ARCHIVED - Emera Brunswick Pipeline Company Ltd. - Audit Report OF-Surv-OpAud-E236 01 - Appendix V: EBPC Crossing Program Audit Evaluation Table

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Appendix V:
EBPC Crossing Program Audit Evaluaion Table

1.0 POLICY AND COMMITMENT

1.1 Policy and Commitment Statements

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

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

Assessment:
EBPC filed its Operations and Maintenance (O&M) Manual, developed by the Operator, as the guidance document for the operation phase of the Brunswick Pipeline and has endorsed the policies and procedures contained therein. According to the O&M Manual, activities related to crossings are included in the overall integrity and pipeline maintenance programs and therefore subsumed in the overall Safety Program. The policy in the manual reads, “Environmental protection, health and safety are considered to be both corporate and personal responsibilities for EBPC and its employees.” (O&M Specifications Manual p.1)

Based on interviews and documents reviewed, the Board verified that EBPC has adopted the Operator’s Environment Health and Safety (EHS) Management System (MS) and that the commitment to managing its safety hazards and risks was visible at all levels within the organization.

Compliance Status: Compliant

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

2.0 PLANNING

2.1 Hazards Identification, Risk Assessment and Control[2]

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

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

Assessment:
As Part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the National Energy Board Pipeline Crossing Regulations (PCR) are managed and executed by the Operator.

The main risk identified for crossing activities is third party damage. To mitigate the risks associated with third parties conducting work near the pipeline, staff indicated that there are hot zone procedures included in the Operations and Maintenance Manual. As part of the procedure, the Lands, Public Awareness and Emergency Management Coordinator (Coordinator) conducts pre-job and project kick-off meetings to ensure that staff and contractors involved in the project are aware of the hazards of working around a hot line. Field staff also attend the project tailgate meetings. Any time there is a third party working within 5 metres of the pipe; procedures dictate that there is a pipeline company representative onsite to supervise the work to ensure that safety instructions are followed. Field staff also indicated a high level of confidence in their ability to alert management to safety issues related to third party crossings.

Documents reviewed onsite show that hazards related to crossing projects are reviewed in pre-job safety meetings and noted in the pre-job checklist to capture safety requirements for each job.

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

Compliance Status: Compliant

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

2.2 Legal Requirements

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, legal requirements outlined in the PCR are managed and executed by the Operator.

During interviews, EBPC stated that the Director of Regulatory Affairs and Government Relations is the primary point of contact with the NEB with regard to any compliance issues or changes to regulatory requirements. Upon receiving notification/correspondence from the NEB, the Director, Regulatory Affairs and Government Relations forwards this information to the Operator as appropriate.

The Operator did not demonstrate that it has a formal process for the tracking and ensuring implementation of legal requirements into the procedures for the operations and maintenance of the pipeline.

Although regulatory requirements were reflected in the procedural documents, the audit identified one issue of particular note to the Board. The Operator had failed to recognize the requirement to file its technical crossing guidelines for Board approval as required by the PCR. The Board notes that subsequent to the onsite portion of this audit, EBPC has filed its guidelines.

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

Compliance Status: Non-compliant

2.3 Goals, Objectives and Targets

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator.

Employee objectives are discussed with their supervisor at the beginning of the year, at least once during the year and again at the end of the year when the past year’s performance is evaluated and objectives are established for the next year. Safety goals, targets and objectives have been identified for all staff and are included in individual job descriptions. Safety performance is included in the overall employee objectives and employees are provided recognition in meeting its EHS performance objectives known as the “Short Term Incentive Programs”.

The Board verified during interviews with staff and document review that the Operator manages third party activities as part of the overall operational program and is represented in the safety goals.

Compliance Status: Compliant

3.0 IMPLEMENTATION

3.1 Organizational Structure, Roles and Responsibilities

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator.

The Coordinator is accountable for senior level crossing activities. This position reports to the Right-of-Way (RoW) Manager of the northeast region in Head Office (Waltham, MA). The Coordinator manages and monitors all third party activities around the Brunswick Pipeline including onsite supervision of third party crossings and post crossing inspections. The Coordinator also manages complex crossing files with the assistance and oversight from engineering staff in Halifax, NS or Waltham, MA. There are also three technical staff positions that were hired to work exclusively on the Brunswick Pipeline. Although the Coordinator does some coaching of these new staff, they receive assignments and report directly to the Operator’s Area Supervisor in New Brunswick. Interviews confirmed that staff understood their roles and to whom they were to report.

The Operator was able to demonstrate that the current structure allows for the crossing program to function effectively.

Compliance Status: Compliant

3.2 Management of Change

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

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

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

Assessment:
As part of the O&M agreement, EBPC has delegated the operational and technical responsibilities to the Operator. The Operator has implemented some elements of a change management program for the operational procedures including third party related activities as part of the Integrity Management Program. Changes to current procedures are addressed through a change request process. Once updated, the administrator posts the most current version on the intranet with all of the other manuals for each discipline for access and these changes are discussed at safety meetings.

However, at the time of the audit, the Operator could not demonstrate that it had a fully developed and implemented Management of Change Program that would identify changes that could affect the management of third party activities, including introduction of new risks, hazards or legal requirements and documenting these changes.

Compliance Status: Non-compliant

3.3 Training, Competence and Evaluation

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

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

Assessment:
According to the O&M agreement between EBPC and the Operator, the Operator is responsible for training of employees. The Operator manages electronic training records in the Houston, Texas office with a Learning Management System. Document review onsite confirmed that hard copies of training records and certifications are managed by administrative staff in the Saint John office. Training updates and renewal notices are sent to employees through the system.

When new technical staff were hired to address the operational requirements of the Brunswick Pipeline, the Operator Area Supervisor identified technical courses that the new technicians required to perform their duties. The Operator created and evaluated the list of courses to confirm the list corresponded with the duties the technicians would be performing. Interviews confirmed that employees also learn by shadowing the Coordinator while conducting third party related activities, such as safety presentations and project kick-offs.

The Operator was unable to demonstrate that training requirements for the Coordinator roles had been formally included in its training program. This position performs tasks requiring high degrees of technical knowledge and training has been provided on an ongoing basis. However,senior staff indicated that there are no skill inventories maintained for these senior technical positions.

Although the Operator demonstrated the existence of a training program for new employees, senior staff were not included in the Training matrix. The Board recommends that the Operator formally identify and incorporate the training needs of Coordinators into its existing Training Program to ensure knowledge and experience of current Coordinators is captured and incorporated into future training needs.

Compliance Status: Compliant with recommendation

3.4 Communication

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

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator.

For the Operator, internal communication is done through regular face to face meetings as well as frequent phone conversations with field staff responsible for crossings activities that cover large geographical areas. To facilitate communication with employees in the field, each company truck is equipped with communication equipment such as satellite phones to ensure that staff are able to remain in contact at all times. The Brunswick Pipeline website is used to communicate with external stakeholders regarding living and working safely around its pipeline. The EBPC site contains accurate information regarding the process for contacting the company, the circumstances under which it is required to do so, as well as the process for obtaining permission to work around its pipeline.

Although there are several informal internal communication mechanisms in place, the Operator could not demonstrate that there is a formalized and implemented communication overarching plan that outlines the distribution of various types of information to appropriate parties. While interviews confirmed communication is occurring throughout technical networks, without a formal communication plan, the Operator cannot ensure that all stakeholders and interested parties are receiving the appropriate information in a timely fashion. For example, the Area Supervisor does not receive any reports regarding the Coordinator’s crossing related workload which makes trending and resource forecasting difficult.

Despite documented communication which takes place during the various meetings, the Board recommends that information related to third party activities be included in a formalized safety related communication plan.

Compliance Status: Compliant with recommendation

3.5 Documentation and Document Control

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator.

The Operator’s administrative staff manage the majority of the crossing related procedural information in the Fredericton office. Document revision logs confirm that the procedures are periodically reviewed and updated and that revisions are approved. For procedures, there is a document revision list to manage all the changes to any of the procedures. Technical staff complete a request for revision form to track and record all requests and subsequent changes to procedures. The revision date is on the front of the procedure. Once approved and revised, the procedures are posted on the intranet by the administrative staff in each office and the outdated versions are removed. The Operator’s staff also control and document the distribution of its as-built plans as part of the crossing application file.

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

Compliance Status: Compliant

3.6 Operational Control - Normal Operations

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator. EBPC receives updates on the operation of the pipeline during weekly conference calls with the Operator. Third party related agenda items are discussed under maintenance issues.

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

Normal operations for crossings-related duties are described in the O&M Manual. In cooperation with the senior staff such as the Area Manager, the Coordinator and technical staff indicate a high level of involvement in the maintenance and enhancement of the procedures. The technicians are cross-trained to perform many of the front line duties for crossings including:

  • Conducting pre-job meetings;
  • Attending all crossing installations on the RoW and within 5 metres and complete the pipeline inspection reports;
  • Post crossing inspections
  • Performing visual analysis to identify anomalies in the coating such as corrosion which would be referred to the Waltham, MA office for review; and
  • Meeting with third parties.

Technical staff are also responsible for performing locates as required. Crossing requests made through the 1-888 number, the administrative staff introduces the request into the process and the technicians receive the locate requests and perform the locates accordingly. The Coordinator addresses the more complex crossing requests with support from the engineers in the Halifax, NS or Waltham, MA offices.

The Operator has adequately documented procedures and processes that address processes and roles for normal operating conditions.

Compliance Status: Compliant

3.7 Operational Control - Upset or Abnormal Operating Conditions

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

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

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator.

Upset conditions for third party related activities would trigger the Emergency Response Plan. The Operator has conducted table tops that tested the third party damage scenario for training purposes. For more information relating to the assessment of the Operator’s Emergency Preparedness and Response Program refer to Appendix IV of this report.

Compliance Status: N/A

4.0 CHECKING AND CORRECTIVE ACTION

4.1 Inspection, Measurement and Monitoring

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator. EBPC receives updates on the RoW patrols during the weekly conference calls.

At the time of the audit, the Operator technicians for the Brunswick Pipeline patrolled the crossing points of the urban RoW daily. The Operator technical staff drives the urban sections of the Brunswick Pipeline are driven by technical staff in order to identify possible issues with unauthorized activity or encroachment. Interviews confirmed that technical staff were aware of how to identify and report any issues along the RoW and patrol reports were reviewed. RoW patrol reports are maintained in the System and Integrity Logging database (SAIL).

The entire RoW is flown once a week by a fixed wing plane. Board auditors interviewed the pilot to confirm that the Operator provided procedures for identification and reporting of hazards such as excavation equipment on or near the RoW. Air patrol was aware of and follows the Operator’s procedure for documenting patrols and reporting any issues to the regional office. The records of the aerial inspections are reviewed and filed in the regional office. The Board was able to view procedures and records for training of aerial patrol staff which ensures consistency as there is turnover in this position.

However, it is noted that a draft Standard Operating Procedure (SOP) detailing the procedure to be followed when encroachments are installed on the RoW, did not adequately address PCR, Part I section 4(b) which requires all encroachments installed on the RoW be given written permission, even if they are subsequently removed. In addition, in order to ensure compliance with the PCR, Part II section 15, the SOP needs to require that all facilities permitted on the RoW be inspected to ensure any deterioration has been detected.

The Operator did not demonstrate that it had PCR compliant procedures in place to monitor the ongoing condition of encroachments on the right of way.

Compliance Status: Non-compliant

4.2 Corrective and Preventive Actions

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

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

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator. EBPC’s Facility Crossing Guidelines, as implemented by the Operator, outline the criteria and expected response to non-compliance such as unauthorized excavation and construction near the facilities. The criteria for reporting non-compliance for crossing related activities are described in EBPC’s Facility Crossing Guidelines and are in compliance with PCR requirements. Staff interviews confirm that they are familiar with the procedure for identifying and addressing unauthorized activity, which is to intervene if there is an immediate threat to public or worker safety and report the incident to the Coordinator.

Although the Operator’s procedures include the requirement to report all instances of non-compliance to the NEB, interviews confirm that reporting is not being done following each instance of non-compliance as required by the PCR and the EBPC’s Facility Crossing Guidelines. Instead, unauthorized activities are addressed with awareness sessions (formal or informal) delivered by the Coordinator.

The Operator was unable to demonstrate that it has implemented its process for reporting unauthorized activity as per its EBPC’s Facility Crossing Guidelines and PCR Part II, Section 13.

Compliance Status: Non-compliant

4.3 Records Management

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

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

Assessment:
As part of an O&M Agreement between EBPC and its Operator, all third party crossings activities outlined in the PCR are managed and executed by the Operator.

All Brunswick Pipeline crossing related documents are maintained for the life of the pipeline. For example, RoW patrol records are maintained in SAIL by the Office Administrators. Office administrative staff also use the SAIL database to manage the maintenance records for the locate equipment. They use the manufacturer recommended maintenance schedule in SAIL to initiate the maintenance requests. Documents reviewed on site such as the schedule of maintenance and the certificates of calibration confirm this process is being executed as described.

Records relating to locates requested and performed as well as locate requests that are beyond the required locate distance and receive the “all clear” are also maintained. The Coordinator maintains the records for complex crossing projects as they are typically ongoing files. These files are also maintained for the life of the pipeline.

The Board verified that the Operator has a process to maintain records in accordance with regulations.

Compliance Status: Compliant

4.4 Internal Audit

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

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

Assessment:
According to EBPC management, an independent audit of the Operator for all of the protection programs as required by the OPR-99 will take place. As the Brunswick Pipeline is still in its first year of operation, there would not be adequate information to conduct an effective audit of its operational programs relating to crossings.

The Board recommends that the Operator conduct an audit of its programs against the PCRs and OPR-99 to ensure compliance with legal requirements and to verify that the programs are being implemented as designed.

Compliance Status: Compliant with recommendation

5.0 MANAGEMENT REVIEW

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

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

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

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

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