User Guide for Record of Site Condition
Contents
1. Disposal Areas Compliance Options for Reclamation Certification Compliance Options 1 and 2 are Phase 1 ESAs and do not require an RSC If a drilling waste disposal area is assessed under Compliance Option 3 it requires an RSC In Section 6 3 1 can I select other if there is guideline exceedance that may be professionally justified as minor or abnormal background concentration Prior to exercising this option any possible justifications for guideline exceedance must be approved by the Department Then you may select Other to justify guideline exceedance that may be deemed as minor or abnormal baseline when exercising professional judgment List this reason as well as the substances this applies to in the space provided December 2012 Page 4 of 8 17 18 19 20 RSC Frequently Asked Questions If there are no contaminated areas e g answer to section 6 3 4 is none is it still necessary to complete sections 6 3 5 6 3 6 6 3 10 6 3 11 and 6 3 12 Yes complete the rest of Section 6 3 How should the required summary tables for the contaminants of potential concern on page 6 of the RSC be completed Will the Department accept any format The summary tables may follow the format of the example tables found in the Appendix of the updated RSC User Guide The Department will accept alternative formats too provided that the information included in summary tables is displayed in units and measurements foun2. RECORD OF SITE CONDITION FREQUENTLY ASKED QUESTIONS December 2012 Jbertos Government RSC Frequently Asked Questions ISBN 978 1 4601 0070 7 Printed version ISBN 978 1 4601 0071 4 On line version Web Site http environment gov ab ca info Record of Site Condition Frequently Asked Questions December 2012 Alberta Environment and Sustainable Resource Development Any comments questions or suggestions regarding the content of this document may be directed to Air Land and Waste Policy Branch Policy Division Alberta Environment and Sustainable Resource Development 10th Floor Oxbridge Place 9820 106 Street NW Edmonton Alberta T5K 6 Fax 780 422 4192 Email land management gov ab ca Additional copies of this document may be obtained by contacting Information Centre Alberta Environment and Sustainable Resource Development Ath Floor Twin Atria Building 4999 98 Avenue Edmonton Alberta T6B 2X3 Phone 780 427 2700 Fax 780 422 4086 Email env infocent gov ab ca December 2012 i RSC Frequently Asked Questions INTRODUCTION Purpose of Record of Site Condition Frequently Asked Questions In April 2009 Alberta Environment released the revised Record of Site Condition form RSC The RSC must accompany all Phase 2 environmental site assessment ESA reports remediation reports and risk management plans submitted to the Department This Record of Site Condition Fre
3. d in the Alberta Tier 1 guidelines Is professional sign off required for the RSC No professional sign off is not required but the operator or their authorized representative must sign the Declaration in section 8 Who can sign the RSC Who is an authorized representative Can a consultant sign the RSC The person who signs the RSC must understand the information contained in the form An operator can authorize their consultant or another person familiar with the information in the RSC to sign December 2012 Page 5 of 8 21 22 23 24 25 RSC Frequently Asked Questions QUESTIONS ABOUT REPORTING Is an RSC form required for emergency release assessments such as 7 day reports A release that results in the requirement to submit a 7 day report will require an RSC when the Phase 2 ESA is submitted to the Department Regarding section 6 3 7 what if an operator has taken over a site and is unaware if a spill was reported in the past Is the spill still reportable To whom should I report Alberta Environment and Sustainable Resource Development or Energy Resources Conservation Board ERCB Does a Phase 2 ESA report count as a report Some spills or releases are not known until they are exposed by other work on the site However they should be reported upon discovery If no contamination is left at the site following assessment or remediation there is no need to answer section 6 3 7 If there is still contamination r
4. emaining and this is the first report to Alberta Environment and Sustainable Resource Development check no even if you are not the original operator of the site at the time of the spill For Upstream Oil and Gas sites that are not operating under approval or code of practice with Alberta Environment and Sustainable Resource Development most common releases are reportable to an agency other than the Department Where you are not the original operator of the facility and there is no historical information regarding the substance release it may be difficult to determine reporting requirements based on a Phase 2 ESA In the instance where it is not clear whether the information was reported historical information is lacking but spills resulting from the activity would have been typically reported to an agency other than the Department check not applicable for section 6 3 7 If a tank pull was completed and no contamination was found does a report or RSC need to be submitted No an RSC only needs to be submitted if a Phase 2 ESA was conducted During the Phase 2 ESA we collected samples for soil surface water and ground water Should I attach all summary tables for the samples collected or only select ones Please attach summary information for all samples taken at the site This provides a more thorough summary of the site information Do soil monitoring reports for Approved Facilities require an RSC Yes soil monitoring reports
5. ized agent must provide justification to the Department to demonstrate that the abnormal background condition was properly assessed If this applies to the COPC question 6 2 3 of the RSC can be answered no The exceedance over the generic values of Alberta Tier 1 guidelines should be highlighted in the tables of the analytical results of the ESA report to facilitate report December 2012 Page 2 of 8 RSC Frequently Asked Questions review For more information see the Alberta Tier 1 Soil and Groundwater Remediation Guidelines AENV 2007a as amended How doI complete the RSC for a site with elevated naturally occurring salinity Follow the foregoing approaches provided under Question 7 Can 1 submit an RSC electronically Is there an on line electronic version of the RSC Yes You should submit an RSC together with the ESA report electronically by email Alberta Environment and Sustainable Resource Development is working to develop a web version of the RSC form that may be completed and submitted electronically on line in the future December 2012 Page 3 of 8 10 11 12 13 14 15 16 RSC Frequently Asked Questions QUESTIONS ABOUT THE RSC FORM What who is a landowner Does a long term lessee count as a landowner The landowner of a property is the owner s registered on the land title A lessee is not a landowner What who is an occupant An occupant is a person who resides on a site except fo
6. ld be used to build on this information Where this is not the case only information from the current report is used in completing the RSC form Do subsequent annual or semi annual groundwater monitoring reports need an RSC An updated RSC must be submitted with the subsequent annual or semi annual groundwater monitoring reports The information in the updated RSC form should include new results obtained over the period covered in the monitoring report Sections in the updated RSC for which there is no new information may be left as is Do other facilities such as waste management facilities require an RSC What do I do about contaminants of potential concern that may be present within a landfill cell The RSC form is not to be used to track waste going into the facility or stored within the facility It is meant to track results of monitoring that may be in place to demonstrate that soil or groundwater is not being impacted in and around the approved facility In completing the form do not include information that is specific to the waste cell itself or to a leachate collection system around the cell that may be monitored However an RSC should be prepared and filed accordingly for soil or groundwater monitoring at the compliance boundary Does the RSC also apply to monitoring on compost facilities land treatment facilities or other types of waste treatment facilities Yes Use the RSC form to track monitoring that is meant to demonstrate soil
7. or groundwater is not being impacted in and around the approved treatment area of interest Do not include any monitoring or records that are specific to materials within the approved treatment area in the form December 2012 Page 7 of 8 32 33 34 35 36 RSC Frequently Asked Questions If I am doing the initial Phase 2 investigation at an upstream oil and gas site should I complete an RSC Does the RSC have to be submitted Yes the RSC should be completed when the Phase 2 ESA report is completed This can help prevent future misinterpretations of the site information by others The RSC is required when the Phase 2 report is submitted If a consultant is submitting a reclamation certificate application for a wellsite and there is more than one Phase 2 ESA report does each report need an RSC No only one RSC is required as the information must reflect the current state of the site For example if there is one Phase 2 ESA report from a drilling waste disposal area and three additional reports from a remediated flare pit the current status of the drilling waste disposal and flare pit should be reported on one RSC It may be necessary to use historical information to complete the RSC When filing an RSC that summarizes information from multiple ESA reports use the title of the most recent ESA report Can an RSC be submitted if a portion of the site was assessed using the 2001 Alberta Soil and Water Quality Guidelines for H
8. quently Asked Questions RSC FAQ document serves as a companion document for the Record of Site Condition User Guide 2012 and the Record of Site Condition 2009 The RSC FAQ is developed to address frequently asked questions received by Alberta Environment and Sustainable Resource Development It is intended to be a living document and may be periodically updated or amended For further information or in the event of discrepancy refer to Alberta Tier I Soil and Groundwater Remediation Guidelines 2007a as amended Alberta Tier 2 Soil and Groundwater Remediation Guidelines 2007b as amended and the Record of Site Condition User Guide 2012 December 2012 Page 1 of 8 RSC Frequently Asked Questions GENERAL QUESTIONS Do I have to submit a Record of Site Condition RSC to Alberta Environment and Sustainable Resource Development Yes Any Phase 2 environmental site assessment ESA report remediation report confirmatory data report or risk management plan required by the Department must be submitted with a completed Record of Site Condition What happens if a Phase 2 ESA is submitted without an RSC A Phase 2 ESA submitted without an RSC will be refused as incomplete Reports for approved facilities without an RSC will be deemed administratively incomplete Do Phase 1 ESA reports need an RSC What if there is a probability of contamination No Phase 1 ESA reports do not require an RSC An RSC would be submitted wi
9. r agricultural sites For agricultural sites an occupant includes someone who may only access the site occasionally for an agricultural operation What is the AENV file number The Development issues file numbers for some types of site activities Sometimes these numbers may change due to a change in site operation In that case use the most recent file number issued by the Department The recent name change of the Department does not affect the numbering system Where do I get an AENV file number An Alberta Environment and Sustainable Resource Development file number will be assigned by a staff member of the Department upon the initial correspondence or first written submission regarding a site activity If there has not been previous correspondence with the Department on a site activity or an Alberta Environment and Sustainable Resource Development file number does not appear on correspondence leave this box blank How do I answer question 6 2 2 on the RSC if a Phase 2 ESA is conducted to assess a drilling waste disposal area but the disposal area is not found If the Assessing Drilling Waste Disposal Areas checklists or calculations require a Phase 2 ESA for the drilling waste disposal area then a reasonable effort must be made to locate and sample the disposal area If it cannot be found then answer no to question 6 2 2 Is an RSC required for the Compliance Option 1 or Compliance Option 2 checklists in Assessing Drilling Waste
10. require an RSC for the area s being monitored in the current report Areas that were monitored in previous years should not be included in the RSC only information from the current report is required December 2012 Page 6 of 8 26 27 28 29 30 31 RSC Frequently Asked Questions Do soil management reports for Approved Facilities require an RSC Yes soil management reports require an RSC for the area s being assessed monitored or remediated in the current report Information from the current report is required to update the status of site Do groundwater monitoring reports at EPEA approved facilities or non approved facilities require an RSC Groundwater monitoring reports add to information about the status of the site and must include an RSC My facility requires an annual or semi annual groundwater monitoring report This is the first groundwater monitoring report for the facility that requires an RSC Do I need to include previous or historical information for the RSC If the previous reports have indicated soil or groundwater contamination and the site has not been remediated or if the facility is currently under a soil or groundwater management program to address contamination at the site the first RSC that is filed for the facility should include historical information to give as accurate a representation as possible of the status of the site at the time of filing The groundwater monitoring information shou
11. th the subsequent Phase 2 ESA following sampling delineation and or remediation of soil and groundwater at a site If a report is dated prior to May 1 2008 but submitted to the Department after that date is an RSC required Yes The requirement to submit an RSC is based upon the report submission date not the date of the report or when the ESA work was done ALL Phase 2 ESA reports and risk management plans submitted to the Department after May 1 2008 require an RSC If a release occurred after the 2009 RSC version was released on April 6 2009 do I have to submit the RSC by June 30 2009 No Please submit the RSC when the Phase 2 ESA report is submitted The June 30 2009 date only applies to reports previously submitted between May 1 2008 and April 06 2009 without an RSC Have Alberta Environment and Sustainable Resource Development s release reporting requirements changed No Only the requirement to submit the RSC as part of the ESA has changed Continue to submit Phase 2 ESA reports risk management plans as in the past How do I complete the RSC form for a site with elevated natural concentrations of the assessed compounds If the natural concentration of a COPC in the absence of any input from anthropogenic sources or activities exceeds the generic values of the Alberta Tier 1 guidelines the natural background concentration may be used as a Tier 1 assessment endpoint The licensed operator or its author
12. ydrocarbons at Upstream Oil and Gas Facilities In 2007 the Department s Tier 1 and Tier 2 guidelines replaced the Alberta Soil and Water Quality Guidelines for Hydrocarbons at Upstream Oil and Gas Facilities 2001 Upstream Guidelines When the reports being submitted are part of a Reclamation Certificate application for an upstream oil and gas site the Department will accept RSC submissions that are compliant with the 2001 Upstream Guidelines or for substances other than hydrocarbons or PAHs the 1994 Alberta Tier 1 Criteria as long as all the laboratory analytical data reports from all Phase 2 ESA and confirmatory sampling events were dated on or before December 1 2007 If this is the case you may check Yes Where is an RSC submitted with the reclamation certificate application An RSC submitted with a report as part of a reclamation certificate application package should be submitted to the Regulatory Approvals Center RAC at the following address Reclamation Certificates Regulatory Approvals Centre Alberta Environment and Sustainable Resource Development 9820 106 Street Edmonton Alberta T5K 2J6 Do I have to submit an RSC for reports that are submitted to the ERCB or the Alberta Utilities Commission No An RSC is only required for Phase 2 ESA and risk management reports submitted to Alberta Environment and Sustainable Resource Development December 2012 Page 8 of 8
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