Background
The Ministry of Energy and Resources (ER) is consulting with the oil and gas industry on proposed amendments to Directive PNG014: Incident Reporting Requirements (the amended directive). The featured changes are intended to support more timely and accurate reporting of incident impacts and to strengthen regulatory oversight of spill impact mitigation efforts.
The Process
ER is launching industry consultations on the amended directive from April 25, 2024, to June 6, 2024. Once the consultation period has concluded, ER will review all consultation feedback in the preparation of a final draft of the amended directive. The amended directive is expected to come into effect in summer 2024.
Summary of Proposed Changes
The main proposed changes in the amended directive will require more information about an incident sooner in the incident response process to support more accurate and timely assessment of spill impacts and to enhance ER’s oversight over incident responses. The directive’s current requirements for incident information reporting in ER’s Integrated Resource Information System (IRIS) do 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, existing reporting timelines may 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 will define 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 ER’s site remediation and reclamation directives. Key changes relating to post-incident reporting in IRIS will also require:
- all incidents in Appendix 1 of the directive to be reported in IRIS within two business days of occurrence (instead of the current five business days) with estimates on the type and volume of the substance spilled and the areas on/off lease and on/off the operating area impacted (presently required as part of the 90-day detailed incident report);
- details on efforts to remediate and reclaim sites impacted by a spill to be provided to ER within 90 days of the incident through an IRIS update and written report (at present, such information is to be submitted to ER within six months of final reclamation);
- a report 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
- Added clarity on the operator’s responsibilities in the incident response process;
- Expanded notification requirements for stakeholders potentially impacted by an incident, including Indigenous organizations;
- Clarification on incident reporting exemptions for wells in potash mine sites and pipelines regulated by the Canada Energy Regulator;
- Linkages to applicable ER directives to follow for proper remediation and reclamation of sites impacted by incidents; and,
- Incorporation of 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. Please submit feedback on the proposed amendments to the ER Service Desk at er.servicedesk@gov.sk.ca by June 6, 2024.