Compliance Verification Activity Report: CV1718-298 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1718-298
Start date: 2017-10-02
End date: 2017-10-05

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Construction Inspection L3RP (OC-63 & AO-1-XO-E101-004-2016) facilities - SK Pipeline installation (Spreads 3, if scheduling allows, could expand to Spread 4), looking at pipe handling, mainline welding; inspection should include the South Saskatchewan River HDD located in Spread 3. Civil works will be ongoing at Loreburn Station (most feasible given location is near South Saskatchewan River HDD site), Craik and Bethune Pump Stations (which are both situated within Spread 4).

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Additional Project-specific requirements or conditions:

Please note: XO-E101-004-2016 has been amended, and now AO-01-XO-E101-004-2016 is in effect. Changes were made to the Shedule A and should be referenced by integrity inspectors.

Observations (no outstanding follow-up required)

Observation 1 - Observations for 3 October 2017

Date & time of visit: 2017-10-03 06:15

Discipline: Integrity Management

Categories:

Facility:

Observations:

Inspectors Meeting
Latitude 51.49112 oN and Longitude 106.99386 oW
At 6:15 am, NEB inspectors attended the inspectors meeting which was conducted at the SA Energy’s yard in Outlook. In attendance was Enbridge and other inspectors. Agenda included safety moment, status on work conducted the day before, work to be conducted today, and tips/things to look out for today.  Due to heavy rain the previous day emphasis was on right-of-way (ROW) maintenance and being aware of poor road conditions.
 
Meeting with Geotechnical Specialist
Latitude 51.49112 oN and Longitude 106.99386 oW
At 6:30 am, NEB Inspectors met with a Geotechnical Specialist from BGC Engineering and a field engineer from Enbridge at the SA Energy’s yard. BGC Engineering was hired by Enbridge to provide applied earth science geotechnical engineering assistance on this project. The Geotechnical Specialist explained that:

HDD SSR West Side
Latitude 51.35584  oN and Longitude 106.99978 oW
At 8:45 am, NEB Inspectors arrived at the SSR HDD site. Also present was Enbridge Client Representative. A site-specific orientation was provided by Mears Super Intendant. Mears Super Intendant stated that:Big Sky Railroad Crossing
Latitude 51.38732 oN and Longitude 107.14355 oW
At 11:00 am, NEB inspectors arrived at the bore crossing of the Big Sky Railroad with the SA Energy Assistant Construction Manager and HDD Coordinator. NEB Inspectors noted that: 
Meeting with Enbridge’s Major Projects Construction Services Department
Latitude 51.49112 oN and Longitude 106.99386 oW
At 12:30, NEB Inspectors met with the following at SA Energy’s yard:
  1. Senior Welding and Non-Destructive Testing (NDT) Specialist (Contractor)
  2. Senior NDT Specialist (Enbridge permanent employee)
  3. Field Surveillance Coating (Contractor)
  4. Field Surveillance NDT (Contractor)
  5. Field Surveillance Welding (Contractor)
  6. Senior Welding Inspector (Contractor employed by Resdin) Note: Resdin is the company hired by Enbridge to provide 3rd party independent inspection services during mainline construction
During the meeting, the following topics were discussed: 
Daily Inspection Reports Review
Latitude 51.49112 oN and Longitude 106.99386 oW
At 1:30 pm, NEB inspectors reviewed binders containing daily inspection reports for bending, welding, coating, HDD, grading and bore crossings stored in the Construction Manager’s Trailer at SA Energy’s yard. NEB Inspectors noted that: A bore crossing daily report stated that contaminated soil had been encountered. NEB Inspectors inquired about this event to the Assistant Construction Manager and he explained that the contaminated soil was from a known historical leak from a nearby valve site, and that previous NEB Environment and Safety Inspectors had already noted this situation. NEB Integrity Inspectors followed up with NEB Environment Inspectors regarding this event. NEB Integrity Inspectors were informed that this event was added to the Contaminated Sites Inventory (REM-096) and that the inspection as well as the remediation aspects at this site will be assessed by the NEB Environment Inspectors.
 

Compliance tool used: No compliance tool used

Observation 2 - Observations for 4 October 2017

Date & time of visit: 2017-10-04 08:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

Morning Meeting with Senior Welding and NDT Specialists
Latitude 51.49112 oN and Longitude 106.99386 oW
At 8:30am, NEB Inspectors met with the Senior Welding and NDT Specialists at SA Energy’s Yard. The specialists informed NEB Inspectors that:

 
Welding at Road 42
Latitude 51.32916 oN and Longitude 106.90731 oW
 
At 9:50 am, NEB Inspectors arrived at welding activities taking place in the vicinity of Road 42. Upon arrival, NEB Inspectors reviewed and signed in on site specific risk assessment. NEB Inspectors observed:NDT at Road 42
Latitude 51.32916 oN and Longitude 106.90731 oW
 
At 10:30, NEB Inspectors walked down the spread to observe NDT of a weld. NEB Inspectors noted that: 
Tie-in Weld at Road 14
Latitude 51.48983 oN and Longitude 107.56472 oW
At 3:00 pm, NEB inspectors arrived at a location where a tie-in weld was being completed in the ditch. NEB Inspectors observed:  
MacDonald Creek at Road 16
Latitude 51.47215  oN and Longitude 107.50381 oW
At 16:00, NEB Inspectors arrived at a site in the vicinity of the MacDonald Creek. At this location, NEB Inspectors observed a welding crew performing the welding as per L3R-WPDS-6 Rev.1. At the time, the welders were conducting the fills done by FCAW in the downhill position. NEB Inspectors noted that the weld was being pre-heated before each pass and ground after a pass was done as per the procedure.
NEB Inspectors reviewed and signed the site specific risk assessment. The pipe segment destined to be installed at the MacDonald Creek requires a concrete coating to be applied onto its surface to provide buoyancy control. NEB Inspectors observed the buoyancy control crew installing mesh wire around the pipe segment in preparation for the concrete to be poured onto the pipe segment. Due to heavy rain on 2nd of October, water was present in the creek at this time, however Enbridge contractors stated that this creek is normally dry.
NEB Inspectors observed the MacDonald Creek slope (site 23E) which is categorized as a typical geohazard site in BGC Engineering’s Summary of Geotechnical Assessment for Slopes – Rev 1 (Enbridge’s submission for Condition 20 of Certificate OC-063). NEB Inspectors noted that the slope was steep, well graded and banks on either side of the ROW were angled and stable (refer to powerpoint presentation for picture).
 
Furthermore, NEB Inspectors noted that the ends of all of the pipe segments expecting to be connected by tie-in welds were protected by plastic wrap to prevent unwanted elements such as rain, wildlife, contaminants, etc. to enter.   
 

Compliance tool used: No compliance tool used

Observation 3 - Observations for 5 October 2017

Date & time of visit: 2017-10-05 10:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Trenching at Road 46
Latitude 51.29022 oN and Longitude 106.80147 oW
At 10:00am, NEB inspectors arrived at a site in the vicinity of Road 46 and observed trenching activities performed by a ditching wheel (refer to powerpoint presentation for picture).
 
Bending at Road 51
Latitude 51.24892 oN and Longitude 106.70224 oW
 
At 11:00am, NEB inspectors arrived at a site in the vicinity of Road 51 and observed a bending crew performing a series of bends. Markings on the pipe, as well as the engineering stakes located beside the pipes, indicated pipe bend requirements. The bend angle created by the bending crew was verified with a level and protractor (refer to powerpoint presentation for picture).
 
Coating at Road 38
Latitude 51.34525 oN and Longitude 106.95302 oW
At 1:00 pm, NEB Inspectors met with the Coating Inspector (a Resdin employee – Resdin was hired by Enbridge to provide inspection services on the project) at a site in the vicinity of Road 38. The Coating Inspector explained that the coating process includes five distinct steps: preparation, sand blasting, dusting, induction and coating. The Coating Inspector stated that:

  1. Preparation: involves roughly cleaning the surface of all field welds by removing tape, any debris, visible dirt/mud, etc.
  2. Sand blasting: corresponds to the surface preparation of all field welds with the purpose of achieving a required level of cleanliness and profile to promote adherence of the coating.
  3. Dusting: represents using wire brushes to remove any dust or particles left by the sand blasting step.
  4. Induction: is associated with the heating of the surface of a field weld to a temperature of 70 – 90 degrees Celsius before coating is applied by using an induction coil.
  5. Coating: entails applying the coating on the surface of all field welds.
NEB Inspectors were informed that Coating Inspectors are responsible for the following tests:NEB Inspectors noted that:NEB Inspectors were informed that: 
WM1 Canal HDD Site
Latitude 51.37174 oN and Longitude 107.07955 oW
At 4:00 pm, NEB Inspectors arrived at the site of the MW1 Canal HDD crossing. NEB Inspectors noted that: 
Meeting with the Quality Coordinator
Latitude 51.49112 oN and Longitude 106.99386 oW
At 5:30pm, NEB Inspectors met with the SA Energy’s Quality Coordinator at the SA Energy’s Yard. The Quality Coordinator provided qualification records for a randomly selected welder. The records provided to NEB Inspectors demonstrated that the selected welder is qualified to perform the welding procedures that he is assigned to in the field. The Quality Coordinator provided qualification records for the coating technicians. The records provided to NEB Inspectors demonstrated that the coating applicators were designated by NACE as well as by the coating manufacturer. The binders prepared and maintained by the Quality Coordinator were well organized and complete.
 

Compliance tool used: No compliance tool used

Observation 4 - Observations on Procedure Qualification Records Review

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

During this integrity focused inspection, NEB Inspectors were given copies of the Procedure Qualification Records (PQR) for the eight welding procedures used on Spread 3 of Line 3’s mainline construction. (Note: scope of this inspection was limited to Spread 3). 

After the inspection, NEB Inspectors reviewed the PQR and identified some issues. These issues are addressed through IR No.1 to 8 below.

Furthermore, NEB Inspectors observed that the Certificate of Testing (Tensile) and Mill Certificate (Chemistry) for pipe are not included in the following PQR:

  1. For ENB-A-WPS-54 Rev.2:
    1. CRC-L3R-36-11.8-3
    2. CRC-L3R-36-11.8-4-BW-1
    3. CRC-L3R-36-11.8-1
  2. For ENB-A-WPS-56 Rev.2:
    1. CRC-L3R-15.1-2-1
    2. CRC-L3R-15.1-3-1
    3. CRC-L3R-36-15.1-4-BW-2
  3. For ENB-A-WPS-58 Rev.2:
    1. CRC-L3R-36-19.1-1
    2. CRC-L3R-36-19.1-2-1
    3. CRC-L3R-36-19.1-3
    4. CRC-L3R-36-19.1-4-BW-2
NEB Inspectors realize that for these abovementioned PQR, the missing certificates can be found in other PQR (that is, same pipe was used to qualify different welds). NEB Inspectors would like to remind Enbridge that each PQR should be complete in itself and have all of its relevant information in one package. It is not acceptable for readers to have to consult documentation associated with another PQR to obtain information on a given PQR. 

Furthermore, NEB Inspectors would like to note that its review of the PQR was not exhaustive and additional issues may be part of the PQR currently being used by Enbridge on this project. In order to avoid any future non-compliances, NEB Inspectors recommend that Enbridge perform a quality assurance and quality control review of all the documentation associated with its Joining Program for Line 3 (that is, WPDS, WPS and PQR) to verify that all included information is accurate, valid and complete.
 

Compliance tool used: No compliance tool used

Observation 5 - IR No. 1 – Superseded Edition of CSA Z245.1 in WPDS

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

During the inspection, NEB Inspectors noted that in five of the WPDS, the edition of the CSA Z245.1 pipe manufacturing standard was not mentioned and for the following three WPDS, a superseded edition of CSA Z245.1 was referenced (i.e. 2007):
  1. L3R-WPDS-1 Rev 2
  2. L3R-WPDS-2 Rev 2
  3. L3R-WPDS-3 Rev 2
At the time, the Senior Welding Specialist explained that the 2007 entry was a typographical error and should be removed from the three WPDS listed above. NEB Inspectors note that since the latest published edition of CSA Z245.1 (that is, 2014) is included in the PQR associated with ENB-A-WPS-54 Rev.2, ENB-A-WPS-56 Rev.2 and ENB-A-WPS-58 Rev. 2, more specifically in the Mill Test Certificates, it is acceptable for Enbridge to remove the superseded edition of 2007 from L3R-WPDS-1 Rev 2, L3R-WPDS-2 Rev 2 and L3R-WPDS-3 Rev 2.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

File with the Board the updated versions of the following three WPDS: L3R-WPDS-1, L3R-WPDS-2 and L3R-WPDS-3.
 

Due date: 2017-11-13

Date closed: 2017-11-20
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 6 - IR No. 2 – Missing UT Report

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The PQR: CRC-L3R-19.1-6-1 for WPS: ENB-A-WPS-58 Rev.2 does not include the Ultrasonic Testing (UT) Report for the weld.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide an explanation for not including the UT Report for the weld in PQR: CRC-L3R-19.1-6-1 of WPS: ENB-A-WPS-58 Rev.2. If the UT Report for the weld was omitted by mistake, Enbridge is requested to submit the complete PQR to NEB Inspectors.
 

Due date: 2017-11-13

Date closed: 2017-11-20
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 7 - IR No. 3 – Missing RT Reports

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:


The following PQR do not include a Radiography Testing (RT) Report for the weld:

  1. CRC-L3R-36-12.7-3-1 for WPS: ENB-A-WPS-54 Rev.2
  2. CRC-L3R-19.1-6-1 for WPS: ENB-A-WPS-58 Rev.2
  3. RMS-L3R-36-19.1-7-1-R2 (Upper & Lower Quadrants) for WPS: ENB-M-R2-WPS-01 Rev.0

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide an explanation for not including the RT Report for the weld in the following PQR:

  1. CRC-L3R-36-12.7-3-1 for WPS: ENB-A-WPS-54 Rev.2
  2. CRC-L3R-19.1-6-1 for WPS: ENB-A-WPS-58 Rev.2
  3. RMS-L3R-36-19.1-7-1-R2 (Upper & Lower Quadrants) for WPS: ENB-M-R2-WPS-01 Rev.0
If the RT Reports for the weld were omitted by mistake, Enbridge is requested to submit the complete PQR to NEB Inspectors.
 

Due date: 2017-11-13

Date closed: 2017-11-20
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 8 - IR No. 4 – Superseded edition of CSA Z662 in UT Report

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

A superseded edition of CSA Z662 is featured in the UT Report in the PQR: EPI-11-WP-10 for WPS: EPI-11-WP10-BW Rev.1.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Submit a revised copy of PQR: EPI-11-WP-10 for WPS: EPI-11-WP10-BW Rev.1 to NEB Inspectors or provide a confirmation that the acceptance criteria for CSA Z662 edition 2007 meet the requirements of CSA Z662 edition 2015.
 

Due date: 2017-11-13

Date closed: 2017-11-20
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 9 - IR No. 5 – Superseded edition of CSA Z662 in RT Report

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

A superseded edition of CSA Z662 is featured in the RT Report of the following PQR:

  1. CRC Weld I.D. 1142-40 for WPS: ENB-WPS-166 Rev. 0, the RT Report is dated 05/17/2017 and the inspection standard is listed as CSA Z662 edition 2011.
  2. CRC-1142-42 for WPS: ENB-WPS-170 Rev.1, the RT Report is dated 05/18/2017 and the inspection standard is listed as CSA Z662 edition 2011.
  3. CRC 1142-40 for WPS: ENB-WPS-174 Rev.0, the RT Report is dated 05/17/2017 and the inspection standard is listed as CSA Z662 edition 2011.
  4. EPI-11-WP-10 for WPS: EPI-11-WP10-BW Rev.1, the RT Report is dated 11/18/2011 and the inspection standard is listed as CSA Z662 edition 2007.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Submit revised copies of the following PQR to NEB Inspectors or provide a confirmation that the acceptance criteria for CSA Z662 edition 2007 and 2011 meet the requirements of CSA Z662 edition 2015:

  1. CRC Weld I.D. 1142-40 for WPS: ENB-WPS-166 Rev. 0
  2. CRC-1142-42 for WPS: ENB-WPS-170 Rev.1
  3. CRC 1142-40 for WPS: ENB-WPS-174 Rev.0
  4. EPI-11-WP-10 for WPS: EPI-11-WP10-BW Rev.1

Due date: 2017-11-13

Date closed: 2017-11-20
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 10 - IR No. 6 – Pipe used to qualify WPS EPI-11-WP10-BW

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

According to the Mill Test Certificates included in the PQR: EPI-11-WP-10 for WPS: EPI-11-WP10-BW Rev.1, the test was done on 2011/6/3. Furthermore, the edition of CSA Z245.1 is not included in the PQR’s Mill Test Certificate.

As a result, NEB Inspectors cannot confirm that the pipe used to qualify the WPS was manufactured to the pipe fabrication requirements of the latest edition of CSA Z245.1 (that is, 2014).
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Submit a revised copy of PQR: EPI-11-WP-10 for WPS: EPI-11-WP10-BW Rev.1 to NEB Inspectors or provide a confirmation that the pipe used to qualify the WPS: EPI-11-WP10-BW meets the requirements of the latest published edition of CSA Z245.1 (that is, 2014).
     
  2. Provide an explanation for not using the pipe manufactured for this project to qualify WPS: EPI-WP10-BW Rev.1.

Due date: 2017-11-13

Date closed: 2017-11-20
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 11 - IR No. 7 – Inconsistent Heat Numbers between Procedure Qualification Test Records (PQRT) and Test Certificates for Weld

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

For the following PQR, the heat numbers provided for the pipe on the PQRT (done by CRC-Evans) are not consistent with the heat numbers found in the Test Certificate for the weld (done by Element):

  1. For ENB-A-WPS-54 Rev.2:
    • CRC-L3R-36-12.7-1-1 (PQRT Heat No. = M17472 & 401685, Test Record Heat No. = M17472)
  2. For ENB-A-WPS-56 Rev.2:
    • CRC-L3R-36-15.1-1 (PQRT Heat No. = M17472 & RS1852, Test Record Heat No. = M17978 & RS1852)
    • CRC-L3R-36-15.1-2-1 (PQRT Heat No. = M17472 & RS1852, Test Record Heat No. = M17978 & RS1852)
    • CRC-L3R-15.1-3-1 (PQRT Heat No. = M17472 & RS1852, Test Record Heat No. = M17978 & RS1852)
    • CRC-L3R-36-15.1-4-BW-2 (PQRT Heat No. = M17472 & RS1852, Test Record Heat No. = M17978 & RS1852)
  3. For ENB-A-WPS-58 Rev.2:
    • CRC-L3R-36-19.1-1 (PQR Heat No. = M17709 & M17713, Test Record Heat No. = M17713)
    • CRC-L3R-36-19.1-2-1 (PQR Heat No. = M17709 & M17713, Test Record Heat No. = M17713)
As a result, NEB Inspectors cannot verify the properties of the weld used to qualify the WPS.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Submit revised copies of the following PQR to NEB Inspectors or provide an explanation for these discrepancies:

  1. For ENB-A-WPS-54 Rev.2:
    • CRC-L3R-36-12.7-1-1
  2. For ENB-A-WPS-56 Rev.2:
    • CRC-L3R-36-15.1-1
    • CRC-L3R-36-15.1-2-1
    • CRC-L3R-15.1-3-1
    • CRC-L3R-36-15.1-4-BW-2
  3. For ENB-A-WPS-58 Rev.2:
    • CRC-L3R-36-19.1-1
    • CRC-L3R-36-19.1-2-1

Due date: 2017-11-13

Date closed: 2017-11-20
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 12 - IR No. 8 – Missing Heat Numbers in Mill Tests for Pipe

Date & time of visit: 2017-10-05 18:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

For the following PQR, the heat numbers provided for the pipe are not found in the provided Mill Certificates (done by Evraz):

  1. For ENB-A-WPS-54 Rev.2:
    • CRC-L3R-36-11.8-5-2 (Heat Number = M17860)
  2. For ENB-A-WPS-56 Rev.2:
    • CRC-L3R-36-15.1-1 (Heat Number = M17472 or M17978 whichever applies)
As a result, NEB Inspectors cannot verify the chemical and mechanical properties of the pipe used to qualify the WPS.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Submit revised copies of the following PQR to NEB Inspectors or provide an explanation for these discrepancies:

  1. For ENB-A-WPS-54 Rev.2:
    • CRC-L3R-36-11.8-5-2
  2. For ENB-A-WPS-56 Rev.2:
    • CRC-L3R-36-15.1-1

Due date: 2017-11-13

Date closed: 2017-11-20
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:

- 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