The British Columbia Energy Regulator has fined Canadian Natural Resources $40,000 for a Sept. 20, 2021 spill at one of its well sites, with the company failing to exercise due diligence under the Energy Resource Activities Act. The well is located in a remote northeast section of the Northern Rockies.
Duing a helicopter inspection, a compliance and enforcement officer with the regulator spotted a plume of water coming from the well site. The officer landed and discovered the site was venting a pig barrel to the atmosphere causing fluid to spray into the air. Pig barrels or pigging is a type of valve and valve installation on pipelines.
In September and October of 2021, Canadian Natural Resources undertook remedial work to remove impacted material from the spill.
Residual hydrocarbons remain above and below ground infrastructure but that these areas can be left to naturally attenuate 'with minimal risk', explained Canadian Natural Resources in a Dec. 11, 2023 response letter to the regulator.
Canadian Natural Resources submitted that they exercised due diligence by implementing a number of policies to prevent the contravention, including a code of practice regarding the vented pig barrel.
"I accept this as fact; however, the response does not show evidence the operator on site had reviewed the document," noted Andy Johnson, Executive Vice President, Safety and Compliance for the BC Energy Regulator in his decision letter.
Canadian Natural Resources also submitted that they have an unwritten site-specific pigging procedure, which they say 'worked well' from 2014 to the date of the incident.
"I have no means to verify this assertion, and regardless, given both the potential safety and environmental impacts from the pigging of this site it would be expected that a site-specific and formalized procedure would be in place and that operators expected to conduct this operation would be trained and their competency verified," wrote Johnson.
"An undocumented procedure does not provide assurance that the 5 operator was educated in the site-specific procedure nor that their knowledge or awareness of the procedure was verified," he added.
Canadian Natural Resources also pointed to a working alone procedure as part of their response.
"While I accept that this procedure provides general guidance when working alone, due diligence requires evidence of steps related to compliance with the specific regulatory obligation. I am not satisfied that on its own, the working alone procedure demonstrates that Canadian Natura Resources took all reasonable steps to prevent the contravention," wrote Johnson.
You can read the full decision letter here:
Administrative-Decision CNRL 2021-0194 9Feb2024 by Tom Summer on Scribd
