Unauthorized Activities Reporting Recommended Practice

Transcription

1 Unauthorized Activities Reporting Recommended Practice Preamble Damage prevention is a shared responsibility. Pipeline operators and all stakeholders in the damage prevention process have a shared responsibility to protect themselves, their workers, the public, and the environment by acting in a safe, responsible and careful manner. In 2014, CEPA member companies committed to core Damage Prevention initiatives, one of which is a commitment to mandatory investigation and reporting of all third party ground disturbance infractions of pipeline crossing/damage prevention regulations, and any third party activity which poses a risk to pipelines. This guidance is being developed to provide CEPA member companies with clear language on the expectations based on regulatory requirements and sound, safe damage prevention practices that are auditable, measurable, and consistent, therefore enabling all companies to be on a level playing field. The goal of all CEPA member companies is to report, and analyze, leading indicators, not lagging indicators. CEPA has an opportunity to raise the bar with regard to identification, reporting and prevention of all unauthorized activities through data mining, rather than reviewing damages after they have already occurred. The intent of reporting leading indicators is to avoid incidents which lead to damages to pipelines. If CEPA member companies are going to take the time to report leading indicators then time should be taken to make those metrics meaningful and impactful. Leading indicators should: Deliver small improvements in performance or rationalize no change Measure the positive: what people are doing versus failing to do 1 Enable frequent feedback to all stakeholders Be credible Be predictive Increase constructive problem solving around damage prevention 2 Affect behavioral change - human factors 1 For example: number of communications to landowners/contractors; how many free learnings are provided ie when an unauthorized occurs did we provide learning to the landowner/contractor; number of contacts to one-call; categorize callers by jurisdiction (homeowners, contractors, municipalities, other); investigating all near miss unauthorized; foot/aerial patrols consistent list of observations 2 Use leading indicator data to inform best practices for damage prevention

2 Objectives of Guidance 1. Identify ways to reduce ambiguity in reporting some activities may be considered nonreportable by some companies and reportable by others. 2. Improve Communication and consultation with provincial and federal regulators enable consistent benchmarks through reporting of unauthorized activities to improve safety performance. Note: Member companies recognize that reporting is based on the discovery and investigation of the unauthorized activity. Definition of Unauthorized Activity Any contravention of existing damage prevention/pipeline protection regulations (federal or provincial) or any activity that the pipeline company considers to be a hazard or risk to the pipeline, including contravention of company conditions that allows third party activity near their pipelines. This includes pipeline right-of-way, safety zones, and facilities, or other proximity location as identified by the pipeline company.

3 Workflow*:

4 Examples of Activities Ground disturbance Any work, operation, or activity on or under the existing surface resulting in a disturbance or displacement of the soil or ground cover. For example, includes but is not limited to: digging; excavation; trenching; ditching; tunneling; boring/drilling/pushing; augering; topsoil stripping; land leveling/grading; plowing to install underground infrastructure; brush clearing and stump removal; subsoiling; blasting/use of explosives; quarrying; grinding and milling of asphalt/concrete; seismic exploration Encroachment activities within the ROW, For example, stockpiling materials (e.g. sand, loam, etc.), building structures or facilities (e.g. sheds, swimming pools, skating rinks, etc.); tree planting, driving fence posts, bars, rods, pins, anchors, or pilings Vehicle crossings in which vehicles or construction equipment operate on or across the RoW without permission. Agricultural equipment and vehicles may be exempt under NEB Order MO For example, crossing of buried pipelines or other underground infrastructure by heavy loads. Other Other activities which may not fall into above, but which can create a hazard Education Opportunities If not reportable: determine if party contacted a One Call centre promotion of One Call service personal visits public awareness initiatives promotion of industry/regulations/company procedures document and retain record of communication

5 Annex Reporting Criteria 1. Name/contact of violator/contractor/all parties 2. Date/time of activity 3. Date/time of discovery 4. Pipeline name, specifications, product, etc. 5. Location of activity (pipeline km or station, AND province/gps/lat-long) 6. Closest city, town, village 7. Population density 8. Details of unauthorized activities, including type of equipment involved, as applicable a. Signage at site? b. Locate requested? c. Permission issued? d. Inspector at site? e. Public Awareness material previously provided to party? 9. Damage to pipeline (if applicable) 10. Description of actions taken or planned to address consequences 11. Name/contact information for person reporting 12. Explore Root Cause

6 APPENDIX Regulatory References NATIONAL ENERGY BOARD ONSHORE PIPELINE REGULATIONS 6.3 (1) The company shall establish documented policies and goals for meeting its obligations under section 6, including (a) a policy for the internal reporting of hazards, potential hazards, incidents and near-misses that includes the conditions under which a person who makes a report will be granted immunity from disciplinary action; and (b) goals for the prevention of ruptures, liquid and gas releases, fatalities and injuries and for the response to incidents and emergency situations. 6.5 (1) A company shall, as part of its management system and the programs referred to in section 55, (c) establish and implement a process for identifying and analyzing all hazards and potential hazards; (d) establish and maintain an inventory of the identified hazards and potential hazards; (e) establish and implement a process for evaluating and managing the risks associated with the identified hazards, including the risks related to normal and abnormal operating conditions; (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks; NATIONAL ENERGY BOARD PIPELINE CROSSING REGULATIONS PART II 13. (1) The pipeline company shall immediately report to the Board (a) every contravention of the National Energy Board Pipeline Crossing Regulations, Part I; (b) all damage to its pipe caused or observed during the construction or installation of a facility or during an excavation or during the operation, maintenance or removal of a facility; and (c) any activity of the facility owner or excavator that the pipeline company considers to be potentially hazardous to a pipe. (2) The report referred to in subsection (1) shall include (a) details of any contravention or of any damage, including, in the case of damage, the cause and nature thereof; (b) any concerns the pipeline company may have regarding the safety of the pipeline as a result of the construction or installation or of the excavation; and (c) any action the pipeline company intends to take or request.

7 TRANSPORTATION SAFETY BOARD REGULATIONS 4.(1) When a pipeline occurrence takes place, the operator of the pipeline and any employee of the operator having direct knowledge of the occurrence shall report the occurrence to the Board if it results directly from the operation of the pipeline and if (g) an unauthorized third party activity within the safety zone jeopardizes the safe operation of the pipeline; CANADIAN STANDARDS ASSOCIATION Z247 NATIONAL ENERGY BOARD DAMAGE PREVENTION REGULATION