Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Québec and Maritimes Pipeline Inc.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Field Inspection of Trans Québec and Maritimes Pipeline Inc. (TQM) Line 2000 (Mainline) between Mirabel and Trois-Rivières (QC). There have been multiple unauthorized activities by the same violator, and this pipeline is located in a high-risk, developed area. Inspection is to verify compliance to NEB Onshore Pïpeline Regulations and NEB Damage Prevention Regulations. This Damage Prevention inspection will assess damage prevention requirements in this area, and along the RoW. Scope of the inspection also includes the watercourse crossings in the Oka area (Rivière des Outaouais - valve AV2 and valve AV3) that were subject to flooding in the May 2017 Quebec floods. Inspection required to obtain information and make field observations on the current status and potential for future work, as well as whether or not TransCanada has identified any need for additional mitigation.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Missing Right-of-Way Signage at Road Crossings
Date & time of visit: 2017-07-11 08:00
Discipline: Damage Prevention
Categories:
Facility:
Observations:
NEB Officers accompanied TransCanada representatives to several locations along the TQM Line 2000 (Mainline) Right-of-Way (RoW) between Les Cèdres and Trois-Rivières (QC). There were several locations along the RoW in both urban and rural areas where the pipeline crosses roadways.
While the signage on the RoW was generally present and visible, there were a few locations where signage maintenance is required as a result of missing signs on the entry and/or exit of the travelled roadway. These locations include:
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
By 31 October 2017, TransCanada will address any non-compliances related to emergency phone numbers, or implement an interim measure to ensure that calls made to out-of-use numbers are automatically directed to the current emergency number until such time that all signage is replaced with the current emergency number.
By 31 October 2017, TransCanada will submit a Corrective Action Plan (CAP) which will provide details on how it will inspect the entire TQM pipeline system ROW and address any non-compliances to CSA Z662 Clause 10.5.3 “Pipeline Identification” (exclusion of Assumption River crossing). The CAP should include information on how TransCanada will prioritize its inspection and signage maintenance efforts and provide specific timelines for completion.
By 30 June 2018, TransCanada will have conducted its inspection of the entire TQM pipeline system ROW and addressed all non-compliances and issues identified.
TransCanada will provide progress reports on 31 December 2017 and 30 April 2018 until completion of the work as committed in its CAP.
Due date: 2018-07-31
Date closed: 2018-08-16 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 2 - Signage Along Pipeline Right-of-Way
NEB Officers accompanied TransCanada staff to several locations along the TQM Line 2000 (Mainline) RoW between Les Cèdres and Trois-Rivières (QC). Observations include:
TransCanada will provide progress reports on 31 December 2017 and 30 April 2018 until completion of the work as committed in its CAP.By 16 July 2018, TransCanada will provide a final report of its inspection and corrective action results for the entirety of the TQM system. The report must include:
Observation 3 - Signage at Assomption River Crossing
Date & time of visit: 2017-07-12 12:30
Watercourse crossing signage at this location is a picture of an anchor with a red slash over it. Signage has limited visibility from the water due to vegetation growth (sign on west bank is completely covered and sign on east bank is partially covered). Both signs are faded and the emergency phone number is not legible from the water. This signage does not meet the CSA Z662 Clause 10.5.3.9 requirements as it is not legible (both west and east banks) and not visible (west bank) from the water.This is a repeat finding for both signage and brushing at this location dating back to October 2016. At that time, TransCanada showed the NEB Inspectors a signage replacement plan and valid permit TransCanada received from the municipality the first week of October 2016 in order to conduct the work.During the July 2017 inspection, TransCanada representatives provided a document titled "River Crossing Signage Replacement Plan" which indicates that signage at this location has been identified as requiring replacement. However, TransCanada representatives were not able to demonstrate when the replacement will take place nor that brushing will take place to ensure visibility from the water. Therefore, although TransCanada was able to demonstrate that it is in the process of implementing mitigation in replacing signage, compliance to CSA Z662 Clause 10.5.3.9 requirements could not be confirmed.
Compliance tool used: Information Request (IR)
TransCanada to provide the following information regarding the watercourse crossing signage on the east bank of the Assomption River (as per its River Crossing Signage Replacement Plan):
Due date: 2017-09-29
Date closed: 2017-10-13 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 - Reduced Visibility of Right-of-Way Signage at Road and Watercourse Crossings
NEB Officers accompagnied TransCanada representatives and inspected various locations along the TQM Line 2000 (Mainline) RoW between Les Cèdres and Trois-Rivières (QC). At most locations being inspected, signage at road crossings was present and visible. However, NEB Officers observed signage with reduced visibility due to overgrown vegetation (phragmites) at the following locations:
By 31 October 2017, TransCanada will submit a Corrective Action Plan (CAP) which will provide details on how it will inspect the entire TQM pipeline system ROW and address any non-compliances to CSA Z662 Clause 10.5.3 “Pipeline Identification” (exclusion of Assumption River crossing). The CAP should include information on how TransCanada will prioritize its inspection and signage maintenance efforts and provide specific timelines for completion.By 30 June 2018, TransCanada will have conducted its inspection of the entire TQM pipeline system ROW and addressed all non-compliances and issues identified.TransCanada will provide progress reports on 31 December 2017 and 30 April 2018 until completion of the work as committed in its CAP.By 16 July 2018, TransCanada will provide a final report of its inspection and corrective action results for the entirety of the TQM system. The report must include:
Observation 5 - Brushing and Vegetation Control Along Right-of-Way
NEB Officers accompanied TransCanada representatives to several locations along the TQM Line 2000 (Mainline) RoW between Les Cèdres and Trois-Rivières (QC). There were several areas along the RoW where brushing maintenance was required to ensure that the pipeline is visible from the air and provide ready access for maintenance crews. The brush was extremely dense and the growth has resulted in mature trees, possibly 20 years old or more according to TransCanada representatives. The following locations were inspected where dense brush and mature trees where observed:
NEB Officers were informed that TransCanada has an Invasive Vegetation Weed Control Management Procedure to manage weeds and smaller growth vegetation along its RoW, and a Brushing Control Procedure to manage large vegetation such as trees - weed control and brushing are treated and managed separately.NEB Officers visited the area where brushing is currently underway near the valve site AV15 in Louiseville (QC). TransCanada representatives discussed current brushing activites and the brushing management plan with the NEB Officers, however, the brushing plan is a multi-year plan and currently does not include all locations that require brushing as observed. NEB Officers were also advised that municipal permits were required and environmental studies for all of the brushing activities which must be in place prior to any removal of vegetation. The presence of dense brush and mature trees as observed is a non-compliance to CSA Z662 Clause 10.6.2 requirements as vegetation on the TQM RoW shall be controlled to maintain clear visibility from the air.
TransCanada to provide the following information by 13 October 2017:
Due date: 2017-10-13
Date closed: 2017-11-14 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 6 - Edge of Right-of-Way Marker Posts Along Pipeline Right-of-Way
Date & time of visit: 2017-07-10 13:00
In the course of the inspection, NEB Officers observed the presence of white with blue top edge of RoW marker posts as per TransCanada Pipeline Right of Way Procedure dated 05-Oct-2015. However, at numerous locations the edge of TQM RoW marker posts were missing, damaged or not visible from the travelled roadway. While these edge of RoW marker posts are not a legislated requirement, pipeline companies are required to ensure that their procedures are implemented in accordance with the legislation and with their internal Damage Prevention Program.During the inspection, TransCanada representatives sought and received internal approval to vary from this procedure for the TQM pipeline system. NEB Inspectors viewed recorded evidence of this approval.
Compliance tool used: No compliance tool used
Observation 7 - Content of Records for Inspections and Field Observations
Date & time of visit: 2017-07-13 09:00
NEB Officers reviewed documents of a completed ground disturbance activity that occurred in the Spring of 2016. TransCanada representatives confirmed that an inspection was carried out although the inspection was not documented. NEB Officers discussed with TransCanada representatives the requirements of the National Energy Board Damage Prevention Regulations - Obligations of Pipeline Companies (DPR-O)with respect to the content of records for inspections and field observations and reminded them of their obligations. As the NEB Officers did not review TransCanada's procedures relating to this type of activity and that the ground disturbance activity occurred prior to the coming into force of the DPR-O in June 2016, no Notice of Non-Compliance was issued.
Observation 8 - Brushing Operations in Louiseville
Date & time of visit: 2017-07-12 14:45
NEB Officers observed brushing operations of the TQM Line 2000 (Mainline) pipeline RoW in Louiseville (QC) near valve site AV15 and spoke with the authorized TransCanada representative on site overseeing the operations. A site-specific tailgate safety meeting was conducted prior to entering the site. The authorized on-site TransCanada representative stated the following regarding the brushing operations:
Observation 9 - Unauthorized Activity Along Highway 40 near Trois-Rivières (QC)
Date & time of visit: 2017-07-13 10:00
NEB Officers inspected the site of a recent unauthorized activity which occured on 11 July 2017 and which was discovered by TransCanada's aerial patrol. The TransCanada Pipeline Technician stated that when he was dispatched on site to address the situation, he observed dirt piles on the pipeline RoW and immediately requested that the dirt piles be moved outside the RoW. Upon arrival at the site of the unauthorized activity, NEB inspector observed numerous dirt piles along the Highway 40 beyond the curb. TransCanada pipeline markers were present and visible at this road crossing.This unauthorized activity is being addressed under a separate NEB process (NEB File UX2017-150).
Observation 10 - Aerial Pipeline Patrol and RoW Monitoring
NEB Officers were informed that TransCanada currently conducts weekly aerial patrols of the entire TQM pipeline system (includes Mainline, laterals and East Hereford M/L) via rotary wing aircraft. TransCanada employs its own pilots and does not use contractors to do the aerial patrols. TransCanada's Ground Based Patrols Procedure stipulates that the Canada Natural Gas pipelines (all class locations) are subject to aerial patrols only at this time, unless otherwise advised due to specific considerations that require ground based patrols.During the course of the TQM inspection between Les Cèdres and Trois-Rivières (QC), NEB Officers observed a number of signage issues being non-compliant with regulatory requirements, as well as vegetation overgrowth and brushing issues which are discussed in more detail in other sections of this inspection report. NEB Officers also reviewed the Aerial Pipeline Patrol Procedure and a small sampling of Aerial Patrol reports of the TQM pipeline system provided by TransCanada representatives. NEB Officers noted some reporting inconsistencies between the information as it was reported in the aerial patrol reports and the information as required by the Aerial Pipeline Patrol Procedure and observations noted during the field inspection.
Observation 11 - Public Awareness Program
Date & time of visit: 2017-07-10 13:30
NEB Officers reviewed Public Awareness (PA) materials that TransCanada sends to affected public with respect to the TQM pipeline system. The following information was provided by Public Awareness Advisor and Indigenous & Community Relations Liaison, Eastern Region:
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