Compliance Verification Activity Report: CV1718-114 - TransCanada PipeLines Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2408
• Inspector In Training 2444T

Regulated company: TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Damage Prevention

Related events:

• CV1819-256
• UX2016-047
• UX2016-063
• UX2016-116
• UX2016-134
• UX2016-152
• UX2016-172
• UX2017-145
• UX2018-101
• UX2018-251

Rationale and scope:

This activity is a field inspection of right-of-way between North Bay, ON - Oshawa, ON. Inspection will verify compliance to OPRs and DPRs, inclusive of site visits to reported unauthorized activity locations, third party construction locations, and road/rail crossings within the Rideau and Maple & Niagara areas.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (2)

Facility details

Facilities:

• LINE 100-1
• LINE 1200-2
• Line 1200-1
• LINE 100-3
• Line 200-2
• LINE 100-2

Facility Types

• Pipeline
• Pipeline right of way (ROW)

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 - Tuesday 3 October 2017 - RoW Inspection between North Bay and Huntsville, ON

Date & time of visit: 2017-10-03 08:00

Discipline: Damage Prevention

Categories:

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

Facility:

• LINE 100-1 (Pipeline)

Observations:

NEB Inspection Officers and TCPL staff conducted a right-of-way(RoW) inspection of signage, vegetation management to ensure clear visibility and access of the RoW, historical unauthorized activity locations, and third-party activity at various locations along the TCPL RoW between North Bay and Huntsville, ON. The RoW at the following locations was observed to be maintained in accordance with CSA Z662 10.6.2. Site locations were as follows:

46.3761 / -79.4661 (Highway 11 at Barnett Road, North Bay, ON - Site of UX2016-047):

• Three active TCPL pipelines at this road crossing location. Discussed UX2016-047 which occurred at this location.

• Signage was compliant with CSA Z662-15 10.5.3.3.

• Two lines at this location. Reviewed and discussed the activity's Stakeout Report and Ground Disturbance Approval form. Signage was compliant with CSA Z662-15 10.5.3.3.

• Site visit and discussion regarding a report of unauthorized activity at this location from 2016. Signage was compliant with CSA Z662-15 10.5.3.3.

• Signage was compliant with CSA Z662-15 10.5.3.3. 
• Agricultural land

• Signage at this overpass road crossing was visible from the travelled portion of the roadway and compliant with CSA Z662-15 10.5.3.4, however, the emergency contact information was not easily accessible due to marsh conditions. Company staff agreed to place the signage closer to the roadway, if possible.

• NEB Inspectors received a site orientation upon arrival at this compressor station, and met with TCPL lands agent who would attend the rest of the day's inspection. Signage at the facility was compliant with CSA Z662-15 10.5.4.1. 

• Signage was compliant with CSA Z662-15 10.5.3.3. Company staff indicated Bell FOTS shared the same RoW in this area. NEB Inspectors were approached by a nearby landowner who asked questions. The landowner was aware of the presence of the pipleline and advised that they had been in reciept of TCPL's public awareness materials and the steps to take in the event they wanted to conduct a ground disturbance or suspected a leak.

• Signage was compliant with CSA Z662-15 10.5.3.3. Company staff indicated Bell FOTS shared the same RoW in this area. TCPL lands agent demonstrated a thorough knowledge of the area and ground disturbance activities therein.

• High-Pressure Natural Gas and Cathodic Protection signage were observed and found to be compliant with CSA Z662-15 10.5.3.3 and 10.5.4.1 for signage at the facility.

Compliance tool used: No compliance tool used

Observation 2 - CNC #1 of 2 - RoW signage did not indicate type of pipeline system

Date & time of visit: 2017-10-03 10:10

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Railway and Road RoW

Facility:

• LINE 100-1 (Pipeline)

Observations:

NEB Inspectors observed signage for three TCPL lines at this road crossing location, however the signage did not display information regarding the type of pipeline system (High-Pressure Natural Gas Pipeline). This was in non-compliance with CSA Z662-15 10.5.3.3(b).

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:

TCPL verbally agreed to replace the RoW signage at this location such that it indicates the type of pipeline system (High-Pressure Natural Gas Pipeline) per the requirements of CSA Z664-15 10.5.3.3(b).

 

Due date: 2017-10-05

Date closed: 2017-10-04
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 - Wednesday 4 October 2017 - RoW Inspection between Barrie, ON and Oshawa, ON

Date & time of visit: 2017-10-04 07:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Public Awareness Program
• RoW Maintenance
• Vegetation
• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Reporting
• Pipeline Identification
• Signs
• Railway and Road RoW
• Locate Markings
• Vehicle or Mobile Equipment Crossings
• Authorization and Consent
• Locates and Information
• Locate Requests
• Ground Disturbance
• Authorization and Consent

Facility:

• LINE 100-1 (Pipeline)

Observations:

NEB Inspection Officers and TCPL staff conducted a RoW inspection of signage, vegetation management to ensure clear visibility and access of the RoW, historical unauthorized activity locations, and third-party authorized activity at various locations along the TCPL RoW between Barrie, ON and Oshawa, ON. The RoW at the following locations was observed to be maintained in accordance with CSA Z662 10.6.2. Site locations were as follows:

44.3396 / -79.7398 (County Road 27, Barrie, ON - Site of UX2016-116):

• Third party construction site and the location of a ground disturbance activity within the 30 metre prescribed area.Two temporary crossing agreements were in place at this location. Construction activities at the site are currently shut down and there has been no new activity for approximately one year. TCPL told the NEB inspectors that a Safety assessment was completed, including geotechnical assessment. The RoW is fully silt-fenced to control erosion and act as a physical barrier, stakes are in place. Signage was compliant with CSA Z662-15 10.5.3.3.
• NEB inspectors were able to view the condition of the RoW adjacent to this site from the above mentioned loaction. The RoW serves as greenspace for adjacent landusers.

• Observed road crossing within the Town of Thornton. RoW well maintained. Signage observed was compliant with CSA Z662-15 10.5.3.3.

• Observed road crossings in agricultural land areas outside the Town of Thornton. RoW well maintained. Signage observed was compliant with CSA Z662-15 10.5.3.3.

• Site visit at newer housing development area where reports of unauthorized activities have occurred throughout the development. As a result of the reports of unauthorized activities, TCPL conducted a Safety Stand-down during which time all work was stopped, and TCPL lands staff provided information and educational materials to contractors and the developer. The company advised they will monitor vacant lots in the development for signs of activity and development. Signage observed was compliant with CSA Z662-15 10.5.3.3.

• Site visit of RoW which is a greenspace through the community. Clean and well maintained RoW for visibility. Company advised there are ongoing discussions with the developer regarding plans for future development of a roundabout and aesthetic structures within proximity to the RoW. The area at the edge of the RoW was marked with non-TCPL red survey stakes which were believed to extend more than 30 centimetres into the ground. The company advised it will confirm depth of stakes and that consents are in place.

• The RoW crosses rail tracks at this location. TCPL advised one of their inspectors will be on-site at this location when a final section of new fencing parallel to the railway is installed.

• Signage observed at road crossing was compliant with CSA Z662-15 10.5.3.3.

• Three active lines and one abandoned line at this location. UA at this location involved commencing work prior to inspector on-site. To proactively address reports of unauthorized activities, TCPL staff conducted a Safety Stand-down with the RM of York (Municipality) in December 2016, and advised that the Municipality has been diligent and compliant in response to the Safety Stand-down. TCPL lands agent was very knowledgeable about activities within the area and and explained the pipeline route through the area. The area is currently an active construction site, with preparatory work for paving. Pipes have been daylighted on both sides of the roadway. TCPL land agent advised he regularly spot checks third parties in his area for forms and maintains ongoing dialogue with contractors. TCPL anticipates their involvement at this location will be complete in a few weeks. One light pole at the location is on-site and awaiting installation, pending approvals for contractor to complete the installation.

• Lines switch from 3 to 2 at this location. Signage observed was compliant with CSA Z662-15 10.5.3.3 and 10.5.4.1.

• Site visit at location of UX2016-134, a UA that was identified by aerial patrols as a ground disturbance without an Ontario One Call or consent. The work was subequently completed with a permit under the supervision of an on-site TCPL inspector. Company discussed their public awareness program and the individual land representative attempts to meet face-to-face with all landowners in the area. Company personnel travel with public awareness packages in vehicle, and the company meets face-to-face with schools and delivers specific public awareness materials to schools.

• Signage observed was compliant with CSA Z662-15 10.5.3.3 and 10.5.4.1.

• The company advised this UA involved pulverizing the road without locates, and the activity was subsequently permitted and the work completed. Company explained they have worked to establish good relationships with regions and contractors, that timely UA response is key, and Ontario One Call law has been helpful.

• TCPL advised that earthworks at this construction site have been completed and the next step is paving. NEB Inspectors were escorted into the construction site via TCPL staff. NEB Inspectors observed markers in place and company staff advised that signage will be placed on fences when the fences are erected. Company representative was knowledgeable in the area and of construction activities, and explained his triage process for locate requests. Company representative noted he is in constant contact with Enbridge counterpart as lines are in the same area. NEB inspectors reviewed completed Stakeout Report & Ground Disturbance Approval forms for the completed earthworks at the construction site, inclusive of amendments and report log.

Compliance tool used: No compliance tool used

Observation 4 - CNC #2 of 2 - RoW signage did not indicate the word "Warning", "Caution", or "Danger" and contained an invalid emergency number

Date & time of visit: 2017-10-04 10:25

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• LINE 100-1 (Pipeline)

Observations:

NEB Inspectors observed signage for two TCPL lines at this rail crossing location, however the signage did not display the word "Warning", "Caution", or "Danger" as required to be compliant with CSA Z662-15 10.5.3.3(a). In addition, the signage appeared weathered and faded, and displayed the emergency phone number 1-800-827-5094. All signage that was inspected prior to this location displayed the emergency phone number 1-888-982-7222.

NEB Inspectors dialed the emergency telephone number displayed on the signage at this location (1-800-827-5094) and were connected to a voicemail message advising to call a different number which is non-compliance to 10.5.3.3(c).

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:

TCPL verbally agreed to replace the RoW signage at this location with new two-sided signage such that the information on the signage displays the word "Warning" and displays a current emergency telephone number (1-888-982-7222) as required to be compliant with CSA Z662-15 10.5.3.3 (a) &(c). 

 

Due date: 2017-10-05

Date closed: 2017-10-05
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

Observations (company follow-up required)

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