Operational Statement
Directional Drilling

Version 3.0 (PDF)

For the purpose of this Operational Statement, the term High-Pressure Directional Drilling (HPDD) means trenchless methods of crossing a watercourse using pressurized mud systems. HPDD is used to install cables and pipelines for gas, telecommunications, fibre optics, power, sewer, oil and water lines underneath watercourses and roads. This method is preferable to open-cut and isolated crossings since the cable or pipeline is drilled underneath the watercourse with very little disturbance to the bed or banks. HPDD involves drilling a pilot bore hole underneath the watercourse towards a surface target, back-reaming the bore hole to the drill rig while pulling the pipe along through the hole. This process typically uses the freshwater gel mud system composed of a mixture of clean, freshwater as the base, bentonite (clay-based drilling lubricant) as the viscosifier and synthetic polymers.

One of the risks associated with HPDD is the escape of drilling mud into the environment as a result of a spill, tunnel collapse or the rupture of mud to the surface, commonly known as “frac-out”. A frac-out is caused when excessive drilling pressure results in drilling mud propagating toward the surface. The risk of a frac-out can be reduced through proper geotechnical assessment practices and drill planning and execution. The extent of a frac-out can be limited by careful monitoring and having appropriate equipment and response plans ready in the event that one occurs. HPDD can also result in excessive disturbance of riparian vegetation and sedimentation and erosion due to operation of equipment on the shoreline or fording to access the opposite bank.

Fisheries and Oceans Canada (DFO) is responsible for protecting fish and fish habitat across Canada. Under the Fisheries Act no one may carry out a work or undertaking that will cause the harmful alteration, disruption or destruction (HADD) of fish habitat unless it has been authorized by DFO. By following the conditions and measures set out below you will be in compliance with subsection 35(1) of the Fisheries Act.

The purpose of this Operational Statement is to describe the conditions under which it is applicable to your project and the measures to incorporate into your project in order to avoid negative impacts to fish habitat. You may proceed with your high-pressure directional drill project without a DFO review when you meet the following conditions:

• there is a low risk of frac-out, supported by a geo-technical assessment,
• you have an emergency frac-out response plan and a contingency crossing plan in place that outline the protocol to monitor, contain and clean-up a potential frac-out and
• you incorporate the Measures to Protect Fish and Fish Habitat when High-Pressure Directional Drilling listed below in this Operational Statement.

If you cannot meet all of the conditions listed above and cannot incorporate all of the measures listed below then your project may result in a violation of subsection 35(1) of the Fisheries Act and you could be subject to enforcement action. In this case, you should contact the DFO office in your area if you wish to obtain DFO’s opinion on the possible options you should consider to avoid contravention of the Fisheries Act.

You are required to comply with all municipal, provincial, territorial and/or federal legislation that applies to the work being carried out in relation to this Operational Statement. In British Columbia, please contact the Water Stewardship Division, Ministry of Environment for information on the Provincial Water Regulation notification requirements when planning to conduct high pressure directional drilling in or around BC waters.

The activities undertaken in this Operational Statement must also comply with the Species at Risk Act. For general information on aquatic SARA species visit the following web site: http://www.dfo-mpo.gc.ca/species-especes/regions/Pac/pacific-index-eng.htm and/or contact DFO by email at: SARA@pac.dfo-mpo.gc.ca.

If you have questions regarding this Operational Statement, please refer to the list of Frequently Asked Questions or contact DFO Regional Headquarters at 1-866-845-6776.

Please notify DFO 10 working days before starting your work by filling out and sending the Pacific Region Operational Statement notification form directly to DFO Regional Headquarters. This information is requested in order to evaluate the effectiveness of the work carried out in relation to this Operational Statement. It is recommended that you keep a copy of the Operational Statement at the work site to demonstrate to Habitat and Fishery Officer staff that the conditions and measures, as outlined in the OS, are being followed.

Area of Application

This Operational Statement applies to the province of British Columbia and Yukon Territory freshwater systems only.

Measures to Protect Fish and Fish Habitat when High-Pressure Directional Drilling

1. Use existing trails, roads or cut lines wherever possible, as access routes to avoid disturbance to the riparian vegetation.
2. Design the drill path to an appropriate depth below the watercourse to minimize the risk of frac-out and to a depth to prevent the line from becoming exposed due to natural scouring of the stream bed. The drill entry and exit points are far enough from the banks of the watercourse to have minimal impact on these areas.
3. While this Operational Statement does not cover the clearing of riparian vegetation, the removal of select plants may be necessary to access the construction site. This removal should be kept to a minimum and within the road or utility right-of-way. When practicable, prune or top the vegetation instead of uprooting.
4. Machinery fording the watercourse to bring equipment required for construction to the opposite side is limited to a one-time event (over and back) and should occur only if an existing crossing at another location is not available or practical to use. A Temporary Ford Stream Crossings Operational Statement is also available.
   
   4.1. To exercise this option, the stream bed at the fording site must be comprised of stable gravel or bedrock and the stream banks must be low and stable.
   
   4.2. If minor rutting is likely to occur, stream bank and bed protection methods (e.g., swamp mats, pads) should be used provided they do not constrict flows or block fish passage.
   
   4.3. Grading of the stream banks for the approaches is not permitted.
   
   4.4. If the stream bed and banks are steep and highly erodible (e.g., dominated by organic materials and silts) and erosion and degradation are likely to occur as a result of equipment fording, then a temporary crossing structure or other practice should be used to protect these areas.
   
   4.5. Time the one-time fording to prevent disruption to sensitive fish life stages by adhering to appropriate fisheries timing windows.
   
   4.6. Fording should occur under low flow conditions and not when flows are elevated due to local rain events or seasonal flooding.
5. Operate machinery on land (above the high water mark (HWM)) and in a manner that minimizes disturbance to the banks of the watercourse.
   
   5.1. Machinery is to arrive on site in a clean, condition and is to be maintained free of fluid leaks, invasive species and noxious weeds.
   
   5.2. Wash, refuel and service machinery and store fuel and other materials for the machinery away from the water to prevent any deleterious substance from entering the water.
   
   5.3. Keep an emergency spill kit on site in case of fluid leaks or spills from machinery.
   
   5.4. Restore banks to original condition if any disturbance occurs.
6. Construct a dugout/settling basin at the drilling exit site to contain drilling mud to prevent sediment and other deleterious substances from entering the watercourse. If this cannot be achieved, use silt fences or other effective sediment and erosion control measures to prevent drilling mud from entering the watercourse. Inspect these measures regularly during the course of construction and make all necessary repairs if any damage occurs.
   
   6.1. Dispose of excess drilling mud, cuttings and other waste materials at an adequately sized disposal facility located away from the water to prevent it from entering the watercourse.
7. Install effective sediment and erosion control measures before starting work to prevent entry of sediment into the watercourse. Inspect them regularly during the course of construction and make all necessary repairs if any damage occurs.
8. Monitor the fluid pressure or watercourse to observe signs of surface migration (frac-out) of drilling mud during all phases of construction.

Emergency Frac-out Response and Contingency Planning

1. Keep all material and equipment needed to contain and clean up drilling mud releases on site and readily accessible in the event of a frac-out.
2. Implement the frac-out response plan that includes measures to stop work, contain the drilling mud and prevent its further migration into the watercourse and notify all applicable authorities, including the closest DFO office in the area. Prioritize clean up activities relative to the risk of potential harm and dispose of the drilling mud in a manner that prevents reentry into the watercourse.
3. Ensure clean up measures do not result in greater damage to the banks and watercourse than from leaving the drilling mud in place.
4. In the event of a frac out, you will be required to contact your local DFO office for a review of an alternate crossing method.
5. Stabilize any waste materials removed from the work site to prevent them from entering the watercourse. This could include covering spoil piles with biodegradable mats or tarps or planting them with preferably native grass or shrubs.
6. Vegetate any disturbed areas by planting and seeding with native trees, shrubs or grasses and cover such areas with mulch to prevent erosion and to help seeds germinate. All seeding and/or planting trees should follow the DFO guidance on Riparian Revegetation. If there is insufficient time remaining in the growing season, the site should be stabilized (e.g., cover exposed areas with erosion control blankets to keep the soil in place and prevent erosion) and vegetated the following spring.
   
   6.1. Maintain effective sediment and erosion control measures until revegetation of disturbed areas is achieved.