2013 Pipeline Safety Survey Comments

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, 2013. 

  1. Do you agree to have your comments shared? (93.75% agreed to share)

  2. 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. Recommendations:
    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 response exercises.

    Pipeline Integrity Management
    4. Create a standardized pipeline risk ranking in Canada.
    5. Routine Audit Integrity Management Programs for all companies.
    6. Create requirements for inspection/testing in high risk areas.
    7. Create personnel certification programs in pipeline safety.
    8. Use performance based regulation.
    9. Review staffing levels associated with pipeline safety.
    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.
    13. Educate 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
    for design, 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?

  3. Do you have any other policies or processes that you think should be considered?  

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 pipeline safety.
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 pipeline integrity.
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 schools.
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.
The desire 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 state.
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 safety outcomes.
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.
Another example 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” alone.

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.
There 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 sources. 

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 made better

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 service.

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 place.

(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.
Our 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 incident rate.
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 Alberta?

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 regarding:

  • public safety

  • emergency preparedness and response

  • integrity management including risk analysis and development of standards

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 public.

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 less.

How can landowners participate in the remediation process when they cannot trust the petroleum producers or the government to value their contribution?