Compliance Verification Activity Report: CV2223-075 - Plains Midstream Canada ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1686

Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Damage Prevention

Rationale and scope:

Field inspection of O&M activities. Inspection of 2nd party oversight in accordance with the Damage Prevention Regulations.

Compliance tool(s) used:

• None

Facility details

Facilities:

• KERROBERT PIPELINE

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• 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

Observations (no outstanding follow-up required)

Observation 1 - Damage Prevention 2nd party field inspection

Date & time of visit: 2022-10-13 07:03

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Processes and Standards
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Vehicle or Mobile Equipment Crossings
• Authorization and Consent
• Ground Disturbance
• Authorization and Consent

Facility:

• KERROBERT PIPELINE (Pipeline)

Observations:

The Canada Energy Regulator (CER) Inspections Officers (IO) conducted a Damage Prevention inspection focusing on second party contractor oversight with Plains Midstream Canada ULC (Plains) on Oct. 13, 2022.
IOs were on site to observe a Plains integrity dig on the Kerrobert Pipeline at the Empress 1-5 facility. The integrity dig followed  an in-line inspection that identified anomalies on the 8” NGL pipeline.
IOs attended Plains 2^nd party tail gate meeting led by the Plains Construction Supervisor, who is a contract employee that has worked for Plains for several years.  BSR (the project contractor) also discussed the work for the day. Topics discussed during the morning safety meeting included:

• Depth of cover monitoring and communication
• The pipeline was daylighted with slot trenches on Oct 12/22
• Depth of pipe was confirmed as 49 inches to the top of pipe
• The hazards related to moving equipment 
• Hand signals required and eye contact with the machinery operator
• Project staff was reminded to obey all signage and speed limits while driving through the Empress facility site fence.
• Wildlife including rattle snakes that are present in the area during warm weather.  Was not a concern at this time of year but be aware
• Walking on uneven ground
• Plains Construction Supervisor conducts an Emergency response Tabletop Rehearsal with crew prior to beginning the project.
• the nearest hospital was identified as Leader or Medicine Hat
• First aid and defibrillator located inside the Empress facility
• All work is stopped if the Construction Supervisor leaves the site.

• Project Safety Plan
• Project site specific Emergency Response Plan
• FLHA
• Arnett & Burgess Oilfield Construction Ltd. Daily Toolbox Meeting sheet

• 6 workers onsite for the project including the Construction Supervisor
• Dig site was located in an uncultivated field owned by Plains just outside the Empress facility fence.
• At the time of the inspection, soil was very dry which made exposing the pipe go relatively quickly.
• Operating pressure was reduced on the pipeline for the duration of the dig and any possible remediation that may be required.
• Locates  were conducted the previous day.
• Excavating equipment to be 60 cm, 2 ft away from top and side of pipe. Plains uses a 2 foot stick to allow for easy visualization of mechanical excavation limits. 
• Construction Supervisor safety procedure is to contact the Plains Control Center when starting and stopping work for the day
• Communication within crew acknowledged 
• Crew was hand-digging with shovels within 2 feet of the line. Crews rule is to stop all work if they lose sight of the pipe
• Excavation runs parallel to the pipe, 18 meters in length. Pipe supports are every 5 meters  
• Excavator used a "spoon" attachment to clear dirt out of the underside of the pipe to avoid having to reach a bucket over the pipe. 
• CER IOs left the site once the pipe had been exposed 
• IOs did not observe any issues of concern to non-compliance while on site
   

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: