NEB releases pre-construction audit report of Trans Mountain and corrective action plan
September 15, 2017 by National Energy Board
CALGARY – The National Energy Board (NEB) has released its pre-construction audit of Trans Mountain Pipeline ULC (Trans Mountain). The audit evaluated Trans Mountain’s preparedness to manage construction of its Trans Mountain Expansion Project in a way that assures worker safety and prevents incidents.
The NEB concluded that Trans Mountain had not yet established, at the time of the audit, all of the necessary oversight measures to manage construction-related safety and environmental protection for the construction of the project.
The company has filed its corrective action plan (CAP) and it has been approved by the NEB. As a result, the company can proceed with its construction where all requirements have been met. On an ongoing basis, the NEB reviews all compliance activities and has the authority to stop work if compliance is not being maintained and to ensure safety and protection of the environment.
“This pre-construction audit is one of our proactive tools for regulatory oversight for the NEB. This is all about prevention and we believe that significant incidents can be avoided in the future by ensuring companies have the proper systems and processes in place even before they begin construction,” said Peter Watson, chair and CEO, National Energy Board.
The NEB will monitor Trans Mountain’s implementation of the CAP, and verify the effectiveness of the company’s management system through targeted compliance verification activities as a part of its ongoing regulatory oversight of the project.
The pre-construction audit involved two months of document review and on-site activities, including extensive interviews with company employees and review of internal documents that describe company procedures, training materials, and staff responsibilities.
- The NEB maintains a proactive approach to safety and incident prevention and we take all available actions to protect Canadians and the environment.
- The NEB reviews the state of all compliance activities on an ongoing basis and has the authority to stop work if compliance is not being maintained.
- The Federal Government approved the Project last November, following a NEB recommendation in May 2016 that the Project be approved subject to 157 conditions.
- The fact-gathering portion of the pre-construction audit occurred between April 13 – June 14, 2017 in accordance with subsection 49(3) of the National Energy Board Act (NEB Act).
- During the audit, the NEB assessed whether the company’s documentation, processes and activities complied with legal and other requirements under the NEB’s authority relating to the NEB Act, the National Energy Board Onshore Pipeline Regulations (OPR), any conditions contained within applicable certificates or orders issues by the NEB and any requirements of applicable NEB safety advisories.
- The NEB reviewed 37 items in the audit. Of those, there were 11 in which the NEB did not identify compliance issues; 15 were found to be non-compliant; and 10 others were not assessed because the process or activities were not yet required at the time of the audit. One other item was not assessed because it was being evaluated through other NEB compliance verification activities.
- The CAP addresses all non-compliances and the NEB will continue to review that CAP to ensure compliance.
- For all items that were not assessed in this audit, the company must have all required practices in place in order to proceed with construction. The NEB, as part of its oversight, will be assessing those areas using other compliance verification activities.
SOURCE National Energy Board
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