ARCHIVED - Letter and Order SO-E101-004-2013 to Enbridge Pipelines Inc.
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File OF-Surv-Inc-2012 04
3 June 2013
Mr. Stephen Wuori
President, Liquids Pipelines and Major Projects
Enbridge Pipelines Inc.
3000 Fifth Avenue Place
425 - 1st Street S.W.
Calgary, AB T2P 3L8
Dear Mr. Wuori:
Enbridge Pipelines Inc. (Enbridge) - Line 2 Overpressure Incidents at the Edmonton Terminal
On 7 January 2012 and 13 March 2012, in accordance with Section 52 of the Onshore Pipeline Regulations Enbridge reported two overpressure incidents which had occurred at its Edmonton Terminal. Enbridge reported that the incidents resulted in an over-pressurization of 115.6% of maximum operating pressure (MOP) and 120.7% of MOP, respectively, on the low-pressure-rated piping feeding into the suction of the mainline pumps.
The National Energy Board (NEB or the Board) notes that Enbridge has undertaken certain site-specific measures to deal with the reported overpressure incidents. However, based on the Board’s investigation of the two incidents referenced above, the Board remains concerned these overpressure issues represent potentially systemic non-compliances on other parts of the Enbridge pipeline system.
Enbridge is reminded that the Board issued safety advisory SA-2012-01 out of its concern with the recurrence of overpressure incidents on Board-regulated pipelines and related facilities. SA 2012-01 provides certain preventative actions and requires companies to consider overpressure incidents to be hazards that may lead to subsequent integrity issues.
The Board expects that integrated and effective management systems be implemented to proactively identify potential issues such as overpressure conditions and prevent similar incidents from occurring in the future. The Board also expects Enbridge to implement prompt corrective actions where required.
The Board has issued the attached Order SO-E101-004-2013 which requires Enbridge to submit:
- The timeline and prioritization rationale for the transient conditions assessment;
- Anticipated timeline for final mitigation plan; and
- Semi-annual status reports on its transient conditions assessment and associated mitigation plan.
Enbridge shall file, for Board approval, by 31 July 2013, the timeline and prioritization rationale for the transient conditions assessment and associated mitigation plan to be completed for all of its NEB-regulated pipeline systems (including terminals).
Enbridge has been ordered to file with the Board regular status reports on their progress. The first status report is to be submitted to the Board by 31 July 2013 and must provide an update on what has been done to date. Subsequent status reports shall be submitted every six months, until the Board is satisfied this issue has been appropriately addressed.
Secretary of the Board
c.c. Mr. Matthew Thompson, Canadian Pipeline Compliance, Enbridge Pipelines Inc. Facsimile 780-420-8177
IN THE MATTER OF the National Energy Board Act (the Act) and the regulations made thereunder; and
IN THE MATTER OF the 7 January 2012 and 13 March 2012 overpressure incidents at the Edmonton Terminal reported by Enbridge Pipelines Inc. (Enbridge) pursuant to Section 52 of the Onshore Pipeline Regulations, 1999 under Files OF-Surv-Inc-2012 04 and OF-Surv-Inc-2012 44.
BEFORE the National Energy Board (NEB or Board) on 23 May 2013.
WHEREAS the Board regulates the operation of Enbridge’s Line 2 piping systems at the Edmonton Terminal;
AND WHEREAS Enbridge has reported two overpressure incidents at the Edmonton Terminal dated 7 January 2012 and 13 March 2012;
AND WHEREAS the Board issued safety advisory SA-2012-01 related to overpressure incidents in April 2012;
AND WHEREAS Enbridge has determined that the root cause of the over-pressurization was inadequate engineering;
AND WHEREAS the Board has become aware that in certain cases Enbridge did not know the pressure rating of components in its system and Enbridge’s overpressure protection system capabilities under all possible operating scenarios;
AND WHEREAS Enbridge has implemented certain short-term and permanent measures to mitigate the reported overpressure incidents of 7 January 2012 and 13 March 2012;
AND WHEREAS Enbridge has initiated a transient conditions assessment and associated mitigation plan of the potential overpressure impact to all of its NEB-regulated pipeline systems (including terminals);
AND WHEREAS the Board has considered Enbridge’s current transient conditions assessment and mitigation plan to date;
AND WHEREAS the Board is of the view that interim precautionary measures are necessary for public safety and protection of the environment;
Pursuant to section 13 and subsection 48(1.1) of the Act, the Board hereby orders the following:
Enbridge shall file, for Board approval, by 31 July 2013, the timeline and prioritization rationale for the transient conditions assessment and associated mitigation plan to be completed for all its NEB-regulated pipeline systems.
Enbridge shall file with the Board on a semi-annual basis, an up-to-date status report which shall include the transient conditions assessment of and associated mitigation plan for the potential overpressure impact to all its NEB-regulated pipeline systems. Each status report shall:
- Include progress on the timelines for completing this assessment and any corrective actions required at each of its NEB-regulated pipeline systems;
- Be submitted to the Board until such time as the transient conditions assessment has been conducted on all of Enbridge’s NEB-regulated pipeline systems and the mitigative actions have been implemented;
- Include a Quality Assurance / Quality Control review of piping system design and material specifications, the process flow path and associated hydraulic pressure profile of its product, and equipment specifications (including pressure rating); and
- Include confirmation as to whether the records of the piping and components utilized in Enbridge’s NEB-regulated pipeline systems are up to date.
The first status report shall be submitted to the Board by 31 July 2013 and provide an update of what has been done to date. Subsequent status reports shall be filed every six months thereafter, until the Board directs otherwise.
NATIONAL ENERGY BOARD
Secretary of the Board
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