The BC Energy Regulator (Regulator) is recommending permit holders ensure effective Management of Change (MOC) processes are implemented, following a recent piping rupture.

On Nov. 9, 2018 a high energy rupture of a separator water discharge line occurred during well flowback operations resulting in injuries to one worker, damage to piping and equipment on site, and a spill of hydrogen peroxide (H2O2) and sour produced water. The Regulator is continuing its investigation of the incident.

Changes that should be addressed by an MOC program include, but are not limited to, changes to process chemicals, operating limits, equipment, procedures, maintenance practices and organization. For example, where produced water treatment systems are designed to use chlorine dioxide (ClO2) to oxidize hydrogen sulphide (H2S) and a decision is made to substitute H2O2 in place of ClO2, a MOC procedure should:

• Follow defined review processes.
• Adhere to defined thresholds for approval of changes including signoff by qualified personnel.
• Assess hazards and risks associated with the change.
• Reduce hazards and risks as required.
• Ensure the change is communicated to affected stakeholders prior to the change.
• Ensure any required training is provided prior to the change.

If you have any questions regarding this Safety Advisory, please contact:

Kevin Parsonage
Supervisor, Field Engineering and Technical Investigations
BC Energy Regulator

Kevin.Parsonage@bcogc.ca
250-794-5259