SECURE Energy Services Inc. Proposed Conklin Class II Landfill Portions of: NE W4, SE W4 and NW W4

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1 26 February 2016 RE: SECURE Energy Services Inc. Proposed Conklin Class II Landfill Portions of: NE W4, SE W4 and NW W4 Dear Sir or Madam, SECURE Energy Services Inc. ( SECURE ) is proposing to develop and operate an Alberta Environment and Parks approved Class II Industrial Landfill in the portions of: NE W4, SE W4 and NW W4. SECURE is taking this opportunity to notify you of the proposed project as public records indicate you are an occupant of lands in the proposed Conklin area. Information regarding the project is attached to this letter. Should you have any additional comments, questions or concerns, please do not hesitate to contact the undersigned at (403) or Mike Pittman, Manager, Environment & Regulatory, by phone at (403) , Ext 2590 or via (mpittman@secure-energy.com). Regards, SECURE ENERGY SERVICES R. (Bob) Clarke Business Development Representative Project Sponsor th Avenue SW, Calgary, Alberta T2P 2V7 Processing, Recovery & Disposal Drilling & Production Services OnSite Services

2 PROPOSED CONKLIN CLASS II INDUSTRIAL LANDFILL INTRODUCTION SECURE Energy Services Inc. (SECURE) is proposing to construct, operate, cap and monitor postclosure of the Conklin Landfill (the Project) and its associated infrastructure which includes a 1.45 km all-weather road, office trailer, scale, shop building, site roads, stormwater pond and discharge area, and tanks and pumps. The Project is a Class II Industrial Landfill for the disposal of non-hazardous oilfield solid wastes generated by the upstream petroleum industry. SECURE has prepared this Project information document to provide landowners, residents, government agencies and interested stakeholders with details about the proposed Project. Also attached as Appendix A is additional information on the Project with a site map. DESCRIPTION OF THE PROPOSED PROJECT NEED FOR THE PROJECT AND PROJECT DESCRIPTION: The upstream petroleum industry generates residual solid wastes from normal, ongoing operations, and these by-products ultimately require proper treatment and/or final disposal. SECURE has determined through discussions with producers in the vicinity that there is a need for an environmentally reliable solids disposal option in Conklin, Alberta. SECURE's Conklin Class II Industrial Landfill will accept non-hazardous solid wastes generated by producers in the area. The majority of the solids to be accepted at the Class II Industrial Landfill consist of drill cuttings, residual solids from spill cleanups, contaminated site cleanups, and residual solids from treatment processes. These solids are soil that are high in salts, may contain a moderate hydrocarbon component and may have metals or miscellaneous compounds in low concentrations. SECURE is not applying to accept municipal, hazardous, or dangerous waste. All waste accepted will meet Alberta Environment and Parks (AEP) criteria as non-hazardous wastes. PROJECT LOCATION: The Landfill site is situated approximately 5 km south on Hwy 881 from the Conklin, Alberta turnoff. The Landfill will be developed on a 110 ha. parcel occupying portions of the N 23, NW 24, SW 25 and S 26, of Twp. 76, Rge.8, W4M (Appendix 1 Detailed Project Information). Currently the site is forested with limited oil and gas activity. COMMUNITY BENEFITS: The Project will benefit the community by providing an opportunity for employment. The Landfill will employ a minimum of 6 full time employees. There are also potential construction opportunities, as well as contracting opportunities for trucking third party waste to the Project during operation. 1

3 Other benefits include a local option for solid waste truck traffic currently utilizing regional highways in the area. This will decrease the amount of time that commercial truck traffic are on the highways and reduce overall traffic and long term road damage. The upstream petroleum industry will benefit from reduced overall waste management costs due to shorter haul distances and reduced transportation costs. TRAFFIC AND NOISE: The Project s typical hours of operation will be 7 a.m. to 7 p.m. Approximately trucks are expected as a daily average. The access to the Project is directly off of Highway 881 and does not pass any residences. Onsite operational noise will consist of trucks unloading into the cells and a dozer for solids handling. A setback of 100m from Highway 881 will create a natural barrier to minimize noise and traffic hazard. ODOURS AND FLARING: There will be no H2S or flaring associated with the facility. The Project has been designed to have a logical setback with a forested barrier. Residual solid waste with strong aromatic odor will be handled as per established operating standards to minimize concern, objection and impact to adjacent neighbors ENVIRONMENTAL IMPACTS AND MITIGATION STRATEGIES: The SECURE management team has extensive experience in successfully constructing and operating 9 of these types of facilities in Alberta, North Dakota and Manitoba. SECURE will construct and operate the Conklin Landfill in an environmentally and socially responsible manner. The site was identified as a suitable site after evaluating several potential options in the region. The criteria used for selecting the site was based on suitable geological(clay) conditions, minimal visual, traffic and noise impact, proximity to market, appropriate access and existing infrastructure. SECURE is employing best engineering practices in the development of the Project. A significant aspect of the Conklin Landfill is that the containment design will exceed regulatory requirements for the types of wastes to be accepted for disposal. The landfill design will feature a composite liner and leachate collection system, which is complemented by excellent natural hydrogeological conditions at the site. A series of groundwater monitoring wells will be installed and tested every six months by a third party contractor and the results of the monitoring program will be submitted to AEP for review. Given the setting of the Project and control mechanisms which will be in place, negligible environmental or aesthetic impacts are expected. The Project has been situated with a 100m forested setback from Highway

4 The operational period of the landfill is expected to be approximately 26 years. Over that period, as final grades are reached, the completed areas will be progressively capped and returned to grassland conditions. SECURE will also continue to manage, monitor and maintain the site for up to 25 years after closure. SECURE will be required to post financial security (an AEP condition) to guarantee that funds will be available for proper postclosure maintenance. PUBLIC CONSULTATION SECURE will work openly with stakeholders to understand and address questions and concerns as effectively and fairly as possible. To assist SECURE in engaging stakeholders in the Project development plans, SECURE's consultation program will include the following: Consultation and engagement with Conklin Resource Development Advisory Committee; One-on-one consultations with stakeholders, adjacent landowners and occupants; Written notification to stakeholders, landowners, occupants and companies within the area; and Meetings with regulatory and municipal agencies. Public consultation will continue as required during project construction and operation. PROPOSED PROJECT SCHEDULE SECURE intends to proceed with regulatory applications involving the following requirements: An application to AEP for approval to construct and operate the Class II Industrial Landfill. Final closure of the proposed landfill will be regulated by AEP. Applications to Regional Municipality of Wood Buffalo to acquire a development permit. Proposed Project Timeline: 1st Quarter 2016: Public Consultation 1st Quarter 2016: Filing of Applications 3rd Quarter 2016: Anticipated project approval 3rd Quarter 2016: Construction 4th Quarter 2016: Operations Approximately 2042: Decommissioning and Reclamation 25 years post closure: Monitoring 3

5 FOR ADDITIONAL INFORMATION If you require additional information regarding this project, please contact: Alastair Graham Sr. Environment and Regulatory Specialist SECURE Energy Services Bow Valley Square , 205 5th Ave SW Calgary, AB T2P 2V7 (403) agraham@secure-energy.com Or Environment and Parks Regulatory Approvals Center Main Floor, Street Edmonton, Alberta T5K 2J6 Fax: (780) aenv.northernepea@gov.ab.ca 4

6 Appendix A - Detailed Project Information In accordance with the Environmental Protection and Enhancement Act (EPEA), SECURE Energy Services Inc. (SECURE) will be applying to Alberta Environment and Parks (AEP) for an approval to construct, operate and reclaim the Conklin Class II Landfill Project (the Project). The Project will include the following associated infrastructure: a 1.45 km all-weather road, office trailer, scale, shop building, site roads, stormwater pond with associated ditches and berms, and tanks and pumps to store precipitation that contacts waste in the landfill (leachate). The Project is located approximately 5 km south on Hwy 881 from the Conklin, Alberta turnoff and in Township 76 Range 8 West of the 4th Meridian. The Project will include design features such as a composite liner system, leachate management system, stormwater management system, wildlife monitoring and control, and groundwater monitoring system. The total combined footprint of the land disposition that will be requested for the Project and associated infrastructure is approximately 110 ha, although the entire operating area will not be allocated to the Landfill cells. The majority of the solids to be accepted at the Conklin Class II Landfill are generated by producers in the area and will consist of drill cuttings, residual solids from spill cleanups, contaminated site cleanups, and residual solids from treatment processes. These solids are soils that are high in salts, may contain a moderate hydrocarbon component and may have metals or miscellaneous compounds in low concentrations. SECURE is not applying to accept municipal, hazardous, or dangerous waste. All waste accepted will meet AEP Class II disposal criteria as non-hazardous oilfield waste. The Project footprint will be built progressively by adding additional waste containment area as space in the existing landfill is filled with waste. Project construction begins by clearing vegetation, saving the topsoil layer and then reworking the natural clay found on location which serves as a primary seal that will prevent leachate (rainwater that percolates though the solid waste) in various cells from entering the groundwater. Each cell is then lined with a geomembrane which acts as a second layer of protection to further protect groundwater. A layer of select waste, free from debris that may harm the liner, will be placed over the geomembrane to prevent the geomembrane from being punctured, cracked or torn. Waste is then placed in the cell. When the cell is full, a cap is placed over the waste to prevent rainwater from percolating through the waste material. Rainwater that percolates through the solid waste is known as leachate. Over time, liquids are removed from the solid waste through the leachate removal system. The end result is a dry entombed solid preventing potential future contamination. The cap is covered with subsoil, soil and reseeded to native grasses as authorized by AEP. The leachate fluids are then disposed of off-site at a third-party regulated deep injection well or facility. 5

