Compliance Verification Activity Report: CV1819-173 - Niagara Gas Transmission Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2463
• Inspector 2538

Regulated company: Niagara Gas Transmission Limited

Operating company: Enbridge Gas Inc. (Enbridge Gas)

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Safety Management

Rationale and scope:

Field Inspection of Niagara Gas Transmission Ltd. (Niagara). Safety Program focus, to verify compliance with the National Energy Board Onshore Pipeline Regulations (OPR) and company-specific requirements.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Cornwall Pipeline
• Rockcliffe/Pointe Gatineau
• THE LINK PIPELINE
• ORLEANS PIPELINE

Facility Types

• Pipeline
• Meter station
• Odorant station
• Valve site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

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

Observations (no outstanding follow-up required)

Observation 1 - General Observations - Safety Program Overview

Date & time of visit: 2019-01-23 13:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Hazard Assessment

Facility:

• Cornwall Pipeline (Pipeline)

Observations:

Niagara/Enbridge Representatives provided and overview of

• Pipeline facilities and pipelines regulated by the NEB.

• Safety Management Program Policy - company provided a copy of the statement and examples of how the company communicates it and demonstrated where it can be found by employees.
• Hazard Identification and Risk Assessment Procedure - company explained the process for identifying and analyzing safety hazards through various programs such as site specific hazard assessments and near miss program. Company confirmed Niagara (Enbridge Gas) has its own registry for hazards and the controls for the hazards.
• Hazard Communication - Company explained and verified how hazards and controls are communicated (i.e. monthly department safety meetings, videos, bulletins, etc.). Can be reactive or proactive.
  • Company confirmed top hazards are Enbridge's "Life Saving Rules," which are based on company fatalities, and demonstrated how those are communicated on a regular basis to employees (i.e. monthly department safety meetings, videos, bulletins, etc.)
• Operations and Maintenance Manual(s) - Company provided an electronic copy of its Operation and Maintenance Manual and explained how the manual is located, controlled, accessed by office and field employees, and how there are links to the OPR and other regulatory requirements in the manual.
• Contractor oversight (hazards and procedures at work sites) - Company explained and demonstrated the pre-qualification/qualification verification system it uses when hiring contractors. Company confirmed it test contractors on usage of tools, ensues contractors have safety programs, and that proper work permits are obtained prior to doing any work.
• Management of change (MOC) program - company described its MOC by reviewing guidelines, standards and procedures.
• Documentation and Document Control - company explained and confirmed its documentation standards, from creation to retirement. The Environment Health and Safety group has its own document control procedure from creation with naming, to approvals, to revisions to retirement that follows the company's Records Management Policy.
• Performance and compliance with the safety program and regulations - company provided an overview of metrics from the last four years that demonstrated a decline in preventable motor vehicle incidents. Company confirmed it has a registry of legal requirements that is populated by a third party. The EHS group confirmed it has a third party complete audits of a targeted group.

• Niagara/Enbridge Representatives provided an site specific orientation for the next days' field portion.

Compliance tool used: No compliance tool used

Observation 2 - St. Lawrence Gate Station (Station)

Date & time of visit: 2019-01-24 10:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Permanent Structures
• Housekeeping
• Shelving and General Storage
• Signage
• Lighting
• General Lighting
• Noise Control
• Signage

Facility:

• Cornwall Pipeline (Pipeline)

Observations:

NEB Inspection Officers observed the following:

• Appropriate signage identifying the station name, operator, and with emergency contact information present at facility entrance.
• Minimum personal protective equipment requirement of entry at site posted.
• Appropriate signage identifying access restrictions (eg. smoking, trespass) present at facility entrance.

• Both Station egress exits (panic gates) we verified and found to be functional and unencumbered by snow accumulation.
• Walkways and door access to buildings cleared of snow.
• Two appropriately sized and fully stocked spill kits present (boiler building, regulator building).
• Appropriate general lighting in Station buildings.
• Buildings with potential for combustible gas have continuous monitoring and readouts located outside the building door entrances.
• Station has natural gas powered generator back up present, noise abatement structure in place (fence present).
• Signage at buildings door entrances is appropriate often identifying additional hazards or providing information.
• Odourant building has a fire suppression system in place, and  secondary containment for the building.
• Odourant building has charcoal filtered systems in place for use during system maintenance activities or in the event of an odourant spill.
• Grounding in place at Odourant building, and boiler building.
• Flammable products stored in appropriate cabinet in regulator building.
• Jersey Barriers in place to protect piping adjacent to regulator building where vehicular access can occur.
• Housekeeping exceptional throughout the Station.
• Medical kit present at electrical control building.

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: