In an effort to obviate official regulation, the old Canadian Petroleum Association – the forerunner to today’s Canadian Association of Petroleum Producers – created an industry-wide voluntary code of waste management practices. Although regarded as a good stop-gap measure, the CPA guidelines didn’t last. Governments soon took over the job of regulation.

The ERCB’s role in waste regulation began in the mid-1980s, when the industry began to recognize that oil could be recovered from oily leftover materials in tank bottoms, separator sludge, flare pits and so on. Facilities known as reclaimers began to emerge in active oil- and gas-producing areas. At first, the board’s regulation of these facilities was aimed at making sure volumes of recovered oil were accounted for properly. Spurred by the federal government’s 1986 proclamation of dangerous goods transportation regulations, though, the board became heavily involved in oilfield waste management, regulation and inspection.

In 1990, Alberta began consolidating existing environmental acts and regulations into a comprehensive document that eventually became known as the Environmental Protection and Enhancement Act. This and other environmental measures slice and dice provincial wastes in a number of ways. They can be classified as oilfield wastes or industrial wastes, and those wastes can be hazardous, dangerous or not-dangerous. Alberta Environment regulates hazardous and industrial wastes. The ERCB regulates oilfield wastes.

As waste regulation evolved, it became apparent that reclamation or recycling services could no longer be permitted to operate without regulation. After all, they were reclaiming wastes that were potentially dangerous, and sometimes hazardous. Hazardous oilfield wastes include hydrocarbons with low flashpoints; highly acidic or alkaline chemicals; and such volatile organic compounds as benzene, toluene, ethylbenzene and xylenes, which collectively go by the acronym BTEX.

After these products had been defined as hazardous, the board gave the owners of the province’s reclaimer operations a simple choice. Transform their facilities into high-standard waste management facilities or, in the words of CCS Corporation’s Greg Dickie, “clean them up and shut them down.” Most chose to convert to quality waste management operations.

With oilfield waste facilities not allowed to handle hazardous materials, the province badly needed a large disposal facility. Accordingly, Alberta developed a “special waste treatment center” northwest of Edmonton at Swan Hills to deal with hazardous oilfield wastes and also carcinogenic PCBs, which are primarily a waste product from electric transformers. Owned by the province but operated by the private sector, Swan Hills is primarily a specialized, high-temperature waste incinerator. The oilfield wastes that require incineration there include spent filters, oily rags and specialized high-BTU wastes.
As the 1990s wore on, regulators developed rules covering everything from the construction of landfills to deep well injection of liquid wastes. Those rules and the constant changes to them are available in a glut of guidebooks, information letters, directives and interim directives – all of which have been posted online by the agencies responsible.

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