- In conjunction with a review of Liquids Pipelines' environmental management systems, E.Vironment, LP conducted an environmental compliance audit in 2006 at seven facilities, including Edmonton and Fort McMurray, Alberta; Norman Wells, Northwest Territories; Sarnia, Ontario; Cushing, Oklahoma; Griffith/Hartsdale, Indiana; and Superior, Wisconsin. Compliance issues that were identified were generally minor. Areas identified for improvement included environmental training, file completeness, labeling, waste management, and understanding permit requirements.
- Liquids Pipelines conducts an environmental review of each of its Canadian operating regions every three years. In 2006, we had a third party conduct a review of the Enbridge Pipelines (Saskatchewan) Inc. (EPSI) region. The objective was to identify areas of compliance and improvement, and to facilitate environmental awareness. In 2007, EPSI will develop an action plan based on the results of the 2006 review.
- In the United States, environmental reviews were conducted on Enbridge Pipelines, North Dakota and the Spearhead Pipeline. There were no significant findings. These reviews are an integral component of the Enbridge Environmental Management System and consist of a formalized program of inspections and reviews to monitor compliance with regulatory requirements, Enbridge policies and procedures, and industry best practices. Our United States Gas Transportation Business uses a corporate EH&S audit program designed to ensure compliance and consistency across our various assets. In 2006, we completed 23 audits throughout the assets. Our field EH&S personnel also performed 385 additional internal audits.
- Enbridge Gas Distribution reviewed six of its gate stations and one of its Toronto operating stations in 2006 for compliance with environment and health and safety regulations. The internal compliance review process is proving valuable in identifying issues, tracking closure of issues, communicating expectations to relevant internal groups, and driving awareness and ownership of EH&S compliance at our facilities to front-line supervisors and managers.
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Reviews and Audits
We use reviews and audits to assess each business segment's compliance with government regulations and our internal policies and management systems, and to provide guidance for making improvements.
Internal EH&S Reviews
We conduct internal EH&S reviews at all facilities we operate. To carry out a review, a team of EH&S professionals inspects the site, conducts interviews, and checks documentation. After the review is completed, the team provides local management with a formal written review report summarizing the findings. Management then develops an action plan to correct deficiencies. The review team follows up on documented issues to ensure they are fully addressed.
Click for a report on internal EH&S reviews in 2006.
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Process Safety Management (PSM) – United States
Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years in various industries that use chemicals with such properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled.
To help ensure safe and healthy workplaces, the U.S. Occupational Safety & Health Administration has issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes using highly hazardous chemicals.
In 2006, there were 27 PSM facilities in Enbridge's U.S. Gas Transportation Business. We have established a separate PSM safety program for these facilities, in addition to standard safety procedures. We also have assigned two EH&S professionals dedicated exclusively to the implementation and management of safety systems and procedures at these PSM regulated facilities.
Process Safety Management – Canada
During 2005 and 2006, the number of requests Enbridge Gas Distribution received from the excavating community to locate our gas lines increased by more than 10 per cent, while during the same period the rate of gas line damages per 1,000 locates decreased by more than 10 per cent. We continued to work with regulatory authorities to advance proposals for ‘One Call' legislation in Ontario that would streamline the ‘Call Before You Dig' process to one phone call. We also continue to target repeat offenders who excavate without locates, or who frequently damage the gas distribution system. As well, we have partnered with other local utilities to acquire locate services through a joint contracting process, which has resulted in overall improvements to locate service quality.
External Audits and Inspections
Local and federal regulatory agencies carry out environmental and safety audits and inspections of our operations. Here are some examples:
- The Oklahoma Department of Environmental Quality completed a comprehensive review of the Title V Air Permit at Liquids Pipelines' Cushing tank farm. Several minor non-compliance issues were identified and resolved, and as a result no Notice of Violation or other formal action was issued. In addition, our terminals at both Broome, Kansas, and Patoka, Illinois, received air compliance inspections by the respective state environmental agencies, also with no notable deficiencies. Liquids Pipelines' U.S. operations received no environmental fines or penalties in 2006.
- Enbridge is continually inspected by the U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA). In 2006, this consisted of more than 16 weeks of records and facilities inspections, including a team operating and maintenance procedure audit and a comprehensive liquids system Integrity Management Program (IMP) audit. At the time of this writing, PHMSA had not formally issued the results of the 2006 audits and inspections, but no violations or fines had been issued. Results of similar PHMSA audits and inspections in 2005 have been received with no violations or fines issued.
- Regulatory agencies conducted 54 external audits at our U.S. Gas Transportation facilities in 2006. These audits resulted in seven violation notifications. All of these violations were minor in nature, with the most severe resulting in a fine of US$2,080 for failure to report upset air emissions within 24 hours. Of the other violations, two resulted in US$500 fines each, with the remaining four having no associated fines.
- U.S. Gas T ransportation also received one additional violation notification in 2006 for a crude oil spill. This 10-barrel spill, which caused a sheen on a creek in Mississippi, resulted in a US$500 penalty.
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