Compliance Verification Activity Report: CV2223-063 - Maritimes & Northeast Pipeline Management Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2648

Regulated company: Maritimes & Northeast Pipeline Management Ltd.

Operating company: Enbridge Inc.

Province(s) / Territory(s):

• New Brunswick

Discipline(s):

• Safety Management

Rationale and scope:

<span style="font-size:11.0pt"><span style="font-family:&quot;Calibri&quot;,sans-serif">M&amp;NP - Saint John Lateral Pipeline - <span style="color:black">Reversing Falls Bridge Replacement</span>.&nbsp;</span></span>Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of hazards and appropriate controls relevant to the job tasks via hazard assessments; company oversight of contractors - training &amp; competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• Policy Committees, Work Place Committees and Health and Safety Representatives Regulations(CLCPC)
• Workplace Harassment and Violence Prevention Regulations(WPHVPR)
• 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
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Plans And Procedures
• Project-specific Contractor/Project Safety Plan (CSP)
• [AO-001-GC-102] 5
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observation - Reversing Falls Bridge Replacement

Date & time of visit: 2022-10-05 08:00

Discipline: Safety Management

Categories:

• Contractor Management & Oversight
• Responsibilities and Accountability
• Supervision, Inspection and Monitoring
• Hazard Management
• Management of Hazardous Energy

Facility:

Observations:

Inspector Officers were briefed on the scope of the project and current activities which included the preparation for a pipe replacement at Reversing Falls railway bridge with support workers and activities located at a near by fabrication yard. An orientation was provided which notably included  pertinent safety information, reference to respectful workplace, harassment and violence prevention requirements and an Indigenous land acknowledgment.

Reversing Falls railway bridge:

• The site was contained to a small, congested footprint. Back up alarms and spotters were required and observed.
• Traffic control included signage, a single lane closure and traffic control personnel. Traffic Control Personnel were trained as per Work Area Traffic Control Manual requirements.
• Designated smoking areas were observed and housekeeping was acceptable.
• A significant scaffolding structure was erected at the east stopple location. Tags observed had been inspected within 1 week as per GCC requirements. All modifications required inspection and sign-off by journeyman scaffolder
• The general work area is located adjacent to an active construction site led by JD Irving (JDI). The vicinity of the the 2 projects made for additional hazards introduced by simultaneous operations. Enbridge reps made clear that the communication between projects is critical to personal safety and damage prevention. IO's observed operators of heavy equipment interfacing appropriately. It appeared evident that the coordination of work was a focus point for management and at the field level. IO verified a record of the bi-weekly worksite coordination meeting and noted attending representatives from JDI, Irving Oil, Enbridge and RBS.
• Daily pipeline inspection reports and daily safety inspection reports are completed by various Enbridge representatives. Records of each were verified.

• IO's observed a well maintained yard, with secure area to be used during hydrostatic testing
• IO's observed a well kept storage C-can equipped with a flammable liquids storage cabinet with Dual 2" capped vents with flame arrestors. 

Compliance tool used: No compliance tool used

Observation 2 - Damage Prevention - Reversing Falls Bridge Replacement

Date & time of visit: 2021-10-06 10:00

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Manage and Mitigate

Facility:

Observations:

Inspection officers observed an extremely congested worksite where M&NP had an existing and operating overhead line secured to the bridge and piping strung at ground level prepared for construction. Both the operating line and the strung pipe were vulnerable due to simultaneous operations of adjacent projects. The following damage prevention efforts were observed:

• It was confirmed that Enbridge projects had a work agreement in place with M&NP operations and verified that "On-Site Approval Agreements are in place between M&NP and Irving Oil and M&NP and JDI.
• Meeting minutes and mitigations from a damage prevention focused safety meeting were verified. The meeting focus was on the prevention of damage to the overhead operating line. A similar meeting focused on the replacement line was in a planning phase.
• Section of pipe that was excavated was done so under the supervision of M&NP operations technicians and the same oversight is planned for backfilling.

Compliance tool used: No compliance tool used

Observation 3 - CNC 1 - Unprotected Edge

Date & time of visit: 2021-10-05 12:00

Discipline: Safety Management

Categories:

• Workplace Practices
• Access to hazardous areas

Facility:

Observations:

IO's observed an unprotected cliff edge in a congested work area, directly above turbulent river currents. The edge was observed to have a warning rope with ribbon serving as an administrative control, which IO's determined to be inadequate protection. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR) 2020-03-16

Relevant section(s):

• • 6.5
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (i) establish and implement a process for identifying and managing any change that could affect safety, security or the protection of the environment, including any new hazard or risk, any change in a design, specification, standard or procedure and any change in the company’s organizational structure or the legal requirements applicable to the company;

Company action required:

• Work with JDI to reduce the risk of a worker falling from the cliffs edge.
• Add an air horn to the work area to serve as an alarm device in case of a fall.

Due date: 2022-10-06

Date closed: 2022-10-11
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 4 - 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

Observations (company follow-up required)

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