Compliance Verification Activity Report: CV2122-218 - Pembina Prairie Facilities Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1686
• Inspector In Training 2557T

Regulated company: Pembina Prairie Facilities Ltd.

Operating company: Pembina Pipeline Corporation

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Damage Prevention

Rationale and scope:

To verify compliance of DP Program and second/third party oversight

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• VANTAGE

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 - Damage Prevention Program Concordance Table (IR)

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Damage Prevention Program
• Monitoring
• Processes and Standards
• Public Awareness Program
• Manage and Mitigate
• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW
• Locate Markings
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Reporting
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Authorization and Consent
• Locates and Information
• Locate Requests
• Duty to Inform
• One-call Centre
• Obligation to Provide Information
• Ground Disturbance
• Authorization and Consent
• Guidelines

Facility:

• VANTAGE (Pipeline)

Observations:

CER IO's completed the Damage Prevention Program Concordance review and require information pertaining to Pembina Prairie Facilities Ltd. Pipeline Damage Prevention Program 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 the 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. 

Due date: 2021-10-21

Date closed: 2021-11-19
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 - Block Valve 21

Date & time of visit: 2021-10-28 08:30

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Vegetation
• Pipeline Identification
• Signs
• Monitoring and Reporting
• Patrols, Inspection and Field Observations

Facility:

• VANTAGE (Pipeline)

Observations:

The ROW was well maintained and the block valve site was well fenced with clear & legible signage.

• CER officers called the emergency contact phone number and it was answered promptly by Pembina personnel.
• Pembina has implemented additional precautions to prevent cows from destroying the fencing by adding "back scratchers" at cow height. (picture attached)
• Aerial patrols are done twice monthly (confirmed by local landowner)
• Ground patrols as required

Compliance tool used: No compliance tool used

Observation 3 - Creek and Road crossing

Date & time of visit: 2021-10-28 09:15

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Vegetation
• Pipeline Identification
• Signs
• Railway and Road RoW
• Monitoring and Reporting
• Patrols, Inspection and Field Observations

Facility:

• VANTAGE (Pipeline)

Observations:

The signage at the road crossing was clear and legible with accurate company and emergency contact information. The cathodic test post was accessible and clearly marked.

• Cathodic readings are done each month.

Compliance tool used: No compliance tool used

Observation 4 - Landowner onsite meeting

Date & time of visit: 2021-10-28 10:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Public Awareness Program
• Monitoring and Reporting
• Patrols, Inspection and Field Observations

Facility:

• VANTAGE (Pipeline)

Observations:

The landowner came to check in at the staging area for the inspection site prior to entering the field and starting work. He stated that Pembina has been easy to work with and has maintained good communications with him prior to and throughout the current activity on his property.

• Pembina has been transparent and open with information
• Frequent telephone contact with Pembina
• Good relationship with Pembina
• Happy with the reparations being made to the creek crossing and ROW with this project.
• Confirmed that Pembina does aerial patrols twice monthly
• Receives public awareness materials, has Pembina fridge magnet with their contact info on his fridge

Compliance tool used: No compliance tool used

Observation 5 - Subsidence repair and soil reparation activity - Pembina oversight of second party contractor - Strongfield Solutions

Date & time of visit: 2021-10-28 11:00

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Vegetation
• Damage Prevention Program
• Monitoring
• Manage and Mitigate
• Pipeline Identification
• Signs
• Watercourses
• Locate Markings
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Vehicle or Mobile Equipment Crossings
• Authorization and Consent
• Locates and Information
• Locate Requests
• Obligation to Provide Information
• Ground Disturbance
• Authorization and Consent
• Guidelines

Facility:

• VANTAGE (Pipeline)

Observations:

On Septenber 28, 2021 CER IOs conducted a damage prevention field inspection focusing on contractor oversight for the Pinto Creek Reclamation activity.

All meetings were held outside and physical distancing observed to comply with COVID protocols.
Attended the site tailboard meeting, subjects covered included:

• Reviewed and discussed the nine life saving rules and how they apply to the activity
• Reviewed the Emergency Response Plan (ERP) and each vehicle (including ours) was provided a copy to ensure that it was close at hand.
  • nearest medical facilities were identified and maps and contact information were provided
  • Personnel onsite with first aid training were identified
• Discussed muster point for the activity
• Discussed respect for the landowner's property and to leave as small a footprint as possible to preserve as much pasture and feed for cattle as possible. Required to stay within the prescribed area.
• Discussed fire prevention and response due to very dry conditions in the pasture (don't leave vehicles running)
• Noxious weed prevention

• Ground disturbance permit
• Work permit
• Locate documentation
• JSA and FLHA
• ERP
• Tailboard meeting documents

• grading, levelling and compacting the soil over the pipe
• restoring a berm alongside the creek that had washed out in prior years
• seeding and conditioning the soil 

• The work area was well identified with stakes marking the pipe, the ROW and the prescribed area (see pictures)
• The creek was dried up with soil cracks approximately 30cm deep in places on the banks
• Signage for the watercourse was present, clear and legible
• CER IO observed the area of subsidence, washed out berm and second party oversight. Oserved at least one Pembina employee was onsite at all times.
• The contractor, Strongfield Solutions, opted to use smaller equipment to minimize impact on the environment while completing the job efficiently.
  • observed line of sight communication between the equipment operator and swamper
  • fire extinguishers were directly adjacent to the work area and moved along with the equipment operator and swamper

Compliance tool used: No compliance tool used

Observation 6 - Opening meeting and Concordance Table review.

Date & time of visit: 2021-09-22 13:30

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Processes and Standards
• Public Awareness Program
• Manage and Mitigate
• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW
• Locate Markings
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Reporting
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Agricultural Activity
• Authorization and Consent
• Locates and Information
• Locate Requests
• Duty to Inform
• One-call Centre
• Obligation to Provide Information
• Ground Disturbance
• Authorization and Consent
• Guidelines

Facility:

Observations:

CER Inspection Officers (IO) conducted an opening meeting with Pembina Prairie Facilities Ltd. (Pembina) on Sept 22, 2021. Observing Covid 19 protocol, this meeting was conducted virtually.
 
Topics discussed are:

• Logistics for CER’s Damage Prevention contractor oversight field inspection scheduled for Sept 28, 2021
• Inspection will be held in the Pinto Creek, SK area as Pembina will be conducting a Pinto Creek Reclamation  
• Discussed PPE, training requirements and Covid 19 safety requirements
• CER IO’s will attend tailgate meeting scheduled for 9 am, Sept 28, 2021
• Pembina confirmed that Pembina’s Damage Prevention documentation provided for the CER’s Damage Prevention document review for Veresen NGL Pipeline Inc., CV2021-363 is the same for documentation provided to Pembina Prairie Facilities Ltd., Vantage Pipeline   
• Pembina confirmed that the Notice of Non-compliance issued for CV2021-363 has been updated and completed to reflect the CER regulatory requirements pursuant to the OPR s.6.5(o)
• IO’s discussed the Damage Prevention Concordance Table that will be forwarded using the CER reporting system as an Information Request
• Pembina personal assigned will be the CER’s main contact for this inspection and will accompany the CER IO’s for this field inspection activity

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: