Compliance Verification Activity Report: CV2223-170 - Foothills Pipe Lines Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2408

Regulated company: Foothills Pipe Lines Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Damage Prevention

Related events:

• CV2223-279

Rationale and scope:

[Field inspection - Test the inspection of 2nd party oversight in accordance with the DPRs.]

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

• South BC - Zone 8

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC) 2021-12-29
• 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
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Information Request

IR from CER (Information Request sent from CER to company)
Documentation from inspection

Legislative Requirement : Onshore Pipeline Regulations (OPR) 2020-03-16

Sections of the Act

Theme and Categories

Due Date : 2022-10-28

Review Response
Acceptable

Follow-up Action
Issue Non-Compliance

Observations (no outstanding follow-up required)

Observation 1 - General Observations:

Date & time of visit: 2022-09-27 08:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Processes and Standards
• Manage and Mitigate
• Pipeline Identification
• Signs
• Locate Markings
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Locates and Information
• Locate Requests
• Duty to Inform
• One-call Centre
• Ground Disturbance
• Authorization and Consent
• Temporary Prohibition Area
• Guidelines
• Facility
• Guidelines

Facility:

Observations:

Site #1 49.12805556, -116.03472222

• Work being done for the Westpath 2022 and 2023 projects
• Contractor(BSR) conducted safety tailgate meeting to discuss activity
• Congested work site situated off Johnson Road and slope of low mountains
• The nearest residence was approximately 200 metres from the work site.
• Landowner access road was cleared and signage delineated property boundary with the work site.
• Open excavations were fully fenced and warning signs were posted.
• 13 km of new 48” pipe connecting with the existing Foothills system
• 4 pipes were exposed in the ditch. Orange painted 2x4’s were placed in the hydrovac holes inside the fence line of the open excavation.
• Contractor stated they had daylighted along the pipe prior to conducting and excavation with heavy equipment. The contractor stated they had reviewed as built data for the areas of excavation to inform them of any curves, dips/rises etc of the pipe.
• Hydrovacing was being conducted in preparation for 2 hot taps
• TC representatives were onsite while the pipelines were exposed to oversee activity.
• Pipe handling was observed as large sections were transported to site and lifted by crane to work area.
• CER observed workers using tag lines and hand signals to slowly unload pipe from the flat bed
• Blasting
• TC staff examined the sections and noted a pattern of several small indents in the coating
• CER observes that rig matts were placed over the existing lines at the point of vehicle and heavy equipment crossing.
• CER observed that the existing ROW had visible pipeline markers and yellow locate markers
• TCE told CER that all diesel equipment working near hot lines in an operational zone would be equipped with a PASO. The Contractor demonstrated a PASO kill switch on their vehicle.
• CER reviewed the completed excavation checklist

• Large work space further off the highway.
• Landowner residence approximately 400 metres
• Soil sifting, welding, and excavation around existing Foothills pipeline were occurring
• CER spoke with the contractor Ground Disturbance coordinator
• Fenced of excavation
• Contractor indicated that excavating within 5 metres required TC representative onsite
• Midwest land services completed the locating and staking. CER noted that several stakes were painted with green or red tips. Workers onsite could not explain the meaning of these stakes. CER unable to determine in the field if the markings on the locate stakes were consistent with TCE Locate procedure.
• CER and company representatives were unable to provide the Midwest locate sheets and excavation checklist for the excavations visited.  – the tubes did not contain information
• CER observes that rig matts were placed over the existing lines at the point of vehicle and heavy equipment crossing.

Compliance tool used: No compliance tool used

Observation 2 - NNC - Locate markings

Date & time of visit: 2022-01-05 12:43

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Locate Markings

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

The CER reviewed the locate(stakeout) report completed on behalf of Foothills see IR 1.7 Response . 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 as required.  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 not 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):

• Damage Prevention Regulations - Obligations 6(1)(c), (2)

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: 2023-01-05

Date closed: 2023-01-05
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: