Compliance Verification Activity Report: CV1819-077 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1819-077
Start date: 2018-06-05
End date: 2018-06-06

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Safety inspection of the company terminals and pump stations to verify compliance to the NEB OPR, CSA Z662-15 and Canada Labour Code.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations - Westover Terminal

Date & time of visit: 2018-06-05 09:25

Discipline: Safety Management

Categories:

Facility:

Observations:

Number of employees permanently on site: 35 including a crew of 11 employees in operations and maintenance.
 
Enbridge said that it has developed a new FLHA based on “Energy Wheel” principles: 10 energy sources are taken into account to elaborate hazards controls.
 
Enbridge presented the overall tank layout and provided explanation on storm water drainage.
 
The following procedures were provided:
 
General Observations:
 
- Shelves were load rated and properly secured.
- Flammable products stored in flammable cabinets.
- Fire extinguishers, eye wash station and first aid kit verified were in apparent good condition and had their monthly inspection recorded. 
- Tools observed were in good conditions with guards when needed.
- Signage present for eye protection for grinder, drills and cutting tools. 
- Good house keeping.
- Proper signage at entrance with company name, emergency phone number, no smoking, hazards associated with products.
- Site has power back-up capable of operating the ESD systems and isolating the stations and terminal.
 
Electrical and Mechanical Shop:
Mezzanine with proper railing.
3 Ton crane with matching components. Log book in place for pre-use inspection records. Crane annual certification was provided.
 
PLM Building 
Staff asked where to find MSDS of the stored goods in the cabinet and Enbridge said they have an online information system which provide access to all MSDS.
3 Ton crane with matching components. Log book in place for pre-use inspection records.
Defibrillator and first aid kit located in the lunch room.
 
Electrical building 201-EB-2
High voltage warning signage on the door. 
Staff noticed that equipment appeared to be locked out properly. 
Clean building, nothing stored in front of the breaker panels.
 
Electrical switchgear 11-ESB1
Pump station ESD push buttons located at each side on the exterior the building. 
High voltage warning signage on the door. 
Clean building, nothing stored in front of the breaker panel.
Strobe lights inside and outside to warn of an imminent pump start and potential arc flash. 
Gas detection outside the building.
 
Pump units
Piping has arrows for direction of flow.
Guards on rotating parts.
Lock-out switches by the units.
 
Terminal control room building
The terminal ESD push button is located in the control room building.
 
Inspection of Storage Tank 224
Storage Tank 224 is currently out of service for 20 year API 653 inspection and refurbishment. A contractor is completing the work.
The tank is considered a confined space even when empty during maintenance work. Confined space entry training is required prior to entering the tank. The company has a small converted sea container being used as a trailer for the maintenance crew, equipped with plans, work permits, etc. While workers are not present, entry to the confined space is restricted by signage and a physical obstacle. While workers are present, entry to the confined space is restricted by the safety watch person. A log of the workers entering the tank is maintained. Two rescue workers are posted outside near the entrance of the tank and a ready to intervene. 
 
 
 

Compliance tool used: No compliance tool used

Observation 2 - CNC - Westover Terminal - Bolting of flange on Tank 224 line

Date & time of visit: 2018-06-05 12:21

Discipline: Integrity Management

Categories:

Facility:

Observations:

NEB inspectors noted that multiple bolts on a tank line flange outside Tank 224 did not have bolt threads protruding past the nuts. The company confirmed that the project was designed to meet CSA Z662 requirements. Several of the bolts did not have a minimum of 2 exposed threads beyond the face of the nut and this is a non-compliance to CSA Z662-15 clause 5.2.7.1.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company replaced the bolts to comply with CSA Z662-15 clause 5.2.7.1 prior to the completion of this report.

Due date: 2018-06-08

Date closed: 2018-06-08
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

There are no observations with outstanding follow-up

Observation 3 - General Observations - North Westover Pump Station

Date & time of visit: 2018-06-05 13:15

Discipline: Safety Management

Categories:

Facility:

Observations:

NEB Inspectors observed signs with the company name, emergency phone numbers, and non-smoking signs were posted at the site main entrance. The pump station is fenced with egress gates in addition to the main site access.
 
The pump building houses two pump units for Line 9. The pump building is equipped with gas detection. At 20% of the Lower Explosive Limit (LEL), an alarm is initiated and the building ventilation is started. At 40% LEL, the two pump units are shut-down, the ventilation is stopped and the station is isolated.  The pump building is also equipped with heat detectors for fire detection. If heat is detected, the two pump units are shut-down, the ventilation is stopped and the station is isolated.
 
There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves and the lighting during a power loss event.
 
The station is equipped with station ESD push buttons located at both ends of the Electrical Switchgear Building (ESB).
 
The ESB had warning signs for high voltage and strobe lights inside and outside to warn of an imminent pump start with a potential for arc flash.
 
Fire extinguishers, first aid kits, eye wash stations and bottles are inspected on a monthly basis.
 
NEB inspectors observed good housekeeping.
 
Station piping had arrows for direction of flow.
 
Valve vaults had confined space warning signs.

Compliance tool used: No compliance tool used

Observation 4 - General Observations - Hilton Pump Station

Date & time of visit: 2018-06-06 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

NEB Inspectors observed signs with the company name, emergency phone numbers, and non-smoking signs were posted at the site main entrance. The pump station is fenced with egress gates in addition to the main site access.
 
The pump building houses two pump units for Line 9. The pump building is equipped with gas detection. At 20% of the Lower Explosive Limit (LEL), an alarm is initiated and the building ventilation is started. At 40% LEL, the two pump units are shut-down, the ventilation is stopped and the station is isolated.  The pump building is also equipped with heat detectors for fire detection. If heat is detected, the two pump units are shut-down, the ventilation is stopped and the station is isolated.
 
There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves and the lighting during a power loss event.
 
The station is equipped with station ESD push buttons located at both ends of the ESB building.
 
The ESB building had warning signs for high voltage on exterior and strobe lights inside and outside to warn of an imminent pump start and potential arc flash.
 
Fire extinguishers, first aid kits, eye wash stations and bottles are inspected on a monthly basis.
 
NEB inspectors observed good housekeeping.
 
Station piping had arrows for direction of flow.
 
Valve vaults had confined space warning signs.
 

Compliance tool used: No compliance tool used

Observation 5 - CNC - Hilton Station - Pre-Inspections and Logbook for Cranes

Date & time of visit: 2018-06-06 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

The gantry in the pump building did not have a pre-use inspection logbook available.  Site staff also indicated that pre-use inspections were not conducted as a matter of practice.  This is inconsistent with the company procedure, which requires a pre-use visual inspection of cranes and ancillary equipment prior to each use and to maintain a logbook.  This a failure to implement the controls developed by the company for that safe use of the cranes and this is a non-compliance to the NEB OPR s. 6.5 (1)(f).

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Log book for documenting pre-use inspections was placed near gantry in the pump building.  Email was sent within the company to the appropriate staff to clarify need for log books and use of them for documenting pre-use inspections. The non-compliance was adressed prior to the completion of this report.

Due date: 2018-06-08

Date closed: 2018-06-08
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

Observation 6 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code