Proceedings of the 2012 9th International Pipeline Conference IPC2012 September 24-28, 2012, Calgary, Alberta, Canada

IPC2012-90730

THE EVOLUTION OF FACILITIES INTEGRITY MANAGEMENT AT ENBRIDGE PIPELINES INC.

Monique Berg Enbridge Pipelines Inc. P.O.Box 398 Edmonton, Alberta, T5J 2J9 CANADA Shadie S. Radmard Enbridge Pipelines Inc. P.O.Box 398 Edmonton, Alberta, T5J 2J9 CANADA

ABSTRACT Public and employee safety, environmental stewardship, increased focus by the regulators, public awareness are some of the reasons why operators need to focus on the integrity of their operations and create solutions to reduce common types of releases. In the past, the focus has been on mainline piping integrity due to the greater consequence of mainline releases but increasing importance is being placed on facilities, such as tank terminals and pump stations. Facilities Integrity Management of a pipeline system is a relatively new concept for many companies; however, it is gaining momentum, particularly with regulators and the public. Prior to 2004, various Enbridge departments were responsible for ensuring integrity was maintained within facilities. There was a renewed emphasis and on Enbridges Facilities Integrity Programs in 2004 with a mandate of reducing facility releases across the Enbridge Pipeline system. In 2005, a small team of engineers drafted a six-page Facilities Integrity Management System document and program documentation to address facilities integrity issues. Today, Facilities Integrity is responsible for more facilities and programs than originally envisioned. The Integrity Management System documentation has since been amended several times and reviewed through internal and external audits. The Facilities Integrity Management System is vital to the success of the various facilities integrity programs as it identifies responsibilities and associated overlaps and gaps as well as the need for documentation and tracking. As there are no set regulations specific to Facilities Integrity, Enbridge has taken the initiative to be at the forefront of industry practice.

This paper will describe Enbridges Facilities Integrity Management System: past and present Facilities Integrity programs, current scope of work, the role of Facilities Integrity, the importance of historical release information and program trending, and future initiatives. INTRODUCTION Over 90% of all Enbridge releases occur at pipeline facilities. Some challenges for Operators are the number of potential release sources, the relatively small size and impact of the releases, and potential difficulties in detection. Although the impacts of a facility release might not be as great as those of a mainline release, such impacts must still be taken into account as they impact: 1. People: a facility release has the potential of injuring workers in that facility, or even the public if the release migrates off-site. Environment: a facility release has the potential of negatively affecting soils, vegetation, wildlife and water. Process: A facility release has the potential of causing a line shutdown, or equipment shut-down resulting in a loss of production and negatively affects the customer. Public Perception: an increase in facility releases, negatively impacts public perception regarding the safety and reliability of pipelines. This results in the public not wanting to support future pipeline projects and negatively impacts the pipeline industry. Economy: costs incurred by loss of production, piping or equipment repair, site remediation and regulatory fines are some of the main economic impacts of a facility release.

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Long term release reduction programs allow Operators to manage integrity issues by identifying the source of the releases, potential impact of releases and determine resources and strategy for achieving and maintaining long term release reduction [1]. Trends have shown that regulators are demanding greater responsibility through increasing fines and actions for Operators to address facility related releases, in an industry where the focus has been on large impact mainline releases. For this reason, system management of facilities integrity is gaining momentum. In 2004, a focus on Facilities Integrity was renewed, with a mandate of reducing facility releases across the Enbridge Pipeline system. Today, Enbridge has taken the initiative and expanded its Facilities Integrity (FI) Management Program to include more integrity programs and an Integrity Management System (IMS) for documenting and tracking vital program information information that, in the past, has been more readily available for the mainline system with its defined regulations. NOMENCLATURE FI Facilities Integrity HCA High Consequence Area IMS Integrity Management System MOC Management of Change ENBRIDGE FACILIITIES INTEGRITY MANDATE The core goal of Facilities Integrity is to prevent leaks or ruptures within Enbridge facilities. This goal is driven by the corporate commitment to protect the general public, environment and health and safety of employees. Core objectives of Facilities Integrity are as follows: 1. The pipeline system, including facilities, will be safe and perceived to be safe. 2. Enbridge will strive to achieve zero failures. 3. The pipeline including facilities will be reliable with minimal customer impact. 4. The pipeline system including facilities will be maintained as a long-life asset. 5. Monitoring programs will define the type, location and extent of defects. 6. Life cycle management approaches will guide resource allocation. 7. Resources will be optimized to ensure efficiency. 8. Innovative technology will be used to enhance integrity. 9. Regulatory and Legal Requirements will be met. 10. Active participant in industry forums. 11. Continuous Improvement. In support of these core objectives, Enbridge sets yearly measurable objectives, as shown in Table 1.

Table 1: Enbridge Facilities Release Metrics Description Significant Impact Facilities Releases Limited Impact Facilities Releases Expectations No Significant Impact Release is Acceptable

Set Based on Yearly Improvement Statistical Weighted Average

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The role of Facilities Integrity is to meet the objectives listed in Table 1 by addressing fatigue, mechanical, cracking and/or corrosion related threats within Enbridge facilities through its inspection and repair programs. The programs have been established to address regulatory requirements and to ensure proper risk mitigation. These programs will be discussed in the following sections. ROLE OF INCIDENT REPORTING, INVESTIGATION AND INCIDENT MANAGEMENT SYSTEM All release incidents at Enbridge, regardless of volume or reportability are recorded in a central database called the Leak Reporting System. This database captures required regulatory information, as well as root cause analysis and corrective action plans for each release, as applicable. Although incident reporting is required at the regulatory level and is used to measure release objectives, it also plays a key role in the establishment of Facility Integrity Programs through trending of release data. Incident reporting was used to determine areas requiring specific facilities integrity focus. Chart 1 below shows that for years 2001 through to 2003, 64% of Enbridges overall releases were caused by Equipment Malfunction or Failure of Non-Pipe Component. The second leading release cause was corrosion -- at 11% of overall releases. This data was further analyzed to determine which equipment type was failing, and what types of programs could be put in place to address those known risk areas. Chart 2 shows 2001 2003 equipment issues. The following programs were formed, based on information from Charts 1 and 2: 1. 2. 3. Station Piping Program: corrosion accounted for 11% of overall releases Flange Program: flanges accounted for 20% of all equipment related releases (or 13% of all releases) Small Diameter Piping Program: Nipple Broken or cracked, Hose or Tubing Failure, Stripped threads,

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defective or loose fitting or tubing, failed coupling together accounted for 27% of equipment related releases (or 17% of all releases). Chart 1 2001-2003 Enbridge Release Causes

pipeline system. Prior to 2004, operations and engineering were jointly responsible for facility related release reduction initiatives. Figure 1: Facilities Integrity Structure in 2005

Chart 2 2001 2003 Equipment Release Sub-Causes

The Facilities Integrity structure, see Figure 1, began with the following programs: Small Diameter Piping, Tank Integrity, Flange Integrity, Sump Tank, Pressure Vessel and Station Piping Programs. These programs were selected based on Enbridges release history data (categorizing the types of incidents based on system configuration and release trending) and/or on regulatory requirements. Small Diameter Piping This program started as an initiative targeting small diameter piping (i.e. piping with a diameter of 2 or less). The program was created with the goal of reducing the use of threaded connections in small diameter piping installations along with using engineering best practices when building new systems or retrofitting existing installations. The initiative became the Small Diameter Piping Program based on release trending, which will be further discussed in a subsequent section. ORIGINAL FACILITIES INTEGRITY PROGRAMS In 2004, Enbridge developed a Facilities Integrity Program mandated to reducing facility releases across the Enbridge Tank Integrity Program The creation of the Tank Integrity Program was driven by regulatory requirements. The scheduling of inspections is in accordance with API 653 regulatory guidelines and maintains

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the safe and efficient operation of the tank facilities. The Tank Integrity Program ensures that the inspections are in compliance with regulatory guidelines in addition to providing technical guidance in the design and repair of new and existing tanks throughout the Enbridge system. Flange Integrity Program The Flange Integrity Program was implemented in 2003 to address flange related releases. The program utilizes the leak reporting database, discussed in the previous section, along with additional parameters to identify high-risk flanges for field investigation. The identified flanges are then inspected by testing the breakaway torque values of the studs making up the mechanical connection. The information obtained is recorded and the flanges re-torqued, if required. Release trending in this area will be discussed further in this paper. Sump Tank Replacement Program Support of the Sump Tank Replacement Program was undertaken by Enbridge in 1994, and adopted by the Facilities Integrity Program in 2005. The program has developed a longrange plan to address integrity of underground sump tanks, taking into account the following: the presence of ground water monitoring wells, environmental consequence data, release history, tank construction and age of installation. Included in this program, single walled sump tanks will be replaced with double walled tanks equipped with leak detection systems. Pressure Vessel Inspection Program The Pressure Vessel Program was also created based on regulatory requirements. The Facilities Integrity Program is responsible for the scheduling and coordination of the inspection of pressure vessels in accordance with API 510 requirements throughout the Enbridge Liquids pipeline system to ensure safe operation and compliance. Station Piping Program The Station Piping Program was created to address both external and internal corrosion threats. Various strategies exist to inspect for and mitigate corrosion. Research and development into various inspection and real time monitoring techniques are utilitzed where appropriate. The intent of this program is to identify, assess, monitor and remediate corrosion at station and terminal facilities in the liquid transportation service.

NEW PROGRAMS AND INITITATIVES Since the development of Facilities Integrity, new programs and initiatives have been and will continue to be developed based on statistical and operational analysis of available data, see Figure 2 below. Figure 2: Current Facilities Integrity Structure

Laterals and Delivery/Receipt Line Inspection Program The Facilities Integrity Laterals Program is responsible for the coordination and scheduling of the inspection of unpiggable pipelines in accordance with both US and Canadian federal and state/provincial regulations. Unpiggable pipelines mainly consist of laterals such as delivery and receipt lines, as well as transfer lines between Enbridge facilities.

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Project Support Facilities Integrity incorporates integrity based requirements into design standards, equipment specifications and comissioing/maintenance procedures. The Facilities Integrity Program provides engineering project support to project teams with regards to identifying and applying facilities integrity related regulations, equipment/piping integrity considerations. MEASURING PROGRAM EFFECTIVENESS Incident reporting continues to play an important role in monitoring the performance of Facilities Integrity programs. In order to monitor program performance the number of releases by program is analyzed. It is important to normalize the data, to ensure that any increases or decreases in release numbers are proportional to increases or decreases in the size of the operating system. Charts 3-7 show the program performance, normalized against billion barrel-miles (the number of billion barrels transported in one year multiplied by the number of pipeline miles). Chart 3 Flange Program Number of Releases per Billion Barrel-Mile

There have been changes made to specifications, regarding small diameter installations (improved drawings showing how these should be installed, increased wall thicknesses required and more detail regarding installation and preferred manufactures). There has been an increased focus on vibration analysis to ensure that areas of concern in the program are addressed. There continues to be a focus on replacing small diamater piping installations with new design protocol.

Chart 4 Small Diameter Piping Program Number of Releases per Billion Barrel-Mile

Chart 5 is showing a favourable trend in the area of station piping with stable results since 2006, again indicating that the program is proving succesful. Chart 6 indicates that in the area of tank integrity, there has been some fluctuation in the number of releases. Within this data set, there have been various root causes. In addition, the number of releases from tanks has been very low (at most one to two failures per year). As such, the tank program continues to focus on regulatory requirements regarding tank inspections. An indication of the overall effectiveness of the current Facilities Integrity programs is shown in Chart 7 which depicts the total number of releases related to Facilities Integrity programs normalized against billion barrel-miles. The decreasing trend in releases is indicative of successful program performance.

Chart 3 is showing a favourable trend for the flange program where there has been a steady decrease since 2005 in the number of flange releases indicating that the program is functioning as it should and is addressing high risk flanges and ensuring these get inspected (torque and gasket inspection) and retorqued/regasketed as necessary. Chart 4 is showing that in the area of small diameter piping there has been some variation in the number of releases and the following mitigative actions have been taken:

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Chart 5 Station Piping Program - Number of Releases per Billion Barrel-Mile

ROLE OF THE INTEGRITY MANAGEMENT SYSTEM As mentioned, in 2005, six-page Integrity Management System document was created to address facility integrity issues. The Integrity Management System documentation has been continually improved as a result of both internal and external audit reviews. Not only does the Facilities Integrity Management System ensure the successful implementation of the aforementioned programs, it plays a key role in the following: documentation of various procedures, including Management of Change, Management Review, Document Management System, Qualification and Training Guidelines. The Enbridge Facilities Integrity Management System documents were developed based on the guidelines presented in CSA Z662 Annex N: Guidelines for Pipelines System Integrity Management System and the US Pipeline and Hazardous Materials Safety Administration, DOT Code of Federal Regulations 49 Part 195.452.

Chart 6 Tank Program - Number of Releases per Billion Barrel-Mile

While these industry documents are used as reference, the Integrity Management System has to be customized to meet the unique needs of the Enbridge system. Enbridges Integrity Management System meets and exceeds applicable regulatory requirements. It has been customized based on information and knowledge collated over many years of operating experience. The Enbridge Facilities Integrity Management System is in place to effectively manage the risk of releases within Enbridge Facilities. The Enbridge Facilities Integrity Management System, as shown in Figure 3, is designed to reduce formalization of failures by the following: Demonstrate corporate commitment and policy Define management accountabilities Designate roles and responsibilities Define corporate policy and provide clear goals Ensure that programs are appropriately implemented and applied.

Chart 7: Number of Releases/Billion Barrel-Mile related to Facilities Integrity Programs

Figure 3: Breakdown of FI IMS

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The following list describes the documents that make up the core of the Facilities Integrity Management System, in addition to the programs mentioned in the last section: Management of Change The FI Management of Change (MOC) Process is based on the corporate MOC. The objective of the Corporate MOC process is to prevent incidents, improve overall operational safety and efficiency. This is done by ensuring that necessary stakeholders are involved in the decisions related to changes to facilities, equipment, processes and policies. Qualifications and Training This document details the qualification requirements, mandatory training requirements and discretionary training opportunities for Facilities Integrity employees, contractors and key vendors. Each position has a defined qualification requirement that includes educational, experience and skill set requirements. These are in line with operational qualification requirements. A procurement prequalification process is used to ensure vendors meet these requirments. Document Management System The Document Management System defines the management of all documents including specifications, reports, communications (i.e. emails, letters etc.) and program specific forms. Along with the corporate document system, this allows for tracking and retention of documents for the life of the pipeline. Integrity Measures Guide In order to measure and report the performance of the Integrity Management System, several data sets are collected and summarized. The Facilities Integrity Measures are divided into two categories: Program Progress -- summarizes all performance measures (i.e. No. of investigations, Scheduling, Expenditures) Effective Measures -- intended to highlight: Inconsistencies and challenges in the development and execution of the programs With the support and commitment of corporate leadership, the framework of the integrity management program allows the various groups and departments to integrate, pace and prioritize threats associated with facilities integrity (see Figure 4). Again, providing an opportunity to assess roles and responsibilities as well as determine process gaps and overlaps.

Integrity Management Review The Facilities Integrity Management System is reviewed to ensure that it is effective and in accordance with regulatory requirements. Some of the items to be reviewed include: Effects of changes in the operating company, the Facilities, or other factors. Findings and status of corrective actions identified during internal and external audits. Status and trends of integrity-related issues and recommendations identified during previous reviews and evaluations, operation, maintenance, or integrity-related work. Release Analysis -- The root causes of recent release incidents; successes and problems experienced in detecting and preventing potential incidents. Staffing (years of experience, engagement etc.) Inspections planned versus performed Figure 4: Process Overview

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LEAK REDUCTION TEAM A cross-functional team was formed by Enbridge to focus on leak reduction and improve integrity across all facilities. This team, called the Leak Reduction Team, is comprised of experts from integrity, engineering and each regional area within operations. The teams mandate is to reduce the likelihood of release reoccurrence and/or consequence. The team reviews both the investigation and analysis of releases as well as develops corrective actions which may include improved detection, new technology, specification revisions, and/or changes to company processes. CONCLUSION Through design standards, equipment and construction specifications, commissioning, operating and maintenance procedures, and targeted tank, equipment and piping inspections, Enbridge is committed to ensuring that its facilities, including pump stations and terminals, are operated and maintained in a safe, responsible manner. Through existing Facilities Integrity Programs, targeted inspections of the components within the facilities occur on an ongoing basis to assure the integrity of our assets. Since its inception in 2004, the Enbridge Facilities Integrity Management System has continually improved. Facilities Integrity has broadened in scope through the addition of programs. The Facilities Integrity Management System has expanded and evolved, making it comparable to the mainline Integrity Management System. A cross-functional Leak Reduction Team has been formed focused on leak reduction by reviewing release investigations and ensuring adequate corrective actions are in place. This continuous improvement has resulted in an overall decrease in the number of normalized releases pertaining to Facilities Programs. Enbridge is committed to further continuous improvement in the area of Facilities Integrity Management and aims to remain as an industry leader in this domain.

REFERENCES [1] McNeil, D. B., and Morrison, T., 2006, Facility Integrity A management Perspective, IPC2006-10206. ACKNOWLEDGEMENTS Brian Ellestad, Manager Facilities Integrity, Enbridge Pipelines Inc. Mark McTavish, Supervisor Facilities Integrity, Enbridge Pipelines Inc.

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