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Tracking and Manifesting Produced Water, AER Bulletin 2019-29

Link to Bulletin Summarized

Bulletin – Waste Management – Produced Water

On November 19, 2018, Alberta Transportation issued Permit 2018-4703 for transporting produced water by truck that has not been cleaned or purged. Due to the overlap with the AER’s tracking and manifesting requirements found in Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry, some confusion has arisen.

All Directive 058 requirements are still in force and are independent of Alberta Transportation requirements. Companies must continue to comply with all AER requirements, including the following:

  • track, report, and manifest produced water using the code “WATER: Water – Produced (including brine solutions),” even if being transported with a transportation of dangerous goods placard;

  • follow the list of codes in Appendix 3 of Directive 047: Waste Reporting Requirements for Oilfield Waste Management Facilities when tracking, reporting, or manifesting oilfield waste; and

  • if contaminants are present, characterize the water. If the properties are deemed dangerous, as outlined in Directive 058, then use the Alberta Oilfield Waste Manifest Form and adhere to manifesting requirements outlined in section 8 of Directive 058 when transporting the waste within Alberta.

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