Compliance Verification Activity Report: CV1819-546 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2646
• Inspector 2408

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Safety Management

Related events:

• INC2017-172
• INC2018-118
• INC2018-127
• INC2018-141
• INC2018-158
• INC2018-171
• INC2018-175
• INC2018-176

Rationale and scope:

Spread 6: Follow up on recent series of reported injuries and incidents on Enbridge Line 3 construction.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Line 3

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Pipeline Damage Prevention Regulations – Authorizations
• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• Enbridge Liquid Projects and Major Projects Safety Manual
• Project-specific Contractor/Project Safety Plan (CSP)
• Banister Project Specific Safety Plan
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General

Date & time of visit: 2018-12-08 06:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Noise Control
• Signage
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

• NEB inspectors participated in visitor safety orientation.
• At the time of this inspection it was reported that Spread 6 had 789 manpower.
• NEB rental vehicle was washed by the NEB and tires were sprayed by Enbridge as part of their biosecurity plan.
• NEB inspectors boots were sprayed by Enbridge as part of their biosecurity plan.
• The ROW at all sites visited were free of garbage and debris. Good housekeeping apparent.
• NEB inspectors participated in the daily Enbridge safety inspector meeting and the daily construction progress meeting.
• During the Enbridge daily morning inspector meeting:
  • the Enbridge Safety representative spoke about the recent 'struck by' and material handling injuries and reminded the inspectors to verify the safety messaging was being disseminated in the field. 
  • Enbridge inspectors were told that there would be overtime work activities happening at specific locations on Sunday. As this was a normal rest day, no employees were being forced to work and therefor specific items were identified.
    • to encourage a shorter work day, there would be no morning inspector meeting
    • each crew would have less members and it was important to work slowly and crews would be shuffled around therefor it was important to exercise patience.
• NEB inspectors reviewed the Enbridge Focused Inspections package that is provided to all Enbridge inspectors.
  • The package contained the blank inspection forms to be completed and submitted. Each inspector is expected to complete a focused inspection once per week in addition to their daily observations.
  • This package also contained blank Safety Observation Cards. Each inspector is expected to complete one safety observation card per week. The inspectors are required to write an observation in the following sections:
    • Positive Observation
    • Ideas for improvement"
    • Yes, actions were taken based on ideas for improvement
  • NEB were told that Enbridge staff review each focused inspection and SOCs by Sunday each week and communicate with the respective inspector when deficiencies and or non-quality observations are noted.
• NEB inspectors reviewed the safe work permit #850329, ground disturbance permit #138674, and FLHA #161996 for the ditching, lowering-in, and tie-in of an elbow joint on December 6, 2018. NEB inspectors noted that the the safe work permit required gas monitoring every 2 hours, however, the results were not captured in the required section of the permit. Enbridge told the NEB that this information was captured elsewhere in the contractor's records for the activity. Enbridge advised that they would capture this along with other QAQC items noted with respect to documentation.
• NEB inspectors noted multiple access road locations were signed to advise of reduced speeds, children playing, close gate (pasture areas)
• NEB inspectors noted that all areas where power lines were present, goal posts and flags were in place
• NEB inspectors were told that Enbridge will be running radio and news paper ads in the communities along Line 3 to remind residents of potential dangers regarding open excavation etc while the crew is shut down for the holiday season.

Compliance tool used: No compliance tool used

Observation 2 - Bending Machine

Date & time of visit: 2018-12-08 09:14

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Hazard Assessment
• Materials Handling
• Conveying Equipment
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Temporary Structures
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

• NEB inspectors and Enbridge staff participated in the toolbox talk and signed on to the JSA for the activities at this location.
• NEB inspectors reviewed the safe work permit and FLHA and noted that the mention of tag lines was present on the safe work permit and not the FLHA.
  • NEB Inspectors spoke with Enbridge regarding the QAQC of the documentation and requirement for safe work permit controls to also be captured on the FLHA.
• NEB inspectors observed the pipe in the bending machine and the crew remained clear of any pinch points as the pipe was being processed.
• NEB inspectors observed that tag lines were present and ready for use where appropriate 
• NEB inspectors observed spotters were present when the side boom and bending machine were moved from one location to the next.
• Tires were placed on the ground prior to the equipment crossing a man made bridge, NEB inspectors were told this was to protect the surface of the crossing against destruction from the equipment tracks
• The foreman told the NEB that the crew was encouraged to take their time and work safely.

Compliance tool used: No compliance tool used

Observation 3 - Road Crossing - Horizontal Directional Bore(HDB) and Hydrovac

Date & time of visit: 2018-12-08 11:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• Task Lighting
• Noise Control
• Signage

Facility:

• Line 3 (Pipeline)

Observations:

• NEB inspectors and Enbridge staff participated in the tailbox talk and signed on to the JSA for the activities at this location.
• Foreman went into great detail in their explanation of the FLHA, ground disturbance permit, safe work permit. The foreman explained that the Enbridge safety bulletins had been shared with the crew that morning and the morning prior. The foreman advised that they instructed their crew members to enter the operators cockpit to get a birds eye view of the blind spots on the equipment.
• the foreman told the NEB that they conducted research on their own to obtain more safety topics and messages that could be shared with the crew.
• NEB inspectors observed the following with respect to the hydrovac activities(sub-contractor):
  • Reviewed the detailed JSA
  • Reviewed the FLHA
  • two noise and hearing protection signs were placed in visible areas
  • the truck operator used a spotter to back into place prior to conducting work and the spotter did a walk around prior to pulling away after the completion
  • the truck was not required to be grounded for the activity being conducted at this location
• NEB inspectors were told that all crossing agreements and locates are housed in blue tubes that are attached to the locate stakes for each specific location. NEB inspector were told that each Enbridge inspector is provided with a ground disturbance spreadsheet that is color coded to respect what activity has their ground disturbance permit and locates in place(depicted by green) and those that do not(depicted by red); NEB inspectors reviewed this document. 
• NEB inspectors observed the following with respect to the HDB activities:
  • NEB was told that all slings used were inspected prior to each use and any damage or if the label was not legible the sling was cut in half and put in the garbage so it could not be put back into use
  • examples of communication:
    • a sling was place on the heavy wall pipe in a manner that the foreman thought was not effective, the foreman told the crew to change it, the crew explained their rational for the use of the sling in that particular manner and the foreman accepted their judgemental and allowed the crew to precede
    • crew member #1 communicated with the bucket operator via hand signals and verbal commands when attaching the reamer to the pipe
    • crew member #1 communicated with the reamer operator via a two way radio. crew member #1 also communicated with the bucket operator lifting the front end of the pipe.
      • crew member #2 subsequently issued hand and verbal signals the two boom operators  
  • Bell hole:
    • NEB were told that the soil was type 2 and the wall slope was 1:1
    • 2 points of egress were present.
      • cut in stairs with the open edge painted in orange, and staked and taped with orange flag tape
      • ladder extending min 3 rungs above the excavation and secured with metal stakes at the top. the metal stakes also were topped with mushroom caps

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: