Eg14e PDF

Guidelines for Conducting
Environmental Audits for the

Projects
Petroleum Industry
Documents
Home
ARPEL Environmental Guide No. 14
Guidelines for Conducting Environmental Audits for the Petroleum Industry
August 25, 1997
Funding
This document has been exclusively prepared for the ARPEL Environmental Project Phase 2. The Project
was funded by the Canadian International Development Agency (CIDA) and co-managed by the
Environmental Services Association of Alberta (ESAA) and the Regional Association of Oil and Natural
Gas Companies in Latin America and the Caribbean (ARPEL).
Environmental Services Association of Alberta Regional Association of Oil and Natural Gas
#1710, 10303 Jasper Avenue Companies in Latin America and the Caribbean
Edmonton, Alberta T5J 3N6 Javier de Viana 2345
Tel: (780) 429-6363 CP 11200 Montevideo, URUGUAY
Fax: (780) 429-4249 Tel.: (598-2) 410-6993 – 410-7454
E-mail: info@esaa.org Fax: (598-2) 410-9207
E-mail: arpel@arpel.org.uy
Copyright
The copyright in this document or product, whether in print or electronically stored on a CD or diskette or
otherwise (the "Protected Work") is held by the Environmental Services Association of Alberta (ESAA).
The Regional Association of Oil and Natural Gas Companies in Latin America and the Caribbean (ARPEL)
has been granted a license to copy, distribute and reproduce this Protected Work on a cost-recovery and
non-commercial basis. This Protected Work shall not, in whole or in part, be copied, photocopied,
reproduced, translated or reproduced to any electronic means or machine-readable form without prior
consent in writing from ESAA. Any copy of this Protected Work made under such consent must include
this copyright notice.
Authors
These Guidelines have been prepared upon request of ARPEL and its Environment, Health and Safety
Committee by:
Western Oilfield Environmental Services
1100, 550 - 6th Avenue S.W.
Calgary, Alberta T2P 0S2
Tel.: (403) 266-3286
Fax: (403) 262-3430
E-mail: wci@cadvision.com
Consultants were assisted in detailed drafting and revision by the ARPEL Environmental Audits Working
Group.
Reviewers
Oldemar Ramirez RECOPE
Jayme de Seta Filho PETROBRAS
Enrique Escobar YPFB
Miguel Moyano ARPEL Executive Secretariat
Oscar González Environmental Services Association of Alberta
Disclaimer
Whilst every effort has been made to ensure the accuracy of the information contained in this publication,
neither ARPEL, nor any of its member, nor ESAA, nor any of its member companies, nor CIDA, nor the
consultants, will assume liability for any use made thereof.
Guidelines for Conducting Environmental Audits for the Petroleum Industry Operations
ABSTRACT
Environmental Auditing is a process of evaluation of environmental performance,

management systems and compliance with regulations as well as internal policies and
procedures. Many benefits can occur by identifying existing or potential problems
within a facility or operations. For example, audits can provide early warning detection,
ensure compliance with regulations and corporate policies and procedures, verify
effectiveness of established environmental management policies, prioritize spending,
etc.
To maintain regulatory compliance, an organization should identify and understand

regulatory requirements applicable to its activities, products and services. An
environmental policy should consider laws and regulations and the organization’s
vision, core values, and beliefs. Environmental policies and procedures set the goals
for the level of performance required of the organization.
There are different types of operational audits: management, exploration, production,

pipeline and transportation, waste management, baseline, maintenance and special
audits. An environmental audit consists of general practices applicable to any
environmental audit which when executed correctly, will lead to consistent, meaningful
and practical results. The audit process involves preliminary activities, site
assessment, analysis and reporting.
Preliminary activities have to be completed before the onsite inspection. This includes
setting up the scope of the audit, selecting representative facilities, scheduling/logistics
and documentation review. Phase I site assessment activities include a detailed
records review, interviewing and a facility/field inspection. The generated data is then
evaluated and a report is prepared. Phase II and III assessments are implemented if a
non-compliance situation is found after Phase I.
A set of specific Protocols and Guidelines are provided for different onshore and
offshore petroleum operations (i.e., Seismic, Drilling, Production, Pipeline,
Transportation and Terminals and Refinery activities). Specific instructions are
provided to conduct a site assessment in the areas of Environmental Planning, General
Operating Procedures, Spill Prevention, Emergency Response, Waste Management,
Abandonment and Reclamation.
i ARPEL Environmental Guideline No. 14

INTRODUCTION
The Guidelines for Conducting Environmental Audits for the Petroleum Industry
Operations is a component of the Environmental Audits Project of the ARPEL
Environmental Program Phase 2. The document has been prepared to facilitate a
process of compliance with local and international regulations, compliance with
corporate policies and procedures and protection of the environment by ARPEL
member companies through the implementation of environmental audits. It contains
general information regarding the environmental auditing process as well as specific
Environmental Audit Guidelines for the ARPEL petroleum member companies.
Many Latin American countries have recently adopted laws and regulations for
environmental protection. Within these regulations, some countries are requiring that
routine environmental audits are conducted within the industry sector.
The specific objectives of this document are:
• To describe general concepts of the environmental auditing process and its

different phases.
• To assist the ARPEL member companies in understanding the requirements for

complying with national environmental regulations, corporate policies and
procedures and the ARPEL industry standards relating to environmental audits.
• To develop a practical manual or guidelines on how to complete environmental

audits for onshore and offshore petroleum operations.
• To assist ARPEL member companies in understanding the benefits of

environmental audits and environmental management systems.
• To enhance environmental auditing techniques and skills within the ARPEL

member companies.
• To complement the “Guidelines for Conducting Environmental Audits for Onshore

Petroleum Operations” developed in the ARPEL Environmental Program Phase 1.
The new guidelines contain a general procedure on how to conduct environmental
audits. They provide more detailed topic information; however, they utilize the
same general headings as the Phase 1 guidelines. In addition, offshore petroleum
operations are covered in the new document.
ARPEL Environmental Guideline No. 14 ii

GUIDELINES FORMAT AND INSTRUCTIONS FOR USE
The Guidelines are provided into three sections as indicated below:
Section I Environmental Audit Reference

Section II Environmental Auditing User Guidelines
Section III Environmental Audit Protocols and Guidelines
Section I Environmental Audit Reference
This section is intended to provide general concepts of environmental auditing.

Section I is divided into the following chapters:
Chapter Title
1 Introduction to Environmental Auditing.

2 Environmental Criteria.
3 Corporate Compliance Strategy.
4 Operational Environmental Audits in the Oil and Gas Industry.
5 Overview of Environmental Assessments.
Section II Environmental Auditing User Guidelines
This section describes the environmental audit process by activities and phases.
Some chapters include examples of checklists and interview questionnaires.
Section II is divided into the following chapters:
Chapter Title
6 Phase I Environmental Audit.

7 Phase II Assessments.
8 Phase III Assessments.
9 Examples of Records Checklists.
10 Examples of Interview Protocols.
11 Examples of Field Inspection Checklists.
iii ARPEL Environmental Guideline No. 14

Section III Environmental Audit Protocols and Guidelines
This section contains specific audit guidelines for onshore and offshore petroleum
operations. Section III has the following chapters:
Chapter Title
12 Onshore Operational Audit Guidelines

13 Offshore Operational Audit Guidelines
Guideline Instructions for Chapters 12 and 13.
Chapter 12 and 13 provide environmental audit guidelines for specific oil and gas
operations.
Chapter 12: Onshore Operational Audit Guidelines
Type of Activity Sections Topics
12.1 Seismic
Environmental Planning Regulatory Environmental Authorization;

Environmental Concerns.
General Operating Procedures Surveying and Staking; Topsoil

Conservation; Access Control; Access
Roads; Stream Crossings; Drainage;
Cutting, Clearing and Timber Salvage;
Erosion Control; Explosives; Fire Control;
Other Environmental Concerns.
Spill Prevention and

Emergency Response Spill Prevention; Spill Response.
Waste Management Waste Storage; Sewage Effluent and

Wastewater Treatment; Disposal
Operations.
Abandonment and Reclamation Cleanup Operations; Road Abandonment;

Land Reclamatio;Revegetation Programs.
12.2 Drilling

Environmental Concerns.
ARPEL Environmental Guideline No. 14 iv

General Operating Procedures Access Control; Stream Crossings; Cutting,

Clearing and Timber Salvage; Topsoil
Conservation; Erosion Control; Drainage;
Access Roads; Protection of Freshwater
Horizons; Blowout
Prevention Plan; Flaring During Completion
and Testing of Gas and Oil Wells; Spill
Containment; Drilling Mud Systems; Noise.

Emergency Response Spill Prevention; Emergency Response for
Well Drilling, Completion or Testing of Sour
Wells; Spill Contingency Plans.
Waste Management Sewage Effluent and Wastewater

Treatment; General Waste Disposal; Sump
Construction; Disposal Waste of Drilling
Fluids and Solids; Disposal Options for the
Sump Fluids; Disposal Options for
Workover and Completion Wastes.
Abandonment and Reclamation Well Abandonment; Rig Dismantling and Site

Completion; Land Reclamation;
Revegetation.
12.3 Production
Environmental Planning and

Administration Regulatory Environmental Authorization;
Personnel Training; Environmental
Concerns.
General Site Information Site Information.
General Operating Procedures Surface Casing Vents; Pigging; Pumpjacks;

Valves and Wellheads; Flowlines; Well-
Blowdowns; Separators and Treaters;
Dehydration Units; Sulphur Recovery;
Cathodic Protection; Tank Operations;
Distribution Lines; Product Storage;
Chemical and Hazardous Material Storage
and Handling; Vapour Recovery Units;
Transportation; Access Roads, Access
Control; Perimeter Berms; Stream
Crossings; Housekeeping; Flare Pits; Flare
Stacks; Release of Produced Water;
Release of Hydrocarbons; Site
Maintenance; Noise; Drainage and Erosion;
Surface Water Monitoring; Soil Sampling
and Monitoring; Groundwater Monitoring;
Water Release; Gaseous Emissions; Air
Quality Monitoring.
v ARPEL Environmental Guideline No. 14

Spill Prevention & Emergency

Response Release/Spill Prevention; Spill/Release
Contingency Plans; Emergency Response.
Waste Management Waste Management Plan; Disposal of

General Solid Wastes; Asbestos; Sewage
Effluent and Wastewater Treatment;
Sewage Lagoons; Recycling; Water
Recycling and Reuse; Disposal of Oil Based
Wastes; Disposal of Gas Processing
Wastes; Filters; Disposal Wells; Sulphur
Handling.
Abandonment and
Reclamation Reclamation Plan; Site Dismantling; Closure
of Flare Pits; Tank Removal; Well
Abandonment; Decontamination; Soil
Remediation; Recontouring; Revegetation;
Reclamation Assessment.
12.4 Pipelines, Transportation and Terminals

Personnel Training; Environmental
Concerns.
General Site Information Site Information.
Pipeline Construction Right-of-Way Survey; Cutting, Clearing and

Timber Salvage; Topsoil Conservation;
Grading; Trenching; Pipe Stringing;
Backfilling; Testing; Fire Control;
Environmental Concerns During
Construction.
General Operating Procedures Distribution Lines; General Operations at

Marine Terminals; Pumps and Transfer
Systems; Valves; Cathodic Protection; Tank
Operations; Product Storage; Chemical
Hazardous Material Storage and Handling;
Vapour Recovery Units; Access Roads;
Access Control; Perimeter Berms; Stream
Crossings; Housekeeping; Flare Stacks;
Release of Produced Water; Release of
Hydrocarbons; Site Maintenance; Noise;
Drainage and Erosion; Surface Water
Monitoring; Soil Sampling and Monitoring;
Groundwater Monitoring; Water Release;
Gas Release; Air Quality Monitoring.
Emergency Response Release/Spill Prevention; Spill/Release
Contingency Plans; Emergency Response.
ARPEL Environmental Guideline No. 14 vi

Waste Management Waste Management Plan; Disposal of

General Solid Wastes; Asbestos; Sewage
Effluent and Wastewater Treatment;
Sewage Lagoons; Recycling; Water
Recycling and Reuse; Disposal of Oil Based
Wastes; Filters.
Abandonment and
Reclamation Reclamation Plan; Site Dismantling; Tank
Removal; Road Abandonment; Risk
Management; Decontamination; Soil
12.5 Refineries
Environmental Planning
and Administration Regulatory Environmental Authorizat ion;Personnel
Training; Environmental Concerns.
Preliminary Audit Activities Process and Installation Drawings.
General Site Information Site Information
General Operating Procedures Processing, Filter Vessels and Treaters;

Sulphur Recovery; Cathodic Protection; Bulk
Product Receipt and Delivery; Tank
Operations; Distribution Lines; Product
Storage; Vapour Recovery Units; Chemical
and Hazardous Material Storage and
Handling; Site Maintenance; Access Roads;
Access Control; Perimeter Berms;
Housekeeping; Flare Stacks; Release of
Hydrocarbons; Noise; Drainage and
Erosion; Surface
Retention/Holding/Industrial Runoff Ponds;
Surface Water Monitoring; Soil Sampling
and Monitoring; Groundwater Monitoring;
Water Release; Gaseous Emissions; Air
Quality Monitoring.
Spill Prevention
and Emergency Response Release/Spill Prevention; Spill/Release;
Contingency Plans; Emergency Response .
Waste Management Disposal of Refinery Wastes; Exposure to

Toxic Substances; Sewage Effluent and
Wastewater Treatment; Specific Effluent
Monitoring Requirements; Laboratory
Analytical Methodology; Waste Management
Plan; Disposal of General Solid Wastes;
Asbestos; Sewage Lagoons; Recycling;
vii ARPEL Environmental Guideline No. 14

Water Recycling and Reuse; Disposal of Oil

Based Wastes; Filters; Disposal Wells;
Sulphur Handling.
Abandonment and Reclamation Reclamation Plan; Site Dismantling; Tank

Removal; Decontamination; Soil
Chapter 13: Offshore Operational Audit Guidelines
Type of Activity Topics
13.1 Seismic Regulatory Environmental Authorization; Environmental

Planning; Consultation and Liaison; Seismic Surveys;
Intertidal Areas; Vessel Operations; Spill Prevention;
Spill Response; Chemical Handling and Storage; Waste
Management; Abandonment/Cleanup Operations.
13.2 Drilling Regulatory Environmental Authorization; Environmental

Planning; Consultation and Liaison; General Operating
Procedures; Vessel Operations; Spill Prevention; Spill
Contingency Plans; Spill Response; Chemical Handling
and Storage; Waste Management; Wastewater
Discharges; Sampling and Analysis of Discharges; Well
Suspension and Abandonment.
13.3 Production Regulatory Environmental Authorization; Environmental

Planning; Consultation and Liaison; General Operating
Procedures; Valves and Wellheads; Flare Stacks;
Tanker Operations; Vessel Operations; Spill Prevention;
Spill Contingency Plans; Spill Response; Chemical
Handling and Storage; Waste Management; Wastewater
Discharges; Sampling and Analysis of Discharges;
Disposal of Produced Water; Decommissioning and
Abandonment.
ARPEL Environmental Guideline No. 14 viii

TABLE OF CONTENTS
SECTION I ENVIRONMENTAL AUDIT REFERENCE
CHAPTER 1.0 INTRODUCTION TO ENVIRONMENTAL AUDITING. 1
1.1 DEFINITION OF THE ENVIRONMENTAL AUDIT ................... 1

1.2 BENEFITS OF AUDITS ............................................................ 3
1.3 AUDIT SUPPORT..................................................................... 3
1.4 AUDIT OBJECTIVES................................................................ 4
1.5 ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) ............. 5
CHAPTER 2.0ENVIRONMENTAL CRITERIA ..................................... 9
2.1 REGULATORY AND LEGAL COMPLIANCE ........................... 9
CHAPTER 3.0 CORPORATE COMPLIANCE STRATEGY............... 11
3.1 CORPORATE ENVIRONMENTAL POLICIES AND PROCEDURES

11
3.2 EMPLOYEE TRAINING .......................................................... 12
3.3 OPERATIONAL PERFORMANCE MONITORING................. 13
3.4 ENGINEERING DESIGN CODES AND STANDARDS .......... 14
3.5 OPERATING PRACTICES ..................................................... 14
CHAPTER 4.0 OPERATIONAL ENVIRONMENTAL AUDITS IN THE OIL

AND GAS INDUSTRY........................................................................ 15
4.1 MANAGEMENT AUDIT .......................................................... 15

4.2 EXPLORATION AUDIT .......................................................... 15
4.3 PRODUCTION AUDIT............................................................ 16
4.4 REFINERY AUDIT .................................................................. 16
4.5 PIPELINE, TRANSPORTATION AND TERMINALS AUDIT .. 17
4.6 WASTE MANAGEMENT AUDIT ............................................ 17
4.7 BASELINE AUDIT................................................................... 18
4.8 MAINTENANCE AUDIT .......................................................... 18
4.9 SPECIAL AUDIT ..................................................................... 18
ix ARPEL Environmental Guideline No. 14

CHAPTER 5.0 OVERVIEW OF ENVIRONMENTAL ASSESSMENTS19
5.1 TYPES OF ENVIRONMENTAL ASSESSMENTS .................. 19
CHAPTER 6.0 PHASE I ENVIRONMENTAL AUDIT ......................... 23
6.1 THE AUDIT TEAM.................................................................. 23
6.1.1 Audit Team Leader Responsibilities .................................. 27

6.1.2 Audit Team Member Responsibilities ................................ 28
6.1.3 Professional Conduct ......................................................... 29
6.2 PRELIMINARY AUDIT ACTIVITIES........................................ 29
6.2.1 Terms of Reference ........................................................... 30

6.2.2 Selecting Representative Facilities .................................... 30
6.2.3 Scheduling/Logistics .......................................................... 31
6.2.4 Documentation Requirements and Review........................ 31
6.2.5 Preparation of Questions for Interviews ............................. 36
6.3 PHASE I ASSESSMENT......................................................... 36
6.3.1 Start Up Meeting................................................................. 37

6.3.2 Records Review ................................................................. 38
6.3.3 Interviewing......................................................................... 40
6.3.4 Facility/field Inspection ....................................................... 40
6.3.5 Close-Out Meeting.............................................................. 41
6.4 AUDIT EVALUATION AND REPORTS .................................. 41
6.4.1 Evaluating Data .................................................................. 41

6.4.2 Scoring ............................................................................... 42
6.4.3 Reports and Follow-up ....................................................... 43
6.5 IMPLEMENTATION OF PHASE I AUDIT RECOMMENDATIONS47
6.5.1 Prioritizing Audit Recommendations .................................. 47

6.5.2 Developing the Action Plan ................................................ 48
ARPEL Environmental Guideline No. 14 x

CHAPTER 7.0 PHASE II ASSESSMENTS ........................................ 50
7.1 PHASE II ASSESSMENT........................................................ 50
7.1.1 Sampling and Analysis Programs ...................................... 50

7.1.2 Initial Phase II Assessment ................................................ 51
7.1.3 Expanded Phase II Assessment......................................... 57
7.1.4 Site Investigation Techniques (Soils, Groundwater, Surface
Water) ........................................................................................... 58
7.1.5 Laboratory Analysis ............................................................ 61
7.1.6 Basic Elements of the Phase II Audit Report ..................... 66
CHAPTER 8.0 PHASE III ASSESSMENTS ....................................... 68
8.1 PHASE III ASSESSMENT....................................................... 68
8.1.1 Remedial Investigation Program Components................... 68

8.1.2 Types of Remediation Technologies.................................. 72
8.1.3 Basic Elements of the Phase III Audit Report..................... 72
8.2 ASSESSMENT AND REMEDIATION CRITERIA ................... 73
CHAPTER 9.0 EXAMPLES OF RECORDS CHECKLISTS ............... 78
CHAPTER 10.0 EXAMPLES OF INTERVIEW PROTOCOLS.......... 83
CHAPTER 11.0 EXAMPLES OF FIELD INSPECTION CHECKLISTS86

SITE LOCATION SIGN: YES / NO SAFETY SIGNS POSTED: YES /
NO 87
CHAPTER 12.0 .................................................................................. 99
CHAPTER 12.0 .......ONSHORE OPERATIONAL AUDIT GUIDELINES 101
12.1 Seismic .................................................................................. 101

12.2 Drilling.................................................................................... 101
12.3 Production.............................................................................. 101
12.4 Pipelines, Transportation and Terminals .............................. 101
12.5 Refineries............................................................................... 101
xi ARPEL Environmental Guideline No. 14

12.2 Drilling.................................................................................... 131

12.5 Refineries............................................................................... 327
CHAPTER 13.0 OFFSHORE OPERATIONAL AUDIT GUIDELINES403
13.1 Seismic .................................................................................. 403

13.2 Drilling.................................................................................... 403
13.3 Production.............................................................................. 403
ARPEL Environmental Guideline No. 14 xii

LIST OF FIGURES
Figure 1 Environmental Management Systems Model

Figure 2 Phases of the Environmental Audit Process
Figure 3 Schematic Overview of the Audit Process
LIST OF TABLES
Table 1 Types of Environmental Assessments

Table 2 Records Review Topic and Anticipated Source
Table 3 Phase II Assessment Sampling Plan
Table 4 Potential Contaminants from Sampling Devices
Table 5 Potential Contaminants of Operations/Facilities
Table 6 Analytical Parameters
Table 7 Remediation Criteria for Contaminated Sites
BIBLIOGRAPHY
GLOSSARY OF TERMS AND ABBREVIATIONS
xiii ARPEL Environmental Guideline No. 14

SECTION I
ENVIRONMENTAL AUDIT REFERENCE
ARPEL Environmental Guideline No. 14

CHAPTER 1.0 INTRODUCTION TO ENVIRONMENTAL AUDITING
1.1 DEFINITION OF THE ENVIRONMENTAL AUDIT
In the following definitions, audit criteria means regulations, environmental operating

guidelines, policies or acceptable standards to measure the audit against.
An Environmental Audit can be defined as
• The International Organization for Standardization (ISO):
A systematic, documented verification process of objectively obtaining and

evaluating audit evidence to determine whether specified environmental activities,
events, conditions, management systems, or information about these matters
conform with audit criteria, and communicating the results of this process to the
client.
• The Canadian Standards Association (CSA):
A systematic process of objectivity obtaining and evaluating evidence regarding a

verifiable assertion about an environmental matter, to ascertain the degree of
correspondence between the assertion and established criteria, and then
communicating the results to the client. A verifiable assertion is a declaration or
statement about a specific subject matter which is supported by documented
factual data.
• The American Society for Testing and Materials (ASTM):
The investigative process to determine if the operations of an existing facility are in

compliance with applicable environmental laws and regulations.
• The Enforcement and Compliance Policy published by Environment Canada

concerning the Canadian Environmental Protection Act:
Internal evaluations by companies and government agencies, to verify their

compliance with legal requirements as well as their own internal policies and
standards. They are conducted by companies, government agencies and others on
a voluntary basis, and are carried out by either outside consultants or employees of
the company or facility from outside the work unit being audited. Audits can identify
compliance problems, weaknesses in management systems, or areas of risk. The
findings are documented in a written report.
1 ARPEL Environmental Guideline No. 14

• The International Chamber of Commerce (ICC):
A management tool comprising of a systematic, documented, periodic and

objective evaluation of how well an environmental organization, management
systems and equipment are performing with the aim of:
1) Facilitating management control of environmental practices
2) Assessing compliance with company policies, including meeting

regulation requirements
Other Names to describe Auditing
A variety of names have been used to describe environmental auditing:
• Review;
• Survey;
• Appraisal;
• Evaluation;
• Assessment; and,
• Inspection.
There are two types of Environmental Audits: Operational and Transactional.
Operational Audit
The operational audit provides the management of a company with the corporation’s
record of compliance. The audit reviews the systems of internal management and
identifies existing or potential environmental, health and safety problem areas.
The operational audit focuses on facility compliance.
• Permitting and compliance issues at an operating facility to meet corporate and

regulatory requirements.
• Identification and evaluation of capital expenditures required.
Transactional Audit
The main purpose of a transactional audit is to assess the transfer of potential

liabilities associated with real estate or business transaction.
An acquisition audit investigates the prospective properties to ensure compliance with

regulations to:
• Demonstrate corporate responsibility;

• Prevent corporate liability from a purchase; and,
ARPEL Environmental Guideline No. 14 2

• Protect or indemnify company from future operations.
1.2 BENEFITS OF AUDITS
Operational auditing has emerged as an effective management tool. By identifying

existing or potential problems the following benefits may occur:
• Provide early warning detection;

• Ensure compliance with regulations;
• Verify the effectiveness of established environmental management policies;
• Provide a basis from which to develop environmental strategies;
• Furnish information for liability insurance programs;
• Identify cost savings; and,
• Assist in the development of a facility rehabilitation budget.
Commercial transactional audits may provide the following benefits:
• Furnish information before purchasing land or diversity of land use;

• Increase property value;
• Enhance saleability of the land; and,
• Enhance public relations and market development.
Other reasons to conduct an audit are:
• To improve management effectiveness in dealing with environmental issues;

• To increase environmental protection regarding day to day activities;
• To improve short and long term corporate decision making;
• To improve communication and relations with the public and government
regulators;
• To improve health and safety by reducing operational risks;
• To improve communications among employees regarding environmental protection
which may result in higher employee morale;
• To assist in financial planning through the early identification of potential
remediation costs and the avoidance of fines, penalties, etc.;
• To assist in securing insurance and financing;
• To assist in providing protection from civil and criminal liability; and,
• To ascertain environmental problems before completing a transaction involving
sensitive assets.
1.3 AUDIT SUPPORT
Typically, the Board of Directors or the executive of the company will request an
operational environmental audit to determine the status of the company, its facilities
and operations and personnel with respect to environmental issues. Management is

responsible for the completion of the audit and for reporting the findings to the Board.
It is essential that the audit team works with management to design the audit to meet
the objectives of the Board and to present a true status report of operations and
facilities with respect to regulatory agency requirements, corporate policy and
procedures compliance and acceptable industry practices within the available
infrastructure.
Audit support also includes allocation of sufficient funds to complete the work and a
commitment to provide funds for the work required to implement the recommendations
arising from the audit.
The performance of an operational or transactional audit needs the explicit support of

top management. This is especially true when an audit is performed for the first time
at a facility or site. Management must communicate to all involved personnel that this
is a serious undertaking and that honest answers must be provided, even if the
information is negative. This support must be felt through all subsequent levels of
management at the given facility. There also has to be a commitment to follow up on
the findings of the audit (from top management on down) or else it is a waste of time
and funds.
1.4 AUDIT OBJECTIVES
The most common reason to conduct operational environmental audits is to make an

assessment of the level of compliance of the audited operation or facility with the legal
requirements of the policies and standards of performance applicable to it.
An operational environmental audit can be looked upon as a proactive, voluntary effort

initiated by some level of management within a company. Its overall purpose is to
identify any existing or potential problems so that remedies can be applied in a timely
fashion.
The main objectives of auditing are to ensure the following:
• Compliance with regulatory and corporate requirements;
• Examination of performance to ensure compliance during operational phase of

industry activity such as management, operations and quality assurance;
• Evaluation of environmental management practices and facilities;
• Identification of risks and liabilities, including those attributed to past practices;
• Identification of the release, or threat of release, of any hazardous substance

affecting the property;
- On-site sources of contamination

- Off-site sources of contamination
• Assessment of liabilities and examination of risks; and,

- Evaluate any risks to health and environment
- Establish a baseline of liability for historic and comparative purposes
- Evaluate any financial risk of environmental liability (cost of cleanup capital
expenditures- required to bring an operating facility into compliance with the
appropriate environmental regulations)
- Provide a basis for valuation
- Identify whether any hazardous substance has been stored, released or
disposed of on the property
• Recommendation for further action.
- Identify the need for additional testing to evaluate the scope, location, source
and nature of any releases or threat of releases of hazardous substances
affecting the property
- Environmental sampling and analysis.
1.5 ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)
As concerns grow for maintaining and improving the quality of the environment and
human health, organizations increasingly are turning their attention to the potential
impacts of their activities, processes, products and services. An organization can
develop and implement an Environmental Management System (EMS).
An Environmental Management System (EMS) is a component of an organization’s

overall management system which includes and provides the organizational structure,
planning activities, responsibilities, practices, procedures, processes and resources
necessary for the development, implementation, review, maintenance and continual
improvement of the organization’s environmental policies. The audit is a small part of
the Environmental Management System. Figure 1 shows an Environmental
Management System Model.
For an EMS to be effective, it must be more than an information management system.

It must be completely integrated into the existing management framework within the
organization, making environmental management a practical component of day-to-day
activities as well as long term operations.
The twelve essential elements of an EMS are as follows:
1. Corporate Support
Corporate support from top management is essential to the effective implementation

and operation of an EMS. The institution of an EMS must begin with the definition of
the organization’s environmental policy by the top management.


2. Positive Proactive Organizational Structure
A commitment to environmental responsibility should be demonstrated within the

organization structure as a proactive approach by management in order to maintain an
ongoing successful company strategy.
3. Effective and Practical Day-to-Day Management Systems
Without the presence of an effective and practical day-to-day management system, it

is impossible for an EMS to operate in real time. The effectiveness of these
management systems is based upon both the type and level of information gathered
and transmitted by the management system.
4. Integrated Policies and Procedures
Environmental protection policies and procedures associated with regulatory

compliance and company operations may be ineffective due to the nature of the
companies activities and related organizational infrastructure. The successful key is to
keep policies and procedures simple, effective and integrated.
5. Strong Communication and Information Recording
Information flow and availability is critical to the success of an EMS.
6. Practical and Effective Practices Manuals and Guidelines
In addition to the written environmental policy, an EMS must have written guidelines
which demonstrate how the organization intends the policy to be applied, and these
guidelines are most effective in the form of manuals.
7. Planning and Verification Systems
It is important to incorporate environmental planning into all exploration, development

and operational procedures as well as a verification system.
8. Project and Program Reviews
Project and program review mechanisms enable project modifications to be made in

the planning stages. Review mechanisms should also involve mid and after project
reviews to provide for continual improvement.

9. Continual Education and Training
Developing effective EMS programs must be supported by personnel capable of

successfully undertaking management programs. Developing a related education and
training program provides the skills needed by personnel to undertake their
responsibilities.
10. Performance Measurements and Recording Systems
The performance of personnel within job activities may be measured through the
success in reporting. The effectiveness of such reporting programs depends on a good
recording system for such issues as compliance permits, pollution control, waste
management and incidence accountability.
11. Compliance Monitoring and Risk Management
An ongoing system should be in place to monitor regulatory compliance requirements,

reporting schedules and environmental risk.
12. Effective and Ongoing Reporting
The final component of an EMS is the generation of regular reports which convey the
overall organization’s environmental status. These reports may include a list of all
environmental activities, environmental deficiencies and corresponding mitigating
actions, steps undertaken to ensure continual improvement and projected
environmental activities.

CHAPTER 2.0 ENVIRONMENTAL CRITERIA
Audit criteria can be defined as laws, regulations, standards, policies, practices and
procedures against which the auditor compares collected evidence about the subject
matter to determine the degree of conformity.
Examples of external and internal standards are presented below.
External Standards
• Government laws and regulations

• Licenses
• Guidelines
Internal Standards
• Corporate policies
• Corporate guidelines
• Corporate standards
• Industry association guidelines
• Facility guidelines
• Good industry practice
• Codes of practice
2.1 REGULATORY AND LEGAL COMPLIANCE
An organization should establish and maintain procedures to identify, have access to

and understand all legal and other requirements to which it subscribes, directly
applicable to the environmental aspects of its activities, products and services.
To maintain regulatory compliance, an organization should identify and understand

regulatory requirements applicable to its activities, products and services. Regulations
can exist in several forms:
• Those specific to the activity;

• Those specific to the organization’s products and services;
• Those specific to the organization’s industry;
• General environmental laws; and,
• Authorizations, licenses and permits.
Several sources can be used to identify environmental regulations including:
• All levels of government;

• Non-Government Organizations (NGOs);
• Industry associations or groups;

• Commercial databases; and,

• Professional services.
To facilitate keeping track of legal requirements, an organization should establish and

maintain a register of all laws and regulations pertaining to its activities, products and
services with reporting requirements for each aspect.

CHAPTER 3.0 CORPORATE COMPLIANCE STRATEGY
3.1 CORPORATE ENVIRONMENTAL POLICIES AND PROCEDURES
An environmental policy is designed to comply with regulatory requirements. It

establishes an overall sense of direction and sets the parameters of action for an
organization. It sets the goal for the level of environmental performance required of the
organization, against which all subsequent actions will be judged. One example of
such policies is the ARPEL Code of Environmental Practice.
The responsibility for setting environmental policy rests with the organization’s top
management. The organization’s management is responsible for implementing the
policy and for providing input to the formulation and modification of the policy.
An environmental policy should consider the following:
• Laws and regulations;

• The organization’s mission, vision, core values and beliefs;
• Requirements of and communication with interested parties;
• Continual improvement;
• Guiding principles;
• Alignment with other organizational policies; and,
• Specific local or regional conditions.
The issues addressed in the policy depend on the nature of the organization. In
addition to compliance with environmental regulations, the policy can state
commitments to:
• Minimize the environmental impacts of new developments through the use of the
integrated environmental management procedures and planning;
• The development of environmental performance evaluation procedures and
associated indicators;
• Embody life cycle thinking;
• Design products in such a way as to minimize their environmental impacts in
production, use and disposal;
• Prevent pollution, reduce waste and the consumption of resources and
commitment to recovery and recycling as opposed to disposal;
• Education and training; and
• Technology transfer.
The corporate environmental policies should state the company’s position with respect
to environmental regulations, management and stewardship. The corporate
environmental procedures should satisfy the requirements of all applicable laws,
regulatory agencies, industry standards and good environmental operating practice.

The assessment of corporate environmental policies and procedures evaluates the

viability to deal with operations and facilities throughout the organization.
An environmental audit should be designed to provide a snapshot in time of the

company, personnel, operations and facilities with respect to environmental matters.
The audit should be used to identify areas or activities where performance is
satisfactory and areas or activities where improvements can be made. The audit
should identify all areas where the company is in compliance with policies, procedures
and regulations and laws and should also identify where non-compliance situations
exist and provide recommendations to correct the situation. The audit should also
identify environmental liabilities or risks and should recommend the corrective action
required, with cost estimates for budget purposes, and should set priorities for action.
3.2 EMPLOYEE TRAINING
The knowledge and skills necessary to achieve environmental objectives should be

identified. These should be considered in personnel selection, recruitment, training,
skills and ongoing education.
Appropriate training for the achievement of environmental policies, objectives and

targets should be provided to all personnel within an organization. Employees should
have an appropriate knowledge base, which includes training in the methods and skills
required to perform their tasks in an efficient and competent fashion and knowledge of
the impact their activities can have on the environment.
The organization should also ensure that contractors working at the site provide
evidence that they have the requisite knowledge and skills to perform the work in an
environmentally responsible manner or may provide training for contractor personnel.
Training programs require the following elements:
• Identification of employee training needs;

• Development of training plans to address defined needs;
• Verification of conformance of training programs to regulatory or organizational
requirements;
• Training of target employee groups; and,
• Documentation of training received.
The organization should train its employees or members, at all relevant levels, to be
aware of:
• The importance of conformance with the environmental policy and procedures;

• The significant environmental impacts, actual or potential, of their work activities
and the environmental benefits of improved personal performance;
• Their roles and responsibilities in achieving conformance with the environmental
policy and procedures; and,

• The potential consequences of non-compliance with specified operating

procedures.
3.3 OPERATIONAL PERFORMANCE MONITORING
Based on existing regulations, appropriate environmental performance indicators

should be identified. Such indicators should be objective, verifiable and reproducible
and should be relevant to the organization’s activities, consistent with its environmental
policy, practical, cost-effective and technologically feasible.
The organization should establish and maintain procedures to monitor and measure
the key characteristics of its processes that can have a significant impact on the
environment. This should include the recording of information to track performance
and conformance with the organization’s objectives and targets.
Monitoring equipment should be calibrated and maintained. Records of this process

should be retained according to the organization’s procedures.
The organization should continuously monitor changes in its business or operating

environment:
• Emerging/growing environmental concerns in specific areas;

• Developing understanding of environmental issues;
• Developing understanding of employee values;
• Potential regulatory developments;
• Market pressures;
• Changing activities of the organization;
• Changes in sensitivity of the environment;
• Information on technology improvements; and,
• Information on competitors.
Examples of performance measures which could be qualitative or quantitative include:
• Emissions/effluent of a substance per unit of production;

• Total volume/weight of all emissions and effluent;
• Total raw material used per unit of production;
• Total waste per unit of production;
• Volume of packaging per unit of current production volume;
• Percentage of recyclable/recycles;
• Use of materials that reduce emissions or waste;
• Implementation of technology that improves energy efficiency;
• Level of implementation of new systems/procedures;
• Effectiveness of new systems/procedures; and,
• Level of training or awareness of environmental policies and procedures.

3.4 ENGINEERING DESIGN CODES AND STANDARDS
Companies must follow codes and standards for facility design, fabrication and
construction. Standard specifications describe manufacturing processes, chemical
and mechanical property requirements, test methods and requirements related to
specific procedures.
Some examples of international standards and codes which influence environmental

issues by defining specific design construction and operating criteria and parameters
are:
American Society for Testing of Materials (ASTM);

American Society of Mechanical Engineers (ASME);
American Petroleum Institute (API);
National Fire Protection Association (NFPA);
American National Standards Institute (ANSI);
International Maritime Organization (IMO);
International Standards Organization (ISO);
National Institute for Occupational Safety and Health (NIOSH); and,
World Bank’s Handbook for Industrial Pollution Abatement.
3.5 OPERATING PRACTICES
Operational practices and procedures should be defined and appropriately

documented and updated as necessary. The organization should clearly define the
various types of documents (i.e., engineering manuals) which establish and specify
effective operational procedures and control. The establishment and maintenance of
operational procedures and controls ensure that the level of environmental
performance is consistent with the organization’s policies, objectives and targets.
The organization should consider the different functions contributing to its significant
impacts when developing operational controls and procedures:
• Design and engineering;

• Purchasing;
• Contractors;
• Raw materials storage;
• Production processes;
• Laboratories;
• Transportation and storage of final products;
• Marketing, advertising, customer service; and,
• Final disposition of product.

CHAPTER 4.0 OPERATIONAL ENVIRONMENTAL AUDITS IN THE OIL

AND GAS INDUSTRY
Operational Audits in the oil and gas industry can be subdivided into:
• Management Audits;
• Exploration Audits;
• Production Audits;
• Refinery Audits;
• Pipeline, Transportation and Terminals Audits;
• Waste Management Audits;
• Baseline Audits;
• Maintenance Audits; and,
• Special (Air Quality, Water Quality, Spill Response, Compliance, etc.) Audits.
4.1 MANAGEMENT AUDIT
Management audits address the corporate philosophy on environmental management

and planning. They are completed prior to a field visit and may require input at the
district or regional level.
Management audits include a review of:
• Policy and Procedures;

• Programs;
• Personnel Training;
• Records;
• Organization; and,
• Operations.
Management audits are completed by verification and documentation and selected site
inspections to ground-proof the documents.
4.2 EXPLORATION AUDIT
Exploration audits are conducted on seismic and drilling activities and must be
scheduled to coincide with the following programs:
• Drilling and construction licenses;

• Actual drilling and well completion activities; and,
• Site restoration and final reclamation.

Exploration audits can be sub-divided into:

• Environmental planning;
• General operating procedures;
• Spill prevention and emergency response;
• Waste management; and,
• Production or abandonment and reclamation.
An exploration audit requires a field visit to confirm compliance.
4.3 PRODUCTION AUDIT
Production audits are conducted at production facilities such as batteries, satellites,

compressor stations, gas plants, straddle plants and pipeline distribution systems.
Production audits usually examine, where possible, the entire production stream
beginning with the inlet to the facility and ending with the product in storage and/or
departing from the facility.
Production audits can be sub-divided into:
• Environmental planning and management;

• Reporting;
• General operating procedures and material balance;
• Site management or abandonment and reclamation.
Production audits require a site visit to confirm compliance.
4.4 REFINERY AUDIT
Refinery audits are conducted at petroleum refining facilities. They require detailed
review of process and installation drawings. Refinery audits can be sub-divided into:
• Environmental planning and management;

• Reporting;
• General operating procedures and material balance;
• Site management or abandonment and reclamation.

4.5 PIPELINE, TRANSPORTATION AND TERMINALS AUDIT
Pipeline audits are primarily associated with maintenance and operations activities and
may include an operational audit component if terminals are a part of the pipeline
company.
Maintenance:
• Vegetation management;
• Erosion control;
• Right-of-way maintenance;
• Emission control; and,
• Land reclamation.
Operations:
• Awareness;
• Leak detection and spill prevention;
• Emergency response and spill cleanup;
• Risk management;
• Hazardous materials and waste management; and,
• Environmental monitoring.
Terminals:
• Waste management;
• Noise;
• Emission control; and,
• Ship/terminal safety operations.
4.6 WASTE MANAGEMENT AUDIT
Waste management audits are completed to determine that all materials are disposed
of in an acceptable manner prescribed by corporate procedures or regulations:
• Waste management principles (reduce, reuse, recycle, recover);

• Waste management program; and,
• Waste classification procedures and waste specific information.
Treatment and disposal methods and options may be:
• Biological treatment;
• Deep well;
• Evaporation ponds;
• Incineration;

• Land treatment;
• Landfills; and,
• Reclaimers.
Storage and transportation of wastes are also a concern and are included in a waste
audit. Some regulations and guidelines in North America are:
• Workplace Hazardous Materials Information System (WHMIS);

• Storage regulations, methods and spill countermeasure; and,
• Transportation regulations, Transportation of Dangerous Goods Act (TDGR) and
waste documentation and manifests.
4.7 BASELINE AUDIT
Baseline audits are detailed and extensive. They focus on the company, operations,
site and facility designs. These audits include considerable historical information on:
• Corporate policies and procedures;

• Regulatory requirements;
• Reporting procedures, internal and external;
• Operating procedures;
• Process considerations; and,
• Engineering design considerations.
4.8 MAINTENANCE AUDIT
Maintenance audits are completed after the baseline audits to ensure that
recommendations arising from the baseline audit have been implemented, are
repeated at regular intervals and focus on specific environmental issues with each
audit anticipating a higher standard than the last.
4.9 SPECIAL AUDIT
Special audits may include air pollution auditing, water pollution auditing, spill
response auditing, etc.

CHAPTER 5.0 OVERVIEW OF ENVIRONMENTAL ASSESSMENTS
5.1 TYPES OF ENVIRONMENTAL ASSESSMENTS
The following table shows definitions and applications of the different types of
environmental assessments.
Table 1
Types of Environmental Assessments
Definitions Applications
Environmental Impact Assessment
Multi-disciplinary investigation of proposed Typically used for large scale projects in

activity to determine the negative potentially sensitive eco-systems.
consequences to sensitive (unique)
environments, human health, property or Identifies and predicts the degree of impact.
socio-economic conditions.
Used to design mitigative measures.
Precipitates the development of remedial
options.
Environmental Site Assessment*
Evaluation of available information (nature of Assessments may determine the relative level
hazard, exposure pathways and receptors) to of risk so that priorities may be established
determine if adverse effects have occurred or for subsequent action.
may occur.
Determines the presence and extent of known
Phase I Site Assessment is typically a contaminants.
historical and operations review.
Phase II Site Assessment is often a

reconnaissance sampling/analytical program.
Phase III Site Assessment is often a more

detailed sampling/analytical program to
determine contaminant extent and remedial
parameters.

Table 1 (Continued)
Types of Environmental Assessments
Definitions Applications
Risk Assessment
Uses available information to determine the Often expressed mathematically as the

probability and severity of adverse effects “product of probability x its consequence”.
that might occur as a result of some activity
or condition. Used to develop emergency response plans
and allocate resources.
Used to calculate risk associated with

contaminants and determine acceptable
minimum level for remediation.
Toxicity Identification and Evaluation
Laboratory process to identify toxic Identifies toxic compounds that are not priority
compounds released from a site or facility. pollutants and may define new, regulated
The process combines chemical manipulation monitoring requirements.
of samples with toxicity testing and chemical
analyses. Establishes a toxicity level that is independent
of numerical criteria and may be used to
establish Tier 2 criteria for acceptable
remediation levels.
May determine an effective and possibly new

remediation process.
Reclamation Assessment
This type of assessment is conducted to Conducted at the time that the site or facility
determine what type of reclamation will be is being abandoned.
required to bring a site to a condition suitable
for release from rental, contractual and Determines what actions must be taken to
regulatory obligations. restore the site to baseline conditions.
* The term “Environmental Audit” should not be used to describe a Phase I

Environmental Site Assessment. An Environmental Audit may include the review
of a Phase I Environmental Site Assessment. As well, a Phase I Environmental
Site Assessment may include a review of previously performed environmental
audits. An Environmental Site Assessment is both different from and less
rigorous than an Environmental Audit.

SECTION II
ENVIRONMENTAL AUDITING USER

GUIDELINES

CHAPTER 6.0 PHASE I ENVIRONMENTAL AUDIT
A Phase I Environmental Audit is a systematic, documented and objective review of

environmental operations, management systems, performance or practices carried out
by obtaining and evaluating evidence regarding a verifiable assertion about an
environmental matter. The goal is to determine compliance with legal requirements
and internal policies and procedures, and then to provide findings in writing. An
environmental audit consists of general practices applicable to any environmental
audit, which when executed correctly, will lead to consistent, meaningful and practical
results.
Figures 2 and 3 show the three Phases of the Environmental Audit Process and a
Schematic Overview of the Audit Process.
6.1 THE AUDIT TEAM
Environmental Audits are conducted by a group of individuals often described as the

Audit Team. The success of the audit will depend primarily on the communication,
cooperation and experience of the team members.
Management should carefully select the environmental auditing team. Experience with
auditing and a knowledge of the type of facility and related processes are important
requirements. The current practice in auditing is for the audit to be conducted by either
employees of the organization from outside the work unit being audited or by
consultants. There are advocates for each method.
A successful audit team must be comprised of qualified, seasoned professionals

capable of providing an impartial review of compliance and management practice
situations. Company-internal personnel may be utilized to form the audit team, as long
as they can function independent of the entity being audited. Oftentimes, corporate
staff conduct the audit, or the team is formed from a combination of corporate
professionals and those stationed at other facilities in the organization. Employees are
familiar with the company, its procedures and the ways and means of getting the work
done. However, employees are also aware of the internal politics which may be a
detriment to providing an objective audit report. Employees may have more flexibility in
scheduling the work to complete the audit investigations and the interviews required.
The use of employees from different operations or locations also results in an
information exchange within the company which may not otherwise occur and the
employees may be able to prepare recommendations which are easily implemented
within the framework of the company policies and procedures.
External auditors may, by virtue of having no connection to the organization being

audited, be more objective in their assessment of compliance than employee auditors,
and external auditors may bring additional expertise to the audit. Typically external
auditors, supported by staff personnel, provide the most effective method of completing
an audit. Reasons to use outside audit team or team members:

• Facility too small to staff a team;

• Facility personnel too busy to perform the audit;
• Facility personnel lack experience;
• Management prefers an independent assessment; and,
• Perceived anonymity by facility employees to independent auditors.
The selection of the appropriate audit team should place a strong emphasis on people
capable of providing the best professional judgement within the auditing process. It is
essential that auditors possess a strong command of the federal, provincial and local
regulations they will be dealing with on the audit.
An auditing team in the petroleum industry may include:
• Design engineers;
• District or project supervisor;
• Area operator; and,
• Environmental/risk/safety professionals.
The team leader should meet the following criteria:
• Knowledge of government regulations and internal policies and procedures;

• Experience in environmental management;
• Experience in operational areas; and,
• General familiarity with facilities, operations.
In small businesses, the auditing team may consist of the operations engineer and a
technician. In large businesses, the environmental managers may delegate the team’s
responsibility to regional environmental specialists, who then in turn will select a team.
A key to successful auditing is the budget and time allocated to the acquisition of
relevant information.
It is also important to find individuals whose expertise can assist the audit team leader
in developing an accurate picture of the status of the facility. In addition, these
individuals must have the time available to do their assigned task and a commitment to
see that it is completed in a timely fashion. Each team member must not only be
knowledgeable in his or her area of expertise, but must also be able to translate the
requirements of the regulations and operating procedures to the real world operations
of the facility. The team members must be impartial in their review of the status of the
facility or site. Managers or supervisors of an area may be team members, but may
not necessarily be team leaders. If the audit team member is such an individual,
negative or deficient areas within their own realm or responsibility must be objectively
reported. If this individual is too close to the situation to be impartial, another audit
team member or outside reviewer must be able to supply an objective assessment. In
any case, periodic audits by individuals completely independent of the audited facility
are advisable.



Outside consultants and specialists may serve as audit team members as long as they
are fully qualified with regard to the audit purpose and protocols. Consultants may be
requested to conduct the audit in its entirety.
6.1.1 Audit Team Leader Responsibilities
Audit team leader responsibilities can be divided into those responsibilities which
correspond to the three types of audit activities: preliminary audit activities, site
assessment activities and analysis and reporting.
Preliminary Audit Activities
During the preliminary audit activities, the audit team leader is responsible for:
• Selecting team members and assigning audit responsibilities;

• Scheduling team meetings;
• Gathering and distributing background information;
• Reviewing appropriate regulations and company policies and procedures;
• Determining which interview questions should be used at the facility;
• Developing any additional questions to reflect facility-specific requirements;
• Reviewing and revising the audit plan and assigned duties as necessary;
• Determining and confirming arrangements with the team members and the facility
(i.e., travel arrangements, hotel/travel reservations, etc.); and,
• Preparing items for the audit (forms, supplies, protocols, etc.).
Site Assessment Activities
During the site assessment activities, the audit team leader is responsible for:
• Leading the startup meeting presentation;
• Serving as liaison between team and facility personnel to ensure all team members
are appropriately scheduled to meet with facility personnel;
• Soliciting feedback from each team member on the status of work accomplished
through the audit;
• Performing audit duties as determined by the audit plan;
• Documenting the rationale for changing the scope of the audit (if necessary);
• Understanding the context for and meaning of each finding reported by the team;
• Providing periodic feedback to facility personnel on the status of the audit and the
findings of the team;
• Leading the preparation of recommendations;
• Reviewing all scores and recommendations with key facility personnel prior to the
close-out meeting to ensure the accuracy of all findings;
• Leading presentation of close-out meeting discussion; and,
• Summarizing reporting schedule and format.

Analysis and Reporting
During the audit evaluation and preparation of reports, the audit team leader is
responsible for:
• Reviewing working papers and ratings to ensure that all topics were covered and
that all findings are supported by working paper notes;
• preparing the draft report;
• Distributing draft report for comments;
• incorporating comments where appropriate into the final report;
• Ensuring that there is an action plan submitted for comment by the facility (3-6
months after audit); and,
• Following up to ensure the action plan is being followed.
6.1.2 Audit Team Member Responsibilities
Responsibilities of the audit team members can also be divided into those relating to
the preliminary audit activities, site assessment activities and analysis and reporting.
During the preliminary audit activities, the audit team members are responsible for:
• Making travel arrangements (if required);

• Attending pre-audit team meeting (if required);
• Preparing for the audit by reviewing appropriate regulations, company policies and
procedures and available background information;
• Determining which interview questions should be used at the facility; and,
• Developing any additional questions to reflect facility-specific requirements.
Site Assessment Activities
During site assessment activities, the audit team members are responsible for:
• Performing duties assigned by the team leader during the audit;

• Serving as a resource for other audit team members during the audit;
• Sharing observations/concerns with other team members during the audit to ensure
that each is addressed appropriately;
• Keeping facility personnel apprised of findings as they are noted;
• Assisting with preparing any score recommendations and summary sheets;
• Ensuring that all findings noted and working papers are presented on the close-out
meeting discussion sheets and accurately reflect the facts; and,
• Contributing during the close-out meeting when questions are raised about findings
which have been discovered.

Analysis and Reporting
During the audit evaluation and preparation of reports, the audit team members are
responsible for:
• Reviewing the draft audit reports for wording changes, suggested input as
necessary, etc.
6.1.3 Professional Conduct
Professional conduct is characterized by responsible performance, and it can be

defined as:
• Evident competence, responsibility and trustworthiness;

• The acquiring and maintenance of technical expertise;
• The beneficial application of this special expertise in the service of others; and,
• The responsibility to act with mature and seasoned judgement so that the
maximum benefit will accrue to society generally.
Within the context of environmental auditing, professionals involved in auditing should

guide their conduct based upon professional integrity and competence. Any
professionals conducting environmental audits should demonstrate the high levels of
technical competence and the high degree of responsibility inherent in such a role.
Mature judgement is required in situations where many alternative actions are possible
and where many persons can be significantly affected by the ultimate decisions taken.
6.2 PRELIMINARY AUDIT ACTIVITIES
These activities are necessary to effectively prepare the audit team to efficiently
complete the work and minimize the time spent at the facility to meet the objectives of
the audit. Preliminary audit activities consist of the development of an audit plan. The
audit plan addresses technical, logistical and timing issues and background
information on the facility and the criteria to be used in evaluating the facility.
The environmental audit is comprised of investigation and review of corporate and field
records including engineering and administration files.
Pre-Audit Activities can be divided into the following five phases:
• Terms of Reference;
• Selecting Representative Facilities;
• Scheduling the Audit/Logistics;
• Documentation Requirements and Review; and,
• Preparation of Questions for Interviews.

6.2.1 Terms of Reference
The following assumptions need to be verified:
• Senior management has approved the audits;

• Facility/area managers are familiar with the audit process;
• Audit purpose is understood; and,
- Management audit
- Exploration audit
- Production audit
- Other or combination of these
• Audit team has been selected.
6.2.2 Selecting Representative Facilities
The method for selection of representative facilities for auditing can be based on the
size of the facility to be audited.
• For large facilities
- Do entire plant (i.e. all on-site facilities), plus:
- Approximately 10-25% of all off-site facilities: well sites, flow lines, pigging
facilities, separators, storage tanks, injection wells, etc.
• For small to medium facilities:
- Try to do entire small or medium plants

These facilities may include:
- Small gas plants

- Compressor stations
- Metering stations
- Satellites
- Batteries
- Well sites
- Pipelines/flowlines
Plus:
- A representative sampling (10-40% depending upon the number

available) of the associated structures (wells, satellites, pipelines, etc.)

6.2.3 Scheduling/Logistics
When scheduling the audit, the following five factors should be considered:
- Provide as much notice as possible;

- Duration: will depend on type and scope of audit;
- Other considerations: schedule interviews in advance, arrange for audit team
to meet prior to audit;
- Logistics: take appropriate forms, camera, clipboards, appropriate safety
clothes, etc.; and,
- Audit team meeting: the team meeting is essential to review the issues with
team members, to identify sensitivities concerning the site, to identify key
personnel at the site, to instruct the team concerning specific safety
requirements at the location and to ensure that all team members clearly
understand the assignment and individual responsibilities.
6.2.4 Documentation Requirements and Review
Key Points to Remember:
• Need to compile information on the facility to be audited prior to arrival;

• Type of audit will determine the scope and magnitude of data collection; and,
• Some data will be located in head, regional or district offices while other data will
be found at field locations only.
Prepare and send out the following document lists prior to the audit:
• Document Checklist (optional)

• Evaluation and Assessment Questionnaire (optional)
Document Checklist
The purpose of this checklist is to confirm availability of documents (that need to be

reviewed/compiled). Page 35 shows an example of a document checklist.
Assessment and Evaluation Questionnaire
This document should be sent prior to the audit and should be completed by the facility
staff.
This questionnaire is to be completed by facility to collect data and information on the

facility to be audited. A detailed review and evaluation of major operational practices is
provided including:
• Administrative/Management;

• Water;
• Air; and,
• Waste Management.
A detailed review, scoring and comment entry should be completed by the audit team
during the audit.
Page 36 shows an example of an assessment and evaluation questionnaire.
Types of Data to Be Collected:
Administrative/Management Data:
• Organizational structure;
• All environmental policies/procedures;
• All environmental reports;
• Minutes or notes of environmental meetings;
• Personnel training records;
• Complaint reports; and,
• Incident Reports.
Regulatory data:
• All federal, provincial and local licenses, permits, certificates, letters of approval,
etc.;
• All pertinent regulatory legislation;
• All correspondence documents with any regulatory agency;

Example of Documentation Checklist
Document Number Not Not Available

Applicable Available
1.0 Regulatory Documents
1.1 Copies of all Federal, Provincial

and Municipal air, water, soil, waste, ____ _____ _____
and other environmentally related
Permits, Licenses, Certificates, etc.
1.2 Copies of all relevant Federal,

Provincial and Municipal Environmental ____ _____ ______
Acts, Regulations, Guidelines, etc.
1.3 Copies of all correspondence received

from or sent to any regulatory agency ____ _____ ______
since the last assessment.
1.4 Copies of all air, water, soil, waste, and

other environmental monitoring reports ____ _____ ______
submitted to regulatory agencies since
the last assessment.
1.5 Copies of all air, water, waste or other

environmental applications to regulatory ____ _____ ______
agencies. Include examples of supporting
documentation such as drawings and
environmental/engineering reports.

Example of Administrative Air Quality Questionnaire
Air Quality Questionnaire
Yes No Not Applicable
1. Are permits in effect for all required ___ ___ ___

emission sources?
2. Has there been any construction and/or

modification of the stationary sources ___ ___ ___
within the time limits of the permits?
3. Were regulatory agencies notified of

any construction and/or modification ___ ___ ___
changes?
4. Does the facility maintain records

indicating the occurrence and duration ___ ___ ___
of any malfunctions during start-up,
operation, or shutdown?
5. Are written reports outlining excess

emissions submitted to the appropriate ___ ___ ____
agency in a timely manner?
6. Is the facility required to install

continuos monitoring systems? ___ ___ ____
7. Has the facility been required to

conduct any performance tests of ___ ___ ____
air pollution control systems?

• All environmental monitoring reports per license/permit requirements;

• All regulatory inspection/audit reports; and,
• All internal action plans or reports arising from regulatory inspections.
Technical/Operational Types:
• Exploration; and,
• Production/Operations.
Exploration:
• Seismic and drilling procedures;

• Line/lease construction;
• Drilling;
• Spill prevention;
• Emergency response;
• Waste management;
• Abandonment and reclamation; and,
• Public consultation.
Production/Operation:
• General facility information;

• Air;
• Water;
• Waste;
• Laboratory;
• Storage tanks;
• Pipeline;
• Emergency response plans;
• Pesticides; and,
• Decommissioning/reclamation plans.
Review Background Material
• Obtain and review site layouts, blueprints and all relevant process flow diagrams
from facility management. These drawings can include surface drainage, sewer
diagrams, tank, equipment and building locations, process flow charts, etc.
• Establish the presence of any major or unusual activities of the operation (eg.
special waste management facilities such as an incinerator) so that the audit team
can prepare appropriately. These activities have to be permitted.
• Review any other information readily available with respect to environmental

activities on-site such as landfilling, hazardous waste storage, etc.

6.2.5 Preparation of Questions for Interviews
Interviews are Used to:
• Obtain historical data/information;

• Identify problems;
• Focus team on major problems/concerns;
• Increase awareness about seriousness of environmental management/procedures;
• Obtain employee’s understanding of management philosophy on the environment;
• Check level of environmental awareness/understanding; and,
• Help to increase level of environmental awareness amongst all those interviewed.
Who to Interview?
• Interview people who have relevant responsibilities and who would be able to
provide the necessary information.
• Include a cross-section from:
- Field/plant management
- Operators
- Maintenance Personnel
- Adjacent Land Owners (optional)
Questions would include the following topics:
• Awareness of environmental policies/procedures;

• Their level of environmental training for:
- Chemical hazards/safety
- Waste management
- Emergency response
- Spill clean ups; and,
• Problems/concerns they have with environmental matters at their facility/field area.
Examples of interview protocols are included in Chapter 10.0.
6.3 PHASE I ASSESSMENT
In general, the on-site assessment should be directed toward:
• Verification of information generated concerning the site;

• Identification of deficiencies found during preparation work;
• Examination of problems identified by the initial information gathering in the pre-
audit activities;

• Documentation of existing environmental controls; and,

• Inspection.
Many of the activities of the environmental assessment may be completed at the site.
If historical records or reports were noted as deficiencies at an earlier stage of the
audit, that information may be available at the site in written form or verbally, subject to
confirmation, during the site visit. The site assessment is an important component of
the audit process but it must be emphasized that the main purpose of the visit is to
confirm the information the audit team has generated concerning the site.
Site Assessment activities can be divided into five groups:
• Startup Meeting;
• Records Review;
• Interviewing;
• Facility/Field Inspection; and,
• Close Out Meeting.
6.3.1 Start Up Meeting
This meeting should be scheduled at the site at the commencement of activity.
• To ensure everyone is comfortable

• To ensure everyone knows what is going on and when
• To describe the product generated
Who should be there?
• Facility manager
• Environmental/safety coordinator
What should be covered?
• Instructions
• Agenda review
• Description of audit process - scoring if used.
Miscellaneous:
• Emphasize confidentiality of interview; and,

• Describe audit report in favourable terms.

6.3.2 Records Review
Existing policies and procedures must be reviewed. Where deficiencies exist, either as
a result of changing regulations or omissions, it should be noted and the matter
scheduled for field review and/or discussion during the interview process. Facilities
files provide design, construction and operational information. Communications with
regulatory agencies highlight incidents or confirm site status. Licenses, permits and
compliance reports note the operating characteristics and point out long term aspects.
Preventive maintenance programs, such as cathodic protection and chemical corrosion
control, indicate the operating problems and the company response to operational
requirements.
The review is generally completed at the main office. However, when information is
not available, site files are reviewed. If the information is still not available, the
deficiency is noted and the data is generated by site inspection. The information
required to complete the records review is presented in table 2.
Historical information is fundamental to the evaluation program. Examples of Records

Checklists are provided in Chapter 9.0. These checklists are completed at each office,
site, facility or operation scheduled for inspections. The information generated should
be utilized in preparation of inspection protocols and will form an integral part of the
report pertaining to information control, communication and records. Deficiencies are
noted.
Key Points to Remember:
• Utilize the document checklist to evaluate documents at the facility or field

locations;
• Review company/departmental environmental policies and procedures as a guide
or standard by which to evaluate the documents;
• Review all applicable license, permits, etc. to become familiar with the regulatory
requirements for the facility being audited; and,
• Make a recommendation if any of these documents is missing/does not exist.
Key items to record during review:
• Is the facility/field operations complying with all terms and conditions of the permits,
licenses, etc.?;
• Note all deviations from the regulatory requirements;
• Make an ongoing list of these deviations;
• Confirm with facility/field personnel that a deviation actually exists; and,
• Modify list of deviations as necessary.

Table 2
Records Review Topic and Anticipated Source*
TOPIC ANTICIPATED SOURCE
LICENSES AND PERMITS

Historical and Current Compliance/Violation Reports FILES
AIR QUALITY MANAGEMENT
Monitoring Programs FILES
Compliance/Violation Reports FILES
Flare Stacks or pits F/FILES, FIELD
WATER QUALITY MANAGEMENT
Surface Water - Analysis, Flow Regimes FILES, F/FILES, FIELD
Groundwater - Analysis, Monitoring FILES, F/FILES, FIELD
Produced Water - Analysis FILES, FIELD
Disposal - Injection, Water Flood, Foreign FILES, FIELD
SOIL QUALITY MANAGEMENT
Monitoring Programs F/FILES, FIELD
Current Status: F/FILES, FIELD
Spills FILES, F/FILES, FIELD
Cleanup Programs FILES, F/FILES, FIELD
Treatment Programs, Flare Pits FILES, F/FILES, FIELD
MATERIALS MANAGEMENT PROGRAM

Inventory
Disposal - Manifests FILES, F/FILES
Contractor- Storage F/FILES
Landfill- Community, Regional Industrial F/FILES, FIELD
Hazardous FILES, F/FILES, FIELD
On-site FIELD
Hazardous Materials FILES, F/FILES, FIELD
VEGETATION MANAGEMENT
Chemical - Contractor, Success F/FILES, FIELD
Mechanical - Method/Success FIELD
Compaction - Measure FIELD
EMERGENCY RESPONSE PLAN
Review and Assessment FILES, F/FILES
Training Exercises FILES, F/FILES
CURRENT LIABILITY INVENTORY FILES, F/FILES, FIELD
CURRENT RISK ASSESSMENT FILES, F/FILES, FIELD
SITE SPECIFIC INFORMATION FILES, FIELD
* FILES indicates the information required should be available in unit or well files.
F/FILES indicates the information required should be available in the operator unit or plant files
FIELD indicates required information by a site inspection and operator interview if possible.

6.3.3 Interviewing
Attempt to:
• Identify who you want to interview in advance;

• Schedule in advance; and,
• Set tentative times as rigid schedules are difficult to maintain during an audit.
In addition:
• Allow 1 to 2 hours per person.
Examples of Interview Protocols are included in Chapter 10.0.
6.3.4 Facility/field Inspection
The inspection is to confirm all the information that has been reviewed by the audit
team and to generate data concerning deficiencies in the records. The site tour
confirms:
• Documents/file review concerns;
• To actually see “the real thing” versus paper model/concept;
• Housekeeping practices;
• The inlet to outlet for process, storage, distribution; and,
• Areas of concern.
On-Site Tour Checklists
As a rule, the auditors should have a set of protocols specific to the activity or facility
they intend to audit. A checklist will reduce the confidentiality concern by acquiring
audit information specifically associated with an activity or a facility, and it will not
present other issues on paper. In the conduct of an audit, a specific audit checklist
should examine:
• Policy;
• Regulations; and,
• Facility Design and Operations.
What to look for:
• Obvious spills to the ground, water, air;

• Hydrocarbon/chemical stains;
• Dead vegetation;
• Oil sheen on water surface;
• Hydrocarbon odours;
• Visible stains on roofs and walls of buildings (near vents);

• Covered up spill areas;

• Open excavations;
• Insulation falling off pipes, vessels;
• Empty/leaking tanks, barrels;
• Unsafe conditions;
• Personnel behaviour;
• General cleanliness of an operation; and,
• Garbage bins/dumpsters.
When to tour:
• During normal day time operations
Examples of field Inspection checklists are included in Chapter 11.0. Section III of
these guidelines contain specific audit protocols and guidelines for different types of
petroleum operations.
6.3.5 Close-Out Meeting
The audit team should meet with key facility personnel as a courtesy and:
• To involve facility staff in a discussion of observations; and,

• To enable management to show support for process.
The audit team must not discuss conclusions with facility personnel during the
meeting.
6.4 AUDIT EVALUATION AND REPORTS
Following the on-site assessment, the following activities must be performed:
• Evaluating data;
• Scoring the Audit;
• Reaching Conclusions and Providing Recommendations; and,
• Reports and Follow-up.
6.4.1 Evaluating Data
After an exploration activity or petroleum facility has been audited, the audit team must
evaluate the results and identify areas and activities of high environmental
performance, as well as areas of concern and environmental liability. The auditor must
evaluate the findings obtained in the records review, site visit and interviews and
present such information so that the significance of the findings is understandable.
The auditor must:

• Distinguish fact from opinion;

• Clearly identify areas of actual or potential contamination and the basis for all
findings; and,
• Indicate the relative degree of uncertainty associated with evidence of potential
contamination.
6.4.2 Scoring
Types of scoring:
• Quantitative such as 45% or 45/100

• Qualitative such as severe, moderate and significant
• Combination such as 45% means severe liability
• The insurance industry method of AAA, AA, A, BBB, BB, B, etc.
• No/Yes type of scoring
A very simple Yes/No scoring could be developed as Yes: acceptable, No:

unacceptable. This type of scoring can be made more specific by expanding to the
following:
A- Acceptable
B- Needs minor improvement
C- Needs moderate improvement
D- Needs great improvement
F- Unacceptable
If the grade is out of 100% , numerical can be additive:
A- 80-100%
B- 66-79%
C- 50-65%
D- 31-49%
F- 0-30%
Scoring and professional judgement involves interpretation of auditor aids,

interpretation of compliance, interpretation of company standards and the degree of
auditor experience.
Challenges and Benefits of Multi Stage (Phase) Scoring.
Challenge:
• Many descriptors
• Many explanations
• Difficult for Reporting
• Difficult to quantify

Benefits:
• Easier for the audit team to provide comment
6.4.3 Reports and Follow-up
Protection of Confidentiality
Commissioning an environmental audit that examines a corporation’s record of

compliance, systems of internal management and possible future problem areas is a
productive, responsible and valuable exercise. However, its greatest drawback is its
potential for not being a confidential document. If an audit report, for example,
recommended certain changes in procedures and those changes were not
implemented and an environmental incident occurred, the audit report in the hands of a
litigator would be damaging evidence. It could be the factor that prevents an accused
from establishing a defence of due diligence. In addition, from the private sector point
of view, it could open the door to increased government inspection, regulation,
prosecution and even civil liability.
Confidentiality is a simple concept to understand in the context of business. The

company, through its activity or day to day commerce, possesses information which is
unique to it and which is essentially an asset. The decision to make public any
information is a decision only for the executives of the company. In the case of an
environmental audit, the information generated by the audit, including the report, is an
asset of the company and should not be disclosed by anyone except the executive. In
addition, the company cannot be compelled to release information unless directed by
the courts or other government agency under due process of law.
In the situation where a consultant participates in or completes an audit for a client, the
client owns the audit documents, including the final report, and the consultant has no
authority or right to disclose any information concerning the audit, even the fact the
audit was performed, without directions from the client. Even though the consultant
may possess a copy of the report and certain documents, the consultant cannot
provide any information to anyone without written instructions. The audit documents in
the possession of the consultant do not exist. If the consultant does reveal information
concerning the company and the audit, the consulting firm may be liable for civil and
criminal legal proceedings.
Objectives of the Phase I Audit Report
The audit team is generally required to prepare a formal written report which should
follow a pre-arranged format or report guideline. The primary focus of an
environmental audit report is:
• To provide all investigative information to management on the findings of the

environmental audit;

• To document all environmental audit findings and to identify related issues and
concerns; and,
• To provide recommendations for corrective action including the reporting of

incidents to the applicable regulatory body, identification of the associated costs
and to establish follow-up action schedules.
Basic Elements of the Phase I Audit Report
There is no common report format for environmental auditing. The following section
describes the basic elements of a Phase I audit report.
Introduction: States the authorization and objective of the audit.
Scope of work: States the scope of work of the audit and identifies the sites
or operations that were assessed.
Methodology: Describes the methods and the criteria used to complete

the study.
Observations: A description of all findings without comment. This is the

most difficult aspect for an assessor who is pre-disposed to
find fault.
Conclusions: An opinion supported by the observations with respect to

regulations, laws and corporate policies and procedures,
facility status, and an inventory of liabilities, if required. If a
grading system with scoring is to be used, it forms part of
the conclusions and should be presented in this section of
the report. Scores should be assigned and the conclusions,
supported by the observations, cited to justify the score
assigned, whether good or bad.
Recommendations: A statement of work required to deal with either physical

non-compliance situations or with deficient policies and
procedures. Recommendations represent specific action
required to deal with these situations.
Implementation: This is the basis of the report. The audit team must be able
to devise ways and means to deal with the concerns
identified by the audit. It benefits no one to present a
recommendation which cannot be implemented and
undermines the credibility of the audit with operational
personnel.

A technique which has been successful is to prepare parallel reports; the first dealing
with policies, procedures and management based on review, interviews and inspection
of facilities and operations. The report comments on the effectiveness of
environmental management and systems. The second report deals with operations
and compliance with regulations and policies and procedures and the physical status
of the facility or operation based on review, interviews and inspection. The report
comments on the compliance of operations and facilities and includes an inventory of
liabilities or deficiencies.
Writing Audit Findings
All findings resulting from the investigations must be included in the report. The report
should specify the dates to which all of the findings relate. Recommended headings
for this section of the report include:
• Records review findings; and,

• Site visit findings.
Records review findings relate to all the information identified during the review of
existing policies and procedures, facility files, communication with regulatory agencies,
licenses, permits, compliance reports, etc. Section 6.3.2 contains more information
regarding records review.
Site visit findings relate to the information collected during the site visit. It is
recommended that the descriptions of the observations are presented separately for
each location (i.e., specific wellsite, battery, etc.). For each location, the auditor should
indicate the unsatisfactory observations with an explanation of the problems found.
Working Papers and Other Support Information
Working papers and checklists should be included in the audit report. All notes taken
during the audit are called working papers. These working papers document the
information gathered and should include enough information to provide effective
reporting and follow-up.
A checklist is designed to evaluate compliance requirements unique to a certain

operation and focus on environmental issues which may require immediate attention.
This process helps to reduce the confidentiality concern.
Final Report
• It must meet the objectives set out in the scope of work and terms of reference.
• It must be concise and include the observations discussed and reviewed at all
close-out meetings.
• The conclusions must be supported by observations and not based on verbal
reports.

• Recommendations must be clear and concise and deal with the issues.
• Implementation procedures, with costs where applicable, must address all
recommendations.
• Finally, the audit team must review their performance in completing the work. They
must critically review the approach to the project, the cooperation of the personnel
they interacted with in the audit, the disruption which was caused to everyday
activity because of the audit and prepare recommendations to improve the
performance of the audit team in all aspects of the work from audit design,
historical review, inspections, interviews, discussions, conclusions and
recommendations and implementation schemes.
• The audit project manager must prepare an Executive Summary of the audit as a
preface to the audit report.
The following is a suggested report format:
Proposed Section Headings
1.0 Executive Summary
2.0 Introduction
3.0 Site Description
4.0 Records Review
5.0 Site Visit
6.0 Interviews
7.0 Findings
8.0 Evaluation of Findings
9.0 Conclusions
10.0 Qualifications of Assessors
11.0 References and Supporting Documentation
12.0 Appendices
A: Maps, Figures, Photographs

B: Ownership/Historical Documentation
C: Regulatory Documentation
D: Documentation of Interviews

Quality Assurance
Quality Assurance can be defined as a set of procedures used to investigate properties

of a system to ensure a high level of performance is attained. The concept of quality
assurance is an important component of the audit program, being used to verify the
accuracy of audit information, to maintain auditor independence, and to measure audit
performance. The audit should incorporate cross-referencing mechanisms to check
the investigative techniques of the audit team.
The integrity of the audit is the responsibility of the audit team. Every fact must be
verified and every anomaly must be identified and investigated. If, during discussions
or interviews, claims are made that justify certain activities, those claims must be
noted and a follow up performed to confirm that the information is correct.
The simplest method of ensuring the accuracy of the audit report is to review the
findings with operating personnel with discussion of all aspects of the audit.
Supervisors, foremen and area managers should be included in the review. They
should be asked to provide documents to support statements or claims.
Quality assurance can also be applied to the implementation of audit

recommendations. In order that action plans are carried out in a timely fashion, a
means of checking the status of system upgrades should be incorporated into the
reporting and feedback channels of the environmental management system. Quality
assurance measures will help maintain an appropriate level of action so that non-
compliance issues will be corrected and environmental goals are met.
Audit Follow-up
It is important that the company is prepared to deal with the findings of the audit before
the audit is commissioned because when a deficiency or liability is reported, the
company has an obligation to rectify the situation as quickly as practicable to
demonstrate the due diligence on behalf of the company. The corrective action may
include aspects of environmental management from modifying policies, operating
procedures or personnel training.
6.5 IMPLEMENTATION OF PHASE I AUDIT RECOMMENDATIONS
6.5.1 Prioritizing Audit Recommendations
The first step in implementing the audit recommendations is to develop an action plan.
In order to do this, it is necessary to determine the priority or rank of the various
recommendations contained in the audit. The action plan can then be designed to
ensure that high ranking recommendations (non-compliance) be given immediate
attention.

In order to prioritize effectively, it is necessary to categorize the type of audit

recommendations. For example, the recommendations can be grouped according to
those dealing with:
• Regulations;
• Internal policy;
• Professional practice;
• Public perception/local conditions;
• Major environmental hazards; and,
• Operating procedures.
Depending on the size of the audit, it may be necessary to further group the
recommendation into sub-categories so that they can be dealt with more easily. For
example, the different categories may be divided up according to the type of emission,
such as air, water, etc.
The responsibility for assigning priority to the recommendations is ultimately that of

corporate and operations management, with input from the audit team and lower
management groups. One method of involving these groups is to discuss during the
pre-audit meeting how the priorities will be assigned. The auditors can then present
the recommendations in the final report in order of decreasing priority. Management
can review the order of priority and make changes as necessary.
The method for assigning priority should be consistent with Best Management
Practices and address factors of interest to management. The recommendations may
be ranked in any of several ways. The following are the more common:
• Probability and severity of the potential hazard and the effect on human health and
the environment;
• The potential enforcement penalties associated with a finding;
• Authority establishing the requirement. Federal legislation is given higher priority
than provincial, and so on; and,
• Impact on public accountability.
6.5.2 Developing the Action Plan
The objective of the action plan is to review audit recommendations and implement
appropriate solutions. It provides the opportunity to target where the major concerns
exist and to allocate the resources and personnel to remediate the issue. In addition to
providing the time span for completing the project, it should clearly specify the roles
and responsibilities for executing the improvements. These recommendations, then,
become discrete programs within the organization’s environmental management
program.

It is also possible that some of the recommendations will not be executed. For
example, management may have further information and valid concerns and may not
agree with the findings of the audit. Also, the technology to implement the findings
may be prohibitive or is not yet available. Whatever the reason a recommendation is
not performed, it is important that the justification for this decision be documented.
A major part of the action plan involves scheduling time, resources and budgeting
funds to ensure that the recommendations are implemented. The schedule should
ensure that high priority recommendations are implemented quickly.
Documentation and reporting of the status of action plans are important components of
the environmental audit follow-up. Ongoing reports ensure that management is kept
aware of the degree of completion of action plans, and that all management groups are
kept involved with environmental commitment.
The documentation of action plan activities is also important from the use of this record
keeping for future audit planning, to legal back-up in the event of an environmental
incident. Proof of an initiative in solving non-compliance problems will act as an
element of due diligence if regulatory authorities investigate the incident.
Documentation acts as an element of security, showing that management has acted
positively to remediate environmental problems.

CHAPTER 7.0 PHASE II ASSESSMENTS
7.1 PHASE II ASSESSMENT
The purpose of a Phase II assessment is usually to confirm and delineate

contamination, or to demonstrate the absence of contamination on a property identified
through the Phase I assessment procedures. Phase II investigations are undertaken
prior to remedial investigation.
Difference Between Phase I and Phase II Assessments
The key technical feature that distinguishes Phase I and Phase II investigations is the
use of quantitative sampling and analytical techniques in Phase II studies. However,
other important nontechnical differences also exist. Depending on the scope of issues
to be dealt with, a Phase II investigation may be much more expensive and time-
consuming than a Phase I assessment. Furthermore, Phase II assessments usually
require contributions from specialized environmental professionals. Unlike Phase I
assessments, the scope, duration, and cost of a Phase II investigation are highly
dependent upon factors such as the methods used; the size of the site; the number,
type, and identity of suspected contaminants; the level of confidence desired in
analytical results; and the environmental matrices (eg. air, surface water, ground water,
soil, plants, animals) to be sampled.
7.1.1 Sampling and Analysis Programs
Field sampling and analysis programs must be developed on a site-specific basis in

consultation between the Client and the environmental professional supervising the
Phase II study. The sampling and analysis program may include elements such as the
following:
• Soil drilling and/or test pitting;

• Geophysical analysis;
• Soil vapour survey probe installation;
• Surface water sampling;
• Ground water sampling and installation of piezometers/monitoring wells;
• Indoor air sampling;
• Outdoor air sampling;
• Sediment sampling;
• Subsurface vapour sampling;
• Sampling of local fauna and/or flora;
• Materials sampling (e.g. asbestos insulation);
• Analysis of organic chemicals, inorganic chemicals and radioactivity; and,
• Analysis of adverse health effects, in individuals or populations.

A Phase II assessment may in itself proceed in stages. Phase II assessments may

commence with screening surveys and coarse sample spacing. More detailed
sampling is frequently necessary to delineate areas of contamination or define
parameters essential for impact/risk assessment of remedial investigation.
7.1.2 Initial Phase II Assessment
Initial Phase II assessments are necessary at properties where the information from
Phase I indicates that a hazardous materials release has occurred, resulting in
potential human health or environmental hazards. The principal objective of the Initial
Phase II assessment is to confirm whether a release has occurred by implementing a
limited program of collection and analysis of appropriate site samples. The key
characteristic of the Initial Phase II assessment is its limited scope; it is only intended
to confirm the occurrence of hazardous materials. Efforts to fully characterize the
release in terms of extent, magnitude and migration potential are beyond the scope of
the Initial Phase II assessment.
There are four principal components of an Initial Phase II assessment that must be
addressed prior to its implementation:
• Development of a sampling plan;

• Preparations for the site visit;
• Conducting the sampling visit; and,
• Making recommendations for further action or no action.
Each of these components are discussed below.
1. Development of a Sampling Plan
The sampling plan is the primary document that provides a detailed description of the
scope and nature of the Initial Phase II assessment sampling to be conducted. The
sampling plan clearly states the objectives to the sampling effort in terms of the types
of samples, the number of samples, the analytical parameters and the rationale for
why the sampling is required. Additionally, the sampling plan provides details
concerning methodologies of sample location and collection, preservation,
transportation, analysis, etc.
The scope of an Initial Phase II assessment is generally small enough so that the
required sampling plan components can usually be presented in a single document.
This contrasts with the sampling plan for an expanded Phase II assessment, which,
due to the greater scope of the effort, may require separately bound documents
dedicated to individual topics (i.e. Sampling and Analysis Plan, Quality Assurance and
Quality Control Plan, etc.)

Evaluation of the Extent and Locations of Sampling
A useful guideline for assessing the appropriate extent of the sampling is to recognize
that the extent of sampling should increase with increases in the availability of
evidence from the Phase I assessment indicative of potential human exposure to
hazardous materials.
At a minimum, one sample of each environmental media suspected to be a source of

hazardous material (e.g. air, soil, floor wipes, etc.) should be collected. Depending on
the analytical procedures required to detect the suspected contaminants, more than
one sample of each environmental media may need to be collected. For example, one
soil sample would be sufficient if all of the suspected contaminants were detectable by
a single analytical procedure. However, if different classes of contaminants are
suspected (i.e. metals and organics) for which different analytical procedures are
required, more than one sample (e.g. a sample for metals analysis an a second
sample for organics analysis) would be necessary. It is necessary to determine what
analysis are to be conducted.
Evaluation of Sampling Methods and Parameters
If there is no knowledge of the type of hazardous materials that may be onsite, but
there is suspicion of their presence, indicator parameters such as total organic
halogens (TOX), total petroleum hydrocarbons (TPH), specific conductivity, pH, etc.
may be appropriate initial parameters. However, such parameters give only limited
information concerning the nature of contamination. Therefore, whenever possible, it is
preferred that specific analytical parameters be identified.
Typically, laboratories that specialize in the analysis of environmental samples classify

the constituents or contaminants of interest into broad classes of compounds for which
class-specific analytical procedures are available. The most common classes are
listed below, although there are many other less common classes:
• Volatile Organic Compounds (VOCs)

• Base-, Neutral-, and Acid-extractable Compounds (BNAs)
• Pesticides and PCBs
• Anions and Cations
• Miscellaneous constituents or contaminants (i.e. cyanide, phenols)
Format
The Sampling Plan is the central guide to follow to ensure successful implementation
of the Initial Phase II assessment. Therefore, it should present a concise synopsis of
the required sampling and associated procedures and analytical methods.
Table 3 summarizes the information that should be contained in the Sampling Plan.

Table 3
Synopsis of the Format/Content of the Initial
Phase II Assessment Sampling Plan
Quality Assurance/Quality Control
The plan should identify the number and type of quality assurance samples,
specifically the number of blanks, duplicates, or spikes that will be taken. The
specific QA/QC guidelines to be followed in this program are to be stipulated
by each Region.
Equipment Decontamination
The sampling plan should identify the reagents and any special procedures
associated with equipment decontamination.
Chain of Custody
All samples collected (including blanks and spikes) must be maintained under
chain-of-custody procedures. Chain-of-custody minimizes the potential for
damaging or closing samples before they are analyzed. Chain-of-custody
tracks the possession of a sample from the time of collection, through all
transfers of custody, to when it is received in the laboratory. In the laboratory,
internal laboratory chain-of-custody procedures take over. Investigators should
generally follow regional protocols for chain-of-custody procedures.
Field Operation
The sampling plan should discuss the sequence for conducting the field
activities.
Sampling Methodology
The sampling plan should include sampling methodology including tools and
collection methodology.

Table 3 (Continued)
Synopsis of the Format/Content of the Initial
Phase II Assessment Sampling Plan
Sampling Locations/Rationale
As precisely as possible, the sampling plan should identify the location of

each sample. A site map should be prepared to guide the investigator to the
appropriate locations. Specific sampling methods, the number of samples,
the parameters being sampled and a description of the objectives for each
sampling activity should be included in the sampling plan. The location of
control samples must be identified.
Analytical Requirements
The sampling plan should discuss the technique and level of detection that will
be used to analyze each sample. This should also include a description of
potential false positives/negatives.
Sample Handling
Sample preservation and other shipping procedures should be described.
Review of the Sampling Plan
The Sampling Plan must be reviewed to ensure that its principal objectives are met
and to eliminate contradictory information concerning scope and objectives. The
review process will also facilitate a summary of the resources necessary to implement
the Sampling Plan. If required resources exceed available resources, than the
Sampling Plan can possibly be revised to eliminate this conflict.
2. Preparation for the Site Visit
Prior to conducting sampling at the property, the following steps should be taken:
• Ensure access to the property; and,

• Prepare a safety plan.
Ensuring Access to the Property
Prior to arriving at the property to be sampled, the sampling team must make sure that
they have the means to gain access to the property and that they are capable of
identifying the locations/media to be sampled. If sampling is to be conducted at
adjacent properties, appropriate arrangements will need to have been made to secure
permission and access.

Prepare a Health and Safety Plan
A health and safety plan should be prepared prior to initiating sampling that addresses
the following issues:
• Suspected hazards and risks;

• Levels of protection to be worn;
• Decontamination procedures;
• Documentation of the appropriate health and safety training given to the sampling
crew; and,
• Emergency procedures should be discussed.
3. Conducting the Sampling Visit
The sampling visit involves:
• Reviewing the sampling plan;

• Documenting the sampling visit with photography;
• Tracking sampling activities with a field logbook;
• Sample shipment; and,
• Decontaminations and demobilization.
Each of these components is discussed below.
Reviewing the Sampling Plan
The sampling plan should be carefully reviewed by the individuals who will be
conducting sampling at the property. This is especially important if the authors of the
sampling plan are not the same individuals who will be conducting the sampling.
Enough time should be allowed between the time of sampling plan review and
sampling to allow issues to be resolved that may surface during review of the sampling
plan.
During implementation of the sampling plan, site conditions may be discovered that
require deviations from the plan. In such circumstances, the nature of the condition
and the rationale for the deviation must be documented. Air quality monitoring should
also be conducted during sampling if the property poses the threat of inhalation
exposure to hazardous materials. The results of the air monitoring would be used to
assess the requirement for using personal protection equipment.
Documenting the Sampling Visit with Photography
Photographs should be taken to document the conditions of the facility and procedures
followed during inspection of the facility. Types of pictures that should be taken
include:

• Representative overall pictures of the facility;

• Evidence of hazardous materials releases;
• Adjacent land use and landform; and,
• Evidence of potential unauthorized property access.
Sampling and Field Logbook
The Sampling and Field Logbook is a very important document that facilitates
integrating the Initial Phase II assessment results into the Initial Phase II assessment
report. This report will provide the rationale for determining if an Expanded Phase II
assessment is advisable. A unique logbook should exist for each property. The
sequentially numbered pages of the logbook should only contain entries that are
tracked by date and time. Types of logbook entries should include:
• Personnel performing the property sampling;

• Times of personnel arrival and departure and initialization and conclusion of the
component sampling efforts;
• Results of field measurements;
• Factual descriptions of structures and features;
• Sketches of the property layout and sample collection locations; and,
• Observations made while sampling at each location.
Sample Shipment and Analysis
Careful tracking of sample shipment and analysis should be provided to ensure that
the samples are analyzed for the appropriate parameters, that all samples sent to the
laboratory are actually received by the laboratory, and that the samples are analyzed
within the prescribed holding times. Depending on the type of analyses being
conducted, sample analysis may require several days to several weeks (sometimes
months for Expanded Phase II assessments). This time lag between sample collection
and receipt of the results must be considered when making projections of the amount
of time necessary to determine the disposition of a property.
Decontamination and Demobilization
Decontamination of persons and equipment should occur, as necessary, prior to

initiating rest breaks and departure from the property. Decontamination after sampling
activities will usually include decontamination of field persons and sampling and field
equipment.
4. Recommendations for Further Action or No Action
The final task of the Initial Phase II assessment is to make recommendations

concerning the need for further actions at the property. These recommendations may
include:
• No further action;

• Conduct an Expanded Phase II assessment to more fully characterize and

delineate contamination confirmed by the Initial Phase II assessment;
• Planning and implementing interim measures at the property; and,
• Notifying environmental regulatory personnel about particular severe environmental
contamination potentially revealed by the Initial Phase II assessment.
7.1.3 Expanded Phase II Assessment
The components of an Expanded Phase II assessment are identical to those of an

Initial Phase II assessment, except for the scope of the investigation. As a general
rule, an Expanded Phase II assessment will concentrate on the sampling and analysis
of environmental media such as soil, ground water, surface water, etc.; whereas, the
Initial Phase II assessment focuses on the sampling and analysis of building materials,
indoor air, materials spilled within the confines of buildings, etc.
Also whereas the purpose of the Initial Phase II assessment is to confirm the presence
or absence of hazardous materials, the objective of the Expanded Phase II assessment
is to characterize the contamination. Characterization refers to:
• Specifying the type of contamination present, particularly if its presence was

confirmed using indicator tests such as TOX, TPH, etc.;
• Delineating the three-dimensional occurrence of the contamination;
• Assessing migration rates, directions, and possible human and environmental
receptors and the risks posed to them; and,
• Establishing a database to begin to facilitate documentation of changes in the
occurrence of the contamination.
The Expanded Phase II assessment’s objectives can begin to be met by increasing

sampling frequencies both horizontally and vertically, assessing natural environmental
conditions such as climate and ground water occurrence and flow direction, and
establishing a computerized database for tracking of the property’s environmental
monitoring data.
The Phase II assessment would evaluate the potential impacts, if any, of the property
on public health and environment by conducting an Endangerment Assessment. The
potential exposure of people and sensitive environmental systems would be estimated.
In assessing potential public health impacts, potential pathways and points of possible
human or environmental exposure should be characterized. Environmental
concentrations of significant constituents should be calculated at all exposure points
and compared to applicable standards and criteria.
There is an almost unlimited variety in the scope and complexity of Expanded Phase II
assessments; each one is determined on the basis of the existing data made available
by implementation of the Initial Phase II assessment. The best guideline for assessing
scope requirements for the Expanded Phase II assessment is verification that the
individuals involved with the interpretation of the Initial Phase II assessment results are

experienced with interpreting such results and that they have a working knowledge of
the environmental regulations concerning the occurrence of hazardous materials in the
environment.
7.1.4 Site Investigation Techniques (Soils, Groundwater, Surface Water)
Sampling Water
There are different types of waters that can be sampled, requiring different sampling
equipment, but most of the samples are treated similarly once they have been
collected. In the case of groundwater, the drilling of a well and the contaminants that
may be associated with the materials used in well construction are considered to be
part of the overall sampling program. The types of water that may be most commonly
sampled at contaminated sites include surface waters (rivers, lakes, artificial
impoundments, runoff, etc.), groundwaters and wastewaters.
Problems Unique to Sampling Water
Waters are usually very heterogeneous, making it difficult to obtain truly representative
samples. Solids with specific gravities only slightly greater than that of water are
usually inorganic. They will remain suspended in the flow, but will also form strata in
smoothly flowing channels. Oils and solids lighter than water (usually organic) will
float on, or near the surface. Some liquids, such as halogenated organic compounds,
are heavier than water and will sink to the bottom. The chemical composition of lakes
and ponds may also vary significantly depending on the season. The composition of
flowing waters, such as streams, depends on the flow and may also vary with the
depth.
Water sample contamination is always a problem, and it increases in importance as

the analyte concentration levels decrease. To some extent, contamination sources
may depend on the body of water being sampled. For example, in groundwater
monitoring, contamination from well construction materials can be significant and
material blanks become very important. However, many potential contamination
sources are common to all water samples.
Groundwater vulnerability to contamination is affected by water depth, recharge rate,

soil composition and topography, as well as other parameters such as the volatility and
persistence of the analytes being determined. In planning groundwater sampling
strategies, knowledge of the physical and chemical characteristics of the aquifer
system is necessary (but almost never known). Groundwaters present special
challenges for obtaining representative samples.
Representative Sampling Approaches
The following general principles apply to the collection of representative water

samples:

• Do not include large nonhomogeneous particles, such as leaves and detritus, in the
sample;
• In flowing waters, place the sampling apparatus upstream to avoid contamination;
and,
• Collect a sufficient volume to permit replicate analyses and quality control testing.
Collecting Representative Water Samples from Rivers and Streams
For water quality sampling sites located on a homogeneous reach of a river or stream,
the collection of depth-integrated samples in a single vertical may be adequate. For
small streams, a grab sample taken at the centroid of flow is usually adequate. When
a single fixed intake point is used, it should be located at about 60% of the stream
depth in a area of maximum turbulence, and the intake velocity should be equal to or
greater than the average water velocity.
For sampling sites located on a nonhomogeneous reach of a river or stream, it is

necessary to sample the channel cross section at the location at a specified number of
points and depths. Generally, the more points that are sampled along the cross
section, the more representative the composite sample will be. Three to five vertical
sampling points are usually sufficient, and fewer are necessary for narrow and shallow
streams.
Collecting Representative Water Samples from Standing Water
When sampling standing water, the sample should be taken from the downwind end of
the water body if possible.
Collecting Representative Groundwater Samples
A professional hydrogeologist or geologist will typically select the location for the
installation of piezometers and/or monitoring wells and supervise the installation of
these wells.
In order to collect representative groundwater samples, temporal issues need to be

considered such as the time of year sampling will be done, whether to sample before
or after rainy seasons, etc. In constructing and using monitoring wells, alteration of the
water being sampled must be minimized. Care must be taken during the drilling
process not to cross-contaminate aquifers with loosened topsoil possibly laden with
agricultural/industrial chemicals. Well construction and materials can profoundly
influence the chemical composition of samples, so material blanks are important.
Purging wells before sample collection eliminates stagnant water. The method and
rate of purging , time between purging and sampling, and sampling itself will depend
on the diameter, depth, and recharge rate of a well. Each well should be slug,
pressure and pump tested to determine the hydraulic conductivity of the formation and
to estimate the extent and rate of purging prior to sampling. Purge volumes usually
range from three to ten well volumes.

The material for well construction should be selected carefully. Cement used for
polyvinyl (PVC) pipe joints can leach into samples from wells; this can be prevented by
using threaded pipes. Equipment for monitoring wells should be constructed of
stainless steel of other inert materials.
Sampling devices and sample containers are always likely sources of contamination.
Contaminant leaching from sampling devices and containers is very complex and
requires serious attention. Table 4 shows the types of contaminants caused by
materials used in sampling devises and well construction monitoring.
Table 4
Potential Contaminants from Sampling
Devises and Well Casings
Material Contaminants prior to steam cleaning

Rigid PVC-threaded joints Chloroform
Rigid PVC-cemented joints Methyl ethyl ketone, toluene, acetone,

methylene chloride, benzene, organic tin
compounds, tetrahydrofuran, ethyl acetate,
cyclohexanone, vinyl chloride
Flexible or rigid Teflon tubing None detectable
Flexible polypropylene tubing None detectable
Flexible PVC plastics tubing Phthalate esters and other plasticizers
Soldered pipes Tin and lead
Stainless steel containers Chromium, iron, nickel and molybdenum
Glass containers Boron and silicon
Variations in the permeability of an aquifer can affect the representativeness of

groundwater samples. If the wells have varying recovery rates, varying concentrations
of the analytes will result. Vertical gradients of flow between permeable strata within
an aquifer can result in samples from multiple zones within one well.
Representative Sampling of Soils
There are two general types of samples: grab samples and composite samples. Grab
samples are single samples collected at a specific spot. Composite samples are
derived by combining portions of multiple samples.
Representative soil sampling assures that a sample or group of samples accurately

reflect the concentration of the parameter of concern at a given time. Analytical results
from representative samples also illustrate the variation in pollutant presence and

concentration across a contaminated site. However, because soils are extremely

complex and variable, this often requires many different sampling methods. The
sampling personnel must select methods that best accommodate specific sampling
needs and satisfy sampling objectives. In addition, the sample collector is responsible
for providing the appropriate samples for laboratory analysis. A soil sample must
provide an adequate size sample to meet the analytical requirements and supply
samples representative of the population to be evaluated.
Deposition of airborne contaminants, especially those recently deposited, is often

evident in the surface layer of soils. Contaminants that have been deposited by liquid
spills or by long-term deposition of water-soluble materials, however, may be found at
depths up to several metres. Plumes emanating from hazardous waste dumps or
leaking storage tanks may be found at considerable depths. As the subsurface
environment is very heterogeneous, contaminants do not spread evenly. They will
follow cracks and lenses of coarse material
It is often impossible to quantify the analyte concentration uncertainties associated

with sample selection. In these instances, qualitative descriptions or the uncertainties
due to sampling limitations should be clearly described and the associated
assumptions fully documented.
Sometimes samples are deliberately collected unrepresentatively. Initial studies at a

contaminated site may focus on the most obviously contaminated areas. Although
such samples will not represent the average conditions, they may establish the worst-
case concentrations of the analytes of interest. Even in these situations, it is important
to obtain background samples of the soil matrix from either local or area control sites.
Variability arises from the heterogeneity of soils, the size and distribution of the
sampling populations, and the bias of the sampling and analysis methods. Because
soil samples are heterogeneous, it is best to select as large a test sample as practical
for preparation. An extract or digested solution will be more homogeneous and provide
more reproducible aliquots than a smaller portion of the sample.
Composite samples may help overcome the lack of homogeneity over time or in the
distribution of chemical species. At the same time, compositing may dilute peak
values of concern. Therefore, if peak concentrations of analytes are important,
compositing should be supplemented with grab samples taken at sites and times
where higher values are suspected.
7.1.5 Laboratory Analysis
Analytical Parameters For Soil Samples
The success and reliability of a site characterization program is contingent upon the
proper analytical parameters being run on the soil samples. If the analytical
parameters are not sufficient to identify and characterize the complete contamination

situation present on a site, any recommendations made utilizing the site

characterization findings will be inadequate.
There are several steps that must be taken when determining which analytical
parameters must be requested to complete a site characterization program. These
steps are:
1. The potential waste/contaminant streams at the facility or resulting from the

operation must be identified. Most importantly, the (potential) contamination
point of the stream must be identified.
2. The area that the sample(s) was collected from must be identified.
3. The contamination characteristics must be determined. This will determine if

there are more than one contaminate present in the stream. The sample must
be analyzed for each individual contaminant (there may be synergistic or
antagonist effects resulting from co-contaminants).
4. The appropriate analytical parameters should be identified, and the analytical

tests that will meet these parameters listed. The potential false positives and
false negatives resulting from each test should be identified and assessed.
5. The analytical request must be made. Ensure that the control sample is
adequately tested to determine the background levels of contaminants that may
be present as a result of neighbouring operations.
Each of these five steps is discussed below in greater detail.
Identification of Potential Waste/Contamination Streams
Small, relatively simple operations tend to have easily identified contaminant streams.
For example, an oil well with no water or sand cut which requires no downhole support
chemicals will have only one contaminant stream: crude oil. However on large
integrated facilities, or on small facilities which have had support operations completed
on them, there will be many contaminant streams.
Consider the oil well discussed above. Obviously, the oil well had to be drilled, which
resulted in the generation of drilling wastes. Depending upon the handling of the
drilling waste, it may be present on the site as a contaminant. Also assume that the
well has been frac'ed in order to improve production. If the frac fluid was blown back
onto the site, the fluid may be present as a contaminant in the soil. An examination of
the operating history quickly changes a "simple' site into one with several potential
contamination streams.
Larger facilities, such as gas sweetening facilities, or large integrated facilities, such as
batteries with treating operations and gas processing, will have an even larger number
of contaminate streams.

The following table can be utilized to assist in the identification of the contamination
streams normally associated with various facilities and operations. It must be stressed
that this table does not address all possible operations or all potential contaminant
streams possible for any given facility or operation. The experience and expertise of
the site assessor must be utilized in determining all of the potential contaminant
streams.
Table 5
Potential Contaminants of Operations/Facilities
Operations/Facility Potential Contaminants

Gas Well Produced water, condensate, methanol
Oil Well Crude oil, produced water, support chemicals
Separator Crude oil, condensate, produced water
Treater Treater hay, crude oil, support chemicals, produced water
Gas Plants Amines, glycols, lube oils, methanol, condensate
Batteries Crude oils, lube oils, support chemicals, waste petroleum

products
Ecology Pits Crude oils, lube oils, produced water, methanols, glycols, support
chemicals
Flare Pits Crude oil, lube oils, condensate, metals, produced water, support
chemicals
Transfer Stations Crude oil, produced water, refined products
Risers/Pig Traps Crude oil, support chemicals, produced water, inhibitors
Bone Yard Metals, support chemicals, lube oils
Chemical Docks Support chemicals, hydrocarbons, metals
Drilling Drilling mud, metals, hydrocarbons, produced water
Frac’ing Frac fluid, hydrocarbon, produced water
Pigging Crude oil, produced water, inhibitor, paraffins
Chemical Vegetation Herbicides

Control
Streams With Multiple Contaminants
It is not unusual for a contaminant stream to contain one or more substances of

concern. When a stream containing multiple contaminants is released, the soil which
is affected by the stream will suffer negative effects of all contaminants. Identifying
only one of these contaminants is not sufficient to characterize the true state of
contamination and threat to the environment.

Some examples of streams containing multiple contaminants are:
• Crude oil with a high content of sodium chloride. (This includes emulsions of crude
oil and produced water with high sodium chloride content);
• Glycol used to scavenge produced water (in those cases where the produced water
has a high content of sodium chloride); and,
• Used lubricants, in particular engine oils. These lubricants often contain high
contents of heavy metals, in addition to the petroleum hydrocarbons.
All contaminant streams must be closely assessed in order to ensure that there are not
multiple contaminants present in that stream. In many cases a simple examination of
the process which generates or contains the stream is sufficient to determine whether
or not multiple contaminants exist. However, in other cases it is necessary to utilize
analytical process to determine the presence or absence of multiple contaminants.
Analytical Parameters
The following table can be used to assist in the identification of the analytical
parameters that should be requested for environmental samples. It must be stressed
that this chart should only be used to assist in the selection of analytical parameters.
The final analytical request must be based on the assessors' knowledge of the
individual facility (i.e. its operations, its history, its potential waste streams, and any
other unique factors).
Code/Analysis Code/Analysis
Am Amines NO3 Nitrate, nitrite, ammonium

BTEX Benzene, Toluene, Ethyl benzene, Xylenes O&G Oil and Grease
C60 C60 Scan PAH Polynuclear Aromatic
EOX Extractable Organo-Halogens Hydrocarbons
PCB Pentachlorobiphenyls PCP Penta-Chloro-Phenols
Gl Glycols Sal Salinity
Gm Germination Tests THE Total Extractable Hydrocarbons
Hb Herbicide Scan Tox Toxicity
Met Metals Scan

Table 6
Analytical Parameters
Suspected Contaminant Analysis, Soil Analysis, Water
Unleaded Gasoline BTEX, THE, Met BTEX, THE, Met
Regular Gasoline, Aviation BTEX, THE, Met BTEX, THE, Met

Gasoline
Fuel Oil, Diesel Fuel, BTEX, THE, C60, Met, PCP, BTEX, THE, Met
Kerosene, Jet Fuel, Mineral PCB
Oil, Motor/Lube Oil
Petroleum Solvents BTEX, THE, Met BTEX, THE, Met
Crude Oils, Hydraulic Fluids O&G, C60, Met, Sal O&G, C60, Met, Sal
Waste Petroleum Products O&G, BTEX, C60, Met, PCB, O&G, Met, Tox
PCP, EOX
Condensate THE, BTEX, O&G, Sal THE, BTEX, O&G, Sal
Tank Bottoms (Crude Oil C60, O&G, Met, Sal O&G, Met, Sal, Tox
Storage)
Frac Fluid/Blowdown NO3, Gm, Sal, Tox NO3, Sal, Tox
Produced Water Sal, Met, O&G Sal, Met, O&G
Drilling Wastes (Muds, Fluids, O&G, Met, Sal O&G, Met, Sal
Cuttings)
Pit Fluids N/A O&G, Met, Sal, Tox
(Flare/Evaporation/Storage)
Pit Sediments EOX, Met, O&G, PAH, PCP, N/A
PCB, Sal, THE
Glycols BTEX, Met, Sal, Tox BTEX, Met, Sal, Tox
Amines BTEX, Met, Sal, Tox BTEX, Met, Sal, Tox
Downhole Support Chemicals BTEX, Met, Sal, Tox BTEX, Met, Sal, Tox
Creosotes, Tars C60, EOX, Met, PAH, PCB, O&G, EOX, PAH, PCB, PCP
PCP
Herbicides Hb, Gm, Tox Hb, Tox
Methanol (Coolant) Gm, Tox Tox
False Positives and False Negatives
Analytical procedures will often provide erroneous or misleading results, even though
the procedure has been completed in strict accordance to recognized and approved
laboratory protocol. The reasons for these erroneous or misleading results are
numerous, and include:
• The analytical procedure is not suitable for the contaminant/matrix in question;

• There is naturally occurring material in the sample matrix which will interfere with
the analytical procedure, obscuring the results. For example, if a standard
hydrocarbon analysis is conducted on a soil with a high organic matter content,
some of the natural soil organic matter will be identified as hydrocarbon. This can
lead to the analytical results being misinterpreted as showing a higher percentage
of petroleum hydrocarbons being present in the sample; and,
• There are multiple contaminants present in the soil, and one or more of those
contaminants interfere with the analytical procedure. For example, a soil with a
high sodium chloride content may show high extractable organo-halogen content, a
result of the chloride interfering with the procedure and showing higher EOX
content that is truly present.
A result that shows a higher content, or the presence of a contaminant which is truely
not present is known as a false positive. The opposite, a result that denies the
presence or shows a lower content of a contaminant than is truly present is known as
a false negative.
Determining whether or not an individual analytical procedure is susceptible to false

positives or false negatives must be determined on a case by case basis. Experience
must be used as a guide, and all unexpected and unusual analytical results must be
closely examined. It is often necessary to enlist the expertise of an analytical chemist
to determine whether or not an analytical procedure will be susceptible to false results.
7.1.6 Basic Elements of the Phase II Audit Report
Introduction It should include purpose and organization of

the report and site background information.
Study Area Investigation Includes field activities associated with site

characterization. These may include physical
and chemical monitoring of some but not
necessarily all of the following:
- Surface features
- Contaminant source investigation
- Meteorological investigations
- Geological investigations
- Soil investigations
- Groundwater and surface water
investigations
- Human population surveys
- Ecological investigations

Physical Characteristics Includes results of field activities to

of the Study Area to determine physical characteristics. These
may include some, but not necessarily all of
the following:
- Surface features
- Meteorology
- Surface water hydrology
- Geology
- Soils
- Hydrogeology
- Demography and land use
- Ecology
Nature and Extent of Presents the results of site

Contamination characterization, both natural chemical
components and contaminants in some, but
not necessarily all of the following media:
- Sources (lagoons, sludges, tanks, etc.)

- Soils
- Groundwater
- Surface water and sediments
- Air
Contaminant Fate and Includes potential routes of migration

Transport and contaminant persistence.
Baseline Risk Assessment Human health evaluation (exposure

assessment, toxicity assessment, risk
characterization).
Summary and Conclusions Data limitations and recommendations for

future work as well as recommended remedial
action objectives.

CHAPTER 8.0 PHASE III ASSESSMENTS
8.1 PHASE III ASSESSMENT
A remedial investigation should be performed whenever a Phase II assessment (or

rarely, a Phase I assessment) reveals contamination that is:
• In contravention of local guidelines, standards or regulations;

• Considered dangerous to human or environmental health, immediately or in the
long term or; and,
• Deemed unacceptable by the Client for any other reason.
The purpose of a remedial investigation is to:
• Identify several feasible approaches to remedy the contamination, including in situ

monitoring or risk management;
• Critically compare these approaches by considering factors such as risks to
workers and the surrounding population, and economic and technical feasibility;
• Determine the extent of remedial measures required;
• Allow remediation costs to be estimated; and,
• Selected criteria against which the success of the remedial measures can be
evaluated.
Differences Between Phase II Assessment and Remedial Investigation
Phase II assessments and remedial investigations differ primarily in their purpose.

Whereas Phase II studies are undertaken to confirm or refute the presence of
contamination, remedial investigation studies are undertaken to develop remedies for
unacceptable levels or contamination. While Phase II studies involve field sampling
and analysis, remedial investigations involve more interpretive procedures, and usually
have a limited field component. Because science, engineering, public policy, social,
economic and legal issues may directly affect the conclusions arising from a remedial
investigation, professionals with expertise in all of these areas may be required.
Typically, the information collected during a Phase II assessment will be used to
develop a remediation investigation.
8.1.1 Remedial Investigation Program Components
Remedial investigation programs must be developed on a site-specific basis in

consultation between the Client and the professional supervising the Phase II study.
The program may include elements such as:
• The assessment of storage, removal, disposal and treatment alternatives for

contaminated materials;
• Quantitative risk assessment for single contaminants and contaminant mixtures;

• Human and/or environmental exposure estimation;

• Computer modelling of environmental fate and transport processes;
• The socioeconomic impact analysis of remedial options;
• The review of rationales for relevant environmental guidelines, standards and
regulations; and,
• The development of site-specific risk based remediation criteria to ensure
protection of human health and the environment and to allow evaluation of the
remedial measures.
If remedial action is warranted, subsequent phases may include:
• Treatability studies (bench-pilot/scale);

• Detailed design;
• Contract document preparation/tendering;
• Implementation;
• Monitoring/confirmation;
• Regulatory liaison/permitting; and,
• Public consultation.
General Approach
The general approach for conducting a phase III evaluation of possible remedial
options and for identifying remedial alternatives can be divided into two parts:
Part 1: Development and preliminary screening of alternatives (general response

actions)
Part 2: Detailed analysis of selected alternatives
The first part consists of a two-stage screening process to narrow the range of
remedial alternatives to be evaluated in the second part. The approach to performing
each part of a remedial alternatives analysis is described below.
Part 1: Preliminary Screening of a Range of Control Measures (General

Response Actions)
The initial phase would involve the development of a comprehensive list of general
remedial actions to be considered. Data from the Phase I and II assessments would
be reviewed to identify general categories of response actions. The remedial
alternatives considered at this stage should consist of general actions that broadly
define the nature of the required response. By eliminating inapplicable responses at
this stage, the universe of potential remedial actions to be considered in the following
steps is substantially reduced, and the emphasis can be placed on alternatives with
greater potential applicability to property problems under consideration.

Performance Standards
A key factor in the first phase of remedial alternatives analysis for the property is the
establishment of appropriate performance standards or cleanup criteria. The
development of appropriate performance standards or cleanup criteria for the property
provides a firm basis for the evaluations of remedial alternatives. Suggested
performance standards should, where possible, be formulated and presented in the
form of target levels (i.e. concentrations) for specific contaminants (where such levels
are available) and/or goals for contamination control (i.e. prevention of further
contaminant migration).
Key factors to be considered in establishing and justifying appropriate performance

standards should include existing regulations and other applicable criteria,
endangerment to the environment and public health, the capabilities of available
remedial action technologies, and past experiences and case histories for similar or
comparable projects.
Property-specific factors affecting risks to public health and the environment (such as
the nature and extent of actual and projected containment migration, dispersion, and
attenuation effects on contaminant levels at downstream locations, human and biotic
populations, and systems at risk ) should also be evaluated in developing a cleanup
criteria.
Preliminary Screening of Alternatives
The next step in Part 1 of the remedial alternatives analysis should consist of a
preliminary screening process to further narrow the range of alternatives requiring
detailed analysis. Lists of specific remedial technologies included in the general
technologies should be combined to develop alternatives required to mitigate any
property problems identified.
The assembled list of remedial alternatives is then screened according to specified

environmental/public health and legal/regulatory and cost criteria. Innovative
technologies should be carried through this screening process if the analysis
demonstrates that there is reasonable probability that they will provide better treatment,
fewer adverse impacts, or lower costs than demonstrated treatment technologies.
Part 2: Detailed Evaluation of Selected Alternatives
After applying the technical, environmental/public health, legal/regulatory and cost

screens, the remaining remedial alternatives should be examined in greater detail.
Depending on the number of remaining alternatives and the nature of the available
data, the alternatives may be ranked subjectively by use of best engineering
judgement, or by a numerical ranking scheme that incorporates the technical,
environmental/public health, legal/regulatory and cost factors previously discussed.
Based on these rankings, a limited number of alternatives may be selected. It should

be noted that a “no action” (no further study or remediation) alternative should be
included in the detailed analysis.
Part 2 requires the development and detailed specification of conceptual designs of the
remaining remedial alternatives. The detailed analysis should include: detailed cost
estimation, including distribution of costs over time; evaluation in terms of engineering
implementation of constructability; an assessment of each alternative in terms of the
extent to which it is expected to effectively mitigate and minimize damage to and
provide adequate protection of public health, welfare, and the environment; and
analyze any adverse environmental impacts, methods of mitigating these impacts, and
costs of mitigation. To meet these requirements, detailed technical, economic,
environmental, legal/regulatory, and public health evaluations should be conducted.
Each remedial alternative should undergo detailed evaluation of several important

technical factors including performance and reliability. The ability to construct each
remedial technology under the site conditions and the time required to implement each
alternative should also be assessed. In addition, the safety of workers and the public
during and after the construction should be considered.
The potential impacts, if any, of each remedial alternative on public health and the
environment would be evaluated in detail and would assess potential exposure of
people and sensitive environmental systems, potential exposure pathways, and
populations at risk. Environmental concentrations of the “indicator chemical” identified
by the Phase II assessment should be estimated at all exposure points and compared
to applicable standards and criteria.
The results of the detailed analyses should be summarized in a tabular format that
compares cost, health risks, environmental impacts, performance, technical reliability
and other important factors; this table will facilitate the selection of a preferred
alternative. The alternative selected should be the lowest cost alternative that is
technologically feasible and reliable and which effectively mitigates and minimizes
damage to and provides adequate protection of public health, welfare or the
environment.
The selected remedy should:
• Be protective of human health and the environment;

• Be cost effective; and,
• Utilize permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable.
If in balancing the relative advantages and disadvantages of the various alternatives, a

single alternative is not clearly preferred as the optimum choice, additional analyses
(such as cost/benefit and decision/risk analysis) may be recommended to assist in the
selection process.

8.1.2 Types of Remediation Technologies
Remediation Treatment Technologies fall into five types:
• Biological Technologies;
• Thermal Technologies;
• Physical Technologies;
• Chemical Technologies; and,
• Encapsulation Technologies.
Biological Technologies
Micro-organisms such as bacteria are used to remove contaminants from media (soil,
sludge or water). Generally used on organic contaminants to reduce them to
components such as carbon dioxide and water. Some micro-organisms incorporate
inorganic contaminants into cellular material.
Thermal Technologies
As the term implies, heat is used. Contaminants are either volatilized and later
recovered, or burned to breakdown or recombine organic components.
Physical Technologies
Physical separation processes, such as adsorption, stripping, extraction, etc. are used
for both organics and inorganics.
Chemical Technologies
Chemical reactions resulting from the addition of chemicals, such as

oxidation/reduction, ion exchange and precipitation remove contaminants.
Encapsulation Technologies
Chemicals are immobilized and prevented from migrating. The process can be done in
situ or in processing equipment (in tank). Technologies include vitrification,
solidification and asphalt incorporation.
8.1.3 Basic Elements of the Phase III Audit Report
Introduction Site background information, data on the

nature and extent of problems and objectives
of remedial action.

Preliminary Screening Discussion and results of the preliminary

screening of remedial alternatives.
Remedial Action Alternatives Description of remedial action alternatives

selected for detailed analysis.
Remedial Alternatives Discussion of the detailed remedial

Analysis alternatives analysis based on technical
engineering feasibility, health/environmental,
legal/regulatory and cost considerations.
Summary Summary of analysis results.
Recommendations Detailed description of the recommended

remedial alternatives.
8.2 ASSESSMENT AND REMEDIATION CRITERIA
Remediation Criteria
Remediation criteria are the target levels and/or allowable levels of a substance
allowed in a matrix. These criteria determine whether or not a site is considered to be
contaminated. There are two general types of remediation criteria: numerical criteria
(also known as regulatory criteria), and risk based criteria.
Numerical Criteria
Numerical criteria are the most common form of remediation criteria. These numerical
limits for contaminants in soil, water and air are developed by regulatory agencies (or,
in some cases, other organizations) to regulate contaminated materials and sites in
order to protect, maintain and improve the environmental quality at those sites. These
criteria are general, and are developed by taking into account the effect of the
contaminant on both human and environmental health or through very generic risk
assessments. For these reasons, numerical criteria are not acceptable in all
situations.
Some numerical criteria are broken into categories based upon land-use. For
example, different criteria may be applied to land used for agricultural, residential, or
industrial purposes. The criteria for a particular contaminant on industrial land may be
much higher than that for residential land. These sliding criteria are based partially on
risk, again showing how numerical criteria are derived from risk based studies and
data.

Numerical criteria are often further divided into Assessment Criteria and Remediation
Criteria. Assessment Criteria are utilized during Initial Phase II Site Assessments in
order to determine if an Expanded Phase II Site Assessment is required. If substances
are identified during the initial Phase II Site Assessment at or above the Assessment
Criteria values, then an Expanded Phase II Site Assessment should be implemented.
Assessment criteria are developed by referencing the "typical" or "representative"
background levels of substances in the environment. The theory behind this
developmental procedure is that if a substance is present above its "normal"
background level, it is likely a non-natural occurrence. However, it must be recognized
that the background levels of various substances will vary from site to site, not too
mention the variance between areas with varying surface geologies, and these generic
assessment criteria can be misleading.
Remediation Criteria are used as target levels. That is, once the substance identified
as a contaminant reaches a level less than the value identified as a Remediation
Criteria (whether it is through the institution of a remedial program, or through more
detailed sampling and assessment), the material should no longer be considered
contaminated.
Risk Based Criteria
Risk-based criteria are developed on a individual case, site-specific basis. These

criteria are developed based on acceptable levels of risk specific to the site and
contaminants in question, taking into account site specific variables such as soil,
geology, hydrology, surface and groundwater, climate and precipitation, land use and
proximity/sensitivity of receptors. Therefore, risk-based criteria can either be more
stringent, or less stringent, than numerical based criteria.
The risk-based criteria must be developed using credible and accepted scientific
practices and principles. Finally, risk-based criteria are not acceptable in all cases, nor
are they always acceptable to regulatory agencies. When-ever risk-based criteria are
going to be developed and/or utilized, the regulatory agencies should be consulted.
The process required to develop risk based criteria is complex and variable. It is fully
explained in risk assessment and risk management resources, and is beyond the
scope of this manual.
Implementing and Utilizing Criteria
Criteria are best utilized to assist in the development of both site management plans
and in the development of remediation objectives. The remediation criteria are utilized
as a threshold value. Those sites which have had uncontrolled releases of
substances, and now exceed the concentration listed in the remediation criteria, are
identified as sites which require management. Those sites which do not have
substances exceeding the "threshold" values do not require additional management.

The use of numerical remediation criteria values as remediation objectives, as

opposed to the use of site specific risk based criteria, is advantageous from three
perspectives:
• the use of existing remediation criteria simplifies the development and

implementation of the remediation program, eliminating the need to independently
research and develop target levels,
• the use of existing remediation criteria as remediation target levels saves both time
and money, allowing a faster design and implementation of a remediation program
and,
• regulatory bodies tend to be more accepting and supportive of numerical criteria

(particularly in those regions where the numerical criteria are a component of the
regulatory framework), eliminating the need to undergo a formal (or informal)
acceptance procedure.
Furthermore, in those jurisdictions which utilize remediation criteria as a component of

an overall regulatory framework, criteria can be utilized to identify and assist in
inventorying those sites which are environmental liabilities (i.e. identify those sites
which are in environmental non-compliance states).
Developing Numerical Remediation Criteria
Some organizations may consider it to be advantageous to develop and adopt their

own numerical based remediation criteria. There are several reasons to do so:
• the existing regulatory framework may not have any numerical remediation criteria;
• the organization may wish to implement a more stringent level of remediation

objectives than is currently required, either as part of corporate policy, or in
anticipation of regulatory changes in the future;
• the organization may want to eliminate the need to conduct risk assessments and
develop site specific risk based criteria on large remediation projects or site
management schemes; and,
• the organization may be active in more than one regulatory jurisdiction, and may
wish to adopt one set of numerical criteria acceptable to all jurisdictions in order to
ease environmental operations.
The development of internal remediation criteria is best done in the following manner:
a) Identify the existing numerical remediation criteria and regulatory criteria (as well
as any draft or interim guidelines) for all of the regulatory jurisdictions in which
the organization has operations (or plans to have operations).

b) Compare the criteria, selecting the most stringent criteria for each category.
Record these values.
c) Collect site specific risk based criteria generated during previous remediation
and risk assessment programs completed for/by the organization. Record all
values, and note the site sensitivity.
d) Examine existing numerical criteria generated by regulatory agencies from

outside jurisdictions. Record these values.
e) Compare all recorded values, selecting those which are the most stringent.
Caution must be taken when selecting criteria values generated for site specific
risk based criteria. Often, these criteria will be exceptionally stringent,
particularly in those areas where receptors are both sensitive and in close
proximity. The adoption of this list of numerical criteria generated through this
process will result in the organization operating to a remediation criteria equal to
or better than the requirements of any regulatory jurisdiction within which they
operate.
It should be noted that this internal numerical remediation criteria list must be
assessed each time any of the regulatory jurisdictions within which the organization
operates adopts a new set of regulatory criteria. This will ensure that the internal
remediation criteria do not result in the organization’s operations becoming non-
compliance.
Example Criteria
The following table provides an example of remediation criteria that have been
generated by referencing numerical remediation criteria from Canada. The criteria
which have been referenced are: "Interim Canadian Environmental Quality Criteria for
Contaminated Sites" and the "Alberta Tier I Criteria for Contaminated Soil Assessment
and Remediation".

Table 7
Remediation Criteria for Contaminated Sites
Substance/Parameters Soil Water

pH 6 to 8.5 -----
conductivity (dS/m) 2 dS/m -----
Sodium Adsorption Ratio 6 -----
arsenic 10 5
barium 600 50
beryllium 5 -----
boron 2 -----
cadmium 1 1
chromium (+6) 5 -----
chromium (total) 100 15
cobalt 20 10
copper 80 25
cyanide (free) 0.5 40
cyanide (total) 5 40
fluoride (total) 200 -----
lead 50 10
mercury 0.2 0.1
molybdenum 4 5
nickel 40 10
selenium 2 1
silver 2 5
sulphur (elemental) 500 -----
thallium 1 ----
vanadium 100 ----
zinc 120 50
benzene 0.05 0.5
chlorobenzenes (total) 0.05 0.1
ethylbenzene 0.5 0.5
toluene 1.0 0.5
xylene (total) 1.0 0.5
styrene 0.1 0.5
PCBs 0.5 0.1
PAHs, non-chlorinated, total 1.0 0.1
PAHs, chlorinated, total 0.1 1.0
phenols 0.05 0.1
pesticides (and metabolites), total 0.1 ----
mineral oil and grease 1000 ----
Note: All values in µg/g dry weight or µg/L unless otherwise stated.

CHAPTER 9.0 EXAMPLES OF RECORDS CHECKLISTS
This chapter contains examples of Records Checklists. Additional information about

Records Checklists is included in Chapter 6.0.

WESTERN OILFIELD ENVIRONMENTAL SERVICES LTD.

RECORDS CHECKLIST PAGE 1
COMPANY FILE NUMBER
FIELD FACILITY
DATE INSPECTOR(S)
ENVIRONMENTAL POLICY AND PROCEDURE

FACILITY PERSONNEL:
NO.OF SUPERVISORS
NO. OF OPERATORS
OTHER PERSONNEL
No. PERSONNEL
ENVIRONMENTAL TRAINING: COMPLETED COURSE NOTE DEFICIENCIES
WHMIS
TRANSPORTATION OF DANGEROUS GOODS
OIL SPILL CONTAINMENT AND RECOVERY
OIL AND SALTWATER RECLAMATION
HAZARDOUS MATERIAL SPILL CONTROL
AIR QUALITY MONITORING
WATER QUALITY MONITORING
PESTICIDE/HERBICIDE APPLICATORS COURSE
OTHER ENVIRONMENTAL PROTECTION COURSES
ENVIRONMENTAL PERFORMANCE:
AWARDS FOR ENVIRONMENTAL PERFORMANCE
PUBLIC COMPLAINT & RESPONSE
ENVIRONMENTAL PROTECTION PROCEDURES

(Repairs. Demolition. Decommissioning. etc.)
CONTRACTOR/CONSULTANT AGREEMENTS


GENERAL OPERATIONAL COMPLIANCE
LICENSES/PERMITS:
HEAD OFFICE FIELD OFFICE LICENSE/PERMIT NO.
OPERATING
CLEAN WATER
CLEAN AIR
WATER USE
OTHER
(SPECIFY)
DRILLING LICENSE CONDITIONS
LANDOWNER R.O.E. OONDITIONS
COOMPLIANCE REPORTS
(NOTE DEFICIENCIES)
FLARE STACKS/PITS AIR MONITORING PROGRAMS

SPILL REPORTS
(NOTE DEFICIENCIES)
WATER QUALITY MANAGEMENT
SURFACE WATER CONTROLS TYPE
MONITORING SCHEDULE
(WEEKLY, MONTHLY,
ANNUALLY?)
SURFACE WATER MONITORING
(RECORDS KEPT?)
ON-SITE GROUNDWATER MONITORING
WATER WEl.LS WITHIN 1 Km
ARE WATER WELLS MONITORED


SPILL PREVENTION AND EMERGENCY RESPONSE

SPILL RESPONSE PLAN LOCATION OF PLAN
SPILL PREVENTION METHODS LOCATION OF MANUALS
BLOWOUT EMERGENCY RESPONSE PLAN
WASTE MANAGEMENT
MSDS/WHMIS MATERIAL ON-SITE MSDS/WHMIS MATERIAL COMPLETE
HEAD OFFICE
FIELD FACILITY
WASTE REGULATIONS TDG
WHMIS
MSDS
PUBLIC HEALTH
OTHER
WASTE INVENTORY NOTE DEFICIENCIES

(COMPLETE?)
(TYPE, VOLUME, ORIGINAL SOURCE,
DISPOSAL METHOD, DISPOSAL LOCATION)
NOTE DEFICIENCIES
HAZARDOUS WASTE/DANGEROUS
GOODS INVENTORY (COMPLETE?)
(TYPE, VOLUME,. LOCATION, SOURCE)
SHIPPING RECORDS
(COMPLETE?) RECORDS LOCATION


SITE SPECIFIC BIOPHYSICAL DATA

LAND USE TYPE
VEGETATION SURROUNDING SITE
VEGETATION CONTROL TYPE (ON-SITE)
CHEMICAL USED
CHEMICAL APPLIED BY
RISK ANALYSIS
CATHODJC PROTECTION CATHODIC TYPE
NON-DESTRUCTIVE TESTING
ABANDONMENT AND RECLAMATION

ABANDONMENT PROCEDURES MANUALS NOTE DEFICIENCIES
ABANDONMENT DOCUMENTS
(COMPLETE?)
SPILL RECLAMATION
COMMENTS

CHAPTER 10.0 EXAMPLES OF INTERVIEW PROTOCOLS
An interview is completed with site personnel to determine the clear understanding of

corporate policies and initiatives. An interview determines if policies and procedures
are in place and are implemented in agreement with the objectives of the
environmental mandate established by senior management and the executive. In
addition, interviews are used to get first hand response from those that deal with the
environmental conditions at a facility/plant/field location for the following areas of
concern:
• Administration/management;
• Air;
• Water;
• Safe work permits;
• Waste;
• Operations/process control/maintenance;
• Laboratory; and,
• Emergency response.
Examples of interview protocols are included in this chapter. Additional information

about Interviews is included in Chapter 6.0.

ENVIRONMENTAL AUDIT
Item No. Protocol Answer Comments
101 Policicles
MGM* 101-1 Is there a company environmental policy in place?
GUIDE Review written company policy.
MGM* 101-2 Has the environmental policy been effectively

communicated to the overall/ organization?
GUIDE Evaluate form and adequacy of the environmental

communication strategy.
MGM* 101-3 Do written policies, standards, procedures and programs

show evidence that environmental concerns have been
consistently addressed and applied throughout the
company?
GUIDE Rate existing written policy and procedure guidelines to

identify the company position on environmental concerns.
Meet with department managers and review departmental
policies and dally procedures In dealing with
environmental issues.
MGM* 101-4 Do the company's written policies, standards, procedures

and programs show evidence that environmental concerns
such as compliance with statutory regulations and industry
guidelines are a primary objective?
GUIDE Compare the company position to environmental

regulations and general corporate practices.
102 Responsibilities/Training
MGM* 102-1 Have employees with designated environmental

responsibilities been given formal job instruction and/or
specialized training?
GUIDE Review facility training program and conduct employee

interviews.

MGM* 102-2 Does the company support or conduct programs to make

the employee aware of industry or company initiatives for
the prevention and control of environmental hazards? Are
contractors advised?
GUIDE Determine if the company supports/encourages participation

in industry associations and Individual efforts to educate
employees in environmental matters.
MGM* 102-3 Does the company support or conduct programs to

make the public aware of industry or company
Initiatives for the prevention and control of
environmental hazards?
GUIDE Determine if the company participates in industry initiatives

(in house; excluding outside advertising) to educate
government and the public. Look for programs that are
aimed at the general public or at site specific populations to
promote company initiatives.
OPS 203-1 Is there a vegetation control management plan or

procedures?
GUIDE Check vegetation on and adjacent to plant sites and ROW,

above-ground facility sites. Look for excessive weed
infestation and poor vegetation cover. This condition may
enhance soil erosion. Review vegetation management plan
and procedures.
OPS 203-2 Is the vegetation control program being properly applied?
GUIDE Verify by inspection.
OPS 203-3 Are mechanical methods of brush control attempted before

or in combination with using chemical methods?
GUIDE Chemical programs are costly and can lead to

environmental impacts from spills and run-off. Verify if this
has been considered by interviewing operations personnel.
OPS 203-4 Are herbicides applied by licensed applicators/contractors?
GUIDE Check records for licensing.
OPS 203-5 Are records kept of all applications of herbicides?
GUIDE Records of the types of herbicide, dale, location and

application rate should be available on-site.

CHAPTER 11.0 EXAMPLES OF FIELD INSPECTION

CHECKLISTS
Utilizing the information generated by the records, files review program and biophysical
descriptions, each facility and well site is inspected to determine the environmental
status and impact. Examples of inspection forms are included in this chapter.
Additional information about Field Inspection Checklists is included in Chapter 6.0.

WELLSITE CHECKLIST
ENVIRONMENTAL PARAMETERS
COMPANY _________________ FILE #: ________________ INSPECTOR(S) ________________
OPERATOR _________________ FIELD: __________________ DATE: ________________
ALTA: LSD ______ SECT _____ TWP _____ R _____ W _______M
BC: MAP ______ UNIT _____ SHEET _____ ZONE____CENTIZONE____SUBUNIT____
SITE LOCATION SIGN: YES / NO SAFETY SIGNS POSTED: YES / NO
ROAD: TOPSOIL SUBSOIL GRAVEL

TRAIL LOW PROFILE/ HIGH PROFILE/ OTHER
CULVERTI TEXAS GATE/ OTHER GATE
CONDITION ______________ LENGTH OF ROAD _____________M
LEASE: FULL SIZE/ REDUCED TO PAD ______________ M BY ______________ M
SITE TYPE: OIL_______GAS _______DISPOSAL _______INJECTION_______ WATER______ SOURCE
SOUR: YES / NO SALT WATER: PRODUCED / INJECTED COMMENTS:
SITE STATUS:
SHUT IN _______PRODUCING _______ SUSPENDED _______ ABANDONED_______
IN USE _______UNCONFIRMED _______D&A _______NOT DRILLED_______
CAPPED (STANDING CASED) _______
VALVES SECURED? (IF WELL IS SHUT IN OR SUSPENDED):

YES_______ NO_______
CASING VENT STATUS (FILL IN FOR EVERY WELL):

OPEN _______ CLOSED _______ BURIED _______ NONE _______
NO SURFACE CASING _______ BULL PLUGGED_______
UNKNOWN _______ VENTING: YES / NO (GAS / WATER / OIL OTHER)
WELL EQUIPMENT (check all that apply):

WELLHEAD ONLY _______ CSG GAS SCRUBBER _______ LEAKS:
WELLHEAD & DEHY _______ OIL/GAS/CHEMICAL
PUMPJACK _______ LINE HEATER _______ WATER
WELLHEAD & PAD _______ PIG TRAP _______
TREATER _______ PRODUCTION MANIFOLD _______
SEPARATOR _______
ROTARY PUMP _______NO EQUIPMENT ON SITE _______
POWERED BY:
PROPANE____NAT GAS____ELECTRIC ____CASING GAS____ OTHER____
NOISE CONTROL: YES / NO

PRODUCTION LINE: BURIED/ ABOVE GROUND
TANKS (Give number and size of tanks):

BURIED TANK(S) _______ PRODUCTION TANK(S) _______
POP TANK _______
TANK DIKES: YES MATERIAL:
NO CLAY/ SILT/SAND/GRAVEL/ TOPSOIL
WELLSITE CHECKLIST

TANK BERMS ADEQUATE: (IF YES HOLDS 1.5 TIMES VOLUME OF LARGEST TANK IN BERM)
YES / NO
CATHODIC PROTECTION: COMMENTS:

NONE _______ TEST POINT _______ N/A _______
UNION _______ RECTIFIER _______ FLANGE _______
COUPLER _______ NIPPLE _______ ANODE _______
PIPELINE/ FLOWLINE ROW:

DESTINATION_________________________
ROW CONCERNS: COMPACTION/ ADMIXING/ SUBSIDENCE
REVEGETATION SUCCESS: GOOD/ ADEQUATE/ POOR

FINISH WORK COMPLETE: YES / NO
LIVESTOCK CONCERNS: OVER GRAZING/ TRAILING

ARE ACCESS CONTROLS NEEDED?: YES / NO
BRUSH CONTROL: GOOD/ ADEQUATE/ POOR
STREAM CROSSINGS:
RECONTOUREDI EROSION CONTROLS/ SLOPES STABILIZED
HAZARDOUS MATERIALS & CHEMICALS:

(Storage and Handling)
ARE WHMIS LABLES POSTED? YES / NO
ARE MSDS SHEETS AVAILABLE ON SITE? YES / NO
CHEMICAL LIST (Stored on site): (give brand name)

CHEMICAL TYPE SIZE LOCATION
Methanol _______ ____________________
Glycol _______ ____________________
Amine _______ ____________________
Corrosion Inhibitor _______ ____________________
Asphaltene Dispersant _______ ____________________
Anti-Foam Agent _______ ____________________
Demulsifier _______ ____________________
Paraffin Control _______ ____________________
Propane _______ ____________________
PITS ON SITE (CIRCLE ALL THAT APPLY):

FLARE/ SUMP/ BURIED/ ABANDONED/ BORROW/ RECLAIMED/ CLOSED
/ OTHER
PIT SIZE: _______ M BY _______ M

Second PIT SIZE: _______ M BY _______ M

WELLSITE CHECKLIST
FLUID IN PIT: WATER/ OIL/ BOTH/ NOTHING
SUBSIDENCE: YES / NO
LEASE SITE MATERIAL: TOPSOIL/ SUBSOIL/ GRAVEL/ OTHER_______

PERIMETER BERMS: YES MATERIAL: CLAY ADEQUATE: YES
NO SILT NO
SAND
GRAVEL
TOPSOIL
FENCED: YES / NO TYPE: BARBED/ LINK/ STEEL/ OTHER

CONDITION _____________________
PROPER DRAINAGE: YES / NO IF NO EXPLAIN: ___________________
COMPACTION: YES / NO
IS TOPSOIL STOCKPILED?YES / NO LOCATION: ___________________
LIVESTOCK CONCERNS: ___________________
SPILLAGE/ STAINING: COMMENTS:

NONE IDENTIFIED
MINOR STAINING AROUND WELL & EQUIPMENT
MODERATE STAINING AROUND WELL & EQUIPMENT
SEVERE STAINING AROUND WELL & EQUIPMENT
OFF LEASE/ ON LEASE
MULTIPLE
SPILL STAIN TYPE (Circle all that apply):

SALT WATER CHEMICAL
OIL (CRUDE/REFINED) UNKNOWN
CONDENSATE EMULSION
SPILL LOCATION:
ACCESS ROAD/ ON LEASE/ OFF LEASE/ PIPELINE ROW/ OTHER
SPILL AREA (TO BE SHOWN ON SKETCH):

FIRST _____________M BY _____________M
SECOND _____________M BY _____________M
SAMPLING RECOMMENDED: YES_____ NO_____

(IF YES, MARK SKETCH WITH SAMPLE LOCATIONS)

WELLSITE CHECKLIST
EROSION:
CONTROLS IN PLACE:YES/ NO TYPE __________________
COMMENTS:
ACCESS ROAD NONE/ MINOR/ MODERATE/ SEVERE

LEASE SITE NONE/ MINOR/ MODERATE/ SEVERE
PIPELINE ROW NONE/ MINOR/ MODERATE/ SEVERE
WATER QUALITY:
NO. OF DOMESTIC WATER WELLS WITHIN 1 Km_______________
PROXIMITY OF WATER WELLS TO SITE _______________M
PROXIMITY OF WATERCOURSE/WATERBODY _______________M
NAME/TYPE: ______________________________________________
IS SURFACE WATER AFFECTED? YES / NO
IS SURFACE WATER THREATENED? YES / NO
AIR QUAL(TY:
AIR QUALITY AUTHORIZATIONS ON SITE? YES / NO
WIND SOCK VISIBLE: YES / NO
EXCESSIVE NOISE: YES / NO
NOISE SOURCE: _____________________________________________
ODOUR: YES / NO SOURCE: ________________________
VAPOUR RECOVERY UNIT: YES / NO/ PARTIAL

FLARE STACK: YES / NO INCINERATOR: YES / NO
IGNITION TYPE _______________ KNOCKOUT TANK: YES / NO
BURIED: YES / NO
VENTS TO STACK:
TREATER/ POP TANKS/SEPARATORS/ DEHY/ FWKO/ OTHER
BIOPHYSICAL ASPECTS:
ADJACENT TOPOGRAPHY
LEVEU GENTL Y ROLLING/ STEEPLY ROLLING/ MOUNTAINOUS
ADJACENT LAND USE

COMMERCIAL _________ INDUSTRIAL ___________
AGRICUL TURAL_________________ WATERSHED ___________
RECREATION _________ RESIDENTIAL ___________
PARK _________ PROTECTED SITE___________
HISTORICAL RESOURCE __________
PROXIMITY OF RESIDENCES TO SITE________________________________
VEGETATION ADJACENT TO SITE:

CROP/ CUL TIVATED/ GRASS/ FOREST/ SCRUB/ MUSKEG/ HAY FJELD
APPEARANCE: HEALTHY/AVERAGE/POOR
VEGETATION ON SITE:
% BARE ON WORKING AREA______________
% BARE ON PERIMETER AREA_____________
VEGETATION TYPE (WEEDS, CONDITION,ETC.):
______________________________________________ .1 i

WELLSITE CHECKLIST
VEGETATION CONTROL:
NONE/ CHEMICAL/ MECHANICAL ADEQUATE?: YES / NO
CHEMICALS USED (IF KNOWN):
___________________________________________________________
WASTE CONTROL:
WASTE NAME WASTE VOLUME STORAGE LOCATION DISPOSAL METHOD
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
_______________ _________________ ____________________ ___________________
HOUSEKEEPING:
GOOD ________ AVERAGE ___________ POOR _____________
SUMMARY COMMENTS ABOUT THE LEASE:
** FIELD ESTIMATED COSTS**
RECLAMATION:
___________________________________________________________________________
(STANDARD RECLAMATION, NO OBSERVABLE EXTRA LIABILITIES)
COMPLIANCE:
___________________________________________________________________________
(REMEDIA TION CAN BE DEFERRED UNTIL FINAL ABANDONMEN.T)
NON-
COMPLIANCE:__________________________________________________________________________
(REMEDIATION CAN NOT BE DEFERRED UNTIL FINAL ABANDONMENT)
PHOTO LOG:
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________
#____________ ___________________________________________________________

WELLSITE CHECKLIST
SITE DIAGRAM:
LEGEND:
slope direction
.fencing

ENVIRONMENTAL AUDIT ATTENTION REQUIRED
COMPRESSOR SITE
COMPANY __________________________ DATE _____________ INSPECTED BY _____________
OPERATOR __________________________ FIELD ____________________ FILE ________________
LOCATION LSD _______ SECTION _______ TOWNSHIP _______

RANGE_____W______ M
INLET MANIFOLD: INLET CATHODIC PROTECTI0N_______ INLET LINES MARKED__________
SEPARATOR AND COMPRESSOR STATI0N: COMPRESSOR FLOOR DRAINS TO___________
CHEMICALS IN COMP STA. ____________________________

____________________________
____________________________
____________________________
____________________________
DEHY DEHY FLOOR DRAINS TO GLYCOL FILTERS

GLYCOL FILTERS DISPOSED TO
BURIED TANKS SIZE PRODUCT10N LINE – BURIED
TANK CONTENTS
FLARE STACK FLARE STACK KNOCKOUT
FLARE STACK SOIL CONTAMINATI0N

IF YES, NOTE SEVERITY
CONDENSATE AND WATER TANKS:
TANKS bbls TANK DIKES SOIL TYPE ADEQUATE

_______ _______
_______ _______ TANK GAUGING _______ _________
T ANK DIKE SOIL CONTAMINATI0N _______________________________

IF YES, NOTE SEVERITY
PIPELINE: DESTINATION _______________________________
CATHODIC PROTECTION __________ UNION __________ FLANGE _________ TEST

POINT______
RECTIFIER ________________ LINE HEATER_____________

SECTION III
ENVIRONMENTAL AUDIT
PROTOCOLS AND GUIDELINES

GENERAL PRACTICES TO UNDERTAKE ALL ASSESSMENTS AND INSPECTIONS
The following elements are common to all physical assessments and inspections:
1.0 Identification of all activities associated with the facility/operations;
Prior to any field inspection, all related operational activities and facility
processes must be identified and understood.
2.0 Verification of all regulations, policies and procedures;
Verification activities confirm that regulations and policies are being adhered to,
identify gaps in common policies and standards and confirm that management
control systems are in place.
3.0 Review of the operations from start to finish;
It is important to understand how the facility design works and what operations
are required to maintain facility processes. An initial activity is to verify facility
design by physically walking through the process from the start where raw
product enters to the end of the facility where produced products such as oil or
gas leaves.
4.0 Determination of material balancing techniques; and,
Facility operations require many types of materials to complete oil and gas
processing activities. The audit program should utilize material balancing
studies to determine all feedstock, product and effluent streams are accounted
for.
5.0 Conduct of the site walkover.
The site walkover confirms all the information generated. It is important that a
complete assessment be undertaken of the facility site. This assessment
should involve walking around the boundary site and a detailed walk within the
site area to observe any potential or existing environmental problems.

CHAPTER 12.0

CHAPTER 12.0 ONSHORE OPERATIONAL AUDIT GUIDELINES
12.1 Seismic
12.2 Drilling
12.3 Production
12.5 Refineries

12.1 Seismic

12.1 SEISMIC OPERATIONS
1.0 Regulatory Environmental Authorization

2.0 Environmental Concerns
General Operating Procedures
3.0 Surveying and Staking

4.0 Topsoil Conservation
5.0 Access Control
6.0 Access Roads
7.0 Stream Crossings
8.0 Drainage
9.0 Cutting, Clearing and Timber Salvage
10.0 Erosion Control
11.0 Explosives
12.0 Fire Control
13.0 Other Environmental Concerns
Spill Prevention and Emergency Response
14.0 Spill Prevention

15.0 Spill Response
Waste Management
16.0 Waste Storage

17.0 Sewage Effluent and Wastewater Treatment
18.0 Disposal Operations
Abandonment and Reclamation
19.0 Cleanup Operations

20.0 Road Abandonment
21.0 Land Reclamation
22.0 Revegetation Programs

SEISMIC
ENVIRONMENTAL PLANNING
SEIS 1.0 Regulatory Environmental Authorization
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained prior to the
commencement of any exploration program. Special conditions and restrictions shall
be reviewed and enforced.
Audit Guideline:
• Review the project records to ensure that all required permits, licenses and
regulatory authorizations were obtained prior to the start of any field operations and
make sure that all information in writing is available on site. Record permit/license
numbers and verify information in the field.
• Review records to verify that consent of the landowner or land occupant has also
been obtained prior to any work. Look for field report sheets on
landowner/occupant contacts.
• Review any particular conditions, restrictions and requirements of the

permits/licenses. Special attention should be paid to those conditions for
Protected and Conservation Areas, Indian Reserves, existing pipelines, especially
in 3D surveys. Verify through inspection of the seismic operations that these issues
were considered during the planning stage of the operations. Verify that they are
enforced during the seismic operations. (Clearing operations, shot lines, etc.)
• Verify through interviews that the project supervisor is aware of any restrictions and
environmental concerns and has provided this information to the contractor. Verify
that those restrictions are enforced with the contractor and personnel, and that the
local government has been contacted about the project prior to the operations start.
• Identify if regulatory personnel will be inspecting the seismic work and attempt to
coordinate the site visit and meet with the government person in the field.

SEISMIC
SEIS 2.0 Environmental Concerns
Audit Protocol:
The planning of seismic operations shall be undertaken in a manner that will anticipate
problems and minimize the effects of the operations.
Audit Guideline:
• Inspect site to verify that environmental concerns were considered during the
planning of the seismic operations. These concerns may include loss of timber,
effect on forage and crops, effect on wildlife, water pollution, erosion potential on
slopes, access and fence crossing requirements.
• Review records and indicate if there are any water quality monitoring programs.
Record any information available if such programs have been implemented.
• Review records to verify that there is a proper recording procedure during an

occurrence of any disturbance to the environment. If any incidents have occurred,
record the types of measures taken.
• Review records to verify that all relevant waste management documentation,

operations manuals and abandonment procedures manuals are available on site.
• Verify that environmental concerns were considered during the planning of access
roads. Existing roads should be used as much as possible to minimize
unnecessary road construction and encroachment on the adjacent land. To
minimize the need for deep cuts, the planner should avoid steep gradients and
identify the areas for detours. Access road location should minimize disturbance to
watercourses and sensitive areas. Clearing widths should be kept to a minimum.
Changes to natural conditions should be minimized while attaining maximum
erosion control.
• Verify through interviews that the work crew has been instructed to stay on
designated trails to avoid trampling of crops.
• Verify that the base camp and existing fly camp were built according to the
recommended waste water regulations.
• Verify that landowners have been contacted prior to any explosive detonations so
that livestock is moved away from shot points. Seismic work can impact upon

livestock sensory systems. It may also be disturbing for livestock to be in the area
when large work crews are in the field.
• Verify that work crews have been instructed to avoid harassment of wildlife.
• Verify that attempts have been made to schedule project activities to avoid the time
periods when high water levels occur in marshes. Walking across marsh areas
can disturb the habitat provided by the marsh. Spawning periods of fish in rivers,
streams and creeks should be taken into consideration to avoid disturbance during
critical periods. Efforts must be made to avoid damage to spawning beds at all
water crossings.
• Identify if limitations of seasonal weather and the parameters for halting work in the
event of serious environmental damage have been considered (i.e. wet weather
causing erosion or extreme dry weather and a high fire risk).

SEISMIC
GENERAL OPERATING PROCEDURES
SEIS 3.0 Surveying and Staking
Audit Protocol:
The initial entry onto a program should be reviewed to determine issues of concern
depending on vegetative cover, land use, terrain and habitat. This may impact the type
and amount of survey required to ensure efficient establishment of seismic right-of-
way.
Audit Guideline:
• Inspect surveying of seismic lines. Seismic lines should be staked at intervals to

clearly mark the seismic line and minimize right-of-way disturbances.
• Determine the method of line cutting and maintaining the proper bearing. In
situations where timber avoidance line cutting is employed, a line of sight may be
required. If the line can be cut “on the face” without pre surveying the line, ensure
items of concern are identified and flagged on the ground for the lead cat (i.e., road
crossings, stream crossings, steep slopes requiring detours). Programs should be
ground truthed prior to construction or cutting of seismic lines to evaluate access,
confirm existing lines and consider the placement of new cut lines in relation to
existing lines.
• Verify that the opportunity to utilize and maximize existing clearing as access or
seismic line is undertaken.

SEISMIC
SEIS 4.0 Topsoil Conservation
Audit Protocol:
Topsoil shall be salvaged from all graded and disturbed areas. Topsoil shall be used
for specific land surface restoration and revegetation.
Audit Guideline:
• Inspect site to verify that topsoil is selectively removed from the disturbed area and
conserved.
• Where ever possible topsoil should be stockpiled at the top of a slope and not at
the bottom to facilitate easy replacement.

SEISMIC
SEIS 5.0 Access Control
Audit Protocol:
Access control shall be implemented to minimize additional disturbances to the

environment and protect people, livestock and wildlife from harm.
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates in place. Verify that
access control is in place for environmentally sensitive areas.
Access controls may be enhanced with doglegs on seismic lines where they
intersect existing public access road or trails. This effectively screens the new cut
line from general viewing and awareness.
Rollback of debris on the first 90 meters of new cut seismic line may effectively
restrict or control unauthorized use of the line in conjunction with the dogleg or
deflection cut.

SEISMIC
SEIS 6.0 Access Roads
Audit Protocol:
Existing roads shall be used as much as possible to minimize unnecessary road

construction. If construction of access roads is necessary, they shall be constructed
and maintained in a manner that prevents erosion, drainage problems and disturbance
to the environment.
Audit Guideline:
• Inspect intersections of access roads and seismic lines. Whenever a proposed

seismic line crosses a road or access road, the line is to be dog-legged and closed.
The closure should be accomplished by putting logs, stumps or slash back over the
length of the dog-leg.
• Inspect access roads near high sensitive areas. Fences or post signing should be
used to limit the use of access roads in sensitive areas.
• Inspect access roads to detect any drainage problems. All access roads should be
maintained to allow proper drainage and to prevent erosion. This includes clean-
out ditches, culverts and erosion control structures.
• Inspect access roads for proper construction of ditches to control runoff water.

SEISMIC
SEIS 7.0 Stream Crossings
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction,
seismic lines or placement of a bridge or culvert for continual crossing use. Measures
shall be taken to reduce the impact of exploration activities on water quality.
Audit Guideline:
• Inspect stream crossings to verify that environmental protections were implemented

to minimize disturbance and pollution.
• Inspect stream crossings for signs of pollution and sediment problems. Sediments
entering streams are a major pollutant and have significant effects on the survival,
reproduction and growth of fish.
• If work crews cross rivers and water bodies in boats, erosion of stream banks can
occur during the loading of work crews into boats. Verify that steep slopes are
avoided for passenger loading areas. Clearing of vegetation on stream banks must
be avoided.
• Inspect stream crossings to verify that no more than one crossing has been
constructed at the intersection of a seismic line and any stream. Inspect that debris
and material is pulled back at a crossing rather than pushed through the stream.
Wood and soil materials should not be placed into any waters.
• Inspect stream crossing to verify that the number of vehicular movements across a
stream is kept to a minimum. Existing bridges should be used whenever they are
available. Work crews should cross rivers and water bodies in boats if bridges are
not available.
• Record proximity of seismic line to watercourses and verify if this distance is

acceptable.
• Verify that an undisturbed vegetative buffer is maintained on stream crossings

which do not require equipment crossings with only a 4 foot wide line of sight cut to
accommodate the laying of geophones across the stream. Intermittent draws
which carry seasonal runoff should be evaluated for buffer requirements. Charges
may be stacked on either side of the crossing to provide suitable seismic data
recording.

SEISMIC
SEIS 8.0 Drainage
Audit Protocol:
Changes in natural conditions should be minimized to prevent altering natural drainage

patterns. Any normal interference with the normal drainage of water from land, where
such interference has been caused by the operation, shall be removed or remedied as
soon as possible.
Audit Guideline:
• Inspect site for any signs of disturbance to drainage patterns. The consequences of
inadequate drainage are extensive and include ponding, flooding, washouts and
inundation of vegetation . Disturbance to drainage patterns can be minimized if
equipment is hand carried within the project area.
• Verify through interviews that work crews have been instructed not to place any
materials in drainages.
• Inspect any bridges that are constructed as required to cross drainage channels to
minimize disturbance of surface runoff.

SEISMIC
SEIS 9.0 Cutting, Clearing and Timber Salvage
Audit Protocol:
Cutting and clearing operations shall be implemented so that disturbance to the

environment is minimized. All necessary precautions to minimize soil erosion and to
avoid pollution of waters and waterways shall be taken. Unnecessary destruction of
merchantable timber should be avoided. Every effort should be made to utilize all
merchantable timber which must be cut.
Audit Guideline:
• Inspect site to verify that any particular restrictions regarding clearing operations
have been enforced.
• Inspect areas outside line right-of-way to verify required environmental protection

measures were taken to minimize disturbance to the environment as a result of
cutting and clearing operations.
• Inspect site to verify that all necessary precautions were taken to minimize soil
erosion and to avoid pollution of waters and waterways.
• Review records to verify that a recording procedure is in place for all sold and
transported timber.
• Verify that after clearing, timber is removed and put to some beneficial use or is
disposed of by sale, wherever it is possible.
• Ensure salvaged timber is located in areas suitable for recovery and in a manner to
facilitate economical removal.

SEISMIC
SEIS 10.0 Erosion Control
Audit Protocol:
Erosion control measures shall be implemented during seismic operations.
Audit Guideline:
• Check for signs of erosion problems, sedimentation of streams or reduction in

watershed capacity caused by the removal of trees, shrubs and other vegetation,
disturbance of land surface, or any other cause resulting from the operations.
Select the most difficult terrain for an initial inspection.
• Inspect access routes and vehicle use to verify that damage to the soil is being
prevented. Look for ruts from large tires or tracked equipment.
• Inspect site to verify that any interference with the normal drainage of water from
land, where such interference has been caused by the operations, has been
remedied or removed.
• Verify that efforts are made to avoid disturbance of the top duff layer during the line
cutting operation. Areas of the seismic line which have been stripped should be
noted for prompt erosion control measures.
• Inspect areas of steep slopes for damage by vehicular traffic. Detours around steep
slopes should be encouraged with hand cut 4 foot wide line of sight cut over the
slopes to facilitate the laying of geophones.
• Inspect discharge points for sedimentation of the native vegetation. Diversion of

runoff water to prevent channelling on the seismic line should be encouraged on
long slopes.
• Verify that a corridor of trees is preserved between the clearings and the river to
prevent erosion of the river bank.

SEISMIC
SEIS 11.0 Explosives
Audit Protocol:
Proper use of explosives shall be implemented.
Audit Guideline:
• Verify that care and handling of explosives conforms to existing government

regulations.
• Through interviews, determine if personnel are familiar with the proper handling of
explosives. Verify that safety measures taken when transporting explosives are
appropriate. Explosives carried to the work area must be stored in a separate,
enclosed, locked compartment. Detonators and explosives shall be separated by at
least 15 cm of solid lumber when transported. For helicopter transportation,
detonators shall be stored inside an aluminum locked container.
• Verify safety measures for handling explosives. Persons loading explosives must
wear safety hats equipped with ear protection. Verify that the detonators were
connected in series circuit along the short array.
• Verify that explosives are not utilized in environmentally sensitive areas.
• Inspect the site where explosives have been detonated. Where a charge is
detonated in the vicinity of a water well, care should be taken to avoid damage to
the well. Check that drill sites are at a sufficient distance from water wells.
• Inspect shot holes. Shot holes found to be flowing when drilled should not be
loaded or shot. All flowing shot holes should be filled to permanently or effectively
stop the flow. Any swamp or marsh area in a topographically low area should be
considered a potential flowing zone. Shot holes must be plugged and filled to the
original contour before progressing to the next shot hole, or as soon as conditions
permit.
• Verify that shot holes are abandoned properly. The following guidelines are
suggested:
Shot holes are abandoned by:
- filling the hole with material obtained from the hole.

- inserting to a depth of 45 cm below the surface an approved metal or plastic

cap, a wooden plug one meter in length or a cement plug one meter in length.
- filling the hole from the plug to the surface and tamping the fill material.
- spread excess material obtained from the hole over the surrounding ground.
• Inspect seismic drilling operations near water bodies. Use of explosives must be
limited within permanent, fish bearing and freshwater water bodies.
• Verify if any water wells have been sampled and analyzed prior to and following
detonation of explosives to ensure water quality and quantity are not disturbed.
Seismic work can disturb groundwater aquifers during the detonation of explosives
if such aquifers are close to the shot hole.
• Verify that all cratered shot points are backfilled and levelled to as near original
contours as possible.
• Verify that warning signs regarding the use of radio-telephones and other electronic
equipment are posted in conjunction with the “shooting” of the program.
• Verify that all shot points are labelled with the appropriate information to relocate
the point at a later date (for drilling) or in the event of an environmental problem
(flowing hole).
• Verify that all shot points located near electric transmission lines have been
skipped.

SEISMIC
SEIS 12.0 Fire Control
Audit Protocol:
It is typical for seismic activity to be the first industrial activity in remote locations or in
areas not frequented by regular traffic. As a result, the potential for serious and hard to
control fire situations is not uncommon. Seismic programs must be sensitive to the
seasonal potential for ignition and wildfire starts. Fuel sources such as grass are very
easy to ignite and prone to rapid spread.
Audit Guideline:
• Determine the level of fire hazard to the seismic operation. Factors to consider is
fuel type and ease of ignition due to fuel moisture and size.
• If open fires are needed, verify that precautions are taken to ensure extinguishment.
• Verify that the method of line cutting and debris windrow is addressed to avoid
wicking a fire. Wicking is referred to the effect of a wildfire following or wicking
along a debris windrow and dramatically increasing a fire front. Alternate piling of
the windrows on the side of the line at 400 meter intervals effectively breaks the
continuity of fuel and restricts the spread potential.
• Determine if there is any fire fighting equipment onsite. A compliment of fire

fighting equipment may be required by all personnel to control initial fire starts
depending on the severity of fire risk.

SEISMIC
SEIS 13.0 Other Environmental Concerns
Audit Protocol:
Depending on the type of terrain, vegetative cover, existing activities and concerns of
other land users, the seismic program may require adjustments to accommodate as
many concerns as is practical or possible.
Audit Guideline:
• Inspect site for any disturbance to agricultural productivity due to trampling of crops,
removal of plantation trees and plants and inconvenience of farming activities.
• In agricultural areas, inspect site for attempts made to avoid disturbance of fields
that are nearing harvests.
• Inspect fence crossings to ensure satisfactory repairs have been made. Where
ever possible existing gates should be utilized to avoid unnecessary damage to
landowner fences.
• Inspect location of camp. Camp and facilities must be located so as not to impede
with local land users.
• Inspect marsh areas. Temporary bridges should be constructed to allow crews to

cross marsh areas. Walking across marsh areas can disturb the habitat provided
by the marsh.

SEISMIC
SEIS 14.0 Spill Prevention
Audit Protocol:
Proper measures shall be taken to prevent the occurrence of spills.
Audit Guideline:
• Check for signs of spills onsite. Record location and size of any spills. Provide a
sketch of the spill area if possible. Indicate the type of spills observed (type of
contaminant, soil contamination, water contamination, etc.)
• Inspect fuel storage areas and equipment. Fuel tanks are preferable to bladders,
and welded steel tanks are preferable to bolted ones. Inspect tank dykes and verify
that they are of adequate size to contain any spills and have impermeable sides
and bases. Other guidelines for fuel storage facilities include:
- Stationary fuel storage facilities should not placed within the annual flood plain
of a water course or closer than the locally recommended distance to a water
body.
- Stationary fuel storage should be located above the high water mark of any lake
or stream.
- Stationary fuel storage should be on flat, stable terrain or in natural depressions
separated from water bodies.
- Stationary fuel storage areas should be free of other combustible material to
isolate potential fires.
• Verify that fuel storage areas are clearly marked to ensure that they are not
damaged by moving vehicles. The markers should be visible under adverse
weather conditions. Check that “No Smoking” signs are posted.
• Through interviews, verify that all personnel are familiar with proper fuel handling
procedures.
• Verify if fuel transfer operations are performed in a manner that prevents spills.
Review records to verify if there is any reporting process in place to record
occurrences of spills. Through interviews, verify that such process has been
implemented and that personnel are knowledgable of such process.
• Verify that all personnel are aware that oil changes or other oil related repairs are to
be completed without random dumping of oil and oil filters. Any such operation
should only be completed with an emergency spill kit close at hand.

SEISMIC
SEIS 15.0 Spill Response
Audit Protocol:
Seismic operations shall have a spill contingency plan. All personnel shall be familiar
with the contingency plan.
Audit Guideline:
• Verify the existence of an appropriate spill contingency plan. Record and analyze
the particular spill prevention and response methods to make sure they are
appropriate. Tools and materials should be available to clean up any spills or drips.
Equipment should include absorbent material, shovels an plastic bags
• Interview personnel to verify the level of knowledge of such plan.
• Verify through inspection that all material and equipment specified in the
contingency plan is available onsite.
• Inspect spill areas to verify proper cleanup operations.

SEISMIC
WASTE MANAGEMENT
SEIS 16.0 Waste Storage
Audit Protocol:
Wastes shall be properly stored and handled. Waste includes all flagging, stakes and
other debris not normally found within the area of operations.
Audit Guideline:
• Inspect waste storage areas. Verify that proper storage procedures are
implemented.
• Verify through interviews the implementation of proper handling procedures.
• Inspect waste storage areas for proper signage and access control. Verify that
measures are taken to prevent access by the public, wildlife or livestock.
• Inspect and verify that putrescible wastes that attract scavengers are placed in
suitable containers that have tight-fitting lids. This type of refuse should be picked
up and hauled to the disposal site every day. Other non-putrescible refuse should
be picked up as required.
• Verify that plastic, organic and metallic garbage has been collected along seismic
lines and transported to a proper disposal place.

SEISMIC
WASTE MANAGEMENT
SEIS 17.0 Sewage Effluent and Wastewater Treatment
Audit Protocol:
Where feasible, work camp wastewater shall be hauled or discharged to an approved

municipal wastewater treatment system. No effluent shall be discharged unless it
meets minimum requirements of existing regulations.
Audit Guideline:
• Verify method of sewage and wastewater treatment/disposal (septic tanks, leach

pits, holding tanks, incineration, lagoons, etc).
• Inspect distances of subsurface disposal facilities (septic tanks, leach pits) from
any sources of water supply and natural water bodies.
• If the septic tanks are used, verify that they provide a 24-hr retention period for the
raw sewage and an equal volume for sludge storage.
• Verify that pump-out and hauling operations are carried out in a manner that does
not expose the driver or people in the area where the tanks are emptied to any
health hazard. Every effort should be taken to avoid any spillage when holding
tanks are emptied or when the truck contents are discharged into the treatment
facility.

SEISMIC
WASTE MANAGEMENT
SEIS 18.0 Disposal Operations
Audit Protocol:
Wastes shall be disposed of properly.
Audit Guideline:
• Verify that waste materials are separated and proper disposal methods of camp
solid and liquid wastes are used.
Incineration, followed by burial of incinerated material is recommended.

Combustible wastes should be incinerated daily. Materials suitable for recycling
should be stored separately and recycled accordingly.
Whenever land is cleared by a linear development, debris disposal is a major

concern. Debris disposal is the total or partial disposal of all unsaleable timber,
brush, roots and other debris on the right-of-way. It is done to reduce fire hazard
and improve aesthetics. A common disposal method is Rollback of debris.
Rollback is the practice of spreading debris from clearing back over the line after
program completion. It is restricted to debris less than 15 cm in diameter, and the
debris should be compacted.
Whenever a linear disturbance crosses a road, total disposal should be completed

for a distance of 90 m from either side of the road’s centre line. The most common
method of total disposal is burning, with the residue hauled down the line and
spread out of sight in the residual trees. Burial of burnt debris is discouraged.
• Verify that proper procedures are in place for the transportation, disposal and
storage of hazardous wastes. Hazardous materials should not be incinerated.
Non-combustible garbage should be properly sent to an authorized disposal facility,
if available, according to local regulations. In the absence of such facilities, waste
should be buried at least one meter below the surface.
• Inspect site to verify method used for sewage disposal. Septic tanks are
acceptable systems for sewage disposal.
• Verify how often the seismic camp is moved. Seismic camps should be moved as
often as practical to minimize the amount of garbage and waste to be disposed at
any one location.
• Open pits are discouraged.

SEISMIC
SEIS 19.0 Cleanup Operations
Audit Protocol:
Proper cleanup operations shall be implemented upon completion of seismic

operations.
Audit Guideline:
• Inspect site to verify that proper cleanup operations have been implemented.
• Verify that all timber and debris not disposed of after the campsites were cleared
has been salvaged or removed. All buildings, trailers, machinery, equipment,
materials, litter and storage containers must be removed from the area. Temporary
access roads from the highway to the campsites must be removed. Abandoned
equipment should either be hauled out of the area or buried in a landfill site.
• Ensure all sites which require rollback as access control have been treated after
debris cleanup and seeding.

SEISMIC
SEIS 20.0 Road Abandonment
Audit Protocol:
Roads shall be abandoned properly.
Audit Guideline:
• Verify that roads are abandoned properly.
a) If the roads have been temporarily abandoned, the following are required:
- All watercourse crossings such as culverts or bridges must be removed.

- Grade must be maintained but cross-ditches of erosion control structures
must be installed as required.
- All exposed areas have to be revegetated.
- Entry onto the road must be blocked if located in wildlife or ecologically
sensitive areas.
b) If roads are permanently abandoned, the following are required:
- Cuts and fills must be recontoured to natural conditions where slope and
materials make this practical.
- Erosion control measures such as diversion berms and cross-ditches must
be installed as required.
- Rollback windrowed debris for erosion control to provide microsites for
vegetation.
- All watercourse crossings must be removed and creek banks stabilized if
necessary.
- Disturbed areas must be revegetated using a suitable seed mix.

SEISMIC
SEIS 21.0 Land Reclamation
Audit Protocol:
Upon completion of seismic operations, land reclamation shall be implemented to

restore site as closely as possible to pre-disturbance conditions.
Audit Guideline:
• Inspect the site to verify that recontouring of the land was implemented as required
to pre-disturbance conditions. As soon as possible, the seismic lines should be
contoured to their original condition.
• Inspect the seismic lines to determine what type of reclamation has been done.
• Inspect shot holes locations. Disturbed ground surface area must be restored to
original condition and reclaimed to prevent erosion. Shot holes must be plugged
during abandonment.
• Inspect stream crossings to determine if land has been recontoured, if erosion

control measures were in place and if slopes were stabilized. Reconstruction of the
banks may be necessary.

SEISMIC
SEIS 22.0 Revegetation Programs
Audit Protocol:
Upon completion of seismic operations and the removal of camps and all related
facilities, a revegetation program shall be implemented to restore the disturbed area to
a productive capability similar to or better than the pre-disturbed condition.
Audit Guideline:
• Inspect site to verify that proper revegetation procedures have been implemented.
Seismic lines should be reseeded and fertilized if necessary. The area should be
revegetated with grasses, shrubs and trees native to the area.
• Inspect that species selected are consistent with the planned use of the area
(commercial forest, recreation area, grazing or wildlife habitat, etc.).
• Verify that the seed mixture is fast growing, self-sustaining and that it requires little
or no maintenance.
• Verify that all steep slopes are treated and any areas which have been stripped of
the surface duff layer receive prompt attention.
• If the site has had time for vegetation, record the success achieved after
revegetation and if more work is required.

12.2 Drilling

12.2 DRILLING OPERATIONS

3.0 Access Control

7.0 Erosion Control
8.0 Drainage
9.0 Access Roads
10.0 Protection of Freshwater Horizons
11.0 Blowout Prevention Plan
12.0 Flaring During Completion and Testing of Gas and Oil Wells
13.0 Spill Containment
14.0 Drilling and Mud Systems
15.0 Noise

17.0 Emergency Response for Well Drilling, Completion or Testing of Sour Gas Wells
18.0 Spill Contingency Plans
Waste Management

20.0 General Waste Disposal
21.0 Sump Construction
22.0 Disposal Waste of Drilling Fluids and Solids
23.0 Disposal Options for the Sump Fluids
24.0 Disposal Options for Workover and Completion Wastes
25.0 Well Abandonment

26.0 Rig Dismantling and Site Completion
27.0 Land Reclamation
28.0 Revegetation

DRILLING
DRILL 1.0 Regulatory Environmental Authorization
Audit Protocol:
be reviewed and enforced.
Audit Guideline:
• Meet with the drilling manager or project supervisor to review the project records to
ensure that all required wellsite construction and drilling permits, licenses and
regulatory authorizations were obtained prior to the start of any field operations.
Check the files to make sure that all information in writing is available and has been
provided to all field supervisors on site. Record permit/license numbers and
contractors specifications and verify information in the field.
landowner/occupant contacts. Check with the project supervisor that field reports
have been reviewed.

permits/licenses, considering environmental requirements for onshore drilling
operations. Verify through inspection of the drilling operations that these issues
were considered during the planning stage of the operations. Verify that they are
enforced during the drilling operations.
• Verify through interviews that the project supervisor is aware of any restrictions and
environmental concerns and has provided this information to the contractor. Verify
that those restrictions are enforced with the contractor and personnel. Check all
written conditions provided to the contractor.
• Identify if regulatory personnel will be inspecting the drilling work and attempt to
coordinate the site visit and meet with the government person in the field.

DRILLING
DRILL 2.0 Environmental Concerns
Audit Protocol:
The planning of drilling operations shall be undertaken in a manner that will anticipate
problems and minimize the effects of the operations to the adjacent environment.
Audit Guideline:
• Verify that environmental concerns were considered during the selection of the
drilling site. For example:
a) Determine the drainage pattern around the drilling site. The site should be
selected so that spills can be easily contained and where natural drainage
moves away from the site. This guideline also applies for staging areas,
camps, fuel dumps and storage areas.
b) Identify if there has been an unnecessary removal of trees or alteration of

other natural features.
c) Verify that the location of campsites and access roads are planned based on
minimized environmental impacts.
d) Verify that the wellsite does not conflict with local land use restrictions (i.e.,
airports, proximity to dwellings, etc.).
e) Verify that the access road and wellsite does not create possible
environmental effects on marshes, river beds, fractured formations, springs,
etc.
f) Verify if wellsites have been constructed with a minimum of 100m of

undisturbed vegetation left intact between the lease site and any
watercourse or fish bearing water body.
g) Verify if wellsites are located so that there is minimum harassment of wildlife

and far enough from a water body to prevent deleterious materials, such as
salt water, spilled oil and grease, from affecting habitat vegetation and water
quality.
h) Verify if wellsites are supported by pollution control resources such as

surveillance aircrafts, oil spill response teams, etc.

DRILLING
DRILL 3.0 Access Control
Audit Protocol:

environment and protect the local population, livestock and wildlife from harm.
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates. Verify that access
control is in place to protect environmentally sensitive areas.
• Check the success of access control and determine if further control methods are
required.

DRILLING
DRILL 4.0 Stream Crossings
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction or
placement of a bridge or culvert for continual crossing use. Measures shall be taken to
reduce the impact of exploration activities on water quality.
Audit Guideline:
• Verify if government regulations require special stream crossing conditions

including seasonal restrictions to the construction of an access road and use of this
road.
• Verify that the protection of streams due to sedimentation contamination has been
taken into consideration in the plans, designs and construction of an access road.
Inspect stream crossings for signs of pollution and sediment problems.
available.

DRILLING
DRILL 5.0 Cutting, Clearing and Timber Salvage
Audit Protocol:
All construction activities shall employ cutting and clearing methods which will result in
the least environmental damage and least forest or grassland growth removed.
Audit Guideline:
• Inspect the wellsite to verify that any particular restrictions regarding clearing
operations have been enforced.
• Verify that areas outside the wellsite requiring environmental protection measures
were identified to minimize disturbance to the environment as a result of cutting and
clearing operations.
erosion and to avoid pollution of waters and waterways.
• Review timber salvage merchantability standards and species to ensure harvesting

of all required timber. Salvage operations should insure proper felling, limbing,
topping and decking of timber to accommodate removal of the timber.
transported timber.
• Verify that after clearing, timber is removed and put to some beneficial use by the
company or is disposed of by sale to a lumber company.

DRILLING
DRILL 6.0 Topsoil Conservation
Audit Protocol:
Audit Guideline:
• Verify, prior to going to the field, if construction specifications provide guidelines for
topsoil removal, storage and replacement.
conserved.
• Inspect the topsoil storage area to determine if the topsoil has been placed in a
location secure from contamination and erosion. Topsoil must be protected from
loss by wind or water erosion. Depending on the period of time the lease will
remain in a disturbed state or the time of year, a vegetative cover may be required
on the topsoil salvage piles.
• Ensure the placement of topsoil salvage piles are located to facilitate replacement
over the disturbed area. Avoid burial or over the edge locations.

DRILLING
DRILL 7.0 Erosion Control
Audit Protocol:
Erosion control measures shall be implemented during the construction of the access
road and wellsite and during drilling operations.
Audit Guideline:
• Inspect the access road and wellsite to look for signs of erosion problems,
sedimentation of streams, suffocation due to siltation of vegetation or reduction in
watershed capacity caused by the removal of trees, shrubs and other vegetation,
disturbance of land surface, or any other cause resulting from the operations.
Select the most difficult terrain for an initial inspection.
• Verify during the inspection that any interference with the normal drainage of water
from land, where such interference has been caused by the operations, has been
remedied or removed.
• Check for signs of serious erosion as a result of any large cuts on sloping land. To
prevent erosion on unstable slopes and to prevent sediment from these slopes
entering streams, controls to water runoff should be built. Controls that could be
used include replanting with shrubs and grass, debris installed on the slope, bales
of straw, rocks bigger than 100 mm mesh size, sacks of sand, logs thicker than 100
mm diameter, and trees and stumps imbedded in the slope to reduce mud slides.
Indicate if there is any need for stabilizing structures like gabions, contour
trenching, berms, terraces or equalizer dams.
• Inspect all areas which have water released to surrounding countryside from
diversion ditches, cross culverts, etc. for the presence of heavy silt loading to the
vegetation. Excessive siltation will smother grasses and the roots of shrubs and
trees causing mortality.
• Inspect soil stability around bridges and culverts to determine if any erosion has
started.
• Verify if all drainage channels, related construction of bridges and erosion controls
have taken high flood conditions into consideration.
• Verify that wind erosion has also been taken into consideration, especially on land
high in sand content.

DRILLING
DRILL 8.0 Drainage
Audit Protocol:
Changes in natural conditions should be minimized to prevent altering natural drainage

patterns. Any normal interference with the normal drainage of water from land, where
such interference has been caused by the operation, shall be removed or remedied as
soon as possible.
Audit Guideline:
• Inspect the access road and wellsite for any signs of disturbance to drainage
patterns. The consequences of inadequate drainage are extensive and include
ponding, flooding, washouts and inundation of vegetation .
• Inspect the wellsite for internal drainage control to contain potential wellsite
pollutants on the site.
• Ensure protection is provided to prevent the collection of runoff from the

surrounding terrain on the site and/or surface runoff is not released from the site to
the surrounding terrain in an uncontrolled manner.

DRILLING
DRILL 9.0 Access Roads
Audit Protocol:

to the environment.
Audit Guideline:
• Inspect access roads near high sensitive areas. Check gates, fences and wellsite
identification signs to limit access or identify environmental concerns.
• Inspect borrow pits required for fill situations. Grade construction should be
planned in advance to reduce the area of disturbance. Borrow pits should be
screened from the access road, take advantage of suitable borrow material,
landscaped to blend with the surrounding terrain, and revegetated to encourage
assimilation back into the pre-disturbance environment.

DRILLING
DRILL 10.0 Protection of Freshwater Horizons
Audit Protocol:
Drilling operations shall protect groundwater sources by placing surface casing through
freshwater horizons.
Audit Guideline:
• Check any freshwater wells onsite. Water wells should be located and cased to
prevent any contamination during drilling operations.
• Inspect surface and production casings to verify that they are cemented to the
surface by the pump-and-plug, displacement or other approved method, to a depth
sufficient to protect all freshwater and to ensure against blowouts or uncontrolled
flows.
• Verify that loss of drilling fluid to freshwater aquifers is avoided. Interview personnel
to verify precautions taken during all drilling operations to prevent casing ruptures.
• Verify that producing wells have appropriate tubulars designed to maintain well
control and prevent possible contamination of freshwater aquifers.
• Inspect site for construction and maintenance of berms and/or ditches to prevent
contamination of surface freshwater. Berming should include the access to the
well site, particularly if access is on the low side of the lease.
• Inspect pumps and engines location when freshwater lake or pond is used as a
water supply. Pumps and engines should be located so as to prevent any
hydrocarbon leaks form contaminating the water source.
• Verify that no pits for containing mud, oil, water and other fluids associated with the
well are constructed closer than 100m to the normal high water mark of a body of
water or permanent stream.

DRILLING
DRILL 11.0 Blowout Prevention Plan
Audit Protocol:
Accidental well blowout during drilling operations can result in extensive damage to the
environment. Blowout prevention measures should be in place prior to the start of any
drilling operations
Audit Guideline:
• Prior to a field inspection, verify if blowout prevention procedures are practised and
if there are any written guidelines. Verify if there is any pollution risk assessment
due to spillage of crude oil, including anticipated reservoir characteristics, shallow
nature and blowout potential studies.
• Contact the drilling supervisor on the wellsite and inspect the blowout prevention
equipment.
• Verify if there are any scheduled or unscheduled blowout prevention drills to ensure
drilling crews and service people know their proper places and job assignments fro
an emergency blowout condition.
• Check if there has been the construction of at least a 1 m high berm on the well site
around facilities which could result in the escape of deleterious material.
• Verify blowout prevention measures such as:
a) Tubular casings/program designed to permit safe drilling and completion of

the well.
b) Use of abnormal pressure detection techniques and personnel trained in

their application.
• Verify if there is provision of equipment and/or suitable methods to accurately

measure fill-up volumes of pits to contain additional fluid should a blowout occur.
Identify if there is careful surveillance of pit volumes during all phases of the drilling
operations.

DRILLING
DRILL 12.0 Flaring During Completion and Testing of Gas and Oil Wells
Audit Protocol:
Flaring operations should be controlled and contained to prevent impacts to the

environment from fire and smoke.
Audit Guideline:
• Inspect flare pits to make sure that no produced fluids, trash or other foreign
materials have entered the flare pit. Inspect the equipment onsite to make sure that
there is no possibility for produced fluids to enter the pit. Inspect the land adjacent
to the flare pit to identify areas of contamination as a result of pit overflow or
excessive flaring. Inspect the walls of the pit and adjacent land for vegetation
control and potential use of soil sterilants. Inspect the security of the pit to prevent
people or livestock from entering the pit area. Inspect location of flare pit so that
prevailing winds will reduce fire hazards and smoke nuisance. Ensure there is
sufficient clearing between the flare pit/stack and standing timber, as a fire
prevention precaution. Preferably, flare pits must be located at least 50m from the
well head.
• Verify that the separated fluid is piped and stored in a closed, dyked tank. After the
completion of testing, the liquid must be disposed of appropriately. Inspect dykes.
• Inspect site for presence of separators in cases where liquid production may be
expected. Verify that the contents of the well are passed through a separator to
separate the gaseous and liquid components.
• If a flare stack is used, inspect the stack and adjacent land to see if liquids have
sprayed off the stack. Inspect flare stack operations. The separated liquids should
not be discharged to a flare stack and burned. Free liquids can escape up the flare
stack to pollute the land.

DRILLING
DRILL 13.0 Spill Containment
Audit Protocol:
Every effort shall be made to avoid spills and contain any accidentally spilled drilling
fluids or chemicals. When sump pit overflows, hydraulic oil or fuels and saltwater is
spilled, immediate steps to contain and clean up the oil or salt water shall be taken.
Audit Guideline:
• Meet with the drilling supervisor and verify that a Spill Contingency Plan or
Emergency Response Plan is on site which identifies appropriate measures to
contain spills. Released produced water and hydrocarbon releases can be
contained using booms, absorbent material or soil berms or trenches as necessary.
Free produced water and hydrocarbons can be recovered using pumps or vacuum
trucks. The area of the spilled produced water should be flushed with a calcium
amendment prior to the application of any fresh water, recovering excess fluid. The
area of spilled hydrocarbons should be flushed with water and surfactant in order to
free and recover additional hydrocarbons.
• Inspect the size of the drilling sump pits, dykes and berms constructed to contain
and permit the recovery of any drilling or spilled fluid.
• Verify that any spilled drilling fluid is contained and transferred to the sump.
• Inspect the wellsite area to determine the direction a spill would flow should one
occur. Check to see that a containment system is in place to contain and remove
the spill material.
• If any spills have occurred, verify that cleanup programs were undertaken.
• Verify if wellsites in onshore areas are supported by pollution control resources

such as surveillance aircrafts, oil spill response teams, etc.

DRILLING
DRILL 14.0 Drilling and Mud Systems
Audit Protocol:
Equipment must be maintained at all times to prevent hydraulic oil and fuel leakage.
Oil spill materials should be utilized for cleanups and spill control drains should be
directed to special runoff holding pits on tanks.
Audit Guideline:
• Inspect the drilling rig for special hydraulic oil, fuel and chemical containment
system, spill control and cleanup materials.
• Verify that equipment is maintained to stop or prevent leaks.
• Inspect for any signs of hydraulic oil leaks.
• Inspect motor systems.
• Inspect for any signs of valve/flange leaks.
• Inspect desanders, desilters and mud cleaners. Record any overflows or leaks.
• Verify that proper measures are taken if emergency or problems with the drilling
program result in a “foreign drilling fluid” being introduced to the system ( i.e.,
contamination of a fresh water gel mud system with diesel fuel due to “stuck in the
hole” problems). Compatibility or segregation with the drilling sump depending on
recycle requirements or disposal options must be used.
• Verify that only drilling additives of chemically known composition is used in the
drilling mud systems. Chemicals and materials should be clearly marked, neatly
stacked and easily accessible.

DRILLING
DRILL 15.0 Noise
Audit Protocol:
The impact of drilling operations’ noise on local residents and workers shall be
minimized.
Audit Guideline:
• If houses are adjacent to the wellsite, verify that discussions regarding noise
potential impacts were held with nearby residents during the planning stage. Verify
that adjustments were made to meet the concerns and needs of the residents.
Adequate public notification and discussion can prevent noise complaints after the
operation starts.
• Identify if there have been public complaints and verify that complaints (if any) have
been responded to. If the noise level is higher than acceptable limits, verify that
measures have been taken to meet or better the acceptable limits. If complaints
have been received, verify that noise monitoring of the wellsite is being done.
• Prior to field inspection, verify that noise control programs are in place. Identify if
the rig has noise reduction mufflers.
• Inspect all motor systems to determine that mufflers are in place and are reducing
noise.

DRILLING
DRILL 16.0 Spill Prevention
Audit Protocol:
Proper fuel, oil and chemical handling measures shall be taken to prevent the
occurrence of spills.
Audit Guideline:
• Through interviews, verify that all personnel are familiar with fuel and chemical
handling procedures.
and bases.
• Inspect chemical storage areas. Bagged material should be properly stored in

weather protected areas. Chemical barrels should be protected so that leaks and
spills can be contained.
weather conditions. Check that “No Smoking” signs are posted.
• Verify if fuel and chemical transfer operations are performed in a manner that
prevents spills. Review records to verify if there is any reporting process in place to
record occurrences of spills. Through interviews, verify that such process has been

DRILLING
DRILL 17.0 Emergency Response for Well Drilling, Completion or Testing of Sour
Gas Wells
Audit protocol:
Drilling operations of sour gas wells shall have an Emergency Response Plan to
protect the public, employees, the environment and property should an emergency
occur.
Audit Guideline:
• Review records to verify the existence of an appropriate emergency response plan.

A copy of such plan should be available on-site. Interview personnel to verify the
level of knowledge of such plan. Verify that discussions with local residents were
held when preparing the Emergency Response Plan.
• Review appropriate level of Emergency Response Plan. The following conditions

are recommended:
a) Emergency Response Plans are required for any well where the potential
3
H2S release rate is greater than 0.01m /s.
b) A reduced plan is required where there are four or fewer permanent

residences within the emergency planning zone. For a reduced plan, the
company should have an internal response plan addressing emergency
procedures.
c) A normal plan is required where there are many more residences in the
emergency planning zone than the reduced plan.
d) A special plan is required where there are large numbers of people in the
emergency planning zone. The special plans go beyond the level of detail
required for a normal plan.
• Review the contents of the Emergency Response Plan. The plan should include:
a) Summary
- Location.
- Size of the emergency planning zone.
- Dates for potential hazard.
- Company contact.
- Local regulatory agency office.

b) Emergency Definition
- Outline of circumstances causing a sour gas release and action to be
taken.
- Stages of alert and action plan.
- Responsibilities of company personnel.
- Responsibilities of government personnel.
e) Evacuation Procedures
- Evacuation criteria.
- Evacuation plan.
- Road blocks.
- Evacuation centre.
- Communications.
- Monitoring.
- Evacuation notification.
d) Ignition criteria
- Description of procedures to be followed by well site personnel to ignite
an uncontrolled flow.
e) Post-emergency procedures
f) Resident Information packages
g) Emergency equipment list
h) Contact information
I) Maps
Emergency Response Plan are available onsite.

DRILLING
DRILL 18.0 Spill Contingency Plans
Audit Protocol:
Drilling operations shall have a spill contingency plan. All personnel shall be familiar
Audit Guideline:
• Review records to verify the existence of an appropriate Spill Contingency Plan.

Record and analyze the particular spill prevention and contingency methods to
make sure they are appropriate.
• Interview personnel to verify the level of knowledge of such plan and level of related
experience.
contingency plan are available onsite. Material and equipment should contain the
following: spill absorbent material, small containment barrels and small pumps,
hoses and suction nozzles.
• If there has been a spill, inspect the area to verify proper cleanup operations and
reporting procedures were undertaken.
• Identify areas of risk due to spill and ensure provisions to handle the situation (i.e.,
if the wellsite is on a slope above a fish bearing river, etc.).
• Inspect the drilling fluid containment pits to asses pit sizes. Through site interviews
and inspection, determine that pit volumes take into consideration extra fluid due to
rain fall or emergency dumping situations. Verify if a contingency plan exists to
transfer fluid to prevent overflows.

DRILLING
WASTE MANAGEMENT
DRILL 19.0 Sewage Effluent and Wastewater Treatment
Audit Protocol:
Where feasible, work camp or drilling site wastewater shall be hauled or discharged to
an approved municipal wastewater treatment system. No effluent shall be discharged
unless it meets minimum requirements of existing local regulations.
Audit Guideline:
• Prior to going in the field, verify that conditions of particular regulations regarding
sewage disposal facilities have been identified and provided as guidelines for
implementation in the field. Verify camp and wellsite specifications for housing
personnel.
• Verify the specific method of sewage and wastewater treatment/disposal (septic

tanks, leach pits, holding tanks, incineration, lagoons, etc) utilized for the drilling
project.
• Inspect distances of subsurface disposal facilities (septic tanks, leach pits) from
any sources of water supply and natural water bodies.
• If the septic tanks are used, verify that they provide a 24-hr retention period for the
raw sewage and an equal volume for sludge storage.
• If leach pits are constructed verify that they have two compartments connected in
series. The first cell should settle out solids and the second cell should be used for
percolation.
• Verify that pump-out and hauling operations are carried out in a manner that does
not expose the driver or people in the area where the tanks are emptied to any
health hazard. Every effort should be taken to avoid any spillage when holding
tanks are emptied or when the truck contents are discharged into the treatment
facility.

DRILLING
WASTE MANAGEMENT
DRILL 20.0 General Waste Disposal
Audit Protocol:
All waste material must be properly identified and handled according to hazardous and
nonhazardous waste handling regulatory requirements. Solid wastes generated by
drilling operations shall be disposed of in an acceptable manner to prevent pollution of
the environment.
Audit Guideline:
• Verify prior to the field inspection, the required regulatory procedures to properly
dispose of all types of solid wastes generated either from drilling operations or
typical wellsite activities.
• Verify that there is a reporting policy established regarding type and quantities of
waste.
• Verify that drilling site is kept free of trash and litter. All trash, litter and garbage
must be placed in metal or plastic containers and disposed of properly.
• Verify that rig wastes such as engine oil, waste oil, grease, etc. are accumulated in
appropriate containers for disposal.
• Verify that wastewater utilized in cleaning the rig, tools and equipment is collected
in reserve or storage pits and separated from the sump pits.
• Inspect site area for disposal methods of general solid wastes. Such wastes
include rags, waste paper, paper cartons, scrap metal, plastic wastes and rubber
wastes. Industrial landfilling and incineration are the most commonly used
methods for disposal of solid wastes. Incineration is followed by burial of the
incinerated residue. Combustible wastes should be incinerated daily. Materials
suitable for recycling should be stored separately and recycled accordingly.
• If incineration is an acceptable disposal practice, verify method of disposal of waste

material not totally consumed by burning. Upon verification, undertake an
inspection to determine:
a) On well sites, any residue may be compacted and buried in sump pits
provided a minimum of 1m of mineral soil covers the debris and the natural
ground contours are maintained.

b) On roads where deep fills are required in the grade, residue may be
compacted and buried provided that a minimum of 1m covers the residue
and the natural ground contours are maintained.
• Inspect garbage disposal sites. Garbage disposal sites should be used for small,
non-toxic, non-perishable refuse and incinerator residues. Holes or pits should be
located above the expected high water level. A minimum distance from the bank of
a water body of 45 m is required. Consider and evaluate the potential of wildlife
intrusions to the garbage disposal sites or attraction to the location.

DRILLING
WASTE MANAGEMENT
DRILL 21.0 Sump Construction
Audit Protocol:
Drilling fluid material is to be contained at all times in such a manner that no soil,
surface water or underground source of water is or may be polluted.
Audit Guideline:
The ARPEL document “Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes” can be used as a guide for the auditor in the conduct of
audits in this area.
• Verify from regulatory permit approvals if specific guidelines are required for sump
construction
• Onsite, inspect the sump system. The size of the drilling sumps must be adequate
for the anticipated volumes of the drilling fluids and should include 1m of freeboard,
depending on the expected variables in the drilling program. The drilling sump
should be excavated from an impervious, undisturbed subsoil and should be
shaped to allow maximum reuse of clear water for mud make-up. The sump
should be located on the high side of the lease, and as far away from water bodies
as possible, and the excavated material stockpiled in a location which will facilitate
backfilling.
• Where the soil is such that an on-site sump is not possible, verify that all fluids are
tanked on-site and trucked to an approved disposal site.
• Inspect any rain runoff diversion ditches. Depending on surrounding contours and
the sensitivity of the area, rain runoff diversion ditches may be required around the
lease. Containment berms are recommended on the low side of the lease.
• Inspect the security of the sump. Where applicable, fences or other structures
should be installed to prevent wildlife, people, and livestock from entering the
sump.
• If sumps are constructed in permeable soil material, inspect and verify the sumps
are sealed by an acceptable clay or synthetic liner of other approved material to
prevent leakage.
• Verify that well work over and completion wastes are isolated from the main sump
on completion of well drilling operations.


DRILLING
WASTE MANAGEMENT
DRILL 22.0 Disposal Waste of Drilling Fluids and Solids
Audit Protocol:
Disposal of drilling fluids and solids must be completed within acceptable procedures
which do not result in pollution to the environment.
Audit Guideline:
Production Drilling Wastes” can be used as a guide concerning waste disposal
methods.
• Verify the approved method for disposal of drilling fluids. The main concern with
drilling fluids is ensuring proper segregation so that handling and disposal can be
undertaken effectively with little environmental impact. The waste drilling fluids
should be stored in a main sump.
• Verify if oil based materials are utilized in the drilling fluid and inspect the method of
disposal of oily wastes. A concrete lined pit, metal tank or impervious lined pit
must be used. Earthen structures should not be permitted.
• Verify that lubricating oil, diesel fuel and other hydrocarbons are not added to the
main sump. Unused chemicals and/or other completion fluids must not be added
to the main sump unless prior approval has been obtained from the drilling
supervisor responsible for the sump disposal program.
• Verify that rig wash detergents are not used where KCl drilling fluids are in use or
where they may be mixed with oils. Detergents will emulsify and disperse KCl
fluids and oils into small droplets that are more readily absorbed by flora and fauna
and are more difficult to treat for disposal. In general, rig wash fluids should be
separated from the drilling fluids.
• Verify that all flammable solid waste material is burned in an approved incinerator
or burn pit, or removed to an approved disposal site.
• Verify by inspection, the proper use of the sump. The sump is not a garbage pit.
All solid waste materials that will not incinerate must be collected and stored for
removal from the site. These materials include:
Scrap iron and steel.

Oil cans and drums.

Mud product containers and sacks.

Grease cartridges.
Casing protectors.
Pump parts.
Worn tong die and cables.
Worn wire rope.
• In addition, verify that the sump is not used to collect solid wastes which could not
be incinerated on their own such as cardboard, wooden boxed and rags. Wire
cable and wire rope should be cut in lengths and bundled for ease of handling.
Burial of any of the above items is detrimental to the environment and a hindrance
to further construction on the site.

DRILLING
WASTE MANAGEMENT
DRILL 23.0 Disposal Options for the Sump Fluids
Audit Protocol:
Drilling fluid wastes are defined as either hazardous or nonhazardous waste material.
Proper storage and disposal for each type of waste material is required.
Audit Guideline:
methods.
• Verify from regulatory permit approvals that appropriate disposal options for the
sump fluids are implemented. Preferred practices include:
a) Conventional Water-Based Drilling Fluid:
The solids (cuttings, bentonite, etc.) can be disposed of by burial or surface

spreading depending on circumstances at the time. Waste drilling fluids may be
disposed of by either injection or to the surface. In case of multi-well sumps, waste
drilling fluids can be recycled to other drill sites. If the sump fluid meets acceptable
criteria, it can be pumped off the lease to the surrounding land but written consent
must be obtained from the landowner, and it is also important to review existing
regulations regarding this practice.
Disposal of fluid on the lease is permitted if the total disposal volume is less than
3
1000 m and there is little or no chance of migration. On-lease disposal is done by
squeezing or by evaporation.
b) KCl Fluids:
KCl fluids should be segregated from other fluids used in the drilling program.
Solids can be disposed of as in item “a” but the solid disposal is not as simple as
above. Squeezing/burial is discouraged by some of the regulatory agencies.
Review existing regulations regarding this practice. Salt levels in solids may need
to be reduced through washing the solids prior to disposal. Where saturated KCl
muds are used to drill through evaporite (salt) formations, the fluids and cuttings
must be segregated from other drilling fluids and wastes. The fluids should be
stored in lined sumps and then disposed of through deep well injection.

c) Oil-Based or Invert Muds:
The cuttings are transferred to a lined sump or steel tank. Free oil is collected and
reused in the active mud system. At the completion of the well, the cuttings are
spread on the lease and allowed to dry. After an initial drying period, the cuttings
are worked into the disturbed surface soil layer and returned to the sump. Fertilizer
addition may be necessary to promote degradation. Where oil-based or invert
muds are used to drill through evaporite (salt) formations, the fluids and cuttings
must be segregated from other drilling fluids and wastes. The fluids should be
stored in lined sumps and then disposed of through deep well disposal.
• Verify that proper disposal procedures are followed by site contract with the drilling
foremen. Review any analytical information.
• Inspect all drilling waste containment sites and assess waste disposal programs.
Verify that fluid sampling and analysis programs are following acceptable regulatory
standards.
• Inspect location of injection lines for deep well disposal. They should be located
downstream (flow of the aquifer) of ponds, lakes, crops and dwellings. Deep well
injection can be used to dispose of liquid wastes, particularly saltwater (produced
water), glycols and drilling workover or completion liquid wastes. However, some
regulatory agencies do not consider deep well injection as the best applicable
technology. Emphasis is now being placed on water reuse systems for produced
waters.

DRILLING
WASTE MANAGEMENT
DRILL 24.0 Disposal Options for Workover and Completion Wastes
Audit Protocol:
During well completions or workovers, a variety of fluids may be circulated through the
well to fracture the formation and otherwise maintain or improve fluid flow to the well
bore. These fluids are returned back to tanks on the surface. The fluids which
accumulate in the tanks at the well site shall be disposed of in an acceptable manner.
Audit Guideline:
methods.
• Review regulatory permit requirement and procedures for a completion and

workover job on the well. Verify disposal procedures for workover and completion
wastes. The preferred practices include:
a) Salt solutions (KCl, NaCl, CaCl2) should be disposed of by deep well

injection.
b) Oil and oil/water emulsions: run fluid through a production treater to salvage
the oil and dispose of water down hole.
c) Frac sand and proppants: bury or spread on surface of the lease.
d) Acid water: neutralize with slaked lime and dispose of down hole.
• Inspect well service operations and verify that waste completion fluids, especially
frac acids, are not discharged to the drilling sump. This would make drilling fluid
disposal more difficult.
• Inspect the service operations and check for signs of leaks and spills. Verify that
spill control is practised and any spills are cleaned up.

DRILLING
DRILL 25.0 Well Abandonment
Audit Protocol:
The well casing and wellsite shall be abandoned to a condition where there exists no
present or potential environmental pollutants.
Audit Guideline:
• Verify through record review that abandonment approvals have been obtained from
related regulatory agency.
• Verify that abandonment procedures have been developed. The preferred practices
include:
a) Abnormal pressure zones must be isolated from natural pressure zones.
b) Any known productive oil and gas zones must be isolated and migration of
fluids in or out of these zones prevented.
c) The open hole must be isolated from the cased hole by a cement plug of a
retainer-cement plug combination placed in the deepest casing string which
extends to the surface.
d) All annulus spaces that are open to formations and that extend to the surface
must be plugged.
e) A surface cement plug must be placed below the ground surface in the
smallest casing string which extends to the surface.
f) Casing below the ground surface (usually 1.0 m) must be removed.
g) Before the drill rig is moved away from the drill site, a tag indicating the
company name and drill hole location must be placed within 10m from the
actual drill hole.
• Verify that an abandoned well has a cement plug extending from a depth of at least
200 metres to surface, unless that interval is covered by casing which is cemented
over the interval.

DRILLING
DRILL 26.0 Rig Dismantling and Site Completion
Audit Protocol:
Rig dismantling, disposing of waste materials, site recontouring and restoring the soil
profile and revegetation shall be undertaken to prevent environmental damage and
revegetate all disturbed areas.
Audit Guideline:
• Inspect abandonment activities and verify that upon completion of the well, rig
components are neatly stacked alongside the drilling site and/or right-of-way or on
other approved sites.
• Inspect the site to verify that all holes are properly tagged, filled or plugged. Cellars
should be filled or provided with a suitable cover.
• Inspect the flare pits for proper closure. Check that no produced fluids have been
allowed to enter the flare pit. If contaminants are present, sampling must be
undertaken to assess if special cleanup work is required.
• Verify that surface wood roads and riprap utilized on the drilling site are dismantled.
Lumber, scraps, nails and debris should be removed from the surface.
• Verify that the sump pit area is appropriately backfilled and restored using the
originally excavated material. The soil should be restored to original or better
condition. The covering fill should be built up above the general site level to allow
for subsequent settlement of the fill material. Impermeable pit lining material
should be removed. If backfilling and final cleanup is not feasible (e.g. due to wet
conditions), the pit should be fenced to ensure the protection of livestock and
wildlife.
• During the site inspection, verify that after cleanup operations are completed, the
site is recontoured utilizing subsoil material. Final surface restoration should be
undertaken utilizing topsoil and organic material.
• Verify that slash from the preliminary clearing operation is chopped or shredded,
and spread over the wellsite surface to act as a mulch fostering revegetation.
• Verify that all sites contaminated by spills and other chemical disturbances have
been decontaminated.

• Inspect stream crossings to verify that all culverts have been removed. Verify that
stream banks have been recontoured to original contour. Stabilized log cribbings
may sometimes be left.

DRILLING
DRILL 27.0 Land Reclamation
Audit Protocol:
Upon completion of the drilling operations, land reclamation shall be implemented to

restore the site, replace topsoil and revegetate those land areas disturbed to complete
well drilling and completion activities. Government regulations generally require the
wellsite and access roads to be returned to an environmental state as good or better
that before.
Audit Guideline:
• Inspect the site to verify that recontouring of the land was implemented as required
to pre-disturbance conditions. Disturbed ground surface area must be restored to
original condition and reclaimed to prevent erosion.
• Inspect the site with the drilling supervisor to determine if all the work has been
performed.
• Inspect the campsite to ensure adequate reclamation has been completed in

accordance with the requirements of the well permit, legislation and the landowner.

DRILLING
DRILL 28.0 Revegetation
Audit Protocol:
Upon completion of drilling operations, a revegetation program shall be implemented to

restore the disturbed area not utilized for production purposes, to a productive
capability similar to or better than the pre-disturbed condition.
Audit Guideline:
• Verify prior to the site inspection, any regulatory requirements.
• Ensure that steps have been taken to re-establish a suitable or required vegetative
cover depending on the well permit or the surrounding land use. The wellsite may
have to be inspected at a later date to assess the success of the revegetation
program.
(commercial forest, recreation area, grazing or wildlife habitat, etc.)
or no maintenance.
• If the site has had time for vegetation growth, record the success achieved after
revegetation and if more work is required.

12.3 Production

12.3 PRODUCTION OPERATIONS

This section applies to Conventional Oil and Gas Production Facilities: Gas
Plants, Compressor Facilities, Batteries, Wellsites and Satellites.
Environmental Planning and Administration

2.0 Personnel Training
General Site Information
4.0 Site Information
- Wellsite and Flowlines
5.0 Surface Casing Vents

6.0 Pigging
7.0 Pumpjacks
8.0 Valves and Wellheads
9.0 Flowlines
10.0 Well Blow-Downs
- Processing
11.0 Separators and Treaters

12.0 Dehydration Units
13.0 Sulphur Recovery
14.0 Cathodic Protection
- Product Storage and Loading
15.0 Tank Operations

16.0 Distribution Lines
17.0 Product Storage
18.0 Chemical and Hazardous Material Storage and Handling
19.0 Vapour Recovery Units
20.0 Transportation
- General Environmental Concerns
21.0 Access Roads

22.0 Access Control
23.0 Perimeter Berms
25.0 Housekeeping
26.0 Flare Pits
27.0 Flare Stacks
28.0 Release of Produced Water

29.0 Release of Hydrocarbons

30.0 Site Maintenance
31.0 Noise
32.0 Drainage and Erosion
33.0 Surface Water Monitoring
34.0 Soil Sampling and Monitoring
35.0 Groundwater Monitoring
36.0 Water Release
37.0 Gaseous Emissions
38.0 Air Quality Monitoring
39.0 Release/Spill Prevention

40.0 Spill/Release Contingency Plans
41.0 Emergency Response
Waste Management
42.0 Waste Management Plan

43.0 Disposal of General Solid Wastes
44.0 Asbestos
46.0 Sewage Lagoons
47.0 Recycling
48.0 Water Recycling and Reuse
49.0 Disposal of Oil Based Wastes
50.0 Disposal of Gas Processing Wastes
51.0 Filters
52.0 Disposal Wells
53.0 Sulphur Handling
54.0 Reclamation Plan

55.0 Site Dismantling
56.0 Closure of Flare Pits
57.0 Tanks Removal
58.0 Well Abandonment
59.0 Decontamination
60.0 Soil Reclamation
61.0 Recontouring
62.0 Revegetation
63.0 Reclamation Assessment

PRODUCTION
ENVIRONMENTAL PLANNING AND ADMINISTRATION
PROD 1.0 Regulatory Environmental Authorization
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained for the planning,
design, construction and operation of any oil and gas production facility. Special
conditions and restrictions shall be reviewed and enforced.
Audit Guideline:
regulatory authorizations were obtained for oil and gas production facilities and
make sure that all information in writing is available on site. Record permit/license
numbers and verify this information is in the field.

permits/licenses (e.g., facilities where sour gas is processed, monitoring reports to
regulatory agencies, stack exit temperatures for acid gas incinerators, etc.). Inspect
the facility to verify these requirements were fulfilled during the design and
construction stage of the facility. Verify that these requirements are enforced during
the operations.
• Verify through interviews that facility operators are aware of any restrictions and
environmental concerns for the operation of the facility. This is particularly
important for sour gas facilities.

PRODUCTION
PROD 2.0 Personnel Training
Audit Protocol:
All facilities operating personnel shall be trained and aware of the environmental
impacts of their operations. They should understand the necessity for environmental
planning and protection measures.
Audit Guideline:
• Verify that all personnel have taken environmental training in their field of
operations and are clear on how to implement and use their training correctly. This
should include, but not be limited to, emergency response/spill containment
training, waste management, current regulatory requirements and best operating
procedures.
• Verify if there is a system in place for all personnel to update their training yearly as
required.
• Inspect the facility technical reference library to identify that environmental training
manuals and reference programs are available.
• Verify through consultation with senior personnel that funds are made available
annually for environmental training.

PRODUCTION
PROD 3.0 Environmental Concerns
Audit Protocol:
The engineering design and site planning of any production facilities shall be
undertaken in a manner that will anticipate potential environmental problems and
provide the design and operating procedures to minimize the impacts of the operations
on the environment.
Audit Guideline:
facility site. For example:
a) The site should be selected so spills can be easily contained and cleanup
vehicles can have ready access. This guideline also applies for staging
areas, camps, fuel dumps and storage areas. The site selection process
should also minimize impact to natural runoff patterns and should prevent
soil erosion and surface water contamination.
b) A site should be selected with minimum impact on crops, vegetation and

forests. Land utilized as, special environmentally protected areas, state
parks and National reserves should be avoided.
c) Unnecessary removal of trees or alteration of other natural features should

be avoided.
d) Access roads should be located along a route which results in minimum

impact to the environment.
e) Present and future land use restrictions (i.e., airports, proximity to dwellings,
etc.) should be considered prior to making a final site decision.
f) Possible environmental effects on marshes, river beds, fractured formations,

springs, etc. should be considered.
g) Well sites should be constructed with a minimum of 100m of undisturbed

vegetation left intact between the lease site and any watercourse or fish
bearing water body.
h) Well sites should be located so there is minimum harassment of wildlife and

far enough from a water body to prevent deleterious materials, such as salt

water, spilled oil and grease, from affecting habitat vegetation and water
quality.
I) Batteries and gas well installation configurations should be planned to utilize

the smallest surface area consistent with safe and prudent operations.

PRODUCTION
GENERAL SITE INFORMATION
PROD 4.0 Site Information
Audit Protocol:
At the start of the audit all general information on site list shall be verified. Site
information should correspond to all engineering and design drawings and plans. All
modifications or amendments to any facility or production operations should be found
in all drawings and plans showing the date of change. All modifications associated
with environmental protection should be recorded.
Audit Guideline:
• Verify that identification signs and safety signs are posted.
• Verify type of site (i.e., disposal, oil, gas, injection, water, etc.).
• Verify site status (i.e., shut in, producing, suspended, abandoned, in use, drilled
and abandoned, etc.).
• Record all equipment and its condition on site (i.e., pumpjacks, pits, tanks, dikes,
berms, sheds, etc.).
• Record biophysical aspects of site including adjacent topography , adjacent land

use, vegetation adjacent to site and vegetation on site.
• Record soil quality, erosion controls, condition of top soil stockpiled and adjacent
wild life habitats and species.
• Verify the nearness of surface water bodies and water wells to facilities.
• Verify the distance and directions to nearest occupied dwellings.
• Record special environmental or ecological areas of concern.
• Undertake a general inspection of the site to verify engineering and design plans
are current. Record any changes in the facility which do not correspond to existing
plans or drawings.

PRODUCTION
Wellsite and Flowlines
PROD 5.0 Surface Casing Vents
Utilization of surface casing is a standard practice to protect ground water from oil and
gas production. Surface casing should be vented to monitor for leaking production
casing and prevent dangerous gas pressure buildup.
Audit Protocol:
Operation and maintenance of surface casing vents at wells shall be performed

properly.
Audit Guideline:
• Inspect surface casing vents and verify that proper operating procedures are in
place. The vents should be opened at all times, unless a problem has been
identified or the well is in a special area. When a vent flow has been identified, the
pressure must be determined after the surface casing vent has been shut-in for 24
hours. Local regulations may require that the gas flow rate be measured annually.
• If the well is sour, verify that proper safety and environmental rules are followed
when working around open casing vents.
• Verify that surface casing vent flows are properly detected and there is a proper
procedure to limit the release of methane (CH4) and carbon dioxide (CO2) (sources
that contribute to greenhouse gases).

PRODUCTION
PROD 6.0 Pigging
Audit Protocol:
Pipelines shall be maintained to prevent spills or leaks. Pigging of pipelines assists

with maintaining pipeline integrity, however, pipe waste material as a result of pigging
operations must be handled and disposed of in an environmentally safe manner.
Audit Guideline:
• Verify that pipelines are pigged regularly to ensure a pipeline does not become
plugged with solids. Inspect records which indicate type and schedule for pipeline
maintenance.
• Verify that pipelines are designed and constructed to allow for different types of
pigging operations.
• Inspect pigging stations where pigs are released or captured within a pipeline
system. Verify that waste containment is undertaken to trap and store waste
material. Verify these areas are properly labelled and the waste properly disposed
of.

PRODUCTION
PROD 7.0 Pumpjacks
Audit Protocol:
Release of hydrocarbons resulting from stuffing box failures on pumpjacks shall be

contained immediately (onsite or offsite).
Audit Guideline:
• Inspect pumpjacks. Check for signs of spills around the well head. New soil
around the wellhead may cover up old spills.
• Inspect the land adjacent to pumpjacks to identify areas of contamination as a

result of stuffing box failures. Oil spray may impact on adjacent land.
• Identify if a mechanical automotive system shut down system exists at the wellhead
which shuts the well down if there has been an oil or gas release (low or high
pressure shut off switches).
• Verify that spill containment equipment is available and that operators are familiar
with the Spill Contingency Plan and Emergency Response Plans. (See Spill
Prevention and Emergency Response section).

PRODUCTION
PROD 8.0 Valves and Wellheads (including Injection Wells)
Audit Protocol:
Valves shall be maintained in order to prevent spills. The operation and maintenance
of wellheads shall be carried out so that impact to the environment is minimized.
Audit Guideline:
• Verify that Inspection of all valves are regularly undertaken. Verify that valves are
secured on shut in or suspended wells and monitored regularly for leaks.
• Inspect wellheads for signs of leaks. If there are any leaks, record the type (i.e., oil,
gas, chemical, water, etc).
• Determine if there is a standard procedure in place to detect any releases from an

injection well system.
• Inspect injection well locations. Pressure of disposal must be monitored. Look for
signs of spills.
• Inspect location of injection lines for deep well disposal. They should be located
downstream (flow of the aquifer) of ponds, lakes, crops and dwellings. Produced
water injection wells are susceptible to corrosion, therefore leaks along the pipeline
right-of-way are always a possibility and must be monitored. Record method of
detecting leaks in pipelines.
• If supplemental water is being used in the injection system, verify that the water
source well(s) are inspected and that the producing zone is not potable and that the
producing zone is not in communication with a potable water zone.

PRODUCTION
PROD 9.0 Flowlines Lines
Audit Protocol:
All production lines shall be maintained properly to reduce the potential of pipeline
failure and resulting pollution to the environment.
Audit Guideline:
• Ensure all lines are marked and maintained and that records are checked before
any excavations are started. Spill containment equipment should be on hand
before any excavations begin.
• Check for saltwater or oil spill along right-of-way, erosion control, slash disposal
and vegetation control.
• Verify that procedures exist which ensure the proper marking and protection of
buried or surface pipelines such as site security and anti-corrosion programs.
• Verify that trained personnel and spill containment equipment is available should a
pipeline break occur.
• Verify that the engineering design and operations of a pipeline utilizes emergency
valve shut-off and leak detection programs and procedures.
• Inspect portions of the production line systems for such items as placement of shut-
off valves, marked facilities, erosion control, vegetation management and spill
cleanup.

PRODUCTION
PROD 10.0 Well Blow-Downs
Audit Protocol:
Well blow-down procedures shall be carried out so that impact to the environment is
minimized.
Audit Guideline:
• Verify that when well production casing is purged of fluids, sediments or waxes
proper waste containment procedures are followed. Local regulations may not
allow earthen structure used for storage of produced fluids. Tanks or other
containment must be used to contain the fluids. Some regulations may allow the
use of centralized blow-down pits provided they are equipped with an impervious
liner, leak detection and groundwater monitoring.
• Inspect wellsites in which wells have been purged. Identify the containment
procedures and verify if waste control was both undertaken and effective.
Document any spills.
• Verify through inspection that engineering designs take into consideration valve
controls at the wellhead to prevent pressure failure during these procedures and
shut-off systems are in place should storage facilities be unable to store related
waste volumes.
• Inspect flare knock-out tanks. They must be adequately sized and emergency
measures must be in place to shut a well down (e.g., high level shut down alarms).

PRODUCTION
Processing
PROD 11.0 Separators and Treaters
Audit Protocol:
Pressure vessels shall be designed, operated and maintained such that impact to the
environment is minimized.
Audit Guideline:
• Determine maintenance/pumping schedules. Verify by inspection that separators

and treaters are maintained.
• During the inspection, check for signs of spills. If there are any spills, record type
and location. Pressure relief valves, rupture disks or burst plates that are installed
on a separator, treater or other pressure vessel which receives production from a
well, must be connected by suitable piping to an open tank. They must also be
connected to the flare stack to ensure complete oxidation of all gaseous
substances prior to their discharge to the atmosphere. Other methods to prevent oil
spills are acceptable if they provide equivalent or better protection than the venting
of relief devices to an open tank.
• Verify that building drains are not to ground and all drains go to tanks for
appropriate disposal. Verify the methods of monitoring these tanks for failure.
• Verify that wastes are properly transported and disposed of.
• Inspect all underground tanks to determine if tank integrity or facility operations

have resulted in spills.

PRODUCTION
Processing
PROD 12.0 Dehydration Units
Audit Protocol:
Dehydration units in gas plants, well sites and batteries shall be used and maintained
so that impact to the environment is minimized.
Audit Guideline:
• Determine maintenance schedule. Verify by inspection that dehydration units are

maintained.
• During the inspection, check for signs of improper gas leakage or spills. If there are
any spills, record type and location. Exhaust gases from dehydration units must be
vented out of the building. If a flare is in use at the site, then the exhaust gas
should be piped into the flare system. Water vapours off the reboiler should be
collected in a tank and disposed of properly.
• Check that generation of greenhouse gases is minimized. In order to limit

greenhouse gases, the instrument gases must be burned in the reboiler rather than
exhausting to the environment.

PRODUCTION
Processing
PROD 13.0 Sulphur Recovery
Audit Protocol:
Sulphur recovery operations, storage and transportation shall be performed properly to

limit impacts to the environment.
Audit Guideline:
• Prior to the field inspection, review plant licenses for emission rates. Determine if
rates are exceeded.
• Review recorded stack exhaust temperatures to verify if they are sufficient.
• Verify that the required number of stack surveys are completed each year.
• Verify if any soil/air monitoring is completed (see Soil Monitoring and Air Quality
Monitoring).
• Verify that sulphur is transported safely and dust control measures are in place.
• Inspect sulphur storage areas. Verify that proper storage procedures are followed
and identify if sulphur depositions are impacting on adjacent water quality or
vegetation.

PRODUCTION
Processing
PROD 14.0 Cathodic Protection
Audit Protocol:
Cathodic protection is a common engineering procedure used in facilities with

underground steel structures to protect them from external corrosion.
Audit Guideline:
• If company policy is to utilize cathodic protection, verify that all underground

facilities are provided with cathodic protection.
• Verify that appropriate cathodic protection methods have been implemented.

Cathodic protection can be applied by two methods: sacrificial or impressed current
methods. Sacrificial anodes are most commonly used on small steel structures
such as tanks; however, the method has also been used on short pipelines.
Impressed current cathodic protection is typically used on pipelines which cover a
large distance.
• Inspect various facilities to identify the cathodic protection.

PRODUCTION
Product Storage and Loading
PROD 15.0 Tank Operations
Audit Protocol:
The operation of aboveground and underground tanks shall be carried out in a manner
which does not cause damage to the environment. Tank operations include all work
which is done in conjunction with tanks. Examples are gauging, disposing of tank
bottoms, loading and unloading of tanks and emergency containment.
Audit Guideline:
• Inspect aboveground tanks onsite. Tanks must be placed on an impervious

compacted clay or synthetic liner and surrounded by a dike which is overlain by the
impervious liner material to prevent ground water contamination due to spills.
Tanks must be painted with a protective coating to prevent corrosion or rusting.
• Inspect dikes: they must meet the following criteria:
a) Except in special areas, the volume contained by the dike must contain a
volume 10% greater than the tank if there is only one tank. If there is more
than one tank, the dyke must contain 100% of the largest tank plus 10% of
the aggregate volume of all tanks. Special areas may require a greater
secondary containment volume and are site specific.
b) Tank berms must be constructed of earthen, concrete or synthetic material.

If any produced liquids enter the berm, they must be collected and disposed
of in an acceptable manner .
• Verify that periodic inspections of tanks are conducted. In order to determine if a

tank is leaking, regular inspections of the tank and liner are undertaken. Any spills
or leaks must be cleaned up. Abnormalities must be documented.
• Verify that underground storage tanks are constructed properly. Underground

tanks do not require secondary containment if the site exhibits low permeable soil
and a seasonally high groundwater table that is not within 1m of the bottom of the
tank. Secondary containment for underground storage tanks include:
a) Double wall tanks where the void space may be monitored.
b) An impervious synthetic liner that is compatible with the product being

stored.

c) Tanks contained in reinforced concrete or steel vaults.
d) Any other system that provides the same level of protection as those listed
above.
• Verify that a leak detection system is used for underground storage tanks. Inspect
this system. This can include:
a) A synthetic liner with a monitoring well.
b) Annual interstitial monitoring of double walled tanks.
c) Annual visual detection of vaulted tanks.
d) Monthly monitoring of weeping tile systems if the soil is of low permeability.
• Verify through interviews that there is a proper reporting and documentation

process in case of leaking from underground storage tanks. Operators should
incorporate measures to prevent the overfilling of tanks. This may include
automatic shut-off devices, alarms or visual indicators. Inspect any logbooks or
incident reports.
• Indicate if there is a special testing program for tanks. Suitable testing of

aboveground storage tanks includes 100% external inspection, internal inspection,
hydrostatic leak tests, soil vapour and ground water monitoring or another method
that provides the same level of confidence. Suitable testing of underground storage
tanks includes internal inspection, hydrostatic leak tests, pneumatic leak tests, soil
vapour and groundwater monitoring, or another method that provides the same level
of confidence.

PRODUCTION
PROD 16.0 Distribution Lines
Audit Protocol:
Tanks and distribution lines shall be located such that they cannot be easily damaged
by moving equipment. Design techniques must be employed to prevent pressure
eruptions and reduce fire hazards.
Audit Guideline:
• See flowlines.

PRODUCTION
PROD 17.0 Product Storage
Audit Protocol:
Oil and gas products shall be stored and labelled properly. All storage and loading
facilities and operations shall have equipment and procedures in place to prevent
spillage or reduce impacts to the environment as a result of a spill.
Audit Guideline:
• Verify the engineering designs and operating procedures, provide tank storage
integrity and that all loading facilities are designed to prevent or reduce accidental
discharge.
• Verify that all storage areas have proper spill containment and spill recovery
systems such as berms, spill drains, spill recovery collection tanks and oil recovery
technology.
• Inspect the storage and loading area for good housekeeping and spill cleanup.
Identify and inspect all central and collection systems. Determine the effectiveness
of such systems.

PRODUCTION
PROD 18.0 Chemical and Hazardous Material Storage and Handling.
Audit Protocol:
The handling, storage and use of chemicals in production operations shall be done
such that impact to the environment is minimized. These chemicals include treatment
chemicals (demulsifiers, friction reducers, surfactants and pad breakers) and corrosion
control chemicals (corrosion inhibitors, biocides, oxygen scavengers and scale
inhibitors). Hazardous materials shall also be handled properly. Chemical and
hazardous materials shall be stored and labelled properly.
Audit Guideline:
• Record chemical type and volume for each storage location. Verify that chemicals
are segregated appropriately.
• Verify methods for injection of treatment chemicals into the line at wellhead
operations and pipeline facilities. When this method is continued on a permanent
basis, it should be achieved by direct injection into the system from bulk tank (e.g.,
45 gallon drum). This method also applies to odorizing chemicals injected into
product pipelines at compressor stations.
• Inspect storage areas. Verify that all chemicals and hazardous materials are stored
safely and labelled properly. To store the chemicals, the following
recommendations are suggested:
a) Bulk tanks should be used for storage whenever treatment/corrosion

chemicals are routinely added to process lines, regardless of volumes
consumed.
b) All tanks should be fitted with an external gauge to monitor content level.
The tank must be externally vented if located in a building.
c) All metal storage/bulk tanks and/or frames should be electrically grounded.
d) Tanks larger than 50 gallons should be diked or an equally effective means

identified to prevent excessive contaminations to the surrounding area in the
event of a major spill or tank fracture.
e) Bulk/storage tanks should be clearly labelled to identify contents.
f) When wall mounted drums (45 gallon) are used as bulk tanks, the refilling
process should be carried out using a barrel transfer pump. The barrel pump

construction should be suitable for use with the specific chemical. Barrel
pumps and both containers involved in the transfer should be grounded.
• Inspect chemical metering pumps. These pumps are essential to control chemical
usage. The following recommendations are suggested:
a) Chemical metering pumps should be clearly labelled by chemical name.
b) All chemical lines should be colour coded and/or labelled at both ends.
c) Chemical metering equipment should be located in a well-ventilated area,

preferably serviced by mechanical ventilation.
• Verify chemical handling methods. Manual handling of chemicals must be actively

discouraged. The transportation of chemicals or empty chemical containers inside
must be avoided. Open top trucks or the equivalent should be used when
transporting chemicals. If a non-routine manual chemical treatment is required,
then the workers are required to:
a) Wear full personal protective equipment specific to the particular chemical

being handled. Suitable respiratory protective equipment should be readily
available and used when toxic or volatile chemicals have been identified in a
product.
b) Use pails with tight fitting lids.
c) Chemical drums or pails must be secured and sealed to prevent spillage

during vehicle transport.
• Verify use of Material Safety Data Sheets. Safety data sheets on each chemical
should be displayed where the chemicals are used. First aid kits should also be
available at all locations where chemicals are handled.

PRODUCTION
PROD 19.0 Vapour Recovery Units
Audit Protocol:
All hydrocarbon release points shall be piped into a vapour recovery unit.
Audit Guideline:
• Verify from engineering drawings the utilization and placement of vapour recovery
units.
• Inspect to determine if the that vapour recovery unit is operating properly.
• Verify through inspection and record reviews that vapours are incinerated.

PRODUCTION
PROD 20.0 Transportation
Audit Protocol:
Trucks, tanks and trailers shall be properly maintained. Operators should have proper
training in transportation safety and emergency response to accidental spillage.
Audit Guideline:
• Verify that policy and procedure are in place related to environmental protection.
Review procedures associated with the proper loading and transportation of oil and
gas products. Determine if all drivers are trained in emergency response
procedures.
• Through interviews, determine driver training effectiveness including training in

transportation of dangerous goods.
• Verify and review vehicle and tank trailer service logs to identify schedules and
procedures undertaken to maintain equipment integrity, therefore further reducing
the potential for spills due to equipment failure.
• Verify that noise control policy is in place and all trucks undertake noise control
monitor.
• Verify that facility personnel are in continuos attendance when trucks are loading.
Determine if there is an appropriate drainage system in case of a spill.

PRODUCTION
General Environmental Concerns
PROD 21.0 Access Roads
Audit Protocol:

and maintained in a manner that prevents erosion, drainage problems and additional
disturbance to the environment.
Audit Guideline:
• Verify that construction guidelines are in place and guidelines pertain to protection
of the environment. Verify that any road maintenance programs do not utilize
harmful chemical negotiation management programs.
• Inspect general conditions of roads. The road surface should be compatible with
heavy loads. Sides of roads should be revegetated and the growth should be
controlled in order to maintain good visibility. Signs should be used to control
speed. Dust should be controlled.
• Inspect roads to detect any drainage problems. All access roads should be
maintained to allow proper drainage and to prevent erosion. Culverts should be
built as needed and maintained. All signs of erosion should be noted and the
cause repaired immediately.
• Inspect access roads near highly sensitive areas. Fences and signs should be

PRODUCTION
PROD 22.0 Access Control
Audit Protocol:

Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates. Verify that access
control is in place for environmentally sensitive areas.
required.

PRODUCTION
PROD 23.0 Perimeter Berms
Audit Protocol:
Berms shall be used to contain surface runoff from oil wells, tank storage and
production facilities in order to minimize/eliminate a pollution release from going off-
site to contaminate the adjacent environment.
Audit Guideline:
• Verify use of berms. Berms should be constructed from an impermeable material.

They should be of a design and size to contain a spill of a size which might occur
before personnel are aware of the release and can respond.
• Verify that berm containment system has a surface water collection disposal
process. Verify that such a system is monitored to allow for water runoff but is
operated in a closed capacity to hold containments
• Verify that berms are inspected and maintained. There should not be any breaches
in the berms. If a release has occurred, the berms should be cleaned and repaired
as needed.
• Inspect berm areas. Identify proper berm design and placement, any berm failure
or breaches, or any permeable material which allows seepage.

PRODUCTION
PROD 24.0 Stream Crossings
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction or
placement of a bridge or culvert for continual crossing use. Measures shall be taken to
reduce the impact of production operation activities on water quality.
Audit Guideline:
• Verify if government regulations require special stream crossing conditions

including seasonal restrictions to the construction of an access road and use of this
road.
• Verify that the protection of streams due to sedimentation contamination has been
taken into consideration in the plans, designs and construction of an access road.
Inspect bridge crossings for signs of pollution and sediment problems.
• Inspect open stream crossing to verify that the number of vehicular movements
across a stream is kept to a minimum. Existing bridges should be used whenever
they are available.

PRODUCTION
PROD 25.0 Housekeeping
Audit Protocol:
All sites shall be maintained properly and kept neat, clean and safe. Housekeeping
refers to the general maintenance of a site with respect to acceptable operating
practices, upkeep maintenance and overall orderliness of the grounds, buildings and
equipment.
Audit Guideline:
• Inspect site to verify that site is kept neat, tidy and free from litter. Trash should be
continuously collected and disposed of at an approved facility. (See Waste
Management section).
• Verify that all chemicals are properly labelled, stored, handled and disposed of.
(See Product Storage and Loading section)
• Verify that waste disposal is carried out such that it does not attract wildlife.
• Verify that clearly legible signs are posted as needed and maintained. Fences and
gates should be constructed as needed and maintained.
• Verify that vegetation control is being used appropriately on site in order to

minimize fire hazards and to provide easy access for maintenance. Mechanical
methods of vegetation control are usually preferred but chemical methods can be
used in some circumstances. Chemical methods are not recommended where
there is a high water table, near lakes, streams or rivers, on sites adjacent to
farmland, etc.
• Verify that all equipment is kept neat and stacked orderly.
• Verify that lighting is sufficient for operating procedures.

PRODUCTION
PROD 26.0 Flare Pits
Audit Protocol:
Regulations may restrict the storage of produced fluids or other foreign materials in an
earthen pit. Produced fluids, garbage or other foreign materials entering the flare pit
shall be removed immediately.
Audit Guideline:
• Inspect flare pits to make sure that no produced fluids, trash or other foreign
materials have entered the flare pit. If produced fluids are present, they must be
removed immediately.
• Inspect the equipment on site to ensure that there is no possibility for produced
fluids to enter the pit.
• Inspect the land adjacent to the flare pit to identify areas of contamination as a
result of pit overflow or excessive flaring.
• Inspect the walls of the pit and adjacent land for vegetation control (particularly use
of soil sterilants).
• Inspect the security of the pit to prevent people, livestock or wildlife from entering
the pit area.

PRODUCTION
PROD 27.0 Flare Stacks
Audit Protocol:
The operation of flare stacks shall be done to minimize impact to the environment.
Audit Guideline:
• Inspect the location of flare stacks. They should be located away from trees, but
downwind of buildings and oil storage tanks. Verify that special restrictions in
forested areas are followed.
• Inspect stacks and adjacent land to see if liquids have sprayed off the stack.
Inspect flare stack operations. The separated liquids should not be discharged to a
flare stack and burned. Free liquids can escape up the flare stack to pollute the
land.
• Verify and inspect associated liquid removal vessels within the flare stack system.
Determine if an overflow shut down system is in place and if this system is working.
• Verify if fluid removal is undertaken on a regular basis.

PRODUCTION
PROD 28.0 Release of Produced Water
Audit Protocol:
Anytime an uncontrolled release of produced water is made to the terrestrial

environment, proper measures shall be taken for containment and initial clean-up. The
definition of a release includes spilling, discharging, disposing, injecting, abandoning,
depositing, leaking, seeping, pouring, emptying, placing and exhausting.
Audit Guideline:
• Verify that there is a Spill Contingency Plan and Emergency Response Plan that
clearly outline measures to be taken during a release of produced water. (See Spill
Prevention and Emergency Response section). A produced water release should
be responded to in the following manner:
a) Identify and control the source of the release; make repairs when safe to do
so.
b) Notify supervisor and any parties at risk due to the release.
c) Contain the released produced water using absorbent material or soil berms
or trenches as necessary.
d) Notify regulatory agencies as required.
e) Recover all free produced water using pumps or vacuum trucks.
f) The area of the spill should be flushed with a calcium amendment prior to
the application of any fresh water, recovering the excess fluid.
g) Begin spill site decontamination.
• Inspect sites for signs of release of produced water.
• Verify that any produced water spills have been properly decontaminated.

PRODUCTION
PROD 29.0 Release of Hydrocarbons
Audit Protocol:
Anytime an uncontrolled release of crude or refined hydrocarbons is made to the

environment (marine or terrestrial), proper measures shall be taken for containment
and initial clean-up. The definition of a release includes spilling, discharging,
disposing, injecting, abandoning, depositing, leaking, seeping, pouring, emptying,
placing and exhausting.
Audit Guideline:
clearly outline measures to be taken during a release of hydrocarbons. (see Spill
Prevention and Emergency Response section). A hydrocarbon release should be
responded to in the following manner:
so.
c) Contain the released hydrocarbons using booms, absorbent material or soil

berms or trenches as necessary.
e) Recover all free hydrocarbons with pumps or vacuum trucks.
f) Using water and surfactant, flush contaminated soil in order to free and
recover additional hydrocarbons.
• Verify that any release of hydrocarbons has been properly decontaminated.

PRODUCTION
PROD 30.0 Site Maintenance
Audit Protocol:
Facilities shall be properly maintained. Equipment should be inspected regularly to

maintain the presence of accidental gas or liquid discharges to the environment.
Audit Guideline:
• Verify the procedures undertaken by operators to ensure all equipment is in proper

working order. Check for leaks. If any leaks are observed, record type and
location.
• Verify that operations and maintenance personnel have guidelines to the proper
storage and disposal of waste materials as a result of site maintenance.
• Inspect a maintenance operation to verify that pollution control and worksite

cleanup is undertaken.
• Verify and inspect that hazardous materials utilized during maintenance operations
are properly handled and that hazardous waste material is properly recorded, stored
and disposed of (see Waste Management section).
• Verify that surface and underground storage tanks are monitored for leaks or
overflows (see Product Storage and Loading section).
• Review operator work schedules to identify ongoing maintenance programs.
• Inspect general site conditions.
• Verify that fences are in good conditions and gates are locked.

PRODUCTION
PROD 31.0 Noise
Audit Protocol:
The impact of production operations’ noise on local residents and workers shall be
minimized.
Audit Guideline:
• If houses are adjacent to the facility, verify that discussions regarding the potential
impacts of noise were held with nearby residents during the design phase of the
facility. Verify that adjustments were made to meet the concerns and needs of the
residents. Adequate public notification and discussion can prevent noise
complaints before the operation starts. An ambient sound survey to measure
existing sound levels may be needed to assist the design.
• Make note of any public complaints (if any), response provided, and, if the noise
level is higher than acceptable limits, verify that measures have been taken to meet
or better the acceptable limits. If complaints have been received, verify that noise
monitoring of the wellsite is being done.
• Inspect wellsite to ensure that facilities are designed to ensure appropriate noise
levels.

PRODUCTION
PROD 32.0 Drainage and Erosion
Audit Protocol:
The facility shall have proper drainage systems. Changes in natural conditions should
be minimized to prevent altering natural drainage patterns. Any normal interference
with the normal drainage of water from land, where such interference has been caused
by the operation, shall be removed or remedied as soon as possible.
Audit Guideline:
• Inspect site for internal drainage control to contain potential pollutants on the site.
• Confirm that protection is provided to prevent the collection of runoff from

• Inspect any contaminated areas and verify that surface drainage in those areas is
segregated from other areas of surface runoff. The contained fluids should be
stored for treatment and/or evaporation.
• Inspect bermed storage areas. Drainage from those areas should be contained to
prevent leakage of a spilled product from entering into the drainage discharge.
• Verify that all proper erosion control measures are being used.
inundation of vegetation.
• Culverts and drainage ditches must be constructed as needed around the plant site
to prevent contamination of surface waters and groundwater.

PRODUCTION
PROD 33.0 Surface Water Monitoring
Audit Protocol:
Surface water shall be monitored after spills, after controlled acceptable releases and
as required to monitor water quality near operating sites. Existing local regulations
should be followed. A certified laboratory shall perform the analysis.
Audit Guideline:
surface water monitoring have been identified and provided as guidelines for
implementation in the facility.
• Prior to the field inspection, review records including surface water monitoring
reports and verify compliance.
• Indicate if the facility has a surface water sampling monitoring program. Surface
water sampling and monitoring are site specific.
• Verify that proper sampling protocols are followed.
• Inspect surface water control and release structures. Identify if these structures are
shut to prevent accidental release runoff water.

PRODUCTION
PROD 34.0 Soil Sampling and Monitoring
Audit Protocol:
Soil sampling and monitoring require proper sampling protocols and a certified
laboratory to perform the analysis. Record keeping is essential, particularly of
sampling locations (to ensure the same locations are sampled during a monitoring
program).
Audit Guideline:
soil sampling and monitoring have been identified and provided as guidelines for
• Prior to the field inspection, review records including soil sampling and monitoring
• Indicate if the facility has a soil sampling monitoring program. Soil sampling and
monitoring are site specific activities in order to assess soil quality. These activities
may be completed to track the progress of a decontamination program, to
determine the extent of a spill and develop remediation programs. Soil monitoring
may be undertaken at any time of a facility’s life, from pre-disturbance, during
operations or during reclamation.

PRODUCTION
PROD 35.0 Groundwater Monitoring
Audit Protocol:
Site where contamination is known to impact the groundwater shall have a

groundwater monitoring system.
Audit Guideline:
groundwater monitoring have been identified and provided as guidelines for
• Prior to the field inspection, review records including water quality reports and verify
compliance.
• Indicate if the facility has any groundwater monitoring systems. Inspect monitoring
well sites and locations. Groundwater monitoring is a site specific issue. Wells
should be installed hydraulically up gradient and down gradient of a potential
contaminant. These wells will be used to determine the depth and direction of
groundwater flow. Monitoring wells must be set in an area that will not interfere
with everyday operations, however, they must be set in order to collect the proper
information.
• Verify that monitoring wells are equipped with a lock in order to prevent
unauthorized entry.
• Verify that only trained personnel or consultants sample the monitoring wells.
Groundwater monitoring is site specific; however, for predisturbance assessments,
it is recommended that the following components be sampled: pH, electrical
conductivity, major ions, total metals and dissolved organic carbon.
• Verify that piezometers/observation wells are placed correctly and functioning

properly.
• Review any sample reports which have been completed.

PRODUCTION
PROD 36.0 Water Release
Audit Protocol:
The discharge of water to the environment shall be minimized. A water release may
occur by opening a berm drain, by overflowing a berm, or by pumping water to the
surrounding land.
Audit Guideline:
• Verify that any water released to the environment meets existing regulations. When
discharging water, a field analysis must be done. Field determination may be done
using an appropriate pH meter and Quan Tabs for the chloride determination. Any
visible hydrocarbon sheen requires that the fluid be disposed of via an appropriate
oil field waste disposal facility. The following criteria are recommended:
a) Water pH must be between 6.0 - 9.0.
b) Oil and grease cannot exceed 10 mg/L or no visible hydrocarbon sheen on

the water surface.
c) Chlorides must not exceed 500 mg/L.
d) No other chemical contamination.
If the discharged water does not meet the above criteria, the fluid must be disposed
of at an approved oil field waste disposal facility or treated and then discharged on
or off lease with the approval of existing regulatory agencies and the landowner
(private land) or public land manager (public lands).
• Verify that any water discharged is not allowed to flow directly into rivers, creeks or
any other permanent body of water.
• Verify that a proper documentation and reporting procedure exists for water
discharges to the environment. Records must include the parameters listed above
as well as an estimation of the volumes of water disposed.

PRODUCTION
PROD 37.0 Gaseous Emissions
Audit Protocol:
Gaseous emissions in oil production batteries or gas plants shall be controlled and
minimized.
Audit Guideline:
gaseous emissions have been identified and provided as guidelines for
• Prior to the field inspection, review records including air quality reports and verify
compliance.
• Determine if any measures are taken to minimize gaseous emissions occurring on-
site. The main air quality parameters of concern are SO2, H2S and NOx. Ozone,
carbon monoxide, carbon dioxide, hydrocarbons and ammonia are also a concern.
Ways to reduce gaseous emissions may include:
a) Increasing efficiency per unit of energy produced
b) Reducing sources of emission in all operations
c) Air quality monitoring, reporting and tracking systems (measured quantities

of emissions, reports, etc.)
• Verify if existing regulations require monitoring and specific reports. Check

compliance reports and verify emission rates are not exceeded. Monitoring and
reporting requirements may include:
a) Standard site criteria for monitoring

b) Documentation
c) Total sulphation calculations
d) Hydrogen sulphide calculations
e) Water soluble fluoride calculations
f) Dustfall calculations
g) Soil pH monitoring procedures
h) High volume sampling procedures
I) Vegetation fluoride analysis
j) Quality assurance procedures

k) Heavy metals analysis

l) Source emission survey report format

PRODUCTION
PROD 38.0 Air Quality Monitoring
Audit Protocol:
Air quality monitoring is required at some locations of the facility to comply with
existing regulations or when due to resident or landowner concerns. Long term
emissions can have an adverse impact on soil and water.
Audit Guideline:
• Prior to the field inspection, review records including air quality emission reports
and verify compliance.
• Verify that air quality monitoring systems are onsite as required (e.g. facilities
where sour gas is processed, etc.). Two types of air monitoring systems may be
undertaken: ambient monitoring and total sulphation/H2S.
• Inspect air quality monitoring equipment. Air quality sampling is done with many
different pieces of equipment including mobile trailers, stationary trailers and
“birdhouses”. Verify that sampling equipment is in working order and correctly
calibrated.
• Through interviews, verify that operators are familiar with the station so that if there
is an upset, they can fix/modify it and it is not down for an extended period of time.
Operators must be familiar with sampling procedures and sampling locations.
• At sour locations, verify that stack surveys are completed, if existing regulations
require them.
• Record any odour and determine source.

PRODUCTION
PROD 39.0 Release/Spill Prevention
Audit Protocol:
Proper measures shall be taken to prevent the occurrence of spills/releases.
Audit Guideline:
• Verify that spill/release prevention methods are used. The prevention of

spills/releases should be a high priority in all industry operations. Prevention can
be achieved by:
a) sound engineering practices;

b) corrosion control, monitoring and routinely scheduled inspections;
c) leak detection and automatic shut-down systems;
d) training programs for all training personnel;
e) modification of existing facilities to reduce the possibility of discharges; and,
f) development of contingency and shut-down plans and at least once yearly
drills.
and bases. (See section Product Storage and Loading section)
weather conditions. Check that “No Smoking” signs are posted and followed.
• Through interviews, verify that all personnel are familiar with fuel handling
procedures.
• Verify the utilization of API oil skimmer systems. Review engineering designs and
identify any modifications. Verify if water analysis is undertaken at water discharge
points.

• Inspect all API oil skimmer units to determine the effectiveness of oil recovery.
Review water analysis to assess the success of these systems. Record any spills
or evidence of hydrocarbons in the water discharge streams.

PRODUCTION
PROD 40.0 Spill/Release Contingency Plans
Audit Protocol:
Production operation facilities shall have a spill/release contingency plan. All

personnel shall be familiar with the contingency plan
Audit Guideline:
• Review records to verify the existence of an appropriate spill/release contingency

plan. Determine if contents of such plan are acceptable. The plan should contain
the following information:
a) A definition of the emergencies covered by the plan.

b) The procedures for handling and investigating leakage reports.
c) The procedure for alerting company personnel and affected outside parties.
d) A clear definition of the responsibilities of everyone involved.
e) Guidelines for reaction and control, including shut-down procedures, leak
locations, leak isolation, spillage/release containment, watercourse
protection, etc.
f) Methods for immediate corrective action including spill/release control
containment recovery, restoration and rehabilitation of the affected resource.
g) Guidelines for the protection of operating personnel and the general public.
h) Safe work procedures for pipeline repair.
I) Guidelines for post-repair inspection and returning the line to service.
j) Maps and descriptions of each subsection of the pipeline system.
k) Guidelines for public relations and the dissemination of information.
l) A telephone contacts summary.
contingency plan is available onsite. Determine locations, types and quantities of
spill control materials available onsite. These may include: sorbent materials, oil
retention booms, sand bags or temporary curbing devices, recovery pumps and
collection hoses, recovery tank trucks and protective equipment.
• Verify that release drills are held. Release drills should be held at least once a
year. All operating personnel should be required to attend. The sites chosen for
the drill should include topography which is representative of the conditions most
likely to be faced in the event of a release.

• Review any past incident reports. If there have been any releases in the past, a
review should be undertaken to review the causes of the release and to provide
recommendations as to how such a release can be avoided in the future. The
review should include an assessment of the contingency plan and the response as
well, assessing whether there should be any improvements made to the plan or the
training provided.

PRODUCTION
PROD 41.0 Emergency Response
Audit Protocol:
Production facilities shall have an Emergency Response Plan to protect the public,
employees, the environment and property should an emergency occur. It is necessary
to provide all employees with a systematic presentation of communication practices
and procedures to be followed in an emergency.
Audit Guideline:

A copy of such plan should be available on-site. Check that the appropriate
contact lists are near telephones.
• If the facility is located near residential areas, verify that discussions with local
residents were held when preparing the Emergency Response Plan.
• Interview personnel to verify the level of knowledge of such plan. All employees
should be familiar with the Emergency Response Plan for their work area. They
should also be familiar with the location of emergency equipment and have
participated in mock exercises, held at least once a year.
• Review appropriate level of Emergency Response Plan. An Emergency Response

Plan for producing wells, collection and processing facilities should contain the
following information:
a) Regulatory Information
b) Scope of the Emergency Plan
c) Local public involvement
d) Contents of the Emergency Procedure Plan:
- An introduction which clearly indicates which facilities are covered by

the plan, the size of the emergency planning zone and the potential
H2S release rates (if applicable).
- An emergency definition and action plan which identifies the different
stages or levels of alert and the action necessary.
- Detection and location of a release which describes the various
methods by which a release may be detected.
- Definition and isolation of a hazard area.
- Communication procedures between the release site, the company
control centre, government agencies and public representatives.

- Evacuation and notification procedures.

- Ignition procedures.
- Control procedures to take control or shut-in the release.
- Responsibilities of government agencies.
- Media relations to give personnel direction when dealing with the
news media.
- Post-emergency procedures.
- Procedures to update the plan on an annual basis.
- Emergency contact lists.
- A plan showing emergency planning zones for all wells and the
collection piping system.
- Overall site plan.
Emergency Response Plan is available onsite.

PRODUCTION
WASTE MANAGEMENT
PROD 42.0 Waste Management Plan
Audit Protocol:
Production facilities shall have a Waste Management Plan to ensure each facility
knows what wastes it produces and how to handle and dispose of those wastes
properly.
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility. Review the plan
and see if the wastes the facility produces match the wastes discussed in the plan.
Review the waste disposal methods recommended in the plan and verify if they are
being followed. Review the training schedules for waste management; when
talking to the operators, determine how well the management plan is taught/how
familiar they are with the plan/how practical it is. Verify that a waste manifest
procedure is in place and is being used properly. Review trucking routes for waste
disposal.
• Inspect all waste handling containers and verify the waste has been sorted and
allocated to the correct container. Verify that the container is the correct type for
the waste.

PRODUCTION
WASTE MANAGEMENT
PROD 43.0 Disposal of General Solid Wastes
Audit Protocol:
All waste material shall be properly identified and handled according to hazardous and
nonhazardous waste handling regulatory requirements. General solid wastes
generated by operations shall be disposed of in an acceptable manner to prevent
pollution to the environment.
Audit Guideline:
dispose of all types of solid wastes generated.
• Verify that all sites and rights-of-way are kept free of trash and litter. All trash, litter
and garbage must be placed in metal or plastic containers and disposed of
properly.

material not totally consumed by burning. Verify that the types and volumes of
wastes incinerated and buried are recorded.
intrusions to the garbage disposal sites or attraction to the location. Verify that pits
are lined.
• Verify that fuel barrels or other containers are not left on the site or along the rights-
of-way.
• Verify that the incinerator(s) is inspected and tested at least yearly to ensure
optimum efficiency.

PRODUCTION
WASTE MANAGEMENT
PROD 44.0 Asbestos
Audit Protocol:
Measures shall be taken to minimize exposure to asbestos containing materials and

man-made vitreous fibres and to prevent any exposures above occupational exposure
limits.
Audit Guideline:
• Indicate if there is any specific code of practice for worksites where asbestos
containing materials and man-made vitreous fibres are present.
• Verify that standard work procedures are in place for working with asbestos
containing materials and man-made vitreous fibres. These measures may include
refraining from smoking, eating or drinking while working with insulation products,
showering, not taking clothes contaminated with fibrous insulation out of specific
areas, following special cleaning procedures for work clothes, wearing the required
safety clothing, posting appropriate signage and using appropriate handling
methods.
• Verify that asbestos containing materials are held in restricted zones or transported
immediately to its final disposal site.
• Inspect buildings and equipment to verify the presence of asbestos containing

materials.

PRODUCTION
WASTE MANAGEMENT
PROD 45.0 Sewage Effluent and Wastewater Treatment
Audit Protocol:
No effluent shall be discharged unless it satisfies existing local regulations.

Regulations limit the deposits of oil and grease, biochemical oxygen demand, fecal
coliforms, phenols, total suspended solids and the pH levels.
Audit Guideline:
implementation in the field.

tanks, leach pits, holding tanks, lagoons, packaged treatment plants, etc) utilized.
• If there are any subsurface disposal facilities (septic tanks, leach pits), inspect
distances from any sources of water supply and natural water bodies. Verify that
pump-out and hauling operations are carried out in a manner that does not expose
the driver or people in the area where the tanks are emptied to any health hazard.
Every effort should be taken to avoid any spillage when holding tanks are emptied
or when the truck contents are discharged into the treatment facility.
• Verify that the flow through the effluent treatment system is carefully controlled.
Oveloading the system hydraulically reduces the effectiveness of pollutant removal.
Also, a sudden shock will upset the biological balance and performance will drop.
The shock can be either an increase in pollutants or an influx of unusual pollutants.

PRODUCTION
WASTE MANAGEMENT
PROD 46.0 Sewage Lagoons
Audit Protocol:
If sewage lagoons are used, they shall be designed properly to ensure that effluents do
not contaminate ground or surface water or soil and do not present a health hazard.
Audit Guideline:
• Inspect sewage lagoons onsite used to treat sewage/effluent. The following criteria
are recommended:
a) Maximum flow will be dependent on the dimensions of the lagoon.
b) Retention time should be sufficient to allow for decomposition.
c) Sewage decomposition should be monitored.
d) Must have sufficient freeboard to prevent overflow in case of heavy rainfall.
e) Must be fenced.
f) Vegetation control on berms.
g) Surface runoff to be diverted around the lagoon.
h) Release limits according to existing regulations.
I) Berms must be minimum 1V:3H.
j) Berms must be sufficiently wide at top to allow for equipment and

personnel.
k) Bottom of lagoon must be level and flat.
l) A small pit in the bottom allows the large lagoon to be emptied.
m) Lagoon must be “relatively impervious” to control seepage (either

compacted clay or lined).
n) Setback distances: the lagoon must be at least:

- 300m from any residence or assembly occupancy outside the site or

not associated with the facility.
- 90m from a residence or assembly occupancy on the site.
- 30m from the property line.
- 30m from any residence.
- all measurements are taken from the outside berm where the side
slope of the berm intersects with the natural grade.
• Verify that lagoon is properly built, effluent is not released before full retention time
and there are no leaks.
• Inspect location of site for suitability of lagoon. Lagoons are recommended in

areas where there are heavy clay subsoils and/or where potable water supplies
make use of subsurface effluent disposal unreliable.

PRODUCTION
WASTE MANAGEMENT
PROD 47.0 Recycling
Audit Protocol:
Production facilities shall have an effective approach to waste management.

Recycling is a key component to conserving resources and reducing wastes.
Recycling assists by either reducing or eliminating the quantity of waste which requires
disposal, thereby reducing potential contamination to the environment. The Waste
Management Plan should contain recycling information.
Audit Guideline:
• Determine if there is a Waste Management Plan for the facility where recycling is
implemented.
• Determine the preferred method of recycling. Materials identified for recycling

should be properly stored and labelled.
• Inspect recycling operations and containers.

PRODUCTION
WASTE MANAGEMENT
PROD 48.0 Water Recycling and Reuse
Audit Protocol:
All water usage shall be assessed for the potential of recycling or reuse. Water usage
shall be minimized by employing the basic principles of water conservation through
reduction of the volume of water used, effective recycling, and maximizing reuse.
Emphasis should be placed on concentrating waste materials in limited volumes of
water.
Audit Guideline:
• Verify if there is an appropriate recycling and reuse system in place for waste
water. This system may include assessment of potential recycling and reuse
methods upon waste identification, determination of preferred methods of recycling
water and identification of alternatives. Waters identified for recycling should be
properly stored and clearly identified.
• Inspect storage areas.

PRODUCTION
WASTE MANAGEMENT
PROD 49.0 Disposal of Oil Based Wastes
Audit Protocol:
The disposal of oil based waste materials shall be done in an acceptable manner.
These materials include waste oil sludge, treater hay and oil spill debris.
Audit Guideline:
• Verify that waste oil sludge is disposed of properly. Oily waste may originate from:
a) Tank bottoms and treater sludge from conventional production.
b) Sand and waste oils from heavy oil production.
c) Pigging wax from line cleaning.
d) Solvents.
e) Lube oil.
Oily wastes may contaminate groundwater or could kill vegetation if disposed of

carelessly. Burial or dumping of any waste oil in an insecure pit or landfill is an
unacceptable practice.
• Inspect site for the provision of tanks at all facilities to ensure temporary storage for
waste oils until they can be properly and safely disposed. Disposal bins equipped
with steam tracing lines may be used to temporarily store pigging wax. The bin can
be transported to a reclaiming facility where it is steamed prior to dumping the
residue into a reclamation tank.
The preferred disposal options are:

a) Recycle : Whenever possible, waste oil should be recycled back into the
production system. Light wax, lube oil and treated slop oil can be pumped
into the crude oil pipeline in a controlled manner.
b) Waste Oil Reclaimers: Waste oil which cannot be recycled within the
operating company’s facilities should be sent to an approved waste
processing and disposal facility. Pigging wax and solvents that cannot be
recycled at company facilities must be sent to a reclaimer.
c) Land Treatment of Sludges: Land treatment is the controlled addition of oily
wastes into natural soil.
Acceptable disposal options (not a permanent solution but generally safe) are:
a) Application on Roads: tank bottoms, treater sludge and waste oil from heavy
oil operations may be applied to roads, subject to approval of appropriate
authorities.
b) Incineration: waste oils can be disposed of by incineration. However, poor
combustion may cause objectionable smoke or odours.

Unacceptable disposal methods include: application of waste oils on dikes,

application of wax solvents and lube oils on roads, disposal to landfills and open
burning.
• Verify that treater hay is disposed of properly. Treater hay results from conventional
treaters that use a filtering medium to enhance impurity removal. The filter material
is called treater hay.
The preferred options to dispose of treater hay are:

a) Approved Incineration: if the contaminated hay can be incinerated in an
acceptable manner, this method of disposal is the preferred method.
b) Industrial Landfill: waste treater hay can also be disposed of at an industrial
landfill site.
The following disposal methods are acceptable if the preferred options are not
available:
a) The hay may be disposed of into flare pits and burned in conjunction with
periodic flaring (subject to regulatory approval). If the hay is adequately
cleaned prior to burning, it may not create smoke problems when burning.
b) Transport in sealed containers to nearby reclaimers equipped with cleaning
facilities and incinerators.
• Verify that oil spill debris is disposed of properly. In the past, most spills were
controlled on site and burned as quickly as possible. However, due to the emission
of unsightly black smoke and the hazard of ash and carbon fallout, regulatory
bodies are often reluctant to give permission to burn unless there are no other
options. The hazards of forest and/or ground fires must also be considered prior to
burning. The heat generated by burning will destroy underground roots and soil
microbiology, making the re-establishment of vegetation much more difficult.
The preferred reclamation option is: After as much oil as possible has been picked
up, the preferred reclamation procedure is to help the residual oil to degrade by
natural microbial action. This can often be enhanced by using fertilizers and
agricultural practice. See Reclamation/Remediation.
• Inspect any on-site waste disposal activities.
• Inspect any off-site facilities providing waste disposal services.
PRODUCTION
WASTE MANAGEMENT

PROD 50.0 Disposal of Gas Processing Wastes
Audit Protocol:
The disposal of gas processing waste materials shall be done in an acceptable

manner. These materials include holding pond sludges, process filters, spent iron
sponge, boiler water/cooling tower blowdown, glycol, desiccants, catalysts,
degradation products from amine an sulfinol treating and waste sulphur.
Audit Guideline:
• Verify that wastes resulting from natural gas processing are disposed of properly.
The following methods are preferred:
a) Disposal of holding pond sludges: sludge composition must first be

determined by analysis before disposal options can be recommended.
There are essentially two acceptable disposal options: land application or
industrial landfilling.
b) Disposal of process filters: see Filters.
c) Disposal of spent iron sponge: it can be either regenerated with air to form
elemental sulphur or it can be removed and disposed.
d) Disposal of cooling tower blowdown: preferred disposal of chromate or zinc

system blowdown is to utilize deep well disposal into a formation whose
characteristics are compatible with the chromate waste water.
e) Disposal of glycols: although glycols are used in several ways in the

petroleum industry, they are not a major source of waste. Accidental
spillage, however, is an ever-present threat. Glycols should be segregated
from other wastes and reused. Glycols from spillage are usually disposed of
by washing to an on-site containment pit, together with other organic
compound spillages, followed by injection into a disposal well.
f) Disposal of desiccants: since molecular sieves are alkaline and often quite
clean from the regeneration process, they can safely be disposed in properly
constructed landfills at the plant site. Contaminated molecular sieves should
not be landfilled. They must be stored in drums or on the plant site. Since
the quantity is often not very large, this is not a problem for most plants.
g) Disposal of Catalysts: catalysts can be used in the manufacture of abrasives

such as sandpaper, however, this industry only uses a small percentage of
the spent catalyst available. Catalysts could possibly be used in light-weight
concrete products or road paving materials.

h) Disposal of degradation products from amine and sulfinol treating:

incineration or industrial landfill.
I) Disposal of waste sulphur: disposal by burial or cultivation on the land is

acceptable provided that steps are taken to neutralize the acids which are
produced by biologically induced conversion of the sulphur in the soil.
• Verify that there is an effective waste handling and disposal program.
• Verify that any waste contractors are properly certified.
• Inspect waste handling activities and disposal containers.

PRODUCTION
WASTE MANAGEMENT
PROD 51.0 Filters
Audit Protocol:
Filters shall be disposed of and changed in an acceptable manner. There are many
types of filters used in the petroleum industry. They include glycol filters, lube oil filters,
domestic water filters, amine and sulfinol filters, etc. Eventually these filters become
clogged and must be replaced. Since filter media will be saturated with the material
being filtered, care must be taken when disposing of them.
Audit Guideline:
• Verify that filters are disposed of properly:
Immediately after use, filters should be stored in a container equipped with screens
to permit fluids to drain. Filters should always be drained prior to disposal and the
entrained liquids can be disposed of at approved disposal wells (see section on
Injection and Disposal Wells). To properly drain a filter, it must be stored in the
screened container for a minimum of three days at room temperature. Entrained
fluids must be kept segregated for recycling or disposal. It must be determined
through sampling if the filter is a dangerous oilfield waste. Examples of filters that
may be a dangerous oilfield waste are: glycol filters, leachate and entrained liquids,
air pollution control filters, sulphinol filters, lub oil filters, methanol filters, gas filters
and produced or process water filters.
If a screened on-site container is not available for drainage, a barrel with a fitted
screen may be used. The filters should be enclosed in separate plastic bags,
sealed in a drum and buried at an industrial landfill site.
Unacceptable disposal options include: unsecured landfill sites, discarded into

open pits, burial and discarded on public areas.
• Inspect disposal activities and disposal containers. Review waste transfer or

transportation manifests.

PRODUCTION
WASTE MANAGEMENT
PROD 52.0 Disposal Wells
Audit Protocol:
The operation and maintenance of disposal wells shall be carried out so that impact to
the environment is minimized.
Audit Guideline:
• Determine if there is a standard procedure in place to detect any releases from the
disposal system.
• Inspect disposal well locations. Pressure of disposal must be monitored. Look for
signs of spills.
• Inspect location of disposal lines for deep well disposal. They should be located
water disposal wells are susceptible to corrosion, therefore leaks along the pipeline
• Verify that the disposal zone is at a depth not less than 600 metres.

PRODUCTION
WASTE MANAGEMENT
PROD 53.0 Sulphur Handling
Audit Protocol:
Proper handling, storage and transportation of sulphur is required.
Audit Guideline:
• Verify that appropriate precautions are taken when handling sulphur. Personnel
should take measures to alleviate or mitigate the following major issues:
a) Potential human hazards.
b) Sulphur dust producing sulphuric acid when it reacts with water.
c) Sulphur spills when pouring molten sulphur into tank cars for transportation
or onto sulphur blocks for storage.
d) Handling runoff and drainage from sulphur storage areas.
e) Reclamation of sulphur contaminated soils.

PRODUCTION
PROD 54.0 Reclamation Plan
Audit Protocol:
A Reclamation Plan shall be used for returning the land to its former land use
capability.
Audit Guideline:
The ARPEL document “Guidelines for Decommissioning and Surface Land

Reclamation at Petroleum Production and Refinery Facilities” can be used as a guide
in the conduct of audits for the Abandonment and Reclamation section.
• Verify that a Reclamation Plan exists.
The reclamation plan will take into account whether it is part of a live site which is
being reclaimed or whether the entire site is being abandoned. This can
significantly alter the procedures used.
The plan should identify all capital salvage items, outline the salvage program,
identify disposal options for items which cannot be reused, identify any
contamination issues and how they are to be dealt with and specify the steps for
the restoration of the site (or the portion being restored).
The plan is based on the Site Assessment (Phase I, Phase II if necessary). The
data from the assessment is then evaluated and the necessary procedures are
specified in order of priority. The plan should include a cost estimate, inventory
control, service contracts, equipment and material handling procedures,
environmental protection measures, safety measures, schedule and priorities and
cost control.
The plan lists the details for the following procedures:

- site dismantling
- closure of flare pits
- removal of tanks
- well abandonment
- decontamination
- soil remediation
- recontouring
- revegetation
- assessment of reclamation success

PRODUCTION
PROD 55.0 Site Dismantling
Audit Protocol:
The physical removal of all buildings, facilities, structures and improvements - above
and below ground - shall be done in an acceptable manner.
Audit Guideline:
• Inspect sites being decommissioned or reclaimed. Verify that all equipment and
structures are removed appropriately. Some items, including access roads, gates
or pads, may be left on site if the landowner and reclamation officer are in
agreement or if the landowner agrees and it does not interfere with the reclamation
of the site.
• Verify that all liquids and sludges from vessels/tanks/lines are removed for
disposal.
• Check for asbestos insulation. It is not possible to visually discern this, a lab test is
required. Asbestos containing materials must be removed by especially trained
crews and double bagged for disposal. See Asbestos
• Verify that after all liquid has been removed from the vessels, flowlines, and tanks,
and that all equipment from the site is removed. Ensure any residual fluids which
remain are collected for disposal.
• Verify that cement pads and other inert materials are broken up and are buried on
site with a minimum cover of 1 m of compacted fill or it can be hauled out. Power
lines, power poles, gas lines, telephone lines, and equipment require removal by a
utility company.
• Verify that gravel is salvaged as much as possible for use elsewhere. Gravel
should not be removed until all heavy traffic is finished in order to prevent
reclamation problems.
• Verify flowlines are cut-off and capped a minimum of 1m below grade.
• Verify that no contaminated material is buried or covered.
• Identify all improvements left in place and locations of buried material.

PRODUCTION
PROD 56.0 Closure of Flare Pits
Audit Protocol:
Flare pits shall be closed in an acceptable manner in order to ensure no harm is done
to the surrounding land and water.
Audit Guideline:
• If there are fluids in the pit, verify that a composite sample of the fluids is taken. All
precautions must be taken, particularly if the site is still in use. Verify that all
applicable safety procedures are followed.
• Verify that proper methods are used for treatment and disposal of contaminated
material.
• Verify that the soil in the pit was sampled and analyzed to determine if
contaminants are present. If analysis indicates contaminants are not present, then
the pit may be backfilled. If contaminants are present, then decontamination must
be completed. Verify that sampling of the flare pit was undertaken without fluids in
the pit.
• Inspect flare pits planned for closure. If feasible also inspect flare pits in which
closure activities are underway.

PRODUCTION
PROD 57.0 Tanks Removal
Audit Protocol:
When sites are being decommissioned or abandoned, the removal of underground and
aboveground storage tanks shall be done with minimum impact to the environment.
Audit Guideline:
• Verify that tanks are removed properly. The following procedure is recommended:
a) Above ground Storage Tanks:
All residual liquid must be removed from the tank. A bull plug must be placed in all
tanks openings.
b) Underground Storage Tanks:
All piping must be exposed and disconnected. All fluid must be removed from the
tank prior to the start of any excavation. Tanks should be purged or inerted prior to
the start of excavation. Purge means to remove the explosive vapours and inert
means to remove the oxygen from the tank.
• Verify that any contamination resulting from the removal of the tanks has been
assessed by a qualified environmental consultant. Soil samples should be
collected.
• Inspect any tank removal programs which are in progress.

PRODUCTION
PROD 58.0 Well Abandonment
Audit Protocol:
The well casing and wellsite shall be abandoned to a condition where there exists no
present or potential environmental pollutants.
Audit Guideline:
• Verify through record review that abandonment approvals have been obtained from
related regulatory agency.
• Verify that abandonment procedures have been developed. Preferred practices

include:
a) Isolate abnormal pressure zones from natural pressure zones.
b) Isolate any known productive oil and gas zones and prevent migration of
fluids in or out of these zones.
c) Isolate the open hole from the cased hole by a cement plug or a retainer-
cement plug combination placed in the deepest casing string which extends
to the surface.
d) Plug all annulus spaces that are open to formations and that extend to the
surface.
e) Place a surface cement plug below the ground surface in the smallest
casing string which extends to the surface.
f) Remove casing below the ground surface (usually 1.0 m).
• Verify that an abandoned well has a cement plug extending from a depth of at least
200 metres to surface, unless that interval is covered by casing which is cemented
over the interval.
• If feasible, inspect abandonment operation to verify procedures are being followed.

PRODUCTION
PROD 59.0 Decontamination
Audit Protocol:
All sites being reclaimed shall have any contaminated soil removed or remediated
before recontouring and revegetation.
Audit Guideline:
• Verify that proper decontamination procedures are implemented. Improper

decontamination procedures can result in further contamination or spreading of the
contaminants. The appropriate procedure will depend on a combination of the
concentration of the contaminants, the mobility of the contaminants, the potential
future land use of the site, the depth of the groundwater, the porosity of the soil,
possible migration paths, the treatability of the contaminated material, the length of
time to decontaminate, the composition/characterization of the contaminants,
disposal options available, type and amount of contaminated material and the
area/depth of contamination.
been decontaminated. Inspect site being decontaminated. The site may require
restricted access, such as fencing to protect people and animals.
• Determine if decontamination is incomplete: level of residual contaminants may be

too high to meet criteria. The following methods of decontamination should be
considered:
Treat material in place.

Landspread on site.
Municipal landfill (nonhazardous materials only).
Industrial landfill (may accept hazardous materials).
Oilfield reclaiming operations.
Solidification.
Hazardous waste treatment facility.
Enhanced microbiological degradation.
Soils leaching.
Low temperature thermal desorption.
High temperature thermal processes.
• Inspect decontamination projects or completed programs.

PRODUCTION
PROD 60.0 Soil Reclamation
Audit Protocol:
Reconstructed soils should be able to produce to the former land capability. Soil shall
be returned to similar conditions as preconstruction/operations. The soil layers on site
should be within 50% of their predisturbance depths (topsoil and subsoil). The topsoil
must be in the same texture class as adjacent land. Approximately 20% of the site
may drop one soil quality class.
Audit Guideline:
• Verify that at least four control sites were examined to a depth of 50 cm in order to
identify what soil conditions should be for the site.
• Determine if soil amendments were used or are needed in order to return the soil to
predisturbance conditions. Verify that the amendments recommended were based
on laboratory analysis of the soil on site. Verify what amendments were used
(manure, straw, tree bark mulch, peat, artificial fertilizer) and determine if they were
consistent with both the predisturbance soil conditions and the laboratory analysis.
• Verify that the soil after remediation is the same texture class, same pH, same
aggregate size and strength, same quantity of gravel and rocks and same organic
matter content as the control sites.
• Ensure that the site has been decompacted and that the soil process restriction
parameters are nonrestrictive as compared to the control. Process restriction
parameters are water permeability, vertical root elongation and soil aeration. No
soil layer should have greater density than before.
• Verify that surface soils have been salvaged and replaced on site.
• Inspect soil remediated sites.

PRODUCTION
PROD 61.0 Recontouring
Audit Protocol:
All sites being decommissioned, reclaimed or portions of “live” sites not required for
operations, shall be restored to a capability equal or better than the surrounding current
land use. This includes restoring the original drainage patterns and ensuring that the
site does not hold water.
Audit Guideline:
• Verify that culvert and creek crossings are removed and banks are recontoured
back to original contour (stabilized log cribbing may sometimes be left).
• Verify that creation of steep slopes is minimized (<3H:1V on clay soils, <5H:1V on
silt soils).
• Verify that runoff is spread over a large area to minimize runoff water velocities.
Water should be drained in a sheet instead of channels on slight to moderate
slopes.
• Verify that berms and diversion ditches are used to move water into vegetated
areas on steep slopes to reduce erosion. Angle across face of slop should be < 30
degrees. There should be no more erosion gullies than on adjacent land.
• Verify that there is no visible evidence of slope movement, slumping, subsidence or

tension cracks. Site drainage should be consistent with the original patterns,
directions and capacity or be compatible with the surrounding landscape. Any
facilities left in place (i.e., roads) must not negatively impact drainage.
• Verify that soil is replaced according to the soil profile - horizons A and B should not
be mixed. Subsoil should be replaced with proper compaction.
• Look for ponding, silt deposition and gully erosion. Altered drainage must not
adversely impact adjacent properties.
• Verify that all surface soils are salvaged and replaced onsite.
• Verify that erosion control measures are used as required including berms,
crimping, mulching, manuring, netting and bale placement.
• Verify fences are used where needed.

• Verify that a slight slope (2%) was created to avoid ponding.
• Verify equipment was used appropriately and in appropriate weather conditions to

avoid compaction, soil loss, and weed introduction.
• Verify any rocks were buried more than 150 cm below grade.
• Ensure microsites are created for enhancing growth of vegetation - site should not
be smooth.
• Inspect sumps and pits locations for signs of settlement. Sumps and pits which are
backfilled will settle - mound 50-100 cm to compensate.

PRODUCTION
PROD 62.0 Revegetation
Audit Protocol:
All sites being decommissioned or reclaimed and all disturbed areas at “live locations”
shall be revegetated to prevent erosion, soil degradation and return site to its former
land use.
Audit Guideline:
• Prior to the site inspection, verify any regulatory or landowner requirements.
Disturbed areas should be revegetated with grasses, shrubs and trees native to the
area.
or no maintenance.
• Preferably certified seed should be used to minimize the introduction of noxious

weeds. Review the seed analysis certificates. Local sources of seed is preferred.
• Verify the density of growth: overly dense or too little plant growth will require further
work. Determine the method of seeding, time of year of seeding and seeding rates
and compare with the success of the revegetation on site.
• Verify if fertilizers were used and if so what kind. Determine if the quantity and type
is appropriate for the site and climate.
• Determine if the weed growth is acceptable or if a management program is needed.
• Verify that the recontouring was appropriate for the vegetation growth (see
Recontouring) i.e., decompaction, microsites, no erosion or ponding.
• Verify fences have been used where necessary to protect new growth.
• If the site has had time for revegetation growth, inspect and record the success
achieved after revegetation and if more work is required.

PRODUCTION
PROD 63.0 Reclamation Assessment
Audit Protocol:
A Reclamation Plan shall determine the success of reclamation. A field inspection

shall be undertaken to assess the success of a reclamation plan. Upon this
assessment, modify the reclamation plan if required.
Audit Guideline:
• Verify that Reclamation Plan was properly followed.
• Verify that wellbores are abandoned properly.
• Verify that all tanks were removed correctly.
• Verify that all equipment was properly removed and that the site has been
completely dismantled.
• Verify that flare pits are closed in an acceptable manner (see Closure of Flare Pits).
• Verify that access roads, borrow pits,etc., have all been removed.
• Verify that all decontamination procedures were performed properly and that the
site is decontaminated (soil and water).
• Verify that the soil was appropriately remediated and recontoured.
• Verify that the soil profiles on site are within acceptable limits to matching the soil
profiles of the off-site controls.
• Verify that the vegetation is, after at least one full growing season, growing well,
with appropriate plant density, cover, plant type and height. Also verify that the
species composition is appropriate for the site and that the vegetation is healthy.
Any bare areas or noxious weeds should be noted.
• Verify that any soil amendments are appropriate for the site and applied correctly.
• Verify that the drainage patterns, contours and slope are appropriate, that there is
no debris on site, that the landscape is stable and that surface rocks match
adjacent land.

• Verify that after operations are completed, the site is restored, as far as practical, to
a condition compatible with existing land use, and that the land capability is equal
to or better than predisturbance conditions.


12.4 PIPELINES, TRANSPORTATION AND TERMINALS.
This section applies to pipelines, tank farms and marine terminal operations.
Some topics may be relevant to each of these facilities or just one or two.

Pipeline Construction (Onshore)
5.0 Right-of-Way Survey

8.0 Grading
9.0 Trenching
10.0 Pipe Stringing
11.0 Backfilling
12.0 Testing
13.0 Fire Control
14.0 Environmental Concerns During Construction
- Operations

16.0 General Operations at Marine Terminals
17.0 Pumps and Transfer Systems
18.0 Valves
- Product Storage

24.0 Access Roads

25.0 Access Control


28.0 Housekeeping
29.0 Flare Stacks
30.0 Release of Produced Water
33.0 Noise
38.0 Water Release
39.0 Gas Release

Waste Management

46.0 Asbestos
48.0 Sewage Lagoons
49.0 Recycling
52.0 Filters

55.0 Tanks Removal
56.0 Road Abandonment
57.0 Risk Management
60.0 Recontouring
61.0 Revegetation

PIPELINES, TRANSPORTATION AND TERMINALS

PIPE 1.0 Regulatory Environmental Authorization
Audit Protocol:
commencement of any pipeline, transportation and marine terminals construction and
operations program. Special conditions and restrictions shall be reviewed and
enforced.
Audit Guideline:
• Meet with the project supervisor to review the project records to ensure that all
required construction permits, licenses and regulatory authorizations were obtained
prior to the start of any field operations. Check the files to make sure that all
information in writing is available and has been provided to all field supervisors on
site. Record permit/license numbers and contractors specifications and verify
information in the field.
landowner/occupant contacts. Check with the project supervisor that field reports
have been reviewed.

permits/licenses. Verify through inspection of the facilities that these issues are
enforced during the field operations. Verify contractor’s awareness of the
requirement.
• Identify if regulatory personnel will be inspecting the work and attempt to coordinate
the site visit and meet with the government person in the field.
• At marine terminals, there is very tight scheduling, and the terminals know well in
advance which vessels will arrive. Most terminals have requirements that vessels
must meet if they are to call at a particular terminal. Review any particular vessel
requirements related to length, draft, equipment (inert gas systems, crude oil
washing systems, segregated ballast, double hulls/double bottoms) and previous
accident or spill response. Verify that these issues are enforced during the terminal
operations.


PIPE 2.0 Personnel Training
Audit Protocol:
Audit Guideline:
procedures.
• Verify if there is a system in place for all personnel to update their training yearly or
as required.
• At marine terminals, there are generally certification requirements for personnel on

the tankers and the dock that stipulate formal training and perhaps competency
assessment. Verify that personnel have proper training to conduct operations at
marine terminals.


PIPE 3.0 Environmental Concerns
Audit Protocol:
The planning and engineering design of pipelines, transportation and marine terminals
facilities shall be undertaken in a manner that will anticipate potential environmental
problems and minimize the impacts of the operations on the environment.
Audit Guideline:
The ARPEL document “Guidelines for the Environmental Management of the Design,
Construction, Operation and Maintenance of Hydrocarbon Pipelines” can be used as a
guide to conduct audits regarding environmental concerns during the planning stage of
pipelines.
• Inspect site to verify that environmental concerns were considered during the
planning of the operations. These concerns may include loss of timber, effect on
forage and crops, effect on wildlife, effect on marine ecosystems, water pollution,
erosion potential on slopes, access, fence crossing requirements, scheduling of
construction, disruption of tides and damage to shorelines, etc.
• Review records to verify that there is a proper recording procedure during an

occurrence of any disturbance to the environment. If any incidents have occurred,
record the type on incident and measures taken.
• Review records to verify that all relevant operations and safety manuals and
abandonment procedures manuals are available on site.
• Verify that environmental concerns were considered during the planning of access
roads. Existing roads should be used as much as possible to minimize
unnecessary road construction and encroachment on the adjacent land. To
minimize the need for deep cuts, the planner should avoid steep gradients and
identify the areas for detours. Access road location should minimize disturbance to
watercourses and sensitive areas. Clearing widths should be kept to a minimum.
Changes to natural conditions should be minimized while attaining maximum
erosion control.
• Verify through interviews that work crew has been instructed to avoid trampling of
crops.
• Verify that work crews have been instructed to avoid harassment of wildlife.

• Verify that attempts have been made to schedule project activities to avoid the time
periods when high water levels occur in marshes. Walking across marsh areas
can disturb the habitat provided by the marsh. Spawning periods of fish in rivers,
streams and creeks should be taken into consideration to avoid disturbance during
critical periods. Efforts must be made to avoid damage to spawning beds at all
water crossings.
• Identify if limitations of seasonal weather and the parameters for halting work in the
event of serious environmental damage have been considered (i.e. wet weather
causing erosion or extreme dry weather and a high fire risk).


PIPE 4.0 Site Information
Audit Protocol:
modifications or amendments to any facility or operations should be found in all
drawings and plans showing the date of change. All modifications associated with
environmental protection should be recorded.
Audit Guideline:
• Verify type of site (i.e., pipelines, tank farm, marine terminals, etc.).
• Verify site status (i.e., in construction, in use, abandoned, etc.).
• Record all equipment and its condition on site (i.e., tanks, pits, dikes, berms,
sheds, etc.).

plans or drawings.


PIPELINE CONSTRUCTION (ONSHORE)
PIPE 5.0 Right-of-Way Survey
Audit Protocol:
Surveying of pipelines shall be done in an acceptable manner to minimize disturbance

to the environment. The primary concern is that surveyors be given appropriate
direction by the owner company regarding standard right-of-way width, location of
additional right-of-way and minor adjustments to skirt around problem areas, road
bores, water crossings, bends, etc.
Audit Guideline:
guide to conduct audits regarding surveying of pipelines.
• Inspect flagged right-of-way and check that field sensitive areas are avoided.
• Verify that surveyors carry out their duties in an environmentally responsible manner
and they are aware of particularly sensitive areas.


PIPE 6.0 Cutting, Clearing and Timber Salvage
Audit Protocol:
Cutting and clearing operations shall be implemented so that disturbance to the

environment is minimized. All necessary precautions to minimize soil erosion and to
avoid pollution of waters and waterways shall be taken. Unnecessary destruction of
merchantable timber should be avoided. Every effort should be made to utilize all
merchantable timber which must be cut.
Audit Guideline:
guide to conduct audits regarding cutting, clearing and timber salvage.
• Inspect site to verify that any particular restrictions regarding clearing operations
have been taken into consideration.
• Inspect areas outside line right-of-way to verify required environmental protection

measures were taken to minimize disturbance to the environment as a result of
cutting and clearing operations.
erosion and to avoid pollution of waters and waterways. Siltation can be avoided by
use of fibrous materials in drainage areas.
• Verify that all stream and river approaches and slopes with potentially unstable
banks are hand cleared to a distance of 100m from the high-water mark or to the
top of the slope, where the slope is greater than 3:1.
transported timber.
• Verify that after clearing, timber is removed and put to some beneficial use or is
disposed of by sale.
• Ensure salvaged timber is located in areas suitable for recovery and in a manner to
facilitate economical removal.


PIPE 7.0 Topsoil Conservation
Audit Protocol:
Audit Guideline:
conserved.
• Where ever possible topsoil should be stockpiled at the top of a slope and not at
the bottom to facilitate easy replacement. Retaining walls can be used to hold soil
on slopes or away from creeks.


PIPE 8.0 Grading
Audit Protocol:
Grading operations shall be performed so that disturbance to the environment is

minimized.
Audit Guideline:
guide to conduct audits regarding grading procedures.
• Verify that grade changes requiring excessive cuts and fills are minimized. Grading
should be done only as necessary to provide an adequate surface for construction
equipment and to allow overbends and sags.
• Determine if disturbance of natural drainage channels is minimized during grading.

Blocking channels with graded material should be avoided. Final grade should not
disrupt natural drainage patterns.
• Verify that grading is done away from watercourses to reduce the risk of material
entering a watercourse. Fill material should not be placed in a watercourse during
grading.


PIPE 9.0 Trenching
Audit Protocol:
Trenching operations shall be performed so that disturbance to the environment is

minimized.
Audit Guideline:
guide to conduct audits regarding trenching procedures.
• Verify that time between trenching and backfilling is minimized.
• Verify that trenching in areas with a high water table is delayed until just prior to
lowering-in to prevent the trench from sloughing.
• Verify that proper safety measures are taken during trenching operations. No
person should enter a trench at any time. Shoring at tie in areas is recommended
where soil is loose or sandy. All trenching should be fenced if it is to be left open
overnight.


PIPE 10.0 Pipe Stringing
Audit Protocol:
Pipe stringing operations shall be performed so that disturbance to the environment is

minimized.
Audit Guideline:
• Verify that appropriate gaps are left in pipe joints to permit vehicular access or
movement of livestock to watering and feeding areas. Within wildlife habitat areas,
gaps should be left for wildlife movement.
• Verify that spent welding rods are not left on the ground or in the trench. Verify that
proper techniques are used in high fire hazard areas (i.e. welding must be shut
down during high winds and water trucks should be available).


PIPE 11.0 Backfilling
Audit Protocol:
Proper backfilling operations shall be implemented to minimize disturbance to the

environment. Backfilling is the first stage in reclaiming the right-of-way. Improper
procedures at this stage can affect the quality of final reclamation on the project.
Audit Guideline:
guide to conduct audits regarding backfilling procedures.
• Verify that the length of open trenches is minimized by backfilling immediately after
lowering-in.
• Verify that subsoil is backfilled prior to replacing topsoil. Topsoil should not be
used for padding the pipe. Backfill material should be kept free of wood, skids,
garbage and other construction debris.


PIPE 12.0 Testing
Audit Protocol:
Testing operations shall be performed in an acceptable manner. Construction and

sizing pigs are propelled through the pipeline by compressed air to clean the pipe and
check for internal damage. Typical test media include water, methanol, air and inert
gases. Air testing is preferred method. Although the testing stage is often of minor
concern, significant environmental impacts may occur, particularly if pipe failures and
repairs are frequent or if they occur in sensitive locations such as water crossings.
Audit Guideline:
• Determine if safe and proper procedures are used for testing operations. Post
warning signs may advise the public of danger. No one should be near lines when
testing.
• Verify that there are sufficient workers and equipment available on site to repair any
rupture, leak or erosion in the event of a test failure.
• Verify that alternatives to natural water bodies are used as a source of hydrostatic
test water. Test pumps should be isolated from water bodies with an impermeable
lined dyke or depression to prevent spills of fuel or lubricants from entering a water
body. Water returned to natural water bodies should be of sufficient quality to avoid
any serious pollution problems.
• Verify that pipelines are dewatered in a manner which prevents soil erosion and
damage to the beds and banks of water bodies.
• Verify that all methanol and ethylene glycol is recovered in tankage. Contamination
to natural water bodies must not be allowed.
• Verify that water is sampled before and after testing.


PIPE 13.0 Fire Control
Audit Protocol:
Measures shall be taken to avoid any fire hazards.
Audit Guideline:
• Verify that proper safety procedures are used for fire control. Restrictions on
smoking and ensuring vehicles carry fire fighting equipment during high fire hazard
periods are recommended. The following equipment and measures are suggested:
- 20lb fire extinguishers should be carried in all vehicles

- No welding should be done on dry soil or grass areas
- All welding rod ends should be put in steel pails
- No smoking should be permitted on right-of-way or near wells
- A water truck on site may be necessary when dry conditions exist
- Use welding wind shields when necessary
- Remove tall grass/crop from right-of-way to reduce fire hazard


PIPE 14.0 Environmental Concerns During Construction
Audit Protocol:
Depending on the type of terrain, vegetative cover, existing activities and concerns of
other land users, the pipelines program may require adjustments to accommodate as
many concerns as is practical or possible.
Audit Guideline:
• Inspect site for any disturbance to agricultural productivity due to trampling of crops,
removal of plantation trees and plants, inconvenience of farming activities.
• In agricultural areas, inspect site for attempts made to avoid disturbance of fields
that are nearing harvests.
• Inspect marsh areas. Temporary bridges should be constructed to allow crews to

cross marsh areas. Walking across marsh areas can disturb the habitat provided
by the marsh.
• Determine if measures are taken to avoid any harassment of livestock and to

protect livestock (i.e., fence around trench).


Operations
PIPE 15.0 Distribution Lines
Audit Protocol:
Distribution lines shall be located such that they cannot be easily damaged by moving
equipment. Design techniques must be employed to prevent pressure eruptions and
reduce fire hazards.
Audit Guideline:
distribution lines such as site security and anti-corrosion programs.
• Check for saltwater or oil spill along right-of-way, erosion control, slash disposal
and vegetation control.
• Verify that trained personnel and spill containment equipment is available should a
pipeline break occur.
• Inspect portions of the distribution line systems for such items as placement of
shut-off valves, marked facilities, erosion control, vegetation management and spill
cleanup.


Operations
PIPE 16.0 General Operations at Marine Terminals
There are at least three distinct types of terminals: those that are primarily used for
export, those that are primarily used for import and those that are designed for
transshipment. Most marine terminals are located at tide water; some are designed to
have ships berth at the dock and offload to tanks on shore; others have an offshore
buoy where vessels discharge their cargoes which move via marine pipelines to a
shore based tank farm. Some terminals are located offshore, but only a limited
number exists. Most crude oil is processed at or near the production site; the vast
majority of crude oil delivered to marine terminals is sales specification with a
minimum of sediment and water.
Audit Protocol:
Accidents frequently occur during the last phases of approach and docking or during
transfer operations. Operations at marine terminals shall be undertaken in a manner
that would minimize impacts to the environment. All equipment and infrastructure have
to be well maintained to prevent any pollution incidents.
Audit Guideline:
• Verify that charts, maps and other written or graphic information are well
maintained; verify that they are current and regular depth and obstruction surveys
are conducted where draft limitations are a concern.
• Pilots are used in some ports and at some terminals. Verify that the relationship
between the Master of the tanker and the Pilot is clear, and that the Pilot’s
credentials are relevant to the location and vessel being berthed.
• Verify that the condition of the dock, mooring lines, fenders, buoys,
connectors/fittings and hoses is acceptable. These issues are important for the
prevention of polluting incidents (also see Spill Prevention and Emergency
Response). Verify that adequate lighting is available for nighttime operations.
• Verify that fire-fighting equipment on-board and on the dock is maintained in a high
state of readiness.
• Verify that there is an appropriate interface between the vessels personnel

responsible for offloading the cargo and the terminal personnel responsible for
receiving the cargo. The cargo is generally offloaded using pumps on the vessel (at
tens of thousands of barrels per hour). The destination tank(s) and transfer lines
are the responsibility of the terminal. Both operations must be closely supervised

and monitored. Effective primary and emergency communication systems must be

maintained to ensure that transfer operations can be immediately terminated.
Language can sometimes be an issue in today’s global tanker industry.


Operations
PIPE 17.0 Pumps and Transfer Systems
Audit Protocol:
Crude oil transfer and shipping to terminals shall be conducted so that environmental
disturbance is minimized. Pipeline, truck and ocean tankers transfer operations shall
have environmental control systems such as electronic fluid control, gauges, lock out
valves, low pressure shut in valves, emergency shut down systems, etc.
Audit Guideline:
• Verify that all crude oil transfers are monitored by personnel at either end of the
connection. Ensure that appropriate emergency shutdown systems are available
and in working condition. Ensure that communication systems connecting the
discharge and receiving facilities are working and that adequate secondary systems
are available and function properly.
• Verify through interview and inspection of records that all components of the
loading/transfer system receive regular inspection and maintenance. Inspect logs
at the facility and tankers for an indication of problems during crude oil transfer and
their resolution. Pay particular attention to reports of emergency disconnects and
any release of oil.
• Check condition of transfer hoses, pumps and any pressure testing procedures.
Review incident history of transfer hoses. At ship terminals, close attendance
during bunkering of the vessel with the pollution control equipment is
recommended.
• Verify vehicle and tank trailer service logs to identify schedules and procedures
undertaken to maintain equipment integrity. Verify that drivers have proper training
in transportation safety and emergency response to accidental spillage.


Operations
PIPE 18.0 Valves
Audit Protocol:
Valves shall be maintained in order to prevent spills and minimize any impact to the
environment.
Audit Guideline:
• Verify that inspection of all valves are regularly undertaken. Verify that valves are
secured and monitored regularly for leaks.
• Inspect valves for signs of leaks. If there are any leaks, record the type (i.e., oil,
gas, chemical, water, etc).
• Inspect engineering guidelines for valves.


Operations
PIPE 19.0 Cathodic Protection
Audit Protocol:

underground or aboveground steel structures to protect them from external corrosion.
Audit Guideline:


large distance.
• Inspect records to determine if routine testing is completed.


Product Storage
PIPE 20.0 Tank Operations
Audit Protocol:
Audit Guideline:





stored.

above.

incident reports.

of confidence.


Product Storage
PIPE 21.0 Product Storage
Audit Protocol:
Oil and gas products shall be stored and labelled properly. All storage, loading
Audit Guideline:
• Verify that engineering designs, operating procedures, tank storage and loading
facilities are designed to prevent or reduce accidental discharge.
technology.
of such systems.

PIPELINE, TRANSPORTATION AND TERMINALS

Product Storage
PIPE 22.0 Chemical and Hazardous Material Storage and Handling.
Audit Protocol:
The handling, storage and use of chemicals in pipeline operations shall be done such
that impact to the environment is minimized. Hazardous materials shall also be
handled properly. Chemical and hazardous materials shall be stored and labelled
properly.
Audit Guideline:

consumed.
d) Tanks larger than 50 gallons should be diked or an equally effective means

identified to prevent excessive contaminations to the surrounding area in the
event of a major spill or tank fracture.
• Inspect chemical metering pumps. These pumps are essential to control chemical
usage. The following recommendations are suggested:
a) Chemical metering pumps should be clearly labelled by chemical name.

b) All chemical lines should be colour coded and/or labelled at both ends.
c) Chemical metering equipment should be located in a well-ventilated area,

preferably serviced by mechanical ventilation.


product.



Product Storage
PIPE 23.0 Vapour Recovery Units
Audit Protocol:
Audit Guideline:
units.


PIPE 24.0 Access Roads
Audit Protocol:

to the environment. Access roads should avoid communities and environmental
sensitive areas.
Audit Guideline:
• Inspect access roads near high sensitive areas. Fences or post signing should be
• Verify that movements of ground vehicles are strictly limited to designated access
roads, ancillary sites (compressor stations, construction camps, equipment yards,
etc.) and right-of-way boundaries.
• Verify that regularly used roads are bored to minimize disturbance to local users.
Verify that signs are posted to warn road users of the construction.


PIPE 25.0 Access Control
Audit Protocol:

Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates to keep people and
wildlife away from the right-of-way. Verify that access control is in place for
environmentally sensitive areas.
required.


PIPE 26.0 Perimeter Berms
Audit Protocol:
Berms shall be used to contain surface runoff from tank storage and pipeline operation
facilities in order to minimize/eliminate a pollution release from going off-site to
contaminate the adjacent environment.
Audit Guideline:
• Verify use of berms. Berms should be constructed from an impermeable material.

They should be of a design and size to contain a spill of a size which might occur
before personnel are aware of the release and can respond.
• Verify that berm containment system has a surface water collection disposal
process. Verify that such a system is monitored to allow for water runoff but is
operated in a closed capacity to hold containments
as needed.


PIPE 27.0 Stream Crossings
Audit Protocol:
Damage to fish habitat may exist due to stream crossings during road construction,
pipeline construction or placement of a bridge or culvert for continual crossing use.
Measures shall be taken to reduce the impact of pipelines activities on water quality.
Water damage to improper bridges can result in environmental/safety hazard.
Audit Guideline:
guide to conduct audits regarding stream crossings.
• Inspect stream crossings to verify that environmental protection measures were

implemented to minimize disturbance and pollution. Verify that stream bed is not
constricted and shoreline armouring is sufficient.
• Inspect stream crossings for signs of pollution and sediment problems. Sediments
entering streams are a major pollutant and have significant effects on the survival,
reproduction and growth of fish.
• Inspect that debris and material is pulled back at a crossing rather than pushed
through the stream. Logs and soil materials should not be placed into any waters.
available.
• Verify that an undisturbed vegetative buffer is maintained on stream banks where

possible.
• Verify that pipeline crossings placed in streams are not buoyant or becoming
exposed due to channel migration and stream bank erosion.


PIPE 28.0 Housekeeping
Audit Protocol:
equipment.
Audit Guideline:
gates should be constructed as needed and maintained in working order.

farmland, etc.


PIPE 29.0 Flare Stacks
Audit Protocol:
Audit Guideline:
land.
• Verify that stack height and distance form facility meets regulations.


PIPE 30.0 Release of Produced Water
Audit Protocol:
Anytime an uncontrolled release of produced water from a source water, disposal or

injection line is made to the terrestrial environment, proper measures shall be taken for
containment and initial clean-up. In this case, release is meant to be leakage due to
line failure or rupture.
Audit Guideline:
• Verify that there is a Spill Contingency Plan and/or an Emergency Response Plan
that clearly outline measures to be taken during a release of produced water. (See
Spill Prevention and Emergency Response section). A produced water release
should be responded to in the following manner:
so.
b) Notify supervisor and any parties impacted by the release.
c) Contain the released produced water using bell holes, soil berms or
interception trenches as necessary.
e) Recover all free produced water using pumps or vacuum trucks.
f) The area of the spill should be flushed with a calcium amendment prior to
the application of any fresh water, recovering the excess fluid.
g) Begin spill area decontamination.
• Inspect along pipeline right-of-ways for signs of released produced water.
• Verify that any produced water release has been properly documented and
decontaminated.


PIPE 31.0 Release of Hydrocarbons
Audit Protocol:

Audit Guideline:
so.

• Verify that any release of hydrocarbons has been decontaminated.


PIPE 32.0 Site Maintenance
Audit Protocol:
Facilities shall be properly maintained. Equipment should be inspected regularly to

maintain the presence of accidental gas or liquid discharges to the environment.
Audit Guideline:

location.

and disposed of (see Waste Management section).
overflows (see Product Storage section).
• Review operator work schedules to identify ongoing maintenance programs.


PIPE 33.0 Noise
Audit Protocol:
The impact of pipelines, transportation and terminal operations’ noise on local

residents and workers shall be minimized.
Audit Guideline:
monitoring of the site is being done.
• Verify that any noise issues at marine terminals are dealt with appropriately. The
offloading operations can involve the generation of noise on a continuous basis for
12 hours or more.


PIPE 34.0 Drainage and Erosion
Audit Protocol:
by the operation, shall be removed or remedied as soon as possible. Proper erosion
control measures should be taken.
Audit Guideline:

• Inspect the site and check for signs of erosion problems, sedimentation of streams
or reduction in watershed capacity caused by the removal of trees, shrubs and
other vegetation, disturbance of land surface, or any other cause resulting from the
operations. Verify if any methods are used for erosion control of exposed soils.

Water spraying and/or soil tackifier is sometimes needed to minimize soil loss due
to wind erosion. If dust is a problem near residences, the site should be sprayed
with freshwater. In general, methods of erosion control can include diversion
berms, rip rap, matting, fibres, etc.
• Inspect access routes and vehicle use to verify that damage to the soil is being
prevented. Look for ruts from large tires or tracked equipment.


PIPE 35.0 Surface Water Monitoring
Audit Protocol:
Audit Guideline:


PIPE 36.0 Soil Sampling and Monitoring
Audit Protocol:
program).
Audit Guideline:


PIPE 37.0 Groundwater Monitoring
Audit Protocol:

Audit Guideline:
compliance.
information.
unauthorized entry.

properly.

PIPELINES TRANSPORTATION AND TERMINALS

PIPE 38.0 Water Release
Audit Protocol:
surrounding land.
Audit Guideline:

the water surface.
of at an approved oilfield waste disposal facility or treated and then discharged on


PIPE 39.0 Gas Release
Audit Protocol:
Emissions from pipelines shall be controlled and minimized. This applies to all gas
pipelines and gas transmission lines (process marketable gas).
Audit Guideline:
• Verify that there is an Emergency Response Plan that clearly outlines measures to
be taken during a gas release. A gas release should be responded to in the
following manner:
a) Identify, isolate and shut down in a controlled manner, as quickly as

possible, the source of the release. Make repairs when safe to do so.
b) Notify supervisor and any parties impacted by the release.
c) If it is a sour gas line, an Emergency Response Plan should be executed

immediately.
• Inspect along pipeline right-of-way for signs of released gas.
• Verify that any gas release has been properly documented.


PIPE 40.0 Air Quality Monitoring
Audit Protocol:
Audit Guideline:
calibrated.
require them.


PIPE 41.0 Release/Spill Prevention
Audit Protocol:
Audit Guideline:

be achieved by:

drills.
and bases.
procedures.
• Transfer operations at marine terminals can result in large spills and loading
efficiency can be affected by oceanographic and meteorological conditions. Verify
that operations are supported by reliable weather forecasting services that can be
used to plan loading/unloading operations at ship terminals. Verify that personnel
are trained to operate properly under unfavorable conditions where tankers may not

be able to connect to the loading system or may have to disconnect to ride out a
storm.
• Verify that tankers have segregated ballast systems that eliminate the problems
associated with the transfer and treatment of oily ballast water.
• If vessels do not have segregated ballast, as the tanker takes on oil, the ballast
must be offloaded (dumping dirty ballast at sea is illegal by international convention
MARPOL). The ballast water must be treated and disposed. Determine how the
ballast water was treated.


PIPE 42.0 Spill/Release Contingency Plans
Audit Protocol:
Pipeline, transportation and marine terminal facilities shall have a spill/release

contingency plan. All personnel shall be familiar with the contingency plan
Audit Guideline:


locations, leak isolation, spillage/release containment, watercourse protection,
etc.
I) Guidelines for post-repair inspection and returning the line to service.
• Verify that ships transferring oil to terminals have a contingency plan that
guarantees an effective response. The plan must be developed with the specific
configuration /size of the terminal, local weather, currents and environmental
sensitivities in mind. The regulators (in many cases involving marine officials for
the Navy/Coast Guard) should be involved in the contingency plan, as should the
P&I Clubs/ITOPF (Protection and Indemnity/International Tanker Owners Pollution
Federation). Generally, if the spill takes place from the vessel before it has
connected to the terminal systems or after if leaves, it is the vessel responsibility to
deal with the spill.

retention booms, skimmers, sand bags or temporary curbing devices, recovery
pumps and collection hoses, recovery tank trucks and protective equipment.
During the construction of pipelines, all fuel and service vehicles should carry a
minimum of 10kg of suitable commercial sorbent material for use on small fuel or
oil spills. Mobile construction equipment should not be serviced or refuelled within
100m of watercourses to prevent water pollution.
training provided.


PIPE 43.0 Emergency Response
Audit Protocol:
Pipeline, transportation and marine terminal facilities shall have an Emergency

Response Plan to protect the public, employees, the environment and property should
an emergency occur. It is necessary to provide all employees with a systematic
presentation of communication practices and procedures to be followed in an
emergency.
Audit Guideline:


Plan should contain the following information:



news media.


WASTE MANAGEMENT
PIPE 44.0 Waste Management Plan
Audit Protocol:
Pipeline, transportation and marine terminal facilities shall have a Waste Management
Plan to ensure each facility knows what wastes it produces and how to handle and
dispose of those wastes properly.
Audit Guideline:
disposal.
the waste.


WASTE MANAGEMENT
PIPE 45.0 Disposal of General Solid Wastes
Audit Protocol:
Audit Guideline:
properly.
During construction of pipelines, verify that receptacles are provided for proper disposal
of welding rods. Whenever land is cleared by a linear development, debris disposal
is a major concern. Debris disposal is the total or partial disposal of all unsaleable
timber, brush, roots and other debris on the right-of-way. It is done to reduce fire
hazards and improve aesthetics. A common disposal method is Rollback of debris.
Rollback is the practice of spreading debris from clearing back over the line after
the completion of the construction program. It is restricted to debris less than 15
cm in diameter, and the debris should be compacted. Whenever a linear
disturbance crosses a road, total disposal should be completed for a distance of 90
m from either side of the road’s centre line. The most common method of total
disposal is burning, with the residue hauled down the line and spread out of sight in
the residual trees. Burial of burned debris is discouraged.
suitable for recycling should be stored separately and recycled accordingly. During
construction, waste materials such as pipe coating, spent welding rods, containers,
cans, lunch wrappings, used engine oil and other garbage arising from normal
pipeline activities should be collected daily by each crew and disposed of in an
approved manner.


are lined.
of-way.
optimum efficiency.
• At marine terminals, verify that wastes are not dumped into the ocean.


WASTE MANAGEMENT
PIPE 46.0 Asbestos
Audit Protocol:

limits.
Audit Guideline:
methods.

materials.


WASTE MANAGEMENT
PIPE 47.0 Sewage Effluent and Wastewater Treatment
Audit Protocol:
No effluent shall be discharged unless it satisfies existing local regulations.

Regulations limit the deposits of oil and grease, biochemical oxygen demand, fecal
coliforms, phenols, total suspended solids and the pH levels.
Audit Guideline:
implementation in the field.

tanks, leach pits, holding tanks, lagoons, packaged treatment plants, etc) utilized.
During the construction of pipelines, work camp wastewater should be hauled or
discharged to an approved municipal wastewater treatment system where feasible.
• If there are any subsurface disposal facilities (septic tanks, leach pits), inspect
distances from any sources of water supply and natural water bodies. Verify that
pump-out and hauling operations are carried out in a manner that does not expose
the driver or people in the area where the tanks are emptied to any health hazard.
Every effort should be taken to avoid any spillage when holding tanks are emptied
or when the truck contents are discharged into the treatment facility.
Overloading the system hydraulically reduces the effectiveness of pollutant removal.


WASTE MANAGEMENT
PIPE 48.0 Sewage Lagoons
Audit Protocol:
Audit Guideline:
are recommended:

e) Must be fenced.
I) Berms must be minimum 1V:3H.
j) Berms must be sufficiently wide at top to allow for equipment and personnel.


WASTE MANAGEMENT
PIPE 49.0 Recycling
Audit Protocol:
Pipelines, transportation and marine terminal facilities shall have an effective approach
to waste management. Recycling is a key component to conserving resources and
reducing wastes. Recycling assists by either reducing or eliminating the quantity of
waste which requires disposal, thereby reducing potential contamination to the
environment. The Waste Management Plan should contain recycling information.
Audit Guideline:
implemented.



WASTE MANAGEMENT
PIPE 50.0 Water Recycling and Reuse
Audit Protocol:
water.
Audit Guideline:


WASTE MANAGEMENT
PIPE 51.0 Disposal of Oil Based Wastes
Audit Protocol:
Audit Guideline:
d) Solvents.
e) Lube oil.


authorities.


burning.

landfill site.
available:
The preferred reclamation option is: After as much oil as possible has been picked

WASTE MANAGEMENT

PIPE 52.0 Filters
Audit Protocol:
Audit Guideline:
entrained liquids can be disposed of at approved disposal wells (see section on
Injection and Disposal Wells). To properly drain a filter, it must be stored in the
screened container for a minimum of three days at room temperature. Entrained
fluids must be kept segregated for recycling or disposal. It must be determined
through sampling if the filter is a dangerous oilfield waste. Examples of filters that
may be a dangerous oilfield waste are: glycol filters, leachate and entrained liquids,
air pollution control filters, sulphinol filters, lub oil filters, methanol filters, gas filters
and produced or process water filters.




PIPE 53.0 Reclamation Plan
Audit Protocol:
capability.
Audit Guideline:
cost control.
- site dismantling
- closure of flare pits
- removal of tanks
- decontamination
- soil remediation
- recontouring
- revegetation


PIPE 54.0 Site Dismantling
Audit Protocol:
Audit Guideline:
or pads, may be left on site if the landowner and regulators are in agreement or if
the landowner agrees and it does not interfere with the reclamation of the site.
• After the construction of pipeline, verify that watercourse crossing structures and
survey stakes are removed, fences and gates are repaired or replaced, topsoil is
prepared for seeding and the right-of-way is reseeded. Verify that all timber and
debris not disposed of has been salvaged or removed. All buildings, trailers,
machinery, equipment, materials, litter and storage containers must be removed
from the area. Temporary access roads must be removed. Abandoned equipment
should either be hauled out of the area or buried in a landfill site.
disposal.
• Verify that after all liquid has been removed from the vessels, distribution lines and
tanks, and that all equipment from the site is removed. Ensure any residual fluids
which remain are collected for disposal.
utility company.


• Verify appropriate handling of any water wells on site.


PIPE 55.0 Tanks Removal
Audit Protocol:
Audit Guideline:
tanks openings.
collected.


PIPE 56.0 Road Abandonment
Audit Protocol:
Roads shall be abandoned properly.
Audit Guideline:
• Verify that roads are abandoned properly.
a) If the roads have been temporarily abandoned, the following are required:
- All watercourse crossings such as culverts or bridges must be removed.

- Grade must be maintained but cross-ditches of erosion control structures
must be installed as required.
- All exposed areas have to be revegetated.
- Entry onto the road must be blocked if located in wildlife or ecologically
sensitive areas.
b) If roads are permanently abandoned, the following are required:
- Cuts and fills must be recontoured to natural conditions where slope and
materials make this practical.
- Erosion control measures such as diversion berms and cross-ditches must
be installed as required.
- Rollback windrowed debris for erosion control to provide microsites for
vegetation.
- All watercourse crossings must be removed and creek banks stabilized if
necessary.
- Disturbed areas must be revegetated using a suitable seed mix.


PIPE 57.0 Risk Management
Audit Protocol:
A progressive approach to site remediation that facilitates risk-based decision making

is recommended. The risk management of contaminated sites should involve
appropriate policies and procedures and a complete appreciation of human health and
environmental implications implied in the criteria used. The environmental audit is a
very important tool in the risk management process.
Audit Guideline:
Serious environmental contamination issues and the results of environmental audits

are reasons for properly managing risks at a facility. A logical and flexible risk-based
approach assures future environmental liability is minimized.
This type of approach has the following advantages: decisions are made based on
reducing the risk of adverse human or environmental impacts to acceptable levels; it
offers a rational and consistent process for selecting appropriate remediation criteria
and options; it allows limited resources to focus on remediating the sites with the
greatest risk; it assures that both the approach taken to remediation and the extent of
remediation is the most cost-effective; and, it assures that environmental audit
activities are directed towards collecting only the information necessary to make
informed decisions.
• Verify the establishment of guidelines/policies that properly manage risks at a

facility. Review risk management approaches and provide any recommendations
on any deficiencies found. Utilize appropriate risk management approaches in the
development of the audit (i.e., during a Phase III Assessment, information from
Phase I and II is analyzed and remedial and risk management options are
explored).
The aim is to reduce the degree of contamination to below appropriate risk

management criteria. Examples of risk management approaches are based on
future land use, site sensitivity and site specific conditions. The use of risk
management based on future land use means that the site will be cleaned up to a
level suitable for general future land uses. The choice of risk management based
on site sensitivity involves a qualitative evaluation of potential exposure pathways.
A site specific risk assessment may be required to develop risk management
objectives that are more appropriate for specific site conditions.


PIPE 58.0 Decontamination
Audit Protocol:
Audit Guideline:


considered:

Landspread on site.
Solidification.
Soils leaching.


PIPE 59.0 Soil Reclamation
Audit Protocol:
Audit Guideline:


PIPE 60.0 Recontouring
Audit Protocol:
All sites being decommissioned, reclaimed or portions of “live” sites not required for
operations, shall be restored to a capability equal or better than the surrounding current
land use. This includes restoring the original drainage patterns and ensuring that the
site does not hold water.
Audit Guideline:
• Verify that culvert and creek crossings are removed and banks are recontoured
back to original contour (stabilized log cribbing may sometimes be left).
• Verify that creation of steep slopes is minimized (<3H:1V on clay soils, <5H:1V on
silt soils).
slopes.
• Verify that berms and diversion ditches are used to move water into vegetated
areas on steep slopes to reduce erosion. Angle across face of slop should be < 30
degrees. There should be no more erosion gullies than on adjacent land.
• Verify that there is no visible evidence of slope movement, slumping, subsidence or

tension cracks. Site drainage should be consistent with the original patterns,
directions and capacity or be compatible with the surrounding landscape. Any
facilities left in place (i.e., roads) must not negatively impact drainage.
• Look for ponding, silt deposition and gully erosion. Altered drainage must not
adversely impact adjacent properties.
• Verify topsoil was distributed as evenly as possible (see Soil Remediation).

• Verify fences are used where needed.

• Ensure microsites are created for enhancing growth of vegetation - site should not
be smooth.
• Inspect sumps and pits locations for signs of settlement. Sumps and pits which are
backfilled will settle - mound 50-100 cm to compensate.


PIPE 61.0 Revegetation
Audit Protocol:
land use.
Audit Guideline:
area. Inspect that species selected are consistent with the planned use of the area
or no maintenance.



PIPE 62.0 Reclamation Assessment
Audit Protocol:

shall be undertaken to assess the success of a reclamation plan. Upon this
assessment, modify the reclamation plan if required.
Audit Guideline:
• Verify that flare pits are closed in an acceptable manner.
adjacent land.
Verify that after operations are completed, the site is restored, as far as practical, to a
condition compatible with existing land use, and that the land capability is equal to or
better than predisturbance conditions.

12.5 Refineries

12.5 REFINERY OPERATIONS

4.0 Process and Installation Drawings
- Processing
6.0 Processing
7.0 Filter Vessels and Treaters
8.0 Sulphur Recovery
- Product Storage and Loading
10.0 Bulk Product Receipt and Delivery


17.0 Access Roads
18.0 Access Control
20.0 Housekeeping
21.0 Flare Stacks
23.0 Noise
25.0 Surface Retention/Holding/Industrial Runoff Ponds
29.0 Water Release
30.0 Gaseous Emissions


Waste Management
35.0 Disposal of Refinery Wastes

36.0 Exposure to Toxic Substances
38.0 Specific Effluent Monitoring Requirements
39.0 Laboratory Analytical Methodology
42.0 Asbestos
43.0 Sewage Lagoons
44.0 Recycling
47.0 Filters
48.0 Disposal Wells
49.0 Sulphur Handling

52.0 Tanks Removal
55.0 Recontouring
56.0 Revegetation
In general, the following ARPEL documents can be used as guides in the conduct of
audits of petroleum refineries:
Guidelines for the Reduction and Control of Gaseous Emissions from Petroleum
Refineries;
Guidelines for the Management of Petroleum Refinery liquid Wastes;
Guidelines for the Management of Petroleum Refinery Solid Wastes; and,
Guidelines for Decommissioning and Surface Land Reclamation at Petroleum
Production and Refining Facilities.

REFINERIES
REFIN 1.0 Regulatory Environmental Authorization
Audit Protocol:
All required licenses, permits and letters of authority shall be obtained for the planning,
design, construction and operation of any refining facility. Special conditions and
restrictions shall be reviewed and enforced.
Audit Guideline:
regulatory authorizations were obtained for refining facilities and make sure that all
information in writing is available on site. Record permit/license numbers and verify
this information is in the field.

permits/licenses (e.g., facilities where sour gas is processed, monitoring reports to
regulatory agencies, stack exit temperatures for acid gas incinerators, etc.). Inspect
the facility to verify these requirements were fulfilled during the design and
construction stage of the facility. Verify that these requirements are enforced during
the operations.
• Verify through interviews that facility operators are aware of any restrictions and
environmental concerns for the operation of the facility.

REFINERIES
REFIN 2.0 Personnel Training
Audit Protocol:
Audit Guideline:
procedures.
• Verify if there is a system in place for all personnel to update their training yearly as
required.

REFINERIES
REFIN 3.0 Environmental Concerns
Audit Protocol:
The engineering design and site planning of any refining facilities shall be undertaken
in a manner that will anticipate potential environmental problems and provide the
design and operating procedures to minimize the impacts of the operations on the
environment.
Audit Guideline:
facility site. For example:
a) The site should be selected so spills can be easily contained and cleanup
vehicles can have ready access. This guideline also applies for staging
areas, fuel dumps and storage areas. The site selection process should also
minimize impact to natural runoff patterns and should prevent soil erosion
and surface water contamination.
b) A site should be selected with minimum impact on crops, vegetation and

forests. Land utilized as, special environmentally protected areas, state
parks and National reserves should be avoided.
c) Unnecessary removal of trees or alteration of other natural features should

be avoided.
d) Access roads should be located along a route which results in minimum

impact to the environment.
e) Present and future land use restrictions (i.e., airports, proximity to dwellings,
etc.) should be considered prior to making a final site decision.
f) Possible environmental effects on marshes, river beds, fractured formations,

springs, etc. should be considered.

REFINERIES
PRELIMINARY AUDIT ACTIVITIES
REFIN 4.0 Process and Installation Drawings
Audit Protocol:
Prior to the field inspection, the auditor shall be become familiar with the process and
installation drawings of the refinery facility.
Audit Guideline:
• Prior to the field inspection, review process and installation drawings to become
familiar with the specific refinery facility. Make sure that historical as well as
current drawings are studied.

REFINERIES
REFIN 5.0 Site Information
Audit Protocol:
modifications or amendments to any facility should be found in all drawings and plans
showing the date of change. All modifications associated with environmental
protection should be recorded.
Audit Guideline:
• Record all equipment and its condition on site (i.e., pits, tanks, dikes, berms,
sheds, etc.).

plans or drawings.

REFINERIES
Processing
REFIN 6.0 Processing
Audit Protocol:
All processing equipment shall be designed, operated and maintained in a manner that
prevents pollution to the environment. Typical refinery activities produce fuel products,
lubricants, sulphur, heavy useable hydrocarbons and processing wastes. Processing
of crude oil generally commences with an oil distillation facility which separates oil into
gasoline, kerosene, fuel oils and reduced crude oil, and sometimes reformer charge
stock, jet fuel or gas oil. Desulphurization is a second facility process from oil
distillation which recovers sulphur. Vacuum distillation is a third typical process which
processes lubricants, waxes, greases, coke and asphalt.
Audit Guideline:
A typical approach to audit a refinery is to break refinery processes into the following
three basic processes:
a) Primary Distillation.
This process may be broken into separate unit processes:
- Wet gas processing

- Desulphurization
- Heavy oil cracking
b) Gas Plant Processing.
The following unit processes may be found:
- Processing of fuel gas hydrogen

- Processing of ethane, propane, butanes
- Processing of motor gasoline
c) Secondary Distillation.
This process may be broken into separate unit processes:
- Processing of lubes, waxes and greases

- Coking
- Asphalt

• For each of these units, undertake an audit based on unit operations, unit pollution
control design (air, water, soil), material balancing, liquid/solid recovery systems,
waste storage and reduction, waste disposal and emergency response procedures.
• For each vessel and processing structure, verify use of emergency shutdown
systems, maintenance of valves and presence of leaks.

REFINERIES
Processing
REFIN 7.0 Filter Vessels and Treaters
Audit Protocol:
Filter vessels and treaters, associated with the oil recovery mechanisms on surface
water retention ponds and open top separation tanks, shall be designed, operated and
maintained such that impact to the environment is minimized.
Audit Guideline:
• Determine maintenance/turnaround schedules. Verify by inspection that filter

vessels and treaters are maintained.
• During the inspection, check for signs of spills. If there are any spills, record type
and location. Pressure relief valves, rupture disks or burst plates that are installed
on filter vessels or treaters must be connected by suitable piping to an open pop or
release tank. Other methods to prevent oil spills are acceptable if they provide
equivalent or better protection than the venting of relief devices to an open pop or
release tank.
• Verify that process area drains are not to ground and all drains go to either recovery
tanks or impermeable and/or lined retention pond for appropriate disposal. Verify
methods of monitoring these tanks for failure.
• Verify that wastes (filters, hay sections, sludge, scale, etc.) are properly transported
and disposed of.

REFINERIES
Processing
REFIN 8.0 Sulphur Recovery
Audit Protocol:
Sulphur recovery operations, storage and transportation shall be performed properly to

limit impacts to the environment.
Audit Guideline:
• Prior to the field inspection, review plant licenses for emission rates. Determine if
rates are exceeded.
• Review recorded stack exhaust temperatures to verify if they are sufficient.
• Verify that the required number of stack surveys are completed each year.
• Verify if any soil/air monitoring is completed (see Soil Monitoring and Air Quality
Monitoring).
• Verify that sulphur is transported safely and dust control measures are in place.
• Inspect sulphur storage areas. Verify that proper storage procedures are followed
and identify if sulphur depositions are impacting on adjacent water quality or
vegetation.

REFINERIES
Processing
REFIN 9.0 Cathodic Protection
Audit Protocol:

underground steel structures to protect them from external corrosion.
Audit Guideline:


large distance.

REFINERIES
REFIN 10.0 Bulk Product Receipt and Delivery
Audit Protocol:
Pipeline, truck and rail car bulk receipt of raw and produced products shall have
environmental control systems in place (such as emergency shut down systems,
gauges, lock out valves, etc.) to effectively store, handle and transfer product in an
environmentally safe manner. Loading and unloading procedures shall be performed
in a manner that prevents pollution to the environment. Tanks, trucks and trailers shall
be properly maintained. Operators should have proper training in transportation safety
and environmental protection.
Audit Guideline:
• Verify that facility personnel are in continuous attendance when trucks are loading
and unloading. If the unloading area does not flow into a catchment basin or into a
treatment facility designed to handle spills, a quick drainage system holding at least
the maximum capacity of one tank/tank car compartment should be used.
• Verify that interlock warning lights are used in loading and unloading areas to
prevent the departure of trucks before lines are disconnected.
• Review service logs.
• Determine hours trucks should be operating.
• Through interviews, determine driver training effectiveness including training in

transportation of dangerous goods, spill response, etc.
• Inspect the loading areas to assess general housekeeping, control and cleanup of
leaks and assess transfer operations which are in progress.

REFINERIES
REFIN 11.0 Tank Operations
Audit Protocol:
Audit Guideline:





stored.

above.

incident reports.

of confidence.

REFINERIES
REFIN 12.0 Distribution Lines
Audit Protocol:
Tanks and distribution lines shall be located such that they cannot be easily damaged
by moving equipment. Design techniques must be employed to prevent pressure
eruptions and reduce fire hazards.
Audit Guideline:
buried or surface pipelines such as site security and anti-corrosion programs.
• Check for spills along right-of-way, erosion control, slash disposal and vegetation
control.
• Inspect pipeline systems for such items as placement of shut-off valves, marked
facilities, erosion control, vegetation management and spill cleanup.

REFINERIES
REFIN 13.0 Product Storage
Audit Protocol:
Oil and gas products shall be stored and labelled properly. All storage and loading
Audit Guideline:
• Verify the engineering designs and operating procedures, provide tank storage
integrity and that all loading facilities are designed to prevent or reduce accidental
discharge.
technology.
of such systems.

REFINERIES
REFIN 14.0 Vapour Recovery Units
Audit Protocol:
Audit Guideline:
units.

REFINERIES
REFIN 15.0 Chemical and Hazardous Material Storage and Handling.
Audit Protocol:
The handling, storage and use of chemicals in refining operations shall be done such
that impact to the environment is minimized. Hazardous materials shall also be
handled properly. Chemical and hazardous materials shall be stored and labelled
properly.
Audit Guideline:

consumed.
d) Tanks larger than 500-1000 barrels should be diked or an equally effective

means identified to prevent excessive contaminations to the surrounding
area in the event of a major spill or tank fracture.



product.


REFINERIES
REFIN 16.0 Site Maintenance
Audit Protocol:
Facilities shall be properly maintained. Equipment should be inspected regularly.
Audit Guideline:

location.

and disposed of.
overflows.
• Review operator training.

REFINERIES
REFIN 17.0 Access Roads
Audit Protocol:
New construction:

construction. Access roads (refinery approach and trucking terminal area) shall be
constructed in a manner that prevents erosion, drainage problems and additional
disturbance to the environment.
Existing access roads:
Access roads should be maintained in a manner that prevents erosion, drainage

problems and additional disturbance to the environment.
Audit Guideline:
New construction:
• Verify that construction guidelines are in place and pertain to protection of the
environment.
• Verify that the road surface is compatible with heavy loads.
• Verify that culverts of the right size are adequately placed along the road to handle
water volume.
• Verify that encroachment of vegetation is controlled in order to maintain good

visibility. Signs should be used to control speed.
• After a road has been constructed, verify that sides of roads are revegetated.
Existing access roads:
• Verify that any road maintenance programs do not utilize harmful chemical
management programs.
• Verify that dust is controlled.

• Inspect general conditions of roads to detect any drainage or erosion problems.

Existing culverts should be kept clear of blockage. All signs of drainage problems
or erosion should be noted and the cause repaired immediately.

REFINERIES
REFIN 18.0 Access Control
Audit Protocol:
Access control is usually not an issue with respect to refineries; however, access
control shall be implemented for safety and to minimize additional disturbances to the
environment where local population, livestock and wildlife encroachment become a
problem at an unfenced refinery.
Audit Guideline:
• Inspect the site for appropriate use of fences, signs or gates.
required.

REFINERIES
REFIN 19.0 Perimeter Berms
Audit Protocol:
Perimeter berms are seldom if ever used at refineries. On occasion they may be
strategically installed along a low section of the refinery site’s natural topography to
contain or divert (using interception ditches or swails) surface runoff in order to
minimize/eliminate a pollution release from going off-site to contaminate the adjacent
environment.
Audit Guideline:
• Verify use of berms and inspect berm areas. Identify proper berm design and
placement. Berms should be constructed from an impermeable material. They
should be of a design and size to contain amounts of rainfall established by
meteorological statistics for the area.
• Verify that the berm containment system has interception ditches or swails to divert
surface runoff to an industrial runoff or surface retention pond for disposal.
as needed.

REFINERIES
REFIN 20.0 Housekeeping
Audit Protocol:
equipment.
Audit Guideline:
gates should be constructed as needed and maintained.

farmland, etc.

REFINERIES
REFIN 21.0 Flare Stacks
Audit Protocol:
Audit Guideline:
land.

REFINERIES
REFIN 22.0 Release of Hydrocarbons
Audit Protocol:

Audit Guideline:
so.

• Verify that any release of hydrocarbons has been properly decontaminated.

REFINERIES
REFIN 23.0 Noise
Audit Protocol:
The impact of refining operations’ noise on local residents and workers shall be
minimized.
Audit Guideline:
monitoring of the wellsite is being done.

REFINERIES
REFIN 24.0 Drainage and Erosion
Audit Protocol:
by the operation, shall be removed or remedied as soon as possible.
Audit Guideline:


REFINERIES
REFIN 25.0 Surface Retention/ Holding/ Industrial Runoff Ponds
Audit Protocol:
Ponds shall be used to collect surface runoff, process liquids (potentially oily water)
and industrial wastewater to obtain and analyze representative grab samples of the
liquid in each pond for concentrations of contaminates before releasing, treating or
disposing.
Audit Guideline:
• Verify that pond and associated equipment design is in compliance with API
procedures and regulations or any other acceptable standards.
• Verify that ponds are constructed from a recompacted bentonite or in-situ clay with
-7
a hydraulic conductivity no greater than 1x10 centimetres per second or such other
impermeable material. Otherwise, ponds must have an impermeable liner or be
constructed of cement.
• Verify that ponds are situated to match the natural drainage of the site topography
and graded to minimize erosion and flooding.
• Verify that ponds are designed to control the rainfall established from
meteorological statistics for that area.
• Verify that pond design and operations incorporate facilities or procedures to

separate floatables such as oil (i.e., skimming, floatation, separation, treating and
pumping equipment).
• Verify that separate ponds are used for each type of fluid stream collected (i.e., oily
water pond, surface runoff pond, etc.). Measures should be taken to avoid cross-
contamination between ponds.
• Verify that pond levels are monitored and pumped off routinely to ensure no
overflow occurs.

REFINERIES
REFIN 26.0 Surface Water Monitoring
Audit Protocol:
Audit Guideline:

REFINERIES
REFIN 27.0 Soil Sampling and Monitoring
Audit Protocol:
program).
Audit Guideline:

REFINERIES
REFIN 28.0 Groundwater Monitoring
Audit Protocol:

Audit Guideline:
compliance.
information.
unauthorized entry.

properly.

REFINERIES
REFIN 29.0 Water Release
Audit Protocol:
surrounding land.
Audit Guideline:

the water surface.
of at an approved oil field waste disposal facility or treated and then discharged on

REFINERIES
REFIN 30.0 Gaseous Emissions
Audit Protocol:
Gaseous emissions in refining facilities shall be controlled and minimized.
Audit Guideline:
gaseous emissions have been identified and provided as guidelines for
• Prior to the field inspection, review records including air quality reports and verify
compliance.
• Determine if any measures are taken to minimize gaseous emissions occurring on-
site. The main air quality parameters of concern are SO2, H2S and NOx. Ozone,
carbon monoxide, carbon dioxide, hydrocarbons and ammonia are also a concern.
Ways to reduce gaseous emissions may include:
•
a) Increasing efficiency per unit of energy produced
b) Reducing sources of emission in all operations
c) Air quality monitoring, reporting and tracking systems (measured quantities
of emissions, reports, etc.)
• Verify if existing regulations require monitoring and specific reports. Check

compliance reports and verify emission rates are not exceeded. Monitoring and
reporting requirements may include:
a) Standard site criteria for monitoring

b) Documentation
c) Total sulphation calculations
d) Hydrogen sulphide calculations
e) Water soluble fluoride calculations
f) Dustfall calculations
g) Soil pH monitoring procedures
h) High volume sampling procedures
i) Vegetation fluoride analysis
j) Quality assurance procedures
k) Heavy metals analysis
l) Source emission survey report format

REFINERIES
REFIN 31.0 Air Quality Monitoring
Audit Protocol:
Audit Guideline:
calibrated.
require them.

REFINERIES
REFIN 32.0 Release/Spill Prevention
Audit Protocol:
Audit Guideline:

be achieved by:

drills.
and bases. (See Product Storage and Loading section)
procedures.
• Verify the utilization of API oil skimmer systems. Review engineering designs and
identify any modifications. Verify if water analysis is undertaken at water discharge
points.

• Inspect all API oil skimmer units to determine the effectiveness of oil recovery.
Review water analysis to assess the success of these systems. Record any spills
or evidence of hydrocarbons in the water discharge streams.

REFINERIES
REFIN 33.0 Spill/Release Contingency Plans
Audit Protocol:
Refining facilities shall have a spill/release contingency plan. All personnel shall be
familiar with the contingency plan
Audit Guideline:


locations, leak isolation, spillage/release containment, watercourse
protection, etc.
i) Guidelines for post-repair inspection and returning the line to service.
retention booms, sand bags or temporary curbing devices, recovery pumps and
collection hoses, recovery tank trucks and protective equipment.

training provided.

REFINERIES
REFIN 34.0 Emergency Response
Audit Protocol:
Refining facilities shall have an Emergency Response Plan to protect the public,
employees, the environment and property should an emergency occur. It is necessary
to provide all employees with a systematic presentation of communication practices
and procedures to be followed in an emergency.
Audit Guideline:


Plan should contain the following information:


news media.

REFINERIES
WASTE MANAGEMENT
REFIN 35.0 Disposal of Refinery Wastes
Audit Protocol:
The disposal of waste materials shall be done in an acceptable manner according to

existing local regulations.
Audit Guideline:
The ARPEL documents “Guidelines for the Management of Petroleum Refinery Liquid
Wastes” and “Guidelines for the Management of Refinery Solid Wastes” can be used
as guides in the conduct of audits regarding waste disposal methods.
• Verify that wastes are disposed of properly. The following disposal guidelines for
refinery wastes are recommended:
SOURCE/WASTE Preferred Disposal Methods
Storage and Handling
• Tank bottoms - Leaded gasoline Weathering of sludge, followed

by secure landfill; chemical
fixation.
• Tank bottoms - Unleaded gasoline Landfarming; chemical fixation,

secure landfill; incineration.
• Tank bottoms - Crude Oil Oil recovery on site or off site;

landfarming; incineration;
secure landfill; chemical
fixation.
• Tank bottoms - distillates Landfarming; secure landfill;

chemical fixation.
• Tank bottoms - Decant Oil Landfarming; incineration;

secure landfill.
• Tank bottoms - bunker Recycling; reclaiming;

landfarming; secure landfill;
incineration.

• Tank bottoms- Slop oil Reclaiming of oil; recycling of

Fluid Catalytic Cracking Unit;
landfarming; incineration.
• Asphalt waste Recycle; reuse; incineration.
Process Units
• Desalter clean out sludges Landfarming; oil recovery;

secure landfill.
• Caustic solution phenolic Reclamation to a chemical plant;

reuse by a pulp mill; disposal wells; desalter pH
adjustment; neutralization with
acid or flue gas before injection
to wastewater treatment;
controlled injection to
wastewater treatment plant as
dictated by effluent limits.
• Caustic solution sulphidic Reclamation to a chemical plant;

to wastewater treatment plant
as
dictated by effluent quality
limits.
• HF acid (Neutralized) Chemical fixation; secure

landfill; wastewater treatment.
• H2SO4 acid (spent) Reclaiming; neutralization and

chemical fixation.
• Clay (spent) Sanitary landfill; landfarming;

incineration before sanitary
landfilling.
• Activated carbon (spent) Recycling to supplier or sanitary

landfill.
• Amine filters Sanitary landfill; landfarming.

• Off specification sulphur Sanitary or secure landfill;

recycling or reuse; incineration.
• Furfural (spent) Incineration.
• Glycol (spent) Incineration; chemical fixation,

wastewater treatment system
(with a biotreater).
• Coke fines Sanitary or secure landfill

depending on heavy metals
content; reuse as a fuel off site;
chemical fixation.
• Stretford solution Wastewater treatment system.
• FCUU (Fluid Catalytic Cracking Unit) Recycle; sanitary landfill;

catalyst (spent) chemical
fixation; reuse as feed to
cement kiln.
• FCUU dust Recycle; sanitary landfill

(wetted down); chemical
fixation; reuse as feed to
cement kiln.
• Poly unit catalyst (spent) Secure landfill; landfarming;

chemical fixation; nutrient for
wastewater treatment plant.
• H2 plant catalyst (spent) Reclaiming of metals; chemical

fixation; secure landfill.
• Reformer catalyst (spent) Reclaiming by supplier.
• Hydrocracker catalyst (spent) Chemical fixation; reclaiming;

secure landfill.
• Hydrotreater catalyst (spent) Reclaiming; chemical fixation;

secure landfill.
• Merox catalyst (spent) Reclamation to a chemical plant;

to wastewater treatment.

• Copper chloride catalyst (spent) Secure landfill.

• Claus plant catalyst (spent) Sanitary landfill.
• HF Acid soluble polymer Retrofit process and eliminate at

source; lime neutralization and incineration; wastewater
treatment system.
Utility Plant
• Cooling tower sludge Chemical fixation; chromate

recovery; secure landfill.
• Lime sludge Reuse in cement plant; sanitary

landfill; landfarming.
• Anthracite filters Sanitary landfill; incineration.
• Spent zeolite resins Sanitary or secure landfill.
• Sand from filters Landfarming; secure landfill;

sanitary landfill.
• Ion exchange regenerant Wastewater treatment.
Wastewater Treatment Plant
• Gravity separator sludge Landfarming; recycle to Coking

Unit; approved industrial
incineration; secure landfill.
• Biotreater sludge Incineration; chemical fixation;

landfarming; sanitary landfill.
• Storm pond silt Chemical fixation; landfarming;

landfilling.
• Sump sludge Landfarming; recycle to Coking

Unit; approved industrial
incineration; secure landfill.
Miscellaneous
• Maintenance wastes:

- Refractory brick Secure landfill or sanitary

landfill.
- Oil contaminated soil Landfarming; secure landfill.
- Used drums Send drums to reclaimer; rinse,

crush and sell for scrap;
storage I dry shelter.
- PCB wastes Secure indoor storage; secure

outdoor storage.
- Demolition scrap Sanitary landfill; reclaiming.
- Heat exchanger cleanings (solids) Secure landfill; chemical

fixation.
- Heat exchanger cleanings (liquids) Wastewater treatment after

neutralization; chemical
fixation; disposal wells;
incineration of organics.
• Laboratory Wastes
- Spent chemicals (liquid) Aqueous: to an enclosed

vented settling tank with liquid
effluent to wastewater treatment
system.
Non-aqueous, non-hazardous: to
an enclosed and vented holding tank for pump out and
reprocessing.
Hazardous chemicals: to a
segregated vented holding tank
for suitable treatment
depending upon chemical
composition.
- Spent chemicals (solid) Secure landfill.

REFINERIES
WASTE MANAGEMENT
REFIN 36.0 Exposure to Toxic Substances
Audit Protocol:
Proper handling and storage of toxic substances shall be performed to minimize harm
to people and the environment.
Audit Guideline:
• Review records and verify that current occupational benzene and other toxic
substances exposures have been adequately evaluated to determine compliance
with existing local regulations. Determine if there are any benzene exposure
monitoring survey reports.
• Verify through interviews that personnel are aware of the dangers of hazardous
substances and materials. Verify that proper handling procedures are used and
personal protective equipment is available.

REFINERIES
WASTE MANAGEMENT
REFIN 37.0 Sewage Effluent and Wastewater Treatment
Audit Protocol:
No effluent shall be discharged unless it meets minimum requirements of existing local

regulations. Regulations usually limit the deposits of oil and grease, phenols,
sulphide, ammonia nitrogen, total suspended solids and the pH levels. The
wastewaters from the various units should be diverted to the wastewater treatment
facility.
Audit Guideline:
• Verify that conditions of regulations regarding sewage disposal/treatment facilities

are followed. A refinery may be given an exemption from the requirements for liquid
effluent once-through cooling water if treatment is provided in facilities outside the
refinery (such as municipal sewage systems). This exemption may be granted if
the off-site facility provides treatment equivalent to that required by the regulations
and guidelines.
• Verify method of sewage and wastewater treatment/disposal. The best practicable

treatment technology to the liquid effluents can be described as:
- Sour water stripping for ammonia and sulphide removal;

- Primary separation followed by;
- Intermediate treatment (such as air flotation) followed by;
- Secondary treatment (such as biological treatment)
- Final effluent clarification if required; and
- Segregation and treatment of stormwater if required.
Overloading the system hydraulically reduces the effectiveness of pollutant removal.

REFINERIES
WASTE MANAGEMENT
REFIN 38.0 Specific Effluent Monitoring Requirements
Audit Protocol:
Refinery plants shall comply with monitoring requirements according to existing local
regulations.
Audit Guideline:
• Verify that the facility complies with monitoring requirements. Regulations may
require that a number of pollutants be monitored to demonstrate that the effluent
treatment system is being operated consistently.
The following pollutants may be required to be monitored by refinery plants:
Daily monitoring:
- Total suspended solids

- Phenolics
- pH and total organic carbon
Three times per week basis:
- Ammonia-nitrogen
- Organic carbon
- Oil and grease
- Sulphides
- Volatile aromatics (benzene, toluene, xylenes, ethylbenzene)
- Zinc and chromium
Monthly:
- aromatic hydrocarbons
- chlorinated volatiles
- acids
- metals
- cyanide

REFINERIES
WASTE MANAGEMENT
REFIN 39.0 Laboratory Analytical Methodology
Audit Protocol:
Refinery plants shall use proper laboratory analytical methodology according to existing
local regulations.
Audit Guideline:
• Verify that proper laboratory analytical procedures are used and comply with
existing local regulations.
• Inspect laboratory facilities. Laboratory wastes shall be disposed of properly (see

Disposal of Refinery Wastes).

REFINERIES
WASTE MANAGEMENT
REFIN 40.0 Waste Management Plan
Audit Protocol:
Refining facilities shall have a Waste Management Plan to ensure each facility knows
what wastes it produces and how to handle and dispose of those wastes properly.
Audit Guideline:
disposal.
the waste.

REFINERIES
WASTE MANAGEMENT
REFIN 41.0 Disposal of General Solid Wastes
Audit Protocol:
Audit Guideline:
properly.

are lined.
of-way.
optimum efficiency.

REFINERIES
WASTE MANAGEMENT
REFIN 42.0 Asbestos
Audit Protocol:

limits.
Audit Guideline:
methods.

materials.

REFINERIES
WASTE MANAGEMENT
REFIN 43.0 Sewage Lagoons
Audit Protocol:
Audit Guideline:
are recommended:

e) Must be fenced.
i) Berms must be minimum 1V:3H.
j) Berms must be sufficiently wide at top to allow for equipment and personnel.


REFINERIES
WASTE MANAGEMENT
REFIN 44.0 Recycling
Audit Protocol:
Refining facilities shall have an effective approach to waste management. Recycling is

a key component to conserving resources and reducing wastes. Recycling assists by
either reducing or eliminating the quantity of waste which requires disposal, thereby
reducing potential contamination to the environment. The Waste Management Plan
should contain recycling information.
Audit Guideline:
implemented.


REFINERIES
WASTE MANAGEMENT
REFIN 45.0 Water Recycling and Reuse
Audit Protocol:
water.
Audit Guideline:

REFINERIES
WASTE MANAGEMENT
REFIN 46.0 Disposal of Oil Based Wastes
Audit Protocol:
Audit Guideline:

d) Solvents.
e) Lube oil.


authorities.

burning.

landfill site.
available:
The preferred reclamation option is: after as much oil as possible has been picked

REFINERIES
WASTE MANAGEMENT
REFIN 47.0 Filters
Audit Protocol:
Audit Guideline:
entrained liquids can be disposed of at approved disposal wells. To properly drain
a filter, it must be stored in the screened container for a minimum of three days at
room temperature. Entrained fluids must be kept segregated for recycling or
disposal. It must be determined through sampling if the filter is a dangerous oilfield
waste. Examples of filters that may be a dangerous oilfield waste are: glycol filters,
leachate and entrained liquids, air pollution control filters, sulphinol filters, lub oil
filters, methanol filters, gas filters and produced or process water filters.



REFINERIES
WASTE MANAGEMENT
REFIN 48.0 Disposal Wells
Audit Protocol:
The operation and maintenance of disposal wells shall be carried out so that impact to
the environment is minimized.
Audit Guideline:
• Determine if there is a standard procedure in place to detect any releases from the
disposal system.
• Inspect disposal well locations. Pressure of disposal must be monitored. Look for
signs of spills.
• Inspect location of disposal lines for deep well disposal. They should be located
water disposal wells are susceptible to corrosion, therefore leaks along the pipeline
• Verify that the disposal zone is at a depth not less than 600 metres.

REFINERIES
WASTE MANAGEMENT
REFIN 49.0 Sulphur Handling
Audit Protocol:
Proper handling, storage and transportation of sulphur is required.
Audit Guideline:
• Verify that appropriate precautions are taken when handling sulphur. Personnel
should take measures to alleviate or mitigate the following major issues:
a) Potential human hazards.
b) Sulphur dust producing sulphuric acid when it reacts with water.
c) Sulphur spills when pouring molten sulphur into tank cars for transportation
or onto sulphur blocks for storage.
d) Handling runoff and drainage from sulphur storage areas.
e) Reclamation of sulphur contaminated soils.

REFINERIES
REFIN 50.0 Reclamation Plan
Audit Protocol:
capability.
Audit Guideline:
The ARPEL document “Guidelines for Decommissioning and Surface Land

Reclamation at Petroleum Production and Refinery Facilities” can be used as a guide
in the conduct of audits for the Abandonment and Reclamation section.
cost control.

- site dismantling
- removal of tanks
- decontamination
- soil remediation
- recontouring
- revegetation

REFINERIES
REFIN 51.0 Site Dismantling
Audit Protocol:
Audit Guideline:
or pads, may be left on site if the landowner and reclamation officer are in
agreement or if the landowner agrees and it does not interfere with the reclamation
of the site.
disposal.
• Verify that after all liquid has been removed from the vessels, flowlines, and tanks,
and that all equipment from the site is removed. Ensure any residual fluids which
remain are collected for disposal.
utility company.
• Verify flowlines are cut-off and capped a minimum of 1m below grade.
• Verify appropriate handling of any water wells on site.

REFINERIES
REFIN 52.0 Tanks Removal
Audit Protocol:
Audit Guideline:
tanks openings.
collected.

REFINERIES
REFIN 53.0 Decontamination
Audit Protocol:
Audit Guideline:


considered:

Landspread on site.
Solidification.
Soils leaching.
• Inspect decontamination projects or completed programs.

REFINERIES
REFIN 54.0 Soil Reclamation
Audit Protocol:
Audit Guideline:

REFINERIES
REFIN 55.0 Recontouring
Audit Protocol:
All refinery sites being decommissioned and reclaimed shall be restored to a capability
equal or better than the surrounding current land use. This includes restoring the
original drainage patterns and ensuring that the site does not hold water.
Audit Guideline:
• Confirm that any culverts that were installed on access roads have been removed.
slopes.
• Verify topsoil was distributed as evenly as possible.

• Verify that all earthen pits and ponds have contaminates removed and properly
disposed of before being backfilled.
• Inspect buried earthen pit and pond locations for signs of settlement. Earthen pits
and ponds which are backfilled will settle - mound 50-100 cm to compensate.

REFINERIES
REFIN 56.0 Revegetation
Audit Protocol:
land use.
Audit Guideline:
area.
or no maintenance.

• Determine if the weed growth is acceptable or if a management program is needed.

REFINERIES
REFIN 57.0 Reclamation Assessment
Audit Protocol:

shall be undertaken to assess the success of a Reclamation Plan. Upon this
assessment, modify the Reclamation Plan if required.
Audit Guideline:
• Verify that the soil was appropriately remediated and recontoured.
• Verify that any soil amendments are appropriate for the site and applied correctly.
adjacent land.
• Verify that after operations are completed, the site is restored, as far as practical, to
a condition compatible with existing land use, and that the land capability is equal
to or better than predisturbance conditions.

CHAPTER 13.0

CHAPTER 13.0 OFFSHORE OPERATIONAL AUDIT GUIDELINES
13.1 Seismic
13.2 Drilling
13.3 Production

Auditing offshore facilities is somewhat more difficult that shore-based facilities as the
impacts for the operations on the surrounding environment are largely impossible to
detect or evaluate by visual means. Most discharges are below the surface and some
at considerable depth below the surface. In fact, most discharge depths are modelled
to a depth where they will not resurface.
For offshore facilities, visual observations must be augmented by inspection of analysis

of discharge systems as well as the results of environmental monitoring. Monitoring of
selected biological species and chemical analysis of sediments will indicate if the
operational discharges, even if in compliance, are having some effect.
These components apply to audits of facilities where there is an interest in looking

beyond compliance such as liability audits.

13.1 Seismic

13.1 SEISMIC OPERATIONS

2.0 Environmental Planning
3.0 Consultation and Liaison
4.0 Seismic Surveys
5.0 Intertidal Areas
6.0 Vessel Operations
8.0 Spill Response
9.0 Chemical Handling and storage
10.0 Waste Management
11.0 Abandonment/Cleanup Operations

OFFSHORE OPERATIONS
SEISMIC
SEIS 1.0 Regulatory Environmental Authorization
Audit Protocol:
be reviewed and followed.
Audit Guideline:
• Audits of this activity are most effective if conducted towards the end of the program
and before demobilization. If regulatory personnel will be inspecting the exploration
work, attempt to coordinate that site visit with the commencement or termination of
the audit.
regulatory authorizations were obtained prior to the start of any exploration
activities. Record permit/license numbers and verify information in the field.

permits/licenses. Special attention should be paid to those conditions for Protected
and Conservation Areas, Indian Reserves, existing pipelines, especially in 3D
surveys. Compare maps showing locations of the lines and anchoring logs with
permit restrictions.
• Verify through interviews that the supervisory personnel are aware of any
restrictions etc. and has provided this information to the contractor. Verify that
those restrictions are enforced with the contractor and personnel, and that the local
government has been contacted about the project prior to the operations start.

OFFSHORE OPERATIONS
SEISMIC
SEIS 2.0 Environmental Planning
Audit Protocol:
The planning of exploration operations shall be undertaken in a manner that will

anticipate problems and minimize the effects of the operations.
Audit Guideline:
• Geophysical programs are generally localized and of limited duration. Operations in

shallow/near-shore waters tend to have greater potential for environmental impacts.
Verify that local authorities, experts and/or agencies were contacted for information
early in the planning process. The International Association of Geophysical
Contractors has developed a set of operating guidelines that were prepared to
promote consideration and conservation of the environment during geophysical
operations.
• Verify that environmental concerns (i.e., recognized habitats for marine mammals,
minimizing acoustic disturbance to small cetaceans, effects of energy sources,
recording cables and anchoring on coral reefs etc. ) were incorporated during the
planning stage of the operations.
• If the operations have taken place, or are taking place, in near-shore areas, review
project records and determine if an assessment of the environmental resources in
near-shore operating areas was undertaken.
• Existing commercial and recreational activities are generally compatible with

geophysical operations. If the operations have taken place, or are taking place, in
near-shore areas, verify that attempts have been made to schedule operations to
avoid the time periods of high commercial/subsistence fishing and significant
recreational activities.
• Verify that a log book or other method of systematically recording environmental

observations was available to the personnel conducting the survey.
• Assess if steps have been taken to use the least hazardous solvents or other
hazardous materials.
• Verify that the base camp and existing fly camp were built according to the
recommended wastewater regulations.

OFFSHORE OPERATIONS
SEISMIC
SEIS 3.0 Consultation and Liaison
Audit Protocol:
During seismic operations, stakeholders such as other marine users, local

communities and coastal business owners shall be consulted as appropriate.
Audit Guideline:
Educating the general public during the planning stage can minimize misperceptions
about the nature of the activity and potential impacts. Those not in the industry are not
always familiar with the operational constraints, time scales and commercial pressures
of the exploration and production industry. Local customs, traditions and religious
beliefs should be considered when planning and conducting operations.
Communication with area users can improve relations between all parties involved.
Operators should be aware that liaison with the fishing industry requires a proactive
approach for the development of a harmonious working relationship..
• Verify if any consultation and liaison has been undertaken with the local
communities/groups, the fishing industry, environmental groups and other external
parties. Determine to what extent the issues raised by these groups, during
planning and operations, have been incorporated into planning and operations or
otherwise resolved.
• Verify that if navigation aids have to be placed onshore to support marine seismic
vessels, local authorities are consulted in advance.

OFFSHORE OPERATIONS
SEISMIC
SEIS 4.0 Seismic Surveys
Audit Protocol:
Seismic surveys shall be undertaken so that disturbance to the environment is

minimized.
Audit Guideline:
• Verify method of seismic survey operations; explosives as an energy source are

likely to have more impacts than air gun sources. Where explosives are used pay
particular attention to the mitigation measures (such as progressive power build-up
in energy sources) to protect fish, marine mammals and coral reefs and any
residual impacts on these resources.
• Verify if the lowest possible energy levels are used to achieve the objectives of the
survey.
• Determine if there has been any interruption of commercial or subsistence fishing

activities and what plans were in place to deal with this situation. Where
compensation is an option or requirement, verify that claims have been settled.
• Verify if any recording and reporting of environmental observations took place.
• Verify if personnel are trained to take appropriate action if marine mammals move
into the area of operation.
• Verify that reasonable efforts were made to retrieve equipment lost overboard as
soon as possible after the loss occurs. Determine if the loss was reported to the
appropriate regulatory agency.

OFFSHORE OPERATIONS
SEISMIC
SEIS 5.0 Intertidal Areas
Audit Protocol:
Where seismic operations are conducted in intertidal areas special precautions shall
be taken as dictated by the sensitivity of the area.
Audit Guideline:
Tidal marshes, mud flats and mangroves can be damaged through changes in salinity,
vegetation and erosion resulting from geophysical operations.
• Determine if appropriate precautions were used to protect the integrity of the

intertidal areas; did lines follow waterways (tidal channels) or bypass stands of
vegetation, was waterborne transportation used instead of creating new land
access, was a barge mounted base and quarters used in preference to shore-
based facilities, were speed limits in effect for watercraft to reduce erosion potential
of navigable channels, etc..
• Verify that care was taken when using vibroseis vehicles, water tenders and other
equipment to prevent undue interference with habitats, amenities and commercial
interests.
• Verify that the use of drilling mud on the foreshore for drilling shot holes for
explosive charges, has been discussed with, and approved by, relevant
authorities.
• Verify that inspection programs were in place and used to ensure that no debris is
left on the shore.
• Verify that the proper authorities were notified if a suspected archeological sites
were encountered.

OFFSHORE EXPLORATION
SEISMIC
SEIS 6.0 Vessel Operations
Audit Protocol:
The survey vessel and auxiliary craft shall operate according to local regulations and in
a manner that minimizes impacts on the environment.
Audit Guideline:
• Inspect vessels and, if possible, observe routine operations to determine if care has
been taken to minimize the possibility of spills and other unacceptable discharges
of fuels, oils and solvents.
• Where vessels are operating in near-shore or inter-tidal areas, verify that operating
procedures include instructions respecting speed, routes etc. that are designed to
reduce the potential for erosion, contact with marine mammals and commercial or
subsistence fisheries.

OFFSHORE OPERATIONS
SEISMIC
SEIS 7.0 Spill Prevention
Audit Protocol:
Measures shall be taken to prevent the occurrence of chronic and accidental spills.
Audit Guideline:
• Verify that drip trays or other containment system is placed under equipment
containing fuel and/or lubricating oil and cable oil and that the fluids collected are
directed to sumps or separators where they are collected for transport to an
approved disposal site.
• Where significant volumes of oils/solvents are being collected, determine if there

are appropriate high level alarms on the sumps or separators.
• Verify that procedures for refuelling operations are posted and, if possible, observe
fuel transfer operation.

OFFSHORE OPERATIONS
SEISMIC
SEIS 8.0 Spill Response
Audit Protocol:
Seismic operations shall have a spill contingency plan. All personnel shall be familiar
Audit Guideline:
• Verify that response equipment is appropriate for the products that could be spilled.
• Verify that personnel are trained in the use of the clean-up equipment and any
personal protective equipment.
• Verify that adequate supplies of sorbent materials are available at locations where
spills could be expected to occur.
• Verify that reporting procedures are posted, and that if a spill did take place, were
the appropriate reports filed.
• Where a spill has taken place, verify that sorbents and other clean-up wastes were
disposed of in accordance with regulations and the contingency plan.

OFFSHORE OPERATIONS
SEISMIC
SEIS 9.0 Chemical Handling and Storage
Audit Protocol:
Chemicals shall be properly stored and handled to minimize pollution risk.
Audit Guideline:
• Inspect storage areas. Verify that storage procedures comply with those specified
by the manufacturer.
• Verify that safety information provided by the manufacturer is available to the crew.
• Verify that a tracking system exists that records purchases, usage, storage, spills
and disposal. If manufacturers package is damaged ensure products are
transferred to appropriate containers, marked accordingly and the transfer noted in
the records.

OFFSHORE OPERATIONS
SEISMIC
SEIS 10.0 Waste Management
Audit Protocol:
Disposal of wastes shall be carried out in a manner that does not impair environmental
quality.
Audit Guideline:
• Verify that a waste management plan exists and that waste are handled
accordingly.
• Where no plan exists, verify that hazardous wastes are segregated from domestic
and other benign wastes.
• Verify that hazardous material wastes are handled in accordance with the
manufacturers directions and/or local regulation.
• If incineration is an option ensure through interview that personnel are aware of

which wastes should not be burned.

OFFSHORE OPERATIONS
SEISMIC
SEIS 11.0 Abandonment /Cleanup Operations
Audit Protocol:
Proper cleanup operations shall be implemented upon completion of seismic

operations.
Audit Guideline:
• Inspect the area and all shorebased facilities to verify that proper cleanup
operations have been implemented. Pay particular attention to shorelines and
coastal waterways. An understanding of local tidal currents will assist in locating
any floating wastes that have come to shore.
• Ensure that any wastes sent to local facilities have been properly transported and
that disposal has not caused any problems.



4.0 General Operating Procedures
8.0 Spill Response
9.0 Chemical Handling and Storage
11.0 Wastewater Discharges
12.0 Sampling and Analysis of Discharges
13.0 Well Suspension and Abandonment

OFFSHORE OPERATIONS
DRILLING
DRILL 1.0 Regulatory Environmental Authorization
Audit Protocol:
commencement of any drilling program. Special conditions and restrictions shall be
reviewed and enforced.
Audit Guideline:
Drilling programs may be limited to a single well, a multiple well program or be part of
a larger field development. Therefore, the drilling may take place within a few months
or over several years. Audits on single well programs are most effective if conducted
towards the end of the well particularly if the well is to be tested. Audits on multi-well
programs can be conducted after the first well and again towards the end of the
program if more than one visit is possible. If only one visit is possible plan the audit for
the latter stages of the program. In the context of a multi-well program reports of
environmental or operational problems associated with drilling could be the trigger for
an audit. Where simultaneous drilling and production operations are planned it may
make sense from logistic and impact assessment perspectives to conduct an audit of
both operations during the same trip.
• If regulatory personnel will be inspecting the exploration work, attempt to coordinate

that site visit with the commencement or termination of the audit.
• Review the records to ensure that all required permits, licenses and regulatory
authorizations were obtained prior to the start of any drilling activities. Record
permit/license numbers and verify information in the field.

permits/licenses, considering environmental requirements for offshore drilling
operations.
restrictions etc. and has provided this information to the contractor. Verify, through
interview, documentation and discussions with the regulators, that those
restrictions were followed by the contractor and personnel.

OFFSHORE OPERATIONS
DRILLING
DRILL 2.0 Environmental Planning
Audit Protocol:
The planning of exploration operations shall be undertaken in a manner that will

anticipate problems and minimize the effects of the operations at offshore locations,
vessel routes and shore bases.
Audit Guideline:
• Drilling programs, even multi-well and programs associated with field development,
occupy relatively small portions of the ocean. Well planned and well run programs
should have little effect on the marine environment and are generally compatible
with other marine activities such as shipping and fishing. Operations in
shallow/near-shore waters tend to have greater potential for environmental impacts.
The E&P Forum has developed operating guidelines for operations near mangroves
and coral reefs that were prepared to promote consideration and conservation of
the environment during drilling and production operations. Verify that local
authorities, experts and/or agencies were contacted for information early in the
planning process.
• Verify that environmental concerns (i.e., recognized habitats for marine mammals,
seabird populations, migration routes etc.) were incorporated during the planning
stage of the operations. If the operations have taken place, or are taking place, in
near-shore areas, review project records and determine if an assessment of the
environmental resources in near-shore operating areas was undertaken.
• Existing commercial and recreational activities are generally compatible with drilling
operations. If the operations have taken place, or are taking place, in near-shore
areas, verify that attempts have been made to schedule operations to avoid the time
periods of high commercial/subsistence fishing and significant recreational
activities.
• Verify that a log book or other method of systematically recording environmental

observations was available to the personnel.
• Assess to what extent steps have been taken to use the least toxic mud systems
and reduce the use of other hazardous materials.
• Verify if wellsites are supported by pollution control resources such as onsite

pollution control vessels, surveillance aircraft, etc.

OFFSHORE OPERATIONS
DRILLING
DRILL 3.0 Consultation and Liaison
Audit Protocol:
During drilling operations, stakeholders such as other marine users, local communities
and coastal business owners shall be consulted as appropriate.
Audit Guideline:
Educating the general public during the planning stage can minimize mispercetions
approach for the development of a harmonious working relationship.
otherwise resolved.

OFFSHORE OPERATIONS
DRILLING
DRILL 4.0 General Operating Procedures
Audit Protocol:
Drilling programs shall be conducted so that disturbance to the environment is

minimized.
Audit Guideline:
Environmental impacts from drilling programs are primarily associated with large oil
spills from a loss of well control and the discharges of drilling mud and cuttings. The
drilling program is dictated by a number of factors including the type of well being
drilled (exploration, delineation, development, high angle, horizontal, etc.) and
anticipated hole conditions. Most of these systems have very low toxicities and can be
discharged in all but the most shallow waters with negligible effect. Oil-based muds
(OBM’s) however cannot be discharged directly to the seabed or water column as even
the low toxicity systems may leave sheens and could result in tainting of fish or
accumulations of hydrocarbons in the sediments below and adjacent to the drilling site.
Where OBM’s are used the bulk muds cannot be dumped when changing systems and
the cuttings from these portions of the hole must be treated prior to discharge.
Generally cuttings can be left where they fall as they are dispersed over time.
However, depending upon local seabed topography and in locations where sediments
accumulate and dredging is required to maintain navigation channels, it may be
reasonable to return cuttings to shore or remove to a dispersing area. However, there is
a high safety and pollution risk in transferring large quantities of cuttings from offshore
platforms and drilling rigs to the shore. It may be necessary in rare cases to disperse
cuttings some distance away form the rig by means of flexible hoses. Grinding and re-
injection into other rock strata, and the return to land of cuttings for disposal has been
considered but it is seen as having only limited application. and there is a lack of
suitable onshore facilities and sites for disposal of the large amounts of oiled cuttings
that can be produced annually.
ARPEL has prepared a guideline for the Treatment and Disposal of Exploration and
Production Drilling Wastes. Part II of that document deals with offshore operations.
• Prior to the field inspection, verify the required regulatory procedures to properly
dispose of drilling fluids and solid wastes.
• Where OBM’s have been used verify through inspection of records and interview,
that the cuttings washing equipment was maintained on a regular basis and that
discharges were within specified limits.

• Where OBM’s have been used, verify through inspection of records and interviews
that there was no dumping of used or unused mud. Verify with rig and shore-based
personnel that mud was shipped to shore, received at shore and treated/disposed
according to procedures and local regulations.
• Verify that well control systems were tested in accordance with procedures and that
all identified problems were corrected prior to commencing or resuming drilling
operations.

OFFSHORE OPERATIONS
DRILLING
DRILL 5.0 Vessel Operations
Audit Protocol:
Stand-by and re-supply vessels shall operate according to existing local regulations
and in a manner that would minimize impact to the environment.
Audit Guideline:
of fuels, oils and bulk products.

OFFSHORE OPERATIONS
DRILLING
DRILL 6.0 Spill Prevention
Audit Protocol:
Audit Guideline:
handling procedures. Instructions for the monitoring of these activities should be
built into the drilling program or other suitable well-specific document.
implemented and that personnel are knowledgeable of such process.
• Verify that regular inspections are performed to detect any leaks or spills.
• Inspect fuel storage areas and equipment.
• Check condition of transfer hoses and any pressure testing procedures. Review
incident history of transfer hoses.
• Close attendance during bunkering of the vessel with the pollution control
equipment is recommended.
• Check that “No Smoking” signs are posted in fuel storage areas. Verify that these
areas are clearly marked. Inspect chemical storage areas. Bagged material
should be properly stored in weather protected areas. Chemical barrels should be
protected so that leaks and spills can be contained.
• Verify that procedures are in place regarding oil well testing. Personnel should
maintain a watch for oil on the sea surface. The pollution control vessel should be
in close attendance at this time in order to be able to take immediate action on any
liquids escaping the flare boom and entering the water.
• Verify if there is any pollution risk assessment due to spillage of crude oil, including
anticipated reservoir characteristic studies and shallow nature and blowout
potential studies.

OFFSHORE OPERATIONS
DRILLING
DRILL 7.0 Spill Contingency Plans
Audit Protocol:
Drilling operations shall have a spill contingency plan that adequately addresses the
spill risks posed by the operations. All personnel shall be familiar with the contingency
plan and capable of fulfilling their roles in that plan.
Audit Guideline:
ARPEL has spent considerable effort in preparing guidance documents that describe
in detail the preparation of contingency plans and spill response options. These
documents can be used a guide for the auditor in the conduct of audits of this area.
• Verify the existence of a Spill Contingency Plan. Verify that local authorities,
including resource managers for fish and wildlife, were contacted in the preparation
of the contingency plan.
• Review contents of the Spill Contingency Plan. Record and analyze the particular
spill prevention and cleanup methods to make sure they are appropriate for the
location and risks posed by the operations. The essential elements of the plan are:
- Responsibilities of personnel and external agencies

- Reporting procedures
- Contact arrangements with statutory agencies
- Spill prevention methods
- Cleanup methods to be adopted
- Immediate and backup facilities available to the operator
- List of contacts
- Well specific data including location, depth and duration
- Drilling rig data and credible spill scenarios
- Calculation of time taken by oil to reach the shore (worst case)
- Environmental data and monitoring programs
- Identification of areas which are sensitive to oil pollution
- Claims adjudication
experience.

• In near-shore areas and sensitive areas, verify that particular attention has been
paid to predicting the effects of local weather and hydrogeography on the
movement of spilled oil. Verify the provision of adequate means of tracking and
surveillance of spilled oil.
• Verify that appropriate arrangements for oil pollution containment and recovery are
provided. The standby vessel can be provider dual purpose rescue and pollution
control duties for short periods of time near the drilling unit; however, the safety and
rescue roles should never be compromised.

OFFSHORE OPERATIONS
DRILLING
DRILL 8.0 Spill Response
Audit protocol:
Drilling operations shall have a spill response capability commensurate with the size
and type of spills associated with those operations.
Audit Guideline:
• Inspect stand-by/ pollution control vessels. Verify that type of vessel is adequate for
the exploration area. Verify that all necessary equipment is available. The vessel
should have a set of operating procedures and well-specific instructions.
• Verify that clear instructions are given on the use of dispersants. Inspect and verify
type, efficiency and approval status of the dispersant stock. The vessel should
deploy and test equipment at regular intervals to ensure it is in a continual state of
readiness. The vessel should be in close proximity to the rig during transfer of fuel,
well testing or at any time when there is considered to be an increased risk of an oil
release.
• Verify that communications systems and reporting networks are tested on a regular
basis.
• Verify that collected oil and spill response wastes are properly stored and that
disposal is in accordance with the contingency plan and local regulations.
• Verify that monitoring of potential spills effects has been carried out. The level of
monitoring should reflect the size or seriousness 0f the spill.
• Determine how damage claims were handled/settled, and verify that all such
matters have been resolved.

OFFSHORE OPERATIONS
DRILLING
DRILL 9.0 Chemical Handling and Storage
Audit Protocol:
Audit Guideline:
the records.

OFFSHORE OPERATIONS
DRILLING
DRILL 10.0 Waste Management
Audit Protocol:
quality.
Audit Guideline:
accordingly. The plan should contain as a minimum, a reporting policy and a
description of disposal methods.
• Verify that suitable and sufficient receptacles are provided for the collection and
storage of refuse. All such receptacles should be kept in a clean condition and
good repair.
• Refuse must not be allowed to accumulate. Daily, or more frequent, emptying of

waste bins should be undertaken. The use of bulk compactors should be
considered for the reception of the waste material. The use of waste paper baling
machines for dry cardboard and paper are recommended for use in waste control.
• Verify that wastes packaged for shipment to shore are properly prepared and
marked.

which wastes should not be burned.

OFFSHORE OPERATIONS
DRILLING
DRILL 11.0 Wastewater Discharges
Audit Protocol:
Wastewater discharges shall comply with existing local regulations.
Audit Guideline:
• Prior to the field inspection, verify the required regulatory procedures for wastewater
discharges.
• Verify that proper procedures are followed regarding wastewater discharges.
• Verify that operations comply with existing local regulations. For blocks outside the
three mile limit, the normal (maceration to 6mm) offshore discharge requirements
should apply. Within three miles of the shore and in other controlled waters,
consent may be required from the appropriate authorities to discharge any
wastewater. The consents may carry conditions on rate of discharge and effluent
composition.
• Verify that proper procedures for the treatment and disposal of oily water are in
place and being followed.

OFFSHORE OPERATIONS
DRILLING
DRILL 12.0 Sampling and Analysis of Discharges
Audit Protocol:
Discharges shall be monitored regularly to ensure that good operating practices are
followed.
Audit Guideline:
• Verify discharges are sampled and analyzed regularly. Inspect records for variance
from sampling schedule.
• Inspect analysis results for values that exceed regulatory or other standards.
• Verify actions taken by supervisory personnel when non-compliance is indicated by

analytical results.

OFFSHORE OPERATIONS
DRILLING
DRILL 13.0 Well Suspension and Abandonment
Audit Protocol:
Suspended and abandoned wells shall be left in a condition that do not pose a risk of
pollution or interference with other marine activities.
Audit Guideline:
• Verify that proper procedures are in place to ensure the seabed is clear of any
debris after the operation is complete. A seabed clearance report can be used to
demonstrate the presence or absence of seabed protrusions.
• Verify that all platforms and subsea structures are removed properly. In choosing
the best abandonment and decommissioning option, consideration should be given
to the relative benefits of the decommissioning versus allowing the materials to
remain in place.
• Verify that there are no obstacles left on the seabed that will be an impediment to
commercial or subsistence fishing interests.

13.3 PRODUCTION

13.3 PRODUCTION

4.0 General Operating Procedures
5.0 Valves and Wellheads
6.0 Flare Stacks
7.0 Tanker Operations
11.0 Spill Response
12.0 Chemical Handling and Storage
14.0 Wastewater Discharges
15.0 Sampling and Analysis of Discharges
16.0 Disposal of Produced Water
17.0 Decommissioning and Abandonment Operations

OFFSHORE OPERATIONS
PRODUCTION
PROD 1.0 Regulatory Environmental Authorization
Audit Protocol:
commencement of any oil and gas production activities. Special conditions and
restrictions shall be reviewed and followed.
Audit Guideline:
• If regulatory personnel will be inspecting the production operations, attempt to

coordinate that site visit with the commencement or termination of the audit.
• Review the records to ensure that all required permits, licenses and regulatory
authorizations are current. Record permit/license numbers and verify information in
the field.

permits/licenses.
•
restrictions etc. and has provided this information to the contractor. Verify, through
interview, documentation and discussions with the regulators, that those
restrictions were followed by the contractor and personnel.

OFFSHORE OPERATIONS
PRODUCTION
PROD 2.0 Environmental Planning
Audit Protocol:
The planning of production operations shall be undertaken in a manner that will

anticipate problems and minimize the effects of the operations.
Audit Guideline:
Once installed, production facilities tend to be in place for many years. The impact of
operations over years can be cumulative. It is important to ensure that operations
strive for continuous improvement in an effort to reduce the potential for unacceptable
impacts. Monitoring programs are an essential component of the management of
these facilities. Audits should be scheduled on a regular basis; the schedule can vary
from facility to facility depending upon performance and relative risk. As a minimum
offshore facilities should be audited every 3 years. Impact from offshore production
facilities are primarily associated with large oil spills and produced water.
• For first audits, verify that environmental concerns (i.e., recognized habitats for
marine mammals, seabird populations, migration routes etc.) were incorporated
during the planning stage of the operations. If the operations have taken place, or
are taking place, in near-shore areas, review project records and determine if an
assessment of the environmental resources in near-shore operating areas was
undertaken.
• For subsequent audits, determine if the environmental databases have been

updated. If the new information indicates some changes have taken place verify
that appropriate responses have been prepared/implemented.
• Offshore production facilities should have an environmental protection plan that

establishes the basis for environmentally safe and responsible operations. This
plan will address the environmental management system to be used as well as the
details of the prevention, protection and effects monitoring programs.

OFFSHORE OPERATIONS
PRODUCTION
PROD 3.0 Consultation and Liaison
Audit Protocol:
The Operators of oil and gas production facilities shall consult with stakeholders such
as other marine users, local communities and coastal business owners shall be
consulted as appropriate.
Audit Guideline:
Educating the general public during the planning stage can minimize misperceptions
approach for the development of a harmonious working relationship..
otherwise resolved.

OFFSHORE OPERATIONS
PRODUCTION
PROD 4.0 General Operating Procedures
Audit Protocol:
Production operations shall be conducted so that disturbance to the environment is

minimized. This protocol applies to offshore facilities, tankers and support vessels in
transit or on station in the field and shore-based installations.
Audit Guideline:
Offshore production is a 24 hour-a-day, 365 day a year operation that is subject to a

wide range of meteorological and oceanographic conditions. Production operations
generally include the entire system of well bores, wellheads, flowlines, manifolds,
risers, processing equipment, accommodation, crude oil storage, export lines to shore
or to a tanker. Safety valves in the well bore and wellhead are the first of several
systems designed to maintain control over the oil as it moves through the production,
process and export systems. While there are usually some redundant systems, it is
important to ensure that each component of the production system is well maintained
and operating efficiently.
• Verify that operations are supported by reliable weather forecasting services that
can be used to plan production and loading operations.
• Verify that the work plans and activities of the maintenance, process operations and
well performance groups all contain environmental responsibilities.
• Verify through interview the extent to which these personnel understand the
environmental impacts that could result from accidents arising from their activities.
• Verify through inspection of records the reliability of all production systems

components. Analyze all unanticipated shutdowns and incident/accident reports for
indications of inadequate controls.

OFFSHORE OPERATIONS
PRODUCTION
PROD 5.0 Valves and Wellheads
Audit Protocol:
Control systems shall be reliable and experience low failure rates.
Audit Guideline:
• Verify through inspection of reports and interview that the schedule for testing,
inspecting and maintaining valves and wellheads has been followed.
• Ensure that unacceptable test results or reports have been properly addressed and
remedial action assigned on a priority that matches the risk posed by the situation.

OFFSHORE OPERATIONS
PRODUCTION
PROD 6.0 Flare Stacks
Audit Protocol:
Flare stacks shall be maintained to reduce the generation of smoke, soot and liquids.
Audit Guideline:
Flaring is generally associated with well testing which may or may not be conducted
from the production facility. Flaring is one method of disposing of unwanted gas
separated from the oil; recompression and reinjection of the gas for gas conservation
or enhanced recovery is a more acceptable option. Flaring should be kept to a
minimum; records of flaring events including the duration and reason for flaring should
be maintained.
• Inspect flare boom and adjacent areas for signs of staining from spray off the stack.
Check logs for times and duration of flaring, correlate with reports of sheen on the
water.

OFFSHORE OPERATIONS
PRODUCTION
PROD 7.0 Tanker Operations
Audit Protocol:
Crude oil transfer and subsequent shipping to onshore storage or market shall be
conducted so that environmental disturbance is minimized.
Audit Guideline:
Production operations, without an export pipeline, may involve internal storage,

dynamic storage (loading a tanker at the rate of processing) or the use of infield
storage tanker (FPSO). The producer generally maintains responsibility for the oil until
the title is transferred. Transfer could take place at the offshore loading system, at a
transhipment point or at the purchasers facility. With the exception of dynamic
storage, cargoes can be loaded at rages exceeding 50,000 barrels per hour. At these
rates, even short delays in terminating transfer operations can result in large spills.
Loading efficiency can be affected by oceanographic and meteorological conditions;
under certain conditions, tankers may not be able to connect to the loading system or
may have to disconnect to ride out a storm. Modern tankers have segregated ballast
systems that eliminate the problems associated with the transfer and treatment of oily
ballast water.
• Verify that all crude oil transfers are monitored by personnel at either end of the
connection. Ensure that appropriate emergency shutdown systems are available
and in working condition. Ensure that communication systems connection the
discharge and receiving facilities are working and that adequate secondary systems
are available and working.
• Verify that pollution control equipment is available onsite and that there are
procedures posted respecting the priorities for spill response. Where dispersant
use has received prior approval, determine is spray systems are active during
transfer operations.
• Verify that all vessels loading at the facility have segregated ballast. Where they do
not, determine how the ballast water was treated.
• Verify that there is a clearly assigned responsibility for spills originating from the
tankers calling at the production facility for spills where they are not connected to
the loading system. Each vessel should have a contingency plan that guarantees
an effective response will be mounted in a reasonable time. Response may be

coordinated between the ship owner, production facility and the destination terminal
dependent upon the location of the spill.
• Verify through interview and inspection of records that all components of the
loading system receive regular inspection and maintenance. Inspect logs of the
production facility and tankers for an indication of problems during crude oil transfer
and their resolution. Pay particular attention to reports of emergency disconnects
and any release of oil.

OFFSHORE OPERATIONS
PRODUCTION
PROD 8.0 Vessel Operations
Audit Protocol:
Stand-by and re-supply vessels shall operate according to existing local regulations
and in a manner that would minimize impact to the environment.
Audit Guideline:
of fuels, oils and bulk products.

OFFSHORE OPERATIONS
PRODUCTION
PROD 9.0 Spill Prevention
Audit Protocol:
Audit Guideline:
handling procedures. Instructions for the monitoring of these activities should be
built into the operations manuals or other suitable facility-specific document.
implemented and that personnel are knowledgeable of such process.
• Verify that regular inspections are performed to detect any leaks or spills.
• Inspect fuel storage areas and equipment.
• Check condition of transfer hoses and any pressure testing procedures. Review
incident history of transfer hoses. Close attendance during bunkering of the vessel
with the pollution control equipment is recommended.
• Check that “No Smoking” signs are posted in fuel storage areas. Verify that these
areas are clearly marked.
• Inspect chemical storage areas. Bagged material should be properly stored in

weather protected areas. Chemical barrels should be protected so that leaks and
spills can be contained.
• Verify that procedures are in place regarding all testing of subsea systems.
Personnel should maintain a watch for oil on the sea surface. The pollution control
vessel should be in close attendance at this time in order to be able to take
immediate action on any liquids escaping the flare boom and entering the water.

OFFSHORE OPERATIONS
PRODUCTION
PROD 10.0 Spill Contingency Plans
Audit Protocol:
Production facilities shall have a spill contingency plan that adequately addresses the
spill risks posed by the operations. All personnel shall be familiar with the contingency
plan and capable of fulfilling their roles in that plan.
Audit Guideline:
ARPEL has spent considerable effort in preparing guidance documents that describe
in detail the preparation of contingency plans and spill response options. These
documents can be used a guide for the auditor in the conduct of audits of this area.
• Verify the existence of a Spill Contingency Plan. Verify that local authorities,
including resource managers for fish and wildlife, were contacted in the preparation
of the contingency plan.
• Review contents of the Spill Contingency Plan. Record and analyze the particular
spill prevention and cleanup methods to make sure they are appropriate for the
location and risks posed by the operations. The essential elements of the plan are:
- Responsibilities of personnel and external agencies

- Reporting procedures
- Contact arrangements with statutory agencies
- Spill prevention methods
- Cleanup methods to be adopted
- Immediate and backup facilities available to the operator
- List of contacts
- Well specific data including location, depth and duration
- Drilling rig data and credible spill scenarios
- Calculation of time taken by oil to reach the shore (worst case)
- Environmental data and monitoring programs
- Identification of areas which are sensitive to oil pollution
- Claims adjudication
experience.

• In near-shore areas and sensitive areas, verify that particular attention has been
paid to predicting the effects of local weather and hydrogeography on the
movement of spilled oil. Verify the provision of adequate means of tracking and
surveillance of spilled oil.
• Verify that appropriate arrangements for oil pollution containment and recovery are
provided. The standby vessel can be provider dual purpose rescue and pollution
control duties for short periods of time near the drilling unit; however, the safety and
rescue roles should never be compromised.

OFFSHORE OPERATIONS
PRODUCTION
PROD 11.0 Spill Response
Audit protocol:
Production facilities shall have a spill response capability commensurate with the size
and type of spills associated with those operations.
Audit Guideline:
• Inspect stand-by/ pollution control vessels. Verify that type of vessel is adequate for
the conditions within the field. Verify that all necessary equipment is available. The
vessel should have a set of operating procedures and facility-specific instructions.
• Verify that clear instructions are given on the use of dispersants. Inspect and verify
type, efficiency and approval status of the dispersant stock.
• The vessel should deploy and test equipment at regular intervals to ensure it is in a
continual state of readiness. The vessel should be in close proximity to the rig
during transfer of fuel, testing of subsea components or at any time when there is
considered to be an increased risk of an oil release.
• Verify that communications systems and reporting networks are tested on a regular
basis.
• Verify that collected oil and spill response wastes are properly stored and that
disposal is in accordance with the contingency plan and local regulations.
• Verify that monitoring of potential spills effects has been carried out. The level of
monitoring should reflect the size or seriousness 0f the spill.
• Determine how damage claims were handled/settled, and verify that all such
matters have been resolved.

OFFSHORE OPERATIONS
PRODUCTION
PROD 12.0 Chemical Handling and Storage
Audit Protocol:
Audit Guideline:
the records.

OFFSHORE OPERATIONS
PRODUCTION
PROD 13.0 Waste Management
Audit Protocol:
quality.
Audit Guideline:
accordingly. The plan should contain as a minimum, a reporting policy and a
description of disposal methods for effluent streams such as produced water and
other wastes such as filters and sludges.
• Verify that suitable and sufficient receptacles are provided for the collection and
storage of refuse. All such receptacles should be kept in a clean condition and
good repair.
Refuse must not be allowed to accumulate. Daily, or more frequent, emptying of

waste bins should be undertaken. The use of bulk compactors should be
considered for the reception of the waste material. The use of waste paper baling
machines for dry cardboard and paper are recommended for use in waste control.
• Verify that wastes packaged for shipment to shore are properly prepared and
marked.
• Verify that clinical waste is stored, labelled and disposed in the manner described
in the waste management plan. “Sharps” should be collected in approved
containers.

which wastes should not be burned. The waste management plan should explicitly

describe where incineration is acceptable from an environmental and marine

operations perspectives.
• Consideration should be given to using the services of specialist companies

providing a comprehensive collection and disposal service.

OFFSHORE OPERATIONS
PRODUCTION
PROD 14.0 Wastewater Discharges
Audit Protocol:
Wastewater discharges shall comply with existing local regulations.
Audit Guideline:
• Prior to the field inspection, verify the required regulatory procedures for wastewater
discharges.
• Verify that proper procedures are followed regarding wastewater discharges.
• Verify that operations comply with existing local regulations. For blocks outside the
three mile limit, the normal (maceration to 6mm) offshore discharge requirements
should apply. Within three miles of the shore and in other controlled waters,
consent may be required from the appropriate authorities to discharge any
wastewater. The consents may carry conditions on rate of discharge and effluent
composition.
• Verify that proper procedures for the treatment and disposal of oily water are in
place and being followed.

OFFSHORE OPERATIONS
PRODUCTION
PROD 15.0 Sampling and Analysis of Discharges
Audit Protocol:
Discharges shall be monitored regularly to ensure that good operating practices are
followed.
Audit Guideline:
• Verify discharges are sampled and analyzed regularly. Inspect records for variance
from sampling schedule.
• Inspect analysis results for values that exceed regulatory or other standards.
• Verify actions taken by supervisory personnel when non-compliance is indicated by

analytical results.

OFFSHORE OPERATIONS
PRODUCTION
PROD 16.0 Disposal of Produced Water
Audit Protocol:
Disposal of produced water shall be conducted so that disturbance to the environment

is minimized.
Audit Guideline:
Produced water management has been the subject of several recent international
conferences. The proceedings of these sessions will provide the auditor with
additional material with which to evaluate the management of this waste stream.
The volumes of produced water vary from field to field but generally tend to increase as
the field matures. Produced water may actually be surface water that has been treated
and injected into the reservoir (waterflood) or waters of geologic age which tend to be
of much higher salinity and contain a wider range of potential contaminants including
radioactive isotopes. produced water is warmer than the receiving seawater and may
tend to rise or remain neutrally buoyant for a short distance from the facility.
• Verify method of produced water treatment and disposal. Generally the

hydrocarbons are separated from the water and discharged at some depth into the
sea. Verify that the depth of discharge is sufficient to prevent the plume of
produced water from reaching the surface. The amount of oil remaining in the
discharged water is usually prescribed by regulation. It is technically possible but
not economically feasible for most offshore operations to reinject produced water.
Similarly, although conceptually attractive, recycling the produced water to make up
subsequent injection requirements, leads to extensive use of more chemicals to
treat that water to an acceptable condition fro re-injection. This involves the
transport and storage of chemicals and generation of concentrated wastes that may
pose more risk to the environment than the existing process described above. The
auditor should consider these points as produced water management is reviewed.
• Many regulations set an upper limit that represents an average concentration over a
fixed period of time, suggesting that it is important to have a sampling program that
allows operations personnel to detect when non-compliance is imminent. Verify
that a regular sampling program is in place that matches the compliance
requirements. Verify that appropriate responses, including notification of regulatory
agencies where necessary, to imminent or actual non-compliance incidents have
been made.

• Verify that environmental effects monitoring has been conducted on a regular basis
as a means of detecting changes in the biological and chemical environments in
the vicinity of the production facilities.
• Verify that where changes have been detected, the matter has been investigated,
mitigated or otherwise resolved.

OFFSHORE OPERATIONS
PRODUCTION
PROD 17.0 Decommissioning and Abandonment Operations
Audit Protocol:
Decommissioning and abandonment operations shall be conducted in a manner that

ensures there are not residual risks of pollution or interference with other marine
activities.
Audit Guideline:
A discussion paper “Decommissioning offshore Oil and Gas Installations; Finding the
right Balance” has recently been prepared by the international oil and natural gas
exploration and production industry. This document and the proceedings of several
international symposiums will provide the auditor with the scope and perspective to
evaluate decommissioning and abandonment plans and operations. The UK Offshore
Operators Association has prepared “An Assessment of the Environmental Impacts of
Decommissioning Options for Oil and Gas Installations in the North Sea” which may
also provide the auditor with additional scope and perspective.
• Verify that proper procedures are in place to ensure the seabed is clear of any
debris after the operation is complete. A seabed clearance report can be used to
demonstrate the presence or absence of seabed protrusions.
• Verify that all platforms and subsea structures are removed properly. In choosing
the best abandonment and decommissioning option, consideration should be given
to the relative benefits of the decommissioning versus allowing the materials to
remain in place.
• Verify that there are no obstacles left on the seabed that will be an impediment to
commercial or subsistence fishing interests.

BIBLIOGRAPHY

BIBLIOGRAPHY
Alberta Environmental Protection. 1994. Tier I Soil Criteria for Contaminated Soil
Assessment and Remediation.
American Society for Testing and Materials (ASTM). 1993. ASTM Standard Practice
for Environmental Site Assessments. Phase I Environmental Site Assessment
Process. ASTM Designation: E 1527-93. Philadelphia, US.
ARPEL Documents: Guidelines for the Treatment and Disposal of Exploration and
Production Drilling Wastes; Guidelines for the Management of Petroleum Refinery
Solid Wastes; Guidelines for Decommissioning and Surface Land Reclamation at
Petroleum Production and Refining Facilities; Guidelines for the Environmental
Management of the Design, Construction, Operation and Maintenance of Hydrocarbon
Pipelines; Guidelines for Control and Mitigation of Environmental Effects of
Deforestation and Erosion and Guidelines for the Management of Petroleum Refinery
Liquid Wastes.
Arthur Little Inc. 1984. Current Practices in Environmental Auditing. Report to US

Environmental Protection Agency.
Canadian Council of Ministers of the Environment (CCME). 1993. Guidance Manual

on Sampling, Analysis, and Data Management for Contaminated Sites. Volume I:
Main Report. Winnipeg, Canada.
Canadian Council of Ministers of the Environment (CCME). 1991. Interim Canadian

Environmental Quality Criteria for Contaminated Sites Guidance Manual on Sampling,
Analysis, and Data Management for Contaminated Sites. Volume II: Analytical Method
Summaries. Winnipeg, Canada.
Canadian Council of Ministers of the Environment (CCME). 1993. Guidance Manual

on Sampling, Analysis, and Data Management for Contaminated Sites. Volume I:
Main Report. Winnipeg, Canada.
Canadian Petroleum Association (CPA). Environmental Audit Guidelines for the

Petroleum Industry. Calgary, Canada.
Canadian Petroleum Association (CPA). 1991. Environmental Audit Guidelines for

Pipelines. Calgary, Canada.
Canadian Petroleum Association (CPA). 1988. Environmental Operating Guidelines

for the Alberta Petroleum Industry. Calgary, Canada.
Canadian Standards Association(CSA). 1994. Z750-94: A Voluntary Environmental

Management System. Toronto, Canada.

Canadian Standards Association(CSA). 1994. Z768-94: Phase I Environmental Site

Assessment. Toronto, Canada.
Canadian Standards Association(CSA). 1994. Z751-94: Guidelines for Environmental

Auditing, Statement of Principles and General Practices. Toronto, Canada.
Center for Training and Understanding (CTU) and the Environmental Business
Association (TEBA). 1991. The Environmental Audit for Real Estate and Property
Transfer. Matawan, US.
E&P Forum. 1996. Environmental Performance Indicators Survey Results. London,

England.
Exploration Logistics Ltd. 1992. Environmental Guidelines for Worldwide Geophysical

Operations. Houston, Texas, US.
International Organization for Standardization (ISO). ISO 14000: 199X. 1995.

Environmental Management Systems.
IR/WA Course 603. Understanding Environmental Contamination in Real Estate.

Session III- the Environmental Auditing Process- Assessing your Environmental
Liabilities. Calgary, Canada.
Petroleum Association for Conservation of the Canadian Environment (PACE). Pace

Report No. 86-2. Waste Management Guidelines for Petroleum Refineries.
1986.
Petroleum Industry Training Service (PITS). 1992. Environmental Auditing in the

Petroleum Industry. Calgary, Canada.
The Environmental Resources Management Group. 1995. Environmental Auditing:

Federal Compliance Guide. Vancouver, Canada.
The International Offshore Oil and Natural Gas Exploration and Production Industry.
Decommissioning Offshore Oil and Gas Installations: Finding the Right Balance.
London, England.
UK Offshore Operators Association. 1995. Environmental Guidelines for Exploration

Operations in Near-Shore and Sensitive Areas. London, England.
UK Offshore Operators Association. 1995. Safeguarding the Offshore Environment.

London, England.
UK Offshore Operators Association. 1995. An Assessment of the Environmental

Impacts of Decommissioning Options for Oil and Gas Installations in the UK North
Sea.

United States Environmental Protection Agency (EPA). 1989. Generic Protocol for
Environmental Audits at Federal Facilities. Washington, D.C.
ADDITIONAL RECOMMENDED REFERENCE MATERIAL
American Public Health Association. 1985. Standard Methods for Examination of

Water and Wastewater, 16th Ed. Washington, D.C.
American Society for Testing and Materials (ASTM). 1986. Inorganic Analytical
Methods Performance and Quality Control Considerations, fifth volume. C. L. Perket
(ed.), STP 925. Philadelphia, Pennsylvania.
American Society for Testing and Materials (ASTM). 1992. Annual Book of ASTM
Standards. Volume 04.08. Philadelphia, Pennsylvania.
American Society for Testing and Materials. 1986. Volatile Organic Analytical
Methods Performance and Quality Control Considerations. Fifth Volume. STP 925,.
Philadelphia, Pennsylvania.
Canadian Council of Ministers of the Environment (CCME). 1994. Subsurface

Assessment Handbook for Contaminated Sites. Report CCME EPC-NCSRP-48E.
Ottawa, Canada.
Kane, M. (ed.). 1987. Manual of Sampling and Analytical Methods for Petroleum
Hydrocarbons in Groundwater and Soil. API Publication No. 4449. American
Petroleum Institute. Washington, D.C.
United States Environmental Protection Agency (EPA). 1977. Procedures Manual for
Groundwater Monitoring at Solid Waste Disposal Facilities. EPA/530/SW-611.
Washington, D.C.
United States Environmental Protection Agency (EPA). 1982. Environmental

Monitoring and Support Laboratory. Office of Research and Development. Methods
for Chemical Analysis of Water and Wastes. EPA-600/4-79-020. Cincinnati, OH.
United States Environmental Protection Agency (EPA). 1987. Office of Emergency

and Remedial Response. Office of Solid Waste. Superfund Public Health Evaluation
Manual . Washington, D.C.
United States Environmental Protection Agency (EPA). RCRA Groundwater Monitoring

Technical Enforcement Guidance Document. OSWER-9950.1. United States
Government Printing Office. Washington, D.C.

United States Environmental Protection Agency (EPA). 1988. Office of Solid Waste
and Emergency Response. Superfund Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA. EPA OSWER. Washington,
D.C.
United States Environmental Protection Agency (EPA). 1986. Test Methods for
Evaluating Solid Wastes. SW-846.
United States Environmental Protection Agency (EPA). 40 CFR. Part 141 and 40 CFR.
Part 136.
United States Environmental Protection Agency (EPA). 1979. Methods for Chemical
Analysis of Water and Wastes. EMSL. EPA - 600/4 - 79 - 020. Cincinnati, OH 45268.

GLOSSARY

GLOSSARY OF TERMS AND ABBREVIATIONS
ABANDON: To cease efforts to produce oil and gas from a well, and to plug a depleted formation and
salvage all material and equipment.
ABSORPTION: The passage of one substance into or through another; to soak up.
ACIDIZING: The treatment of formations with hydrochloric or other type acids in order to increase
production or injection.
ADSORPTION: Adhesion of molecules of gas, liquid or dissolved solids to the surface.
AIR POLLUTANT: Any substance in air which could cause, if in high enough concentration, harm man,
other animals, vegetation or material. Pollutants may include any natural or artificial composition of
matter capable of being airborne. They may be in the form of solid particles, liquid droplets, gases or in
combinations of these forms.
AIR POLLUTION: The presence of contaminant or pollutant substances in the air that do not disperse
properly and interfere with human health or welfare, or produce other harmful environmental effects.
ANNULAR SPACE: The space around a pipe (casing or tubing) suspended in a wellbore is often termed
the ANNULUS, and its outer wall may be either the wall of the borehole or the casing.
ANSI: The American National Standards Institute.
API: The American Petroleum Institute.
AQUIFER: An underground geological formation, or group of formations, containing usable amounts of

ground water that can supply wells and springs.
ASBESTOS: A mineral fibre that can pollute air or water and cause cancer or asbestosis when inhaled.
This material has been banned and its use severely restricted.
ASME: The American Society of Mechanical Engineers.
ASTM: The American Society for Testing and Materials.
ATMOSPHERIC EMISSIONS: Residual discharges of emissions to the air (usually expressed in pounds
or kilograms per unit output) following emission control devices. Includes point sources such as stacks
and vents as well as area sources such as storage piles.
AUDIT: A systematic check of relevant aspects of an operation. Audits may include energy, wastes or a
full environmental audit of all matters that influence environmental performance.
AUDIT CONCLUSION: Professional judgement or opinion expressed by an auditor about the subject
matter of the audit, based on and limited to reasoning the auditor has applied to audit findings.
AUDIT CRITERIA: Policies, practices, procedures or requirements against which the auditor compares
collected audit evidence about the subject matter.
AUDIT EVIDENCE: Verifiable information, records are statements of fact.

AUDIT FINDINGS: Results of the evaluation of the collected audit evidence compared against the agreed
audit criteria.
AUDIT TEAM: Group of auditors, or a single auditor, designated to perform a given audit: the audit team
may also include technical experts and auditors-in-training.
AUDITEE: Organization to be audited.
AUDITOR (environmental): Person qualified to do environmental audits.
BATTERY (tank battery): The production handling equipment on a lease.
BENTONITE: A naturally occurring clay, which is often a major constituent of drilling muds.
BIOLOGICAL TREATMENT: A treatment technology that uses bacteria to consume waste. This
treatment breaks down organic materials.
BLOWOUT: An uncontrolled flow of gas, oil or other fluids from a well.
BLOWOUT PREVENTER (BOP): The equipment installed at the wellhead for the purpose of controlling
pressures in the annular space between the casing and drill pipe during drilling.
BNAs: Base-, Neutral-, and Acid-extractable Compounds.
BOILERHOUSE: To make up or fake a report without actually doing the work.
BOTTOM-HOLE: The lowest or deepest part of a well.
BRINE: Water that has a large quantity of salt, especially sodium chloride, dissolved in it. Salt water.
BUFFER STRIPS: Strips of grass or other erosion-resisting vegetation between or below cultivated
strips or fields.
CASED HOLE: A wellbore in which casing has been run.
CASING PRESSURE: Pressure measured at a wellhead casing outlet.
CASING STRING: The pipe run in a well, for example: surface string, intermediate string, production
string, etc.
CATALYST: A substance which alters the velocity of a chemical reaction without itself being altered.
CELLAR: A hole dug, usually before digging a deep well, to allow working space for the
casinghead equipment.
CLEANUP: Actions taken to deal with a release or threat of release of a hazardous substance that could
affect humans and/or the environment. The term “cleanup” is sometimes used interchangeably with the
terms remedial action, removal action, response action or corrective action.
CLOSED IN: A well capable of producing oil or gas, but temporarily shut in.
COLLAR: usually refers to a coupling used to join two lengths of pipe.

COMPOSITE SAMPLE: A sample which is made up of material combined from two or more samples. It is
a common practice to use composite samples made from samples taken from across an area. Sample is
seen to be a representative sample.

COMPOSTING: A waste management option. The biodegradation of organic solid wastes. A waste
management option involving the controlled biological decomposition of organic materials into a relatively
stable humus-like product that can be handled, stored, and/or applied to the land without adversely
affecting the environment.
CONDENSATE: Hydrocarbons which are in the gaseous state under reservoir conditions but which
become liquid either in passage up the hole or in the surface equipment.
CONSERVATION: Protection of the soil against physical loss by erosion or against chemical
deterioration; that is, excessive loss of fertility by either natural or artificial means.
CONTAMINATION: The presence in soil, water, groundwater, air or structures of a material which may
adversely affect human health or the natural environment.
CONTINGENCY PLAN: A document setting out an organized, planned, and coordinated course of action
to be followed in case of fire, explosion, or other accident that releases toxic chemicals, hazardous
wastes, or radio-active materials which threaten human health or the environment.
COOLING TOWER: A large structure in which atmospheric air is circulated to cool water by evaporation.
CORRECTIVE ACTION: Action taken to eliminate the causes of an existing nonconformity, defect or
other undesirable situation in order to prevent recurrence.
CRATER: To fail. To cave in.
CRUDE OIL: A mixture of hydrocarbons that exists in the liquid phase in the underground reservoir and
remains liquid at atmospheric pressure after passing through surface separating facilities.
CSA: The Canadian Standards Association.
CUT OIL: Oil that contains water, usually in the form of a emulsion. Also called wet oil.
DANGEROUS SUBSTANCE: Substances that, when accidentally released, and in such a quantity as
may result in serious harm to life, property or the environment.
DECOMMISSIONING: The remediation of a mine or industrial site once the operations on the site have
come to an end or closed.
DECOMPOSITION: The breakdown of matter by bacteria and fungi. Changes the chemical makeup and
physical appearance of materials.
DISPOSAL: Final placement or destruction of toxic, radioactive or other wastes; surplus or banned
pesticides or other chemicals; polluted soils; and drums containing hazardous materials from removal
actions or accidental releases.
DISPOSAL FACILITY: A plant or structure used for the destruction, removal and disposal of waste
materials.
DREDGING: Removal of mud from the bottom of water bodies using a scooping machine. This disturbs
the ecosystem and causes silting that can kill aquatic life. Dredging of contaminated muds can expose
aquatic life to heavy metals and other toxins.

DRILL STRING: Lengths of steel tubing roughly 10 meters long screwed together to form a pipe
connecting the drill bit to the drilling rig. The string is rotated to drill the hole and also serves as a conduit
for drilling mud.
DYKE: A low wall that can act as a barrier to prevent a spill from spreading. (Also referred to as a
BERM)
ECOLOGY: The relationship of living things to one another and their environment or the study of such
relationships.
ECOSYSTEM: The interacting system of a biological community and its nonliving environmental
surroundings.
EFFLUENT WASTE WATER: Treated or untreated water flowing out of a treatment plant, sewer or
industrial outfall. Generally refers to wastes discharged into surface waters.
ELECTRICAL CONDUCTIVITY (EC): Environmental context refers to the method to determine the
salinity level of a soil or water sample. As the concentrations of salt increase in a solution, so does the
electrical conductivity.
EMERGENCY PLAN: A written detailed program of action to minimize the effects of an abnormal event
requiring prompt actions beyond normal procedures to protect human life, minimize injury, optimize loss
control and to reduce physical asset and environmental exposure.
EMISSION: Pollution discharged into the atmosphere from smokestacks, other vents, and surface areas
of commercial or industrial facilities.
EMS: Environmental Management Systems.
EMULSION: A mixture of crude oil and formation water. Generally requires time and heat, chemicals
(called demulsifiers or emulsion breakers) or electricity to separate the water from the oil.
ENHANCED OIL RECOVERY: A process whereby oil is recovered other than by the natural pressure in
a reservoir, using secondary or tertiary recovery methods.
ENTRAINED GAS: Gas suspended in bubbles in a stream of liquid such as water or oil.
ENTRAINED LIQUIDS: Mist-size liquid droplets occurring in a gas stream. Special design separators,
with a mist extractor, are used to remove the liquid from the gas stream.
ENVIRONMENT: Surroundings in which an organization operates, including air, water, land, natural
resources, flora, fauna, humans, and their interrelation.
ENVIRONMENTAL AUDIT: Systematic, documented verification process of objectively obtaining and

evaluating audit evidence to determine whether specified environmental activities, events, conditions,
management systems, or information about these matters conform with audit criteria, and communicating
the results of this process to the client.
ENVIRONMENTAL AUDIT CRITERIA: Laws and regulations, standards, policies, practices or

procedures, against which the auditor compares collected evidence about the subject matter to
determine the degree of conformity.
ENVIRONMENTAL AUDITOR: A person who carries out an environmental audit.

ENVIRONMENTAL IMPACT: Any change to the environment, whether adverse or beneficial, wholly or
partially resulting from an organization’s activities, products or services.
ENVIRONMENTAL MANAGEMENT SYSTEM: That part of the overall management system which
includes organizational structure, planning activities, responsibilities, practices, procedures, processes
and resources for developing, implementing, achieving, reviewing and maintaining the environmental
policy.
ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT: Systematic and documented verification process

to objectively obtain and evaluate evidence to determine whether an organization’s environmental
management system conforms to the environmental management system audit criteria set by the
organization, and communication of the results of this process to management.
ENVIRONMENTAL PERFORMANCE: Measurable results of the environmental management system,

related to an organization’s control of its environmental aspect, based on its environmental policy,
objectives and targets.
ENVIRONMENTAL POLICY: Statement by the organization of its intentions and principles in relation to
its overall environmental performance which provides a framework for action and for the setting of its
environmental objectives and targets.
ENVIRONMENTAL RISK ASSESSMENT: A structured process for identifying environmental risks,

predicting the magnitude and probability of specific environmental Risk Assessment is concerned with
both ecological consequences and consequences to human health and security.
ENVIRONMENTAL SITE ASSESSMENT: An inspection of property to determine the environmental

condition of that property.
EOX: Exractable organo-halogens.
EROSION: The wearing away of land surface by wind or water. Erosion occurs naturally from weather
or run-off but can be intensified by land-clearing practices.
EXPLORATION DRILLING: Drilling carried out to determine whether hydrocarbons are present in a
particular area or geological structure.
FIELD FACILITY: An installation designed for one or more specific field processing units--scrubbers,
absorbers, drip points, compressors, single or multiple stage separation units, low temperature
separators, and other types of separation and recovery equipment.
FLARING: Burning of gas extracted from an oil and gas reservoir which is not worth commercial
production.
FLOCCULATION: The process by which clumps of solids in water or sewage are made to increase in
size by biological or chemical action so that they can be separated from the water.
FLOW LINE: The surface pipe through which oil travels from the well to the field processing facility.
FLOW STRING: The string of casing or tubing through which fluids from a well flow to the surface.
FLOW PRESSURE: The pressure at the wellhead of a flowing well.
FLOWING WELL: A well that produces without the means of an artificial lift.

FLUID: A substance that flows. Both liquids and gases are fluids. In common oilfield usage, the term
fluid refers to liquids.
FLUID INJECTION: Injection of gases or liquids into a reservoir to force oil toward and into producing
wells.
FLUME: A natural or man-made channel that diverts water.

FORMATION PRESSURE: The pressure exerted by the formation fluids, recorded in the hole at the
level of the formation, with the well shut in.
FRACTIONATOR: A cylindrical refining vessel where liquid feedstocks are separated into various
components or fractions (e.g., distillation).
FRACTURING: Application of hydraulic pressure to the reservoir formation to create fractures through
which oil or gas may move to the wellbore.
FUGITIVE EMISSIONS: Emissions from valves or leaks in process equipment of material storage areas
that are difficult to measure and do not flow through pollution control devices. They escape.
GAS PROCESSING PLANT: A facility designed to achieve the recovery of natural gas liquids from the
stream of natural gas which may or may not have been processed through lease separators and field
facilities. Also, to control the quality of the natural gas to be marked.
GAS WELL: A well capable of producing natural gas.
GATHERING LINES: The flow lines which run from several wells to a central lease or plant facility.
GEOLOGY: The scientific study of the origin, history and structure of the earth as recorded in rocks. A
person trained in geology is a GEOLOGIST. A Petroleum Geologist is primarily concerned with
sedimentary rocks where most of the world’s oil has been found.
GEOPHONES: The detectors used in seismic surveys to pick up sound waves reflected from sub-
surface strata.
GROUND WATER: The supply of fresh water found beneath the earth’s surface (usually in aquifers)
which is often used for supplying wells and springs. Because ground water is a major source of drinking
water, there is growing concern over areas where leaching agricultural or industrial pollutants or
substances from leaking underground storage tanks are contaminating ground water.
HALOGEN: Any of a group of five chemically related nonmetallic elements that includes bromine,
fluorine, chlorine, iodine and astatine.
HAZARD: A condition with the potential for causing an undesirable consequence. For a chemical for
instance, it is the potential the substance has for causing adverse effects at various levels of exposure.
A situation with a potential for human injury, damage to property, damage to the environment or some
combination of these.
HAZARDOUS MATERIAL: A material which may, upon exposure, constitute an identifiable risk to human
health or the natural environment. Hazardous material criteria are established in consultation with the
appropriate regulatory authorities.
HAZARDOUS WASTE: Any waste containing significant quantities of a substance which may present
danger to the life or health of living organisms when released into the environment or safety of humans or
equipment in disposal plants in incorrectly handled. Hazardous properties include toxic, carcinogenic,

mutagenic or teratogenic characteristics, as well as flammability, chemical reactivity or other biologically

damaging properties. Hazardous wastes are subject to special handling, recycling and disposal
requirements.
HERBICIDE: A chemical pesticide designed to control or destroy plants, weeds or grasses.
HYDROCARBON: A compound consisting of molecules of hydrogen and carbon. Petroleum is a mixture

of many hydrocarbons.
HYDROGEOLOGY: The geology of ground water with particular emphasis on the chemistry and
movement of water.
HYDROLOGY: The science dealing with properties, distributions and circulation of water.
ICC: The International Chamber of Commerce.
IMO: The International Maritime Organization.
IMPACT: A change to the environment and the associated consequences for both humans and other
ecosystem components caused directly by the activities of product or service development and
production. Impacts include secondary and tertiary consequences with direct upstream links to primary
changes to environmental systems.
IMPACT ASSESSMENT: A process to determine the magnitude and significance of environmental

impacts.
INCINERATION: Burning of certain types of solid, liquid or gaseous materials. A treatment technology
involving destruction of waste by controlled burning at high temperatures. e.g. Burning sludge to
remove the water and reduce the remaining residues to a safe, nonburnable ash which can be disposed
of safely on land, in some waters or in underground locations.
INJECTED GAS: High pressure gas injected into a formation to maintain or restore reservoir pressure
or otherwise enhance recovery.
INJECTION PUMP: A pump that injects chemicals into a flow-line system for the purpose of treating
emulsions or corrosion, or injects the ground for disposal or to enhance recovery.
INJECTION WELL: A well used to inject gas or water into an oil/gas reservoir rock in order to maintain
reservoir pressure during the secondary recovery process.
IN-SITU REMEDIATION: Remediation that can be done on site through advanced technology such as
soil cleaning.
ISO: The International Organization for Standardization.
KNOCK OUT: A kind of tank or vessel used to separate water from oil.
LANDFILL: A controlled site for disposal of wastes for land,run in accordance with safety and
environmental requirements laid down by a regulatory authority.
LAND TREATMENT: The controlled application of industrial wastes to the soil surface and the
incorporation of the waste into the upper soil zone in such a manner that, by using the natural capacity of
the soil system, the waste constituents are physically, chemically or biologically degraded, assimilated
and immobilized within the treatment zone.

LAYING DOWN TUBING: Pulling tubing, pipe or rods from the well and laying it on a pipe rack.
LEACHATE: A liquid that results from water collecting contaminants as it trickles through wastes,
agricultural pesticides or fertilizers. Leaching, particularly from landfills, may result in hazardous
substances entering surface water, ground water or the soil.
LEASE: A legal document that conveys to an operator the right to drill for oil and gas. The tract of land,
on which a lease has been obtained, where the producing wells and production equipment are located.
MANAGEMENT: Effective control of activities involving waste materials. Cradle-to-grave management

involves the supervision of all phases in the life cycle of a waste material.
MANIFEST: A certificate or trip-ticket, usually comprising multiple copies, which accompanies a load of
transported waste so as to verify that it has reached its intended destination.
MATERIAL SAFETY DATA SHEET (MSDS): A compilation of information required on the identity of
hazardous chemical, health and physical hazards, exposure limits and precautions.
MIGRATION: The movement of oil from the area in which it has formed to a reservoir rock where it can
accumulate.
MINIMIZATION: Actions to avoid, reduce or in other ways diminish the hazards of waste at their source.
Recycling is, strictly speaking, not a minimization technique but is often included in such programs for
practical reasons.
MITIGATION: Measures taken to reduce adverse impacts on the environment.
MUD: The liquid that is circulated through the wellbore during rotary drilling and workover operations.
NATURAL GAS: A mixture of hydrocarbons and varying quantities of nonhydrocarbons that exists either
in the gaseous phase or in solution with crude oil in natural underground reservoirs.
NFPA: The National Fire Protection Association.
NGOs: Non-Government Organizations.
NIOSH: The National Institute for Occupational Safety and Health.
NITRATE: A compound containing nitrogen which can exist in the atmosphere or as a dissolved gas in
water and which can have harmful effects on humans and animals. Nitrates in water can cause severe
illness in infants and cows.
NITRITE: An intermediate in the process of nitrification.
OFFSHORE: That geographic area which lies seaward of the coastline.
OFF-SITE: Away from the site of production of waste.
OIL & GAS SEPARATOR: An item of production equipment used to separate the liquid components of
the well stream from the gaseous components.
OIL WELL: A well completed for the production of crude oil from at least one oil zone or reservoir.
OPEN HOLE: Uncased portion of a well.

PAH: Polyaromatic Hydrocarbons, Polynuclear Aromatic Hydrocarbons or Polycyclic Aromatic

Hydrocarbons.
PARAFFIN: Heavier paraffin-base hydrocarbons often form a waxlike substance called paraffin.
Paraffin may accumulate on the walls of tubing, flow lines and other production equipment, thus
restricting the flow of well fluids to the extent that it must be removed.
PCB: Polychlorinated biphenyls.
PERMEABILITY (of a reservoir rock): The ability of a rock to transmit fluid through the pore spaces - A
key influence on the rate of flow, movement and drainage of the fluid. There is no necessary relation
between porosity and permeability. A rock may be highly porous and yet impermeable if there is no
communication between pores.
PETROLEUM: Oil or gas obtained from the rocks of the earth by drilling down into a reservoir rock and
piping them to the surface.
PHASE 1 ENVIRONMENTAL SITE ASSESSMENT (ESA): The systematic process, as prescribed by the
standard, by which an assessor seeks to determine whether a particular property is or may be subject to
contamination. It does not involve the investigative procedures of sampling, analyzing and measuring
unless enhancements are agreed upon between the client and assessor. The term environmental audit
should not be used to describe a Phase 1 Environmental Site Assessment. As well, a Phase 1 ESA may
include a review of previously preformed environmental audits.
Phase I: A qualitative Environmental Site Assessment which does not involve any physical testing but is
based on historical and regulatory reviews as well as a visual inspection of the property.
Phase II: An Environmental Site Assessment which involves sampling and laboratory to determine the
extent, if any, of environmental contamination of the property.
Phase III: An Environmental Site Assessment which concentrates on the remedial actions necessary to
eliminate or minimize the environmental contamination and degradation of property,
Phase IV: Pollution Prevention/Remediation.
PIG: A device inserted in a pipeline for the purpose of sweeping the line clean of water, rust or other
foreign matter. (Also known as GO DEVIL)
PITS, PONDS, or LAGOONS: Man made or natural depressions in a ground surface that are likely to
hold liquids or sludge containing hazardous substances or petroleum products. The likelihood of such
liquids or sludge being present is determined by evidence of factors associated with the pit, pond, or
lagoon, including, but not limited to, discolored water, distressed vegetation, or the presence of an
obvious wastewater discharge.
POLLUTANT: Generally, any substance introduced into the environment that adversely affects the
usefulness of a resource.
(PVC): POLYVINYL CHLORIDE
POROSITY (of a reservoir rock): The percentage that the volume of the pore space bares to the total
bulk volume. The pore space determines the amount of space available for storage of fluids.
POTABLE WATER: Water that is safe for drinking and cooking.

PRESSURE-RELIEF VALVE: A valve that opens at a preset pressure to relieve excessive pressures
within a vessel or line.
PRE-TREATMENT: Initial treatment of waste materials to make them safe to handle, or precondition
them for subsequent processing or disposal.
PREVENTION OF POLLUTION: Use of processes, practices, materials, or products that avoid, reduce
or control pollution, which may include recycling, treatment, process changes, control mechanisms,
efficient use of resources and material substitution.
PRIMARY TREATMENT: First steps in waste water treatment; screens and sedimentation tanks are
used to remove most material that floats or will settle. Primary treatment results in the removal of about
30 percent of carbonaceous biochemical oxygen demand from domestic sewage.
PRODUCTION: The yield of an oil or gas well. Also that branch of the petroleum industry that has to do
with bringing the well fluids to the surface and separating them, and with storing, gaging and otherwise
preparing the product for the pipeline.
PRODUCTION CASING: The last string of casing set in a well; the casing string set to the top or
through the producing formation and inside of which is usually suspending tubing string.
PRODUCING PLATFORM: An offshore structure accommodating a number of producing wells.
PRODUCTION PLATFORM: An offshore structure providing a central processing and disposition point
for fluids produced from wells on adjacent
PRODUCING and WELL PLATFORMS. The treated oil and gas is moved to shore through submarine
pipelines. Produced water is generally disposed of within the field.
QUALITY ASSURANCE: All the planned and systematic activities implemented within the quality system
and demonstrated as needed to provide adequate confidence that an entity will fulfil requirements for
quality.
QUALITY CONTROL: A system which measures the extent to which an audit is conducted according to
the objectives and scope of the audit, and the principles and practices contained in this standard.
Operational techniques and activities that are used to fulfil requirements for quality.
RAW MATERIALS: The total inputs for a subsystem including all material present in the product and
material found in losses due to emissions, scrap and off-spec products, and no-emission losses such as
moisture during a drying step.
RAW SEWAGE: Untreated waste water.
RECYCLE: The process of reusing an item by converting it to another state or by reclaiming valuable
resources for another use.
RECYCLING: The retrieval of materials or products for re-use in their original form, or for re-processing
into products of similar composition.
RELEASE: Includes discharge, spray, inject, inoculate, abandon, deposit, spill, leak, seep, pour, emit,
empty, throw, dump, place and exhaust.
REMEDIAL ACTION: The actual construction or implementation phase of a Superfund site cleanup that
follows remedial design.

REMEDIATION: The elimination or minimization of the environmental contamination/degradation which

has already occurred.
RESERVOIR: A subsurface porous and permeable rock body that contains oil and/or gas. Any natural
or artificial holding area used to store, regulate or control water.
REUSE: Using an item again for its original purpose of for a new purpose rather than throwing it away
without any treatment or modification.
RIG: The derrick, drawworks and attendant surface equipment of a drilling operation.
RISER: A pipe through which liquid travels upward.
RISK ASSESSMENT: The qualitative and quantitative evaluation performed in an effort to define the
risk posed to human health and/or the environment by the presence or potential presence and/or use of
specific pollutants.
SALTWATER DISPOSAL: The method and system for the disposal of salt water produced with crude
oil. A typical system is composed of collection centers and disposal wells of which treated salt water is
injected into a suitable formation.
SCRUBBER: A vessel through which gas is passed to remove liquid and foreign matter.
SECONDARY CONTAINMENT: Refers to an area which is used to contain a spill or leak in case a
container ruptures or breaks. Storage tanks, under and aboveground, are often surrounded by
secondary containment.
SECONDARY TREATMENT: The second step to most public owned waste treatment systems in which
bacteria consume the organic parts of the waste. It is accomplished by bringing together waste, bacteria
and oxygen in trickling filters or in the activated sludge process. This treatment removes floating and
settleable solids and about 90 percent of the oxygen-demanding substances and suspended solids.
Disinfection is the final stage of secondary treatment.
SEISMIC SURVEY: A technique for determining the detailed structure of the rocks underlying a
particular area by passing acoustic shock waves into the strata and measuring the reflected signals.
SEPARATOR: A pressure vessel used for the purpose of separating gas from crude oil and water.
SHALE SHAKER: A vibrating or rotating screen which removes the coarse drill cuttings from the drilling
mud prior to recirculation.
SHOT HOLE SEISMIC METHOD: Seismic survey which uses a small explosion down a shallow
borehole to produce shock waves.
SHUT IN: To close valves on a well so that it stops producing; said of a well on which the valves are
closed.
SITE RECONNAISSANCE: Includes, but is not limited to, the site visit done in connection with such a
Phase I ESA.
SOLID WASTE: Any garbage, refuse, trash, dry sludge or material that is discarded or abandoned and
is intended for disposal. Technically, solid waste also refers to liquids and gases in containers.

SOUR CRUDE OIL (Sour Crude): An oil containing free sulfur or other sulfur compounds whose total
sulphur content is in excess of one percent.
SOUR GAS: Natural gas containing hydrogen sulfide.
SPACING: Distance between wells producing from the same reservoir (usually expressed in terms of
acres, e.g. 10 acre spacing)
STRING: Refers to the casing, tubing, or drill pipe in its entirety.
STRIPPING: The removal of the more volatile components from a mixture.
STUFFING BOX: A packing gland; a chamber or “box” to hold packing material around a moving pump
rod, valve stem or wireline to prevent the escape of gas or liquids.
SURFACE CASING: The first string of casing to be set in a well. Its principal purpose is to protect fresh
water sands.
SURFACE WATER: All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams,
impoundments, seas, estuaries, etc.) And all springs, wells, or other collectors which are directly
influenced by surface water.
SUSPENDED SOLIDS: Small particles of solid pollutants that float on the surface of, or are suspended
in sewage or other liquids. The resist removal by conventional means.
SUSTAINABLE DEVELOPMENT: Development that meets the needs of the present without
compromising the ability of future generations to meet their own needs.
SWEET: Said of oil or gas when it contains no sour impurities.
TDGR: Transportation of Dangerous Goods Act.
TERTIARY TREATMENT: Advanced cleaning of waste water that goes beyond the secondary or
biological stage. It removes nutrients such as phosphorus and nitrogen and most suspended solids.
THRESHOLD LIMIT VALUE (TLV): Represents the air concentrations of chemical substances to which
it is believed that workers may be exposed daily without adverse effects.
TOTAL SUSPENDED SOLIDS (TSS): A measure of the suspended solids in waste water effluent or
water bodies determined by using tests for “total suspended non-filterable solids”
TOX: Total organic halogens.
TPH: Total petroleum hydrocarbons.
TRAP (Geologic): An arrangement of rock strata or structures that halts the migration of oil and gas and
causes them to accumulate.
TREATMENT: A change in the composition or concentration of a waste substance so as to make it less

hazardous or to make it acceptable at disposal facilities.
UNDERGROUND STORAGE TANK (UST): A tank located all or partially underground that is designed to
hold gasoline or other petroleum products or chemical solutions.

VAPOR RECOVERY UNIT: A facility for collecting stock or storage tank vapors to prevent their loss to
the atmosphere.
VENT: A connection in a vessel, line, or pump tp permit the escape of air or gas.
VOC: Volatile Organic Compounds.
WATER FLOODING: One method of enhanced recovery in which water is injected into an oil reservoir
to force additional oil out of the reservoir rock and into the well bores of producing wells.
WATER WELL: A well drilled to obtain a fresh water supply to support drilling and production operations
or to obtain a water supply to be used in connection with an enhanced recovery program.
WASTE: An output with no marketable value that is disposed of in the environment.
WASTE MANAGEMENT: The storage, separation, recycling, disposal and manifestation/documentation

of waste including hazardous, liquid and non-hazardous waste.

WASTE MINIMIZATION: Involves any technique, process or activity which either avoids, eliminates or
reduces waste at its source, usually within, but not limited to, the confines of the production unit, or
allows reuse or recycling of the waste for benign purposes. This is a technique for creating commercial
advantages while achieving compliance. All emissions to air, water and soil as well as energy
consumption should be considered as part of a waste minimization program.
WATER TABLE: The upper surface of ground water of regulated pollutants (usually expressed in
kilograms per unit output) after existing treatment processes.
WASTEWATER: Water that is or has been used in an industrial or manufacturing process. Water that
conveys or has conveyed sewage. Water that is directly related to manufacturing, processing, or raw
materials storage areas at an industrial plant. Wastewater does not include water originating on or
passing through or adjacent to a site, such as stormwater flows, that has not been used in industrial or
manufacturing processed, has not been combined with sewage, or is not directly related to
manufacturing, processing, or raw materials storage areas at an industrial plant.
WHMIS: Workplace Hazardous Materials Information System.
WORKOVER: A process by which a completed production well is subsequently re-entered and any
necessary cleaning, repair and maintenance work done.
WORKING PAPERS: Written documentation of the work performed during an audit, including the
procedures followed, observations made, discussions held, and the conclusions reached by the auditor.

Mission
It is our mission to generate and carry out activities that will lead to the creation of
a more favorable environment for the development of the oil and natural gas
industry in Latin America and the Caribbean, by promoting:
* The expansion of business opportunities and the improvement of

competitive advantages of its members.
* The establishment of a framework to favor competition in the sector.
* The timely and efficient exploitation of hydrocarbon resources and the

supply of its products and services; all this in conformity with the
principles of sustainable development.
To accomplish this mission, ARPEL works in cooperation with international

organizations, governments, regulatory agencies, technical institutions, universities
and non-governmental organizations.
Vision
ARPEL aims at becoming an international level organization that through its

guidelines activities and principles exert an outstanding leadership in the
development of the oil and natural gas industry in Latin America
and the Caribbean.
Objectives
* To foster cooperation among members.
* To study and assess actions leading to energy integration.
* To participate pro-actively in the process of development of laws and

regulations concerning the industry.
* To support actions that expand the areas of activity and increase

business opportunities.
* To serve as an oil and gas activity information center.
* To develop international cooperation programs.
* To promote a responsible behavior for the protection of the

environment, thus contributing to sustainable development.
* To take care of the oil and natural gas industry’s public image.
* To study and disseminate criteria and opinions on the sector’s relevant

issues.
Regional Association of Oil and Natural Gas Companies in Latin America and the Caribbean
Javier de Viana 2345 – CP 11200 Montevideo – URUGUAY
Phone: (598 2) 400 6993* Fax (598 2) 400 9207*
E-mail: arpel@arpel.org.uy
Internet web site: http://www.arpel.org

Eg14e PDF

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Eg14e PDF

Uploaded by

Copyright:

Available Formats

Guidelines for Conducting

Environmental Audits for the

Environmental Auditing is a process of evaluation of environmental performance,

To maintain regulatory compliance, an organization should identify and understand

There are different types of operational audits: management, exploration, production,

i ARPEL Environmental Guideline No. 14

The specific objectives of this document are:

• To describe general concepts of the environmental auditing process and its

• To assist the ARPEL member companies in understanding the requirements for

• To develop a practical manual or guidelines on how to complete environmental

• To assist ARPEL member companies in understanding the benefits of

• To enhance environmental auditing techniques and skills within the ARPEL

• To complement the “Guidelines for Conducting Environmental Audits for Onshore

ARPEL Environmental Guideline No. 14 ii

GUIDELINES FORMAT AND INSTRUCTIONS FOR USE

The Guidelines are provided into three sections as indicated below:

Section I Environmental Audit Reference

Section I Environmental Audit Reference

This section is intended to provide general concepts of environmental auditing.

1 Introduction to Environmental Auditing.

Section II Environmental Auditing User Guidelines

Section II is divided into the following chapters:

6 Phase I Environmental Audit.

iii ARPEL Environmental Guideline No. 14

Section III Environmental Audit Protocols and Guidelines

12 Onshore Operational Audit Guidelines

Guideline Instructions for Chapters 12 and 13.

Chapter 12: Onshore Operational Audit Guidelines

Type of Activity Sections Topics

Environmental Planning Regulatory Environmental Authorization;

General Operating Procedures Surveying and Staking; Topsoil

Spill Prevention and

Waste Management Waste Storage; Sewage Effluent and

Abandonment and Reclamation Cleanup Operations; Road Abandonment;

Environmental Planning Regulatory Environmental Authorization;

ARPEL Environmental Guideline No. 14 iv

General Operating Procedures Access Control; Stream Crossings; Cutting,

Spill Prevention and

Waste Management Sewage Effluent and Wastewater

Abandonment and Reclamation Well Abandonment; Rig Dismantling and Site

Environmental Planning and

General Site Information Site Information.

General Operating Procedures Surface Casing Vents; Pigging; Pumpjacks;

v ARPEL Environmental Guideline No. 14

Spill Prevention & Emergency

Waste Management Waste Management Plan; Disposal of

12.4 Pipelines, Transportation and Terminals

Environmental Planning Regulatory Environmental Authorization;

General Site Information Site Information.

Pipeline Construction Right-of-Way Survey; Cutting, Clearing and

General Operating Procedures Distribution Lines; General Operations at

ARPEL Environmental Guideline No. 14 vi

Waste Management Waste Management Plan; Disposal of

Preliminary Audit Activities Process and Installation Drawings.

General Site Information Site Information

General Operating Procedures Processing, Filter Vessels and Treaters;

Waste Management Disposal of Refinery Wastes; Exposure to

vii ARPEL Environmental Guideline No. 14

Water Recycling and Reuse; Disposal of Oil

Abandonment and Reclamation Reclamation Plan; Site Dismantling; Tank

Chapter 13: Offshore Operational Audit Guidelines

Type of Activity Topics

13.1 Seismic Regulatory Environmental Authorization; Environmental