Compliance verification activity type: Field Inspection
Team:
Regulated company: Spectra Energy Midstream Canada Partner Corporation
Operating company: Spectra Energy Midstream Canada L.P. (TBD)
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Damage Prevention Inspection to verify compliance with the National Energy Board Act (NEB Act), National Energy Board Onshore Pipeline Regulations (OPR), NEB Pipeline Damage Prevention Regulations – Obligations of the Pipeline Companies (DPR-O) and NEB Pipeline Damage Prevention Regulations – Authorizations (DPR-A). Damage Prevention Inspection to focus on agricultural land, forested and residential land in NE BC (near Taylor)”
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Damage Prevention field inspection Opening Meeting (West Doe Pipeline)
Date & time of visit: 2019-06-26 08:00
Discipline: Damage Prevention
Categories:
Facility:
Observations:
The National Energy Board (NEB) met with NorthRiver Midstream Inc (NorthRiver) and conducted a Damage Prevention program opening meeting and right-of-way field inspection on the NorthRiver Pipeline on June 26, 2019. The following list outlines documents reviewed and information provided during the meeting:
Compliance tool used: No compliance tool used
Observation 2 - Damage Prevention Field Inspection Information Request
Date & time of visit: 2019-06-26 17:00
NEB staff conducted a close out meeting at the conclusion of the field inspection to dicuss our preliminary observations, discuss follow up and any questions. NEB staff has requested additional information from NorthRiver (information request) for NEB Inspection Officers review. Information Requested below;
1) When was the last depth of cover conducted on the ditches, both sides of the Leucrotta access road and the depth of cover over the pipeline now?2) Crossing Agreement for the construction of the Leucrotta access road as well as documentation pertaining to locating/marking of the pipe and onsite supervision.3) The number of landowners and/or land users on the NEB-regulated NorthRiver West Dow and Tupper pipelines?4) Documentation pertaining to the inspections and field observations of exposed pipe prior to any backfilling per the DPR-O section 8. What are the company’s rep’s oversight for backfilling activities?5) Oversight of Third Party activities - The safety information NorthRiver provides per DPR-O section 6. How do third parties conducting work on NorthRiver right-of-way/prescribed area informed of North River’s safety practices and third party sign off?6) Copy of the work order (S.A.P.) for right-of-way signage maintenance.7) On the aerial report dated 15 Oct 2018 shown to NEB staff, it indicated there was erosion on landowner’s property. Please provide a copy of the work order and any information and documents demonstrating completion the work that was done to address the erosion issue.8) NorthRiver’s onsite approval process (proximity permit) for third party activities
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
NEB staff has requested additional information from NorthRiver (information request) for NEB Inspection Officers review. Information Requested below;
Due date: 2019-07-12
Date closed: 2019-09-13 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.
Reason closed: Requirement met
Compliance achieved: Yes
Observation 3 - Notice of Non-Compliance
Pursuant to the National Energy Board Onshore Pipeline Regulations s. 47.2, A company shall develop, implement and maintain a damage prevention program that anticipates, prevents, manages and mitigates damage to its pipeline and meets the requirements set out in section 16 of the National Energy Board Pipeline Damage Prevention Regulations - Obligations of the Pipeline Companies.Upon review of North River's documentation provided, NEB inspector officer (IO) noted several instances of outdated information that referenced the Pipeline Crossing Regulations, outdated reference to past NEB brochures and outdated revision dates to North River's documentation providing inaccurate information to but not limited to the public and third parties contractors pursuant to the Onshore Pipeline Regulations (OPR) s. 47.2 and the National Energy Board Pipeline Damage Prevention Regulations.Based on the outdated and inaccurate information noted throughout NorthRiver's material and related procedures, NorthRiver has not demonstrated that it maintains its Damage Prevention program as required by the OPR section 47.2Therefore, the IO requires that NorthRiver provide it's updated documentation ensuring that it reflects current regulatory requirements and how it will be maintained it going forward to the NEB by December 31, 2019.
Compliance tool used: Notice of Non-compliance (NNC)
Upon review of North River's documentation provided, NEB inspector officer (IO) noted several instances of outdated information that referenced the Pipeline Crossing Regulations, outdated reference to past NEB brochures and outdated revision dates to North River's documentation providing inaccurate information to but not limited to the public and third parties contractors pursuant to the Onshore Pipeline Regulations (OPR) s. 47.2 and the National Energy Board Pipeline Damage Prevention Regulations.Based on the outdated and inaccurate information noted throughout NorthRiver's material and related procedures, NorthRiver has not demonstrated that it maintains its Damage Prevention program as required by the OPR section 47.2.Therefore, the IO requires that NorthRiver provide it's updated documentation ensuring that it reflects current regulatory requirements and how it will be maintained it going forward to the NEB by December 31, 2019.
Due date: 2020-03-31
Date closed: 2020-04-17 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.
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