FORT ST. JOHN, B.C. – The BC Oil and Gas Commission is clarifying fencing requirements around drilling sumps.
The development of clear expectations for fencing requirements around drilling sumps for the purpose of wildlife exclusion has been identified as an area for improvement by the Commision.
Section 51(2) of the Drilling and Production Regulation (DPR) requires “a well permit holder who deposits into an earthen pit drilling fluids that may be harmful to domestic livestock or big game must maintain the pit so as to prevent domestic livestock or big game from ingesting the fluids”.
Where necessary, fencing is the primary tool used by permit holders to satisfy this requirement. Where wildlife exclusion fencing is required under the DPR, installation of snow fencing is not an acceptable method of excluding wildlife from the site.
Fencing requires the following parameters will be considered acceptable;
32 centimetre (12 ½”) gauge high tensile galvanized steel woven wire (commonly referred to as ‘page wire’), or similar material, to achieve the same results. Minimum height of 2.5 metres (8’).
Either a minimum diameter of 10 centimetres (or 4”) and 3.5 meters (or 12’) in length for pressure treated wood or steel posts with a minimum diameter of 5 centimetres (27/8”) and 4.5 meters (14’10”) in length, depending on installation conditions.
Access / egress:
As it pertains to personnel and/or equipment access, the expectation is for the permit holder to choose a gate, or set of gates, that will achieve continued and safe access and egress while maintaining a minimum height of eight feet to prevent wildlife or livestock entry to the area.
In the event that wildlife or livestock enter the fenced off area, the fencing should include a one-way exit gate (or similar feature), built during construction, to facilitate safe exit from within.
As of Jan. 1, 2019, this fencing requirement is applicable to all newly constructed sumps with the following exceptions:
• Locations that are manned 24 hours per day, or
• Sumps that will be decommissioned within 14 days of the site no longer being manned 24 hours/day, or
• Sumps that have been demonstrated through laboratory analysis to not contain any substance in a concentration exceeding livestock standards of the Contaminated Sites Regulation schedule 3.2, and have passed accepted toxicity assessment protocols without treatment.
Alternative wildlife exclusion methods may be approved by the Commission on a site-specific basis.