Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Inspection of Sarnia and Westover Terminals for Tank Fire Protection System and Line 5 Above Ground Facilities to verify compliance to the OPR, CSA-Z662-19 and CLC.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Sarnia Terminal – Fire Protection System
Date & time of visit: 2020-12-09 09:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
CER inspectors met with Enbridge representatives at the Sarnia Terminal to inspect the fire protection system of the terminal as a follow-up to the previously conducted Information Exchange Meeting CV2021-061. Warm Storage WarehouseThe terminal fire foam concentrate supply and firefighting trailer is located in the Warm Storage Warehouse. There were four 250 gallon totes of foam concentrate located in the warehouse, with two of totes mounted on the firefighting trailer. The foam is Aerolite 3% and had a manufacturing date of 2008 and a manufacturer recommended expiry date of 2028. Enbridge explained that the four foam totes are sampled every year and that the samples are sent for analysis to confirm the foam concentrate is still adequate. Enbridge also explained that the foam concentrate could be used beyond the manufacturer recommended expiry date as long as the foam concentrate sample analysis demonstrate that it is still adequate. Enbridge also indicated that it is planning to replace its foam when the new local environmental requirements comes into place. Enbridge explained that the foam trailer can be pulled by any of its trucks that have a 2 inch hitch. The trailer is equipped with all the tank firefighting equipment including the foam concentrate pump, the foam proportioning system, hoses, monitors and nozzles. This trailer is designed to connect to the terminal semi-fixed fire protection system for a tank rim seal fire scenario at any of the terminal storage tanks. The trailer is checked by Enbridge maintenance staff on a monthly basis and at which time the diesel engine foam concentrate pump is run to verify its functionality. Enbridge also explained that the hoses are sent for hydrostatic testing annually. The firefighting trailer and its equipment appeared to be in good condition. Fire Pump and Water SupplyEnbridge has a large reservoir of firefighting water with a capacity of 4.5 million gallons. In addition, Enbridge has an agreement with a company across the street to access their water supply in the event of a full surface tank fire. A 2000 Gallons Per Minute (GPM) fire pump supplies the water to the terminal fire hydrant system. This fire pump is designed to provide sufficient water for a rim seal fire scenario and certain spill fire scenarios, but would not provide sufficient water in the event of a full surface tank fire. If more water supply capacity was needed, there is an 8 inch line connected to the reservoir that firefighting personnel could connect to and water could also be drawn directly from the reservoir with hoses as needed. The fire pump is powered by a diesel engine. The pump is run automatically every Monday for 30 minutes. The diesel tank level can be monitored by a sight glass and there is also a diesel low level alarm. The diesel level was above the low level alarm mark on the diesel tank at the time of the inspection. The fire pump and building is not powered by the terminal back-up generator but Enbridge explained that the pump would still run as required in the event of a power loss (it would still be able to detect a pressure loss in the hydrant system and start on battery power). Tank 201CER inspectors inspected Tank 201 and its secondary containment. This tank, as well as all the tanks at the terminal, has a single secondary containment system capable of holding at least 110% of the volume of the storage tank. The tank shell and base were in apparent good condition. The secondary containment was free of any significant accumulation of water and vegetation. The roof was also in apparent good condition with some water accumulation. Enbridge explained that the tank roof is winterized (drain filled with antifreeze and plugged) in winter but that when water accumulates on it during winter, it is drained as necessary. The tank is equipped with a radar system for level monitoring. Alarms are triggered at Hi and Hi-Hi levels and the control room operator must take actions to address the alarm situations. There is also a mechanical switch to warn the control room of a Hi-Hi level situation. There were six foam makers and diffusers on this tank and the roof was equipped with a foam dam. Enbridge explained that the valves on the roof drain and secondary containment drain are normally kept closed. The fire hydrants were winterized but the underground water supply remained charged. The foam solution line for the tanks are made of carbon steel and in order to mitigate the risk of corrosion products plugging the foam makers, Enbridge conducts an annual flush of the foam solution line. There was a monitor beside the foam solution line. This monitor could be used for cooling, creating a water screen or foam the area surrounding the tank.
Compliance tool used: No compliance tool used
Observation 2 - Line 5
Plains Take Off Within the Sarnia terminal, Line 5 connects with Plains Midstream Canada to deliver Natural Gas Liquids at their facility. Enbridge explained that the valves for the Plains take off and Enbridge’s delivery line are schedule for refurbishing in 2021. The above ground piping was in apparent good condition and properly supported. The above ground piping was coated with white paint and the coating observed at the air-to-soil interface locations was also in good condition. There is a densitometer for batch detection to ensure the delivery of the right product.Line 5 Pig TrapThis area is also located within the Sarnia Terminal. Line 5 ends at this location and there is a pig receiving trap. Enbridge explained that it normally flows through the pig trap to minimize risk of internal corrosion. The above ground piping was in apparent good condition and properly supported. The above ground piping was coated with white paint and the coating at the air-to-soil interface locations observed was also in good condition. Nova Take OffThis area is located on the right-of-way upstream of the Sarnia Terminal. This site is bermed to contain a potential release. The valve for the Nova take off was replaced this past summer. The above ground piping was in apparent good condition and properly supported. The above ground piping was coated with white paint and the coating at the air-to-soil interface locations observed was also in good condition. There is a densitometer for batch detection to ensure the delivery of the right product. Suncor Take OffThis area is located on the right-of-way upstream of the Sarnia Terminal. This site is bermed to contain a potential release. The valve for the Suncor take off was recently refurbished. The above ground piping was in apparent good condition and properly supported. The above ground piping was coated with white paint and the coating at the air-to-soil interface locations observed was also in good condition. There is a densitometer for batch detection to ensure the delivery of the right product. St. Clair River Isolation ValveA new isolation valve has been installed as part of the St. Clair River crossing pipe replacement project which was recently completed. This site is bermed to contain a potential release. This valve is in close proximity of the river and the road that goes by the river shore. There was signage warning of the pipeline crossing at the road as well as large signs on both sides of the river warning of the pipeline crossing.
Observation 3 - Line 5 - Pressure Control Valve Area
Date & time of visit: 2020-12-09 10:00
Pressure Control Valve AreaThis area is also located within the Sarnia Terminal. There is a flow meter and pressure control valve (PCV) to reduce the pressure of Line 5 when delivering at the terminal. There is a pressure relief valve to protect the piping from overpressures and the relief line discharges into tank 204. CER inspectors observed that for both Line 5 and Line 6 (also located in this area) that the valves just upstream of the pressure relief valves had no means to prevent their unauthorized operation. Enbridge locked those valves in the open position to address the non-compliance to CSA Z662-19 clause 4.18.2(e). The above ground piping was in apparent good condition and properly supported. The above ground piping was coated with white paint and the coating at the air-to-soil interface locations observed was also in good condition.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Enbridge locked the valves in the open position to address the non-compliance to CSA Z662-19 clause 4.18.2(e).
Due date: 2020-12-09
Date closed: 2020-12-10 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 - Westover Terminal – Fire Protection System
Date & time of visit: 2020-12-10 09:00
CER inspectors met with Enbridge representatives at the Westover Terminal to inspect the fire protection system of the terminal as a follow-up to the previously conducted Information Exchange Meeting CV2021-061. Foam trailer BuildingThe terminal fire foam concentrate supply and firefighting trailer is located in the Foam Trailer Building. There were four 250 gallons totes of foam concentrate located in the warehouse, with one of totes mounted on the firefighting trailer. The foam is AFFF 3% and had a manufacturing date of 2008. Enbridge explained that the four foam totes are sampled every year and that the samples are sent for analysis to confirm the foam concentrate is still adequate. Enbridge also explained that the foam concentrate could be used beyond the manufacturer recommended expiry date as long as the foam concentrate sample analysis demonstrate that it is still adequate. There was also a tote of training foam that can be used for exercise purposes. Enbridge explained that the foam trailer can be pulled by any of its trucks at the Westover terminal. The trailer is equipped with all the tank firefighting equipment including the foam concentrate pump, the foam proportioning system, hoses, monitors and nozzles. The procedure for the system was mounted on the inside of one of the cabinets on the trailer. This trailer is designed to connect to the terminal semi-fixed fire protection system for a tank rim seal fire scenario at any of the terminal storage tanks. The trailer is checked by Enbridge maintenance staff on a monthly basis and at which time the diesel engine foam concentrate pump is run to verify its functionality. The firefighting trailer and its equipment appeared to be in good condition. Fire Pump and Water SupplyThe Westover terminal has a reservoir of firefighting water with a capacity of 870 000 gallons. A 2000 Gallons per Minute (GPM) fire pump normally supplies the water to the terminal fire hydrant system. However, there recently was a fire with the pump and it is currently being repaired. This incident was reported to the CER. In the interim, the Hamilton Fire Department has agreed to provide the necessary equipment while the pump is being repaired. Enbridge indicated that tests were conducted with the Hamilton Fire Department to confirm that their equipment could achieve the required flow rate and pressure. This fire pump is designed to provide sufficient water for a rim seal fire scenario and certain spill fire scenarios, but would not provide sufficient water in the event of a full surface tank fire. The fire pump is powered by a diesel engine. The pump is run automatically every Monday for 30 minutes. The fire pump and building is not powered by the terminal back-up generator but Enbridge explained that the pump would still run as required in the event of a power loss (it would still be able to detect a pressure loss in the hydrant system and starts on battery power). Tank 221CER inspectors inspected Tank 221 and its secondary containment. This tank, as well as all the tanks at the terminal, has a single secondary containment system capable of holding at least 110% of the volume of the storage tank. This tank had a 20 year out-of-service inspection completed two years ago. The tank shell and base were in apparent good condition. The secondary containment was free of any significant accumulation of water and vegetation. The roof was also in apparent good condition with some water accumulation. Enbridge explained that the tank roof will soon be winterized (drain filled with antifreeze and plugged) but that when water accumulates on it during winter, it is drained as necessary. The tank is equipped with a radar system for level monitoring. Alarms are triggered at Hi and Hi-Hi levels and the control room operator must take actions to address the alarm situations. There is also a mechanical switch to warn the control room of a Hi-Hi level situation. There were six foam makers and diffusers on this tank and the roof was equipped with a foam dam. Enbridge explained that the valves on the roof drain and secondary containment drain are normally kept closed. The foam solution line for the tanks are made of carbon steel and in order to mitigate the risk of corrosion products plugging the foam makers, Enbridge conducts an annual flush of the foam solution lines.
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
