There are a large number of oil and gas sites with salts in soil that exceed one or more generic
guideline values. The nature of generic guidelines is that, by definition, they do not uniquely
consider site-specific conditions and therefore may indicate the potential for an adverse effect when in actuality there is no such potential. Undertaking remedial activities where no potential for adverse effect exists will result in a negative net environmental benefit. Resources (equipment, consultants, money, landfill space, time, etc.) allocated to remediation with no benefit to environmental protection could be used to address more significant environmental problems or to increase the number of sites reclaimed. The benefit of generic guidelines is that they are easily administered with clear remedial endpoints.
Given the concerns noted above with applying generic guidelines to salt sites, there is a need for an alternative method of managing these sites. The alternative method should be efficient (cost, timely) and science-based. A method meeting these objectives will enable timely, economic regulatory closure and will significantly reduce the net negative environmental benefit that can occur when unnecessary intrusive remediation occurs. This would be beneficial to landowners, regulators, the public and industry. Petroleum Technology Alliance Canada has initiated a project to look for a solution to these issues. The current document provides a proposed solution.
The objective of this project is to develop a scientifically-defensible protocol for closure of salt-affected sites in native prairie settings where there are no current, and no likely future adverse effects from the salts.