Background
The Ministry of Energy and Resources was seeking written comments on changes to Directive PNG014. The featured changes were intended to support more timely and accurate reporting of incident impacts and to strengthen regulatory oversight of spill impact mitigation efforts.
Summary of Proposed Changes
The main change in the directive requires more information about an incident sooner in the incident response process to support more accurate and timely assessment of spill impacts and to enhance the ministry’s oversight over incident responses. The directive’s previous requirements for incident information reporting in the Integrated Resource Information System (IRIS) did not always provide a complete picture of spill impacts extending beyond a well or facility site, the area also known as the lease operating area. Also, the existing reporting timelines could hinder timely mitigation efforts relating to incident impacts outside the lease operating area, sometimes causing delays in understanding the magnitude of spills and associated clean-up costs.
To address these issues, the amended directive defines the “operating area” of a lease to distinguish incidents that fall within and outside this area to more precisely determine spill impacts and the application of the criteria in the ministry’s site remediation and reclamation directives. Post-incident reporting in IRIS will require:
- All incidents in Appendix 1 of the directive reported in IRIS within two business days of occurrence with estimates on the type and volume of the substance spilled and the areas on/off lease and on/off the operating area impacted;
- Detailing of efforts to remediate and reclaim sites impacted by a spill provided to ER within 90 days of the incident through an IRIS update and written report;
- Reporting at six months from the date of the initial incident submission to update ER on the reclamation status if an incident has not been closed by 90 days; and
- New status updates in IRIS on the progress of remediation and reclamation activities.
Miscellaneous items of note
- Adding clarity on the operator’s responsibilities in the incident response process;
- Expanding notification requirements for stakeholders potentially impacted by an incident, including Indigenous organizations;
- Clarifying incident reporting exemptions for wells in potash mine sites and pipelines regulated by the Canada Energy Regulator;
- Linking to applicable directives to follow for proper remediation and reclamation of sites impacted by incidents; and
- Incorporating reporting procedures regarding releases of drilling fluids from horizontal directional drilling for pipeline construction (previously outlined in ER Bulletin BT2019-008).
Review of Draft Directive
Further details on the amended directive may be found at Notice of Proposed Directive Amendment.