Pipeline Safety Information Letter No. 01/20

200 Promenade du Portage
Place du Centre, 4th floor
Gatineau QC  K1A 1K8

11 December 2020

Director, Regulatory Affairs
Railway Association of Canada
99 Bank Street, Suite 901
Ottawa ON  K1P 6B9

Since April 2016, there have been 13 instances^{Footnote 1} of unauthorized activities by railway companies near operating pipelines. In these occurrences, railway companies or contractors working for railway companies engaged in ground disturbances and/or the operation of heavy equipment in close proximity to operating pipelines without first notifying the pipeline operators by way of a locate request. As such, the exact location of the buried pipelines was not identified prior to initiation of the activities. In two of these occurrences, the structural integrity of the pipeline was unintentionally affected (TSB occurrence numbers P20H0010 and P17H0135, described in Appendix A).

Pipeline operators need to be informed of planned ground disturbances and related activities in the vicinity of their pipelines to ensure that the pipelines are marked and protected in advance of these activities. For pipelines under federal jurisdiction, Canada Energy Regulator (CER) regulations^{Footnote 2} include requirements for any person intending to engage in an activity that would cause a ground disturbance within a prescribed area^{Footnote 3} to make a locate request prior to commencing work.

Given the risks posed by ground disturbances and related activities in close proximity to unidentified buried pipelines, the Railway Association of Canada may wish to remind its members of their obligations to make locate requests when planning to undertake such activities in the vicinity of operating pipelines.

Yours sincerely,

Original signed by

Paul Treboutat
Director, Rail/Pipeline Investigations Branch

cc:

Vice President, Systems Operations, Canada Energy Regulator
Director General, Rail Safety, Transport Canada
Vice President, Performance, Canadian Energy Pipeline Association
Assistant Vice President, Safety, Canadian National Railway Company
Assistant Vice President, Safety and Sustainability, Canadian Pacific Railway
Manager, Damage Prevention, Trans-Northern Pipelines Inc.
Vice President, Regulatory and Compliance, Trans Mountain Pipeline ULC

Appendix A — Unauthorized activities in the vicinity of pipelines

Occurrence number, date and location	Railway company	Pipeline company	Occurrence summary
P20H0010, on 03 February 2020 in Mississauga, ON	Canadian Pacific Railway	Trans-Northern Pipelines Inc.	Ground disturbance in close proximity to the pipeline and multiple instances of heavy equipment being operated across the pipeline without prior notification to the pipeline company by way of a locate request.
P17H0135, on 06 September 2017 in Albreda, BC	Canadian National Railway Company	Trans Mountain Pipeline ULC	Ground disturbance directly over the top of the pipeline without prior notification to the pipeline company by way of a locate request.