Once construction of any given pipeline spread or facility is complete, there are several steps that are required before operations can begin.
In accordance with the Canada Energy Regulator (CER) Act, companies require permission from the CER before commencing operations of a pipeline or facilities associated with transporting oil and gas or any other commodity.
The process is called Leave to Open (LTO) and requires results from a series of testing, inspections and safety information that demonstrates the pipeline and associated facilities can be safely opened for operation.
It’s important to note that Trans Mountain is taking a phased approach to construction and is therefore submitting LTO applications in a phased approach as well. That means if the CER Commission were to grant LTO approval for a portion of the pipeline, it would not apply to the Expansion Project as a whole. The expected benefit to this phased approach is that once commissioning and startup is ready to commence, Trans Mountain will already have a number of approvals and won’t need to wait for one overall approval. It will allow flexibility during the commissioning and startup process.
The application includes detailed safety and pipeline integrity information such as:
- A list of standards, specifications and procedures under which the facilities were designed, constructed and tested
- A summary of continuous pressure and temperature readings over a test period
- A summary of all piping, welds and valves not subjected to a pressure test following installation (e.g., pre-tested pipe and assemblies) with justification for not pressure testing following installation
- A statement that all control and safety devices were or will be inspected and tested for functionality
- Confirmation that all field joints were non-destructively examined
- Confirmation that pressure testing was performed under the direct supervision of a company representative
- All logs, test charts and other test records, signed and dated by the company representative
- Confirmation that the test pressure did not fall below 97.5 per cent of the minimum strength test pressure
- Details regarding any unsuccessful pressure tests, including the cause of the test failure
Additionally, the Expansion Project is subject to 156 conditions that are enforced by the CER and demonstrate the rigour and detail that will go into every stage of the Project to mitigate risks, respect the rights of those directly affected. The conditions are designed to reduce possible risks and ensure the pipeline is planned, built and operated safely.
The 156 conditions apply during various stages of the Project’s lifecycle, including a number of conditions associated with LTO and ”prior to operation” that need to be satisfied before the Project can commence operations. Trans Mountain is already working on the submissions required for these conditions to ensure we are prepared and ready for Line 2 operations.
In addition, Trans Mountain has made thousands of commitments to address concerns raised by Indigenous communities, the public and local and provincial governments that encompass a wide range of areas. Trans Mountain is required by the CER to adhere to every one of these commitments.
The CER is Trans Mountain’s lifecycle regulator and will continue to enforce conditions, inspect facilities and conduct other oversight activities to protect people and the environment.