Compliance verification activity type: Field Inspection
Team:
Regulated company: Maritimes & Northeast Pipeline Management Ltd.
Operating company: Maritimes and Northeast Pipeline Management Ltd.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
[Verify compliance to the OPR and DPR with focus on third party oversight procedures.]
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observations - Bridge Construction - Wilkinson Avenue
Date & time of visit: 2022-07-14 10:00
Discipline: Damage Prevention
Categories:
Facility:
Observations:
CER IO's met with the Area Supervisor for Nova Scotia to open the inspection and partake in the company orientation. An Indigenous land acknowledgement was completed by the company representative. The scope of the project was described including the construction of a "box culvert" with air gap to mitigate the effect of the highway crossing for which the class 2 piping was not designed. The area supervisor described their own physical presence at the project location as "periodic" but confirmed that M&NP has a permanent on-site represent overseeing the third party activity. The on-site representative was described as a contingent worker with pipeline technician 1 credentials who has been with the company for 18 months. CER IO's reviewed several documents including the crossing agreement, the Guideline: Requirements for Construction Near Company Pipelines and dig plans. While on-site IO's observed appropriate stakes, markings and signage. Updated locate reports were available from the company representative. The company representative demonstrated a clear understanding of her authority to suspend consent and of reporting requirements. The Company representative appeared to have a strong line of communication with her provincial counterpart and the contractor leadership. An opportunity was discussed for the company representative to document her daily activities as demonstrable record of oversight. IO's were unable to verify that the company had implemented a process for developing contingency plans, in particular, No contingency plan was in place for the event of a line strike emergency.
Compliance tool used: No compliance tool used
Observation 2 - NNC 1 - Contingency Plans
Date & time of visit: 2022-07-14 13:00
Discipline: Management System
During the inspection, CER IOs noted that the Company representatives were unable to demonstrate that it had developed a contingency plan that included emergency procedures for a line strike or other abnormal events that may be reasonably expected to occur as required by OPR section 6.5(1) (t)
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The company is required to provide its contingency plan for abnormal events that may reasonably be expected to occur during the project, including a line strike. The company must also describe how it will communicate its emergency procedures to all potentially affected parties, during upcoming crossings by Halifax Regional Municipality and Heritage Gas.
Due date: 2022-08-23
Date closed: 2022-08-25 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
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program
