Compliance verification activity type: Field Inspection
Team:
Regulated company: 6720471 Canada Ltd.
Operating company: 6720471 Canada Ltd.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Verification of Damage Prevention program implementation through inspection - MB/SK Border
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - CNC #1 Missing signage at Rural Road near Gainsborough, Saskatchewan
Date & time of visit: 2016-09-29 14:10
Discipline: Damage Prevention
Categories:
Facility:
Observations:
NEB Inspectors observed lack of signage on one side of the RoW at intersection near 7-17-2-29W1, near Gainsborough, SK. The company provided an email on September 30 confirming that signage had been installed.This was a Corrected Non-Compliance under CSA Z662-15 10.5.3.4
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Company must install signage where pipelines enter and exit road RoW at intersection near 7-17-2-29W1, near Gainsborough, SK as per CSA Z662 10.5.3.4
Due date: 2016-09-29
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.
Reason closed: Requirement met
Compliance achieved: Yes
Observation 2 - Damage Prevention RoW Inspection to verify compliance on the area around Gainsborough, SK and Pierce MB.
Date & time of visit: 2016-09-29 09:53
NEB accompanied company staff to several sites along the ROW; observations include:RoW was clear and free from brush as per CSA Z662-15 10.5.3.9With the exception of one corrected non-compliance, NEB staff observed several road crossings and signs were appropriately located on both sides of the road as per CSA Z662-15 10.5.3.4. Signage observed included company name, warning, type of commodity and emergency number and is in compliance with CSA Z662 10.5.3.3.NEB Inspector contacted Nottingham Midstream Limited's Emergency Control Center phone number to verify it was accurate and operational.The operator who answered the call did not identify the Pipeline Company or demonstrate an understanding of how to process the call had this been an Emergency. After some prompting, the operator transferred the IO to a supervisor who was then able to process the Inspector's call. NEB Inspectors observed the site of hole referenced by the Company in the Damage Prevention Observation. NEB Inspectors observed that reclamation of the site appeared incomplete (company staff indicated that it appeared to have settled since filling in the hole the previous year) and requested that NAL follow-up.
Compliance tool used: No compliance tool used
Observation 3 - Damage Prevention Program
NEB Inspectors were advised that Nottingham Midstream, the owners of Canada 6720471, employs third party providers to manage their NEB regulated Pierson Line. North American Life (NAL) manages the facility's operations and Watson Land oversees landowner and damage prevention matters. Represenetatives from both companies were present at the meeting. RoW patrols are managed by Absolute Locators and cathodic protection by Allied Cathodic..At the opening meeting, and during the Inspection, meeting attendees discussed Nottingham's, Public Awareness program, Crossing Agreements/Technical Guidelines and Ticket Management processes.The third party providers (NAL And Watson Lands) stated that there are 8 or 9 nine landowners on the 10 km Pierson line. They also reported that there were zero locates or one-calls this year due to the line's limited length, and that aerial patrols are not performed. Flame Ionization Detection is performed every two years and RoW ground patrols are scheduled on a yearly basis.NEB Inspectors noted that none of the third party providers present were aware of the new Damage Prevention Regulations. An alleged Unauthorized Activity discovered by a third party party (Absolute Locating) reported to Inspectors during the course of a meeting was never reported to the NEB by Nottingham Midstream as per DPR (Authorizations) section 11 . On 26 October 2015, Absolute Locating reported evidence of Hydrovaccing at a site. NAL reported Depth of Cover at 8 feet, where a 2.5 foot deep trench was present. NAL representatives were unaware of any investigation into the cause of this hole.Update: On 19 October 2016, Company emailed NEB IO's with further analysis suggesting that the alleged Unauthourized Activity could have occured naturally due to floods in the area since 2013 and that there are no other facilities buried in the area.
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