Compliance Verification Activity Report: CV1819-004 - 2193914 Canada Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2463
• Inspector 2538

Regulated company: 2193914 Canada Limited

Operating company: Enbridge Gas Inc. (Enbridge Gas)

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Safety Management

Rationale and scope:

Field Inspection of 2193914 Canada Limited, operated by Enbridge Gas Inc. Safety Program focus, to verify compliance with the National Energy Board Onshore Pipeline Regulations (OPR) and company-specific requirements.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (2)

Facility details

Facilities:

Facility Types

• Pipeline
• Odorant station
• Pipeline right of way (ROW)
• Station piping
• Valve site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Winston Churchill & Steeles Station

Date & time of visit: 2019-03-28 10:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Electrical Safety
• Fire Protection
• Hazard Assessment
• Permanent Structures
• Housekeeping
• Signage

Facility:

Observations:

• Company representative led a discussion with inspection participants and completed a site specific hazard assessment (SSHA) for the station’s inspection.
• Appropriate pipeline identification markers were present on either side of the road crossing.
• Appropriate pipeline identification marker was present on north side of site fence line at the valve site.
• Signage indicating danger, no trespassing, no smoking or vaping, as well as site name and operating company were present at the valve site.
• Appropriate signage indicating danger, no trespassing, no smoking or vaping, the station name and operating company, as well as the telephone number for emergencies were present at the feeder station.
• Egress gate (panic gate) at station was functional.
• Jersey barriers were in place along fence lines adjacent to traveled roadway.
• Housekeeping  at facilities and in communications building was appropriate
• Rodent pest controls were in place.    

Compliance tool used: No compliance tool used

Observation 2 - Winston Churchill & Steeles Station – Communications Building

Date & time of visit: 2019-03-28 10:45

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Fire Protection

Facility:

Observations:

Fire extinguisher in communications building had up to date annual certification and monthly inspection tag. This fire extinguisher was on the floor of the building and not installed as prescribed in Clause 6.1.3.4 of NFPA 10 – Standard for Portable Fire Extinguisher, referenced in Clause 10.2.7.2 (e) of CSA Z662, which is in non-compliance to the paragraph 4(1)(d) of the National Energy Board Onshore Pipeline Regulations (OPR).

OPR
Paragraph 4(1)(d)
4 (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of (d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons.
 
CSA Z662
Clause 10.2.7.2 (e) of CSA Z662  
Operating companies shall maintain appropriate firefighting equipment. Such equipment shall be (e) positioned as specified in NFPA standards.
 
NFPA 10 – Standard for Portable Fire Extinguishers
Clause 6.1.3.4
Portable fire extinguishers other that wheeled extinguishers shall be installed using any of the following means: (1) Securely on a hanger intended for the extinguisher (2) In a bracket incorporating releasing straps or bands supplied by the extinguisher manufacturer (3) in a listed bracket incorporating releasing straps or bands approved for such purpose (4) In approved cabinets or wall recesses.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 4. General
    • (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of
      • (d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons; and

Company action required:

Company is to demonstrate the portable fire extinguisher has been installed in accordance with NFPA 10. 

Due date: 2019-04-02

Date closed: 2019-04-02
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 - Lisgar Gate Station

Date & time of visit: 2019-03-28 11:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Housekeeping
• Signage
• Lighting
• General Lighting

Facility:

Observations:

• Company representative led a discussion with inspection participants and completed a site specific hazard assessment (SSHA) for the station’s inspection.
• Appropriate pipeline identification markers were present on either side of the road crossing.
• Signage indicating danger, no trespassing, the station name, operating company, as well as an emergency contact number, were present.
• Verified egress gate (panic gate) on the eastern fence line of the station was functional.
• Receiver barrel and pipeline components were stored in the station yard. Pipe components were stored off the ground on skids or other appropriate temporary structures, and open piping components have bolted on end caps. Company representatives explained that these are utilised when the line is inspected or cleaned with in-line tools. Storage is necessary between uses as company does not currently have sufficient space or authorizations to install the launch/receiver permanently at the end of the pipeline at the Pine Valley Road site.
• Remote / sensor gas detection was present in station buildings.
• Hazard signage, TDG placard signage, and other signage within the station and buildings was appropriate.
• The station’s control / office building was equipped with an air horn, medical kit, and an eyewash station was present.
• Housekeeping was appropriate in all visited buildings.
• Verified egress doors in station building were functional and provided unimpeded escape routes.
• Racking units in Heat Exchange Building were labeled with load capacity restriction.
• Fully stocked large spill kits were present in the Odorant Control Building and in the boiler room of the Heat Exchange Building.
• From discussions with company representatives, and further from a review of a station piping diagram, NEB Officers are of the view that the mainline and associated components such as valves, launcher / receiver are in fact in the NEB's jurisdiction, the remainder of buildings and facilities at this station would fall outside the NEB's jurisdiction.  

Compliance tool used: No compliance tool used

Observation 4 - Gore Road Valve Site

Date & time of visit: 2019-03-28 11:55

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Hazard Assessment
• Permanent Structures
• Signage

Facility:

Observations:

• Company representative led a discussion with inspection participants and completed a site specific hazard assessment (SSHA) for the Valve Site’s inspection.
• Appropriate pipeline identification markers were present on either side of the road crossing to the east of valve.
• Appropriate and necessary signage was present at valve site.

Compliance tool used: No compliance tool used

Observation 5 - Gore Road Valve Site - Vegetation

Date & time of visit: 2019-03-28 14:00

Discipline: Safety Management

Categories:

• Permanent Structures
• Housekeeping

Facility:

Observations:

Woody overgrown vegetation was present within the valve site, which not as prescribed in Clause 10.6.2 - Vegetation control, 10.5.8 Environmental Effects, and Clause N.10.2 - External interference of CSA Z662 which is in non-compliance to the paragraph 4(1)(d) of the National Energy Board Onshore Pipeline Regulations (OPR).

OPR
Paragraph 4(1)(d)
4 (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of (d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons.
 
CSA Z662
Vegetation control
10.6.2
Where the terms of the easement permit, vegetation on rights-of-way shall be controlled to maintain clear visibility from the air and provide ready access for maintenance crews.
 
Environmental effects
10.5.8 (j)  
Operating companies shall establish effective prevention and control measures to maintain the effect of pipeline system operations upon the environment within acceptable levels. Precautions listed in Clause 6.6 shall be taken to avoid uncontrolled fires.
Note: Matters that should be considered include the following:
(j) aesthetics;
 
External interference
Clause N.10.2 (c)
The options that may be used to reduce the frequency of failure and damage incidents associated with external interference include the following, as applicable:  (c) vegetation control to improve right-of-way visibility.
 

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 4. General
    • (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of
      • (d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons; and

Company action required:

To ensure vegetation is controlled, aesthetics are maintained and to minimize external interference, company is to demonstrate it is in compliance with NEB OPR 4(1)(d) with respect to vegetation control.

Due date: 2019-04-05

Date closed: 2019-04-02
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 6 - Pine Valley Road Site

Date & time of visit: 2019-03-28 14:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Hazard Assessment
• Permanent Structures
• Signage

Facility:

Observations:

• Company representative led a discussion with inspection participants and completed a site specific hazard assessment (SSHA) for the valve site’s inspection.
• This is the terminal point of the pipeline and is located between two other pipelines also regulated by the NEB.
• Site only has a valve and associated riser that are federally regulated; distribution regulators present are likely outside of the NEB's jurisdiction.
• Appropriate pipeline identification markers were present on either side of the road crossing to the east of valve.
• Appropriate and necessary signage was present at valve site.
• There was limited vehicle access to site location; appropriate traffic safety measures were taken.

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: