Compliance Verification Activity Report: CV2223-022 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2927
• Inspector 2935

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Safety Management

Related events:

• CV2223-030
• CV2223-305
• CV2324-030
• CV2324-040
• CV2324-252
• CV2425-049

Rationale and scope:

Process Safety - Regina Terminal. Assessing implementation of identification, analysis and control of process hazards including established process hazard inventory. Assessing completion of preventive maintenance (inspection and testing) activities on critical safety equipment including tank/sump level sensors and pressure relieving devices per prescribed frequencies under CSA Z662 and company programs.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

• REGINA TERMINAL

Facility Types

• Pipeline
• Meter station
• Pipeline
• Pump station
• Station piping
• Terminal
• Valve site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• National Energy Board Act (NEBA)
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observations - Process Safety Management

Date & time of visit: 2022-08-09 08:00

Discipline: Safety Management

Categories:

• Hazard Management
• Process Hazard Inventory
• Equipment, Tools, Machinery
• Safety Critical Equipment Identification, Inspection, Testing and Maintenance
• Management of Change
• Management of Change

Facility:

• REGINA TERMINAL (Facility)

Observations:

General Observations - Process Safety Management 

• Canada Energy Regulator (CER) Inspection Officers (IO) met with company representatives at the facility office, and conducted an opening meeting and visitor orientation.
  • CER IOs interviewed three company representatives to gain an understanding of process safety,  management training and awareness, and craft specific responsibilities at the facility. 
  • Prior to a site tour, the Enbridge Compliance Advisor completed a field level hazard assessment applicable to CER inspection activities.

• CER IOs discussed with company representatives the fact a baseline and comprehensive Process Hazard Analysis (PHA) was not available for the Enbridge Regina Terminal (see IR 2 and 3).
  • IOs noted the age of some process equipment on location is dated from the 1950's.
  • IOs reviewed company documentation noting criteria for establishing when PHAs will be undertaken by the company for process systems, and that the Enbridge Regina Terminal does not meet the defined company criteria for a process wide PHA.
• IOs reviewed a Management Of Change (MOC) package for recent facility updates that included a PHA for that project, and that this PHA aligned with company documentation
  • IOs reviewed the MOC package and confirmed any remaining action Items from the PHA were completed and closed out.

• CER IOs reviewed an example of a completed facility change package including:
  • a PHA completed for the change, and
  • updated P&ID drawings representing the changes.

• IOs asked about the Covid-19 pandemic and potential supply chain issues leading to lack of 'critical spare' parts for important instrumentation or control devices, IOs were told this facility has not had any supply chain issues and maintains a warehouse with spare devices and parts on site.
• The inspection and maintenance of safety critical equipment is tracked by the company's internal asset management software. The software generates work orders based on the required inspection and maintenance interval.
• The work order is accompanied by a job plan that lists detailed instructions for completing the task. When asked by IOs, workers tasked with the inspection and maintenance of safety critical equipment appeared knowledgeable of the job plan requirements.
• CER IOs recorded identification and instrumentation device numbers from a variety of equipment and reviewed the operations, inspection and maintenance records related to:
  • Underground Sump Tank #201
    • The company identified the inspection and maintenance frequency for sump level devices to be 6 months, 1 year, and 3 years.
    • IOs reviewed a semi-annual sump inspection completed on 19 April 2022, an annual inspection completed on 28 Sep 2021, and a 3-year sump systems level switch calibration completed on 29 Sep 2021.
      • IOs noted a follow-up work order was created during the annual inspection due to the fact the interstice could not be verified due to a stuck tube. The follow-up work order had not been completed as of 10 Aug 2022. The company indicated verbally they were awaiting an engineering assessment.
      • The 3-year level switch inspection also generated a follow-up work order indicating the "LSHH doesn't ring in as an alarm". This follow-up work order had not been completed as of 10 Aug 2022 although the company indicated verbally the level switch does not discriminate between high and high-high alarms, and rings in as a high-high in either circumstance.
         
  • Inlet manifold Pressure Safety Valve (PSV)
    • The company identified the inspection and maintenance interval for PSVs on manifolds to be 1-year, and as determined by CSA Z662-19.
    • IOs requested maintenance and calibration records for thermal relief valve identified as 201-PSV-11.
      • Records were provided for 28 June 2022. No deficiencies were identified.
         
  • Storage Tank #71
    • IO requested inspection and maintenance records for the tank level indicators and transmitter.
    • The company identified the maintenance interval for critical level indicators and level transmitters to be 1-year.
    • IOs reviewed level transmitter inspection records dated 13 Sep 2021 and level switch inspection records dated 14 Sep 2021. No deficiencies were noted on the inspection records.
    • IOs also reviewed the most recent API 653 in-service tank inspection report. The report stated the tank was fit to remain in service.

• CER IO asked a facility Electrician(s) about an ARC Flash safety program. The electricians was able to speak to several components of an ARC Flash safety program including facility surveys, equipment labelling, and PPE.
• Electrician had noted some electrical equipment was in operation since the 1970's but there was evidence of updating equipment over select time frames.
• Electricians were able to speak to facility back up power systems including independent generators dedicated to ensure various mainline control systems remain functional
• IO asked the electrician(s) about knowledge of a facility Lightning Risk Assessment, as found in NFPA 780, electricians noted there was no knowledge of that information or if a lightning risk assessment had been completed.
• With regard to oil storage tank grounding and bonding inspection and maintenance, IO asked electrician(s) about a tank bonding and grounding assessment and frequency of that inspection; electricians were not able to speak to a tank bonding and grounding testing process. The Enbridge Compliance Advisor was able to produce a copy of an API 653 formatted tank inspection that included confirmation of checking for a ground cable on the storage tank.
  • The CER IO was not able to confirm that grounding and bonding systems for oil storage tanks are tested for adequate conductivity on a regular or intermittent schedule as related for purposes of dispersing lightning strike. 

• CER IOs were provided a facility plot plan noting Restricted and Hazardous Areas.
• CER IOs toured the storage tank area and observed tank berm integrity as well as the sites natural water drainage arrangement.
• IOs observed each tank to be impounded by an open dike. Water drainage valves were accessible from outside the diked area and appeared to be in the closed position.
• The terminal facility is monitored for fire conditions with smoke and heat detection as well as fire-eye systems.
• Hot Work permits are issued when sources of ignition are employed at facility work site areas.
• IO was told facility employees receive training on fire fighting. 
• IO was told facility employees are able to use water monitor and foam suppression systems. 
• IO was told facility employees practice and use fire fighting equipment at least annually.

Compliance tool used: No compliance tool used

Observation 2 - NNC - 1 - Failure to complete an Information Request

Date & time of visit: 2022-08-25 08:00

Discipline: Safety Management

Categories:

• Records & Documentation
• Occupational & Process Safety Information

Facility:

• REGINA TERMINAL (Facility)

Observations:

NNC - 1 - Failure to complete an Information Request in the required time frame.

1. On August 15, 2022, the CER Inspection Officer requested through Information Request (IR), a copy of the Enbridge, Regina area LP Risk Register. The requested due date for the IR was originally stated as August 17, 2022, and at the request of Enbridge Senior Compliance Advisor, the due date was extended to August 24, 2022. As of August 24, 2022, the requested document was still not submitted, and without justification or prior conversation to inform the CER IO there would be delays etc.
   1. The CER IO requires the requested document to assess for a demonstration of hazard identification processes, as related to inspection activities pursuant to CVA 2223-022. 
   2. The CER IO views the requested risk register document, as what should be a readily available document for applicable stakeholders, such as a CER Inspection Officer. The delay in providing the requested document, in its entirety, is not acceptable. 

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

Regulatory requirement:

• Canadian Energy Regulator Act (CERA)

Relevant section(s):

• • Administration and Enforcement
    • Duty to assist
      103 (4) The owner or person in charge of the place and every person in the place must give all assistance that is reasonably required to enable the inspection officer to perform their duties and functions under this section and must provide any documents or information, and access to any data, that are reasonably required for that purpose.

Company action required:

Enbridge is to file to the requested document, in its entirety, by end of day, August 31, 2022. 

Due date: 2022-08-31

Date closed: 2022-08-31
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: