Compliance Verification Activity Report: CV2122-329 - Minell Pipeline Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1618

Regulated company: Minell Pipeline Limited

Operating company: Manitoba Hydro

Province(s) / Territory(s):

• Manitoba
• Saskatchewan

Discipline(s):

• Damage Prevention
• Emergency Management
• Safety Management
• Integrity Management

Related events:

• CV2122-331
• CV2122-370
• CV2223-272
• INC2021-147
• DPR2021-247

Rationale and scope:

Emergency response activity related to incident INC2021-147, a rupture of the Minell pipeline near Moosomin, SK. This activity does not include additional compliance verification activities not related to the Emergency Phase of the incident.

Compliance tool(s) used:

• Information Request (IR) (2)

Facility details

Facilities:

• MINELL NATURAL GAS PIPELINE

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)

Observations (no outstanding follow-up required)

Observation 1 - Emergency Response Activities

Date & time of visit: 2022-01-18 16:30

Discipline: Emergency Management

Categories:

• Incident Response Summary
• Incident Summary

Facility:

• MINELL NATURAL GAS PIPELINE (Pipeline)

Observations:

The CER EM Inspection Officer (IO) oversaw Manitoba Hydro's (MH) emergency response activities at the incident site NE of Moosomin, SK, just east of the SK/MB border, and at the Emergency Operations Centre in Russel, MB. 

Incident Site

• The CER EM IO arrived at the incident site at 13:51 CT on 6 Oct 2021, approximately 24 hours after the initial pipeline rupture. By then, no emergency response activities were occurring at the incident site and MH had transitioned resources to repair activities. MH and contractor staff were on site to facilitate repairs.
• The CER safety IO engaged with MH safety personnel throughout the course of the event. As indicated in this report, the IO required some additional information from MH but no substantive safety issues were noted throughout the course of the inspection.
• A CER Pipeline Integrity IO also oversaw repair activities at the incident site. 
• CER IOs observed that there was less than a foot of cover over the pipe where it had been punctured by the landowner during grading activities. Subsequent CER activities related to depth of cover and damage prevention are not included in this report
• Representatives of the Transportation Safety Board also attended the incident site
• Pipeline repairs were completed and the pipeline was returned to service by approximately noon on 8 October.

Emergency Operations Centre (EOC)

• The CER EM IO attended several meetings at the EOC and provided oversight of MH's emergency response activities and made inquiries as to specific elements of the response as required
• The EOC was a hybrid in-person/virtual EOC that included MH personnel from across the company. MH uses an in-house incident management team structure that incorporates elements of the Incident Command System
• The focus of the EOC was:
  1. managing field repair activities in a safe and timely manner
  2. preparing for a safe return to service of the pipeline 
  3. managing gas supply to minimize disruptions to residential and commercial customers
  4. external communications 
• EOC meetings were efficient and effective and the EOC played an appropriate support role to the incident site as well as focusing on items 2, 3, and 4
• The EOC appropriately considered contingency planning in areas related to gas supply and potential problems during start-up of the line
• Gas supply for customers was provided through existing gas in the line outside of the shut-in section and via portable compressed natural gas trailers supplying the Dauphin hospital. By the time the pipeline was returned to service, there were no substantive customer impacts with the exception of a large Canola crushing plant that was without gas for the duration of the emergency phase. Warm weather during the emergency phase significantly mitigated potential gas supply impacts.
• Representatives of the Transportation Safety Board also attended a limited number of EOC meetings.
• Pipeline repairs were completed and the pipeline was returned to service by approximately noon on 8 October. The EOC was stood down at 14:00 and an informal review and learn was conducted prior to that time to be followed by a formal review and learn and after action report at a later date
• Overall, the CER EM IO observed that MH managed the emergency in a safe, competent manner and MH is commended for its proactive planning. It is likely that MH's experience with electrical outages readily transferred to the natural gas outage in the case of the Minell pipeline

Compliance tool used: No compliance tool used

Observation 2 - IR 1 - Cutting - Personal Protective Equipment

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment

Facility:

• MINELL NATURAL GAS PIPELINE (Pipeline)

Observations:

CER Inspection Officer (IO) observed company workers cutting pipe with a handheld angle grinder and cut off disk. The worker wore eye protection but no face shield. Upon inquiry, company safety representative confirmed that no face protection was required for the task.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;
      • (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks;
      • (g) establish and implement a process for identifying, and monitoring compliance with, all legal requirements that are applicable to the company in matters of safety, security and protection of the environment;

Company action required:

1. Provide a copy of the procedure or safe work practice that described the PPE required for cutting pipe with a handheld grinder.
2. Provide a confirmation that the above standard meets the requirements of CSA Z94.3-15, Eye and Face Protectors and CSA Z94.3.1-16, Guideline for selection, use, and care of eye and face protectors (as required by subsection 6.13(1) of the Manitoba Workplace Safety And Health Regulation.

Due date: 2022-02-05

Date closed: 2022-02-15
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 3 - IR 2 - Cutting - Wheel Guards

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding

Facility:

• MINELL NATURAL GAS PIPELINE (Pipeline)

Observations:

CER Inspection Officer observed a portable angle grinder fitted with a cut-off disc. The wheel guard appeared to be Type 27 & 28, and did not cover a full 180° area on all sides of the wheel. Note - the grinder was not in use at the time of observation.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;
      • (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks;
      • (g) establish and implement a process for identifying, and monitoring compliance with, all legal requirements that are applicable to the company in matters of safety, security and protection of the environment;

Company action required:

1. Describe how workers tasked with cutting activities described above are trained how to select proper wheel guards based on the task they are performing.

Due date: 2022-02-15

Date closed: 2022-02-15
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

Observations (company follow-up required)

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