Compliance Verification Activity Report: CV1718-399 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2615
• Inspector In Training 2814T
• Inspector In Training 2691T

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Integrity Management

Rationale and scope:

Construction Inspection L3RP (OC-63 & AO-1-XO-E101-004-2016) facilities - Hardisty Tank Construction. Looking at construction, welding, and inspection practices.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Line 3

Facility Types

• Pipeline
• Terminal

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XO-E101-004-2016
• OC-063

Observations (no outstanding follow-up required)

Observation 1 - Construction Office Documentation Review

Date & time of visit: 2018-03-26 12:30

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels
• Pipeline
• Inspections
• Welding Operations
• Repairs
• Materials
• Evaluation Imperfections
• Documentation
• Record Retention
• Updating

Facility:

• Line 3 (Pipeline)

Observations:

• Welder Qualification Records for a selection of welders were reviewed. 
• Discussed how weather conditions were taken into account while welding and that mechanized welding is completely enclosed and protected from the elements. 
• Company representatives confirmed that welding inspectors are independent of the contractor.
• Inspectors observed that Order and commitments was available on site.
• It was confirmed that non destructive examination (NDE) inspectors are required to be qualified to Canadian General Standards Board (CGSB) level II or III.
• Some NDE inspector qualification records were reviewed.  It was noted that one inspector had an expired CGSB ticket.  Later it was confirmed that the inspector's certification was up to date, however CGSB was behind on issuing tickets.
• Confirmed that no essential changes have been made to the qualified welding procedures.
• The visual inspection procedure and some records of visual inspection were reviewed.
• Tank 50 annular ring radiographic inspection records were reviewed.
• Inspectors inquired about any recently rejected welds and it was noted that most rejected welds were due to porosity.  Rejected welds are removed and re-welded. There is no formal tracking of weld repair rates as it is not required within the approved welding procedures.
• Enbridge representatives confirmed that the contractor is inspecting all material as it is received.  Material test reports and Heat Numbers are being tracked.

Compliance tool used: No compliance tool used

Observation 2 - Tank Construction Inspection

Date & time of visit: 2018-03-26 13:15

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels
• Pipeline
• Welding Operations
• Repairs
• Materials
• Coating
• Cathodic Protection
• Evaluation Imperfections
• Procedures

Facility:

• Line 3 (Pipeline)

Observations:

• Reviewed and signed off on field level hazard assessment at the contractor (TWI) site office.
• Welding rod storage and ovens were inspected.  Temperatures for heat and reheat were confirmed with the Chief Inspector.  Special pouches are used to transport rods from storage to the welding area in order to protect the rods.
• Observed stockpile of tank shell materials near Tank 49 with Heat Numbers noted on them.
• The minimum preheat temperature is confirmed with temp sticks and heat guns, maximum preheat temperate is not checked as it is not practical to exceed the maximum preheat in this case as the minimum is only 10° Celsius.
• It was noted that welding and weld repair procedures were available at several locations on site including in the welding rod storage sea-can.
• It was confirmed by the Enbridge representative that cathodic protection (CP) was installed under each tank as part of the foundation work.  Ancillary CP equipment will be installed once tank construction is complete.
• Inspectors viewed the sump area at Tank 49 and discussed its functionality with Enbridge representatives.
• Enbridge representatives confirmed that after hydrotesting, the tank bottom and 1 m up the tank wall will be coated.
• Enbridge representatives confirmed that Radiographic inspections are performed in the evening when other workers are not on site, and the areas are flagged off to ensure others are aware of the work being completed.
• NEB inspectors looked at inspection records on various fire extinguishers around the construction site and all were found to be up to date.  75-ton RT crane at Tank 50 daily inspection reports were reviewed and found to be complete.

Compliance tool used: No compliance tool used

Observation 3 - Additional Document Review

Date & time of visit: 2018-03-26 14:45

Discipline: Integrity Management

Categories:

• Pipeline
• Inspections
• Integrity Management Program
• Training

Facility:

• Line 3 (Pipeline)

Observations:

Returned to Meeting trailer and reviewed the current CGSB qualification ticket expiration date for the NDE inspector that was noted to have an expired ticket earlier.

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: