Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans-Northern Pipelines Inc.
Operating company: Trans-Northern Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
An exposed pipeline was reported in Saint Lazare, Quebec. Inspectors will attend the site to confirm compliance.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Site Access
Date & time of visit: 2016-06-30 16:10
Discipline: Damage Prevention
Categories:
Facility:
Observations:
The area of the incident is in in a forested area, located approximately 450 meters east of the landowner's house in Saint Lazare, Quebec. A gravel access road extends east from the main road and meeting the forested Right-of-Way (RoW) approximately 300 m east of the home. Diverse vegetation, including deciduous trees, woody herbaceous species, ferns and other established understory plants were observed on the RoW leading to the site of the temporary fix for the exposed pipeline. The Trans-Northern Pipeline Inc. (TNPI) Representative indicated that aerial patrols of the pipeline are conducted once a week in this area. Vehicle patrols are conducted weekly, and the pipeline is patrolled on foot annually. The TNPI representative indicated that the issue of the exposed pipe was not identified as part this RoW patrolling by TNPI. The issue was brought to the company's attention by a relative of the landowner who noticed the exposed pipe while hiking in the area.Yellow caution tap were stretched and tied across the RoW leading to the site. According to the TNPI Representative, the purpose of the caution tape was to keep members of the public away from the work area. In addition, yellow ropes were also in place near the creek as a safety precaution against slips, trips and falls.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Please provide a response confirming the monitoring program for this section of the RoW functions, including confirmation of frequency of patrols and the most recent patrol records.
Due date: 2016-07-31
Date closed: 2016-09-09 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 - Regulatory Requirements - IR
Date & time of visit: 2016-06-30 17:10
Discipline: Environmental Protection
At the time of the inspection, a representative from the Quebec Provincial Ministry of the Environment (Ministere du Developpement durable, de l'Environnement, de la Faune et des Parcs) was on site. The Provinical Represenative indicated that TNPI requested a provincial permit for the work, however TNPI went ahead with the repair prior to the signing and completion of the permit. Enforcement may be pending from the province on this issue.
Please submit a copy of provincial permits, issue dates, and provide confirmation that allprovincial and federal requirements were met prior to commencement of work on the temporary repair.If any provincial or federal requirements were not met, please provide rationale for the omission.Please provide TNPI's plans including a schedule to meet all federal, provincial and/or municipalnotifications, permits and/or requirements prior to any further work at the exposure site.
Due date: 2016-09-09
Date closed: 2016-11-09 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.
Observation 3 - Regulatory Requirements
Compliance tool used: Notice of Non-compliance (NNC)
Please provide a written response indicating how TNPI will ensure that in the future, all required federal, provincial and/or municipal permits will be obtained in full prior to the start of work. Provide copies of any plans, procedures or programs that have been updated, that have been updated in order to ensure this does not happen again, with attention drawn to the updates.
Due date: 2016-09-30
Date closed: 2016-11-02 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.
Observation 4 - Temporary Repair of Exposed Pipeline
Date & time of visit: 2016-06-30 17:25
During the inspection, the NEB Inspection Officer (Officer) observed area of exposed pipeline at the watercouse crossing for a tributary named Cours d'eau Paiement. A temporary repair had been put in place that day. Works was completed, however workers had not yet departed the site. All work was conducted using hand tools, with no machinery or large large equipment used, according to the TNPI Representative on site.According to the TNPI Representative, the temporary repair was built using rock shield in layers, large rocks on either side of the pipeline, and approximately 30 bags of 2.5 inch river stone. Pickets were used to secure the fix in place, and river rock was placed over the repair. TNPI is in the process of planning a permanent repair. Additional follow-up is being conducted by the NEB's Pipeline Integrity group, as tracked by NEB Incident 2016-065.
Compliance tool used: No compliance tool used
Observation 5 - Erosion and Sediment Control
Date & time of visit: 2016-06-30 17:40
The work area is at the lower apex of east and west banks of a slope. Signs of erosion were noted on the east slope, in an area approximately 1 meter by 0.25 meters. This, along with the exposed pipe issue (Incident 2016-065) indicates that the area may be currently prone to erosion. TNPI represenatives indicated the following measures were implemented to avoid erosion and/or sedimentation issues during the temporary repair:
Please provide a written response to the following Information Request (IR) questions:Is the stream fish-bearing? If it is determined not to be a fish-bearing watercourse, please provide evidence, rationale and any assumptions that were made in reaching this conclusion.Is corrective action planned to stabilize and/or repair the slopes on an interim basis?The TNPI representative indicated that the area of the incident will be monitored for evidence of erosion weekly, and following a significant rain event. Please provide a written response that includes, but it not limited to the following:
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
