ARCHIVED - Maritimes and Northeast Pipeline Management Ltd. - Audit Report OF-Surv-OpAud-M124 01 - Appendix V: M&NP Crossing Program Audit Evaluation Table

This page has been archived on the Web

Information identified as archived is provided for reference, research or recordkeeping purposes. It is not subject to the Government of Canada Web Standards and has not been altered or updated since it was archived. Please contact us to request a format other than those available.

Appendix V:
MN&P Crossing Program Audit Evaluaion Table

1.0 POLICY AND COMMITMENT

1.1 Policy and Commitment Statements

Expectations: The company shall have a policy approved and endorsed by senior management (the Policy). It should include goals and objectives and commit to improving the performance of the company.

References:[1]
OPR-99 sections 4, 47 and 48
CSA Z662-07 Clause 10.2.2

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party activities near the M&NP system. During the audit, it was noted that the Operator’s crossing or third party activities are subsumed in the Operator’s O&M activities that are adequately addressed by the corporate safety policy.

The Board also noted that the safety policy has been integrated by the Operator’s staff when working with third parties. During the interviews, Staff consistently emphasized their personal accountability for public and worker safety when they inspect or observe crossing-related activities. Technical staff described personal authority and obligation to intervene with third parties to ensure that the procedures were being adhered to during crossing activities.

This element is more fully evaluated in Element 1.1 of Appendix II - M&NP Safety Program Audit Evaluation Table.

Compliance Status: Compliant

[1] Each “Reference” in this table contains specific examples of the “legal requirements” applicable to each element but are not necessarily a complete list of all applicable legal requirements.

2.0 PLANNING

2.1 Hazards Identification, Risk Assessment and Control[2]

Expectations: The company shall be able to demonstrate a procedure to identify all possible hazards. The company should assess the degree of risk associated with these hazards. The company should be able to support the rationale for including or excluding possible risks in regard to its environment, safety, integrity, crossings and awareness and emergency management and protection programs (management and protection programs). The company should be able to implement control measures to minimize or eliminate the risk.

References:
OPR-99 sections 4(2), 37, 39, 40, 41
CSA-Z662-07 Clause 10.2, 10.14

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system. By reviewing the hazard identification process, the Board noted that the Operator had identified the common crossing-related hazards for communication to its staff and the public. Common hazards for third parties are included in the third party information such as the Crossing Guidelines as well as within related internal procedures.

Additionally, document review showed that specific hazards related to crossing projects are addressed in pre-job safety meetings and noted in the pre-job checklist to identify and control the hazard associated with each crossing activity.

Further to these processes, operations field staff identified that it is routine practice to proactively identify and address potential crossing hazards where possible including communicating directly with third party workers near the rights of way. If staff observe unattended excavation equipment parked near the RoW, they will leave a brightly coloured note on the equipment to notify third party operators that there is a high pressure gas pipeline in the vicinity and to contact the company prior to beginning any excavation.

The Operator demonstrated that it has mechanisms in place to report and address hazards introduced by third parties working around pipelines.

Compliance Status: Compliant

[2] Hazard: Source or situation with a potential for harm in terms of injury of ill health, damage to property, damage to workplace environment, or a combination of these. Risk: Combination of the likelihood and consequence(s) of a specified hazardous event occurring

2.2 Legal Requirements

Expectations: The company shall have a verifiable process for the identification and integration of legal requirements into its management and protection programs. The company should have a documented procedure to identify and resolve non-compliances as they relate to legal requirements which includes updating the management and protection programs as required.

References:
OPR-99 sections 4 and 6
PCR Part II sections 4, 5(1) and 13(1)(a)
CSA Z662-07 Clause 10.2.2(g)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system. During interviews, Operator staff stated the standard practice for analyzing legal requirements consisted of staff participation in industry groups such as CSA and Canadian Energy Pipelines Association as well as monitoring of regulatory updates posted on relevant government websites. The Operator did not demonstrate that it has a formal process for the tracking of legal requirements for the operation and maintenance of the pipeline. Although regulatory requirements were reflected in the procedural documents, the audit identified one issue of particular note to the Board. The Operator did not have a process in place that recognized the requirement to file separate technical crossing guidelines for Board approval as required by the National Energy Board Pipeline Crossing Regulations (PRC) Part II. The Board notes that subsequent to the onsite portion of this audit, the guidelines were filed.

The Operator could not demonstrate that it has a formal process to identify and integrate PCR requirements into its programs.

Compliance Status: Non-compliant

2.3 Goals, Objectives and Targets

Expectations: The company should have goals, objectives and quantifiable targets relevant to the risks and hazards associated with the company’s facilities and activities (i.e., construction, operations and maintenance). The objectives and targets should be measurable and consistent with the Policy and legal requirements, and ideally include continual improvement and prevention initiatives, where appropriate.

References:
OPR-99 sections 47 and 48
CSA-Z662-07 Clause 10.2.2(h)(ii)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

As noted elsewhere, crossings and related activities are included in the overall operations and maintenance safety program. As such, the evaluation of the goals, targets and objectives for crossing activities such as locates were incorporated into the review of Element 2.3 of the Safety Program (Appendix II).

Review of the Safety Program identified that the Operator was able to demonstrate that it sets objectives and targets relevant to its hazards and risks and has integrated them into individual and corporate performance measures.

Compliance Status: Compliant

3.0 IMPLEMENTATION

3.1 Organizational Structure, Roles and Responsibilities

Expectations: The company shall have an organizational structure that allows its management and protection programs to effectively function. The company should have clear roles and responsibilities, which may include responsibilities for the development, implementation and management of the management and protection programs.

References:
OPR-99 sections 40, 47 and 48
CSA-Z662-07 Clauses 10.2.1 and 10.2.2(b)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

A review of the organizational structure and interviews confirmed that, based on M&NP’s present facilities and level of activity, it has an adequate structure in place with respect to its Crossing Program. Records review indicated that crossing-related responsibilities were incorporated in job descriptions across the organization where required.

M&NP facilities are located in Eastern Canada (Nova Scotia and New Brunswick). There is an Area Manager with responsibilities for both provinces and each province has field staff, a District Manager and a Lands, Emergency Preparedness and Public Awareness Coordinator.

Field technical staff that perform crossing-related duties such as locates and the supervision of third party crossings, etc. report to the provincial District Managers. The Operation Technicians are cross trained to address tasks involved in operating and maintaining the pipeline as well as some crossing matters. For example, technical staff are onsite for all work being done within 5 metres. Field staff indicated that complex crossings near the pipeline, or those crossings requiring a heavy equipment assessment, are escalated to the Coordinators and the engineers in Halifax and/or Waltham in order to ensure appropriate technical review. The Coordinator in each province reports to and takes direction from the Manager, right-of-way (RoW) Division, East RoW in Head Office (Waltham, MA). The current structure and reporting relationships are well understood by field staff. Interviews confirmed that there is a clear definition of roles and responsibilities in the Crossing Program.

During the audit, an area of potential concern was noted with respect to adequacy of resourcing of the Coordinators’ positions. The Coordinators, while managing the Awareness, Emergency Response and Land Matters Programs, also have significant responsibilities for crossing-related activities. It was identified during the audit that there is a small number of staff in each office performing multi-task roles and the staffing level is currently effective due to the large number of long-term staff.

However, if circumstances change such as an increase in staff turnover or in crossing activities, the Operator may not be able to remain effective in carrying out its Crossing Program. It is recommended that the Operator review the organizational structure and responsibilities related to the Crossing Program to maintain a compliant level of effectiveness.

Compliance Status: Compliant with Recommendation

3.2 Management of Change

Expectations: The company shall have a management of change program. The program should include:

  • identification of changes that could affect the management and protection programs;
  • documentation of the changes; and
  • analysis of implications and effects of the changes, including introduction of new risks or hazards or legal requirements.

References:
OPR-99 section 6
CSA-Z662-07 Clause 10.2.2 (g)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

The Operator is in the process of implementing a Management of Change (MOC) process which outlines the identification, assessment and implementation of changes once they have been approved by the appropriate responsible individuals according to the EHS MS MOC Performance Standard 2.7.

However, the Board could not verify that there was a fully implemented MOC procedure. The current process did not include proactive formal identification of required changes and a formal analysis of the effects that the changes may require.

Although an MOC process exists, the audit identified that the present MOC process is only partially implemented. As the regulations require the MOC to be implemented as designed, this element has been evaluated as Non-Compliant.

Compliance Status: Non-compliant

3.3 Training, Competence and Evaluation

Expectations: The company shall have a documented training program for employees and contractors related to the company’s management and protection programs. The company shall inform visitors to company maintenance sites of the practices and procedures to be followed. Training requirements should include information about program-specific policies. Training should include emergency preparedness and environmental response requirements as well as the potential consequences of not following the requirements. The company should determine the required levels of competency for employees and contractors. Training shall evaluate competency to ensure desired knowledge requirements have been met. Training programs should include record management procedures. The training program should include methods to ensure staff remains current in their required training. The program should include requirements and standards for addressing any identified non-compliances to the training requirement.

References:
OPR-99 sections 28, 29, 30(b), 46, 47, 48 and 56
CSA Z662-07 Clause 10.2.2(c)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

Crossing related activities such as locating and post-activity inspections are performed by Coordinators and operations technical staff as part of their routine duties. The majority of the Operator’s staff are long-term employees who have been trained to these activities during their tenure and on an “as-required” or “as-available” basis. For example, training on the pipeline locate equipment has been provided in this manner by the vendor. Also, the Operator utilizes mentor-based training for its new and existing employees.

Document review confirmed that training for the field staff is being managed. Hard copies of training records are maintained by the administrator in the regional offices and electronic versions are managed at an offsite location (Houston, Texas). Managers and employees receive electronic notifications when select training is due to be renewed. There is an annual evaluation on overall performance and the records are maintained by administrative staff.

Although field technicians were being given training and that training was documented and managed, at the time of the audit, the Board was unable to review a formally established training program for staff performing crossing activities. However, interviews with senior staff indicated that the Operator is developing a matrix establishing training and qualifications requirements for application to its technical staff. As well, in response to the recent hiring, management developed a list of core training required for any new technical level field staff. This list will serve as an initial inventory of training needs for all field staff and help populate the matrix described above.

The company has a process to ensure its contractors have the appropriate competencies in completing its crossing related activities. It was noted that the Operator has a list of pre-approved contractors to perform duties such as crossings and integrity digs. These contractors are evaluated upon completion of each contract.

The Operator was unable to demonstrate that training requirements for the Coordinator roles had been formally included in its training program. These positions have evolved to include tasks with varying degrees of technical knowledge required and training has been provided on an ongoing basis. However, senior staff indicated that there are no succession plans in place or skill inventories developed to identify the training requirements for the Coordinator positions.

Although the Operator has established training requirements, the management of training records and the communication of renewal notices for crossing related duties for technical staff, it was not able to demonstrate that there is a formal matrix. In order to ensure Coordinators maintain the appropriate training in the future, and that the training needs for staff at that level are documented, it is recommended that the Operator formally identify, document and incorporate the training needs of the Coordinators into the training program.

Compliance Status: Compliant with recommendation

3.4 Communication

Expectations: The company should have an adequate, effective and documented communication process(es):

  • to inform all persons associated with the company’s facilities and activities (interested persons) of its management and protection programs policies, goals, objectives and commitments;
  • to inform and consult with interested persons about issues associated with its operations;
  • to address communication from external stakeholders;
  • for communicating the legal and other related requirements pertaining to the management and protection programs to interested persons; and
  • to communicate the program’s roles and responsibilities to interested persons.

References:
OPR-99 sections 18, 28 and 29
CSA Z662-07 Clause 10.2.2(d)
PCR Part II sections 4 and 5

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

Internal communication takes place through regular face-to-face meetings as well as frequent phone conversations and consultations since field staff cover large areas. Each company truck is equipped with communication equipment such as satellite phones to ensure that staff are able to remain in contact at all times.

For external stakeholders, M&NP maintains a company website as one way to effectively communicate regarding living and working safely around its pipeline. At the time of the audit, the M&NP site contained adequate information regarding the process for contacting the company, the circumstances under which it is required to do so, as well as the process for obtaining permission to work around its pipeline.

Although there are several internal and external mechanisms in place for communicating third party related activities, the Operator could not demonstrate that there is a formalized and implemented communication plan that outlines the distribution of various types of information to appropriate parties. While interviews confirmed communication is occurring throughout technical networks and through the means identified above, without a formal communication plan, the Operator cannot ensure that all stakeholders and interested parties are receiving the appropriate information in a timely fashion.

The Operator was able to demonstrate that it has adequate communication processes regarding crossing related information. However, the Board recommends that information related to third party activities be included in a formalized communication plan.

Compliance Status: Compliant with recommendation

3.5 Documentation and Document Control

Expectations: The company should have documentation to describe the elements of its management and protection programs-where warranted. The documentation should be reviewed and revised at regular and planned intervals. Documents should be revised immediately where changes are required as a result of legal requirements or where failure to make immediate changes may result in negative consequences. The company should have procedures within its management and protection programs to control documentation and data as it relates to the risks identified in element 2.0.

References:
OPR-99 section 27
CSA-Z662 Clause 10.2.2(e) and (f)
PCR Part II sections 10 and 11

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

The Operator staff follows the procedures and processes documented in the M&NP O&M Manual and well as Spectra Energy Transmission (SET) Standard Operating Procedures (SOP). Revision logs in each of the procedures confirm that these procedures are periodically reviewed and revisions are signed off by Management. The Operator’s administrative staff manages the majority of the crossing related information in each regional office. For procedures, there is a document revision list to manage all the changes to any of the procedures. Technical staff complete a request for revision form to track and record all requests and subsequent changes to procedures. The revision date is on the front of the procedure. Once approved and revised, the procedures are posted on the intranet by the administrative staff and the outdated versions are removed. The administrative staff also control and document the distribution of its as-built plans as part of the crossing application file.

There is currently an initiative that is automating the maintenance of procedures. Operational Technicians are participating in an SET SOP harmonization project with the U.S. office using “Veriforce” software. Changes to procedures are evaluated by staff. Once approved they are integrated and communicated to applicable employees. The system alerts other staff that there has been a change to a process or procedure and the system ensures that each employee signs off verifying that they have acknowledged the change.

The Operator was able to demonstrate that there is a process in place to review and control the versioning of procedures related to Crossings.

Compliance Status: Compliant

3.6 Operational Control - Normal Operations

Expectations: The company should establish and maintain a process to develop, implement and communicate mitigative, preventive and protective measures to address the risks and hazards identified in elements 2.0 and 3.0. The process should include measures to reduce or eliminate risks and hazards at their source, where appropriate.

References:
OPR-99 sections 27-49
CSA Z662-07 Clauses 10.2.2(f) & 10.3.1
PCR Part II sections 4 and 5

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

The M&NP RoW goes through both urban and rural settings and so there are several types of projects that take place nearby. Those parties who have an activity that meets the legal and company criteria for requiring permission to build or excavate, normally do so by contacting the company directly. Requests made through the 1-888 number, are initially received by the administrative staff and then technical staff evaluate them for what level of follow-up is required. In New Brunswick, some requests for permission come through the Saint John Digline (one-call centre). Digline forwards all requests for locates within 500 metres as well as a daily report of all requests that were given the “all clear” because they were beyond 500 metres. Requests between 200-500 metres are cleared at the office and those under 200 metres are reviewed by field technicians. The technicians do locates for any request between 5 and 10 metres from the RoW and they are present for any excavation activity within 5 metres. Within 3 metres, the Coordinators typically observe the construction or excavation activity.

Normal operations for crossings-related duties are described in the O&M Manual. The Coordinators for each province address the more complex crossings with support from the engineers in the Halifax, NS or Waltham, MA office. In cooperation with the senior staff such as the Area Manager, operational staff indicated a high level of involvement in the maintenance and enhancement of the procedures. Operational staff in the field offices are long term staff and the majority of them have been with the company since the pipeline was being built or shortly thereafter. As the teams consist of cross-trained experienced technicians, they perform many of the front line duties regarding crossings, such as:

  • Conducting pre-job meetings;
  • Attending all crossing installations on the RoW and within 5 metres and completing the pipeline inspection reports;
  • Performing visual analysis to identify anomalies in the coating such as corrosion which would be referred to Head Office for review; and
  • Meeting with third parties and performing pipeline locates.

The Operator was able to demonstrate that it has documented procedures that address processes for normal operating conditions. Interviews and document review confirm that Operations staff follows the O&M Manual for addressing normal hazards related to crossings.

Compliance Status: Compliant

3.7 Operational Control - Upset or Abnormal Operating Conditions

Expectations: The company shall establish and maintain plans and procedures to identify the potential for upset or abnormal operating conditions, accidental releases, incidents and emergency situations. The company shall also define proposed responses to these events, and prevent and mitigate the likely consequences and/or impacts of these events. The procedures must be periodically tested and reviewed, and revised where appropriate (for example, after emergency events).

References:
OPR-99 sections 32, 52
CSA-Z662-07 Sections 10.3.2 and 10.14

Assessment:
Upset conditions for crossing-related activities would constitute an emergency and would be mitigated as per the Emergency Response Plan. It was noted that the Operator has conducted table tops that tested these types of emergencies such as third party damage. The Emergency Preparedness and Response Program was evaluated as a distinct program as part of this audit. For an evaluation of the program refer to Appendix IV of this report.

Compliance Status: N/A

4.0 CHECKING AND CORRECTIVE ACTION

4.1 Inspection, Measurement and Monitoring

Expectations: The company shall develop and implement surveillance and monitoring programs. These programs should address contract work being performed on behalf of the company. These programs should include qualitative and quantitative measures for evaluating the management and protection programs and should, at a minimum, address legal requirements as well as the risks identified as significant in elements 2.0 and 3.0. The company should integrate the surveillance and monitoring results with other data in risk assessments and performance measures, including proactive trend analyses. The company shall have documentation and records of its surveillance and monitoring programs.

References:
OPR-99 sections 36 and 39
CSA-Z662-07 Clauses 9 and 10
PCR Part II sections 4, 5, 10 and 14(1)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system. The Operator’s inspection procedures dictate that inspection-related duties are to be performed by technical field staff. For example, if the pipeline is exposed, field staff conduct inspections of the pipeline to document the condition, take pictures and check for anomalies. Also, these staff conduct surveillance and monitoring of the M&NP system by various means. The urban sections of the M&NP line are driven by technical staff once a week. Staff indicated that they are aware of the conditions and situations that need to be noted in the reports, such as signage issues and evidence of unauthorized activity. The entire RoW is flown weekly by a fixed-wing plane. Interviews with the pilot confirmed there are procedures and training pertaining to the crossing-related issues that should be reported (i.e., activity or equipment on the RoW). Air patrol was aware of the reporting procedure which requires that patrols are documented and any issues are reported to the regional office to ensure they are investigated. The weekly aerial inspection reports are reviewed and then filed at the regional offices. M&NP staff also drive the RoW on an all-terrain vehicle once a year to assess its condition and repair any signage that has been damaged. Examples of the different patrol reports were reviewed as part of the audit.

For situations where encroachments such as fences were installed on the RoW without permission, they were removed. In cases where they have been allowed to remain, record review indicates that permitted encroachments are recorded. In order to ensure compliance with the PCR, Part II section 15, all facilities permitted to be installed on the RoW must be inspected to ensure “any deterioration has been detected.” As the pipeline is approaching its second decade of operation, any facilities that were permitted on the RoW should be inspected to ensure that they are being maintained and not posing a threat to the safety of the pipeline. In addition, in order to ensure compliance with the PCR, Part II section 15, the SOP needs to address the requirement that all facilities permitted to be installed on the RoW be inspected to ensure any deterioration has been detected.

Although the Board was able to verify that various aspects of the surveillance and monitoring program were implemented as designed, the Operator did not demonstrate that it has developed and implemented surveillance and monitoring programs that address all legal requirements.

Compliance Status: Non-compliant

4.2 Corrective and Preventive Actions

Expectations: The company shall have a process to investigate incidents or any non-compliances that may occur. The company shall have a process to mitigate any potential or actual issues arising from such incidents or non-compliances. Such mitigation may include appropriate timing and actions for addressing the issues that arise. The company shall demonstrate that it has established a documented procedure to:

  • set criteria for non-compliance;
  • identify the occurrence of any non-compliances;
  • investigate the cause(s) of any non-compliances;
  • develop corrective and/or preventive actions; and
  • effectively implement the required corrective and/or preventive actions.

The company should develop procedures to analyze incident data in order to identify deficiencies and opportunities for improvement in its management and protection programs and procedures.

References:
OPR-99 sections 6 and 52
CSA-Z662 Clause 10.2.2(g)(h) and 10.14
PCR Part II section 13

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

The criteria for non-compliance are described in the PCR and the Operator has incorporated those requirements in its procedures. According to field staff, there are few incidents of unauthorized activity on the M&NP RoW with the majority of the issues identified in the urban centres. Technical staff have had to intervene and shut down companies who were working on the RoW without a crossing agreement. Staff assert that the offenders receive awareness information. According to staff, if the activity meets the criteria for a simple crossing, field technicians follow the onsite approval process as presented in the M&NP Facility Crossing Guidelines. If the investigation of unauthorized activity is on the RoW or in the safety zone, follow-up consists of an informal discussion and awareness material is provided to the offender regarding the regulatory requirements and safety issues. In some cases, Operations technical staff gave onsite approvals for unauthorized activity without immediately notifying the Coordinator. Some field staff were unaware of the requirement to report each occurrence of unauthorized activity to the NEB. The Board concluded that the reporting of unauthorized activity has not been done in accordance with the PCRs or the M&NP policy. Although identified as a requirement in the NEB PCR Part II section 13 as well as M&NP’s Facility Crossing Guidelines, the Operator’s staff are not reporting all unauthorized activities to the NEB or to their Coordinator.

The Operator did not demonstrate that it has implemented its process for reporting unauthorized activity as per its Guidelines and the expectations for this element.

Compliance Status: Non-compliant

4.3 Records Management

Expectations: The company shall establish and implement procedures to ensure that the records supporting the management and protection programs are retained, accessible and maintained. The company shall, as a minimum, retain all records for the minimum lengths of time as required by the applicable legislation, regulation and standards incorporated by reference into the regulation.

References:
OPR-99 sections 41, 51, 52, 56
CSA-Z662-07 Clause 10.2.2(e) and 10.14
PCR Part II sections 10(c), 11(1) and 16

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

The Operator manages its crossing-related files at the regional offices. Onsite document review confirmed that records for locates, including the locate requests that received the “all clear” when it was determined that no locate was necessary, as well as crossings and related inspection reports are kept in the regional offices and maintained for the life of the pipeline. The Coordinators maintain complex crossing files and any subsequent reports or correspondence in the office for the life of the pipeline. Other records such as the aerial and ground RoW patrol reports are maintained in hard copy in the regional offices. As-builts are tracked as requested and distributed during the crossings application and design phase as part of records control to ensure that they are aware of who has a map of the system and why.

For the equipment related to the crossing program, office administrators manage maintenance records in System and Integrity Logging and initiate the maintenance requests based on a manufacturer recommended schedule. Documents reviewed on site such as the certificates of calibration confirm this process is being implemented as described.

The Operator was able to demonstrate that it has a process in place to maintain crossing-related files for the life of the pipeline as required.

Compliance Status: Compliant

4.4 Internal Audit

Expectations: The company shall develop and implement a documented process to undertake audits of its management and protection programs and procedures. The audit process should identify and manage the training and competency requirements for staff carrying out the audits. These audits shall be conducted on a regular basis.

References:
OPR-99 section 53
CSA Z662-07 Clause 10.2.2(h)

Assessment:
As part of an O&M Agreement between M&NP and its Operator, the Operator is implementing and maintaining all aspects of the safety program including activities related to third party excavation and construction activities near the M&NP system.

The Operator’s internal audit process currently includes in its scope: safety; environment; emergency preparedness and response; and integrity. However, it did not mention that the PCR requirements were included in the protocols. Therefore, although some of the activities would have been reviewed under the IMP audit, PCR-specific requirements were not included. Activities related to third party excavation and construction activities form an integral part of each of those programs as the outcome of an interaction with third parties could potentially affect the safety of the public or personnel, environmental protection, and/or integrity of the pipeline.

The Operator could not demonstrate that its current internal audit process included an evaluation of the adequacy with which the PCR requirements are met.

Compliance Status: Non-Compliant

5.0 MANAGEMENT REVIEW

5.1 Management Review

Expectations: Senior management should formally review the management and protection programs for continuing suitability, adequacy and effectiveness. The review should be based on appropriate documentation and records including the results of the surveillance, monitoring and audit programs. This review should be formal and documented and should occur on a regular basis. The management review should include a review of any decisions, actions and commitments which relate to the improvement of the programs and the company’s overall performance.

References:
OPR-99 section 53 and section 55
CSA Z662-07 Clause 10.2.2(h)(iii)
PCR Part II, sections 4 and 5

Assessment:
See Appendix VII for the assessment of this element.

Compliance Status: See Appendix VII for the assessment of this element.

Date modified: