ARCHIVED - Emera Brunswick Pipeline Company Ltd. - Audit Report OF-Surv-OpAud-E236 01 - Appendix I: EBPC Integrity Management Program Audit Assessment Table

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Appendix I
EBPC Integrity Management Program Audit Assessment 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, 47and 48
 Z662-07 Clause 10.2.2 and 10.14

Assessment:
Emera Brunswick Pipeline Company’s (EBPC) Integrity Management Program (IMP) document, dated March 31, 2010 was developed and implemented by the Operator. It includes Section 2: Corporate Policies, Objectives, and Organization. Subsection 2.1 includes a Policy and Objectives description of short term (1-4 years) and long term (5-10 year) plans for all integrity related program developments, including hazard identification, inspection and investigation and maintenance activities for all pipelines included within the scope of the document. The IMP Policy is endorsed and approved by the Operator’s senior management and had been adopted by EBPC. In addition, there is the Pipeline Integrity Oversight Committee (PIOC), whose mandate it is to administer the IMP for all of the Operator’s Canadian regulated pipelines. PIOC committees are comprised of the Operator’s senior management including: Director, Pipeline Integrity (Houston), Manager, Pipeline Design (Houston), Manager, Metallurgical Services (Houston), Director, Operations Compliance (Houston), Director, Facilities Operations (Houston), Director, Technical Operations (Southeast Region), Director, Technical Operations (Northeast Region).

Based on documents reviewed and interviews, the Operator was able to demonstrate that it has a policy which commits to continual improvement and is communicated to its staff.

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), 39, 40, 41
CSA Z662-07 Clauses 10.2, 10.3.1.1(d), 10.14.1(a)(b), 16.2

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The Hazard Identification process is described in the IMP Section 8: Hazard Identification and Control. This section summarizes the hazards that are considered to be relevant to its operations. The identified hazards are used as input for a commercial risk assessment software program (RiskAnalyst) offered and administrated by Dynamic Risk Assessment Systems, Inc. The Operator has segmented this pipeline system into logical and logistical segments. This dynamic segmentation allows the risk values of individual segments to be calculated so that the overall risk of one segment to another can be compared. The hazards input into the program include: internal corrosion, external corrosion, stress corrosion cracking, manufacturing, construction, equipment and weather-related and outside forces.

The Operator’s integrity management team has recognized the possibility of internal corrosion and has committed to implement a corrosion control program on all pipelines. The program would follow the Operator’s Standard Operating  Procedure (SOP) Volume 2 - Corrosion, 2-3010 Internal Corrosion Monitoring and Mitigation which includes maintenance pigging and analysis of any deposits resulting from the pipeline pigging. The pigging program would have a targeted frequency of twice per year per pipeline segment, but ultimately the frequency for each pipeline would be assessment based. The integrity management team also indicated that during the harmonization and revision of the IMP, Section 8.3.2 Internal Corrosion would be revised from “internal corrosion is not considered a viable threat” to reflect that there is some evidence that internal corrosion should be considered, and thus mitigated. Based on the evidence presented to the Board during the audit, the Board is of the opinion that internal corrosion will be appropriately monitored and mitigated.

Based on documents reviewed and interviews, the Operator was able to demonstrate that it has a program to identify its hazards and associated risk and mitigate the risk appropriately.

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, 6, 40 and 41(1)
CSA Z662-07 Clause 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The Operator’s Operations and Maintenance Specifications Manual (O&MSM), Section 00 Forward, recognizes the applicable pipeline codes and regulations (including all applicable Canadian and United States (U.S.) codes). The IMP, Section 1.1 states “This Integrity Manageme nt Program has been developed in accordance with the guidelines of CSA Z662-07 Annex N and the Onshore Pipeline Regulations - 1999”. While CSA Z662-07 Annex N is not a mandatory requirement for pipelines regulated by the NEB, voluntary adoption of its Guidelines for Integrity Management Programs provides a comprehensive framework for the structure and evaluation of the IMP. The Operator utilizes SOPs which describes in detail its IMP. The SOPs are being revised against all its applicable regulatory requirements and best practices (Canadian and U.S.).

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it had identified its legal requirements and had integrated its regulatory obligations into the IMP.

Compliance Status: 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 40, 47 and 48
CSA Z662-07 Clauses 10.2.2(h)(ii) and 10.14.1

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The IMP, Section 2: Corporate Policies, Objectives and Organization, and Subsection 2.1 Policies and Objectives, states that the “pipeline integrity objectives are established as part of an ongoing process to develop short term (1-4 years) and long term (5-10 year) plans and budgets for all integrity-related program development, hazard identification, inspection and investigation, and maintenance activities for all pipelines included within the scope of this document”.

The IMP Section 2.3, Subsection 2.3.2: Performance Measures details EBPC’s Performance Plan which determines if the objectives of the IMP are being achieved and if pipeline integrity is being improved through the IMP. Through collection and analysis of performance data which is collected semi-annually, demonstrate that the IMP is being executed as planned. Performance Report from 2009 inclusive was reviewed and found to be in compliance with the expectations of the audit.

Based on documents reviewed and interviews, the Operator was able to demonstrate that it has goals, objectives and targets to continually improve upon its IMP.

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, 10.2.2(b) and 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The Operator’s organizational structure, roles and responsibilities are detailed in several documents. The IMP, Section 2.2: IMP Administration and Responsibilities and Subsection 2.2.1: Pipeline Integrity Oversight Committee provides a high level outline of the functional relationships for the IMP.

The Operator’s Operations and Maintenance Specifications Manual (O&MSM), Section 00, Reference 05 also outlines the organizational structure of overall pipeline operation including management, field personnel and field staff and establishes reporting relationship of all levels of staff and the inter-relationship of all work functions.

Twelve (12) organization charts were provided that delineated the structure and reporting relationships, including specific roles and responsibilities for the IMP. Interviewees specifically responsible for the IMP provided a clear understanding of their responsibilities for the development, management and implementation of the various facets of the IMP.

Based on documents reviewed and interviews, the Operator was able to demonstrate that it has an organizational structure that allows it to implement its IMP appropriately and as designed.

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 an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The IMP, Section 6: Management of Change (MOC) addresses the requirements for the IMP and is intended to cover physical, procedural, technical and organizational changes that may impact the pipeline system. The MOC process describes in detail the types of changes that could be of impact to the pipeline system as well as the critical elements of change management. Section 6.3.1 of the IMP documents the MOC roles and responsibilities within the organization from a functional standpoint and includes an MOC process flow diagram describing the interrelationship between those roles and responsibilities.

Appendix 2 of the IMP contains the instructions for the Record of Change Form (Figure 6) with functional responsibilities and chronological sequencing of the procedures outlined in Annex N.8.1. While CSA Z662-07 Clause 10.2.2(g) requires a (generic) MOC process, EBPC has voluntarily chosen to incorporate CSA Z662-07 Annex N, Section N.8.1 and N.8.2 into its IMP which include more specific and detailed MOC requirements. On a more local level, the Operator’s Annual Corrosion Review Meeting identifies current items requiring change, determines the type of remedial actions required and follows-up / resolves integrity related MOC issues.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has an effective MOC process to identify, document and analyze changes that could affect the IMP.

Compliance Status: 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 4, 18, 29 and 46
CSA Z662-07 Clauses 10.2, 10.5 and 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The IMP, Section 5: Competency and Training recognizes the increasingly complex nature of pipeline systems and the associated maintenance, inspection and monitoring requirements. The Operator also recognizes the need for personnel involved in the pipeline integrity program to possess highly specialized skills and that staff will be required to demonstrate competence in the areas for which they are responsible.

The Operator has classified personnel involved in the planning and execution of the IMP into General Service Providers and Critical Service Providers. The former consists of personnel involved in general activities and the latter consists of personnel involved in the execution of specialized pipeline inspection and maintenance activities. Technical competency requirements for both groups are based on an analysis of an individual’s present or expected involvement in basic or advanced aspects of the IMP activities. Following the analysis and assessment of basic training needs, the design and planning of training is conducted regularly, with training sessions scheduled no less frequently than annually.

Training and qualifications for Critical Service Providers includes Brunswick Pipeline staff, vendors and contractors. These include: in-line inspection (ILI), engineering and risk assessments, non-destructive testing, stress corrosion cracking (SCC) and corrosion investigations, mechanical or materials defect assessments, pipeline defect repair, field recoating, hot taping and maintenance welding. Where industry standards or certification are an applicable aspect in the qualification and evaluation of competency, the Operator includes these requirements for staff or contract personnel. These include: Professional Engineering Associations, Certified Engineering Technicians/Technologists, Non-Destructive Examination (NDE) service providers having CGSB Level II or III in MPI, UT or radiography and SCC.

Management responsible for the IMP are required to provide relevant support for both the trainers and trainees with respect to equipment, software and opportunities to exercise the competencies. The audit program as outlined in Section 15.4 of the IMP must include in its scope, evaluation of the effectiveness of the training program and ensure that the objectives and expectations of the Training Program are being achieved. Documents and records of the completed Training Program for all Operator staff with specific O&M responsibilities for the Brunswick Pipeline are maintained in the local area offices.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has a training program for its staff and contractors as it relates to its IMP.

Compliance Status: Compliant

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 4, 18, 28, 29, 40, 47 and 48
CSA Z662-07 Clauses 10.2.2 (d) and 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management plan (IMP).

The IMP includes sections that document relevant aspects of its integrity programs. Examples of the most relevant of these to communication are: Section 1: IMP Scope; Section 2: Corporate Policies, Objectives and Organization; Subsection 2.2.2.6 Administrative/Technical/Regulatory Document Teams with eight tables outlining the functional roles and responsibilities; Subsection 2.3.2 Performance Measures; Section 3: Documentation and Information Methods; Section 6: Management of Change Plan which includes Table 2 Responsibilities for Providing Approvals for Change and Section 11: Integrity Management Program Planning.

The IMP document, in addition to the SOP’s, provide sufficient detail to support the effective implementation of the IMP elements as well as ensuring that the inspection, measurement, monitoring and maintenance activities are conducted in accordance with EBPC’s specifications.

Although there are several formalized communication mechanisms being implemented for the IMP, the Operator could not demonstrate that there is an overall formalized and implemented communication plan that outlines the content and required distribution of various types of information to appropriate parties. While interviews confirmed communication is occurring through technical networks and through the means identified above, without a formal communication plan, the Operator cannot ensure that all stakeholders and interested parties outside of the Integrity program are receiving the appropriate information in a timely fashion. For example, a formalized communication would identify what IMP information needs to be communicated to management to assist in planning.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has effective communication to inform all interested persons of activities related to its IMP. The Board recommends that the Operator include identified IMP information in the overarching formalized communication plan.

Compliance Status: Compliant with recommendation

3.5 Documentation and Document Control

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

References:
OPR-99 sections 4, 27, 47, 48
CSA Z662-07 Clauses 10.2.2(e)(f), 10.3.1.1(d) and 10.14.1

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management plan (IMP).

During a preceding audit of the Operator for the M&NP Pipeline, its pigging procedures as, documented, were compared to actual field practices. SOP, Volume 1 - Pipeline, Procedure Number 1-5030 states “The following procedures for running pigs demonstrate general practices only; operating personnel shall develop and implement site specific procedures and thoroughly familiarize themselves with the requirements of these procedures prior to their use and operation.” Additionally, pigging has been recognized as a hazard in the O&MSM, Section 04: Cleaning, Testing and Purging, Reference 05: Pipeline Pigging - General where it states that “Pigging is extremely dangerous when done incorrectly”. Item #3 in this document states “The pigging barrel is a pressure vessel. Operations involving opening of the door should be done with extreme care as the energy stored in high-pressure gas is sufficient to tear the door off its hinges and launch a pig out of the barrel at high velocity. Assurance that the barrel is fully vented is the pigging crew’s responsibility and is a major factor to their personal safety.”

At this point, due to the short time in operation, the Operator has not performed pipeline pigging (cleaning runs or ILI) on the Brunswick Pipeline. In the future, as a result of the internal corrosion program to be implemented in 2011, maintenance pigging programs will be initiated. This increased exposure to operations personnel necessitates detailed, accurate and complete procedures for each pig launcher and receiver to identify site specific hazards and mitigate the risks associated with pipeline pigging.

A site inspection of the pig launcher and receiver at the Red Head facility revealed that both the launcher and receiver had been constructed with concentric versus eccentric reducers. While this type of design does not contravene any code or standard, it can pose a problem during pig launching. The concentric reducer makes it difficult to achieve a tight seal on the front pig cup because the pig is tilted rather than level in the launch position.   The lack of a tight seal, especially in a gas line, can mean that repeated attempts are required to seal the pig in the reducer to achieve a successful launch. Repeatedly pressurizing, depressurizing and purging the pig launcher can lead to operator frustration and possibly to taking shortcuts in the pigging procedure. These factors can increase the possibility of injury to operations personnel. The Operator was unaware of this potential situation when Board auditors identified it to operations personnel during the audit.

The Board recommends that in order to prevent this situation from occurring in future pigging operations, when the site specific pigging procedures are developed and documented for Brunswick Pipeline facilities, they should incorporate special instructions to operations personnel to address this unique design of its facilities.

Compliance Status: Compliant with recommendation

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 4, 27, 36, 37, 39 and 40
CSA Z662-07 Clause 10

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The O&MSM contains numerous sections that address implementation of the technical requirements of OPR-99 section 36. These requirements include: maintaining communication facilities, periodic testing of instruments and equipment, continually recording suction and discharge pressures, marking the open and closed positions of critical valves and posting signage at facilities boundaries for critical contact information.  

The IMP includes 15 Sections and 2 Appendices and addresses the requirements of OPR-99 section 27 requiring the development, regular review and updating of manuals to provide information and procedures to promote efficiency in the operation of its pipeline and facilities. The hazards identified in Section 8: Hazard Identification and Control and Section 9: Risk Assessment are effectively addressed in Section 10: Hazard Control and Risk Reduction; Section 12: Integrity Assessment Methods; Section 13: Inspections, Testing, Patrols and Monitoring and Section 14: Mitigation and Repair.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has a process to address the risks and hazards associated with its facilities and activities.

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:
Integrity:
OPR-99 sections 4, 32, 37, 40 and 52
CSA Z662-07 Clauses 10.2, 10.3.2 and 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The O&MSM Section 14, Reference 01: Contingency Plan is intended to provide communications and gas control operations for all pipeline facilities operated by the Operator. The communications systems are comprised of a wholly-owned and controlled satellite system to ensure ideal communication along the pipeline route. A 1-888 emergency telephone system has been put into place to be used by the public. The number is displayed on all EBPC line signs, valve sites, stations and related facilities. An after-hours answering service receives calls and communicates specific needs to the appropriate Operations Center or on call technician.

As per CSA Z662-07 Clause 10.3.2.5, the Operator has made provisions for pre-tested pipe and related fittings to be stored at one or more of the Operation Centers or valve sites along the pipeline route or use in emergency repairs. Site visits confirmed the storage of pipe and fittings.

Section 14, Reference 02 covers emergency and planned pipeline shutdown requirements and References 03 to 06 inclusive provide pipeline schematics with mainline valve identification.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has plans for upset or abnormal operating conditions.

Compliance Status: Compliant

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 4, 27, 28, 36, 37, 39, 47, 48, 53(1) and 54(1)
CSA Z662-07 Clauses 9 and 10

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The IMP, Section 13: Inspection, Testing, Patrols and Monitoring outlines the procedures to conduct inspections, testing, patrols and monitoring in accordance with Clauses 9 and 10 of CSA Z662-07. The detailed procedures are contained in the Operator’s SOPs. The SOP’s have been “harmonized” such that the requirements for the U.S. and Canadian regulators are specified in terms of specific tasks and the frequencies of those tasks. The SOP’s have been organized to address threat specific requirements. For example, IMP Section 1.6: Inspection and Damage Prevention contains ten (10) procedures covering pipeline Right-of-Way (RoW) patrols and leakage surveys. IMP Section 2.2: External Corrosion includes thirty (30) detailed procedures with the focus on cathodic protection inspection, testing and monitoring. Review of the Annual Cathodic Protection Survey Report for 2009 indicated that the survey scope (test points) and results (NACE criteria) met regulatory requirements.

CSA Z662-07 Clause 10.6.1.2 states that the frequency of pipeline patrolling shall be determined by considering such factors as: operating pressure, pipeline size, population density, etc., which are risk-based considerations. The inclusion of risk-based frequencies as required by CSA Z662-07 is evident in SOP 1-6010 Pipeline Patrol and Leakage Survey Frequency Criteria, which specifies bi-weekly aerial RoW patrols.

To ensure appropriate documentation and records of the inspection, surveillance and monitoring programs, each SOP contains links imbedded in the electronic document to the “Reporting” and “Forms” requirements upon completion of the SOP tasks.

In terms of data integration and analysis, IMP Section 13.2: Evaluation of Inspection, Testing, Patrol and Monitoring Results stipulates that upon completion of each task, the results are evaluated to determine whether a potential threat exists, and when the results indicate the presence of conditions that might lead to a failure incident with significant consequences or to an external interference incident, an engineering assessment is to be performed in accordance with CSA Z662-07 Clause 10.14.

In terms of risk assessment, IMP Section 9.2.2: Review of Previous Integrity Management Processes states that information gained from integrity audits, performance metrics, integrity assessments and mitigative actions (i.e. Inspection, Testing, Patrols and Monitoring) over the previous year will be incorporated into the annual updating of the risk information for each threat.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has surveillance and monitoring programs to address its hazards and risks as it relates to the IMP.

Compliance Status: 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 4, 6 and 52
CSA Z662 Clauses 10.2.2(g) and (h), 10.3 and 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

IMP, Section 7: Incident Investigations details the requirements for incident reporting, on-site investigation, follow-up investigation and inclusion of any recommendations to the IMP that would reduce the likelihood of such an incident recurring. Section 2.3.2 Performance Measures includes threat specific incident data that would constitute non-compliances.

The data is collected, monitored, reviewed and investigated by the Pipeline Integrity Oversight Committee on a semi-annual basis. An internal report is presented and reviewed by senior management as well as the integrity management staff. While no incidents had occurred that required action for the Operator, it is noted that the annual Corrosion Review Meeting has a standing agenda item of Review of Action Items, which addresses incident related action items from previous years that are to be resolved.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has an appropriate process for investigating incidents and non-compliances.

Compliance Status: 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 4, 41 and 56
CSA Z662-07 Clauses 9.11, 10.2, 10.3, 10.4 and 10.14

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The IMP, Section 4: Integrity Management Program Records summarizes the record management system whereby the records of integrity management activities and related operations and maintenance are maintained in many files and types of formats. These records are completed and retained as per the requirements of the individual related procedures. The records related to the pipeline design, construction, operation and maintenance are prepared, managed and maintained in accordance with its record retention rules. The types of records that are included in the records management program include:

  • Pipeline design records
  • Materials standards and specifications
  • Material test reports
  • Joining and inspection records
  • Coating inspection records
  • Pressure test records
  • Pipeline environment records
  • Pipeline location records
  • Class location records
  • Cathodic protection records
  • Risk assessment records
  • Repair records
  • Other records covering implementation and completion of risk mitigation activities.

An example of one of these records that was reviewed was the Annual Cathodic Protection Survey for 2009 which included all of the required data, including pipeline test points, inspection date, pipe-to-soil cathodic protection potential measurements and sign off by the operations technician.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate it has a records management program to ensure records relating to the Integrity Program are retained as required, accessible and maintained.

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 sections 4, 53 and 55
CSA Z662-07 Clause 10.2.2(c) and (h)(iii)

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the integrity management program (IMP).

The IMP, Section 15: IMP Review & Evaluation, Subsection 15.4 Audits, specifies that both internal and external audits will be utilized to formally validate and improve its IMP. While CSA Z662-07 Annex N is not specifically a requirement of the NEB, EBPC has chosen to adopt it and therefore must meet the requirements of Annex N.17.2(a) through (f) which include: audit scope and objectives, audit frequency and timing, responsibilities for managing and performing audits, auditor independence, auditor competency and audit procedures.

The Board recommends that the Operator amend its internal audit program to ensure requirements identified in OPR-99 and other referenced and regulatory documents are appropriately defined (see also Element 2.2 Legal Requirements) and that internal audits incorporate all regulatory requirements that apply to the Brunswick Pipeline and facilities. Further, during the audit, EBPC staff provided documentation of its parent company’s internal environmental management system which includes internal audit requirements. If EBPC implements its contemplated practices it could result in an effective and fully compliant process.

Based on documents reviewed and interviews with operations staff, the Operator was able to demonstrate that it has a process to undertake audits of its IMP as it relates to the Brunswick Pipeline system and it is recommended that EBPC complete an audit of its IMP as per its IMP requirements in the near future.

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 4, 40 and 55
CSA Z662-07 Clause 10.2.2(h)(iii) and 10.14.1

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

Compliance Status: N/A

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