Filing Manual – Guide K – Decommissioning

K.1 Filing Requirements – General Requirements

  1. Provide a complete description of the facilities being decommissioned. This should include a description of any adjacent facilities that are impediments to allowing the facility to be abandoned.
  2. An application for abandonment must be filed for all NEB-regulated facilities when they have reached their end of life, including associated decommissioned facilities. Therefore companies should demonstrate that they are planning for eventual abandonment of decommissioned facilities by providing the anticipated timing of abandonment activities (as best known at this time) for each facility being decommissioned as well as any measures taken to prepare for this eventual abandonment.

K.2 Filing Requirements – Engineering

  1. Pipeline:

    Provide details to confirm that the pipeline is going to be:
    • emptied of service fluids;
    • purged or appropriately cleaned or both in a manner that leaves no mobile materials remaining in the pipeline;
    • physically separated from any in-service piping;
    • capped, plugged, or otherwise effectively sealed;
    • left without any internal pressure;
    • left in a state where road, railway or utility crossings are not at risk of disturbance due to settlement;
    • equipped with signage; and
    • monitored as appropriate for subsidence and to maintain adequate cover for existing and future land use.

      Note: Pipelines containing liners or constructed of polymeric pipe may require repeat purging and maintenance to accommodate out gassing of hydrocarbon or H2S. See CSA Z662 clause 13.2.8.6.
  2. Surface Equipment:

    Provide details on the removal of pipeline related surface equipment.
    • describe equipment to be removed to pipeline depth, except where surface equipment is within an existing surface facility that is in continuing operation, or is required for the operation of any other remaining pipelines.

      Examples of such equipment could be, but are not limited to: pipeline risers, liner vent piping, casing vents, underground vault vents or valve extenders, inspection bell holes, and cathodic protection rectifiers, test posts, or anode wiring, storage tanks and associated piping and equipment.
    • describe how above ground pipelines and all related surface equipment are to be decommissioned except where they are part of or within an existing surface facility that is in continuing operation, or is required for the operation of any other remaining pipelines.
  3. Facilities:

    Provide details on decommissioning of pipeline related facilities such as compressors and pump stations unless they are still part of an operating site. Disposition of associated piping, supports and foundations shall also be described.
  4. Underground Components:

    Provide details on the decommissioning of underground vaults and closed-top pits. Discuss the decommissioning of any underground tanks in relation to requirements in API 1604.
  5. Records:

    Describe the records that are to be maintained of all pipeline components and facilities that are to be decommissioned.

K.3 Filing Requirements – Environmental & Socio-Economic

  1. Describe the ecological setting and current land use of the project footprint as well as adjacent areas.
  2. Describe any known areas of contamination in the project areas as well as historical, ongoing or planned remediation activities associated with those sites. Describe any regulatory requirements for the reclamation and remediation of these sites and how these requirements will be met.
  3. Provide an Environmental and Socio-Economic Assessment (ESA) (see guidance notes below).
  4. For decommissioning projects that are located outside of lands owned or leased by the applicant, provide a monitoring plan outlining how the decommissioned facility will be monitored for the period of time between decommissioning and abandonment. This plan should include:
    • a description of the baseline data that has been collected or obtained for future monitoring results to be measured against. Baseline data should be of sufficient scle, scope and intensity to meet project monitoring requirements.
    • A description of how soils, vegetation establishment, invasive weeds, wetland hydrology and surface and ground water quality will be monitored.
    • Contingency plans for the discovery of soil and water contamination, loss of depth of cover, or extreme weather events affecting the integrity of the decommissioned facilities.
    • Input from interested parties. Any comments from stakeholders should be considered and, where appropriate, incorporated into the plan.
  5. For decommissioning projects that are located outside of lands owned or leased by the applicant, provide an explanation of how natural regeneration of the project footprint in forested areas or native prairie have been considered in the planning for decommissioning. This should include:
    • a discussion of whether or not non-agricultural lands will be allowed to naturally re-vegetate while the facility is in a decommissioned state; and
    • a discussion of any limitations that this would have on the ability to monitor the facilities. A discussion of whether allowing re-vegetation of the project footprint would limit future physical abandonment choices (i.e., pipeline removal vs. abandonment in place). And if so, how that has been factored into decommissioning planning.

K.4 Filing Requirements – Economics

  1. Provide details of the costs associated with the proposed decommissioning.
  2. Confirm that funding is and will be available to finance the proposed decommissioning project.
  3. Where the pipeline has or is likely in future to have third party shippers, provide:
    • Information on the original book cost of the facilities and accumulated depreciation to the retirement date
    • Explain any impact on remaining ratebase, providing accounting details as outlined in the Gas Pipeline Uniform Accounting Regulations (GPUAR) or  Oil Pipeline Uniform Accounting Regulations (OPUAR), including details of whether the retirement is ordinary or extraordinary.
  4. Explain the impact on the company’s abandonment funding program or verify that the decommissioning does not impact it. For example, explain:
    • Any resulting changes to the abandonment cost estimate for the system, or to the estimated timing of abandonment for various segments;
    • Any resulting changes to the plans to fund future abandonment costs.

K.5 Filing Requirements – Lands Information

  1. Describe the location and the dimensions of the existing RoW or facility lands that would be affected by the decommissioning activities.
  2. Provide a map or site plan of the facilities to be decommissioned.
  3. Identify the locations and dimensions of any temporary workspace required for decommissioning activities
  4. Provide a record of public consultation activities that have been undertaken with affected landowners. This record should include a description of:
    • All discussions with landowners regarding the proposed decommissioning activities;
    • A summary of any issues or concerns identified by the landowner; and
    • How the applicant proposes to address any concerns or issues raised by potentially affected people or landowners or an explanation as to why no further action is required.
  5. Provide a plan for how consultation with affected people or landowners will be conducted during the period of time between decommissioning and abandonment.

K.6 Filing Requirements – Consultation

  1. The Board expects applicants will consider consultation for all projects. Please refer to Chapter 3.3 of the NEB’s Filing Manual for additional information. Sharing contamination remediation plans, if any, with landowners, stakeholders – refer to Abandonment Guide B.2

Guidance

Environment and Socio-Economic

Environmental and Socio-Economic Assessment

The Board requires proponents to conduct an ESA for all valued components for which decommissioning activities may potentially interact. ESA requirements are outlined in Guide A, Section A.2 of this Filing Manual. Section A.2.4 describes the level of detail required in an ESA, and Table A-1 provides examples of the range of circumstances that may lead to the need for detailed information.

For smaller projects that may have fewer interactions with the valued components, proponents may choose to file an environmental and socio-economic interations table with their application. This table should include a description of any potential adverse effects that may result from the project, the mitigation that would be implemented to avoid or minimize those effects, and any potential residual effects, as well as cumulative effects.

Decommissioning Plan

An application to decommission the operation of a pipeline could include an decommissioning plan tailored to the individual project and should include input from interested parties such as:

  • landowners;
  • aboriginal groups;
  • occupants;
  • land managers;
  • lessees;
  • municipal agencies (federal or provincial);
  • shippers; and
  • upstream and downstream users.

If a decommissioning plan is shared with interested parties, any comments from these stakeholders should be considered and, where appropriate, incorporated into the plan.

Environmental, safety and land-use issues may all be considered in the application. The application may also address reclamation of sites where surface facilities have been or will be removed and the management of any pipeline components that will be maintained in a deactivated state.

Economics and Finance

Decommissioning Costs

Describe the methodology and assumptions used to estimate costs. Identify and describe any associated section 52 or 58 applications. Provide a level of detail and technical description appropriate to allow regulators, the public, and others to understand the estimates to a reasonable level.

As decommissioning is not the final stage in the lifecycle of a Board-regulated pipeline, provide estimates of average annual future costs for post-decommissioning activities.

Provide estimates of:

  • any future costs associated with maintaining these facilities in a decommissioned state, up until abandonment of these and nearby facilities.
  • the costs to complete the abandonment of these facilities (including recognition of costs of post abandonment activities (i.e., for any facilities proposed to be left in the ground, the costs of monitoring and contingent remediation of any discoveries of contamination or subsidence).
  • explain if and how the total costs to abandon the entire pipeline system have been adjusted for the decommissioning of these facilities, and any related impact on funding for those future costs that remain.

For more information, refer to RH-2-2008, MH-001-2012, MH-001-2013 and the 4 March 2010 Revisions to the Base Case.

Liability Exposure

As decommissioning is not the final stage in the lifecycle of Board-regulated pipelines, the description of future liabilities should include:

  • the type of each liability and an estimate of the associated cost; and
  • a statement of which decommissioning work is associated with a legal obligation and which work is not.

Explain the impact to the company’s abandonment funding program. For example, in what manner does this alter the total abandonment cost estimate for the system, and the timeline for accumulating funds.

Financing

The confirmation that funding is available for the decommissioning work, and the funding will continue to be available to fund the future abandonment, including updated description of any funding, financial guarantees or other arrangements designed to cover these costs.

If the pipeline will still be providing service to third party shippers, include:

  • the expected toll treatment and toll impact, including:
    • an explanation of how the tolls were determined;
    • the expected impact, if any, on shippers and other parties; and
    • a statement regarding the extent of shippers' and other parties' support for any toll increase.

Explain how this decommissioning plan compares to the abandonment plan for these facilities or this site.

Accounting

The GPUAR or OPUAR prescribe the accounting treatment for both ordinary and extraordinary retirements, including informing the Board if the gain or loss on an extraordinary retirement is material.

Next Steps...

Next Steps...

File the completed application. Applicants are encouraged to include the completed relevant checklists from Appendix I.

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