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1 2 3 4 5 6 ALBERTA ENERGY AND UTILITIES BOARD 7 HEARING, COMPTON 8 PETROLEUM CORPORATION 9 APPLICATION NOS. 1276857,1276858, 10 1276859, 1276860, 1307759, 1307760, 11 1278265 and 1310361 12 13 14 15 Board: Mr. Arden Berg, Chairperson 16 Mr. John Nichol, Board Member 17 Mr. Gordon Miller, Board Member 18 19 20 21 Held: Calgary, Alberta 22 23 February 2nd, 2005 24 25
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1 APPEARANCES 2 J.R. McKee )Board Counsel 3 Barbara Kapel Holden ) 4 5 Allan McLarty )Compton Petroleum Corp. 6 Lars Olthafer ) 7 8 Stan Carscallen (np) )AG, Sandy Soutzo and 9 Brent Robinson )Ollerenshaw Ranch 10 Student-at-law 11 12 Gavin Fitch (np) )Front Line Residents Group 13 14 Richard Secord )White Family 15 16 Lewis Manning )Calgary Health Region 17 18 Shawn Munro (np) )Adjacent East Owners 19 20 Leila J. Gosselin )City Of Calgary 21 22 Craig Tomalty (np) )MD of Rocky View 23 Daron Naffin (Np) )Evans Development Ltd 24 Brian O' Ferrall, Q.C. (np) )Brian and Janice Evans 25 Andrew G. Kay )
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1 APPEARANCES (cont'd) 2 3 Don Edie )Carma Developers Ltd. 4 5 James Laycraft )Richard and Sue Pearson 6 7 David Brett )Coalition of Concerned 8 Communities 9 10 Nick Baiton )Joyce Newton 11 12 Harald Thimm (np) )Private Citizen 13 14 Michael Queenan )Private Citizen 15 16 Patricia Brown (np) )Calgary Friends Of 17 Medicare 18 19 Brian Pincott (np) )Sierra Club 20 21 Jeff Burns (np) )Burns West Corp 22 Tracy Clark ) 23 24 25
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1 TABLE OF CONTENTS 2 Page No. 3 List of Exhibits 3459 4 List of Undertakings 5 6 Compton's Panel 3: 7 GARY FOLLENSBEE, Resumed; 8 WADE MROCHUK, Resumed; 9 RUSSELL BROWN, Resumed; 10 JOSEPH KENNY, Resumed; 11 GREGORY CROOKS, Resumed; 12 RICHARD BISSETT, Resumed; 13 DEREK LONGFIELD, Resumed; 14 15 Questions by Mr. J.R. McKee 3485 16 17 Reporter's Certificate 3734 18 19 20 21 22 23 24 25
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1 LIST OF EXHIBITS 2 No. Description Page No. 3 039-001 Compton- Report on Corporate 4 Governance (see Undertaking No. 1 5 page 62, line 21 given to Mr. Fitch 62 6 039-002 Compton - 2003 Annual Report (see 7 Undertaking No. 2, page 171 give to 8 Mr. Brett) 171 9 039-003 Compton - Information Compton Board 10 had when making the determination 11 to proceed with the applications. 12 (See Undertaking No. 3, page 176, 13 line 16, given to Mr. Brett) 176 14 39-004(a)(b) Copy of LRD Agreement February 15, 15 (c) 2001 and Amending Agreement May 31, 16 2002 and Amending Agreement May 14 17 2004 301 18 39-005 Application by Burns West 19 Corporation, dated January 12, 20 2005, for Intervenor Status. 367 21 39-006 Response to Undertaking 4 22 regarding drilling timing 23 and scenarios.(Given to Mr. Secord, 24 page 525, line 20) 572 25
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1 EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-007 Mr. Longfield's calculation of 4 spare capacity for Mr. Richard 5 Secord - (see Undertaking 6 No. 5, page 530, line 19) 575 7 39-008(a)(b) Responses to Undertaking 7 8 and 8 re material data sheets. 9 (Given to Mr. Secord at page 578 10 line 16 and page 579, line 5) 579 11 39-009 Answer to Undertaking No. 9 12 - revised Completions Plan Program. 13 (Given to Mr. Secord at page 582, 14 line 23) 583 15 39-010 Response to Undertaking 10 - 16 spec sheet on the high stage 17 separator (Given to Mr. Secord at 18 page 614, line 11) 615 19 39-011(a) Response to Undertakings 11 re 20 (b) provide MSDS for Greencide; 21 Undertaking 12 provide MSDS for 22 Amine. (Given to Mr. Secord at 23 page 623, line 1 and page 624 24 line 5) 626 25
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-011(c) Response to Undertaking 13 re 4 Provide Compton's specs for 5 compressor that is now part of 6 Appendix IV. (Given to Mr. Secord 7 page 645, line 8) 645 8 39-011(d) Response to Undertaking 14- 9 specifications of additional 10 Tank on Well site.(Given to Mr. 11 Secord, page 666, line 23) 667 12 39-011(e) Response to Undertaking No. 15 13 - Schematic Flow Process 14 (Given to Mr. Secord page 668, line 1 668 15 39-011(f) Specification sheet for the 16 Questor 5000 Incinerator. (Given to 17 Mr. Secord page 549, line 18 763 18 39-012 Excerpt of transcript of 19 October 30, 1997. 640 20 21 22 23 24 25
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1 LISTS OF EXHIBITS (cont'd) 2 EXHIBIT No. Description Page No. 3 39-013 Response to Undertaking 16 - 4 Give some thought to, if relief 5 wells were required, what would 6 be the location of those, what you 7 would consider to be the quote 8 "ideal" or the sort of the 9 reasonable location for them, also 10 the minimum distance from the 11 existing wells that you think might 12 be practical and do it for drilling 13 and completion scenarios separately. 748 14 (Given to the Chair, page 745, line 24) 15 39-013(a) Schematic of Compton pad site 16 10 of 13-23-29 with a hand-drawn 17 revision on it and some 764 18 information. (Given to the Chair, 19 page 745, line 24) 20 39-013(b) Document entitled ARP-1 21 Review 1993. (Given to the Chair, page 22 745, line 24) 765 23 24 25
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-013(c) Compton, North Okotoks's 4 Horizontal Well Program, 5 hypothetical events leading 6 to a blowout condition. (Given to the 7 Chair, page 745, line 24 765 8 39-014 Response to Undertaking Number 17 9 - A document which speaks to the 10 hypothetical events leading to 11 a blowout on servicing. (Given to 12 Mr. Manning, page 808, line 17 809 13 39-015 Response to Undertaking No. 18 14 - Document setting out insurance 15 coverage that is in place, and 16 the option to increase. (Given to 17 Mr. McKee, Page 884, line 8) 884 18 039-016 Compton's Engineering Environmental 19 Health and Safety Committee Charter 1026 20 039-017 Confirmation of whether production 21 testing will include a line heater 22 (Given to Mr. Secord, Undertaking No. 23 19 page 1040, line 4) 1040 24 25
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1 LIST OF EXHIBITS (Cont'd) 2 Exhibit No. Description Page No. 3 039-018(a) Clarification from Grant Testing 4 on equipment specifications 5 (Given to Mr. Secord, Undertaking 6 No. 20, page 1044, line 24) 1045 7 039-018(b) Request specifications from 8 Grant Production Testing Services 9 for the 740 Frac Separator.(Given 10 to Mr. Secord, Undertaking No. 21, 11 page 1048, line 5) 1048 12 39-019(a) List of commitments made by Compton 13 during the Hearing (Given to 14 Chairperson as Undertaking No. 22, 15 page 1209 Line 12 1210 16 39-019(b) Compliance and Inspection Record 17 for drilling and completions for 18 the last five years (Given to 19 Chairperson as Undertaking No. 23, 20 page 1232, Line 1) 1232 21 39-019(c) Compliance and Inspection Record for 22 production operations for the last 23 five years (Given to Chairperson as 24 Undertaking No. 24, page 1232, Line 16) 25 1232
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1 2 3 List of Exhibits (cont'd) 4 Exhibit No. Description Page No. 5 39-019(d) Analysis conducted by Compton 6 of relationship between length 7 of horizontal wellbore and H2S 8 release rate. (Given to 9 Chairperson as Undertaking 10 No. 25, page 1245, Line 17) 1246 11 39-020 List of EUB Pre-filed Exhibits 1353 12 39-021(a) Compton's verification from 13 Firefly that the one (1) minute 14 ignition is achievable.(Given to Mr. 15 Gavin Fitch as Undertaking No. 26, 16 page 1410, line 13) 1410 17 39-021(b) Compton's update of the 5.2 Ignition 18 Procedure in the Emergency Response 19 Plan (Given to Mr. Gavin Fitch as 20 Undertaking No. 27, page 1414 line 21) 1415 21 39-021(c) Records from ignition drills from other 22 critical sour wells drilled by 23 Compton in the past two years. 1496 24 39-021(d) Date when Mr. Crooks of JW Environmental 25 Ltd. became involved in the preparation
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1 of Compton's submission 1496 2 3 LIST OF EXHIBITS (cont'd) 4 EXHIBIT NO. DESCRIPTION PAGE NO. 5 and how they have incorporated this 6 information into their drilling and/or 7 emergency response plans. (Board 8 order/Undertaking No. 28, page 1495, 9 line 15) 1496 10 39-022 Package of two (2) letters. One 11 (1), a letter dated April 29th, 12 2002 from Mr. Fitch to Mr. Longfield 13 and a response of May 21st, 2002 14 from Mr. Longfield to Mr. Fitch on 15 the matter of the Jacques Whitford 16 report. 1528 17 39-023 Excerpts from EUB model sour well EPZ 18 calculation spread sheet Volume 2, 19 User's Guide (Draft) December 2003. 1605 20 39-021(e) Jacques Whitford Environment Limited to 21 provide results of H2S modeling using 22 alternate parameters to those used in 23 Exhibit 002-004E (Given to 24 Mr. Gavin Fitch as Undertaking 25 No. 30, page 1667 line 9) 1667
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1 2 3 LIST OF EXHIBITS (cont'd) 4 Exhibit No. Description Page No. 5 39-021(f) Compton's framework for ERP 6 training and information program 7 dated July 12th, 2004 (Given to 8 Mr. Gavin Fitch as Undertaking 9 No. 31, page 1730 line 10) 1730 10 39-024 Paper presented by Mr. Brown 11 entitled, "How to Design and 12 Establish Site-Specific Emergency 13 Plans" presented at the Dealing 14 with New Gas Flaring Rules, 15 September 25th, 26th, 2001. 1844 16 39-025 Mr. Bissett to review and provide 17 comment on EUB General Bulletin 18 2003-23, "Revised Guide 56: Energy 19 Development Applications and 20 Schedules," June 27, 2003 (Given to 21 Chairperson as Undertaking No. 32, 22 page 1846 line 23) 1847 23 39-026 Appendix 1 of the October 2000 24 version of EUB Guide 56 entitled, 25 EUB Policy and Technical
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1 Guidelines. 1915 2 3 4 LIST OF EXHIBITS (cont'd) 5 Exhibit No. Description Page No. 6 39-021(g) Provide the date when the 7 Compton North Okotoks Project 8 video was removed from Compton's 9 web site 1969 10 39-027 Excerpt from EUB Decision Report 11 2002-041, Compton Petroleum 12 Corporation Applications for A 13 Sour Gas Well, Batteries, and 14 Associated Pipelines, Vulcan Field; 15 pages 1, 18 and 19. 1985 16 39-028 Article from the Daily Oil Bulletin 17 July 12, 2001 titled "Alberta Well 18 Blowouts Brought Under Control" 19 as well as a two (2) page printout 20 from the web. 1987 21 39-29(a) Compton to provide a document 22 addressing the integrity of the 23 North Mazeppa pipeline. (Undertaking 24 No. 38 given to Mr. Secord at 25 page 2042, line 20) 2045
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-029(b) Compton to provide a letter 4 from EUB confirming the EUB's 5 satisfaction with Compton's 6 current corrosion mitigation 7 program for the North Mazeppa 8 pipeline. 2048 9 39-029(c) Compton to produce the six month 10 reviews with the EUB Pipeline 11 Department since 2000. (Given to 12 Mr. Secord as Undertaking No. 40, 13 page 2047 line 12) 2049 14 39-029(d) Copy of management agreement between 15 Compton and the Mazeppa Processing 16 Partnership. 17 39-029(e) Package of six letter from EUB to 18 Border Midstream Services Ltd. and 19 Mazeppa Processing Partnership 20 regarding the corrosion mitigation 21 program implemented on the Mazeppa 22 pipeline system (2001-2004) 23 39-029(f) Copy of the monthly cathodic protection 24 checklist and the daily visitation 25 checklist from the 10-13 lease
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-030 Package containing: 1. A letter 4 from D. Patterson of the Mazeppa 5 Processing Partnership to D. Grzyb 6 of the EUB regarding a pipeline 7 integrity program review request, 8 Oct 29, 2003; 2. Excerpts from 9 Baker Hughes report dated June 2003 2054 10 039-031 Package containing three (3) 11 reports prepared by Baker 12 Hughes: 1. "Mazeppa Processing 13 Partnership, North Section, 14 Corrosion Mitigation Program 15 Changes," Oct. 24, 2003; 2. 16 "Mazeppa Processing Partnership, 17 11-24-22-29 to 10-13-22-29 Line 18 Mitigation Proposal," Oct 24, 19 2003; 3. "Mazeppa Monitoring 20 Recommendations," Oct. 27, 2003. 2055 21 039-032 File of information contained 22 in Ex. 039-030 and Ex. 039-031 2056 23 24 25
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1 LIST OF EXHIBITS 2 EXHIBIT NO. DESCRIPTION PAGE NO. 3 039-033 Compton to calculate emergency 4 planning zone radii based on 5 release rate results contained 6 in Exhibit 039-021(e) 7 039-021(h) Mr. Crooks to perform additional 8 dispersion modeling using a drag 9 coefficient of 2 for 15-minute 10 and 30-minute time-to-ignition cases. 2257 11 39-034(a) Letter regarding further insurance 12 coverage available to the Mazeppa 13 Processing Partnership (Undertaking 14 No. 45, given to Mr. Manning 15 page 2385, line 25) 2386 16 39-034(b) To provide retainer agreement 17 between Compton and Jacques 18 Whitford Environment Limited for 19 the preparation of "Risk Analysis 20 of the Compton Petroleum Corporation 21 North Okotoks Horizontal Sour Well 22 Project" (December 2001) 23 (Undertaking No. 44 given to Mr. 24 Manning at page 2368, line 8. 2369 25
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-035 Excerpt from ERCB Decision 84-9 4 (Lodgepole Blowout Inquiry), Section 5 1, pages 3 and 4 2396 6 39-036 Letter from CRHA to Mr. Bissett dated 7 May 11, 2001 2401 8 39-037 Page iii from Jacques Whitford December 9 10, 2001 draft of the ERP provided 10 to the CHR 2464 11 039-029(g) Estimate of time from Mazeppa 12 gas plan to the 10 of 13 well site. 2492 13 39-038 Excerpt from Jacques Whitford December 14 10, 2001 draft of the ERP provided 15 to the CHR 2517 16 39-034(c) Mr. Crooks to determine how many 17 versions of the draft Jacques Whitford 18 Environment Limited report "Risk 19 Analysis of the Compton Petroleum 20 Corporation North Okotoks Horizontal 21 Sour Well Project" (December 10, 2001) 22 were produced and what differences 23 may exist between the versions. 24 (Reserved Exhibit No. 039-034(c), 25 given to Mr. Manning, page 2603, line 23) 2604
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-034(d) Provide information regarding 4 Compton's insurance coverage as 5 it relates to liability with 6 respect to the public in the event 7 of a blowout(Undertaking No. 46, 8 Given to Mr. Manning, page 2388, 9 line 8) 2388 10 39-039(a) Compton to determine whether there 11 is a separate assignment agreement 12 between Dynegy Canada Ltd. and Border 13 Midstream Services Ltd. with respect 14 to the Land Use and Resources 15 Development Agreement of February 15, 16 2001. (Undertaking No. 50 given to 17 Mr. Edie, page 2621, line 3) 2619 18 39-039(b) Compton to determine whether the 19 Mazeppa Processing Partnership would 20 be willing to commit to the 21 abandonment of the Chestermere pipeline 22 north of the Bow River within 15 years 23 of the issuance of the subject well 24 licences (Undertaking No. 51, given 25 to Mr. Edie page 2629, line 11) 2629
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-040(a) Provide compliance records for Mazeppa 4 pipeline (Undertaking No. 52, given to 5 the Chairperson, page 2785, line 13) 2785 6 39-040(b) Comment on response(s) to incident(s) 7 documented in Exhibit 039-019(b)(c). 8 (Undertaking No. 53, given to The 9 Chairperson, page 2787, line 16) 10 278739-040(c) Mr. Kenny to describe how horizontal 11 wellbore flow rates were derived in 12 Exhibit 039-019(d)(Undertaking No. 13 54, given to The Chairperson, 14 page 2790, Line 9) 2790 15 39-041 Upstream Petroleum Incident 16 Support Plan (2002), accompanied 17 by a foreword by the Minister 18 of Alberta Municipal Affairs 19 dated April 7, 2003 2793 20 39-042 Confirm licence number for sweet 21 fuel gas pipeline running 22 parallel to Chestermere pipeline 23 (Undertaking No. 55, given to 24 Mr. O'Ferrall, page 2840, line 25. 2841 25
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 39-043 Mr. Crooks to model 500-, 1000-, 4 and 1500-metre horizontal wellbore 5 release rates using 3-minute 6 and 7.5 minute times-to-ignition. 7 (Undertaking No. 56, given to Mr. 8 Thimm, page 3060, line 18. 3061 9 39-044(a) Confirm whether, at the time of the 10 Canadian Occidental purchase in 1977, 11 Compton was already engaged in sour 12 Operations (Undertaking no. 58, given 13 to Mr. David Brett, page 3167, line 8) 3167 14 39-044(b) Confirm that Compton was aware that 15 the Chestermere pipeline licence was 16 due for renewal in 1999 when it 17 was acquired in 1997. (Undertaking 18 No. 59, given to Mr. Brett, page 19 3209, line 1) 3209 20 21 22 23 24 25
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 039-044(c) Mr. Longfield to determine whether, 4 prior to the issuance of the 5 Jacques Whitford Environment 6 Limited (JWEL) draft report 7 "Risk Analysis of the Compton 8 Petroleum Corporation North 9 Okotoks Horizontal Sour Well Project" 10 (December 2001), Compton had received 11 any verbal report from JWEL to provide 12 comfort regarding the proposed 13 reduced EPZ (Given to Mr. Brett 14 page 3203, line 22) 3483 15 039-044(d) Confirm the date that the 16 Engineering, Environmental Health 17 and Safety Committee was founded, 18 and whether there is an earlier 19 charter than the one found in 20 Exhibit 039-016. Additionally, 21 confirm whether its predecessor 22 was named the Reserves Safety and 23 Environment Committee. (Undertaking 24 No. 59 given to Mr. Brett, page 25 3209, line 1. 3484
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1 LIST OF EXHIBITS (cont'd) 2 EXHIBIT NO. DESCRIPTION PAGE NO. 3 039-044(e) Provide those documents listed in 4 Ex. 002-001(a) (p. 5) which are not 5 available on the EUB web site 6 (Given to Mr. Brett, page 3262, 7 line 8 3484 8 039-045 Statement of Carma Developers Ltd. 3245 9 (Supplied by Mr. Donald Edie) 10 039-046 Set of two (2) maps: 1. Southeast 11 Calgary Emergency Planning Zones, 12 Forecasted Growth 2004-2018; 13 2. Southeast Calgary Emergency 14 Planning Zones, Forecasted Growth 15 2004-2023 (Supplied by Mr. Donald 16 Edie) 3247 17 039-047 Set of two (2) maps: 1. Emergency 18 Planning Zone Showing 15-year Growth 19 and Selected Land Holdings; 2. 20 Emergency Planning Zone Showing 21 20-year Growth and Selected Land 22 Holdings (Supplied by Mr. Donald 23 Edie) 3248 24 039-048 Curriculum Vitae for Robert F.E. 25 Clark (Supplied by Mr. Donald Edie. 3248
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 039-049 Letter from Compton to Mr. Baiton 4 regarding pre-hearing submission 5 and the inclusion of Mrs. Newton 6 in the EPZ (October 15, 2003) 7 (Supplied by Mr. Baiton) 3436 8 039-050 Compton to confirm distance from 9 westernmost well on the 10-13 lease 10 to the eastern boundary of the new 11 hospital (Undertaking No. 60 given 12 to Mr. Baiton, page 3453, line 5) 3453 13 039-051 Letter dated July 20th, 2004 from 14 the Law Department of the City of 15 Calgary to Fraser Milner Casgrain, 16 for the attention of Mr. McLarty 17 (supplied by Ms. Gosselin) 3567 18 19 20 21 22 23 24 25
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1 LIST OF EXHIBITS (cont'd) 2 Exhibit No. Description Page No. 3 039-052(a) For Compton to determine whether 4 or not there was a letter or an 5 e-mail or some sort of written 6 communication in and around the 7 end of August 2004, from the City 8 to Compton. And if it exists, to 9 produce it. Expanded on page 3577 10 to include a package of correspondence 11 as between Compton's Counsel and 12 the City of Calgary, as it pertains 13 to the discussions concerning the 14 planning of the ERP. (Undertaking 15 No. 61, given to Mr. J.R. McKee, 16 page 3571, line 19) 3572 17 039-052(b) Copy of email dated July 13th, 2004 18 from Harvey Rindfliesch of the City 19 to Murray Castle of Bissett (supplied 20 by Ms. Gosselin.) 3641 21 22 23 24 25
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1 LIST OF UNDERTAKINGS 2 Undertaking No. Description Page No. 3 61 For Compton to determine whether 4 or not there was a letter or 5 an e-mail or some sort of written 6 communication in and around the 7 end of August 2004, from the City 8 to Compton. And if it exists, 9 to produce it. Expanded on page 3577 10 to include a package of correspondence 11 as between Compton's Counsel and the 12 City of Calgary, as it pertains to the 13 discussions concerning the planning of 14 the ERP. (Reserved Exhibit No. 15 039-052(a), given to Mr. J.R. McKee, 16 page 3571, line 19) 3571 17 18 19 20 21 22 23 24 25
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1 --- Upon commencing at 8:31 a.m. 2 3 THE CHAIRPERSON: Good morning, everyone, 4 and good morning, Panel. 5 Before we start this morning I just want 6 to go over something, and reviewing my questions to the 7 Compton Panel last night, it may have seemed that I was 8 calling into question the honesty of certain of the Panel 9 members. And no, I can assure you that that was not the 10 case, and rather may have been an unfortunate choice of 11 words on my part. 12 But I was simply trying to reconcile the 13 statement that there were no changes to the Application, 14 in light of the evidence that has been surfaced and 15 heard. 16 And from my perspective, the Panel 17 explained the discrepancy and explained why we got to 18 that situation, and I understand how we got to that 19 situation. So that's understood at this point. 20 So, I just wanted to mention that. Mr. 21 McLarty, do you have any matters you want to bring up? 22 MR. ALLAN MCLARTY: I do, sir. But just 23 before I do get to the undertaking responses, let me say 24 I do appreciate the clarification that you've just added 25 to the record. And that is appreciated, because indeed
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1 the credibility and the integrity of the people who 2 appear as witnesses before this Board is important, and 3 it's important I think not only to them, it's important 4 to you, it's important to the process, and it's important 5 to the decision that you ultimately have to make here. 6 So, all of those reasons I think make it 7 ultimately imperative that the credibility and the 8 integrity of -- of witnesses, when they're sitting there, 9 in a pretty vulnerable position, and not being impugned 10 or challenged either lightly or carelessly. 11 So, I just say that, sir, and I appreciate 12 your comment. 13 THE CHAIRPERSON: Yes, you're welcome and 14 understood. Thank you. 15 MR. ALLAN MCLARTY: Now, with respect to 16 the responses this morning. We have a number of them 17 that fall into the 39-044 series to Mr. Brett. There is 18 -- and these have all been distributed I think now. 19 There's a response at 39-044(a), which 20 occurs at transcript dated January 31, 2005, at page 21 3150, line 17. In -- in that undertaking, Mr. Brett 22 asked Compton to confirm whether at the time of the 23 Canadian Occidental purchase in 1997, Compton was already 24 engaged in sour operations. The response is provided in 25 writing, and indeed, it was involved with sour
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1 operations. 2 There's a -- the next undertaking 3 response, which we marked as Exhibit 039-044(b), occurs 4 at transcript dated January 31, 2005, at page 3167, line 5 8. Again, in response to a request by Mr. Brett for 6 Compton to confirm whether it was aware that the 7 Chestermere license term was up for renewal in 1999, when 8 it was acquired in 1997. The response simply says that 9 there is no specific reference in the 1997 purchase and 10 sale documents to the pipeline license term renewal, but 11 Compton assumes, but cannot confirm, that it would have 12 been aware that at the time of the acquisition, the 13 license was subject to a reviewable term of expiry. 14 The next undertaking response is the 15 document for which we have reserved Exhibit 039-044(c), 16 that occurred at transcript dated January 31, 2005, at 17 page 3203, line 22. There Mr. Brett requested that Mr. 18 Longfield of Compton, review his notes to determine 19 whether prior to the issuance of the December 31 -- 20 issuance of the December 2001 draft, Jacques Whitford 21 Risk Assessment and Plume Dispersion Modelling Report, 22 Compton had received any verbal, that is oral report from 23 Jacques Whitford that gave Compton some comfort about the 24 proposed EPZ. And there is a written response to that. 25 Next was an undertaking which we've marked
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1 as Exhibit 039-044(d). Again, that occurs at transcript 2 -- or does occur at transcript January 31, 2005, page 3 3209, line 1. And, again, is a response to a request by 4 -- made by Mr. Brett of Compton to undertake to look at a 5 number of matters relating to the history of the 6 engineering environmental health and safety committee. 7 And there's a response to that particular request. 8 And lastly for today, sir, is the document 9 we've marked as Exhibit 039-044(e), that occurs at 10 transcript dated February 1, page 3262. Again, Mr. Brett 11 requested and you, Mr. Berg, directed that Compton file 12 those documents listed in Exhibit 002-01(a), in brackets, 13 that Compton North Okotoks Horizontal Drilling Program 14 and the materials that were shown as accompanying 15 documents that are not posted on the Board's website. 16 Copies of those documents are attached to this response. 17 And that, I believe, covers the 18 undertakings outstanding to date. 19 20 --- EXHIBIT NO. 039-044(c): Mr. Longfield to determine 21 whether, prior to the issuance of the 22 Jacques Whitford Environment Limited 23 (JWEL) draft report "Risk Analysis of 24 the Compton Petroleum Corporation North 25 Okotoks Horizontal Sour Well Project"
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1 (December 2001), Compton had received 2 any verbal report from JWEL to provide 3 comfort regarding the proposed 4 reduced EPZ (Given to Mr. Brett 5 page 3203, line 22) 6 7 --- EXHIBIT NO. 039-044(d): Confirm the date that the 8 Engineering, Environmental Health 9 and Safety Committee was founded, 10 and whether there is an earlier 11 charter than the one found in 12 Exhibit 039-016. Additionally, 13 confirm whether its predecessor was 14 named the Reserves Safety and 15 Environment Committee. (Undertaking 16 No. 59 given to Mr. Brett, page 17 3209, line 1. 18 19 --- EXHIBIT NO. 039-044(e): Provide those documents 20 listed in Ex. 002-001(a) (p. 5) which 21 are not available on the EUB web site 22 (Given to Mr. Brett, page 3262, line 8 23 24 THE CHAIRPERSON: Okay. Thank you. I 25 appreciate your assistance.
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1 Are there any other matters that anybody 2 needs to bring up before we start today? Seeing none, 3 Mr. McKee...? 4 MR. J.R. MCKEE: Thank you, Mr. Chairman. 5 6 GARY FOLLENSBEE, Resumed; 7 WADE MROCHUK, Resumed; 8 RUSSELL BROWN, Resumed; 9 JOSEPH KENNY, Resumed; 10 GREGORY CROOKS, Resumed; 11 RICHARD BISSETT, Resumed; 12 DEREK LONGFIELD, Resumed; 13 14 QUESTIONS BY MR. J.R. MCKEE: 15 MR. J.R. MCKEE: Good morning, gentlemen. 16 As I woke this morning it occurred to me 17 it being Groundhog's Day, I wasn't sure of the 18 significance. I can assure you that Board Counsel did 19 not see a shadow, so I assume that means there will not 20 be six (6) more weeks of hearing then this point forward. 21 However, I'm not so sure you can put much stock in that. 22 Mr. Longfield - can I catch you when your 23 mouth is full of coffee - one (1) of the themes that 24 seems to be very clear in Compton's presentation to date 25 is that this Application presents the Board, and by
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1 extension the landowners and the City and the community 2 in general, with a -- with a choice. 3 On the one hand, status quo, the continued 4 production of the existing wells, which, but for this 5 Hearing, many people probably didn't realize were there 6 in the first place, and the attendant difficulties or 7 restrictions that the existence of those wells would 8 place on the landowners' ability to deal with their land, 9 the City's expansion et cetera off into the future. 10 Versus the proposal which would see an 11 intensified development over a couple of years, the 12 difficulties associated with that in terms of traffic and 13 the safety issues that we've discussed with a withdrawal 14 of all of the sour activities within a much shorter 15 period of time, allowing the landowners and community 16 then to use the land and the City to grow within the 17 encumbrances or difficulties associated with sour gas 18 wells existence. 19 Have I set out the two (2) choices 20 clearly? 21 MR. DEREK LONGFIELD: Well, there is 22 about twenty (20) years of history that you tried to sum 23 up in one (1) or two (2) minutes, but it -- it's a 24 reasonable summary, Mr. McKee. 25 MR. J.R. MCKEE: Okay. And -- and the
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1 one (1) spectre that sort of hovers over this choice or 2 the clarity of this choice would seem to be the 3 unreleased decision by the Board with respect to the 4 Chestermere pipeline. 5 Would you agree with that? 6 MR. DEREK LONGFIELD: It's -- it's one 7 (1) of the unknowns. 8 MR. J.R. MCKEE: And when -- this has 9 been discussed prior and by other -- other examiners, 10 you've indicated that Compton is maintaining its position 11 that it is going to produce this resource, absent this 12 Application for fifty (50) years, or however long it 13 takes, in keeping with your interpretation or your views 14 as to the necessity of conserving the resource. 15 And the position that Compton's taking, 16 based on the facts as we have them today is 17 understandable, but I'm -- what I'm wondering is, is 18 Compton suggesting that it is its intention to continue 19 to produce the two (2) existing wells, and that any sort 20 of attempts or rulings, which might shorten the length or 21 the natural life of those wells would be resisted or 22 attempted to be resisted by Compton in some fashion? 23 MR. DEREK LONGFIELD: I -- I can't 24 speculate as to what is in that decision that is sealed, 25 on the pipeline license. Is it renewable, is it not, is
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1 it reviewable, is it not? I can't speculate on that. 2 The only known I have is that we have a large resource, 3 68.75 percent of it which is owned fee simple by Compton 4 Petroleum and Compton has an obligation to continue to 5 produce that resource. 6 So, you have encapsulated our position, 7 yes; an obligation not only to the Province of Alberta, 8 but also to its shareholders. 9 MR. J.R. MCKEE: And so if some 10 limitation were to be placed on the pipeline, then that 11 would not be in keeping with Compton's view or its -- its 12 view of its responsibility to conserve that resource; is 13 that fair? 14 MR. DEREK LONGFIELD: Well, that becomes 15 a matter of speculation, but what I will say -- what I 16 will say is that we would have concerns with anything 17 that would limit the recovery of a resource in this 18 Province. 19 MR. J.R. MCKEE: So, without speculating, 20 what I hear you saying is that you'll consider your 21 options if that should occur, and one (1) of those 22 options would likely be an attempt to try and resist that 23 sort of limitation; is that fair? 24 MR. DEREK LONGFIELD: I mean resist the 25 limitation, that we're resisting something that's a
3490
1 speculation. We -- we'll continue to produce the 2 resource. We will resist premature abandonment of this 3 resource, yes, Mr. McKee. 4 MR. J.R. MCKEE: Thank you. Now, 5 gentlemen, I intend to spend a little bit of time looking 6 at ID-2001-5. And I'm wondering -- I assume the Panel 7 has access to copies, do you? 8 MR. DEREK LONGFIELD: I believe it's in 9 002-01(a), Mr. McKee. 10 MR. J.R. MCKEE: Okay. Thank you. And 11 indeed, I would like you to refer to that particular 12 exhibit, 002-001(a), the reduced EPZ Application binder. 13 MR. DEREK LONGFIELD: It might not be in 14 that one. I have it, I know that though. 15 MR. J.R. MCKEE: Okay. Well, we need to 16 have a look at that binder, in any event, as well. 17 18 (BRIEF PAUSE) 19 20 MR. J.R. MCKEE: Mr. -- Mr. Longfield, I 21 -- Mr. Brett spent some time going over this, and I don't 22 want to -- to spend an enormous amount of time revisiting 23 this. However, what I'd like to discuss briefly is the 24 initial decision that was taken by Compton, regarding the 25 calculated zone, and that initial decision being that it
3491
1 was impractical to properly preserve the safety of the 2 parties or the persons within that calculated zone, and 3 the decision then taken to seek a reduced zone. 4 And in the letter, which opened the 5 reduced EPZ Application binder at page 5, in the first 6 full paragraph, the letter states: 7 "Because of the size and population of 8 the fifteen (15) kilometre calculated 9 Emergency Planning Zone, Compton 10 believes public safety by conventional 11 evacuation [round bracket] (if you 12 cannot remove the hazard, remove the 13 people)[end round bracket] is 14 impractical and unrealistic." 15 You see that there? 16 MR. DEREK LONGFIELD: Yes, it's page 4. 17 MR. J.R. MCKEE: Right. I'm sorry, did I 18 say page 5? 19 MR. DEREK LONGFIELD: Yes, sir. 20 MR. J.R. MCKEE: I gave the wrong 21 notation. I apologize. 22 MR. DEREK LONGFIELD: Same -- the same 23 thing has happened before on this document. 24 MR. J.R. MCKEE: And if we refer to ID 25 2001-5 looking at Section 3.1 of the ID entitled, Request
3492
1 For Reduced EPZ, the ID discusses the assessment of the 2 calculated EPZ which should be undertaken prior to 3 developing the -- the ERP. 4 And the assessment includes, and I'm just 5 reading starting with the last word on page 3, "this...", 6 carrying over the next page: 7 "... evaluation should examine the 8 public safety protective measures 9 available versus the EPZ size 10 including, but not limited to, 11 population density, topography, access, 12 egress routes and other identifiable 13 factors that may affect timely 14 implementation of emergency response 15 measures." 16 Do you see that there? 17 MR. DEREK LONGFIELD: Yes, I do. 18 MR. J.R. MCKEE: Did Compton undertake a 19 study or an examination of the calculated EPZ which 20 included those various features prior to making its 21 decision to seek a reduced zone? 22 MR. DEREK LONGFIELD: Yes, I believe that 23 was probably in one of the very first things that we had 24 contacted Bissett Resource Consultants regarding and, in 25 particular, Mr. Bissett.
3493
1 MR. J.R. MCKEE: And -- and, Mr. Bissett, 2 perhaps I'll ask you then, what -- what sort of study was 3 undertaken? I mean, Mr. Brett, I think, referred to the 4 decision as a -- as a no-brainer and I think that we've, 5 sort of -- many people have taken it as a -- as a given 6 that this was undoable. 7 But I am curious as to what thought or 8 what analysis went into that decision? 9 MR. RICHARD BISSETT: Basically, we went 10 out and -- and, in compliance with 2001.5, surveyed the 11 fifteen (15) kilometre emergency planning zone. And, 12 starting on page 2, continuing on page 3 and also at the 13 top of page 4, were the entities, if you will, that we 14 found within that fifteen (15) kilometre emergency 15 planning zone. 16 And as Mr. Brett said, it -- it really was 17 a no-brainer that -- that to evacuate or for Compton to 18 evacuate the City of Calgary would be, A), impractical, 19 B), we did not talk to Disaster Services prior to that to 20 see if they were prepared to undertake that or not, but 21 that would just be impractical and unmanageable for 22 Compton to undertake an evacuation of that magnitude. 23 So, we basically pulled back, and keeping 24 in mind that 2001-5 was issued in August and we're 25 talking about attempting to understand a new document at
3494
1 the same time we're doing -- putting all of this together 2 and also arriving at -- at how can we protect the public 3 and a plume modelling study, why, basically we settled 4 upon the four (4) kilometre emergency planning zone as 5 being suitable or manageable for Compton. 6 MR. J.R. MCKEE: Now, was it Compton's 7 understanding, Mr. Bissett, or was it your understanding 8 that within the calculated zone which, in this case, of 9 course, encompassed a large portion of the City of 10 Calgary, that the obligation or the sole obligation for 11 protection of the public would fall on Compton's 12 shoulders to the exclusion of the municipality; was that 13 your understanding? 14 MR. RICHARD BISSETT: No, that -- we did 15 -- we had not discussed with the local authorities who 16 would evacuate the City of Calgary, that high density 17 part up there. 18 MR. J.R. MCKEE: Okay. So, you concluded 19 that -- that Compton couldn't do it? 20 MR. RICHARD BISSETT: That's right. 21 Exactly. 22 MR. J.R. MCKEE: But you didn't explore 23 what possible arrangements might be in place or 24 responsibilities that might fall to the City, if the 25 calculated zone was in existence and if some sort of
3495
1 evacuation or alert was necessary; is that right? 2 MR. RICHARD BISSETT: At that time, no, 3 we did not discuss that with Disaster Services people, 4 no. 5 MR. J.R. MCKEE: So, for the sake of the 6 analysis that you made, in terms of the impracticality, 7 you restricted that analysis to the -- to the capability 8 or resources of Compton; is that correct? 9 MR. RICHARD BISSETT: Yes, sir, that's 10 correct. And -- and as a matter of fact, in -- in our 11 letter, why -- why the only entities that we counted in 12 the City of Calgary were the public facilities, such as - 13 - such as schools and community centres, shopping malls, 14 church, and -- and so forth, that was within that area, 15 and -- and mentioned that we did not count -- did not 16 attempt to count the residences, within that area. 17 MR. J.R. MCKEE: Now, there's been a 18 great deal of discussion and sadly, there will probably 19 be some more, concerning the sort of responsibilities in 20 protection of the public, within the various municipal 21 district. 22 But I'm guessing -- from what you're 23 telling me then, at that time, there was no consideration 24 of the City's jurisdiction or its responsibilities, 25 legislated responsibilities, for emergency planning when
3496
1 considering the impacts of the calculated EPZ; is that 2 correct? 3 MR. RICHARD BISSETT: Not really. Mr. 4 Brown just pointed out to me, if I may have a moment, Mr. 5 McKee. 6 MR. J.R. MCKEE: Certainly. 7 8 (BRIEF PAUSE) 9 10 MR. RICHARD BISSETT: Our -- our first 11 meeting with the City of Calgary Disaster Services people 12 occurred on October the 24th, so -- so we had started 13 talking to the City about the project, as a whole. 14 I do not believe that we had any 15 conversations concerning evacuation of the people within 16 the emergency planning zone in these earlier meetings. 17 The earlier meetings was to -- to introduce Compton, 18 introduce the project, and -- and see what differences 19 that we may have, what is needed to -- to inform the 20 Disaster Services people, and then chart a strategy of 21 how -- how do we go forward from here. 22 So, in terms of discussing with the 23 Disaster Services, the issue of, would you do it, would 24 we do it, is some other means going to be used; no sir, 25 Mr. McKee, we did not at that time discuss who might do
3497
1 it or how it was going to be done. 2 MR. J.R. MCKEE: And October the 24th -- 3 I'm sorry, what year was that? 4 MR. RICHARD BISSETT: 2001, sorry, I 5 should have added that. 6 MR. J.R. MCKEE: And that would have been 7 a couple of months prior to the reduced Application being 8 submitted. 9 MR. RICHARD BISSETT: Yes, sir, that's 10 correct. And I would have to check the dates here, but I 11 know we were out in the field, I know we were out in the 12 field doing the ground truthing and the counting at the 13 time. 14 MR. J.R. MCKEE: Did the notification 15 requirements of the Board's Guide 56 play any factor or 16 play a role in the conclusion that it was impractical for 17 Compton to deal with the calculated EPZ? 18 MR. RICHARD BISSETT: That was Guide 56; 19 that would be the 2000 version -- 20 MR. J.R. MCKEE: Yes, sir. 21 MR. RICHARD BISSETT: -- I'm assuming. 22 MR. J.R. MCKEE: Yes, sir. 23 MR. RICHARD BISSETT: Would you mind 24 asking that again, Mr. McKee, I'm -- 25 MR. J.R. MCKEE: Well, I'm just wondering
3498
1 when the -- when the decision was made or the conclusion 2 was reached that this was impractical, you had mentioned 3 some of the factors that led to that. 4 I'm just wondering whether the 5 notification requirements that Compton would have had 6 under the Guide 56 at that time, played a role in that 7 conclusion; was it one (1) of the factors? 8 MR. RICHARD BISSETT: May I check 9 Guide 56, Mr. McKee, please? 10 MR. J.R. MCKEE: Certainly. 11 MR. RICHARD BISSETT: Thank you. 12 13 (BRIEF PAUSE) 14 15 MR. J.R. MCKEE: Mr. Bissett, perhaps I 16 can -- I can -- was it -- would it have been your 17 understanding at the time that if the calculated EPZ had 18 remained, that Compton would have been obligated to make 19 notification to the residents, all the residents, 20 personal notification to all the residents within the 21 calculated EPZ; was that your understanding at that time? 22 MR. RICHARD BISSETT: I -- if we did not 23 apply for a modified or reduced emergency planning zone, 24 then yes, you would -- you would be required to contact 25 all the residents within the EPZ or emergency planning
3499
1 zone size that you were going to use. 2 However, going with the reduced plan, then 3 we -- then I would switch back to the two thousand and 4 one point five (2001.5) and refer to the direction 5 provided in that document, which would supercede Guide 6 56. 7 MR. J.R. MCKEE: Fair enough. But, and I 8 guess then my question was, was the task of potentially 9 making personal notification upon all of the people 10 residing within the calculated EPZ one (1) of the factors 11 which led you to conclude that it was impractical to deal 12 with the calculated EPZ? 13 MR. RICHARD BISSETT: No, sir. To -- to 14 contact everybody is -- that's a matter of time, to -- to 15 do that. That's not an insurmountable problem or -- and 16 it doesn't deal with public safety; it's just time. 17 To evacuate those people, however, is 18 another matter that deals with safety of the public. We 19 just didn't feel, in all honesty, that Compton would be 20 capable of providing that type of assurances that they 21 could protect the public safety. 22 MR. J.R. MCKEE: And, again, no thought 23 was given as to whether the City or the Province or 24 anyone else could in fact have even made that evacuation? 25 MR. RICHARD BISSETT: I guess you can --
3500
1 you can say we had an understanding of the upstream plan 2 that was in -- that was in place. Probably not a real 3 good understanding of who would lead the charge if you 4 did have to evacuate the city; would it be Compton, would 5 it be the Disaster Services? 6 I think that holds true throughout the 7 Province, whether we were here or in -- in Calgary, or 8 elsewhere, you know. 9 MR. J.R. MCKEE: But, for the sake of -- 10 of the conclusion that it was impractical, you didn't go 11 past, in your analysis, the -- the resources or the 12 ability of Compton to execute? 13 MR. RICHARD BISSETT: No, sir. That's 14 correct. 15 MR. J.R. MCKEE: Thank you. Now, I 16 wonder if we could look at -- back to ID 2001-5 and in 17 particular, again, Section 3.1 and that portion of that 18 section which is on the fourth page of the ID. 19 There are a number of things which it is 20 suggested must be submitted with the request for a 21 reduced EPZ. Do you see that there? 22 MR. RICHARD BISSETT: Yes, sir. 23 MR. J.R. MCKEE: And one (1) of the 24 things is the size of the calculated -- pardon me, the 25 maximum anticipated accumulative H2S release rate at the
3501
1 proposed well, the size of the calculated H2S EPZ, and 2 the size of the proposed reduced EPZ. 3 Mr. Bissett, I'll start with you but feel 4 free to deflect to whomever you feel. There has been 5 some discussion here about the size of the -- of the 6 proposed reduced zone. What currently and what at 7 present is the size of the reduced zone that you're 8 seeking? 9 I've heard -- the Application speaks of a 10 four (4) kilometre zone. However, I believe I heard Mr. 11 Brown talking about something in the order of four point 12 three (4.3). Can you clarify for the record what is the 13 size of the proposed reduced zone? 14 MR. RICHARD BISSETT: Yes, sir. I have a 15 map -- a map here that we keep referring to. I -- I 16 don't know if you have that -- if we could put that map 17 on the screen or not, but we started off with, as we -- 18 as we discussed, I believe with Mr. Brett, we drew a four 19 (4) kilometre circle on the map. 20 And then we went to the field and in 21 compliance with two thousand and one point five (2001.5), 22 or just in compliance with emergency preparedness 23 standards, we started off with the four (4) km. When we 24 went to the field and ground truthed and contacted the -- 25 the residents, then we started making it a site specific
3502
1 emergency response plan, rather than a generic one, which 2 you start off with as a four (4) km. 3 So, consequently we end up with an odd 4 shaped emergency planning zone that is depicted on the 5 map that's on the screen, and -- and at a -- at about a 6 two ninety (290) degree heading, the radius is four point 7 (4.) -- four point o-five (4.05) kilometres, and Mr. 8 Brown would point that out on the -- on the map for -- 9 for everybody to see. 10 That's the shortest axis on that radius is 11 -- is that four point o-five (4.05). If we go down to 12 the southeast, the -- the maximum distance is five point 13 eight zero (5.80) kilometres at that point. 14 If we go north of the well, and slightly 15 east, we will find it is four point eight six (4.86) 16 kilometres at that point right there. 17 If we come back down to -- to that little 18 dimple at the very south of the well, that's 19 approximately four point five three (4.53) kilometres. 20 We could perimeter this area and come up with a mean 21 radius, or a mean diameter; we didn't. But the -- the -- 22 it started out as a four (4) kilometre Reduced Emergency 23 Planning Zone, and it ended up as a site specific, 24 considering egress routes, topography, and -- and other 25 dead end roads that -- that we ended up with this
3503
1 configuration, Mr. -- Mr. McKee. 2 MR. J.R. MCKEE: And again, I guess from 3 yesterday, there's going to be some further dimples or - 4 - or peninsulas added to the -- added to the zone, as it 5 is currently; is that correct? 6 MR. RICHARD BISSETT: That's right. 7 Right without -- without even leaving the room, Mrs. 8 Newton and probably the -- the three (3) or four (4) 9 other residents on that Range Road, will also be included 10 within the emergency planning zone. 11 MR. J.R. MCKEE: And in your further work 12 within the ERP, do I assume then that you'll be similarly 13 going out to determine whether there should be any other 14 additions or any other inclusions within the zone? 15 MR. RICHARD BISSETT: Yes, sir. As a 16 matter of fact, I believe we have an undertaking to -- to 17 locate the -- the precise site or the eastern extremity 18 of the hospital that's being built to the west. 19 And that's an issue that if this goes 20 ahead, then I'm sure we will be sitting down -- we're 21 going to have to sit down with the Disaster Services 22 personnel, and decide on if -- if we ever did get into a 23 problem, how are we going to evacuate that hospital. 24 MR. DEREK LONGFIELD: I don't -- I don't 25 think that's a problem from our -- from everything we've
3504
1 heard in we're not going to have a hospital there. 2 There's certainly going to be some concern as -- as 3 addressed by counsel for the Intervenors, and I don't 4 believe it was for CHR, I believe it was possibly Carma, 5 that they -- that there could be an ongoing construction 6 operation there, at the time we've envisioned drilling 7 the wells. 8 But this of course is -- is all part of 9 having a final ERP in a -- in a lengthy process like 10 this, where of course now we're looking at a map that was 11 first conceived over three (3) years ago. The question 12 is, is that EPZ appropriate and if it is appropriate, we 13 will finalize it. 14 MR. J.R. MCKEE: Okay. Is there a 15 similar -- Mr. Bissett, is there a similar analysis done 16 or have you done or do you intend to do a similar 17 analysis vis-a-vis the -- the -- the border of the 18 awareness zone? 19 And what I mean by similar is as -- as 20 you've indicated, you've -- you've drawn the -- the 21 circle on the map -- the four (4) kilometre circle and 22 then gone out and looked at what's really happening on 23 the ground and made decisions about including parties or 24 -- or places that, because of topography, access, et 25 cetera, are you -- are you planning to do a similar
3505
1 exercise vis-a-vis the border of the awareness zone? 2 MR. RICHARD BISSETT: We -- I'm not sure 3 the border of the awareness zone. I would say the 4 emergency -- myself I would use emergency planning zone 5 and beyond. Compton is going to have to look at, in 6 conjunction with the local authorities, and we are going 7 to have to decide that if we, again, did get into a 8 problem, how are we -- how are we going to protect the 9 public in that area? 10 I think the -- the awareness area is 11 something that was coined a little earlier on in -- in 12 emergency preparedness saying that the awareness area 13 around the emergency planning zone, the industrial 14 operator must be aware of what is inside twice the 15 emergency planning zone in case it has to be expanded. 16 So, myself, I would prefer to say, we will 17 be working with the Disaster Services for the local 18 authorities to finalize an understanding of what is going 19 to happen beyond the emergency planning zone during an 20 emergency situation. 21 MR. J.R. MCKEE: And, to date, those 22 discussions haven't taken place; is that correct? 23 MR. RICHARD BISSETT: They have not been 24 -- been concluded or there's been no resolve or endpoint 25 reached.
3506
1 MR. J.R. MCKEE: So, Mr. Bissett, you've 2 indicated that from the map we have today we know that 3 there's going to be a change to reflect Mrs. Newton. 4 There's likely or potentially a change, and you've 5 undertaken to advise, with respect to the hospital. 6 I wonder if we could just expand on that 7 undertaking or seek an undertaking from you to advise us 8 of if -- advise us if there are any other expansions or 9 changes currently on the radar for Compton to the -- to 10 the zone? 11 MR. RICHARD BISSETT: Yes, sir. How far 12 are we going to put any -- any distances? Do we want to 13 look within a half a kilometre for anything that could 14 impact the boundary of the -- of the EPZ as it exists 15 today; is that -- that correct? 16 MR. J.R. MCKEE: Yes. Anything that 17 would, yes. 18 MR. RICHARD BISSETT: Okay. I don't see 19 any -- any problem with that. We'll make sure that we 20 get that recorded and that we understand that. That's 21 not going to be done this afternoon or tomorrow or the 22 next day. It'll be somewhere into the future that -- 23 that it may take -- may take a day or two or three to do 24 that. 25 MR. ALLAN MCLARTY: It strikes me that
3507
1 there may be some mis-communication going on here. I 2 thought I heard you ask, Mr. McKee, whether there were 3 any other -- asked whether there were any other 4 expansions that were currently on Compton's radar? 5 MR. J.R. MCKEE: That's correct. Yes. 6 MR. ALLAN MCLARTY: And that's without 7 going out and looking at anything else -- 8 MR. J.R. MCKEE: That's right. We're not 9 ask -- 10 MR. ALLAN MCLARTY: -- or doing any other 11 work? 12 13 CONTINUED BY MR. J.R. MCKEE: 14 MR. J.R. MCKEE: Yeah. No, Mr. McLarty 15 is absolutely right, Mr. Bissett. 16 Just for clarity's sake, what I'm looking 17 for now is if we can get to the point where at least we 18 know what is currently there, what we currently know 19 about. We're not asking that you go out and do that work 20 at this point. 21 MR. RICHARD BISSETT: Oh, I see. Okay. 22 MR. RUSSELL BROWN: Mr. McKee, I think we 23 are aware of some of the other activities and public 24 facilities that are located from four (4) kilometres to 25 eight (8) kilometres.
3508
1 In the summer when we were ground truthing 2 we did go out and identify some of the -- I'm going to 3 call them public facilities from four (4) to eight (8) 4 kilometres. 5 We're talked to the Carnmoney Golf Course 6 and the Heritage Point Golf Course, found out what their 7 course is all about and -- and, you know, do they have a 8 -- you know, like a weather warning system where they 9 could call all the golfers in for bad weather and they 10 both confirmed they do. 11 And we talked to the railway and the Indus 12 Winter Air Park, the Alberta Motor Association Driving 13 School, some new subdivisions, located the Calgary South 14 Hospital. There's an Enmax substation, power substation 15 being -- being built in there. 16 The Race City Motor Speedway, just their 17 grounds, not the actual speedway, I think impacts the 18 south end of the emergency planning zone and a Davisburg 19 Community Hall. And those have been identified on the 20 map. 21 We've taken some pictures of -- of the -- 22 the various areas, and they are loaded onto the map, so 23 Compton did identify those in the -- in the summer time. 24 And we -- we know there's dirt being turned just outside 25 the emergency planning zone, and have that all documented
3509
1 in a -- in a picture format. So -- so, when we go 2 forward, we understand what was out there as recently as 3 July/August. 4 MR. RICHARD BISSETT: And that summary is 5 in the revised emergency response plan that Mr. Brown is 6 reading off of. So, if that would suffice, for that 7 undertaking? 8 MR. J.R. MCKEE: Well, I -- it may 9 indeed, but I guess what I'm trying to accomplish is that 10 if we -- if we can say with some certainty, at least as 11 we stand here in this Hearing, that we know now what 12 Compton has considered to include or what other bumps or 13 protrusions we might see in the four (4) kilometre zone. 14 And if those things that Mr. Brown has identified are all 15 of the things currently being considered, then, yes, it 16 would. 17 But if you're prepared to say that today? 18 MR. RUSSELL BROWN: I'll just -- maybe 19 I'll add some more. Kelly, if you can show some of the 20 pictures as well. But there is -- the -- the area that 21 is presently shown on the map, and I don't want to guess 22 at this, so I'll just have a quick look. 23 24 (BRIEF PAUSE) 25
3510
1 MR. RUSSELL BROWN: There -- there is a 2 Road Block Number 7, on that map. And we are aware that 3 there's -- there's currently infrastructure being built 4 in there, sewers, roadways, and -- and the -- the road -- 5 Township Road 224, west of the modified reduced emergency 6 planning zone as it stands today. It -- it may be 7 impacted, depending on access and egress. 8 The road block may have to move. There 9 could be -- there could be access to the south, and that 10 interchange may be built within a couple of years, and 11 maybe one (1) or two (2) more road blocks have to be 12 added. 13 This area is definitely going to have some 14 significant changes, and some discussions will have to go 15 on with Carma, Calgary Health Region, Enmax, the 16 substation, and -- and all of those entities. 17 MR. RICHARD BISSETT: And I -- and I 18 might also add, Mr. McKee, that -- that this map will 19 probably never be completed until all the drilling is -- 20 drilling and completion work is done. It is a living 21 document and will be updated as necessitated by any new 22 developments that would have to be included in the 23 emergency planning zone. 24 MR. J.R. MCKEE: All right. 25
3511
1 (BRIEF PAUSE) 2 3 MR. J.R. MCKEE: All right. We could 4 just, Mr. Bissett, refer back again to the ID, and we 5 were looking at the list of items which are required for 6 a reduced -- or the Board to consider a reduced EPZ. And 7 moving down, the fifth bullet in the middle of the page: 8 "A description of the discussions, 9 interactions and agreements made with 10 the relevant public and municipal 11 emergency services, regarding emergency 12 response roles, and responsibilities." 13 And if I could then jump to the 14 Application, which would identify it as Exhibit 002-001- 15 1(a), just looking at page 5 of that opening letter, 16 dated December the 20th, there are a number again, of 17 bulleted points set out with respect to the Application. 18 And again, the fifth one (1) on that 19 particular page states: 20 "Compton will establish [sorry] will 21 establish a protocol for communicating 22 and working with the Disaster Services 23 personnel in the City of Calgary, MD of 24 Rocky View and Foothills and Calgary 25 Health Region and Headwaters Health
3512
1 Region, during any sour operations. 2 This relationship will allow Compton to 3 work with the local authorities, in 4 determining any real perceived sour gas 5 risks, H2S and SO2, beyond the reduced 6 emergency planning zone and to 7 establish a cooperative action plan. 8 Compton understands that the modified 9 reduced emergency planning zone will be 10 expanded if warranted." 11 And then again on page 6, near the bottom 12 of the page, in the third bulleted paragraph, "The 13 local... ", it says: 14 "The local authorities, City of 15 Calgary, MD of Rocky View [and so on] 16 are aware of their emergency response 17 abilities and feel that they have the 18 capability to fulfill their duties and 19 are prepared to cooperate with Compton 20 during any emergency. However, the 21 Calgary Health Region has some concerns 22 regarding the effective capacity of 23 treating sensitivities exposed to SO2. 24 Additional studies are ongoing in an 25 attempt to reach an endpoint regarding
3513
1 this matter. All agencies have 2 expressed the desire to go forward on a 3 cooperative basis." 4 Do you see that there, sir? 5 MR. RICHARD BISSETT: Yes, sir, I do. 6 MR. J.R. MCKEE: So, clearly then, ID 7 2001-5 contemplates as a requirement some agreement and 8 coordination to be in place between the Applicant, in 9 this case Compton, and the various municipal authorities. 10 You understand that, sir? 11 MR. RICHARD BISSETT: Yes, sir, I do 12 indeed. 13 MR. J.R. MCKEE: And I think it's pretty 14 clear from the evidence that we've heard over the last 15 couple of weeks that as we stand today, no formal 16 agreements or arrangements have been reached with either 17 the City of Calgary, the Calgary Health Region and the MD 18 of Rocky View, and I don't know that we've ever talked 19 about the other municipal district but I'm -- I'm 20 suggesting that there's no agreements in place currently; 21 is that correct? 22 MR. RICHARD BISSETT: That's correct. 23 That's with the MD of Foothills. 24 MR. J.R. MCKEE: Right. And so, when I 25 look back at the page 6 now of the -- of the Application
3514
1 and the paragraph I just paraphrased, it does seem to 2 suggest that some level of communication had taken place 3 at least in December of 2001, so that Compton could state 4 that these various agencies were firstly aware of their 5 emergency responsibilities abilities and that they have 6 the capability to fulfill their duties. 7 What was that based on? Were there 8 discussions and meetings prior to that which led you to 9 that conclusion? 10 MR. RICHARD BISSETT: Yes, sir, Mr. 11 McKee. And I -- and, of course, I have a document here 12 that you don't have but let me -- let me tell you or give 13 you some dates and -- and the agencies that we met with 14 on those dates. 15 Starting in October we met with the City 16 of Calgary -- 17 MR. J.R. MCKEE: I'm sorry, again. 18 October of? 19 MR. RICHARD BISSETT: I'm sorry. October 20 24th, 2001 -- these are all 2001. The 24th of October, 21 the City of Calgary. 29th of October, MD of Foothills. 22 The -- October the -- or the 30th of October we met with 23 Cindy Ady, MLA. October the 30th we also met with the 24 Indus Coalition Group. On the 31st of October, the 25 Calgary Regional Health Authority and included the City
3515
1 of Calgary. 2 On the 2nd of November there was a -- a 3 Ms. C. Haley, MLA. 8th of November, the -- Ken Jones, 4 the Emergency Management Alberta representative in town 5 here. The 20th of November, the Foothills Regional 6 Health Unit. On the 21st of November there was the Indus 7 open house that was held in conjunction with this 8 Application. 9 On the 26th of November we met with -- 10 with a Mr. Soutzo, who is part of the LRD agreement. 11 There was a -- 28th of November, the Douglasdale Golf 12 Course, there was the second open house that was held in 13 conjunction with this application. On the 5th of 14 December we met with the MD of Rocky View and then on the 15 7th of December with Carma and Hopewell personnel. 16 So, throughout the -- and I didn't read in 17 the June, July and September meeting with EUB staff and 18 so forth. So, we -- we had a, I think, a pretty active 19 schedule in -- in attempting to spread the word about the 20 project and the fact that we want to -- to establish a 21 relationship and move forward. 22 One (1) date -- one (1) date I missed; the 23 10th of December, the -- the Calgary Health Region also. 24 MR. J.R. MCKEE: So, then those series of 25 meetings that you've just described to us led you to, at
3516
1 least, ascertain that the various groups that you've 2 described were aware of their emergency responsibilities 3 and feel that they have the capacity to fulfil their 4 duties and are prepared to cooperate with Compton during 5 an emergency; is -- is that fair to say? 6 MR. RICHARD BISSETT: Yes, that's right. 7 I would say with some trepidation they were -- they were 8 prepared. They, at this juncture, why they're just 9 really getting a taste of -- of what it is that we're 10 talking about. And it takes time to absorb all of this 11 information and -- and reach a conclusion on it. 12 But, I guess, the -- as far as I am 13 concerned, there was, at least, a promise that there were 14 no closed doors and that we would move forward on a 15 cooperative rather than a confrontational basis. 16 MR. J.R. MCKEE: So, at the time that you 17 submitted the Application for the reduced EPZ then, none 18 of these bodies had said, no, we -- we can't handle this 19 or we don't intend to work with you or anything of that 20 nature? 21 MR. RICHARD BISSETT: There were -- there 22 was the MD of Foothills was going to defer to Calgary. 23 There was the MD of Rocky View, at the time, would defer 24 to Calgary. The Calgary Health Region, the issue 25 concerning evacuating SO2 and so forth was an issue and a
3517
1 concern. 2 But -- but outside of that, I -- I would 3 say, why, there was an understanding of what we were 4 attempting to do and that they were aware of their duties 5 and responsibilities under the upstream ERP. 6 MR. DEREK LONGFIELD: If I can add to 7 that, I think the word defer might get misconstrued and I 8 think what we're -- what we're attempting to say and Mr. 9 Bissett could correct me, but they looked, both of those 10 municipalities, looked to the City of Calgary to take the 11 lead role in disaster response and they did have 12 capabilities to assist. 13 Similarly, we were under the understanding 14 there was a -- I'm going to call it a mutual aid 15 agreement. I might not be correct, with the Headwaters 16 Health Authority and the CHR that basically, again, a 17 lead role kind of thing, that would go to the CHR in this 18 respect and as far as expertise and that kind of thing. 19 So just to be clear about defer, they weren't abdicating, 20 they were just looking to other authorities to take the 21 lead. 22 MR. J.R. MCKEE: Okay. 23 MR. RICHARD BISSETT: And, Mr. McKee, if 24 I may, one (1) -- one (1) point that I did miss when I 25 was going through the meetings with the various
3518
1 organizations that we had was the fact that when we met 2 with the -- with the Emergency Management Alberta people, 3 we discussed the municipal jurisdiction and as to who is 4 responsible for what and discussed and reviewed ID 2001.5 5 because, keeping in mind, it was two (2) months old at 6 that time and perhaps not fully understood. 7 MR. J.R. MCKEE: And, I'm sorry, you 8 probably mentioned this and I didn't note it; who was at 9 that meeting? 10 MR. RICHARD BISSETT: That was Mr. Ken 11 Jones was the -- was the Alberta Management 12 representative at the time. 13 MR. J.R. MCKEE: All right. Was there 14 any representatives of the City or the municipalities? 15 MR. RICHARD BISSETT: No, sir. No, sir. 16 There would have been -- I -- I believe Mr. Longfield and 17 I met with Ken Jones. 18 MR. J.R. MCKEE: From those meetings, or 19 at those meetings, what -- what was presented to the 20 various municipalities and Government agencies by 21 Compton? 22 MR. RICHARD BISSETT: We -- you know, we 23 really looked like a -- looked like a caravan when we 24 walked into these people's offices. We had maps that 25 depicted the four (4) km emergency planning zone, we had
3519
1 the eight (8) km awareness, we had the twelve (12) km 2 drilling scenario, we had the fifteen (15) km map on 3 there. 4 We had, at the time, not -- not the topo 5 part of -- topographical part or the land air photographs 6 on the map. We did on part of the City of Calgary; they 7 were updated later. We -- we presented the LRD handout, 8 we -- we presented handouts that's in this Application to 9 them, we had the video, and I believe the video was -- 10 was presented to the -- to the people as well. 11 We -- we would spend, I don't know, 12 perhaps an hour presentation, minimum -- on a minimal 13 basis, to each of the organizations and then depending 14 upon your questions or concerns they may have, why at 15 times we'd be a half a day going through the information. 16 We went through the release rates, we went through 17 drilling, we went through the accelerated depletion, the 18 life of the project. In all honesty, much like we're 19 doing here, in trying to impart as much of this project 20 to those organizations, as -- as we possibly could in -- 21 in a short period of time. 22 MR. DEREK LONGFIELD: Mr. Bissett's 23 correct, we did leave each of those agencies, individuals 24 with copies of the video. As well as the August 2001 25 draft or the information for residents handout, that is
3520
1 attached to the -- 2 MR. J.R. MCKEE: Hmm hmm. 3 MR. DEREK LONGFIELD: -- spacing -- or 4 not the spacing, the EPZ Application. 5 I'm not certain what else we left. Did 6 you have a list there, Mr. Brown? 7 MR. RICHARD BISSETT: Yes, I have a -- I 8 have a technical agenda, if you would like for me to go 9 through it, I sure would. Of if you -- you don't want to 10 spend the time, why I'm going to leave that. 11 MR. J.R. MCKEE: No, I think we -- we've 12 got a flavour of the fact. And what I think you're 13 expressing to us is that -- that you went in there ready 14 to provide them with the full -- the full benefit of all 15 of the work that had been done to date, and -- and bring 16 them to the point of understanding of where you were at 17 in the project. 18 Is that a fair encapsulation? 19 MR. RICHARD BISSETT: Yes, sir, that's 20 correct. And also LRD applicable regulations 2001, for 21 ID-2001.5, and -- and the video we did hand out, and EUB 22 Decision 2000-20, was discussed. And so forth. 23 MR. J.R. MCKEE: All right. So, from 24 those meetings, and in some cases within -- within a 25 short time afterwards, the application was made to the
3521
1 Board for the Reduced -- for the Reduced Zone. 2 What was the plan at that time, in terms 3 of follow-up discussions or meetings with the City and 4 the various Municipalities and the Health Region, to 5 attempt to come to the understandings that the ID 6 contemplates, and that I think we've acknowledged are 7 required. 8 What was the plan? What was going to 9 happen next? 10 MR. DEREK LONGFIELD: I think I can 11 answer that one, Mr. McKee. We of course explained to 12 anyone we spoke to, that there were stages in this 13 process, and this was the first stage, that involved 14 everything that Mr. Bissett has -- has spoken about, and 15 that really the Well License Applications were a second 16 stage that would involve further and more detailed 17 consultation and development of an Emergency Response 18 Plan. 19 But at that time, our understanding of 20 2001-5 was that we would -- we would apply for this 21 Reduced EPZ and then we would either get it approved or 22 not approved, and from there we would proceed with the 23 second stage, if we had some sort of a -- a closure on 24 the size of the EPZ, and where we would need to consult 25 directly with individuals, as far as getting resident
3522
1 information and building an ERP. 2 So we were -- we were clear that there 3 were stages in this process, and what we weren't 4 obviously -- what we couldn't assume, at that time, was 5 how long this process would take. 6 But we definitely did not leave the 7 impression that this was the final consultation and the 8 next thing they know they'd have wells drilling. 9 MR. J.R. MCKEE: And so -- and I know 10 we've heard discussion previously that -- that at least 11 as far as the City, and I think the Health Region is 12 concerned, Mr. Longfield, you've indicated that there was 13 no desire or no interest expressed by these parties - and 14 correct me if I'm wrong or if I misheard you - in 15 finalizing these arrangements until such time as they 16 knew that the Reduced Zone had been -- had been approved, 17 is that correct? 18 MR. DEREK LONGFIELD: That primarily, but 19 other things as well. And certainly there would -- we 20 needed some closure on endpoints, and evacuation criteria 21 and that kind of thing as well, but -- or there was a 22 sense that we needed that. 23 But that probably the major issue was the 24 size of the EPZ and whether it was appropriate. 25 MR. J.R. MCKEE: And so did discussions
3523
1 continue -- let's back up a bit. I'm -- I think I hear 2 what you're saying, Mr. Longfield, that at the time that 3 the Application for the reduced zone was submitted, it 4 was the anticipation, at least, of Compton, that within a 5 short period of time, a relatively short period of time, 6 there would be some decision made with regard to the 7 reduced EPZ and then these discussions would carry on at 8 that -- at that point; is that fair? 9 MR. DEREK LONGFIELD: Yes. 10 MR. J.R. MCKEE: And so, when it became 11 apparent that the Board had determined that it could not 12 make a decision, a final decision with regard to the 13 reduced EPZ, did that change the approach or the plan on 14 Compton's behalf in approaching the various municipal 15 bodies in dealing with these matters? 16 MR. DEREK LONGFIELD: No, other than to 17 say we didn't have an approved EPZ and this was a new ID 18 and, you know, that they -- that we had been directed to 19 continue with the public consultation and development of 20 a site specific ERP, but that at no time I don't -- at no 21 time did we indicate that we had an EPZ that was 22 approved. 23 So, we were proceeding along on the 24 proviso that the EPZ would be one of the things that 25 would be assessed at the time of making well license
3524
1 applications. 2 MR. J.R. MCKEE: But you knew then, and 3 you know now, and I don't think it's any -- any 4 revelation, that part of what must be included in the ERP 5 is a description and a -- and a plan as to how the 6 various bodies, the municipal bodies, the health region 7 and Compton, will cooperate and work with one another on 8 a going-forward basis. 9 We understand each other on that; is that 10 -- is that fair? 11 MR. DEREK LONGFIELD: Yes, that's -- 12 that's correct. 13 MR. J.R. MCKEE: Okay. And so, when 14 Compton realized that it wasn't going to get approval of 15 the reduced EPZ, was a decision taken at that time not to 16 pursue these agreements with the municipal bodies, 17 pending the outcome of this process, or was there still 18 attempts at trying to work these matters out on the 19 understanding that that was something that was going to 20 have to be included in the ERP eventually? 21 MR. DEREK LONGFIELD: There certainly 22 were continued discussions, as I've stated previously, 23 with the City, up into September of 2004 and even as late 24 as late December of 2004, with the Health Region, albeit 25 it, really just with the Health Region to identify what
3525
1 the issues were, whether they still remained outstanding 2 and whether there was anything we could remove from the 3 table, prior to the Hearing. 4 MR. J.R. MCKEE: So, was it Comptons's 5 desire or was it Compton's intention to conclude these 6 arrangements as best as could be done? 7 MR. DEREK LONGFIELD: Well it was, 8 recognizing we have a very complex Application here, Mr. 9 McKee, and we appreciate that -- that other local 10 authorities may have a different perspective than -- than 11 what we have, with respect to what is appropriate, what 12 is -- what does ensure public safety. And, you know, 13 those discussions have -- have been ongoing, but are as 14 yet unresolved. 15 MR. J.R. MCKEE: And is the reason that 16 they're not resolved to this point, because one party or 17 another has decided that there is no point continuing it 18 until this process has been completed? 19 MR. DEREK LONGFIELD: No, I think, as 20 we've said in our directive evidence, it all backs up to 21 unfortunately not having the protocols that are 22 identified on the first page of 2001-5 that we had 23 expected, in eighteen (18) to twenty-four (24) months 24 from that ID, that simply aren't in place right now. 25 MR. J.R. MCKEE: I -- and I appreciate
3526
1 that. But I guess my question is, is that if everybody, 2 and in particular Compton, understood that it was an 3 important element of the CRP and this Application, to try 4 and finalize the -- the agreements or the working 5 arrangements with these municipal bodies, why or for what 6 reason that has not been concluded or at least taken to 7 the point of preliminary agreement, et cetera? 8 MR. DEREK LONGFIELD: Well, let's be 9 perfectly clear that, you know, right up until the time 10 of the Hearing, we were certainly, I believe I can speak 11 for Mr. Bissett as well, we were certainly of the 12 impression that we had a structure of an ERP, a structure 13 that was solid and that was agreed upon and there were 14 some fine details that needed to be ironed out, largely 15 revolving around the size of the EPZ. 16 But, the basic structure, we believed, we 17 were in agreement on. Evidence at this Hearing is 18 suggesting that that may not be the case. Even as I sit 19 here, I am absolutely certain that we will be able to 20 work out structuring a final structure that complies with 21 everyone's responsibilities for emergency response. 22 MR. J.R. MCKEE: And, Mr. Longfield, you 23 said that you were certain that we, I think you used the 24 word we had an agreement on the basic structure. 25 Who are you referring to as "we"?
3527
1 MR. DEREK LONGFIELD: Basically, local 2 authorities, MDs and the City of Calgary, as far as 3 taking lead roles in emergency response, Mr. McKee. 4 MR. RICHARD BISSETT: Mr. McKee -- if I 5 may interrupt here, Derek, I'll add a little bit to it. 6 One (1) binder I have lying here in front of me is 7 representative of notes that we kept at all the various 8 meetings that we had with the local authorities, with the 9 health units, with the MLA, the City of Calgary Planning 10 Department, on and on and on. 11 One (1) letter that I was looking at here 12 dated August 6th, 2002 from the MD of Rocky View says: 13 "I have reviewed the emergency response 14 plan, drilling and completion 15 operations, draft 1, as per your 16 request. Please find the Rocky View 17 Fire Service Industrial Emergency 18 Response Plan required checklist." 19 And they went through the plan and did 20 not, basically, have any revisions or whatever to it. 21 So, we were out. We were presenting everything in -- in 22 a -- in a proper manner and seeking input, feedback, work 23 with us, whatever type of thing, in order to finalize the 24 emergency response plan and our plans and so forth. 25 So, perhaps, on the surface, it may appear
3528
1 that we don't have a clear understanding, but -- but 2 Compton has definitely made a concerted effort to inform 3 and -- and work out arrangements with the various 4 agencies. 5 MR. J.R. MCKEE: Mr. Longfield, who's 6 been the primary person that's been designated to 7 represent Compton in the discussions with these municipal 8 bodies? 9 MR. DEREK LONGFIELD: I've been present 10 in many of the meetings. But when we're getting down to 11 revisions to the emergency response plan, such as the 12 several revisions that have come out of comments, let's 13 say, from the City of Calgary over the last year and a 14 half, certainly Mr. Bissett and/or Mr. Brown have -- and, 15 I believe, staff members from their Company, they could - 16 - they could conclude that they have been in direct, 17 ground level, discussions with the staff at, say, 18 Disaster Services, revising, revamping and -- and 19 improving the plan. 20 MR. J.R. MCKEE: Mr. Bissett, let me ask 21 you this then, have the discussions with the City and the 22 Health Region come to a halt prior to this -- to this 23 Hearing or at some point? 24 MR. RICHARD BISSETT: Yes, in both cases. 25 The -- Mr. Longfield could probably address the Health
3529
1 Region better than I can but the -- but the City disaster 2 -- City of Calgary Disaster Services, basically we 3 presented the training program and requested, I believe, 4 feedback and -- and wanted to get together to decide how 5 we were going to put this together, what context we need 6 to build in to it and so forth. And we got a reply back 7 that -- that we need to wait and see whether or not 8 Compton actually gets a well license. 9 And if we get a well license then we're 10 full -- full steam -- it's my understanding we would be 11 full steam ahead in that case. And so -- and I can 12 appreciate that -- that they do not want to commit 13 resources to it if it's a no-go. 14 MR. J.R. MCKEE: When was that letter? 15 MR. RICHARD BISSETT: The meeting was, I 16 believe, July 8th, 2004. 17 MR. J.R. MCKEE: And you say that you 18 submitted a training program to the City subsequent to 19 that meeting? 20 MR. RICHARD BISSETT: No, that -- not to 21 that meeting, no. The training program just -- we'll get 22 that for you. 23 MR. DEREK LONGFIELD: We -- I think the 24 dates are important, Mr. McKee, if you could just -- 25 MR. J.R. MCKEE: Absolutely.
3530
1 MR. DEREK LONGFIELD: -- give Mr. Bissett 2 a minute. 3 MR. J.R. MCKEE: Are these documents in 4 evidence in the record? 5 MR. DEREK LONGFIELD: No, I don't believe 6 so. Well, the training program -- is that what you're 7 asking; that, of course, is. 8 MR. RICHARD BISSETT: Yes, sir. It... 9 10 (BRIEF PAUSE) 11 12 MR. RICHARD BISSETT: The letter -- the 13 meeting we're referring to is July the 8th, Mr. McKee, 14 with the City of Calgary, Compton and ourselves, 2004. 15 MR. J.R. MCKEE: Okay. And you indicated 16 then there was -- the training program was submitted to 17 the City of Calgary? 18 MR. RICHARD BISSETT: I'm sorry, the 19 training program was not submitted, because they did not 20 want to see it until they knew whether or not this was a 21 -- or knew whether or not well licenses would be issued. 22 MR. J.R. MCKEE: And -- and you learned 23 that at this meeting in July of 2004; is that correct? 24 MR. RUSSELL BROWN: There was a -- an 25 initial meeting on July the 8th, with the City, Compton
3531
1 and Bissett, and -- and I think at that time it was 2 verbally stated that Compton did not want to -- or sorry, 3 my fault, the City of Calgary did not want to allocate 4 the resources at this time, until the reduced emergency 5 planning zone was approved. 6 Bissett, through -- through our office, 7 continued to have some -- some informal discussions, 8 phone conversations, lunch meetings with -- with 9 representatives of the City of Calgary, between the 10 middle of July and the end of August. 11 Those -- those again, were informal 12 discussions about the training program, do you want to 13 see it? How can we work to start to develop 14 communication protocols between the City. They were 15 discussions, there was no agreements, and -- and it was 16 at the start of September, and -- that basically I think 17 it was formalized, that on -- on paper but I don't have a 18 copy of that letter. 19 MR. J.R. MCKEE: I'm sorry, Mr. Brown, 20 when you say it was formalized on paper, the -- the -- 21 MR. RUSSELL BROWN: The -- 22 MR. J.R. MCKEE: -- the position of the 23 City? 24 MR. RUSSELL BROWN: The position of the 25 City.
3532
1 MR. J.R. MCKEE: All right. And that was 2 in the form of a letter directed to Compton? 3 MR. RUSSELL BROWN: I don't know. I 4 don't -- I don't -- I can't answer that question. Derek, 5 was it to your Counsel, or was it to you, or -- 6 MR. DEREK LONGFIELD: I don't have it 7 here with me, but I -- I'm -- my recollection is, there 8 is either an e-mail or a letter, Mr. McKee, and -- and I 9 believe it's early September, but -- 10 MR. J.R. MCKEE: All right. 11 MR. DEREK LONGFIELD: -- I can certainly 12 look into it. 13 MR. J.R. MCKEE: All right. Well, and -- 14 and to just -- just to be clear then, so that this 15 communication, in whatever form it was, was in September 16 of 2004, and did it represent the last sort of 17 communication or discussion between Compton and the City, 18 prior to this process commencing? 19 MR. DEREK LONGFIELD: I'm going to say 20 probably -- but I'm just going to have to say probably -- 21 MR. J.R. MCKEE: All right. 22 MR. DEREK LONGFIELD: -- because I can't 23 say definitive, yes or no. 24 MR. J.R. MCKEE: Well, perhaps then I 25 could get you to undertake to A), determine whether in
3533
1 fact -- or what form this communication in September of 2 2004 took, whether it was a letter or e-mail, ascertain 3 whether you have a -- a copy, and I see Ms. Gosselin 4 working her way to the podium, so we -- we may be stopped 5 in mid-undertaking request here, Mr. Chairman. I'll 6 yield. 7 MS. LEILA J. GOSSELIN: If I -- if I 8 could assist the Board, there was a letter dated July 9 20th. Originally Mr. McLarty had correspondence with me 10 or a phone call, and indicated he didn't think it should 11 be part of the record, and I agreed at that time. 12 I'm suspecting now that it's been 13 discussed, he will have a different opinion. I at least 14 have a different opinion, and think it should now form 15 part of the record. We'd be happy to give it to the 16 Board to have copies made. 17 THE CHAIRPERSON: Mr. McLarty, did you 18 have any advice to the Board? 19 MR. ALLAN MCLARTY: I certainly -- I 20 certainly have no objection or concern. We were 21 communicating privately, and as you would understand, 22 Compton want to maintain good relations with -- with the 23 City. They have to work with City people in the future 24 so we want to make sure that we're not revealing any 25 confidences. But if Ms. Gosselin is happy to have that
3534
1 marked, I certainly have no objection. 2 THE CHAIRPERSON: Thank you, Mr. McLarty. 3 MR. J.R. MCKEE: So, gentlemen, we'll 4 return to that document once I've had a chance to look at 5 it and decide how we're to go forward on that basis. 6 THE CHAIRPERSON: By the way, thank you, 7 Ms. Gosselin -- 8 MR. J.R. MCKEE: Yes. 9 THE CHAIRPERSON: -- for your assistance. 10 MR. J.R. MCKEE: Yeah. Thank you, Ms. 11 Gosselin. 12 13 CONTINUED BY MR. J.R. MCKEE: 14 MR. J.R. MCKEE: So, and -- and we'll get 15 back to that in terms of the City. There was a point at 16 which discussions came to an end. 17 And it's -- if I understand you then, Mr. 18 Bissett or Mr. Brown, it's because of the City's view 19 that it didn't want you to devote resources to these 20 discussions until such time as a -- a decision was made 21 on the licences and the reduced planning zone; is that 22 correct? 23 MR. RICHARD BISSETT: Part of that may be 24 my presumption that they did not want to devote resources 25 to it, but that would be my feeling, yes.
3535
1 MR. J.R. MCKEE: Okay. Now, in regards 2 to the Health Region, was there a similar continuation of 3 discussions that came to an end at some point? Maybe you 4 can describe how that -- how that came to an end. 5 MR. DEREK LONGFIELD: I was probably more 6 involved in those discussions than Mr. Bissett and 7 certainly correspondence that is on the record of this 8 Hearing with respect to the Health Region and I think it 9 very simply could boil down to technical differences as 10 to acceptable protective measures and -- and exposure 11 limits, and dispersion modelling, and obviously of course 12 the relief well which we have discussed in detail at the 13 Hearing. 14 But I think probably the most recent 15 correspondence, we were talking around four (4) different 16 areas, as I recall, that there was still some -- there 17 was no agreement between the two (2) parties. And those 18 are pretty clearly on the record and positions were 19 taken that were unlikely to be -- to change too much. 20 MR. J.R. MCKEE: Now, Compton 21 acknowledges, Mr. Longfield, that -- that in order to 22 comply with ID 2001-5, it is likely going to have to 23 provide some plan or some description of how the various 24 government, branches of government and Compton are going 25 to work together; is that fair? Do you understand that?
3536
1 MR. DEREK LONGFIELD: Yes. Especially in 2 the area outside the EPZ in particular, I mean very 3 important in that area, Mr. McKee. 4 MR. J.R. MCKEE: And I think, from 5 discussions I heard I think last week, there was some 6 discussion about the go-forward plan should this 7 application be granted, that these applications be 8 granted. 9 And, Mr. Brown, I think it was you who -- 10 who indicated that if this proved to be impossible, this 11 -- when I say "this", I mean an agreement between Compton 12 or some sort of arrangement Compton and the City or 13 Compton and the Region, that you would -- you would come 14 back to the Board; did -- did I hear that correctly ? Do 15 you recall that? 16 MR. RUSSELL BROWN: Did I say that or Mr. 17 Bissett say that? I'm going -- 18 MR. DEREK LONGFIELD: I might have. 19 MR. J.R. MCKEE: Well, someone said it 20 and I guess I'm curious, let's -- I'd like to spend just 21 a bit of time on that. I mean, again, I -- we're not 22 here to -- to speculate. However, it is clear that at 23 some point in time there -- these differences or these -- 24 these matters have to be set out, resolved, and there has 25 to be a plan put in place.
3537
1 And if there are irresolvable differences 2 between Compton and one (1) of these government bodies, I 3 guess I'll put the question to you as to what -- has 4 Compton thought about what its next step might be or how 5 it might resolve these issues? 6 MR. DEREK LONGFIELD: Let's be clear that 7 we are making the applications under the Oil and Gas 8 Conservation Act. So, when we run into that sort of 9 problem and, of course, emergency response being part of 10 -- of the regulations and the guides, we would probably 11 try to get all the parties together, as we have on a few 12 occasions in the past, I'm sure you are aware, to get all 13 the issues out on the table and determine what the best 14 way would be to resolve them. 15 So, obviously, we would include the EUB in 16 these discussions, and that's -- I think that's, if it 17 was me speaking, that certainly would have been what I 18 was intending to indicate by that. 19 MR. RICHARD BISSETT: And I think it was 20 me that made -- Mr. Brown was right -- that it was me who 21 made that remark that if we did reach an impasse as we 22 have with other agencies and people over time and we do 23 look and come back to the Board and -- and seek guidance, 24 advice and also direction on how to resolve these things. 25 That's a partnership that -- that I think
3538
1 the Province should be very proud of, between the Board 2 and industry and resolving these issues that stand in the 3 way of going forward. 4 5 (BRIEF PAUSE) 6 7 MR. J.R. MCKEE: So, Mr. Longfield, I -- 8 I take it then that it's understood, or it's reasonably 9 clear amongst everyone, that the Application for Reduced 10 EPZ under the -- the interim directive, is based on a 11 number of concepts. 12 Firstly, and we've discussed this, that 13 the calculated zone cannot be safely managed, or 14 practically managed. And so there has to be some action 15 taken to remove or change the -- the hazard, in such a 16 way that it can become manageable. 17 MR. DEREK LONGFIELD: Hmm hmm. 18 MR. J.R. MCKEE: And the first element of 19 that is rather than an unignited release of H2S, that 20 instant ignition take place and the hazard be changed 21 from H2S to SO2, and that there is provided a plan, an 22 ERP, which will provide the proper assurances that the 23 reduced zone and the awareness zone can be properly 24 managed, and that safety can be -- can be achieved. 25 Would you agree with that assessment?
3539
1 MR. DEREK LONGFIELD: Yes. In the middle 2 of that I did hear a new phrase coined, instant ignition. 3 I don't think that's probably an EUB recognized phrase. 4 But I think that was a reasonable encapsulation, 5 regardless of 2001-5, safety and public protection have 6 to take precedents, and the idea behind this fifteen (15) 7 kilometre calculated EPZ, assuming that you're allowing a 8 well to release uncontrolled H2S unignited is simply not 9 acceptable to Compton. 10 So that's -- that's the only thing I'd add 11 to that. It's -- it was not an option. 12 MR. J.R. MCKEE: All right. And so one 13 (1) of the key then, elements, of the Application for the 14 Reduced -- for the Reduced Zone, is the concept, and -- 15 and it's been discussed at some length to date, of 16 immediate ignition. 17 That's understood by everyone, is that 18 correct? 19 MR. DEREK LONGFIELD: Yes, that's 20 correct. 21 MR. J.R. MCKEE: All right. Mr. 22 Bissett...? 23 MR. RICHARD BISSETT: Yes, sir. 24 MR. J.R. MCKEE: I believe it was back at 25 the beginning of our -- of our Hearing, at least in the
3540
1 first week, that when we were talking about ignition, you 2 said and somewhat ruefully, that in your experience 3 you've never had to, and I believe your phrase was, burn 4 a well down. 5 Did I hear that correctly? 6 MR. RICHARD BISSETT: I believe I have 7 never had to burn a well down, or set a well on fire. 8 Lots of flare pits, lots of flare stacks, but never a 9 well on fire. 10 MR. J.R. MCKEE: And that's what we're 11 talking about here, potentially, with immediate ignition? 12 MR. RICHARD BISSETT: Yes, sir, that's 13 correct. 14 MR. J.R. MCKEE: And would it be fair to 15 say, sir, that for someone in the drilling business, a 16 professional whose -- whose job it is, is to drill wells 17 and do so safely, that igniting a well, burning a well 18 down as you phrased it, is about the last thing that they 19 want to do? 20 MR. RICHARD BISSETT: Yes, sir, that's 21 correct. 22 MR. J.R. MCKEE: And every element of 23 their training and every element, or every bit of their 24 experience, would lead them to try virtually anything 25 before lighting it up, is that fair?
3541
1 MR. RICHARD BISSETT: I think that would 2 be a -- would be a fair assessment, given that -- that -- 3 and the Chairman likes analogies, and let me give you one 4 (1), in this case. 5 It never amazes me and I've never had the 6 opportunity and I'm not sure I could force myself to put 7 on a parachute and jump out of a perfectly good aircraft. 8 Likewise, I find it very difficult to -- I would, myself, 9 to set a well on fire, because as soon as you do then you 10 or I can no longer fix the problem. We have now got to 11 rely upon outside sources. 12 So, I go back upstream and say, okay, I'm 13 going to devote my resources to making sure that I don't 14 have a blowout and here's what I'm going to do. I will 15 spend my efforts at prevention rather than having to, as 16 you say, burn the well down, you know, type of thing 17 so... 18 MR. J.R. MCKEE: Well, and in -- it's -- 19 it's a good analogy. Let me throw -- throw another one 20 at you if we're going to have an analogy. 21 MR. RICHARD BISSETT: You may as well. 22 MR. J.R. MCKEE: A driller or someone in 23 charge of a rig is -- the thought of igniting the well 24 and destroying it and -- and the things that go with that 25 is, of course, probably considered probably the largest
3542
1 or the most difficult decision that he's likely or she's 2 likely to have to make; is that fair to say? 3 MR. RICHARD BISSETT: Yes, sir. It would 4 be -- it would be one of the major decisions confronting 5 a drilling or completion supervisor. 6 MR. J.R. MCKEE: And it's -- and it's a 7 in decision which, in many ways I guess, is an admission 8 that everything I've done that you've described to 9 prevent it from happening has failed? 10 MR. RICHARD BISSETT: That's right. 11 That's -- you're -- you're defeated. You -- 12 MR. J.R. MCKEE: Yes. And so the analogy 13 that -- that occurs to me and it may be a little far- 14 fetched, but I think we've probably all seen films of or 15 documentaries about the poor individuals who are stuck in 16 missile silos somewhere in the -- the Colorado plans and 17 whose job it is one day is to get a phone call turn a key 18 and potentially kill millions of people -- 19 MR. RICHARD BISSETT: Yes, sir. 20 MR. J.R. MCKEE: -- and you know what I'm 21 talking about? 22 MR. RICHARD BISSETT: Yes, sir. 23 MR. J.R. MCKEE: And there's a constant 24 worry with those individuals that, being human beings, 25 when they get that call there may be a Gee, I can't do
3543
1 this or, I'm going to wait until they double check or 2 there'll be some natural hesitation; you hear what I'm 3 saying? 4 MR. RICHARD BISSETT: Yes, sir, I do. 5 MR. J.R. MCKEE: And the way they counter 6 that, so I'm told, is by training. Constant training so 7 that it's a mechanical response. The phone call comes, 8 the code is punched the key is turned and no one thinks 9 twice about it; do you understand what I'm saying? 10 MR. RICHARD BISSETT: Yes, sir. I sure 11 do. 12 MR. J.R. MCKEE: So, bringing that 13 analogy down a thousand pegs or so to our situation, for 14 the individual who's charged on the wellsite of making 15 that decision, what training -- what assurances will 16 Compton give us that that individual is going to be able 17 to make that decision at the appropriate time? 18 We've heard and we've read all of the 19 criteria; this must happen, this must happen. But we 20 have a human being who, at some point in time, has to 21 say, I give up, we have no choice. Human nature being 22 what it is and given that this is the last thing anyone 23 would want to do, you would agree with me there is the 24 risk that someone is going to try one more thing, come up 25 with something else or possibly delay this.
3544
1 And given the time sensitivities here, 2 what can you say that would make us less concerned of 3 that particular human element? 4 MR. RICHARD BISSETT: Okay. Let me -- 5 let me give you my view upon it. Mr. Longfield, on 6 behalf of Compton, may also wish to add to this. But 7 there's been a lot of thought, Mr. McKee, given to that 8 very issue about how are we going to ensure that this 9 thing will be set on fire when it comes time to do that. 10 And we -- we've built some safeguards in 11 there and you did indeed hit the nail on the head; is the 12 training. It must -- the training is paramount to 13 igniting that well. Everybody that's there has got to 14 understand their duties, their responsibilities. That 15 individual who's going to have to pull that trigger has - 16 - has to have, not only the -- the responsibility but the 17 authority and they will have. 18 We have -- we have said that Mr. Cover, 19 who is the drilling and completions manager for Compton 20 will go to the location at the declaration of a Level 1. 21 As far as that drilling or completion supervisor that 22 will help to remove any of -- any of the stress that he 23 or she may have when it comes time to do that. 24 And -- and, having said that, we do have 25 two (2) supervisors; they are working twelve (12) hour
3545
1 shifts. But -- but that also brings up tiredness, 2 perhaps not being as sharp as you can be and so forth. 3 So we have assigned to this location a two 4 (2) man ignition crew that will be onsite twenty-four 5 (24) hours a day. And their only responsibility with 6 respect to this operation will be to ignite that well if 7 it ever blows out of -- out of control. 8 The -- the one (1) thing I'll say is that 9 -- that we or -- or the Canadian oil and gas industry 10 does not have to take a back seat to any other 11 jurisdiction in this world when it comes to -- to 12 technology and when it comes to -- to developing new 13 ideas. 14 But, more importantly, the competence of 15 the people in this industry is -- is better, as good or 16 better than any other industry when it comes to doing 17 what they do on a day-to-day basis. And the training 18 that will go into this, the responsibility that these 19 people will be made to realize will be transferred to 20 them and I can -- I will assure you that that well, if 21 it's not ignited, it won't be because of indecision on 22 those people's part. They will understand the importance 23 of igniting it as -- as quick as possible. 24 And I suppose that's -- that's -- that's 25 my analogy of going back upstream a little further.
3546
1 Let's -- let's put all of our efforts into not having a 2 blowout rather than one that we -- that -- that we fail 3 at. But having said that, well, if Murphy is, indeed, 4 here then we'll -- we're not going to shortchange the 5 effort to ensure that we can set it on fire. 6 So, I don't know if that gives you or the 7 public any feeling of comfort but that will be the way 8 that -- that -- that my feeling is to ensure that it does 9 get ignited regardless. 10 And, Mr. Longfield may wish to add to 11 that, Mr. McKee. 12 MR. DEREK LONGFIELD: You will likely be 13 thankful that I will be brief. But, I do think we need 14 to underscore that before we even get into the sour zone 15 there is an emergency response plan meeting in the 16 office. There's an emergency response plan meeting out 17 in the field and everyone -- it goes through in detail 18 what everyone's responsibilities are out there. 19 That is the type of thing that's 20 underscored by an individual like Mr. Brown. He's taller 21 than everybody there. He's bigger than everybody there. 22 He commands respect. And, having said that, there are 23 also ignition drills that are done and you are -- you are 24 absolutely right, Mr. McKee, it is training, training, 25 training.
3547
1 And they have those responsibilities; the 2 people out there on that rig. They know they have them. 3 And they're very cognisant. They've accepted those 4 responsibilities when they go on that well. 5 MR. RUSSELL BROWN: Can I add to this 6 analogy. Being lucky enough to have been stationed at 7 CFB Cold Lake where there is a NORAD radar station that 8 does communicate to the bunker, I highly doubt it, that 9 they have one (1) person turning a key. It's not going 10 to happen. 11 There is constant communication, there is 12 a chain of command. I could be totally wrong on this but 13 there is independent people, six (6) feet apart doing the 14 same job to reduce this psychological task. 15 This is exactly the same types of 16 procedures that are in here. It's a great analogy. I 17 thank you for coming up with it. 18 MR. J.R. MCKEE: Mr. Bissett, you said 19 the other day and I think you've said a couple of times, 20 it's the intention to hire, I believe, the best in terms 21 of the drilling contractors; did I hear you say that? 22 MR. RICHARD BISSETT: Yes, sir. I would 23 -- I would say not -- I wouldn't restrict that to 24 drilling contractor. I would also include all other 25 services that's going to be at the wellsite and, in
3548
1 particular, the safety service. 2 MR. J.R. MCKEE: It makes one wonder when 3 -- when you'd hire the mediocre ones, but leaving that 4 aside, I -- I'm guessing what you mean by that is that 5 you are going to only deal with organizations or 6 companies that have standards that are similar to what 7 you view is required for this project? 8 MR. RICHARD BISSETT: Yes, and now I'm -- 9 I'm sort of starting to get into Mr. Cover's area, to -- 10 to some degree, in selecting services for -- for this 11 site. 12 MR. DEREK LONGFIELD: And I can add, that 13 I do recall part of the transcript, and I don't recall 14 page numbers, but Mr. Cover did elaborate that experience 15 was very important. And the nature of the drilling 16 business is that when you get up into one (1) of these 17 big rigs, you have the experience; you work from the 18 small rigs up. 19 And these are their most experienced, 20 these are their best people. The same thing with our 21 wellsite supervisors. Our most experienced, our best 22 supervisors, are the two (2) fellows that will be on 23 these wells. 24 MR. J.R. MCKEE: And do I understand, 25 however, that the training and the -- the types of things
3549
1 that we've just been discussing, those aren't going to be 2 delegated to the drilling companies themselves. 3 This is something that Compton, through 4 you, Mr. Bissett, is going to be taking on directly? 5 MR. RICHARD BISSETT: Yes, sir, that's 6 correct. The -- the training that we're talking about, 7 will be through -- directed by Compton, yes, sir. 8 MR. J.R. MCKEE: Okay. And the training 9 and the exercises, are they the ones that we discussed at 10 some length with Mr. Cover, that are set out in the 11 drilling plan, for starters? 12 MR. RICHARD BISSETT: Yes, sir, that's 13 correct. 14 MR. J.R. MCKEE: And then the -- 15 MR. RICHARD BISSETT: BOP drills, man 16 down drills, ignition drills. 17 MR. J.R. MCKEE: And these will be done 18 with the crews and with the individuals who will be 19 actually drilling the wells; is that correct? 20 MR. RICHARD BISSETT: That's exactly 21 right. By the time Mr. Cover gets done with these boys, 22 they're probably going to be looking for work elsewhere. 23 24 (BRIEF PAUSE) 25
3550
1 MR. J.R. MCKEE: And is it fair to say 2 that the reason that that is important, and again, we're 3 talking about the human element here, is that any delay 4 in making the decision to ignite, will have an impact on 5 the timeframe for ignition, and everything that flows 6 from that; is that fair to say? 7 MR. RICHARD BISSETT: Yes, sir, I think 8 that's a fair statement. And to our -- it's a true 9 statement. 10 MR. J.R. MCKEE: And so we can talk about 11 seven and a half (7 1/2) minute ignition times, fifteen 12 (15) minute ignition times, but the clock doesn't start 13 running until such time as the wellsite is evacuated, and 14 that's not going to happen until someone actually makes 15 the decision -- makes that difficult decision? 16 And so again, that is a potential area 17 where time can be lost, and -- and for that reason it is 18 -- it is of concern. 19 MR. RICHARD BISSETT: Sorry, in the 20 evacuation of the wellsite? 21 MR. J.R. MCKEE: No, the -- I think 22 you've told me earlier that -- that once the decision is 23 made to ignite, evacuation takes place. And once 24 evacuation is completed, then the clock starts running 25 for ignition. And did I understand that from previous
3551
1 testimony? 2 MR. RICHARD BISSETT: That's right, you 3 were talking about evacuation of the worker -- 4 MR. J.R. MCKEE: Yes. 5 MR. RICHARD BISSETT: -- to a safe area-- 6 MR. J.R. MCKEE: Yes. Yes. 7 MR. RICHARD BISSETT: -- before -- yes, 8 sir, that -- 9 MR. J.R. MCKEE: Yes. 10 MR. RICHARD BISSETT: -- that's correct. 11 If you found yourself where you had no warning, and you 12 had a blowout happening, like turning that light switch 13 on over there, why then, yes, that's -- that's correct. 14 Or any other situation. 15 MR. J.R. MCKEE: So a precursor to that 16 is the decision to ignite? 17 MR. RICHARD BISSETT: That's right. That 18 man or lady, he or she that pulls that trigger, has to 19 ensure that the location has been evacuated. 20 MR. J.R. MCKEE: Right. 21 MR. RICHARD BISSETT: That's paramount. 22 MR. J.R. MCKEE: But they wouldn't 23 evacuate, they wouldn't say, everybody let's -- it's time 24 to go, until they've made the decision to ignite; is that 25 correct?
3552
1 MR. RICHARD BISSETT: The alarm would be 2 sounded, and everybody will proceed to the safe briefing 3 area, that's already been determined. The ignition crew 4 will be there waiting for them, and that ignition crew 5 will look to that drilling supervisor for a thumbs up, 6 and they will immediately begin ignition. 7 MR. J.R. MCKEE: I think -- and I 8 appreciate that, Mr. Bissett, I think we're missing each 9 other. 10 What I'm trying to say is that none of 11 that happens until the person has said, we have to -- we 12 have to light this up, we have to -- we have to ignite, 13 let's start the sequence in motion to -- towards that? 14 MR. RICHARD BISSETT: Yes. 15 MR. J.R. MCKEE: Is that correct? 16 MR. RICHARD BISSETT: That's correct. 17 MR. J.R. MCKEE: And so that any delay, 18 any misunderstanding of duty, any problems communicating 19 because of noise, any slowness because of exhaustion, 20 that leads that person to be a little slow to make that 21 decision, is going to ultimately affect the timing of the 22 ignition. 23 MR. DEREK LONGFIELD: Before Mr. Bissett 24 responds, I'd have to say that, no, quite often that 25 decision, I shouldn't say quite often, because it's not
3553
1 something that happens often, but normally there still 2 would be some time before you had gas-to-surface. So 3 that I want to be clear this question back a bit, that 4 the ignition time starts click -- ticking would -- takes 5 from when we have gas to surface. 6 But, I think the situation we're talking 7 would be the automatic, immediate loss of the well where 8 you immediately had gas-to-surface. And in that -- that 9 situation, I cannot conceive of any situation where 10 someone would be going, Oh, should I or shouldn't I. I - 11 - I can't conceive of it, and as a precursor to Mr. 12 Bissett talking, I just wanted to make sure that that's 13 certainly Compton's position all along, and that's how 14 I've understood all of my discussions with Mr. Bissett 15 and Mr. Cover. 16 MR. RICHARD BISSETT: I concur with that, 17 Mr. McKee. 18 MR. J.R. MCKEE: And I understand that, 19 Mr. Longfield, in terms of the timing, but, again, some 20 of that time that we've discussed, and I don't want to 21 get back into the hour, two (2) hour business just to 22 this point, but some of that time could be lost if 23 someone is trying herculean efforts to bring it under 24 control or going beyond the criteria, and -- and I guess 25 that's -- that's the point of the question is, is Compton
3554
1 satisfied that its training -- 2 MR. RICHARD BISSETT: Yes. 3 MR. J.R. MCKEE: -- and drills that they 4 have, will prevent that eventuality from occurring. 5 MR. DEREK LONGFIELD: Well, I can let Mr. 6 Brown speak to that if it's necessary, but absolutely, 7 you mentioned training, that's was what I was going to 8 say, if you've trained the people well, there is a 9 process, there are steps, we've gone through them in 10 detail and when you get to the point where you have no 11 options, then you have your other option, which is 12 ignition. 13 MR. RICHARD BISSETT: And if there is 14 sufficient time, Mr. Cover will be on location. And I 15 will assure you that ignition will be -- will be a 16 nickname on this location, that -- that will be at 17 foremost in everybody's mind, if we ever did find 18 ourselves in a well control situation, Mr. McKee. 19 MR. J.R. MCKEE: All right, gentlemen. 20 I'd like to, again now, we've talked about the notion of 21 immediate ignition as being an integral element of the 22 Application to reduce the EPZ, and again, the other -- 23 one of the other integral elements is the -- the ability 24 to manage the zone, the -- the -- and the reduced zone, 25 and the awareness zone, and that of course is manifested
3555
1 in the -- the emergency response plan itself. 2 And, Mr. Bissett, is -- I gather that the 3 emergency response plan that we have, the -- the version 4 that we're looking at here, is designed to deal with all 5 of the wells that are the subject of these Applications? 6 MR. RICHARD BISSETT: Yes, sir, that's 7 correct, the six (6) -- six (6) wells, Mr. McKee. 8 MR. J.R. MCKEE: Okay. And of course 9 we've talked about the timeframes that we could be 10 looking at, but it would seem that it's a distinct 11 possibility that this, assuming all six (6) wells were to 12 be drilled, this could be over a -- a fairly significant 13 period of time. 14 What will you do or what will Compton do 15 to continue to ensure that the ERP is valid and 16 appropriate in the passage of time, from the drilling of 17 the first well to the conclusion of the program? 18 MR. RICHARD BISSETT: Let me take a run 19 at it first, Mr. McKee, and then Mr. Longfield may wish 20 to -- to add to it. 21 My thought on this would be that -- that 22 we will have public safety coordinators working twenty- 23 four (24) hours, we will have rovers within the emergency 24 planning zone, while critical sour operations are 25 ongoing.
3556
1 Part of the rover's duties and 2 responsibilities is to become familiar with his -- his or 3 her particular area, and -- and note any activities that 4 -- that could impact evacuation. And that would include 5 somebody starting to build a new home or whatever. The 6 emergency response plan would be updated as soon as that 7 happens. As soon as they would identify these -- these 8 activities or these new areas, the emergency response 9 plan would -- would have to be updated. 10 After six (6) months, it would be my -- my 11 thought that we would update all the confidential 12 resident information. Go back to the residents to ensure 13 that nothing's changed and that everything is still as it 14 -- as it was. 15 So, it's really a living document. It 16 will be ongoing. The Rovers -- the Rovers will 17 precipitate changes and -- and if the drilling program 18 goes on as Mr. Cover has predicted for perhaps eighteen 19 (18) months or -- or -- or fifteen (15) to eighteen (18) 20 months then the emergency response plan will have to be 21 updated as required. 22 MR. J.R. MCKEE: And -- and just to be 23 clear, and I think, Mr. O'Ferrall discussed this with you 24 it's -- in some -- some detail, prior to any drilling 25 taking place, the Board has to accept and approve the
3557
1 ERP. 2 The living document, to that point, has to 3 contain the necessary elements in order for the Board to 4 allow you to proceed that -- you understand that? 5 MR. RICHARD BISSETT: Yes, sir. As a 6 matter of fact, I also understand that that plan has to 7 be on location before that well spuds. 8 MR. J.R. MCKEE: But I take it, it's not 9 Compton's current intention or understanding that it 10 would have to resubmit the ERP prior to the drilling of 11 each of the individual wells through the period of the 12 program; is that correct? 13 MR. RICHARD BISSETT: I -- I -- 14 MR. DEREK LONGFIELD: It depends on how 15 long in between. Like, if we drilled the first two (2) 16 wells and waited three (3) months and that added up to 17 seven (7) months, absolutely it would have to be updated 18 or if there's anything that was significantly different. 19 I think when Mr. Bissett said that it was 20 a living document I would expect each well license has 21 the requirement for that ERP to be on site and I'm not 22 sure lately, but I'm certain that the EUB would want to 23 know that on well 2 that that plan was certainly still 24 appropriate as it was for well 1. 25 If we go to the situation where we're
3558
1 going vertical first and then do the sour operations one 2 after the other, obviously I think you would expect to be 3 in the same plan because it would be a continuous type of 4 operation, Mr. McKee. 5 So if there was some sort of gap in 6 between that necessitated changes, those changes would 7 have to be made and they would be made. 8 MR. J.R. MCKEE: Well, this might be a 9 good opportunity then, why don't we turn to Exhibit 039- 10 006? 11 12 (BRIEF PAUSE) 13 14 MR. J.R. MCKEE: To assist, gentlemen, 15 that is the various scenarios that were put together 16 earlier. 17 MR. RICHARD BISSETT: Yes, sir. 18 MR. J.R. MCKEE: Mr. Bissett, you'll 19 recall that this exhibit reflects four (4) different 20 scenarios for the timing of the -- of the drilling of the 21 -- of the wells should licenses be granted. 22 And we discussed, I think with Mr. Cover 23 and Mr. Longfield, you know, the challenges or the -- the 24 pros and cons of the various scenarios, to some extent, 25 from a drilling perspective.
3559
1 I'm wondering if you, sir, have any 2 concerns or have identified any particular challenges 3 that any of these particular cases might present from an 4 ERP standpoint? 5 MR. RICHARD BISSETT: Certainly, there's 6 -- there are additional concerns during certain parts of 7 the year, particularly, a case in point, would be the 8 golf course; The Cottonwood Golf Course which is within 9 the EPZ. 10 11 (BRIEF PAUSE) 12 13 MR. RICHARD BISSETT: And -- and 14 scheduling of it, I -- no, I don't see anything that 15 stands out in my mind that would make it difficult. Mr. 16 Brown, though, did want to make mention about the 17 emergency response plans and updating and -- and a little 18 bit about the approval process as well. 19 MR. RUSSELL BROWN: Yes. The EUB 20 approval process is against -- would have to be against 21 each particular well, when that well license was issued. 22 Not to my recollection, can -- can they 23 approve a six (6)-well ERP all at one time, unless six 24 (6) well licenses have been issued. 25 If -- if they would license or they -- an
3560
1 ERP approval letter, which means that ERP has to be 2 reviewed and approved against each well as that license 3 comes out, and it has to be -- meet the minimum 4 requirements, which include updating and making sure it 5 is current and accurate. 6 MR. RICHARD BISSETT: And -- and also to 7 pick up on your scheduling, when I look at Mr. Cover's 8 schedule, I do see that there's a one (1) to twelve (12) 9 month period in most of the -- in all four (4) cases, 10 there's potentially a one (1) to twelve (12) month 11 period. The emergency response plan would definitely 12 have to be updated at the end of twelve (12) months. 13 MR. J.R. MCKEE: All right. I guess, 14 more to my -- more to the point, and I guess I didn't -- 15 maybe I didn't make it as clear as I'd hoped, each of 16 these scenarios has a different sort of grouping of when 17 sour operations would happen. 18 In Case A we see it's sort of spread out 19 with gaps in between, Case B we see a sixty-five (65) day 20 period of sour operation, and then in Case C a hundred 21 and seven (107), and in Case D a hundred and thirty-nine 22 (139). 23 Do you foresee any problems or any 24 difficulties in -- in an ERP or -- from an ERP 25 perspective, in terms of a hundred and thirty nine (139)
3561
1 day, for instance, period where there's sour operations? 2 I'm thinking in terms of -- of resources 3 and the ability to keep, you know, the plan on the 4 necessary level of preparedness for a lengthy period like 5 that. 6 Do you see that as a problem? 7 MR. RICHARD BISSETT: Yes and no. I 8 believe we have responders, alternate responders for -- 9 for all positions. If they were to go a hundred and 10 thirty nine (139) days, then -- then definitely there 11 would have to be -- the alternates would have -- there 12 would have to be a schedule set up to where alternates 13 took over on a -- a ten (10) and three (3) basis or -- or 14 whatever, to ensure that there's relief, not only for the 15 responders, but for the field personnel as -- as well. 16 There would have to be alternates and a 17 schedule set up to ensure that -- that nobody works a 18 hundred and thirty-nine (139) straight days, but that's - 19 - that will not -- will not occur. 20 MR. J.R. MCKEE: Have you, sir, in your 21 experience, had an ERP that was engaged for -- for that 22 length of time? 23 MR. RUSSELL BROWN: Yes. 24 MR. J.R. MCKEE: And -- and how did you 25 overcome the -- the sort of challenges that a lengthy
3562
1 period of time would -- would offer? 2 MR. RUSSELL BROWN: Planning, proper 3 planning, and proper scheduling, to make sure that people 4 were rotated out on a -- on a scheduled basis, making 5 sure that those people that were rotated in were trained 6 and ready to go before they went in. 7 There was usually, I forget, I'm 8 embarrassed now that I forget the term, oh, it was 9 shadowing for a period of time, so -- so the, for 10 example, just let me get the term correct. 11 So for example, public safety coordinator, 12 if -- if we're going to switch out a public safety 13 coordinator, he's been the public safety coordinator for 14 -- for two and a half (2 1/2) weeks, it's time for him to 15 go, the new public safety coordinator is going to come in 16 a day ahead of time. 17 It's not just, hi Bob, bye Tom, you know, 18 they don't just switch out, they -- they shadow each 19 other, much like good emergency preparedness when 20 incoming commanders change out, there should be a 21 shadowing period. 22 We've done it before, and -- and actually 23 we did two (2) extended ERPs at the same time, in -- in 24 two (2) different areas of the Province, and had to 25 manage that process.
3563
1 MR. J.R. MCKEE: Does the current ERP, 2 the current ERP that's before us currently, provide any 3 of that sort of planning or information that -- that 4 would be required for an extended period like this? 5 MR. RUSSELL BROWN: No, it does not. 6 MR. J.R. MCKEE: Now, reverting back then 7 to Case A, we'd have the -- the oper -- operations and 8 sour -- sour zone for twenty-six (26) days, followed by a 9 gap and then again a re-evaluation. 10 Would it be -- would the ERP be stood down 11 in between these two (2) sour zone operations? Would 12 that be the normal way you would handle it, or would you 13 leave it in place for the entire period of the .. 14 MR. RICHARD BISSETT: The -- the -- in -- 15 in Case A, I would say that it would be stood down and 16 the notices delivered or given or sent to the public, 17 because we've got to keep in mind we're going to notify 18 the public prior to start, and at the conclusion of sour 19 operations. 20 Given that there are concerns and issues 21 with being exposed to a hazard during a period of time, 22 there's no use putting any more stress upon the public 23 than is necessary. 24 So, the ERP will still remain there. The 25 notice will be given to the public that it's -- that it's
3564
1 stood down. The safety services, the -- the ignition 2 crew, and -- and other sour service related personnel 3 equipment would probably be either released or else put 4 onto -- to standby, until the sour operations began on 5 the next well. 6 But the ERP would -- would sit -- sit 7 there, and I suppose you could say it would -- it would 8 be stood down. 9 MR. J.R. MCKEE: Now, assuming that any 10 one (1) of these particular cases is the one (1) that -- 11 that Compton adopts in its drilling program, should it -- 12 should it be granted these licenses, would this sort of 13 sequencing and the results on the ERPs standing down and 14 -- and being engaged again, would that be part of the 15 public information process that would proceed the 16 commencement of the drilling? 17 So in other words, one could understand 18 why a resident might be confused that they're notified 19 that, yes, we're in sour operations and the ERP's 20 engaged, and then twenty-six (26) days later it's down 21 again, and then thirty (30) days later it's up again. 22 Would that be -- would Compton contemplate 23 explaining that as part of its education process? 24 MR. RICHARD BISSETT: At this juncture we 25 really haven't, we have in the Emergency Response Plan
3565
1 suggested messages that would be sent to the public prior 2 to a sour operation beginning, and when it's stood down. 3 If -- if it was beneficial, then 4 definitely a further explanation would be given to the 5 public that -- that that would provide more information. 6 The public safety coordinators will man a 7 telephone twenty-four (24) hours a day that the public 8 can phone and find out, ask questions. They will be 9 holding informational sessions during the sour operation, 10 that the public can -- can go to. But if it -- again, I 11 would say that if that was beneficial, it would be done. 12 MR. DEREK LONGFIELD: And I can certainly 13 say that I understand your point about potential 14 confusion, and I think we have gone on the record saying 15 that that has been one (1) of the benefits of this 16 Hearing that -- excuse me, in this Hearing, that the -- 17 the compression of time frames when we're sour, as in 18 Case B. This is certainly probably an improvement on the 19 plan as presented in August of 2002. 20 So, for what that's worth, Mr. McKee. 21 MR. RUSSELL BROWN: And -- and I can 22 further add, just this Monday morning, as a matter of 23 fact, there's a well west of town here that we were 24 involved in, and -- and there was an extensive public 25 consultation program, as well as information about going
3566
1 from drilling to completions, two (2) separate functions 2 with a -- with a gap -- time gap in between, and the 3 public was informed about that. 4 Again, completion of operations were about 5 to start up this week and the public was notified, both 6 by a telephone and in person and -- and there was no 7 doubt, one -- we did receive one (1) call back from a 8 member of the public saying, you know, I just -- I just 9 got the -- I just got the termination phone call and 10 notice five (5) days ago, what's going on? 11 And, you know, within minutes we were -- 12 we phoned him, explained it to him and asked if he would 13 like somebody to come by and visit his house and no, he 14 was -- he was more than happy. 15 So, even though you do inform the public 16 and everybody, you still have to be prepared to respond 17 to the individual needs of the public inside the EPZ. 18 MR. RICHARD BISSETT: And to take that a 19 little further, I think, given that we would be able to 20 assess, to some degree, the adequacy of our notices and 21 our program by the number of telephone calls that -- that 22 the public safety coordinator or Compton would receive 23 and if they were high on the line then we would know that 24 evidently our system is -- is inadequate and would need 25 revising or changing.
3567
1 MR. J.R. MCKEE: Thank you, gentlemen. 2 Mr. Chairman, I see that it is probably a good time to 3 take our morning break and this would be an opportune 4 time. 5 THE CHAIRPERSON: Right you are, Mr. 6 McKee, we will take our twenty (20) minute break and 7 return at ten (10) minutes to 11:00. Thank you. 8 9 --- Upon recessing at 10:32 a.m. 10 --- Upon resuming at 10:55 a.m. 11 12 THE CHAIRPERSON: Yes, Mr. McKee, you can 13 continue. 14 MR. J.R. MCKEE: Thank you, Mr. Chairman. 15 Mr. Chairman, before we broke for the morning coffee 16 break, Ms. Gosselin, with the permission of Mr. McLarty, 17 circulated a letter dated July 20th, 2004 from the Law 18 Department of the City of Calgary to Fraser Milner 19 Casgrain, for the attention of Mr. McLarty. 20 I've now had the opportunity to review 21 that and perhaps we should mark that as the next exhibit 22 in these proceedings before we proceed. 23 THE CHAIRPERSON: Yes, thank you. That 24 would be Exhibit 39-051 as described by Mr. McKee and 25 just, court reporter, if you would add, "supplied by Ms.
3568
1 Gosselin"; would that be appropriate, Mr. McKee? 2 MR. J.R. MCKEE: That would be fine, sir. 3 4 --- EXHIBIT NO. 39-051: Letter dated July 20th, 2004 5 from the Law Department of 6 the City of Calgary to Fraser 7 Milner Casgrain, for the 8 attention of Mr. McLarty 9 (supplied by Ms. Gosselin) 10 11 CONTINUED BY MR. J.R. MCKEE: 12 MR. J.R. MCKEE: Now, I believe, Mr. 13 Bissett and Mr. Brown, we were talking about the 14 discussions that took place between Compton and the City 15 of Calgary and, more to the point, we were zeroing in on 16 the point at which it became apparent that there was not 17 going to be any sort of conclusion of the various plans 18 or arrangements that would become necessary between 19 Compton and the City for inclusion in the -- in the ERP. 20 You recall that discussion, sir? 21 MR. RICHARD BISSETT: Yes, sir. 22 MR. J.R. MCKEE: And you'd indicated a 23 series of meetings and, I believe, a discussion about a 24 meeting which took place on July the 8th, 2004 and then 25 there was some discussion of a correspondence that I
3569
1 think Mr. Brown had recollected occurred subsequent to 2 some further meetings and discussions and that that 3 correspondence was sometime in September. 4 Have I recalled that correctly, Mr. Brown? 5 MR. RUSSELL BROWN: Before September. 6 Between mid-July and the end of August. 7 MR. J.R. MCKEE: All right. And in the 8 midst of that discussion Ms. Gosselin on behalf of the 9 City, provided us with a copy of a letter that has now 10 been marked as Exhibit 39-051, dated July the 20th, 2004, 11 between herself and Compton's solicitor, Mr. McLarty. 12 And do you have a copy of that, gentlemen? 13 MR. RICHARD BISSETT: Yes, sir, we do. 14 MR. J.R. MCKEE: Now, in this letter, and 15 -- and again, the letter speaks for itself, but it -- it 16 doesn't seem to indicate that the City, at least on the 17 20th of July, 2004, is unprepared to proceed with any 18 further discussions. 19 It would seem that the letter is -- is 20 setting out some discussions that did take place, and 21 detailing some information that the City was expecting to 22 receive from Compton. 23 Is this the correspondence that you had in 24 mind, Mr. Brown, when we were having our earlier 25 discussion?
3570
1 MR. RUSSELL BROWN: I'm -- I'm sorry, I 2 was -- can you just please ask that question again? 3 MR. J.R. MCKEE: Is this -- when we were 4 talking before, you'd indicated that you recollected, and 5 I think Mr. Longfield actually offered that it might have 6 been an e-mail or some sort of correspondence that -- 7 that -- at which point it became clear that Compton and 8 the City were not going to sort this out prior to this 9 process, and that's when this letter was offered up. 10 And I guess my first question is: Is this 11 -- is this the correspondence you had in mind when you 12 were -- you were attempting to recollect when it 13 occurred? 14 MR. RUSSELL BROWN: No, sir. 15 MR. J.R. MCKEE: All right. So, if I 16 understand things then, Mr. Brown, there were discussions 17 subsequent to this letter being directed between the 18 lawyers, between Compton/Bissett and the City, which led 19 to some sort of end of discussions, you say before 20 September of 2004, have I got that right? 21 MR. RUSSELL BROWN: It was informal 22 discussions, telephone conversations, e-mail, a lunch, 23 and then September -- the last one (1) I have is August 24 30th, and then after that it's -- that's the end of 25 discussions that Bissett has had with the City.
3571
1 MR. J.R. MCKEE: And it's your 2 recollection that that was encapsulated in some written 3 way, whether it be e-mail or letter, is that correct? 4 MR. RUSSELL BROWN: It -- the e-mail was 5 not to me. And I now know of that e-mail. But it was 6 not to me at all. 7 MR. J.R. MCKEE: All right. Well perhaps 8 then we could ask, as I was asking before, for an 9 undertaking to A, determine whether or not there was a 10 letter or an e-mail or some sort of written communication 11 in and around the end of August 2004, from the City to 12 Compton. And if it exists, to produce it. 13 MR. DEREK LONGFIELD: We will undertake 14 to do that, Mr. McKee. 15 MR. J.R. MCKEE: Thank you. 16 THE CHAIRPERSON: So we'll reserve the 17 series Exhibit 39-052, for undertakings to Board staff. 18 19 --- UNDERTAKING NO. 61: For Compton to determine 20 whether or not there was a 21 letter or an e-mail or some 22 sort of written communication 23 in and around the end of 24 August 2004, from the City to 25 Compton. And if it exists,
3572
1 to produce it. Expanded on 2 page 3576 to include a 3 package of correspondence as 4 between Compton's Counsel and 5 the City of Calgary, as it 6 pertains to the discussions 7 concerning the planning of 8 the ERP. (Reserved Exhibit 9 No. 039-052(a), given to Mr. 10 J.R. McKee, page 3570, line 11 19) 12 13 --- EXHIBIT NO. 039-052(a) For Compton to determine 14 whether or not there was a 15 letter or an e-mail or some 16 sort of written communication 17 in and around the end of 18 August 2004, from the City to 19 Compton. And if it exists, 20 to produce it. Expanded on 21 page 3576 to include a 22 package of correspondence as 23 between Compton's Counsel and 24 the City of Calgary, as it 25 pertains to the discussions
3573
1 concerning the planning of 2 the ERP. (Undertaking No. 3 61, given to Mr. J.R. McKee, 4 page 3570, line 19) 5 6 MR. J.R. MCKEE: Thank you, Mr. Chairman. 7 8 CONTINUED BY MR. J.R. MCKEE: 9 MR. J.R. MCKEE: Now, Mr. Longfield, I'll 10 address this to you now. This letter that we've marked 11 as Exhibit 051, certainly was a letter between the City 12 of Calgary's Legal Department and Compton's counsel. 13 Are you familiar with this letter, had 14 you seen it before this morning? 15 MR. DEREK LONGFIELD: I am almost certain 16 I have seen it before, Mr. McKee. There were -- there 17 were -- there was more than one (1) letter, back and 18 forth kind of thing. So, I think this is one (1) of a 19 sequence of letters, is my recollection. So, it's a -- 20 it's a recollection, nothing I can confirm right now, Mr. 21 McKee. 22 But I do recall certainly the discussions 23 about the two (2) different models. And here we are, 24 modellers have come up with different results, and 25 clearly the City relying on the RWDI model, and of course
3574
1 that will be discussed in more detail in these 2 Proceedings. 3 MR. J.R. MCKEE: So can you confirm point 4 2 of the letter, indicates that Compton advised through 5 counsel, that the information requested, and I believe 6 that's referring to the previous paragraph, and that is 7 some of the information from the Jacques Whitford Report: 8 "Request it would not be provided in 9 advance of a scheduled public Hearing 10 on the applications. Instead, this 11 information would be presented as 12 evidence during the Hearing." 13 Can you confirm that that indeed was 14 Compton's position at that time? 15 MR. DEREK LONGFIELD: No, I can't, 16 because the letters are between Counsel. I can't. 17 MR. ALLAN MCLARTY: Can I just interrupt? 18 Sorry, Mr. Chairman, I apologize for -- for interrupting, 19 but as -- as Mr. Longfield has said, that this letter 20 happens to be one (1) of a series of letters that went 21 back and forth. Some of the comments were written for, 22 obviously, the -- from the perspective of the individuals 23 writing the letters. 24 And I guess one of the concerns I have 25 here is -- is that, if we're going to get into a
3575
1 discussion of what that letter means, it would probably 2 be helpful if Ms. Gosselin's concurrence, to perhaps put 3 the whole series in front of the Board so that -- that 4 there's a full explanation of the communications that 5 went back and forth. 6 I'm just concerned having one (1) isolated 7 document out of -- out of the -- the materials, is 8 leaving an impression that may not be entirely accurate. 9 MR. J.R. MCKEE: And thank you, Mr. 10 McLarty. And perhaps as we go along that -- that may 11 become necessary. I guess I'm less interested in -- in 12 the specifics of this letter than I am in trying to 13 explore what the state of negotiations were between 14 Compton and the City at that point in time that Mr. 15 Bissett and Mr. Brown have identified that they came to - 16 - came to a halt. 17 18 CONTINUED BY MR. J.R. MCKEE: 19 MR. J.R. MCKEE: And, it seems to be that 20 -- that at some stage there was requested information 21 going back and forth, you've indicated that quite apart 22 from the -- the terms of this letter, that did Compton at 23 some stage say, rather than provide you with that 24 information, it'll be at the Hearing, you can -- you can 25 deal with it at that time, or anything like that?
3576
1 MR. DEREK LONGFIELD: Compton, as in -- 2 as an employee of Compton, I suppose, I mean, it's quite 3 clear in this letter that Compton's Counsel has said 4 something to that effect, but again, I do know there is 5 more than one (1) letter in this train and there's 6 probably subsequent letters, Mr. McKee so. 7 MR. J.R. MCKEE: Well then, Mr. McLarty, 8 perhaps I will take you up, assuming that Ms. Gosselin 9 doesn't have any concerns with presenting us with that 10 exchange of letters. 11 I'm sort of in your hands, Ms. Gosselin 12 and Mr. McLarty, in terms of the parameters, the 13 timeframe and sort of thing, but... 14 MS. LEILA J. GOSSELIN: As far as letters 15 from the City, we have no objection to those being 16 produced at all. I don't know about the series of 17 correspondence based on that letter that Mr. McLarty is 18 actually referring to, but if he has copies, he's welcome 19 to produce them, sir. 20 MR. ALLAN MCLARTY: It strikes me that -- 21 that it would be useful to explain the context, and I 22 know you're asking the question -- Mr. McKee is asking 23 the question now about responses and what communications 24 took place in terms of -- between Compton and the City, 25 and indeed, some of those communications actually
3577
1 occurred as between our office and Ms. Gosselin at the 2 City, and to the extent that those are now relevant 3 material and become part of the discussion, then I guess 4 I'm just concerned that the Witnesses here may not have 5 all of those informations -- all of those documents and 6 information in front of them. 7 So, for them to fairly respond to those, 8 we'd probably need to put them on record. 9 MR. J.R. MCKEE: And, well then perhaps 10 we can ask, then, that Compton undertake to provide that 11 series of correspondence. 12 Now, I'm not in a position to ask Ms. 13 Gosselin to undertake anything at this point, but 14 perhaps, Mr. McLarty, if you and she could ensure that 15 what is being offered up is the complete set of 16 correspondence, then we can deal with that matter when 17 it's produced. 18 MR. ALLAN MCLARTY: I'll certainly 19 discuss that with Ms. Gosselin and we'll come up with 20 something that's satisfactory. 21 MS. LEILA J. GOSSELIN: And the City will 22 cooperate with that, sir. 23 THE CHAIRPERSON: Yes, we appreciate your 24 assistance. So we'll just amend the last undertaking 25 then, to be a package of correspondence?
3578
1 MR. J.R. MCKEE: Yes. The package of 2 correspondence as between Compton's Counsel and the City 3 of Calgary, as it pertains to the discussions concerning 4 the planning of the ERP. Thank you, Mr. McLarty. Thank 5 you, Ms. Gosselin. 6 7 CONTINUED BY MR. J.R. MCKEE: 8 MR. J.R. MCKEE: Mr. Bissett, I wonder if 9 you could have before you, Exhibit 002 -- the ERP, if you 10 would, sir. 11 THE CHAIRPERSON: That would be 64(f). 12 MR. J.R. MCKEE: Thank you, sir. 13 14 15 CONTINUED BY MR. J.R. MCKEE: 16 MR. J.R. MCKEE: I just have some general 17 questions on various elements of it, so forgive me if we 18 bounce around a little bit. 19 Section 2, sir, on pages 7 -- starting 20 with page 7 of Section 2, sir, there's a table there's 21 which is entitled, Time Required To Notify Occupants 22 Inside The Modified Reduced Emergency Planning Zone; you 23 see that there? 24 MR. RUSSELL BROWN: Yes, sir. 25 MR. J.R. MCKEE: And, similarly, on page
3579
1 11, we have a similar table. This time, Time Required To 2 Evacuate The Modified Reduced Emergency Planning Zone? 3 MR. RUSSELL BROWN: Yes, sir. 4 MR. J.R. MCKEE: Which, of course, is the 5 same title as before but this one deals with the higher 6 level. And, again, on page 14 a similar table with 7 similar times for evacuation; you see that, sir? 8 MR. RUSSELL BROWN: That's correct. 9 MR. J.R. MCKEE: I wonder if you could 10 describe how these various time frames were -- were 11 calculated and arrived at? 12 MR. RUSSELL BROWN: These are calculated 13 and arrived at through driving the roads, seeing what the 14 egress issues are, distance between residences, travel 15 time, you know, from within a rover area and also then 16 taking that data and looking at the number of residences 17 inside the emergency planning zone that may require 18 what's called evacuation assistance. The more people 19 that require evacuation assistance the more time it could 20 take. 21 Then, along with that, analysing the usage 22 of -- usage and -- or number and usage of public 23 facilities inside the emergency planning zone and then 24 looking at a general, for lack of a better word, 25 transient use of the emergency planning zone.
3580
1 It's a combination of bunch of different 2 inputs. 3 MR. J.R. MCKEE: And these inputs, sir, 4 were they derived from research and -- and actually 5 physically going over and driving through the various 6 areas we're talking about? 7 MR. RUSSELL BROWN: It was part of their 8 responsibility, our field people, to drive the roads and 9 identify access, egress issues. So, did we drive every 10 road and time it inside a rover area, the answer is, not 11 in this case. 12 MR. J.R. MCKEE: But your staff did, in 13 fact, make these calculations based on observations and 14 review of the roads and the topography, et cetera, of the 15 area we are concerned with in this Application? 16 MR. RUSSELL BROWN: Yes. They would 17 supply me with the initial numbers. They would just say 18 if there's any access or egress. Now, again, in this 19 case, we didn't drive the road and say it took seven 20 point five (7.5) minutes to drive the road. 21 MR. J.R. MCKEE: And in those 22 calculations was there any concern or any consideration 23 given to traffic volumes, times of day traffic volumes 24 that might be encountered on some of the roads in that 25 area?
3581
1 MR. RUSSELL BROWN: I would say yes. And 2 it was given mostly to the traffic volumes south of the 3 river. As has been indicated in -- in previous 4 testimony, there has been now some -- some issues 5 relating to Range Road 280 and traffic volumes; that was 6 not taken into account. 7 MR. J.R. MCKEE: Was there any 8 consideration given to the potential for reaction to an 9 incident or a problem outside of the modified zone? And 10 what I mean is, when considering roads, considering 11 issues of traffic, was there consideration for the fact 12 that there may be people attempting to leave the area 13 within the awareness zone or even beyond in light of a -- 14 of a problem? 15 Was that taken into consideration? 16 MR. RUSSELL BROWN: No, sir, those are 17 discussions, again, that we are hoping to hold with the 18 municipal authorities. 19 MR. J.R. MCKEE: Would you agree though, 20 that -- that would be a factor that might have an impact 21 on the ability of people within the modified zone, to get 22 out within a certain amount of time? 23 MR. RUSSELL BROWN: I'd have to look at 24 the map. 25
3582
1 (BRIEF PAUSE) 2 3 MR. RUSSELL BROWN: Not exiting the 4 modified reduced emergency planning zone on my initial 5 review. 6 MR. J.R. MCKEE: So, you don't feel that 7 -- and I'm guessing that -- that your analysis, which you 8 described, was only concerned with the -- the particular 9 features of the reduced zone; is that correct -- the four 10 (4) kilometres? 11 MR. RUSSELL BROWN: Our major analysis, 12 there would be a -- a subdivision in the Southeast of 3- 13 22-29, west of the 5th meridian. That is outside the 14 modified reduced emergency planning zone, and they would 15 have -- they have two (2) accesses or egresses from their 16 subdivision; one (1) directly to Dunbow Road. 17 And again, if that -- you know, if that 18 type of road wasn't connected to Dunbow Road, then 19 potentially those thirty (30) houses could -- could exit 20 48th Street, and -- and could impede, you know, could -- 21 I'm not going to say impede, but could add to the traffic 22 volume on that, but they do have straight access to 23 Dunbow Road. 24 So, we did look at situations like that, 25 and -- and with the beauty of the electronic map is you
3583
1 get to blow it right up and -- and have some good looks 2 at it. 3 But I can say what we did do was we -- we 4 would hold lunches in -- in Bissett's office, we would 5 put the map on the wall, and we would invite our entire 6 company to come in, and -- and buy pizza and say, Okay, 7 go at the map, tell us the issues, tell us what you see. 8 And that involved professional emergency responders, 9 administration staff. And we wanted -- and we looked at 10 all those types of things, these discussions from all 11 angles. 12 MR. J.R. MCKEE: Including the angle of 13 the possibility or the likelihood that parties outside 14 the four (4) kilometres, through the awareness zone, and 15 perhaps even into the City of Calgary, may decide that it 16 was a good idea to visit their cousin in the north part 17 of Calgary on that particular day, because of what is 18 going on. 19 Do you -- was that a scenario, was that 20 that part of this analysis? 21 MR. RUSSELL BROWN: That specific case 22 was not part of this analysis. Some of the things we did 23 look at, is we -- if you were to look at the east half of 24 16-21-28 west of the 4th meridian, there's the -- there's 25 the Highwood River proceeding right -- right through the
3584
1 Section 16 there. Can you see that? 2 Now, in looking at the population to the 3 south of the modified reduced emergency planning zone, 4 there was a concern that did the 306th Avenue, did they 5 have access south across that river? I mean, that's well 6 outside the awareness area, well out -- I'm going to 7 guess, thirteen (13) kilometres away from the well. 8 But I specifically remember talking to our 9 field people and saying, Okay, drive that road as far as 10 you have to, to ensure that -- that this large amount of 11 population has ways away from the emergency planning 12 zone. So, that those types of situations were taken into 13 account. 14 MR. DEREK LONGFIELD: And, Mr. McKee, any 15 traffic conditions that might exist, and we all have to 16 remember, are outside of the reduced emergency planning 17 zone. So, they are already evacuated from that zone. 18 And supposedly, or presumably, people 19 outside of that area would not be heading towards the 20 well, and they certainly can't get through the road 21 block. So, personally, I don't see that as being an 22 issue. 23 MR. J.R. MCKEE: And I -- and I 24 understand that's -- that's your position. I guess, you 25 know, what -- what my question is really aimed at, is
3585
1 that planning for the four (4) kilometre zone is one (1) 2 thing, but we can't -- and I think it's been repeated 3 over again, in this -- in this process, is that we have a 4 very unique situation. 5 And you don't have to go very far outside 6 the four (4) kilometre zone, before you encounter large 7 populated areas, and very, very important thoroughfares 8 and large thoroughfares, highways. 9 And that when you are planning and 10 suggesting times for evacuation, I'm asking you, is it -- 11 is it appropriate to take that into consideration? There 12 is going to be, I would suspect, a ripple effect, outside 13 of the four (4) kilometre zone, and perhaps you don't 14 agree with that. That may or may not have an impact on 15 your ability to evacuate that four (4) kilometre zone. 16 And I guess what I'm asking is, has that 17 been part of the planning? Has there been a 18 consideration for the fact that this is not a normal 19 scenario, that there are large amounts of people, 20 important thoroughfares, very close to this area, which 21 may in fact become very busy, and very, very much backed- 22 up? Does that likely pose you a problem in evacuating 23 your four (4) kilometre zone? 24 MR. RUSSELL BROWN: These factors were 25 taken into account. These factors were not directly --
3586
1 did not have a factor on these tables, the three (3) 2 tables that you mention in Section 2, and -- and I think 3 a classic example of that is -- is in Section 30, 31 and 4 32, Range 21 -- Township 21, Range 28, west of the 5th 5 meridian, there's -- there is a -- there is a large 6 scatter of -- of population in -- in density, in those 7 three (3) Townships, or -- yeah, sorry, three (3) 8 Sections. 9 However, those three (3) -- those three 10 (3) Sections have the ability to -- to proceed away from 11 the emergency planning zone, south on 306th Avenue, south 12 on 96th Street, then go south on 80th Street. They can 13 go east/west on 550 -- secondary highway 552. So, these 14 were not identified as having inputs to the tables but 15 they were all looked at. 16 MR. J.R. MCKEE: Okay. Is Highway 22X 17 one (1) of the main egress routes? 18 19 (BRIEF PAUSE) 20 21 MR. RUSSELL BROWN: It is a -- it is 22 inside the emergency planning zone, so it would be 23 blocked. They would have to -- the public would either 24 come up or down, and -- and the road blocks 3 and 6, 25 would stop the public from entering the emergency
3587
1 planning zone. 2 MR. J.R. MCKEE: But -- but people 3 leaving the planning zone would be using it though, would 4 they not? 5 MR. RUSSELL BROWN: Yes, they would. 6 MR. J.R. MCKEE: And Highway 22X doesn't 7 go very far before it becomes -- I believe it's still the 8 Marquis of Lorne Trail, which is a rather important 9 thoroughfare in the City of Calgary. Is there not the 10 possibility that that road will become blocked very 11 rapidly, if there was some sort of a problem? Has that 12 been considered -- 13 MR. RUSSELL BROWN: Yes, it has. And -- 14 and maybe I'll just turn to the appropriate section here. 15 16 (BRIEF PAUSE) 17 18 MR. RUSSELL BROWN: Maybe I would direct 19 you to Section 4, page 20. Section 4, page 20, the -- 20 the fourth bullet down. Sorry, the third bullet down. 21 Initially when this plan was written it recognized 22 Highway 22 and it's high volume of traffic. 23 And I think if you were to look at -- and 24 I hate to use -- if you were to look at conventional 25 emergency planning techniques, such as those based on
3588
1 something called the incident command system, they would 2 have somebody called a government liaison who would be 3 contacting the government agencies. 4 This plan does not use that method to 5 contact the Strathmore and Okotoks RCMP. It uses direct 6 contact from -- from the public safety coordinator who is 7 going to have his -- he is the man responsible for -- for 8 public evacuation and so the person in charge of public 9 evacuation, dealing with the Rovers, with an assistant is 10 also initially responsible for notifying the RCMP. 11 And this is early on at a declaration of a 12 Level 1 emergency to -- to see if -- to start to prepare 13 for this type of situation. 14 MR. J.R. MCKEE: And so, just to be 15 clear, you've referred me -- was it page 20 of Section 4. 16 MR. RUSSELL BROWN: Section 4, page 20, 17 third bullet down. 18 MR. J.R. MCKEE: Which says -- 19 MR. RUSSELL BROWN: "Advise the..." 20 MR. J.R. MCKEE: "...Strathmore and 21 Okotoks RCMP, the City of Calgary 22 Disaster Services, MD of Rocky View and 23 MD of Foothills about the Level 1 24 emergency." 25 MR. RUSSELL BROWN: That's right. And
3589
1 that means we want to start talking to the RCMP early 2 about -- about Highway 22 as this is a major thoroughfare 3 and what -- what is -- what needs to be done, what can be 4 done ahead of time, to start to try to minimize these 5 issues. 6 MR. J.R. MCKEE: All right. But to the 7 point that -- that I'm interested in, has that formed 8 part of the analysis which led to your estimated 9 evacuation times? Has considerations like that which are 10 outside of the 4 kilometre zone? 11 MR. DEREK LONGFIELD: Mr. McKee, maybe 12 I'm being obtuse but once they are out of the four (4) 13 kilometre zone they are evacuated and they are proceeding 14 to the evacuation centre. Mr. Brown could correct what 15 I'm calling it but they are evacuated. So that time that 16 we're giving in these tables, to my understanding, is the 17 time to evacuate the four (4) kilometre zone. 18 So I don't see a situation, as I was 19 saying, where you're going to have a line up of cars from 20 Marquis of Lorne Trail all the way to our EPZ. 21 MR. J.R. MCKEE: Well, and that may very 22 well be and I guess that's my question is, has that 23 scenario been considered? 24 MR. DEREK LONGFIELD: Maybe. If Mr. 25 Brown can answer it in that context I think that's --
3590
1 MR. RUSSELL BROWN: It's been considered. 2 But it has -- is not seen as needed at this time for this 3 emergency response plan. 4 MR. J.R. MCKEE: And so the times as 5 they're reflected in the ERP, as we have it today, are, 6 in your view, proper assessments of evacuation time 7 taking into consideration the unique aspects of both this 8 particular geographic location and its location in 9 proximity to the other centres of population? 10 MR. RUSSELL BROWN: As we see it today, 11 that is correct. 12 13 (BRIEF PAUSE) 14 15 MR. J.R. MCKEE: One of the concepts that 16 is routinely discussed in an emergency response plan is 17 the notion of sheltering. 18 I wonder, gentlemen, if you could describe 19 what role sheltering plays in this particular emergency 20 response plan as we have it today? 21 MR. RUSSELL BROWN: Okay. I guess 22 sheltering is throughout the plan, but the main role it 23 plays would be in Section 2, page 12, which is an 24 overview of the alert and levels of emergency and 25 Compton's appropriate response, public protection,
3591
1 recommendations for the public. 2 And sheltering plays a role in -- in a 3 level 3 emergency, which is there is or soon will be an 4 uncontrolled sour gas release, and the concept is to have 5 the public remain in a shelter, their residence, to -- to 6 remove them from the H2S, until the H2S is removed from 7 the atmosphere via ignition. 8 MR. J.R. MCKEE: And I see that 9 reference, sir, and the wind sheltering would likely be 10 resorted to, and I wonder, what is the plan to try and 11 educate or inform the public within the reduced zone, as 12 to the benefits of sheltering? 13 You would agree with me that it, from a 14 distance, it seems somewhat counter-intuitive to say, no, 15 don't run away, stay exactly where you are, as being the 16 safest thing to do, and perhaps I'm -- I'm reducing it 17 too much, but I think that the average person may find 18 that a bit surprising. 19 And I'm wondering what plans Compton has 20 in place to try and educate the population in that 21 regard? 22 MR. RUSSELL BROWN: Sheltering in our 23 framework for Emergency Response Plan, Training and 24 Information Program, and I've gotten the reference wrong 25 before and I'm going to get it wrong again; does anybody
3592
1 know the reference, please? Is it 39006? No. 2 3 (BRIEF PAUSE) 4 5 THE CHAIRPERSON: Is it the framework 6 you're looking for? 7 MR. RUSSELL BROWN: Yes, sir. 8 THE CHAIRPERSON: That's 39021F. 9 MR. RUSSELL BROWN: I'll get it right 10 next time, sorry. 11 Again, yes, sheltering is a -- is a 12 concept used in -- in the oil and gas industry, used in - 13 - in all types of public safety where, basically it's 14 asking people to temporarily stay indoors to remove them 15 from any potential exposure to something in the 16 atmosphere outside. 17 Again, the Public Information Program is - 18 - has been outlined to try and provide as much 19 information to the public about sheltering, and its use. 20 We do want, again, to also post sheltering and -- and its 21 use and how to do it, instructions for it, on the 22 Internet, it will be through Compton's web sites, so the 23 public can go access that at any time, so if they want to 24 educate themselves about it. 25 But I think Compton intends to inform the
3593
1 public and help inform the public about sheltering and I 2 think people always remember key phrases and key 3 statements, as opposed to boring lectures. 4 And what I always try to teach sheltering, 5 I always try to teach something that the people will try 6 and remember, and -- and Mr. McLarty will kill me for 7 using an analogy, but I can -- every time I use it, 8 people have always remembered it: If you're downtown on 9 a Friday night and having a good time at Cowboy's and you 10 come out of Cowboy's and you hear the screeching of 11 railway tracks and cars and the crashing of railway cars, 12 you know what to do, you get your butt back inside 13 Cowboy's and have another beer. 14 Because that will shelter you temporarily 15 from any potential hazard that could be on that train 16 travelling through downtown Calgary. 17 If you don't know what's in the 18 atmosphere, then you shelter. 19 20 CONTINUED BY MR. J.R. MCKEE: 21 MR. J.R. MCKEE: Yes, Mr. Brown, I -- the 22 mind boggles at the -- the nature of the sheltering that 23 one (1) could encounter at Cowboy's, however -- 24 MR. DEREK LONGFIELD: Mr. McKee, if I 25 could refer us all to -- I just want to get off that
3594
1 track, if I can refer us to the record, to the Emergency 2 Response Plan, I believe where we should be looking is 3 Section 9(b), page 17, which is the Information Sheet for 4 Sheltering, which I think we should get back on track 5 here -- 6 MR. J.R. MCKEE: Okay. 7 MR. DEREK LONGFIELD: -- and just say 8 this is currently what's in the -- in the manual, and -- 9 and Mr. Brown can, I'm sure, speak to that. 10 THE CHAIRPERSON: Could you give me the 11 page reference again, Mr. Longfield? 12 MR. DEREK LONGFIELD: Yeah, page 17, Mr. 13 Chairman. 14 THE CHAIRPERSON: Seventeen (17). 15 MR. DEREK LONGFIELD: 9(b), 17, and at 16 the top it says, B-5, Notification Text. 17 MR. RICHARD BISSETT: I might add as 18 well, that only the EUB and Compton has those sections, 19 nobody else -- 20 MR. DEREK LONGFIELD: Oh, okay. 21 MR. RICHARD BISSETT: -- in -- in the 22 Hearing Room has the confidential resident sections, so 23 A, B and C, you all don't have. 24 THE CHAIRPERSON: Okay, that explains, 25 because it's just in my version that I have
3595
1 electronically, only goes to page 5. 2 MR. DEREK LONGFIELD: Well, I guess by 3 way of explanation then, it is a notification text that's 4 used to advise people about sheltering, and just from my 5 standpoint, as not an expert in this, there is the 6 question, do you understand these instructions? 7 There are some detailed instructions as to 8 how to shelter, and then a question, do you understand? 9 So, this kind of interactive thing, which I'm hopeful 10 is -- 11 12 CONTINUED BY MR. J.R. MCKEE: 13 MR. J.R. MCKEE: And I appreciate that, 14 Mr. Longfield, both for the information and for the -- 15 the stern return to sobriety. 16 Perhaps you could tell us when this -- 17 this notification text would be -- would be used? 18 MR. DEREK LONGFIELD: Can I defer to Mr. 19 Brown? 20 MR. J.R. MCKEE: Certainly. 21 MR. RUSSELL BROWN: The declaration of a 22 level 3. 23 MR. J.R. MCKEE: And how would it be -- 24 how would it be circulated? 25 MR. RUSSELL BROWN: It would be
3596
1 circulated via an automated telephone, computerized 2 message system, this would not be the message used. 3 Section B, page 4, is the computer message system that 4 would be used, and basically the computer would be 5 instructed to send the sheltering message, and it would 6 send a message out to all households inside the Emergency 7 Planning Zone, and I have to emphasize, who have 8 telephones. 9 MR. J.R. MCKEE: And prior to that 10 though, do I take it then, it is Compton's hope and 11 intention, that the residents who received this message, 12 would have some idea as to why sheltering is being 13 requested and -- and whether it is a safe idea or not. 14 I appreciate that you -- you know, the 15 notification would be there, but I'm wondering if this 16 would be the first time anybody would have been -- been 17 told of this concept, and I -- I have to express some 18 skepticism, that a disembodied computer voice telling you 19 to hide in your basement, isn't necessarily going to give 20 people much comfort. 21 So, I'm wondering what they would know 22 beforehand? 23 MR. RICHARD BISSETT: Yes, sir. Mr. 24 McKee, I will refer you to the Mazzepa, and I'm not sure 25 what exhibit that is, and that's the Emergency Response
3597
1 Plan for the 002-03(g). And it's Information Request 2 CCC-3. 3 That -- that contains the Emergency 4 Response Plan that's used by the Mazzepa Processing 5 Partnership, and just out of curiosity the other night, 6 we sat down and counted the number of residents that are 7 listed in this plan, and the number of residents that are 8 listed in the site specific plan for the drilling of the 9 six (6) wells. 10 And it turns out, I believe there's two 11 hundred and twenty-five (225) out of two hundred and 12 thirty-one (231) are in the Mazzepa Processing 13 Partnership. 14 This -- this plan has been in affect for 15 many years, and -- and there is a sheltering component 16 associated with that plan, so the residents that have 17 been -- that's -- that's lived in this area for years, 18 except for people that may have moved in, in the last few 19 months, have been exposed to sheltering as a means of 20 protecting public safety. 21 So -- so, hopefully, that will lend in 22 creating public familiarity with sheltering whenever it - 23 - whenever the term is applied or announced over the 24 telephone. 25 And also, I might add, that in support of
3598
1 the automated system, there are live telephoners that 2 will be addressing any issues that the -- that may arise 3 as a result of sheltering. 4 MR. J.R. MCKEE: So, to the extent that - 5 - that two hundred and twenty-five (225) of the two 6 hundred and thirty-one (231) are in both -- are covered 7 by both zones, is it Compton's hope then that information 8 or education about the benefits of sheltering has been 9 taken care of as a result of them being subject to the 10 Mazeppa ERP; is that what you're suggesting? 11 MR. RUSSELL BROWN: That's just one of 12 the components. The other component is the public 13 information program that Compton wants to hold ahead of 14 time. I'm sure when we're out gathering -- updating the 15 emergency response plan again the -- there will be a 16 handout that will be left with the public. 17 The public will also be gone over the 18 handout, if they so choose, with -- with a Bissett 19 representative on public safety. They can discuss 20 sheltering at that time. Get further information on 21 sheltering at that time. And also, as is -- is required 22 now, is those specific sheltering messages will accompany 23 that handout. 24 MR. J.R. MCKEE: Gentlemen, if there is 25 an incident and the various plans have to come into force
3599
1 I'm wondering where the resources are going to be drawn 2 from to man the roadblocks, the Rovers and the various 3 other manpower that is needed to execute the plan? 4 Are you able to help me with that? 5 6 (BRIEF PAUSE) 7 8 MR. RUSSELL BROWN: Yes. First of all, 9 we identified those resources in the ERP and then, on a 10 daily basis, the -- if you were to turn to Section 8, 11 Section 8 is a -- is a raft of a -- it's not page 12 numbered because they're individual forms that go -- will 13 go into individual books for various responders. 14 But there's an emergency response team 15 checklist in there. And it will be -- it will be the 16 public safety coordinator's job to -- to -- to constantly 17 communicate to the company that is supplying those 18 resources and documenting that those resources are 19 available. So there is steps 1 and 2. 20 Step 3 is -- is we have and we have met 21 with the company that -- that Compton has pre-identified, 22 the safety company that has been pre-identified to supply 23 those resources. We have held meetings with that 24 company. 25 They understand that this is going to
3600
1 happen. They understand that they have to have these 2 resources available and their resources, as it stands, 3 they're -- they're going to be dispatching out of 4 Airdrie. 5 MR. J.R. MCKEE: All right. So then 6 there -- there is going to be a third party safety 7 provider who will provide the resources necessary; is 8 that correct? 9 MR. RUSSELL BROWN: Yes, sir. 10 MR. J.R. MCKEE: And to this state, the 11 ERP as we have it today, has that company now -- the 12 appropriate resources that it is able to dedicate for the 13 various periods of time that we might be talking about in 14 this -- in this application? 15 MR. RUSSELL BROWN: We have discussed 16 that and they have committed to it, yes. 17 MR. J.R. MCKEE: What sort of response 18 time, coming out of Airdrie, would this company expect to 19 -- to encounter, in getting its resources to this area? 20 MR. RUSSELL BROWN: I would not want to 21 speculate a guess at the moment. It'd be just -- it 22 would be speculation as to how long that would take, but 23 I -- I do want to add that -- that the resources are 24 brought out in advance of them being required. 25 So -- so the road blocks are not -- the --
3601
1 the road -- the road block resources are not mobilized on 2 a level 2 emergency, when they are required. They are 3 mobilized locally to the remote command 4 post/communication centre, on a level 1 emergency, where 5 they are put on standby locally, right -- right next to 6 the modified Reduced Emergency Planning Zone. 7 MR. J.R. MCKEE: So, are there any 8 resources that this company will be supplying, that would 9 be only drawn upon once a -- an emergency had happened, 10 such that response time becomes an issue, or are they all 11 going to be in place in advance? 12 MR. RUSSELL BROWN: There will be certain 13 responders in -- in place in advance, and certain 14 responders who will be called out, depending upon the 15 level of emergency. 16 MR. J.R. MCKEE: So there would be a 17 potential for some of these resources to have to be 18 dispatched. 19 Are they physically going to be dispatched 20 from Airdrie, is that where they all are at, or are they 21 going to be coming from various places, or do you know? 22 MR. RUSSELL BROWN: We're not that deep 23 into the discussions yet. 24 MR. J.R. MCKEE: All right. As someone 25 who lives just south of Airdrie, and has sat on the
3602
1 Deerfoot Trail for more than I care to remember, you -- 2 you'd agree with me that -- that although from a 3 kilometre point of view, it isn't very far, the response 4 time from Airdrie, might be an issue, depending on the 5 time of day, et cetera? 6 MR. RUSSELL BROWN: That's why the 7 resources are brought out before they're needed. 8 MR. J.R. MCKEE: All right. And it would 9 be Compton's intention to ensure that this service 10 provider has the appropriate resources at its disposal, 11 for the dedicated times that are required to properly 12 execute this ERP, is that right? 13 MR. RUSSELL BROWN: Absolutely, that has 14 been done in the past. 15 MR. J.R. MCKEE: Now, we talked a little 16 while ago about Highway 22 and you referred me to a 17 section of the ERP, which talked about liaison with the 18 Strathmore RCMP, and I gather they are the ones we would 19 look to, to deal with traffic issues on Highway 22X; did 20 I understand that correctly? 21 22 (BRIEF PAUSE) 23 24 MR. RUSSELL BROWN: Strathmore RCMP. 25 MR. J.R. MCKEE: Has there been any
3603
1 analysis of their response time, or their manpower 2 availability to perform these tasks, has that -- has 3 those discussions taken place? 4 MR. RICHARD BISSETT: We -- we have 5 talked to the RCMP, but not in terms of how long would it 6 take to respond down there. They did tell us that it 7 would either -- it may be Strathmore's Detachment, but in 8 all likelihood, it'd be the Okotoks' Detachment that 9 would supply the units to come up to the area. 10 MR. J.R. MCKEE: But no timing has been 11 done to this point in time? 12 MR. RICHARD BISSETT: No, sir, not at 13 all. 14 MR. J.R. MCKEE: I wonder if you could 15 look at page 15, Section 1 of the ERP? 16 MR. RUSSELL BROWN: That's the one (1) 17 we're holding, sir. 18 MR. J.R. MCKEE: Right. And it does talk 19 about in the note there, Highway 22X runs through the 20 modified Reduced Emergency Planning Zone, Compton must be 21 prepared to work with Alberta Transportation, Volker 22 Stevin Contracting, and as we discussed, the Strathmore 23 RCMP to close the highway. 24 What point are those discussions or 25 preparations at, at this point in time?
3604
1 (BRIEF PAUSE) 2 3 MR. RICHARD BISSETT: We have -- we have 4 met with them, and that's -- that's about all, or 5 discussed it with them but we have no worked out any -- 6 or formulated any firm plans at this time. 7 MR. J.R. MCKEE: So, apart from 8 identifying those as the parties you would have to work 9 with on that, there hasn't been any planning or anything 10 further to date? 11 MR. RICHARD BISSETT: No, sir. That's 12 correct. 13 MR. J.R. MCKEE: Has there been any 14 discussion to date about the possibility of alternate 15 routes than the one's you've identified in the ERP or 16 detours? 17 MR. RICHARD BISSETT: No, sir. Not at 18 all. You know, as a matter of fact, when we started that 19 -- this, Deerfoot Trail wasn't even open south of 22X. 20 MR. J.R. MCKEE: Now, to my understanding 21 that Compton is planning and is prepared to do a full 22 exercise of the emergency response plan prior to 23 commencing any drilling; is that correct? 24 MR. RUSSELL BROWN: That would be the 25 culmination of the training. Yes, that is correct.
3605
1 MR. J.R. MCKEE: Approximately, when 2 would you project that exercise occurring vis-a-vis the 3 commencement of drilling? 4 5 (BRIEF PAUSE) 6 7 MR. RUSSELL BROWN: I guess, it's, sort 8 of, a two (2) part answer. I guess I -- I would foresee 9 that there is going to be the requirement for a full 10 emergency response plan exercise that is going to be 11 reviewed, watched and audited by the various Government 12 agencies. And I am sure that is going to take place 13 before drilling operations occur. 14 Likewise, I think there would be another 15 full scale exercise just prior to entering a sour zone 16 within ninety-six (96) hours to make sure that 17 everybody's roles, responsibilities are fresh in their 18 mind. 19 So, I would probably foresee it a two (2) 20 part -- two (2) full scale exercises. 21 MR. J.R. MCKEE: Okay. So when I -- 22 MR. RICHARD BISSETT: May -- maybe even 23 three (3) if the first one didn't turn out satisfactory. 24 MR. J.R. MCKEE: Thank you, Mr. Bissett. 25 I was going to ask whether or not there was going to be
3606
1 any sort of criteria applied as to whether it was a 2 satisfactory exercise or not. 3 And so my -- it would be fair to say 4 you'll do it as many times as it takes to get it right 5 and then proceed? 6 MR. DEREK LONGFIELD: That's intrinsic in 7 the plan. 8 MR. J.R. MCKEE: Thank you. Mr. Brown, 9 you said you foresaw that happening; is that not 10 Compton's plan as we speak? Is that still something 11 that's being discussed and what I'm talking about is the 12 two (2) -- the two (2) part element? 13 MR. RUSSELL BROWN: It -- we've discussed 14 it. My concern, when I was talking back and forth, is 15 whether it's on the record somewhere and I'm not sure 16 whether it is or not, Mr. McKee. That's certainly been 17 our discussions. 18 MR. J.R. MCKEE: So, is that Compton's 19 plan currently that it is prepared to conduct the type of 20 exercises that Mr. Brown has described? 21 MR. DEREK LONGFIELD: That's been -- 22 yeah, that's what we're planning. Yes. 23 MR. J.R. MCKEE: Thank you. I wonder if 24 we could have a look, gentlemen, at what was marked as 25 Exhibit 093-21(f).
3607
1 (BRIEF PAUSE) 2 3 MR. RUSSELL BROWN: Yes, sir. 4 MR. J.R. MCKEE: And I think, Mr. Brown, 5 this was the document that you had produced for, I 6 believe it was Mr. Fitch, and I may be wrong? 7 MR. RUSSELL BROWN: That's correct. 8 MR. J.R. MCKEE: And it's a draft 9 entitled, Framework for Emergency Response, Planning, 10 Training and Information Program. Do you have that, sir? 11 MR. RUSSELL BROWN: Yes, I do. 12 MR. J.R. MCKEE: Okay. And, sir, this -- 13 this particular program, do you have any sense of the 14 time it will take to properly implement and execute this 15 program as -- as we see it here? 16 MR. RUSSELL BROWN: I may be wrong, but I 17 do believe Mr. Bissett said six (6) months. 18 MR. J.R. MCKEE: Okay. Now, that -- that 19 brings me to -- Mr. Bissett, maybe this is as good a time 20 as any. 21 I had -- and -- and again, I might be 22 wrong but I -- I thought I had heard you say, Mr. 23 Bissett, that you estimated that it would take something 24 in the order of six (6) months to bring the ERP up to the 25 point where it had all the necessary elements, and you
3608
1 would be looking to the Board to approve it. Did I 2 misunderstand that? 3 MR. RICHARD BISSETT: Let me just take a 4 quick look here -- 5 MR. J.R. MCKEE: Certainly. 6 MR. RICHARD BISSETT: -- and make sure 7 that -- that that's what I did say. 8 9 (BRIEF PAUSE) 10 11 MR. RICHARD BISSETT: Mr. McKee, what we 12 were talking about there, was -- was to work with the 13 various Government agencies. Once approval was granted 14 to work with the various Government agencies, to finalize 15 this training program, that -- that we have in front of 16 us. There are two (2) components to that and that is 17 informing and updating the public. 18 The other component is to carry out the 19 actual training program, to analyse the results of these 20 programs, update and send the resultant ERP to the 21 various Government agencies, for their review, revise as 22 -- I'm sorry, send to the various Government agencies for 23 their review, revise as necessary, and then submit the 24 EUB -- or submit the revised ERP to the EUB, for their 25 approval.
3609
1 MR. J.R. MCKEE: And -- and so the 2 timeframe then from -- and I think you were basing this 3 as should these licenses be granted, was six (6) months 4 from that time to the time you would be able to present 5 the ERP to the Board for a review; is that -- is that 6 correct? 7 MR. RICHARD BISSETT: That's correct, 8 exactly. 9 MR. J.R. MCKEE: And within that six (6) 10 month period, you would see the completion and execution 11 of this framework, this training framework? 12 MR. RUSSELL BROWN: The majority of it, 13 that's correct, yes. 14 MR. J.R. MCKEE: Okay. And you would 15 anticipate hammering out whatever agreements are 16 necessary with the -- the various Government agencies and 17 departments, City of Calgary, et cetera? 18 MR. RUSSELL BROWN: I think past has 19 shown that it would not -- hopefully will not be 20 hammering it out, it will be resolved. 21 MR. J.R. MCKEE: Poor choice of words; 22 resolution. 23 MR. RUSSELL BROWN: Thank you. 24 MR. J.R. MCKEE: Consensus will be 25 obtained.
3610
1 MR. RUSSELL BROWN: Thank you. 2 MR. J.R. MCKEE: And there will be, Mr. 3 Bissett, again, within that six (6) months, a re- 4 examination of the areas, to ensure that the most up-to- 5 date information is in the ERP, with respect to 6 residents, businesses, and that sort of thing? 7 MR. RICHARD BISSETT: Yes, sir, that's 8 correct. The -- the confidential resident information 9 and industrial operators entities that are within that 10 emergency planning zone, would be updated and the ERP 11 revised accordingly. 12 MR. J.R. MCKEE: Okay. Now, Mr. Bissett, 13 I think that this goes without saying, and but of course 14 in this business, nothing is ever going -- goes without 15 saying, we'll -- we'll say it, the ERP as we see it today 16 is incomplete, there's many things which need to be done, 17 and we've been discussing most of those this morning; is 18 that -- is that fair? 19 MR. RICHARD BISSETT: Yeah, maybe -- 20 maybe incomplete might be a little harsh, but -- but it 21 needs -- it needs updating, to bring it up to what 22 exactly exists out in the Emergency Planning Zone right 23 now. 24 MR. J.R. MCKEE: Okay. 25 MR. RICHARD BISSETT: So, you know, if
3611
1 incomplete fits fine, or -- 2 MR. J.R. MCKEE: Whatever. 3 MR. RICHARD BISSETT: -- it remains to be 4 updated. 5 MR. J.R. MCKEE: I wonder if you -- you'd 6 be able to, and maybe you could do this perhaps by an 7 undertaking, is to identify for us the elements of the 8 ERP, which need, to use your word, updating, from the 9 version we see today, to what would be presented to the 10 Board for approval in that six (6) month time period. 11 Would you -- would you be able to do that, 12 and if you wish to do it by undertaking, that would be 13 fine. 14 15 (BRIEF PAUSE) 16 17 MR. RICHARD BISSETT: If I could, Mr. 18 McKee, perhaps I'll get away from homework. I think 19 everything will have to be updated with the exception of 20 the -- of the communication flow chart in Section 3.0. 21 I believe all of those sections will 22 require updating. 23 MR. J.R. MCKEE: So there's a significant 24 amount of work, and you don't see any other than what 25 you've told me, you don't see any part of the ERP that
3612
1 won't require updating at this -- from this stage? 2 MR. RICHARD BISSETT: I -- I would 3 venture to say that once we get done with this process, 4 and an approval is granted, why the -- the whole plan is 5 going to -- to be revised, I'm positive. 6 MR. J.R. MCKEE: Now, Mr. Brown, we were 7 looking briefly at the -- the framework, Exhibit 039- 8 21(f). I wonder if you could look at page 2. And I -- 9 and I appreciate this is a draft document, and -- and 10 however, I'm -- I'm looking at the testing section. 11 MR. RUSSELL BROWN: Yes, sir. 12 MR. J.R. MCKEE: And the second paragraph 13 states: 14 "Compton's program will also include a 15 series of exercises. Compton's 16 committed to holding several 17 communication, table top and full scale 18 exercises involving Government 19 emergency responders, prior to 20 beginning sour operations --" 21 MR. RUSSELL BROWN: Yes, sir. 22 MR. J.R. MCKEE: "-- at the first well." 23 One (1) of the difficulties when we have a 24 process like this, is we've talked to Mr. Cover about 25 various exercises and drills, which are described in the
3613
1 drilling program. And we've talked this morning about 2 the ERP exercises, we talked with respect to ignition 3 drills and the various other things this morning, when 4 talking about the decision to -- to light up the well. 5 Is this something in addition to all of 6 that, or is this meant to encompass the various things 7 that I've just described? 8 MR. RUSSELL BROWN: In addition to. 9 MR. J.R. MCKEE: All right. And so when 10 would you envisage holding these exercises that you're 11 describing here? 12 MR. RUSSELL BROWN: It'll be in the early 13 stages of that six (6) month process that Mr. Bissett 14 talked about. 15 MR. J.R. MCKEE: And would this be -- 16 would these exercises or these -- these exercises as 17 described to you, would they simply be held prior to the 18 commencement of the first well, or was it the plan to 19 hold them prior to the commencement of each well 20 thereafter? 21 MR. RUSSELL BROWN: I'm not sure I've 22 thought about that at the moment, sir. That I haven't -- 23 or Bissett has not considered that yet. 24 MR. J.R. MCKEE: So that's a possibility 25 that will be looked at as -- is that a possible, possible
3614
1 approach to do these prior to each well, or is that just 2 not something you've ever considered, because it's -- you 3 don't consider it appropriate, or is it just something 4 you've never considered. 5 MR. RUSSELL BROWN: Well, I think that, 6 you know, there's -- to -- to go out and hold a full 7 scale exercise, call a date for a whole full scale 8 exercise and expect it to -- to come off without a hitch 9 with three (3) local authorities and -- and two (2) RCMP 10 Detachments, is -- is a pipe dream, it's not going to 11 happen. I mean, how would -- how do those -- how do 12 those different authorities and RCMP Detachments even 13 talk to each other over a radio. 14 That's -- that's just you know, that's not 15 going to happen by -- by flipping a light switch. 16 So I think we need to start to sit down 17 and --and discuss with those agencies, what are our 18 communication requirements? You know, history has shown 19 that -- that emergency response plans fail for two (2) 20 reasons: inability to communicate and inability to 21 understand who's in charge. 22 So, how are -- is Compton and the various 23 Government agencies going to communicate? Should we sit 24 down and talk about it around a table? 25 Then we need to understand what equipment
3615
1 is going to be required. Then we need to dry-run that 2 equipment in a -- in a table-tops setting. And that's 3 just one aspect about -- for running the communications 4 up in preparation for this full-scale exercise. 5 MR. DEREK LONGFIELD: Mr. McKee, if I can 6 add, I think you were asking about for each well, would 7 you be doing it? And a lot would depend on the 8 sequencing, case be, I would suspect that we would 9 propose to the Board that we're going into a sour 10 operations period that will be basically continuous and 11 we would like this exercise to reflect that period of 12 time. 13 And that I think there would be a 14 communication with the Board back and forth if it were, 15 say, Case 'C' or Case 'A', but I think it has to deal 16 with the operation and how continuous that operation is 17 and if we were to have a six-month period in between, as 18 I said earlier, I'm absolutely certain we'd be doing 19 another set, so, if that helps. 20 MR. RICHARD BISSETT: I think also, Mr. 21 McKee, if I could poke my nose in here as well, I think a 22 lot of it depends upon -- upon the performance of the 23 exercise that you just did, if -- if everything went well 24 and we're happy and satisfied that -- that further 25 training right now would be -- would not mat -- add much
3616
1 value to the process, probably not. 2 But if we stubbed our toe, fumbled, 3 dropped the ball, then -- then most definitely, another 4 one would -- would have to be held. 5 So I think, to some degree, evaluation of 6 the previous exercise is going to dictate when the next 7 one is perhaps necessary, changing personnel, issues like 8 that. 9 MR. J.R. MCKEE: And who will make that 10 decision, if further exercises are necessary or, you 11 know, the result of any of those things that you've just 12 described? 13 MR. RICHARD BISSETT: I would say that 14 that would be a joint decision, and now Mr. Longfield may 15 want to step in, but that would be a joint decision 16 between -- between the stakeholders, the -- the local 17 authorities, Calgary Health Region and EUB. 18 MR. DEREK LONGFIELD: The ERP and 19 associated exercises, ultimately have to be acceptable to 20 the EUB, so, but there is that, obviously that 21 coordination before it gets to that point, Mr. McKee. 22 MR. J.R. MCKEE: Mr. Brown, I wonder if 23 you could now turn to the record keeping section of the 24 framework, and it says: 25 "Compton will keep records of all
3617
1 training sessions and make these 2 records reasonably available for review 3 by various stakeholder groups". 4 What sort of criteria would be used to 5 determine what amounts to reasonably available? I wonder 6 if you could tell me what you mean by that? 7 MR. RUSSELL BROWN: I would just say that 8 the records will be open for review by the -- by the 9 various Government agencies, and to show that it's been 10 done, and then discussions would have to take place 11 between those and the Government agencies, as it -- if 12 some community leaders want to look at the training 13 records, then let's bring it down and have a look at it 14 with them. 15 MR. J.R. MCKEE: Mr. Longfield, maybe 16 you...I heard you inhale, and that...? 17 MR. DEREK LONGFIELD: I'm doing lots of 18 inhaling this morning, but I'm trying to get enough 19 oxygen in. 20 The only concern I have with all this 21 records and whenever I hear records, and that's probably 22 why I inhaled, where there is obviously, we referred to 23 previously, there is a whole section of this that a 24 considerable number of people in this room don't have, 25 because of the Privacy Act.
3618
1 So, that could be the meaning of the word 2 reasonably, it certainly would be my meaning of the word 3 reasonably. 4 MR. J.R. MCKEE: All right. Mr. Brown, 5 if you could turn to page 10 and under the heading of 6 Information Objectives, we see in the second paragraph: 7 "Sixty (60) days prior to sour 8 operations Compton will host an open 9 house to allow the public a chance to 10 obtain information about public 11 protection measures." 12 Is there any magic or any -- any thoughts 13 to the sixty (60) days prior to sour operations? Why 14 that was chosen? 15 MR. RUSSELL BROWN: No magic number to 16 sixty (60) only enough time to ensure that, you know, the 17 public has a change to learn about it and, if need be, 18 get further information on it. You know, a week or two 19 (2) just wouldn't be appropriate. 20 So it's enough of a lead time so that 21 allowing public to -- to get further information, 22 education as needed. 23 MR. J.R. MCKEE: What sort of 24 notification is considered appropriate for this meeting? 25 MR. RUSSELL BROWN: I'm going to defer
3619
1 that question to Mr. Longfield and I think he was talking 2 to Mr. Bissett so if I could get you to re-ask the 3 question. 4 MR. DEREK LONGFIELD: First for 5 everything. Sorry, Mr. McKee. 6 MR. J.R. MCKEE: Pardon me? 7 MR. DEREK LONGFIELD: It's a first for 8 everything. I think that might have been the first one 9 that I really missed. So I apologize. 10 MR. J.R. MCKEE: Not a problem. I'm just 11 curious about how notification for this open house is 12 going to be handled? 13 MR. DEREK LONGFIELD: Well, it's going to 14 be handled carefully, there's no question about that. 15 And if we were at that stage, we're going to seek 16 information or -- advice from many directions. 17 And we haven't got it finalized yet but 18 it's going to be full and complete notification and a lot 19 of arguments about whether two (2) weeks is enough, one 20 (1) week is enough, how we do it. 21 We are going to be listening and designing 22 the notification system so that everyone who is 23 interested in being notified or might be interested in 24 being notified, is notified and has the opportunity. 25 And, again, our good media has been pretty
3620
1 good in being on this story over the last little while. 2 I expect that that part of it certainly won't stop 3 either. And that's a part of the reason for the 30 days' 4 prior open house. 5 There's some learnings there and possibly 6 some different notifications and that kind of thing that 7 could come out of it too. 8 MR. J.R. MCKEE: Fair to say that you'll 9 draw upon your experience from your previous open houses 10 and notification and the attendance at those open houses? 11 MR. DEREK LONGFIELD: Absolutely. 12 MR. J.R. MCKEE: I want to return to ID 13 2001-5 and I'd like to talk a bit about the whole notion 14 of the awareness zone. 15 And I'm looking in Section 3 of ID 2001-5 16 which is entitled "use of reduced EPZs" and I noted in 17 the second paragraph there that the ID states it was also 18 concerned, and it's referring back to the advisory 19 committee: 20 "It was also concerned that ERPs with 21 reduced EPZs do not clearly define who 22 is responsible for public safety beyond 23 the reduced EPZ." 24 You see that there, Mr. Longfield? 25 MR. DEREK LONGFIELD: No, I'm still
3621
1 finding it. 2 MR. J.R. MCKEE: Sorry. Page 3 of the 3 ID. 4 MR. DEREK LONGFIELD: My problem is I've 5 gotten mine off the EUB's site so my page numbering is 6 different. 7 MR. J.R. MCKEE: All right. Just let's 8 got to just Section 3 then. 9 MR. DEREK LONGFIELD: Section 3, yeah, 10 I'm there now and I'm on my page 2 but that's fine. 11 MR. J.R. MCKEE: Fair enough. And the 12 second full paragraph "it was also concerned...". And 13 I'll just -- I'll just read it again "it was also ..." 14 MR. DEREK LONGFIELD: Yes. 15 MR. J.R. MCKEE: So, clearly the -- the 16 notion of who are responsible for public safety outside 17 the emergency planning zone is a reasonably critical 18 matter -- matter in the Board's consideration of an 19 Application for the reduced EPZ; does Compton appreciate 20 that? 21 MR. DEREK LONGFIELD: Yes. 22 MR. J.R. MCKEE: And looking again at the 23 ID 3.6 -- Section 3.6 the evacuation section, and the 24 second paragraph: 25 "If there is a situation that requires
3622
1 immediate ignition as outlined above, 2 the following evacuation procedures 3 must be implemented in addition to 4 those above." 5 And the first bullet states: 6 "Notification to all individuals beyond 7 the reduced EPZ to a distance twice the 8 reduced EPZ or the distance to the 9 calculated zone whichever is less so 10 that action may be taken voluntarily, 11 such as leaving the area, until the 12 release is controlled to avoid any 13 exposure to SO2." 14 You see that there? 15 MR. DEREK LONGFIELD: Yes. 16 MR. J.R. MCKEE: And then it talks about 17 the mandatory evacuation for SO2 exposure in the second 18 paragraph; do -- do you see that? 19 MR. DEREK LONGFIELD: Hmm hmm. 20 MR. J.R. MCKEE: All right. So, clearly 21 then where there is ignition there is a requirement under 22 this particular directive to notify individuals within 23 this awareness zone. 24 And we -- I know there's been discussion 25 previously about this but I'm -- I'm curious at this
3623
1 point in time and I'm hoping to clarify at this point in 2 time, does Compton see it as its responsibility to notify 3 these individuals or is this the responsibility of 4 another body? 5 MR. RICHARD BISSETT: May we have a 6 moment, Mr. McKee? 7 MR. J.R. MCKEE: Certainly, Mr. Bissett. 8 9 (BRIEF PAUSE) 10 11 MR. DEREK LONGFIELD: You can imagine, 12 Mr. McKee, we've had considerable discussions in this 13 area and we are back to one (1) of those concerns with 14 timing and applying under 2001-5. And, obviously, the 15 ERP has been resubmitted to be compliant with Guide 71, 16 the new June 2003 edition of Guide 71 and so based in, I 17 think, it's Section 4.3.2 of that Guide it's pretty clear 18 that broadcast media, radio and television: 19 "will be used to notify residents 20 outside the EPZ in the event that 21 immediate evacuation of the area must 22 take place. Evacuation of the area 23 outside the EPZ should be a coordinated 24 response through a licensee's ERP and 25 the municipality plan."
3624
1 Which I believe is -- the acronym for that 2 is I think the MEP. Yeah. Okay. 3 So, we -- we're in a situation here where 4 they're using broadcast media. And to my understanding, 5 and subject to correction by anyone who wants to, only a 6 local authority can declare a state of local emergency by 7 Sections 18 of the Disaster Services Act where part of 8 that would be this taking over the airwaves and they be 9 using I think some sort of plan, Mr. Brown, the 10 Alberta... 11 MR. RUSSELL BROWN: Public Warning 12 System. 13 MR. DEREK LONGFIELD: Right. So that's 14 our understanding of it, as it sits right now. And 15 there's, you know, clearly coordinate effort and that 16 kind of thing but the notification does get a little 17 complex when we start looking to Guide 71. 18 MR. J.R. MCKEE: So, then from your 19 interpretation of that section which seems to require 20 media and your understanding that only a Government 21 institution can break on, if you will, or use the media 22 for that sort of a response, that leads you to conclude 23 that it isn't Compton's sole responsibility for the 24 notification of the awareness zone. 25 Do I understand that correctly?
3625
1 MR. DEREK LONGFIELD: My understanding 2 is, that it's -- they only have the authority, also they 3 have the obligation under that Alberta Public Warning 4 System to do that. So that's where we sit at this time. 5 MR. J.R. MCKEE: All right. And so then 6 would it be fair to say that any sort of plan or how the 7 notification would actually be sent or the form of that 8 notification is all -- are all matters which are going to 9 have to be dealt with as part of the ongoing discussions 10 with the various levels of Government and the 11 Municipalities, is that correct? 12 MR. DEREK LONGFIELD: Without question 13 that certainly was our intent, and -- and will -- is our 14 intent, I should say, I didn't want to put a past tense 15 on that. 16 17 (BRIEF PAUSE) 18 19 MR. J.R. MCKEE: And so if I could direct 20 you to page 17, Section 1 of the ERP. 21 22 (BRIEF PAUSE) 23 24 MR. J.R. MCKEE: And page 17 of Section 25 1, the first bullet. And this is again, talking about in
3626
1 a situation that requires immediate ignition: 2 "Compton will implement the following 3 procedures. Address --" 4 I'm sorry: 5 "-- advise the City of Calgary Disaster 6 Services, MD of Rocky View and MD of 7 Foothills about the well control 8 situation, and request that individuals 9 inside the awareness zone be notified 10 about the SO2 hazard." 11 Do you see that there? 12 MR. DEREK LONGFIELD: Yes. 13 MR. J.R. MCKEE: So then do I take it 14 then that that -- that is another area of the -- of the 15 ERP that may be subject to some change or revision based 16 on what we've just been discussing? 17 18 (BRIEF PAUSE) 19 20 MR. DEREK LONGFIELD: It's possible. 21 It's certainly our understanding of it at this point in 22 time, Mr. McKee. 23 MR. J.R. MCKEE: I'm sorry, you say it 24 is, which -- which? The section we just looked at? 25 MR. DEREK LONGFIELD: The -- no, the --
3627
1 MR. J.R. MCKEE: The one (1) we just -- 2 MR. DEREK LONGFIELD: -- you'd asked if 3 it's something that could be subject to revision, I 4 believe, and I said, it's possible, but it's certainly 5 our understanding of -- of how this would progress, I 6 think we're just looking to another reference here. 7 8 (BRIEF PAUSE) 9 10 MR. DEREK LONGFIELD: I think that just 11 confirms it, sir, knowing our understanding and 12 discussions with local authorities. 13 MR. J.R. MCKEE: Okay, now I'm confused. 14 Did you mean the -- the passage we just referred to in 15 the ERP? 16 MR. DEREK LONGFIELD: Yeah. Compton will 17 remain actively involved in this ERP, but there's a 18 transfer of leadership roles. And we notify them, and 19 that's our active involvement. We have monitoring of 20 SO2. 21 MR. J.R. MCKEE: Hmm hmm. 22 MR. DEREK LONGFIELD: And this kind of 23 thing. 24 And levels and you know, decisions to do 25 something from there, we believe lie with the local
3628
1 authorities, Mr. McKee. 2 MR. RUSSELL BROWN: Compton will also 3 supply resources in the way of Rovers. It's outlined in 4 the ERP. 5 MR. RICHARD BISSETT: Road block 6 personnel, downwind air monitor, and so forth, all with 7 Compton's responders. 8 MR. J.R. MCKEE: But in terms of actual 9 notification, it's Compton's current understanding then, 10 that its role is to notify as it's said here in the MD's 11 -- City of Calgary Disaster Services, and then the 12 notification will be taken care of by those 13 organizations, is that the current understanding? 14 MR. DEREK LONGFIELD: And I mean, I hate 15 to keep going to other documents that post-date 2001-5, 16 but based on that understanding, and I -- I won't go into 17 detail, but on the provisions in the Upstream Petroleum 18 Incident Support Plan of 2002. So, we believe it's clear 19 in there, but it's -- certainly we're prepared to answer 20 questions in that regard. 21 MR. J.R. MCKEE: Well you -- and you're 22 aware, and I don't know that we need to -- to go through 23 it chapter and verse, but the ID is -- is reasonably 24 clear that it -- the responsibility beyond the EPZ is a 25 shared one (1) between the -- the Applicant --
3629
1 MR. DEREK LONGFIELD: Yes, absolutely. 2 MR. J.R. MCKEE: All right. And so it's 3 defining where the sharing lines are drawn, if you will, 4 that -- that proves to be the difficult question, is that 5 fair? 6 MR. DEREK LONGFIELD: Lead role lines, I 7 think we've been clear on that through this whole train, 8 which has crossed a few examiners. 9 MR. J.R. MCKEE: So, in any event, if 10 there is an instant -- instant, I'm back to that again, 11 immediate ignition, and there's no question that through 12 some means, the parties within the awareness zone, twice 13 the reduced zone, are going to be notified of the 14 ignition. And there'll be monitoring of the SO2 levels 15 to determine whether any evacuation both within or 16 without the reduced zone becomes necessary. 17 But in some fashion or another, media will 18 be used to advise that there has been an incident, that 19 there is an ignition, and that SO2 is present, and that 20 people I presume should stay tuned for -- for further 21 details, is that roughly the understanding? 22 MR. DEREK LONGFIELD: I mean, certainly 23 that's my understanding of Guide 71 requirements, Mr. 24 McKee. 25 MR. J.R. MCKEE: And so presumably then,
3630
1 this -- this notification, using the media, will be heard 2 for -- for -- throughout the City of Calgary, and 3 probably through the surrounding communities in Southern 4 Alberta, is that a fair assumption? 5 MR. DEREK LONGFIELD: Well, yeah, and I - 6 - I mean, the one (1) I can remember is -- and I don't 7 know the exact timing, but it's -- it was in an oil 8 industry operation, but the Sarcee dump fire, where we 9 obviously had some sort of chemicals that the local 10 authorities were concerned about being in the atmosphere, 11 and there was this interruption of the media, and a 12 recommendation, as I recall it, you know, to take action. 13 And you know, that's the -- I expect the 14 same kind of thing that would happen in this unlikely 15 event, based on monitoring and that kind of thing. 16 MR. J.R. MCKEE: And in the event that 17 evacuation becomes necessary as a result of SO2 outside 18 of the reduced zone, do I take it that it's Compton's 19 position that that is the primary responsibility of the 20 MD and the City of Calgary? 21 MR. DEREK LONGFIELD: Shared, but again 22 we go to that Upstream Petroleum Incident Support Plan, 23 and it does say in Section -- I think it's 1.3.2: 24 "The local authority is the lead agency 25 in matters concerning public safety
3631
1 within its jurisdiction." 2 That's what we're going to, and obviously 3 where this becomes problematic is that we have not yet 4 fixed the size of the EPZ, so I fully appreciate the 5 conundrum that puts people in. 6 MR. J.R. MCKEE: And we're not able to 7 say and you're not able to say at this point, what 8 Compton's role might be, if an evacuation outside of the 9 reduced zone became necessary as a result of SO2? 10 MR. DEREK LONGFIELD: It would be, in our 11 opinion, at the direction of the local authority. 12 MR. J.R. MCKEE: And that could be 13 everything from providing resources to every -- anything 14 that's -- that is available within the ERP, or to the 15 extent that you're able, is that fair to say? 16 MR. DEREK LONGFIELD: I -- I think that's 17 correct, Mr. Brown? 18 MR. RUSSELL BROWN: Yes, Section 1, page 19 18 of the Emergency Response Plan states that Compton 20 will provide guidance, assistance and resources. 21 MR. J.R. MCKEE: Now, my feeling I say 22 then, and from what I understand from previous 23 examination and review of the maps, the -- the awareness 24 zone does encompass a number of neighbourhoods within the 25 southeast portion of Calgary, is that correct?
3632
1 MR. DEREK LONGFIELD: Yes, that's right. 2 MR. J.R. MCKEE: And so it is conceivable 3 then, should SO2 levels reach the point where evacuation 4 becomes necessary, that evacuation of a significant 5 number of residents within Southeast Calgary is possible? 6 MR. DEREK LONGFIELD: I guess you've made 7 a statement that it's possible, I guess all the technical 8 information we have which, with respect to SO2 dispersion 9 modelling for this characterization of a maximum kind of 10 release here, suggests that, no, it isn't possible. 11 And I just want to make sure that that 12 was something you understood that we don't believe any 13 kind of massive actual -- evacuation is ever going to be 14 enacted as a result of SO2 levels. 15 MR. J.R. MCKEE: And I appreciate that. 16 And, indeed, we'll be talking to Mr. Crooks, probably 17 after lunch, about that very topic. 18 But, again, as we are often doing in this 19 process, we are -- we are dealing with the nightmare of 20 nightmare scenarios and trying to understand how things 21 will work should, as Mr. Bissett said, Murphy's law not 22 only exist but predominate. 23 And so, to that extent, you know, the SO2 24 concentrations, although from our best guess at this 25 point in time, won't cause evacuation, if that were to
3633
1 occur we could be talking about neighbourhoods within the 2 City of Calgary; is that -- is that correct? 3 MR. DEREK LONGFIELD: Yes. 4 MR. J.R. MCKEE: Would that not then 5 raise the same sort of impracticalities and concerns that 6 Compton identified right at the beginning of this process 7 when it looked at the calculated zone in terms of the 8 actual logistics of an urban evacuation? 9 Would we not be encountering those same 10 problems? 11 MR. DEREK LONGFIELD: Not based on our 12 discussions with the City of Calgary. It would pose a 13 problem if Compton were to do it, but from our 14 discussions with the City of Calgary, this is why we have 15 disaster services. 16 MR. J.R. MCKEE: And so Compton, to this 17 date at least, and given the state of discussions between 18 Calgary and Compton, has been satisfied that the City of 19 Calgary possesses the wherewithal to actually execute 20 that sort of an evacuation? 21 I think we've established Compton, 22 certainly within itself, doesn't have those resources but 23 you're satisfied the City does? 24 MR. DEREK LONGFIELD: I'm going to say, 25 yes, but I'll let Mr. Brown elaborate on that.
3634
1 MR. RUSSELL BROWN: I think there is an 2 emergency -- repeating myself after several times, there 3 is an emergency management system in Canada that is 4 braced on progressive response. Individual is the first 5 layer of response. The individual is unable to cope then 6 governments respond progressively. 7 The local authorities manage response 8 locally. Each province and territory has a provincial 9 plan that the local authorities can call upon. And the 10 province can call on the country. It's -- it's -- we 11 don't want to break the mould that has been put in place. 12 MR. J.R. MCKEE: And, Mr. Brown, I guess 13 my natural question to that is, where was that analysis 14 or maybe it was taking place at the beginning when 15 determining that the first calculated zone was 16 impractical? 17 You suggest that to me as the answer to 18 any concerns that might be raised about an urban 19 evacuation for SO2, I'm wondering, because those 20 discussions didn't seem to occur in the first instance 21 about evacuation as a result of H2S and I'm curious as to 22 why that would be? 23 MR. DEREK LONGFIELD: Mr. McKee, I'm 24 going to move from obtuse to bull headed, but I have to 25 get back to we're talking about the hazard. And the
3635
1 hazard for the size of the EPZ is H2S. The hazard 2 outside the SO2 -- outside the EPZ is the SO2. So the 3 responses are different. 4 I can't say anything different than that. 5 But the responses are different. 6 MR. J.R. MCKEE: That might be a good 7 place to leave it for our lunch break, Mr. Chairman, if 8 that's satisfactory. 9 THE CHAIRPERSON: Right you are. Thank 10 you. We will adjourn and come back at two o'clock. 11 Thank you. 12 13 --- Upon recessing at 12:32 p.m. 14 --- Upon resuming at 2:07 p.m. 15 16 THE CHAIRPERSON: Before we start, Mr. 17 Fitch, I just have a question for you. 18 You sent in some material yesterday? 19 MR. GAVIN FITCH: Yes. 20 THE CHAIRPERSON: And I just -- is that 21 all the material now? 22 MR. GAVIN FITCH: That is all the -- that 23 is essentially a written version of the -- as I said, 24 PowerPoint presentations that the expert Witness Panel 25 for the Frontline Residents Group will be -- will be
3636
1 presenting. 2 And as I indicated to you, Mr. Chairman, 3 some time ago now, I wasn't proposing to put in any 4 written evidence, if you will, for the resident Panel, 5 although we may actually. We were going to put up our 6 expert Panel first. We may indeed put in a written 7 presentation by one (1) of the members of the resident 8 Panel, because it's somewhat lengthy. 9 But -- so, I think -- I think that -- I 10 hope that answers your question. 11 THE CHAIRPERSON: Are you, as far as 12 timing goes, are your residents -- is it satisfactory for 13 them to go on our normal sitting hours, are we going to 14 meet -- are you going to want us to sit in an evening or 15 something, to make it more comfortable for your 16 residents, or...? 17 MR. GAVIN FITCH: We had been proceeding 18 on the assumption that we would seat our resident Panel 19 during -- 20 THE CHAIRPERSON: Regular hours? 21 MR. GAVIN FITCH: -- regular hours. 22 THE CHAIRPERSON: Okay, so -- 23 MR. GAVIN FITCH: And they're aware of 24 that. 25 THE CHAIRPERSON: -- okay. So if
3637
1 anything changes you'll let us know, otherwise we don't 2 have to -- 3 MR. GAVIN FITCH: That's right, sir. 4 THE CHAIRPERSON: Okay. 5 MR. GAVIN FITCH: Thank you. 6 THE CHAIRPERSON: And will you be 7 providing a list of who those residents are going to be? 8 MR. GAVIN FITCH: Yes. 9 THE CHAIRPERSON: Okay. 10 MR. GAVIN FITCH: I'm sorry, sir, I 11 actually thought I'd done that, but you're right, I have 12 not. 13 THE CHAIRPERSON: May -- okay. 14 MR. GAVIN FITCH: No, I haven't. So, we 15 will do that. Thank you. 16 THE CHAIRPERSON: Okay. But, for the 17 rest of it, we've got all the material you're going to -- 18 MR. GAVIN FITCH: That's right. 19 THE CHAIRPERSON: And now I haven't had a 20 chance to look at the material yet, we had given you an 21 opportunity to respond to -- equivalently to an 22 undertaking you have given it to Compton, is that in the 23 material as well? 24 MR. GAVIN FITCH: Yes, it is. It's part 25 of the RWDI presentation. So, the RWDI presentation
3638
1 essentially consists of kind of summarizing the report 2 that was filed back in March 2004, and then responding to 3 some -- essentially of the evidence that's already come 4 out thus far -- 5 THE CHAIRPERSON: Okay. 6 MR. GAVIN FITCH: -- in the Hearing. And 7 in addition, specifically we do provide RWDI's response 8 to the undertaking that the Board requested of -- of 9 Compton. 10 THE CHAIRPERSON: Great. Thank you very 11 much, I appreciate -- 12 MR. GAVIN FITCH: Thank you. 13 THE CHAIRPERSON: -- your assistance. I 14 was just waiting to see if Mr. Manning is starting to 15 walk. I didn't know if he was starting to walk to the 16 front or not, but, Mr. McLarty...? 17 MR. ALLAN MCLARTY: Thank you, sir. 18 There's one (1) additional undertaking that I think we 19 can respond to now. 20 THE CHAIRPERSON: Oh, yes. 21 MR. ALLAN MCLARTY: You will recall this 22 morning, in questions raised by Mr. McKee, he was getting 23 into the area of -- of communications as between Compton 24 and the City of Calgary. 25 We've now managed to, I think to pull
3639
1 together that information. I've reviewed the response 2 with Ms. Gosselin, and she tells me that it is largely 3 complete, although apparently there's one (1) additional 4 communication that is not included in the package that 5 I've put together that Ms. Gosselin believes should be 6 part of that package. And I'm happy to -- to make it so. 7 So, I guess what I've circulated, sir, is 8 a document that's now referred to as Exhibit number 039- 9 051(a); that's in error. It should I think be marked as 10 Exhibit 52, probably (a), assuming that there might be 11 more undertakings at some point in time, given to Mr. 12 McKee. 13 And -- and perhaps Ms. Gosselin would like 14 to speak to the additional communique that should be part 15 of that package. 16 THE CHAIRPERSON: Thank you, sir. Ms. 17 Gosselin...? 18 MS. LEILA J. GOSSELIN: Yes, there's -- 19 there's one (1) e-mail that isn't part of that package. 20 Mr. Rindfliesch still has to go back and check to make 21 sure that there isn't any more e-mails, but there is one 22 (1) e-mail that was part of the correspondence, that I 23 would like to have included with. 24 THE CHAIRPERSON: Certainly. Do you have 25 those now?
3640
1 MS. LEILA J. GOSSELIN: Yes. 2 THE CHAIRPERSON: Yes. So, we could just 3 mark that as 052(b) then? Would that be the easiest or 4 did you just want it tacked on to what Mr. McLarty has 5 already added? 6 MS. LEILA J. GOSSELIN: I like the 7 separate number, sir, because I'll be referencing it in 8 our direct. 9 THE CHAIRPERSON: Oh, okay, so that'll be 10 (b), 39-052(b). Thank you. 11 12 (BRIEF PAUSE) 13 14 THE CHAIRPERSON: Ms. Gosselin, could you 15 just assist just so that we can get the description down 16 properly. Who is Murray Castle? 17 MS. LEILA J. GOSSELIN: Actually Compton 18 may be better able to answer that question, it's -- 19 THE CHAIRPERSON: Is he -- 20 MS. LEILA J. GOSSELIN: -- someone that 21 they've retained. 22 THE CHAIRPERSON: -- is he -- is he a 23 Compton consultant or employee? 24 MR. ALLAN MCLARTY: I believe he's 25 associated with Bissett Consultants.
3641
1 MR. RICHARD BISSETT: Yes, sir, that's 2 correct. 3 THE CHAIRPERSON: So for 039-052(b), it 4 would be a copy of an e-mail dated July 13th, 2004 from 5 Harvey Rindfliesch of the City, to Murray Castle of 6 Bissett. 7 MS. LEILA J. GOSSELIN: And Russ Brown, 8 if you notice, Mr. Chairman. 9 THE CHAIRPERSON: Sorry? 10 MS. LEILA J. GOSSELIN: If you look in 11 the cc line it was cc'd to Russ Brown as well, sir. 12 THE CHAIRPERSON: Yes. 13 MS. LEILA J. GOSSELIN: Thank you. 14 THE CHAIRPERSON: Thank you. 15 16 --- EXHIBIT NO. 039-052(b): Copy of email dated July 17 13th, 2004 from Harvey Rindfliesch of 18 the City to Murray Castle of Bissett 19 (supplied by Ms. Gosselin.) 20 21 THE CHAIRPERSON: Mr. McKee...? 22 MR. J.R. MCKEE: Thank you, Mr. Chairman. 23 24 CONTINUED BY MR. J.R. MCKEE: 25 MR. J.R. MCKEE: Good afternoon,
3642
1 gentlemen. Before we broke, we were discussing among 2 other things, the notion of an ignited well and the 3 issues of SO2 and notification outside of the emergency 4 response zone. 5 In its planning and its considerations, 6 has Compton evaluated or considered the problems that 7 might be associated with not a -- not an evacuation 8 scenario as the results of higher than acceptable SO2 9 levels but a scenario in which members of the public 10 perceive a danger and take steps to protect themselves in 11 a -- in a -- in the large part by leaving their homes and 12 trying to -- to leave the area. 13 Has the notion of the perceived threat and 14 people's reaction to that been something that Compton has 15 considered? 16 MR. DEREK LONGFIELD: Yes, we have 17 considered it. I don't think I could provide you with 18 much detail in that regard. It's something we spoke 19 about with Bissett Consultants. 20 MR. J.R. MCKEE: And, Mr. Bissett, in 21 your discussions with the City and the other municipal 22 districts, has that been a topic that has been discussed? 23 MR. RICHARD BISSETT: Not to any great 24 detail. No, sir. We're still back at that training 25 stage and -- and planning stages.
3643
1 MR. J.R. MCKEE: So, I'm guessing there 2 hasn't been any, sort of, modelling or -- or analysis of 3 traffic issues and that sort of thing that might occur 4 once, for instance, notification went out to the 5 awareness zone via the media of an ignition? 6 There hasn't been any sort of an analysis 7 of traffic problems and what might be necessitated by 8 that to date; is that fair? 9 MR. RICHARD BISSETT: That's correct. 10 With respect to this project, that's right. 11 MR. J.R. MCKEE: Does -- does Compton see 12 that as an issue or something that it needs to consider 13 or be involved in the planning to deal with such an 14 eventuality? Is that something that Compton feels it's 15 going to have to be involved in? 16 MR. RICHARD BISSETT: My thoughts would 17 be that -- that we would follow the disaster services 18 lead on issues concerning traffic. 19 MR. J.R. MCKEE: Has there been any 20 analysis by Compton of the cost -- potential cost to the 21 municipalities and to the Province if, as the result of a 22 perceived problem, road blocks became necessary, roads 23 became -- traffic issues arose and congestion arose, that 24 sort of thing? 25 Has there been any analysis of that
3644
1 potential cost? 2 MR. RICHARD BISSETT: To the best of my 3 knowledge, no, sir. 4 MR. J.R. MCKEE: And, again, has that 5 subject been discussed to date between Compton and the 6 City or any of the other municipalities? 7 MR. RICHARD BISSETT: No, sir. 8 MR. J.R. MCKEE: Does Compton feel that 9 it is a distinct possibility that in the event of an 10 ignition that the consequences of a perceived threat, 11 rather than a real one, would be every bit as difficult 12 to deal with and every bit as costly to deal with as if 13 you were dealing with a real evacuation scenario? 14 MR. RICHARD BISSETT: My thoughts on that 15 is, if we do a good enough job of explaining precisely 16 what's happening, what's going on, that -- that it should 17 be no different than -- than another ho-hum day at work. 18 And I don't mean to downplay it or 19 anything else. But if we do not inform the public in a 20 manner that -- that is well understood as far as what the 21 hazard is, where it's occurring, then we could very 22 easily create panic. 23 And I'm starting to get out into an area 24 that really should be answered by -- by somebody with -- 25 with experience in that area.
3645
1 MR. J.R. MCKEE: And is there someone 2 amongst you who has that experience? 3 MR. RICHARD BISSETT: No, sir. Not at 4 all. Not when we start talking about large urban 5 centres. No, sir. 6 MR. J.R. MCKEE: All right. So, what 7 you're saying, I guess, Mr. Bissett, is that you would 8 hope that prior to any of this coming to pass that there 9 would be some education out there to the public so that 10 when they heard the notification, for instance, you know, 11 burst in on their radio or their television that they 12 would be able to assess the danger with some rationality. 13 Is that what you're saying? 14 MR. RICHARD BISSETT: That's exactly 15 where we're coming from. As a matter of fact in our 16 normal oil and gas industry, emergency preparedness and 17 notifying the public we're very much aware of the fact 18 that -- that if we notify the public of a sour well being 19 drilled on a specific area and that there's a hazard 20 associated with it and if we were to have a shallow 21 emergency or an emergency at that location prior to 22 drilling in the sour formation, the public could very 23 easily perceive themselves to be at risk and thus react 24 in a -- in a negative manner. 25 And in our normal planning why we -- we
3646
1 would notify the public that there was an emergency at 2 the well but that it would not involve hydrogen sulphide 3 or sulphur dioxide. So, we do have that in our normal 4 planning, yes sir. 5 MR. J.R. MCKEE: All right. What is -- 6 what is Compton see as its role in providing that level 7 of understanding or education to the public so that they 8 -- when they hear that alert or when they see that 9 notification, they can make a rational decision about how 10 they should conduct themselves? 11 MR. RICHARD BISSETT: My thoughts on that 12 would be is work through the disaster services 13 representative of the -- representatives of the local 14 authorities that any -- any announcements of that -- of 15 that -- or any releases going to the public would be 16 presented in -- in keeping with the standards that -- 17 that the local authority would advise us on. 18 And we would not be doing that but -- but 19 I would like to think the local authority will be making 20 those announcements. 21 MR. J.R. MCKEE: So maybe I misunderstood 22 but I thought then it would have been -- it was your hope 23 -- Compton's hope that some amount of information would 24 be out there before any sort of alert was released, some 25 sort of education, so that should that occur, that --
3647
1 that party -- the -- the public would be able to say 2 well, you know, we were told this might happen and -- and 3 there's nothing to -- nothing to concern ourselves with 4 rather than trying to process an emergency broadcast 5 warning that starts with don't panic but -- or something 6 along those lines. 7 So, maybe I misunderstood what -- what 8 you're -- what you're getting at. Did you -- did you 9 mean to say that there would be some attempt at informing 10 the public prior to drilling, prior to any of this 11 happening so that they could process that information 12 better or were you eluding to the content of the warning 13 itself? 14 MR. RICHARD BISSETT: I guess, number 1, 15 to answer your first part of that question, is that we 16 have not worked out any details of prior notification of 17 the public beyond the emergency planning zone. The 18 public within the emergency planning zone will indeed be 19 notified of the fact that sour operations are beginning 20 and when they end. 21 I believe earlier today, we had discussed 22 that if -- that if it was necessary and beneficial, then 23 whatever program deemed appropriate would indeed be 24 looked after in order to -- to educate the public that 25 could be impacted by sulphur dioxide. That's -- that's
3648
1 such a large area I -- I guess we would want to sit down 2 and discuss it with and seek advice from the local 3 authorities as to what would be appropriate notification. 4 If it's deemed necessary I have no doubt 5 that that will be written into -- written into the 6 program. 7 MR. J.R. MCKEE: Because -- it -- it 8 would certainly and from what I understood, it's your 9 hope -- it's Compton's hope that in the event of an 10 ignition and in the event of the notification, that 11 people will be able to respond in a way that is based on 12 information rather than fear. 13 Is that -- is that your hope? 14 MR. RICHARD BISSETT: That is exactly the 15 hope right there that -- that -- and a well informed 16 public you would like to think would react in a rational 17 manner. Not necessarily, but -- but you would -- you 18 would hope that that would occur. 19 MR. J.R. MCKEE: And wouldn't -- isn't it 20 -- is it true that -- that the expertise and knowledge 21 about the hazards, about these sorts of matters, the kind 22 of thing that you would want the public to know about, to 23 understand, resides with Compton rather than the City; is 24 -- is that not true? 25 MR. RICHARD BISSETT: I would -- I would
3649
1 hope that the City would have as good an understanding 2 about hydrogen sulphide and sulphur dioxide as Compton 3 would have. 4 MR. J.R. MCKEE: But this -- 5 MR. RICHARD BISSETT: You know, because 6 again, hydrogen sulphide is not entirely restricted to 7 the oil and gas industry. Anywhere you have 8 decomposition of organic material, you have hydrogen 9 sulphide being produced, and it's my understanding that 10 the sewer system in Calgary, one (1) of the hazards is 11 hydrogen sulphide; a worker hazard. 12 MR. DEREK LONGFIELD: And to -- to just 13 add to that, Mr. McKee, certainly the specifics of this 14 hazard, you know, what would cause it, what -- what 15 events have occurred if there is this hazard potential. 16 I think those are the kind of things 17 certainly Compton is -- is better to speak to the 18 processes that would go on, that would get you to that 19 stage, where there's this don't panic message. 20 So, certainly one (1) of the ways is 21 starting with the open houses that we talked about before 22 lunch hour; that's certainly a starting point. But from 23 those there may be certainly I think as I've alluded to, 24 there could be other methods that we would use as well. 25 But the -- the important thing is that I
3650
1 think it would be a -- a combined informational process, 2 that that's exactly where we would like to be heading in 3 this, where you have a -- a local authorities plus 4 Compton. 5 And Compton's certainly providing the 6 specifics relating to the oil industry where -- where we 7 are aware of what the operation is -- and -- and what the 8 risks are and what the hazard might -- might wind up 9 being. 10 MR. J.R. MCKEE: But -- but Compton 11 recognizes the problem in that when you -- when you put 12 out an announcement like the one (1) we were discussing 13 on the media, when someone is having their -- their -- 14 you know, their latte in their -- their walk up 15 brownstone in Mackenzie Lake, they're -- they're not 16 likely to be -- be, you know, processing anything other 17 than the fact that, my goodness, there's an ignited sour 18 gas well, I better get out of here. 19 And -- and they're not going to find -- 20 the niceties of EPZs and radiuses and things like that, 21 are not -- that's not the best time to convey that 22 information. And -- and the potential result again, is 23 the panic response that we're talking about, which of 24 course has that sort of a chain reaction, and Compton 25 recognizes that don't they?
3651
1 MR. DEREK LONGFIELD: Absolutely. 2 MR. RICHARD BISSETT: Absolutely. Sorry. 3 MR. DEREK LONGFIELD: Yes, I would say so 4 certainly, and -- and I would add that case in point, 5 probably three/four (3/4) years ago, even after the 6 Dynegy Hearing, there was a considerable number of 7 people, in fact, the vast majority that weren't aware 8 there were two (2) wells producing sour gas. And this 9 whole process has certainly, I think, reached a lot more 10 people in that regard, that they are aware there are two 11 (2) wells producing there, and that, you know, this 12 project revolves around that. 13 But even very early on in the project 14 there wasn't that understanding. So, that's a very basic 15 situation where there's an information -- a set of 16 information that needs to be out there. And there's a 17 lot more information that'll need to be out there, well 18 in advance of the drilling commencing. 19 MR. J.R. MCKEE: So suff -- suffice it to 20 say then that this is another matter that needs to be 21 finalized and discussed and agreed to between Compton and 22 the -- the various municipal bodies and governmental 23 bodies. 24 But Compton recognizes that it has a role 25 to play in that process; is that fair?
3652
1 MR. DEREK LONGFIELD: Yes, obviously so, 2 and obviously as well, we need to know what the program 3 is, which obviously isn't finalized at this point. 4 MR. J.R. MCKEE: Okay. And just -- just 5 to finish that particular notion. Has Compton done any 6 work or any modelling or had any serious consideration of 7 traffic management issues outside of the emergency 8 response zone? 9 MR. DEREK LONGFIELD: Not to my 10 knowledge, no. 11 MR. J.R. MCKEE: Mr. Crooks...? 12 MR. GREGORY CROOKS: Yes, sir. 13 MR. J.R. MCKEE: I wonder if you could 14 have reference to and for the -- for the -- hopefully the 15 only time, we've heard Jacques Whitford, we've heard 16 Jacks Whitford, we've heard J.W., which would you prefer? 17 MR. GREGORY CROOKS: The official version 18 of our names is Jacques Whitford and that's our -- our 19 founder's name was Hector Jacques. However, just to 20 complicate things he does actually allow it to be called 21 Jacques Whitford in Quebec. 22 MR. J.R. MCKEE: It's probably a very 23 perceptive move on his part. In any event, I would like 24 you to have a look at the Jacques Whitford report of 25 January 12th, 2004 which I believe is located at
3653
1 CRH/Compton-8 which I believe, again, is Exhibit 00 -- 2 I'm sorry, not CHR/Compton-8, I'm looking at the wrong 3 reference. 4 CHR/Compton-1 and I believe it was an 5 appendix to that response; have you got that there? 6 MR. GREGORY CROOKS: Yes, sir. 7 MR. J.R. MCKEE: And now, Mr. Crooks, is 8 this a report that you played a role in preparing? 9 MR. GREGORY CROOKS: The original work 10 was done in 2001. For this report, what we did was we 11 extracted the analysis and the relevant sections of the 12 2001 draft report and consolidated it into this report. 13 So my role in it was not in actually 14 running the models but in reviewing the text and making 15 sure that everything was, from the previous draft 16 version, was in this version with respect to the SO2 17 analysis. 18 MR. J.R. MCKEE: And indeed this -- this 19 report deals with the SO2 analysis; is that correct? 20 MR. GREGORY CROOKS: That's correct. 21 MR. J.R. MCKEE: All right. Now, just 22 to, sort of, set the table, I understand from a number of 23 sources that we have in this matter that the evacuation 24 guidelines for SO2 are five (5) parts per million over 25 fifteen (15) minutes, one (1) part per million over three
3654
1 (3) hours, point three (.3) parts per million over 2 twenty-four (24) hours; have I got that correct? 3 MR. GREGORY CROOKS: That's correct. 4 MR. J.R. MCKEE: And that is the standard 5 which you used in this report to determine whether or not 6 the potential SO2 release in these -- in these wells 7 would exceed the evacuation standard. That's the 8 standard you used; is that right? 9 MR. GREGORY CROOKS: Yes, sir. 10 MR. J.R. MCKEE: And your report 11 separates the maximum predicted SO2 dispersions for both 12 -- not both but all of the drilling, the completion and 13 the production scenarios; is that right? 14 MR. GREGORY CROOKS: Yes, sir. 15 MR. J.R. MCKEE: And I note from a review 16 of the report that none of the maximum predicted SO2 17 dispersions, whether it be the drilling, the completion, 18 servicing or the production scenarios exceeds the 19 evacuation guidelines as I've just set them out; is that 20 correct? 21 MR. GREGORY CROOKS: That's correct, sir. 22 MR. J.R. MCKEE: And so, in your report, 23 in the conclusion, in your opinion, if these wells were 24 ignited or these -- one of these wells was ignited the 25 SO2 hazard would not, for any of the areas with which
3655
1 we're concerned, reach the level that evacuation became 2 necessary? 3 MR. GREGORY CROOKS: That would be my 4 opinion, yes, sir. 5 MR. J.R. MCKEE: Now, I wonder if you 6 could look at Table 1 in your report. And Table 1 is on 7 page 4 of the report and is entitled, Health Effects; 8 have you seen that there? 9 MR. GREGORY CROOKS: Yes, sir. 10 MR. J.R. MCKEE: And the first 11 concentration -- parts per million concentration is: 12 "point one, seven (.17) on a one (1) 13 hour average Clean Air Act air quality 14 standard for avoiding vegetation 15 damage." 16 Do you see that? 17 MR. GREGORY CROOKS: Yes, sir. 18 MR. J.R. MCKEE: What Clean Air Act are 19 we talking about? 20 21 (BRIEF PAUSE) 22 23 MR. GREGORY CROOKS: Sir, that is the 24 Alberta Environment one (1) hour average SO2 guideline. 25 MR. J.R. MCKEE: The Alberta Environment
3656
1 one (1) hour average SO2 guideline. Now, the comment in 2 parenthesis there for avoiding vegetation damage, does 3 that mean that that concentration is only something the 4 plant should be worried or is there -- there some human 5 health consequence that might be attached to that level? 6 MR. GREGORY CROOKS: That's actually a 7 good question and I would have to go back and look 8 through the Alberta Environment document to determine 9 that exactly. However, in general, a lot of ambient air 10 quality guidelines for long term exposure to S02 are 11 based on vegetation rather than human health affects as 12 those tend to be the more severe affect. 13 MR. J.R. MCKEE: So, it's entirely 14 possible then that we are talking about plants at that 15 level? 16 MR. GREGORY CROOKS: Yes, sir. 17 MR. J.R. MCKEE: I wonder if you could 18 have a look briefly at the RWDI report which is in 19 Exhibit 003-11(a). Do you have that, Mr. Crooks? 20 MR. GREGORY CROOKS: Yes, sir, I do. 21 22 MR. J.R. MCKEE: And in Schedule A which 23 is the RWDI report entitled, Review of the Hazards and 24 Risks Associated with the Compton North Okotoks 25 Horizontal Drilling Program, at page 7 of that report
3657
1 there is another table dealing with health issues 2 regarding S02. Do you see that? 3 MR. GREGORY CROOKS: Yes, sir. 4 MR. J.R. MCKEE: Now that one at point 5 one (.1) part per million talks about bronchial 6 constriction in sensitive asthmatics. Do you see that 7 there? 8 MR. GREGORY CROOKS: Yes, sir. 9 MR. J.R. MCKEE: Now, do you take any 10 issue with the suggestion that at low a concentration 11 there could be that affect with respect to sensitive 12 asthmatics? 13 MR. GREGORY CROOKS: Well, sir, as I 14 stated previously I'm not a toxicologist so I -- I can't 15 make a judgement on that. 16 MR. J.R. MCKEE: Okay. So, one way or 17 the other you can't offer a comment? 18 MR. GREGORY CROOKS: That may very well 19 be true. I can't say one way or the other based on my 20 experience. 21 MR. J.R. MCKEE: And it would seem, 22 looking back at the chart for Table 1 in the Jacques 23 Whitford report. When we go up to point three (.3) parts 24 per million it notes that evacuation if levels persist 25 levels persist over twenty-four (24) hour period.
3658
1 And I note further down in that table and 2 it's similar to what we see in the RWDI report, the 3 threshold for odour appears to be point three (.3) parts 4 per million. 5 Do I read that correctly? 6 MR. GREGORY CROOKS: Point three (.3) to 7 five (5) parts per million for odour, sir. 8 MR. J.R. MCKEE: So when we look back at 9 the -- your findings in regards to the maximum predicted 10 levels, it would seem that at least for the fifteen (15) 11 minute and three (3) hour readings or -- or analysis, we 12 are going to be well past and into the -- the odour 13 range; is that fair? 14 MR. GREGORY CROOKS: Potentially, sir. I 15 would like to -- to comment though that the numbers that 16 we present when we do these dispersion modelling 17 assessments are the maximum predicted over a five (5) 18 year meteorological data set. So, we've looked at -- 19 what is five (5) years -- roughly forty-three thousands 20 (43,000) hours and come up with the worst case 21 concentration. 22 And those are what are presented in these 23 figures. Now for a lot of the time the concentrations 24 are obviously going to be quite a bit less than what 25 we've presented as the maximum. So, that's something
3659
1 that we have to keep in mind is that when we're looking 2 at this, we have the maximum that could potentially 3 happen, but then we also have to keep in mind that we may 4 not necessarily have that combination of meteorological 5 conditions occurring, it's -- it's going to be a -- a 6 probability. 7 MR. J.R. MCKEE: Well, and that -- and 8 that's fair enough, and I think that that's obviously 9 part of the -- what makes dispersion modelling of any 10 sort an interesting enterprise. 11 However, I think that it -- it is true 12 then, that taking into consideration those qualifiers, 13 within the tests that you would run, there is the 14 potential for the concentration to be sufficient that it 15 becomes noticeable to parties, the odour is present, 16 whether it's consistent, whether it comes and goes, that 17 is a likely potential? 18 MR. GREGORY CROOKS: Yes, sir, that -- 19 that potential is there. 20 MR. J.R. MCKEE: All right. Now, Mr. 21 Bissett, just if you could reconfirm my recollection, the 22 ignited wells, we could be talking anything from a couple 23 of days to something in excess of a month; is that right? 24 MR. RICHARD BISSETT: Yes, sir, that's 25 correct.
3660
1 MR. J.R. MCKEE: Okay. Now, Mr. Crooks, 2 help me understand this. And this may be just me. Does 3 it change your analysis or your projected concentrations, 4 if we're dealing with a well burning for a day or twenty- 5 five (25) days or thirty (30) days, does it change 6 anything in terms of the concentrations that -- that you 7 would predict? 8 MR. RICHARD BISSETT: In terms of the 9 maximum concentrations, no, sir. We -- essentially what 10 we do when we do our modelling is that we assume for our 11 entire five (5) year meteorological period, that the well 12 is burning continuously during that period, which is an 13 extreme -- obviously an extremely conservative assumption 14 and then we generate our maximum based on that. 15 MR. J.R. MCKEE: Are you able to tell me 16 whether you were basing calculations of SO2 on this one 17 (1), on the basis of a vertical release or a horizontal 18 release? 19 MR. GREGORY CROOKS: In terms of the SO2, 20 it really doesn't matter whether it's vertical or a 21 horizontal release. We're assuming that the well is 22 ignited. And that the release is at one (1) metre above 23 ground. 24 And then what we plug into our model 25 essentially, is a buoyancy flux, to look at how much rise
3661
1 we get due to the combustion of a plume. So, in that 2 respect, whether it's a horizontal or a vertical release 3 at the pipe, it doesn't really matter. 4 MR. J.R. MCKEE: So, that's not a factor 5 that's put into the model? 6 MR. GREGORY CROOKS: No, sir. 7 MR. J.R. MCKEE: So, that's a neutral 8 factor, as far as you're concerned? 9 MR. GREGORY CROOKS: Yes. 10 MR. J.R. MCKEE: How were the fifteen 11 (15) minute averages calculated? 12 MR. GREGORY CROOKS: The fifteen (15) 13 minute average is calculated based on the hourly average 14 values, which are -- which are calculated by the model, 15 and then adjusting that based on a ratio of -- of 16 essentially plume heights for different averaging 17 periods. 18 And I mean it follows a standard equation 19 for doing this, which is the -- which is the ratio of the 20 averaging period that you're looking at, to the sixty 21 (60) minute average that's predicted by the model, to the 22 power of point two five (.25). 23 MR. J.R. MCKEE: Maybe we could look at 24 Figures 3 and Figure 6 from the report? 25
3662
1 (BRIEF PAUSE) 2 3 MR. GREGORY CROOKS: Yes, sir. 4 MR. J.R. MCKEE: And again, remember 5 you're just -- you're talking to a lawyer here, and -- 6 and I mean that in the charitable sense. 7 These are both -- I'm assuming is what the 8 product of the -- the dispersion modelling is projecting 9 for the concentrations of SO2, in this particular 10 geographic area; have I got that right? 11 MR. GREGORY CROOKS: That's correct, sir. 12 MR. J.R. MCKEE: Right. And both Figure 13 6 and Figure 3, deal with maximum predicted fifteen (15) 14 minute average ground level SO2 concentrations in parts 15 per million, associated with emergency flaring in the 16 event of a blowout during drilling of the most prolific 17 proposed Compton well from 10 of 13 surface location; is 18 that right? 19 MR. GREGORY CROOKS: For Figure 3, that's 20 correct, sir. For Figure 6, the predictions are for 21 completion and servicing of the most prolific well. 22 MR. J.R. MCKEE: My -- my apologies. All 23 right. Now, I'm noticing, and I've noticed this in a 24 couple of these figures and I've ask you to look at these 25 two (2). If I read this correctly some of the highest
3663
1 concentrations that you're projecting for SO2 are 2 somewhat to the south and west -- significantly to the 3 south and west of the -- not just the emergency response 4 zone but, indeed, the calculated EPZ. 5 Am I reading that correctly? 6 MR. GREGORY CROOKS: Yes, sir. 7 MR. J.R. MCKEE: I wonder if you could 8 explain to me why it would be that the modelling would 9 suggest that the poor souls in Longview would be getting 10 the levels of this -- of this magnitude when those who 11 are much closer don't seem to be getting anywhere near 12 the concentrations? 13 MR. GREGORY CROOKS: The -- the 14 explanation for that, sir, is that to the west and south 15 of the proposed well we have an area of elevated terrain 16 and what is occurring is that the plume from the -- from 17 the ignited well is coming in proximity to the terrain 18 and it's interacting with it. 19 Essentially, if we have a plume that's 20 high above ground but that we're bringing our receptor up 21 closer to the plume because it's on higher -- at a higher 22 elevation, essentially. 23 MR. J.R. MCKEE: So, Mr. -- Mr. 24 Longfield, in Compton's ongoing discussions with 25 emergency planners and other municipal agencies, is
3664
1 Compton taking note of these dispersion models showing 2 that the -- the concentration of SO2 could conceivably be 3 significantly higher somewhat to the west and south of 4 the areas that we're concerned with? 5 MR. DEREK LONGFIELD: Well, the maximum 6 predicted concentration? 7 MR. J.R. MCKEE: Yes. 8 MR. DEREK LONGFIELD: That's right. Yes. 9 I think the terrain is the controlling factor in that. 10 In that we have noticed that, yes. And -- and, I mean, 11 certainly have discussed these -- these results as well. 12 I think the important thing from these results is that 13 the worst possible conditions and maximum release all 14 stay well below evacuation guidelines. 15 MR. J.R. MCKEE: Well, again, it sort of 16 connects back to what we were talking about earlier this 17 afternoon and that's the perceived -- perceived or the 18 perception of a risk. 19 And if the tables are to be believed, once 20 we hit a point seven, five (.75) concentration and, 21 forgive me, Mr. Crooks, is that a -- am I reading that 22 correctly in the -- in these scenarios; figure 3 in 23 particular, to the west and to the south? Point seven, 24 five (.75) or -- 25 MR. DEREK LONGFIELD: It gets to one (1)
3665
1 actually. 2 MR. GREGORY CROOKS: Yeah, we have a 3 contour there. 4 MR. J.R. MCKEE: When you have a one (1). 5 So we're well past the odour point at that point, are we 6 not? 7 MR. GREGORY CROOKS: For some people, 8 yes, sir. 9 MR. J.R. MCKEE: So -- 10 MR. GREGORY CROOKS: And odour is, if I 11 might just digress slightly, is a very subjective thing 12 and different people sense odours at different 13 sensitivities. 14 That's why we have in our table the range 15 of -- of values for the threshold. 16 MR. J.R. MCKEE: I think most of us who 17 have purchased perfume for our wives are cognisant of 18 that. But I guess what I'm -- what I'm interested in is, 19 again, the perception of risk, people's own senses, are 20 going to add to that. 21 If, on the one hand, it's being told over 22 the radio there's a problem, but on the other hand the 23 scent or the smell of SO2 is likely, again, I would 24 suggest, and disagree with me if you will, Mr. Longfield, 25 that there is something wrong and may again lead to the
3666
1 sort of panic response that we were discussing earlier; 2 would you -- would you agree with that? 3 MR. DEREK LONGFIELD: Not if the 4 information is communicated properly. I wouldn't think 5 so. I think the incident I can think of that parallels 6 that is the mercaptans spill in South Calgary and it 7 wasn't a health hazard but it's definitely something 8 people could -- could smell. 9 MR. J.R. MCKEE: And so I guess I go back 10 to my original point, is Compton going to take into 11 consideration the fact that the perception, the odour is 12 going much further afield than -- than even the 13 calculated zone in the information that it feels should 14 be out there and in its discussions with the various 15 municipal districts? 16 MR. DEREK LONGFIELD: Yes. We -- we have 17 the knowledge that it could be out there. We have the 18 roving air -- mobile air monitors and we certainly will 19 have the knowledge available if, indeed, these 20 Applications are approved and we proceed to that -- that 21 point where we are proceeding with the drilling program. 22 MR. J.R. MCKEE: And the monitors, the 23 stationary monitors, which Compton is suggesting it was 24 going to position. 25 Are there locations coordinated with this
3667
1 modelling, has -- has that been taken into consideration 2 in the locating of these monitors? 3 MR. DEREK LONGFIELD: Mr. McKee, those 4 are for H2S, I believe primarily. Mr. Bissett just 5 nodded at me. 6 MR. J.R. MCKEE: So, there's no monitors 7 for SO2? 8 MR. RICHARD BISSETT: The stationary 9 monitors are H2S and SO2, although the placement of them 10 is primarily for H2S, rather than SO2, but they would be 11 recording SO2, and of course the mobile air monitors 12 would be H2S, when H2S is being released, and of course 13 switched to SO2, when SO2 is being released. 14 MR. J.R. MCKEE: And will their 15 deployment be based in any way, on the projected 16 dispersion modelling we're looking at here? 17 MR. RICHARD BISSETT: Their -- their 18 deployment would be in conjunction with the -- the local 19 authorities. 20 MR. DEREK LONGFIELD: And conditions at 21 the time. 22 MR. RICHARD BISSETT: And the conditions 23 at the time. 24 MR. DEREK LONGFIELD: Meteorological 25 conditions at the time, Mr. McKee.
3668
1 MR. RICHARD BISSETT: Wind direction -- 2 wind direction and so forth. 3 MR. GREGORY CROOKS: Yes, again if I -- 4 if I might just point out, when we look at our contour 5 plots here, these are an amalgamation of -- of five (5) 6 years worth of meteorology, in which time the wind has 7 been constantly shifting directions. 8 So, it would certainly make sense to me 9 that if we're putting out mobile SO2 monitors, we should 10 be looking at which direction the wind is blowing, and -- 11 and making sure that we have those downwind. 12 MR. J.R. MCKEE: And that would be a more 13 relevant consideration than the modelling itself? 14 MR. GREGORY CROOKS: At that -- at that 15 time, absolutely. 16 MR. J.R. MCKEE: Okay. Mr. Crooks, have 17 you or, Mr. Longfield, has Compton done any work or 18 analysis of the effect of the SO2, of the effect that any 19 SO2 deposition might have on soil and vegetation in the 20 area? I think we've noted that point one seven (.17) is 21 a problem for vegetation. 22 As the well is ignited and as SO2 is going 23 into the atmosphere, there is going to be a certain 24 amount of that finding its way to the earth, I'm 25 presuming?
3669
1 Has there been any analysis of the effect 2 that will have on soil and vegetation? 3 MR. DEREK LONGFIELD: I can say no from 4 Compton's standpoint. 5 6 (BRIEF PAUSE) 7 8 MR. J.R. MCKEE: All right, Mr. Crooks, 9 let's talk for a bit about H2S, and the dispersion 10 modelling that was done. 11 And I guess before we get to you 12 precisely, Mr. Crooks, I would like to revisit with Mr. 13 Bissett, the minimum sort of warning times that we might 14 be dealing with in some of these scenarios that we've 15 been -- been kicking around. 16 But I know this has been touched on 17 repeatedly, but I was hoping that today we could -- we 18 could just sort of walk through and establish what the 19 minimum in your mind, would be. 20 And again, acknowledging we're talking the 21 nightmare scenario here. And -- and we're mindful of all 22 of the -- all of the -- the things that are in place, 23 which would mitigate against that ever occurring, but 24 concentrating on that, what would be the minimum advanced 25 warnings that you could foresee for an incident in the
3670
1 drilling, the completion and then the production phase? 2 And advance warning meaning -- meaning 3 before gas to surface? 4 5 (BRIEF PAUSE) 6 7 MR. RICHARD BISSETT: I'm not certain how 8 to answer that in a manner that would be meaningful. 9 During a drilling scenario, I can hardly imagine anything 10 happening under twelve (12) hours from the first warning 11 sign until something got away. Perhaps ten (10) hours 12 minimum. Maximum I would like to think could be -- could 13 be a day or two (2) or three (3). If things really 14 started to go bad why we could have that period of time. 15 Now having said that, then I would -- then 16 I would think probably ten (10) as the minimum keeping in 17 mind this truly is an estimate. And that perhaps forty- 18 eight (48) hours maximum. 19 MR. J.R. MCKEE: And that's drilling? 20 MR. RICHARD BISSETT: Yes, sir. That's 21 correct. 22 MR. J.R. MCKEE: And on the completion 23 side? 24 MR. RICHARD BISSETT: And on the 25 completion side there's -- there's probably a period of
3671
1 time when a worse case scenario -- minimum time I -- I 2 suppose would be -- would be a heartbeat. 3 If we were running -- when we would have 4 the well alive and no subsurface safety valve in there, 5 no back pressure valve in the wellhead and the wellhead 6 not evaporated but became damaged, then we could have a 7 release in a heartbeat. 8 Maximum amount of time probably would -- 9 would rival drilling giving that the pressures that we 10 could have, time to wash out and things like that. 11 Probably another forty-eight (48) hours or twenty-four 12 (24) to forty-eight (48) hours maximum time. 13 MR. J.R. MCKEE: Production? 14 MR. RICHARD BISSETT: Production wise I 15 would say it's -- it's hard to imagine that we would have 16 a re -- or a release because the -- we have the wellhead 17 on, we have the subsurface safety valve in there. 18 So if we were or if Mr. Mrochuk was 19 servicing or replacing one of those valves, then there 20 would be a -- a very short period of time, a short window 21 there to where that subsurface safety valve would not be 22 in the wellbore. 23 The tubing is alive, there would be no 24 back pressure valve set in there and again, if the 25 wellhead became damaged then we could have a -- we could
3672
1 have a -- almost instantaneous release. 2 MR. WADE MROCHUK : If I could -- 3 MR. RICHARD BISSETT: Mr. Mrochuk may 4 want to add onto that as well. But let me add one other 5 thing while we're talking about that is, during the 6 producing suspended release rate, potential is -- is zero 7 point nine three (0.93) metres cube per second versus -- 8 versus almost nine (9) metres cube and eleven (11) cubic 9 metres for completion and service. 10 MR. WADE MROCHUK: I just wanted to add, 11 just a -- a notation on the subsurface safety valve 12 servicing situation. When this valve is being serviced 13 by the wire line procedure, we are connected to the 14 wellhead with a pump truck and kill fluid just for that 15 specific event if we had an issue at the wellhead whereby 16 we could not close it for whatever reason with the 17 subsurface safety valve out of the landing nipple. 18 We would pump the kill fluid to the tubing 19 at that time and -- and kill the well with the kill 20 fluid. 21 MR. J.R. MCKEE: Thank you. So then, Mr. 22 Bissett, then the seven and a half (7 1/2) minute 23 ignition time would apply and Compton is confident that 24 it can ignite the well in seven and a half (7 1/2) 25 minutes regardless of we're dealing with the minimum
3673
1 scenario of, that you've projected from drilling or in 2 completion; is that correct? 3 MR. RICHARD BISSETT: Yes, sir. That's 4 correct. 5 MR. J.R. MCKEE: Mr. Bissett, there's one 6 matter that, for some reason, I can't get -- I haven't 7 been able to shake it from my mind so I'll do it by 8 putting it to you. 9 When we talked about the Firefly the last 10 time, you indicated in passing that the workers on the 11 rig don't appreciate having a Firefly aiming at them 12 while they're working. 13 Do you -- did you mean to suggest that 14 while the rig is in operation and while there's no 15 problems that the Firefly device is going to be aiming 16 somewhere else or in a holster somewhere and it'll then 17 have to be calibrated and aimed before it's engaged? I'm 18 just curious about that. 19 MR. RICHARD BISSETT: From time to time 20 you will have rig crews that are not appreciative of that 21 thing being pointed up into the derrick. There's less 22 and less of that as time goes on and people become 23 comfortable with the fact -- or workers become 24 comfortable with the fact that there has been no 25 incidents. There's been no misfires, if you will, or
3674
1 accidental activation of the Firefly and so forth and -- 2 and it becomes less and less prevalent. 3 MR. J.R. MCKEE: What's involved in 4 actually aiming the nozzle on the device? Is it a 5 complicated thing or is it simply like pointing a gun? 6 MR. RICHARD BISSETT: It's somewhat like 7 pointing a gun. 8 MR. J.R. MCKEE: So would -- would there 9 be any time lost if -- if the device wasn't pointed in an 10 appropriate direction? Would that be one more thing that 11 had to have been dealt with within your seven and a half 12 (7 1/2) minute window? 13 MR. RICHARD BISSETT: It's -- it's one 14 more thing that you would have to deal with. And -- and, 15 of course, it's -- it's -- it's another possibility for 16 human error that somebody failed to either turn the 17 trailer or turn the nozzle to point it in the proper 18 direction and you could end up discharging off into 19 another direction. 20 MR. DEREK LONGFIELD: Mr. McKee, I think 21 -- I think the human error that Dick just brought up 22 would be one thing, but it would be insubordination as 23 well. You'd have someone who's contravening Mr. Cover's 24 directions, the drilling supervisor's directions and the 25 safety supervisor's directions.
3675
1 I appreciate it's an interesting anecdote 2 but it has no bearing on these applications under my 3 watch or Mr. Cover's watch. 4 MR. J.R. MCKEE: And so I take that to 5 mean then that we made clear that the device would be 6 properly aimed at all times. 7 MR. DEREK LONGFIELD: Absolutely. 8 MR. RICHARD BISSETT: And, Mr. McKee, 9 that would be the ignition team's responsibility and 10 we've heard that -- that their only responsibility is to 11 ignite the well and part of that would be checking that 12 equipment on a daily basis to ensure that it is 13 functional, pointed in the right direction, no damage has 14 occurred to the controls. 15 MR. J.R. MCKEE: Thank you. 16 MR. RICHARD BISSETT: You're welcome. 17 MR. J.R. MCKEE: Sorry, Mr. Crooks. I 18 took a bit of a side trip to get to you. H2S dispersion 19 modelling. Mr. Crook, I take it it's -- the expert 20 opinion -- your expert opinion that the dispersion 21 modelling that has been done by Jacques Whitford and -- 22 and in your opinion the dispersion modelling supports the 23 notion of a four (4) kilometre reduced zone? 24 There's nothing in the dispersion 25 modelling which would indicate, in your view, that a
3676
1 larger zone would be appropriate? 2 MR. GREGORY CROOKS: I think that the -- 3 the dispersion modelling does indicate that a -- a four 4 (4) Kilometre EPZ is -- is appropriate. 5 MR. J.R. MCKEE: Now, Mr. Crooks, both in 6 submissions that were made prior to the start of this 7 hearing and in undertakings subsequent, there's been a 8 number of runs, if you will, done using various 9 parameters and various scenarios. 10 As an expert, and as an expert whose 11 opinion is that the dispersion modelling, the H2S 12 dispersion modelling supports the notion of the reduced 13 EPZ, are you able to direct me to one (1) particular run, 14 or one (1) particular set of parameters, which you feel 15 is the most appropriate and is the one (1) that could be 16 relied upon as support for your opinion? 17 MR. GREGORY CROOKS: Well, yes, sir, I 18 think that the appropriate run is -- is one (1) that was 19 submitted -- put into our original submission, which was 20 for an -- an eight (8) minute release period for a direct 21 co-efficient of one point zero (1.0). 22 MR. J.R. MCKEE: Okay. I wonder if you 23 could direct me to that one (1), sir? 24 MR. GREGORY CROOKS: That would be in 25 Exhibit 002-48, the second tab, Table 2.
3677
1 (BRIEF PAUSE) 2 3 MR. J.R. MCKEE: My apologies, I thought 4 I had it with me, but I don't. Just one (1) second. 5 6 (BRIEF PAUSE) 7 8 MR. J.R. MCKEE: All right, and so that 9 is the one (1) -- I'm sorry, did you -- did you direct us 10 to table number .. 11 MR. GREGORY CROOKS: Table 2. 12 MR. J.R. MCKEE: Table 2. So in your -- 13 your view, Mr. Crooks, we could -- when I say we, the -- 14 the Board, in considering the dispersion modelling 15 evidence, could concentrate solely on this run, as in 16 your professional opinion, this is the most appropriate 17 set of parameters, this is the most appropriate analysis 18 in the particular circumstances that we're looking at 19 here; is that correct? 20 MR. GREGORY CROOKS: Yes, sir. And I -- 21 I would draw your attention to the bottom portion of that 22 Table 2, which is the predictions for the toxic load 23 equivalent concentration, as being the -- the appropriate 24 values to examine. 25 MR. J.R. MCKEE: And so I think you said
3678
1 the eight (8) minute release; is that correct? 2 MR. GREGORY CROOKS: Yes, sir. 3 MR. J.R. MCKEE: And you said a drag co- 4 efficient of one (1)? 5 MR. GREGORY CROOKS: Yes, sir, in this 6 submission all data is done with the drag co-efficient of 7 one (1). 8 MR. J.R. MCKEE: And what ambient 9 temperature were you using on that one (1)? 10 MR. GREGORY CROOKS: We were using the 11 EUBMODELS' default, which is five (5) degrees C . 12 MR. J.R. MCKEE: Stagnation temperature? 13 MR. GREGORY CROOKS: The stagnation 14 temperatures were the calculated stagnation temperatures, 15 based on the ATECH data. 16 MR. J.R. MCKEE: And I'm sorry, what were 17 those again? 18 MR. GREGORY CROOKS: They were three 19 point five (3.5) C for drilling, nineteen point seven 20 (19.7) C for completion servicing, and one point three 21 (1.3) C for production. 22 23 (BRIEF PAUSE) 24 25 MR. J.R. MCKEE: Am I correct, sir, that
3679
1 you were using the draft EUBMODELS, that is the -- the 2 model tool that you were using in this particular run 3 that you are directing our attention to? 4 MR. GREGORY CROOKS: Yes, sir. 5 MR. J.R. MCKEE: And so that if I'm 6 reading this correctly, we're talking about a three point 7 four (3.4) kilometre for drilling, maximum? 8 MR. GREGORY CROOKS: That's correct. 9 MR. J.R. MCKEE: Three point seven (3.7) 10 for completion? 11 MR. GREGORY CROOKS: That's correct. 12 MR. J.R. MCKEE: And one point eight 13 (1.8) for production? 14 MR. GREGORY CROOKS: Yes, sir. 15 MR. J.R. MCKEE: All right. And, Mr. 16 Crooks, it probably comes as little surprise to you that 17 the other expert evidence that has been submitted in this 18 process and that we will hear more about in the coming 19 days, performed by RWDI, takes a different view with 20 respect to H2S dispersion modelling. 21 You understand that? 22 MR. GREGORY CROOKS: Yes, sir. 23 MR. J.R. MCKEE: And have you had the 24 opportunity of reviewing RWDI's report? 25 MR. GREGORY CROOKS: Yes, I have.
3680
1 MR. J.R. MCKEE: All right. Are you able 2 to tell us today, what the differences are, other than 3 they came to a different conclusion, what the differences 4 are in the approach and parameters that were used by 5 RWDI, and the ones that you've just outlined to me and 6 highlighted from Table 2? 7 MR. GREGORY CROOKS: In terms of in the 8 RWDI report, they're US EPA SLAB modelling, or their 9 EUB's modelling, sir, they had two (2) approaches in 10 their report? 11 MR. J.R. MCKEE: The SLAB modelling? 12 MR. GREGORY CROOKS: In their SLAB 13 modelling it's -- it's very much difficult to -- for me 14 to actually say what the input parameters were for their 15 modelling, because there was not enough detail in the 16 report for me to really evaluate what they did. 17 MR. J.R. McKEE: So, and -- if we went 18 through the checklist like I just did with you, ambient 19 temperature, drag coefficient and so on and so forth, 20 you're not able to tell me from the RWDI report what 21 those parameters were? 22 MR. GREGORY CROOKS: There are -- some of 23 the parameters are listed. For instance, in the RWDI 24 report they did use a range of drag coefficients from 25 zero (0) to two (2). I believe, and I would have to
3681
1 double check, that they do say they used ambient 2 temperature of fifteen (15) degrees C., but they do not 3 provide the stagnation temperatures that they utilized 4 for their modelling, nor do they provide any of the other 5 input parameters that you would need to be able to 6 evaluate the US EPA SLAB model, such as the density of 7 the -- of the release that's input into the model, the 8 area of the release and so on. 9 MR. J.R. McKEE: So if I asked you to 10 compare and contrast, to use my Grade 12 Social teacher's 11 favourite exam question, the -- the report that you -- 12 that Jacques Whitford had prepared and the RWDI report, 13 you wouldn't be in a position to do that, I'm guessing? 14 MR. GREGORY CROOKS: No, sir. 15 MR. J.R. McKEE: But the parameters that 16 we are aware of, perhaps we could talk about those. 17 You've used a drag coefficient of one (1), that's 18 correct? 19 MR. GREGORY CROOKS: Yes, sir. 20 MR. J.R. McKEE: And RWDI used something 21 from zero (0) to two (2). Are you able to explain why 22 you feel that a drag coefficient of one (1) is the 23 appropriate drag coefficient to use for this particular 24 circumstance? 25 MR. GREGORY CROOKS: Certainly, sir.
3682
1 This comes back a little bit to the whole philosophy of 2 how we conduct a hazard assessment. When we're -- when 3 we're determining these emergency planning zones, we base 4 our analysis on a reasonable worse case scenario. 5 Now, if you were to ask six (6) different 6 experts, you'd -- you could probably get seven (7) 7 different opinions on what the worse -- reasonable worse 8 case scenario is. 9 MR. J.R. McKEE: I believe we've heard 10 them all, sir, over the years. 11 MR. GREGORY CROOKS: My personal feeling 12 is that within EUBMODELS and the methodology it takes for 13 accounting for drag coefficient is that a drag 14 coefficient of two (2) is very much on the conservative 15 side, because it doesn't allow for ambient entrainment of 16 air to dilute the plume due to -- due to impingement on 17 an object. 18 So my view, really, is that -- and one of 19 the whole -- let me, actually digress for one second, is 20 that one of the whole objectives of the EUBMODELS is to 21 come up with a standardized approach so that we're 22 avoiding these sorts of discussions and arguments. 23 And to my point of view, the default 24 values that are provided in EUBMODELS provides to me, 25 what the EUB considers to be an appropriate, reasonable
3683
1 worse case scenario. 2 The only places that we changed the 3 default parameters in our modelling were where we 4 actually improved the science. We put in the -- the real 5 stagnation temperatures, rather than a default one which 6 is something that the model specifically says you can do 7 and that improves the science of our -- of our 8 simulation. 9 The other thing that we looked at was the 10 ignition time and we have, based on -- on some of the 11 other experts on the panel, a pretty good understanding 12 that a -- a shorter ignition time, seven and a half (7 13 1/2) minutes is -- is easily achievable. 14 So to my point of view, that is probably 15 the best approach -- is to say -- is to look at what is 16 in the model right now and say that that is a reasonable 17 worse case scenario. 18 MR. J.R. McKEE: Okay. So when we're 19 talking about a drag coefficient, and I remember Mr. 20 Kenny's explanation of -- of that -- that notion and I 21 was hanging on to it by a thread, but is there any sort 22 of consideration of the actual well site or the actual 23 things that -- that would likely be encountered when 24 you're deciding on what an appropriate drag coefficient 25 is?
3684
1 MR. GREGORY CROOKS: Well, one of the -- 2 one of the -- again this goes back to how do we define a 3 reasonable worse case scenario, is that the drag -- the 4 idea of the drag coefficient in the modelling, is that it 5 accounts for when you have a release, the plume impinging 6 on an object and hitting an object and then it takes some 7 of the velocity out of our jets. 8 Now depending on -- on the orientation of 9 your jets and the equipment around -- around your sites, 10 you may or may not have impingement at all, or you may 11 have some impingement or you may have more impingement, 12 you know. 13 So, it's one of those parameters that's 14 very much hit and miss in terms of whether you actually 15 will have it or not. So, that's why it becomes very 16 difficult to say what is -- what is the most appropriate 17 and we end up having these sorts of arguments between 18 experts about what level of conservatism we need to put 19 in the model. 20 MR. J.R. MCKEE: To the -- to the -- the 21 more simpleminded, and I could myself amongst those 22 numbers, can it be -- can we look at the two (2) drag 23 coefficients and say, well, we'll use the drag 24 coefficient of one (1), the next result usually is in a 25 smaller zone.
3685
1 If we use two (2) then usually what that's 2 going to result in is a somewhat larger zone. Does it 3 always follow that those two (2) conclusions follow? 4 MR. GREGORY CROOKS: Not necessarily. 5 It's, again with very much in dispersion modelling it's - 6 - it's the reason why we run a lot of scenarios, for 7 instance, is because some things aren't intuitively 8 obviously. 9 So, I wouldn't want to go on the record 10 and say that a drag coefficient of two (2) will always 11 give you a larger EPZ number than a drag coefficient of 12 one (1). It's going to be somewhat dependent on other 13 release characteristics as well. 14 MR. J.R. MCKEE: Now, the ambient 15 temperature of five (5) degrees, can you -- can you 16 advise me as to why you feel that's a reasonable 17 temperature to use? 18 MR. GREGORY CROOKS: That is the annual 19 average temperature for Calgary. 20 MR. J.R. MCKEE: Was there any, in your 21 models that you've run, and I apologize I appreciate this 22 is some -- much of this work was done before you arrived, 23 but there's been talk here amongst earlier Panels and 24 this Panel and the various parties questioning about the 25 time of year, the better time of year.
3686
1 Is there a better time of year to be doing 2 this drilling? Can you -- can you tell me, when you say 3 five (5) degrees centigrade is the average temperature 4 for this particular area, that's -- that's a three 5 hundred and sixty-five (365) day, sort of, calculation; 6 is that correct? 7 MR. GREGORY CROOKS: Yes, sir. 8 MR. J.R. MCKEE: So, if we were to say to 9 you, well, we know that these wells -- or these wells 10 will likely be drilled between the months of July and 11 September, although most of us who live in Calgary 12 probably wouldn't argue too much about a 5 degree average 13 temperature, would it -- would it change then the 14 appropriate ambient temperature that you'd be using in 15 the model? 16 MR. GREGORY CROOKS: Potentially. If -- 17 if we had an actual timeframe that we could actually 18 stick our hats on. But, I would also like to note that 19 we did do some sensitivity studies on temperature as well 20 just to see what the effects were and we varied the 21 temperature going up to plus fifteen (15) and down to 22 minus five (-5) degrees C and found very little 23 sensitivity with respect to the model predictions on 24 that. 25 And we also have to look at the
3687
1 temperature with respect to the worst case conditions 2 that are, or sorry, the meteorological conditions that 3 are producing our worst case predictions of the EPZ 4 distance. 5 And in all of our cases and it's -- it's 6 true in -- in most releases is that these are due to 7 stable conditions which are generally when you have the 8 least favourable dispersion characteristics of the 9 atmosphere. 10 And typically stable conditions occur 11 during nighttime and during cold conditions. So, if you 12 were to actually look at the average temperature when we 13 have these types of meteorological conditions, the 14 temperature is actually quite a bit lower -- the average 15 temperature is actually quite a bit lower than five (5) 16 degrees C. It's -- I think it's running around minus one 17 (-1) or zero. 18 MR. J.R. MCKEE: Mr. Chairman, I wonder 19 if this might be a good time to take the afternoon break? 20 THE CHAIRPERSON: Yes, I agree. We will 21 now take our twenty (20) minute break and we'll return at 22 twenty (20) minutes to 4:00. 23 24 --- Upon recessing at 3:19 p.m. 25 --- Upon resuming at 3:51 p.m.
3688
1 THE CHAIRPERSON: Thank you. Please be 2 seated. 3 MR. J.R. MCKEE: Thank you, Mr. Chairman. 4 5 CONTINUED BY MR. J.R. MCKEE: 6 MR. J.R. MCKEE: Mr. Crooks, I just want 7 to briefly flip back for a moment. I wonder if you could 8 look at the response to undertaking which has been marked 9 as Exhibit 039-034(b)? 10 THE CHAIRPERSON: Did you say (e) or (b)? 11 MR. J.R. MCKEE: (b), I'm sorry. B as in 12 Bob. 13 THE CHAIRPERSON: Thank you, sir. 14 MR. GREGORY CROOKS: Yes, sir. 15 16 CONTINUED BY MR. J.R. MCKEE: 17 MR. J.R. MCKEE: Now, just a question on 18 the second page of the undertaking. And -- and indeed 19 attached to the undertaking there's some preliminary 20 notes that were taken when the first discussions were 21 taking place between Jacques Whitford and Compton with 22 regards to this work. 23 And I appreciate, Mr. Crooks, that you 24 weren't party to it and you weren't there but I noted 25 that initially it was suggested or it was Jacques
3689
1 Whitford's intention to used the CALPUFF dispersion model 2 for the S02 modelling. And in fact that changed and then 3 ISC model was used. 4 Are you familiar with the reasons that 5 went into changing the -- the modelling? 6 MR. GREGORY CROOKS: I can make a -- an 7 estimate based on what's written down here. I -- I can't 8 say for -- with 100 percent certainty. But I can give 9 you my best -- 10 MR. J.R. MCKEE: All right. Fair enough. 11 MR. GREGORY CROOKS: -- understanding 12 which is -- I would say that based on what Dr. Preston 13 has put in here. She was thinking of using the CALPUFF 14 model if the concentrations within our -- our domain that 15 we were using with ISC RTDM were -- were still greater 16 than twenty (20) PPM to one (1) ppm. 17 If -- in which case we would've had to 18 have gone to a much larger domain to determine what the 19 extents of the one (1) ppm level was. And when you get 20 in to a much larger domains than what we were using with 21 the ISC model, you have to go to a different model which 22 accounts for the -- for the fact that as you go farther 23 and farther away from the source, the -- we have what we 24 call causality which is the travel time increases as 25 well.
3690
1 And models like ISC are generally 2 considered to be valid for twenty (20) kilometres or less 3 from the source. Whereas a model such as CALPUFF which 4 is not a Gaussian plume model but a Gaussian puff model, 5 would be valid for a much larger range of -- of distances 6 from the source. 7 MR. J.R. MCKEE: Thank you. Mr. Kenny, I 8 wonder if you could have a look at the RWDI report that 9 Mr. Crooks and I were just examining and it's attached in 10 Exhibit 00311 at Schedule A. And in particular page 12 11 of the RWDI model reports. 12 13 (BRIEF PAUSE) 14 15 MR. J.R. MCKEE: It's Section 3.2. Do 16 you have it there, sir? 17 MR. JOSEPH KENNY: Yes, yes, I do. 18 MR. J.R. MCKEE: And this is the 19 reservoir and the wellbore deliverability calculations. 20 Sir, have you had the opportunity to review that section 21 of the RWDI report? 22 MR. JOSEPH KENNY: Yes I have reviewed 23 it. 24 MR. J.R. MCKEE: Sir, do you have any 25 assistance you can provide and again I'm using the phrase
3691
1 that I used with Mr. Crooks, comparing that with the work 2 that ATECH did in this matter. Are you able to -- to 3 assist with an -- a comparison of the ATECH work versus 4 this particular aspect of the RWDI report? 5 MR. JOSEPH KENNY: I recognize some of 6 the inputs that -- that are in this report that came from 7 onsite wellbore geometry, some of the samprias (phonetic) 8 inputs but when you asked me, like, I'm not sure what -- 9 MR. J.R. MCKEE: Well -- 10 MR. JOSEPH KENNY: -- you're asking. 11 MR. J.R. MCKEE: I guess, again, it goes 12 back to our attempt to try and be able to understand the 13 differences between the professional opinions that are 14 being offered to us by both yourself and Mr. Crooks 15 versus the ones being offered by RWDI. 16 And I'm wondering if you are in a position 17 or whether there's sufficient information for you to 18 explain the differences in calculations that ATECH 19 arrived at versus RWDI? 20 MR. JOSEPH KENNY: Yeah, well, it's not 21 clear to me from this report what calculations and where 22 the comparison might be made. I mean, what we were told 23 was that -- that they used our source characterization. 24 My impression is when they said that they 25 were using our source characterization at the sand face
3692
1 and -- and that they were using some model that was 2 reporting conditions at -- at the -- at the well head 3 what -- what -- what they used I'm not sure and what -- 4 what conditions they were reporting for the well head 5 isn't too clear for me in this report either. 6 MR. J.R. MCKEE: All right. So, similar 7 to what Mr. Crooks advised us, there's not sufficient 8 detail there for you to -- to, sort of, provide a 9 comparative analysis? 10 MR. JOSEPH KENNY: Yes. 11 MR. J.R. MCKEE: Now, Mr. Crooks, I 12 wonder if you could look at what's been marked as Exhibit 13 039-33? 14 MR. GREGORY CROOKS: Yes, sir. 15 MR. J.R. MCKEE: And, in particular, 16 Table 1? 17 MR. GREGORY CROOKS: Yes, sir. 18 MR. J.R. MCKEE: Now, in Table 1 what we 19 have is a summary of input parameters used for 20 calculating well head stagnation temperature and you'll 21 recall this was some work that you did at the request of 22 the Panel Chair; you recall that? 23 MR. GREGORY CROOKS: Yes, sir. 24 MR. J.R. MCKEE: And I'm looking here at, 25 in the completion servicing and, specifically, the
3693
1 calculated stagnation temperatures in the completion 2 servicing area; do you see that? 3 MR. GREGORY CROOKS: Yes, sir. 4 MR. J.R. MCKEE: And it would appear that 5 you've used a -- a completion servicing temperature of 6 nineteen point seven five (19.75) for the fifteen hundred 7 (1500) metre well -- horizontal well length; is that 8 right? 9 MR. GREGORY CROOKS: That's correct. 10 MR. J.R. MCKEE: Four point six (4.6) for 11 the thousand (1,000)? 12 MR. GREGORY CROOKS: That's correct. 13 MR. J.R. MCKEE: And thirteen point four 14 (13.4) for the five hundred (500)? 15 MR. GREGORY CROOKS: That's right. 16 MR. J.R. MCKEE: And I think you told me 17 as well that these calculated stagnation temperatures 18 were provided to you from ATECH; is that right? 19 MR. GREGORY CROOKS: The calculated 20 stagnation temperatures were provided by ATECH. As well, 21 I -- I took the data that was provided by ATECH for the E 22 Plane temperatures exit velocity, mass fractions and 23 replicated those stagnation temperatures as well myself. 24 MR. J.R. MCKEE: All right. Now, in the 25 case that I asked you earlier, the one that you pointed
3694
1 us to that being the one (1) particular run that you feel 2 the best, the most comfortable in suggesting as the most 3 representative, I think you told me that for the 4 completion scenario you used the stagnation temperature 5 of nineteen point seven (19.7); is that right? 6 MR. GREGORY CROOKS: Yes, sir. 7 MR. J.R. MCKEE: All right. Now, I'm 8 just curious, given the, sort of, conservative, worst 9 case scenario approach to the modelling, why you would 10 have chosen the nineteen point seven five (19.75) 11 stagnation temperature rather than the four point six 12 (4.6) that we see here as -- as also coming from ATECH? 13 MR. GREGORY CROOKS: I guess maybe it's a 14 little bit of semantics but when you were asking your 15 question before, sir, I -- I wasn't thinking of this 16 particular undertaking. 17 I thought we were referring to our 18 previous submissions. Certainly if you look at the 19 values here when we look at the shorter wellbore length, 20 we do get, for CD of a drag coefficient of one (1) for an 21 eight (8) minute release a marginally larger distance for 22 the EPZ for the thousand (1,000) metre case than we do 23 for the fifteen hundred (1500) metre case which is what 24 our -- the previous work was based upon. 25 MR. J.R. MCKEE: Sorry, I'm not sure that
3695
1 I understand what you're telling me then. It -- again, 2 and just so that we are clear I asked you, and whether it 3 came from the work that was done previous or it came from 4 work that you've done as a result of requests made here, 5 what I was hoping to get you to do was point me to one 6 (1) particular -- 7 MR. GREGORY CROOKS: Okay. 8 MR. J.R. MCKEE: -- set of parameters 9 that you feel is the most representative. 10 MR. GREGORY CROOKS: Sure. Yeah. Well, 11 definitely, if we take into consideration these data 12 here, that we have here for the different wellbore 13 lengths, then certainly the thousand (1,000) metre case 14 gives us a slightly larger number for the distance to the 15 EPZ. 16 So, that would be the appropriate number 17 to take. 18 MR. J.R. MCKEE: All right. Thank you. 19 Mr. Kenny, I think we -- I'm pretty sure 20 you were asked this before and I'm just wondering if we 21 could just briefly revisit this, on these calculated 22 stagnation temperatures in Table 1 -- and I apologize, 23 we're looking at Exhibit 039-033, Table 1. 24 And with respect to the stagnation 25 temperatures that we see on the completion servicing
3696
1 scenarios, that -- I believe you were asked before and 2 I'm wondering if I could -- could trouble you again to 3 explain, or least provide us with your advice as to the 4 difference, the variance, that we see between the -- the 5 fifteen hundred (1,500) metre length and the -- the one 6 thousand (1,000) and then again the five hundred (500). 7 We seem to have that and I believe that 8 the camel analogy is -- we used to -- to discuss that 9 previously. Are you -- are you able to offer an 10 explanation as to -- as to the differences? 11 MR. JOSEPH KENNY: Yeah. As I pointed 12 out in -- previously, the -- in the fifteen hundred 13 (1,500) metre case we have a lot more and -- mass of fuel 14 -- a lot more enthalpy being taken up from the bottom of 15 the reservoir to the top as the gas is travelling up the 16 wellbore. And this -- only a certain amount of heat that 17 can be lost out of the wellbore, right, relative to the 18 smaller flow rates. 19 So, for giving those sort of wellbore 20 conditions, there's more enthalpy ending up at the exit 21 plain and during that full process at those higher rates. 22 As the rates -- as you see, as the rates get -- as we go 23 down into the thousand (1,000) metre five hundred (500), 24 our rates are starting to approach those that we're 25 seeing in the drilling case and the temperatures tend to
3697
1 approach those of -- of the drilling case at the -- at 2 the end -- exit plain and, as I say, have an affect on 3 the stagnation temperature. 4 And -- and, of course, it's a complex 5 problem, I mean, in the west. That's -- there are other 6 factors come into play and you're solving them on linear 7 -- linear problem with equations of state and the fluid, 8 you know, hold up -- liquid hold-up correlations, multi- 9 phase flow correlations are all interplaying too at those 10 different ranges as the fluid's going up the wellbore. 11 MR. J.R. MCKEE: I'd like to talk a 12 little bit about pressure safety valves. I know they're 13 -- Mr. Mrochuk, is this your -- your bailiwick? 14 MR. WADE MROCHUK: Sorry? 15 MR. J.R. MCKEE: Pressure safety valves, 16 is this your area? 17 MR. WADE MROCHUK: Yes, it is. 18 MR. J.R. MCKEE: There's been talk 19 previously about a -- about the flare stack and I'm 20 wondering how -- and I believe from previous testimony 21 there was a flare stack of thirty-six (36) metres being 22 proposed; is that correct? 23 MR. WADE MROCHUK: Are you referring to 24 the production testing scenario after the completion? 25 MR. J.R. MCKEE: Yes.
3698
1 MR. WADE MROCHUK: Yes. 2 MR. J.R. MCKEE: Okay. Why was that 3 particular height chosen? 4 MR. WADE MROCHUK: I -- I think it's a -- 5 a fairly standard height for production testing 6 situations. It's -- it's a height of stack that's 7 probably readily available and it gives us sufficient 8 height so that if we did get into an emergency relief 9 case with any of the pressure vessels, then your -- your 10 radiant heat is -- is going to be far enough off the 11 ground that it's going to be, you know, away from 12 personnel, and things like that. 13 MR. J.R. MCKEE: And are you aware, has 14 there been any dispersion modelling performed for any 15 sort of dispersion coming from this flare stack? 16 MR. WADE MROCHUK: Not to my knowledge, 17 no. 18 MR. J.R. MCKEE: Mr. Crooks, have you 19 been asked to perform any such modelling? 20 MR. GREGORY CROOKS: No, sir. 21 22 (BRIEF PAUSE) 23 24 MR. J.R. McKEE: Mr. Crooks, I seem to 25 recall there was some discussion with you with regard to
3699
1 risk analysis or risk assessment. 2 Have you had the opportunity of reviewing 3 the RWDI risk assessment report? 4 MR. GREGORY CROOKS: Yes, I have, sir. 5 MR. J.R. McKEE: I wonder, do you have an 6 opinions or any observations that you wish to share with 7 us regarding that risk assessment report? 8 MR. GREGORY CROOKS: I guess there are a 9 couple of observations that I'd like to make on it. One 10 is that it's very difficult to determine the level of 11 conservatism that is in this report because their risk 12 assessment is based on their EPA SLAB modelling and 13 again, we do not have sufficient information to be able 14 to replicate that modelling to be able to really 15 understand what levels of conservatism were involved in 16 that. 17 With respect to some other aspects of the 18 reports, I would -- I tend to find the assumptions that 19 were made quite conservative and in terms of not counting 20 for some frequencies that have been recognised by the 21 Board as being important in doing a risk assessment. 22 MR. J.R. McKEE: Can you provide me with 23 some examples? 24 MR. GREGORY CROOKS: One example of that 25 is a critical -- critical sour well factor which is to
3700
1 account for the fact that the frequency of occurrence of 2 blowouts of critical sour wells are quite a bit less than 3 a regular sour well. 4 The number that's typically used to 5 account for that is a reduction in frequency by a factor 6 of four (4). RWDI did not include that in their -- in 7 their calculations as far as I can determine, based on 8 the data that's provided in their report. 9 They use blowout frequencies which are 10 based on all sour wells as opposed to critical sour 11 wells, and I think as Mr. Bissett has mentioned in the 12 past, there actually hasn't been a blowout of a critical 13 sour well since the regulations came into effect which 14 provided for greater safety measures in terms of drilling 15 those wells. 16 So not using a reduction factor in the 17 frequency is, I think, highly conservative. 18 Another level of conservatism in their 19 modelling, in the risk assessment, is that they assume 20 that the release is always horizontal. That's fine for 21 doing a hazard assessment, in fact, that's part of the 22 reasonable worse case scenario -- standard reasonable 23 worse case scenario that we look at. 24 But in reality, not all well blowouts are 25 horizontal releases. Some of them are vertical and you
3701
1 can also have releases that are somewhere between 2 vertical and horizontal and that has a significant effect 3 on the dispersion of the -- of the plume. 4 Typically, the concentrations that we see 5 in vertical releases are quite a bit lower than those in 6 horizontal releases. So not accounting for the frequency 7 of horizontal versus vertical releases, is again quite 8 conservative in my view. 9 MR. J.R. McKEE: Anything else? 10 11 (BRIEF PAUSE) 12 13 MR. GREGORY CROOKS: Again, I would say, 14 if we go back to the drag coefficient question, again 15 we're looking at -- at the highest drag coefficient 16 which, again, may or may not occur. 17 As we discussed, you may have plume 18 impingement, you may not. So always assuming an 19 extremely conservative plume impingement is over- 20 estimating the risks. 21 Also with the wind speeds that are used in 22 the RWDI reports, they have categorised their wind speeds 23 into six (6) combinations of stability and wind speed and 24 that tends to -- and they've done it in a fairly 25 conservative matter, so that tends to over-estimate the
3702
1 occurrence of worse case meteorological conditions. 2 So that again is another level of 3 conservatism in the analysis. 4 MR. J.R. McKEE: And you say beyond that, 5 it's difficult for you to assess because you aren't able 6 to determine some of the other parameters, some of the 7 other factors that were being used? 8 MR. GREGORY CROOKS: That's right. In 9 terms of the dispersion modelling that -- that is used as 10 an input into the risk assessment. 11 MR. J.R. McKEE: So it's the same as we 12 were talking about before the break in terms of the 13 parameters that went into the dispersion modelling? 14 MR. GREGORY CROOKS: Yes, sir. 15 MR. J.R. McKEE: And so the same 16 difficulties that you find in analysing or reviewing 17 their work in dispersion modelling are -- are hampering 18 your analysis of their risk assessment; is that fair? 19 MR. GREGORY CROOKS: Yes, sir. 20 MR. J.R. McKEE: Okay. Mr. Bissett...? 21 MR. RICHARD BISSETT: Yes, sir. 22 MR. J.R. MCKEE: There's been a lot of 23 talk about the lighter, for want of a better word, the -- 24 for ignition, the third line of ignition? 25 MR. RICHARD BISSETT: Yes, sir.
3703
1 MR. J.R. MCKEE: I'm not sure I've 2 understood from previous discussions where in the scheme 3 of things the control for that particular device is going 4 to be located on the -- on the well site? 5 MR. RICHARD BISSETT: We anticipate 6 having -- having -- having two (2) safe briefing areas, 7 we'll say, opposed or cross-wind from each other so that 8 both Firefly units can be activated from those two (2) 9 locations. 10 We have, with respect to the igniter head 11 that we've been talking about, we need also to have the 12 igniter head activation switch at those two (2) 13 locations. It will be a keyed -- a key would be inserted 14 and turned to activate the -- the two (2) igniter heads 15 that would be located under the sub-structure. 16 So there would be two (2) remote controls 17 at these two (2) safe briefing areas right alongside the 18 Firefly controls. Also, we need a fuel gas line that -- 19 that will also be tied in to the -- to a nozzle under the 20 sub-structure that the two (2) igniter heads will -- will 21 -- will set on fire. 22 We haven't really decided yet whether 23 we're going to have one (1) location or we're going to 24 have two (2) locations. But, regardless, there will be a 25 locked valve on that line on the sweet gas supply line
3704
1 that'll have to be locked, unlocked and turned on. 2 We have considered in -- or discussed 3 anyways and haven't really decided yet that if -- if 4 there was an issue with the gas supply accidentally being 5 released under the sub-structure we could have a quick 6 disconnect and connect the line back up before it could 7 be activated. I don't like that. 8 But, nevertheless, it's a consideration. 9 Likewise, with the igniter heads cannot be energized if 10 they are disconnected from the battery packs. So they 11 could be disconnected as well. I don't like either of 12 those options, but for your information those are things 13 that we're talking about. 14 So, to activate the igniter heads will be 15 from two (2) safe briefing areas right alongside the 16 Firefly and we may have a gas valve, locked gas valve at 17 those two (2) locations or perhaps one (1) location 18 removed but, more than likely, the two (2). 19 MR. J.R. MCKEE: Thank you. 20 MR. RICHARD BISSETT: You're welcome. 21 MR. J.R. MCKEE: Mr. Follensbee...? 22 MR. GARY FOLLENSBEE: Yes. 23 MR. J.R. MCKEE: I've got a number of 24 questions with respect to the pipeline and I'll try and 25 be as direct as I possibly can in the interests of -- of
3705
1 getting through them. 2 Pipeline license 21027, what sections of 3 that particular pipeline license were inspected in 4 October of 2003? 5 MR. GARY FOLLENSBEE: That would be from 6 11 of 24, 22, 29 to 10 of 13, 22, 29. 7 MR. J.R. MCKEE: And that was an inline 8 inspection? 9 MR. GARY FOLLENSBEE: That's correct. 10 MR. J.R. MCKEE: And were any repairs 11 conducted following that inspection? 12 MR. GARY FOLLENSBEE: There were three 13 (3) on the log. There was three (3) imperfections 14 identified. They were cut out and replaced and the 15 coupons were sent to Canspec for analysis. 16 MR. J.R. McKEE: Okay. And can you tell 17 me how much pipe was replaced? 18 MR. GARY FOLLENSBEE: No, I don't know 19 the exact footage that was replaced. I'm sorry. 20 MR. J.R. McKEE: During that in-line 21 inspection, were any other defects identified that -- 22 that were under the criteria for replacing that section 23 of pipe? 24 MR. GARY FOLLENSBEE: Could you repeat 25 the first part?
3706
1 MR. J.R. McKEE: During that in-line 2 inspection, were there other defects noted that were 3 under the criteria for replacement? 4 MR. GARY FOLLENSBEE: No, there weren't. 5 There were no -- the log only shows defects in Level -- 6 or Groups 2, 3 and 4 and there were no -- nothing below 7 Level 2 which is 25 percent. 8 MR. J.R. McKEE: And when is it 9 anticipated that there will be another in-line inspection 10 on that particular segment? 11 MR. GARY FOLLENSBEE: Well I think what 12 we're kind of building the plan for is to have a five (5) 13 year plan to inspect all our sour gas lines. So I guess, 14 worse case it would be another five (5) years. But we 15 haven't really finalized that plan. 16 We want to have a -- a laid out plan on 17 when -- when what sections, what pieces we're going to 18 inspect over the next few years. 19 MR. J.R. McKEE: What sort of -- sort of 20 considerations or rationale would go into determining the 21 timing for the next inspection or this program that 22 you're describing? 23 MR. GARY FOLLENSBEE: Well, as I 24 understand it, we use Canspec to help us with that, but 25 the kind of things that they're looking at would be flow
3707
1 velocities, liquid hold up, perhaps not of liquid at the 2 well's water, but the wells are producing indication from 3 the -- the various coupons or probes as to the degree of 4 corrosion they might think is going on, and perhaps if 5 it's in a line that has more sulphur -- elemental 6 sulphur, stuff like that. 7 So, we -- we do prioritize every year 8 which lines to look at. 9 MR. J.R. McKEE: And with respect to the 10 10 of 13 to A10-02 segment, when was that last 11 inspected? 12 MR. GARY FOLLENSBEE: I think -- excuse 13 me, I think it was in 2000 and it is on our schedule to 14 be re-inspected this summer or fall. 15 MR. J.R. McKEE: Okay. Were any repairs 16 necessary during that last inspection? 17 MR. GARY FOLLENSBEE: I don't think there 18 were, but there were a number of imperfections 19 identified. They were probably below the criteria at the 20 time. 21 MR. J.R. McKEE: And you say -- I'm 22 sorry, and you said that this was due for inspection this 23 year? 24 MR. GARY FOLLENSBEE: 2005, yes. It'd be 25 either in the summer or the fall.
3708
1 2 (BRIEF PAUSE) 3 4 MR. J.R. McKEE: Now, MPP, I'm gathering 5 is confident that the pipeline is suitable then, will be 6 able to withstand the increased pressures from the 7 increased production that would be coming from these 8 proposed wells. 9 Am I correct? 10 MR. GARY FOLLENSBEE: That's correct. 11 It's not currently operating at the MOP -- of the MOP 12 being about 7240 kPa I believe. 13 We've done a little bit of modelling that 14 suggests that for the incremental gas we're looking at, 15 that five twenty-four (524) E3-M3 per day that using the 16 same inlet pressures at the plant that we now see, that 17 we wouldn't expect to go much higher than 6300 kPa. 18 And I might add that the MOP of the line, 19 the 7240, is actually only about 44 percent of the yield 20 strength of the pipe and normal numbers suggest that we 21 could go to 60 percent of the yield strength and still be 22 well within a lot of the safety factors that are applied 23 to -- to these pipelines. 24 And that would equate to a number 25 somewhere around 9900 kPa. So we're really not, even at
3709
1 full MOP, we're really not putting a lot of stress on 2 that pipe. 3 MR. J.R. McKEE: And would that same 4 answer, I've asked you specifically about the pipeline 5 south beyond A10-02, is that a -- would you have similar 6 confidence? 7 MR. GARY FOLLENSBEE: Yes. 8 MR. J.R. McKEE: I wonder if you could 9 help me, on the 11 of 24, A10-02 section, is there a 10 sulphur dispersant presently being added? 11 MR. GARY FOLLENSBEE: Just if you could 12 hold on a minute? 13 MR. J.R. MCKEE: Certainly. 14 15 (BRIEF PAUSE) 16 17 MR. GARY FOLLENSBEE: I just can't seem 18 to locate but Mr. Mrochuk helped me out a little bit and 19 said we are putting in the sulphur dispersant in 11 of 20 24. And I believe we are at 10 of 13 as well. 21 MR. J.R. MCKEE: So, 10 of 24 and 10 of 22 13? 23 MR. GARY FOLLENSBEE: I'd have to check 24 10 of 13 but -- 25 MR. J.R. MCKEE: Okay.
3710
1 MR. GARY FOLLENSBEE: -- 11 of 24 for 2 sure. 3 MR. J.R. MCKEE: 11 of 24 and perhaps 10 4 of 13. How is it determined -- or how do you determine 5 whether sulphur dispersant should be -- should be added 6 or used? 7 MR. GARY FOLLENSBEE: I think from the 8 solids that we would get out of the pig trap on the 9 monthly pigging if we're seeing elemental sulphur and 10 also we're looking at, on the liquid analysis, if we're 11 getting polysulphides which, under some conditions, can 12 result in elemental sulphur dropping out. 13 MR. J.R. MCKEE: And that would be likely 14 the criteria you'd apply in the future? 15 MR. GARY FOLLENSBEE: Yes. 16 MR. J.R. MCKEE: I believe, Mr. Mrochuk, 17 Mr. Cover told me that this probably would fall in your 18 bailiwick and what I'm interested in is the criteria that 19 would be applied to establish when completion fluids have 20 been successfully recovered and that the well production 21 can safely re-enter the pipeline without further 22 separation. 23 Is that an area that you would determine? 24 MR. WADE MROCHUK: No, just in reference 25 to when we felt the wellbore fluids would be adequate to
3711
1 enter the pipeline instead of being recovered on -- on 2 lease? 3 MR. J.R. MCKEE: Yes. 4 MR. WADE MROCHUK: Historically, on these 5 inline tests that's been, I think, a decision that's been 6 made between the drilling completions department and -- 7 and MPP or whoever was the midstream or the plant and the 8 gathering system at the time. 9 And they were looking for -- for criteria 10 such as, you know, adequate ph levels of fluid for one. 11 Solids probably another. But, from the production side 12 of it, we historically haven't been party to those 13 conversations or setting the criteria for that. It's 14 been primarily between the plant operator, the gathering 15 system operator and the completions directly. 16 MR. J.R. MCKEE: Mr. Follensbee, do you 17 have anything to add to that? 18 MR. GARY FOLLENSBEE: I'm sorry, I was 19 thinking about my last question. If you could repeat 20 that? 21 MR. J.R. MCKEE: Not a problem. We were 22 just talking about the criteria for establishing when 23 there's been successful removal of completion fluids 24 recovered and the well production can be safely entered 25 into the pipeline?
3712
1 MR. GARY FOLLENSBEE: Right. Probably 2 two (2) conditions. When the ph is at six point five 3 (6.5). And, again, among other things is polysulphides 4 when the ph goes below six point five (6.5) that's when 5 the sulphur starts dropping out. But also, the -- the 6 acidic product is -- is bad for the coating, et cetera. 7 And the other one is the chlorides should 8 be down to about where we normally find them in that 9 pipeline. So I don't have an exact number but we would 10 look at perhaps that segment of pipe to see what 11 chlorides that normally experiences and that's about 12 where we're treating for -- for corrosion and mitigation. 13 So those two (2) criteria would govern 14 when we would let it in. And it's mostly the criterias 15 for the pipeline, not so much for the plant. 16 MR. J.R. MCKEE: Now, Mr. Follensbee, 17 which Compton Belly River wells that are north of 11 of 18 24 anticipated to be producing into this pipeline? 19 MR. WADE MROCHUK: I could probably 20 answer that. There's -- to the east there, there would 7 21 of 19 and 12 of 20 which are two (2) current Belly River 22 producers. And north of those of the Chestermere line as 23 you go further north, you see 6 of 29 and 11 of 29. 24 And then once you get further north of 25 that up to the Chestermere 10 of 21 battery, then you're
3713
1 into a mix of Belly River gas and some Turner Valley gas. 2 MR. J.R. MCKEE: And so what sort of 3 characteristics would we see in the -- the production 4 coming from those -- those wells? 5 MR. WADE MROCHUK: From the Belly River 6 producers it's -- it's primarily a sweet gas. We remove 7 free water on the site. We don't put Belly River water 8 into the pipeline because of compatibility issues with 9 the Crossfield water. So that's removed from site and 10 basically the only thing entering the pipeline is the -- 11 the sweet gas. 12 MR. J.R. MCKEE: And is there any 13 particular corrosion concerns that the production from 14 these wells bring to bear in the pipeline? 15 MR. WADE MROCHUK: Not -- no I -- I would 16 say no. It should be noted that the Turner Valley Gas 17 that enters the system further north on the pipeline 18 system is sour gas as well. It's, you know, 1 1/2 to 2 19 percent sour. 20 MR. J.R. MCKEE: Now, Mr. Follensbee, I 21 think you stated earlier that when the corrosion 22 management program is changed, or changes, they are in 23 fact reviewed and planned in advance by a group which 24 consists of the plant manager, the field production 25 foreman and the chemical supplier.
3714
1 How often does this management group 2 meet? 3 MR. GARY FOLLENSBEE: Well right now it 4 would be probably specific to when there -- when there's 5 a change identified on the -- the management of change 6 form. However, setting that aside, right now we -- I 7 believe we see the Baker guy out in the field every one 8 (1) or two (2) weeks. And he's got a pretty open 9 communication with the production manager. 10 And I believe we have a monthly report 11 from -- from Baker and the team meets to discuss the 12 corrosion mitigation efforts every two (2) months. 13 MR. J.R. MCKEE: So there's a regular 14 meeting every two (2) months? 15 MR. GARY FOLLENSBEE: I think that's 16 correct. 17 MR. J.R. MCKEE: And if the situation 18 warrants, is there meetings held more frequently than 19 that or as the situation requires? 20 MR. GARY FOLLENSBEE: Yes. If -- if 21 anything were to come up in -- in the testing analysis et 22 cetera, they would -- they would deal with that as it 23 arises. 24 MR. J.R. MCKEE: How important is that 25 the a fairly rapid change is adopted in a corrosion
3715
1 program if something's identified or a problem was 2 identified? 3 MR. GARY FOLLENSBEE: Well I think it 4 would be very important. I don't know, you know, the 5 rate of say if there were a -- a corrosion event 6 happening at the rate of growth. But certainly some of 7 these lines that we've inspected probably suggest that 8 it's taking quite a while. 9 But I think as soon as we -- we find out 10 something has deviated from where we expect it to be, 11 then it -- and we're a pretty small shop, it's just not - 12 - hard for us to address it right away. 13 MR. J.R. MCKEE: Corrosion is a fairly 14 rapid progressing problem, is it not? 15 MR. GARY FOLLENSBEE: Can be. It can be 16 under certain circumstances. 17 MR. J.R. MCKEE: And so -- I'm sorry. 18 MR. GARY FOLLENSBEE: We -- we spend, I 19 mean that's -- of our production group that's their top 20 priority. They spend more time and money on that than 21 anything. 22 MR. J.R. MCKEE: So a timely response or 23 timely change in the program is -- is critical as -- 24 perhaps as critical what you -- what you actually end up 25 doing about it, is that fair?
3716
1 MR. GARY FOLLENSBEE: Yes. 2 MR. J.R. MCKEE: Does MPP Management 3 support and -- and support the costs necessary for 4 maintaining the corrosion control activities? 5 MR. GARY FOLLENSBEE: Yes. We actually 6 have a significant portion in the MPP budget every year 7 for chemicals and in-line inspection, that's never been 8 questioned. 9 MR. J.R. MCKEE: Now, would you consider 10 it reasonable that should these wells be approved, that a 11 pressure test or inspection should be conducted on the 12 section of pipeline from 10 of 13 to A10-02, keeping in 13 mind the new -- the new pressures that might be present? 14 MR. GARY FOLLENSBEE: Could you repeat 15 that, I didn't quite catch the -- 16 MR. J.R. MCKEE: I'm just wondering 17 whether you -- whether you or MPP consider it reasonable 18 that if these wells are approved and the pressure on the 19 line from 10 of 13 to A10-02 is increased, that there 20 should be a -- a pressure test or an inspection prior to 21 that increase in pressure. 22 MR. GARY FOLLENSBEE: Hum. Well, I -- I 23 think -- I haven't seen the results of, obviously, of the 24 next set of logs on the portion from 10 of 13 to 10 of 2, 25 so. But, you know, from what we saw from 11 of 24 to 10
3717
1 of 13, where we were seeing no -- no wall loss and, in 2 fact, that we're well under the yield strength of the 3 pipe, that I'm not sure that a pressure test is going to 4 add anything. 5 It will give people comfort. And if it 6 was the decision of the Board to have that, well, 7 certainly we would do it. 8 MR. J.R. MCKEE: So, it's currently not 9 planned but it's something that you would consider doing? 10 MR. GARY FOLLENSBEE: That's correct. 11 MR. J.R. MCKEE: Just one moment, sir. 12 13 (BRIEF PAUSE) 14 15 MR. J.R. MCKEE: My apology, gentlemen. 16 MR. GARY FOLLENSBEE: Well, Mr. McKee, 17 Mr. Mrochuk suggests that I used the term "imperfection" 18 and I should maybe clarify that again for the folks. I 19 think I've covered it once before but. 20 Under the Code that's just something that 21 looks like it could be a defect and until it doesn't meet 22 the requirements of Z-662. It's not a defect, it's 23 just -- 24 MR. J.R. MCKEE: And I remember you 25 pointing that out earlier. Thank you, Mr. Follensbee.
3718
1 Mr. Mrochuk, there's been some discussion 2 of the -- the line heaters and such that would be 3 necessary on this site should the wells be licenced and - 4 - and drilled. 5 MR. WADE MROCHUK: Yes. 6 MR. J.R. MCKEE: Is there any -- any 7 advantage to using fewer larger pipeline heaters rather 8 than individual heaters? 9 MR. WADE MROCHUK: That's something that 10 has been explored and is something that may continue to 11 be explored once we get into the actual design phase of - 12 - of this -- of the construction. 13 What individual line heaters do for you is 14 -- is flexibility. You have one (1) line heater attached 15 to one (1) well and -- rather than, let's say, one (1) 16 line heater -- a larger line heater for three (3) wells. 17 That takes away a little bit of your operational 18 flexibility, in that if you lost that line heater you 19 would be shutting in three (3) wells as opposed to just 20 the well that it's devoted to. 21 MR. J.R. MCKEE: Okay. 22 MR. WADE MROCHUK: You would still 23 require pretty much the -- the same BTU capacity 24 regardless if you went with the two (2) big ones or six 25 (6) smaller ones.
3719
1 MR. J.R. MCKEE: Well, noise issues, 2 would that be improved at all by going that route as 3 opposed to the individual ones. 4 MR. WADE MROCHUK: Noise-wise, line 5 heaters are pretty benign. There's not a lot of noise 6 associated with the line heater. It's not like a piece 7 of rotating equipment like a compressor, for example, 8 where you've got significantly more noise. 9 MR. J.R. MCKEE: Thank you. Mr. Bissett, 10 I want to throw this one at you and I'm not sure that 11 you're the right fellow. I think the empty chair between 12 you and Mr. Longfield is where this should probably go 13 and if that's the case please tell me. 14 But I -- I'm wondering if there is, within 15 the -- the current program, a program for corrosion 16 protection of tubulars and -- and well casing? 17 MR. RICHARD BISSETT: Yes, that, I think 18 properly, would be addressed to Mr. Cover. 19 MR. J.R. MCKEE: Fair enough. 20 MR. DEREK LONGFIELD: I believe -- I 21 believe he did cover it in testimony but that's fine. 22 MR. J.R. MCKEE: Mr. Longfield, I wonder 23 if you could turn to Exhibit 002-01(b) and, Mr. Chairman, 24 I believe -- that's -- the portion I'm looking at is 25 attachment 3 which is electronic page 149 of that
3720
1 attachment. 2 3 (BRIEF PAUSE) 4 5 MR. DEREK LONGFIELD: Yes, I have it. 6 Thank you. 7 MR. J.R. MCKEE: You have it? I'm sorry. 8 And the document, just so that we're looking at the same 9 thing is "Information for Landowners, North Okotoks 10 Horizontal Well Program June 2002" and I believe that's 11 Attachment 3 on that exhibit? 12 13 (BRIEF PAUSE) 14 15 MR. DEREK LONGFIELD: Yes, I have it. 16 Thank you. 17 MR. J.R. MCKEE: Okay. I wonder if you 18 could look at, past the title page, the first page, and 19 this was a handout, I'm guessing, at a -- an information 20 session; is that correct, or an open house? 21 MR. DEREK LONGFIELD: Yes, it was. As 22 well as, I believe, during the public consultation 23 program individual visits to residences. 24 MR. J.R. MCKEE: There is some discussion 25 there with respect to your setbacks or separation
3721
1 distances and there's a chart there; you see that there? 2 It should be on the first page, perhaps I -- 3 MR. DEREK LONGFIELD: Okay, I was in 4 Information for Residents, I'm sorry. And I'm not 5 certain, Mr. Bissett could confirm it, this was probably 6 available at the open house. I don't know if it was 7 handed out much. Is that important? 8 9 (BRIEF PAUSE) 10 11 MR. J.R. MCKEE: I'm sorry, Mr. Bissett, 12 were you able to confirm what this was used for? 13 MR. RICHARD BISSETT: Yes, sir. Just one 14 moment please? 15 MR. J.R. MCKEE: Certainly. 16 17 (BRIEF PAUSE) 18 19 MR. RICHARD BISSETT: Mr. McKee, this 20 information for landowner handout was -- was handed out 21 with the public disclosure and consultation program that 22 was -- that was completed and it's, as you say, in 23 Attachment 3 and the covering letter at the very start of 24 that section describes what was handed out and when. 25 MR. J.R. MCKEE: Thank you.
3722
1 MR. RICHARD BISSETT: Yes, sir. You're 2 welcome. 3 MR. J.R. MCKEE: So then, Mr. -- Mr. 4 Longfield, just below the chart there on the first page 5 there's a star and it states: 6 "The EUB may recommend that residences 7 be separated by three hundred (300) to 8 four hundred (400) metres from Level 3 9 and Level 4 sour wells." 10 I'm curious, Mr. Longfield, are you aware 11 of where that information came from? 12 MR. DEREK LONGFIELD: No, I'm not. I 13 didn't prepare that. Again, we may -- may have to look 14 to Bissett Resource Consultants. 15 MR. J.R. MCKEE: Did you prepare this, 16 Mr. Bissett, or your organization? 17 MR. RICHARD BISSETT: Yes, sir. We did. 18 And I'll have the answer here in a moment where that 19 passage came from. 20 MR. J.R. MCKEE: Thank you, sir. 21 MR. RICHARD BISSETT: You're welcome. 22 23 (BRIEF PAUSE) 24 25 MR. RICHARD BISSETT: Okay. Sorry about
3723
1 that, Mr. McKee. 2 MR. J.R. MCKEE: It's quite all right, 3 Mr. Bissett. 4 MR. RICHARD BISSETT: Guide 56 dated 5 October 2000, I believe it is. And then the Appendix 3 6 that's attached to that particular Guide 56 is ID 97-6 7 and that's on page 23. 8 The Table 2.1 is a summary of the minimum 9 distance requirements separating proposed sour wells from 10 residential and other developments and underneath that 11 table is a paragraph that talks about -- about the -- the 12 EUB, may recommend that residences be separated by three 13 (3) to four hundred (400) metres from Level 3 and 4 sour 14 wells. 15 MR. DEREK LONGFIELD: To be -- 16 MR. J.R. MCKEE: Thank you, Mr. Bissett. 17 MR. RICHARD BISSETT: Yes, sir, you're 18 welcome. 19 MR. DEREK LONGFIELD: To be exact it does 20 say three (3) to four (4) times the minimum distance, 21 Mr. McKee, I don't know if I heard that, but. 22 MR. J.R. MCKEE: Okay. Mr. Chairman, if 23 I might have two (2) minutes just to consult with staff 24 and -- 25 THE CHAIRPERSON: Certainly.
3724
1 MR. J.R. MCKEE: -- to make sure we've 2 caught up with everything. Excuse me. 3 4 (BRIEF PAUSE) 5 6 CONTINUED BY MR. J.R. MCKEE: 7 MR. J.R. MCKEE: There is light at the 8 end of the tunnel, gentlemen. 9 Mr. Longfield, just staying with that 10 document then for a moment. To my understanding, and it 11 is late in the day and I may be getting confused, but 12 it's -- it's considered that -- or it's well settled that 13 these wells will produce at a Level 2 classification; is 14 that -- is that correct? 15 MR. DEREK LONGFIELD: That's the 16 expectation, yes, sir. 17 MR. J.R. MCKEE: Okay. Now, looking 18 again at that document -- I'm sorry -- and you've put it 19 away now. 20 21 (BRIEF PAUSE) 22 23 MR. J.R. MCKEE: Okay. And if you turn 24 to the last page of that particular handout there's a bit 25 of a map there. And it's showing a five hundred (500)
3725
1 metre setback radius. Do you see that there? 2 MR. DEREK LONGFIELD: Yes, I see it. 3 MR. J.R. MCKEE: All right. Now, in -- 4 in the -- chart that we were -- on the first page, it 5 indicates that for dwellings and country developments -- 6 unrestricted country developments setbacks in a Level 2 7 would be one hundred (100) metres and I'm curious as to 8 why the map is -- is exhibiting a five hundred (500) 9 metre radius setback? 10 MR. DEREK LONGFIELD: Not having made the 11 map, I'm probably not the right person to answer. My -- 12 my view would be that it's representing the maximum set 13 back distance for urban recognizing adjacent land owners' 14 concerns about urban development in the time period that 15 these wells would be on production. 16 MR. J.R. McKEE: Okay. And I see Mr. 17 Bissett's nodding in agreement. Is that correct, sir? 18 MR. RICHARD BISSETT: Yes, sir, that's 19 correct. The public facility or an urban centre must be 20 outside the five hundred (500). So, typically, on -- on 21 these land owner set back maps, we will show the maximum 22 radius that comes out of the level of sour gas facility 23 separation table. 24 MR. J.R. McKEE: Mr. Longfield, we spent 25 a lot of time earlier today and indeed a lot of time over
3726
1 the last two (2) weeks talking about the ERP and we -- in 2 our discussions earlier today, when I asked Mr. Bissett 3 what parts of the ERP would require updating and -- and 4 changes prior to it being submitted to the Board for 5 final approval, he indicated basically everything. 6 We've heard it referred to as a living 7 document and what I've taken you to mean by that is that 8 the document has to be adaptable, it has to be able to 9 reflect the realities that it is meant to -- adheres to 10 at any point in time. 11 Is that what you mean when you -- when you 12 use that phrase? 13 MR. DEREK LONGFIELD: Which phrase am I 14 using? 15 MR. J.R. McKEE: The living -- the living 16 document. 17 MR. DEREK LONGFIELD: The living 18 document, yes. It's -- it's got to be current to the 19 time of the drilling operation, I guess. In response to 20 Mr. Bissett's "everything will be updated", I'm not 100 21 percent sure he was thinking updated or reviewed. I know 22 that everything will be reviewed. He's very thorough but 23 I don't know if that was some sort of commercial for -- 24 for him to secure a contract for us to re-write the whole 25 thing.
3727
1 And I -- I know that there are parts of 2 this and as I said, the basic structure is certainly -- 3 is certainly valid. I do agree that it needs to be 4 reviewed in its entirety but I would not be in agreement 5 that it needs to be entirely updated. 6 MR. J.R. McKEE: Okay. Mr. Bissett...? 7 MR. RICHARD BISSETT: Yes, I'll -- I'll 8 even add on to that. If you remember when this 9 discussion started, I believe the term was it has to be 10 re-completed. And I attempted to soften that language up 11 to say, well, the structure is there; it's sound. And we 12 will revise it or update as required by our new ground 13 truthing that's out there and, probably, every section 14 will be impacted to some degree by what we find out in 15 the area. 16 But, I'm most certainly not talking about 17 preparing a new emergency response plan. This one is -- 18 the structure is there, it's sound, it's doable and all 19 we're going to do is revise it; if that's soft enough 20 language? 21 MR. J.R. McKEE: Well, and that -- that 22 gets us to the point that I'm -- that I wanted to discuss 23 with you, is that -- that, you know, what does Compton 24 expect the Board in this process to do with the ERP that 25 it has before it?
3728
1 Now, we -- we appreciate that the final 2 approval is a process that will be ongoing and be dealt 3 with down the road. But is there -- is there not some 4 basic elements of the ERP which must be in evidence here 5 at this process for this Board to review and if nothing 6 else gain a sufficient comfort to consider the reduction 7 of the EPZ. Would you agree with that? 8 9 (BRIEF PAUSE) 10 11 MR. DEREK LONGFIELD: A real -- a real 12 simple answer is in our direct evidence on -- of this 13 Panel on page -- I have it on page 7, about line 29. 14 "This, in Compton's view should narrow 15 the focus of the issue as to whether 16 Compton's emergency response plan is 17 adequate to protect the public." 18 And that -- that's certainly -- certainly 19 the main issue at hand here. And the -- obviously, the 20 other issue is that we have identified in our direct 21 evidence that we realize that it cannot be approved at 22 this time and is -- for -- for many reasons, is going to 23 have to be a post -- post-Hearing approval. 24 MR. J.R. MCKEE: Is it -- is it Compton's 25 position that the ERP that is before the Board today
3729
1 contains the basic constituent elements that one would 2 expect to find in a workable and appropriate ERP? 3 MR. DEREK LONGFIELD: I'm going to say 4 yes but Mr. Brown's just chomping at the bit, so. 5 MR. RUSSELL BROWN: It contains the basic 6 and much more. 7 MR. J.R. MCKEE: Mr. Bissett...? 8 MR. RICHARD BISSETT: Yes, sir. I -- I 9 think we did touch up on the, you know, what -- what 10 would we expect of the EUB as far as -- as approving this 11 plan. And -- and I don't believe we're asking the Board 12 to approve it as it exists right now. 13 Because earlier on today we were talking 14 about -- about what would have to be done to upgrade it, 15 if you will, to build in issues and concerns that the 16 local authorities may have, and how long might that take. 17 And I think we've walked through our steps 18 there and said that before this document would be ready 19 for final approval, the -- the local authorities will 20 take a look at it. We will incorporated whatever 21 enhancements, improvements that they feel is necessary. 22 And then the final step would then -- the ERP would be 23 submitted to the EUB for final approval. 24 MR. J.R. MCKEE: But as it sits today, 25 there is, in Compton's view, sufficient detail,
3730
1 sufficient content that the Board could get the comfort 2 it requires to grant the reduced EPZ, grant the licences 3 on whatever conditions it chose to, comfortable in the 4 knowledge that the finished product will contain these 5 changes but will not be demonstrably different in 6 structure than the plan that we see before us today; is 7 that -- is that correct? 8 MR. DEREK LONGFIELD: You -- you're a 9 little more eloquent than I, so I would say that's a 10 pretty good encapsulation, Mr. McKee. 11 MR. J.R. MCKEE: Mr. Chairman, even 12 though I told My Friends I'd be something in the order of 13 three (3) hours, I did manage to get it in inside of one 14 (1) day. And subject to the undertakings, those are my 15 questions. 16 Thank you, gentlemen, for your frankness 17 and your answers. Thank you. 18 MR. RICHARD BISSETT: You're welcome. 19 THE CHAIRPERSON: Thank you, Mr. McKee. 20 At some point here in the next day or so 21 probably, we'll be asking for any updates that anybody 22 will have in terms of their estimates for direct 23 evidence. 24 The Board is trying to update its 25 calendar of hearing time and so on because the Board does
3731
1 have a number of other obligations. So, we want to see 2 where we're sitting with respect to those. So, you might 3 give that some thought. 4 The one thing, since we've got a few 5 minutes here today, is what I would like to know if -- I 6 know Mr. McLarty likely will have questions for every 7 Intervenor panel that's going up. 8 That's a fairly safe assumption, wouldn't 9 it be, Mr. McLarty? 10 MR. ALLAN MCLARTY: I would assume we 11 would have at least a couple of questions, yes, sir. 12 Thank you. 13 THE CHAIRPERSON: And so, my question is: 14 Do any of the Intervenor groups plan to cross-examine any 15 of the other Intervenor panels, so that we can have an 16 update in our schedule in that regard. 17 Mr. Secord...? 18 MR. RICHARD SECORD: No, sir. 19 THE CHAIRPERSON: So, everybody doesn't 20 need to come up to the mike, just to save time and 21 effort, but thank you, Mr. Secord. 22 So, if anybody is considering it or is 23 going to, if they would step forward. If not, I will 24 assume silence means nobody is planning to step forward. 25 MR. GAVIN FITCH: Mr. Chairman, my answer
3732
1 is, probably not. But there are some other Intervenors 2 whose evidence I'm going to be interested to listen to. 3 But, you know, even if I did have some 4 questions for some other Intervenors, I -- you know, I 5 can't imagine that it would be -- take very long. But 6 there are a couple that -- I don't know what they're 7 going to say and I'm interested to hear and depending on 8 what I hear, I might want to ask a couple of questions 9 anyways. 10 THE CHAIRPERSON: So, probably -- 11 MR. GAVIN FITCH: But I wouldn't think it 12 would add -- 13 THE CHAIRPERSON: -- less than an hour, 14 then, you would say? 15 MR. GAVIN FITCH: Oh, yeah, I would think 16 so. I really can't imagine it would add much time to the 17 process. 18 THE CHAIRPERSON: Okay, fair enough. Mr. 19 Laycraft...? 20 MR. JAMES LAYCRAFT: Mr. Chairman, I just 21 echo Mr. Fitch's comments. I wouldn't want to commit to 22 not asking any questions at all, but I would certainly 23 try to keep those to a minimum. 24 THE CHAIRPERSON: Sure. And just to be 25 clear, the Board is not asking anybody to make any
3733
1 commitments, you know, we'll still go down the line and 2 certainly, if you say you don't have many questions and 3 you actually do, that's fine too. 4 We're not limiting the -- or attempting to 5 limit the rights of any party to get all the information 6 I need. This is strictly a forecasting exercise. 7 MR. J.R. McKEE: Mr. Chairman, from 8 staff's point of view, we anticipate having some 9 questions for most of the Intervenors and it's difficult 10 to say at this time what sort of time frame we're looking 11 at. 12 THE CHAIRPERSON: Certainly, because I 13 know it depends on the people that go before you -- 14 MR. J.R. MCKEE: Yes. 15 MR. BRENT ROBINSON: The same goes for 16 us, Mr. Chairman, that depending on what the evidence is 17 of various other Intervenor panels, we may have cross- 18 examination but it shouldn't be of a exceptionally 19 extensive nature. 20 THE CHAIRPERSON: Okay, fair enough. So 21 that's helpful, just in our scheduling and just a 22 reminder tomorrow, we will start at 8:30 but we're just 23 going to take one (1) hour for lunch from 12:30 to 1:30 24 and we're going to adjourn at 4:30. 25 So, with that -- sorry, Mr. Fitch...?
3734
1 MR. GAVIN FITCH: Just one last question. 2 I'm assuming that in the morning, Mr. Chairman, we're 3 going to start with cross-examination on responses to 4 undertakings? 5 THE CHAIRPERSON: Yes, that is correct. 6 And thank you for bringing that issue forward. You're 7 correct. 8 Well, thank you. Have a good evening 9 everyone. We'll see you tomorrow at 8:30. 10 MR. RICHARD BISSETT: Thank you. 11 12 --- Upon adjourning at 4:57 p.m. 13 14 15 16 Certified Correct, 17 18 19 20 21 __________________ 22 Dustin Warnock 23 24 25