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National Energy Board Onshore Pipeline Regulations (OPR) – Final Audit Report of the Alliance Pipeline Ltd. Environmental Protection Program – OF-Surv-OpAud-A159-2014-2015 02 [PDF 681 KB]

File OF-Surv-OpAud-A159-2014-2015 02
31 March 2016

Mr. Terrance Kutryk
President and Chief Executive Officer
Accountable Officer under the NEB Act
Alliance Pipeline Ltd.
800, 605 – 5^th Avenue S.W.
Calgary, AB  T2P 3H5

Dear Mr. Kutryk:

Alliance Pipeline Ltd. (Alliance)
National Energy Board Onshore Pipeline Regulations, (OPR)
Final Audit Report – Environmental Protection Program

The National Energy Board has completed its Final Audit Report for its audit of Alliance’s Environmental Protection Program.

A draft report documenting the Board’s evaluation of Alliance’s Environmental Protection Program was provided to Alliance on 23 February 2016 for review and comment. On 17 March 2016, Alliance submitted its response.

The Board has considered Alliance’s comments and has made changes to the Final Audit Report and its Appendices as it determined to be appropriate.

The findings of the audit are based upon an assessment of whether Alliance was compliant with the regulatory requirements contained within:

• National Energy Board Act;
• National Energy Board Onshore Pipeline Regulations; and
• Alliance’s policies, programs, practices and procedures.

Alliance was required to demonstrate the adequacy and effectiveness of the methods selected and employed within its Programs to meet the regulatory requirements listed above.

The Board has enclosed the Final Audit Report and associated appendices with this letter. The Board will make the Final Audit Report and Appendices public on the Board’s website.

Alliance is required to file a Corrective Action Plan (CAP), which describes the methods and timing for addressing the Non-Compliant findings identified through this audit, for approval by the Board prior to 2 May 2016.

The Board will make the CAP public and will continue to monitor and assess all of Alliance’s corrective actions with respect to this audit until they are fully implemented. The Board will also continue to monitor the implementation and effectiveness of Alliance’s Environmental Protection Program and management system through targeted compliance verification activities as a part of its on-going regulatory mandate.

If you require any further information or clarification, please contact Tim Sullivan, Lead Auditor, Operations Business Unit at 403-801-1289 or toll-free at 1-800-899-1265.

Yours truly,

Original signed by

Sheri Young
Secretary of the Board

Attachment – Final OPR Audit Report documents

National Energy Board Onshore Pipeline Regulations (OPR)

Final Audit Report of the Alliance Pipeline Ltd. Environmental Protection Program

File Number: OF-Surv-OpAud-A159-2014-2015 02

Alliance Pipeline Ltd. (Alliance)
Suite 800
605 – 5^th Avenue S.W.
Calgary, Alberta  T2P 3H5

31 March 2016

Executive Summary

Companies regulated by the National Energy Board (NEB or the Board) must demonstrate a proactive commitment to continual improvement in safety, security and environmental protection. Pipeline companies under the Board’s regulation are required to incorporate adequate, effective and implemented management systems into their day-to-day operations. These systems and associated technical management programs include the tools, technologies and actions needed to ensure NEB regulated pipelines are safe and remain that way over time. In the public interest, the Board holds companies accountable for safety and environmental outcomes.

This report documents the Board’s comprehensive audit of Alliance’s management system and Environmental Protection program applicable to its facilities that are regulated by the NEB. The audit was conducted using the National Energy Board Onshore Pipeline Regulations (OPR) as amended on 21 April 2013. This amendment clarified the Board’s expectations for establishing and implementing a documented management system and Environmental Protection program. Before issuing the amendment, the Board consulted and communicated with its regulated companies with respect to the new requirements; therefore, an implementation grace period was not given when the OPR was promulgated. As a result, when evaluating compliance, this audit did not consider any extra time Alliance may have needed to implement changes associated with the formalized management system requirements. As indicated in the amendments, companies must have an effective and well-documented Environmental Protection program as a key component of their management system.

The Board conducted the audit following its published audit protocol, which identifies five management system elements. These five elements are broken into 17 sub-elements. Each sub-element reflects several regulatory requirements. Companies must comply with 100 per cent of the regulatory requirements of each sub-element being assessed. If a company’s program is found to be deficient with respect to any regulatory requirement, the entire sub-element will be found Non-Compliant. This report also includes an assessment of Alliance’s management system against the requirements of OPR, section 6.1.

The Board’s audit of Alliance’s regulated facilities found that Alliance is in the process of establishing and implementing an operational management system that will account for all of the technical programs required by the Board.

The Board noted that Alliance’s records indicate that an Operational Excellence Management System (OEMS) was implemented in 2008 for the purpose of creating a structured platform for the ongoing identification and active discussion of operational risks. Since then, quarterly OEMS management review meetings have been held to which discussions on current risks, operational matters and regulatory updates are discussed.

Alliance’s records also indicated that an internal evaluation of OEMS was conducted in 2012, which resulted in a new iteration of Alliance’s management system that is being rebranded as the Operational Risk Management System (ORMS). Alliance indicated that ORMS is “designed to be an overarching, integrated framework of vision, policies, standards, programs and governance processes to be used by the company in working towards meeting its corporate objectives of “zero safety, pipeline or environmental incidents and compliant, ethical and good neighbor wherever we operate”.

Regardless of when Alliance started its management system development, the Board identified that Alliance’s management system is in a transitory state between the program-based management practices it used in the past and its new management system approach. This has contributed to a Non-Compliant finding related to establishing and implementing a compliant management system. It is important to understand that the Board’s finding regarding Alliance’s management system primarily reflects the company’s stage in developing and applying its management system. It does not necessarily reflect the lack of technical management activities being undertaken to ensure the protection of the environment.

The Board’s audit of Alliance’s management system included an assessment of the individual management system processes as described in the OPR and the Board’s audit protocol. As documented in this report, the Board found that Alliance has documented some of the required processes within its Operational Risk Management System. However, the Board found that most of Alliance’s management system processes were not sufficiently systematic, explicit, comprehensive and proactive to meet the OPR requirements.

The Board notes that, regardless of the reasons for non-compliance, companies were required to be compliant with the Board’s management system requirements when the OPR were updated in 2013. Alliance will need to develop and implement corrective actions to ensure establishment and implementation of its management system.

In addition to evaluating Alliance’s management system and associated processes, the Board’s audit also included an evaluation of Alliance’s Environmental Protection program to determine the applicability and integration of the management system within it and to assess whether Alliance is meeting its requirements to develop, implement and maintain an Environmental Protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment. The Board found that, notwithstanding the documentation issues relating to its management system processes, the processes and practices presently used by Alliance identified the majority, and most significant, of its environmental related hazards and that Alliance has developed and implemented operational controls and inspection and monitoring programs to address these hazards. The Board notes that Alliance’s Environmental Protection program has been in existence for many years, thus its related practices and procedures are well established within the organization. The Board did identify some deficiencies not related to management system process development. All of the Board’s findings are documented in Appendix I of this audit report.

In analyzing the results of its audit as a whole, the Board notes that it has made a significant number of Non-Compliant findings. The majority of these findings fall into three general categories:

• Non-compliances relating to management system process development;
• Non-compliances relating to Alliance’s interpretation of OPR requirements; and
• Non-compliances relating to technical content.

The Board notes that the majority of all of the Non-Compliant findings made by the Board relate to management system process development.

The Board has determined that enforcement actions are not immediately required to address the Non-Compliant findings identified in this audit. Within 30 days of the Final Audit Report being issued, Alliance must develop and submit a Corrective Action Plan for Board approval. The Corrective Action Plan must detail how Alliance intends to resolve the non-compliances identified by this audit. The Board will assess implementation of the corrective actions to confirm they are completed in a timely manner and applied consistently across Alliance’s regulated system. The Board will also continue to monitor the overall implementation and effectiveness of Alliance’s management system and Environmental Protection program through targeted compliance verification activities as part of its ongoing regulatory mandate.

Table of Contents

• 1.0 Audit Terminology and Definitions
• 2.0 Abbreviations
• 3.0 Introduction: NEB Purpose and Framework
• 4.0 Background
• 5.0 Audit Objectives and Scope
• 6.0 Audit Process and Methodology
• 7.0 Audit Activities
• 8.0 Management System Evaluation
• 9.0 Program Summary
• 10.0 Summary of Audit Findings
• 11.0 Conclusions
• Appendix I: Audit Evaluation Table
• Appendix II: Facility Summaries and Maps
• Appendix III: Company Representatives Interviewed
• Appendix IV: Documents Reviewed

1.0 Audit Terminology and Definitions

(The Board has applied the following definitions and explanations in measuring the various requirements included in this audit. They follow or incorporate legislated definitions or guidance and practices established by the Board, where available.)

Adequate: The management system, programs or processes complies with the scope, documentation requirements and, where applicable, the stated goals and outcomes of the NEB Act, its associated regulations and referenced standards. Within the Board’s regulatory requirements, this is demonstrated through documentation.

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 to audit criteria and legal requirements and communicating the results of the process to the company.

Compliant: A program element meets legal requirements. The company has demonstrated that it has developed and implemented programs, processes and procedures that meet legal requirements.

Corrective Action Plan: A plan that addresses the non-compliances identified in the audit report and explains the methods and actions that will be used to correct them.

Developed: A process or other requirement has been created in the format required and meets the described regulatory requirements.

Effective: A process or other requirement meets its stated goals, objectives, targets and regulated outcomes. Continual improvement is being demonstrated. Within the Board’s regulatory requirements, this is primarily demonstrated by records of inspection, measurement, monitoring, investigation, quality assurance, audit and management review processes as outlined in the OPR

Established: A process or other requirement has been developed in the format required. It has been approved and endorsed for use by the appropriate management authority and communicated throughout the organization. All staff and persons working on behalf of the company or others that may require knowledge of the requirement are aware of the process requirements and its application. Staff has been trained on how to use the process or other requirement. The company has demonstrated that the process or other requirement has been implemented on a permanent basis. As a measure of “permanent basis”, the Board requires the requirement to be implemented, meeting all of the prescribed requirements, for three months.

Finding: The evaluation or determination of the compliance of programs or elements in meeting the requirements of the National Energy Board Act and its associated regulations.

Implemented: A process or other requirement has been approved and endorsed for use by the appropriate management authority. It has been communicated throughout the organization. All staff and persons working on behalf of the company or others that may require knowledge of the requirement are aware of the process requirements and its application. Staff has been trained on how to use the process or other requirement. Staff and others working on behalf of the company have demonstrated use of the process or other requirement. Records and interviews have provided evidence of full implementation of the requirement, as prescribed (i. e. the process or procedures are not partially utilized).

Inventory: A documented compilation of required items. It must be kept in a manner that allows it to be integrated into the management system and management system processes without further definition or analysis.

List: A documented compilation of required items. It must be kept in a manner that allows it to be integrated into the management system and management system processes without further definition or analysis.

Maintained: A process or other requirement has been kept current in the format required and continues to meet regulatory requirements. With documents, the company must demonstrate that it meets the document management requirements in OPR, section 6.5 (1)(o). With records, the company must demonstrate that it meets the records management requirements in OPR, section 6.5 (1)(p).

Management System: The system set out in OPR sections 6.1 to 6.6. It is a systematic approach designed to effectively manage and reduce risk, and promote continual improvement. The system includes the organizational structures, resources, accountabilities, policies, processes and procedures required for the organization to meet its obligations related to safety, security and Environmental Protection.

(The Board has applied the following interpretation of the OPR for evaluating compliance of management systems applicable to its regulated facilities.)

As noted above, the NEB management system requirements are set out in OPR sections 6.1 to 6.6. Therefore, in evaluating a company’s management system, the Board considers more than the specific requirements of section 6.1. It considers how well the company has developed, incorporated and implemented the policies and goals on which it must base its management system as described in section 6.3; its organizational structure as described in section 6.4; and considers the establishment, implementation, development and/or maintenance of the processes, inventory and list described in section 6.5(1). As stated in sections 6.1(c) and (d), the company’s management system and processes must apply and be applied to the programs described in section 55.

Non-Compliant: A program element does not meet legal requirements. The company has not demonstrated that it has developed and implemented programs, processes and procedures that meet the legal requirements. A corrective action plan must be developed and implemented.

Practice: A repeated or customary action that is well understood by the persons authorized to carry it out.

Procedure: A documented series of steps followed in a regular and defined order thereby allowing individual activities to be completed in an effective and safe manner. A procedure also outlines the roles, responsibilities and authorities required for completing each step.

Process: A documented series of actions that take place in an established order and are directed toward a specific result. A process also outlines the roles, responsibilities and authorities involved in the actions. A process may contain a set of procedures, if required.

(The Board has applied the following interpretation of the OPR for evaluating compliance of management system processes applicable to its regulated facilities.)

OPR section 6.5(1) describes the Board’s required management system processes. In evaluating a company’s management system processes, the Board considers whether each process or requirement: has been established, implemented, developed or maintained as described within each section; whether the process is documented; and whether the process is designed to address the requirements of the process, for example a process for identifying and analyzing all hazards and potential hazards. Processes must contain explicit required actions including roles, responsibilities and authorities for staff establishing, managing and implementing the processes. The Board considers this to constitute a common 5 w’s and h approach (who, what, where, when, why and how). The Board recognizes that the OPR processes have multiple requirements; companies may therefore establish and implement multiple processes, as long as they are designed to meet the legal requirements and integrate any processes linkages contemplated by the OPR section. Processes must incorporate or contain linkage to procedures, where required to meet the process requirements.

As the processes constitute part of the management system, the required processes must be developed in a manner that allows them to function as part of the system. The required management system is described in OPR section 6.1. The processes must be designed in a manner that contributes to the company following its policies and goals established and required by section 6.3.

Further, OPR section 6.5(1) indicates that each process must be part of the management system and the programs referred to in OPR section 55. Therefore, to be compliant, the process must also be designed in a manner which considers the specific technical requirements associated with each program and is applied to and meets the process requirements within each program. The Board recognizes that single process may not meet all of the programs; in these cases it is acceptable to establish governance processes as long as they meet the process requirements (as described above) and direct the program processes to be established and implemented in a consistent manner that allows for the management system to function as described in 6.1.

Program: A documented set of processes and procedures designed to regularly accomplish a result. A program outlines how plans, processes and procedures are linked; in other words, how each one contributes to the result. A company regularly plans and evaluates its program to check that the program is achieving the intended results.

(The Board has applied the following interpretation of the OPR for evaluating compliance of programs required by the NEB regulations.)

The program must include details on the activities to be completed including what, by whom, when, and how. The program must also include the resources required to complete the activities.

2.0 Abbreviations

Alliance: Alliance Pipeline Ltd.

CAP: Corrective Action Plan

CSA Z662-11: CSA Standard Z662 entitled Oil and Gas Pipeline Systems, 2011 version

GOT: Goals, Objectives and Targets

EMS: Alliance’s Environmental Management System

NEB: National Energy Board

OPR: National Energy Board Onshore Pipeline Regulations

ORMS: Alliance’s Operational Risk Management System

EPP: Environmental Protection program

3.0 Introduction: NEB Purpose and Framework

The NEB’s purpose is to promote safety and security, environmental protection and efficient energy infrastructure and markets in the Canadian public interest within the mandate set by Parliament in the regulation of pipelines, energy development and trade. In order to assure that pipelines are designed, constructed, operated and abandoned in a manner that ensures: the safety and security of the public and the company’s employees; safety of the pipeline and property; and protection of the environment, the Board has developed regulations requiring companies to establish and implement documented management systems applicable to specified technical management and protection programs. These management systems and programs must take into consideration all applicable requirements of the NEB Act and its associated regulations. The Board’s management system requirements are described within OPR, sections 6.1 through 6.6.

To evaluate compliance with its regulations, the Board audits the management system and programs of regulated companies. The Board requires each regulated company to demonstrate that they have established and implemented, adequate and effective methods for proactively identifying and managing hazards and risks.

As part of the audit, the Board reviews the compliance and incident history of the company as recorded in NEB files. This helps the Board determine the appropriate scope for the audit. During the audit, the Board reviews documentation and samples records provided by the company in its demonstration of compliance and interviews corporate and regionally-based staff.

The Board also conducts separate but linked technical inspections of a representative sample of company facilities. This enables the Board to evaluate the adequacy, effectiveness and implementation of the management system and programs. The Board bases the scope and location of the inspections on the needs of the audit. The inspections follow the Board’s standard inspection processes and practices. Although they inform the audit, inspections are considered independent of the audit. If unsafe or non-compliant activities are identified during an inspection, they are actioned as set out by the Board’s standard inspection and enforcement practices.

After completing its field activities, the Board develops and issues a Final Audit Report. The Final Audit Report outlines the Board’s audit activities, provides evaluations of the company’s management system and programs, identifies deficiencies and communicates compliance findings. The Final Audit Report follows the format of the Board’s published Audit Protocol. Once the Board issues the Final Audit Report, the company must submit and implement a Corrective Action Plan to address all Non-Compliant findings. Final Audit Reports are published on the Board’s website. The audit results are integrated into NEB’s risk-informed lifecycle approach to compliance assurance.

4.0 Background

Alliance operates approximately 1,600 km of pipeline in three Canadian provinces. These pipeline facilities include mainline and lateral compressor stations, mainline block valves and associated operational assets. All of these facilities are within the definition of a “pipeline” as included in the NEB Act. Alliance also has a considerable amount of infrastructure in the United States, which completes its North American system. Alliance’s system allows it to transport rich natural gas from the Western Canadian Sedimentary Basin and the Williston Basin to end-users in the United States Midwest and other downstream markets. In order for Alliance to operate its pipelines effectively, it has developed a management structure that reflects its safety and security management, and environmental obligations, as well as its corporate, national, and regional needs.

For Alliance facility information, refer to Appendix II of this report.

During audit planning, company staff indicated that Alliance operates its pipelines and facilities using a common management system and technical programs. In order to effectively evaluate compliance of such an expansive system within a reasonable timeframe, the Board chose to conduct individual, comprehensive audits of Alliance’s required technical programs and management system. This report documents one of five management system and program audits. The audits are titled:

• Alliance Safety Management Program Audit;
• Alliance Environmental Protection Program Audit;
• Alliance Emergency Management Program Audit;
• Alliance Third-Party Crossings Program Audit; and
• Alliance Public Awareness Program Audit.

Audit results confirmed that Alliance operates its facilities using a common organizational structure to implement a common governance management system that applies to all of its business and operational activities. Some findings are therefore similar in each audit and the individual audit reports reflect this.

5.0 Audit Objectives and Scope

The objective of the audit was to determine the establishment and implementation of Alliance’s management system and the adequacy and effectiveness of its Environmental Protection program. Alliance was audited against the requirements contained within the following:

• National Energy Board Act;
• National Energy Board Onshore Pipeline Regulations; and
• Alliance’s policies, programs, practices and procedures.

This audit was conducted using the National Energy Board Onshore Pipeline Regulations (OPR) as amended on 21 April 2013. This amendment clarified the Board’s expectations for establishing and implementing a documented management system and Environmental Protection program. Before issuing the amendment, the Board consulted and communicated with its regulated companies with respect to the new requirements; therefore, an implementation grace period was not given when the OPR was promulgated. As a result, when evaluating compliance, this audit did not consider any extra time Alliance may have needed to implement changes.

6.0 Audit Process and Methodology

In undertaking this audit, the Board has applied its standard audit practice following its published protocols. The Board’s standard practice and audit activities include:

• Formal notification of the Board’s intent to audit by letter;
• Interactive planning processes with the company;
• Information gathering;
• Documentation and record review;
• Program presentations by company personnel and interviews with company personnel;
• Associated inspections and facility reviews;
• Close-out discussions and meetings;
• Developing and Issuing Draft Audit Report to Alliance;
• Developing, finalizing and issuing the Final Audit Report;
• Reviewing and approving any required Corrective Action Plans;
• Reviewing implementation of Corrective Action Plans; and
• Issuing closure letters.

These audit activities allow the company to demonstrate whether its management system and programs comply. They also allow the Board to evaluate the company with respect to: assuring compliance to regulatory requirements; and assuring appropriate safety, security and environmental outcomes as described in OPR, section 6.

As noted, Alliance uses a common management system and Environmental Protection program and at the time of the audit divided its Canadian assets into four operational regions: Grande Prairie, Whitecourt/Morinville, Kerrobert, and Regina. The Board therefore developed its audit plan to evaluate Alliance’s management system and Environmental Protection program and to assure that it was appropriate to manage and applied to all of its regulated facilities regardless of location. To this end, the Board conducted interviews, inspections and documentation and record reviews in each region as well as the Calgary office. It is the Board’s expectation that any audit Non-Compliant findings made and corrective actions required by the Board must be applied across all of Alliance’s Board regulated systems.

7.0 Audit Activities

The Board informed Alliance of its intent to audit its NEB regulated facilities in a letter dated 24 June 2014. Following the issuance of that letter, Board audit staff met with Alliance staff on a regular basis to arrange and coordinate this audit. The Board also provided Alliance with an information guidance document to help Alliance prepare for the audit as well as to provide access to documentation and records to demonstrate its compliance. Alliance established a digital access portal for Board staff to review documentation and records.

On 27 April 2015, an opening meeting was conducted with representatives from Alliance in Calgary, Alberta to confirm the Board’s audit objectives, scope and process. The opening meeting was followed by Calgary office interviews from 27 April to 1 May 2015, and various field level audit activities as described in the table below.

Environmental Protection Program Audit Office and Field Activities

• Audit opening meeting (Calgary, AB) – 27 April 2015
• Calgary office interviews (Calgary, AB) – 27 April – 1 May 2015
• Field verification activities:
  • Interviews – Grande Prairie, AB – 11-12 May 2015
  • Interviews – Morinville, AB – 13 – 14 May 2015
  • Interviews – Regina, SK – 25 – 28 May 2015
• Calgary office interviews (Calgary, AB) – 22 – 26 June 2015
• Audit pre-close-out meeting of information gaps (Calgary, AB) – 30 July – 6 August 2015
• Audit close-out meeting (Calgary, AB) – 30 September 2015

Throughout the audit, Board audit staff gave Alliance daily summaries with action items, where required.

From 30 July to 6 August 2015, the Board held an audit pre-close-out meeting with Alliance. At this meeting Board staff and Alliance staff discussed potential deficiencies identified during field activities and discussed additional information that could be of value to the Board prior to compiling its draft audit report. An audit close-out meeting was held on 30 September 2015 to provide Alliance with a description of the recommendations that staff would be bringing to the Board for decision.

8.0 Management System Evaluation

OPR, section 6.1 outlines the Board’s management system requirements as follows:

In assessing Alliance’s management system the Board applied the definitions and guidance as described in Section 1.0 Audit Terminology and Definitions of this report. The Board’s audit of Alliance’s regulated facilities found that Alliance has not established, implemented and maintained a management system that meets the requirements of the OPR. Currently, Alliance relies on their protection programs practices and activities to ensure that it meets the Board’s requirements to ensure the safety and security of the people, the pipeline and the protection of the environment. This is evident in Appendix I as the majority of the Non-Compliant findings relate to a lack of a documented management system process. While Alliance has established and implemented certain processes that could be considered part of their management system, it was limited to these processes and does account for all of the requirements set forth in OPR, sections 6.1 and 6.5(1). As a result, the Board has found Alliance Non-Compliant with OPR, section 6.1(a) to (e).

The Board noted that Alliance’s records indicate that an Operational Excellence Management System (OEMS) was implemented in 2008 for the purpose of creating a structured platform for the ongoing identification and active discussion of operational risks. Since then, quarterly OEMS management review meetings have been held to which discussions on current risks, operational matters and regulatory updates are discussed.

Alliance’s records also indicated that an internal evaluation of OEMS was conducted in 2012, which resulted in a new iteration of Alliance’s management system that is being rebranded as the Operational Risk Management System (ORMS). Alliance indicated that ORMS is “designed to be an overarching, integrated framework of vision, policies, standards, programs and governance processes to be used by the company in working towards meeting it’s corporate objectives of “zero safety, pipeline or environmental incidents and compliant, ethical and good neighbor wherever we operate”.

Regardless of when Alliance started its management system development, the Board’s audit identified that Alliance’s management system was in a transitory state between the program-based management practices it used in the past and its new management system approach.

In determining Alliance’s compliance with respect to establishing and implementing a management system, the Board reviewed the audit results of Alliance’s Environmental Protection program processes along with the audit results of other Board program audits completed concurrently. This aided the Board in evaluating Alliance’s systematic practices and deficiencies.

The Board found that Alliance has not met the requirements for establishing and implementing a management system. For the most part, this reflected the transitory nature of its management system as applied to the Environmental Protection program. The issues related to designing and establishing processes as described below and in Appendix I also contributed to the Board’s Non-Compliant finding. This is especially true with respect to Alliance’s Quality Assurance Program and auditing process design.

The Board notes that it is important to understand that the Board’s management system Non-Compliant finding reflects the company’s deficiencies in developing and applying its management system. It does not necessarily reflect the lack of technical management activities being undertaken to ensure the protection of the environment.

The Board notes that, regardless of the reasons for non-compliance, companies were required to be compliant with the Board’s management system requirements when the OPR were updated in 2013. Alliance will need to develop and implement corrective actions to ensure establishment and of its management system.

As part of Alliance’s Corrective Action Plan to address its management system Non-Compliant finding, the Board is of the view that, Alliance must develop and implement a compliant document control processes that meet OPR requirements for all new and existing documents in the company’s management system. This will serve to assure that the management system processes are designed appropriately and that existing or referenced documents fully meet the OPR requirements.

Based on the Board’s evaluation of Alliance’s management system against the OPR requirements, the Board has determined that Alliance is Non-Compliant with section 6.1. Alliance will have to develop a Corrective Action Plan to address the described deficiencies.