This comment report lists all the questions in the Pipeline Safety Report Survey and the 18 comments
made (those that have asked their comments not be shared are extracted).
Comments were collected from August 19th until October 6th,
Do you agree to have your comments shared? (93.75% agreed to share)
Group 10’s report includes a number of recommendations to reduce risks to
the environment, public and industry through an improved Integrity Management
Program (IMP). IMPs are programs to ensure the safe operation of pipelines and
are part of the Albert Energy Regulators Safety and Loss Management System.
An SLMS is a proactive process to manage the life-cycle of a
pipeline from design, construction and operation, to discontinuation and
abandonment. A strong SLMS also helps to ensure the protection of people,
environment, and property.
Work to enhance the AER’s SLMS is currently
underway, with completion of the design process proposed by mid-2014.
Group 10’s recommendations are as follows:
Public Safety and Response to Pipeline Incidents
1. Develop a stakeholder
education and awareness program targeted at right of way encroachment and
reaction to emergencies.
2. Extend Alberta’s mandatory “Call Before You Dig”
program across Canada.
3. Increase AER participation in stakeholder emergency
Pipeline Integrity Management
4. Create a standardized pipeline risk
ranking in Canada.
5. Routine Audit Integrity Management Programs for all
6. Create requirements for inspection/testing in high risk
7. Create personnel certification programs in pipeline safety.
Use performance based regulation.
9. Review staffing levels associated with
10. Set clear goals to manage pipeline failure rates to as
low as reasonably practicable.
11. Define record retention for takeovers,
mergers and sales.
12. Harmonize with other regulators.
industry and public on pipeline set-backs.
Safety of Pipelines near Water Bodies
14. Confirm definition of what
constitutes a water body and clearly define expectations
inspection, mitigation and monitoring at water bodies.
15. Require map
inventories of water crossings.
16. Require a process to mitigate risks at
high consequence areas.
17. Define depth of cover requirements at all
critical and high-risk water crossings.
Do you have any comments on these recommendations?
Do you have any other policies or processes that you think should be
Question 2 Responses
Date of response (DOR) August 27 - Hard for a third party
company to report on pipelines without understanding what is currently happening
and the processes in place. Emergency response plan requirements need
considerable improvements to be effective. Plans should be spatial, electronic
and updated annually rather than when required or every five years. Linkage
should be built between other industries and the government of Alberta emergency
response system to ensure maximum efficiencies. Item 10 is a critical item that
the AER does an extremely poor job in tracking. Spills are tracked by the legal
sub division on reports and should be by GPS coordinates. Companies can have
multiple breaks on a single line without the regulator being aware the line
needs to be replaced. Safety of pipelines near water bodies is poorly understood
by the author. Current inspection requirements and technology exists to improve
on the information significantly.
DOR August 29 - Overall, we support the recommendations,
with the following provisos: Recommendation 5: Routine Audit Integrity
Management Programs for all companies: The Report suggests self-audit as one
option for IMP audits. Self-audits should not be an option. By definition, an
audit must be conducted by an independent third party, either a government
agency or a truly independent third party. Recommendation 10: Set clear goals to
manage pipeline failure rates: The Report references working with stakeholders
to set these goals. The public are impacted by pipeline failures and are clearly
stakeholders in this process. There must be opportunity for the public to
participate in setting these goals.
DOR August 30 - sent to responder for clarification, final
response - 5. Audit of integrity management programs for all companies ... it
seems to me the present team of field inspectors are increasingly focused upon
identifying deficiencies within the pipeline integrity management plans of the
owner companies vs. educating and assisting companies to better understand the
regulations and to assist with compliance efforts. Although it may be a
romantic notion, but it seems to me the relationship between AER, inspectors and
owner companies has changed substantially over the past 20 years, and has
migrated towards a “policing” body vs. serving as an enabling resource to the
industry as a strategy for elevating compliance to regulations, and improving
4. A standardized risk ranking for pipelines is a good
objective; however it seems unlikely an effective standard method could ever be
established. At present a number of risk ranking methods exist within owner
companies and within a number of technical organizations working in the area of
The objective of a risk assessment project is to
narrow-the-focus of the owner towards the most likely pipeline segment to
experience a release, and with consideration of the cost consequence of
environmental impact and reclamation, and business losses.
The issue here is
that the present risk assessment methods applied by the owners are typically
created in-house without inclusion of qualified third-party consultation. These
in-house methodologies are simplistic and do not include complete consideration
of data, and data assessment algorithms necessary to characterize all root-cause
issues that may contribute to a pipeline release. The AER has long recognized
the risk assessment methods created within owner groups, and throughout many of
the third-party creators of risk assessment models deliver insufficient
results. Furthermore, the presentation of risk results by means of a standard
“risk matrix” causes all methods to appear equivalent whereas the rigour of the
data model and technical assessment algorithms will substantially vary in
quality and completeness.
There is a challenge in this area as to the
determination of a quality risk assessment model. The skills to assess the
models in use throughout Alberta may not lie within the AER. Even more
confusing is that the world-wide corrosion technical organization dedicated to
training on pipeline risk assessment (NACE International) promotes incomplete
risk assessment methods within their technical standards and technical training
Simply stated, the root cause of 65% of all pipeline failure events
attributed to internal corrosion (14,000 since 1980) is the inability of the
owner to properly characterize the internal corrosive environment, and the
changes to this environment that occur vs. time as a result of declining
production trends from the upstream producing wells feeding the pipelines.
With an insufficient characterization of the severity of the internal corrosive
environment, the owners are unable to schedule the proper mitigation activities
aligned to the actual corrosive environment within the pipelines.
of the owner companies is to do assessments, and to rely upon the outcome of
these assessments to schedule and execute mitigative and maintenance activities
to abate the corrosion attack and failure.
At present, industry demonstrates
no reluctance whatsoever to spend monies to execute effective mitigation
programs. The lack of success is the insufficient and simplistic technical
methods by which industry, and third-party specialists assess the hazard
conditions within the pipelines. The present technical risk assessment
standards create recommendations for mitigation that are seldom aligned to the
actual internal corrosion hazard condition within the pipeline structures; the
root cause of most pipeline failure events in Alberta.
It may be prudent for
the AER to fund a project on behalf of the public to create, by inclusion of a
sufficiently qualified technical team, a standard risk assessment method for
producing pipeline systems that would be available to all users as an
alternative to the proliferation of insufficient methods; the present
It is not impossible to create an effective risk assessment method,
but it will only occur if industry technical "experts" let go of the idea
existing ineffective risk assessment methods are delivering the desired pipeline
9. Staffing levels trigger an impression that man-count
will result in improvement to pipeline performance. As an alternative, I see
lack of alignment of field inspectors’ activities to a consistent philosophy of
enabling improvement with the owner community, and this inconsistency manifests
a conclusion of insufficient resources.
Inconsistent behaviours and a
spectrum of expectations imposed by field inspectors onto the owner community
occur across disparate regions of Alberta.
I encourage a consistent culture
whereby the field inspectors focus on participating with owners on the design
and execution of pipeline integrity programs, and correspondingly reduce the
focus on finding fault, and initiating enforcement. An example of cooperation
vs. policing would be if the AER published a series of Standardized Integrity
Management Manuals for selection and use by the owner companies (based upon
complexity of asset base) as opposed to requiring every owner company to create
their own Pipeline Management Manual; it is likely there are over 400 different
manuals (and standards for assessment and control of failure events) in Calgary
that have been created for management of the provincial pipeline asset base, and
these manuals are audited by AER inspectors, and the programs created from these
manuals are not providing satisfactory pipeline performance to the public, or
the owners; the creation and implementation of standardized pipeline integrity
management programs could easily become more efficient, and effective if enabled
by AER, inspection teams.
It may be time for the AER to simply publish
acceptable standard manuals so the industry can move ahead in a consistent
manner, eliminate non-productive and redundant work, and avoid the proliferation
of ineffective maintenance programs that prevail in Alberta.
of needed collaboration is by empowering regional AER field inspectors to
advocate qualified third-party pipeline integrity services / risk assessment
methodologies and associated services to owner companies based upon actual
experience of AER. There are barriers at present in Alberta to the connection
of owner companies (who may be subject to repeated pipeline failure events and
high-risk enforcement) with the necessary and available expertise and services
to alleviate active pipeline integrity issues. Aligning needed services to the
owner companies will directly reduce failure events for the owner and deliver
improved pipeline safety to the public. In summary, it is often the case that
an operating company is under duress, has a desire and a demonstrated
willingness to implement quality programs to address pipeline integrity, and yet
is uncertain how to access appropriate, quality resources; the AER inspection
team could be an affective enabler.
14. & 15. I recognize water
crossings are an important issue for pipeline operations, however it is my
experience that pipeline releases most often travel from a leak site to an
adjacent water body and enter at locations other than a true “crossing”. For
example, a pipeline operating nearby a water body (swamp, river, lake etc.) but
with no specific crossing may represent a tremendously expensive exposure to
environmental damage yet would not be considered in a risk assessment model if
true “crossings” were the only focus. A spatial data model that identifies
vulnerable water bodies around a specific buffer around a pipeline structure
will provide a more detailed, and meaningful characterization of vulnerable
water resources attributed to potential interaction with a pipeline leak vs. a
nominal characterization of the hazard by consideration of “crossings”
DOR August 31 - I completely agree in principle to the
notion of improvements in Integrity Management and Safety & Loss Management
System. The question is whether these improvements will be substantive.
The goal of these programs and improvements should be avoidance of pipeline
incidents rather than responding quickly to incidents. The recent rash of
pipeline incidents have more to do with the integrity and compliance of owners
to their present operations management systems [OIMS] than a lack of capability
to respond after the fact (although, as the US Department of Transport has said
on the record, some Owners operate like the Keystone Cops).
Underlying this integrity and compliance to present OIMS is the view that
conformance to the pipeline requirements of CSA Z662 is the sine qua non of
pipeline operations. While it is an excellent document, it also is subject to
misuse and abuse by pipeline designers and operators. This is not a deficiency
in the Standard, but rather a case of the standard writers relying on the
experience and judgment of the standards users to use the Standard
appropriately. For several reasons, this is not the case even among the more
sophisticated pipeline operators. These reasons extend from the deliberate, from
ignorance and from lack of suitable engineering skills in designer and owner
organizations. While training in design and operations of pipelines is an easy
answer, regulators and owners need to look past the superficial aspects of the
Standard and look at the more technically intricate aspects of design and
operations which likely play the major role in incident occurrence.
DOR Sept. 3 - Inadequate Scope, Inadequate Public
Consultation, Inadequate Inspections, Inadequate Detection Systems, Inadequate
Enforcement, Inadequate Respect for Essential Ecosystems!
DOR Sept. 3 -11. There should be no takeover, mergers or
sales allowed of pipeline companies who have built the pipelines.
should be a fund set up by the companies who stand to gain from profits of the
pipeline (i.e. like BP). This fund should contain the minimum amount of money
that would have to be spent should there be a leak (i.e. Louisiana). This fund
should have at least 1 billion dollars (NOT TAXPAYERS money). This money must be
provided from the oil/gas/pipeline owners who are making money via the pipeline.
NO government money either.
ONLY Canadians and those who reside in the
province where the pipeline is being constructed have the authority to develop
standards, personnel certifications, set staffing levels, as well as approve or
disapprove of any pipeline construction at, near, over or around water
DOR Sept. 7 - I would recommend that an independent registry
and audit system should be created to ensure compliance is reached and
sustained. I believe that regulations and standards have been in place for
companies to use but without a scalable model for policing we will have huge
difficulties in ensuring compliance. There are a a number of processes that AER
has now that are great, there efforts to combine Environmental under the same
umbrella as facility and pipeline is a home run.
The true hole is in
document collection, retention and accessibility. If you measure it it can be
DOR Sept. 12 - Need to inspect watercourse crossings after
high water flow events. Define the high water flow events - 1 in 5 year event
for example, or more than 10 cm in 48 hour period. Some pipelines are attached
to oilfield road bridges, but the bridges are out of service and only maintained
to support the pipe. Need to review strength of bridges. Need to put ROE
Land-use dispositions under authority of either ESRD or AER. Currently these
dispositions are under authority of the surface rights board only, which has no
monitoring agency. Many are in non-compliance. Pipeline crossings for emergency
wildfire equipment or other business such as logging - in many situations
equipment may not be able to cross pipelines, every size, style, material,
depth, and age of pipe, and every company, has their own pipeline crossing
standards. This affects safety of crossings, safety of workers crossing
pipelines, especially emergency workers. Need all pipes constructed and designed
that some pre-determined crossing design will allow for safe crossing of all
pipes. often thee are multiple pipes in one right of way. Some pieces of
forested land become in-accessible to forest industry because they can not
safely cross a pipeline. For major lines - require pre-constructed emergency
crossing locations every x distance. need records of what materials of have been
transported through a pipe. pipes get bought and sold and the products being
transported changes over time. a pipe carry sour this year marry carry sweet gas
next year. Different products corrode pipes at different rates. need a record.
As much as possible, pipelines should be pushed into common corridors, easier to
manage on the landscape, reduced wildlife impact, less pipeline corridors to
worry about impacting. Train ESRD emergency response division in pipeline
cleanup and pollution control. Pressure integrity testing of pipelines at 10
years of age, and every 5 years thereafter, and if a pipeline has been out of
service more than 1 year - integrity testing required before placing back in
DOR Sept. 16 - The recommendations are fine but need to be
much more robust to deal with Alberta's mounting pipeline problems. One
recommendation is to ensure that companies are employing the best available
spill detection technology. Most pipeline spills are not detected by current
spill detection. This means that spills will generally be larger and more of the
environment will be impacted. Countries like Germany employ much more robust
spill detection systems and Alberta should do the same. This type of best
technology should be used throughout Alberta's pipeline network.
DOR Sept. 18 (See answer in #3)
DOR Sept. 23 - Response from the Pembina Institute:
(i) The recommendations indicate there are clear gaps in protecting public
safety and the environment with an aging and growing pipeline system. A recent
report by Global News found that in the past 37 years, there has been an average
of 2.2 crude oil spills from pipelines per day. When considering all substances
that are shipped via pipeline, this number increases to an average of over 4
spills of any type per day. We welcome the swift implementation of these
recommendations, and to some extent are surprised that some aren't already in
(ii) The recommendations have the potential to improve the oversight of
pipelines in the province. The key going forward will be the accountability
associated with implementing these recommendations, and whether they reduce
impacts of pipelines or the overall number of incidents in the province. This is
a test of leadership for the new AER, which we hope they will meet through
adequate implementation and enforcement.
DOR Oct. 3 - We, the public need to have faith in the
operation of our province’s resources, we should not be reviewing the government
decisions to ensure that the government has a long term plan. We should not need
to resort to changing governments for unsatisfactory decisions.
government political leaders could have shown true leadership by initiating a
pipeline safety review rather than needing encouragement from the Coalition. I
am disappointed at the political game of sitting on this report for eight
months, formulating technical teams and then releasing the report as close to
the Labour Day long weekend as possible. A public comment time of forty five
days was too short.
Alberta Minister Ken Hughes asked Group 10 Engineering
to “examine the safety and integrity of the province’s pipeline system”.
Group 10 Engineering only concluded that Alberta has the most “thorough
overall regulatory regime of all assessed Canadian jurisdiction” for almost a
half million dollars.
“Thorough overall regulatory” only means that Alberta
has the most regulations, i.e. rules. Group 10 did not assess the validity of
these regulations or the adherence to these rules. Since Alberta has always
prided itself as superior performer and abhors government regulation, the
standard of Canada Standard Association standards would be the minimum
performance level. Group 10 also makes no assessment of the safety or integrity
of the pipeline system.
Since 80% of Canada’s production is in Alberta,
Alberta should be the leader of best practices. As an Albertan, superior
performance would be my expectation. Since Alberta is the starting point of most
pipelines and waterways, Alberta owes Canadians the greatest duty of care.
The conclusion that the “presentation and comparison of pipeline leak and
failure statistics… is not possible” is probably irrelevant since 80% of the
Canada’s production is sourced from Alberta. According to CAPP, Saskatchewan
produces 15% of Canada’s production. Saskatchewan has had 15,000 incidents of
leaks/failures since 1985. Their reporting is immediate and detailed. Location
of incidents as well as the companies experiencing multi failure can be clearly
identified. An excel user could extract the necessary information for
comparative purposes. Alberta’s reporting delay has grown from 6 months to 18
months from end of the reporting year.
Alberta Energy uses the indicator of
breaks per 1,000 km and boasts about the significant decrease of breaks. In
actuality, this reporting method is used to obscure the actual incident
occurrence. Since about a half of the pipelines have been built within the last
15 years using improved technology, these pipeline should have a zero weight
A group of sixteen owners were selected to contribute their
thoughts about the safety of their operations and if their pipelines were
effectively regulated. I would like to know the names of these companies and
compare their safety record against the incident reports. Some companies are
upstanding corporate citizens but others might not be questionable. Which
companies would admit that they were not operating safety and felt that
regulations were not effective? A group of 16 out of licensees is 1% the total.
That is quit a stretch to extrapolate findings based on such a small sample
size. Is it even statistically reliable?
Government as our asset steward,
owes us responsible resource development. Governments balance the need of a
revenue stream with measures that ensure safety to the public. Our future is not
to be sold for a handful of beans today.
If I can quote Minster Hughes “Organization that creates the risk should
manage the risk and be responsible for the consequences”. We, Albertans expect
that the government manages on our behalf.
Some organizations are engaged in responsible activities, yet some are not.
If companies do not value our lands and our water and our people, as evidenced
by endless mishaps and public information, should they be doing business here in
Development of Alberta’s natural resources is a collaborative effort between
producers and landowners.
DOR October 4 - Thank you for the opportunity to respond to
the recommendations made in the independent review of pipeline safety released
on August 23, 2013. Alberta has a long and proud history of responsible energy
development that includes strong energy regulation. Alberta’s self-regulated
Professional Engineers and Geoscientists are an integral part of that history.
We know that we must also be an integral part of future solutions.
The Association of Professional Engineers and Geoscientists of Alberta
(APEGA) is very interested in assisting the Government of Alberta and the
Alberta Energy Regulator (AER) in addressing a number of the report’s
recommendations related to public safety, response to pipeline incidents and
pipeline integrity management.
Specifically, APEGA has access to a robust national network and we are
prepared to bring together resources (people) and provide direct advice
In addition, APEGA, in conjunction with the Association of Science &
Engineering Technology Professionals of Alberta, is prepared to take a leading
role in developing pipeline inspection qualifications.
We are in contact with the AER and we look forward to working with them. We
have also offered our assistance to the Auditor General.
APEGA’s mission is to serve the public interest and our social license flows
from our commitment to public safety. We look forward to working with you and
the other regulators in order to ensure our professions best serve Alberta’s
Mark Flint, P.Eng.
Question 3 - Do you have any other policies or processes that
you think should be considered?
DOR August 27 -
Liability Management - There is a huge shortfall with respect to liability in AB
that should be addressed.
DOR August 27 - Establish or track age of pipelines as part
of the risk ranking. Track breaks and spills by the GPS location not by legal
subdivision Establish a monitoring program based on age, risk and material being
transported. Review older field infrastructure that is being re-vitalized due to
new fracking techniques and increase in volume within the pipelines. Promote the
use of high resolution infra-red imagery and technology for pipeline inspections
Investigate high temperatures within pipelines and how they are changing the
surface eco-system as the surface is not freezing during winter periods
Standardize the pipeline crossing requirements to meet a Provincial or national
standard to safe guard pipe integrity. Create inspection criteria on waterbodies
based on risk not on definition. Inspection has to include watercourse flows and
risk to pipe integrity.
DOR August 29 - A pipeline safety review should identify the
most common root causes of pipeline failures and then should provide
recommendations for a regulatory regime to address those root causes. The
Alberta Pipeline Safety Review clearly failed to achieve this. There was no
consideration of the causes of pipeline failures, there was no assessment of the
condition of Alberta's pipeline systems and there was no independent review or
verification of compliance with existing regulations. A more thorough inquiry,
with an opportunity for public input, is required. The AER should conduct more
frequent audits of compliance and results of compliance audits should be posted
publicly. Further, existing penalties under the Pipeline Act are insufficient to
encourage compliance. Penalties under the Pipeline Act should be increased to be
in line with other modern environmental regulations. Finally, the Pipeline
Regulations should set firm timelines for addressing pipeline integrity issues
identified in pipeline integrity management programs. For example, any evidence
of pipeline corrosion or defect identified through in-line inspection tools must
be excavated and investigated within 6 months of the in-line inspection.
DOR August 31 - My personal experience with pipeline
operators was alarming with regards to skill levels and attitudes among
personnel. Probably the most disturbing was the combination of attitude and
owner’s management practices. The specific incident deals with a serious
operational incident for which the owner did not want to conduct a root cause
failure analysis [RCFA]. This is a fundamental management technique to find root
cause and identify mitigation. It is a well-established technique in heavy
industry and in the engineering community as a fundamental OIMS approach but was
completely ignored by the operator.
My recommendation is that the regulator review current OIMS and SLMS programs
and benchmark to best practices of comparable industries (such as the downstream
hydrocarbon processing industry) to ensure present pipeline safety programs have
substance and are being effectively executed.
DOR September 3 - Public Health Act, Public Lands Act, Water
Act, Environmental Protection and Enhancement Act Should All Be Enforced!!
DOR September 3 - Make sure that pipelines
are built to the highest standards of safety, as well as taking into account any
natural hazards. It is time these oil/gas and pipeline companies quit trying to
squeeze every penny in order to keep their shareholders happy while putting at
risk our communities, our sources of drinking water and our livelihood.
DOR September 7 - A couple new user friendly scalable
processes that make sense are Vintri Technologies and BlackBox IDC.
DOR September 16 - Major changes to Alberta's enforcement,
inspection, and oversight should be considered and implemented. Alberta needs
more inspections. The regulator should be completely independent and be given
teeth to ensure that companies comply.
DOR September 18 - Currently, it is very difficult to find
spill incidence rates for pipelines in Alberta. It is possible to find spill
rates for NEB regulated pipelines, but this is just a subset of the overall
pipeline inventory. As an investor, we are interested in being able to compare
individual companies against their peers, and would be concerned with companies
that fall short of the industry average. However, it is currently not possible
to determine the average spill frequency or volume as the data is not available
to the public. The collation and publication of this data would be very
beneficial, not only to investors, but in ensuring the public that pipelines are
being well managed.
DOR September 23 - Response from the Pembina Institute:
(i) In addition to the Group 10 recommendations, we strongly recommend the
Government of Alberta implement the findings of the upcoming Auditor General
Pipeline safety audit, which will focus on evaluating pipeline monitoring and
inspection systems, and overall compliance with current Alberta pipeline
regulations. This addresses a significant gap in the Group 10 report. While the
report concluded Alberta has the most thorough regulatory regime amongst
assessed Canadian jurisdictions on paper, it fails to assess real-world
performance of the pipeline system and enforcement of regulations.
(ii) It is concerning that the Group 10 report finds that Alberta has a
mature pipeline system with “the most thorough overall regulatory regime of all
assessed Canadian jurisdictions,” but yet pipelines in Alberta continue to spill
on a daily basis. This is potentially indicative of Alberta's track record of
being too lenient in enforcing its own regulations. An ERCB report from June of
this year stated that all oil sands companies have failed to meet Directive 074
over the past two years and no enforcement action will be taken. The ERCB's
report was followed in July by a Global Forest Watch report stating that from
1996-2012, Alberta's environmental enforcement rate in the oil sands region was
less than 1%. These reports indicate that in Alberta, an assessment of the
regulatory regime without an assessment of enforcement is insufficient. An
assessment of enforcement, which builds on the current report by considering the
effectiveness of regulations within the context of real-life incidents, should
be completed and used to inform additional recommendations.
DOR October 3 As per Section 37, spillage – “contain and
eliminate spillage”. When spillage occurs on lands, the landowners have an
interest in the remediation of damage. The landowners are usually the first on
site, they alert the producers. The landowners know the land intimately but quit
often their knowledge with land and water flow is discounted. Landowners have
successfully managed the land for many years. Yet, there is no recourse to
participate if the remediation is not properly done. The landowners may not be
as experienced in dealing with the endless incidents but are vested none the
How can landowners participate in the remediation process when they cannot
trust the petroleum producers or the government to value their