FOR IMMEDIATE RELEASE:

December 18, 2000

PROVINCIAL ADVISORY COMMITTEE ON PUBLIC SAFETY AND SOUR GAS
RELEASES FINAL REPORT: FINDINGS AND RECOMMENDATIONS

Final Report - PDF

Final Report - DOC

Appendices - PDF

Appendices - DOC

The Report concludes that Alberta has an extensive and comprehensive oil and gas regulatory and enforcement system. The Committee is of the view that the EUB and the industry, on an overall basis, are endeavoring to ensure that sour gas operations have minimal negative impacts on the public. However, the Committee believes that improvements must be made. On the basis of all of the information it received throughout the process, it has developed 87 detailed recommendations. The recommendations are generally directed towards increasing awareness of sour gas and its impacts on public health and safety, improving the sour gas regulatory system and encouraging better consultation that must take place with the public on all sour gas matters.

The Committee has requested that the EUB develop a plan to implement all of its recommendations, make the plan public, and publicly report progress towards implementation on a quarterly basis until all of the recommendations have been addressed.

Some of the key recommendations are:

• Develop comprehensive health effects information for sour gas mixtures and the combustion products of sour gas
• Identify and support required research respecting the health effects of sour gas
• Develop a framework and methodology for standardizing dispersion modelling and probabilistic risk assessment
• Review the current criteria for sour gas setbacks and emergency planning zones
• More complete and concise requirements for the development and implementation of emergency response plans
• Consolidations of existing sour gas requirements and consideration of additional or revised regulations
• Increased inspections and audits on sour gas operations with poor performance records
• Improve response to sour gas complaints and more rigid enforcement of requirements,
• Greater reliance on mediation and less formal hearings
• More recognition of public input and descriptive material on public interest criteria in EUB decision reports
• Greater emphasis by the EUB on its role as a neutral regulator and on the profile of matters related to public health and safety

PROVINCIAL ADVISORY COMMITTEE ON PUBLIC SAFETY AND SOUR GAS

• More stringent action by the EUB to ensure public consultation programs are effective and consistent
• Formation of an EUB information office and a staff resource team that focuses on public consultation
• Special attention to improve the relationship between the EUB and Aboriginal people
• Clarifying and coordinating the roles of all parties that have some jurisdiction respecting sour gas, and
• Improved training for both industry and EUB personnel related to sour gas and public health and safety.

A copy of an Executive Summary of the Report is attached.

For more detailed information and how to get a copy of the Advisory Committee's final report, please contact the Advisory Committee at:

• Phone: (403) 297-8855
• Fax: (403) 297-8114
• Address: 640 - 5 Avenue SW, Calgary, AB T2P 3G4
• Online: http://www/publicsafetyandsourgas.org

EXECUTIVE SUMMARY

The Alberta Energy and Utilities Board (EUB) formed an Advisory Committee (Committee) on Public Safety and Sour Gas in January 2000 to review the regulatory system for sour gas as it relates to public health and safety. The Advisory Committee includes representation from all major stakeholders. It conducted an extensive outreach program and received considerable input from persons living in sour gas areas or involved with sour gas in some other manner.

On the basis of the input received, the Committee reviewed the sour gas regulatory system. In October 2000, it issued an interim Directions document that identified those issues related to the sour gas regulatory system that it believed to be of greatest importance. It also identified the direction it was moving in with respect to recommendations to address each of the issues.

The Committee conducted a second outreach program and received considerable input by way of reaction to its Directions report. It used that input to finalize its findings and recommendations.

Alberta currently has an extensive and comprehensive oil and gas regulatory and enforcement system. The Committee is of the view that the EUB and the industry are overall endeavoring to ensure that sour gas operations have minimal negative impacts on the public. While the Committee is aware that progress has been made, most notably in initiatives like the Appropriate Dispute Resolution process and increased public consultation requirements, the Committee believes that further improvements must be made. On the basis of all the information received throughout the process, it has developed 87 detailed recommendations directed towards

• a better understanding of sour gas,
• improving the sour gas regulatory system,
• reducing the impacts of sour gas on public health and safety, and, most importantly,
• improving the consultation that takes place with the public on all sour gas matters.

A major area where further effort is needed, on a priority basis, is in the understanding of the effects of sour gas on human health. Effort is also needed to standardize the technical procedures related to dispersion modelling and probabilistic risk assessment. These should then be used with the improved knowledge of health effects, to review current policy and requirements to protect public health and safety.

To accomplish this, the Committee is recommending that the EUB work with appropriate stakeholders to

• Develop comprehensive health effects information for sour gas mixtures and the combustion products of sour gas;
• Identify and support required research respecting the health effects of sour gas;
• Develop a framework and methodology for standardizing dispersion modelling and probabilistic risk assessment, and update them regularly;
• Upgrade EUB sour gas databases; and
• Review the current criteria and approach for establishing sour gas setbacks and for emergency planning zones (EPZ's) on the basis of the health effects information and standardized dispersion modelling and risk assessment methodology.

Another area of major concern relates to the effectiveness of consultation amongst all parties involved with sour gas. In this respect, the Committee is recommending

• A more consistent approach to public consultation;
• More stringent action by the EUB to ensure public consultation programs are effective;
• Development of effective public consultation and communications training programs;
• Formation of an EUB information office and a staff resource team that focuses on public consultation;
• Improved written material on technical issues related to sour gas and the role of the EUB and its regulatory and enforcement actions;
• Greater emphasis by the EUB in developing relationships with all stakeholders;
• More information sessions and workshops respecting sour gas; and
• Actions that would make it easier for the public to contact appropriate industry and EUB officials.

The Committee believes special attention is required to improve the relationship between the EUB and Aboriginal people. Towards this objective, it is recommending that the EUB

• Engage appropriate staff, including First Nations persons, and consider forming an Aboriginal advisory committee, to ensure more interaction among the EUB, industry and Aboriginal people;
• Strictly apply its public consultation requirements in and around First Nations and Metis communities;
• Ensure that a good complaint, monitoring and incident response program exists in First Nations and Metis communities; and
• Work with federal and other levels of government to ensure effective relationships among all parties, to eliminate gaps in regulation, to ensure overlap in regulation is handled efficiently, and to provide adequate infrastructure and resources to Aboriginal people for planning and development of disaster services capability.

The Committee heard many concerns about all aspects of emergency response planning (ERP), including the decision-making processes used to approve reduced emergency planning zones. It is making many recommendations to address these matters. They include

• At the time of application, assessment by the EUB of the capability of an operator to effectively implement an ERP;
• Improved early coordination with other responders and other plans in the area;
• More frequent audits by the EUB and development of requirements for mandatory testing of ERPs;
• Development of requirements and clear evacuation criteria for sulphur dioxide(SO₂) when a well is ignited;
• Development of clear criteria for introducing a reduced EPZ;
• Clarification of additional required protective measures for public health and safety when an EPZ is reduced, including improved definition of immediate ignition and roles and responsibilities; and
• More complete and concise guidelines and requirements for the development and implementation of ERPs.

The Committee directs numerous recommendations towards improving the EUB sour gas regulatory system as it relates to public health and safety. These include

• Consolidation, where possible, of sour gas requirements, and preparation of a summary document of requirements;
• Consideration of some additional or revised regulations;
• Increased inspections and audits, particularly for operators without a good performance record in sour gas operations;
• Improved response to sour gas complaints and more involvement of EUB staff in solving operational issues;
• Alterations to the enforcement ladder for sour gas operations to involve fewer, faster steps and more severe sanctions where there is a threat to public health and safety;
• Greater attention to the content and review of sour gas applications;
• Greater reliance on mediation and less formal hearings when they do occur;
• Recognition by the EUB of the performance of applicants in sour gas operations when making decisions;
• Greater recognition of public input and more descriptive material respecting public interest criteria in decision reports;
• The availability of appropriate expertise to the EUB; and
• Greater emphasis by the EUB on its role as a neutral regulator and on the profile of matters related to public health and safety.

The Committee recommends that, as the principal regulator of sour gas matters, the EUB take the lead role in clarifying and coordinating the responsibilities and roles of all parties that have some jurisdiction respecting sour gas. The Committee believes there are benefits to be gained by the parties working together in this regard. In terms of planning, the Committee recommends the immediate formation of a task force to investigate the possibility of improving coordination between subsurface and surface planning and development. It also recommends more stringent enforcement of the EUB's sour plant proliferation policy, and increased efforts to minimize proliferation of other sour gas facilities.

A number of recommendations are directed towards improved follow up of major sour gas releases, and efforts towards a more consistent medical response and improved records for those who have experienced substantial exposures to sour gas. Additionally, the Committee recommends that the EUB review current monitoring capability and ensure that it is adequate, not only for significant sour gas releases, but for other required monitoring such as complaint response and compliance programs.

A number of recommendations deal with the need to review, and, as appropriate, improve training for both industry and EUB personnel, in all relevant areas, including knowledge of sour gas, communication of risk and other technical information, and consultation with the public.

The Committee is asking the EUB to develop a plan to implement all of its recommendations, to make the plan public, and to publicly report progress towards implementation, each calendar year quarter, until all of the recommendations have been addressed.