Trans-Northern Pipelines Inc. (TNPI) – Amending Safety Order AO-002-SO-T217-03-2010 – Conditions 5.a and 5.c Report Filing
File OF-Surv-Gen-T217 01
15 November 2017
Mr. John Ferris
President and CEO
Trans-Northern Pipelines Inc.
45 Vogell Road, Suite 310
Richmond Hill, ON L4B 3P6
Dear Mr. Ferris:
- Trans-Northern Pipelines Inc. (TNPI)
Amending Safety Order AO-002-SO-T217-03-2010
Conditions 5.a and 5.c Report Filing
On 24 October 2016, the National Energy Board (Board) issued Amending Safety Order AO-002-SO-T217-03-2010 (Amending Safety Order) to TNPI allowing operation of its pipeline system subject to certain conditions. For the reasons that follow, the Board considers that Conditions 5.a and 5.c are complied with.
Background and Events
Condition 5.a of the Amending Safety Order requires TNPI to perform “a historical review of past overpressures to identify casual and contributing factors specific to management systems and organizational factors, as well as recommended corrective and preventive measures”.
Condition 5.c of the Amending Safety Order requires TNPI to “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 analytical results, and the implemented and required preventive and mitigative measures. The report shall include a timeline to implement the preventive and mitigative measures that are not implemented when the report is filed (outstanding measures)”.
On 30 December 2016, TNPI filed (1) a Det Norske Veritas (Canada) Ltd. (DNV GL) report entitled Review of Overpressure Incidents – Condition 5.a (DNV GL Report), and (2) TNPI Condition 5.c Report – Prevention Measures and Timelines (Condition 5.c Report), in compliance with the Amending Safety Order.
Subsequently, the Board issued two rounds of Information Requests (IRs) to TNPI requesting additional information. TNPI filed the responses as requested by the Board. The final response filed by TNPI on 12 September 2017, in the revised report entitled Review of Overpressure Incidents – Condition 5.a (Revised Report), included a Table that contains DNV GL recommendations, TNPI Prevention Measures, and Implementation Timelines.
Views of the Board
The Board has reviewed all information filed by TNPI including the reports and responses to IR No.1 and IR No.2 to address the requirements of the Condition 5.c of the Amending Safety Order. The Board finds that TNPI has complied with Conditions 5.a and 5.c of the Amending Safety Order.
Therefore, the Board considers that Conditions 5.a and 5.c are complied with.
The Board reminds TNPI that Conditions 5.b and 5.d are not yet complete and expects TNPI to file the outstanding information related to Conditions 5.b and 5.d by 31 December 2019. The Condition 5.b requires TNPI to implement the associated corrective and preventive measures resulting from the Condition 5.a. The implementation timelines for the TNPI corrective and preventive measures are described, and are committed to by TNPI in the Revised Report.
Original signed by
Secretary of the Board
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