Compliance Verification Activity Report: CV1819-088 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector In Training 2444T

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Manitoba

Discipline(s):

• Safety Management
• Indigenous Monitoring

Rationale and scope:

Compliance verification field inspection against regulatory requirements, including National Energy Board (NEB) Onshore Pipeline Regulations (OPR), project specific safety requirements and applicable Canada Labour Code Part II (CLC II) requirements. Field observations of ongoing construction activity of Line 3 Replacement on Spread 9, focused on pipe-handling, including stringing and bending, welding and contractor oversight. Indigenous Advisory Monitoring Committee (IAMC) Indigenous Monitors (IM) accompanying NEB inspectors.

Compliance tool(s) used:

• Information Request (IR) (3)

Facility details

Facilities:

• Line 3

Facility Types

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

Life-cycle Phases

• Construction

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
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Contractor/Project Safety Plan (CSP)
• SA Energy Group Enbridge Project Specific Safety Plan (PSSP) Enbridge L3R Project – Spread 9
• Emergency Response Plan (ERP)
• Enbridge Spread 9 Emergency Response Plan
• Project-specific plan or procedure
• Unloading Pipe with Deckhand - Stringing on ROW Procedure - Premay Pipeline Hauling L.P.
• Standard Operating Procedure or Plan (SOP)
• Enbridge Cargo Management Loading, Transportation, and Unloading
• Project-specific plan or procedure
• Loading / Off Loading of Pole Trailer with Deckhand Procedure - Premay Pipeline Hauling L.P.
• Standard Operating Procedure or Plan (SOP)
• Enbridge Canadian Projects Pipe Handling for Bending Operations - Best Practices ... Revision 2.1
• Standard Operating Procedure or Plan (SOP)
• Enbridge Safe Cribbing and Skidding Guidelines
• Standard Operating Procedure or Plan (SOP)
• Enbridge Canadian Mainline Projects Safe Work Guidelines Operator/Spotter Training - Where Do I Stand?
• Standard Operating Procedure or Plan (SOP)
• Enbridge Liquid Pipelines/Major Projects Canadian Contractor Alcohol and Drug Policy
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Pipe Stringing Crew on Right of Way

Date & time of visit: 2018-09-17 14:35

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Training and Competency
• Training, Competency and Qualification
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

Prior to arrival at location of pipe stringing, the NEB Inspection Team, including Indigenous Monitor and Company Representatives met to kick off the inspection, plan travel logistics and sites to be visited. 

• Company representatives equipped the NEB vehicle with fire extinguisher, tie downs and whip flag and ensured biosecurity measures were taken, washing of the vehicle, work boots, bleaching of treads and provision of biosecurity spread 9 sticker.
• Vehicles traveled safely in convoy to the work site for inspection.
•  Upon arrival, Field Level Hazard Assessment (FLHA) and Safety Meeting Report presented by the contracted site foreman and acknowledged by signature.
• Stringing Job Safety Analysis (JSA) available. 
• The work area was well graded, flat and free of debris.
• Topsoil was segregated and stored away from excavated areas.
• The right of way perimeter was staked and fenced by rope with posts capped to prevent exposure to sharp object hazard.
• Cribbing material observed was in good condition and cribbing stacks appeared [properly erected and adequate for pipe support.
• "Goalposts" were erected marked the safe distance under hydro power transmission line.
• Sections of pipe on truck were securely loaded.
• Two bell hole excavations unsafe for entry (with water visible at bottom) completely fenced and with Danger Open Pit signage.
• Ladder in good shape properly positioned and secured.
• Crawler unit, safely parked, with fire extinguisher, daily or pre-use inspection log entries completed but not signed.*
• Deckhand® Pipe Handling System, attachment on excavator using hydraulics, observed safely unloading and stringing pipe.
• Equipment daily pre-use inspection daily brigade system check log entries completed and signed by Deckhand operator.
• ERP, fire extinguisher and "Where Do I Stand?" spotter card with both spotters signed off.
• Camera on deckhand operational.
• Spotters and Deckhand operator communicated with appeared alert, knowledgeable of their tasks and fit for duty.
• Documentation of Deckhand operator competency verification was requested and provided.
• All persons observed on site wore appropriate and required personal protective equipment (PPE).
• Observed ‘Watercourse Crossing Ahead’ signage.
• Observed ‘Riparian Buffer Zone’ signage.
• Observed trucks arriving for unloading of pipe with deckhand.
• Inspection team informed that currently four operators competent to operate deckhand are available if needed on the spread.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (k) establish and implement a process for verifying that employees and other persons working with or on behalf of the company are trained and competent and for supervising them to ensure that they perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment;

Company action required:

Information Request 1
The Company to provide pipe handling procedure(s) used by the contractor on Spread 9.

Information Request 2
The Company to provide written assurance of inspection process to ensure operators of crawler not only complete but also sign daily / pre-use inspection forms.

Due date: 2018-09-18

Date closed: 2018-09-18
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 2 - Pipe Loading Crew in Laydown Yard

Date & time of visit: 2018-09-18 09:05

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Fire Protection
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Lighting
• General Lighting
• Training and Competency
• Training, Competency and Qualification
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

Prior to arrival at East Morden Pipe Yard, NEB Inspection Team met with Indigenous Monitors and Company Representatives and confirmed site visits to observe bending and welding.

• The inspection team were informed by company representatives of a precautionary measure taken to replace worn vests of the stringing crew observed yesterday with new High Visibility Vests.
• The group traveled in convoy led by Company vehicle.
• Upon arrival, Tailgate Safety Meeting Report and FLHA presented and acknowledged by signature.
• Yard clean and orderly.
• Reviewed Cargo Management Hazard Assessment and JSA documentation finding all documentation properly completed.
• Observed deckhand safely loading pipe onto Pole Trailer / Truck in accordance with procedure (middle first to prevent rollover).
• Discussed pipe loading procedure with Supervisor on site who demonstrated a thorough understanding..
• Observed securement of three pipe segment load on truck.
• Informed of 24/7 security at the yard.
• Pipe stored in yard on adequately supporting timbers.
• Deckhand operator spoken with demonstrated a thorough understanding of the loading operation and documentation required.
• Oily spot on deckhand part (no sign of dripping) discussed with Company representatives as needing follow up inspection.
• Deckhand equipment appearing to be otherwise in good shape with glass windows and shield intact and fire extinguisher on board with inspection indicated on tag.
• Competency verification process for deckhand operator discussed with evaluating supervisor, includes documented on job training observation.
• Magnetic flags on ends of pipe on trailer tested for strength of adhesion and found to be strongly adherent.
• All persons on site wearing proper PPE.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Project-specific plan or procedure
• Loading / Off Loading of Pole Trailer with Deckhand Procedure - Premay Pipeline Hauling L.P.

Relevant section(s):

• 2.2 Deckhand is mechanically sound and safe to use How to Do: The Operator shall examine the following items prior to each shift:. . . 6. Hoses, connection, cylinders - inspect for leaks and damage. Tighten, repair or replace parts as necessary.

Company action required:

Information Request 3
Following a precautionary approach, Company to provide documentary evidence that oily spot on deckhand part receives preventative maintenance.  

Due date: 2018-09-24

Date closed: 2018-09-24
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 - Pipe Setup Crew

Date & time of visit: 2018-09-18 10:15

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Occupational Medical Surveillance
• Fire Protection
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Training and Competency
• Training, Competency and Qualification
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

 Arrived at shoofly 26, to observe pipehandling during setup to bending activity. 

• Traveled in convoy led by Company vehicle.
• The right of way (RoW) was free of debris and perimeter marked.
• Cribbing material observed was in good condition, cribbing stacks appeared proper and any substandard material was not used.
• Company Safety Specialist explained process of "sweep" of RoW to inspect for an remove all debris and this was observed.
• Pipehandling observed was performed without the use of tag lines.
• Company Safety Specialist explained the activity as "setup for the bending crew" during which pipe not lifted above shoulder height is permitted to be moved without the use of tag lines.
• Pipehandling procedures permitting this activity were requested and a copy of procedure "Pipe Handling for Bending Operations- Best Practices" was provided on site with the proviso by the Company Safety Specialist to ensure the most current document will also be verified and provided.
• The Company Safety Specialist informed the NEB inspection officer that the pipehandling procedures were developed after consultation with industry experts, including employee representatives involved in performing the task.
• The area was well graded and relatively flat and there was no observable undue swing when pipe segments were lifted.
• From a distance, it appeared an employee on the crew broke into a short trot and this resulted in Company Specialist discussion with foreman and reminder communicated to crew to not run and no further haste was observed.
• Company Safety Specialist explained medics assigned to each spread, including physician assistant or nurse available twelve hours per day per spread (MEDI-CAMP).

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Enbridge Canadian Projects Pipe Handling for Bending Operations - Best Practices ... Revision 2.1

Relevant section(s):

• 2.2 Tag Line Use A tag line must always be used when the joint is raised above shoulder height. If clearance is needed for spoil piles or other obstacles, a second tag line can be used. Tag lines should not be used when a greater hazard is created as a result. IE. Feeding the joint into the bending machine, or maneuvering pipe between knee and shoulder height while travelling. [This sentence italicized in document].

Company action required:

The Company shall provide the most current documented pipehandling procedures permitting the activity of moving pipe segments as observed without the use of tag lines.  

The Company provided documented pipehandling procedures permitting the activity of moving pipe segments as observed without the use of tag lines. 
 
However, examination of "SA Energy Group Enbridge Project Specific Safety Plan (PSSP) Enbridge L3R Project - Spread 9 REV:02 July 18, 2018" may contradict or is not sufficiently clear on the procedure to be used. The PSSP makes no apparent reference to the documented pipehandling procedures permitting the activity of moving pipe segments as observed without the use of tag lines. Moreover,  it states on page 56 of 100:
 
[Begin quotation]

36         Pipe Handling

When moving or lifting pipe, SAEG and Subcontractors must exercise care to not damage the pipe, pipe ends, and/or bevels.  Appropriate lifting equipment must be selected when handling and moving pipe. Lifting equipment includes:

• Side booms
• Pipe Layers
• Picker Trucks with Grapples, Hooks, or Vacuum Lifter
• Tag lines shall be used and of sufficient length
• No riding on pipe at any time
• Do not walk under suspended loads
• Ensure pipe is clean at lifting points
• Rigging must be completed by a qualified rigger
• Tension shall be maintained on rigging and not released until load is secure
• Keep the pipe as low as possible while moving

Due date: 2018-10-25

Date closed: 2018-10-19
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 - Pipe Bending Crew

Date & time of visit: 2018-09-18 11:05

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Fire Protection
• Hazard Assessment
• Materials Handling
• Conveying Equipment
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Training and Competency
• Training, Competency and Qualification
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

• Traveled safely in convoy to site of Pipe bending activity.
• Bore location bell holes with Danger Open Pit signage and fenced off.
• Mushroom caps observed on all metal fence posts.
• Riparian Zone signage in place.
• Contractor bending crew supervisor presented "Daily Toolbox Meeting," which identified hazards and risks associated with the bending machine operation.
• Bending integrity inspector on site explained sampling requirements and results.
• Task Analysis Safety Card examined.
• Observed bending crew of cribbing/skid setter, pipe fitter, bending machine operator and side boom operator, with swampers.
• The bending crew supervisor demonstrated competency in explaining pipe handling procedures for bending crew and bending operation in general, including remote control of and function of mandrel.
• Each piece of equipment had portable fire extinguishers on board.
• All personnel were properly equipped with required PPE appeared alert and remained focus on the critical tasks at hand.

Compliance tool used: No compliance tool used

Observation 5 - Welding Pipe Gang

Date & time of visit: 2018-09-18 12:40

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Training and Competency
• Training, Competency and Qualification
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

• Traveled safely in convoy led by Company vehicle to site to observe welding crew. 
• Traffic safely controlled on busy right of way and our convoy observed from safe Poston on the sideline, pending meeting of site supervisor and presentation of Daily Toolbox.
• Backup alarms were clearly audible and all vehicle onsite were properly equipped with whip flags.
• Portable fire extinguishers on pick-up trucks.
• The right of way (RoW) was well graded, free of debris, the terrain relatively flat and materials stock piled at edge of RoW away from the working area.
• Cribbing was of sound material and grapple hooks used effectively by workers to handle cribbing material.
• Seven side booms worked safely in the area.
• Five welding shacks working in the area were all equipped with tag lines and safely lifted, moved and lowered in place by side booms.
• Many compressed gas cylinders were all properly secured on equipment and trucks.
• Welding supervisor presented Daily Toolbox Supplement Bulletin and Daily Toolbox Meeting, acknowledged by signatures.
• All employees on site were observed with appropriate and required PPE appeared alert and remained focus on the critical tasks at hand.
• Supervisors competently explained torch and welder PPE requirements, welding process and functions of specialized equipment, including "the goose," that is, the internal welding machine.

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: