Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Integrity and Emergency Inspection for Tank Fire Protection at Regina and Cromer Terminals. Purpose is to verify compliance to the OPR, CSA Z662-19, CLC, COHSR.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Day 1 – Cromer Terminal
Date & time of visit: 2023-01-17 09:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
CER inspectors met with Enbridge representatives at the Cromer Terminal to inspect the fire protection system of the terminal and to follow up on the INC2022-082 Tank Roof Incident. Discussion: Tank 94 Incident INC2022-082 Enbridge discussed the improvements and lessons learned from the incident with Tank 94 (INC2022-082). The continuing action plan included improvements to the precipitation management protocols. Current methods for removing precipitation include tank roof drains, pumping operations when roof drains are inoperable, or using cranes and platforms to manually remove snow. Enbridge explained that improvements will include site specific procedures that will identify the method that the facility will use to measure and track rain fall. This may include a rain gauge on site or other methods like a nearby weather stations. The improvements will also include clarifying options for and actions to be taken to remove precipitation. These improvements will be written into protocols by the spring of 2023. Enbridge explained that the 3 inches of precipitation criteria to drain the roof prior to the incident was providing a significant safety margin since the roof is designed to hold up to 10 inches of precipitation. As a result of the incident, the corrective and preventive actions also included improvements to be made to OMM Book 3 09‐02‐02 Tank Inspections to clarify roles and responsibilities on inspection recommended repairs. Enbridge indicated that the draft wording of the improvements is still going through reviews and is planned to be completed in 2023. Enbridge indicated that Tank 94 is still being cleaned in preparation for an out-of-service inspection that will be conducted prior to returning the tank into service. Enbridge explained that this inspection will allow inspection of the roof from the inside to determine if other contributing factors could have played a role in the sinking of the roof. CER inspectors indicated that if there are new findings on contributing factors to the incident that this information would have to be submitted to the CER. See Information Request #2 for further details. Tank Fire Protection Systems All tanks are visually inspected monthly by Enbridge staff and annually by a third-party contractor. Enbridge and CER inspectors reviewed the Cromer Annual Fire Protection System Testing and Inspection Report findings provided by the third-party contractor. Tanks 107 and 93 have roof drains to be repaired. Enbridge explained that both tanks require a full outage to replace the drains and that this is planned for the next out-of-service inspection. Currently, the tanks get precipitation pumped off the roof, which is sufficient to maintain the roof integrity and float according to Enbridge. The report noted multiple position indicator valves (PIVs) and hydrant deficiencies which Enbridge is tracking and having repaired on an ongoing basis as part of routine maintenance. Some repairs may require excavation which must wait for the ground to thaw before addressing. Enbridge indicated that all tanks are able to be supplied with an adequate amount of water in the event of a rim-seal fire. The annual inspection identified a number of water main leaks, as well as a number of plugged nozzles on three of the tanks. Enbridge stated that the leaks and nozzles have recently been repaired and are working well. The report also found there are foam makers on a number of tanks with dome roofs which could not be regularly tested due to the roof structure; Enbridge has hired a specialized contractor to come in February 2023 and make modifications to the system to allow it to be tested going forward. The foam truck was found to have a balancing valve not working. Enbridge explained that a new valve has been ordered and in the interim that the proportioning has been set manually to mix the right amount of foam concentrate with the water, i.e. 3% foam concentrate. Field Inspection: Tank 94 A contracted company was in the process of installing the Balbo ® tank cleaning technology to remove the remaining sludge in the tank. The technology injects a warm liquid into the tank through jets installed on the roof to dissolve the sludge and get it out of the tank. There were about 30 inches of heavy sludge remaining in the tank at the time of the inspection. This technology avoids the need for workers to go into the tank space under the roof during the cleaning process. The contractor explained that nitrogen is injected into the vapour space under the roof to maintain a non-explosive atmosphere during the cleaning process. He also explained that the oxygen level in the tank is continuously monitored during the process and that the system would stop injecting heated product if the oxygen level reached 8% to allow for the nitrogen to catch up. The system normally runs at 0-4 % oxygen. CER inspectors observed the condition of the roof. There were significant deformations in some areas of the roof and some damage to the rim seal and foam dam. The two guiding poles also appeared to have shifted from their normal position during the roof sinking event. CER inspectors verified the connecting location for the foam delivery trailer at Tank 94, located just outside of Tank 94’s secondary containment. Hoses would be used to connect the trailer to the hydrant located there for water supply and to the tank foam solution line for delivering the foam solution to the tank. Enbridge explained that the hydrant has been winterized but remains functional if needed. The foam solution line to the tank is made of carbon steel and Enbridge explained that the older foam solution lines at the terminal are all carbon steel and that they are flushing the lines on an annual basis to remove potential corrosion products from the lines. Enbridge explained that the newer tanks have galvanized foam solution lines, as per the requirements of the more recent versions of NFPA 11. 850 Fire Pump Building The fire pump and the foam injection truck and trailer are housed in this building. The fire pump is a centrifugal pump with a 2000 GPM rated capacity at a rated pressure of 126 psi. The piping was labelled for the direction of flow and the valves were also labelled to indicate their normal position. The fire pump is powered by a Detroit diesel engine. Enbridge explained that it is in the process of formally documenting its preventive maintenance system to formalize the monthly checks to be done on the fire pump. See NNC #1 for more details on fire pump monthly checks. Enbridge explained that a third-party contractor also conducts an inspection and testing of the fire equipment and pump on an annual basis. The latest annual inspection and testing report was provided prior to the inspection and reviewed during the discussion that occurred prior to the field portion of this inspection. Enbridge representatives confirmed that the water resources on-site (storage tank and ponds) are consistent with the information listed in the Pre-Fire Plans. CER inspectors verified that the foam concentrate (Ansulite AFFF 3%) volumes stored in the building are also consistent with the information listed in the Pre-Fire Plans. Enbridge indicated that the foam is sampled and tested annually to confirm its adequacy. They also confirmed that their fire hoses are annually pressure tested and couplings inspected. The fire pump, piping, foam trailers and truck appeared to be in good condition. The building was heated, had emergency lighting, and a fixed exhaust system for the fire pump. Enbridge explained that the diesel level in the tank was verified the day before the inspection and that the tank was almost full with a level of 2 inches from the top, although there was no easy way to check the fuel level aside from climbing and looking into the tank. The fire pump water storage tank is located behind the building. The level is monitored by the local control room and maintained at a minimum at the volume listed in the Pre-Fire Plan (651,000 Gal). The tank is insulated and heated. The water tank received an out-of-service API 653 inspection in June 2021 and is internally inspected every 5 years.
Compliance tool used: No compliance tool used
Observation 2 - NNC – Weekly and Monthly Maintenance of the Fire Pump at the Cromer Terminal
Date & time of visit: 2023-01-17 12:00
Enbridge explained that their staff have checked and run the fire pump monthly in the past but there was no formal documented procedure for this maintenance activity and that records could not be provided to demonstrate that these activities were conducted and what was verified or tested. On the second day of the inspection, Enbridge confirmed that the new preventive maintenance procedures for the monthly checks of the fire pumps were just being implemented for the Cromer terminal. Enbridge indicated the preventive maintenance requests have been issued and the Monthly Job Plan describing the maintenance activities to be conducted is now available to the Cromer terminal field staff and a copy was provided to CER inspectors. Enbridge indicated that the weekly pump testing does not have a formal job plan at this time and that the first implementation of the weekly and monthly maintenance activities for the fire pump will be completed by the end of January 2023. CER inspectors note that the monthly testing of the fire pump conducted in the past did not align with the industry-recognized standard NFPA 25 (2020 Edition) section 8.3.1 which requires a weekly run test unless supported by an approved risk analysis. Since Enbridge did not have a documented procedure for the pump's monthly maintenance activities and no records to demonstrate that these activities were conducted, Enbridge is in non-compliance with OPR s. 27 and OPR s 6.5(1) (p). In addition, the Monthly Job Plan provided and identified as Fire Pump Systems – Monthly B6_OP100001 does not provide any details on the maintenance or testing of the fire pump diesel engine drive and its fuel tank and therefore does not demonstrate that Enbridge performs adequate maintenance and testing for this type of equipment. Enbridge indicated after the inspection that it has identified an opportunity for improvement for the weekly test and will be reviewing it to include more comprehensive weekly testing in addition to running the engine.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
CER inspectors request that Enbridge provides the following: a) Documented procedures for the weekly and monthly maintenance and testing of the fire pump, fire pump building and related equipment to demonstrate compliance to OPR sections 27 and 36 (b), and to CSA Z662-19 clause 10.2.7.2. b) Explanations from Enbridge on whether the requirements of NFPA 25 were considered and how they were incorporated (as applicable) for the development of the weekly and monthly maintenance procedures for the fire pump, fire pump building and related equipment; c) The first records produced for the weekly and monthly maintenance of the fire pump, fire pump building, and related equipment for the Cromer Terminal when completed.
Due date: 2023-04-28
Date closed: 2023-05-09 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 3 - Day 2 – Regina Terminal
Date & time of visit: 2023-01-18 08:30
Pre-Inspection Discussion CER inspectors met with Enbridge representatives at the Regina Terminal Office to inspect the fire protection system of the terminal and to follow up on some risk register items identified in a previous safety inspection (CV2223-022). Follow-up to CV2223-022: Enbridge provided the following information regarding the risk register items:
There are no observations with outstanding follow-up
Observation 4 - NNC #2 - Disposition of Recommended Repairs for Tank 94
Date & time of visit: 2023-04-19 15:32
In response to IR #3 d), Enbridge provided the following information: "For the 2019, 2020 and 2021 inspections, required repairs were actioned. Items identified in the report as “recommended repairs” were reviewed and discussed through emails with subject matter experts to determine if action was required or if deferral of action was appropriate, however there was no clear process on documenting the disposition of the recommended repairs. If recommended repairs were deferred, the recommended repairs would be reviewed and actioned when the tank is taken out of service for inspection or other scheduled outages. The Tank 94 internal investigation identified that documenting the dispositions of recommended repairs from inspections was an area for improvement. Improvements are being made to reviewing inspection reports and documenting the disposition of recommended repairs. The internal investigation identified that there was a lack of clarity on roles and responsibilities for reviewing inspection recommended repairs. A corrective action has been created to address this." The fact that Enbridge did not document the disposition of the recommended repairs made in the the Tank 94 inspection reports for the years 2019, 2020, and 2021 is a non-compliance to API 653 clause 6.9.3.2.
Enbridge to provide a corrective action plan to address the non-compliance to API 653 clause 6.9.3.2 by 5 May 2023.
Due date: 2023-08-31
Date closed: 2023-09-18 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.
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program
Observation 5 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
This information has been redacted pursuant to Section 144(5) of the Canada Labour Code
