Compliance Verification Activity Report: CV2223-279 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2408
• Inspector 2927

Regulated company: NOVA Gas Transmission Ltd.

Operating company: NOVA Gas Transmission Ltd.

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Damage Prevention
• Safety Management

Related events:

• CV2223-170

Rationale and scope:

Field inspection of integrity dig on NPS16 North Lateral Extension.

Compliance tool(s) used:

• Assurance of Voluntary Compliance (AVC) (2)
• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

• NORTH LATERAL EXTENSION - NPS 16

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies

Observations (no outstanding follow-up required)

There are no observations with outstanding follow-up

Observation 1 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

There are no observations with outstanding follow-up

Observation 2 - NNC 1 - Damage Prevention and NNC locate marking

Date & time of visit: 2022-10-04 13:00

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Damage Prevention Program
• Processes and Standards
• Locates and Information
• Locate Requests
• Duty to Inform
• Ground Disturbance
• Authorization and Consent
• Temporary Prohibition Area
• Guidelines

Facility:

• NORTH LATERAL EXTENSION - NPS 16 (Pipeline)

Observations:

• CER observed appropriate ROW markers in place.
• The landowner was onsite during the CER and told the CER that they are familiar with the requirements to make a one call, emergency contacts for the company, and have a good relationship with their land agent. 
• All representatives on site were considered to be 'embeded contractors' of TCE.
• When asked about procedures, ground disturbance permits, locate forms, third party crossing agreements the workers responsible for conducting oversight of the activity and the worker responsible for excavating around the buried facilities were able to demonstrate that they knew where to find the required documentation.
• The CER were told that a hydrovac was used to expose all of the pipelines within the excavation. 
• The CER observed that two third party lines were exposed in the ditch and had been protected by placing plywood over them. 
• The CER were told that the excavation followed TCE's excavation specification and was at 1.5:1/34 degrees slope and the soil type was all Class C as it had been previously disturbed. 
• The CER reviewed the locate(stakeout) report completed on behalf of NGTL. The report contained safety instructions for the workers and a sketch of the work area. The CER observed that the locate stakes to identify the numerous pipelines were painted in yellow, however, each tip of the stake were painted in different colors, which constitutes a deviation from the TCE color code for locate markings. The locate report did not explain the deviation.  The CER were told that the deviation was done to provide a visual reference to easily identify and separate the numerous pipelines within the search area. While the CER finds this practice to be reasonable, it is not in line with the Damage Prevention Regulations - Obligations 6(1)(c), (2) and the companies standard for locating as the deviation was documented to explain the significance of the markings. 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies

Relevant section(s):

• 6(1)(c), (2) (c) provide information to the person that clearly explains the significance of the markings. Marginal note:Markings (2) The markings must be consistent with the standards for locating a pipeline that are set out in the pipeline company’s damage prevention program.

Company action required:

TCE is required to ensure that its 'One Call Locating and Marking Procedure' and 'Stakeout Report and Ground Disturbance Approval (CA)' reflect the actions required where there is deviation from TCE's approved 'Locate Marking' color scheme. 
 

Due date: 2022-11-30

Date closed: 2022-12-28
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:

Observation 3 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 4 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code