Guidance Notes for the Canadian Energy Regulator Onshore Pipeline Regulations

4 September 2013
Sections 47.2 and 55, and Annex A – updated 7 October 2016
Section 42 – updated 15 November 2018
Alignment with CER Act (name and term changes) and
the CER’s Online Event Reporting system – updated 19 August 2021

Guidance Notes
for the
Canadian Energy Regulator Onshore Pipeline Regulations

Introduction

The Canadian Energy Regulator Onshore Pipeline Regulations (OPR) provides regulatory requirements for oil and gas companies under the Canadian Energy Regulator Act (CER Act).

These Guidance Notes are provided to assist interested parties in understanding the requirements of the OPR. These Guidance Notes are not a substitute for the CER Act or any regulations made thereunder including the OPR, or any other applicable legislation or standards enforced by the Canada Energy Regulator (CER or Regulator) or which the CER audits companies against. To achieve or evaluate compliance with the OPR, reference should be made to the OPR itself, and reliance should not be placed on these Guidance Notes. To the extent there is any inconsistency between these Guidance Notes and the CER Act or its regulations, or any other applicable legislation or standards, the legislation and standards are paramount.

The CER’s compliance activities include conducting compliance assessment meetings, inspections and audits to review a company’s compliance with the CER Act and related regulations. The CER’s Management System and Protection Program Audit Protocols and a Guidance Document are provided in separate documents and outlines the framework for assessment in a CER audit.

The CER’s Filing Manual contains filing requirements for OPR requirements involving applications that require CER authorization.

The CER expects pipeline companies to approach operating in a systematic, explicit, comprehensive and proactive manner that manages risks. The CER also expects that companies have fully developed and implemented management systems and protection programs that provide for continual improvement. A carefully-designed and well-implemented management system supports a strong culture of safety and is fundamental to keeping people safe and protecting the environment.

As required by the OPR, companies must establish, implement and maintain management systems and protection programs in order to anticipate, prevent, manage and mitigate conditions that may adversely affect the safety and security of the company’s pipelines, employees, the public, as well as property and the environment. A company’s management system applies to the company’s programs for safety, pipeline integrity, environmental protection, emergency management, damage prevention and security.

When requested by the CER, companies must demonstrate the adequacy and effectiveness of the management processes and procedures employed.

Table of Contents

• Introduction
• Interpretation
• Application
• General
• Management System
  • Management System Processes
  • Annual Report
• Design of the Pipeline
  • Detailed Designs
  • HVP Pipelines
  • Stations
  • Storage Facilities
• Materials
  • Specifications
  • Quality Assurance Program
• Joining
  • Joining Program
  • Non-destructive Examination
• Construction
  • Construction Safety
  • Right-of-way and Temporary Work Areas
  • Crossing a Utility or Private Roadway
• Pressure Testing
  • Pressure Testing Program
  • Permits for Use and Disposal of Water
  • General Testing Requirements
• Operation and Maintenance
  • Operation and Maintenance Manuals
  • Maintenance Safety
  • Emergency Management Program
  • General Operation Requirements
  • Pipeline Control System
  • Maintenance Welding
  • Surveillance and Monitoring
  • Integrity Management Program
  • Change in Class Location
  • Change of Service or Increase in Maximum Operating Pressure
  • Deactivation and Reactivation
  • Decommissioning
  • Training Program
  • Safety Management Program
  • Security Management Program
  • Damage Prevention Program
  • Environmental Protection Program
  • Commission Authority
• Abandonment
  • Application for Leave to Abandon
• Reporting
  • Crossing Reports
  • Incident Reports
• Audits and Inspection
  • General Compliance
    • Audits
    • Inspections
  • Construction Inspection
  • Program Audits
• Record Retention
  • Requirements
• Annexes
  • Annex A. Further Information for Emergency Management Program
  • Annex B. Further Information for Integrity Management Program

Interpretation

1. The definitions in this section apply in these Regulations.

"abandon" means to permanently cease operation such that the cessation results in the discontinuance of service. (cessation d'exploitation)

"accountable officer" means a person appointed as accountable officer under subsection 6.2(1). (dirigeant responsable)

"Act" means the Canadian Energy Regulator Act. (Loi)

"change of service" means a change in the type of fluid transported in the pipeline, which necessitates changes to the design requirements in accordance with CSA Z662.(modification du service)

"class location" means a class location as defined in CSA Z662 and as determined in accordance with that standard. (classe d'emplacement)

"Commission" means the Commission referred to in subsection 26(1) of the Act. (Commission)

"component" means a component as defined in CSA Z662. (élément)

"CSA" means the Canadian Standards Association. (CSA)

"CSA Z246.1" means CSA Standard Z246.1 entitled Security Management for Petroleum and Natural Gas Industry Systems, as amended from time to time. (norme CSA Z246.1)

"CSA Z276" means CSA Standard Z276 entitled Liquefied Natural Gas (LNG) – Production, Storage and Handling, as amended from time to time. (norme CSA Z276)

"CSA Z341" means CSA Standard Z341 entitled Storage of Hydrocarbons in Underground Formations, as amended from time to time. (norme CSA Z341)

"CSA Z662" means CSA Standard Z662 entitled Oil and Gas Pipeline Systems, as amended from time to time. (norme CSA Z662)

"deactivate" means to remove temporarily from service. (mettre hors service)

"decommission" means to permanently cease operation such that the cessation does not result in the discontinuance of service. (désaffectation)

"environment" means elements of the Earth and includes

• a) land, water and air, including all layers of the atmosphere;
• b) all organic and inorganic matter and living organisms; and
• c) the interacting natural systems that include elements referred to in paragraphs (a) and (b). (environnement)

"HVP" means high vapour pressure as defined in CSA Z662. (HPV)

"incident" means an occurrence that results in

• a) the death of or serious injury to a person;
• b) a significant adverse effect on the environment;
• c) an unintended fire or explosion;
• d) an unintended or uncontained release of LVP hydrocarbons in excess of 1.5 m³;
• e) an unintended or uncontrolled release of gas or HVP hydrocarbons; or
• f) the operation of a pipeline beyond its design limits as determined under CSA Z662 or CSA Z276 or any operating limits imposed by the Regulator. (incident)

"inspection officer" means an inspection officer designated by the Chief Executive Officer under section 102 of the Act. (inspecteur)

"joining" means the joining of pipe and components, performed after the pipe and component manufacturing processes. (assemblage)

"LVP" means low vapour pressure as defined in CSA Z662. (FPV)

"management system" means the system set out in sections 6.1 to 6.6. (système de gestion)

"maximum operating pressure" means maximum operating pressure as defined in CSA Z662. (pression maximale de service)

"onshore pipeline or pipeline" means a pipeline intended for the transmission of hydrocarbons that is not in an offshore area. (pipeline terrestre ou pipeline)

"operate" includes repair, maintain, deactivate, reactivate and decommission. (exploitation)

"release" includes discharge, spray, spill, leak, seep, pour, emit, dump, and exhaust. (rejet)

"serious injury" includes an injury that results in

• a) the fracture of a major bone;
• b) the amputation of a body part;
• c) the loss of sight in one or both eyes;
• d) internal hemorrhage;
• e) third degree burns;
• f) unconsciousness; or
• g) the loss of a body part or function of a body part. (blessure grave)

"station" means a facility that is used in connection with the operation of a pipeline, and includes a facility for pumping, compression, pressure reduction, storage of hydrocarbons, metering, receiving or delivering. It also includes the land and other works connected with the facility. (station)

"storage facility" means a facility that is constructed for the storage of oil and includes the land and other works connected with the facility. (installation de stockage)

"toxic substance" means a substance that enters the environment in a quantity or concentration that may

• a) have an immediate or long-term adverse effect on the environment;
• b) constitute a danger to the environment on which human life depends; or
• c) constitute a danger to human life or health. (substance toxique)

GOAL (Section 1): Provide definitions for terms used in the OPR.

Section 96 of the CER Act provides the CER with the authority to make regulations (subject to the approval of the Governor in Council) governing the design, construction, operation and abandonment of a pipeline and providing for the protection of property and the environment and the safety and security of the public and of the company's employees in the construction, operation and abandonment of a pipeline.

The definition of "pipeline" is provided at section 2 of the CER Act:

"pipeline" means a line – including all branches, extensions, tanks, reservoirs, storage or loading facilities, pumps, racks, compressors, interstation communication systems, real or personal property, or immovable or movable, and any connected works – that connects at least two provinces or extends beyond the limits of a province, Sable Island or an area referred to in paragraph (c) of the definition designated area in section 368 and that is used or is to be used for the transmission of oil, gas or any other commodity. It does not however include a sewer or water pipeline that is used or is to be used solely for municipal purposes.

The term "onshore pipeline" is specifically defined within the OPR to clarify that the OPR applies to pipelines intended for the transmission of hydrocarbons in onshore areas. Onshore areas are generally accepted to be pipelines installed on land above the ordinary high water mark of major water bodies.

The CER has developed the following definition of a "major bone" to assist companies in complying with the reporting requirements set out in section 52 of the OPR:

“major bone”

• skull, mandible, spine, scapula, pelvis, femur, humerus, fibula, tibia, radius, and ulna.

In addition to the terms defined within section 1 of the OPR, the terms "audit", "inspection", "management system", "program", "process", procedure", "plan", "manual", and "practice" appear in the OPR and in this document. For clarity, these terms are generally understood to have the following meanings:

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

inspection

• An on-site and site-specific methodical examination and assessment of a company's construction, operation, or abandonment activities against its regulatory obligations, standards, acceptable industry practice, and the inspector's professional judgment. An inspection focuses on compliance requirements, usually pursuant to an approval condition or regulatory requirement, at an individual facility at a given point in time.

management system

• The system set out in sections 6.1 to 6.6 of the OPR. It is a systematic approach designed to effectively manage and reduce risk, and promote continual improvement. It includes the necessary organizational structures, resources, accountabilities, policies, processes and procedures required for an organization to fulfill all tasks related to safety, security and environmental protection.

manual

• A document that contains a set of instructions on methods which are employed to accomplish a result. These instructions will be detailed and comprehensive. The document will be organized for ease of use.

plan

• A detailed, documented formulation for action to achieve an end.

practice

• A repeated or customary action which is well understood by persons who are authorized to carry it out. Safe work practices are generally written methods outlining how to perform a task with minimum risk to people, equipment, materials, environment, and processes.

procedure

• A procedure indicates how a process will be implemented. It provides a documented series of steps followed in an established order. A procedure includes the identification of roles, responsibilities and authorities required for completing each step.

process

• A documented series of actions taking place in an established order, with identified roles and responsibilities, and directed toward a result. A process includes the roles, responsibilities and authorities for the actions. A process may contain a set of procedures, if required.

program

• A documented set of processes and procedures designed to regularly accomplish a result. A program outlines how plans, processes and procedures are linked, and how each one contributes toward the result. Program planning and evaluation are conducted regularly to check that the program is achieving intended results.

The terms "practical" and "practicable" are used in the OPR and are generally understood to have the following meanings:

practical

• Typically used to describe an activity or function that satisfies a need in the most economical and time expedient manner while considering social and economic factors as well as maintaining safety and the protection of property and the environment.

practicable

• Means that something can and will be done even if it may not be practical.

Acronyms in Guidance Notes

ANSI: American National Standards Institute

CSA: Canadian Standards Association

ESD systems: Emergency shut down systems

ILI: In line inspection

MOP: Maximum Operating Pressure

MSDS: Material Safety Data Sheet

NDE: Non-destructive examination

PPE: Personal protective equipment

SCADA: Supervisory Control and Data Acquisition

Application

GOAL (Section 2): Provide the scope of the application of the OPR.

The OPR applies to onshore pipelines intended for the transmission of hydrocarbons.

GOAL (Section 3): Provide the scope of application of the OPR.

Design and construction requirements within the OPR do not apply to pipelines which, prior to 01 August 1999, were:

• a) in operation;
• b) under construction;
• c) in receipt of an Order authorizing construction; or
• d) in receipt of a Certificate of Public Convenience and Necessity.

They do, however, apply to any modifications, additions and re-testing performed on or made to those pipelines after 01 August, 1999.

The balance of the OPR applies to all onshore pipelines.

General

GOAL (Section 4): Pipelines are designed, constructed, operated and abandoned according to the OPR and appropriate standards.

The word "company" has the same meaning in these Guidance Notes and in the OPR as it does in the CER Act. Thus, the company which holds the Certificate or the Order must follow the OPR. The company must also ensure that all agents, contractors, operators, etc. are aware of and comply with the OPR, follow good safety and environmental practices, and obtain all necessary approvals and permits.

Referenced standards are part of the OPR. Companies may direct questions on interpretation or application of reference standards to the appropriate standards body. The CER is not bound by the interpretation of the standards body but would normally consider this interpretation in providing its own interpretation.

Standards incorporated by reference within the OPR are in force from the date of publication of the standard. Companies should confirm compliance with changes to referenced standards upon their publication.

GOAL (Section 5): Outline the Commission's authority in ordering changes.

GOAL (Section 5.1): A consistent level of safety and protection is provided for all pipelines.

When a company creates any design, specification, program, manual, procedure, measure or plan which is not governed by a standard referenced within the OPR, it must be submitted to the Commission for approval. As a general rule, these documents would be evaluated against existing or relevant standards whenever possible.

Pressure vessels which are owned and operated by a federally regulated pipeline company and which are associated with the operation of the pipeline should be designed, constructed, operated and abandoned in accordance with the CER’s Guidance Notes for the Design, Construction, Operation and Abandonment of Pressure Vessels. This document provides guidance to pipeline companies for the development of a program for the management of pressure vessels.

Boilers which are owned and operated by a federally regulated pipeline company and which are associated with the operation of the pipeline should be designed, constructed, operated and abandoned in accordance with Part V of the Canada Occupational Health and Safety Regulations. The CER has oversight over the regulatory compliance of boilers in accordance with a Memorandum of Understanding between Employment and Social Development Canada and the CER.

GOAL (Section 6): A company meets its obligations for safety, security and protection of the environment when designing, constructing, operating or abandoning a pipeline.

Section 6 is a statement of the purpose of these Regulations, which is to require and enable a company to design, construct, operate and abandon a pipeline in a manner that ensures safety, security and protection of the environment. The company must do this in the course of performing any of its activities under the OPR or authorized under any certificate, order or other approval issued by the CER. A company implements its management system, as required in sections 6.1 to 6.6 of the OPR, to meet these obligations.

Management System

GOAL (Sections 6.1 – 6.4): A company has a management system and programs that enable it to meet its obligations for safety, security and protection of the environment.

Through its management system, a company manages and reduces risk, and continually improves its operations. A carefully-designed and well-implemented management system supports a strong culture of safety and is fundamental to keeping people safe and protecting the environment.

Management systems provide a consistent framework for the design, development and implementation of protection programs, as well as for the cyclical planning, implementation, review and adjustment of operational activities which is essential for a company to effectively address risks, manage its resources appropriately and achieve desired outcomes. To meet the requirements of the OPR, management systems must be formally established and consistently implemented and managed.

Management System (Section 6.1)

• A management system that is explicit, comprehensive and proactive
  
  A management system must be applied consistently throughout the organization, its sites, business units, and any aspect of the organization, in order for it to be a complete management system. A company’s management system must be explicit, comprehensive and proactive; this provides for continual improvement. A description of each of these characteristics is provided below.
  
  Explicit – A company’s management system, and its policies and goals are documented and visible.
  
  Comprehensive – A company’s management system addresses all aspects of a company’s business that may affect safety, security and protection of the environment. This includes areas beyond operational activities such as administrative and support functions, which may also impact safety, security and environmental outcomes (i.e., finance, procurement, human resources).
  
  Proactive – A company’s management system involves planning and foresight that emphasizes hazard identification and anticipation, and risk control and mitigation, before events that affect safety, security and environmental protection occur.
• Integrates operational activities and technical systems with management of human and financial resources
  
  A company integrates operational activities and technical systems with its management of human and financial resources to make sure it is able to achieve safety, security and environmental protection outcomes. This integration recognizes and effectively manages the relationship between traditionally technical issues (e.g., materials selection or training and capacity) and financial or human resource management practices (e.g., purchasing, procurement, recruitment and contracting), both of which may affect safety, security and environmental protection outcomes.
• Applies to all of a company’s relevant activities and programs
  
  A company’s management system applies to the company’s programs for safety, security, integrity, environmental protection, damage prevention and emergency management. For programs to be explicit, comprehensive, and proactive, they must include the requirements in section 6.5. These include processes to identify and analyze hazards and potential hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance. A company’s management system and programs are based on the company’s policies and goals as well as the requirements of the OPR.
  
  The company’s management system applies to all of the company’s activities involving the design, construction, operation or abandonment of a pipeline. For example, when a company plans and designs a pipeline, it uses its hazard assessment process to identify hazards and potential hazards to safety and the environment. The company also uses its risk management process to evaluate and manage risk associated with the identified hazards and potential hazards, and develop the controls included in its proposed project. When a company constructs and operates its pipeline, it applies its management system through its safety management program, its environmental protection program, and the other management programs required by the OPR.
• Coordination between programs
  
  A company’s management system provides coordination between the company’s activities and protection programs. For example, if a hazard is identified through the safety management program, that may also be a consideration in the environmental protection program, this information would be considered in the planning for both programs.
  
• Scalable, corresponding to the nature and scope of a company’s activities
  
  Each company’s management system and its programs are based on its own situation and the activities it conducts, and should systematically address the hazards and risks that may affect it.

Timeframe for establishing a management system: (Subsection 6.1(2))

A company shall establish its management system within 90 days after the day on which the certificate or order authorizing to construct or operate a pipeline is issued under the Act.

This timeframe allows the company to conduct the coordination and communication needed to implement a functioning management system.

Accountable Officer Appointment and Notification (Section 6.2)

A company must appoint an accountable officer who has authority for the financial and human resources of the company required to meet its obligations for safety, security and protection of the environment.

The accountable officer is the person responsible for the company’s management system and related programs (safety, security, integrity, environmental protection, damage prevention, and emergency management).

The accountable officer provides the focus, direction, influence and leadership, which is required to create a robust safety culture, and implement and continually improve a well-functioning management system within the organization. For example, the accountable officer communicates the company’s commitment to its policies and goals to the company’s employees. Corporate culture is driven by the top down and, as a result, engagement and commitment at the most senior level is required to effect change as needed.

The accountable officer is typically the person who holds the most senior position in the company. Based on a company's organizational structure, this person may hold the position of CEO, President, or some other designation. See the CER website, in the Guidance section of the OPR page, under Company Submission Requirements, for a flowchart to assist companies with identifying their accountable officer.

When a company has appointed an accountable officer, within 30 days of the appointment, the company must notify the CER of the name of the person appointed. The OPR also requires the accountable officer to submit a signed statement to the CER accepting the responsibilities of the position.

See the CER website, in the Guidance section of the OPR page, under Company Submission Requirements, for suggested template letters for (i) company notification to the CER that it has appointed its accountable officer, and (ii) the signed statement from the accountable officer.

For further guidance on safety governance, see the Organization for Economic Co-operation and Development’s paper entitled Corporate Governance for Process Safety, Guidance for Senior Leaders in High Hazard Industries (June 2012).

Policies and Goals (Section 6.3)

A company’s commitment to safety, security and environmental protection is stated in its policies, and these policies are the foundation upon which an organization’s management system is based. A company’s goals reflect the direction and desired outcomes of the policies, and provide the basis for a company’s commitment to continual improvement through its management system.

In addition to typical high level goals of zero spills, ruptures, injuries and fatalities, the OPR requires that a company sets goals that contribute to the prevention of ruptures, liquid and gas releases, fatalities and injuries, and for the response to incidents and emergency situations.

A company is required to have a policy and a related process for the internal reporting of hazards, potential hazards, incidents and near-misses. The policy for internal reporting of hazards, potential hazards, near misses and incidents sets the circumstances, in addition to those set out in the Canada Labour Code, under which a person making such a report will be immune from disciplinary action.

This policy is intended to promote the routine practice and enable employees to identify and report hazards, potential hazards, incidents and near-misses they may encounter during work activities, without fear of reprisal. The company’s internal process provides the steps to follow for internal reporting. With this process, the company tracks internal reporting through a data management system in order to continually improve safe operations and its safety culture.

Documented organizational structure (Section 6.4)

In order to have a fully functioning management system, a company must have a documented organizational structure. Determination and communication of roles, responsibilities and governance structure are integral to a well-functioning management system. Up-to-date assessments of human resource needs, and appropriate allocation of human resources, are also critical for safety, security and environmental protection outcomes.

Management System Processes

GOAL (Section 6.5): A company establishes and implements the processes and documentation required for an explicit, comprehensive and proactive management system.

A company’s management system and protection programs contain processes for identifying hazards and potential hazards, evaluating and managing risks, training and managing workers, communicating, managing records and documentation, monitoring and evaluating progress, and continually improving performance.

All processes and procedures, as well as the related documents and lists, are documented. Processes and procedures, and related products, are reviewed on a regular basis and part of continual improvement. Processes and procedures evolve over time as the technology and tools evolve and in response to lessons learned from incidents and near misses.

See the CER website, in the Guidance section of the OPR page, under the 2020 Amendments made to the Onshore Pipeline Regulations, for more a detailed description on the management system changes in section 6.5 (and more).

Annual Report

GOAL (Section 6.6): Companies complete annual reports on the performance of their management system, and document the actions taken to correct deficiencies.

A company must submit to the CER a statement, signed by the accountable officer, that it has completed its annual report, no later than April 30 of each year.

See the CER website, in the Guidance section of the OPR page, under Company Submission Requirements, for a suggested template letter for notification to the NEB of a company’s completion of its annual report.

Design of the Pipeline

GOAL (Section 9): Appropriate designs are developed for all pipelines.

Detailed designs and supporting information demonstrate:

• a) conformance to the requirements established by the company to ensure the design is fit for its intended service;
• b) compliance with applicable regulations, codes, and standards;
• c) consideration of unique design circumstances and specific direction on special or unique requirements as appropriate;
• d) the appropriateness of selected or specified materials for their intended purpose; and
• e) that the design provides for adequate and effective protection of property and the environment, security of the pipeline, and the safety of all persons.

Designs may also include provision for compliance with the environmental protection program referred to within section 48, and other relevant programs required in the OPR.

GOAL (Section 10): An acceptable level of safety for HVP pipelines is provided for in the vicinity of railways and roadways.

For assistance in preparing the documented risk assessment, companies are directed to CSA Z662, Annex B, Guidelines for Risk Assessment of Pipelines. The nature and magnitude of the risk assessment should be commensurate with the nature, magnitude, and potential impact of the associated potential hazards.

GOAL (Section 11): Appropriate design considerations are used for all stations.

Stations should be equipped with security systems to prevent unauthorized entry or operation including remote operation through a SCADA system. Measures to deter mischief or acts of malicious intent could be considered.

Year round access, security, spill containment, waste handling, and noise limits are essential to the safe and environmentally sound operation of a station. Stations should be designed to prevent soil, groundwater and surface water contamination by employing methods and systems such as secondary containment, surface run-off retention ponds, leak detection, spill prevention and loss control programs.

Additional consideration may be given to design features that limit and monitor emissions and/or noise, lighting, emergency egress, confined space, ventilation, electrical classification, etc.

For noise levels, the company should identify any applicable or adopted federal, provincial and municipal legislation and guidelines or, in the absence of legislation and guidelines, the company standard that the facility has been designed to, or would be operated in accordance with, and submit that information to the Commission for approval under section 5.1. The information provided should clearly demonstrate how the facility would be in compliance with the OPR and the company standard.

GOAL (Section 12): Stations can be shut down in a safe and controlled manner in the event of primary power interruption.

Alternate sources of power for essential station systems should be designed so they can be tested periodically and should be in compliance with the requirements of the Canada Occupational Health and Safety Regulations, Part VIII, Electrical Safety.

Emergency shut down (ESD) systems and controls should be designed to provide reliable service under all conditions.

Additional consideration should be given to design features such as lighting, emergency egress, confined space, ventilation, electrical classification, etc.

GOAL (Section 13): Storage facilities are properly located and designed safely.

The location of a storage facility should be chosen so as to maximize employee and public safety, and to minimize environmental damage, including any threats to the quality of soil, surface water and groundwater, environmentally sensitive areas, and the health of humans, animals and plants during the construction, operation, deactivation, or abandonment of the storage facility. General construction considerations for storage facilities must meet the requirements of the applicable standards referred to in section 4.

In order to prevent soil, groundwater and surface water contamination and to protect the environment, the design of storage facilities includes consideration of operating practices mentioned in the applicable standards referred to in section 4. This includes consideration of:

• a) primary containment storage devices complete with integrity monitoring and enhancement features;
• b) secondary containment systems;
• c) leak detection systems;
• d) spill prevention;
• e) loss control programs (including fire suppression);
• f) weather protection systems;
• g) operating procedures;
• h) integrity management;
• i) nuisance noise and odours;
• j) environmental risk;
• k) groundwater monitoring programs; and
• l) documentation and records control.

Storage facilities may have site specific operating procedures and integrity management requirements.

Materials

GOAL (Section 14): Pipe and components are appropriate for their intended service.

Specifications should include, but are not limited to, the following:

• a) a description of the item and the limits for which the specification applies (e.g., diameter range, thickness, service, pressure range/ANSI rating, etc.);
• b) a reference to required conformances (e.g., to applicable reference standards respecting the design and manufacture of the item);
• c) material requirements at variance with those required by applicable reference standards (e.g., specifications which require a more stringent tolerance than that which is provided by the standard);
• d) test requirements at variance with those required by applicable reference standards;
• e) any additional requirements based on different types of service;
• f) quality control requirements for the vendor or manufacturer;
• g) coating requirements (e.g., type, thickness, application processes, test requirements, conformances, etc.);
• h) marking requirements at variance with those required by applicable reference standards;
• i) shipping requirements; and
• j) required documentation.

GOAL (Section 15): Pipe and components meet the specifications developed under section 14.

The purpose of a quality assurance (QA) program for pipe and components is to confirm that materials purchased by the company meet the company's specified requirements. The rigour of the QA program is commensurate with the scale of the order and its intended application. QA programs should be comprised of the elements of a recognized standard, such as the ISO 9000 series of QA standards, and should include:

• a) requirements for pipeline company (or their agents) evaluation of the manufacturer's or supplier's quality management system prior to the award of any contract;
• b) requirements for company (or their agents) audits and inspection during manufacture and fabrication, shipping, storage, etc.;
• c) requirements for random and progressive product testing;
• d) inspection procedures and inspector qualifications;
• e) requirements for handling and review of documentation;
• f) a system for managing non-conformances to specifications; and
• g) procedures for company acceptance of products.

Pipeline companies should consider the history of compliance and satisfactory product performance when developing programs aimed at ensuring that products from specified manufacturers or suppliers are acceptable for their intended purpose.

Joining

GOAL (Section 16): Joining is designed and conducted in a manner that will ensure quality and integrity.

The joining program shall meet the requirements of the applicable standards referred to in section 4 and should include a description of:

• a) the joining procedure specifications;
• b) the requirements for the qualification of joining procedures;
• c) the requirements for the qualification of joiners;
• d) the requirements for the qualification and duties of joining inspectors;
• e) the number of joining inspectors that will be employed (the number of joining inspectors should be sufficient to visually inspect all welds; this number may fluctuate with daily productivity);
• f) the non-destructive examination procedures;
• g) the requirements for the qualification of the personnel engaged in non-destructive examination;
• h) the standards of acceptability of imperfections;
• i) the procedures for the repair or removal of defects associated with or resulting from the joining process; and
• j) documentation requirements.

Pertinent sections of the joining program could be:

• a) available on site whenever joining is taking place;
• b) readily accessible to welders and welding inspection personnel;
• c) available within company offices; and
• d) maintained as part of the permanent record of the pipeline construction.

The aforementioned guidance pertains primarily to welded steel pipelines. Joining programs are required for all types of materials and joining methods (i.e., mechanical joints, heat fusion, threaded joints, etc.).

GOAL (Section 17): The integrity of each welded joint is confirmed.

This section applies only to welded steel joints.

The OPR requires that all pipeline joints be examined non-destructively. This includes butt welds, fillet welds, and branches.

Because the geometry of certain weld types makes inspection by radiography or ultrasonics impractical, Order MO-08-2000 was issued on April 28, 2000. The Order pertains to all federally regulated pipeline systems, and provides that another appropriate non-destructive examination method may be employed if a radiographic or ultrasonic method is not practicable in the particular circumstances. The Order also requires that companies document the methods used and the inspection results, and also clarifies that the use of a visual method as a means of non-destructive examination is not permitted under the terms of the Order.

Section 17 and Order MO-08-2000 apply only to the joining of pipe and components performed after the manufacturing processes associated with fabrication of the pipe within the pipe mill and the fabrication of components within the manufacturer's facilities. As a matter of clarification, neither section 17 nor Order MO-08-2000 apply to the welded assembly of storage tanks forming part of the pipeline system.

Girth welds performed within pipe mills are not considered to be part of the manufacturing process (within the context of the "joining" definition in section 1 of the OPR), and are therefore subject to the terms of the Order.

Order MO-08-2000 also provides case-specific exemptions, which have been made for certain specific auxiliary piping systems associated with stations.

Variations from section 17 and Order MO-08-2000 are permitted only in cases where a project-specific exemption order has been issued. A request for exemption from the terms of Order MO-08-2000 may include:

• a) a description of the specific joints for which an exemption is being sought;
• b) the proposed alternatives for quality assurance of completed joints if an exemption is granted;
• c) the rationale for seeking an exemption; and
• d) a discussion of risk considerations including such factors as location and service fluids.

Construction

GOAL (Section 18): Construction activities are conducted in a safe manner.

The company and contractor responsibilities for safety and regulatory compliance should be clearly defined at the beginning of a project. A company must instruct contractors in all relevant practices and procedures pertaining to their work prior to commencing construction activities. The company informs contractors about, and contractors should be aware of:

• a) the contractor’s responsibilities in relation to the processes and procedures required by the management system provisions in paragraph 6.5(1)(l) of the OPR;
• b) the requirements as set out in the construction safety manual;
• c) safety reporting requirements;
• d) a description of the project specific safety management structure;
• e) a listing of pertinent federal and provincial legislation; and
• f) project specific hazards as well as safety commitments/requirements.

GOAL (Section 19): Pipelines are constructed in a safe and environmentally responsible manner.

By their very nature, construction activities may pose a risk to persons associated with or near the activities as well as to property and the environment.

Everyone at a worksite should be aware of the practices and procedures necessary for their safety as well as the safety of others. At least one person at the worksite should be knowledgeable of potential environmental impacts associated with the construction activity and any appropriate management and mitigation measures.

Paragraph 6.5(1)(q) of the OPR requires a company to have a process for coordinating and controlling the operational activities of employees or contractors so that they are able to work in a manner that is safe, ensures the security of the pipeline, and protects the environment.

GOAL (Section 20): A comprehensive construction safety manual is developed, kept current, and is readily accessible.

A company’s construction safety manual must contain the relevant information and procedures outlined in the standards referenced in section 4 of the OPR, and should include, but is not limited to, the following:

• a) the safety related responsibilities of company and contractor managers, supervisors, and workers;
• b) a description of the method or program established by the company to fulfill its responsibilities under sections 18 and 19;
• c) the safety practices and procedures to be followed in the construction of the pipeline;
• d) the name(s) or position(s) of the person(s) with suitable qualifications responsible for safety inspections during pipeline construction;
• e) the name(s) or position(s) of the person(s) authorized to halt a construction activity under the requirement of paragraphs 18(d);
• f) the company’s policy for the internal reporting of hazards, incidents and near misses, and the process for the reporting of such matters; and
• g) any other relevant processes and requirements from the company’s management system, safety management program, and other programs, related to construction activities.

Companies are expected to submit their construction safety manual to the CER at least four weeks prior to anticipated start of construction activities. Practices set out in the construction safety manual should meet applicable federal and provincial occupational health and safety requirements.

The contents of the construction safety manual should be shared and understood by all appropriate parties. The company’s environmental protection plan should also be available at the work site and its requirements shared and understood by all appropriate parties.

For additional guidance, companies are referred to the Safety Guide for Pipeline Construction in Canada, issued by the Pipe Line Contractors Association of Canada.

GOAL (Section 21): Land affected by pipeline construction is restored to pre-construction conditions to the extent practicable.

Restoration to pre-existing conditions may not be practical under all circumstances. For example, rights-of-way through forested areas which have been cleared to provide construction access may have to be kept partially cleared to provide access for emergency and maintenance operations.

The success of restoration efforts should be evaluated by a quantitative and qualitative comparison similar to surrounding undisturbed areas.

GOAL (Section 22): Minimize and avoid, to the extent practical, any disruption with the use of a utility or road during pipeline construction.

The definition of "utility" is provided at Section 217 of the CER Act:

• "utility" means a highway, an irrigation ditch, a publicly owned or operated drainage system, sewer or dike, an underground telecommunications line or a line for the transmission of hydrocarbons, electricity or any other substance.

For additional requirements concerning crossing matters, companies are directed to the Canadian Energy Regulator Damage Prevention Regulations – Authorizations and the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies, and the related CER guidance document Construction Near Pipelines.

Pressure Testing

GOAL (Section 23): An acceptable pressure testing program is developed that, when followed, will assist in proving the integrity of the pipeline.

The pressure testing program must meet the requirements of the applicable standards referred to in section 4 and should include, but is not limited to, the following:

• a) a diagram of the test section together with an elevation profile and the location of all measurement points and instrumentation;
• b) the specifications of the pipe and components of the pipeline to be tested;
• c) a description of the instruments to be used, the degree of accuracy, and the calibration data and certificates of those instruments;
• d) the procedures to be used during line filling, pressurization, depressurization, dewatering, and the associated environmental protection procedures to be implemented;
• e) an identification of the test medium and any additives;
• f) the test duration;
• g) the minimum and maximum permitted test pressures;
• h) the standards of acceptability;
• i) a description of the safety precautions to be implemented during the pressure test;
• j) test head assembly pressure testing and non-destructive examination requirements;
• k) an assessment of the design compliance of the test heads; and
• l) the measures to be taken for the protection of property, the environment and the safety of persons in the event of a rupture during testing.

The standards referred to within section 4 permit the use of various test fluids under specific conditions. Usually, hydrotesting should be performed when pressure testing pipelines. Any proposal to use alternative fluids (such as air) should be based on recognized engineering principles. The sensitivity and reliability of any test using an alternative test fluid should be compared to that of a hydrotest.

GOAL (Section 24): Hydrostatic test water use and disposal are adequately addressed.

Companies are directed to federal, provincial, and local authorities to determine their specific requirements for water use and disposal. For assistance with developing a plan for water use and disposal when conducting a pressure test, companies are directed to the guidelines for Hydrostatic Test Water Management Guidelines jointly sponsored by the Canadian Association of Petroleum Producers and the Canadian Energy Pipeline Association.

GOAL (Section 25): Pressure testing is conducted objectively.

GOAL (Section 26): As many girth welds as practicable are subjected to the required pressure test.

Operation and Maintenance

GOAL (Section 27): Comprehensive operation and maintenance manuals are developed, kept current and are readily accessible.

A company’s operation and maintenance manual must contain the relevant information and procedures outlined in the standards referenced in section 4. A company’s operation and maintenance manual should include, but is not limited to, the following:

• a) the elevation profile for pipelines containing liquid hydrocarbons;
• b) the operating limits of the pipeline and the method for maintaining these limits under all operating conditions;
• c) an accurate and current listing of materials and the associated Material Safety Data Sheets (MSDS) for product(s) transported in the pipeline or associated with the operation and maintenance of the pipeline;
• d) the policies and procedures for accident prevention and fire protection;
• e) the policies and procedures for response and investigation of incidents and emergencies;
• f) the safety related responsibilities of company and contractor managers, supervisors, and workers;
• g) operator duties and responsibilities (e.g., shift change, visual checks, coordination with gas controller, tasks list);
• h) personal protective equipment (PPE) requirements;
• i) management of change process and procedures;
• j) procedures for failure analyses and investigations;
• k) procedures for repairs and maintenance activities including precautions to be taken in the event of product release during these activities;
• l) practices and guidance on communications with media and the public;
• m) environmental and safety implications of the release of product or chemicals referred to in (c);
• n) the company’s policy for the internal reporting of hazards, incidents and near misses, and the process for the reporting of such matters; and
• o) any other relevant processes from the company’s management system, safety management program, and other programs, related to operations and maintenance activities.

GOAL (Section 28): Persons associated with operation activities are aware of all operations practices and procedures and aware of applicable information contained in the operations and maintenance manuals.

It is the company’s responsibility to inform those who are associated with operations and maintenance activities on the pipeline of the applicable information contained in the operations and maintenance manuals. Paragraph 6.5(1)(m) of the OPR requires companies to implement a process for internal and external communication of information relating to safety, security and protection of the environment.

GOAL (Section 29): Maintenance activities are conducted in a safe manner.

The company and contractor’s responsibilities for safety and regulatory compliance should be clearly defined and communicated. A company must instruct contractors in all relevant practices and procedures pertaining to their work prior to commencing maintenance activities. The company informs contractors about, and contractors should be aware of:

• a) the contractor’s responsibilities in relation to the processes and procedures required by the management system provisions in paragraph 6.5(1)(l) of the OPR;
• b) the requirements as set out in the maintenance safety manual;
• c) safety reporting requirements;
• d) a description of the project specific safety management structure;
• e) listing of pertinent federal and provincial legislation; and
• f) maintenance specific hazards as well as safety commitments/requirements.

GOAL (Section 30): The public and the environment are protected during maintenance activities.

By their very nature, maintenance activities may pose a risk to persons associated with or near the activities, as well as to property and the environment.

Everyone at a worksite should be aware of the practices and procedures necessary for their safety as well as the safety of others. At least one person at the worksite should be knowledgeable of potential environmental impacts associated with the maintenance activity and any appropriate management and mitigation measures.

Paragraph 6.5(1)(q) of the OPR requires that a company has a process for coordinating and controlling the operational activities of employees or contractors so that they are able to work in a manner necessary for safety, security of the pipeline and protection of the environment.

GOAL (Section 31): Specific safety procedures are in place and are made available to all applicable personnel.

A maintenance safety manual contains specific safety procedures and is available to all applicable personnel. The company documentation should include, but is not limited to:

• a) the safety related responsibilities of company and contractor managers, supervisors, and workers;
• b) the safety practices and procedures to be followed in the maintenance of the pipeline;
• c) the name(s) or position(s) of the person(s) with suitable qualifications responsible for safety inspections during pipeline maintenance activities where applicable;
• d) the company’s policy for the internal reporting of hazards, potential hazards, incidents and near misses, and the process for the reporting of such matters; and
• e) any other relevant processes and requirements from the company’s management system, safety management program, and other programs, related to maintenance activities.

GOAL (Section 32): Management of, and response to, emergencies is achieved through the development, implementation and maintenance of an emergency management program.

An emergency management program manages and mitigates the risks and effects of incidents and emergencies that could adversely affect property, the environment or the safety of workers or the public.

An emergency management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the emergency management program. In order for an emergency management program to be explicit, comprehensive, and proactive, it must include the management system processes referenced at section 6.5 of the OPR. This includes processes to identify hazards and potential hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the emergency management program, and the company’s programs for safety, security, integrity, damage prevention, and environmental protection.

The emergency management program must meet the requirements of section 4 of the OPR. A company’s emergency management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the emergency management program, with a maximum interval of three years.

Further information on an emergency management program, including hazard assessment, the emergency procedures manual, agency liaison, communications, continuing education, emergency response processes and capability, emergency response exercises and equipment is provided in Annex A.

Emergency Procedures Manual

A company’s emergency management program includes an up-to-date emergency procedures manual that is filed with the CER. An emergency procedures manual includes roles and responsibilities in the event of an emergency, response procedures, contact lists and relevant documentation including contact lists, maps, agreements, and forms and records.

Further information on the emergency procedures manual is provided in section 2 of Annex A.

GOAL (Section 33): All applicable agencies are aware of the contents of the Emergency Procedures Manual.

A company’s emergency management program includes liaison with all agencies that may be involved in an emergency situation. A company should identify the parties with whom liaison is required, develop a consultation process, and incorporate the results of consultation into its emergency management planning and emergency procedures manual.

Further information on agency liaison is provided in section 4 of Annex A.

GOAL (Section 34): All applicable parties are prepared to respond to emergency situations.

A company’s emergency management program includes communicating relevant practices and procedures to all persons who may be associated with an emergency response activity.

Further information on communications for emergency response is provided in section 5 of Annex A.

GOAL (Section 35): All appropriate parties are aware of the potential emergency situations and their specific roles and responsibilities.

A company’s emergency management program includes continuing education for the police, fire departments, medical facilities, all appropriate agencies, organizations and the public adjacent to their pipeline. A company should inform these parties of the:

• location of the facilities;
• potential emergency situations (e.g., hazards); and
• procedures to be followed in the case of an emergency (e.g., methods and timing of communication during an emergency, circumstances and procedures for sheltering and evacuation).

Further information on continuing education for emergency response is provided in section 6 of Annex A.

GOAL (Section 36): Safe operation of facilities on the pipeline.

GOAL (Section 37): Pipeline operating parameters are being adequately monitored.

GOAL (Section 38): Appropriate welding procedures are employed which prevent cold cracking in steels with high carbon equivalents.

The potential for delayed hydrogen cracking increases proportionally with the carbon equivalent of the base materials to be joined. This effect may be compounded by the quenching effects of flowing liquids within the pipeline on weld deposits placed on the surface of in-service pipelines. Weld hardness is typically used as one indicator of susceptibility of a weld to cracking.

Companies should refer to CSA Z662 for additional information on the development of welding procedures and the qualification of welders for in-service welding on liquids (and gas) pipelines.

GOAL (Section 39): Protection of the pipeline, the public, and the environment is achieved during the operation of the pipeline through the development and implementation of a surveillance and monitoring program.

The surveillance and monitoring program must meet the requirements of sections 40 and 48 and the applicable standards referred to in section 4.

For the purposes of this section, monitoring is defined as ongoing observations made on a regular basis to confirm that pipeline operation is within defined normal parameters. Surveillance may be defined as an aspect of monitoring, focused on certain parameters during periods of activity (construction, operation, and abandonment).

A monitoring program is aimed at the identification of any issues or potential concerns that may compromise the protection of the pipeline, property, persons and the environment (e.g., pipeline integrity or erosion, security, etc.). It includes methods for developing measures to prevent or mitigate the impact of the identified issue(s). The program also provides for follow-up monitoring of sites where mitigative measures have been undertaken to determine their success or failure, a system for implementing additional mitigative measures as necessary and a feedback system that allows for adaptation of successful mitigation to future pipeline projects.

Surveillance is a component of the monitoring program that focuses on the frequency and methods of surveillance of the pipeline. This includes ensuring employees use approved safety procedures, contractors are adhering to the environmental requirements of a task, encroachments upon rights-of-way are detected, construction activities are known, etc.).

Surveillance and monitoring programs should include, but are not limited to, the following:

• a) aerial and terrestrial patrols;
• b) pipeline pigging;
• c) soil-to-pipe surveys;
• d) crossing inspections;
• e) construction and operation inspections;
• f) pressure testing;
• g) purchased material inspections;
• h) class location surveys;
• i) erosion monitoring;
• j) slope stability monitoring;
• k) health or occupational exposure monitoring; and
• l) relevant environmental practices, such as those for the management of:
  • i. materials storage and waste;
  • ii. vegetation;
  • iii. soil quality;
  • iv. air quality;
  • v. noise;
  • vi. wildlife and wildlife habitat;
  • vii. water quality and aquatic resources; and
  • viii. heritage resources (including traditional land use).

Monitoring programs should have specific goals and targets and could include methods for the evaluation and interpretation of collected data.

GOAL (Section 40): Pipeline integrity is achieved through the development, implementation and maintenance of an integrity management program.

A company’s integrity management program is designed to identify hazards and potential hazards, and manage risks so that pipelines are suitable for continued safe, reliable and environmentally responsible service. Key features of a company’s integrity management program that provide for this outcome include hazard and consequence identification, evaluation and continuous monitoring, mitigation and record keeping related to the location and functioning of the pipeline.

An integrity management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the integrity management program. In order for an integrity management program to be explicit, comprehensive, and proactive, it must include the management system processes referenced at section 6.5 of the OPR. This includes processes to identify hazards and potential hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the integrity management program, and the company’s programs for safety, security, environmental protection, damage prevention, and emergency management.

The integrity management program must meet the requirements of section 4 of the OPR. A company’s integrity management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the integrity management program, with a maximum interval of three years.

Further information for integrity management programs is provided in Annex B.

GOAL (Section 41): Pipeline defects and corrective actions are adequately documented.

Records for defect repairs should include:

• a) date, time, and location at which the defect was detected;
• b) type of defect;
• c) method by which the defect was detected;
• d) defect assessment methods;
• e) defect repair methods and rationale; and
• f) date, time, and location of the repair.

In evaluating any defect, consideration should be given to the mechanism or nature of the defect and the possibility of its recurrence under similar conditions. Manufacturing defects may be systemic.

GOAL (Section 42): Public safety is maintained as class location factors decrease.

The plan should:

• a) identify what changes in circumstances have occurred;
• b) identify potential concerns resulting from the change in circumstances; and
• c) describe the mitigative actions where applicable, to address potential concerns.

See the CER’s Filing Manual Guide E for submission requirements concerning this section of the OPR. The CER’s Filing Manual was updated in January 2020 to clarify that companies need to report any change in class location to a higher designation and submit the proposed plan to deal with the change to the CER.

GOAL (Section 43): Adequate levels of safety are maintained for any change of service or increase in Maximum Operating Pressure.

A change of service occurs when the fluids being transported by the pipeline are changed. CSA Z662 defines "service fluid" as "the fluid contained, for the purposes of transportation, in an in-service pipeline system".

A change in pressure of the pipeline contents below maximum operating pressure may not constitute a change in service. However, if there are pressure restrictions (voluntary or Commission imposed) in place, or a company intends to increase the operating pressure of a pipeline that has historically operated well below its maximum operating pressure, then the Commission should be consulted to determine if an application is required. The Commission should also be consulted for a change in flow direction and any associated changes involving equipment or facilities.

Any application for a change in service or change in maximum operating pressure must meet the minimum requirements as set out in CSA Z662. See the CER’s Filing Manual for application requirements concerning this section of the OPR.

GOAL (Section 44): Deactivation of a pipeline is carried out in a safe and environmentally responsible manner.

Deactivation is defined in section 1 of the OPR as meaning "to remove temporarily from service". The definition of "pipeline" in the CER Act applies to the OPR and therefore this section applies to portions of the pipeline other than line pipe that are not being maintained for peak flow, standby (ready for immediate use), or emergency use. In practice, it is accepted that portions of pipeline, though maintained in a deactivated state, may never be returned to service, or may be maintained in a deactivated state for an unspecified length of time. Cathodic protection continues to be required for a deactivated pipeline. This status may ultimately be addressed in an application to abandon the operations of the pipeline.

Deactivation may impose a higher level of risk to the integrity of the pipeline depending on the measures specified for the maintenance of the deactivated pipe.

Deactivation of pipelines may impact upstream and downstream users of the pipeline. A company proposing deactivations could consider using a consultative approach similar to that which is used for applications made pursuant to section 214 of the CER Act.

Applications for deactivation pursuant to section 44 should include:

• a) a schedule outlining when the deactivation is planned for completion;
• b) a complete description of the activities associated with the deactivation; and
• c) an estimate of the costs associated with the proposed deactivation.

Approvals of applications for deactivation may be subject to conditions and will normally include a requirement for periodic status reporting.

If deactivation results in a suspension of service, an application pursuant to either section 239 or 240 of the CER Act may also be required. See the CER’s Filing Manual for application requirements concerning this section of the OPR.

GOAL (Section 45): Reactivation of a pipeline is carried out in a safe and environmentally responsible manner.

The contents of the Guidance Note for section 44 should also be applied to applications pursuant to section 45. See the CER’s Filing Manual for application requirements concerning this section of the OPR.

GOAL (Section 45.1): Decommissioning of a pipeline is carried out in a safe and environmentally responsible manner.

Decommissioning is defined in section 1 of the OPR as meaning "to permanently cease operation such that the cessation does not result in the discontinuance of service". For guidance on decommissioning, see the CER’s Guidance Notes for Decommissioning Provisions. See the CER’s Filing Manual for application requirements concerning this section of the OPR.

GOAL (Section 46): Employees are trained in the applicable safety and operating procedures required to conduct their duties.

The training program for day-to-day operations should include the following:

• a) the general objectives of the training program;
• b) the policies and procedures of the training program;
• c) the types and format of training;
• d) a description of the testing methods and practical (mock, simulated or table-top) exercises, and their frequency; and
• e) a means of ensuring the effectiveness of the training.

The training program for day-to-day operations is part of the company’s training process as required in paragraphs 6.5(1)(j) and (k) of the OPR.

Training programs are directed toward the construction and operation of pipelines to enable employees and other persons working with or on behalf of the company to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment.

GOAL (Section 47): Safety is achieved through the development, implementation and maintenance of a safety management program.

Safety management is an organizational function that strives to continually identify hazards and potential hazards and to evaluate associated safety risks through a systematic approach that includes the necessary organizational structure, accountabilities, policies, and procedures, measures and monitoring, and continual improvement efforts. A safety management program identifies hazards, potential hazards and risks associated with operational activities in order for an organization to proactively reduce or eliminate unsafe conditions and activities by improving the related organizational influences such as the prescribed resources, processes, procedures and controls. Safety management programs are designed to address systemic safety vulnerabilities before they result in an active failure. They are also designed to capture changing conditions that introduce new hazards and risks.

A safety management program is focused on all hazards that have the potential to cause harm to the public, workers, and contractors. Safety management is designed to eliminate or reduce risk to the public, workers, the environment and assets. For this reason, there is a strong relationship between safety management and organizational programs related to security, emergency management, environmental protection, integrity, and damage prevention.

A safety management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the safety management program. In order for a safety management program to be explicit, comprehensive, and proactive, it must include the management system processes referenced at section 6.5 of the OPR. This includes processes to identify hazards and potential hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the safety management program, and the company’s programs for security, integrity, environmental protection, damage prevention, and emergency management.

For additional requirements concerning damage prevention for facilities, companies are directed to the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations and the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies, and the related CER guidance document Construction Near Pipelines.

The safety management program must meet the requirements of section 4 of the OPR. The CER is also responsible for verifying compliance with and enforcing Part II of the Canada Labour Code, which applies to the occupational safety and health of pipeline workers. A company’s safety management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the safety management program, with a maximum interval of three years.

GOAL (Section 47.1): Pipeline security is achieved through the development, implementation and maintenance of a security management program.

A company’s security management program is designed to identify hazards so that the risk of the facility or facilities is adequately and appropriately addressed and that the facility or facilities are being protected. When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company must ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of CSA Z246.1.

CSA Z246.1 provides a framework to protect energy infrastructure from malicious damage through risk-based and performance-based management processes. A company’s security management program is based on factors such as type, size, location and criticality of the assets being protected. A company makes decisions based on their internal assessment of risk related to their facility. CSA Z246.1 was developed to be scalable, enabling it to be used by both small operators and large companies.

A security management program is based on the relevant policies and goals set by the company.

A company’s management system applies to the security management program. In order for a security management program to be explicit, comprehensive, and proactive, it must include the management system elements referenced at section 6.5 of the OPR. This includes processes to identify hazards and potential hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the security management program, and the company’s programs for safety, integrity, environmental protection, damage prevention, and emergency management.

The security management program must meet the requirements of section 4 of the OPR. A company’s security management program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the security management program, with a maximum interval of three years.

Further information for companies on pipeline security can be found on the CER website, under Security.

GOAL (Section 47.2): Safety of people and protection of the environment is achieved through the development, implementation and maintenance of a damage prevention program.

A company must proactively identify hazards and potential hazards and manage the related risks for its pipelines that may be introduced by ground disturbance activities, the construction of facilities near its pipelines, and vehicle crossings over its pipelines.

A company’s damage prevention program is developed to anticipate, prevent, and mitigate conditions that have the potential to adversely affect the safety of people who live and work around federally regulated facilities, thereby managing safety, security and environmental risks throughout the lifecycle of the pipeline.

A company’s damage prevention program must be based on the requirements found in both the OPR and the framework contained in the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations and the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

As part of its damage prevention program, a company is required to: have a public awareness program; monitor land use and land ownership changes near its pipeline(s); have processes for timely responses to locate requests and for managing requests for consent under the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations; and have standards for locating pipes. For details related to the damage prevention program requirements, see section 16 of the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

A company’s damage prevention program is based on the relevant policies and goals set by the company as required by sections 6.3 and 6.5 of OPR.

A company’s management system applies to the damage prevention program. For a damage prevention program to be explicit, comprehensive, and proactive, it must include the management system elements referenced at section 6.5 of the OPR. This includes processes to identify and analyze hazards and potential hazards, manage risks, train and manage workers, communicate with those who live and work around the pipeline, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the damage prevention program, and the company’s programs for safety, environmental protection, security, integrity and emergency management.

Companies are encouraged to examine each section of the OPR for applicability to their damage prevention programs. Note that a company’s damage prevention program will also consider and integrate many other aspects of the OPR, such as those addressed in sections 18, 21, 22, 27, 29, 32 – 35, 39, 42, 46, and 54.

Damage prevention programs are closely tied to the emergency management requirements in the OPR. Specifically, sections 32 through 35 of the OPR contain requirements for pipeline companies with respect to an emergency management program, emergency preparedness and response, continuing education and liaison, and section 39 contains monitoring and surveillance requirements. These requirements should form part of a company’s damage prevention program.

The damage prevention program must meet the requirements of section 4 of the OPR. A company’s damage prevention program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the damage prevention program, with a maximum interval of three years.

GOAL (Section 48): Protection of the environment is achieved through the development, implementation and maintenance of an environmental protection program.

A company proactively manages environmental hazards and effects and systematically tracks its environmental performance through its environmental protection program. Program components are developed to anticipate, prevent, and mitigate conditions that have the potential to adversely affect the environment, thereby managing environmental risk throughout the lifecycle of the pipeline.

A company’s environmental protection program is based on the relevant policies and goals set by the company.

A company’s management system applies to the environmental protection program. For an environmental protection program to be explicit, comprehensive, and proactive, it must include the management system elements referenced at section 6.5 of the OPR. This includes processes to identify hazards and potential hazards, manage risks, train and manage workers, communicate, manage records and documentation, monitor and evaluate progress and continually improve performance.

A company’s management system provides coordination between the environmental protection program, and the company’s programs for safety, security, integrity, damage prevention and emergency management.

The environmental protection program must meet the requirements of section 4 of the OPR. A company’s environmental protection program must follow the compliance requirements of sections 53 and 55 of the OPR. This includes the requirement to conduct regular internal audits of the environmental protection program, with a maximum interval of three years.

Note that an environmental protection program will also consider and integrate many other aspects of the OPR, such as those addressed in sections 21, 24, 27, 39, 46, and 54.

GOAL (Section 49): Describe the Commission’s authority to require pipeline assessments in order to confirm that pipelines are operated and maintained in a safe and environmentally responsible manner.

Abandonment

GOAL (Section 50): Abandonment of pipelines is done in a safe, efficient and environmentally responsible manner.

"Abandon" is defined in section 1 of the OPR as meaning "to permanently cease operation such that the cessation results in the discontinuance of service". Pursuant to section 241 of the CER Act, an application is required when a company is seeking leave from the Commission to abandon the operation of a pipeline. An application for abandonment of a pipeline requires a public hearing.

Facility owners and operators are responsible for the retirement of facilities and reclamation of the right of way as well as any liabilities arising from those facilities post-retirement. See the CER’s Principles for the End State of Land Post-Retirement and Next Steps [Filing A22297] when planning for abandonment of a facility.

The CER’s process for abandonment includes the company’s abandonment plan, which addresses safety and environmental matters, as well as consultation requirements.

See the CER’s Filing Manual for application requirements concerning this section of the OPR.

For additional information, refer to the following CER documents:

• Pipeline Abandonment - A Discussion Paper on Technical and Environmental Issues
• Remediation Process Guide

Reporting

GOAL (Section 51): The CER is aware of potential or actual effects associated with a pipeline crossing a utility or a private road.

A company must notify the CER of the details of unplanned interruption of a utility or private road during pipeline construction. In addition to the requirements of section 51, companies should be aware of the contents of the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations and the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

The CER has published a document entitled Pipeline Damage Prevention – Ground disturbance, Construction and Vehicle Crossings, which provides guidance for the understanding of and compliance with the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations and the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies.

GOAL (Section 52): Companies provide timely and factual reporting of all incidents.

The CER has developed a web-based Online Event Reporting System (OERS) that regulated companies are required to use to report events under the regulations administered by the CER. The OERS guides the reporter through the reporting process, and asks for all of the required information. The report is done in two stages – the preliminary report which should be submitted immediately and contains the basic information regarding the event, and the final report which provides more fulsome information surrounding the event or incident.

Audits and Inspections

GOAL (Section 53): Companies implement effective inspection and audit processes to continually improve their management system and programs, and to ensure regulatory compliance.

Audits

A company must have a documented process for conducting audits of their programs and systems.

The responsibility for managing audits should be assigned to qualified individuals with a knowledge of audit principles and techniques and management skills relevant to the activities being audited.

Audits are conducted with a maximum interval of three years to verify compliance with internal programs and systems, and compliance with regulatory requirements. Audits should include any aspect of the pipeline lifecycle (design, construction, operations, abandonment) that is occurring at the time of the audit. For additional audit requirements, see section 55.

An audit report is required that documents findings and recommendations. The audit report and audit records must be maintained as per section 56 and should be available to CER auditors upon request.

Audits should be carried out by company employees or third parties provided they are independent of the activities being audited.

A company must have a process for conducting audits as part of its quality assurance program (paragraph 6.5(1)(w) of the OPR). The audit process should include, but is not limited to, the following:

• a) activities and areas to be covered in audits (scope and objectives);
• b) frequency of audits;
• c) responsibilities associated with managing and conducting audits;
• d) communication plan for audit results;
• e) auditor competency requirements;
• f) audit procedures;
• g) how corrective actions and follow up will be undertaken;
• h) records and reporting requirements; and
• i) management review.

Inspections

Paragraph 6.5(1)(u) of the OPR requires that a company has a process for conducting inspections and monitoring the company’s activities to evaluate the adequacy and effectiveness of its programs, and for taking corrective and preventive actions if deficiencies are identified. The inspection process should include, but is not limited to, the following:

• a) documented procedures for conducting inspections during the construction and operation of the pipeline (including the number and type of inspectors, reporting requirements, etc.);
• b) documentation outlining the roles, responsibilities, qualifications, duties and tasks of inspectors; and
• c) documented schedules for post construction inspections and or regular monitoring and surveillance program as per section 39.

The inspector must be independent of the contractor and must have the authority to shut work down pursuant to paragraph 18(1)(d).

GOAL (Section 54): Qualified inspectors are employed to monitor construction activities.

Inspection is defined as the surveillance and assessment of compliance of activities associated with the construction of a pipeline. Qualified inspectors must be employed to monitor construction activities. Typical inspection activities include:

• a) construction activity inspection;
• b) welding inspection;
• c) environmental inspection; and
• d) safety inspection.

Typically, non-destructive examination (NDE) is performed by an independent contractor retained by the company. Often, the company will perform an additional level of inspection by subjecting the results of NDE to a random audit performed by qualified persons. In cases where the contractor performing NDE has been retained by the construction contractor, the company must provide independent inspection of NDE results.

GOAL (Section 55): Companies conduct audits for key programs with a maximum audit cycle of three years.

Although audits can be designed to be all-encompassing, the following key programs must be addressed in a company’s audit or audits:

• Emergency management program
• Integrity management program
• Safety management program
• Security management program
• Environmental protection program
• Damage prevention program

A company’s audit or audits of these programs must be conducted with a maximum audit cycle of three years.

In accordance with a company’s management system, documents prepared following the audit shall include any deficiencies noted and any corrective action taken or planned to be taken.

Record Retention

GOAL (Section 56): Appropriate records are maintained.

Paragraph 6.5(1)(p) of the OPR requires that a company has a process for managing its records. The related record management system should outline what, when, and how appropriate records are to be created, stored, retrieved, modified, and removed (when no longer valid) in a timely manner. Companies are to maintain other appropriate records at pertinent locations to capture relevant reviews, analyses, and decisions made during the implementation of company programs.

A record management system should provide sufficient documentation to demonstrate a company’s due diligence as well as the adequacy and effectiveness of its programs in ensuring the safety and security of persons and for the protection of property and the environment during the design, construction, operation, and abandonment of its pipelines.

Annexes

Annex A. Further Information for Emergency Management Program

Annex A. provides further information for a company’s emergency management program (OPR sections 32-35).

1. Hazard Assessment

A company’s hazard assessment process for its emergency management program should include, but is not limited to:

• plume dispersion or similar dispersion modeling (if applicable);
• identification and documentation of worst-probable emergencies involving the specific products being used or transported;
• a determination of what can go wrong, its effects, its likelihood of occurrence, how often it could occur and the location of occurrence;
• consideration of the dangers arising from human activity, such as fire, explosion, environmental contamination, hazardous substance release or pipeline ruptures, in addition to natural perils;
• an evaluation of the potential for multi-hazard emergencies; and
• measures that could reduce or eliminate the hazard.

The hazard assessment should be used to create and delineate the Emergency Planning Zone(s) to be utilized for developing the various elements of the emergency management program.

2. Emergency Procedures Manual

The contents of the emergency procedures manual should include, but are not limited to, the following:

• manual distribution list (or on separate file);
• manual updating procedures and schedule (or on a separate file);
• description of initial actions when someone reports an incident;
• definitions and levels of emergencies;
• corporate and operational chains of command (e.g., organization structures);
• management of threat information;
• incident management system (e.g., Incident Command System);
• spill control procedures and locations of spill control points (if applicable);
• debriefing procedure;
• internal and external communications;
• external communication information, warnings and evacuations (e.g., public relations or media plan);
• alternative means of communication;
• roles and responsibilities for internal positions involved in a response (including contractors);
• roles and responsibilities for agencies that would likely be involved in a response;
• environmental or other areas requiring special consideration or protection;
• detailed product information;
• internal and external reporting requirements;
• up-to-date internal and external contact lists;
• lists of persons in the Emergency Planning Zones (or on a separate file);
• description and location of response equipment, including information on how to access the response equipment on a 24-hour basis;
• up-to-date area maps or mapping;
• agreements with other companies or organizations (or on a separate file) or a reference to agreements in the emergency procedures manual;
• templates and records to document the events, actions and meetings during an incident.

Emergency procedures manuals must be submitted to the CER. They are to be reviewed and updated by the company regularly and published on the company’s website as of 30 September 2016. Portions of the published manuals may not be available where there is personal information or information that can affect the security of the pipeline or particular properties.

Order MO-006-2016 Compelling Publication of Emergency Procedures Manuals [Filing A79720].

A company must also have a site-specific plan for sensitive areas. A sensitive area may be an area with a large population of people or an environmentally sensitive area such as wetlands, national parks, rivers and lakes.

3. Incident Management System

The CER expects companies to have an incident management system such as the Incident Command System. The system should take into account the functions of the federal and provincial governments, local authorities and governments, and the responsible party to achieve an effective and efficient response.

The system should be a standardized approach to emergency management that includes personnel, facilities, equipment, procedures, and communications operating within a common organizational structure.

4. Liaison with Agencies Involved in Emergency

CER-regulated companies must establish and maintain a close working relationship with agencies that may be involved in an emergency response on a pipeline. These could include first responders, city planners, municipalities, and indigenous groups. Companies must have discussions with these agencies to make sure they co-ordinate the response if an incident occurs. These discussions must take place during the development and updating of the emergency procedures manual.

Examples of topics for discussion include:

• accountabilities
• responsibilities
• key roles
• public safety measures
• communications
• response capabilities (including equipment, people and training)
• response times

In consulting with agencies that may be involved an emergency response, a company should, among any other relevant steps:

• use the hazard, safety and/or emergency planning zones calculated as part of the hazard assessment to identify the parties with whom liaison should be established;
• have up-to-date contact lists;
• have a description of the consultation process including a schedule for contacts, nature of discussions, type of information to be provided and the methods to assess the effectiveness of the consultation process;
• include records and documentation of all liaison activities; and
• include actions taken based on the results of the feedback received.

5. Communication with Persons Involved in Emergency Response

A company informs anyone associated with an emergency response activity on the pipeline of the relevant information consistent with the emergency procedures manual. This information should include:

• the type and locations of company facilities;
• all potential hazardous products transported and/or stored at company facilities in significant volumes;
• MSDS sheets or similar information on the properties of products;
• plume dispersion information and ignition guidelines (if applicable);
• spill control points;
• key roles of all company personnel and agencies involved in an emergency response;
• practices and procedures to be followed consistent with those specified in the emergency procedures manual; and
• any relevant information consistent with the manual.

6. Providing Continuing Education for Emergency Response

The company must develop a continuing education program for police, fire departments, medical facilities, and other organizations and agencies and the public living near the pipeline. The continuing education program informs these groups about the location of the pipeline, potential hazards and the emergency situations involving a pipeline, and the safety procedures to be followed in the case of an emergency.

This would also include:

• procedures for informing local authorities, response organizations, and the public, procedures on responder health and safety, and scene arrival protocols
• how to notify the company of an incident; and
• hotlines and/or websites set up to respond to inquiries during an emergency.

In developing and implementing continuing education for emergency management, a company should:

• use the hazard, safety and/or emergency planning zones calculated as part of the hazard assessment to identify the parties with whom continuing education should be conducted;
• have up-to-date contact lists of all persons potentially affected by an emergency situation;
• have a rationale for the methods used to distribute information as well as a documented assessment of the success in delivering the safety message;
• document actions taken to deliver information and identify recipients including examples of the information delivery tools; and
• include actions taken based on the results of the feedback received.

7. Emergency Response Processes and Capability

A company’s emergency management program includes:

• procedures for the safe control or shutdown of the pipeline system in the event of an emergency and safety procedures for personnel at emergency sites (CSA Z662 Clause 10.5.2.1); and
• verifiable capability to respond to an emergency in accordance with their emergency procedures and response plans demonstrated through exercises (OPR section 46 and CSA Z662 Clause 10.5.2.4).

8. Emergency Response Training and Exercises

A company must have a training program for its employees to enhance the knowledge, skills, and abilities required to support the company’s emergency management program. This includes training for persons having a role in an emergency (for example, those providing equipment or involved in the incident management system) and competency requirements. This ensures that staff and first responders are trained on all aspects of their roles and responsibilities as identified in the Emergency Procedures Manual.

A company is also required to demonstrate response capabilities. This is tested through exercises such as drills, tabletops, functional and full-scale exercises.

Emergency response exercises should:

• be held with sufficient frequency. At least one simulated exercise annually (e.g., tabletop, functional) and a full scale exercise (involving all agencies identified in the company’s liaison) should be held at least every three years;
• be varied to confirm that all aspects of potential emergencies are tested; and
• simulate a wide range of potential geographic and weather conditions as well as worse-case spill or gas release scenarios.

9. Emergency Response Equipment

An assessment on whether firefighting and other special equipment is necessary, based on the hazard assessment (CSA Z662 Clause 10.2.7.1).

Sufficient response equipment (including firefighter and special equipment) is necessary to respond to a serious emergency as determined by their hazard assessment (CSA Z662 Clause 10.2.7.1).

Placement of equipment should be based on people, property and environmental considerations to minimize response times and reduce potential impacts of incidents. If equipment resides with mutual aid partners, spill co-operatives, government agencies or other organizations, formal agreements should be in place for access to the equipment by company personnel.

Companies should have documented procedures and schedules for preventative maintenance of response equipment. These procedures should include regularly scheduled sessions for operational testing and inventory control.

For further guidance in developing an emergency management program, companies may use the applicable provisions of the ISO 14000 series of Standards and CSA Z246.2 as a reference.

Annex B. Further Information for Integrity Management Program

Annex B. provides further information for a company’s integrity management program (OPR section 40).

1. Records Management

A company’s process for managing records (paragraph 6.5(1)(p) of the OPR) related to the integrity management program follows the requirements of the applicable standards referred to in section 4 of the OPR and the requirements of section 56. A company’s records management process for its integrity management program, should allow timely access, by section, to records regarding the pipeline system.

• a) The records should include information on the original pipe and all modifications and repairs such as:
  • i. pipe material, manufacturer and date of manufacture, category, seam and girth weld type, grade, welder identification, non-destructive examination records, heat number and weld maps;
  • ii. coating type for line pipe, joints and tie-ins, manufacturer, application method and weather conditions at the time of application;
  • iii. repair history;
  • iv. mapping;
  • v. all pressure test data and records, maximum operating pressure, construction drawings, in-line inspection tool data and reports, corrosion control and cathodic protection records including design and survey results;
  • vi. inspection records of pressure relieving and emergency shutdown devices; and
  • vii. valve inspection records;
• b) A company’s process for record management should:
  • i. allow for documentation of condition monitoring and mitigation programs and past condition monitoring and mitigation decision analyses; and
  • ii. provide for reviews of integrity management program effectiveness.

2. Condition Monitoring

Condition monitoring is intended to be a comprehensive, proactive, consistent, process where the various components of the process are reviewed on an ongoing basis and updated as necessary. Condition monitoring should include:

• a) periodic internal inspections (frequency of inspections should be based on engineering principles) with in-line inspection (ILI) tools (or their equivalent) for all steel pipelines operating above 30% specified minimum yield strength;
• b) an engineering assessment (a documented assessment of variables using engineering principles) of facilities or line pipe segments to address pipeline integrity. Time-dependent, non-time-dependent and geotechnical hazards could be considered and investigated in the engineering assessment. The engineering assessment may consider the results of such methods as pressure testing, use of ILI tools and investigative digs. Note that cathodic protection surveys are not by themselves considered adequate to determine pipeline integrity;
• c) the risk assessment methods to be used when assigning priorities for integrity evaluation of facilities or line pipe segments. Factors which may be included in the risk assessment are items such as: product handled; pipeline location; stress levels; product pressure; pipeline age and condition; coating age and condition; cathodic protection data, and ILI data. Consideration may be given to determining the area affected (consequence) by a product release;
• d) where appropriate, monitoring and surveillance programs for slope movement, river crossings, depth of cover, frost heave and thaw settlement;
• e) a program to minimize third party damage including line patrols;
• f) the methods used to evaluate and maintain pipeline integrity and the criteria for their application, which may include:
  • i. the use of the appropriate ILI tool technology and the methods used to verify ILI findings,
  • ii. the hydrostatic retesting procedure,
  • iii. the corrosion control monitoring methods and cathodic protection survey documentation,
  • iv. the methods used to evaluate remaining life where defects exist,
  • v. the methods used to verify the coating type and condition,
  • vi. the methods used to establish equipment inspection intervals,
  • vii. the methods used to inspect equipment, tankage and pressure vessels, and
  • viii. any other methods for defect detection utilized;
• (g) the procedures used to track, analyze and trend the condition of the pipeline; and
• (h) the steps to be taken to evaluate the cause of a pipeline failure including the minimum investigation and documentation.

3. Mitigation

A company’s mitigation process for ensuring integrity should consider:

• a) the criteria and procedures for evaluation of imperfections and repair of pipelines containing defects;
• b) the procedure for performing consequence analyses to establish repair priorities;
• c) the criteria and procedures for consideration of such measures as pipe replacement, pipe repair, hot taps, hot work, excavation procedures, maintenance welding, recoating, hydrostatic retesting, and reduction in operating pressure (temporary or permanent);
• d) the criteria and methods for repair of tanks and pressure vessels;
• e) equipment and pipe isolation and purge procedures and de-icing and hydrate removal procedures, where applicable; and
• f) an outline of the short-term (i.e., 1 to 3 year(s)) and long-term (i.e., 4 to 10 years) mitigation program plans and priorities.

Date modified:

2023-05-23