Compliance verification activity type: Field Inspection
Team:
Regulated company: Spectra Energy Empress Management Inc. as General Partner and Agent for Spectra Energy Empress L.P.
Operating company: Spectra Energy Empress Management Inc. as General Partner and Agent for Spectra Energy Empress L.P.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Verfication of Damage Prevention program implementation through inspection - Regina SK area.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Damage Prevention Program
Date & time of visit: 2016-09-26 14:30
Discipline: Damage Prevention
Categories:
Facility:
Observations:
At the opening meeting and during the Inspection, NEB Inspectors discussed Plains Midstream Empress Management ULC (PMEMULC)'s Aerial Surveillance program, Public Awareness program, Crossing Agreements/Technical Guidelines and its Ticket Management Process. Company staff indicated that it conducts aerial surveillance every two weeks with fixed winged aircraft with a single pilot. PMEMULC stated it will be transitioning to a pilot/spotter situation in 2017 and that land patrols are performed on a seven year interval.Company staff stated that as of September 2016, 17 crossing agreements have been processed and 948 locate requests were made in Saskatchewan and 73 in Manitoba. These are performed by in-house staff and around one-tenth by an outside contractor. PMEMULC stated that public awareness materials are mailed out and reviewed with the approximately 1 400 area landowners and that face to face meetings with landowners are conducted by its staff once every three years. PMEMULC staff indicated that one of the ways they monitor new tenants and property transfers via Rural Municipalities Offices. New residents are then contacted by PMEMULC staff and forwarded Public Awareness material. Due to the sale of the PTC pipeline from Spectra Energy Empress Management Inc. as General Partner and Agent for Spectra Energy Empress L.P. to PMEMULC on 4 August 2016, Company representatives expect full implementation of its Management of Change program with regards to change of ownership and Damage Prevention Regulations by the end of 2017. Company representatives advised that they are currently updating signs to reflect the new ownership, with a completion date for all signage along the PTC pipeline of 4 November 2016 (90 days after the acquisition). Company representatives provided a spreadsheet that identified signs to be updated and tracked the status of each sign.
Compliance tool used: No compliance tool used
Observation 2 - NNC #1 Signage with incorrect company name.
Date & time of visit: 2016-09-27 09:02
During the inspection, NEB Inspectors observed multiple road crossings, and noticed that signage in many locations was appropriate on the PTC line ROW inspected. The NEB Inspector contacted Plains Midstream Empress Management ULC's Emergency Control Center phone number and verified it was accurate and operational.However, Inspectors observed that signage at KMP 338.3, 428.3, 433.2, 446.8, 451.7.,464.9, 487.7 and 496.2. identified Spectra Energy as the company, rather than Plains. This was a non-compliance under CSA Z662-15 10.5.3.3 (c)Additionally, Inspectors observed that the sign at KMP 428.3 was faded such that legibility was impaired on the northern side of the ROW. This was in non-compliance with CSA Z662-15 10.5.3.3 (a).
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Plains Midstream Empress Management ULC (PMEMULC) must replace signage along the length of the PTC Pipeline such that the signage meets the requirements of CSA Z 662-15 10.5.3.3 as listed above by the agreed upon date of 4 November 2016.PMEMULC will provide photographs of signage replacement at the locations identified above, and written confirmation that signage along the RoW specified has been replaced.
Due date: 2016-12-30
Date closed: 2017-01-09 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 3 - NNC #2 Missing signage at RoW where pipelines enter and exit roads.
Date & time of visit: 2016-09-27 11:16
NEB Inspectors observed lack of signage on the east side of the road where pipelines enter and exit at KMP 451.7This is a non-compliance under CSA Z662-15 10.5.3.4.
Company must install signage at the above stated location as per CSA Z662-15 10.5.3.4. by the agreed upon date of 4 November 2016.PMEMULC will provide photographs of signage replacement and written confirmation that signage along the RoW specified has been installed.
Observation 4 - NNC #3 Incorrect signage at block valve
Date & time of visit: 2016-09-28 10:07
NEB Inspectors observed lack of signage identifying Spectra as operating company on fencing at PMEMULC's Block Valve MLV 490 (Wolseley) by Highway 617 near Odessa SK.This is in non-compliance with CSA Z662-15 10.5.4.1
The Company must install signage compliant with CSA Z662-15 10.5.4.1 at this location by the agreed upon date of 4 November 2016.PMEMULC will provide photographs of signage replacement and written confirmation that signage has been installed.
Observation 5 - Unauthorized Activity
Date & time of visit: 2016-09-27 14:20
NEB Inspection Officers observed the site where two Unauthorized Activities were reported in April 2016 (UX2016-036) and September 2016(UX2016-155). Just one week prior, the Company had reported that an Unauthorized Crossing UX2016-155 was conducted over the PTC Pipeline RoW on 21 September 2016 where a third party had crossed and left heavy equipment over the PTC RoW without a Company representative being present. NEB Inspectors observed the area in question had been fenced by the Company to prevent further crossings outside of the permitted area.
Observation 6 - CNC # 1 Vegetation making signage not legible
Date & time of visit: 2016-09-27 10:58
NEB Inspectors observed signage at the Provincial Highway 35 crossing (KMP 446.8) which was not visible due to the presence of vegetation which obstructed visibility.This was in non-compliance under CSA Z662-15 10.5.3.9.
Compliance tool used: Corrected Non-compliance (CNC)
The Company must clear the vegetation around the signage east of Provincial Highway 35 as per CSA Z662-15 10.5.3.9. making it visible from the road.
Due date: 2016-09-27
Date closed: 2016-10-07 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 7 - NNC # 4 Lack of signage at River Crossing on east side of Moose Jaw Creek
Date & time of visit: 2016-09-27 15:34
NEB Inspectors observed lack of signage on Eastern side of Moose Jaw Creek in Saskatchewan.This is a Non-Compliance under Plains Midstream Empress Management ULC standard operation procedure document No. 12.10 "Pipeline Warning Signage".
Plains Midstream Empress Management ULC will install signage on the East side of Moose Jaw Creek as per Pipeline Warning Signage Doc. 12.10. by the agreed upon date of 4 November 2016.
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