Compliance Verification Activity Report: CV2122-314 - Hydro One Networks Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-314
Start date: 2021-09-07
End date: 2021-09-10

Team:

Regulated company: Hydro One Networks Inc.

Operating company: Hydro One Networks Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Field inspection to verify compliance to the International and Interprovincial Power Line Damage Prevention Regulations (IPLDPRs) during a construction project and regular operations.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - IPL:J5D DP Inspection

Date & time of visit: 2021-09-08 07:30

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Staff inspected J5D towers and accessories. The general condition of the site around the towers was satisfactory except for the deficiencies described in this report. Public access to the inspection sites on this line was restricted by padlocked gates. The vegetation on the tower 6 ROW was dense, further inhibiting public access to the tower, and providing environmental benefits for pollinators.  At times, the dense vegetation made inspection of the towers challenging.
 
According to the requirements of CSA 22.3 as described below, the following deficiencies were identified on the inspected sections of IPL J5D:

  1. Climbing Aid (CSA 22.3 Section 4.2.5.2): Structures that can be climbed without the use of special means shall be protected against climbing. 
  2. Signage:
    1. (CSA 22.3 Section 4.3.1d): Conductors, cables, and equivalent longitudinal strands of supply and communication lines shall be installed in such a manner as to facilitate identification by qualified persons. This may be achieved by one or more means, including marking or numbering; and
    2. (CSA 22.3 Section 4.2.5.2) Structures that can be climbed without the use of special means shall be protected by fences or other means against climbing, or shall carry signs in the predominant languages of the locality that warn against trespassing and call attention to the hazards.
 
Tower 8:
Deficiencies:Tower 7:
Deficiencies:Tower 6:
Deficiencies:Keith Substation:
Observations:
There was a ground disturbance activity in the station conducted by HO’s second party contractor for this job, Amico Affiliates.

Compliance tool used: No compliance tool used

Observation 2 - IPL: L4D Damage Prevention Inspection

Date & time of visit: 2021-09-08 13:00

Discipline: Damage Prevention

Categories:

Facility:

Observations:

This site was publicly accessible and there were no observed deficiencies at tower 13. Staff inspected L4D towers and accessories. The general condition of the towers were found satisfactory (except for the deficiencies).
The vegetation on the tower 10 ROW was dense, further inhibiting public access to the tower, and providing environmental benefits for pollinators.  At times, the dense vegetation made inspection of the towers challenging, particularly with the presence of wild parsnip on some ROWs. Hydro One personnel provided clear information and mitigation measures for CER inspectors regarding exposure to wild parsnip.
 
Tower 13:

According to the requirements of CSA 22.3 as described below, the following deficiencies were identified on the inspected sections of IPL L4D:
  1. Climbing Aid (CSA 22.3 Section 4.2.5.2): Structures that can be climbed without the use of special means shall be protected against climbing. 
  2. Signage:
    1. (CSA 22.3 Section 4.3.1d): Conductors, cables, and equivalent longitudinal strands of supply and communication lines shall be installed in such a manner as to facilitate identification by qualified persons. This may be achieved by one or more means, including marking or numbering; and
    2. (CSA 22.3 Section 4.2.5.2) Structures that can be climbed without the use of special means shall be protected by fences or other means against climbing, or shall carry signs in the predominant languages of the locality that warn against trespassing and call attention to the hazards.
Tower 10:
Deficiencies:

Compliance tool used: No compliance tool used

Observation 3 - IPL: L33P and L34P Damage Prevention Inspection

Date & time of visit: 2021-09-09 12:30

Discipline: Damage Prevention

Categories:

Facility:

Observations:

This site was publicly accessible and there were no observed deficiencies at tower 11. Staff inspected L33P & L34P towers and accessories. The general condition of the towers was found to be satisfactory. 
There was a linear park pathway running alongside of the ROW beyond tower 11, and vegetation on the tower 10 ROW was dense, inhibiting public access to the tower, and providing environmental benefits for pollinators.  At times, the dense vegetation made inspection of the towers challenging, particularly with the presence of wild parsnip on the ROW. Hydro One personnel provided clear information and mitigation measures for CER inspectors regarding exposure to wild parsnip.
Tower 11:

According to the requirements of CSA 22.3 as described below, the following deficiencies were identified on the inspected sections of IPL L33P and L34P:
  1. Climbing Aid (CSA 22.3 Section 4.2.5.2): Structures that can be climbed without the use of special means shall be protected against climbing. 
  2. Signage:
    1. (CSA 22.3 Section 4.3.1d): Conductors, cables, and equivalent longitudinal strands of supply and communication lines shall be installed in such a manner as to facilitate identification by qualified persons. This may be achieved by one or more means, including marking or numbering; and
    2. (CSA 22.3 Section 4.2.5.2) Structures that can be climbed without the use of special means shall be protected by fences or other means against climbing, or shall carry signs in the predominant languages of the locality that warn against trespassing and call attention to the hazards.
Tower 12:Substation:Deficiencies:Tower 10:
Deficiencies:
 

Compliance tool used: No compliance tool used

Observation 4 - Hydro One Damage Prevention document review

Date & time of visit: 2021-09-01 14:30

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Hydro One returned the concordance table sent with the required references to their programs, policies, and public awareness.  
CER staff reviewed the information with respect to IPLDPR-O s.8 (a) Damage prevention program public awareness requirements and found:

Deficiencies:
IPLDPR-O s.4 - Locates  
If a holder receives a request to locate the holder’s international or interprovincial power line from a person who intends to construct a facility across, on, along or under an international or interprovincial power line or engage in an activity that causes a ground disturbance within the prescribed area, the holder must, within three working days, after the day on which the request is made, or any longer period agreed to by the holder and that person,
inform the person, in writing, of safety practices to be followed while working in the vicinity of the holder’s international or interprovincial power line and, in case of a ground disturbance, within the prescribed area;
  1. inform the person, in writing, of safety practices to be followed while working in the vicinity of the holder’s international or interprovincial power line and, in case of a ground disturbance, within the prescribed area;
  2. mark the location of the underground portion of the holder’s international or interprovincial power line in the vicinity of the proposed facility or the prescribed area using markings that are clearly visible and distinct from any other markings that may be in the vicinity of the proposed facility or the prescribed area; and
  3. provide information to the person that clearly explains the significance of the markings.
 
While Hydro One’s locate response policy is 5 working days, the CER regulatory requirement is to provide a locate is 3 working days, after the day on which the request is made, or any longer period agreed by the holder and that person (IPLDPR-O s.4).

Notice of Non-compliance (NNC):
IPLDPR – O section 8 
The damage prevention program that a holder is required to develop, implement and maintain under section 8.1 of the International and Interprovincial Powerline Damage Prevention Regulations must include:
Public Awareness Program (*in the context of third party activities) an ongoing public awareness program to inform the public:

viii.  on the obligation to obtain an authorization before constructing a facility across, on, along or under an international or interprovincial power line, engaging in an activity that causes a ground disturbance within the prescribed area or operating vehicles or mobile equipment across an international or interprovincial power line, in the case of a vehicle or mobile equipment that is not operated within the travelled portion of a highway or public road,

Corrective action required:
Update the CER information on the Hydro One Secondary Land Use web page  which is outdated and inaccurate as it refers to orders MO-040-2019 and MO-41-2019, which were rescinded when the IPLDPRs came into force in 2019 (IPLDPR - Authorizations) and 2020 (IPLDPR - Obligations).

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

Regulatory requirement:

Company action required:

Update the CER information on the Hydro One web page(s) to reflect the current International and Interprovincial Power Line Damage Prevention Regulations - Authorizations and  International and Interprovincial Power Line Damage Prevention Regulations - Obligations of Holders.

Due date: 2021-11-05

Date closed: 2021-10-25
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