Compliance Verification Activity Report: CV1920-295 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector In Training 2444T
• Inspector 2391

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Damage Prevention

Rationale and scope:

Damage Prevention field inspection to verify compliance to the Damage Prevention Regulations and Onshore Pipeline Regulation requirements with a focus on agricultural, forested, and developed areas near Grande Prairie, Alberta.

Compliance tool(s) used:

• Information Request (IR) (2)

Facility details

Facilities:

• GRANDE PRAIRIE MAINLINE

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Pipeline Damage Prevention Regulations – Authorizations
• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• GPLO-N081-004-2012
• GPLO-N081-006-2012
• XG-N081-011-2011
• AO-002-GC-113
• AO-001-GC-113
• GC-113

Observations (no outstanding follow-up required)

Observation 1 - General Observations: Overview, Public Awareness Program, Damage Prevention Program, and ROW Inspection

Date & time of visit: 2019-07-24 08:00

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Vegetation
• Damage Prevention Program
• Monitoring
• Processes and Standards
• Public Awareness Program
• Manage and Mitigate
• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Reporting
• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW
• Locate Markings
• 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
• Authorization and Consent
• Guidelines

Facility:

• GRANDE PRAIRIE MAINLINE (Pipeline)

Observations:

General Observations:

Overview  

• NOVA Gas Transmission Ltd. (NGTL) is a wholly-owned subsidiary of TC Energy Corporation (TC Energy).

• PA program is based in Calgary, Alberta for all areas to facilitate an umbrella approach, with regionally-based PA advisors, land agents, and locate technicians.
• NGTL is a member of the Alberta Common Ground Alliance (ACGA), and is a member of Alberta One-Call.
• PA Program has identified four key stakeholder types: affected public, excavators, emergency management officials, and landowners.
• Bi-annually, all affected stakeholders within 300m of centerline of pipe receive PA materials.
• Annually, excavators and emergency management officials receive PA materials.
• Targeted initiatives within specific geographic areas are initiated per identification of audience and offenders, including:
  • safe dig messaging advertised on weather app was launched to target farmers;
  • creation of a Youth Energy Safety Award; and
  • participation in April’s Safe Dig Month.

• NGTL Representatives provided an overview of the Online Crossing Tool located on the company external website (www.writtenconsent.transcanada.com). The tool has been active since late 2017 and prompts the user for the minimum information required in order to process a crossing request.
• Crossing requests are sent to a crossings coordinator for quality assurance / quality control on the application. Multiple activity types within an application will be issued multiple agreements specific to each activity being undertaken.
• Within the Grande Prairie Area, the majority of written consent is issued for ground disturbance activities involving other utilities.
• Locates are completed by NGTL Representatives, as well as contracted locators.
• When a pipe is located, a Stakeout Report is generated containing a locate slip, aerial photograph or satellite photo of the area, and a colour-coded legend to explain markings.
  • Stakeout Reports created by NGTL Representatives are emailed to the requestor.
  • Stakeout Reports generated by contracted locators are vetted by NGTL Representative prior to being sent to the requestor.
  • In instances of a field approval, a Stakeout Report may serve as a ground disturbance permit.
• NEB Inspectors reviewed Pipeline Inspection Report (PIR). PIR is required to be completed every time a pipe is exposed.
• The Grande Prairie Area is patrolled by helicopter aerial patrols three times per year (visual) and one time per year (instrument). Ground-based patrols are done by exception. Aerial patrols are completed by a contacted provider.
• NEB Inspectors viewed Eagle Eye patrol reporting system and discussed aerial patrol procedures. NGTL Representatives advised that aerial patrol procedures are contained within contract issued to contracted provider, and that all contracted patrollers must complete a yearly training session.
• NGTL Regulatory Compliance group tracks and trends Unauthorized Activities (UA).
  • UAs are reported to NEB via OERS. NGTL Representatives advised they track how UAs are discovered.

• NGTL Representatives created a Job Safety Analysis (JSA) and discussed field-level hazards associated with the ROW inspection. JSA was signed by NEB Inspectors prior to commencing the ROW inspection.
• NEB Inspectors conducted a spot check of roadway and railway crossings along NEB the Grande Prairie Mainline ROW.
• Emergency phone number on signage (1-888-982-7222) was verified to be operational and connected NEB Inspectors to a manned control centre.
• ROW areas inspected were agricultural and were observed to be maintained for access and vegetation control.
• Signage was present during spot check of roadway and railway crossings. One sign was observed to have multiple bullet holes and NGTL Representatives advised they would submit a work order to have the sign replaced.
• No authorized or unauthorized 1st, 2nd, or 3rd party ground disturbance, construction of a facility, vehicle crossing activities, or areas of active locating or staking were occurring or discovered during the inspection.

Compliance tool used: No compliance tool used

Observation 2 - Information Request 1: Obligations Respecting Certain Locations - Agricultural Activity

Date & time of visit: 2019-07-24 13:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Public Awareness Program
• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Reporting
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Agricultural Activity
• Authorization and Consent

Facility:

• GRANDE PRAIRIE MAINLINE (Pipeline)

Observations:

Section 7 of the NEB Pipeline Damage Prevention Regulations (DPR) - Obligations of Pipeline Companies states:
Even if the conditions set out in paragraph 13(1)(a) of the NEB DPR - Authorizations is met, when the operation of vehicles or mobile equipment across a pipeline at specific locations for the purposes of performing an agricultural activity could impair the pipeline's safety or security, the pipeline company must identify those locations and notify the following persons in writing of those locations:
     (a) landowners of the specific locations in question; and
     (b) persons that are engaged in agricultural activities, rent or lease the land or work as service providers or employees at the specific locations in question.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies

Relevant section(s):

• • 7 Even if the condition set out in paragraph 13(1)(a) of the National Energy Board Pipeline Damage Prevention Regulations – Authorizations is met, when the operation of vehicles or mobile equipment across a pipeline at specific locations for the purposes of performing an agricultural activity could impair the pipeline’s safety or security, the pipeline company must identify those locations and notify the following persons in writing of those locations:
    • (a) landowners of the specific locations in question; and
    • (b) persons that are engaged in agricultural activities, rent or lease the land or work as service providers or employees at the specific locations in question.

Company action required:

NGTL Representatives shall provide NEB Inspectors with documentation that demonstrates how the pipeline company meets the requirements of Section 7 (a) and (b) of the NEB DPR - Obligations of Pipeline Companies.
 

Due date: 2019-09-30

Date closed: 2019-10-17
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 - Information Request 2: Maintenance of Pipeline Markers

Date & time of visit: 2019-07-24 13:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Reporting
• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW

Facility:

• GRANDE PRAIRIE MAINLINE (Pipeline)

Observations:

CSA Z662-19 section 10.5.3.9 states:
Signs shall be inspected periodically and maintained to ensure legibility and visibility.

NGTL provided documentation indicating the company has pipeline marker procedures and established standards, but did not provide documentation to indicate how the company ensures the requirements of CSA Z662-19 section 10.5.3.9 are being met in the Grande Prairie area.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-19 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662-19 section 10.5.3.9: Signs shall be inspected periodically and maintained to ensure legibility and visibility.

Company action required:

NGTL Representatives shall provide NEB Inspectors with documentation that demonstrates how the pipeline company meets the requirements of CSA Z662-19 section 10.5.3.9.
 

Due date: 2019-09-30

Date closed: 2019-10-17
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: