Compliance Verification Activity Report: CV2122-377 - Canadian Natural Resources by its Managing Partner, Canadian Natural Resources Limited, Canadian Natural Resources Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2927
• Inspector 2659

Regulated company: Canadian Natural Resources by its Managing Partner, Canadian Natural Resources Limited, Canadian Natural Resources Limited

Operating company: Canadian Natural Resources by its Managing Partner, Canadian Natural Resources Limited

Province(s) / Territory(s):

• Northwest Territories

Discipline(s):

• Safety Management
• Conservation of Resources

Related events:

• CV2122-382

Rationale and scope:

Field inspection of TUK M-18 sump repair work completed in 2021/2022. Verify there are no ongoing work activities which require an authorization under NWT Oil and Gas Operations Act section 6. Identify any conditions that are likely to result in serious bodily harm or environmental damage.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)
• Information Request (IR) (1)

Facility details

Facilities:

Facility Types

• Exploration and Production
• Onshore
• Well Site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - NNC 1 - Tuk M-18 sump work

Date & time of visit: 2022-02-17 15:00

Discipline: Safety Management

Categories:

• Management of Change
• Management of Change

Facility:

Observations:

• CNRL holds an operating licence issued under Northwest Territories Oil and Gas Operations Act (OGOA) 10(1)(a) for the suspended TUK M-18 well located within the Inuvialuit Settlement Region (ISR).
• Section 6 of OGOA states that no person shall carry on any work or activity related to the exploration or drilling for or the production, conservation, processing or transportation of oil or gas in any area to which this Act applies unless… that person is the holder of an authorization issued, before the commencement of operations, under paragraph 10(1)(b) for each such work or activity.
• On 22 Dec 2021 the Commission of the CER sent a letter to companies that own and operate suspended well in the ISR, including CNRL, providing notice that an authorization is required to conduct any work or activity related to a well, including site and sump maintenance and remediation. 
• On 8 Feb 2022 and 9 Feb 2022 CER learned through telephone conversations with CNRL representatives that the TUK M-18 sump remediation work has been completed between November 2021 and January 2022.
  • The work included construction of a winter access trail from the Inuvik - Tuktoyaktuk Highway to Tuk M-18 between November - December 2021, and
  • Remediation of the sump by capping and installing ground temperature cables between in December 2021 and January 2022.
• On 9 Feb 2022 CER received a verbal and written commitment from CNRL that no further field work will happen on the Tuk M-18 site without the required authorization from the CER.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• Oil and Gas Operations Act

Relevant section(s):

• 6. No person shall carry on any work or activity related to the exploration or drilling for or the production, conservation, processing or transportation of oil or gas in any area to which this Act applies unless.... (b) that person is the holder of an authorization issued, before the commencement of operations, under paragraph 10(1)(b) for each work or activity

Company action required:

Provide to the Safety Officer:

1. Confirmation if CNRL is the a) title owner, and b) operator of TUK M-18. If no longer the title owner, provide the date of transfer.
2. A description of the work activity related to the TUK M-18 sump including the schedule of work activities related to both the access road and sump work from January 1, 2021 to present.

Due date: 2022-02-18

Date closed: 2022-02-18
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Referred to enforcement

Compliance achieved: No

Observation 2 - IR 1 - Signed confirmation from CNRL

Discipline: Safety Management

Categories:

• Management of Change
• Management of Change

Facility:

Observations:

1. Provide to the CER a confirmation signed by Vice President, Lands dated no later than 23 Feb 2022 indicating that any future work by CNRL related to TUK M-18 and the TUK 2 Productive Acreage Block will comply with OGOA section 6.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Oil and Gas Operations Act

Relevant section(s):

• 6. No person shall carry on any work or activity related to the exploration or drilling for or the production, conservation, processing or transportation of oil or gas in any area to which this Act applies unless.... (b) that person is the holder of an authorization issued, before the commencement of operations, under paragraph 10(1)(b) for each work or activity

Company action required:

1. Provide to the CER a confirmation signed by Vice President, Lands dated no later than 23 Feb 2022 indicating that any future work by CNRL related to TUK M-18 and the TUK 2 Productive Acreage Block will comply with OGOA section 6.

Due date: 2022-02-23

Date closed: 2022-03-10
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 3 - TUK M-18 field observations

Date & time of visit: 2022-03-09 11:00

Discipline: Safety Management

Categories:

• Management of Change
• Management of Change

Facility:

Observations:

• On 9 March 2022 CER Officers visited the TUK M-18 site, accompanied by a representative from CNRL and contractor representatives. Officers noted that an officer from the ILA, local wildlife monitor and local environmental monitor were on site.
• Officers confirmed the winter access trail was constructed, and the installation of a sump cap was complete.  No additional activity was observed by Officers.
• The top half of the TUK M-18 wellhead was visible (the lower half being covered in snow). Close visual inspection of the wellhead was not possible due to snow. Pipe racks surrounded the well head - Contractor representatives stated they were placed there to protect the wellhead from unintentional contact with vehicles and heavy equipment during the sump repair work.
• Officers observed no imminent threats to health, safety, or the environment during their field visit on 9 Mar 2022.
• CNRL stated to Officers that remediation of the sump, but not grading or drainage, was required prior to sale of Tuk M-18.
• CNRL confirmed that a Phase I and Phase II ESA were completed.  Sump contents were tested for hydrocarbons and salinity. CNRL confirmed that no migration of contamination from sump was detected.
• Officers observed rig mats over creek crossing on the winter access trail.  Officers were informed that rig mats were placed directly on top of the snow, covering both watercourse banks and no gravel was placed within the watercourse.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: