Compliance Verification Activity Report: CV1718-054 - Genesis Pipeline (Canada) Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2408

Regulated company: Genesis Pipeline (Canada) Ltd.

Operating company: Nova Chemicals Corporation

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Damage Prevention

Related events:

• CV1718-155
• CV1718-156
• CV1718-411

Rationale and scope:

Damage Prevention Right-of-Way inspection of the Genesis Pipeline (Canada) Ltd. in Sarnia, Ontario to ensure compliance with the National Energy Boards legislative requirements, including the Damage Prevention Regulations and Onshore Pipeline Regulations.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

• Genesis Line 20 Extension
• 8" NGL Pipeline from St. Clair River to Sarnia
• 6" Propylene Pipeline from St.Clair River to Sarnia
• 6" Ethylene Pipeline from St.Clair River to Sarnia

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• 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
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Damage Prevention Right-of-Way inspection of the Genesis Pipeline (Canada) Ltd. to ensure compliance with the National Energy Boards regulatory requirements

Date & time of visit: 2017-05-09 13:00

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Railway and Road RoW

Facility:

• Genesis Line 20 Extension (Pipeline)

Observations:

NEB staff observed three pipeline identification/warning signs at the same location.  Two signs were in compliance but NEB inspectors noted that one sign did not indicate the area code with the emergency number. This is in contravention to CSA Z662-15. s.10.5.3.3 (c).

Inspectors also note that this is a repeat finding, as this was identified at another location on the Genesis Pipeline RoW during an inspection conducted in 2010 in the same geographical area. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 10. Operating, maintenance, and upgrading
    • 10.5 Operating and maintenance procedures
      • 10.5.3 Pipeline identification
        • 10.5.3.3 Signs shall include the following information, printed on a background of sharply contrasting colour:
          a) the word “Warning”*, “Caution”*, or ”Danger”* prominently displayed, in 25 mm high, bold lettering;
          b) the type of pipeline system, such as “High-Pressure Natural Gas Pipeline”†, prominently displayed in 13 mm high bold lettering; and
          c) the name of the operating company and emergency notification information, including an emergency telephone number with area code.
          * The equivalent French wording is “Avertissement“, “Attention”, or “Danger“, respectively.
          † The equivalent French wording is “Canalisation de gaz naturel à haute pression“.
          Note: It is recommended that
          a) signs include a statement such as “Call before you dig” (equivalent French wording: “Téléphoner avant de creuser”) or “Call for locate” (equivalent French wording: “Téléphoner pour repérer“); and
          b) consideration be given also to including the required information in a language appropriate to the region in which the sign is located.

Company action required:

Sign is to be corrected to comply with the Onshore Pipeline Regulations (OPR) 4 (1) (d) and CSA Z662-15 10.5.3.3 (c)

OPR 
4 (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of
(d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons;

CSA Z662-15 10.5.3.3
(c) the name of the operating company and emergency notification information, including an emergency telephone number with area code.

Due date: 2017-05-10

Date closed: 2017-05-10
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 - Damage Prevention Right-of-Way inspection of the Genesis Pipeline (Canada) Ltd. to ensure compliance with the National Energy Boards regulatory requirements

Date & time of visit: 2017-05-09 13:00

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Vegetation
• Damage Prevention Program
• Monitoring
• Processes and Standards
• Public Awareness Program
• Manage and Mitigate
• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW
• Locate Markings
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Vehicle or Mobile Equipment Crossings
• Guidelines
• Authorization and Consent
• Locates and Information
• Locate Requests
• One-call Centre
• Ground Disturbance
• Authorization and Consent
• Guidelines
• Facility
• Existing Facilities

Facility:

• Genesis Line 20 Extension (Pipeline)

Observations:

Genesis Pipeline (Canada) Ltd. is owned and operated by Nova Chemical (Canada) Limited. NEB staff conducted a Compliance Screening meeting the morning of May 9th, 2017 with Nova Chemicals and interviews and documents reviewed informed the right-of-way inspection. The following list outlines some of the documents reviewed and information provided during the meeting:

• Locating and Ground Disturbance Process;
• Safety practices, locate forms and vehicle management program;
• Safe Ground Disturbance practices;
• Reviewed Crossing and Proximity Agreements;
• Nova Chemicals Responsible Care & Sustainable Program refers back to Nova Chemicals Pipeline Damage Prevention Program; 
• Nova Chemicals Ongoing Monitoring of Land Use and Ownership maintaining stakeholders contact lists;
• Open houses are organized once or twice a year addressing questions and concerns for the public;
• Nova Chemicals regularly meets with local First Nations communities;
• Aerial surveillance is conducted on a weekly basis;
• Ground surveillance is conducted 26 times per year;
• No agricultural activity in the area;.
• Contracted excavation services are certified in Level II Ground Disturbance, or Ground Disturbance Supervisor;
• Connection Newsletters are distributed several times throughout the year to multiply organizations and neighbors;
• Nova Chemicals is a member of the Ontario Regionals Common Ground Alliance (ORCGA) and Ontario One Call service; and
• Nova Chemicals Damage Prevention external website detailing below:
  • Dig Safe Month – April 2017
  • Keeping in Touch pipeline brochure
  • Guidance for Working Near Our Pipelines
  • Design and Construction Guidance and Crossing/Proximity Information Form. 

• NEB staff called Nova Chemicals emergency number posted on their RoW markers and confirmed it was answered. The emergency number goes to Nova Chemicals Control Room and is manned 24/7.
• NEB staff observed Nova Chemicals facility and RoW signage to be in good condition and in compliance with the CSA Z662-15 10.5.3 Pipeline Identification and 10.5.4 Signage at Stations and Other Facilities. 
• NEB staff observed a section of the RoW staked with pink locate markers as part of an approved ground disturbance in the prescribed area. The use of pink locate stakes is not consistent with Nova Chemicals Damage Prevention program, however, to avoid confusion with another company’s yellow markers running parallel to theirs, Nova Chemicals' staff received permission from their superior to deviate from the normal locate marking procedure. During the inspection Nova Chemicals staff stated that they knew, in this case, the pink markers actually meant the location of the pipe and that it took the place of the standard yellow marker. Nova Chemicals staff confirmed the next day that the recipient of the encroachment agreement was made aware of the significance of the pink marker and that at this location the Nova Chemicals pink marker meant the oil/gas pipe and not a survey marker as required per the National Energy Boards Damage Prevention Regulations-Obligations s6(1)(b)
• NEB staff observed the right-of-way to be maintained such that vegetation was controlled to ensure adequate visibility as per as per CSA Z662-15 10.6.2 

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: