Compliance Verification Activity Report: CV2122-037 - Enbridge Southern Lights GP Inc. on behalf of Enbridge Southern Lights LP

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2391

Regulated company: Enbridge Southern Lights GP Inc. on behalf of Enbridge Southern Lights LP

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Damage Prevention

Rationale and scope:

Verify compliance to the requirements contained within the Onshore Pipeline Regulations (OPR) and the CER Damage Prevention Regulations - Obligations of Pipeline Companies (DPR-Obligations) with a focus on third party oversight procedures. Field Inspection to include document review and site inspection of active third party crossing activity.

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• Line 13

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Damage Prevention Program Pre-Inspection IR

Discipline: Damage Prevention

Categories:

• Monitoring and Reporting
• Records
• Patrols, Inspection and Field Observations
• Damage Prevention Program
• Public Awareness Program
• Manage and Mitigate
• Locates and Information
• Locate Requests
• Ground Disturbance
• Authorization and Consent
• Facility
• Authorization and Consent
• Pipeline Identification
• Locate Markings

Facility:

• Line 13 (Pipeline)

Observations:

As part of the scope of this field inspection which included document review, the CER IOs require information pertaining to the Enbridge Southern Lights GP Inc. on behalf of Enbridge Southern Lights LP (Enbridge SL) Damage Prevention Program as required pursuant to section 47.2 of the OPR.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 47.2 A company shall develop, implement and maintain a damage prevention program that anticipates, prevents, manages and mitigates damage to its pipeline and meets the requirements set out in section 16 of the National Energy Board Pipeline Damage Prevention Regulations — Obligations of Pipeline Companies.

Company action required:

• Refer to the Documents Section in the link provided for the full text of this Pre-Inspection Information Request.
• Indicate which documents within your company’s Damage Prevention Program or related program address the applicable regulatory requirements.
  • Include details such as document name and applicable sections and/or page numbers.
  • Please do not attach documents at this time. All responses must be entered into the template provided. 
• Follow the instructions provided in the Documents Section to upload and submit your company response by the specified due date.

• LP Ticket Response User Guide;
• OMM Book 3_08-03-09 Inspecting & Examining Buried Pipe When Exposed;
• Crossing Report Form (blank form); 
• Facility Location Request/Prescribed Area Excavation Request Form (blank form); and
• Form B3_E001 Exposed Pipe and Daylight Inspection Form (blank form). 
  
   

Due date: 2021-09-27

Date closed: 2021-10-26
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 2 - Field Visit of Planned Horizontal Directional Drilling (HDD) 3rd Party Project Worksite

Date & time of visit: 2021-10-14 13:00

Discipline: Damage Prevention

Categories:

• Locates and Information
• Locate Requests

Facility:

• Line 13 (Pipeline)

Observations:

The planned HDD 3rd party project consisted of a tunnel to be drilled eastbound (entry west and exit east of right-of-way) under 7 pipelines (including the Enbridge SL Line 13) for the installation of a 3rd party pipeline. The CER IO accompanied Enbridge representatives and 3rd party project Prime Contractor Foreman onto the worksite. There was no work underway at the time of the field visit as work was temporarily suspended due to poor weather (recent rain episode) in the area: 

• The work area outside the right-of-way (RoW) was graded and 3rd party pipeline to be installed was laid out. The bore entry and exit points were located outside the RoW and were identified by t-posts and X-shaped wooden stakes.
• Rigs mats were installed on top of all 7 pipelines. Rubber tires were lined up on each sides of the rig mats. CER IO was informed that the tires are used to protect the surface of the rig mats when heavy equipment is crossing over. Geotextile fabric was placed under the rig mats to facilitate clean-up.
• Enbridge representatives indicated that the rig mats were initially installed directly over the bore path and as such, it was requested that the mats be moved a few meters north. This was to ensure that a slash pit can be dug directly over the bore path to verify depth and alignment of the drill bit before crossing the Enbridge Line 4 (i.e. the first pipeline to be crossed on the west side of the RoW) and so that the pipelines could also be daylighted in line with the bore path.
• A slash pit was observed near the Enbridge Line 4. CER IOs were informed that it was dug to a depth of approximately 9 metres. A temporary ramp with handrails was placed over the slash pit which was barricaded by orange snow fence to restrict access. 
• All pipelines were staked using wooden stakes to mark the Enbridge pipelines. The depth of the Enbridge SL Line 13 at the point of crossing was written on the stake to be 1.2 metres.
• Excavated daylight holes and slash pit were covered with plywood and barricaded by snow fence. 
• Temporary yellow signage ("Caution - Open Excavation" written in black) was erected on the east and west entrances of the RoW beside the rig mats, and one sign was placed on the snow fence barricading the slash pit.
• Enbridge representatives confirmed that no pressure reduction was required for the 3rd party work near the pipeline. CER IO was informed that the bore path is to be drilled to a depth of approximately 9 metres. 

• Signed 3rd party project crossing agreement dated 15 July 2021 for the installation of underground 3rd party pipeline and temporary ramping:
  • The agreement included the requirement for the 3rd party to provide the pipeline company with 3 days' notice prior to the commencement of any ground disturbance within the prescribed area.
  • The agreement also specified the minimum clearance of 5 m for the 3rd party pipeline installation.
• Safe Work Permit issued on 24 Sept 2021 for the installation of the rigs mats and hydro-vac activities on the RoW:
  • This document included:
    • work scope and identification of specific hazards at the site;
    • frequency of 3rd party contact with the pipeline company (in this case, daily);
    • emergency muster point location;
    • crossing agreement number; and
    • confirmation that the applicable procedures have been reviewed. 
• Prescribed Area Excavation Request issued 24 September 2021 for work within the prescribed area (but outside the RoW) such as grading and trenching:
  • This document included:
    • locate expiry date;
    • locate sketch including the work area, location of the pipeline and RoW as well as other features such as nearby railways;
    • requirement for an Enbridge Representative to be on site prior to any excavation; and
    • information specifying that no excavation or no vehicle crossing is permitted within Enbridge's RoW.
• Exposed Pipe and Daylight Inspection Form dated 24 September 2021: 
  • This document contained information about the physical state of the pipe when it was exposed as part of the 3rd party project (e.g., depth, coating condition, etc).
  • The crossing agreement number was noted on the form.
  • There were no damage noted at the time of the exposure.  
• Crossing Report dated 24 September 2021:
  • The form contained information about the construction of the rig mat access road which took place on 24 September 2021.
  • The form was partially filled out at the time of review because the project was ongoing.
  • This document contained information for the work on the RoW that was supervised by the Pipeline Maintenance personnel such as:
    • method used to confirm the depth of the pipe;
    • method used for the ground disturbance;
    • details of the temporary equipment crossing (e.g, rig mats);
    • information regarding the compliance with the measures as set out in the CER Damage Prevention Regulations - Authorizations; and
    • information on any unsafe event that may have had an effect on the pipeline's safety or integrity.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: