National Energy Board’s Filing Requirements for Offshore Drilling in the Canadian Arctic - Update
File OF-EP-Gen-NSD-RSRF 0101
6 October 2014
To: Regulated Companies & Other Interested Parties
National Energy Board’s Filing Requirements for Offshore Drilling in the Canadian Arctic - Update
In 2014, the National Energy Board (NEB or the Board) undertook a proactive review of the Filing Requirements for Offshore Drilling in the Canadian Arctic (Filing Requirements). The document has now been amended to clarify for companies the comprehensive information required when filing an application to explore in the Arctic.
The goal of the Filing Requirements amendment is to have applicants describe their emergency response procedures with enough detail to demonstrate that any incident will be managed using industry best practices. The NEB expects that an application would describe an incident management system that is both consistent and compatible with the Incident Command System.
The amendment provides greater clarity to regulated companies regarding the information requirements for proposed incident management systems and processes. Companies preparing applications to the Board for Arctic offshore oil and gas exploration and production activities are directed to use these Filing Requirements.
There are currently no applications for exploration in the Canadian Beaufort Sea under consideration by the NEB. No work or activity proposed for the exploration of oil or gas in the Canadian Arctic will occur unless the NEB is satisfied that a company’s plans are safe for workers and the public, and will protect the environment.
The Filing Requirements have been developed in accordance with the NEB’s mandate under the Canada Oil and Gas Operations Act. They are available on the Board’s website (www.neb-one.gc.ca) and hard copies may be requested by calling the NEB at 1-800-899-1265.
The Board is committed to continual improvement in the areas of safety and environmental protection and will continue to update these Filing Requirements as necessary.
Yours truly,
Sheri Young
Secretary of the Board
Attachment
Attachment to Board Letter
Dated 6 October 2014
4.19 Emergency Response Procedures
Goal
The application describes the emergency response procedures with enough detail to demonstrate that any incident will be managed by integrating a combination of facilities, equipment, personnel and communications within a common organizational structure. The NEB expects that the application would describe an incident management system that is both consistent and compatible with the Incident Command System (ICS), thereby:
- minimizing the impacts to the marine, terrestrial, and atmospheric environments from unauthorized or accidental discharges;
- protecting workers and the public; and
- permitting coordinated emergency response activities when multiple jurisdictions or response agencies are involved.
Filing Requirements
- 1. Describe the criteria used to determine the severity of the emergency, including the definitions of levels or tiers of the emergency.
- 2. Describe the process and criteria to activate, escalate and de-escalate the emergency response.
- 3. Describe the process and criteria to downgrade the level of an emergency and to stand down the emergency phase. Describe the procedures to communicate this information to all responders and agencies.
- 4. Describe the incident management system, including roles, responsibilities and organizational charts that identify clear chain of command to address:
- Command, including safety, communications and liaison;
- Operations;
- Planning;
- Logistics; and
- Finance and administration.
- 5. Describe the process to enable the full engagement of applicable government agencies and stakeholders in the command structure, which shall include Unified Command, where appropriate.
- 6. Describe how the emergency response procedures provide appropriate coordination with relevant municipal, territorial and federal emergency response plans and, where appropriate, with jurisdictions outside of Canada.
- 7. Describe the mutual aid agreements, including the sharing or augmenting of response resources, and any international arrangements to be in place in advance of the proposed drilling activities.
- 8. Describe how designated personnel will be alerted to be deployed to an emergency and how additional resource needs will be assessed throughout the emergency.
- 9. Describe how the conditions associated with an emergency and the effectiveness of the response will be continually assessed throughout the emergency phase.
- 10. Describe the protocol for company/inter-agency operational communications (including land, air and marine).
- 11. Describe the procedures for communications with communities potentially impacted by an emergency and with the media.
- 12. Describe the logistical support, locations and timelines for implementation for a worse case incident, including:
- all facilities that support the emergency response including:
- a Command Post, suitable to support the applicant’s incident management team, as well as agency personnel;
- pre-designated primary and alternate coordination centres;
- staging areas for equipment (including countermeasures) and personnel;
- facilities for repairing out-of-service equipment;
- lodging for all personnel;
- locations where heli- and the required fixed-wing resources could land;
- disposal and clean-up;
- meals;
- communications;
- medical support; and
- on-water support.
- all facilities that support the emergency response including:
- 13. Describe the internal and external incident notification procedures and reporting requirements. Include:
- a listing of agencies and companies;
- the role of the agencies and companies;
- critical information types to be shared;
- maximum timeframe for issuance of initial notification or reporting;
- ongoing notification or reporting frequency; and
- a situation report template.
- 14. Provide a list of the incident management system forms and documents to be used during an emergency.
- 15. Describe:
- b. the incident management system training curriculum, targeted participants, training frequencies, competency requirements and competency evaluation;
- c. the type and frequency of conducting emergency response exercises, with varying degrees of complexity, scale, and interaction with agencies, mutual aid partners, stakeholders and local participants; and
- d. the mechanisms to ensure that lessons learned from exercises are documented and that corrective actions are developed, implemented and evaluated.
- 16. Describe the target timelines for response to a worse case spill under weather and sea conditions that will allow for the appropriate response strategies. Include the timelines for each phase of the response including activation of incident command, command post and mobilization of required personnel, resources, equipment and air and sea support.
To be added to section 5.12:
- 14. Describe the training, competency evaluation and/or qualification requirements of personnel for the blow-out prevention (BOP) and well control operations. Describe the essential personnel and positions to be in place during all phases of drilling and completion operations that will have successfully completed the required training, competency evaluation and/or qualification requirements.
- 15. Demonstrate that the essential personnel to be involved in BOP and well control operations will meet or exceed the International Association of Drilling Contractor certification requirements.
- 16. Describe the well control exercise program including the types of exercises, scenarios, frequency and personnel to be involved in the exercises.
To be added to section 4.18
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30. Describe the procedures for aerial observation and tracking during the emergency phase.
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