Compliance Verification Activity Report: CV2122-018 - Emera Brunswick Pipeline Company Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2808
• Inspector 2648

Regulated company: Emera Brunswick Pipeline Company Ltd.

Operating company: Emera New Brunswick

Province(s) / Territory(s):

• New Brunswick

Discipline(s):

• Damage Prevention

Rationale and scope:

Field inspection to verify compliance to the requirements contained within the Onshore Pipeline Regulations (OPR) and the CER Damage Prevention Regulations - Obligations of Pipeline Companies (DPR-Obligations) with a focus on third party oversight procedures. Field inspection to include document review and site inspection of active third party activity in vicinity of the pipeline.

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• BRUNSWICK PIPELINE

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - IR 1 - Damage Prevention Program Concordance Table

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Manage and Mitigate

Facility:

Observations:

As part of the scope of this field inspection which includes document review, the CER IOs require information pertaining to the EBPC Damage Prevention Program as required pursuant to section 47.2 of the OPR. 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 47.2 A company shall develop, implement and maintain a damage prevention program that anticipates, prevents, manages and mitigates damage to its pipeline and meets the requirements set out in section 16 of the National Energy Board Pipeline Damage Prevention Regulations — Obligations of Pipeline Companies.

Company action required:

Refer to the Documents Section in the link provided for the full text of this Pre-Inspection Information Request.

• Indicate which documents within your company’s Damage Prevention Program or related program address the applicable regulatory requirements.
  • Include details such as document name and applicable sections and/or page numbers.
  • Please do not attach documents at this time. All responses must be entered into the template provided. 
• Follow the instructions provided in the Documents Section to upload and submit your company response by the specified due date.

Due date: 2021-09-27

Date closed: 2021-11-17
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 2 - Field Inspection - Water Upgrade Oversight

Date & time of visit: 2021-11-17 10:00

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Locate Markings
• Damage Prevention Program
• Manage and Mitigate
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Locates and Information
• Locate Requests
• Duty to Inform
• Obligation to Provide Information
• Ground Disturbance
• Authorization and Consent
• Guidelines
• Facility
• Authorization and Consent
• Existing Facilities

Facility:

Observations:

• IO's arrived on site and were provided with an overview of the hazards and mitigations on in work area including expectation with respect to COVID 19 mitigations.
• An overview of the project was provided including the particular phases that were impacting the pipeline and mitigations planned to protect the community from excessive noise.
• IO's reviewed On-Site Activity Permit and Locate Forms. Both were completed with excellent detail and clarity as per EBPC On-Site Activity Permit Application and Technical Guideline and Locate Request Procedure respectively.
• The process in case of emergency response plan activation was described including coordination with the Crisis Management Team from Emera Corporate.
• Written consent was discussed including the authorization and process to withdraw consent. The notification process was described with an emphasis placed on first addressing, with the involved third party, any threat to the pipeline, people and environment.
• Site technician described the locate and pipeline depth determination methods used onsite.
• Line was marked with staked and yellow paint at 3 meter intervals and directional changes,
• Third party representation accompanied the group demonstrating exemplary coordination and communication amongst all parties.
• A discussion regarding third party authorization to place spoil pile above the pipe resulted in understanding that authorizations are implied when the On-site Activity Permit is approved and when Emera representative is providing active oversight.
• It was confirmed that the "significance of markings" are provided to locate requester during the locate process. IO's and company representatives discussed a potential opportunity to improve communication of the significance of markings (eg.colour codes) requirement by including the information on the locate form.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: