Guidance Notes for the National Energy Board Onshore Pipeline Regulations

4 September 2013
Sections 47.2 and 55, and Annex A – updated 7 October 2016

GUIDANCE NOTES FOR THE

NATIONAL ENERGY BOARD ONSHORE PIPELINE REGULATIONS

INTRODUCTION

The National Energy Board Onshore Pipeline Regulations (OPR) provide regulatory requirements for oil and gas companies under the National Energy Board Act (NEB Act).

These Guidance Notes are provided to assist interested parties in understanding the requirements of the OPR. These Guidance Notes are not a substitute for the NEB Act or any regulations made thereunder including the OPR, or any other applicable legislation or standards enforced by the National Energy Board (NEB or Board) or which the Board audits companies against. To achieve or evaluate compliance with the OPR, reference should be made to the OPR itself, and reliance should not be placed on these Guidance Notes. To the extent there is any inconsistency between these Guidance Notes and the NEB Act or its regulations, or any other applicable legislation or standards, the legislation and standards are paramount.

The Board’s compliance activities include conducting compliance assessment meetings, inspections and audits to review a company’s compliance with the NEB Act and related regulations. The NEB’s Audit Protocol is provided in a separate document and outlines the framework for compliance assessment in an NEB audit.

The NEB’s Filing Manual contains filing requirements for OPR requirements involving applications that require NEB authorization.

The NEB expects pipeline companies to approach operating in a systematic, comprehensive and proactive manner that manages risks. The Board also expects that companies have fully developed and implemented management systems and protection programs that provide for continual improvement. A carefully-designed and well-implemented management system supports a strong culture of safety and is fundamental to keeping people safe and protecting the environment.

As required by the OPR, companies must establish, implement and maintain management systems and protection programs in order to anticipate, prevent, manage and mitigate conditions that may adversely affect the safety and security of the company’s pipelines, employees, the public, as well as property and the environment. A company’s management system applies to the company’s programs for safety, pipeline integrity, environmental protection, emergency management and security.

When requested by the Board, companies must demonstrate the adequacy and effectiveness of the management processes and procedures employed.

Table of Contents

Interpretation

1. The definitions in this section apply in these Regulations.

"abandon" means to permanently cease operation such that the cessation results in the discontinuance of service. (cessation d'exploitation)

"accountable officer" means a person appointed as accountable officer under subsection 6.2(1). (dirigeant responsable)

"Act" means the National Energy Board Act. (Loi)

"change of service" means a change in the type of fluid transported in the pipeline, which necessitates changes to the design requirements in accordance with CSA Z662.(modification du service)

"class location" means a class location as defined in CSA Z662 and as determined in accordance with that standard. (classe d'emplacement)

"component" means a component as defined in CSA Z662. (élément)

"CSA" means the Canadian Standards Association. (CSA)

"CSA Z246.1" means CSA Standard Z246.1 entitled Security Management for Petroleum and Natural Gas Industry Systems, as amended from time to time. (norme CSA Z246.1)

"CSA Z276" means CSA Standard Z276 entitled Liquefied Natural Gas (LNG) – Production, Storage and Handling, as amended from time to time. (norme CSA Z276)

"CSA Z341" means CSA Standard Z341 entitled Storage of Hydrocarbons in Underground Formations, as amended from time to time. (norme CSA Z341)

"CSA Z662" means CSA Standard Z662 entitled Oil and Gas Pipeline Systems, as amended from time to time. (norme CSA Z662)

"deactivate" means to remove temporarily from service. (mettre hors service)

"decommission" means to permanently cease operation such that the cessation does not result in the discontinuance of service. (désaffectation)

"environment" means elements of the Earth and includes

  • (a) land, water and air, including all layers of the atmosphere;
  • (b) all organic and inorganic matter and living organisms; and
  • (c) the interacting natural systems that include elements referred to in paragraphs (a) and (b). (environnement)

"HVP" means high vapour pressure as defined in CSA Z662. (HPV)

"incident" means an occurrence that results in

  • (a) the death of or serious injury to a person;
  • (b) a significant adverse effect on the environment;
  • (c) an unintended fire or explosion;
  • (d) an unintended or uncontained release of LVP hydrocarbons in excess of 1.5 m³;
  • (e) an unintended or uncontrolled release of gas or HVP hydrocarbons; or
  • (f) the operation of a pipeline beyond its design limits as determined under CSA Z662 or CSA Z276 or any operating limits imposed by the Board. (incident)

"inspection officer" means an inspection officer designated by the Board under section 49 of the Act. (inspecteur)

"joining" means the joining of pipe and components, performed after the pipe and component manufacturing processes. (assemblage)

"LVP" means low vapour pressure as defined in CSA Z662. (FPV)

"management system" means the system set out in sections 6.1 to 6.6. (système de gestion)

"maximum operating pressure" means maximum operating pressure as defined in CSA Z662. (pression maximale de service)

"onshore pipeline or pipeline" means a pipeline intended for the transmission of hydrocarbons that is not in an offshore area. (pipeline terrestre ou pipeline)

"operate" includes repair, maintain, deactivate, reactivate and decommission. (exploiter)

"release" includes discharge, spray, spill, leak, seep, pour, emit, dump, and exhaust.(rejet)

"serious injury" includes an injury that results in

  • (a) the fracture of a major bone;
  • (b) the amputation of a body part;
  • (c) the loss of sight in one or both eyes;
  • (d) internal hemorrhage;
  • (e) third degree burns;
  • (f) unconsciousness; or
  • (g) the loss of a body part or function of a body part. (blessure grave)

"station" means a facility that is used in connection with the operation of a pipeline, and includes a facility for pumping, compression, pressure reduction, storage of hydrocarbons, metering, receiving or delivering. It also includes the land and other works connected with the facility. (station)

"storage facility" means a facility that is constructed for the storage of oil and includes the land and other works connected with the facility. (installation de stockage)

"toxic substance" means a substance that enters the environment in a quantity or concentration that may

  • (a) have an immediate or long-term adverse effect on the environment;
  • (b) constitute a danger to the environment on which human life depends; or
  • (c) constitute a danger to human life or health. (substance toxique)

GOAL (Section 1): Provide definitions for terms used in the OPR.

Section 48 of the NEB Act provides the Board with the authority to make regulations (subject to the approval of the Governor in Council) governing the design, construction, operation and abandonment of a pipeline and providing for the protection of property and the environment and the safety and security of the public and of the company's employees in the construction, operation and abandonment of a pipeline.

The definition of "pipeline" is provided at section 2 of the NEB Act:

"pipeline" means a line that is used or to be used for the transmission of oil, gas or any other commodity and that connects a province with any other province or provinces or extends beyond the limits of a province or the offshore area as defined in section 123, and includes all branches, extensions, tanks, reservoirs, storage facilities, pumps, racks, compressors, loading facilities, interstation systems of communication by telephone, telegraph or radio and real and personal property, or immovable and movable, and works connected to them, but does not include a sewer or water pipeline that is used or proposed to be used solely for municipal purposes.

The term "onshore pipeline" is specifically defined within the OPR to clarify that the OPR applies to pipelines intended for the transmission of hydrocarbons in onshore areas. Onshore areas are generally accepted to be pipelines installed on land above the ordinary high water mark of major water bodies.

Companies may consider reporting to the Board events having the potential to attract public and/or media attention or which have or may have significant adverse effects on property, the environment or the safety of persons regardless of whether or not they meet the strict definition of an "incident". In addition, the Board has developed the following definition of a "major bone" to assist companies in complying with the reporting requirements set out in section 52 of the OPR:

"major bone"
skull, mandible, spine, scapula, pelvis, femur, humerus, fibula, tibia, radius, and ulna.

For other fractured skeletal bones not listed, only those fractures that require an individual to undergo immediate corrective surgery are classified as a serious injury, hence a reportable incident.

In addition to the terms defined within section 1 of the OPR, the terms "audit", "inspection", "management system", "program", "process", procedure", "plan", "manual", and "practice" appear in the OPR and in this document. For clarity, these terms are generally understood to have the following meanings:

audit
A systematic, documented verification process of objectively obtaining and evaluating evidence to determine whether specified activities, events, conditions, management systems or information about these matters conform with audit criteria and legal requirements, and communicating the results of the process to the company.
inspection
An on-site and site-specific methodical examination and assessment of a company's construction, operation, or abandonment activities against its regulatory obligations, standards, acceptable industry practice, and the inspector's professional judgment. An inspection focuses on compliance requirements, usually pursuant to an approval condition or regulatory requirement, at an individual facility at a given point in time.
management system
The system set out in sections 6.1 to 6.6 of the OPR. It is a systematic approach designed to effectively manage and reduce risk, and promote continual improvement. It includes the necessary organizational structures, resources, accountabilities, policies, processes and procedures required for an organization to fulfill all tasks related to safety, security and environmental protection.
manual
A document that contains a set of instructions on methods which are employed to accomplish a result. These instructions will be detailed and comprehensive. The document will be organized for ease of use.
plan
A detailed, documented formulation for action to achieve an end.
practice
A repeated or customary action which is well understood by persons who are authorized to carry it out. Safe work practices are generally written methods outlining how to perform a task with minimum risk to people, equipment, materials, environment, and processes.
procedure
A procedure indicates how a process will be implemented. It provides a documented series of steps followed in an established order. A procedure includes the identification of roles, responsibilities and authorities required for completing each step.
process
A documented series of actions taking place in an established order, with identified roles and responsibilities, and directed toward a result. A process includes the roles, responsibilities and authorities for the actions. A process may contain a set of procedures, if required.
program
A documented set of processes and procedures designed to regularly accomplish a result. A program outlines how plans, processes and procedures are linked, and how each one contributes toward the result. Program planning and evaluation are conducted regularly to check that the program is achieving intended results.

The terms "practical" and "practicable" are used in the OPR and are generally understood to have the following meanings:

practical
Typically used to describe an activity or function that satisfies a need in the most economical and time expedient manner while considering social and economic factors as well as maintaining safety and the protection of property and the environment.
practicable
Means that something can and will be done even if it may not be practical.

Acronyms in Guidance Notes

ANSI: American National Standards Institute

CSA: Canadian Standards Association

ESD systems: Emergency shut down systems

ILI: In line inspection

MOP: Maximum Operating Pressure

MSDS: Material Safety Data Sheet

NDE: Non-destructive examination

PPE: Personal protective equipment

SCADA: Supervisory Control and Data Acquisition

Application

2. Subject to sections 2.1 and 3, these Regulations apply to onshore pipelines designed, constructed, operated or abandoned after the coming into force of these Regulations.

2.1 These Regulations do not apply in respect of a hydrocarbon processing plant that is subject to the National Energy Board Processing Plant Regulations.

GOAL (Section 2): Provide the scope of the application of the OPR.

The OPR applies to onshore pipelines intended for the transmission of hydrocarbons.

3.(1) Subject to subsection (2), sections 9 to 26 apply in respect of any construction, maintenance or repairs undertaken with respect to a pipeline.

(2) Sections 9 to 26 do not apply in respect of a pipeline or any part of a pipeline

  • (a) that exists on the coming into force of these Regulations; or
  • (b) for which an authorization to construct, maintain or repair it was issued on or before the coming into force of these Regulations.

GOAL (Section 3): Provide the scope of application of the OPR.

Design and construction requirements within the OPR do not apply to pipelines which, prior to 01 August 1999, were:

  • (a) in operation;
  • (b) under construction;
  • (c) in receipt of an Order authorizing construction; or
  • (d) in receipt of a Certificate of Public Convenience and Necessity.

They do, however, apply to any modifications, additions and re-testing performed on or made to those pipelines after 01 August, 1999.

The balance of the OPR applies to all onshore pipelines.

General

4. (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of

  • (a) these Regulations;
  • (b) CSA Z276, if the pipeline transports liquefied natural gas;
  • (c) CSA Z341 for the underground storage of hydrocarbons;
  • (d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons; and
  • (e) CSA Z246.1 for all pipelines.

(2) Without limiting the generality of subsection (1), the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the design, specifications, programs, manuals, procedures, measures and plans developed and implemented by the company in accordance with these Regulations.

(3) If there is an inconsistency between these Regulations and a standard referred to in paragraphs (1)(b), (c), (d) or (e) these Regulations prevail to the extent of the inconsistency.

GOAL (Section 4): Pipelines are designed, constructed, operated and abandoned according to the OPR and appropriate standards.

The word "company" has the same meaning in these Guidance Notes and in the OPR as it does in the NEB Act. Thus, the company which holds the Certificate or the Order must follow the OPR. The company must also ensure that all agents, contractors, operators, etc. are aware of and comply with the OPR, follow good safety and environmental practices, and obtain all necessary approvals and permits.

Referenced standards are part of the OPR. Companies may direct questions on interpretation or application of reference standards to the appropriate standards body. The Board is not bound by the interpretation of the standards body but would normally consider this interpretation in providing its own interpretation.

Standards incorporated by reference within the OPR are in force from the date of publication of the standard. Companies should confirm compliance with changes to referenced standards upon their publication.

5. If a company is required by these Regulations to develop a design, specification, program, manual, procedure, measure or plan, the Board may order amendments to it if the Board considers it necessary for safety or environmental reasons or if it is in the public interest to do so.

GOAL (Section 5): Outline the Board's authority in ordering changes.

5.1(1) Designs, specifications, programs, manuals, procedures, measures or plans for which no standard is set out in these Regulations shall be submitted by a company to the Board for approval.

(2) The Board shall approve a design, specification, program, manual, procedure, measure or plan if

  • (a) it provides for a level of safety or protection at least equivalent to the level of safety or protection generally provided for by a comparable CSA standard, or by another applicable standard; or
  • (b) in the absence of a comparable CSA or other applicable standard, it provides for a level of safety or protection that is adequate in the circumstances.

GOAL (Section 5.1): A consistent level of safety and protection is provided for all pipelines.

When a company creates any design, specification, program, manual, procedure, measure or plan which is not governed by a standard referenced within the OPR, it must be submitted to the Board for approval. As a general rule, these documents would be evaluated against existing or relevant standards whenever possible.

Pressure vessels which are owned and operated by a federally regulated pipeline company and which are associated with the operation of the pipeline should be designed, constructed, operated and abandoned in accordance with the NEB’s Guidance Notes for the Design, Construction, Operation and Abandonment of Pressure Vessels. This document provides guidance to pipeline companies for the development of a program for the management of pressure vessels.

Boilers which are owned and operated by a federally regulated pipeline company and which are associated with the operation of the pipeline should be designed, constructed, operated and abandoned in accordance with Part V of the Canada Occupational Health and Safety Regulations. The Board has oversight over the regulatory compliance of boilers in accordance with a Memorandum of Understanding between Human Resources Development Canada and the NEB.

6. When a company designs, constructs, operates or abandons a pipeline, it shall do so in a manner that ensures

  • (a) the safety and security of the public and the company’s employees;
  • (b) the safety and security of the pipeline; and
  • (c) the protection of property and the environment.

GOAL (Section 6): A company meets its obligations for safety, security and protection of the environment when designing, constructing, operating or abandoning a pipeline.

Section 6 is a general duty clause that sets out a pipeline company’s duty to conduct its activities in a manner that ensures the safety and security of people and the pipeline and protection of the environment. The company must do this in the course of performing any of its activities authorized under the OPR and any certificate, permit or other approval issued by the NEB. A company implements its management system, as required in sections 6.1 to 6.6 of the OPR, in furtherance of these obligations.

Management System

6.1 A company shall establish, implement and maintain a management system that

  • (a) is systematic, explicit, comprehensive and proactive;
  • (b) integrates the company’s operational activities and technical systems with its management of human and financial resources to enable the company to meet its obligations under section 6;
  • (c) applies to all the company’s activities involving the design, construction, operation or abandonment of a pipeline and to the programs referred to in section 55;
  • (d) ensures coordination between the programs referred to in section 55; and
  • (e) corresponds to the size of the company, to the scope, nature and complexity of its activities and to the hazards and risks associated with those activities.

6.2(1) The company shall appoint an officer as accountable officer to ensure on its behalf that its management system and the programs referred to in section 55 are established, implemented and maintained in accordance with section 6.1, this section and sections 6.3 to 6.6 and that its obligations under section 6 are met.

(2) Within 30 days after the appointment of its accountable officer, the company shall notify the Board in writing of the name of the person appointed and ensure that the accountable officer submits to the Board a signed statement accepting the responsibilities of their position.

(3) The company shall ensure that the accountable officer has authority over the human and financial resources required to

  • (a) establish, implement and maintain the management system and the programs referred to in section 55; and
  • (b) ensure that the company’s activities are carried out in a manner that enables it to meet its obligations under section 6.

6.3(1) The company shall establish documented policies and goals for meeting its obligations under section 6, including

  • (a) a policy for the internal reporting of hazards, potential hazards, incidents and near-misses that includes the conditions under which a person who makes a report will be granted immunity from disciplinary action; and
  • (b) goals for the prevention of ruptures, liquid and gas releases, fatalities and injuries and for the response to incidents and emergency situations.

(2) The company shall base its management system, as well as the programs referred to in section 55, on those policies and goals.

(3) The accountable officer shall prepare a policy statement that sets out the company’s commitment to those policies and goals and shall communicate it to the company’s employees.

6.4 The company must have a documented organizational structure that enables it to

  • (a) meet the requirements of the management system and meet its obligations under section 6;
  • (b) determine and communicate the roles, responsibilities and authority of the officers and employees at all levels of the company; and
  • (c) demonstrate, based on an annual documented evaluation of need, that the human resources allocated to establishing, implementing and maintaining the management system are sufficient to meet the requirements of the management system and to meet the company’s obligations under section 6.

GOAL (Sections 6.1 – 6.4): A company has a management system and programs that enable it to meet its obligations for safety, security and protection of the environment.

Through its management system, a company manages and reduces risk, and continually improves its operations. A carefully-designed and well-implemented management system supports a strong culture of safety and is fundamental to keeping people safe and protecting the environment.

Management systems provide a consistent framework for the design, development and implementation of protection programs, as well as for the cyclical planning, implementation, review and adjustment of operational activities which is essential for a company to effectively address risks, manage its resources appropriately and achieve desired outcomes. To meet the requirements of the OPR, management systems must be formally established and consistently implemented and managed.

Management System (Section 6.1)

  • Systematic, explicit, comprehensive and proactive

    The OPR requires a management system to be systematic, explicit, comprehensive and proactive; this provides for continual improvement. A description of each of these components is provided below.

    Systematic – A company’s management system is applied in a consistent manner throughout the organization, its sites, regions, business units, and any aspect of the organization.

    Explicit – A company’s management system, and its policies and goals are documented and visible.

    Comprehensive – A company’s management system addresses all aspects of a company’s business that may affect safety, security and protection of the environment. This includes areas beyond operational activities such as administrative and support functions, which may also impact safety, security and environmental outcomes (i.e., finance, procurement, human resources).

    Proactive – A company’s management system involves planning and foresight that emphasizes hazard identification and anticipation, and risk control and mitigation, before events that affect safety, security and environmental protection occur.
  • Integrates operational and technical systems with management of resources

    A company integrates operational and technical systems with its management of human and financial resources to make sure it is able to achieve safety, security and environmental protection outcomes. This integration recognizes and effectively manages the relationship between traditionally technical issues (e.g., materials selection or training and capacity) and financial or human resource management practices (e.g., purchasing, procurement, recruitment and contracting), both of which may affect safety, security and environmental protection outcomes.
  • Applies to all of a company’s relevant activities and programs

    A company’s management system applies to the company’s programs for safety, security, integrity, environmental protection and emergency management. For programs to be systematic, comprehensive, explicit and proactive, they must include the requirements in section 6.5. These include processes to identify hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance. A company’s management system and programs are based on the company’s policies and goals as well as the requirements of the OPR.

    The company’s management system applies to all of the company’s activities involving the design, construction, operation or abandonment of a pipeline. For example, when a company plans and designs a pipeline, it uses its hazard assessment process to identify hazards to safety and the environment. The company also uses its risk management process to evaluate and manage risks, and develop the controls included in its proposed project. When a company constructs and operates its pipeline, it applies its management system through its safety management program, its environmental protection program, and the other management programs required by the OPR.
  • Coordination between programs

    A company’s management system provides coordination between the company’s management and protection programs. For example, if a hazard is identified through the safety management program, that may also be a consideration in the environmental protection program, this information would be considered in the planning for both programs.
  • Scalable, corresponding to the nature and scope of a company’s activities

    Each company’s management system and its programs are based on its own situation and the activities it conducts, and should systematically address the hazards and risks that may affect it.

Accountable Officer Appointment and Notification (Section 6.2)

A company must appoint an accountable officer who has authority for the financial and human resources of the company required to meet its obligations for safety, security and protection of the environment.

The accountable officer is the person responsible on the company’s behalf for the company’s management system and related programs (safety, security, integrity, environmental protection and emergency management).

The accountable officer provides the focus, direction, influence and leadership, which is required to create a robust safety culture, and implement and continually improve a well-functioning management system within the organization. For example, the accountable officer communicates the company’s commitment to its policies and goals to the company’s employees. Corporate culture is driven by the top down and, as a result, engagement and commitment at the most senior level is required to effect change as needed.

The accountable officer is typically the person who holds the most senior position in the company. Based on a company's organizational structure, this person may hold the position of CEO, President, or some other designation. See the NEB website (www.neb-one.gc.ca), in the Guidance section of the OPR page, under Company Submission Requirements, for a flowchart to assist companies with identifying their accountable officer.

When a company has appointed an accountable officer, within 30 days of the appointment, the company must notify the Board of the name of the person appointed. The OPR also requires the accountable officer to submit a signed statement to the Board accepting the responsibilities of the position.

See the NEB website (www.neb-one.gc.ca), in the Guidance section of the OPR page, under Company Submission Requirements, for suggested template letters for (i) company notification to the NEB that it has appointed its accountable officer, and (ii) the signed statement from the accountable officer.

For further guidance on safety governance, see the Organization for Economic Co-operation and Development’s paper entitled Corporate Governance for Process Safety, Guidance for Senior Leaders in High Hazard Industries (June 2012).

Policies and Goals (Section 6.3)

A company’s commitment to safety, security and environmental protection is stated in its policies, and these policies are the foundation upon which an organization’s management system is based. A company’s goals reflect the direction and desired outcomes of the policies, and provide the basis for a company’s commitment to continual improvement through its management system.

In addition to typical high level goals of zero spills, ruptures, injuries and fatalities, the OPR requires that a company sets goals that contribute to the prevention of ruptures, liquid and gas releases, fatalities and injuries, and for the response to incidents and emergency situations.

A company is required to have a policy and a related process for the internal reporting of hazards, potential hazards, incidents and near-misses. The policy must contain conditions where immunity will be granted for internal reporting of hazards, near misses and incidents.

This policy will enable employees to identify hazards and risks they may encounter during work activities, without fear of reprisal. The company’s internal process provides the steps to follow for internal reporting. With this process, the company tracks internal reporting through a data management system in order to continually improve safe operations and its safety culture.

Documented organizational structure (Section 6.4)

In order to have a fully functioning management system, a company must have a documented organizational structure. Determination and communication of roles, responsibilities and governance structure are integral to a well-functioning management system. Up-to-date assessments of human resource needs, and appropriate allocation of human resources, are also critical for safety, security and environmental protection outcomes.

Management System Processes

6.5(1) A company shall, as part of its management system and the programs referred to in section 55,

  • (a) establish and implement a process for setting the objectives and specific targets that are required to achieve the goals established under subsection 6.3(1) and for ensuring their annual review;
  • (b) develop performance measures for assessing the company’s success in achieving its goals, objectives and targets;
  • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;
  • (d) establish and maintain an inventory of the identified hazards and potential hazards;
  • (e) establish and implement a process for evaluating and managing the risks associated with the identified hazards, including the risks related to normal and abnormal operating conditions;
  • (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks;
  • (g) establish and implement a process for identifying, and monitoring compliance with, all legal requirements that are applicable to the company in matters of safety, security and protection of the environment;
  • (h) establish and maintain a list of those legal requirements;
  • (i) establish and implement a process for identifying and managing any change that could affect safety, security or the protection of the environment, including any new hazard or risk, any change in a design, specification, standard or procedure and any change in the company’s organizational structure or the legal requirements applicable to the company;
  • (j) establish and implement a process for developing competency requirements and training programs that provide employees and other persons working with or on behalf of the company with the training that will enable them to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment;
  • (k) establish and implement a process for verifying that employees and other persons working with or on behalf of the company are trained and competent and for supervising them to ensure that they perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment;
  • (l) establish and implement a process for making employees and other persons working with or on behalf of the company aware of their responsibilities in relation to the processes and procedures required by this section;
  • (m) establish and implement a process for the internal and external communication of information relating to safety, security and protection of the environment;
  • (n) establish and implement a process for identifying the documents required for the company to meet its obligations under section 6;
  • (o) establish and implement a process for preparing, reviewing, revising and controlling those documents, including a process for obtaining approval of the documents by the appropriate authority;
  • (p) establish and implement a process for generating, retaining and maintaining records that document the implementation of the management system and the programs referred to in section 55 and for providing access to those who require them in the course of their duties;
  • (q) establish and implement a process for coordinating and controlling the operational activities of employees and other people working with or on behalf of the company so that each person is aware of the activities of others and has the information that will enable them to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment;
  • (r) establish and implement a process for the internal reporting of hazards, potential hazards, incidents and near-misses and for taking corrective and preventive actions, including the steps to manage imminent hazards;
  • (s) establish and maintain a data management system for monitoring and analyzing the trends in hazards, incidents and near-misses;
  • (t) establish and implement a process for developing contingency plans for abnormal events that may occur during construction, operation, maintenance, abandonment or emergency situations;
  • (u) establish and implement a process for inspecting and monitoring the company’s activities and facilities to evaluate the adequacy and effectiveness of the programs referred to in section 55 and for taking corrective and preventive actions if deficiencies are identified;
  • (v) establish and implement a process for evaluating the adequacy and effectiveness of the company’s management system and for monitoring, measuring and documenting the company’s performance in meeting its obligations under section 6;
  • (w) establish and implement a quality assurance program for the management system and for each program referred to in section 55, including a process for conducting audits in accordance with section 53 and for taking corrective and preventive actions if deficiencies are identified; and
  • (x) establish and implement a process for conducting an annual management review of the management system and each program referred to section 55 and for ensuring continual improvement in meeting the company’s obligations under section 6.

(2) In this section, a reference to a process includes any procedures that are necessary to implement the process.

(3) The company shall document the processes and procedures required by this section.

GOAL (Section 6.5): A company establishes and implements the processes and documentation required for a systematic, explicit, comprehensive and proactive management system.

A company’s management system and protection programs contain processes for identifying hazards, managing risks, training and managing workers, communicating, managing records and documentation, monitoring and evaluating progress, and continually improving performance.

All processes and procedures, as well as the related documents and lists, are documented. Processes and procedures, and related products, are reviewed on a regular basis and part of continual improvement. Processes and procedures evolve over time as the technology and tools evolve and in response to lessons learned from incidents and near misses.

See the NEB website (www.neb-one.gc.ca), in the Guidance section of the OPR page, under OPR Management System Amendment – Questions and Answers, for more information on the management system processes required in section 6.5.

Annual Report

6.6(1) A company shall complete an annual report for the previous calendar year, signed by the accountable officer, that describes

  • (a) the performance of the company’s management system in meeting its obligations under section 6 and the company’s achievement of its goals, objectives and targets during that year, as measured by the performance measures developed under paragraphs 6.5(1)(b) and (v); and
  • (b) the actions taken during that year to correct any deficiencies identified by the quality assurance program established under paragraph 6.5(1)(w).

(2) No later than April 30 of each year, the company shall submit to the Board a statement, signed by the accountable officer, indicating that it has completed its annual report.

GOAL (Section 6.6): Companies complete annual reports on the performance of their management system, and document the actions taken to correct deficiencies.

A company must submit to the NEB a statement, signed by the accountable officer, that it has completed its annual report, no later than April 30 of each year.

See the NEB website (www.neb-one.gc.ca), in the Guidance section of the OPR page, under Company Submission Requirements, for a suggested template letter for notification to the NEB of a company’s completion of its annual report.

Design of the Pipeline

Detailed Designs

9. A company shall develop detailed designs of the pipeline and submit them to the Board when required to do so.

GOAL (Section 9): Appropriate designs are developed for all pipelines.

Detailed designs and supporting information demonstrate:

  • (a) conformance to the requirements established by the company to ensure the design is fit for its intended service;
  • (b) compliance with applicable regulations, codes, and standards;
  • (c) consideration of unique design circumstances and specific direction on special or unique requirements as appropriate;
  • (d) the appropriateness of selected or specified materials for their intended purpose; and
  • (e) that the design provides for adequate and effective protection of property and the environment, security of the pipeline, and the safety of all persons.

Designs may also include provision for compliance with the environmental protection program referred to within section 48, and other relevant programs required in the OPR.

HVP Pipelines

10.(1) When an HVP pipeline is to be situated in a Class 1 location and within 500 m of the right-of-way of a railway or paved roadway, a company shall develop a documented risk assessment to determine the need for heavier wall design, taking into account such factors as pipeline diameter and operating pressure, HVP fluid characteristics, topography and traffic type and density of the traffic on the railway or paved road.

(2) A company shall submit a documented risk assessment to the Board when required to do so.

GOAL (Section 10): An acceptable level of safety for HVP pipelines is provided for in the vicinity of railways and roadways.

For assistance in preparing the documented risk assessment, companies are directed to CSA Z662, Annex B, Guidelines for Risk Assessment of Pipelines. The nature and magnitude of the risk assessment should be commensurate with the nature, magnitude, and potential impact of the associated potential hazards.

Stations

11. A station shall be

  • (a) designed to provide year-round suitable access for personnel;
  • (b) designed to prevent unauthorized entry to and unauthorized operation of the station;
  • (c) equipped with facilities for the containment, handling and disposal of wastes incidental to the station's operation; and
  • (d) designed so that the noise level during operations meets the noise level requirement approved by the Board pursuant to section 5.1.

GOAL (Section 11): Appropriate design considerations are used for all stations.

Stations should be equipped with security systems to prevent unauthorized entry or operation including remote operation through a SCADA system. Measures to deter mischief or acts of malicious intent could be considered.

Year round access, security, spill containment, waste handling, and noise limits are essential to the safe and environmentally sound operation of a station. Stations should be designed to prevent soil, groundwater and surface water contamination by employing methods and systems such as secondary containment, surface run-off retention ponds, leak detection, spill prevention and loss control programs.

Additional consideration may be given to design features that limit and monitor emissions and/or noise, lighting, emergency egress, confined space, ventilation, electrical classification, etc.

For noise levels, the company should identify any applicable or adopted federal, provincial and municipal legislation and guidelines or, in the absence of legislation and guidelines, the company standard that the facility has been designed to, or would be operated in accordance with, and submit that information to the Board for approval under section 5.1. The information provided should clearly demonstrate how the facility would be in compliance with the OPR and the company standard.

12. A compressor station or pump station shall be equipped with an alternate source of power capable of

  • (a) operating the station's emergency shut-down system;
  • (b) operating an emergency lighting system for the safe evacuation of personnel from the station and for other emergency procedures; and
  • (c) maintaining any other service essential to the safety of personnel or the public or the protection of the environment.

GOAL (Section 12): Stations can be shut down in a safe and controlled manner in the event of primary power interruption.

Alternate sources of power for essential station systems should be designed so they can be tested periodically and should be in compliance with the requirements of the Canada Occupational Health and Safety Regulations, Part VIII, Electrical Safety.

Emergency shut down (ESD) systems and controls should be designed to provide reliable service under all conditions.

Additional consideration should be given to design features such as lighting, emergency egress, confined space, ventilation, electrical classification, etc.

Storage Facilities

13. A storage facility shall

  • (a) be located in an area that is known to be free from flooding, landslides, rockfalls and geological faults;
  • (b) be serviced by an all-weather road that gives access to all permanently installed fire-fighting equipment located at or near the storage facility; and
  • (c) have a containment area designed to prevent the release or migration of stored products or toxic substances.

GOAL (Section 13): Storage facilities are properly located and designed safely.

The location of a storage facility should be chosen so as to maximize employee and public safety, and to minimize environmental damage, including any threats to the quality of soil, surface water and groundwater, environmentally sensitive areas, and the health of humans, animals and plants during the construction, operation, deactivation, or abandonment of the storage facility. General construction considerations for storage facilities must meet the requirements of the applicable standards referred to in section 4.

In order to prevent soil, groundwater and surface water contamination and to protect the environment, the design of storage facilities includes consideration of operating practices mentioned in the applicable standards referred to in section 4. This includes consideration of:

  • (a) primary containment storage devices complete with integrity monitoring and enhancement features;
  • (b) secondary containment systems;
  • (c) leak detection systems;
  • (d) spill prevention;
  • (e) loss control programs (including fire suppression);
  • (f) weather protection systems;
  • (g) operating procedures;
  • (h) integrity management;
  • (i) nuisance noise and odours;
  • (j) environmental risk;
  • (k) groundwater monitoring programs; and
  • (l) documentation and records control.

Storage facilities may have site specific operating procedures and integrity management requirements.

Materials

Specifications

14. A company shall develop specifications for the pipe and components to be used in the pipeline and shall submit them to the Board when required to do so.

GOAL (Section 14): Pipe and components are appropriate for their intended service.

Specifications should include, but are not limited to, the following:

  • (a) a description of the item and the limits for which the specification applies (e.g., diameter range, thickness, service, pressure range/ANSI rating, etc.);
  • (b) a reference to required conformances (e.g., to applicable reference standards respecting the design and manufacture of the item);
  • (c) material requirements at variance with those required by applicable reference standards (e.g., specifications which require a more stringent tolerance than that which is provided by the standard);
  • (d) test requirements at variance with those required by applicable reference standards;
  • (e) any additional requirements based on different types of service;
  • (f) quality control requirements for the vendor or manufacturer;
  • (g) coating requirements (e.g., type, thickness, application processes, test requirements, conformances, etc.);
  • (h) marking requirements at variance with those required by applicable reference standards;
  • (i) shipping requirements; and
  • (j) required documentation.

Quality Assurance Program

15. A company shall develop a quality assurance program for the purpose of ensuring that the pipe and components to be used in the pipeline meet the specifications referred to in section 14.

GOAL (Section 15): Pipe and components meet the specifications developed under section 14.

The purpose of a quality assurance (QA) program for pipe and components is to confirm that materials purchased by the company meet the company's specified requirements. The rigour of the QA program is commensurate with the scale of the order and its intended application. QA programs should be comprised of the elements of a recognized standard, such as the ISO 9000 series of QA standards, and should include:

  • (a) requirements for pipeline company (or their agents) evaluation of the manufacturer's or supplier's quality management system prior to the award of any contract;
  • (b) requirements for company (or their agents) audits and inspection during manufacture and fabrication, shipping, storage, etc.;
  • (c) requirements for random and progressive product testing;
  • (d) inspection procedures and inspector qualifications;
  • (e) requirements for handling and review of documentation;
  • (f) a system for managing non-conformances to specifications; and
  • (g) procedures for company acceptance of products.

Pipeline companies should consider the history of compliance and satisfactory product performance when developing programs aimed at ensuring that products from specified manufacturers or suppliers are acceptable for their intended purpose.

Joining

Joining Program

16. A company shall develop a joining program in respect of the joining of pipe and the components to be used in the pipeline and shall submit it to the Board when required to do so.

GOAL (Section 16): Joining is designed and conducted in a manner that will ensure quality and integrity.

The joining program shall meet the requirements of the applicable standards referred to in section 4 and should include a description of:

  • (a) the joining procedure specifications;
  • (b) the requirements for the qualification of joining procedures;
  • (c) the requirements for the qualification of joiners;
  • (d) the requirements for the qualification and duties of joining inspectors;
  • (e) the number of joining inspectors that will be employed (the number of joining inspectors should be sufficient to visually inspect all welds. This number may fluctuate with daily productivity);
  • (f) the non-destructive examination procedures;
  • (g) the requirements for the qualification of the personnel engaged in non-destructive examination;
  • (h) the standards of acceptability of imperfections;
  • (i) the procedures for the repair or removal of defects associated with or resulting from the joining process; and
  • (j) documentation requirements.

Pertinent sections of the joining program could be:

  • (a) available on site whenever joining is taking place;
  • (b) readily accessible to welders and welding inspection personnel;
  • (c) available within company offices; and
  • (d) maintained as part of the permanent record of the pipeline construction.

The aforementioned guidance pertains primarily to welded steel pipelines. Joining programs are required for all types of materials and joining methods (i.e., mechanical joints, heat fusion, threaded joints, etc.).

Non-destructive Examination

17. When a company conducts joining on a pipeline, the company shall examine the entire circumference of each joint by radiographic or ultrasonic methods.

GOAL (Section 17): The integrity of each welded joint is confirmed.

This section applies only to welded steel joints.

The OPR requires that all pipeline joints be examined non-destructively. This includes butt welds, fillet welds, and branches.

Because the geometry of certain weld types makes inspection by radiography or ultrasonics impractical, the Board issued Order MO-08-2000 on April 28, 2000. A copy of the Order is available on the NEB website at www.neb-one.gc.ca. The Order pertains to all federally regulated pipeline systems, and provides that another appropriate non-destructive examination method may be employed if a radiographic or ultrasonic method is not practicable in the particular circumstances. The Order also requires that companies document the methods used and the inspection results, and also clarifies that the use of a visual method as a means of non-destructive examination is not permitted under the terms of the Order.

Section 17 and Order MO-08-2000 apply only to the joining of pipe and components performed after the manufacturing processes associated with fabrication of the pipe within the pipe mill and the fabrication of components within the manufacturer's facilities. As a matter of clarification, neither section 17 nor Order MO-08-2000 of these regulatory instruments apply to the welded assembly of storage tanks forming part of the pipeline system.

Girth welds performed within pipe mills are not considered to be part of the manufacturing process (within the context of the "joining" definition in section 1 of the OPR), and are therefore subject to the terms of the Order. The Board has issued case-specific exemptions from the 100% non-destructive examination requirement of section 17 and Order MO-08-2000 pursuant to subsections 48(2.1) and 48(2.2) of the NEB Act. These exemptions have been for certain specific auxiliary piping systems associated with stations.

Variations from section 17 and Order MO-08-2000 are permitted only in cases where a project-specific exemption order has been issued by the Board. A request for exemption from the terms of Order MO-08-2000 may include:

  • (a) a description of the specific joints for which an exemption is being sought;
  • (b) the proposed alternatives for quality assurance of completed joints if an exemption is granted;
  • (c) the rationale for seeking an exemption; and
  • (d) a discussion of risk considerations including such factors as location and service fluids.

Construction

Construction Safety

18. (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall

  • (a) inform the contractor of all special conditions associated with the construction;
  • (b) inform the contractor of all special safety practices and procedures necessitated by the conditions or features specific to the construction;
  • (b.1) inform the contractor of the contractor’s responsibilities referred to in paragraph 6.5(1)(l);
  • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and
  • (d) authorize a person to halt a construction activity in circumstances where, in the person's judgement, the construction activity is not being conducted in accordance with the manual developed under section 20 or is creating a hazard to anyone at the construction site.

(2) The person referred to in paragraph (1)(d) must have sufficient expertise, knowledge, and training to competently carry out the obligations set out in that paragraph.

GOAL (Section 18): Construction activities are conducted in a safe manner.

The company and contractor responsibilities for safety and regulatory compliance should be clearly defined at the beginning of a project. A company must instruct contractors in all relevant practices and procedures pertaining to their work prior to commencing construction activities. The company informs contractors about, and contractors should be aware of:

  • (a) the contractor’s responsibilities in relation to the processes and procedures required by the management system provisions in paragraph 6.5(1)(l) of the OPR;
  • (b) the requirements as set out in the construction safety manual;
  • (c) safety reporting requirements;
  • (d) a description of the project specific safety management structure;
  • (e) a listing of pertinent federal and provincial legislation; and
  • (f) project specific hazards as well as safety commitments/requirements.

19. A company shall, during the construction of a pipeline, take all reasonable steps to ensure that

  • (a) the construction activities do not create a hazard to the public or the environment; and
  • (b) all persons at the construction site who are not involved in the construction of the pipeline are informed of the practices and procedures that are to be followed for their safety.

GOAL (Section 19): Pipelines are constructed in a safe and environmentally responsible manner.

By their very nature, construction activities may pose a risk to persons associated with or near the activities as well as to property and the environment.

Everyone at a worksite should be aware of the practices and procedures necessary for their safety as well as the safety of others. At least one person at the worksite should be knowledgeable of potential environmental impacts associated with the construction activity and any appropriate management and mitigation measures.

Paragraph 6.5(1)(q) of the OPR requires a company to have a process for coordinating and controlling the operational activities of employees or contractors so that they are able to work in a manner that is safe, ensures the security of the pipeline, and protects the environment.

20. (1) A company shall develop a construction safety manual and shall submit it to the Board.

(1.1) If a company contracts for the provision of services in respect of the construction of a pipeline, the construction safety manual shall set out the contractor’s responsibilities referred to in paragraph 6.5(1)(l).

(2) A company shall keep a copy of the construction safety manual or the relevant parts of it at each construction site of the pipeline, in a location where it is accessible to every person engaged in construction at the site.

GOAL (Section 20): A comprehensive construction safety manual is developed, kept current, and is readily accessible.

A company’s construction safety manual must contain the relevant information and procedures outlined in the standards referenced in section 4 of the OPR, and should include, but is not limited to, the following:

  • (a) the safety related responsibilities of company and contractor managers, supervisors, and workers;
  • (b) a description of the method or program established by the company to fulfill its responsibilities under sections 18 ands 19;
  • (c) the safety practices and procedures to be followed in the construction of the pipeline;
  • (d) the name(s) or position(s) of the person(s) with suitable qualifications responsible for safety inspections during pipeline construction;
  • (e) the name(s) or position(s) of the person(s) authorized to halt a construction activity under the requirement of paragraphs 18(d);
  • (f) the company’s policy for the internal reporting of hazards, incidents and near misses, and the process for the reporting of such matters; and
  • (g) any other relevant processes and requirements from the company’s management system, safety management program, and other programs, related to construction activities.

Companies are expected to submit their construction safety manual to the Board at least four weeks prior to anticipated start of construction activities. Practices set out in the construction safety manual should meet applicable federal and provincial occupational health and safety requirements.

The contents of the construction safety manual should be shared and understood by all appropriate parties. The company’s environmental protection plan should also be available at the work site and its requirements shared and understood by all appropriate parties.

For additional guidance, companies are referred to the Safety Guide for Pipeline Construction in Canada, issued by the Pipe Line Contractors Association of Canada.

Right-of-way and Temporary Work Areas

21. After a pipeline is constructed, the right-of-way and temporary work areas of the pipeline shall be restored to a condition similar to the surrounding environment and consistent with the current land use.

GOAL (Section 21): Land affected by pipeline construction is restored to pre-construction conditions to the extent practicable.

Restoration to pre-existing conditions may not be practical under all circumstances. For example, rights-of-way through forested areas which have been cleared to provide construction access may have to be kept partially cleared to provide access for emergency and maintenance operations.

The success of restoration efforts should be evaluated by a quantitative and qualitative comparison similar to surrounding undisturbed areas.

Crossing a Utility or Private Roadway

22. When a pipeline is constructed across a utility or private road, the company constructing the pipeline shall ensure that there is no undue interference with the use of the utility or road during construction.

GOAL (Section 22): Minimize and avoid, to the extent practical, any disruption with the use of a utility or road during pipeline construction.

The definition of "utility" is provided at Section 108 of the NEB Act:

  • “utility” means a highway, an irrigation ditch, a publicly owned or operated drainage system, sewer or dike, an underground telegraph or telephone line or a line for the transmission of hydrocarbons, electricity or any other substance.

For additional requirements concerning crossing matters, companies are directed to the National Energy Board Pipeline Damage Prevention Regulations - Authorizations and the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies, and the related NEB guidance document Pipeline Damage Prevention – Ground disturbance, Construction and Vehicle Crossings. See also The Lifecycle of Pipeline Watercourse Crossings in Canada for information on planning for, and installing, pipelines crossing watercourses.

Pressure Testing

Pressure Testing Program

23. Before putting a pipeline into service, a company shall develop a program in respect of pressure tests to be conducted for pipe and components used in its pipeline, and shall submit it to the Board when required to do so.

GOAL (Section 23): An acceptable pressure testing program is developed that, when followed, will assist in proving the integrity of the pipeline.

The pressure testing program must meet the requirements of the applicable standards referred to in section 4 and should include, but is not limited to, the following:

  • (a) a diagram of the test section together with an elevation profile and the location of all measurement points and instrumentation;
  • (b) the specifications of the pipe and components of the pipeline to be tested;
  • (c) a description of the instruments to be used, the degree of accuracy, and the calibration data and certificates of those instruments;
  • (d) the procedures to be used during line filling, pressurization, depressurization, dewatering, and the associated environmental protection procedures to be implemented;
  • (e) an identification of the test medium and any additives;
  • (f) the test duration;
  • (g) the minimum and maximum permitted test pressures;
  • (h) the standards of acceptability;
  • (i) a description of the safety precautions to be implemented during the pressure test;
  • (j) test head assembly pressure testing and non-destructive examination requirements;
  • (k) an assessment of the design compliance of the test heads; and
  • (l) the measures to be taken for the protection of property, the environment and the safety of persons in the event of a rupture during testing.

The standards referred to within section 4 permit the use of various test fluids under specific conditions. Usually, hydrotesting should be performed when pressure testing pipelines. Any proposal to use alternative fluids (such as air) should be based on recognized engineering principles. The sensitivity and reliability of any test using an alternative test fluid should be compared to that of a hydrotest.

Permits for Use and Disposal of Water

24. Before conducting a pressure test, a company shall obtain any permits required in respect of the use and disposal of water for test purposes.

GOAL (Section 24): Hydrostatic test water use and disposal are adequately addressed.

Companies are directed to federal, provincial, and local authorities to determine their specific requirements for water use and disposal. For assistance with developing a plan for water use and disposal when conducting a pressure test, companies are directed to the guidelines for Hydrostatic Test Water Management Guidelines jointly sponsored by the Canadian Association of Petroleum Producers and the Canadian Energy Pipeline Association.

General Testing Requirements

General Testing Requirements

25. (1) Pressure testing shall be performed under the direct supervision of the company or an agent appointed by it.

(2) The agent referred to in subsection (1) shall be independent of any contractor that carries out the pressure testing program or that constructed the pipeline.

(3) The company or agent shall date and sign any logs, test charts and other test records that are referred to in CSA Z276 or CSA Z662, as applicable.

GOAL (Section 25): Pressure testing is conducted objectively.

26. The number of welds in a pipeline that are not subjected to a pressure test following the installation of fabricated assemblies or pipe segments into the pipeline shall be minimized to the extent that is practicable.

GOAL (Section 26): As many girth welds as practicable are subjected to the required pressure test.

Operation and Maintenance

Operation and Maintenance Manuals

27. A company shall develop, regularly review and update as required, operation and maintenance manuals that provide information and procedures to promote safety, environmental protection and efficiency in the operation of the pipeline, and shall submit them to the Board when required to do so.

GOAL (Section 27): Comprehensive operation and maintenance manuals are developed, kept current and are readily accessible.

A company’s operation and maintenance manual must contain the relevant information and procedures outlined in the standards referenced in section 4. A company’s operation and maintenance manual should include, but is not limited to, the following:

  • (a) the elevation profile for pipelines containing liquid hydrocarbons;
  • (b) the operating limits of the pipeline and the method for maintaining these limits under all operating conditions;
  • (c) an accurate and current listing of materials and the associated Material Safety Data Sheets (MSDS) for product(s) transported in the pipeline or associated with the operation and maintenance of the pipeline;
  • (d) the policies and procedures for accident prevention and fire protection;
  • (e) the policies and procedures for response and investigation of incidents and emergencies;
  • (f) the safety related responsibilities of company and contractor managers, supervisors, and workers;
  • (g) operator duties and responsibilities (e.g., shift change, visual checks, coordination with gas controller, tasks list);
  • (h) personal protective equipment (PPE) requirements;
  • (i) management of change process and procedures;
  • (j) procedures for failure analyses and investigations;
  • (k) procedures for repairs and maintenance activities including precautions to be taken in the event of product release during these activities;
  • (l) practices and guidance on communications with media and the public;
  • (m) environmental and safety implications of the release of product or chemicals referred to in (c);
  • (n) the company’s policy for the internal reporting of hazards, incidents and near misses, and the process for the reporting of such matters; and
  • (o) any other relevant processes from the company’s management system, safety management program, and other programs, related to operations and maintenance activities.

28. A company shall inform all persons associated with operation activities on the pipeline of the practices and procedures to be followed and make available to them the relevant portions of the operation and maintenance manuals.

GOAL (Section 28): Persons associated with operation activities are aware of all operations practices and procedures and aware of applicable information contained in the operations and maintenance manuals.

It is the company’s responsibility to inform those who are associated with operations and maintenance activities on the pipeline of the applicable information contained in the operations and maintenance manuals. Paragraph 6.5(1)(m) of the OPR requires companies to implement a process for internal and external communication of information relating to safety, security and protection of the environment.

Maintenance Safety

29. (1) If a company contracts for the provision of services in respect of the maintenance of a pipeline, the company shall:

  • (a) inform the contractor of all special conditions associated with the maintenance;
  • (b) inform the contractor of all special safety practices and procedures necessitated by the conditions or features specific to the maintenance;
  • (b.1) inform the contractor of the contractor’s responsibilities referred to in paragraph 6.5(1)(l);
  • (c) take all reasonable steps to ensure that maintenance activities are conducted in accordance with the manual developed under section 31; and
  • (d) authorize a person to halt a maintenance activity in circumstances where, in the person's judgement, the maintenance activity is not being conducted in accordance with the manual developed under section 31 or is creating a hazard to anyone at the maintenance site.

(2) The person referred to in paragraph (1)(d) must have sufficient expertise, knowledge, and training to competently carry out the obligations set out in that paragraph.

GOAL (Section 29): Maintenance activities are conducted in a safe manner.

The company and contractor’s responsibilities for safety and regulatory compliance should be clearly defined and communicated. A company must instruct contractors in all relevant practices and procedures pertaining to their work prior to commencing maintenance activities. The company informs contractors about, and contractors should be aware of:

  • (a) the contractor’s responsibilities in relation to the processes and procedures required by the management system provisions in paragraph 6.5(1)(l) of the OPR;
  • (b) the requirements as set out in the maintenance safety manual;
  • (c) safety reporting requirements;
  • (d) a description of the project specific safety management structure;
  • (e) listing of pertinent federal and provincial legislation; and
  • (f) maintenance specific hazards as well as safety commitments/requirements.

30. A company shall, during the maintenance of a pipeline, take all reasonable steps so that

  • (a) the maintenance activities do not create a hazard to the public or the environment; and
  • (b) all persons at the maintenance site who are not involved in the maintenance of the pipeline are informed of the practices and procedures that are to be followed for their safety or for the protection of the environment.

GOAL (Section 30): The public and the environment are protected during maintenance activities.

By their very nature, maintenance activities may pose a risk to persons associated with or near the activities, as well as to property and the environment.

Everyone at a worksite should be aware of the practices and procedures necessary for their safety as well as the safety of others. At least one person at the worksite should be knowledgeable of potential environmental impacts associated with the maintenance activity and any appropriate management and mitigation measures.

Paragraph 6.5(1)(q) of the OPR requires that a company has a process for coordinating and controlling the operational activities of employees or contractors so that they are able to work in a manner necessary for safety, security of the pipeline and protection of the environment.

31. (1) A company shall develop a maintenance safety manual and shall submit it to the Board when required to do so.

(1.1) If a company contracts for the provision of services in respect of the maintenance of a pipeline, the maintenance safety manual shall set out the contractor’s responsibilities referred to in paragraph 6.5(1)(l).

(2) The company shall keep a copy of the maintenance safety manual or the relevant parts of it at each maintenance site of the pipeline, in a location where it is accessible to every person engaged in maintenance at the site.

GOAL (Section 31): Specific safety procedures are in place and are made available to all applicable personnel.

A maintenance safety manual contains specific safety procedures and is available to all applicable personnel. The company documentation should include, but is not limited to:

  • (a) the safety related responsibilities of company and contractor managers, supervisors, and workers;
  • (b) the safety practices and procedures to be followed in the maintenance of the pipeline;
  • (c) the name(s) or position(s) of the person(s) with suitable qualifications responsible for safety inspections during pipeline maintenance activities where applicable;
  • (d) the company’s policy for the internal reporting of hazards, incidents and near misses, and the process for the reporting of such matters; and
  • (e) any other relevant processes and requirements from the company’s management system, safety management program, and other programs, related to maintenance activities.

Emergency Management Program

32. (1) A company shall develop, implement and maintain an emergency management program that anticipates, prevents, manages and mitigates conditions during an emergency that could adversely affect property, the environment or the safety of workers or the public.

(1.1) The company shall develop an emergency procedures manual, review it regularly and update it as required.

(2) A company shall submit the emergency procedures manual and updates that are made to it to the Board.

GOAL (Section 32): Management of, and response to, emergencies is achieved through the development, implementation and maintenance of a systematic emergency management program.

An emergency management program manages and mitigates the risks and effects of incidents and emergencies that could adversely affect property, the environment or the safety of workers or the public.

An emergency management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the emergency management program. In order for an emergency management program to be systematic, comprehensive, explicit, and proactive, it must include the management system processes referenced at section 6.5 of the OPR. This includes processes to identify hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the emergency management program, and the company’s programs for safety, security, integrity and environmental protection.

The emergency management program must meet the requirements of section 4 of the OPR. A company’s emergency management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the emergency management program, with a maximum interval of three years.

Further information on an emergency management program, including hazard assessment, the emergency procedures manual, agency liaison, communications, continuing education, emergency response processes and capability, emergency response exercises and equipment is provided in Annex A.

Emergency Procedures Manual

A company’s emergency management program includes an up-to-date emergency procedures manual that is filed with the Board. An emergency procedures manual includes roles and responsibilities in the event of an emergency, response procedures, contact lists and relevant documentation including contact lists, maps, agreements, and forms and records.

Further information on the emergency procedures manual is provided in section 2 of Annex A.

33. A company shall establish and maintain liaison with the agencies that may be involved in an emergency response on the pipeline and shall consult with them in developing and updating the emergency procedures manual.

GOAL (Section 33): All applicable agencies are aware of the contents of the Emergency Procedures Manual.

A company’s emergency management program includes liaison with all agencies that may be involved in an emergency situation. A company should identify the parties with whom liaison is required, develop a consultation process, and incorporate the results of consultation into its emergency management planning and emergency procedures manual.

Further information on agency liaison is provided in section 3 of Annex A.

34. A company shall take all reasonable steps to inform all persons who may be associated with an emergency response activity on the pipeline of the practices and procedures to be followed and make available to them the relevant information that is consistent with that which is specified in the emergency procedures manual.

GOAL (Section 34): All applicable parties are prepared to respond to emergency situations.

A company’s emergency management program includes communicating relevant practices and procedures to all persons who may be associated with an emergency response activity.

Further information on communications for emergency response is provided in section 4 of Annex A.

35. A company shall develop a continuing educational program for the police, fire departments, medical facilities, other appropriate organizations and agencies and the public residing adjacent to the pipeline to inform them of the location of the pipeline, potential emergency situations involving the pipeline and the safety procedures to be followed in the case of an emergency.

GOAL (Section 35): All appropriate parties are aware of the potential emergency situations and their specific roles and responsibilities.

A company’s emergency management program includes continuing education for the police, fire departments, medical facilities, all appropriate agencies, organizations and the public adjacent to their pipeline. A company should inform these parties of the:

  • location of the facilities;
  • potential emergency situations (e.g., hazards); and
  • procedures to be followed in the case of an emergency (e.g., methods and timing of communication during an emergency, circumstances and procedures for sheltering and evacuation).

Further information on continuing education for emergency response is provided in section 5 of Annex A.

General Operation Requirements

36. A company shall

  • (a) maintain communication facilities for the safe and efficient operation of the pipeline and for emergency situations;
  • (b) periodically test instruments and equipment at the pipeline stations to verify their proper and safe operation;
  • (c) continually record the suction and discharge pressures of the pipeline pump and compressor stations;
  • (d) clearly mark the open and closed positions of sectionalizing valves on any main line;
  • (e) clearly mark the open and closed positions and the function of isolating valves, blow-down valves, and other major valves within a pipeline station; and
  • (f) post along the boundaries of the pipeline stations signage indicating the name of the company and the telephone number to call in the event of an emergency involving the pipeline.

GOAL (Section 36): Safe operation of facilities on the pipeline.

Pipeline Control System

37. A company shall develop and implement a pipeline control system that

  • (a) comprises the facilities and procedures used to control and monitor the operation of the pipeline;
  • (b) records historical pipeline operation data, messages and alarms for recall; and
  • (c) includes a leak detection system that, for oil pipelines, meets the requirements of CSA Z662 and reflects the level of complexity of the pipeline, the pipeline operation and the products transported.

GOAL (Section 37): Pipeline operating parameters are being adequately monitored.

Maintenance Welding

38. (1) A company shall not perform welding on a liquid-filled pipeline with a carbon equivalent of 0.50% or greater, except if it has been demonstrated that no other practical alternative is available.

(2) If a company performs welding referred to in subsection (1), the company shall treat the weld as a temporary installation and replace that installation with a permanent one as soon as is practicable.

(3) Despite subsections (1) and (2) and section 16, if a company intends to perform welding on a liquid-filled pipeline with a carbon equivalent of 0.50% or greater and to treat it as a permanent installation, the company shall submit the welding specifications and procedures and the results of the procedure qualification tests to the Board for approval.

GOAL (Section 38): Appropriate welding procedures are employed which prevent cold cracking in steels with high carbon equivalents.

The potential for delayed hydrogen cracking increases proportionally with the carbon equivalent of the base materials to be joined. This effect may be compounded by the quenching effects of flowing liquids within the pipeline on weld deposits placed on the surface of in-service pipelines. Weld hardness is typically used as one indicator of susceptibility of a weld to cracking.

Companies should refer to CSA Z662 for additional information on the development of welding procedures and the qualification of welders for in-service welding on liquids (and gas) pipelines.

Surveillance and Monitoring

39. A company shall develop a surveillance and monitoring program for the protection of the pipeline, the public and the environment.

GOAL (Section 39): Protection of the pipeline, the public, and the environment is achieved during the operation of the pipeline through the development and implementation of a systematic surveillance and monitoring program.

The surveillance and monitoring program must meet the requirements of sections 40 and 48 and the applicable standards referred to in section 4.

For the purposes of this section, monitoring is defined as ongoing observations made on a regular basis to confirm that pipeline operation is within defined normal parameters. Surveillance may be defined as an aspect of monitoring, focused on certain parameters during periods of activity (construction, operation, and abandonment).

A monitoring program is aimed at the identification of any issues or potential concerns that may compromise the protection of the pipeline, property, persons and the environment (e.g., pipeline integrity or erosion, security, etc.). It includes methods for developing measures to prevent or mitigate the impact of the identified issue(s). The program also provides for follow-up monitoring of sites where mitigative measures have been undertaken to determine their success or failure, a system for implementing additional mitigative measures as necessary and a feedback system that allows for adaptation of successful mitigation to future pipeline projects.

Surveillance is a component of the monitoring program that focuses on the frequency and methods of surveillance of the pipeline. This includes ensuring employees use approved safety procedures, contractors are adhering to the environmental requirements of a task, encroachments upon rights-of-way are detected, construction activities are known, etc.).

Surveillance and monitoring programs should include, but are not limited to, the following:

  • (a) aerial and terrestrial patrols;
  • (b) pipeline pigging;
  • (c) soil-to-pipe surveys;
  • (d) crossing inspections;
  • (e) construction and operation inspections;
  • (f) pressure testing;
  • (g) purchased material inspections;
  • (h) class location surveys;
  • (i) erosion monitoring;
  • (j) slope stability monitoring;
  • (k) health or occupational exposure monitoring; and
  • (l) relevant environmental practices, such as those for the management of:
    • (i) materials storage and waste;
    • (ii) vegetation;
    • (iii) soil quality;
    • (iv) air quality;
    • (v) noise;
    • (vi) wildlife and wildlife habitat;
    • (vii) water quality and aquatic resources; and
    • (viii) heritage resources (including traditional land use).

Monitoring programs should have specific goals and targets and could include methods for the evaluation and interpretation of collected data.

Integrity Management Program

40. A company shall develop, implement and maintain an integrity management program that anticipates, prevents, manages and mitigates conditions that could adversely affect safety or the environment during the design, construction, operation, maintenance or abandonment of a pipeline.

GOAL (Section 40): Pipeline integrity is achieved through the development, implementation and maintenance of a systematic integrity management program.

A company’s integrity management program is designed to identify hazards and manage risks so that pipelines are suitable for continued safe, reliable and environmentally responsible service. Key features of company’s integrity management program that provide for this outcome include hazard and consequence identification, evaluation and continuous monitoring, mitigation and record keeping related to the location and functioning of the pipeline.

An integrity management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the integrity management program. In order for an integrity management program to be systematic, comprehensive, explicit, and proactive, it must include the management system processes referenced at section 6.5 of the OPR. This includes processes to identify hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the integrity management program, and the company’s programs for safety, security, environmental protection, and emergency management.

The integrity management program must meet the requirements of section 4 of the OPR. A company’s integrity management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the integrity management program, with a maximum interval of three years.

Further information for integrity management programs is provided in Annex B.

41. (1) If a company finds a level of defect in excess of that allowed by CSA Z662 on its pipeline, the company shall document the particulars of the defect, its likely cause and the corrective action taken or planned to be taken.

(2) A company shall submit the documentation referred to in subsection (1) to the Board when required to do so.

GOAL (Section 41): Pipeline defects and corrective actions are adequately documented.

Records for defect repairs should include:

  • (a) date, time, and location at which the defect was detected;
  • (b) type of defect;
  • (c) method by which the defect was detected;
  • (d) defect assessment methods;
  • (e) defect repair methods and rationale; and
  • (f) date, time, and location of the repair.

In evaluating any defect, consideration should be given to the mechanism or nature of the defect and the possibility of its recurrence under similar conditions. Manufacturing defects may be systemic.

Change in Class Location

42. If the class location of a section of a pipeline changes to a higher designation that has a more stringent location factor, the company shall, within six months after the change, submit the proposed plan to deal with the change to the Board.

GOAL (Section 42): Public safety is maintained as class location factors increase.

The plan should:

  • (a) identify what changes in circumstances have occurred;
  • (b) identify potential concerns resulting from the change in circumstances; and
  • (c) describe the mitigative actions where applicable, to address potential concerns.

See the NEB’s Filing Manual for submission requirements concerning this section of the OPR.

Change of Service or Increase in Maximum Operating Pressure

43. If a company proposes a change of service or an increase in the maximum operating pressure for the pipeline, the company shall submit an application for the change or increase to the Board.

GOAL (Section 43): Adequate levels of safety are maintained for any change of service or increase in Maximum Operating Pressure.

A change of service occurs when the fluids being transported by the pipeline are changed. CSA Z662 defines "service fluid" as "the fluid contained, for the purposes of transportation, in an in-service pipeline system".

A change in pressure of the pipeline contents below maximum operating pressure may not constitute a change in service. However, if there are pressure restrictions (voluntary or Board imposed) in place, or a company intends to increase the operating pressure of a pipeline that has historically operated well below its maximum operating pressure, then the Board should be consulted to determine if an application is required. The Board should also be consulted for a change in flow direction and any associated changes involving equipment or facilities.

Any application for a change in service or change in maximum operating pressure must meet the minimum requirements as set out in CSA Z662. See the NEB’s Filing Manual for application requirements concerning this section of the OPR.

Deactivation and Reactivation

44. (1) If a company proposes to deactivate a pipeline or part of one for 12 months or more, has maintained a pipeline or part of one in a deactivated mode for 12 months or more or has not operated a pipeline or part of one for 12 months or more, the company shall submit an application for deactivation to the Board.

(2) The company shall include in the application the reasons, and the procedures that were or are to be used, for the activity that is the subject of the application.

GOAL (Section 44): Deactivation of a pipeline is carried out in a safe and environmentally responsible manner.

Deactivation is defined in section 1 of the OPR as meaning "to remove temporarily from service". The definition of "pipeline" in the NEB Act applies to the OPR and therefore this section applies to portions of the pipeline other than line pipe that are not being maintained for peak flow, standby (ready for immediate use), or emergency use. In practice, it is accepted that portions of pipeline, though maintained in a deactivated state, may never be returned to service, or may be maintained in a deactivated state for an unspecified length of time. Cathodic protection continues to be required for a deactivated pipeline. This status may ultimately be addressed in an application to abandon the operations of the pipeline.

Deactivation may impose a higher level of risk to the integrity of the pipeline depending on the measures specified for the maintenance of the deactivated pipe.

Deactivation of pipelines may impact upstream and downstream users of the pipeline. A company proposing deactivations could consider using a consultative approach with stakeholders similar to that which is used for applications made pursuant to section 58 of the NEB Act.

Applications for deactivation pursuant to section 44 should include:

  • (a) a schedule outlining when the deactivation is planned for completion;
  • (b) a complete description of the activities associated with the deactivation; and
  • (c) an estimate of the costs associated with the proposed deactivation.

Approvals of applications for deactivation may be subject to conditions and will normally include a requirement for periodic status reporting.

If deactivation results in a suspension of service, an application pursuant to either section 71 or 72 of the NEB Act may also be required. See the NEB’s Filing Manual for application requirements concerning this section of the OPR.

45.(1) If a company proposes to reactivate a pipeline or part of one that has been deactivated for 12 months or more, the company shall submit an application for the reactivation to the Board.

(2) The company shall include in the application the reasons, and the procedures that are to be used, for the reactivation.

GOAL (Section 45): Reactivation of a pipeline is carried out in a safe and environmentally responsible manner.

The contents of the Guidance Note for section 44 should also be applied to applications pursuant to section 45. See the NEB’s Filing Manual for application requirements concerning this section of the OPR.

Decommissioning

45.1 (1) If a company proposes to decommission a pipeline or part of one, the company shall submit an application for the decommissioning to the Board.

(2) The company shall include in the application the reasons, and the procedures that are to be used, for the decommissioning.

GOAL (Section 45.1): Decommissioning of a pipeline is carried out in a safe and environmentally responsible manner.

Decommissioning is defined in section 1 of the OPR as meaning "to permanently cease operation such that the cessation does not result in the discontinuance of service". For guidance on decommissioning, see the NEB’s Guidance Notes for Decommissioning Provisions. See the NEB’s Filing Manual for application requirements concerning this section of the OPR.

Training Program

46. (1) A company shall develop and implement a training program for any employee of the company who is directly involved in the operation of the pipeline.

(2) The training program shall instruct the employee on

  • (a) the safety regulations and procedures applicable to the day-to-day operation of the pipeline;
  • (a.1) the security processes, procedures and measures applicable to the day-to-day operation of the pipeline;
  • (b) responsible environmental practices and procedures in the day-to-day operations of the pipeline;
  • (c) the procedures for the proper operation of the equipment that the employee could reasonably be expected to use; and
  • (d) the emergency procedures set out in the manual developed under section 32 and the procedures for the operation of all emergency equipment that the employee could reasonably be expected to use.

(3) The company shall use reasonable efforts to ensure that any employee who attends a training program has a working knowledge of the subject-matter of the program at the end of the program.

GOAL (Section 46): Employees are trained in the applicable safety and operating procedures required to conduct their duties.

The training program for day-to-day operations should include the following:

  • (a) the general objectives of the training program;
  • (b) the policies and procedures of the training program;
  • (c) the types and format of training;
  • (d) a description of the testing methods and practical (mock, simulated or table-top) exercises, and their frequency; and
  • (e) a means of ensuring the effectiveness of the training.

The training program for day-to-day operations is part of the company’s training process as required in paragraphs 6.5(1)(j) and (k) of the OPR.

Training programs are directed toward the construction and operation of pipelines in a safe and effective manner and include provision for the safety of persons and the protection of property and the environment.

Safety Management Program

47. A company shall develop, implement and maintain a safety management program that anticipates, prevents, manages and mitigates potentially dangerous conditions and exposure to those conditions during all activities relating to construction, operation, maintenance, abandonment and emergency situations.

GOAL (Section 47): Safety is achieved through the development, implementation and maintenance of a systematic safety management program.

Safety management is an organizational function that strives to continually identify hazards and to assess and manage associated safety risks through a systematic approach that includes the necessary organizational structure, accountabilities, policies, and procedures, measures and monitoring, and continual improvement efforts. A safety management program identifies hazards and risks associated with operational activities in order for an organization to proactively reduce or eliminate unsafe conditions and activities by improving the related organizational influences such as the prescribed resources, processes, procedures and controls. Safety management programs are designed to address systemic safety vulnerabilities before they result in an active failure. They are also designed to capture changing conditions that introduce new hazards and risks.

A safety management program is focused on all hazards that have the potential to cause harm to the public, workers, and contractors. Safety management is designed to eliminate or reduce risk to the public, workers, the environment and assets. For this reason, there is a strong relationship between safety management and organizational programs related to security, emergency management and integrity.

A safety management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the safety management program. In order for a safety management program to be systematic, comprehensive, explicit, and proactive, it must include the management system processes referenced at section 6.5 of the OPR. This includes processes to identify hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the safety management program, and the company’s programs for security, integrity, environmental protection, and emergency management.

For additional requirements concerning damage prevention for facilities, companies are directed to the National Energy Board Pipeline Damage Prevention Regulations - Authorizations and the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies, and the related NEB guidance document Pipeline Damage Prevention – Ground Disturbance, Construction and Vehicle Crossing.

The safety management program must meet the requirements of section 4 of the OPR. The NEB is also responsible for verifying compliance with and enforcing Part II of the Canada Labour Code, which applies to the occupational safety and health of pipeline workers. A company’s safety management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the safety management program, with a maximum interval of three years.

Security Management Program

47.1 A company shall develop, implement and maintain a security program that anticipates, prevents, manages and mitigates conditions that could adversely affect people, property or the environment.

GOAL (Section 47.1): Pipeline security is achieved through the development, implementation and maintenance of a systematic security management program.

A company’s security management program is designed to identify hazards so that the risk of the facility or facilities is adequately and appropriately addressed and that the facility or facilities are being protected. When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company must ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of CSA Z246.1.

CSA Z246.1 provides a framework to protect energy infrastructure from malicious damage through risk-based and performance-based management processes. A company’s security management program is based on factors such as type, size, location and criticality of the assets being protected. A company makes decisions based on their internal assessment of risk related to their facility. CSA Z246.1 was developed to be scalable, enabling it to be used by both small operators and large companies.

A security management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the security management program. In order for a security management program to be systematic, comprehensive, explicit and proactive, it must include the management system elements referenced at section 6.5 of the OPR. This includes processes to identify hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the security management program, and the company’s programs for safety, integrity, environmental protection, and emergency management.

The security management program must meet the requirements of section 4 of the OPR. A company’s security management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the security management program, with a maximum interval of three years.

Further information for companies on pipeline security can be found on the NEB website (www.neb-one.gc.ca), under Security / Pipeline Security Management.

Damage Prevention Program

47.2 A company shall develop, implement and maintain a damage prevention program that anticipates, prevents, manages and mitigates damage to its pipeline and meets the requirements set out in section 16 of the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

GOAL (Section 47.2): Safety of people and protection of the environment is achieved through the development, implementation and maintenance of a systematic damage prevention program.

A company must proactively identify hazards and manage the related risks for its pipelines that may be introduced by ground disturbance activities, the construction of facilities near its pipelines, and vehicle crossings over its pipelines.

A company’s damage prevention program is developed to anticipate, prevent, and mitigate conditions that have the potential to adversely affect the safety of people who live and work around federally regulated facilities, thereby managing safety, security and environmental risks throughout the lifecycle of the pipeline.

A company’s damage prevention program must be based on the requirements found in both the OPR and the framework contained in the National Energy Board Pipeline Damage Prevention Regulations – Authorizations and the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

As part of its damage prevention program, a company is required to: have a public awareness program; monitor land use and land ownership changes near its pipeline(s); have processes for timely responses to locate requests and for managing requests for consent under the National Energy Board Pipeline Damage Prevention Regulations – Authorizations; and have standards for locating pipes. For details related to the damage prevention program requirements, see section 16 of the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

A company’s damage prevention program is based on the relevant policies and goals set by the company as required by sections 6.3 and 6.5 of OPR.

A company’s management system specifically applies to the damage prevention program. For a damage prevention program to be systematic, comprehensive, explicit and proactive, it must include the management system elements referenced at section 6.5 of the OPR. This includes processes to identify and analyze hazards, evaluate and manage risks, train and manage workers, communicate with those who live and work around the pipeline, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the damage prevention program, and the company’s programs for safety, environmental protection, security, integrity and emergency management.

Companies are encouraged to examine each section of the OPR for applicability to their damage prevention programs. Note that a company’s damage prevention program will also consider and integrate many other aspects of the OPR, such as those addressed in sections 18, 21, 22, 27, 29, 32 – 35, 39, 42, 46, and 54.

Damage prevention programs are closely tied to the emergency management requirements in the OPR. Specifically, sections 32 through 35 of the OPR contain requirements for pipeline companies with respect to an emergency management program, emergency preparedness and response, continuing education and liaison, and section 39 contains monitoring and surveillance requirements. These requirements should form part of a company’s damage prevention program.

The damage prevention program must meet the requirements of section 4 of the OPR. A company’s damage prevention program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the damage prevention program, with a maximum interval of three years.

Environmental Protection Program

48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

GOAL (Section 48): Protection of the environment is achieved through the development, implementation and maintenance of a systematic environmental protection program.

A company proactively manages environmental hazards and effects and systematically tracks its environmental performance through its environmental protection program. Program components are developed to anticipate, prevent, and mitigate conditions that have the potential to adversely affect the environment, thereby managing environmental risk throughout the lifecycle of the pipeline.

A company’s environmental protection program is based on the relevant policies and goals set by the company.

A company’s management system applies to the environmental protection program. For an environmental protection program to be systematic, comprehensive, explicit and proactive, it must include the management system elements referenced at section 6.5 of the OPR. This includes processes to identify hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the environmental protection program, and the company’s programs for safety, security, integrity and emergency management.

The environmental protection program must meet the requirements of section 4 of the OPR. A company’s environmental protection program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the environmental protection program, with a maximum interval of three years.

Note that an environmental protection program will also consider and integrate many other aspects of the OPR, such as those addressed in sections 21, 24, 27, 39, 46, and 54.

Board Authority

49. When the protection of property and the environment and the safety of the public and the company's employees warrant it, the Board may direct a company to test, inspect or assess a pipeline in accordance with CSA standards or any other comparable standards.

GOAL (Section 49): Describe the Board’s authority to require pipeline assessments in order to confirm that pipelines are operated and maintained in a safe and environmentally responsible manner.

Abandonment

Application for Leave to Abandon

50. A company shall include in an application made under section 74 of the Act for leave to abandon a pipeline or part of one the reasons, and the procedures that are to be used, for the abandonment.

GOAL (Section 50): Abandonment of pipelines is done in a safe, efficient and environmentally responsible manner.

"Abandon" is defined in section 1 of the OPR as meaning "to permanently cease operation such that the cessation results in the discontinuance of service". Pursuant to section 74 of the NEB Act, an application is required when a company is seeking leave from the Board to abandon the operation of a pipeline. An application for abandonment of a pipeline requires a public hearing.

Facility owners and operators are responsible for the retirement of facilities and reclamation of the right of way as well as any liabilities arising from those facilities post-retirement. See the NEB’s Principles for the End State of Land Post-Retirement and Next Steps [Filing A22297] and Regulating Pipeline Abandonment when planning for abandonment of a facility.

The NEB’s process for abandonment includes the company’s abandonment plan, which addresses all safety and environmental matters. The process also includes the company’s consultation for obtaining stakeholder input, including landowners, occupants, land managers, lessees, municipal agencies and upstream and downstream users.

See the NEB’s Filing Manual for application requirements concerning this section of the OPR.

For additional information, refer to the following NEB documents:

Reporting

Crossing Reports

51. If a company constructs a pipeline that crosses a utility or private road, the company shall

  • (a) immediately notify the Board of the details of unplanned interruption in the operation of the utility or any unplanned closure of the road if the interruption or closure results from the construction of the crossing; and
  • (b) on request, submit a crossing report to the Board that sets out
    • (i) the description and location of the utility or road, and
    • (ii) the name of the authority having control over the utility or the name of the owner of the road.

GOAL (Section 51): The Board is aware of potential or actual effects associated with a pipeline crossing a utility or a private road.

A company must notify the Board of the details of unplanned interruption of a utility or private road during pipeline construction. In addition to the requirements of section 51, companies should be aware of the contents of the National Energy Board Pipeline Damage Prevention Regulations - Authorizations and the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

The Board has published a document entitled Pipeline Damage Prevention – Ground disturbance, Construction and Vehicle Crossings, which provides guidance for the understanding of and compliance with the National Energy Board Pipeline Damage Prevention Regulations - Authorizations and the National Energy Board Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

Incident Reports

52. (1) A company shall immediately notify the Board of any incident relating to the construction, operation or abandonment of its pipeline and shall submit a preliminary and detailed incident report to the Board as soon as is practicable.

(2) After notification of an incident, an inspection officer may partially or completely relieve a company from the requirement to submit a preliminary and detailed incident report.

GOAL (Section 52): Companies provide timely and factual reporting of all incidents.

The Board has developed a web-based Online Event Reporting System (OERS) that regulated companies are required to use to report events under the regulations administered by the Board. The OERS guides the reporter through the reporting process, and asks for all of the required information. The report is done in two stages – the preliminary report which should be submitted immediately and contains the basic information regarding the event, and the final report which provides more fulsome information surrounding the event or incident.

Audits and Inspections

General Compliance

53. (1) A company shall conduct inspections on a regular basis and audits, with a maximum interval of three years, to ensure that its pipeline is designed, constructed, operated and abandoned in compliance with

  • (a) Part III of the Act;
  • (b) Part V of the Act, as it relates to the protection of property and the environment and the safety and security of the public and of the company's employees;
  • (c) these Regulations; and
  • (d) the terms and conditions of any certificate or order issued by the Board, as they relate to the protection of property and the environment and the safety of the public and of the company's employees.

(2) The audit shall document

  • (a) all non-compliance noted; and
  • (b) any corrective actions taken or planned to be taken.

GOAL (Section 53): Companies implement effective inspection and audit processes to continually improve their management system and programs, and to ensure regulatory compliance.

Audits

A company must have a documented process for conducting audits of their programs and systems.

The responsibility for managing audits should be assigned to qualified individuals with a knowledge of audit principles and techniques and management skills relevant to the activities being audited.

Audits are conducted with a maximum interval of three years to verify compliance with internal programs and systems, and compliance with regulatory requirements. Audits should include any aspect of the pipeline lifecycle (design, construction, operations, abandonment) that is occurring at the time of the audit. For additional audit requirements, see section 55.

An audit report is required that documents findings and recommendations. The audit report and audit records must be maintained as per section 56 and should be available to NEB auditors upon request.

Audits should be carried out by company employees or third parties provided they are independent of the activities being audited.

A company must have a process for conducting audits as part of its quality assurance program (paragraph 6.5(1)(w) of the OPR). The audit process should include, but is not limited to, the following:

  • (a) activities and areas to be covered in audits (scope and objectives);
  • (b) frequency of audits;
  • (c) responsibilities associated with managing and conducting audits;
  • (d) communication plan for audit results;
  • (e) auditor competency requirements;
  • (f) audit procedures;
  • (g) how corrective actions and follow up will be undertaken;
  • (h) records and reporting requirements; and
  • (i) management review.

Inspections

Paragraph 6.5(1)(u) of the OPR requires that a company has a process for conducting inspections and monitoring the company’s activities to evaluate the adequacy and effectiveness of its programs, and for taking corrective and preventive actions if deficiencies are identified. The inspection process should include, but is not limited to, the following:

  • (a) documented procedures for conducting inspections during the construction and operation of the pipeline (including the number and type of inspectors, reporting requirements, etc.);
  • (b) documentation outlining the roles, responsibilities, qualifications, duties and tasks of inspectors; and
  • (c) documented schedules for post construction inspections and or regular monitoring and surveillance program as per section 39.

The inspector must be independent of the contractor and must have the authority to shut work down pursuant to paragraph 18(1)(d).

Construction Inspection

54.(1) When a company constructs a pipeline, the company or an agent independent of any construction contractor retained by the company shall inspect the construction to ensure that it meets the requirements of these Regulations and complies with the terms and conditions of any certificate or order issued by the Board.

(2) An inspection shall be performed by a person who has sufficient expertise, knowledge and training to competently carry out the inspection.

GOAL (Section 54): Qualified inspectors are employed to monitor construction activities.

Inspection is defined as the surveillance and assessment of compliance of activities associated with the construction of a pipeline. Qualified inspectors must be employed to monitor construction activities. Typical inspection activities include:

  • (a) construction activity inspection;
  • (b) welding inspection;
  • (c) environmental inspection; and
  • (d) safety inspection.

Typically, non-destructive examination (NDE) is performed by an independent contractor retained by the company. Often, the company will perform an additional level of inspection by subjecting the results of NDE to a random audit performed by qualified persons. In cases where the contractor performing NDE has been retained by the construction contractor, the company must provide independent inspection of NDE results.

Program Audits

55. (1) A company shall conduct audits, with a maximum interval of three years, of the following programs:

  • (a) the emergency management program referred to in section 32;
  • (b) the integrity management program referred to in section 40, including the pipeline control system referred to in section 37;
  • (c) the safety management program referred to in section 47;
  • (d) the security program referred to in section 47.1;
  • (e) the environmental protection program referred to in section 48; and
  • (f) the damage prevention program referred to in section 47.2.

(2) The documents prepared following the audit shall include

  • (a) any deficiencies noted; and
  • (b) any corrective action taken or planned to be taken.

GOAL (Section 55): Companies conduct audits for key programs with a maximum audit cycle of three years.

Although audits can be designed to be all-encompassing, the following key programs must be addressed in a company’s audit or audits:

  • Emergency management program
  • Integrity management program
  • Safety management program
  • Security management program
  • Environmental protection program
  • Damage prevention program

A company’s audit or audits of these programs must be conducted with a maximum audit cycle of three years.

In accordance with a company’s management system, documents prepared following the audit shall include any deficiencies noted and any corrective action taken or planned to be taken.

Record Retention

Requirements

56. A company shall, in addition to complying with the record retention requirements set out in the CSA standards referred to in section 4, retain

  • (a) until at least one month after the date on which they were recorded, the records made under paragraphs 36(c) and 37(b) except for leak detection data, which shall be retained for six months;
  • (b) an annual report on the training program developed under section 46 that compares the actual training received by employees to the planned training;
  • (c) for at least one year after a pipeline or part of one is placed into service, any information with respect to the quality assurance program developed under section 15;
  • (d) for the most recent five years of operation or for the period covered by the two most recent complete audits, whichever period is longer, the records for the audits and inspections required by sections 53 to 55;
  • (e) for as long as the installations referred to in section 38 remain on the pipeline, detailed records of those installations, including
    • (i) the location of the installation,
    • (ii) the type of installation,
    • (iii) the date of installation,
    • (iv) the welding procedure used,
    • (v) the carbon equivalent of the pipeline,
    • (vi) the results of the non-destructive testing performed on the installation, and
    • (vii) the planned date of removal of the installation;
  • (f) accurate records of the location of all buried facilities, until they are removed; and
  • (g) for at least two years after the operation of a pipeline or part of one has been duly abandoned in accordance with all applicable requirements
    • (i) all records available to the company in respect of the procedures used in each stage of the construction of the pipeline or part,
    • (ii) the production reports and mill certificates,
    • (iii) the specifications and name-plate data, if any, of the pumps, compressors, drivers, storage tanks and other major equipment of the pipeline,
    • (iv) the performance curves of all main line pumps and compressors of the pipeline,
    • (v) the reports of all surveillance and monitoring programs developed under section 39,
    • (vi) the documentation referred to in section 41 in respect of pipeline defects, and
    • (vii) the documentation on all incidents reported under section 52.

GOAL (Section 56): Appropriate records are maintained.

Paragraph 6.5(1)(p) of the OPR requires that a company has a process for managing its records. The related record management system should outline what, when, and how appropriate records are to be created, stored, retrieved, modified, and removed (when no longer valid) in a timely manner. Companies are to maintain other appropriate records at pertinent locations to capture relevant reviews, analyses, and decisions made during the implementation of company programs.

A record management system should provide sufficient documentation to demonstrate a company’s due diligence as well as the adequacy and effectiveness of its programs in ensuring the safety of persons, security of the pipeline, and the protection of property and the environment during the design, construction, operation, and abandonment of its pipelines.

ANNEXES

Annex A. Further Information for Emergency Management Program

Annex A. provides further information for a company’s emergency management program (OPR sSection 32-35).

1. Hazard Assessment

A company’s hazard assessment process for its emergency management program should include, but is not limited to:

  • plume dispersion or similar dispersion modeling (if applicable);
  • identification and documentation of worst-probable emergencies involving the specific products being used or transported;
  • a determination of what can go wrong, its effects, its likelihood of occurrence, how often it could occur and the location of occurrence;
  • consideration of the dangers arising from human activity, such as fire, explosion, environmental contamination, hazardous substance release or pipeline ruptures, in addition to natural perils;
  • an evaluation of the potential for multi-hazard emergencies; and
  • measures that could reduce or eliminate the hazard.

The hazard assessment should be used to create and delineate the Emergency Planning Zone(s) to be utilized for developing the various elements of the emergency management program.

2. Emergency Procedures Manual

The contents of the emergency procedures manual should include, but are not limited to, the following:

  • manual distribution list (or on separate file);
  • manual updating procedures and schedule (or on a separate file);
  • description of initial actions when someone reports an incident;
  • definitions and levels of emergencies;
  • corporate and operational chains of command (e.g., organization structures);
  • management of threat information;
  • incident management system (e.g., Incident Command System);
  • spill control procedures and locations of spill control points (if applicable);
  • debriefing procedure;
  • internal and external communications;
  • external communication information, warnings and evacuations (e.g., public relations or media plan);
  • alternative means of communication;
  • roles and responsibilities for internal positions involved in a response (including contractors);
  • roles and responsibilities for agencies that would likely be involved in a response;
  • environmental or other areas requiring special consideration or protection;
  • detailed product information;
  • internal and external reporting requirements;
  • up-to-date internal and external contact lists;
  • lists of persons in the Emergency Planning Zones (or on a separate file);
  • description and location of response equipment, including information on how to access the response equipment on a 24-hour basis;
  • up-to-date area maps or mapping;
  • agreements with other companies or organizations (or on a separate file) or a reference to agreements in the emergency procedures manual;
  • templates and records to document the events, actions and meetings during an incident.

Emergency procedures manuals must be submitted to the NEB. They are to be reviewed and updated by the company regularly and published on the company’s website as of 30 September 2016. Portions of the published manuals may not be available where there is personal information or information that can affect the security of the pipeline or particular properties.

Order MO-006-2016 Compelling Publication of Emergency Procedures Manuals

A company must also have a site-specific plan for sensitive areas. A sensitive area may be an area with a large population of people or an environmentally sensitive area such as wetlands, national parks, rivers and lakes.

3. Incident Management System

The NEB expects companies to have an incident management system such as the Incident Command System. The system should take into account the functions of the federal and provincial governments, local authorities and governments, and the responsible party to achieve an effective and efficient response.

The system should be a standardized approach to emergency management that includes personnel, facilities, equipment, procedures, and communications operating within a common organizational structure.

4. Liaison with Agencies Involved in Emergency

NEB-regulated companies must establish and maintain a close working relationship with agencies that may be involved in an emergency response on a pipeline. These could include first responders, city planners, municipalities, and indigenous groups. Companies must have discussions with these agencies to make sure they co-ordinate the response if an incident occurs. These discussions must take place during the development and updating of the emergency procedures manual.

Examples of topics for discussion include:

  • accountabilities
  • responsibilities
  • key roles
  • public safety measures
  • communications
  • response capabilities (including equipment, people and training)
  • response times

In consulting with agencies that may be involved an emergency response, a company should, among any other relevant steps:

  • use the hazard, safety and/or emergency planning zones calculated as part of the hazard assessment to identify the parties with whom liaison should be established;
  • have up-to-date contact lists;
  • have a description of the consultation process including a schedule for contacts, nature of discussions, type of information to be provided and the methods to assess the effectiveness of the consultation process;
  • include records and documentation of all liaison activities; and
  • include actions taken based on the results of the feedback received.

5. Communication with Persons Involved in Emergency Response

A company informs anyone associated with an emergency response activity on the pipeline of the relevant information consistent with the emergency procedures manual. This information should include:

  • the type and locations of company facilities;
  • all potential hazardous products transported and/or stored at company facilities in significant volumes;
  • MSDS sheets or similar information on the properties of products;
  • plume dispersion information and ignition guidelines (if applicable);
  • spill control points;
  • key roles of all company personnel and agencies involved in an emergency response;
  • practices and procedures to be followed consistent with those specified in the emergency procedures manual; and
  • any relevant information consistent with the manual.

6. Providing Continuing Education for Emergency Response

The company must develop a continuing education program for police, fire departments, medical facilities, and other organizations and agencies and the public living near the pipeline. The continuing education program informs these groups about the location of the pipeline, potential hazards and the emergency situations involving a pipeline, and the safety procedures to be followed in the case of an emergency.

This would also include:

  • procedures for informing local authorities, response organizations, and the public, procedures on responder health and safety, and scene arrival protocols
  • how to notify the company of an incident
  • hotlines and/or websites set up to respond to inquiries during an emergency.

In developing and implementing continuing education for emergency management, a company should:

  • use the hazard, safety and/or emergency planning zones calculated as part of the hazard assessment to identify the parties with whom continuing education should be conducted;
  • have up-to-date contact lists of all persons potentially affected by an emergency situation;
  • have a rationale for the methods used to distribute information as well as a documented assessment of the success in delivering the safety message;
  • document actions taken to deliver information and identify recipients including examples of the information delivery tools; and
  • include actions taken based on the results of the feedback received.

7. Emergency Response Processes and Capability

A company’s emergency management program includes:

  • procedures for the safe control or shutdown of the pipeline system in the event of an emergency and safety procedures for personnel at emergency sites (CSA Z662 Clause 10.5.2.1); and
  • verifiable capability to respond to an emergency in accordance with their emergency procedures and response plans demonstrated through exercises (OPR section 46 and CSA Z662 Clause 10.5.2.4).

8. Emergency Response Training and Exercises

A company must have a training program for its employees to enhance the knowledge, skills, and abilities required to support the company’s emergency management program. This includes training for persons having a role in an emergency (for example, those providing equipment or involved in the incident management system) and competency requirements. This ensures that staff and first responders are trained on all aspects of their roles and responsibilities as identified in the Emergency Procedures Manual.

A company is also required to demonstrate response capabilities. This is tested through exercises such as drills, tabletops, functional and full-scale exercises.

Emergency response exercises should:

  • be held with sufficient frequency. At least one simulated exercise annually (e.g., tabletop, functional) and a full scale exercise (involving all agencies identified in the company’s liaison) should be held at least every three years;
  • be varied to confirm that all aspects of potential emergencies are tested; and
  • simulate a wide range of potential geographic and weather conditions as well as worse-case spill or gas release scenarios.

9. Emergency Response Equipment

An assessment on whether firefighting and other special equipment is necessary, based on the hazard assessment (CSA Z662 Clause 10.2.7.1).

Sufficient response equipment (including firefighter and special equipment) is necessary to respond to a serious emergency as determined by their hazard assessment (CSA Z662 Clause 10.2.7.1).

Placement of equipment should be based on people, property and environmental considerations to minimize response times and reduce potential impacts of incidents. If equipment resides with mutual aid partners, spill co-operatives, government agencies or other organizations, formal agreements should be in place for access to the equipment by company personnel.

Companies should have documented procedures and schedules for preventative maintenance of response equipment. These procedures should include regularly scheduled sessions for operational testing and inventory control.

For further guidance in developing an emergency management program, companies may use the applicable provisions of the ISO 14000 series of Standards and CSA Z246.2 as a reference.

Annex B. Further Information for Integrity Management Program

Annex B. provides further information for a company’s integrity management program (OPR Section 40).

1. Records Management

A company’s process for managing records (paragraph 6.5(1)(p) of the OPR) related to the integrity management program follows the requirements of the applicable standards referred to in section 4 of the OPR and the requirements of section 56. A company’s records management process for its integrity management program, should allow timely access, by section, to records regarding the pipeline system.

  • (a) The records should include information on the original pipe and all modifications and repairs such as:
    • (i) pipe material, manufacturer and date of manufacture, category, seam and girth weld type, grade, welder identification, non-destructive examination records, heat number and weld maps;
    • (ii) coating type for line pipe, joints and tie-ins, manufacturer, application method and weather conditions at the time of application;
    • (iii) repair history;
    • (iv) mapping;
    • (v) all pressure test data and records, maximum operating pressure, construction drawings, in-line inspection tool data and reports, corrosion control and cathodic protection records including design and survey results;
    • (vi) inspection records of pressure relieving and emergency shutdown devices; and
    • (vii) valve inspection records;
  • (b) A company’s process for record management should:
    • (i) allow for documentation of condition monitoring and mitigation programs and past condition monitoring and mitigation decision analyses; and
    • (ii) provide for reviews of integrity management program effectiveness.

2. Condition Monitoring

Condition monitoring is intended to be a comprehensive, proactive, consistent, process where the various components of the process are reviewed on an ongoing basis and updated as necessary. Condition monitoring should include:

  • (a) periodic internal inspections (frequency of inspections should be based on engineering principles) with in-line inspection (ILI) tools (or their equivalent) for all steel pipelines operating above 30% specified minimum yield strength;
  • (b) an engineering assessment (a documented assessment of variables using engineering principles) of facilities or line pipe segments to address pipeline integrity. Time-dependent, non-time-dependent and geotechnical hazards could be considered and investigated in the engineering assessment. The engineering assessment may consider the results of such methods as pressure testing, use of ILI tools and investigative digs. Note that cathodic protection surveys are not by themselves considered adequate to determine pipeline integrity;
  • (c) the risk assessment methods to be used when assigning priorities for integrity evaluation of facilities or line pipe segments. Factors which may be included in the risk assessment are items such as: product handled; pipeline location; stress levels; product pressure; pipeline age and condition; coating age and condition; cathodic protection data, and ILI data. Consideration may be given to determining the area affected (consequence) by a product release;
  • (d) where appropriate, monitoring and surveillance programs for slope movement, river crossings, depth of cover, frost heave and thaw settlement;
  • (e) a program to minimize third party damage including line patrols;
  • (f) the methods used to evaluate and maintain pipeline integrity and the criteria for their application, which may include:
    • (i) the use of the appropriate ILI tool technology and the methods used to verify ILI findings,
    • (ii) the hydrostatic retesting procedure,
    • (iii) the corrosion control monitoring methods and cathodic protection survey documentation,
    • (iv) the methods used to evaluate remaining life where defects exist,
    • (v) the methods used to verify the coating type and condition,
    • (vi) the methods used to establish equipment inspection intervals,
    • (vii) the methods used to inspect equipment, tankage and pressure vessels, and
    • (viii) any other methods for defect detection utilized;
  • (g) the procedures used to track, analyze and trend the condition of the pipeline; and
  • (h) the steps to be taken to evaluate the cause of a pipeline failure including the minimum investigation and documentation.

3. Mitigation

A company’s mitigation process for ensuring integrity should consider:

  • (a) the criteria and procedures for evaluation of imperfections and repair of pipelines containing defects;
  • (b) the procedure for performing consequence analyses to establish repair priorities;
  • (c) the criteria and procedures for consideration of such measures as pipe replacement, pipe repair, hot taps, hot work, excavation procedures, maintenance welding, recoating, hydrostatic retesting, and reduction in operating pressure (temporary or permanent);
  • (d) the criteria and methods for repair of tanks and pressure vessels;
  • (e) equipment and pipe isolation and purge procedures and de-icing and hydrate removal procedures, where applicable; and
  • (f) an outline of the short-term (i.e., 1 to 3 year(s)) and long-term (i.e., 4 to 10 years) mitigation program plans and priorities.
Date modified: