Sep. 28. 2015 3:45PM No. 0180 -P, 3 RooM - ‘ COURUE; ¢ TransCanada 28 P35) In business to deliver 450- Ast Street S.W ee Calgary, Alberta, T2P SH1 s.19(1) 3transcanada.com 28 September 2015 National Energy Board 517 10" Avenue SW. Colgary, Alberta, T2ROAB ‘Attention: Ms Sheri Young, Secretary ofthe Board Dear Ms. Young: re: NEB File OF-Surv-PI-1221-05 Response to the National Energy Boards (NEB) Draft Report Examining Allegations of ‘TransCanada Non-Campllance with Regulations Thank you for providing TransCanada Pipelines Limited (TransCanada) with a daft copy af the NEB report which examined allegations ralsed by @ complainant of reguistory non-compliance in TransCanada's construction and maintenance practices. We appreciate the opportunity you have provided to TransCanada to review and comment on the report, TransCanada’s comments and suggested changes to the draft report are attached to this letter (see ‘Attachment 3) for your consideration. Please contact ma with any questions or If you require additional information. Yours truly, TransCanada PipeLines Limited ‘Manager, Canadian Regulatory Compliance cer Russell Girling, President and CEO, TransCanada PipeLines Limited SEP~28-2015 16:20 96% P .00‘Aoo10052_1-000106Seo. 28. 2015 3:45PM . Ne 0180 PT Tanacunad et Coe care mrs Q rransconaca asec — bos evinbr 28 206 Attention ‘Ms. Sheri Young, Secretary of the Board Fax (403) 292-5503 Pann ‘From rane Fax No.ofPages * 9 (includes this page). ‘TransCanada PpeLines Lite provides comments in regard tothe Naina] Energy Board “Report Examining Alegatons of ‘TransCanada Non-Compltance with Regustions”, . Please contact mei there are any probiems with this transmission You Tru, — ‘Maneger, Canadian Regutatory Compliance a ertdetn Tax ecu ante yr ad nese. Tscomricsfan may eelin boalon all pag, crete or eaves ‘rac fem com end ol bed, capi. waed rae wot aan. you hve meted sak hee plas raly na ‘sederinesuely nd cate aed dauneton. Tako fo Your coopera. \vanecnada com, .A0010052_2.000107 SEP-28-2016 16:19 96% t ~Sep. 28. 2015 3:45PM he 0180 -F 4 ‘Comments on Draft Report Examining Allegations of TransCanada’s Non-Compliance with Regulations 15 Al ‘Text appearing under ‘As the Board has acknowledged in "Requirements for intarnal | section 1.5, the report has been prepared ‘Company Reporting” ‘outside of the OPR audit process. ‘Accordingly, inclusion of this section could cause confusion and TransCanada suggests that comments regarding the results of the 2013 OPR audit be removed {rom the report. — Dad 1 “The allegation was that that | Remove duplicate word. ‘mechanical damage.." aad 1 “pipeline. . Although" Remove duplicate period, 2a2 1 "TransCanada was not TransCanada suggests changing the ‘required to report this to | sentence to, “The pipeline was the Board fortwo reasons" | depressurlzed at the time and “TransCanada was not required to report this to the Board for two reasons" to clarify that at no time was there any danger to the public, employees or the environment, as stated In TransCanada's original response. 232 Last bullet | “Pipe damage was assessed | TransCanada suggests darification of this on pi2 | by athird-party non- statement. The wording suggests that destructive examination _| TransCanada inspected 360 degrees of (NDE} contractor using the pipe during the initial inspection ‘magnetic particle inspection | following the line strike. This was not the {MPI} over the entire case, During the initial Inspection, MPl ‘circumferential area of the | was performed to the exposed area of pipeline that was potentially | the pipeline that was potentially affected affected bythe pipeline | by the pipeline strike. An inspection of strike {The Board notes that | the entire circumferential area of the this type of examination can | pipeline that was potentially affected by ‘only be performed when the | the pipeline strike was performed during Pipeline Is fully exeavated | the investigative dig in May 2014, and exposed, versus belng I Inaddition, the wording in square partly backed} brackets is incorrect and should be removed from the report. | ‘TransCanada suggests the folowing wording for this bullet to reflect its SEP-20-2015 16:20 96% ‘A0010082_2-000108Sep. 28, 2015 3:45°M Ho, 0180 P. above: "Pipe damage was assessed by a third-party non-destructive examination (NDE) contractor using magnetic particle inspection (MPi} over the area of the pipeline that was potentially affected by the pipeline strike." 5 242 last paragraph “may have been caused by the hydro-vacing activity ‘during the original ‘excavation conducted on 18 ‘May 2013." ‘The hydovac activity referenced ‘occurred on June 1, 2033 as mentioned in ‘TransCanada's submitted response, 213 "The Board finds that this allegation was partially ‘substantiated in that a pipeline strike occurred." ‘TransCanada requests that this allegation bbe changed to a Case 3 scenarlo for the {following reasons: 1) The allegation as stated both inthis report and as originally communicated to ‘TransCanada In February 2014 clearly tefers to "mechanical damage caused to the pipeline", Through TransCanada's investigation immediately following the line strke and its subsequent Investigation in May 2044, tt has been demonstrated that there was no ‘mechanical damage to the NPS 42 Edson Mainline Loop pipeline during preparation for the 2013 hydrotest; 2) As agreed by the Board in this draft report, the coating used in the intial ‘epalr was a common and industry acceptable coating repair practice; 3) As described in TransCanada's response to this allegation, TransCanada believes the unrepaired coating damage found in May 2014 was caused by bhydrovac activities in June 2013, nat from ‘contact with a hoe bucket, 213 "While the company appeared to be following its ‘TransCanada suggests changing. “mechanically assisted hand excavation” SEP-28-2018 16:20 3 ‘Aoo10052_4-000108Sep. 28. 2015 3:46 No. 0180 F. 6 ‘to “excavation” to correctly reflect the procedures with respect to _| type of excavation that was taking place. the mechanically assisted hand excavation..." 218 1 "TransCanada should TransCanada conducted a comprehensive Identify the raot cause of | root cause analysis of this incident. As the failure to identify this | stated in our original submission, the crossover.” results of the investigation were presented to TransCanada’s Operations ‘and Engineering senior leadership team ‘on July 9, 2013 and TransCanada's Corporate Health, Safety and Environment Committee on July 17, 2013. Following the root cause analysis, actions taken Included: additonal taining and evaluation of on- site personnel; logging and communicating 2 non- conformance against the contract survey company; = ceview of TransCanada's Excavatton Checklist and Excavation Training Package. 222 1 “at 13:30, TransCanada field | TransCanada sugnests changing "drop personnel estimated It ta be | every five seconds" to "drop of water ‘one dop every five every five seconds" to clarify for external seconds" readers ofthe report that this was not = hazardous lquld release 223 3 “since the leaks acceptable | TransCanada suggests deleting this there is no need to sentence as it appears to endorse speculate.” speculation. 232 First “A TeansCanade Right of | TransCanada suggests changing "Right of bullet | Way patra report." ‘Way patrol” to “serial pipeline patrol” to be consistent with the fourth bullet. 262 2 "TransCanada submitted | inits response, TransCenada did not that.” provide the commentary on CSA 2662-11 ‘mentioned in the third, fourth and fifth bullets. TransCanada believes there is value inincluding this but suggests Lo moving these bullets to a different SEP-28-2015 16:20 96% Avotbds2_s-000110Sep. 28, 2015 3:46RU 262 3 “in photograph submitted | In accordance with CSA 2662-11, by TransCanada, two mitre _| TransCanada suggests changing ‘mitre bends less than 3 degrees.." | bends" to “deflection welds, as mitre bends are not fess than 3 degrees. 262 4 "The Board notes that the | In accordance with CSA 2662-11, dallberate use of multiple | TransCanada suggests changing "multiple Imitre bends, each less than | mitre bends" to "muhtiple deflection 3 degrees." | welds", as mitre bends are not less than 3 degrees, 263 2 “"The Board notes that tn accordance with CSA 2662-11, . ‘TransCanada did use two | TransCanada suggests changing “mitre mmitreed bends less then 3 bends" to "deflection welds", as mitre degrees..." bends are not fess than 3 degrees. 263 2 "The two mitre bends were | In accordance with CSA 2662-11, ' notin close proximity to _| TransCanada suggests changing "mitre eachother” bbends* to "deflection welds", as mitre bends are not less than 3 degrees, 263 2 “While the practice of using. In accordance with CSA 2662-11, ‘multiple mitre bends... | TransCanada suggests changing “multiple ritre bends" to "multiple deflection welds", as mitre bends are nat less than 3 degrees, 2.63 2 “welding inspectors would | tnaccordance with CSA 2662-11, ‘consutt with Engineering on | TransCanada suggests changing "multiple project-by-project basis for | mitra bends" to "multiple deflection the acceptability if multiple | welds", as mitre bends are not less than 3 mitre bends were degrees. considered fora repair.” 266 1 “Board Inspectors may Inaccordance with CSA 2662-11, perform additional checks | TransCanada suggests changing “multiple {or the use of multiple mnitre bends" to “multipie deflection ritreed bends to correct for | welds", as mitre bends are not less than 3 misalignment degrees. . 272 1 "This allegation is related to. | TransCanada suggests changing this repair activities that took | sentence to “This allegation pertains to place foliowing a rupture | pipeline repair work on the North Central ‘that occurred," Corridor Loop in October and November SEP-28-2018 16:20 5 ‘Aoo10052_6-000111, 96%Sep. 28. 2015 3:46PM No. 0180 A 8 2013." which makes it consistent with the wording used in section 2.6.2 aoa a "The allegation s thatthat | Remove duplicate word. the mitre bend." -——- 21020 | 3 “This allegation pertains to | TransCanada suggests changing remediation activties... | “remediation activities” to “planned construction activities" as this was work related tothe installation of new pig launcher and receiver assembtes and not to any type of repair. 2.102 | Bulleton | "TransCanada believes the | TransCanade suggests that this statement p39 ‘weld location referenced in | be removed from the report as itwas ‘thisreportisincorrect* | Intended only to help guide the Board towards understanding the attached evidence provided In support of ‘TransCanada's responses. 2030 a "TransCanada submitted —_| In accordance with CSA 2662-12, evidence verifying ithad | TransCanada suggests changing “mitre Installed mitre bends... __| bends'"to "deflection welds", a8 mitre bends are not less than 3 degrees, 2103 |2 “The statement that a ‘TransCanada suggests revising this practice of using multiple | wording to match the statementin the mitre bends in excess of | allegation. Eg. "The complainant's three degreesisrisky's _| statement that, “cutting small pieces of directionally valld." pipe tofit into a curve Instead of using @ large piece of bended pipe... would put ‘extra stress levels on the line” is directionally vali.” ama 4 “TransCenada submitted _| in accordance with CSA 2662-11, documented evidence ‘TransCanada suggests changing the first verifying ithad installed | occurrence of “mitre bends" to mitre bends that were in| "deflection weds" and deleting the compliance with CSA 266-11 | second occurrence of “miter bends”, as 11, Cause 6.2.3 (g), which | mitre bends are not less than 3 degrees. allows deflections (mitre bends) up to 3 degrees.” 2a43 }iand2 } “csazs6-13" Both occurrences should be “CSA 2662- a” SEP-28-2015 16:20 96% ‘aoo100s2_7-000112Ses. 28 2015 3:46PM No. 0180 Pg SEP-28-2016 16:20 Indicated thatthe TransCanada." 2232 | First “TransCanada personne! _—_| The correct number far this Incident is bullet | entered this incident into its | 259566 as submitted In TransCanada's Incldent and issue Tracking} response. ‘System (W259732).." 2.18.2 | Second | *28,une 2013, following the | The Accident/incident Report was bullet | Incident, the cantractor and | completed by the contractor's TransCanada representatives and shared with epresentatives completed | TransCanada after completion. an Accident / incident Report." 22 |s "Based on the date specified in the information provided | that this was a “purge conducted ina bythe complainant, the | controlled manner rather than by blow blow down activity..." down." This s also confirmed later in section 2.14.3, Accordingly, TransCanada suggests changing the words “blow down activity" to “de-watering activity” of "water purging activity’ inthis paragraph. 21a 2 "The Board finds thet there | TransCanada suggests changing “blow- ‘was ne contamination of | down” to “de-watering activity’ or trees by fluids from the | “water purging activity” to he consistent block valve blow-down.” | with the conclusions in the following Paragraph, 2522 "The incident report stated | Inadequate assessment of the required that the contractor's PPE by the contractor was noted as the management was contacted | cause, as submitted In TransCanada's to inform them of the ‘esponse ta this allegation. This is Inadequate PPE issue as the | different from “inadequate PPE" as being root cause of the incident.” | the cause, Jaass 1 “Board inspectors will TransCanada suggests changing this to, continue to be mindful of | "Board inspectors will continue to Include the need to check for a check that appropriate PPE is being inadequate PPE for both —_| worn by employees and contractors employees and contractors | during future TransCanada site In ts future inspections of | inspections." TransCanada." 1 96% pootoosa_e.aoetssSee. 28. 2015 3:46PM Wo. 0180 P10 “nthe Board will review whether ar natits inspector ‘alning program." SEP~28-2018 16:21 ‘pAv010082_9-000114