Compliance Verification Activity Report: CV1718-254 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 994
• Inspector 2773

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Management System
• Safety Management

Related events:

• CV1718-253
• CV1718-255
• CV1718-284
• CV1718-298

Rationale and scope:

Construction inspection of the Line 3 Replacement Program, Spread 4 from Aug 2017 to April 2018. Identify primary contractors for random sample. Focus on Contractor Management program, site-specific hazards identified in the Construction Safety Manuals, other high risk activities. Also include Craik and Bethune pump stations.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (4)

Facility details

Facilities:

• Line 3
• BETHUNE [ALBERTA CLIPPER]
• CRAIK [ALBERTA CLIPPER]

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)
• Pump station
• Station piping

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 Act (NEBA) 2016-06-19
• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies
• Plans And Procedures
• Project-specific Contractor/Project Safety Plan (CSP)
• Enbridge LP/MP Safety Manual Liquids Pipelines and Major Projects Spread 4
• Emergency Response Plan (ERP)
• Enbridge Orientation and Identified in LP/MP Safety Handbook for Contractor Personnel
• Project-specific Environmental Protection Plan (EPP)
• Pipeline Environmental Protection Plan for the Enbridge Inc. Line 3 Replacement Program
• Project-specific plan or procedure
• Canadian Mainline Project Enbridge and SA Energy Group Safety Accountability and Responsibility Plan
• Project-specific plan or procedure
• Enbridge Canadian Major Projects Safe Work Guidelines
• Project-specific plan or procedure
• Enbridge Where Do I Stand
• Project-specific plan or procedure
• SA Energy SSSP Spread 4
• Spill Response Plan (SRP)
• Enbridge Orientation Line 3 Replacement Program > Environmental Handbook for Contractor Personnel
• Project-specific plan or procedure
• Enbridge Life Takes Energy - Ground Disturbance Requirements

Regulatory instrument number(s):

• XO-E101-004-2016
• OC-063

Observations (no outstanding follow-up required)

Observation 1 - General Safety Observations November 28, 2017

Date & time of visit: 2017-11-28 08:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Occupational Medical Surveillance
• Fire Protection
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• General Lighting
• Training and Competency
• Training, Competency and Qualification

Facility:

• Line 3 (Pipeline)

Observations:

Document Review FLHA Done in Safety Trailer at SA Yard

• Enbridge provided documentation that demonstrated that Tailgate meeting were being reviewed by Enbridge safety personnel.  Hazard Assessment Cards, Tailgate along with the associated Permits was perused and appeared to be correct. Safe Work Permits are not issued until  the Permit issuer receives the daily tool box meeting pertaining to the specific permit request. All Daily Tool Box meetings are reviewed by Enbridge Safety personal, and findings are recorded on the the Field Inspectors daily report. Should a issue be noted on a tailbox meeting submittal, the Field Inspectors meet with the issuer to discuss the corrective measures.  Review of FLHA and corresponding Safe work Permits is a 100% review. 
• Emergency Response Plan (version 8) was reviewed and complete.

• NEB staff reviewed the satisfactory completed Cargo Management Hazard Assessment Card for Type 3 load removal (Pipe from pipe truck by excavator and deck hand.  Crew had the current ERP (Revision 8) available on site and presented NEB inspectors and Enbridge inspection staff.  Also presented for our review and prior to entering the workspace a satisfactory Hazard Assessment Card was also presented for inspection staff review.  All forms were complete and very legible and appeared to identify the associated hazard with the task.  Premay was the contractor performing the stringing activity.  ROW was very clean and no debris or garbage was visible in area inspected.
• A 450 DL excavator unit # FC41 with a deckhand was being used.  Deckhand attachment and excavator pre inspecting sheets were complete and NEB inspectors requested operator to demonstrate what he inspects on his pre inspecting for both the excavator and deckhand.  Operator appeared to be very knowledgeable and was very accommodating to NEB inspectors.  The operator discussed his satisfaction with the Brigade camera system, but did identify concerns he had with the proximity sensors being too sensitive and that they had been adjusted but were still alarming on a constant basis.  Enbridge said the system was new and positive feed back was encouraged and they would review and see what could be done to remedy the situation (false signals).  Operator confirmed it was his personal responsibility to inspect the fire extinguisher as part of his equipment check.  It was noted that although the fire extinguisher appeared to be satisfactory, and the monthly check had been done that the annual inspection tag was not present. This was identified as a non compliance as per Enbridge LP/MP Safety Manual section 4.16 Table 2 Maintenance Frequency.  This was rectified the same day and the extinguisher was replaced making this a Corrected Non-Compliance.

