Compliance Verification Activity Report: CV1920-511 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-511
Start date: 2020-02-19
End date: 2020-02-19

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

In particular, the inspection will focus on the following: - The adherence to the DPP as written for work around its own existing facilities and other utilities - The management of and compliance to the permits obtained - Managing safety in proximity to various utilities including roads, traffic, other pipelines and buried infrastructure. - Communication of safety requirements and procedures between all parties onsite during the crossings - The roles of parties onsite - Record keeping - Other related issues if observed

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - TMEP Damage Prevention Inspection, Line 2

Date & time of visit: 2020-02-19 10:40

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Feb 19, 2020 CER staff conducted an opening meeting with TMEP followed by a damage prevention field inspection on TMEP Line 2.
CER Observations noted below.

Opening Meeting conducted at 8:23 am:

TM’s Safety Orientation presented to CER staff at 9:50 am prior to field inspection. Safety orientation covered;CER staff signed TM’s Orientation Sign Off Sheet and SA's Sign Off Sheet

Field Inspection:
Documentation viewed on site;First field inspection stop @ 10:40 am        KP 44   N 53.51615   W -113.69122
CER staff observed locate markings for boring activity to take place under road way. Locate marking are in a narrow green space with houses on both sides.
No crews were on site and no activity at the time of observation.

Second field inspection stop @ 11:25 am    N 53.48360    W -113.33390
DPI presented CER staff with FLRA
There are 6 utility owner in this area. Enbridge has three lines, Apple (Trans Northern), NOVA and Atco.
Pipeline corridor crosses Hwy 13.
CER staff signed SA’s Task Analysis Safety Card.

Thrid field inspection stop @ 1:55 pm   N 53.43739   W -113.41365
CER staff observed stripping activity taking place.
EPCOR and Shaw are working close by in the area.
Building pad is underway for HDD activity under 50st NW.

Fourth field inspection stop @ 2:32 pm   N 53.46420    W -133.61863
SA Energy conducted a site specific orientation to CER staff.
HDD activity taking place that crosses the North Saskatchewan River, approx. 1400 meters. Pipe will be 52 meters below the water line.
At this location, Atco runs parallel with Line 2. Additionally, Line 2 will cross a fiber optic line and walking paths.
CER staff observed the Facility Crossing Agreement.

Fifth field inspection stop   N 53.50303   W -113.66111
CER staff observed hydrovac activity in this location. TM is running Line 2 under Atco.
CER staff observed boot cleaning stations located at various sites to prevention weed contamination 

4:40 pm, CER IO's conducted a close out meeting with TMEP staff and discussed our days observations and if TMEP staff had any questions.

Compliance tool used: No compliance tool used

Observation 2 - Notice of Non-Compliance - Reporting Obligations, Competency and Training

Date & time of visit: 2020-02-19 08:23

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Upon review of TMEP’s Damage Prevention Plan and the Canada Energy Regulator (CER) information requests, the CER inspection officer (IO) has determined that TMEP has not implemented a procedure for reporting to the CER as required by the Damage Prevention Regulations-Obligation of Pipeline Companies (DPR-O) s. 11. As TMEP is obligated to report any contravention of the Damage Prevention Regulations-Authorizations, the CER IO is requiring that reporting procedures be put in place.

Additionally, based on discussions with TMEP staff onsite the CER IO noted that TMEP employees/contractors unaware of how the DPR-O requirements would be applied to this project.

The CER IO requires that TMEP provide reporting procedures ensuring it reflects the DPR-O section 11 reporting requirements. In addition, TMEP must provide its method for ensuring that TMEP employees/contractors will be trained and competent to implement these procedures.

The above noted is due on or before 17 April, 2020.
 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Upon review of TMEP’s Damage Prevention Plan and the Canada Energy Regulator (CER) information requests, the CER inspection officer (IO) has determined that TMEP has not implemented a procedure for reporting to the CER as required by the Damage Prevention Regulations-Obligation of Pipeline Companies (DPR-O) s. 11. As TMEP is obligated to report any contravention of the Damage Prevention Regulations-Authorizations, the CER IO is requiring that reporting procedures be put in place.

Additionally, based on discussions with TMEP staff onsite the CER IO noted that TMEP employees/contractors unaware of how the DPR-O requirements would be applied to this project.

The CER IO requires that TMEP provide reporting procedures ensuring it reflects the DPR-O section 11 reporting requirements. In addition, TMEP must provide its method for ensuring that TMEP employees/contractors will be trained and competent to implement these procedures.

The above noted is due on or before 17 April, 2020.

Due date: 2020-04-17

Date closed: 2020-05-15
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 - Backfilling Report, Inspection and Field Observations

Date & time of visit: 2020-02-19 08:23

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Upon review of TMEP’s UG Facility Crossing Backfill Report template and procedures, the CER IO could not confirm that the company is addressing each of the requirements of the DPR-O section 8.  
 
In particular, the DPR-O section 8 states:
8 The pipeline company must

As these requirements are not explicitly accounted for in the current template and procedures relating to backfill inspections, the CER IO has noted these omissions as non-compliant and requires that TMEP provide its updated documentation to reflect  the current regulatory requirements pursuant to the DPR-O s. 8 (c) (ii)(iv) by April 17, 2020

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

Regulatory requirement:

Relevant section(s):

Company action required:

Upon review of TMEP’s UG Facility Crossing Backfill Report template and procedures, the CER IO could not confirm that the company is addressing each of the requirements of the DPR-O section 8.  
 
In particular, the DPR-O section 8 states:
8 The pipeline company must

As these requirements are not explicitly accounted for in the current template and procedures relating to backfill inspections, the CER IO has noted these omissions as non-compliant and requires that TMEP provide its updated documentation to reflect  the current regulatory requirements pursuant to the DPR-O s. 8 (c) (ii)(iv) by April 17, 2020

Due date: 2020-04-17

Date closed: 2020-05-15
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