Compliance verification activity type: Field Inspection
Team:
Regulated company: EnCana Corporation
Operating company: EnCana Corporation
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Damage Prevention Right-of-Way field inspection of the Tupper-Hythe Sour Gas, Mid-Tupper Sour, Tupper South Pipeline Loop and Tupper South Pipeline in British Columbia/Alberta to verify compliance with the National Energy Boards federal regulations
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Inspection Observations
Date & time of visit: 2017-09-12 08:00
Discipline: Damage Prevention
Categories:
Facility:
Observations:
Compliance tool used: No compliance tool used
Observation 2 - Signage visibility at road crossings
Date & time of visit: 2017-09-12 14:05
NEB inspectors conducted an aerial inspection of all of Encana's federally regulated lines(Tupper-Hythe Fuel Gas and Mid-Tupper) and subsequent ground inspection of three specific locations that were identified by NEB inspectors as points of interest during the aerial inspection. NEB inspectors saw that the ROW markers were obstructed by vegetation, as a result they were not visible from the traveled roadway at the following road crossings :
As a result Encana is in non-compliance with CSA Z662-15 clause 10.5.3.9 whereby, signs shall be inspected periodically and maintained to ensure legibility and visibility.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Encana will correct the non-compliances identified to ensure sign visibility from the travelled roadway, and provide photos to the NEB to confirm.
Due date: 2017-12-15
Date closed: 2018-02-16 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 - Ground Disturbance Practice
During the inspection NEB Inspectors were told that Encana's Ground Disturbance Practice is being provided to third parties conducting ground disturbances in order to satisfy their requirement to inform the person, in writing, of safety practices to be followed while working in the vicinity of its pipes. The NEB Inspectors were also told that the Ground Disturbance Practice serves as the internal procedure for Encana's employees to use as part of their daily activities when it comes to conducting and supervising ground disturbance activities with respect to the Encana's pipelines. Upon review of the Ground Disturbance Practice, NEB Inspectors determined that the practice only discusses Encana's internal safety practices and does not provide internal staff with information in order for them to know what is and isn't considered to be a ground disturbance under federal legislation and the subsequent measures to be followed by any person engaged in an activity that causes a ground disturbance within the prescribed area.
Compliance tool used: Information Request (IR)
Encana is to provide the NEB with their procedures that define what is an unauthorized activity and subsequent reporting of an unauthorized activity when one is identified.
Due date: 2017-09-19
Date closed: 2017-10-31 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 - Inaccurate ROW Marker
Date & time of visit: 2017-09-12 16:00
NEB inspectors saw a Veresen ROW marker in the place of an Encana ROW marker on the West side of the Tupper-Hythe Fuel Gas pipeline - A29 to 15-31 located at 201 road. Two signs on the West side of roadway are Veresen Energy(Sour) and on the East side of roadway one sign is Veresen Energy(Sour) and the other sign is Encana Corporation(Sweet). This is in non-compliance as per CSA-Z662-15 s 10.5.3.3 (b) (c)
Encana shall correct the signage on both the East and West side of roadway to ensure that the correct company name and product type are listed.Encana shall provide the NEB with a photo of the replaced sign(s) at this location.
Date closed: 2018-03-08 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 5 - Identification and reporting of unauthorized activities
Date & time of visit: 2017-09-19 16:00
The NEB reviewed the following documents provided by Encana to address the the NEB's IR of 18 September 2017 and determined that they do not provide Encana staff with the information required in order to be able to identify when a ground disturbance is or has occurred and when the ground disturbance has resulted in an unauthorized activity. Further, the documentation provided does not address Encana's requirement to report every contravention to the Damage Prevention Regulations - Authorizations to the Board.
Encana shall ensure that its procedures provide internal staff with the required information to:
Due date: 2018-03-30
Date closed: 2018-04-09 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.
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