Compliance Verification Activity Report: CV2021-132 - Montreal Pipe Line Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2408
• Inspector 2391
• Inspector 2474

Regulated company: Montreal Pipe Line Limited

Operating company: Montreal Pipe Line Limited

Province(s) / Territory(s):

• Quebec

Discipline(s):

• Damage Prevention

Related events:

• CV2223-254

Rationale and scope:

[Verify compliance to the OPR and DPR with focus on third party oversight procedures]

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• 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
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 2 - Documentation Review and Process Discussion.

Date & time of visit: 2021-09-20 15:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Processes and Standards
• Public Awareness Program
• Manage and Mitigate
• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Reporting
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Agricultural Activity
• Authorization and Consent
• Temporary Crossings
• Locates and Information
• Locate Requests
• Duty to Inform
• One-call Centre
• Obligation to Provide Information
• Ground Disturbance
• Authorization and Consent
• Temporary Prohibition Area
• Guidelines
• Facility
• Authorization and Consent
• Existing Facilities

Facility:

Observations:

Documentation Review and Process Discussion.
 

• The Company holds 280 easement agreements and has 400 landowners along its ROW from the US border to their Montreal-area facilities in Quebec.
• The Company stated that it conducted approximately 98 locates in 2020 and 70 so far in 2021 around the prescribed area and 68 locates around the area that extends 30 metres from the edge of the ROW. MPLL contacts approximately 334 landowners twice a year and ensures that all landowners are contacted once in the four-year cycle.
• Documentation provided by MPLL around suggest that Aerial patrols are performed on a biweekly basis using fixed wing aircraft. The pilot is teamed  once a year by MPLL Maintenance Technician.
• The Pilot conducts visual inspections and reports on what he sees on and adjacent to the ROW directly to Company representatives. Interviews with field staff suggest that a combination of vehicular/foot patrol inspection is conducted by on a quarterly basis.
• Findings are then filed and stored in their Continual Improvement (CI) database.

Compliance tool used: No compliance tool used

Observation 3 - Aerial Patrol Documentation Provided was Exception-Based.

Date & time of visit: 2021-09-20 15:30

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Reporting

Facility:

Observations:

• IO Observed that the Aerial Patrol Documentation Provided was Exception-Based.
• Patrol Reports: Exception reporting (recording issues only), does not adequately document that an assessment of the conditions on the right of way has occurred. This is a non-compliance under CSA 10.6.1.1..
• In order to meet the requirements, Company must demonstrate that conditions as listed in CSA 10.6.1.1. are subject to documented ongoing monitoring.
•  Company will be required to demonstrate how it is meeting its regulatory requirements for patrols.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• CSA Z662-19 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 10.6.1.1. Operating companies shall periodically patrol their pipelines in order to observe conditions and activities and adjacent to their rights of way that can affect the safety and operation of the pipelines. Particular attention shall be given to the following: A) construction activity B) Dredging operations C) Erosion D) Ice effects E)Scour next F) Seismic activity G) Soil slides H) Subsidence I) Loss of cover J) Evidence of leaks; and K) Unauthorized activities

Company action required:

• IO Observed that the Aerial Patrol Documentation Provided was Exception-Based.
• Patrol Reports: Exception reporting (recording issues only), does not adequately document that an assessment of the conditions on the right of way has occurred. This is a non-compliance under CSA 10.6.1.1..
• In order to meet the requirements, Company must demonstrate that conditions as listed in CSA 10.6.1.1. are subject to documented ongoing monitoring.
•  Company will be required to demonstrate how it is meeting its regulatory requirements for patrols.

Due date: 2022-01-31

Date closed: 2022-02-04
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: