Mountain View County councillors have passed a motion expressing concerns with proposed changes being made to provincial legislation governing emergency response and preparedness in the event of oilfield emergencies.
The Energy Resources Conservation Board (ERCB) is proposing changes to its Directive 071 Emergency Preparedness and Response Requirements.
As part of that process, municipalities and industry groups have been asked for input and comments on the proposed changes.
One of the changes being proposed would require energy resource companies (called duty holders in the directive) to "strive to obtain the following information for each surface development in the emergency planning zone: emergency contact representative name; exact location of the surface development; a 24-hour contact telephone number.î
That change is of concern to the county because the duty holder would now be required to "strive to obtainî but would no longer be "required to obtainî the information, which, in turn, could create a public safety concern if the information is not required to be available, said Reeve Bruce Beattie.
During last week's policies and priorities committee meeting, councillors passed the following motion: "That the committee recommend that a letter from council regarding Directive 071 (be sent to the ERCB) and that we perceive that there is a weakening in the public safety and that that would not be acceptable in the final document.î
In a Gazette interview following the motion, Beattie added: "We are concerned that because they are proposing to relax the requirement for oil companies to collect this information, that information will no longer be available should there be an emergency.
"So are we going to be expected to collect that information? We think it could be a significant downloading on the county.î
Changes to Directive 071 are being proposed in a large number of areas, including notification of residents in emergency response zones, the operation of incident command centres, and the setup of emergency response plans.
One change would require duty holders to "strive (again, no longer require) to reach an agreement with local and aboriginal authorities on the specific needs, roles, and responsibilities of each party during an emergency, and include a summary of these roles and responsibilities in its emergency response plan.î
The updated directive also would require duty holders to have site-specific emergency response plans, public awareness and corporate emergency management programs in place.
Another proposed change would require the duty holder to develop communication plans that identify such things as call-out procedures and immediate action checklists.
For critical sour well drilling or completion operations, the duty holder would be required to ensure that the equipment identified in the emergency response plan is located where specified in the plan before critical zone operations begin.
The duty holder's emergency response plans would also be required to include well information, including if applicable, the maximum expected H2S concentrations and corresponding maximum cumulative H2S release rates, and pipeline information, including the location of emergency shutdown valve locations and the segment distance between valves, and licensed and maximum expected operating pressures.
Under the Municipal Government Act and the Emergency Management Act, counties, including Mountain View County, are assigned the authority and the responsibility for all aspects of an emergency response.
As part of the Directive 071 review process, Sundre Petroleum Operators Group (SPOG) officials have also reviewed the proposed changes and provided the following comments to the ERCB:
ï Regarding the new requirement that would require the duty holder to complete risk assessment on all oil and gas activities that pose a potential risk to the public, SPOG said: "To ensure consistency from one duty holder to another the directive should be prescriptive in the methodology to be used in industry risk analysis. Otherwise one duty holder may interpret and then classify the risk at a different level than another.î
ï Regarding the assigning of authority and the responsibility for all aspects of an emergency to counties, SPOG said: "Typically municipalities do not have the knowledge or experience with oil operations to deal appropriately with incidents within the emergency planning zones. The emergency response plan planning and response should fall on the duty holder and the mutual aid agreement should ensure functional relationships exist with the municipalities and the duty holder.î
ï Regarding the collection of rental resident information, SPOG's recommendation is to collect that information from the rental property owners, adding: "Typically renters are a transient population and do not stay in a residence for more than one year.î
SPOG is also recommending that duty holders actively participate in all local mutual aid and synergy groups, saying: "In today's world, companies are doing more with fewer resources and these groups help fill the gap between the minimum requirement and the social licence to operate in a community.î
SPOG is a collection of oil and gas companies with operations in West Central Alberta. It promotes awareness of oilfield issues through open houses, newsletters and other activities.
The ERCB expects to have all changes to Directive 071 completed by 2015.
