Compliance Verification Activity Report: CV2021-087 - Express Pipeline Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-087
Start date: 2020-10-21
End date: 2020-10-22

Team:

Regulated company: Express Pipeline Ltd.

Operating company: Express Pipeline Limited Partnership

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Safety oversight of operations at Hardisty Terminal, Youngstown Pump Station, and Ribstone Creek pump station. Assess compliance with the OPR (safety management program) and CLC requirements. Verify energy isolation is performed in accordance with written procedures; verify Covid-19 mitigations have been effectively implemented; assess Process Hazard Analysis/HAZOP of Hardisty Terminal and management of change related to the recent tie-ins of DRA skids (see CER order XO-002-2020).

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations - Express Hardisty Terminal

Date & time of visit: 2020-10-21 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 2 - General Observations - Ribstone Creek Pump Station

Date & time of visit: 2020-10-21 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 3 - General Observations - Youngstown Pump Station

Date & time of visit: 2020-10-22 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 4 - General Observations - Covid-19

Date & time of visit: 2020-10-21 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 5 - IR 1 - Request for Documents

Discipline: Safety Management

Categories:

Facility:

Observations:

Documents are requested for the purpose of planning the inspection and facilitating a mutual understanding between CER staff and company representatives regarding Covid-19 protective measures.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the plans, procedures, or standards that describe the expectations for workers and contractors to minimize the risk of Covid-19 transmission. Provide the latest revision of the Process Hazard Analysis/HAZOP that applies to Express Hardisty Terminal. Provide a copy of the electrical isolation procedures that apply to the planned VFD maintenance at Youngstown Pump Station on 22 Oct 2020.

Due date: 2020-10-19

Date closed: 2020-10-16
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 6 - CNC 2 - Pressure Safety Valves

Date & time of visit: 2020-10-22 13:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

On 22-Oct-2020 CER Inspection Officers (IOs) observed inlets to pressure safety valves (PSV 702 and 711) at Youngstown Pump Station that were not fitted with locks or seals to prevent unauthorized or inadvertent operation. A review of the station drawings for Youngstown identified these valves as C.S.O (car seal open). 

IOs also observed a pressure safety valve at Ribstone Pump Station on 22-Oct-2020 that was not sealed in the open position.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

With respect to seals on pressure safety valves, implement the controls identified on the station drawings or explain why these valves are not sealed in the open position.

Due date: 2020-10-23

Date closed: 2020-10-23
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 7 - NNC 1 - Express Hardisty Terminal PHA

Date & time of visit: 2020-10-22 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) requested a process hazard analysis (PHA) for the Express Hardisty Terminal (Company). Company staff replied that a PHAs were only completed for project execution or for management of change (MoC), and that a PHA did not exist for the Express Hardisty Terminal. The company was unable to provide documented evidence that process hazards at Express Hardisty Terminal had been identified, analyzed, managed, or mitigated.

Company provided CER with documents on 28 Oct 2020 that evidence a process for identifying, analyzing, managing, and controlling process safety hazards has been established. These documents include:

  1. Enbridge Risk Analysis Process, v. 2.1
  2. Enbridge Hazard & Risk Management Process, v. 3.0
  3. Enbridge Liquid Pipelines Inventory of Hazard & Potential Hazard Categories, v. 5.1
  4. Enbridge Process Hazard Analysis Process, v. 1.1
Missing, however, was evidence that these processes have been implemented with respect to hazard analysis, management, and control for Express Hardisty Terminal.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following for Express Pipeline Hardisty Terminal:
CSA Z662-19 Clause 2.2 defines a hazard as a a condition or event that might cause a failure or damage incident or anything that has the potential to cause harm to people, property, or the environment
 

  1. Demonstrate that all and potential hazards that might cause a failure or damage incident such as a release of hazardous material and/or energy with the potential to cause harm to people, property or the environment have been identified and analyzed, inclusive of consequences associated with such hazards.
  2. Provide the inventory of identified and potential hazards(including descriptions) that might cause a failure or damage incident such as a release of hazardous material and/or energy with the potential to cause harm to people, property or the environment.
  3. Demonstrate that the risks associated with the identified and potential hazards from #2 have been evaluated, inclusive of normal and abnormal operating conditions and a description of such operating conditions.
  4. Demonstrate that controls to prevent, manage and mitigate the hazards from #2 have been implemented and communicated to anyone exposed to the risks. 

Due date: 2021-03-01

Date closed: 2021-03-25
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 8 - IR 2 - PHA schedule

Discipline: Safety Management

Categories:

Facility:

Observations:

Section 2.3(a) of Enbridge Process Hazard Analysis Process describes the process for performing PHA planning for existing facilities.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide the schedule for performing process hazard analysis (PHA) for Express Pipeline Ltd. CER-regulated facilities. Include the rationale for risk prioritization for these facilities.
  2. State why process hazard analysis (PHAs) are limited to MoC’s and project execution and not considered applicable to the operations and other life cycle phases of facility. As part of your response, indicate how the limited applicability of PHA’s is consistent with lifecycle approach of safety at the facility given that process hazards remain present across the facility lifecycle.

Due date: 2020-12-11

Date closed: 2021-03-25
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 9 - IR 3 - DRA Tie-Ins PHA

Discipline: Safety Management

Categories:

Facility:

Observations:

Company provided CER with a copy of the Express Line DRA tie-ins Process Hazard Analysis Report, Rev A. Section 1.2 report contains one recommendation (category = FIN), and five parking lot items.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Indicate if any follow up action has been taken or is required for the following parking lot action identified in the Express Line DRA tie-ins PHA Report, Rev A. 

Due date: 2020-12-11

Date closed: 2020-11-30
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 10 - IR 4 - PHA parking lot items

Discipline: Safety Management

Categories:

Facility:

Observations:

n/a

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide information on the status of the five parking lot items identified in Express Line DRA tie-ins Process Hazard Analysis Report, Rev A.

Due date: 2021-04-06

Date closed: 2021-04-07
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 11 - 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