Pipelines and People - Preventing Damage and Harm - Questions and Answers
- Are there consequences for not registering with One Call?
- It is clear that legislating membership to one call will ensure that all buried infrastructure will be contacted. Excavator awareness is the other half of the solution to prevent damages. Commercial excavators are fairly straight forward but how do we raise awareness to those who aren't aware they need to call such as homeowners or landowners.
- How many of the DIRT reporting damages were related to the oil and gas industry and how many associated with other industries?
- What is the pipeline integrity management requirements for sections of pipeline which cannot be in-line inspected? Example: a San Bruno section was noted as 18% piggable.
- What reportable inspection requirements will a pipeline company provide for their integrity management program (IMP) that would be acceptable to the NEB?
- Why does the CCGA have the DIRT report expectation and yet regulators use different reports?
- What is the minimum standard for depth of cover?
Are there consequences for not registering with One Call?
Mike Sullivan: If registering with a One-Call service is mandated by legislation, there could be legal / non-compliance consequences for the underground infrastructure owner if they have not done so. In Ontario, underground infrastructure within a public right of way must be registered with Ontario One-Call. In Alberta and British Columbia, underground infrastructure governed by the Alberta Energy Regulator and the British Columbia Oil & Gas Commission must be registered with Alberta One-Call and BC One Call respectively.
The far greater consequence of not registering with a One Call service is the risk of damage to underground infrastructure by uncontrolled excavation / ground disturbance and the consequence of those damages on public safety, the environment and services such as 9-1-1.
It is clear that legislating membership to one call will ensure that all buried infrastructure will be contacted. Excavator awareness is the other half of the solution to prevent damages. Commercial excavators are fairly straight forward but how do we raise awareness to those who aren't aware they need to call such as homeowners or landowners.
Mike Sullivan: Effectively promoting awareness is undoubtedly a key element of successfully preventing damage to underground infrastructure and there are countless methods of doing so. Traditionally, mainstream media (radio, television & newsprint) have successfully imprinted key messages such as "Call Before You Dig" into society. Despite those efforts, damages still occur. To be successful, awareness needs to move with the times. Today, social media is playing a growing awareness role and is displacing traditional mainstream awareness methods.
Promoting awareness to homeowners and landowners is tricky. This stakeholder group only digs once every five to ten years so it's a case of being there when they need you - and to do that, the CCGA is of the view the damage prevention process needs to be recognizable through a universally consistent brand. A successful brand could be used everywhere to trigger awareness and is intended to make that person stop and think "I need to do something". In our case, the goal is to initiate a locate request to the regional One-Call Centre setting the damage prevention process in motion. Think of it this way, how successful would a STOP sign be if it was a different colour and shape in every jurisdiction? That's what we need to achieve - simple and effective - to raise general / universal awareness.
How many of the DIRT reporting damages were related to the oil and gas industry and how many associated with other industries?
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What is the pipeline integrity management requirements for sections of pipeline which cannot be in-line inspected? Example: a San Bruno section was noted as 18% piggable.
Alan Murray: For non pigable lines a company has two choices, neither of which is ideal for its own reasons. The first is hydro-testing, which is doable if the line can be taken out of service for the requisite length of time to fill, test, empty and dry the line. Hydro-testing will find all critically sized defects except very short deep ones. A “critically sized defect” is one where the combination of length and depth is such that the pipe locally cannot remain intact at the test pressure conditions. It would of course remain intact if the pressure was to be reduced to normal operating conditions. The second method is referred to as “Direct Assessment”. Two independent techniques must be used, the second to validate the results of the first. It does not, nor can it, address all modes of failure. Rather, it focusses on metal loss due to corrosion. When the pipe corrodes, the cathodic protection system will draw more current. The direct assessment approach essentially tries to find where the pipe coating may have failed and a corrosion site started. It is not fool proof and can be inaccurate particularly where the soil is dry; the pipe is covered in concrete etc.
What reportable inspection requirements will a pipeline company provide for their integrity management program (IMP) that would be acceptable to the NEB?
NEB: Section 40 of the National Energy Board Onshore Pipeline Regulations (OPR) requires that a company IMP must anticipate and prevent all conditions that could adversely affect safety or the environment. Paragraph 6.5(1)(u) of the OPR requires a management system process for inspecting and monitoring activities and facilities to evaluate the adequacy and effectiveness of the IMP. The OPR also requires coordination between programs such as the IMP and the damage prevention program to ensure that risks are managed.
Why does the CCGA have the DIRT report expectation and yet regulators use different reports?
NEB: The CCGA DIRT (Damage Information Reporting Tool) report is based on information rolled up from the regional partner (provincial) CGAs who have their own DIRT reports. The DIRT gathers information on incidents and near misses from all of the stakeholders in the ground disturbance community – buried infrastructure owners (not just pipelines) as well as ground disturbers and even regulators.
The NEB recently implemented the Event Reporting System (ERS) which is intended for use by regulated companies to provide notification to the NEB and Transportation Safety Board (TSB) of various events that are defined in regulation including incidents, unauthorized activities, and operations and maintenance activities. The functionality of the ERS allows companies to meet the regulatory requirements to report events immediately with a preliminary report, then finalize the report at a later date when all relevant information has been gathered. This functionality was not available with DIRT.
The NEB is the federal regulatory champion of the CCGA, and supports the development of the national DIRT reports because the data gathered from all stakeholders informs ongoing damage prevention strategies and initiatives for all stakeholders. Unauthorized ground disturbance activities are near miss events and because NEB regulated pipelines are required to report these, we have excellent near miss data. If you can prevent near misses by correcting the behaviours leading up to them, you will see a reduction in full on incidents; it is the most proactive way to prevent damage. The NEB submits these unauthorized activities/near miss incidents into the DIRT reports with privacy protected information removed to give that proactive edge to the ground disturbance community.
What is the minimum standard for depth of cover?
NEB: The Onshore Pipeline Regulations reference CSA Z662 Standard for minimum depth of cover. The Z662 Standard is reviewed every four years to address changing requirements and emerging technologies as a part of their process for continual improvement.
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