Compliance Verification Activity Report: CV2223-029 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2480
• Inspector In Training 2960T

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Integrity Management

Related events:

• CV2021-059
• CV2324-040
• INC2019-024

Rationale and scope:

Field inspection required to verify the information provided in the Information Request (IR) responses to CV2021-059. 

Compliance tool(s) used:

• None

Facility details

Facilities:

• HARDISTY

Facility Types

• Pipeline
• Electrical facility
• Pipeline

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• 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

Observations (no outstanding follow-up required)

Observation 1 - Line 4 Relief Section, UPS and PLC

Date & time of visit: 2023-01-16 08:00

Discipline: Integrity Management

Categories:

• Facilities
• Overpressure Protection
• Piping
• Electrical Workmanship
• Batteries and UPS
• Documentation
• Record Retention
• Updating

Facility:

• HARDISTY (Facility)

Observations:

• CER inspectors met Enbridge staff at the Hardisty facility, attended Enbridge Safety Orientation, and reviewed and signed the Safe Work Permit and the Field Level Hazard Assessment.

• The activity scope, an inspection of the Line 4 relief section and the UPS and PLC, was discussed. 

a) Relief system for Line 4:

• Danflo pressure relief valve (YP-813-PSV-1227) is installed on the NPS 16 PN 50 pipe and set at 515 psi, below 110% of  MOP.

• It was noted that the buckling pin which was installed upstream to the Danflo pressure safety valve was removed from the relief system and replaced with a spool piece as previously communicated to the CER.

• Enbridge staff confirmed that the removal of the buckling pin would not affect the overprotection of the system since it was only used for the custody transfer purposes. The system remains protected by the Danflo pressure safety valve.

• The replacement spool piece was confirmed to have been pressure tested in the shop prior to installation. CER inspectors requested information regarding the pressure testing and the non-destructive examination (NDE) of the pipe spool (Action Item 1, not yet provided - refer to Information Request (IR) 1). The bolts and studs used for the spool connection extended beyond the face of the associated nuts and appeared to be in good condition. Metal gaskets were confirmed to be used for connections. 

• Enbridge staff confirmed that the Danflo valve relief capacity is designed for full mainline relief into Tank 41. The valve is tested annually and visually inspected for leaks at any time when work is conducted to replace the nitrogen supply (e.g., weekly to up to ten days in winter time). The last Danflo valve test report was requested by the CER inspectors (Action Item 2) and provided by Enbridge. The test report provided (Work Document Details 7045374) was later reviewed and no further information was required. 

  • The following observations were made regarding the piping condition: the external coating appeared to be in good condition, the pipe segments were properly supported (not welded to the pipe), no dead legs were identified, flow directions were marked on the pipe segments, no visible corrosion at the soil-to-air interface as it was possible observed due to presence of snow.  

b) Uninterruptible Power System (UPS) unit and Programmable Logic Controller (PLC) system:

• The UPS switching procedure was in place.

• The existence of an alternate (backup) source of power (diesel power generator) to maintain the station instrumentation and the emergency shut-down system (ESD) in operation during a power loss event, was confirmed by Enbridge staff. 

• Electrical reference drawings were in place.

• Arc flash hazard warning signs with arc flash rating working distances and personal protective equipment requirements were present.

• The UPS battery ventilation system could not be observed within the UPS cabinet. Staff noted that Safety Advisory SA 2014-01 mentions that:

  • Rule 26-546 of the Canadian Electrical Code (CEC) states: Storage battery rooms or areas shall be adequately ventilated; storage batteries shall not be subjected to ambient temperatures greater than 45 °C or less than the freezing point of the electrolyte.

  • Rule 2-3000(2) of the CEC states that: Electrical equipment deemed for emergency service, shall be periodically inspected and tested as necessary to ensure its fitness for service.

  • CER staff is requesting further information to verify the company's compliance with SA 2014-01 (refer to IR 2)

• The lock-out/tag-out procedure was explained by Enbridge staff. Panels locked for decommissioning have the tags labeled and include the rationale, contact name, and phone number. Once the decommissioning is completed, the instrumentation is removed, and the panels are labeled as "spare" and properly tagged. 

• The PLC system located in the control room was inspected. Staff discussed the PLC diagram provided in the Presentation dated 18 February 2021. Enbridge staff clarified that the diagram was inaccurate in the sense that a single wire connects the UPS to the two power cards to Terminal TS2, then the wire splits, into two Terminals, TS2-1 and TS2-4, to feed the power cards. CER inspectors requested clarification about the scope of visual inspections of the power cards, UPS and PLC. Enbridge staff clarified that:

  • the visual inspection is limited to verifying that the equipment LED indicators are ON and do not signal any anomaly (e.g., OFF or Alarm).

  • the entity monitoring the station alarms 24/7 is Communication Control Operation (CCO) located in Edmonton. Upon receiving an alarm CCO would either:

    • follow up with the operation staff at Hardisty in the case of critical issues, or

    • creates a job order for non-critical issues.

  • In the event of a failed power card, CCO would receive a continuous alarm until the power card is repaired or replaced.

• CER inspectors requested a copy of the latest 2021 revision of the UPS annual maintenance job plan (EP10018)(Action Item 3). The plan was presented, a copy was provided and later reviewed. Further information was required regarding the document, specifically regarding the UPS load test and the UPS batteries test (refer to IR 2). CER inspectors also inquired about which part of the Canadian Electrical Code is referenced in the 2021 UPS EP10018. The response could not be provided during the inspection and it will be submitted by Enbridge (Action Item 4, not yet provided - refer to IR 3).  

• Enbridge staff confirmed that the PLC preventive maintenance is completed every five years. 

• A short online discussion with Enbridge SMEs was conducted to address and clarify any outstanding questions from the inspection.  

• CER inspectors followed up on Enbridge's previous response of 11 June 2021 regarding the fact that the contractor was not notified of the defective PLC backup power card. CER inspectors requested further clarification regarding Enbridge's communication with contractors regarding such situations that could lead to hazardous conditions. Enbridge staff confirmed that mitigative measures regarding the company and contractor communications have been implemented since the 2019 event. CER inspectors requested the mitigative measures confirmed by Enbridge to demonstrate that the communication issue has been addressed and the contractors will be informed of similar situations and therefore such incidents can be avoided (Action Item 5, not yet provided - refer to IR 4)

• Following up on Enbridge's previous response of 11 June 2021 regarding the fact that the PLC backup power card was not working since 2018 (i.e., one year prior to the incident), the Enbridge staff reconfirmed that this was scheduled for maintenance at a later date, and therefore, the system was relying only on the primary power card. CER inspectors requested clarification on what Enbridge's processes consider an imminent issue with the PLC power cards, in order to be immediately replaced and thus to ensure proper functionality and provide redundancy to the PLC (Action Item 6, not yet provided - refer to IR 5).

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: