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


Compliance verification activity type: Field Inspection

Activity #: CV2223-170
Start date: 2022-09-27
End date: 2022-09-27


Regulated company: Foothills Pipe Lines Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):


Related events:

Rationale and scope:

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

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations:

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

Discipline: Damage Prevention




Site #1 49.12805556, -116.03472222

Site #2
Although the work was not at the stage of backfill, The TCE representatives did not appear to be aware of their DPR-O s.8 requirements as it relates to inspection requirements for the existing line.

Compliance tool used: No compliance tool used

Observation 2 - NNC - Locate markings

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

Discipline: Damage Prevention




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:

Relevant section(s):

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:

- 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