AUC review of gas utility pipeline integrity management and emergency response plan manuals
Gas utility pipelines in the province transport high pressure natural gas to industrial users, to other pipeline systems, and to distribution systems, which further distribute natural gas at a lower pressure to customers in Alberta. The Commission regulates many aspects of gas utility pipelines. It approves new pipeline construction, issues licences for pipeline construction, operation, abandonment and removal, reviews and approves routing, approves rates to be paid to transport gas through the pipeline system, and establishes rules and regulations for the design, construction, operation and abandonment of gas utility pipelines.
The AUC only regulates gas utility pipelines operating within the province of Alberta. The National Energy Board regulates any pipeline that crosses provincial or international borders.
For gas distribution pipelines operated at pressures less than 700 kilopascals, approval from the AUC is not required under the Pipeline Act. The AUC does not issue licences for low-pressure distribution pipelines. Under the Gas Distribution Act, the Rural Utilities Branch of Alberta Agriculture is responsible for the setting and enforcement of all standards related to the design, construction, operation, maintenance, quality assurance, plant records, surveys and as-built drawings for rural gas utilities and low-pressure distribution pipelines. The Rural Utilities Branch aggregates licence data for low-pressure gas distributors on an annual submission basis. With respect to routing of low-pressure gas distribution lines within cities and towns, the municipality reviews the routing within public thoroughfares and determines the associated facility line assignment. The AUC provides rate regulatory oversight for low-pressure distribution pipelines and has authority to investigate issues and resolve disagreements associated with distribution matters. Ongoing safety and operation concerns on these low pressure pipelines are addressed as required by the AUC through the provisions of the Gas Utilities Act.
The AUC has a memorandum of understanding (MOU) with the Alberta Energy Regulator (AER) for the AER to perform inspections and investigations for high-pressure gas utility pipelines owned by ATCO Pipelines and AltaGas Utilities. The AER maintains records of these tasks and reports the results to the AUC. Under the MOU, the AER investigates incidents and makes the situation safe. After the situation is safe, subsequent investigations are conducted by the AUC. In the event of a major disastrous incident investigation by the AUC a report would be prepared with the results made publicly available.
The Commission regulates two gas utility pipelines. One is owned by ATCO Pipelines, the other by AltaGas Utilities Inc. ATCO Pipelines is part of the ATCO Ltd. group of companies and owns and operates more than 8,500 kilometres of pipeline in Alberta. AltaGas owns four natural gas transmission systems in Alberta having a cumulative length of 530 kilometres.
Neither ATCO Pipelines nor AltaGas Utilities produce the gas they transport on their systems. ATCO and AltaGas do, however, build pipelines to move high pressure gas to customers. The gas in these systems is under sufficiently high pressure (greater than 700 kilopascals), that approval of construction and operation is required by the AUC.
AUC review of pipeline integrity and emergency response procedural manuals
In order to satisfy itself that gas utility pipelines have appropriate documentation of procedures to monitor pipeline integrity and to respond to a potential emergency incident, the Commission undertakes to review the relevant procedure manuals for the gas utility pipelines it regulates in Alberta. This examination assists in the process to ensure safe and reliable pipeline facilities in Alberta, considering the economic, social and environmental effects. This examination was further referenced in Decision 2014-010 ATCO Pipelines Urban Pipeline Replacement Project where the Commission stated that a consultant had been engaged by the Commission to verify that policies, methods and procedures are in place to manage pipeline integrity on the ATCO Pipelines system. In that decision, the Commission indicated that the results of that review would be shared and that the Commission would deal with any issues that might arise.
The AUC requested AltaGas Utilities Inc. and ATCO Pipelines, under the authority of the Pipeline Regulation, sections 7 and 8, to file copies of their manuals relating to pipeline integrity management and emergency response plans. An independent consultant was engaged by the AUC to review the content of the manuals against the criteria established in the relevant standards and legislation. The consultant’s reviews and the utilities’ response to those reviews are provided below.
In general, the consultant found the pipeline integrity management manuals for ATCO and AltaGas to be satisfactory with some clarification opportunities identified. The emergency response manuals for ATCO were assessed similarly. A number of opportunities for improvement were initially identified by the consultant for the AltaGas emergency response manual. In that respect, Commission staff and the consultant met with AltaGas in October 2013. AltaGas subsequently filed updated manuals and provided further clarification details. The Commission is now satisfied that previously identified shortcomings for AltaGas have been demonstrated to be resolved and that AltaGas has adequate documentation within its emergency procedure manuals. The Commission considers that completion of this review also satisfies the reference in Decision 2014-010 to share the results of the review process for the ATCO Pipelines integrity management procedures.
The Commission intends to update its review of the pipeline integrity management and emergency response procedural manuals on a five-year basis.
AUC review of risk identification, integrity inspections, overpressure protection and pipeline water crossings
In September 2014, the Commission requested reporting from ATCO and AltaGas with respect to risk identification, integrity inspections, overpressure protection and pipeline water crossings. Responses were received in November 2014. In February 2015 the Commission requested further information from ATCO and AltaGas respecting overpressure protection. In December 2015, additional responses were submitted. ATCO Pipelines indicated in November 2016 that it was finalizing its investigation at several sites. In February 2017, ATCO pipelines confirmed that adequate overpressure protection is in place at all sites and that it will be re-verified annually.
AltaGas Utilities Inc. September 29, 2014 - AUC letter to AltaGasNovember 28, 2014 - AltaGas letter to AUCFebruary 12, 2015 - AUC letter to AltaGasDecember 1, 2015 - AltaGas letter to AUCMarch 2, 2017 – ATCO email update
ATCO PipelinesSeptember 29, 2014 - AUC letter to ATCO PipelinesNovember 28, 2014 - ATCO Pipelines letter to AUCNovember 28 - 2014 - Attachment to ATCO Pipelines letterFebruary 12, 2015 - AUC letter to ATCO PipelinesDecember 22, 2015 - ATCO Pipelines letter to AUC
AUC review of potential substandard pipeline materials and design
In March 2016, the AUC requested ATCO Pipelines and AltaGas Utilities to ensure that substandard pipe materials and installation practices such as identified in National Energy Board safety advisories have not occurred and are prevented. Both utilities provided responses in June 2016 confirming that their installations were appropriate and providing their associated design and installation processes.
March 3, 2016 - AUC letter to ATCO Pipelines and AltaGasJune 28, 2016 - ATCO Pipelines letter to AUCJune 28, 2016 - AltaGas letter to AUC
AUC review of ATCO Pipelines radiographic weld inspections
On April 27, 2016, ATCO Pipelines verbally advised the AUC that it was investigating potential shortcomings associated with radiographic inspections for prefabricated piping assemblies conducted by outside contractors in the ATCO Edmonton welding shop between 2008 and 2015. The investigation scope includes review of both the quality of the radiographic films as well as the quality of the welds. The following correspondence describes the process undertaken:
May 3, 2016 voluntary self-disclosure letter from ATCO Pipelines to the AUC and AERMay 13, 2016 letter from AUC to AER regarding lead investigative role
May 13, 2016 letter from AUC to ATCO requesting informationMay 31, 2016 letter from ATCO to AUCMay 31, 2016 attachment from ATCO to AUC
June 27, 2016 letter from AUC requesting further informationJuly 18, 2016 letter from ATCO to AUCJuly 18, 2016 attachment 1 from ATCO to AUCJuly 18, 2016 attachment 2 from ATCO to AUC
September 29, 2016 letter from AUC to ATCO requesting further informationOctober 25, 2016 letter from ATCO to AUCOctober 25, 2016 attachment 1 from ATCO to AUCOctober 25, 2016 attachment 2 from ATCO to AUCOctober 25, 2016 attachment 3 from ATCO to AUCMarch 7, 2017 letter from ATCO to AUC with quarterly updatesMarch 7, 2017 attachment quarterly updates to December 2016April 4, 2017 letter from ATCO to AUC with quarterly updatesApril 4, 2017 attachment quarterly updates to March 2017
The AUC will continue activities to ensure the ongoing safety of the pipeline systems it oversees.
For further information or clarification, contact Brian Shand at email@example.com or 403-592-4434.