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Docket No.: 171476138P1 IN THE PROVINCIAL COURT OF ALBERTA JUDICIAL DISTRICT OF FORT MCMURRAY BETWEEN: HER MAJESTY THE QUEEN and: ‘CNOOC PETROLEUM NORTH AMERICA ULC (formerly known as. NEXEN ENERGY ULC) AGREED STATEMENT OF FACTS 41. CNOOC Petroleum North America ULC (‘CPNA") (formerly known as Nexen Energy ULC (Nexen") pleads guity to Count 1 on Informetion 17447613804 that tt (On or about January 15, 2016, at or near Anzac, Alberta, being an employer, did fall to ensure as far as it was reasonably practicable to do so the health and safety ‘of David Willams and Drew Foster, workers engaged inthe work of that employer, ‘contrary to section 2(1}aX) of the Occupational Health and Safety Act, RS.A, 2000, 0-2, as amended. (CPNA admits the following facts pursuant to section 606(1.1) ofthe Criminal Code. Background 2. As at January 15, 2016, Nexen was a validly subsisting company registered in the province of Brish Columbia and extra-provincally registered in the province of ‘Alberta, On Deoomber 31, 2018, Nexen changed its name to CNOOC Petroleum North America ULC (‘CPNA’) and is now canying on business in that name. anos ascuoa ‘Throughout this document, Nexen and CPNA are used interchangeably and refer to ‘the same entity. 3. CPNAis an upstream oil and gas company developing energy resources around the ‘world, including Westen Canada. 4. As partof ts oll sands business, CPNA owns and operates the Long Lake facility near ‘Anzac, Alberta (‘Long Lake Facility") which, as at January 18,2016, was an integrated fll sands steam-assisted gravity drainage (‘SAGD") and upgrading operation (Upprader, '5, Fleld construction atthe Long Lake Facility commenced in 2004 and involved sourcing vast amounts of materials from all over the world, including large prefabricated ‘modules, such as the Make-Up Gas (MUG) Compressors. The MUG Compressors ‘are electric motor-driven, reciprocating compressors and were manufactured by Neuman & Esser in 2004. 6. SAGD bitumen production from the Long Lake Facility aommenced in 2007, and production of premium synthetic crude from the Upgrader began in 2008. 7. TheUpgrader was designed to process bitumen generated from SAGD. As partof the process, dituted bitumen from SAGD was sent to the Upgrader where It was treated ‘and distiled and further processed to separate asphaltene from bitumen, with the remaining heavy deasphalted oil being cracked to Gas Oil weight products. The recovered Gas Oil products were combined to make an inlermediate product, which was thereafter fed to the HOU, '8, TheMake-up Hydrogen Section of the HCU supplied high purty hydrogen co-ningled with recycle gas where it was used for hydrotreating, hydrecracking and reactor loop. pressure control. The purpose ofthe Compression facility was to compress the make- up hydrogen from a supply pressure of approximately 4,900 kPag to the reactor ‘section pressure of approximately 19,000 kPag. The Compression facility consisted (of two identical parallel trains: MUG Compressor A (3100-C-002A) (‘MUG A) and on ous: sen MUG Compressor B (3100-C-0028), each wit two separate stages of compression (Cetage 1 and “stage 2). 9. Atany given time, only one of the MUG Compressors was in operation. 10.MUG A was taken out of service on October 26, 2015, due to @ high temperature ‘ylinder valve on stage 1. Valve parts were ordered in November 2015, ‘The Incident 11. On November 2, 2015, a CPNA Maintenance Coordinator initiated a maintenance ‘notification to replace al the valves on stage 1 of MUG A. A CPNA Planner created the work package for the job (Work Package"). This Work Package contained ‘marked up Piping and Instrumentation Diagrams (‘P&iDs") showing the blind locations. ‘as part of he isolation process. 12.Before meintenance work can be performed on MUG A, it must be shut down,