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responsibilities

    BP Canada Energy Company Contents

    Standard Environmental Practices Manual Page: 1 of 2

    BP CANADA ENERGY COMPANY

    STANDARD ENVIRONMENTAL PRACTICES MANUAL

    TABLE OF CONTENTS

INTRODUCTION

    A1: AIR QUALITY MONITORING

    E1: EMERGENCY RESPONSE PLANNING AND IMPLEMENTATION ENVIRONMENTAL

    CONSIDERATIONS

    E2: ENVIRONMENTAL PROTECTION PLANNING AND IMPLEMENTATION

    E3: ENVIRONMENTAL SAMPLING

    F1: FLARE PITS CLOSURE F2: FLARING OF GASES

    G1: GROUNDWATER MONITORING

    H1: HOUSEKEEPING AND SITE MAINTENANCE

    I1: INJECTION AND DISPOSAL WELLS

    N1: NOISE CONTROL

    P1: PERMITTING AND LICENSING OF FACILITIES -- ALBERTA

    P2: PIPELINE AND RIGHT-OF-WAY MAINTENANCE

    P3: PIPELINE DISCONTINUATION (SUSPENSION)

    P4: PIPELINE REPAIR/EXPANSION -- PROTECTION OF TERRESTRIAL RESOURCES

    P5: PIPELINE REPAIR/EXPANSION -- CREEK & STREAM CROSSINGS

    P6: PIPELINE RIGHT-OF-WAY TRAVEL PRACTICES

    P7: PIPELINE HYDROSTATIC TESTING

    P8: PIPELINE RIGHT-OF-WAY REVEGETATION

    R1: RECLAMATION CERTIFICATION

    R2: RECLAMATION PLANNING FOR DECOMMISSIONING

    S1: SOIL MONITORING

    S2: SOIL REMEDIATION AND DECONTAMINATION

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    BP Canada Energy Company Contents

    Standard Environmental Practices Manual Page: 2 of 2

    S3: SPILL OR UNCONTROLLED RELEASE

    S4: STORAGE TANKS OPERATIONS, MAINTENANCE AND INSPECTION PRACTICES

    S5: SURFACE WATER MANAGEMENT

    S6: SURFACE WATER MONITORING

    T1: TANK OPERATIONS ISOLATING AND CLEAN-OUT

    T2: TRAINING

    V1: VEGETATION MANAGEMENT

    W1: WASTE MANAGEMENT -- GENERAL

    W2: WASTE MANAGEMENT -- FILTERS

    W3: WASTE MANAGEMENT -- LANDFILLS

    W4: WASTE MANAGEMENT -- LANDSPREADING

    W5: WASTE MANAGEMENT -- N.O.R.M. CONTAMINATED WASTE

    GLOSSARY

    CONVERSIONS

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BP Canada Energy Company Introduction

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Standard Environmental Practices Manual

    Authority: Custodians: GHSER Practices Committee Jason Groot, Gas BU

    Jim Robert, NGL BU Scope: Issuing Dept. BP Canada Energy Company BP Canada HSE Issue Date: Last Revision Date: January 15, 2003 January 15, 2003 Control Status: Next Revision Date: Uncontrolled Document January 15, 2004

INTRODUCTION

Purpose:

    To provide a tool for use in BP Canada‘s Environmental Management System to help guide employees and contractors when undertaking activities that require the implementation of

    environmental protection procedures.

Scope:

Activities associated with Gas and NGL production regularly generate and ultimately release to

    the environment liquid, solid and gaseous products (environmental aspects). Failure to provide

    proper management of such materials results in environmental impacts that may require

    remediation and reclamation. Changes to operations or procedures may be required to mitigate

    the environmental impact. These changes, although sometimes costly, reduce BP Canada‘s

    environmental liability and save money over the full life of the project.

This resource manual provides information on a variety of environmental practices and related

    regulatory documents. The manual can be used as a guide to ensure that environmental

    protection and awareness are given proper attention in all components of the operations of Gas

    and NGL plants, pipelines, wells and associated facilities. The SEPM serves as a guide for BP

    Canada operations in Alberta, British Columbia, Saskatchewan and Ontario. These operations

    may be provincially or federally regulated. The majority of the environmental practices are

    applicable across provincial and federal jurisdictions, but in some cases a practice will be

    applicable only to operations within a specific jurisdiction. The requirements of legislation for the

    applicable regulatory jurisdiction will always supersede the specifics of any practices described

    in this manual. The listing of related regulatory documents for each practice may not include all

    potential regulatory requirements that would apply to the use of the practice, or recent changes

    in regulatory requirements. Users of the manual should always check with the HSE Coordinator

    for recent amendments or additions to regulatory requirements.

This manual is prepared for use by all BP Canada employees, contracted employees and

    contractors in the development and implementation of work methods designed to minimize

    environmental risk while at the same time maximizing environmental protection. Materials

    included in the manual comply with governing regulations, standards, BP Canada requirements

    and proven environmental practices. These practices should be used as a guide when

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BP Canada Energy Company Introduction

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conducting task analysis and establishing procedures in alignment with BP‘s GHSER

    Management System.

The practices have been developed and presented such that they can be readily incorporated

    by field personnel into the planning, design and implementation activities of all operations. The

    manual covers many, but by no means all of the jobs and situations encountered in BP

    Canada‘s operations. Should situations arise which are not adequately covered in the manual,

    please bring it to the attention of your HSE Coordinator.

The responsibility for environmental protection rests with all employees and contractors.

    Management and employees must work together if incident prevention is to be effective. No job

    is so urgent that it cannot be done without due care and consideration for health, safety and

    environmental protection.

Revision Procedure:

The Environmental Practices Manual is intended to be a ―living‖ document, and suggestions for

    revisions by BP Canada employees and contractors will be welcomed. To initiate a revision,

    please follow these procedures:

    1. Fill out the form on the next page or prepare an e-mail using the form as a guide.

    2. Clearly identify the practice to be revised.

    3. Forward the form or send your e-mail to the HSE Coordinator responsible for your

    Area.

    4. Alternatively, call a HSE Coordinator and provide them with the details of your

    suggested revision.

The GHSER Practices Committee will convene periodically to review all suggested revisions.

Practices Manual Updates:

When you receive revised practices, immediately replace the old practices in your manual with

    the revised practices. If you receive an entire revised manual, immediately discard (paper

    recycle) the old manual. It is important that the replacement be done immediately upon receipt

    of a revision, so your manual will always be up-to-date.

Always check the BP Canada or your Business Unit web site, or check with your HSE

    Coordinator, to ensure you are using the most recent version of a practice.

Revision Log

Revision Date Authority Revisers Revision Details

    January 15, 2003 GHSER Practices Peter Zimmerman ? Entire environmental practices

    Committee Jim Robert manual updated to address EMS,

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    regulatory and other changes.

    SUGGESTED REVISION

Title of Environmental Practice:

Suggested Revision:

     (use additional sheets if necessary)

Suggested by: ____________________________________________________________

Location: _________________________________________________________________

Telephone Number: _______________________ Date: ___________________________

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BP Canada Energy Company A1

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A1: AIR QUALITY MONITORING

PURPOSE:

To describe BP Canada‘s responsibilities in monitoring source emissions and reporting the

    findings as per regulatory approvals.

APPLICATION:

Air quality sampling and monitoring is required when specified in environmental licenses, in

    response to resident or landowner concerns, or in cases of spills, blowouts, pipeline breaks and

    other uncontrolled releases. Airshed or regional monitoring alliances may also define

    specialized air quality sampling and monitoring programs that BP Canada may participate in

    either on a voluntary basis or as a requirement of an environmental approval. Sampling

    protocols and criteria for ambient and stack monitoring are typically specified in directives,

    codes or guidelines issued by provincial regulatory agencies with responsibility for air quality.

DEFINITION:

Sampling is the activity of taking a single measurement or sample, while monitoring is a series

    of measurements or samples taken over a period of time. Various types of air monitoring may

    be undertaken:

    ? Ambient monitoring measures the concentration of a contaminant on a continuous basis 3over time. Results are reported in ppm or mg/m. Common ambient monitoring parameters

    include HS, SO, NOx, total hydrocarbon and particulates. The air monitoring 22

    instrumentation may be set up at a fixed location or in a mobile unit. Mobile units are

    preferred in the case of an uncontrolled release or pipeline release. Air monitoring data are

    important in assessing the safety of the public and addressing any public concerns on air

    quality related to an incident.

? Static monitoring is used to measure the total exposure to a chemical over a given period

    (monthly or quarterly), e.g., HS and total sulphation. Results of HS and total sulphation 222static monitoring are reported as SO equivalent mg/day/100 cm. This is typically done by 3

    housing the sampling device in a structure commonly referred to as a ―birdhouse‖.

    ? Continuous stack emission monitoring (CSEM) may be used to analyze and quantify one

    or several compounds emitted in stack gas on a continuous basis, as well as related

    parameters such as stack top temperature. For example, continuous stack emission

    monitoring is a regulatory requirement for incinerator stacks at sour gas processing plants

    with sulphur recovery in order to monitor SO emissions on a continuous basis. 2

    Stack surveys may be conducted by third-party consultants at specified intervals (e.g., twice

    per year at sulphur recovery plants in Alberta) to verify the accuracy of the CSEM and to

    calibrate emission estimation parameters. Regulatory agencies publish standards for CSEM

    performance and for stack sampling procedures.

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BP Canada Energy Company A1

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RESPONSIBILITIES:

HSE Coordinator

    ? Reviews number, location and site conditions for air monitoring devices to ensure

    conformance with regulatory approvals, codes, directives and/or guidelines. ? Initiates mobile air monitoring unit in the case of an uncontrolled or pipeline release. ? Maintains liaison with Airshed or Regional Monitoring Alliances, if company is a participant. ? Ensures any license requirements with respect to Airshed or Regional Monitoring Alliances

    are being met.

    ? Ensures, where required, that monthly and annual air reports are submitted to regulatory

    agency by the deadline dates.

HSE Coordinator and/or Foreman

    ? Coordinates stack surveys, as per regulatory requirements, with plant staff and consultant. ? Ensures Operations personnel or contractor (qualified instrument technicians) provide

    calibration and maintenance of air monitoring devices.

    ? Ensures Continuous Emissions Monitoring (CEM) systems meet regulatory code

    requirements for installation, operation, maintenance, certification, and quality assurance

    and quality control of CEM data.

Operator/Contractor

    ? Conducts monthly visual inspection of monitoring trailers and birdhouses, and notifies HSE

    Coordinator of any obvious problems (e.g., vandalism, birdhouse knocked off fencepost,

    etc.).

    ? Maintains and calibrates CSEM and ensures all necessary parameters are being recorded. ? Notifies HSE Coordinator of significant problems with CSEM.

    ? Changes static monitoring devices as per defined schedule and forwards to laboratory for

    analysis.

PROCEDURES:

    ? Identify and understand all air monitoring and reporting requirements contained in facility

    approvals or environmental licenses.

    ? Identify reporting deadlines for monthly and annual air reports.

    ? Fulfill reporting requirements in an accurate and timely fashion.

    ? Identify the locations of the facility‘s air quality monitoring trailers and/or ―birdhouses‖.

    ? Identify any requirements for participation in Airshed or Regional Monitoring Alliances. ? Check the integrity of air monitoring devices to protect against vandalism or other

    disruptions.

    ? Follow the specifications set out in the applicable regulatory directive, code or guideline in

    choosing and siting air monitoring equipment.

    ? Ensure CSEM is operated, maintained and certified in accordance with CEMS code

    requirements.

    ? Report on and follow-up on any exceedences as applicable.

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POTENTIAL HAZARDS/PRECAUTION/RISK/LIABILITY:

? Long-term exposure to air emissions can have an adverse impact on soil, water and

    vegetation.

    ? Air emissions and their related smoke or odours can result in harm to neighbour/community

    relationships.

    ? Failure to meet a facility‘s monitoring and reporting requirements may result in fines,

    prosecution or suspension of operations.

SUPERVISOR/ADMINISTRATION/REPORTING:

? Monthly and annual air reports must be submitted to regulatory agencies by the deadline

    dates; refer to the facility‘s approval or environmental license for report submission

    requirements.

RELATED LEGISLATION/REGULATORY REQUIREMENTS:

    (Always check with the HSE Coordinator for recent amendments or additions.)

    ? Facility environmental license or approval (Alberta, B.C., Saskatchewan, Ontario).

Alberta

    ??AENV: Air Monitoring Directive (AMD), June 1989; Alberta Stack Sampling Code, 1996;

    ??Continuous Emissions Monitoring System (CEMS) code, May 1998; Air Quality

    ?Model Guideline, October 2000; Alberta Ambient Air Quality Guidelines, February

    ?2000; Environmental Protection and Enhancement Act, RSA 2000, c. E-12, as

    ?amended; Substance Release Regulation, AR 124/93, as amended.

    ?EUB: IL 79-16, Revised Incinerator Stack Exit Temperature Criteria for Plants Processing

    ?Sour Gas; ID 2001-03, Sulphur Recovery Guidelines for the Province of Alberta.

British Columbia

    ?WLAP Air Audit Criteria For Continuous Air Quality Monitors: CEMs and Ambient Air Quality,

    ?December 1999; Source Testing Code For the Visual Measurement of The Opacity

    ?of Emissions From Stationary Sources, October 1994; Stationary Air Emissions

    ??Testing, 2000; Emission Criteria for Gas Turbines, December 1992; Sulphur

    ?Recovery Criteria For Natural Gas Processing Plants, January 1994; British

    Columbia Field Sampling Manual: For Continuous Monitoring, plus the Collection of Air,

    Air-Emission, Water, Wastewater, Soil, Sediment, and Biological Samples (1996).

Saskatchewan

    ??SE: Clean Air Act, Statutes of Saskatchewan c. C-12.1 as amended; Clean Air

    Regulations, Chapter C-12.1 Reg 1 (effective November 1, 1989).

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Ontario

    ??MOE: Ambient Air Quality Criteria, R.R.O. 1990, Reg 337, as amended; Airborne

    ?Contaminant Discharge Monitoring and Reporting, O. Reg. 127/01; GeneralAir

    ?Pollution, R.R.O. 1990, Reg. 346, as amended; Guideline for the Installation and

    Operation of Continuous Emission Monitoring (CEM) Systems and Their Use for

    ?Reporting under the Provisions of Regulation O. Reg. 127/01, April 2001; Step by

    Step Guideline for Emission Calculation, Record Keeping and Reporting for Airborne

    ?Contaminant Discharge, August 2002; Ontario Source Testing Code (Version #2),

    ?November 1980; Environmental Protection Act, R.S.O. 1990, c. E.19, as amended;

    ?Guideline A-5 Atmospheric Emissions From Stationary Combustion Turbines.

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