Pipeline Construction
Regulatory Requirements
May 28, 2016
Agenda
Pipeline Act and Pipeline Rules – Overview
Public Lands Act and Requirements
– Overview
Water Act Requirements and Codes
Of Practice – Overview
Summary
Questions
AER 2
The Pipeline Act
The Alberta Pipeline Act is the main document
that gives legislative power for the governance
of pipelines in Alberta. The Pipeline Act defines
a pipeline as follows:
• “Pipeline” means a pipe used to convey a
substance or combination of substances,
including installations associated with the pipe,
but does not include
– a pipe used to convey water other than water
used in connection with an energy facility
or scheme;
AER 3
The Pipeline Act
– a pipe used to convey gas at pressures less than
700 kilopascals, and is not used to convey gas in
connection with an energy facility or scheme; or
– a pipe used to convey sewage.
AER 4
The Pipeline Act
Pipelines can be built for use above or
below ground, for temporary (well testing)
or permanent use.
The act outlines various requirements
such as
• ground disturbance,
• pressure testing, and
• release of product.
AER 5
Depth of Cover
• Must be deep enough to meet
the requirements of CSA and
the Pipeline Rules.
• Helps the pipeline operate safely
and minimizes risk to public safety
by providing a barrier between the
pipeline and the surface.
• Pipelines in place before the
Pipeline Rules came into force:
if less earth cover was permitted
by the construction standards and
regulatory requirements
in place at time of construction,
then less cover is acceptable.
(Pipeline Rules, section 20(3))
Figure 107. Adequate
depth of cover.
AER 6
Ditch Preparation
AER 7
Trenching/Top Soil Separation
Suitable soil, to
eliminate damage
to pipe
Figure 110. Clean ditch ‒ satisfactory.
AER 8
Boring
Figure 126. Water Crossing Bore.
AER 9
HDD Containment and Cleanup
In order to minimize impacts of an unexpected
frac out, a specialist and all necessary
equipment required for cleanup are required
to be on site at all times during the drill.
• A written execution plan must be developed
prior to HDD and used during the completion
of such drilling. (CSA Z662-11 [6.2.11.1])
• drill bit directing,
• tracking equipment,
AER 10
HDD Containment and Cleanup
(continued)
• workspace requirements, and
• environmental protection requirements
AER 11
Drilling Waste
Mud/water slurry produced as a result of
a bore/HDD
Handled through Directive 050, section 8
Most bores seen in the field are
considered nontoxic
• Can be managed on site in pipeline trench
where generated
• Must be disposed of within same soil horizon
where bore initiated
AER 12
Drilling Waste (continued)
Larger bore/HDD with large volumes
of mud or that contain extra additives
require more precautions
AER 13
Drilling Execution Plan
CSA Z662-15, clause 6.2.11.1
Before boring/HDD:
• Drill bit direction/tracking equipment to confirm
drill path, avoid no-drill zone, and provide
acceptable “as built” info
• Workspace requirements at entry/exit points
• Workspace requirements to construct and
lay out the pipe drag
• Drilling mud/water requirements
AER 14
Drilling Execution Plan (continued)
• Environmental protection/monitoring plan
• Drilling fluid management plants (trucking,
pits, or tanks)
• Spill/fluid loss contingency, response,
cleanup, and mitigation plans
• Equipment specs, condition, and integrity
• Mitigation of potential detrimental effects
of geological formations
AER 15
Public Lands Act Requirements
Applicable items during an inspection
include the following:
• Timing restrictions of construction
• Routing of an EAP pipeline
• Rollback/line of sight
• Wildlife surveys (if applicable)
• Low-impact construction techniques
(grassland areas)
• Watercourse crossings
(type, installation procedures, etc.)
AER 16
PLA Authorizations
Generally in the form of a disposition, typical
types under AER authority:
• LOC (licence of occupation – access roads)
• MSL (mineral surface lease – well sites)
• PLA pipeline agreements – pipeline ROW)
• PIL (pipeline installation – riser sites and
compressor facilities)
• MLL (miscellaneous lease – i.e., plants)
AER 17
PLA Authorizations
• TFA/DOA (temporary field authorizations /
disposition operational approval – used for
various short term [<1yr])
Specific purpose – use of the land for a
purpose other than what was approved
is unacceptable
AER 18
Though a pipeline right of way may ‘belong’ to a company,
they may not use it for unrelated access purposes.
AER 19
Disposition Requirements
Dispositions are spatially referenced: specific
piece of land tied to approval conditions
• Sketch/survey plan submitted during application
Discrepancies have been found between an
approved location (previously submitted during
application phase) and the “as-built” location.
•
may require an amendment to the disposition
AER 20
Timber Salvage Requirements
• Timber Salvage not removed
within 60 days (Brush Disposal).
• Inspection of the Log Deck areas
along the PLA Route.
• Difficult to remove salvage after
pipeline is complete.
Timber Salvage not completed.
AER 21
Brush Disposal Requirements
Brush disposal not completed.
AER 22
Time Restriction Requirements
• Applies to sensitive wildlife zones
(caribou, grizzly, etc.)
• Activity timing conditions dictated
in disposition approval or letter
of authority
• Restricts operations during
certain periods of the year
(i.e., breeding cycles).
• Operating within restricted time
periods is a serious offence and
often grounds for suspension
of activities.
AER 23
Examples:
1. PLA pipeline built in key wildlife and biodiversity
zone, restricted activity period from Jan. 15
to Apr. 30. The pipeline is within 100 m of
existing arterial all-weather road, therefore
it is exempt from the restriction.
2. Approved pipeline being built in caribou zone.
The approval has a timing restriction of
Feb. 15–Jul. 30. Inspection conducted on
Feb. 20 indicates construction is ongoing.
Company is in contravention, and operations
will likely be suspended.
AER 24
Water Management Requirements
A licensee who has deposited deleterious
material into a watercourse must take
all reasonable effort to remove it from
the watercourse.
• This includes water in all seasons
(ice or flowing)
AER 25
Permanent or Fish-Bearing
Watercourses
Responsibility of the disposition holder
to ensure the crossing and associated
banks are maintained.
• Public safety
• Protection of watercourse and habitat
Permanent watercourses (channel width
>70 cm) and fish-bearing watercourses
are most sensitive and require the
most protection.
AER 26
Permanent or Fish-Bearing
Watercourses (continued)
Primary concerns:
• Sedimentation
• Maintaining flow
• Impeding fish passage
All permanent watercourses and streams
that are directly connected to permanent
watercourses are considered fish bearing.
• Unless proven otherwise
(multiyear, multiseason study)
AER 27
Permanent or Fish-Bearing
Watercourses (continued)
• Both pipeline and road
crossings, permanent
or temporary, must
- have proper crossing installed,
- have sediment control, and
- maintain fish passages.
• Temporary crossings:
- Separation layer preventing
sedimentation is not installed
between logs and clay on a
log till
- Soil must not be mixed with
snow on a snow fill (snirt fill)
Example of a ‘Snirt’ Fill over a
Permanent fish bearing creek.
AER 28
Satisfactory crossing of small permanent
creek after open cut. Flow has been restored
to its natural trajectory, is unimpeded, and
banks are stable with erosion control.
AER 29
Intermittent Watercourse, Wetland,
Cross-Drain, other Non-FishBearing Watercourse
Similar concerns:
• Stability/erosion
• Downstream sedimentation
• Ensuring drainage is maintained
AER 30
Crossing Types as Per Approval
Certain approvals will specify what type of
crossing is required for certain watercourses.
• Example: All large and small permanent
watercourses are to be bored unless
geotechnical data indicates unsuitable bore
conditions or the watercourse is proven nonfish-bearing.
Conflicts between PLA approval and WA
code, the more stringent standard will apply.
AER 31
Interference with Natural Drainage
Interrupting natural water drainage paths is
not acceptable. Temporary interruption may
be allowed for crossing installation (strict
parameters under the code).
Problems:
•
Localized flooding
• Erosion
•
Damage to vegetation
•
Damage to habitat
Must be restored immediately upon discovery.
AER 32
Construction of a pipeline interfering with drainage
causing flooding of the Right of Way.
AER 33
Disturbance to Bed and Shore
All beds and shores of waterbodies in Alberta
are property of the Crown.
Any disturbance requires approval from the
government or a representative.
Anything outside of the operating parameters
of an approval or WA COP is considered a
trespass and serious offence.
AER 34
Conservation and
Reclamation Techniques
Ultimate goal of soil conservation:
• Section 21(f) of Public Lands Administration
Regulation (PLAR)
• “The holder of a formal disposition… must,
on the expiry, cancellation, surrender, or
abandonment of the formal disposition,
reclaim the subject land to an equivalent
land capability.”
AER 35
Soil Conservation and Handling
Proper techniques have direct impact
on success of long-term reclamation.
Improper techniques:
• Poor nutrient retention
• Soil sterilization
• Suppress vegetation growth
AER 36
Soil Conservation and Handling
(continued)
Typical items (but not limited to) reviewed
at time of construction:
1. What is the soil conservation strategy?
Stripping? Frozen access?
Matting/minimal disturbance?
a) Is it appropriate?
b) Is it being applied properly?
2. Stripped soil – one/two/three lift?
Are lifts stored separately?
AER 37
Soil Conservation and Handling
(continued)
3. Ad-mixing – excessive parent material
mixed with topsoil?
4. Soil stockpiles interfere with drainage?
AER 38
Rollback Requirements
Rollback: spreading of coarse woody debris
(CWD; stumps, merchantable logs, etc.)
across a ROW after pipeline has been
installed and soil respreads.
CWD: valuable for moisture and nutrient
retention, effective in limiting access for
public (sensitive wildlife zones)
Companies are discouraged from excessive
mulching where rollback is required.
AER 39
Example:
• Approved pipeline built in grizzly-bear zone.
Approval Standard 100.9.3.5, rollback required
at least 40 per cent of the linear distance of
the ROW, with breaks of 25 m every 250 m.
AER 40
Siting Requirements
Most common issues are associated with
watercourse crossings, existing disturbances,
and wildlife features.
Examples:
1. Approval condition 100.1.1: “New linear
developments shall… adjoin existing
occupied linear industrial dispositions,
unless doing so results in greater disturbance
(i.e., footprint hectares), and/or negative
environmental impacts…”
AER 41
Siting Requirements
If a company’s proposed route goes crosscountry where an opportunity exists to stick
to an existing corridor, the company might be
in contravention (unless the disturbance
is smaller).
2. A mineral lick is discovered 52 m away from a
proposed pipeline ROW during wildlife sweep.
A 100 m buffer is required. Company must
either reroute the pipeline or reapply as
nonstandard to the AER.
AER 42
Wildlife Surveys
Sensitive areas identified in the approval
process are required to complete a wildlife
survey to identify whether the species are
present at the proposed location.
The following species, as described in the
Sensitive Species Survey Guidelines require
a survey:
• sensitive raptors
• burrowing owl
AER 43
Wildlife Surveys (continued)
•
sensitive snakes
•
sharp-tailed grouse
•
swift fox
•
Ord’s kangaroo rat
•
endangered and threatened plants
This requirement differs from the 100 m
wildlife sweep required for all dispositions.
AER 44
Wildlife Surveys (continued)
If a company does not complete the
survey, it may miss important features
that could impact timing and location
of their disturbances.
AER 45
Wildlife Sweeps
Approval Standard 100.8.1 requires a wildlife
sweep of the site and a 100 m buffer prior
to construction.
There is no specific procedure, and companies
must document and be able to prove they
have done due diligence to fulfil intent of the
standard. The AER may request proof of
the sweep at any time.
AER 46
Incidental Activities
Any incidental activities falling outside of
parameters would require additional
authorization through a DOA/TFA.
Example:
• 30 × 60 m log deck planned in conjunction with
construction of a pipeline. Log deck is situated
100 m away from the new pipeline in an old
existing clearing.
• Because log deck is not abutted to the
associated well site, it will require a DOA/TFA.
AER 47
Pipeline ROW Width
Approval Standard 100.6 outlines
maximum ROW width limits.
Based on size, number and routing
of proposed pipeline:
• Cross-Country
i.
Conventional pipeline with an outside
diameter of >200 mm must not exceed
20 m.
AER 48
Pipeline ROW Width (continued)
ii. Conventional pipeline with an outside
diameter of <200 mm must not exceed
15 m.
iii. Multiple pipeline installation projects within
a single ROW must not exceed 20 m.
AER 49
Slope
After a ROW is constructed, stable slopes
must be re-established for stability.
Attempt to mimic natural slopes
wherever possible.
Failure to adequately back slope:
•
Erosion
•
Slumping
•
Damage to infrastructure
•
Personal injury
AER 50
Slope (continued)
Good rule of thumb is 3:1 back slope
(Horizonal:Vertical)
Properly sloped right of way
following natural contours.
AER 51
Erosion
The movement of surface soil because
of natural processes (wind and water).
Typically associated with watercourse
crossings or roads
Erosion control is important to soil
conservation; excessive erosion can cause
• mixing of the soil profile and future growing
capacity and
• slope instability
AER 52
Erosion (continued)
Unaddressed, erosion inevitably worsens,
so control is imperative.
Examples of unacceptable erosion.
AER 53
Weed Management
Scentless Chamomile
Perennial Sow Thistle
Canada Thistle
AER 54
Water Act Code of Practice
Further details can
be found on the
AEP website.
AER 55
Water Act Code of Practice
Further details can
be found on the
AEP website.
AER 56
Water Act Code of Practice
Persons responsible for placement,
construction, installation, maintenance,
replacement, or removal of a pipeline crossing
a water body must ensure their activities are
in compliance with the COP requirements.
Following requirements set out in the COP
allows the owner or proponent to proceed
with crossing a water body without the
obtaining an approval under the Water Act.
AER 57
Water Act Code of Practice (continued)
COP applies to any works: placing,
constructing, installing, maintaining, replacing,
or removing a pipeline or telecommunication
lines crossing.
“Pipeline crossing” is defined in section
1(2)(m) of the act and generally means
a pipe and associated structures under
a water body.
AER 58
Water Act Code of Practice (continued)
The owner of a pipeline that will cross a water
body is required to prepare a plan for the work
which complies with the COP and other
resource/land management requirements.
Plan must be prepared before written notice
is given to the director.
AER 59
Water Act Code of Practice (continued)
Plan will include the following:
• Description of construction method and
conditions to be used, determined in
accordance with section 8 and Schedule 3,
including specifications and recommendations
of a qualified aquatic environment specialist
where required.
• Specifications of a professional engineer
that are prepared in accordance with
Part 2 of Schedule 2.
AER 60
Water Act Code of Practice (continued)
• Contingency measures to deal with
potential problems.
•
Monitoring plans
AER 61
Water Act Codes of Practice
4 Classes of Watercourse Crossings
– A, B, C, and D
• Class is determined based on “sensitivity”
of fish habitats and known distribution:
• Class A: highest sensitivity; habitat areas
sensitive enough to be damaged by any
type of activity; known habitats critical to
the continued viability of a population of
fish species in the area.
AER 62
Water Act Codes of Practice (continued)
• Class B: high sensitivity; habitat areas sensitive
enough to be potentially damaged by any
activity; habitat areas important to continued
viability of a population of fish species in
the area.
• Class C: moderate sensitivity; habitat areas
are sensitive enough to be potentially damaged
by unconfined or unrestricted activities; broadly
distributed habitats supporting local fish
species populations.
AER 63
Water Act Codes of Practice (continued)
• Class D: low sensitivity; fish species as
defined under this COP not present.
COP references a distance of 2 km to
determine the class of the waterbody.
The 2 km distance refers to the “length
of stream” distance measurement.
AER 64
Water Act Codes of Practice (continued)
Approved Construction Methods Relating
to Water Body Classification
• COP sets out construction methods and
conditions under which pipeline crossings are to
be carried out.
• Other than when crossing is within a Class A
water body, the owner may choose to follow the
construction methods and conditions set out in
the COP.
AER 65
Water Act Codes of Practice
• If it is determined that the method is not
technically or environmentally feasible, the owner
may choose an alternate construction method
based on the specifications and
recommendations of a qualitied aquatic
environment specialist.
• Refer to the Code of Practice for Approved
Construction Methods related to each
water body classification.
AER 66
Water Act Codes of Practice
Restricted Activity Periods
• Times when works that disrupt the bed or
banks must be avoided.
• Maps under the COP identify restricted activity
periods for mapped Class B and C water bodies.
• Restricted activity periods for a Class A water
body are determined by a qualified aquatic
environment specialist.
• Restricted activity periods for Class D
water bodies do not exist.
AER 67
Water Act Codes of Practice
Restricted Activity Periods
• For unmapped water bodies, COP sets out how
restricted activity periods may be determined.
• If the crossing is to be carried out within a
restricted activity period, the recommendations
of a qualified aquatic environment specialist
are required unless specified otherwise under
the COP.
• Refer to the Code of Practice for restricted
activity periods related to each water
body classification.
AER 68
Water Act Codes of Practice
Further details can
be found on the
AEP website.
AER 69
All photos are taken from the AER’s EOP Pipeline
Training Manual, unless otherwise noted.