Compliance Verification Activity Report: CV2122-041 - Express Pipeline Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-041
Start date: 2021-10-14
End date: 2021-10-14

Team:

Regulated company: Express Pipeline Ltd.

Operating company: Express Pipeline Limited Partnership

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of Hardisty Terminal for Tank Fire Protection.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Hardisty Terminal

Date & time of visit: 2021-10-14 13:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The CER inspector met with the Express representatives at the Hardisty Terminal Office. Express explained that the terminal is manned 24 / 7. All the 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 agreements would have to be brought on site. Express explained that the terminal has a power back-up system capable of operating the fire protection system for the tanks.
 
As a general observation, and excepted where noted below, the fire protection pumps, piping, and other equipment at the Hardisty Terminal were in apparent good condition. Express 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.

Fire Pump Building

Tank 106 
Foam Trailer

Compliance tool used: No compliance tool used

Observation 2 - Fire Water Tank - Notice of Non-Compliance

Date & time of visit: 2021-10-14 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Firewater Tank

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

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge is to provide a plan to address the non-compliances to the OPR s. 37(a), and s.36(b) to ensure that the water tank level is adequately monitored and to ensure that the level monitoring device is tested to verify its proper operation.

Due date: 2022-01-14

Date closed: 2022-01-18
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

There are no observations with outstanding follow-up

Observation 3 - Annual Inspection and Testing of the Fire Protection Systems - Information Request

Discipline: Integrity Management

Categories:

Facility:

Observations:

Express 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 Report for the Express Hardisty Terminal was 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:

Relevant section(s):

Company action required:

  1. Please provide an update on the status of the corrective actions for each of the hazards or deficiencies listed on PDF page 3 of the Fire Systems Testing – 2021 Report, dated 15 June 2021. In the status update, indicate if the corrective actions have been completed to address the hazard or deficiency identified. If not yet addressed, provide the details for the corrective actions to implement and provide a timeline for implementing those.

Due date: 2021-11-30

Date closed: 2021-12-17
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 - Fire Water Tank - Information Request

Discipline: Emergency Management

Categories:

Facility:

Observations:

The water level was at 79.8% at the time of the inspection. Express explained that the tank has low and high level alarms with the low level alarm set at 20%. The 20% low level alarms corresponds to a calculated volume of 2400 bbl (100,800 Gal). The volume corresponding to the 20% low level alarm is sufficient for a rim seal fire but is not sufficient for a full surface tank fire which would require 189,305 Gal of water for the minimum foam solution required. Although this water volume is sufficient for the fixed fire protection system that is normally in place for the rim seal fire scenario that it is designed for, the low level alarm does not ensure an adequate volume of water in the event of a full surface fire, even without accounting for potential water cooling. The Pre-Fire Plan for this terminal does not provide plans or details about how Express could ensure an adequate supply of water in the event of a full surface fire with a water tank level that could be as low as 20%. After the inspection, Express explained that the tanks are designed to prevent a fully engulfed tank fire, including the installation of steel pontoon style floating roofs, and that for more complex events exceeding rim seal fire response, Express would access water through mutual aid partners and external contract resources.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

1.  Assuming that a sufficient volume of water is maintained in the fire water tank, explain if that tank would normally be the supply of water for the unlikely event of a full surface tank fire. Also explain if the connections to that tank would allow to drain water at a sufficient flow rate for extinguishing the fire of that scenario (assuming that the proper equipment and other resources would be mobilized at the site).

2. a) Explain what other water resources are available to Express in the area for extinguishing a full surface tank fire and explain how Express would be able to access them.

b) Explain if Express has documented plans for accessing water through mutual aid partners and external contract resources for that scenario. If yes, please provide them.

Due date: 2021-11-30

Date closed: 2021-12-17
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:

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program

Observation 5 - 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