Compliance Verification Activity Report: CV2122-090 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-090
Start date: 2022-05-02
End date: 2022-05-04

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Canada Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Verify compliance to the requirements contained within the Onshore Pipeline Regulations (OPR) and the CER Damage Prevention Regulations - Obligations of Pipeline Companies (DPR-Obligations) with a focus on third party oversight procedures. Field inspection included document review and site inspection of active third party crossing activity.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Information Request

IR from CER (Information Request sent from CER to company)
IR#1 - 30m GD Permit and Additional Future Works

Legislative Requirement : Onshore Pipeline Regulations (OPR)

Sections of the Act

  • Onshore Pipeline Regulations (OPR)
    • 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 Pipeline Companies.

Theme and Categories

Damage Prevention
  • Damage Prevention Program
    • Manage and Mitigate
  • Ground Disturbance
    • Authorization and Consent

Due Date : 2022-05-17

Review Response
Acceptable

Follow-up Action
None

Observations (no outstanding follow-up required)

Observation 1 - Damage Prevention Program Pre-Inspection IR

Discipline: Damage Prevention

Categories:

Facility:

Observations:

As part of the scope of this field inspection which includes document review, the CER IOs require information pertaining to the TQM Damage Prevention Program as required pursuant to section 47.2 of the OPR. 

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

IR#1 - Sent 20 Oct 2021

Due date: 2021-10-29

Date closed: 2022-05-05
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 - Oversight of 3rd Party Excavation for Watermain Installation

Date & time of visit: 2022-05-02 07:30

Discipline: Damage Prevention

Categories:

Facility:

Observations:

CER IO arrived at site at 7:30am (Pacific Time) and attended the safety meeting led by the Trans Mountain (TM) Pipeline Inspector who went through the Safety Meeting for Ground Disturbance/Proximity Installation and Pipeline Protection Inspection Security Checklist and had everyone present sign the document (i.e., prime contractor, hydrovac personnel and CER):

The 3rd party construction project being observed was the installation of a watermain on top and across the TM pipeline along Chilliwack River Road, with isolation valves to be installed 1.5m from either side of the pipe to allow the waterline to be shut off and lifted if work on the TM oil pipeline is required in the future. CER IO requested reason the waterline was going over the TM pipeline rather than under, where it was explained that (1) the watermain needed to be maintained at a certain elevation and (2) that two isolation valves were to be installed 1.5m away from the pipe to allow TM to access its pipeline if it needs to inspect the pipe or work on it - TM would have the City shut the water off at the isolation valves and lift the waterline out. The following was observed:  The CER IOs reviewed the following documentation with respect to the ductile iron watermain facility installation:

Compliance tool used: No compliance tool used

Observation 3 - Sites of Previous DPR Contraventions and Active Developments

Date & time of visit: 2022-05-03 09:30

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Site visit of location of recent DPR contravention in Abbotsford, BC:

IOs accompanied Trans Mountain representatives to the site of a recent damage to pipe which was discovered by the pipeline company in April 2022 in Abbotsford. Upon arrival at the site, CER IOs observed the following:

Company representatives explained that the pipeline damage was assessed upon discovery, repaired accordingly and backfilled. They have followed up with the parties involved and expect the final submission of the report to be completed within the deadline.

Company representatives also shared concerns with crop changes in the area and, in particular, the new crop of hops which grow high thus impeding the view for aerial patrols and requiring the installation of posts. Changes in lessees have also created challenges recently but the company continues to monitor the area. 

Site visit of location of previous DPR contravention and active developments on Cottonwood Avenue in Coquitlam, BC:

IOs accompanied Trans Mountain representatives along Cottonwood Avenue in Coquitlam, BC where previous DPR contraventions events had taken place in 2021 during disconnection of services in preparation for construction of a new housing development at the corner of Cottonwood Avenue and Fairview Street.

The IOs observed the following: Trans Mountain explained that this area is patrolled by air twice a week (weather permitting) as well as ground patrols conducted also twice a week. The Pipeline Inspector added that he also walks or drives on Cottonwood Avenue every workday.

Trans Mountain also informed the CER IOs that some of the developments will eventually require to be connected to services such as water which will involve the installation of underground facilities to be installed across the pipeline.

Trans Mountain further added that these large housing development projects underway have created communication difficulties between the developers and various contractors undertaking the work. CER IOs noted Trans Mountain's efforts in engaging with the developers and other 3rd parties involved to date. Continued engagement with Trans Mountain will be considered to follow the progress made on the construction projects progress and engage the appropriate stakeholder as required.

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:

- 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