7 Figure 1 provides an illustration of a typical construction process of a landfill. Equipment such as backhoes and track type tractors will be utilized during operation of the Project. Trucks that deliver oilfield waste to the Project will usually be end dump units. SECURE expects that between 15 to 20 trucks will visit the Project daily. Daily operating hours for the Project will be from 7:00 am to 7:00 pm. Figure 1 Typical Class II Landfill Construction 6

8 Figure 2 is an example of a typical Class II Landfill. A landfill is usually located in an area surrounded by forest to improve sight-lines from nearby highways, roads and residences. Figure 2 Typical Class II Landfill The construction of the Project and associated infrastructure is expected to occur in the third quarter of Operation of the Project will commence in the fourth quarter of 2016 and will operate for approximately 20 to 25 years. Over that period, as final grades are reached at the Project, the completed areas will be progressively capped and returned to grassland conditions. SECURE will also continue to manage and maintain the site for up to 25 years after closure. SECURE will be required to post financial security (an AEP condition) to guarantee that funds will be available for proper post-closure maintenance. The potential impacts to Stakeholders are outlined below: Access Management - During the Project life, SECURE will progressively cap and return the site to an authorized land use by AEP. SECURE will also monitor the site for a minimum of 25 years after closure. - In the interest of safety for local land users, SECURE s employees, the public and industry operators, hunting will be prohibited on the access road and within the Project footprint. - Hunting in the vicinity of the Project will be limited by the provisions of the Alberta Wildlife Act, which includes prohibiting the discharge of a weapon within 183 m of any 7

9 occupied building, or along a road that is paved, oiled, graded or regularly maintained (Alberta Government 2012). Regional Groundwater - SECURE commits to submitting a groundwater monitoring program in accordance with the Standards for Landfills in Alberta, completed and certified by a third-party professional, prior to commencing construction of the Project. The monitoring program will be designed in accordance with AEP Groundwater Monitoring Directive, which includes limits and response requirements. Regional Surface Water - SECURE commits to submitting a surface water monitoring program in accordance with the Standards for Landfills in Alberta, completed and certified by a third-party professional, prior to commencing construction of the Project. The baseline information gathered from the investigation, including sampling upstream and downstream surface water bodies, will be submitted to the AEP. Bi-annual sampling will be completed and compared to from baseline parameter control limits. Reclamation - Landfill Final Closure Plan: SECURE will submit a Landfill Final Closure Plan that will include erosion control, restoration of surface water drainage, groundwater monitoring plan, reclamation of monitoring wells, leachate collection and monitoring, and a facilities decommissioning plan. - Once the Final Closure Plan is implemented, SECURE will enter a minimum 25-year period post-closure stage of monitoring and care. At the completion of the post-closure period, SECURE will reclaim the site to a land use authorized by AEP. For further technical information about this Project Description, please contact: Alastair Graham Sr. Environment and Regulatory Specialist SECURE Energy Services Bow Valley Square , 205 5th Ave SW Calgary, AB T2P 2V7 (403) agraham@secure-energy.com 8

10 Glossary of Terms Cap: means a barrier layer placed over the waste in landfill cells to protect the environment from the landfill contents. The cap restricts surface water infiltration into the contaminated subsurface to reduce the potential for contaminants to leach from the site. Class II Landfill: means a landfill for the disposal of waste, not including hazardous waste. Entombed Solid: means solid waste encapsulated between the cap structure and landfill liner that is not exposed to precipitation. Geomembrane: means a sheet of manufactured synthetic material designed to control migration of liquid and gas. Leachate: means a liquid that has been in contact with waste in the landfill cell and has undergone chemical or physical changes. It is created when rain or snow falls on the contaminated solid waste while the cell is in active operation. Oilfield Waste: (I) inert waste means a solid waste that, when disposed of in a landfill or reused, is not reasonably expected to undergo physical, chemical or biological changes to such an extent as to produce substances that may cause an adverse effect and includes without limitation, demolition debris, concrete, asphalt, glass, ceramic materials, scrap metal and dry timber or wood that has not been chemically treated; and, (ll) industrial solid waste means solid waste resulting from or incidental to any process of industry. Progressively Capped: means the capping of the landfill cells throughout the life of the landfill as cells are at capacity and stabilized to prevent leachate from forming. Stormwater Management System: means the infrastructure designed to contain the rainwater or melt water that drains as surface flow on the landfill area (excluding waste areas) during major storm events. This system prevents water from leaving the landfill area until it has been verified that it is not impacted by landfill operations. Stormwater Pond: means the storage pond for the rainwater or melt water that drains as surface water flow on the landfill area and is part of the Stormwater Management System. 9

11 Project Location