Compliance Verification Activity Report: CV2223-041 - Enbridge Southern Lights GP Inc. on behalf of Enbridge Southern Lights LP

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2648

Regulated company: Enbridge Southern Lights GP Inc. on behalf of Enbridge Southern Lights LP

Operating company: Enbridge Southern Lights LP

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Safety Management

Rationale and scope:

[Field inspection of O&M activities] - Hazardous Energy Management and LOTO practices

Compliance tool(s) used:

• None

Facility details

Facilities:

• Line 13

Facility Types

• Pipeline
• Terminal
• Valve site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Policy Committees, Work Place Committees and Health and Safety Representatives Regulations(CLCPC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Workplace Harassment and Violence Prevention Regulations(WPHVPR)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Information Request

IR from CER (Information Request sent from CER to company)
IR1 - Pre-Inspection Documentation

Legislative Requirement : Canadian Energy Regulator Act (CERA)

Theme and Categories

Due Date : 2022-05-09

Review Response
Acceptable

Follow-up Action
None

Observations (no outstanding follow-up required)

Observation 1 - Site Specific Procedure and Supporting Documentation

Date & time of visit: 2022-05-17 13:00

Discipline: Safety Management

Categories:

• Training and Competency
• Training, Competency and Qualification
• Workplace Practices
• Procedures/Work Instructions
• Hazard Management
• Management of Hazardous Energy

Facility:

Observations:

The Enbridge PLM supervisor led an overview of the site specific procedure for pig launching including lock out tag out requirements for the operation.

Planning

• The operation is initiated by generation of a Capacity Outage Planning and Approval System (COPAS), which is received by the COO
• The open system Job Planning Complexity Tool was described. The tools provides a systematic methodology to categorize the work activity based on complexity and risk. The output of the tool includes the identification of required personnel and level of approval for a given activity. This particular activity did not require elevated resource allocation or approval (i.e. routine).
• Safe work permits and Energy Isolation Forms were reviewed. The roles and responsibilities of affected workers were discussed. The work crew was deemed to be competent as per Enbridge evaluations process.
• Competency record for all employees were verified and assessment process was described which included computer based, instructor led, operating qualification and task assessment through on the job training by a trained mentor. Competency is re-certified every 3 years.
• Aside of a labourer working directly with the company crew the vac truck operator was the only contractor involved in the operation. Competency is generally verified through ISN and established relationships. IO's verified completion of the contractor FLHA for their particular task.
• In discussion with company personnel it was confirmed that the Enbridge Control of Hazardous Energy Standard is intended to align with and satisfy the requirements of CSA Z460 - Control of Hazardous Energy.  Company personnel indicated that they will be revisiting s.6.2.3 of the company standard to confirm that the wording clearly meets the intent of s.7.3.2.2.3 of the CSA standard which requires that where the device cannot be locked out, energy-isolating devices be secured in an effective isolating position using a means that prevents inadvertent operation of the device in addition to using an information tag.

• Critical controls including continuous atmospheric monitoring, grounding of equipment, PPE use, positive air shut off and signage were verified.
• The cleaning tool inspection for task was complete and reviewed
• PLM supervisor described the process of verifying drawings and valve identification by walking the line.
• PLM is authorized to conduct basic electrical work based on the arc flash hazard rating.
• It was confirmed that all valves were switched to local so that travel could be visually verified.
• LOTO equipment was standardized and included colour codes based on its purpose. LOTO tags were also standardized and used solely for LOTO purposes.
• The LOTO procedure for the particular activity is considered routine and is reviewed every three years
• Double block and bleed was not achieved so an engineer certified alternate isolation plan (AIP) was executed as per the site specific procedure. The implementation of the AIP does not change the requirements with respect to safety, approvals or permits etc.
• PLM Supervisor explained how the trap is emptied and purged with nitrogen which is confirmed by monitoring the positive and then negative pressure drawn by the vac truck.

Compliance tool used: No compliance tool used

Observation 2 - Simulation - LOTO and Line 13 Pig Launch Pre-planning Meeting

Date & time of visit: 2022-05-18 09:00

Discipline: Safety Management

Categories:

• Workplace Practices
• Procedures/Work Instructions
• Hazard Management
• Management of Hazardous Energy

Facility:

Observations:

Attended a simulated pre-work planning meeting for a cleaning tool launch on line 13. The meeting included a review of the pertinent documents including:

• The COPAS - which triggers the activity
• Field level hazard assessments for company and contractor - an opportunity exists to include additional detail in hazard assessment documents when new workers are involved, when a plan change or, in non-routine and unique and unusual hazard situations.
• Open system job planning complexity tool - opportunity was discussed to apply methodology to other scopes of work
• Site specific procedure - an opportunity was discussed to add clarification around the requirement to have a "Safety Person" in place (step 29).
• Energy isolation forms - an an opportunity was discussed to add clarification around the requirement to have a dedicated "fire watch" in place - company reps indicated that fire watch was a shared responsibility amongst entire crew.
• Cleaning Tool Inspection
• Alternate isolation plan
• Safe Work permits

Compliance tool used: No compliance tool used

Observation 3 - Simulation - LOTO and Line 13 Pig Launch Execution

Date & time of visit: 2022-05-19 11:00

Discipline: Safety Management

Categories:

• Workplace Practices
• Procedures/Work Instructions
• Hazard Management
• Management of Hazardous Energy

Facility:

Observations:

Isolation and Lock-out
Workers walked through the process to Launch a cleaning tool on Line 13 including the de-energization, isolation and application of locks and tags on valves and electrical switches. An explanation of the verification step for double block and bleed (DIB) was received including the applicable scenario where DIB was not achieved and the engineer certified Alternate isolation Plan was followed.

Vac truck operations were explained including the grounding method and requirement for H2S/Benzene indicators and signage.

Loading Tool
Workers described the requirement for gas/benzene detection, proper PPE, fire extinguishers and bonding cables and confirmation that all ignition sources are monitored at least 100 feet away from work area (vehicles, air compressor). Personnel to wear full face mask respirators when working near open trap door and front of the trap is flagged or signage installed to prevent workers from inadvertently walking or working within 15 m (50 ft) of trap.

Tool is loaded with non-critical lift, however load charts are verified and rigging is inspected. Tool is loaded into trap with care taken to avoid damage to the o-ring which is cleaned and inspected prior to closing the trap door.

Flooding and Pressurizing
Drawings are verified for all steps including valve operation. The trap is flooded from the vac truck and valve breakers are energized. LOTO for drain and vent valves is verified to be in closed position. Valve is opened to flood and pressurize trap and the door seal and fittings are verified for no leaks. Tools is launched as per procedure CCO confirms acceptable conditions and control center is notified of time of launch.

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: