned code of facility from which

the waste is being shipped.

Address to which the manifest (and

invoicing) would be sent.

LSD, Battery/Facility Code, and Facility

Operator Code (may be different from

above operator code).

Name of Waste Receiver to which the

waste is sent. Included is the waste

receivers Business Address, Receiving Site

Location and Receiving Batter/Facility

Code (EUB or AEP assigned codes)

N = non-DOW and D = DOW

Waste Description (from Waste

Management Chart)

EUB assigned codes (Waste Management

Chart)

Obtained from TDG

I – Very Dangerous

II – Dangerous

III – Moderately Dangerous

Obtained from Transportation and Utilities

Report to the nearest 0.1m³ or 0.1 tonne

t = tonne m = m³

Specify value where applicable



Field .

Special Handling/

Emergency Instructions

Date, Time Shipped,

Scheduled Arrival Date

Name, Telephone No., 24

Hour Emergency Telephone

No. and Sign

Part D – Generator

Consignor:

Field .

Discrepancy Reconciliation

Details

Corrective Action

Name, Date, Telephone No.

and Sign

Description .

Self Explanatory

Self Explanatory

Self Explanatory

Description .

Note any discrepancies (if any) between the

waste details that were shipped and those

that were received. If any serious

discrepancies are noted, immediately notify

the EUB

Describe any corrective action taken.

Self Explanatory

Notes:

If some portions of the manifest are not able to be completed when the waste is

shipped, leave those portions blank. When the manifest is returned form the

receiver, the remaining sections can be completed then. For example, if the

receiver codes are not known, leave them blank (in Section A) and fill them in

once the receiver has filled in Section C.

Complete enough of the manifest to ensure the TDG requirements are met. The

EUB required data only has to be complete on page 1 when it is sent in to the

EUB Office.



3.2 EUB HANDLING CODES

Code Disposal Description

01 Storage Facility

02 Transfer Station (Specify intended treatment / disposal)

03 Oilfield Waste Processing Facility

04 Class Ia Disposal Well

05 Class Ib Disposal Well

06 Class II Disposal Well

07 Cavern

08 Class Ia Landfill

09 Class Ib Landfill

10 Class II Landfill

11 Class III Landfill

12 Thermal Treatment

13 Biodegradation Facility

14 Small oilfield Waste Incinerator

15 Used Oil Recycler

16 Recycling Facility (excluding Used Oil)

17 Swan Hills Facility

18 Road Spreading

19 Biodegradation (On-site)

20 Burial (On-site)

21 Other (specify)

3.3 OTHER MANIFESTS

Swan Hills Waste Treatment Facility Manifest

There is a specific manifest required to ship waste to this facility. This manifest

and the instructions for use may be obtained from Chem. Security or Alberta

Environmental Protection. This manifest is provided by the third party waste

management brokers such as: Hazco, WasteCo or RB Williams. This manifest is

referred to as the federal / provincial waste manifest. If this manifest is used, the

facility must have a waste generator number from Alberta Environmental

protection.



Out of Province Wastes

The shipping manifest must meet the federal TDG Regulations. These manifests

may be obtained from the third party waste management brokers. The company

must receive a copy showing the final disposition of the waste within 30 days of

the shipping date. This manifest does not have to be submitted to the EUB,

however, the waste details must be retained and reported in the annual report.

Alberta Environmental Protection requires a copy of the completed manifest. The

company is responsible for ensuring that this is performed. The completed

manifest may be submitted by the waste broker or by the generator. This manifest

must by submitted to Alberta Environmental Protection within 2 days after

shipping. The waste broker usually does this for the generator.

Hazardous Recyclables

A Hazardous recycle docket may be used in place of a waste manifest, for all

products listed as hazardous recyclable. This waste must however, still be tracked

and included in the annual EUB report. Used lube oil is an example of a

hazardous recyclable.



Alberta Waste Management Table



Waste Name [WASTE

CODE]

EUB tracking

Waste

Class

(N or D

Required

Document

TDG PIN TDG

Class

Packing

Group

Criteria Treatment Storage Disposal Option

Absorbents

[OILABS]

Tracking

N-DOW Bill of Lading N/A N/A N/A Flashpoint,

Leachate

Drain and recover any free

liquids

Cover, labeled container Recycle or Landfill – Class II.

Aerosols

(Empty)

[EMTCON]

Not Tracked

N-DOW N/A UN 1950 2.1 N/A Flammable Invert can and remove all

contents prior to storage and

disposal.

Store in covered container.

Keep away from heat or

combustion sources

Ensure container is empty and

landfill.

Batteries

(Dry cell)

[BATT]

Not Tracked

N-DOW Bill of Lading N/A N/A N/A KOH or NI-Cd

content

Place in general refuse

containers

Recycle or Municipal Landfill.

Batteries

(Wet cell)

[BATT]

Tracking

DOW Manifest UN 2794 8 III Corrosivity,

leachae (heavy

metals)

Remove and neutraliz fluids,

handle container and fluids

separately.

Store in covered container.


combustion sources

-Recycle via battery recycler.

-Dispose container at approved

Class Ia, Ib or II landfill.

Boiler Blowdown Water

[BLBDWT]

Tracking

N-DOW Bill of Lading N/A N/A N/A Heavy Metals

(Cr, V or other)

Neutralize pH. Release to

surface if material meets Surface

Water Discharge Criteria (EUB

G-55

Store in a corrosive resistant

container (fiberglass, etc.)

Reuse, Neutralize pH, surface

discharge, disposal well.

Contaminated Debris

(Crude/Condensate)

[SOILCO]

Tracking

N-DOW Bill of Lading N/A N/A N/A Flashpoint

(Residual

Hydrocarbons

Remove any free liquids prior to

disposal

Store on a covered, lined pad

until disposal

On-site bioremediation or Waste

Treatment Facility or landfill.

Contaminated Soil

(Produced Water)

[SOILPW]

Tracking


(Residual

Hydrocarbons)

Remove any fee liquids prior to

disposal


until disposal

Waste Treatment Facility, or

landfill at approved Class Ia, Ib

or II facility.

Contaminated Debris

(Refined Oil/Fuel)

[SOILRO]

Tracking

DOW Manifest 3175 4.1 II Flashpoint

Leachate

Remove an free liquids prior to

disposal.

Sore on a covered, lined pad

until disposal



Contaminated Soil

(Sulphur)

[SOILPW]

Tracking

N-DOW N/A N/A N/A N/A Not TDG

Regulated

On-site Treatment may include

lime addition to neutralize.

Store in covered container prior

to disposal.

Material may be taken to an

approved Class II or higher

landfill.

Descicant [DESICT]

Tracking

Testing

Required

Manifest or Bill

of Lading

Corrosivity,

flashpoint,

leachate

Drain and recover free liquids Store in covered container.


combustion sources.



landfill.

Domestic Garbage

[DOMWST]

Not Tracked

N-DOW N/A N/A N/A N/A Municipal Landfill Municipal Landfill

Drums/Barrels

(Methanol, oil, etc.)

[EMTCON]

Not Tracked

N-DOW Bill of Lading TDG ma be

dependent on

previous contents

Return to vendor

Recycle

Landfill

Empty, Store covered to prevent

access to elements

-Return to vendor

-Recycle

-Approved Industrial Landfill



Waste Name [WASTE

CODE]

EUB tracking

Waste

Class

(N or D

Required

Document

TDG PIN TDG

Class

Packing

Group


Filters

(Fuel Gas)

[FILOTH]

Tracking

DOW Manifest UN 1202 3

(4.2)

(9.3)

II Flashpoint,

Pyrophoric,

leachate

Drain and collect liquids.

Liquids should be Recycled

Deep well Disposed – Ia or Ib

Store filters in a covered sealed

container, away from sources of

heat or spark

Drain (24 hours) and crush –

Class Ia or Ib landfill

Filters

(Glycol)

DOW Manifest UN 1325 4.1 Flashpoint,

phyrophoric,

leachate

Drain and collect liquids.

Liquids should be Recycled

Deep well Dipsoed – Ia or Ib

Store filters in a covered sealed


heat or spark.

Recycle, Landfill at Class Ia, Ib

or II facility, thermal treatment

Filters

(Lube oil, UNDRAINED)

[FILLUB]

Tracking

N-DOW Recycle Docket NA 9500 9.3 III Leachable Toxic Drain and crush Store filters in a covered sealed


heat or spark

-Recycle

-Incinerate


Filters

(Gas Sweetening, Amine, Sulphinol)

[FILSWT]

Tracking


Phyrophoric,

leachate

Drain and contain free fluid.

Fluids are DOW. Recycle filters

(metal)

Store in an air tight container,

away from sources of heat or

spark

Thermal treatment,

containerized waste ma be

disposed at Class Ia, or Ib

landfill

Filters

(Produced water)

[FILPWT]

Tracking


phyrophoric,

leachate

Drain to remove free liquids. Store filters in a covered sealed


heat or spark.

-Recycle

-Incinerate


Grease Cartridges [EMTCON]

Not tracked

N-DOW N/A N/A N/A N/A Store with general refuse. Landfill Municipal

Glycol Solutions

(Heavy metals – Waste Type 202)

[GLYCHM]

Tracking

DOW Manifest NA 9500 3

(9.3)

III Flashpoint,

Toxicity

Do not mix waste with other

materials (i.e. lube oil)

Store in a covered sealed

container, way from sources of

heat or spark

-Return to supplier.

-Recycle through Waste Broker

-Dispose of at Swan Hills

Glycol Solutions

(No heavy metals)

[GLYC]

Tracking

N-DOW

(Testing)

Recycle Docket NA 9500 3

(9.3)

III Flashpoint

Toxicity

Do not mix waste with other

materials (i.e. lube oil)


container, away form sources of

heat or spark

-Return to supplier.

-Recycle through Waste Broker.

Lube Oils

(Waste type 201)

[LUBOIL]

Tracking

N-DOW Recycle Docket NA 9500 9.3 III Leachable Toxic Do not mix waste with other

materials (i.e. glycol, etc.)



heat or spark

-Return to supplier

-Recycle through a Waste

Broker

Oily Rags

[OILRAG]

Not Tracked

N-DOW Recycle Docket N/A N/A N/A Not TDG

regulated unless

contaminated

with a DOW

Remove all free liquids prior to

disposal

Store material in a covered,

sealed container.

-Recycle

-Remove free liquids and

landfill

Metal

(Scrap)

[SMETAL]

Not Tracked

N-DOW Bill of Lading N/A N/A N/A Store away from other wastes to

prevent contamination

Recycle

Methanol

[METHNL]

Tracking

DOW Manifest UN 1230 3.2

(6.1)

II Flashpoint,

Toxicity

Reuse material in other

processes



heat or spark

Reuse, Recycle, Disposal Well



Waste Name [WASTE

CODE]

EUB tracking

Waste

Class

(N or D

Required

Document

TDG PIN TDG

Class

Packing

Group


Paint

(Wet Paint)

[WPAINT]

Tracking

DOW Manifest UN 1263

(flammable)

UN 3066

(corrosive)

3

8

II

II

Flashpoint,

Corrosivity

Remove lid and allow paint to

dry out. Once dry the waste is

considered an “empty container”

and may be treated as such.

Store material in a sealed

covered container to prevent

access by the elements.

Thermal Treatment, Recycle,

Toxic Round-up (sm. Volume

Paint

(Cans and brushes)

[WPAINT]

N-DOW Bill of Lading N/A N/A N/A Remove lid and allow contents

to dry out



access by the elements

Dispose dry material in a landfill

Pipe Dope Containers

(Lead and non-Lead)

[EMTCON]

Not Tracked

N-DOW N/A N/A N/A N/A Not a DOW if

empty and dry

Open container and allow

contents to dry out.



access by the elements.

Dispose material at an approved

Class Ia, Ib or II landfill.

Sludge (Flare Knock-out)

[SLGGLY]

Tracking

DOW Manifest NA 9500 3

(9.3)

II Flashpoint,

Leachate,

Pyrophoric

Remove and collect all free

fluids prior to disposal.

Store material in a covered

container to prevent access to

the elements. Store away from

sources of spark or flame.

Free fluids should be deep well

disposed. Solids should be

treated and then landfilled.

Sludge

(Flare Pit)

[SLGPIT]

Tracking

DOW Manifest UN 3175 4.1 II Flashpoint,

Leachate,

Toxicity


fluids prior to disposal



the elements. Store away from





Spill Material (Produced water)

[SOILPW]

Not Tracked

N-DOW Bill of Lading N/A N/A N/A Not a TDG

regulated waste


fluids prior to disposal.



the elements. Store away form





Contaminated Soil

(Produced Water)

[SOILPW]

Tracking


(Residual

Hydrocarbons)

Remove any fee liquids prior to

disposal


until disposal

Waste Treatment Facility, or

landfill at approved Class Ia, Ib

or II facility.

Contaminated Debris

(Refined Oil/Fuel)

[SOILRO]

Tracking

DOW Manifest 3175 4.1 II Flashpoint

Leachate

Remove an free liquids prior to

disposal.

Sore on a covered, lined pad

until disposal



Contaminated Soil

(Sulphur)

[SOILPW]

Tracking

N-DOW N/A N/A N/A N/A Not TDG

Regulated

On-site Treatment may include

lime addition to neutralize.

Store in covered container prior

to disposal.



landfill.

Descicant [DESICT]

Tracking

Testing

Required

Manifest or Bill

of Lading

Corrosivity,

flashpoint,

leachate

Drain and recover free liquids Store in covered container.


combustion sources.



landfill.

Domestic Garbage

[DOMWST]

Not Tracked

N-DOW N/A N/A N/A N/A Municipal Landfill Municipal Landfill

Drums/Barrels

(Methanol, oil, etc.)

[EMTCON]

Not Tracked

N-DOW Bill of Lading TDG ma be

dependent on

previous contents

Return to vendor

Recycle

Landfill

Empty, Store covered to prevent

access to elements

-Return to vendor

-Recycle




*Note

- Treated Wood, such as fence post’s and lumber, as long as they are not

contaminated, are a non-trackable waste.

- Contaminated wood is manifested as “Contaminated Debris”. It could be

contaminated b any of the following, and should be manifested as such:

Crude / Condensate – [SOILCO]

Produced Water – [SOILPW]

Refined Oils – [SOILRO]


Balzac Gas Plant 4.0 MINIMIZATION

A. INTRODUCTION

This Section describes the policy for the minimization of waste.


The purpose for implementing a minimization policy is three-fold; reduction of

costs, reduction of liability and compliance to regulations. The first step in

managing waste is through realization and implementation of the 4-R’s are:

Reduce

Reuse

Recycle

Recover

C. PROCEDURES

Reduce Generate less waste through more effective practices

Cost savings – less waste to dispose of

Reduction in liability – less wastes means reduced liability in case

there is an adverse environmental impact involving your waste

Safety – less waste to handle (especially DOWs) means less worker

exposure

Environmental – less chance of impacting the environment

Some of the more effective practices are:

Substitute non-hazardous products for hazardous ones in order that the

waste streams by non-DOW

Segregate DOWs from non-DOWs as all waste contaminated with a

DOW will become a DOW and increase the volume of DOWs

Segregate wastes into recyclable and non-recyclable categories to

reduce the disposal costs and to facilitate recycling

Purchase products in larger quantities to reduce the amount of

containers whenever possible

Eliminate spill and leaks through proper equipment inspection and

handling procedures

Reuse: Generate less waste through reuse of materials

Some of the more effective practices are:

Return containers to the supplier

Return used lube oils to the supplier

Use of used oils for other purposes


Balzac Gas Plant 4.0 MINIMIZATION

Recycle: Minimize treatment and disposal of waste by utilizing recycling

Facilities

Some of the more effective practices include recycling the following

materials:

Rags

Sorbent material

Lube oils

Metals

Paper and cardboard

Plastic

Containers

Batteries

The plants also recycle their used filters, by sending them to RB Williams

which recycle almost all parts of the filter.

Recover: Recover useful components of a waste including energy content

This is the most difficult of the 4-R’s to implement. Some of the more

effective practices are:

Use of lube oils as boiler fuel

Recovery of hydrocarbons at a waste management facility

Recovery of metal cores from filters

Recovery of gold and silver from tower trays


Balzac Gas Plant 5.0 STORAGE REQUIREMENTS

A. INTRODUCTION

All storage tanks used in the Upstream Petroleum Industry are under the control

of the AEUB Guide G-55 Guidelines. These guidelines direct the use, testing and

monitoring of Above Ground Storage Tanks (ASTs), Underground Storage Tanks

(USTs) and Container Storage.


This practice applies to new and existing facilities. For more detailed information

refer to the G-55 Storage Guidelines.

All wastes must be properly stored, so as to prevent:

Leaking

Spilling

Contact with incompatible wastes

Contact with the environment

Creating a hazard to humans and livestock and wildlife

Mixing of DOW and non-DOWs

Creating a safety hazard

C. REQUIREMENTS

Aboveground Storage Tanks

Construction

Volume 1m³ to 5m³

The tank must have non-leaking hoses, fittings and nozzles. There is no

secondary requirement; however, it is a good idea to install a liner or tray

under the tank at the time of construction. This will contain any spills

should they occur.

As well, a drip tray should be installed around any filling areas to contain

any leaks, spills or over-fills.

Volume >5m

The tank must have cathodic protection (steel tanks in corrosive

environments) and all steel tanks must be externally coated (also internal

coating in a corrosive environment)

The tank(s) must be placed in a lined and bermed area. The liner must be

impervious to the materials being stored as well as to water. The

hydraulic conductivity must be at least 1 x 10-6

cm/s.



The diked area must be graded such that there is one low corner to

facilitate clean-up and water removal.

The dikes must be large enough to contain 100% of the volume of the tank

(where only one tank is present) or 110% of the largest +10% of each

remaining tanks contained within the same tank area. This extra 10% per

tank is to facilitate the displacement the tanks present to overall volume.

Inspections

All Aboveground Storage Tanks required a monthly visual inspection.

This inspection includes a physical walk around the tank(s) and tank area

to inspect for leaks, blowovers, etc. Any spills, leaks, overfills, etc must

be documented.

The berm must be inspected to ensure there are no breaks and that the dike

drain (if present) is closed.

Storage Areas / Barrel Docks

Construction

When the total stored volume of the storage area is greater than 1m³ (5 –

45 gallon drums), the following conditions must be met as per EUB Guide

55):

Secondary containment – a clay or synthetic liner, impervious to

the stored material, which prevents a direct connection to the

ground underneath or the surrounding area.

Weather protection – a cover or roof to prevent exposure to the

elements. Alternatively, use of weather resistant containers is also

appropriate.

Inspections

The storage area must be visually inspected monthly. This inspection

must include a physical inspection of the lined / bermed area, ensuring that

the liners is intact; the storage containers must not be leaking; and the

surrounding area must not show signs of a spill.

All monthly inspections must be documented. This may be done in an

operator’s log book or in a specific Inspection Form. The records of these

inspections must be retained for a minimum of two years. The EUB may

request these records when performing a facility or waste audit.



Underground Storage Tanks

Construction

All USTs constructed after January, 1996 must have secondary

containment. This is not a retroactive regulation where all tanks have to

meet this regulation, only those installed after January 1996.

The secondary containment requirements may be met by utilizing one of

the following methods:

Synthetic liner (External or internal tank liners)

Double-walled tanks

Concrete vault

Etc.

Whenever a UST is exposed for testing or repair, it must be brought up to

regulation.

Underground storage tank vents must be checked to ensure that they are

not over-flowing (e.g. flare-knockout tanks, etc.)

D. TANK INTEGRITY TESTING

Aboveground Storage Tanks (ASTs)

Testing

All storage tanks used in the Upstream Petroleum Industry must have their

integrity verified prior to October 31, 2001.

The following test types are approved methods for verifying the integrity

of the tanks:

Air Pressure Test

Air Vacuum Test

Hydrostatic Test

48 Hour Volumetric Test

Other tests if they are approved by the EUB

Once the tank has had its integrity verified, the records of the test must be

retained a minimum of five years. The tank must be checked every 3

years thereafter.



Monitoring

The integrity of the tank must be verified to demonstrate that the material

has not escaped. This verification may be demonstrated in the following

ways:

Monthly visual inspections of tanks and liners for evidence of

spills.

Incorporation of a weeping tile system, which is monitored

monthly.

Documentation

All records of tank integrity verification and monitoring should be retained

at the field or area offices. These records should be retained for a

minimum of five years.

Underground Storage Tanks (USTs)

Testing

All storage tanks used in the Upstream Petroleum Industry must have their

integrity verified prior to October 31, 2001, and every 3 years thereafter.

In order to comply with this requirement, the validity of every tank will be

verified using one of the following tests:

Integrity Testing (if tank can be blinded)

Air Pressure Testing

Air Vacuum Testing

Hydrostatic Testing

Other EUB approved testing procedure

Integrity Testing (if tank can not be blinded)

Volumetric test

Monitoring wells (dedicated to the tanks)

Other EUB approved testing procedure

If a UST is excavated and/or removed for repairs, it must meet the G-55

guidelines in order to be returned to service.

Monitoring

All USTs must be monitored regularly to ensure their integrity. This may

be achieved in one or more of the following methods:

A monitoring well located between the synthetic liner and the tank.

The well should be situated at the low end of the sloped liner. The

well should be sampled monthly.

Annual monitoring of the interstitial space of the double walled

tanks.



Monthly monitoring of a weeping tile system.

Integrity verification

All records of tank integrity verification and monitoring should be retained at the

field or area offices. These records should be retained for a minimum of three

years.

Containers

Separate storage bins or barrels should be set up for aerosol containers, paint cans,

pipe dope containers, and any other such containers that can be collected and

disposed of at a Class 1a, 1b or Class II landfill.


Balzac Gas Plant 6.0 WASTE MANAGEMENT FACILITIES

EUB APPROVED LANDFILLS

Anadime Processing and Disposal Inc

430, 1015 – 4 St. SW

Calgary AB

T2R 1J4

(403) – 777-4310

Anadime Elk Point

Location: 4-18-57-4 W5M

EUB Approval No: WM 045

Anadime Hays



Anadime Niton Junction



Upstream oilfield waste liquids and solids, DOW and non-DOW including sour fluids.

Processing of drilling wastes, completion fluids, production fluids and solids, workover

fluids and solids, spill materials, pit and pond fluids and solids and pipeline fluids.

Facility has a Class Ib disposal well for disposing of glycols, amines, inhibitors and wash

waters. Not permitted to receive lube oil or refined products such as gasoline or

industrial wastes. Have interim license for invert drill cuttings (expected June/99).

Anadime Provost



Anadime Stettler





Area 1 Reclaiming Ltd

21369 Highway 38

Box 646

Redwater AB

T0A 2W0

(403)-875-7752

Area 1 Redwater



Canadian Crude Separators

2400, 530 – 8Ave SW

Calgary, AB

T2P 3S8

(403)-233-7565

Canadian Crude Separators Big Valley

CCS

Box 221

Big Valley, AB

T0J 0G0

Phone: (403)-876-2636

Fax: (403)-846-2248

Plant Manager: Kelly Shanks

Facility Code: 653



Big Valley Waste Management Facility Acceptable Waste Streams:

All waste streams compatible with Class 1b disposal well as per Alberta Energy and

Utilites Board Guide G-51 (Injection and Disposal Wells). Select upstream oilfield waste

as per Alberta Energy and Utilities Board Guide G-58 (Oilfield Waste Management

Requirements for the Upstream Petroleum Industry).

Canadian Crude Separators Coronation

CCS c/o Coronation Tire

4901 Victoria Avenue

Coronation, AB

T0C 1C0

Phone: (403)-575-3911



Fax: (403)-575-3927

Plant Manager: Mark Zimmer



Facility Code: 654

Canadian Crude Separators Brazeau

Phone: (780)-894-2291

Fax: (780)-894-2296

Location: 11-3-47-11- W5M


Facility Code: 694

The Brazeau Waste Management Facility Acceptable Waste Streams:


Utilities Board Guide G-51 (Injection and Disposal Wells). Select upstream oilfield

waste as per Alberta Energy and Utilities Board Guide G-58 (Oilfield Waste

Management Requirements for the Upstream Petroleum Industry). Acid Solution, Boiler

Blowdown Water, Caustic Solution, Contaminated Debris and soil (Crude

Oil/Condensate), Contaminated Debris and Soil (Produced Water), Contaminated Debris

and Soil (Sulphur), Corrosion Inhibitor/Oxygen Scavenger Solutions, Crude

Oil/Condensate Emulsions, Drilling Sump Materials (Gel Chem), Drilling Sump

Materials (KCl), Drilling Sump Materials (Hydrocarbons), Frac Sand - Non Radioactive,

Glycol Solutions (no Heavy Metals), Hydrotest Fluids - Water, Wash Fluids - Organic,

Water - Process (with Heavy Metals), Water - Process (with Organic Chemicals), Water -

Produced, Well Workover Fluids.

Canadian Crude Separators Edson



Canadian Crude Separators Fox Creek

CCS

Box 120

Fox Creek, AB

T0H 1P0

Phone: (780)-622-3355

Fax: (780)-622-3664

Plant Manger: Ralph Juuti

Facility Code: 686





Waste handled/processed at this facility:




Management Requirements for the Upstream Petroleum Industry).

Canadian Crude Separators Fox Creek Landfill

CCS

Box 120

Fox Creek, AB

T0H 1P0

Phone: (780)-622-2981

Fax: (780)-622-2361

Plant Operator: Matt Harrington

Location: SE1/4-6-62-18 W5M



Non-dangerous solid oilfield waste as per Alberta Energy and Utilities Board Guide G-58

(Oilfield Waste Management Requirements for the Upstream Petroleum Industry).

Canadian Crude Separators Judy Creek

CCS c/o Whitecourt Answering Service

Box 2071

Whitecourt, AB

T7S 1P7



Judy Creek Waste Management Facility Acceptable Waste Streams:





Canadian Crude Separators LaGlace

CCS c/o Phoenix Oilfield Supply

10933 - 96 Avenue

Grande Prairie, AB

T9V 3J4

Plant Manager: Tim Dalgleish




1. Treating Facility


Phone: (780)-766-3111

Fax: (780)-766-2959

2. Disposal Facility #1


Phone: (780)-766-2401

Fax (780)-766-2620

3. Disposal Facility #2


Phone: (780)-766-3550

Fax: (780)-3777

La Glace Waste Management Facility Acceptable Waste Streams:





Canadian Crude Separators Lindbergh



Canadian Crude Separators Mitsue



Canadian Crude Separators Mitsue Landfill



Mitsue Class II Oilfield Landfill Acceptable Waste Streams:

Non-Dangerous solid oilfield waste as per Alberta Energy and Utilities Board G-58

(Oilfield Waste Management Requirements for the Upstream Petroleum Industry).

Canadian Crude Separators Valleyview

Box 1779

Valleyview, AB



T0H 3N0

Phone: (780)-524-3336

Fax: (780)-524-3957

Plant Manager: Randy Woolston

Facility Code: 669





waste as per Alberta Energy and Utilities Board Guide F-58 (Oilfield Waste Management

Requirements for the Upstream Petroleum Industry).

Canadian Crude Separators Wolf Lake



Medicine River Oil Recyclers Ltd.

Medicine River Eckville Medicine River Oil Recyclers Ltd

P.O Box 76 Box 58

Eckville AB Eckville, AB

T2R 1L9 T0M 0X0

Phone: (403)-746-3130

Fax: (403)-746-2666

Upstream petroleum wastes including produced oilwater and water spill debris; oilfield

pits and ponds; tank and treater bottoms; frac sands, emulsion; KCl water sands; frac

fluids; caustic water; cement water; frac oils; boiler blowdown water; oilfield fresh water;

neutralized acid water; Hydro-Test fluids; inhibited annular fluids; uncrosslinked diesel

gel; oilfield spill fluids; and wash water from upstream oil and gas operations. This

facility also approved to handle waste streams and emulsions containing hydrogen

sulphide and has a Class Ib disposal well.

Newalta Corporation

1200, 333 – 11 Ave SW

Calgary, AB

T2R 1L9

(403)-266-6556

Newalta Brooks





Newalta Brooks



Newalta Clairmont



Newalta Drayton Valley



Newalta Drayton Valley Disposal Well



Newalta Eckville



Upstream oilfield waste management (DOW and non-DOW) including crude oil

emulsions, drilling mud, hydrocarbon sludge for treatment and disposal. Sour water

solutions for class 1b well disposal. Lubricating oil, glycol solutions and waste

flammable liquids accepted for storage and transfer.

Newalta Elk Point



Dangerous and Non-Dangerous oilfield waste.

Newalta Gordondale





Newalta Grande Prairie



Newalta Hughenden



Newalta Red Earth



Newalta Stauffer



Newalta Taber



Newalta Valleyview



Newalta Zama Disposal Well



Newalta Zama



Normcan Control Inc.

1430, 717 – 7 Ave SW

Calgary, AB

T2P 0Z3

(403)-294-3031



Normcan Standard

Location: NW1/4-3-25-22 W4M


PetroVera Resources Limited

P.O Box 1070

Llyodminister SK

S9V 1E9

(780)-875-9186

PetroVera Frog Lake

Location: SE1/4-32-55-03 W4M


Producers Disposal Services Ltd

P.O Box 7318

Edson AB

T7E 1V5

(780)-693-2226

PDS Paddle River



Rag Industries Inc. 4804 – 44 Ave

Stettler AB

T0C 2L0

(403)-742-6900

Rag Industries Stettler

Location: 4804 – 44 Ave.


Canadian Natural Resources Limited

P.O. Box 6926

Station D

2500, 855 – 2 St. SW

Calgary, AB

T2P 2G1

(403)-221-2100



CNRL Lindberg



RemedX Remediation Services Inc. 308, 1305 – 11 Ave SW

Calgary, AB

T2P 2G1

(403)-209-0004

RemedX Breton

Location: NW1/4-12-48-4 W5M


Western Canadian Environmental Services Ltd.

P.O Box 1009

105, 150 Crowfoot Crescent NW

Calgary AB

T3G 3T2

(403)-239-3797

WCES Rainbow Lake

Location: 16-32-110-05 W6M


Western Oil Processors Ltd. 1104, 10080 Jasper Ave.

Edmonton, AB

T5J 1V9

(780)-941-2380

(780)-421-1698

Western New Sarepta





Alberta Environment Approved Landfills

Brooks Newell Waste Recovery Facility

Location: 4-15-19-34

Approval No: 00070359 00 00

Facility Owner: Newell Regional Solid Waste Management Authority

Expiry: Sept. 1, 2006

Document Type: AENV Approved

Classification: Class II

Sanitary Landfill

Accepted Waste Types: Non-hazardous solid industrial and oilfield wastes.

Calgary BFI Landfill

Location: 5-1-22-13 NW

Approval No: 00018690 00 00

Facility Owner: BFI Canada Inc.


Document Type: Health Approved

W 0358



Municipal Solid Waste

Sulphur

Asbestos

Construction and Demolition

Autoclaved Biomedical Waste

White Goods (w/removal of freon certification)

Non-hazardous industrial including contaminated soils and sludges (must have a

flashpoint greater than 61ºC, no free liquids, pH must be between 2.0 and 12.4

Wastes not handles/processed at this facility:

Propane tanks, batteries, non-treated biomedical, air conditioning units, hazardous

waste, radio active waste (>2400cpm), putresibles, and free liquids.

City of Calgary: East Calgary Landfill

Location: 4-29-24-11 E

Approval No: 00019090 01 00

Facility Owner: City of Calgary






City of Calgary: Shepard Landfill

Location: 4-29-23-2 N & 4-29-23-11

Approval No: 00111216 00 04





City of Calgary: Spyhill Landfill

Location: 5-2-25-26

Approval No: 00019101 01 00




Classification:

Drumheller Regional Landfill

Location: 4-20-28-36 NE

Approval No: 00047449 00 00

Facility Owner: Drumheller and District Solid Waste Management Association.



Classification:

Okotoks/Foothills Regional Landfill

Location: 4-29-19-32 SE

Approval No: 000417447 00 00

Facility Owner: Foothills Regional Services Commission



Classification:

Three Hills Municipal Landfill


Approval No: 00018653 00 00

Facility Owner: Town of Three Hills



Classification:



Cold Lake/WMF/Municipal Landfill


Approval No: 00047716 00 00

Facility Owner: Town of Cold Lake



Classification:

Edmonton/WMF/Municipal Landfill, Clover Bar


Approval No: 00047140 00 00

Facility Owner: City of Edmonton, Asset Management and Public Works.



Classification:

Edmonton/WMF/Municipal Landfill, West

Location: 4-25-53-15 S

Approval No: 00048819 00 00

Facility Owner: Canadian Waste Services Inc.



Classification:

Fort McMurray/WMF/Municipal Landfill

Location: 4-9-88-22

Approval No: 00020670 00 00

Facility Owner: Regional Municipality of Wood Buffalo



Classification:

Sturgeon/WMF/Municipal Landfill/Compost, Sturgeon Regional

Location: 4-25-55-36 SW

Approval No: 00047061 00 00

Facility Owner: Sturgeon Regional Landfill Authority

Expiry:


Classification:

Cholla Sand and Dry Waste Inc.



Location: 4-26-52-35

Approval No: 00020686 00 00

Facility Owner: Cholla Sand and Dry Waste Inc.



Classification:

Northlands Sand and Gravel


Approval No: 00049589 00 00

Facility Owner: Northlands Sand and Gravel.



Classification:

Alberta Special Waste Treatment Centre

Location: 8-08-67-06 W

Approval No: 00001744 00 00

Facility Owner: Chem-Security (Alta) Ltd

Expiry: Dec. 1, 2005


Classification:

Pembina Hazardous Waste Landfill

Location: 5-11-50-17 SW & 5-11-50-18 SE

Approval No: 00048516 00 00

Facility Owner: Byram Industrial Services Ltd.

Expiry: March 31, 2009


Classification:

Fairview/WMF/Municipal landfill


Approval No: 00020940 00 00

Facility Owner: Town of Fairview


Document Type: Health Approved (AENV Approval under consideration)

Classification:

High Prairie/WMF/Municipal landfill




Approval No: 00020969 00 00

Facility Owner: Town of High Prairie


Document Type: AENV (Registered) (Approval process in progress)

Classification:

Peace River/WMF/Municipal Landfill, East Peace Regional


Approval No: 00020252 00 00

Facility Owner: Municipal District of East Peace No.131

Expiry: Nov. 30, 2000

Document Type: Health Approved (AENV Approval process in progress)

Classification: Sanitary Landfill Class II

Red Earth Creek/WMF/Municipal Landfill/Transfer Station

Location: 5-8-87-19

Approval No: 00071127 00 00

Facility Owner: Municipal District of Opportunity No. 17


Document Type: AENV (Registered) (AENV Approval process in progress)

Classification:

Grande Prairie/WMF/Municipal Landfill


Approval No: 00020954 00 00

Facility Owner: City of Grande Prairie



Classification:

High Level – Mackenzie/WMF/Regional landfill


Approval No: 00073493 00 00

Facility Owner: Town of High Level



Classification:

MD of Spirit River




Approval No:

Facility Owner:

Expiry:

Document Type: AENV Approval process in progress

Classification:

Slave Lake/WMF/Lesser Slave Lake Regional Landfill


Approval No: 00072856 00 00

Facility Owner: Lesser Slave Regional Waste Management Services Commission

Expiry: Nov. 30, 2009

Document Type: AENV Approved (Under construction)

Classification:

Leduc/WMF/Municipal Landfill, Regional


Approval No: 00047073 00 00

Facility Owner: Leduc & District Regional Waste Management Authority




Ridgeview/WMF/Municipal Landfill, Regional


Approval No: 00046896 00 00

Facility Owner: Central Alberta Waste Management Authority



Classification:

West Dried Meat Lake/WMF/Municipal Landfill, Regional


Approval No: 00078945 00 00

Facility Owner: West Dried Meat Lake Regional Waste Management Authority



Classification:

Camrose/WMF/Municipal Landfill, Regional

Location: 4-20-46-16 N



Approval No: 00047636 00 00

Facility Owner: Camrose Regional Solid Waste Authority



Classification:

Drayton Valley/WMF/Industrial, Municipal Landfill, Regional


Approval No: 00047415 00 00

Facility Owner: Drayton Valley Regional Sanitary Landfill Authority



Classification: Regional Sanitary

Red Deer/WMF/Municipal Landfill


Approval No: 00074348 00 00

Facility Owner: City of Red Deer


Document Type: Health Approved (New Landfill under construction)

Classification:

Rocky Mountain House/WMF/Industrial, Municipal Landfill, Regional


Approval No: 00047645 00 00

Facility Owner: Rocky Mountain Regional Solid Waste Authority



Classification:

Ryley/WMF/Municipal Landfill, Beaver, Regional


Approval No: 00020754 00 00

Facility Owner: Beaver Regional Waste Management Commission




Big Valley




Approval No:

Facility Owner: Canadian Waste Service



Classification:

Bow Island/WMF/Municipal Landfill, North Forty Mile Regional


Approval No: 00074841 00 00

Facility Owner: County of Forty Mile No. 8



Classification:

Boychuk/WMF/Municipal Dry Waste Landfill


Approval No: 00020983 01 00

Facility Owner: William Boychuk

Expiry: March 1, 2008


Classification:

Cardston/WMF/Chief Mountain Regional Landfill


Approval No: 000801109 01 00

Facility Owner: Chief Mountain Regional Solid Waste Authority

Expiry:


Classification:

Claresholm/WMF/Municipal Landfill


Approval No: 00050110 01 00

Facility Owner: Town of Claresholm

Expiry:


Classification:

Claresholm/WMF/Willow Creek Regional Landfill, Dry Waste


Approval No: 00077849 00 00



Facility Owner: Willow Creek Regional Waste Management Commission

Expiry:


Classification:

Crowsnest – Pincher Creek/WMF/Municipal Landfill, Regional


Approval No: 00018701 00 00

Facility Owner: Crowsnest – Pincher Creek Regional Waste Management

Authority



Classification:

Enchant/WNF/Municipal


Approval No: 00137502 00 00

Facility Owner: Municipal District of Taber.



Classification:

Grassy Lake/WMF/Municipal Landfill


Approval No: 00018787 00 00

Facility Owner: Municipal District of Taber



Classification:

Hays/WMF/Municipal Landfill


Approval No: 00137508 00 00

Facility Owner: Municipal District of Taber



Classification:

Iron Springs/WMF/Dry Waste Landfill


Approval No: 00018746 00 00



Facility Owner: Lethbridge Waste Services Commission



Classification:

Lethbridge County/WMF/Dry Waste Landfill


Approval No: 00018753 00 00

Facility Owner: County of Lethbridge No 26



Classification:

Lethbridge/WMF/Municipal Landfill, Regional


Approval No: 00019028 00 00

Facility Owner: City of Lethbridge



Classification:

Medicine Hat/WMF/Dry Landfill, Westar

Location: 4-4-12-31

Approval No: 00072729 00 00

Facility Owner: Westar Landfill Ltd.



Classification:

Medicine Hat/WMF/Municipal Landfill,


Approval No: 00078246 00 00

Facility Owner: City of Medicine Hat



Classification:

Redcliff-Cypress/WMF/Municipal Landfill


Approval No: 00074850 00 00

Facility Owner: Town of Redcliff





Classification:

Taber/WMF/Municipal Landfill


Approval No: 00018985 00 00

Facility Owner: Town of Taber



Classification:

Vauxhall/WMF/Municipal Landfill


Approval No: 00137512 00 00

Facility Owner: Town of Vauxhall



Classification:



Others

Safety-Kleen (Ryley) Ltd

P.O. Box 390

Ryley, AB

T0B 4A0

Class I Landfill/Transfer Station

Facility is a hazardous waste transfer station and secure Class 1b landfill. All classes of

waste acceptable except explosives, biological/pathological and radioactives.

Hazco Environmental Services Ltd.

200, 5720 - 4 Street S.E.

Calgary, AB

T2H 1K5

Phone (403)-297-0415

East Peace Industrial Waste Treatment and Disposal Site.

Location: SW 1/4-2-84-20 W5M

Facility Owner: M.D of East Peace No. 131

Class 2 Sanitary Landfill - acceptable wastes are non-hazardous (non-DOW) petroleum

wastes and other non-hazardous industrial wastes (no free liquids). Bioremediation

option available.

Beaverlodge Transfer Station

This facility is licensed by AEP to store, process and transfer hazardous wastes and

recyclables. The facility can accept Class 3-6, 8 and 9 hazardous wastes. Dangerous

Oilfield Wastes (DOW's), Hazardous recyclables and non-hazardous materials. The

facility cannot accept PCB's, explosives, compressed gases, radioactive wastes and

biological/pathological wastes. Although the facility is licensed to volume reduce shred,

segregate, separate and recover liquids, the facility serves only as a collection point and

all further processing occurs at the Calgary Transfer Station.

Calgary Waste Storage and Transfer Facility

Hazardous and industrial waste storage, recyclables processing and transfer facility.

Wastes from the following TDG classes are acceptable: 2,3,4,5,6,8 and 9. Combined

capacity of 230 tonnes including 20 tonnes of PCB waste.

rbw Waste Management Ltd. 4625 - 101 Street



Edmonton, AB

T6E 5C6

Fax: (780)-437-0281

Permit No. 00068686 00 00

For Recycle

1. rags and sorbents contaminated with hydrocarbons or glycol

2. filters contaminated with hydrocarbons, sulfinol, produced water, filter backwash

water, amines, natural gas liquids, raw and fuel, glycol and air

3. engine lube oil filters

Brokerage of:

1. Liquid hydrocarbons and glycols

2. Spent dry alkali and Ni-cd batteries

3. Spent aerosol containers

Newalta Corporation 6110 27 Street

Edmonton, AB

T6P 1J9

Phone: (780)-440-6780

Fax: (780)-468-0964

Newalta Corporation Edmonton Process Facility

Hazardous Recyclables - Hydrocarbons, Glycols, Amines

BFI

Big Valley Landfill

Class II Industrial

Waste handled / Processed at this facility:

Sulphur

Asbestos

Construction and Demolition

Non-hazardous industrial including contaminated soils and sludges (must have a

flashpoint greater than 61ºC, no free liquids, pH must be between 2.0 and 12.4)

Waste not handled/processed at this facility



Propane tanks, batteries, non-treated biomedical, air conditioning units, hazardous

waste, radioactive waste (>2400 cpm), putresibles, municipal solid waste, white

goods and free liquids.

Environmental Waste Management

7100 44 Street SE

Calgary, AB

T2C 2V7

Phone: (403)-720-1046

Fax: (403)-720-1050

All waste types: biohazardous, radioactive or explosive.

E.I.L. Environmental Services

16041 - 132 Avenue

Edmonton, AB

T5V 1H8

Phone: (780)-448-0866

Fax: (780)-482-5750

E.I.L. Environmental Services Onoway Facility/Transfer Station and Transportation

Network

All types of hazardous waste with the exception of explosives, radioactives,

biohazardous. All liquids, solids and sludges. Bulk waste oil, fuels, solvents and

contaminated water.

Byram Industrial Services Ltd. P.O Box 6478

5610 - 50th

Avenue

Drayton Valley, AB

T7A 1R9

Pembina Area Landfill

PAL is fully licensed to dispose of hazardous and dangerous oilfield wastes; and non-

hazardous and non-dangerous oilfield wastes that are solid wastes (as defined by the

Paint Filter Test). Examples of the material accepted into the facility are: Hydrocarbon

and/or salt contaminated soil, process sludges, drilling mud and cuttings, flare pit

reclamation material, sulphur block contaminated soils, filters incinerator ashes, service

station reclamation material, railway sidings material, process material from mining,

manufacturing or refining industries, decommissioning refuse, catalysts and desiccants,

and other solid wastes.



Cleanit Greenit Composting Systems Inc. 15619 - 112 Avenue

Edmonton, AB

T5M 2V8

Phone: (780)-488-7926

Fax: (780)-452-8284

Site: (780)-451-0921

Site 1, Edmonton


All waste accepted for processing at this site must be compostable. All waste must meet

the waste acceptance criteria. Waste can/may be tested in the mini-lab at the site. Some

hazardous recyclables can be accepted; however, they must meet the criteria for waste

acceptance and be justified as hazardous recyclable. Composted is done using the static

pile process.

WasteCo Environmental Services Ltd. P.O Box 3009

Sherwood Park

Edmonton, AB

T8A 2A6

Phone: (780)-944-0057

Fax: (780)-475-3465

CEDA Reactor Ltd.

Waste handled/processes at this facility:

Handle both regulated and non-regulated waste. All classes of regulated waste except

explosives, radioactive and biohazardous.

Sumas Environmental Services Inc.

Nisku Hazardous Waste Transfer Station

#7 - 1301 4th

Street

Nisku, AB

Phone: (780)-955-2390

Fax: (780)-955-2070

Permit #: 167-02-000

Receiver #: ABR 01097

Carrier #: ABC 02265

Generator #: ABG 05716


All classes of toxic, hazardous and non-hazardous wastes for treatment and transfer.

CWR Waste Management Corporation Inc



Box 848

Coronation, AB

T0C 1C0

Location: NE 1/4-34-36-11 W4M

EUB

Proeco Environservices Ltd 7722 9

th Street

Edmonton AB

T6P 1L6

Phone: (780)-440-1825

Fax: (780)-440-2428

Custom Environmental Services Ltd.

7722 9th

Street

Edmonton AB

T6P 1L6


Approval No. 95-IND-085

The operation of a hazardous waste storage and hazardous recyclable reclamation and

processing facility.

Plant storage of hazardous waste, hazardous recyclables, and dangerous oilfield waste.

The treatment of hazardous waste by commingling phase separation, solids dispersion

physical segregation and crushing for volume reduction and liquid recovery.

Processing of hazardous recyclable by commingling, phase separation, crushing for

volume reduction and liquid recovery, removal of hazardous residuals and any other

authorized process.

Recycling and processing of PCB electrical equipment.

Interstate Batteries of Northern Alberta 11404 - 156 Street

Edmonton, AB

Phone: (780)-454-4343


Collecting wet acid batteries for recycling.


Balzac Gas Plan 7.0 ALBERTA APPROVED LANDFILLS

ALBERTA LANDFILLS

There are a number of landfills in Alberta that may be used by waste producers

for disposition of waste streams. It is important to note that the onus is on the

waste producer to ensure proper waste classification prior to land filling a waste.

Landfills in Alberta are regulation by the EUB for Oilfield Landfills and by

Alberta Environmental Protection for regional and Industrial landfills.

Landfills have different classifications based on construction. And siting. All

landfills have classification, based on these two criteria, and the classification of a

landfill determines the waste products that may be disposed of at these sites.

AEP LANDFILL CLASSIFICATION

Class I landfills

Class I landfills may accept hazardous wastes up to a certain limit. This limit is

above the Alberta Tier I levels for heavy metals and for BTEX.

There are only two landfills with a class I designation in Alberta.

1. Safety-Kleen (Ryley) Ltd. at Ryley, Alberta

2. Chem. Security Landfill at the Swan Hills Treatment Center

Class II landfills (Industrial)

Class II landfills may only accept non-hazardous or non-DOW materials

There are a number of Class II landfills in Alberta and are all private landfills that

accept third party waste. The following landfills are Class II landfills:

1. Hazco Landfill at Peace River

2. BFI Landfill at Calgary

3. BFI Landfill at Big Valley

4. EWM Landfill at West Edmonton

5. Clover Bar Landfill at Edmonton

6. Rocky Mountain House Regional Landfill at Rocky Mountain House

The remaining landfills that are regulated by AEP are either regional, county, or

local landfills. These have a Class III designation. These types of landfills are

only able to accept inert wastes form the Upstream Oilfield Industry, such as

construction material and normal refuse. These landfills are not recommended for

use for other types of waste disposal.


Balzac Gas Plan 7.0 ALBERTA APPROVED LANDFILLS

EUB REGULATED LANDFILLS

The EUB also has different classifications of Oilfield Landfills under its

jurisdiction. The criteria for classifying its landfills are identical to AEP.

Class Ia Oilfield landfill

There are no Class Ia oilfield landfills in Alberta at this time

Class Ib Oilfield landfill

There are no class Ib oilfield landfills in Alberta at this time, however there are a

number which are in the application stage.

Class II Oilfield landfill

There are a number of Class II oilfield landfills in Alberta that accept third party

waste for disposal. They are as follows:

1. NOS Landfill at Zama

2. CCS Landfill at Slave Lake

3. Newalta Landfill at Taber

NEXEN may use landfills for proper disposal, whether a landfill is regulated by

AEP or EUB.


Balzac Gas Plan 8.0 SPILL REPORTING

ALBERTA Spill Response and Reporting

All spills, leaks, and releases of potentially harmful substances are to be reported

to a company field superintendent or member of management and a written report

will be sent to the Environmental Coordinator and filed with regulatory

authorities if required.

EUB Reportable spills

If a spill occurs with an unrefined product (crude oil or produced water) the

following guidelines should be followed:

Complete an incident report and forward to the Field Supervisor if the volume is

less than 2m³ and is contained on lease.

Contact the local AEUB Field Office if:

The volume of spilled material is >2m³ on lease; or

Any spill material escapes off-lease

The rig manager or driller is responsible for reporting spills or leaks of hazardous

or dangerous goods where the spill:

Is of a volume greater than 2m³ on lease;

Enters into any natural waterway; and/or

Escapes from the lease site

Reports must be made to the local AEUB field office immediately upon discovery

of the spill. If required, a written report will be submitted to the AEUB with the

information requested. The AEUB may require a written report with the

following information:

The name, address, etc. of the drilling company and operator;

The location of the spill;

The source and cause of the spill

The type and volume of product spills

The final distribution of recovered and unrecovered product; and

Other details as required

If a spill occurs with a refined product (diesel, varsol, chemical, lube oil, glycol,

etc.) the following guidelines should be followed:

Spills of controlled substances greater than the thresholds specified in the

Transportation of Dangerous Goods Regulations should be reported to:

the Director of Pollution Control, Alberta Department of Environment

through Industrial Incident Reporting


Balzac Gas Plan 8.0 SPILL REPORTING

Anyone directly affected by the spill (for example, other yard sites,

municipality, private landowners, etc.)

The report to the Director should include:

The location and time of the release;

A description of circumstances leading up to the spill;

Details of any action taken or planned at the release site;

The final distribution of recovered and unrecovered product; and

Reclamation plans if required

A written report must also be sent to the Director’s office within seven days of the

initial report being made. It should contain the following information;

Date and time of the spill;

Location of the spill;

Duration of the release and its release rate;

Composition of the release showing, for each substance;

Its concentration;

The total weight, quantity or amount;

A detailed description of the circumstances leading up to the release;

Steps or procedures which were taken to minimize, control or stop the

release; and

Any other information as required by the Director.

The report should be sent to:

ALBERTA ENVIRONMENT

Pollution Control Division

11th

Floor, 9820 – 106 Street

Edmonton, Alberta

T5K 2J6

Spills or leaks may not be detected until days or even weeks after the incident

occurs, however, if such a release occurs, it should be reported and active clean-

up measure implemented as soon as possible.


Balzac Gas Plan 9.0 COMPANY FACILITY CODES

Company Code 0JT3

Prov. ID Number ABG05629

Facility Name Location Facility Code

Balzac Gas Plant 10-02-26-29 W4M 2670030


Balzac Gas Plan 10.0 WASTE / ENVIRONMENTAL AUDIT REPORTS

Waste and

Environmental Audits


Balzac Gas Plan 11.0 RECYCLING

A. INTRODUCTION

This section will describe the policy for the recycling of wastes.


The implementation of a waste recycling program is designed to reduce the

volume of waste that is sent to landfills and reduce the costs of disposal.

Recyclable wastes are collected throughout the operating facility and sent off site

to recycling facilities.

Those wastes included in the recycling program are batteries, used oil, metal,

paper and cardboard and miscellaneous materials. Each type of waste is collected

and stored in a designated site and prepared for transport.

C. PROCEDURES

Each type of recyclable waste is collected by plant employees and stored in their

designated site.

1. Batteries - All Dry cell and Vehicle batteries are collected and placed on

the Environmental Waste Storage Pad located in the plant. When enough

batteries are collected they are transported by Hazco to a battery recycling

facility.

2. Used Oil - Used oil removed from the process machinery is collected in

blue double walled storage tanks that are placed throughout the plant site

(Treater, Boiler House, KVSR buildings, SVG building and Site G).

When the tanks are full the used oil is transferred to the waste oil settling

tank in flare area. Newalta is called and a manifest is completed for

transport.

3. Metal - All metal that no longer has a use is placed in an orange bin,

located at the west end of the plant, that has been designated for metal.

When this bin becomes full Calgary Metal transports the bin to their metal

recycling facility. Payment for recyclable metal is made to the generator.

4. Paper and Cardboard - Recyclable Paper and Cardboard is placed in bins

located throughout the office facilities. All paper should be collected in

plastic bags. When the individual bins are full the waste is collected in

green paper/cardboard recycling bins. The paper and cardboard is

transported by BFI to their recycling facility.

5. Miscellaneous Recyclables – Depending on quantity some materials may

be recycled i.e. glycol, solvents, varsol, diesel, etc.

BALZAC GAS PLANT


104

Appendix III – List of Environmental Reporting Completed

for the BGP

Balzac Gas Plant

Summary of Environmental Reporting

Year Report Title

1992 Komex Report: Terrain Conductivity and Magnetometer Survey at the Petrogas Processing Plant, Balzac Alberta A92-2553-2

1993 Petrogas Report Entitled: Activity Change – Upgrade of Runoff Water Control around Sulphur Block Area – Central File 001-20

1995 Komex Report: Stable Isotope Study at the Petrogas Processing Facility KI94-2553-5

1995 Komex Report: 1995 Geophysical Program and Limited Soil Sampling Investigation – Petrogas Processing Ltd. KI95-2553-6

1996 Komex Report: 1996 Soil Monitoring Program – Balzac Gas Plant – Canadian Occidental Petroleum Ltd. KI96-2553-7-3-6

1997 Komex Report: Effects of Acid Conditions on Element Distribution Beneath a Sulphur Basepad KI96-4374

1997 Komex Report: Study of Soil, Sludge and Groundwater Conditions Around the Blowdown Ponds at the Balzac Gas Plant 2553-7-2

1997 Komex Report: Soil Quality Adjacent to the Sulphur Contaminated Soil Pile at the Balzac Gas Plant – 2553-8-2

1997 Komex Report: Hydrocarbon Burn Pit, Filter Cake Pond and Chemical Pond Remediation at the Balzac Gas Plant - KI - 2553-10-2

1997 Komex Report: Screening Level Human Health and Ecological Risk Assessment (Ponds) Wascana Energy - Balzac Gas Plant - KI 98-4683

1998 Komex Report: 1998 Integrated Soil and Groundwater Investigation Program - Wascana Energy Inc. KI-2553-9 T01/T02

1998 Komex Report: Delineation of Free Product Contamination in the LPG Recovery Area – Balzac Gas Plant KI-2553-10-5

1999Delineation of Free Product Contamination in LPG Recovery Area – 1999 , Komex Report KI-2553-10-5 dated May 9, 1999.

Conductivity probes were used in delineation of plume.

1999 Remediation Options Analysis - LPG Recovery Area , Komex Report KI-2553-11-02 (Draft) dated May 1999.

1999 Komex Report: Soil and Sludge Remediation Program of Flare Pits at Well site 2-2 C25531204

1999 Komex Report: Remediation Options Analysis LPG Recovery Area – Balzac Gas Plant KI2553-11-02 (Draft)

1999 Komex Report: Installation and 1999 Performance Review LPG Recovery Area Free Phase Recovery System C25531106

1999 Komex Report: 1998/1999 Cremona Pipeline Remediation at the Balzac Gas Plant - Komex Report C47480100

2000 Installation and 1999 Performance Review - LPG Recovery Area , Komex Report C2553‑1106 dated March 2000.

2000 Proposed Expansion of Free Product Recovery System - LPG Recovery Area , Komex Report C25531205 dated June 2000.

2000 Komex Report: Balzac Parking Lot – Underground Petroleum Storage Tank Investigation – File No. 25531208

2000

Komex Report: Balzac Gas Plant – Delineation of the Flare Area and Condensate Loading Area – File No. C25531104 Draft

Komex Report: Balzac Gas Plant – Condensate Loading Area Remediation – File No. 25531211 Draft

2000 Komex Report: Balzac Gas Plant – Underground Tank Removals – File No. C-2553-1206

2000 Komex Report: Balzac Gas Plant – Landtreatment Activities – File No. C-2553-1211

2000 Komex Report: 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area Free Phase Recovery System C25531212

2000 Komex Report: Proposed Expansion of the Free Product Recovery System LPG Recovery Area – Balzac Gas Plant C25531205

2001 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area , Komex Report C2553-1212 dated October 2001.

2001 2001 Performance Report Free Phase Recovery - LPG Recovery Area , Komex Report C2553-1303 dated July 2002.

2001 Komex Report: Balzac Gas Plant – North and South Landfill Characterization Program – File No. 25531309

Balzac Gas Plant


Year Report Title

2001Komex Report: Balzac Gas Plant – 1998 Integrated Soil and Groundwater Investigation Program Volume 1 of 2 - File No. KI-2553-9


2001 Process Research Associates Ltd. Report: Project No. 00-05207

2001 Komex Report: Balzac Gas Plant – Land Treatment Activities – File No. C-2553-1211

2001 Komex Report: Balzac Gas Plant – Methanol Storage Tank Investigation - File No. 25531306

2001 Komex Report: Balzac Gas Plant – Inhibitor Tank Remediation – File No. 25531408

2001 Komex Report: 2001 Performance Report - Free Phase Recovery - LPG Recovery Area C25531303

2001 Komex Report: Hydrocarbon Monitoring Results Waterline Installation C25531307

2001 Komex Report: Hydrocarbon Monitoring Results Fuel Gas Line Installation C25531307

2001 Komex Report: Arsenic Detection’s in S.W. Dugout – Review and Recommendations C25531302

2001 Komex Report: 5 Year Remediation Management Plan Summary - Balzac Gas Plant - C25531300

2002 2002 Performance Report - LPG Recovery Area , Komex Report C2553-1407 dated March 19, 2003.

2002 Komex Report: Installation and 1999 Performance Review LPG Recovery Area Free Phase Recovery System C2553-1106

2002 Komex Report: 2000 Performance Review Phase I and Phase II Installation - LPG Recovery Area Free Phase Recovery System C25531212

2002Worley Parsons Komex Report: Remediation Status Report 01-08-027-27 W4M and 06-23-027-27 W4M. File No. C25532006. (In

Draft).

2002 Komex Report: Balzac Gas Plant – PCB Soil Sampling and Delineation – File No. C25531403

2003 2003 Groundwater Monitoring Report. Balzac Gas Plant. Komex International Ltd. Report No. C25531502.

2003 Balzac Gas Plant. Stormwater Management Report. Westhoff Engineering Resources Inc. July 2003




2003 Komex Report: Balzac Gas Plant – North Landfill Closure Report - File No. 25531505

2003Komex Report: Balzac Gas Plant – 2002 Performance Report – Free Phase Recovery System LPG Recovery Area Balzac Gas Plant – File

No. C25531407 – Draft Report

2003 Komex Report: Balzac Gas Plant – Delineation of the Flare Area and Condensate Loading Areas – File No. C25531104 – Draft Report

2003 Komex Report: 5 Year Remediation Management Plan Summary - Balzac Gas Plant - C25531501

2003/2004 2003/2004 Performance Report LPG Recovery Area , Komex Report C25531605 dated July 27, 2005

2004 2004 Groundwater Monitoring Report. Balzac Gas Plant. Komex International Ltd. Report No. C25531603.

2004 Komex Report: Balzac Gas Plant – Updated Risk Assessment – C25531301 June 2004

2004Komex Report: Balzac Gas Plant – 2003/2004 Performance Report – Lean Oil Remediation System – LPG Recovery Area – File No.

C25531605

2004 Komex Report: Updated Risk Assessment (Ponds) - Balzac Gas Plant - C25531301

2005 2005 Groundwater Monitoring Report. Balzac Gas Plant. Komex International Ltd. Report No. C25531701

2005 Komex Report: Balzac Gas Plant – 2003/2004 Soil and Groundwater Investigation in the Flare Area - File No. C25531504

2005 Komex Report: Balzac Gas Plant – 2005 Environmental Summary Update- File No. C25531700

Balzac Gas Plant


Year Report Title

2006 2006 Groundwater Monitoring Report. Balzac Sour Gas Plant. Worley Parsons Komex Report No. C25531804. ;

2006 Decommissioning and Reclamation Plan – Sulphur Handling Facility. Worley Parsons Komex. Report No. C25531604.

2006 2006 Soils Management Plan. Worley Parsons - Report No. C25531901

20062006 Environmental Assessment for Management of Contaminated Sulphur And Materials Contaminated with Sulphur. WorleyParsons

Komex. Report No. C25531803.

2006 Worley Parsons Komex Report: Balzac Gas Plant – 2006 Industrial Runoff Assessment - File No. C25531806

2006 2006 Soil Monitoring Program. Balzac Sour Gas Plant. Worley Parsons. Report C25531803. 30 November 2006.

2006 Worley Parsons Komex Report: Balzac Gas Plant – 2006 Soil Monitoring Program - File No. C25531803

2006Worley Parsons Komex Report: Balzac Gas Plant – 2006 Environmental Assessment for the Management of Contaminated Sulphur and

Materials Contaminated with Sulphur - File No. C25531803

2006Worley Parsons Komex Report: Balzac Gas Plant – Decommissioning and Reclamation Plan Sulphur Handling Facility - File No.

C25531604

2006Worley Parsons Komex Report: Balzac Gas Plant – 2005-2008 Performance Report Lean Oil Remediation System - File No. C25532004

(Draft)

2007 2007 Groundwater Monitoring Report. Balzac Gas Plant. Worley Parsons Komex. Report No. C25531903.

2007 2007 Soil Management Activities Program at Balzac Sour Gas Plant. Worley Parsons. Report C25532002.

2007 Worley Parsons Komex Report: Balzac Gas Plant – Soil Management Plan - File No. C25531901

2007 Worley Parsons Report: Balzac Gas Plant – Sulphur Soil Pile Closure Sampling - File No. C25532001

2007 Worley Parsons Komex Report: Balzac Gas Plant – Directive 001 Site Specific Liability Assessment - File No. C25531801


(In Draft)

2007 Worley Parsons Report: Balzac Gas Plant – Sulphur Pit Construction - File No. 25531902 (In Draft)

2008 2008 Groundwater Monitoring Report. Balzac Gas Plant. Worley Parsons. Report No. C25532003.

2008 2008 Soil Management Activities Program at Balzac Sour Gas Plant. Worley Parsons. Report C25532105. March 27, 2009

2008 Worley Parsons Report: Balzac Gas Plant – Sulphur Soil Pile Closure Sampling - File No. C25532001

2008Worley Parsons: Sulphur Impacted Soil Stockpile Removal in Sulphur Handling Facility at Balzac Sour Gas Plant. File No. C25532007.

(In Draft)

2008Worley Parsons Komex Report: Balzac Gas Field – Pipeline Release Remediation Program at 7-15-25-28 W4M Wellsite - File No.

C50920500

2009 2009 Groundwater Monitoring Report. Balzac Gas Plant. Worley Parsons. Report No. C25532103.

2009 2009 Soil Management Activities Program at Balzac Sour Gas Plant. Worley Parsons. Report C25522109. March 30, 2010.

2009Sediment Sampling in McDonald Lake to Assess the Potential for Natural Hydrogen Sulphide Generation. Matrix Solutions Inc. January

29, 2009.

2009 Unknown Sump Excavation. 02-26-29W4M, Alberta. Worley Parsons. Report C25531802. January 30, 2009.

2009 Worley Parsons. Confirmatory Soil Sampling Summary Report C25532005. December 23, 2009.

2009 Worley Parsons Komex Report: Balzac Gas Plant – Topsoil Stockpile Removal - File No. C25532007 DRAFT

2009 Worley Parsons Komex Report: Balzac Gas Plant – Sulphur Ditch Assessment - File No. C25532106


Balzac Gas Plant


Year Report Title


T01/T02


(Draft)

2009 Worley Parsons Report: Balzac Gas Plant – Unknown Sump Excavation Update - File No. C25531802

2009 Worley Parsons Report: Confirmatory Soil Sampling Summary, Balzac Plant Ditch Excavation – File No.C25532106, 23-March-2011.

2009Worley Parsons: Interim As-Built Drawings of Surface Water Collection Ditches Constructed During 2009 at the Balzac Gas Plant -.

Report C25532005. December 23, 2009.

2009 Worley Parsons-2009 DEA UST Removal and Replacement - Letter Report. Report C25532107. May 10, 2011. DRAFT

2009-2010 2009-2010 Performance Report Lean Oil Remediation System , Worley Parsons Report C25532104 (Draft)

2010 2010 Groundwater Monitoring Program. Balzac Sour Gas Plant. Worley Parsons. Report No. C25532202.

2010 2010 Soil Management Activities Program at Balzac Sour Gas Plant. Worley Parsons. Report C25532301. March 11, 2011

2011 Confirmatory Soil Sampling Summary Balzac Plant Ditch Excavation. WorleyParsons Report No. C25532106 – March 23, 2011.

2011 Sulphur Pit Construction. Balzac Sour Gas Plant. WorleyParsons. Report No. C25531902. Report still in Draft. May 9th, 2011

2011 Sulphur Pile Closure Sampling. Balzac Sour Gas Plant. Worley Parsons. Report No. C25532001. April 11, 2011.

2011 Topsoil Stockpile Removal Sulphur Handling Facility. Balzac Sour Gas Plant. Worley Parsons. Report C25532007. May 9th, 2011.

2011 Condensate Loading Area (CLA) Excavation, Balzac Sour Gas Plant. Worley Parsons. Report C25531211. Draft May 4th, 2011.

2011 Remediation Status Report. 01-08-027-27W4M/06-23-027W4M. Worley Parsons. Report C25532006. May 9th, 2011 (In Draft).

2011 2009 DEA UST Removal and Replacement - Letter Report. Worley Parsons. Report C25532107. May 10, 2011.

2005-2008 2005-2008 Performance Report Lean Oil Remediation System , Worley Parsons Report C25532004 (Draft)

Komex Report: Terrain Conductivity Survey at the Petrogas Processing Plant, Balzac Alberta A94-2553-6

Worley Parsons Komex Report: Balzac Gas Plant – Topsoil Stockpile Removal - File No. C25532007 DRAFT

35

APPENDIX IV – BALZAC POWER STATION MAPS

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NE-2026-29 W4

Image Date = 14/09/2008

High Pressure Pipelines and Wells current to November 30, 2009 *** Low Pressure Pipelines current to November 1, 2005ROCKY VIEW

FIgure 3. Aerial Photo of existing Thermal Electric Power Plant & Balzac Gas Plant

N

Compaq_Owner

Text Box

Electric Thermal Power Plant

Compaq_Owner

Text Box

Cooling Towers

Compaq_Owner

Polygonal Line

Compaq_Owner

Polygonal Line

Compaq_Owner

Text Box

Aerial photo of the Electric Thermal Power Plant. The power plant which is the primary component of this application document is outlined in yellow. All other infrastructure visible in the photo is associated with the Balzac Gas Plant, and is not a component of this application document.

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APPENDIX V – PROPOSED 2012 GROUNDWATER MONITORING PROGRAM

WorleyParsons Canada4500 16th Avenue NW Calgary, AB T3B 0M6 CANADA Phone: +1 403 247 0200 Toll-Free: 1 800 668 6772 Facsimile: +1 403 247 4811 www.worleyparsons.com

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14 December 2011 Proj. No.: C25532306 File Loc.: Calgary

Nexen Inc. P.O. Box 239 Balzac, AB T0M 0E0

Attention: Todd Jorgensen-Nelson

Dear Mr. Jorgensen-Nelson:

RE: PROPOSED 2012 GROUNDWATER MONITORING PROGRAM AT BALZAC SOUR GAS PLANT

Groundwater conditions at the Balzac Sour Gas Processing Plant (Plant) have been documented in great detail through monitoring from 1992 to 2011. The main findings of the groundwater monitoring include:

generally, natural groundwater quality in the Plant area is of poor quality as indicated by high sulphate and total dissolved solids (TDS) concentrations;

groundwater flow velocities outside of the process area are low, in all three monitored groundwater zones, primarily due to low hydraulic gradients;

groundwater quality, including in zones of contamination, is relatively stable with small seasonal and annual variability; and

inorganic and organic groundwater impacts related to Plant operation identified within the process area, ponds and adjacent areas are aerially stable and have not expanded greatly over the monitoring period.

Considering the significant hydrogeological information available and the anticipated Plant decommissioning, a major revision in the forthcoming groundwater monitoring program is recommended. Proposed changes to the 2012 program include:




concentrating monitoring activities around the process area and perimeter “C” wells.

C25532306-CA-LTR GW 2012 Changes-Rev0.doc Page 2 of 2 14 December 2011

The proposed groundwater monitoring program would include sampling once a year in the spring, instead of spring and fall sampling, with the number of monitored wells reduced. To address operational issues during the 19 year history of groundwater monitoring, several monitoring wells were installed in relatively close proximity to each other, often duplicating and/or confirming information obtained from existing wells. These expansions to the monitoring network were required at the time of installation. However, in view of the Plant decommissioning, some monitoring wells are of lesser importance. It should be noted that during Plant decommissioning and remediation of the area, several wells installed near facilities will be removed. These monitoring wells should be properly abandoned.

Monitoring wells selected for continued monitoring should be sampled according to WorleyParsons’ preferred operating procedures. Reduction in laboratory analysis is also recommended. Testing at select monitoring locations should include:

laboratory analysis for benzene, toluene, ethylbenzene, xylenes (BTEX) and petroleum hydrocarbon (PHC) fractions F1 and F2 and amines; and

field measured parameters including depth to groundwater surface, temperature, electrical conductivity (EC) and pH. If significant changes in EC and/or pH are measured as compared to historical field measurements, a sample should be submitted for routine potability analysis for the well in question. Otherwise, laboratory testing for main ions and dissolved metals should be discontinued.

Based on the information noted above, a recommended analytical schedule is provided on Table 1.

It is WorleyParsons recommendation that Nexen submits proposed changes to the groundwater program to Alberta Environment (AENV) for approval. We trust that the proposed changes meet AENV requirements as well as Nexen’s long-term commitment to environmental protection.

Regards,

Steve Hardy, B.A.Sc., P. Eng. Dr. Tad Dabrowski, P.Eng. Staff Environmental Engineer Technical Director, Hydrogeology

Prairie Business Unit Infrastructure & Environment WorleyParsons Canada Services Ltd.

Table 1 2012 Schedule of Analyses

PROJECT NO.: C25532306

Monitoring Station

Fiel

d Pa

ram

eter

s

BTE

X/F1

ATF

1F2

Am

ine

GPW

WR

2

92-3A X92-3B X92-4A X92-8A X X X92-8B X X X98-8C X X X92-11A X92-11B X92-12A X92-12B X92-13A X92-14A X93-15A X93-15C X X94-17C X X94-18C X X94-19C X X96-22A X98-24A X X98-24B X X98-24C X X98-26A X98-26C X X98-28C X01-33A X01-34A X X03-37A X03-38A X X04-42A X06-44A X06-45A XMW-1A XMW-4A XMW-8A XMW-9A XMW-9B XMW-10A X

SW Dugout X XMcDonald Lake X X X X

Dup I = Trip Blank XDup II = X

TOTALS 42 15 3 5 5

NOTES: - GPWWR2 (non rush)- consists of Ammonia-N, COD, Cl, pH, Sheen, TSS, SO4

- ATF1F2 includes BTEX, F1 and F2- Field Parameters include depth to groundwater surface, temperature, pH and electrical conductance

- Amines can be submitted from routine bottle

Open Drain Collection Pond (Water from Tile Drain)

X

X

Duplicates

X

Open Drain Collection Pond (Water between Liners)

X

XX

Spring 2012

Groundwater-Bearing Zone

XOpen Drain Collection Pond (Surface Water) X

Surface WaterX

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BALZAC THERMAL ELETRIC POWER PLANT