• Checked Field Level Risk Assessments and Safe Work Permits and confirmed that they were legible, complete and cross-referenced to each other. Crew provided ERP version 8 and discussed the site evacuation procedures and communication process. Workers were observed to be wearing required PPE, and equipment spotters were negotiating right of way traffic. Right of way was very clean and equipment placement was orderly. Daily pre-use Equipment check was completed by operator. Operator explained Mandril operation well on site. 
• While on site it was noticed that a leak had started at the hydraulic tank, operator immediately placed spill absorbent padding in the area of the spill and contacted the Environmental representative from SA Energy. Approximate spill less than 1 litre (report 71).

• Checked Field Level Risk Assessments and Safe Work Permits and confirmed that they were legible, complete and cross-referenced to each other. Crew provided ERP version 8 and discussed the site evacuation procedures and communication process. Workers were observed to be wearing required PPE, and equipment spotters were negotiating right of way traffic. Right of way was very clean and welding assembly sequence very uniform with continuous process flow. Inspector relationship between crew was very positive. Welding shacks had hydraulic lock-outs to disconnect crane when welders inside shack as a safety device.Shacks were ventilated with fans. Welders donned fulled respirators with supplied air. Grinder guards were in place and size of grinder wheels were properly mated with the grinder/speed. Tag lines were used when all shacks were moved to reduce and control swing. Double eye protection was being utilized and proper donning and doffing of welding shield was observed. Ultrasonic non-destructive testing of the welds was observed and operator had level 2 certification.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and

Company action required:

Enbridge shall have an annual inspection conducted on the fire extinguisher or replace and take out of service until it has been inspected for the annual inspection.

Due date: 2017-11-28

Date closed: 2017-11-28
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 - Direct Pipe Installation Safety Observation November 29th

Date & time of visit: 2017-11-29 08:36

Discipline: Management System

Categories:

• Checking and Corrective Actions
• Inspection, Measurement and Monitoring
• Investigating and Reporting Incidents
• Records Management
• Implementation
• Communication
• Documentation and Document Control
• Management of Change
• Operational Control - Normal Operations
• Operational Control - Upset or Abnormal Conditions
• Training, Competence and Evaluation
• Management Review
• Management Review
• Planning
• Goals, Objectives and Targets
• Hazard Identification, Risk Assessment and Control
• Legal Requirements
• Organizational Structure, Roles and Responsibilities
• Policy and Committment
• Leadership Accountability

Facility:

• Line 3 (Pipeline)

Observations:

Qu' Appelle River Crossing- Michel Direct Pipe

• Attended Michel's visitor/vendor site safely orientation, which covered ERP evacuation plan, medical facilities, muster points, first aiders, paramedic on site with medical treatment vehicle  and communications for site. Michel's project manager provided NEB representatives with a project overview of the direct pipe procedure through to the terminating point for the direct pipe install (i.e.. drill terminated at a 4 meter depth at exit point). 
• Michel's Tool Box, Field Level Risk Assessments and Safe Work Permits were checked and Safety Inspectors confirmed that they were legible, complete and that tool box and safe work permits cross-referenced to each other. Michel's project Inspector provided ERP and discussed the site evacuation and rescue team (confined space) procedures and communication process.
• Emergency Drill for rescue records were checked by Inspection Officers.
• Site was designated as a Star site # 4859. Paramedic appear to be very qualified and his narcotics were double locked as pre requirements. Paramedic records and certificates were confirmed to be valid. Confined space entry certificates were available and on site for crew. Discussions pertaining to pre training requirements and on site rescue training were discussed and deemed appropriate.
• Workers were observed to be wearing required PPE, and equipment spotters were negotiating right of way traffic.  Proper ladder placement, caps on anchor posted were utilized, spill trays being used, snow fence and signage around excavation site was also observed. 
• Safety Data Sheets and appropriate PPE was available for the products being utilized was on site.  Despite the muddy conditions, the site was viewed to be very clean and orderly.  Equipment layout was satisfactory and site was not congested.  Wind socks were present and crew, especially project manager, HSE manager, site safety and medic were very knowledgeable, cooperative and enthusiastic about the operation.  Senior staff on site was questioned by NEB staff how things could go wrong and how they would adapt contingency plans to address.  Personnel were prepared and knowledgeable as to how contingency plans how they would be implemented.
• Worker safety observation cards are completed by all workers (i.e.. including contractors) and all are reviewed by HSE management. This data is then input in a safety management database which enables trending of safety metrics creating a management output of leading and lagging indicators. Michel's safety team uses this information to communicate project safety areas that safety results are high and areas that require improvements at tool box safety meetings and reports up to management. Michel's demonstrated this Key Point Indicator process which they are very proud of as it enables them to measure and communicate specific safety progress areas. 

Compliance tool used: No compliance tool used

Observation 3 - Bethune Pump Station- Line 3 Safety Observation November 29th

Date & time of visit: 2017-11-29 11:20

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Occupational Medical Surveillance
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• General Lighting
• Task Lighting
• Noise Control
• Enclosures
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• Line 3 (Pipeline)

Observations:

• Bethune Pump Station - Line 3 opening meeting conducted by  NEB representatives
• NEB staff signed on to visitor sign-in sheet
• Enbridge Senior Safety Coordinator- Major Projects and On-site Senior inspector provided Site Specific Orientation, Job Hazard Analysis, Field Level Risk Assessment (FLHA), Review of Enbridge's 6 Life Saving Rules, Emergency Response Plan for site, and Muster points. All attendee's of presentation signed off on Site Specific Orientation topics reviewed acknowledgement form
• Site was secured and main gate locked. Inspection team was met by Enbridge personnel and escorted to the construction office for Site Orientation
• Construction activities at time of inspection were, material handling, rebarring-piles and forms, welding, scaffolding for tarping and earthwork/excavation.
• Enbridge Major Projects Safety Information Board contained the following posted documents: Work Authorization Form, Environmental Hazard Assessment, Safe Work Permits, Ground Disturbance Permits, Man Counts, List of First Aiders, and ERP
• Randomly selected and checked completed Hazard Analysis Review safety documentation and verified that Foreman/Management checked and signed-off on forms.  FLHA and Safe Work Permits were also posted and cross reference. 
• Personnel on site and sign-in sheet was posted.
• Contractor tool storage shed (Sea Can) was inspected and contained various equipment including cables and slings that were all satisfactory.
• Secondary containment was in place for small jerry cans of fuel and lighting equipment generators
•  Spill kits and 20 lb fire extinguishers were on equipment, jersey barriers and control zones had been established to protect work areas from vehicle traffic.
• Parked heavy equipment, generators  etc were placed in spill trays to eliminate spillage.
• Checked equipment on site, skid-steer, excavators, welding trucks, and side boom.
• Equipment Operator was very accommodating in explaining his job and documentation that he had completed (FLHA/Daily Equipment check)
• All equipment checked had 20lb ABC Fire Extinguishers, First Aid and Spill Kits
• Automated External Defibrillator (AED's) were in all Supervisor and Safety Representative trucks
• Yard was clean and house cleaning in temporary construction trailers on site was good
• Evacuation sign and mapping was posted in site trailer and lunch room, First Aider list posted on bulletin board
• Smoking area was designated on site, with both cigarette containment and an  ABC 20lb Fire Extinguisher
• Portable light generators were grounded
• Pile caps were installed, ladders tied off.
• ERP plans revision 2 were observed to be readily available on dash or under visor of vehicles for immediate reference in the event of an emergency.
• Daily equipment checks were verified to have been conducted and were with the vehicles checked.
• Checked FLHA cards for workers (they were presented without request by workers).  Reviewed and signed on. 
• All excavators (material handling) equipment checked had the Brigade Surveillance System installed, which included both rear and side sensors with cameras
• Mini excavator operator had his Ground disturbance level II certification that was current till 2020.
•  On the mini excavator 60D unit # 68306 and a skid steer 328D unit 68311 it was noted that although the fire extinguishers appeared to be satisfactory, and the monthly checks had been done that the annual inspection tags were not present. This was identified as a non compliance as per Enbridge LP/MP Safety Manual section 4.16 Table 2 Maintenance Frequency.  This was rectified the same day and the extinguisher was replaced making this a Corrected Non-Compliance.
• On two contractor scaffolding trucks, and in one Seacan it was also noted that the annual inspection tags was not present.  This was identified as a non compliance as per Enbridge LP/MP Safety Manual section 4.16 Table 2 Maintenance Frequency.  This was rectified the same day and the extinguisher was replaced making this a Corrected Non-Compliance.
• In one seacan it was also noted the the weight tag on a sling was not legible and was removed for service.  Strap was not in service therefore no further action was taken.  In this seacan, tools storage was very organized and flammable cabinet was properly vented to the outside. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and

Company action required:

Enbridge shall have an annual inspection conducted on the fire extinguisher or replace and take out of service until it has been inspected for the annual inspection.

Due date: 2017-11-29

Date closed: 2017-11-29
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 4 - Craik Pump Station- Line 3 Safety Observation November 29th

Date & time of visit: 2017-11-29 15:50

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Occupational Medical Surveillance
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• General Lighting
• Task Lighting
• Noise Control
• Enclosures
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• Line 3 (Pipeline)

Observations:

• Craik Pump Station- Line 3 opening meeting conducted by  NEB representatives
• NEB staff signed on to visitor sign-in sheet
• Enbridge Senior Safety Coordinator- Major Projects and On-site Senior inspector provided Site Specific Orientation, Job Hazard Analysis, Field Level Risk Assessment (FLHA), Review of Enbridge's 6 Life Saving Rules, Emergency Response Plan for site, and Muster points. All attendee's of presentation signed off on Site Specific Orientation topics reviewed acknowledgement form
• Site was secured and main gate locked. Inspection team was met by Enbridge personnel and escorted to the construction office for Site Orientation
• Construction activities at time of inspection were, material handling, rebarring-piles and forms, welding, scaffolding for tarping and earthwork/excavation.
• Enbridge Major Projects Safety Information Board contained the following posted documents: Work Authorization Form, Environmental Hazard Assessment, Safe Work Permits, Ground Disturbance Permits, Man Counts, List of First Aiders, and ERP
• Randomly selected and checked completed Hazard Analysis Review safety documentation and verified that Foreman/Management checked and signed-off on forms.  FLHA and Safe Work Permits were also posted and cross reference. 
• Personnel on site and sign-in sheet was posted.
• Contractor tool storage shed (Sea Can) was inspected and contained various equipment including cables and slings that were all satisfactory.
• In the carpenter's seacan it was noted that a screw driver had apparently been used as a chisel and the handle had been compromised.  This screw driver was removed from service. 
• Secondary containment was in place for small jerry cans of fuel and lighting equipment generators
•  Spill kits and 20 lb fire extinguishers were on equipment, jersey barriers and control zones had been established to protect work areas from vehicle traffic.
• Parked heavy equipment, generators etc were placed in spill trays to eliminate spillage.
• Checked equipment on site, skid-steer, excavators, welding trucks, and side boom.
• Equipment Operator was very accommodating in explaining his job and documentation that he had completed (FLHA/Daily Equipment check)
• All equipment checked had 20lb ABC Fire Extinguishers, First Aid and Spill Kits
• Automated External Defibrillator (AED's) were in all Supervisor and Safety Representative trucks
• Yard was clean and house cleaning in temporary construction trailers on site was good
• Evacuation sign and mapping was posted in site trailer and lunch room, First Aider list posted on bulletin board
• Smoking area was designated on site, with both cigarette containment and an  ABC 20lb Fire Extinguisher
• Pile caps were installed, ladders tied off.
• Tamper operator was wearing hearing protection.
• ERP plans revision 8 were observed to be readily available on dash or under visor of vehicles for immediate reference in the event of an emergency.
• Daily equipment checks were verified to have been conducted and were with the vehicles checked.
• Checked FLHA cards for workers (they were presented without request by workers).  Reviewed and signed on. 
• All excavators (material handling) equipment checked had the Brigade Surveillance System installed, which included both rear and side sensors with cameras
• On the site there were six frost heaters connected to an electrical power supply.  It was suggested by NEB inspectors that they could use cord management and group cables together to reduce the tripping hazard.
• At excavation ditch multiple frost fighter heaters were observed at the ditch edge.  One had wheels chocked and it was mentioned that all heaters should have wheels chocked.  This was corrected immediately. 
• On a fuel storage tank skid the grounding rod was loose, the grounding was not satisfactorily installed.  This deficiency  was corrected immediately (wiring and grounding rod were loose), This grounding issue was also observed on a generator and was immediately corrected as the connection and ground rod was loose.  This was identified as a non compliance as per Enbridge LP/MP Safety Manual section 4.13 Bonding and Grounding . This was rectified the same day and the appropiate grounding was installed making this a Corrected Non-Compliance.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and

Company action required:

Enbridge shall have an annual inspection conducted on the fire extinguishers or replace and take out of service until it has been inspected for the annual inspection. 
Enbridge shall properly ground the fuel storage and generator prior to next use and verify to the NEB inspectors that this had been done. 

Due date: 2017-11-30

Date closed: 2017-11-30
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 5 - Bethune pipe yard, Coating and Lowering-in Safety Observation November 30th

Date & time of visit: 2017-11-30 10:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Occupational Medical Surveillance
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Signage
• Lighting
• General Lighting
• Task Lighting
• Noise Control
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• Line 3 (Pipeline)

Observations:

Bethune Stock Pile Yard 50.58300000, -105.18333000

• Yard is being decommissioned.
• Remaining pipe in yard both ends are chocked preventing pipe roll.
• Bulk diesel storage site was being planned to be removed, but site was still inspected. 
• Skill site was not accessible due to being locked.
• Straps securing tank to skid were worn but where changed out the same day prior to removal from site.
• At the hose refuel site, it was noted that there was a fuel spill that had not been cleaned up.  It was determined that the environmental unit was aware, but there was some question as to whether it was a spill initially reported.  Once this was identified, the spill was cleaned up and a spill report was submitted (Approximately 3-4 liters SA Energy Spill report report # 73 SW 7-19-23 W 2).  This was deemed by the inspectors to be a Corrected Non Compliance.

• Checked Field Level Risk Assessments and Safe Work Permit and confirmed that they were legible, complete and cross-referenced to each other. Crew provided ERP version 8 and discussed the site evacuation procedures and communication process. Workers were observed to be wearing required PPE, and equipment spotters were negotiating right of way traffic. Right of way was very clean and equipment placement was orderly. Daily pre-use Equipment check was completed by operator.
• Inspected the coating pump house, SDS where available, Appropriate PPE was being used and sufficient eye wash was on site to provide 15 minute flush.
• Foreman explained preparations for coating and curing operation.
• Hearing protection and ambient air supplied system and air intake was located on the up wind side away from contaminants.
• Glass enviro grit was being used for sand blasting (Inert).
• Acetone solvent wash wipe was being used to remove possible oil contaminants from the pipe.
• Heat pencil was being used to ensure proper pipe heat was being maintained for bot prior and post coating.
• Induction coil  heating of the pipe was being used for coating , and torch heating was being used to maintain heat separation prior to coating.

• Checked Field Level Risk Assessments and Safe Work Permit and confirmed that they were legible, complete and cross-referenced to each other. Crew provided ERP version 8 and discussed the site evacuation procedures and communication process. Workers were observed to be wearing required PPE, and equipment spotters were negotiating right of way traffic. Right of way was very clean and equipment placement was orderly. Daily pre-use Equipment check was completed by operator.
• Observed excavators with long sticks performing the crumbing operation (removing fallen rocks from ditch prior to pipe install).
• Inspector explained the laying-in of pipe in ditch and showed inspectors the engineering lift plan.
• Observed Holliday detection being done prior to pipe being lowered in ditch.
• Observed four cradle tractors and one catch off tractor required for a smooth pipe install.
• Skid Hustler (Caterpillar) followed immediately after the first cradle tractor to remove skids as the pipe was being laid in ditch.
• Operation went very smooth and pipe was installed very gently into ditch.
• Construction staff were very accommodating and open to discussion.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• OC-063

Relevant section(s):

• Environmental protection Enbridge shall implement or cause to be implemented all of the policies, practices, programs, mitigation measures, recommendations, procedures and its commitments for the protection of the environment included in or referred to in its Application or in it's related submissions.

Company action required:

Enbridge shall submit an environmental report, clean up the spill and supply evidence to the inspectors that this has been completed.

Due date: 2017-11-30

Date closed: 2017-11-30
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: