Enbridge Class Location Change Management Plan. 1.1 Additional Information for Identified Changed Class Locations
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1 Information Request No Additional Information for Identified Changed Class Locations Reference: i. (A70936) Preamble: ii. Canadian Standards Association (CSA) Z662-15, Oil and Gas Pipeline Systems Reference i) states that Enbridge is submitting its class location management plan to deal with class location designation increases identified in December 2014 through Enbridge s class location survey process and in alignment with Section of CSA Z Reference i) also states that Enbridge is reviewing the new 2015 version of CSA Z662 released June 15, 2015 and will take the steps necessary as soon as practical to ensure compliance with any new standards. Reference ii) describes requirements for different class locations. The NEB requires additional information in order to verify that the current operating conditions for these sections meet the CSA Z requirements for corresponding Class Locations as described in Reference ii). Request: For all identified pipe sections in Reference i), please provide: a) Pipe attributes: 1. Licensed maximum operating pressure (MOP); 2. Current operating pressure; 3. Grade; 4. Wall thickness; 5. Outside diameter; 6. Coating type and its condition; 7. Minimum depth of cover 8. Number of Road crossings (identify whether cased or uncased) and 9. Construction year b) Location map of identified sections showing valve spacing and type. c) Confirmation that the reduction of the maximum operating pressure at Page 1 of 8
2 Information Request No. 1 - all identified changed class locations to a maximum of 64% of the Specified Minimum Yield Strength ( SMYS ) is a permanent mitigation measure. Response: a) For all identified pipe sections, pipe attributes are listed in Appendix 1. b) Location maps of identified sections showing valve spacing and type are included as Appendix 2. The following legend is provided for the location maps which have been auto generated via a GIS software package. Pipeline color green class 1 location Pipeline color blue class 2 location Pipeline color red class 3 location Dashed lines shown are 200m from the pipeline Dwellings are shown as white dots Lime Green areas are industrial installations, outdoor areas occupied by 20+ people or buildings occupied by 20+ people c) Enbridge confirms that the reduction of the maximum operating pressure at all identified changed class locations to a maximum of 64% of the Specified Minimum Yield Strength ( SMYS ) is a permanent mitigation measure. Page 2 of 8
3 Information Request No Class Location Change Assessment Reference: i. (A70936) Preamble: ii. Canadian Standards Association (CSA) Z662-15, Oil and Gas Pipeline Systems Reference i) provides a list of ten new class location changes and twenty-two extensions of existing class locations. Reference ii) describes requirements for different class locations. The NEB requires additional information in order to verify that the class location designation at identified sites meets the CSA Z requirements as described in Reference ii). Request: 1. For all identified pipe sections in Reference i), please provide : 1.a) A description of the drivers for the class location change, including the number of dwelling units, buildings occupied by 20 or more persons during normal use, well-defined outside areas, buildings with 4 or more storeys, industrial installations, along with an aerial map of each location where the class location assessment area is clearly marked. 1.b) 1.c) 1.d) Whether consideration was given to buildings intended for human occupancy from which rapid evacuation could be difficult (e.g., hospitals or nursing homes) in assessing the class location changes at each identified location. The number of dwellings for class 3 location sites and an explanation of Enbridge s definition of prevalence of buildings intended for human occupancy with 4 or more storeys aboveground as per CSA Z Confirmation that Enbridge has considered the potential for future development beyond class 2 or 3 location designation in its assessment of class location changes. Page 3 of 8
4 Information Request No For the twenty two extensions of existing class locations please provide: 2.a) When the class location change was initially identified 2.b) Was the notification of class location change sent to the Board Please provide the filing ID Response: 1.a) The drivers for the class location changes are included in Appendix 1. The numbers of dwelling units in class 2 locations are detailed below. The numbers of dwelling units in class 3 locations are separately detailed in response c). Please note, there are no buildings present with 4 or more stories. Aerial maps showing the class location assessment area are attached as Appendix 3. i. Existing location extension at KP 2.41 to dwelling unit (the proximity to the first 10 houses in the adjacent class 3 location have resulted in this class 2 extension) ii. Existing location extension at KP to total dwelling units in class 2 location, downstream class 2 extension due to building occupied by 20+ people and outdoor area occupied by 20+ people iii. Existing location extension at KP to dwelling unit (the proximity to the first 10 houses in the adjacent class 3 location have resulted in this class 2 extension) iv. Existing location extension at KP to Dwelling units located near the 16 houses in the adjacent class 2 location have resulted in this class 2 extension v. Existing location extension at KP to No dwelling units located in this class 2 extension. Per the Class Location Management Plan submitted on June 26, this extension was due to the use of an updated Page 4 of 8
5 Information Request No. 1-1.b) methodology in calculating the class location boundaries. vi. Existing location extension at KP to Dwelling units (the proximity to the last 8 houses in the adjacent class 2 location have resulted in this class 2 extension). In assessing the class location changes at each identified location, consideration was given to buildings intended for human occupancy from which rapid evacuation could be difficult. Specifically, such consideration was given to an assisted living complex constructed in Kipling, SK. Near kilometre post (KP) 851. The location has been identified as class 3 per Note 3 in Table 4.1 of CSA Z c) The number of dwellings for class 3 location sites included in the 2014 changes are listed below. vii. Existing location extension at KP 6.87 to total dwellings in overall class 3 location from KP 3.06 to viii. Existing location extensions from KP to and KP to total dwellings in overall class 3 location from KP to ix. Existing location extension from KP to total dwellings in overall class 3 location from KP to x. Existing location extension from KP to total dwellings in overall class 3 location from KP to xi. Existing class location extensions from KP to and KP to total dwellings from KP to Enbridge would assess each building intended for human occupancy with 4 or more stories above-ground in context with of all nearby 4- Page 5 of 8
6 Information Request No. 1-1.d) 2.a) 2.b) storey (and greater) buildings on situational basis to determine whether there is a prevalence of these buildings, referring to commentary provided in CSA Z662-15, Table 4.1 for guidance on interpretation. There were no buildings with 4 or more stories intended for human occupancy included in the 2014 changes. Enbridge has considered the potential of increasing class locations in our original design and construction of the Line 1 pipeline. We will continue to assess during the annual class location survey. The twenty two class location extensions were identified on December 23, Following identification of the extensions to the existing class locations, detailed analysis was undertaken during the next six months, January to June 2015, to identify whether the extensions to the existing class locations met CSA Z (which was applicable at this time) and to identify and plan for necessary mitigation plans. The Enbridge s proposed Class Location Management Plan to address the changes was submitted to the Board on June 26, 2015 as per the requirements in Paragraph 42 of the National Energy Board Onshore Pipeline Regulations. Page 6 of 8
7 Information Request No Engineering Assessments Reference: i. (A70936) ii. Canadian Standards Association (CSA) Z662-15, Oil and Gas Pipeline Systems Preamble: Reference i) identifies completion of Engineering Assessments (EA s) on valve spacing as a mitigative action for a number of changed class location sites. Reference ii) Clause 3.3 and Clause 10.1 provide guidance on the requirements for engineering assessments. Reference ii) Clause 10.7 provides guidelines on the requirements for the new class location. The NEB requires additional information regarding the engineering assessments that are going to be conducted for the changed class location sites. Request: Please provide: a) The timeline for Enbridge to file the Engineering Assessments with the Board for sections identified in the table of reference i). b) A copy of each EA upon completion. c) A description demonstrating that Enbridge has identified and addressed all hazards (i.e. internal/external corrosion, SCC, Cracking, overpressure, road crossing, etc.) at all identified changed class location sites. d) A discussion demonstrating that the degree of risk associated with each identified hazard in c) has been evaluated and taken into consideration for the class location designation. e) A demonstration that a stress loading analysis has been performed for all identified road crossings in the changed class location sites, including: 1. Cyclical traffic loads 2. Combined stresses 3. Existing anomalies under road crossing Page 7 of 8
8 Information Request No. 1 - f) A list of existing anomalies under road crossings as well as input values for depth of cover and external loads that were taken into consideration in e). Response: a) The Engineering Assessments (EA) will be filed with the Board by December 23, b) A copy of each EA will be provided to the Board by December 23, c) A description demonstrating that Enbridge identifies and addresses all hazards (i.e. internal/external corrosion, SCC, Cracking, overpressure, road crossing, etc.) as a part of its integrity management program is included in Appendix 4. Engineering assessments are being prepared which will consider all of these hazards in the context of the proposed class location changes. d) A discussion demonstrating that the degree of risk associated with each identified hazard in c) has been evaluated and taken into consideration for the class location designation and is also provided in Appendix 4. e) A stress loading analysis, with consideration given to cyclical traffic loads, combined stresses and existing pipeline anomalies under road crossings, will be completed in conjunction with the Engineering Assessments. f) A list of existing anomalies under road crossings, as well as depth of cover information and external loading information considered in the stress loading analysis, will be provided along with the Engineering Assessment information in (b) above. Page 8 of 8
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