Last Updated on February 23, 2020
TransMountain Pipeline Expansion Work Within the Armisie (Oil) Field – a Potentially Explosive Matter
Landowners and residents in Edmonton Cameron Heights and Windermere neighborhoods have likely noticed that construction of the TransMountain Expansion Pipeline, Spread 1, has commenced in the general area of Armisie Field in Urban Edmonton. Armisie Field is located directly south of the Cameron Heights/184th Street overpass on Anthony Henday Drive or Highway 216 (Edmonton’s ring road). Travelers on Anthony Henday Drive will surely have noticed the pipeline construction activity, but is it safe?
Welding and other sources of ignition (such as vehicles and human activities) can (and will if air mixtures are within explosive range) ignite fugitive Armisie Field ignitable vapours.
The TransMountain Contractor (SA Group, a joint venture) has been formally advised not to work within the drag or staging area leased to weld up pipes to be pulled under Anthony Henday Drive, until a facility known as the Armisie Tank Battery and Compressor Station has been shut in (rendering adjacent pipeline work safe).
Because virtually all authorities with regulatory responsibilities have been contacted and requested to intervene to ensure public safety in the area have been contacted, but none have taken appropriate actions to ensure public safety, below links to videos and documents explaining the scandalous situation are provided. The party with the ultimate responsibility is MAGA Energy Operations Ltd. (“MAGA“).
The most responsible persons are: MAGA CEO Mark Ross, cell number (403) 850-1300. The Minister of Infrastructure, the Honorable Prasad Panda (because of the Transportation/Utility Corridor). Mr. Tyler Callicutt (if still employed) of the Alberta Energy Regulator (Edmonton Field Office), Phone: (780) 638-5658.
In the photo below, the Transportation Utility Corridor (TUC) is shown in pink. The lands impacted by pipeline work are shaded yellow. An existing ATCO gas line route is shown in yellow, and the TransMountain Expansion Pipeline route is shown in green parallel to the ATCO line. The offending tank battery and compressor station can be seen in the southernmost part of the yellow-shaded work area. The north portion is in the TUC and the south portion is on private land.
The same area as depicted by Alberta Energy Regulator software is shown below. Land ownership details have been added. “ERDA” means the Edmonton Restricted Development Area, administered by Alberta Infrastructure. The route of the TransMountain Expansion (TMX) is shown in grey.
The new Riverview Substation, built in Location B as illustrated above, has recently been connected to power lines. It is potentially in danger as are area residents and travelers on Anthony Henday Drive if fugitive gases in explosive mixtures make their way into the Riverview substation shown below (substations inherently are sources of ignition for ignitable gas vapours).
Regular Armisie Field Sour Gas Emissions, and Lack of Sour Gas Emergency Response Planning to Regulated Standards
Travelers and workers in the area may also have noticed, from time to time, the stench of sour gas that has regularly emitted from the Armisie Tank Battery, Licence F-20254 now said to be owned by MAGA Energy Operations Ltd. Construction by EPCOR Distribution & Transmission Inc. of the new Riverview Power Substation adjacent to Maskekosihk Trail is similarly noticeable.
VIDEO: Below are links to five videos that outline the issues. The first three videos pertain to spacing issues and TMX welding work to occur adjacent to the tank battery facility. Two more videos pertain to past and current sour gas emergency response planning that has never conformed to the regulated requirements of Alberta Energy Regulator Directive 071 requirements.
Sour Gas Emergency Response Planning (Lack Thereof) Videos: Part 1. Part 1 explains past errors, Part 2. Part 2 reviews recent errors related to a current update, and ties these into the Riverview Substation approval issues.
Natural gas (called solution gas) produced by Armisie Field oil wells is not very sour (it contains less than 2.5% Hydrogen Sulphide (H2S) by volume, and should be less than 0.66% H2S to be compliant with tank battery and compressor station Licence No. F-20254). H2S is a marker, by way of alerting one’s sense of smell, that potentially explosive natural gas that is odorless is also in the area in much higher concentrations. A mixture of between approximately 5% to 15% of natural gas in air is explosive.
Proximity Issues: Other Unsafe and Regulatory Non-Compliant Operations Within Armisie Field
Major Power Transmission Line No. 1202 (owned by AltaLink Management Ltd.), more accurately the right-of-way this power line is contain in, is too close to tanks within the Armisie Tank Battery by law, as shown below. As shown above, no residential subdivision is to be approved if it is within 1.5 kilometres of a sour gas facility (there are two of such facilities in Armisie Field). For these and other reasons tank battery operations simply must be shut down.
LETTERS SENT TO MAGA AND VARIOUS OFFICIALS – February 23, 2020
Today’s date, two letters have been sent to MAGA demanding that the tank battery be shut in for public safety and other reasons (non-conformance of operations with various laws). Copied are APEGA (the Alberta Professional Engineer and Geologist Association), whose members have a public safety and self-regulating mandate, the Alberta Energy Regulator, the provincial Minsters of Infrastructure and Energy, and the power line and substation owners.
The City of Edmonton and the Alberta Energy Regulator have been contacted today’s date regarding proximity of residential subdivisions to Armisie Field facilities as first illustrated above.
If the necessary actions are not taken by MAGA, such letters will be posted in this space below because the traveling public and area residents, landowners, and land developers have a right to know.
2017 Archives: Proposed EPCOR Power Station Near Armisie Tank Battery
While Armisie field area landowners await an Alberta Energy Regulator decision on re-injection of sour oil well solution gas, and while flaring of sour gas continues (apparently without the necessary permit) as a result, there are new developments:
- EPCOR wishes to build a power substation near the tank battery, in the Transportation Utility Corridor, to service the future needs of Southwest Edmonton including the Riverview Area.
- EPCOR has contacted adjacent landowners for input, which we have provided. Links below.
March 15, 2017 – Report Provided to EPCOR: Risk Mitigation and Land Use Issues. Proposed Riverview Substation Location (the “EPCOR Report“). Also: Attachments (TABS 1-14) to the EPCOR Report
Regulatory Appeal of Solution Gas Re-Injection Approval
December 12, 2016 – Approval Holder Submissions, AER Regulatory -Appeal – 1869031
September 23, 2016 – Submissions-Regulatory-Appeal-1869031
October 19, 2016 – Response to Alberta Energy Regulator October 19, 2016
October 18, 2016 – Alberta Energy Regulator Correspondence, Regulatory Appeal No. 1869031
October 13, 2016 – Regulatory Appeal with attachments as follows:
October 13, 2016 – 1832419-Dorin-NOD-Final-AER-Reasons.pdf
October 13, 2016 – Approval12447.pdf
May 16, 2016 – Dorin Management Recommendations and Notices with four attachments as follows:
- 2005_07_28 EUB Decision 2005-085
- 2007 SRB Decision w Comment
- 2015_06_26. AER Correspondence Sales Gas Line Use and Battery Inlet
- 1954_01_28. Trust Deed between Armisie and National Trust Company including Schedule A 1950 Mineral Lease Chain of Title
May 12, 2016 – Penn West response to Singh Statements of Concern
May 12, 2016 – Penn West response to Dorin Statements of Concern No. 30235
Related doctoral thesis by Topal Cagri: Thesis-Topal_Cagri_Fall-2011
Alberta Energy and Utilities Board, Decision 2005-085, Petrofund Corp., Application for a Well Licence, Armisie Field, July 28, 2005
Penn West Petroleum Ltd. has requested approval of an Enhanced Oil Recovery scheme, involving re-injection of solution gas. Alberta Energy Regulator Application 1832419
Statements of Concern Related To Penn West Application Number 1832419
Filed on April 8, 2016
Addenda to Statements of Concern:
Letter sent to the Alberta Energy Regulator dated March 21, 2016 with regards to Application 1832419 by Penn West:
Documents relating to Application 1832419 from the AER’s Integrated Application Registry (May require Microsoft Internet Explorer to view individual files):
Current Proposal for Enhanced Oil Recovery and Re-Injection of Sour Gas
Armisie Oil Field. Urban Edmonton
Between Anthony Henday Drive and 23 Avenue, at 184th Street / Cameron Heights Drive
Information for those seeking to be included in a group filing Statements of Concern
Preliminary Issues for review by potential group participants have been posted as Revision 0.
The Armisie field was discovered in 1951. It now consists of the following active activities:
- Some seven sour oil wells (producing and/or capable of producing).
- A suspended gas well
- A water disposal well
- An oil tank battery and compressor station (Licence F-20254)
- A sales gas pipeline that extends to the south and east of the field, through the new Riverview Heights area of Edmonton and Parkland County (Licence 35962)
The Current Problems and Issues
According to Alberta Energy Regulator Records, the sales gas pipeline was shut down and discontinued on February 1, 2015. Penn West’s position, on record with said Regulator, is there was a break in the sales gas pipeline, which Penn west appears unwilling or unable to repair.
Sales gas pipeline problems gave rise to the pending application for Enhanced Oil Recovery (EOR) and gas re-injection. Re-injection of gas in the producing Blairmore formation would negate the need for future use of the sales gas pipeline.
Ongoing Flaring and Venting of Sour Gas
Since shut in of the sales gas pipeline the operator, Penn West Petroleum Ltd., shut down all but two oil wells and:
- Presumably has been incinerating produced sour gas in an incinerator stack at the tank battery (located near the Anthony Henday Drive/Cameron Heights Drive overpass.
- Has definitely been venting sour gas to atmosphere as recorded by the Alberta Energy Regulator.
Regulator Inspectors Claimed the Sales Gas Pipeline Was Still In Use
Dorin Management, as representative of Armisie Field landowners, has been opposed to use of the sales gas line since 2013. We filed applications with the former ERCB and current Regulator in such regards, which have not been disposed of. The allegation is that natural gas containing hydrogen sulfide that exceeds the licensed H2S concentration for the sales gas pipeline was transported in the past and could still be transported in future.
Circa June of 2015, Regulator inspectors assured us that gas being transported in the sales gas pipeline (which was to have been shut in according to the Regulator’s public records) was well below licensed H2S concentrations.
Penn West’s proposal has the benefit of increasing safety along the sales gas pipeline.
Penn West’s proposal has the disadvantages of:
- Decreasing safety for those traveling on local roads, including Anthony Henday Drive
- Decreasing safety for local residents, present and future.
Our regulator bodies, the Alberta Energy Regulator, Occupational Health and Safety, and the Surface Rights Board must balance the rights of all stakeholders. We intend to do our part to ensure a reasonable balance is struck.
If the Alberta Energy Regulator acts on Penn West’s woefully inadequate Application No. 1832419, such a balance is impossible.
The critical shortcomings of Penn West’s application are set out in the Preliminary Issues we have developed (Link Below).
- Penn West did not fill out the portion (Section 5) of the Application Form related to Notification of stakeholders in the area;
- It apparently took some nine months for this to be noticed by the Regulator
- Participant Involvement should have been conducted, and Penn West should have set out landowner concerns (the landowners should not be requested to do so at this late date by way of Statements of Concern)
In our view, the Regulator’s proceedings are tainted. The Regulator should begin afresh, to avoid unnecessary costs to landowners and injustice arising from Penn West’s Application and Proposal. These are fundamental principles of natural justice, which have been ignored.
To learn about or join a group that is filing statements of concern (deadline April 8, 2016 unless extended) please contact Dorin Land and Oilfield Management Inc.