Filing Manual – Guide G – Deactivation (OPR section 44)

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Table of Contents

  1. Goal
  2. G.1 Filing Requirements – Engineering
  3. G.2 Filing Requirements – Environment and Socio-economic Assessment
  4. G.3 Filing Requirements – Economics
  5. Guidance
    1. Engineering
    2. Environmental and Socio-economic Effects

Section 44 of the OPR states:

  1. (1) If a company proposes to deactivate a pipeline or part of one for 12 months or more, has maintained a pipeline or part of one in a deactivated mode for 12 months or more or has not operated a pipeline or part of one for 12 months or more, the company shall submit an application for the deactivation to the [CER].
  2. (2) The company shall include in the application the reasons, and the procedures that were or are to be used, for the activity that is the subject of the application.

Goal

The application explains the need for the proposed deactivation, includes a description of the proposed activities, and identifies all potential impacts.

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G.1 Filing Requirements – Engineering

1. Describe the rationale for the deactivation and the measures to be employed or that were employed for the deactivation to maintain the integrity of the pipeline and protect the public and the environment.

2. Provide a schedule outlining when the deactivations are planned for completion.

3. Describe the activities associated with the deactivations.

4. Provide an estimate of the costs associated with the deactivations.

5. Confirm deactivation activities will follow the requirements of the latest version of CSA Z662.

6. Provide the details of the ongoing monitoring of the deactivated pipeline or a section of it to verify that the public and the environment are continually protected.

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G.2 Filing Requirements – Environment and Socio-economic Assessment

1. Describe how the environmental and socio-economic effects have already been considered in an ESA by the Commission.

2. If the environmental and socio-economic effects have not been addressed by a previous ESA, provide the filing requirements outlined in s A.2.

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G.3 Filing Requirements – Economics

1. Provide the necessary economic information as outlined in s A.3.

Guidance

Deactivation is defined in section 1 of the OPR as meaning “to remove temporarily from service”. An improperly deactivated pipeline or a section of it may be a source of risk to the public and the environment.

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 (such as above ground facilities) that are not being maintained for peak flow, standby (ready for immediate use) or emergency use.

For a pipeline or a section of it that is expected to be idle or otherwise not operating for periods of 12 months or more, the CER expects a company to apply for deactivation in accordance with section 44 of the OPR.

In practice, it is accepted that portions of pipeline, though maintained in a deactivated state:

  • may never be returned to service;
  • may be maintained in a deactivated state for an unspecified length of time; and
  • 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 shippers and upstream and downstream users of the pipeline. Companies proposing deactivations could consider using an engagement approach with stakeholders similar to that which is used for applications made pursuant to section 214 of the CER Act (see Guide A). Engagement should address all issues arising from the deactivation that relate to the protection of property and the environment as well as the safety of persons.

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

Notification should address all issues arising from the deactivation that relate to the protection of property and the environment as well as the safety of persons.

If deactivation results in a suspension of service, an application pursuant to either section 239 or section 240 of the CER Act may also be required.

For a pipeline or a section of it that has been idle or otherwise not operating for periods of 12 months or more, the CER expects a company to apply in advance for leave of the Commission to reactivate the pipeline or a section of it in accordance with section 45 of the OPR. Information regarding reactivation applications is found in Guide H.

Engineering

Any application for a reactivation must meet the minimum requirements as set out in CSA Z662.

Environmental and Socio-economic Effects

To address the environmental and socio-economic effects of a deactivation that have not been previously assessed, applicants are referred to section A.2. Applicants should carefully review the sections discussing the scoping of the ESA and the level of detail required. Appropriate scoping of the ESA ensures the ESA will focus on relevant issues and concerns, and assists in determining the appropriate level of effort to be used to prepare the ESA.

Next Steps...

File the completed application. Applicants are encouraged to include the completed relevant checklists from Appendix 1.

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