Compliance Verification Activity Report: CV2122-032 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2083

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Emergency Management
• Integrity Management

Related events:

• CV2021-062

Rationale and scope:

Inspection of Edmonton and Hardisty Terminals for Tank Fire Protection.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)
• Information Request (IR) (1)

Facility details

Facilities:

• EDMONTON TERMINAL
• EDMONTON TERMINAL SOUTH
• HARDISTY

Facility Types

• Pipeline
• Terminal

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• 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 - Edmonton North Terminal

Date & time of visit: 2021-10-13 09:00

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• EDMONTON TERMINAL (Facility)

Observations:

Edmonton North Terminal:
The CER inspector discussed the inspection scope and plan with Enbridge at the Edmonton Terminal Office. Enbridge explained that a consultant was hired approximately three years ago to verify that the terminal’s tank fire protection equipment was compatible with Strathcona County Fire Department and Suncor, who is mutual aid partners with Enbridge. Enbridge also indicated that training had occurred at the terminal last week to train staff on the semi-fixed rim seal fire protection system at Tank 303-TK33.
 
Enbridge indicated that all storage tanks are equipped with both semi-fixed and fixed rim seal fire protection systems. For a full surface tank fire, portable equipment and supplemental foam concentrate from their contracted firefighters (Fire Master), mutual aid agreements, or the Strathcona County Fire Department would have to be brought on site. The newer tanks have galvanized foam solution piping for the fixed fire protection system while the older tanks have carbon steel foam solution piping. Enbridge explained that the carbon steel foam solution piping is flushed annually as part of the annual inspection and testing of the fire protection system to remove potential corrosion products that could affect the performance of the fire protection system.
 
As a general observation, and except where noted below, the fire protection pumps, piping and other equipment were in apparent good condition. Enbridge explained that the fire protection equipment is checked monthly by its staff to verify its condition and ensure its readiness. The buildings housing the fire protection equipment were heated and free of clutter that could prevent access to the equipment.
 
 
Foam Truck Building:

• A foam truck and a foam trailer are stored in this building with some extra totes of foam concentrate.
• The foam truck and trailers were in apparent good condition and appeared ready to be used if needed.
• The foam truck has four 1000 Liters (L) of foam concentrate and a foam concentrate pump and proportioning system. This truck can be connected to any of the tanks with the semi-fixed fire protection system.
• The foam trailer has two 1000 L totes of foam concentrate as well as a mounted foam cannon that could be used on small spill fires.
• There were also two other 1000 L totes of foam concentrate in the building and Enbridge indicated that two new 1000 L totes have been ordered.
• All the foam in this building was Alcohol Resistant Aqueous Film Forming Foam (AR-AFFF) 3%.
• Enbridge stated the fire truck and trailers are checked monthly by Enbridge staff.
• The CER Inspector identified inconsistencies between the resources listed in the Pre-Fire Plan and what was onsite. For example, 4160 L of Unifoam Fluoroprotein 3% and a 104,420 L underground water storage are listed in the resources of the Pre-Fire Plan but these resources do not exist anymore. However sufficient foam concentrate and water are located onsite, therefore these inconsistencies are not affecting Enbridge’s capacity to respond to a tank rim seal fire. Enbridge indicated that it will review the Pre-Fire Plan to address those inconsistencies and the CER inspector will follow-up on those during the Information Exchange Meeting (CV2122- 035) planned for later this fiscal year.

• Enbridge indicated that the water pond, which contains 1.4 million L of water, is checked monthly by maintenance staff at the same time the firewater pumps and equipment is verified.
• There are two diesel firewater pumps in the building, each with a capacity of 1500 Gallons Per Minute (GPM), with one acting as back-up.
• Enbridge indicated that they have a power back-up on site and that the fire protection system would be functional during a power loss event.
• The firewater pumps can be operated locally or remotely from the control center.

• Foam concentrate storage and the injection system for the rim seal fire protection system of several tanks (1, 3, 5, 7, 9) is located in this building. This fixed system was installed recently.
• There is a 700 Gallon (Gal) foam contrate tank in the building.
• Two diesel foam concentrate injection pumps are in the building to mix the foam concentrate with the water supply and make the foam solution.
• The piping and valves were well identified. The valves were car sealed with their normal position indicated.
• The foam solution piping going to the tanks was galvanized.
• The level of fuel in the diesel tanks for the pumps is monitored electronically. At the time of the inspection, the strobe light indicating a low fuel level for one of the tanks was flashing. The level of diesel indicated for the transmitter of that tank was 87.7%. Enbridge added some diesel fuel to bring the level above the level of 90% at which the low level alarm is set.

• This a 254,000 Barrels (Bbl) crude oil storage tank with a diameter of 53 m. The tank was built in 2012 and has a steel external floating roof.
• This tank has both fixed and semi fixed rim seal fire protection systems.
• The tank has a radar level monitoring device and a high level switch to prevent an overflow. The high level switch is redundant and independent from the radar level monitoring. There is a High and a High-High level alarm which would trigger the control center to respond to the situation and shutdown the flow to the tank to prevent an overflow.
• The roof had a foam dam and was free of water.
• Shunts for grounding the roof to the tank shell were installed on the secondary seal and the ladder was also grounded to the roof.
• There were eight fire eyes on the tank.
• The coating on the tank shell and roof was in good condition.
• The grounds at the tank base were in apparent good condition.
• This tank shares its secondary containment with tanks 23 and 24. Intermediates dikes separated the share containment between the tanks to contain small spills.

• The foam concentrate storage and injection system for the rim seal fire protection system of several tanks (2, 4, 8, 14, 21, 32, 33, 37) is located in this building.
• There is a 500 Gal foam concentrate tank in the building with about 475 Gal of foam concentrate in it, which is above the minimum required for a rim seal fire on the largest diameter tank served by this fixed system according to both Pre-Fire Plan (351 Gal for Tank 33) and NFPA 11. Enbridge later confirmed that it had added some foam concentrate to that tank to bring the level to 500 Gal and that all the foam tanks had just been topped-up at the North Terminal.
• Two diesel foam concentrate injection pumps are in the building to mix the foam concentrate with the water supply and make the foam solution.
• The diesel tanks for the pumps had visual indicators for the diesel level. Both tank level indicators were indicating full.

Compliance tool used: No compliance tool used

Observation 2 - Edmonton South Terminal

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

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• EDMONTON TERMINAL SOUTH (Facility)

Observations:

Edmonton South Terminal
 
As a general observation, and except where noted below, the fire protection pumps, piping, and other equipment at the South Terminal were in apparent good condition. Enbridge explained that the fire protection equipment is checked monthly by its staff to verify its condition and ensure its readiness. The buildings housing the fire protection equipment were heated and free of clutter that could prevent access to the equipment.
 
Firewater Reservoir and Pump Building:

• The South Terminal has a 1.6 million L water pond.
• The firewater pump building houses three diesel pumps and two jockey pumps to supply water to the fixed rim seal fire protection system and hydrant system of the South Terminal.
• The tanks have carbon steel foam solution piping for the fixed fire protection system. Enbridge explained that the carbon steel foam solution piping is flushed annually as part of the annual inspection and testing of the fire protection system to remove potential corrosion products that could affect the performance of the fire protection system. Although some of the tanks were recently built and should not have carbon steel pipe for the foam solution piping, the flushing program implemented by Enbridge was determined to be an acceptable mitigation in a previous CER inspection.

• Foam House Building 851-BLDG-1 is for the newest five tanks of this terminal. There are two diesel pumps and the diesel fuel levels are monitored electronically.
• There is a 500 Gal tank but the content of foam concentrate was only of 350 Gal. The volume of foam concentrate required for the tanks protected by this system is 456 Gal according to Enbridge’s current Pre-Fire Plan (for a rim seal fire on any of tanks 303-307). Enbridge explained that the volume of 456 Gal of foam concentrate is for a discharge time of 30 minutes which goes beyond the minimum discharge time of 20 minutes required by NFPA 11. For a 20 minute discharge time, the volume of foam concentrate required for a rim seal fire on one of those tanks is 304 Gal and therefore Enbridge had sufficient foam concentrate in that tank to satisfy the minimum requirements of NFPA 11. Enbridge explained that its Emergency Management staff had already identified this difference and that Enbridge will revise its Pre-Fire plans to require a 20 minute application time. The CER inspector will follow-up on the required update during the Information Exchange Meeting (CV2122-035) planned for later this fiscal year.
• There was a low fuel alarm on one of the diesel tanks. Enbridge added some diesel fuel that day to top-up that tank.

• Foam House Building 851-BLDG-2 is for the two original tanks of the South terminal.
• One of the foam pumps had leaked some engine oil on the building floor at the time of the inspection. The leak appeared to be recent and Enbridge had a mechanic conduct repairs the same day. Since only one of the pumps is required at any time, with the other acting as a back-up, the fire protection would still have operated as intended if it had been needed.
• There was approximately 460 Gal of foam concentrate in the tank.

Compliance tool used: No compliance tool used

Observation 3 - Hardisty Terminal

Date & time of visit: 2021-10-14 08:30

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• HARDISTY (Facility)

Observations:

The CER inspector met with the Enbridge representatives at the Hardisty Terminal Office. Enbridge explained that the terminal is manned 24 / 7. All tanks have fixed rim seal fire protection systems. For a full surface tank fire, portable equipment and supplemental foam concentrate from their contracted firefighters (Fire Master) or through mutual aid would have to be brought on site. Enbridge explained that the terminal has a power back-up system capable of operating the fire protection system for the tanks. The fixed fire protection system is automated and will operate upon opening the tank foam solution valve. The newer tanks have galvanized foam solution piping for the fixed fire protection system while the older tanks have carbon steel foam solution piping. Enbridge explained that the carbon steel foam solution piping is flushed annually as part of the annual inspection and testing of the fire protection system to remove potential corrosion products that could affect the performance of the fire protection system.
 
As a general observation, and except where noted below, the fire protection pumps, piping and other equipment at the Hardisty Terminal were in apparent good condition. Enbridge explained that the fire protection equipment is checked weekly by its staff to verify its condition and ensure its readiness. The buildings housing the fire protection equipment were heated and free of clutter that could prevent access to the equipment.
 
Tank 301-TK-47

• This a 360,000 Bbl crude oil storage tank with a diameter of 62.79 m. The tank was built in 2003 and has a steel external floating roof.
• This tank has a fixed rim seal fire protection system.
• The tank has a radar level monitoring and a high level switch to prevent an overflow. The high level switch is redundant and independent from the radar level monitoring. There is a High and a High-High level alarm which should trigger the control center to respond to the situation and shutdown the flow to the tank to prevent and overflow.
• The roof had a foam dam and was free of water.
• Shunts for grounding the roof to the tank shell were installed on the secondary seal.
• There were nine foam makers on the tank.
• The coating on the tank shell and roof was in good condition.
• The grounds at the tank bases were in apparent good condition.
• This tank had its own secondary containment.
• The roof drain was winterized.
• This tank has no fire detection devices. Fire detection is relied upon visual detection.

• Foam concentrate storage and injection system for the rim seal fire protection system of several tanks (42-50) is located in this building.
• There was about 670 Gal of foam concentrate in the 700 Gal tank.
• There is one diesel foam concentrate injection pump in the building to mix the foam concentrate with the water supply and make the foam solution.
• The diesel tank for the pump had a visual indicator for the diesel level.
• The pump, the piping, and other equipment in the pump building were in apparent good condition.
• The equipment in this building is checked on a weekly basis.

• One diesel firewater pump supplies all the water for the terminal fire protection system.
• The diesel tank has a low fuel alarm. The tank has a visual indicator for the level which indicated a tank level of about 50% at the time of the inspection.
• The pump, the piping, and other equipment in the pump building were in apparent good condition.

• Foam storage and injection system for the rim seal fire protection system of two tanks (40 & 41) is located in this building. The building is heated.
• There was about 625 Gal of foam concentrate in the 700 Gal tank.
• One diesel foam concentrate injection pump in the building to mix the foam concentrate with the water supply and make the foam solution.
• The diesel tank for the pump had a visual indicator for the diesel level and the tank was full.
• The pump, the piping, and other equipment in the pump building were in apparent good condition.

Compliance tool used: No compliance tool used

Observation 4 - Hardisty Terminal - Firewater Tank - NNC

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

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• HARDISTY (Facility)

Observations:

Firewater Tank

• The firewater pump is fed by a 12,000 bbl above ground storage tank standing beside the Fire Protection Building. The tank is insulated and heated. A minimum level of 9.2 meters is automatically maintained which corresponds to a calculated volume of 11,416 bbl (479,472 Gal), which is sufficient for producing enough foam solution for a rim seal or full surface tank fire at the largest diameter tank on site (Tank 301-TK-45).
• The water level was at 9.2 m at the time of the inspection.
• Enbridge explained that the water level can be seen by the control center via SCADA in addition to the local level display.
• Enbridge explained that it has no formal method currently in place to verify the accuracy of the level monitoring device. There is no calibration verification or other independent method in place to validate the water level in the tank. This is a non-compliance to the OPR s. 36 (b) and a Notice of Non-Compliance was issued.
• The tank had an internal inspection completed in the last year. Enbridge indicated that the tank is internally inspected every 3 years as per NFPA 25.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 36. A company shall
    • (b) periodically test instruments and equipment at the pipeline stations to verify their proper and safe operation;

Company action required:

Enbridge is to provide a plan to address the non-compliance to the OPR s. 36 (b) to ensure that the level monitoring device for the water tank is tested to verify its proper operation.

Due date: 2021-12-17

Date closed: 2021-12-14
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 5 - Annual Inspection and Testing of the Fire Protection Systems - Information Request

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• EDMONTON TERMINAL (Facility)

Observations:

Enbridge explained that the tank fire protection equipment is inspected and tested annually by a contractor (Total Fire Solutions) and copies of the 2021 Fire Systems Testing Reports for the Enbridge Edmonton North, Edmonton South, and Hardisty Terminals were provided. The Fire Systems Testing Reports have identified a list of hazards or deficiencies, ranked as either “Non-Critical Deficiency”, “Critical Deficiency” or “Impairment”.  An Information Request has been issued to obtain an update on the status of those deficiencies and their corrective actions and to verify compliance to the OPR s. 36 (b) and to CSA Z662-19 clause 10.2.7.2.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 36. A company shall
    • (b) periodically test instruments and equipment at the pipeline stations to verify their proper and safe operation;

Company action required:

​1. Please provide an update on the status of the corrective actions for each the of the hazard or deficiency listed in the following reports:

• For the Enbridge Edmonton North Terminal, the hazards or deficiencies listed on PDF page 3 of 101 of the Fire Systems Testing – 2021 Report, dated 27 Augusts 2021.
• For the Enbridge Edmonton South Terminal, the hazards or deficiencies listed on PDF page 3 of 65 of the Fire Systems Testing – 2021 Report, dated 27 Augusts 2021.
• For the Enbridge Hardisty Terminal, the hazards or deficiencies listed on PDF page 3 of 35 of the Fire Systems Testing – 2021 Report, dated 10 July 2021.

Due date: 2022-01-14

Date closed: 2022-01-14
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

Observations (company follow-up required)

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