Trans-Northern Pipelines Inc. - Application dated 29 April 2024 to change the approved maximum operating pressure of the NPS 16 Nanticoke to Hamilton Junction pipeline and to remove the pipeline from Order AO-001-SO-T217-03-2010

Trans-Northern Pipelines Inc. - Application dated 29 April 2024 to change the approved maximum operating pressure of the NPS 16 Nanticoke to Hamilton Junction pipeline and to remove the pipeline from Order AO-001-SO-T217-03-2010 [PDF 881 KB]

File 4668651
11 June 2025

Gail Sharko
Trans-Northern Pipelines Inc.
109-5305 McCall Way NE
Calgary, AB   T2E 7N7

Dear Gail Sharko:

On 29 April 2024, the Commission of the Canada Energy Regulator received an application from Trans-Northern Pipelines Inc. (TNPI), to change the approved maximum operating pressure (MOP) of the NPS 16 Nanticoke to Hamilton Junction pipeline (Pipeline) by varying Order OPLO-T2-33-78, and to remove the Pipeline from Schedule D of Order AO-001-SO-T217-03-2010. TNPI requested this relief pursuant to Condition 4.f of Order AO-001-SO-T217-03-2010 and section 69 of the Canadian Energy Regulator Act (CER Act). On 18 November 2024, TNPI filed an amendment to its application to clarify that it seeks to change the approved MOP of the Pipeline to match the existing restricted MOP, as set out in Order AO-001-SO-T217-03-2010, and to confirm that it seeks to remove the Pipeline from Schedule D of Order AO-001-SO-T217-03-2010.

The approved MOP for the Pipeline is set out in Order OPLO-T2-33-78 as 1,170 psig (equivalent to 8 066 kPa) at the Nanticoke, Ontario end, and 1,321 psig (equivalent to 9 108 kPa) at the Hamilton Junction, Ontario end. Order AO-001-SO-T217-03-2010 (as amended by Order AO-003-SO-T217-03-2010) restricts the MOP for this Pipeline to 7 260 kPa. TNPI has applied to change the approved MOP in Order OPLO-T2-33-78 to 7 260 kPa for the entire Pipeline.

The Commission notes that Condition 4.f is not applicable to TNPI’s requested relief because TNPI is not seeking approval to raise the restricted MOP of the Pipeline above 7 260 kPa. Nevertheless, TNPI framed its application in relation to this condition and provided all information that would otherwise be required if this condition applied, including the submission of an engineering assessment. The Commission used this information to assess TNPI’s requested relief. In relation to TNPI’s request to vary Order OPLO-T2-33-78 to change the approved MOP for the Pipeline, the Commission considered the engineering assessment to determine whether the Pipeline is fit for service at 7 260 kPa. In relation to TNPI’s request to remove the Pipeline from Schedule D of Order AO-001-SO-T217-03-2010, the Commission considered both the engineering assessment and TNPI’s submissions related to its compliance with various conditions of Order AO-001-SO-T217-03-2010 applicable to the TNPI pipeline system on the whole.

For the reasons set out below, the Commission grants TNPI’s requested relief.

Test for applications to review and vary previous decisions or orders

Subsection 69(1) of the CER Act provides that the Commission may review, vary, or rescind any decision or order it makes. Section 44 of the National Energy Board Rules of Practice and Procedure, 1995 sets out the required content of an application for this type of relief. There is no automatic right of review. Rather, the Commission has a discretionary power to review its decisions, which it must exercise sparingly and with caution.^{Footnote 1}

The Commission considers applications for review through a two-step process.^{Footnote 2} In step 1, the Commission considers whether the applicant has raised a doubt as to the correctness of the decision. The Commission will consider any ground that raises a doubt, including an error of law or of jurisdiction, changed circumstances or new facts that have arisen since the close of the original proceeding, or facts that were not placed in evidence in the original proceeding and that were then not discoverable by reasonable diligence. A review application must also include the nature of the prejudice or damage that has resulted or will result from the decision or order. If the Commission finds that the applicant has met step 1, then it will proceed to step 2 and determine whether the decision should be confirmed, amended, or overturned.

Application to vary Order OPLO-T2-33-78 to change the approved MOP for the Pipeline to 7 260 kPa

The Commission grants TNPI’s request to vary Order OPLO-T2-33-78 to change the approved MOP for the Pipeline, on the basis that the circumstances of the Pipeline have changed since the issuance of Order OPLO-T2-33-78, and the new circumstances support the requested change in MOP.

Order OPLO-T2-33-78, which approves the MOP for the Pipeline, was issued on 20 September 1978. To address safety concerns, the Pipeline has been restricted to a lower MOP since 20 September 2016 pursuant to Order AO-001-SO-T217-03-2010, which, at the time of TNPI’s application, was 7 260 kPa. Rather than applying pursuant to Condition 4.f of Order AO-001-SO-T217-03-2010 to resume operating the Pipeline at its higher approved MOP, TNPI applied to change the approved MOP to the lower MOP at which it is currently operating.

TNPI submitted, in support of its application, an engineering assessment that meets the requirements of Condition 4.f.iii of Order AO-001-SO-T217-03-2010, including that it was prepared in accordance with CSA Z662-23^Footnote 3 Oil and gas pipeline systems. The Commission is satisfied that the engineering assessment demonstrates that the Pipeline is safe to continue to operate at an MOP of 7 260 kPa.

The Commission finds that TNPI could be prejudiced if Order OPLO-T2-33-78 was not varied to change the MOP for the Pipeline to 7 260 kPa because TNPI has demonstrated that it is safe to continue to operate at 7 260 kPa, while Order AO-001-SO-T217-03-2010 reflects that the Pipeline is not safe to operate at the higher MOP currently approved by Order OPLO-T2-33-78. If the Commission were to not vary Order OPLO-T2-33-78 to change the approved MOP to 7 260 kPa, then the Pipeline may become subject to additional safety orders in the future.

Accordingly, the Commission issues Order AO-001-OPLO-T2-33-78 to vary Order OPLO-T2-33-78, to change the MOP for the Pipeline to 7 260 kPa.

Application to vary Order AO-001-SO-T217-03-2010 to remove the Pipeline from Schedule D

The Commission grants TNPI’s request to remove the Pipeline from Schedule D of Order AO-001-SO-T217-03-2010, on the basis that the circumstances of the Pipeline have changed since the issuance of Order AO-001-SO-T217-03-2010, and the new circumstances support the removal of the Pipeline from the Order.

When Order AO-001-SO-T217-03-2010 was issued on 20 September 2016 to address safety concerns related to a number of TNPI’s pipelines, including the Pipeline, the approved MOP for the Pipeline as stated in OPLO-T2-33-78 was 1,170 psig (equivalent to 8 066 kPa) at the Nanticoke, Ontario end, and 1,321 psig (equivalent to 9 108 kPa) at the Hamilton, Ontario end. Two main circumstances have changed since this time in relation to this Pipeline. First, the Commission has approved, above, a lower MOP of 7 260 kPa based on the engineering assessment that TNPI submitted with its application. The engineering assessment demonstrates that the Pipeline is safe to continue to operate at this MOP. Second, TNPI has demonstrated through its submissions that it has met the requirements of Order AO-001-SO-T217-03-2010 that apply to its pipeline system as a whole, including the Pipeline (i.e., Conditions 4.a to 4.e). As a result of these two changes in circumstance, the Commission finds that the safety concerns that resulted in including the Pipeline in Order AO-001-SO-T217-03-2010 have been resolved by TNPI. Accordingly, the Commission finds that it is no longer necessary to include the Pipeline in Order AO-001-SO-T217-03-2010.

The Commission finds that TNPI would be prejudiced if the Commission were to not vary Order AO-001-SO-T217-03-2010 to remove the Pipeline, because TNPI would continue to be required to file yearly engineering assessments for the Pipeline pursuant to Condition 8.e, despite having resolved all safety concerns that led to that requirement.

Accordingly, the Commission issues Order AO-012-SO-T217-03-2010 to vary Order AO-001-SO-T217-03-2010 to remove the Pipeline from Schedule D. Following the removal of the Pipeline from Schedule D, there are no pipelines remaining in Schedule D. As a result, Order AO-012-SO-T217-03-2010 reflects the deletion of Schedule D, as well as consequential amendments to conditions 4 and 7, and the deletion of condition 8.

A copy of Order AO-001-SO-T217-03-2010, reflecting all amendments to date, is included with this letter.

Yours sincerely,

Signed by

Ramona Sladic
Secretary of the Commission

Attachments:
Order AO-001-OPLO-T2-33-78
Order AO-012-SO-T217-03-2010
Appendix I – Copy of Order AO-001-SO-T217-03-2010, as amended

c.c. Jane Keast, TNPI

ORDER AO-001-OPLO-T2-33-78

BEFORE the Commission of the CER on 10 June 2025.

WHEREAS the CER regulates the construction and operation of the TNPI pipeline system; AND

WHEREAS on 20 September 1978, the National Energy Board issued Order OPLO-T2-33-78;

AND WHEREAS Order OPLO-T2-33-78 approves the maximum operating pressure (MOP) for the NPS 16 Nanticoke to Hamilton Junction pipeline as 1,170 psig (equivalent to 8 066 kPa) at the Nanticoke, Ontario, end, and 1,321 psig (equivalent to 9 108 kPa) at the Hamilton, Ontario, end;

AND WHEREAS Order AO-001-SO-T217-03-2010 imposes certain requirements on TNPI in relation to the safe operation of the NPS 16 Nanticoke to Hamilton Junction pipeline;

AND WHEREAS the Commission received an application from TNPI, dated 29 April 2024, and amended on 18 November 2024, to vary Order OPLO-T2-33-78 to change the MOP for the entire NPS 16 Nanticoke to Hamilton Junction pipeline to 7 260 kPa, and to vary Order AO-001-SO-T217-03-2010 to remove this pipeline from Schedule D, both pursuant to section 69 of the CER Act;

AND WHEREAS on 10 June 2025, the Commission issued its reasons for granting TNPI’s requested relief;

IT IS ORDERED that, pursuant to subsection 69(1) of the CER Act, Order OPLO-T2-33-78 is varied to change the MOP for the entire NPS 16 Nanticoke to Hamilton Junction pipeline to 7 260 kPa.

THE COMMISSION OF THE CANADA ENERGY REGULATOR

Signed by

Ramona Sladic
Secretary of the Commission

ORDER AO-012-SO-T217-03-2010

BEFORE the Commission of the CER on 10 June 2025.

WHEREAS the CER regulates the construction and operation of the TNPI pipeline system; AND

WHEREAS on 20 September 2016, the Commission’s predecessor, the National Energy Board, issued a Letter Decision and Order AO-001-SO-T217-03-2010, which it varied on 24 October 2016 and 11 April 2017, and the Commission further varied on 17 July 2020, 8 June 2022, 6 September 2022, 1 November 2022, 30 November 2022, 5 September 2023, 11 March 2024, and 9 September 2024;

AND WHEREAS Order AO-001-SO-T217-03-2010 imposes certain requirements on TNPI in relation to the safe operation of the NPS 16 Nanticoke to Hamilton Junction pipeline;

AND WHEREAS the Commission received an application from TNPI, dated 29 April 2024, and amended on 18 November 2024, to vary Order OPLO-T2-33-78 to change the maximum operating pressure (MOP) for the entire NPS 16 Nanticoke to Hamilton Junction pipeline to 7 260 kPa, and to vary Order AO-001-SO-T217-03-2010 to remove this pipeline from Schedule D, both pursuant to section 69 of the CER Act;

AND WHEREAS on 10 June 2025, the Commission issued its reasons for granting TNPI’s requested relief;

IT IS ORDERED that, pursuant to subsection 69(1) of the CER Act, Order AO-001-SO-T217-03-2010, as amended, is varied by:

• deleting Line 1 in Schedule D to remove the NPS 16 Nanticoke to Hamilton Junction pipeline and deleting Schedule D in its entirety;
• deleting condition 8; and
• varying conditions 4 and 7 as set out in the following table:

  Varying conditions 4 and 7

  Condition	Delete	Replace
  4	“For each of the pipeline sections listed in Schedules A, B, C and D”	“For each of the pipeline sections listed in Schedules A, B, and C”
  4.a.vi.	“1.a., 2.a., 3.a. and 8.a”	“1.a., 2.a., and 3.a.”
  7	“7.e. TNPI shall include the requirements of condition 8 in its quarterly updates to the Commitment Plan.”	-

THE COMMISSION OF THE CANADA ENERGY REGULATOR

Signed by

Ramona Sladic
Secretary of the Commission

Appendix I – Copy of Order AO-001-SO-03-T217-2010, as amended

Appendix I is a copy of the preambular text and conditions of Order AO-001-SO-03-T217-2010, originally issued by the National Energy Board on 24 October 2016, incorporating all changes made through amending orders up to and including Order AO-012-SO-T217-03-2010.

WHEREAS the Board regulates the construction and operation of the TNPI pipeline system;

AND WHEREAS the Board has issued Safety Orders SG-T217-04-2009, SG-T217-01-2010, and SO-T217-03-2010 (Safety Orders) requiring specific safety measures;

AND WHEREAS TNPI has operated the pipeline system beyond design limits and Board-established pressure restriction;

AND WHEREAS TNPI participated in a Technical Meeting with the Board and made undertakings related to facility and pipeline integrity management programs;

AND WHEREAS TNPI has not yet satisfied all of the conditions in the Safety Orders and all of the undertakings agreed to at the TNPI-Board Technical Meeting;

AND WHEREAS TNPI has reported eleven overpressure incidents on its pipeline systems since SO-T217-03-2010 was issued;

AND WHEREAS the Board is of the view that the recurrence of overpressure incidents demonstrates that TNPI has not yet effectively resolved its overpressure hazard and that TNPI will be required to conduct additional work to meet the Board’s requirements;

AND WHEREAS, as an interim measure, the Board is of the view that requiring further pressure reductions would increase the safety of the pipeline system;

AND WHEREAS the Board is not satisfied that TNPI has addressed all possible causal factors related to its overpressure incidents, particularly with respect to management systems and organizational factors;

AND WHEREAS the Board is of the view that TNPI should develop and implement a Water Crossing Management Program for its pipeline system, and that the Board should provide further direction with respect to on-going remediation activities related INC 2010-034 on Bronte Creek near Oakville, Ontario:

AND WHEREAS the majority of the Board decided to issue Amending Safety Order AO-001-SO-T217-03-2010 (this Order) and letter decision dated 20 September 2016;

AND WHEREAS Member Richmond and Member Ballem dissent from the majority decision, and their dissent decision, outlining the reasons, is in Appendix A to the letter decision of the majority of the Board dated 20 September 2016;

NOW THEREFORE, pursuant to paragraph 12(1)(b), subsection 21(1) and subsection 48(1.1) of the NEB Act, the Board rescinds Safety Orders SG-T217-04-2009, SG-T217-01-2010 and SO-T217-03-2010 and their associated conditions, and hereby orders that TNPI may continue to operate its pipelines, subject to the following conditions:

1. For each pipeline section listed in Schedule A
   1. TNPI shall immediately restrict the operating pressure to the lower of 90% of the authorized MOP (Maximum Operating Pressure) or 10% below the highest pressure reached within the 90 day period prior to the issuance of this Order;
   2. TNPI shall file with the Board, within 60 days after the date of issuance of this Order, a report which includes the following information:
      1. the new restricted MOPs for each section, as directed in Condition 1.a.;
      2. all applicable overpressure protection system set points; and
      3. the overpressure system configuration.
2. For each pipeline section listed in Schedule B
   1. TNPI shall immediately restrict the operating pressure by 30% of the authorized MOP;
   2. TNPI shall file with the Board, within 60 days after the date of issuance of this Order, a report which includes the following information:
      1. the new restricted MOPs for each section as directed in Condition 2 a.;
      2. all applicable overpressure protection system set points; and
      3. the overpressure system configuration.
   3. TNPI shall file with the Board a yearly Engineering Assessment, on or before 30 September 2017 and 30 September of each year thereafter that demonstrate the fitness for service of the pipeline sections listed in Schedule B at the reduced pressure. The Engineering Assessment must include, but not be limited to:
      1. revised defect growth rates since 2010; and,
      2. time-to-failure calculations, commencing September 2017 and ending when the pressure restriction has been lifted for each section of pipeline listed in Schedule B.
3. For each pipeline section listed in Schedule C
   1. TNPI shall immediately restrict the operating pressure by 30% of the authorized MOP;
   2. TNPI shall file with the Board, within 60 days after the date of issuance of this Order, a report which includes the following information:
      1. the new restricted MOPs for each section as directed in Condition 3.a.;
      2. all applicable overpressure protection system set points; and
      3. the overpressure system configuration.
   3. TNPI shall file with the Board a yearly Engineering Assessment, on or before 31 December 2016 and 31 December of each year thereafter that demonstrate the fitness for service of the pipeline sections listed in Schedule C at the reduced pressure. The Engineering Assessment must include, but not be limited to:
      1. revised defect growth rates since 2009; and
      2. time-to-failure calculations, commencing December 2016 and ending when the pressure restriction has been lifted for each section of pipeline listed in Schedule C.
4. For each of the pipeline sections listed in Schedules A, B, and C
   1. TNPI shall perform the following actions:
      1. TNPI shall conduct a hydraulic analysis that includes all possible steady and non-steady state condition scenarios for all TNPI facilities and pipeline segments at 100% MOP and their reduced operating pressures to identify where overpressure events may occur. TNPI shall include in the hydraulic analysis an assessment of the collateral effects to the operation of third party pipelines in the event of an overpressure;
      2. TNPI shall conduct and validate the hydraulic analysis results by correctly predicting all of the reported overpressure incidents;
      3. TNPI shall develop and implement corrective and preventive measures in response to the results of the hydraulic analysis that are in compliance with CSA Z662-15 Clause 4.18. The recommended measures shall include the installation of pressure-relieving systems to ensure that overpressure will not occur at any point in the TNPI system;
      4. TNPI shall integrate and optimize pressure-limiting systems; pressure-relieving systems; and Supervisory Control and Data Acquisition (SCADA), programmable logic controllers (PLC) and programming;
      5. TNPI shall file with the Board a report that describes the security measures with respect to its SCADA and PLCs operating systems;
      6. TNPI shall notify the Board within 2 days after derating a pipeline section, if TNPI derates the operating pressure of any section set out in Conditions 1a., 2a., and 3a. due to an identified transient analysis related issue. The notice shall include the rationale for reducing the pipeline’s pressure;
      7. TNPI shall file with the Board for approval by 30 September 2017, a report that describes all specific evaluated scenarios, hydraulic analysis results, the recommended corrective and preventive measures, and the locations where overpressure protection system are proposed to be installed;
      8. TNPI shall implement the recommended corrective and preventive measures within 24 months after receiving Board approval under 4.a.vii. TNPI shall file with the Board a report confirming that it completed the measures.
   2. TNPI shall review and revise its operational and emergency response procedures and manuals, for its pipeline system, that are related to pressure control and overpressure protection systems. TNPI shall file with the Board by 30 June 2017 a report confirming that the procedures and manuals have been revised and implemented.
   3. TNPI shall implement all outstanding proposed preventive and mitigation measures outlined in the 17 July 2015 “Comprehensive Review of Overpressure Incidents and Systemic Plan for Corrective Action” report. TNPI shall file with the Board by 31 December 2016 confirmation that TNPI has implemented the measures.
   4. TNPI shall evaluate its pipeline risk and reliability at all water crossings, and develop and implement a water crossing management program on the TNPI pipeline system within 24 months after the date of issuance of this Order. TNPI shall file with the Board for approval by 31 December 2018, a report which includes TNPI’s pipeline water crossing management program, and pipeline risk and reliability assessment. The Water Crossing Management Program must include, but is not limited to:
      1. A Depth of Cover survey;
      2. An Engineering Assessment for pipeline underwater crossings;
      3. A Scouring assessment based on 50-year and 100-year storm event conditions, as well as bank erosion and channel migration analysis;
      4. Mitigation, prevention and monitoring programs as per section 39 and 40 of the National Energy Board Onshore Pipeline Regulations (OPR);
      5. A schedule for implementation of all mitigation, prevention and monitoring programs identified in Condition 4.d.iv.
   5. TNPI shall take the following actions with respect to undertakings agreed to at the TNPI-Board technical meeting:
      1. TNPI shall revise and implement the TNPI Integrity Management Programs (IMPs) for its pipeline system (Facility and Pipeline) as required in sections 6.1 to 6.5 and section 40 of the OPR.
      2. TNPI shall file the revised IMPs with the Board by 30 September 2017;
      3. TNPI shall, as part of its IMPs for facility and pipeline, establish and implement a Risk Management process. The process with a management system framework shall contain the steps for evaluating and managing the pipeline risks associated with identified pipeline and facility integrity hazards, including risk reduction measures related to normal and abnormal operating conditions. TNPI shall file the management risk process with the Board by 30 September 2017;
      4. TNPI’s Accountable Officer shall file with the Board, by 31 December 2016, a report demonstrating that TNPI has met the requirements of the OPR sections 6.5(1) (v), (w) and (x) and make available for the Board’s review TNPI’s required management system process and records.
   6. TNPI shall, at least 45 days before it would like any increases to the restricted MOP of any pipeline or section of pipeline to take effect, file a request for approval to increase the restricted MOP, with information that includes, but is not limited to:
      1. Information demonstrating that TNPI has implemented Conditions 4.a. to 4.e. of this Order;
      2. Evidence that, as a result of lifting the pressure restriction, the integrity condition on the pipeline or section of pipeline will not be negatively affected within 36 months after the date of the return to service application;
      3. An Engineering Assessment prepared in accordance with CSA Z662-15 Clause 10.1 that demonstrates that the pipeline or section of pipeline is safe to operate at its maximum operating pressure. The Engineering Assessment must include, but not be limited to, the following items:
         1. A Risk Assessment guided by CSA Z662 Annex B including guidelines for documented reporting by CSA Z662 Annex B Clause B.6;
         2. An imperfection assessment including, but not be limited to, pressure cycling, tool validation (Probability of Detection, Probability of Identification, and Sizing Accuracy), representative material properties, defect interaction, time-to-failure calculations, Safety Factor targets, revised defect growth rates and Probability of Exceedance; and
         3. Required mitigative, preventive and monitoring measures;
         4. A schedule for implementation of all mitigation, prevention and monitoring programs identified in Condition 4.f.iii.3.
5. TNPI shall perform the following actions:
   1. A historical review of past overpressures to identify causal and contributing factors specific to management systems and organizational factors, as well as recommended corrective and preventive measures.
   2. Implementation of the associated corrective and preventive measures resulting from the historical review.
   3. TNPI shall file with the Board for approval by 31 December 2016, a report which describes the process of incident investigation and analysis including the incidents assessed, the analytic results, and the implemented and required preventive and mitigative measures. The report shall include a timeline to implement the preventative and mitigative measures that are not implemented when the report is filed (outstanding measures).
   4. TNPI shall file with the Board, within 30 days after the conclusion of the timeline to implement the outstanding measures, confirmation that the outstanding measures referred to in Condition 5(c) have been implemented.
6. TNPI shall perform the following actions with respect to the on-going remediation activities related to the 16 March 2010 incident (INC 2010-034) on the portion of the TNPI NPS 10 Cummer Junction to Oakville pipeline (Schedule B) that crosses Bronte Creek near Oakville, Ontario:
   1. TNPI shall file with the Board for approval by 31 March 2017 a Remedial Action Plan (RAP) consistent with the guidance provided in the Board’s Remediation Process Guide, which includes but is not limited to:
      1. confirmation that TNPI will send the RAP and the following notation to all previously identified stakeholders (as per the original stakeholder agreement).
      2. a detailed description of how the RAP is supported by the Community Based Risk Assessment (CBRA), including a letter from the Ontario Ministry of the Environment and Climate Change which notes its acceptance of the CBRA.
      3. confirmation that TNPI has sent the RAP and the following notation to all previously identified stakeholders (as per the original stakeholder agreement):

         “This Remedial Action Plan (RAP) is concurrently being filed with the National Energy Board for approval. Please file any comments in respect of this RAP for the Board’s consideration within 21 days after receipt of this correspondence”.

   2. TNPI shall file with the Board an annual status report, on or before 31 December 2017 and 31 December of each year thereafter until TNPI files its Remediation Closure Report for the incident site. The annual status report shall summarize remediation activities and progress to date, and include an estimated timeframe for completing remediation activities.
   3. TNPI shall file with the Board for approval a Remediation Closure Report the content of which is consistent with the guidance provided in the Board’s Remediation Process Guide. TNPI shall file the report with the Board after TNPI has completed the remediation objectives noted in the RAP.
7. TNPI shall perform the following actions in order to track and report its progress in completing all condition requirements of this Order:
   1. TNPI shall immediately appoint an independent third party responsible for the following actions:
      1. Developing a Commitment Plan;
      2. Updating the Commitment Plan on a quarterly basis;
      3. Tracking the Commitment Plan for all Conditions of this Order;
      4. Reporting on the status of all requirements associated with this Order;
   2. TNPI’s Accountable Officer, appointed under subsection 6.2(1) of the OPR, shall sign the Commitment Plan and its Updates.
   3. TNPI shall file the Commitment Plan with the Board for approval within 30 days after the issuance of this Order.
   4. TNPI shall file updates to the Commitment Plan with the CER on an annual basis on 17 February, commencing on 17 February 2023, and continuing until otherwise directed by the Commission.

SCHEDULE A

AO-001-SO-T217-03-2010

Schedule A - Pressure Reduction to the lower of 90% of Authorized MOP or 10% below the highest pressure reached within 90 days prior to the issuance of this Order.

SCHEDULE B

AO-001-SO-T217-03-2010

Schedule B - Pressure Reduction of 30% of Authorized MOP (as Specified)

SCHEDULE C

AO-001-SO-T217-03-2010

Schedule C - Pressure Reduction of 30% of Authorized MOP (as Specified)

Date modified:

2025-12-02