Compliance verification activity type: Field Inspection
Team:
Regulated company: Souris Valley Pipeline Limited
Operating company: Dakota Gasification Company (DGC).
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
The Souris Valley Carbon Dioxide Pipeline is a 61 km operating line running from Southern Saskatchewan to the USA. Construction was completed in 1999. This inspection focused on reclamation and company oversight.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations
Date & time of visit: 2019-05-01 10:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
National Energy Board (NEB) Inspection Officers (IOs) visited several locations along the pipeline right-of-way (RoW) during the inspection. The majority of the RoW is on private, cultivated land. The following summarizes the observations made by IOs during the inspection:- RoW was reclaimed at all sites visited, with vegetation composition and growth comparable to off-RoW conditions. No weeds were observed along the RoW.The RoW was indistinguishable from the adjacent land at the cultivated sites visited by IOs. One exception was near test post 20 at a road crossing. Company representative indicated that additional topsoil had been added to the RoW at the landowners' request in fall 2017. In this area the RoW was faintly visible for approximately 100 m. IOs note that land use is not impacted as the RoW had been cultivated the prior year and is consistent with adjacent land.- Approximately 10 km of the RoW traverses pasture land (private and Crown land). The RoW was largely visible throughout the pasture, but it was well vegetated (grasses) and did not appear to be impacting land use. No weeds were observed and the vegetation was consistent with off-RoW conditions.- IOs visited several (i.e., 10-15) pipeline road crossings. Pipeline signage was in place at all road and watercourse crossings visited, although some maintenance was required (see NNC #1).- Mainline valve station (MLV-11) was fenced and graveled. No weeds were observed within or outside the fence line. Company representative indicated that weeds are controlled through mechanical and chemical means. The station was generally tidy and organized. IOs observed evidence of rodent activity (i.e., burrows) within the fence line.- IOs did not observe any vegetation or weed issues at the crossing of Jewel Creek. Company representative indicated that the watercourse was crossed by a horizontal directional drilling (HDD) method.The vegetation on the banks of the creek was consistent on and off-RoW.- The Central Receiving Terminal (CRT) was fenced and graveled. A soil pile was observed approximately 1m from the west side of the fence. Company representative indicated that this was topsoil from construction of the station. The topsoil pile was largely vegetated (grasses) and no weeds were observed. Evidence of wildlife activity (i.e., burrows) was observed within the topsoil pile. Materials stored at the CRT were kept in an organized fashion (i.e., locked seacan or piled in a corner). An operations manual was not present at the CRT (see NNC #2).- IOs discussed patrol (aerial and ground) processes with the Company Representative and reviewed procedures and recent patrol notes. IOs noted that aerial procedures in March/April 2019 did not occur with the frequency outlined in Company procedures (see NNC #3).
Compliance tool used: No compliance tool used
Observation 2 - Notice of Non-Compliance (NNC) #1 - Crossing Signage
Discipline: Damage Prevention
NEB IOs visited approximately 10-15 road crossings, as well as three watercourse/drainage crossings. Pipeline identification signage was present at all locations, however, in some instances the signs were damaged. Due to the damage, some signs did not include the information required for pipeline identification purposes (e.g., phone number or Company information), or the information was not legible. Company Representative indicated the signs would be replaced in spring/summer 2019 as required.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
1. Assess all pipeline identification signs for legibility and visibility.2. Replace or repair signs that are damaged or otherwise illegible.3. Provide records of replacement by way of notes and/or photographs to confirm that parts 1) and 2) were completed.
Due date: 2019-07-31
Date closed: 2019-07-15 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 - NNC #2 - Pipeline Operations and Maintenance Manual
Discipline: Management System
NEB IOs visited mainline valve site #11 as well as the central receiving terminal. Neither site contained any documentation relating to pipeline operations and maintenance or safety data sheets (SDS) for hazardous substances. Company representative indicated that the SDS are part of the manuals, which are kept in company vehicles as well as the emergency response trailer. IOs note that condition 41a) of Certificate of Public Convenience and Necessity (CPCN) CC-1 requires that Souris Valley Pipeline Ltd. keep up-to-date copies of the pipeline's operation and maintenance manuals at each station.
1. Provide a printed copy of the pipeline's operaiton and maintenance manual at each of MLV-11 and CRT. This manual should include the SDS for hazardous materials at each station.2. Provide evidence to IOs that this was done.
Due date: 2019-05-24
Observation 4 - NNC #3 - Procedures for Aerial and Ground Patrols
Date & time of visit: 2019-04-30 08:00
During the opening meeting, IOs reviewed processes related to aerial and ground patrols to look for abnormal operating conditions. IOs also requested documentation from the most recent patrols. An aerial report from 22 April 2019 indicated that only the US portion of the pipeline was patrolled. Company Representative indicated that this was due to issues with cross-border flight permits and indicated that an aerial fly-over happens annually. Company Representative further indicated that when this occurs, a ground patrol by foot and/or ATV is completed. The most recent aerial patrol that included the Canadian portion of the pipeline was conducted on 27 March 2019. A report from the latest ground patrol was provided and was dated 17 April 2019 (3 weeks from the last Canadian aerial patrol). IOs reviewed Procedure 74-013 "Pipeline Patrol and Inspections", which states that aerial patrols will be conducted at intervals not exceeding 3 weeks.Company Representative later provided Procedure 74-003 "Right of Way Maintenance" which specifies that surface conditions on and adjacent to the pipeline will be visually observed from the air or from the ground at intervals not exceeding three weeks.IOs note that although 74-003 allows for either type of patrol, Procedure 74-013 specifically states that aerial patrols are required for the entire length of the pipeline at intervals not exceeding three weeks. Therefore, Souris Valley Pipeline Ltd. is in non-compliance to Procedure 74-013.
1. Explain how Souris Valley Pipeline Ltd. will ensure that patrols are completed in a manner that is in compliance with Procedure 74-013. If Souris Valley Plans to use ground patrols in lieu of aerial patrols, provide justification.
Date closed: 2019-06-13 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.
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
