Compliance Verification Activity Report: CV1718-252 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1137
• Inspector 2773

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta
• Saskatchewan

Discipline(s):

• Safety Management

Related events:

• CV1718-242
• CV1718-284

Rationale and scope:

Planned construction inspection of the Line 3 Replacement Program, specifically, Spread 1. Focus on Contractor Management program, assess compliance with the NEB Onshore Pipeline regulations, site-specific hazards identified in the Construction Safety Manuals, pipe-handling, and any potential high risk activities. Include two pump stations, Metiskow and Cactus Lake.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (2)

Facility details

Facilities:

• METISKOW [Line 4]
• CACTUS LAKE [Line 1]
• Line 3

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 Processing Plant Regulations (PPR)
• 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 1
• Emergency Response Plan (ERP)
• Enbridge Orientation and identified in LP/MP Safety Handbook for Contractor Personnel
• Project-specific plan or procedure
• Canadian Mainline Projects Enbridge & 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
• OJ Pipelines SSSP R02 L3R mainline construction Spread 1 manual
• 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
• Project-specific Environmental Protection Plan (EPP)
• Pipeline Environmental Protection Plan for the Enbridge Pipelines Inc. Line 3 Replacement Program

Regulatory instrument number(s):

• OC-063
• XO-E101-004-2016

Observations (no outstanding follow-up required)

Observation 1 - Metiskow Pump Station

Date & time of visit: 2017-10-03 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
• 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:

• METISKOW [Line 4] (Facility)

Observations:

Tuesday, October 3rd Enbridge Line 3RP (S.E. 1/4 1 40 5 W4M)

• Metiskow Pump Station 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 (FLRA), 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 hydro-vac, material handling, rebarring-piles and forms, and earthwork/excavation
• Enbridge Positive air shut off (PASO) procedure was reviewed, continuous air monitoring is required on ALL diesel equipment until "PASO" procedure is implemented Company wide on December 31st, 2017
• 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
• Contractor tool storage shed (Sea Can) was inspected and contained various equipment including cables and slings that were all satisfactory
• Buggy Whips are required on all vehicles on site
• 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
• Checked equpment on site, Zoom-boom, skid-steer, 2 Excavators, and a Vac-Truck
• Equipment Operator was very accommodating in explaining his job and documentation that he had completed (FLRA/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 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
• All excavators (material handling) equipment checked had the Brigade Surveillance System installed, which included both rear and side sensors with cameras

Compliance tool used: No compliance tool used

Observation 2 - Cactus Lake Pump Station

Date & time of visit: 2017-10-03 15:45

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
• Noise Control
• Enclosures
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• CACTUS LAKE [Line 1] (Facility)

Observations:

Tuesday, October 3rd Enbridge Line 3RP (Lat. 52.1410 Long. -109.8133  K.P. 180.13)

• Cactus Lake Pump Station 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 (FLRA), Review of Enbridge's Six (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
• Inspection team was met by Enbridge personnel and escorted to the construction office trailer for Site Orientation
• Activity at pump station consisted of piling, pumping, material handling, and excavation
• Observed Operator on Roterra equipment inserting screw piles, the operator demonstrated precision in aligning and placing of the screw piles
• Randomly selected and checked completed Chemco sub-contractor Hazard Analysis Review Task (HART) safety cards and verified that Foreman/Management check and sign-off on cards 
• Enbridge Positive air shut off (PASO) procedure was reviewed, continuous air monitoring is required on ALL diesel equipment until "PASO" procedure is implemented Company wide on December 31st, 2017
• 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
• Contractor tool storage shed (Sea Can) was inspected and contained various equipment including cables and slings that were all satisfactory
• Buggy Whips are required on all vehicles on site
• 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
• Checked Volvo Loader- L90G equipment on site and Operators maintenance daily equipment check list
• Equipment Operator was very accomodating in explaining his job and documentation that he had completed (HART/FLRA/Daily Equipment check)
• Danger and Caution zones were marked off with either red or yellow tape, and complimented with High-vis- Cones
• All equipment checked had 20lb ABC Fire Extinguisher, First Aid and Spill Kits on Board
• Automated External Defibrillator (AED's) were in all Supervisor and Safety Representative trucks
• Emergency Response Plan posted in Office trailer and lunch room.
• First Aider list posted on door of both fridges in lunch room (Class 2 First Aid kit in lunch room)
• Yard was clean and house cleaning in temporary construction trailers on site was good
• Smoking area was designated on site, with both cigarette containment and an  ABC 20lb Fire Extinguisher
• Portable light generators were grounded
• All equipment checked had the Brigade Surveillance System installed

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

Observation 3 - Provost Stock Pile- Pipe Line Yard

Date & time of visit: 2017-10-05 08:05

Discipline: Safety Management

Categories:

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

Facility:

• Line 3 (Pipeline)

Observations:

O.J. Pipelines Provost Pipeline Stock Yard

• Upon entering the site, NEB Inspectors completed FLHA, Tailgate Meeting, and reviewed Cargo Management Hazard Assessment
• Reviewed Job Hazard Assessment for pipeline yard
•  A Hitachi 470 LC excavator equipped with a Deckhand was inspected, NEB Inspector reviewed daily equipment check, first aid and spill kit, and fire extinguisher. No discrepancies were noted
• Observed 36 inch - 22 metre lengths of steel pipe being off loaded from truck hauling trailer and lowered onto skids at ground level. The Deckhand equipment "pipe arms" used to position pipe were not released from pipe until chocks had been placed on each side of pipe, preventing pipe from moving
• Operator was very cooperative in offering to present to NEB inspectors a completed daily equipment check list and explained operation of the computerized deckhand program for operating the  pipe arms (safety systems are built in to prevent unplanned release of a pipe joint)
• Confirmed that Klondike crane is inspected yearly, next inspection date is August 28, 2018
• Checked daily log book for crane and equipment maintenance records (i.e. ratchet belts), log book were up to date
• Inspected camera mounted on stick Deckhand attachment (back of pipe arms), and observed functionality to be working

Compliance tool used: No compliance tool used

Observation 4 - Lowering 36" Pipe and Coating "Jeeping"

Date & time of visit: 2017-10-04 09:55

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
• Noise Control
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• Line 3 (Pipeline)

Observations:

Construction Chainage> 10+229.5 Lowering Pipe

• Electrical Line Marker goal posts were in place to identify safe clearance to the 14.4 kv powerline
• O.J. Pipelines Coating Inspector was on-site, Job Hazard Analysis and Task Analysis Safety Card was presented for review and signing, and NEB staff reviewed the Safe Work Permit issued by Enbridge
• Pipe was observed to be whitewashed as pipe had been stored for approximately two years and whitewashing protected the coating from UV rays
• Daily excavation check list at every Bell Hole
• Ladders were tied off "secured"
• Side boom unit number D8T Cat, was inspected and equipment check was verified
• Physically inspected D8T- #KPZ03508 and three 2017 John Deer- with Brandt Side Boom attachment R11-143 the Brigade system (front and side-mounted cameras and proximity warning device), first aid kit, fire extinguisher, FLHA, equipment check and all was satisfactory. Operators were complimentary of the Brigade System
• Warning Danger signs were placed on all equipment to identify the 6 Metre> Stay Clear Message
• Coating and Jeeping crew were wearing the appropriate PPE
• Jeeping Crew grounded Pipe to enable proceeding with using the 2.2kv DC Holiday Detector to detect coating deficiencies
• Observed Spill trays under portable electric generators
• Enbridge Inspector was on-site as well as the Foreman. Both had a copy of the ERP
• Good Signage was posted at ditch ends with temporary snow fencing in place as a barricade
• Porta-Toilets were clean, and secured via guy wires to prevent the wind from blowing them over

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

Observation 5 - 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

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