Compliance Verification Activity Report: CV2021-437 - Commandité gestion energy windmill DREAM Québec inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-437
Start date: 2020-05-20
End date: 2020-05-20

Team:

Regulated company: Commandité gestion energy windmill DREAM Québec inc.

Operating company: Commandité gestion energy windmill DREAM Québec inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Status observation of Commandité gestion energy windmill DREAM Québec inc. (Windmill) deactivated pipelines identified under MO-071-2018.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Chaudiere Bridge

Date & time of visit: 2020-05-20 10:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide photos of the current status of the pipes under the Chaudiere Bridge. The photos should capture the width of the bridge as shown below in the sample image and in addition to zoomed in photos of the damage.
 

Due date: 2020-05-28

Date closed: 2020-05-22
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 2 - Ongoing Monitoring

Date & time of visit: 2020-05-20 12:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Condition 2 in MO-071-2018 states https://apps.cer-rec.gc.ca/REGDOCS/Item/View/3611064 :

2.Windmill shall maintain the Pipelines in a deactivated state in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related submissions.

In the application to deactivate the lines, National Energy Board Information Request No. 1 1 Response, Windmill comitted to monitoring the lines: https://apps.cer-rec.gc.ca/REGDOCS/Item/View/3580085
A92793 Reference No.: OF-Fac-OtherComm-C991-2018-01 01. Windmill’s Responses

1.3 Deactivated Facility Monitoring

Please clarify how Windmill will conduct ongoing monitoring of the deactivated pipelines as required in Reference i).

The deactivated pipelines are continuously monitored and will continue to be monitored for the foreseeable future by on site security staff. Security staff conduct regular visual surveys of the pipelines and will report any concern to Windmill. Note that the pipelines are relatively inaccessible as they are suspended from a bridge.

During a phone call as part of this inspection the company told the CER that it was unaware that a section of the 4-inch pipe was missing and unsure of the specific date this occured, however, it suspected that it was during the April 2019 flood. During the phone call the company was unable to confirm to the CER that it has continuously monitored the pipelines. 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Due date: 2020-06-12

Date closed: 2020-06-01
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 - Mitigation

Date & time of visit: 2020-05-20 12:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

In the section 5.3.1 of its 29 March 2018 application to deactivate the lines, Windmill stated “Windmill will continue to manage the already deactivate pipelines as at present.”
 
During a pre-application meeting between the CER and Windmill in May 2020, Windmill told the CER that asbestos may present in the wrapping on the pipes.
 
During the field inspection on 20 May 2020, the inspector observed the 4 inch pipe and its supports may be severely damage and/or missing. The inspector also observed the wrapping on all of the pipes may be severely damaged and/or missing.
 
The CER is of the view that the pipes in their current state, may not have been managed in a manner to “mitigate potentially adverse safety or environmental effects”.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Windmill shall immediately:

Due date: 2020-06-12

Date closed: 2020-06-01
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