Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Compliance verification field inspection against regulatory requirements, including National Energy Board (NEB) Onshore Pipeline Regulations (OPR), project specific safety requirements and applicable Canada Labour Code Part II (CLC II) requirements. Field observations of ongoing construction activity of Line 3 Replacement on Spread 9, focused on pipe-handling, including stringing and bending, welding and contractor oversight. Indigenous Advisory Monitoring Committee (IAMC) Indigenous Monitors (IM) accompanying NEB inspectors.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Pipe Stringing Crew on Right of Way
Date & time of visit: 2018-09-17 14:35
Discipline: Safety Management
Categories:
Facility:
Observations:
Prior to arrival at location of pipe stringing, the NEB Inspection Team, including Indigenous Monitor and Company Representatives met to kick off the inspection, plan travel logistics and sites to be visited.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Information Request 1The Company to provide pipe handling procedure(s) used by the contractor on Spread 9.Information Request 2The Company to provide written assurance of inspection process to ensure operators of crawler not only complete but also sign daily / pre-use inspection forms.
Due date: 2018-09-18
Date closed: 2018-09-18 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 2 - Pipe Loading Crew in Laydown Yard
Date & time of visit: 2018-09-18 09:05
Prior to arrival at East Morden Pipe Yard, NEB Inspection Team met with Indigenous Monitors and Company Representatives and confirmed site visits to observe bending and welding.
Information Request 3Following a precautionary approach, Company to provide documentary evidence that oily spot on deckhand part receives preventative maintenance.
Due date: 2018-09-24
Date closed: 2018-09-24 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.
Observation 3 - Pipe Setup Crew
Date & time of visit: 2018-09-18 10:15
Arrived at shoofly 26, to observe pipehandling during setup to bending activity.
The Company shall provide the most current documented pipehandling procedures permitting the activity of moving pipe segments as observed without the use of tag lines. The Company provided documented pipehandling procedures permitting the activity of moving pipe segments as observed without the use of tag lines. However, examination of "SA Energy Group Enbridge Project Specific Safety Plan (PSSP) Enbridge L3R Project - Spread 9 REV:02 July 18, 2018" may contradict or is not sufficiently clear on the procedure to be used. The PSSP makes no apparent reference to the documented pipehandling procedures permitting the activity of moving pipe segments as observed without the use of tag lines. Moreover, it states on page 56 of 100: [Begin quotation]36 Pipe HandlingWhen moving or lifting pipe, SAEG and Subcontractors must exercise care to not damage the pipe, pipe ends, and/or bevels. Appropriate lifting equipment must be selected when handling and moving pipe. Lifting equipment includes:
Due date: 2018-10-25
Date closed: 2018-10-19 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.
Observation 4 - Pipe Bending Crew
Date & time of visit: 2018-09-18 11:05
Compliance tool used: No compliance tool used
Observation 5 - Welding Pipe Gang
Date & time of visit: 2018-09-18 12:40
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program