A0V5U9 - Response To NEB IR 2 Southern Access Upstream Expansion Appendix A

TABLE OF CONTENTS
1.0 FOREWORD ................................................................................................................... 2
2.0 OVERVIEW..................................................................................................................... 3
3.0 POLICY AND GOALS ................................................................................................... 5

3.1 Principal Objectives ..................................................................................................... 6
4.0 RESPONSIBILITIES.................................................................................................... 11
5.0 PLANNING.................................................................................................................... 12
5.1 Planning Horizons ...................................................................................................... 12
5.2 Planning Tools ............................................................................................................ 13
5.3 Planning Sequence ..................................................................................................... 13
6.0 PROGRAMS.................................................................................................................. 15
6.1 Prevention Programs ................................................................................................. 15
6.2 Monitoring Programs ................................................................................................ 16
6.3 Mitigation Programs .................................................................................................. 18
6.4 Trending and Analysis............................................................................................... 20
7.0 MANAGEMENT SYSTEMS ................................................................................................ 22

7.1 Training and Qualifications ...................................................................................... 23
7.2 Codes, Standards and Procedures ............................................................................ 25
7.3 Continuous Improvement.......................................................................................... 25
7.4 Document Management System................................................................................ 26
7.5 Performance Metrics.................................................................................................. 27
7.6 Risk Assessment.......................................................................................................... 28
8.0 SUMMARY OF COMMITMENT .......................................................................................... 29
Enbridge Pipeline Integrity Management Program

SECTION 1.0 FOREWORD
1.0 FOREWORD
From its beginnings in 1949, Enbridge Pipelines Transportation Group North has invested
heavily in the branch of technology known as pipeline integrity management and maintenance.
The Enbridge integrity management program encompasses all of the tools, technologies,
documents and strategies needed to ensure the transmission pipeline systems have the strength
and operating ‘fitness’ to operate safely and reliably. This focus on pipeline integrity is a
major step toward ensuring safe, incident-free operations on one of the longest and most
complex pipeline systems in the world. This document is a framework of all of the activities
that play a part in the program and is summarized as follows:
Integrity Management Program
Objectives Plans & Procedures & Management

Programs Specifications Systems
The Enbridge pipeline integrity management program involves a dynamic process where
continuous evaluation is conducted within the program design. This ensures that integrity
management techniques are progressive and the pursuit of enhancements is formally
conducted. The following diagram illustrates the underlying approach for achieving the
integrity management objectives:
Plan
Improve Integrity
Implement
Management
Measure
Enbridge Pipeline Integrity Management Program Page 2

SECTION 2.0 OVERVIEW
2.0 OVERVIEW
Enbridge transports a variety of liquid and natural gas products through a complex network of
transmission pipelines spanning North America. The pipelines are operated and maintained by
individual business units and companies. Portions of the pipeline system are relatively new but
the majority was built 30 or more years ago. Integrity management risk control programs are
incorporated within all stages of the pipeline lifecycle including system design, construction,
operation, and if required, decommissioning. This document summarizes the Enbridge
integrity management program.
Enbridge applies integrity management policies that are intended to meet applicable codes and
standards. These policies have been customized based on information and knowledge collated
over many years of operating experience. The focus of the Enbridge integrity program is to
prevent leaks or ruptures caused by duty-related deterioration such as corrosion and cracks.
Ongoing monitoring programs are employed to determine whether deterioration or damage has
occurred. Where it has, the pipeline condition is restored so that a constant-base integrity level
is preserved.
This framework document summarizes the approach within Enbridge to ensure essential risk
control measures are carried out with minimal operational disruption. The Enbridge process is
designed to formalize the following:
• Demonstrate corporate commitment and policy.

• Clarify management accountabilities.
• Designate roles and responsibilities.
• Maintain an acceptable standard of engineering procedures and practices.
• Establish management systems to ensure that programs are appropriately implemented
and applied.
The Pipeline Integrity Department is responsible for implementing the integrity programs and
the following diagram describes the key activities related to the department role.
Welding
Non-destructive testing Pipeline Integrity Activities
Steel properties
Failure investigation
Fracture mechanics
Defect assessment
Excavation & repair

ials
ter y In-line inspection
Ma nolog Internal corrosion mitigation
ech Station piping integrity
T
y
grit Integrity science
Inte rams (i.e., protective coatings,
g
Pro cathodic protection
Data management & trending
Risk assessment
rity Process audits & improvements
nt eg sis
I a ly
An

SECTION 2.0 OVERVIEW
Other asset management programs within Enbridge that have an association with integrity
management program development but are the central responsibility of other Company
departments include the following:
• Route selection, facility design, and construction quality assurance and quality control.
• Selection and maintenance of rotating equipment.
• Management of appurtenances such as pressure relieving equipment, instrumentation and
control equipment.
• Supervisory Control and Data Acquisition.
• Pipe strain assessments related to slope stability, spans and other geotechnical
phenomenon.
• Storage tank integrity.
• Water body crossing surveys.
• Third party damage prevention and depth of cover assessments.
• Emergency response.

SECTION 3.0 POLICY AND GOALS
3.0 POLICY AND GOALS
The core goal of the integrity management program is to prevent leaks or ruptures caused by
duty-related deterioration of the transmission pipeline system. This goal is driven by the
corporate commitment to protect the health and safety of employees, the general public, and the
environment and is formalized within the Enbridge Environment, Health and Safety Policy.
This Policy summarizes and guides the Company’s overall approach to corporate commitment
and is implemented through programs such as those described further in this document. The
Policy is shown below.

3.1 Principal Objectives
In addition to the core integrity management goal, there are a number of objectives that
underlie all Enbridge integrity management activities. These objectives are an outward
demonstration of the prevailing values of the organization and are more subject to
evolution than revision. The objectives are developed to complement the corporate
vision, mission and values, which are explicitly expressed within the Company strategic
planning processes and documents. The integrity management objectives, which are
woven into all integrity management actions and decisions, are as follows:
The pipeline system will be safe and perceived to be safe.
Above all else, integrity programs will be developed and implemented to ensure
maximum protection for the public and the surrounding environment. Although the
organization exists for economic profit, this in no way compromises the ability of
employees to address pipeline integrity challenges. Enbridge views the maintenance of
pipeline reliability and the development of defensible, easily communicated integrity
programs as good business and key to future expansion of the system.
Enbridge will strive to achieve zero failures.
Pipelines are engineered and built with a balanced view to economic viability and safe
operation. By their nature, as manmade structures exposed to operating regimes that
cause deterioration and potential damage by outside forces, pipeline leaks are possible,
albeit rare; the risk associated with pipeline leaks is finite but, cannot be completely
eliminated. However, the commitment to use innovative technology is geared towards
continuously identifying potential integrity defects and treating them as needed. Further,
any known imminent problems are dealt with immediately. The overall commitment to
system reliability is expected to tend towards continuous improvement regarding failure
probability, as shown in the diagram below. Should a leak occur, emergency response
actions are implemented to minimize the impact.
Continuously Improving Performance

>0
1 Current Performance
2 Innovation better performance, sa me resource allocation

Number of Failures
3 Innovation equal performance, fewer resources
2 Toda y
0 Future
Asym ptote = Risk diminishing but not eliminated
Resource Allocation
0 >0

The pipeline will be reliable with minimal customer impact.
The potential for pipeline system shutdown due to a breach in the pipe is minimized
through proper design, operation and maintenance. Prevention, rather than breakdown
maintenance, provides a better way to achieve product delivery commitments. Further,
maintenance activities are planned and controlled to ensure minimal disruption to the
pipeline throughout.
The pipeline system will be maintained as a long-life asset.
The occurrence of pipeline defects is related to the length of time the pipeline is exposed
to operating conditions. However, the Enbridge transmission pipelines are built, operated
and maintained with a view the asset will be required indefinitely, without an end point
design life. The transmission pipelines are maintained so that, regardless of age, they
meet applicable codes and standards for structural fitness. In other words, preventative
maintenance is continuously employed in a timely fashion to ensure that age is not a
determining factor in relation to the safety of the transmission system.
Preventative Maintenance at Set Intervals
Pipeline Strength Tolerance

Defect Occurrence
Enbridge Tolerance
3 3
4
2
1
Time
1 Benign defects in a new pipeline
2 Onset of defect growth
3 Pipeline is revalidated through monitoring & mitigation
4 Some duty-related defects will be un-repaired

Monitoring programs will define the type, location and extent of defects.
Enbridge takes a proactive approach to understanding the type, extent, and effect of
defects. As such, the intent is to identify defects using best technologies so that each
specific defect can be managed. Mitigative programs are implemented to address, in a
timely fashion, the risk associated with defects that exceed Enbridge tolerances. For
other defects not compromising tolerances, continued deterioration is arrested or
monitoring programs are set up to address the defects in a timely fashion. The aim of this
preventative program is to correct low-level damage and deterioration before major
repairs are needed.
Liquid Pipeline Operating Pressure
Likelihood of Defect Occurrence

x
x x x
x x
Defect Failure Pressure (x = defect)
x
Certain (Benign defects - monitored regularly)
x x x x
Design Pressure
x Likely (Low level deterioration - repaired in a timely
x x
x fashion)
x
x x x x Unlikely (Moderate deterioration - repaired in a

timely fashion, temporary lower MOP evaluated)
Maximum Operating Pressure x
Rare (Unacceptable occurrence - MOP reduced

x until defect repaired. Future maintenance frequency
modified)
Act
ual
Ope
ratin
gP
ress
ure
Distance from Pump Station
Life cycle management approaches will guide resource allocation.
Integrity programs and insights are applied at all phases of the pipeline lifecycle – design,
construction, operation, and if required, deactivation. At all stages of the lifecycle, the
integrity measures are employed with a long-term view of cost and function. For
example, advanced corrosion protection coatings may be used for new pipelines in
situations where other coating alternatives would result in lower pipeline installation
costs. However, the advanced coating may permit greater corrosion protection in the
long-term thereby requiring less maintenance resources during future operations.
Learnings from any stage of the pipeline lifecycle are applied to ensure the most
appropriate technology is utilized.

Resources will be optimized to ensure efficiency.
Resource allocation must be conducted strategically to make best use of manpower,

equipment, and knowledge. A controlled and coordinated spending approach encourages
process control, program formalization and a structured documentation approach.
Through preplanning, resourcing needs can be clarified in order to ensure the primary
objectives of pipeline reliability will be met. Consideration of future spending provides a
platform for internal communication and evaluation amongst a broad Company audience,
and affords the appropriate advance scheduling to ensure the right resources will be
available.
Strategic financing of maintenance expenditures is part of running an effective program.

For example, by aiming to maintain relative spending levels of routine maintenance
activities at a steady or improving profile, as shown below, it becomes necessary to
ensure the continuous improvement of processes and the implementation of new
technologies. This is demonstrated through numerous approaches such as the bundling of
activities, bulk purchasing and related supply chain initiatives, and information
technology solutions. Taken together, such initiatives maximize long term cost effective
use of the asset while encouraging pipeline integrity innovations.
Historic and Forecasted Expenditures
Average Capital Spending

Budget Value
Average Operating Spending
Budget
Capital
Year Operating

Innovative technology will be used to enhance pipeline integrity.
The most appropriate technology available worldwide will be implemented to prevent the
onset of potential concerns, to monitor existing conditions, and to mitigate the effects of
defects. Enbridge actively seeks to understand the inventory of available integrity tools
and potential benefits to the pipeline system. The most sophisticated or costly technology
is not always the “best technology” and the utilization of the technology must be properly
matched to the specific requirements of any given pipeline, as represented in the diagram
below. In all cases, the intention is to use sound engineering to ensure that the goals of
Enbridge’s pipeline integrity program are met and that adequate information is available
for planning decisions.
External Corrosion Defect Identification Tools
3
Very
lu e
High
le Va
cyc
Life
um
Technology Cost
6
p t im
High dO
4
5
aliz e
rm
No
Med
2
Low 1
Technology Precision
1 Cathodic Protection Survey 4 Standard Resolution In-Line Inspection

2 Coating Impedence + Investigative Dig 5 High Resolution In-Line inspection - Tool A
3 Maintenance Hydrotest 6 High Resolution In-Line Inspection - Tool B

SECTION 4.0 RESPONSIBILITIES
4.0 RESPONSIBILITIES
The direct responsibility for the preparation and implementation of the integrity management
program lies with the following key organizational groups:
Group Integrity Management Program Responsibilities

Senior Management • Provide timely and accurate communication to the Board of
Directors.
• Oversee program to ensure that the objective of safe, reliable pipeline
operation is met.
• Allocate resources for implementation and continuous improvement
of the integrity programs.
Pipeline Integrity • Directs program to meet objective of safe, reliable pipeline operation.
• Attain, train, and develop personnel for implementation of the
integrity management program.
• Identify key integrity management issues and develop systems for
responding to objectives.
• Administer projects related to the prevention, monitoring, and
mitigation of integrity challenges.
• Provide sound technical advice and service for other functional
groups.
• Continually improve the overall strategic direction and detailed
systems related to integrity management.
Operations • Provide technical and construction manpower for the application of
integrity field projects.
Engineering • Scope, design, and build pipelines in accordance with the appropriate
lifecycle codes, standards and practices, which then set the initial
pipeline safety level.
• Ensure quality assurance and quality control of integrity measures
applied during new asset installations.
A schematic summarizing the Enbridge Pipeline Integrity Department structure and key
personnel is provided below:
Manager
Administrator
Materials Technology Integrity Programs Integrity Analysis
Engineers Supervisor, Engineers Supervisor, Engineers

Technologists, Clerks Technologists, Clerks Technologists, Clerks
Does not include personnel from other departments also affiliated with integrity management activities (i.e., District Corrosion Technicians)

SECTION 5.0 PLANNING
5.0 PLANNING
Integrity management activities involve the application of specific risk control measures at
each stage of the pipeline lifecycle beginning with pipeline need determination, then design,
constructing the pipeline, and then operation. While pipeline integrity measures are planned at
each stage, the major focus is on preventative maintenance programs, which identify potential
damage mechanisms so that failure risk can be minimized through proactive repair. The types
of damage that deteriorate the fitness of the pipeline system over time and are managed through
planned programs by the Pipeline Integrity Department fall into one or more of the following
categories:
• Metal loss such as corrosion or gouging.

• Pipe deformation such as denting.
• Cracking related to steel manufacturing or forming processes.
• Cracking related to exposure to the operating or natural environments.
• Combination of the above items.
The extension of pipeline life is achieved through planned rehabilitation in which defects and
damage that are not fit-for-purpose1 are repaired. Any pipe with defects that are not repaired is
deemed to have sufficient strength and is monitored in a planned approach, which considers
potential growth during operation.
5.1 Planning Horizons
The management of age- and duty- related damage mechanisms requires continuous
attention. Specific planning activities have the following goals:
1. Long-term plans (>2 years) that forecast the scale of required resources.
The intention is to build awareness and ensure alignment with other Company
initiatives for system utilization. The long-term view foresees potential fluctuations
from typical resource allocation trends, thereby prompting additional analysis
regarding the intended activity. The variables used as inputs to the plans can then be
reviewed or alternative activities can be considered (i.e., repair versus replace).
2. Medium-term plans that identify annual programs.

The intention is to secure specific resources for committed work. Within this
planning stage a final review of the procedure, process and need is conducted.
3. Project management planning.

The intention is for the integrity engineer or technician to mobilize resources to
complete the activity with sufficient infrastructure to ensure technical success, safe
implementation, and minimal operational disruption.
1
Fitness-for-Purpose – terminology representing engineering assessments which calculate the adequacy of the
structure for continued service under current conditions.

5.2 Planning Tools
A variety of planning mechanisms are utilized to facilitate the planning processes.

Examples of high level planning tools are as follows:
Operational Reliability Assessments
The Company has a vast bank of information that describes the construction, operation,
and maintenance of each transmission pipeline within the system. Information pertinent
to integrity management planning is collated, trended, and tabulated into reports specific
to each individual pipeline. These reports, or operational reliability assessments, serve as
a single-source reference guide for the integrity engineer or technician.
Planning Sessions
Formal strategy planning meetings are conducted on a regular basis. Operational

reliability assessments and other resources are evaluated at the planning sessions and the
results of the sessions outline the strategy and objectives for future programs.
Budget Cycles
Plans for integrity management activities undergo rigorous review at various levels
within the organization. The budget cycle is a built-in forum for reviewing the
appropriateness of the strategy and enables a broad audience, including Senior
Management, to ensure the goals and objectives of the Company are met.
The Operational Risk Management Initiative
While the key components of risk management have long been in place, Enbridge is
taking steps to formalize its approach for risk assessment. The Company is continually
developing processes and information management tools which collate pipeline failure
probability calculations with consequential damage estimates in order to enhance
resource allocation methodologies.
5.3 Planning Sequence
The type and frequency of resource allocation applied to a particular section of a pipeline
is a reflection of the likelihood of deterioration or damage occurring at that location, and
is set at an appropriate level by qualified Engineers and Technicians. Operational
experience, industry fault data, and pipeline codes and standards are used to optimize
integrity procedures with the intent of ensuring an indefinite pipeline life at a constant fit-
for-purpose level. The activities are planned to ensure minimal disruption to the pipeline.

All phases of planning encompass the review of operational information collected from
previous implementation steps, as conducted by qualified Engineers and Technicians.
While planning steps must meet Company scheduling milestones, the plans can change at
any point in the work year to reflect newer information. Planning takes place year round
in various forms but the following demonstrates a typical format:
Develop Long Range Plan

using most recent
information
Submit annual budget
Year-end review to ensure

plans are appropriate prior
to implementation
Implement plans

SECTION 6.0 PROGRAMS
6.0 PROGRAMS
The Enbridge pipeline system is designed, built and operated to codes, standards, and practices
with a view to long-term need of the asset. Control measures are incorporated to prevent
defects from initiating and growing in the pipeline. The condition of the pipeline is constantly
monitored to identify defects that may occur and remedial action is undertaken in a planned
approach to ensure the continued, uninterrupted, safe and efficient operation of the pipeline
system.
Enbridge’s approach to pipeline management is based on applying risk-control measures over

the life cycle of the pipeline so that a constant base integrity level is maintained. The pipelines
are operated at pressures significantly lower than design strengths and the integrity programs
are employed at frequencies that aim to manage defect growth so that the operational strength
requirements are not compromised. Each time integrity repair programs are implemented, the
pipeline is revalidated to ensure all strength requirements are met. The integrity management
activities, which are applied over the life of the pipeline, are summarized as follows.
6.1 Prevention Programs
The risk of pipeline failure is minimized through careful planning of pipeline routing,
selecting suitable construction materials, limiting operating stress through the design
factor, and ensuring a high quality pipeline installation. The pipeline integrity activities
related to these efforts are as follows:
Participate on project scope teams.
Pipeline Integrity personnel participate in project development teams and provide input
regarding the integrity measures required to ensure a long-life asset based on the
proposed operating regime. The characteristics of the product to be shipped, the terrain
that will be traversed, hydraulics, pressure patterns and other properties that affect
pipeline deterioration are reviewed. Requirements for integrity measures are integrated
into the project economics. This early participation is a feature of greenfield projects as
well as system retrofit or expansion activities. The commitment from integrity personnel
carries through to the regulatory evaluation and approval phase.
Design the procedures and materials for minimizing pipe defects.
• Define and endorse pipeline configurations, which minimize dead-legs in the system
where liquids can collect and create a stagnant environment that may initiate internal
corrosion.
• Identify modifications to pressure spectra in order to lessen the impact of cyclic
fatigue.
• Provide metallurgical expertise in the selection of pipeline steels and welding
procedures.

• Specify protective paints, coatings, and linings that serve to protect components from
corrosion.
• Design cathodic protection systems that work in conjunction with protective coatings
to prevent corrosion.
• Prevent the onset of corrosion related to shorted pipeline casings by filling casing
annulus with a dielectric material.
Incorporate quality assurance and quality control measures.
• Development of nondestructive testing procedure and implementation specifications.

• Assistance with design of hydrotesting.
• Training and audit of contractors and Company personnel involved in
implementation of integrity related activities.
• Contractor selection, negotiations and contract preparation related to installation of
new facilities.
These activities are implemented for new facilities and for repair of existing facilities.
Further, Pipeline Integrity personnel are often called upon to review and authorize
“Design Basis Memorandum” documents. For all assets, the integrity requirements are
detailed within Company Engineering Standards, Pipeline Integrity Specifications and
Operating & Maintenance Procedures Manuals.
6.2 Monitoring Programs
Appropriate design, construction and operational measures, combined with ongoing

monitoring programs, are aimed at preventing corrosion and cracking that have the
potential to cause deterioration of the pipeline system. In order to check pipeline
integrity and confirm that prevention mechanisms are intact, Enbridge uses the following
techniques to monitor the system and assess operational data:
In-Line Inspection
In-line inspection is used to measure the size, frequency and location of defects.
Increasingly sophisticated inspection tools travel with the flow of the product in the
pipeline and gather information about the condition of the pipe on a millimetre by
millimetre basis. The tools detect corrosion, cracks, dents, gouges and other types of
defects that may occur on either the internal or external surface of the pipe. Most defects
that are detected are minor and do not threaten the integrity of the pipe. All are analyzed
and monitored through regular inspections to ensure that the defects are addressed prior
to compromising the structural strength requirements of the pipeline. The inspection
intervals are set based on the following parameters:
• Measured and calculated defect growth rates.

• Type, number and severity of defects.

• Change in operating condition.

• Previous data type and quality.
• Transported product characteristics.
• Population and environmental sensitivity.
Of all monitoring techniques, in-line inspection provides the most detailed information
about the condition of the pipeline system. Virtually all of the Enbridge Transportation
Group North mainline piping is configured to allow access of inspection tools.
Cathodic Protection
The operability of the cathodic protection system is regularly monitored to ensure that the
cathodic protection equipment is functioning properly and that performance criteria are
being achieved. All buried, steel structures, including storage tank bottom plates, are
connected to cathodic protection. Typical surveys, which measure the electrical output of
the cathodic systems, are conducted monthly and yearly. In some cases, more in-depth
close interval surveys are conducted to gather further information. Specific attention is
also directed toward the cathodic protection effectiveness at casings, crossings, along
high voltage AC corridors, and at other potential interference structures. The data
gathered from the cathodic protection surveys serves as an indicator of external coating
damage and the onset of external corrosion in general.
Internal Corrosion Devices
Although the liquids transported by Enbridge are not particularly corrosive, the internal
steel surfaces of the system, other than storage tanks, are typically not protected with
barrier coatings or cathodic protection and can become susceptible to internal corrosion
in isolated areas depending upon characteristics of line elevation profile, flow regime,
and product corrosivity. The key method for monitoring internal corrosion activity on the
mainline system is the use of in-line inspection. Also, information regarding internal
corrosion activity is gathered through the use of corrosion probes and the analysis of
crude samples gathered during line cleaning operations. Corrosion probes most
commonly used on the Enbridge mainline system are installed on the external surface of
the pipeline at key locations and effectively measure the presence of hydrogen ions
generated as part of the corrosion reaction. The technology, known as “hydrogen foils”,
captures hydrogen that permeates through the steel to the external surface of the pipe and
provides an indirect measure of corrosion activity.
Hydrotesting
Prior to placing a new pipeline in service, a hydrotest is conducted to commission the

pipeline. In some instances, a hydrotest is also used to validate the existence or
nonexistence of critical defects in lines that have been in service for some time. While
hydrotests serve as an absolute monitor of critical defects, little is learned about the
existence or nature of subcritical defects and, in fact, some subcritical defects may

actually grow when exposed to the high pressures used in hydrotesting. Further, due to
the need to gather and dispose of large quantities of test water, the potential for
contaminated water to come in contact with the environment, and the extensive downtime
of the pipeline, this monitoring technique is rarely used.
Direct Assessments
By considering the impact of variables that lead to the occurrence of pipeline

deterioration, it is possible to deduce the susceptibility and the location of certain defects
without measuring pipeline strength using in-line inspection or hydrotest. For example,
by combining the overall aspects of failure history, pressure history, pipeline construction
specifications (i.e., coating type), results from cathodic protection surveys, soil types, and
other characteristics, one can deduce the likelihood of certain types of defects. The
operator can then excavate the pipeline at high susceptibility locations and directly
examine the pipe at that location – a process known as “direct assessment”. The process
involves development of a model to be used in situations where more finite techniques
for locating defects, such as in-line inspection or hydrotesting, would be impractical.
Examples of this technique include stress corrosion cracking landscape models. These
models help develop an understanding of susceptibility to stress corrosion cracking by
exposing the pipeline at locations where previously observed conditions leading to this
feature are also known to exist on the subject pipeline. The same approach can be used
for most types of pipeline defects.
Investigative Excavations
Investigative excavations are conducted as a result of defects identified by in-line

inspection, the selection of a specific location based on a direct assessment approach, or
perhaps in conjunction with some other maintenance activity. At the excavated site,
information regarding soil type, water, topography, coating condition, and many other
characteristics are gathered and serve to develop a better understanding of the root causes
of pipeline defects.
6.3 Mitigation Programs
In order to manage risks posed by pipeline deterioration, defects identified through

monitoring are categorized using comprehensive fitness-for-purpose criteria. The need
for remedial action or repair work is based on the goal of ensuring a long-life asset and
preventing failures. Defects which do not meet acceptance levels will be subject to
maintenance activities. Any remaining defects will have sufficient failure margin and
will be monitored and investigated for future repair needs. Restoring the target integrity
level through defect management essentially revalidates the pipe strength level and
removes the ‘end-of-life’ stage of the asset life cycle.

Implementation of mitigative actions on the Enbridge transmission pipeline systems

requires the involvement of various departments within the Company, including Enbridge
operations and maintenance crews. The following techniques comprise the key
mitigative methods used by Enbridge:
Repair
This is the most commonly used Enbridge remedial activity for treatment of pipeline
defects. Repair techniques are based on well-documented industry guidelines and
typically comprise one or more of the following activities:
• Grinding to remove the defect;

• Installation of a reinforcement or pressure-containing sleeve to transfer the pipeline
pressure load to the repair sleeve; and/or
• Applying a new coating to halt further growth of defects which do not presently
exceed fitness-for-purpose criteria.
Repairs are confined to bellhole pipeline segments and are used to address specific
defects identified during monitoring activities. The directed repair technique is generally
the most effective technique for Enbridge to revalidate the pipeline to a constant integrity
level while ensuring minimal operational disruption.
Pipe Replacement
Complete removal and replacement of pipe is undertaken in situations where the pipe has
been damaged beyond repair as in a rupture failure. Pipe replacement may also be an
option for repairing defects in general. For example, if the concentration of repair
requirements is high in a particular segment of pipeline it may be more economical to
replace the pipe than to repair.
Pressure Reduction
Pressure reductions are normally used as an additional safety measure by reducing the
stress level of the pipe with the aim of preventing the failure of a defect while under
investigation or repair. Pressure reductions are also used as a means of restoring the
target safety margin. For example, in some cases it may be preferable to postpone
permanent repair due to difficult site access, the need to ensure minimal operational
disruption, or the need to conduct more rigorous evaluations related to long-term repair
strategies. This approach ensures suitability for continued service at a revised integrity
target level. However, treatment of the defect is required if a higher pressure is desired.

Rehabilitation
In the past, Enbridge has conducted pipeline maintenance activities involving the large-
scale stripping of deteriorated external coatings and recoating with a new high-integrity
material. The aim was to correct low-level damage before major repairs were needed.
While this approach focuses on treating several contiguous kilometres of exposed piping,
rehabilitation concentrated at shorter bellhole-type locations may also be considered.
Rehabilitation techniques, other than coating removal and replacement, include the
installation of slip-liners into pipe to manage low level internal corrosion. While
Enbridge will continue to review the use of this approach for managing the pipeline
lifecycle, the overall cost-benefit analysis, as well as other parameters related to safety
and practicality, favours the continuation of defect management through repair.
Internal Corrosion Mitigation
Enbridge employs an internal corrosion mitigation program to manage the effect of

corrosion growth in pipeline segments where the conditions which cause internal
corrosion cannot be prevented through design or operation. The goal is to minimize the
growth of low-level defects and postpone or eliminate the need for repair. The approach
involves mechanical cleaning using pigs to scour the internal surface of the pipe and
remove sediment deposits and water. Chemical inhibitors are then injected into the
pipeline to counteract the corrosion process by treating bacterial constituents in free water
and by establishing a protective film on the pipe surface.
6.4 Trending and Analysis
Enbridge integrity management policy and procedures are developed through the
application of competent engineering judgement which makes use of operational
experience to specify the types of integrity activities needed and their optimal frequency.
Data gathered as a result of the integrity activities is trended and analyzed in order to
improve the effectiveness of the programs. Specifications and procedures are amended as
needed. Key trends provide guidance for program development in the following ways:
Data from ILI
• Delineates the type and concentration of integrity defects.

• Provides core information for establishing growth rate of defects.
• Confirms acceptability of other integrity measures such as inhibition programs.
• Permits the evaluation of secondary integrity issues (i.e., corrosion under casings).

Information gathered from investigative excavations
• Confirms the accuracy and repeatability of ILI equipment.

• Provides information related to the factors that lead to the integrity concern (i.e.,
coating condition, soil type, and topography).
• Assists with cost/benefit analysis of various repair options (i.e., sleeve versus
replace).
Remote monitoring
• On-line readings provided from the SCADA system record pipeline operating
conditions, such as pressure or temperature, which can be related to causal analysis of
pipeline defects.
• Communication links to integrity monitoring devices such as corrosion coupons or
cathodic protection components provide constant updates regarding the effectiveness
of integrity measures such as inhibitor injections.
Financial analysis
• Spending trends may reveal activities that should be bundled, or integrity materials
that would be more effectively purchased in bulk. Not only does this improve
profitability, it also frees up resources that can be better utilized elsewhere.
• Financial analysis assists in developing the engineering solution for the selection of
best technology and focuses on activities which optimize pipeline integrity value.
Failure investigations
• The possible failure modes are leak or rupture caused by damage to the pipeline.
Laboratory investigation of failed pipe, as well as forensic evaluation of the failure
site and related operating conditions, provide a causal analysis of pipeline failures.
The results of the analysis are reported to key stakeholders.
• Damage may originate during any stage of the pipeline lifecycle. The failure
analysis, which includes a survey of any similar previous occurrences, provides an
additional forum for evaluating the appropriateness of the damage prevention,
monitoring and mitigation activities. In order to minimize future failures, additional
control measures may be introduced based on the results of the failure analysis.

Vast amounts of data and information are gathered during integrity programs and, in
itself, the handling of the information involves detailed processes, technology, and
technical judgment. Maximizing the informative potential of collected data requires the
ongoing development of information technology tools and systems such as the following:
Integrated Spatial Analysis System
• Integrated Spatial Analysis System provides a means for managing the Pipeline
Integrity databases. The design of the system is such that key databases are
accessible through a single interface and selected information can be plotted on a
base mapping system that shows an overhead view of the pipeline right-of-way.
Field Excavation Report System
• Data collected during field maintenance activities is enhanced through the use of
palm pilots which enables the field technician to quickly enter the results of
observations and download the data to a central database that screens the information
for correctness. The information can then be sent directly to trending algorithms
providing the engineers and technologists with rapid field activity feedback.

SECTION 7.0 MANAGEMENT SYSTEMS
7.0 MANAGEMENT SYSTEMS
Enbridge assesses pipeline integrity through monitoring and review of operational data
and ensures the safe and efficient operation of pipelines through a range of preventative
maintenance programs. The goal of management systems is to ensure events are
accurately documented, roles and responsibilities are defined, consistency is
maintained, decisions are easily communicated and justified, and continuous
improvement can be directly employed. The management systems are formalized
through implementation of the collective policies, procedures and practices that guide
the technical and administrative requirements for achieving the pipeline integrity
objectives. The facets of the integrity management system are summarized as follows:
7.1 Training and Qualifications
Pipeline integrity management entails the implementation of specialized fields of

knowledge related to the engineering and physical sciences. In support of the
activities, other areas of knowledge are integral, including financial awareness
related to lifecycle management, safety and environment, document management,
and system operations.
Engineers, technologists, administrative and other support professionals are relied

upon to implement integrity programs and ensure the best technology is
employed. Where additional expertise outside of the capabilities of Enbridge
employees is required, third party consultants are commissioned, and the third
party contracts are managed by Enbridge employees.
Pipeline integrity expertise requirements are evaluated on an ongoing basis. New

technology requirements, workload, stakeholder needs, and other Company
matters may necessitate additional manpower or training. These needs are
monitored and acted upon by the Pipeline Integrity Manager.
The following elements ensure that personnel are qualified to address integrity
requirements:
Educational Background
Except for documented exceptions, all employees of the Pipeline Integrity

department shall have post-secondary education certification from an accredited
institution. The level of educational background required will vary depending
upon department needs and will be at the discretion of the Manager. On an as-
needed basis, post-secondary students will be hired to supplement temporary
needs.

Work Experience
Prior job history with other companies or experience within other Company
departments shall be used to evaluate the appropriateness of prospective new
employees. Performance management records or candidate references shall
provide guidance. Human Resources and other personnel may assist in
evaluating a candidate’s appropriateness but the final decision regarding the
hiring of an individual shall reside with the Manager.
Training
The nature of Pipeline Integrity work is intimately related to operational aspects

and as a result, field assignments are a necessity. Company communication
protocols, facilities operation, safety, and other skills are obtained during the field
assignments. Other training requirements for all Pipeline Integrity personnel are
assessed on an ongoing basis and are commensurately budgeted within the
Pipeline Integrity operating budget. Each employee is responsible for identifying
his or her professional development needs with assistance from the Manager but
it is the responsibility of the Manager to identify any competency gaps and
approve training requests. Training includes the following:
• new employee Company orientation

• specialized industry courses, seminars or conferences
• night courses
• in-house courses, seminars and demonstrations
• on-the-job training
• courses sponsored by vendors
• committee participation.
Mentoring
Senior members of the Pipeline Integrity Department are given supervisory

responsibilities and directly oversee the work of select department members.
This approach develops leadership qualities and ensures greater person-to-person
interaction. The reportees benefit by gaining from the knowledge and experience
of more senior employees. The Manager monitors the success of these working
relationships.
Performance Management
Appraisals serve to monitor each employee’s training and professional growth.

Performance appraisals are implemented as per Company protocol to document
development needs and training accomplished. Tools for tracking and recording
personnel training and qualification include the following:

• “TARGET” performance appraisals

• the “Pipeline Integrity Safety Training Spreadsheet”
• “Employee Training History” documentation
• the “Pipeline Integrity Course and Conference Listing”
• Human Resource Advisors
• personal resumes
• “Job Description Profiles”
• professional designations (i.e., “Professional Engineer”)
• the Pipeline Integrity Operating Budget
7.2 Codes, Standards and Procedures
All Enbridge pipelines are designed, constructed, and operated to meet stringent
safety and reliability codes, standards, and procedures set by multi-stakeholder
organizations which include regulators, industry organizations and the Company
itself. At many levels, from the high-level Enbridge corporate policy statement to
the detailed technical specifications regarding particular areas of integrity science
implementation, these documents formally define the requirements for
implementing work, documenting and reviewing results, and assigning
responsibilities to ensure that stipulations are strictly followed. Examples of
codes, standards, and procedures that have a key influence on the Enbridge
integrity management program are as follows:
• Enbridge Environment, Health and Safety Policy.

• National Energy Board (NEB) and U.S. Department of Transportation (DOT)
regulations.
• Canadian Standards Association (CSA) and American Petroleum Institute
(API) standards.
• Enbridge Operating & Maintenance Procedures manuals.
• Pipeline Integrity Department specifications.
• Enbridge Engineering Standards manuals.
• National Association of Corrosion Engineers (NACE), Canadian Energy
Pipeline Association (CEPA), and other industry consensus standards and
guidelines development organizations.
7.3 Continuous Improvement
The employment of applicable codes, standards and procedures leads directly to

the generation of operational data related to performance, incidents, areas of risk,
and changed conditions. This data is used by competent, experienced engineers
and technologists to amend integrity management procedures and accompanying
documents as required. Reviews of processes and key documents are conducted
with the intention of satisfying the following objectives:

• Reflect changes due to regulatory requirements.

• Change management related to pipeline reconfiguration.
• Incorporate better technologies or new developments in management
practices.
• Refine approaches as driven by new learnings from operational data.
• Optimize cost of activities.
Continuous improvement of the program also includes the audit of the entire
scope of the Pipeline Integrity Department which is formally facilitated by the
Enbridge Audit group or through audits conducted by regulatory agencies.
7.4 Document Management System
Document Management is an important component of an effective Integrity

Management Program. Pipeline integrity management activities generate large
volumes of information and this documentation must be readily accessible in
order to provide timely responses to both internal needs and external stakeholder
requirements. A “Pipeline Integrity Document Management System” has been
developed to organize electronic and paper documents, allowing for efficient
access to and the effective use of this information.
The system defines the handling of all formal information relating to the Pipeline
Integrity Department including specifications, reports, communications and
completed forms. The system defines the nomenclature for consistent filing of
documents and the mechanism for queries relating to document searches. The
following describes features of the system:
• Training of user guidelines is provided to all department employees.

• The filing index nomenclature is based on an alphanumeric structure that is
intuitive and consistently applied.
• Relevant e-mails are electronically filed within the database structure of
Lotus Notes, thereby increasing accessibility of communications for all
employees.
• Electronic reports, presentations, photographs and other documents are stored
on a department shared computer drive.
• Titles of key reports available only in hardcopy format are electronically
recorded to enhance document search capability.
• Various sets of data are transferred to on-line databases.
• Storage furniture (i.e., shelves, and cabinets) is strategically fixtured for
convenient filing and retrieval with consideration to ergonomics.
• Dated and rarely used binders and data scrolls are stored off-site to optimize
storage space usage. If needed, retrieval of the information is reliable and
prompt.
• Critical electronic information is backed-up and stored in a separate secure
area.
Documents and information not directly generated by the Enbridge Pipeline

Integrity Department but nonetheless relevant to pipeline integrity management

are maintained by respective departments within the company. The information

is stored and easily retrievable using methods developed by the respective
document owners. This information may include data related to pipeline design,
construction quality control, and condition monitoring such as temperatures and
pressures.
7.5 Performance Metrics
Performance metrics serve as a tool for evaluating the success of the integrity
management program. Enbridge seeks methods for gauging the extent to which
the principal objectives have been met. Several of the objectives are high-level
Company values that are not explicitly quantifiable. However, their success can
still be demonstrated in a formal and conveyable way that indicates whether
integrity management activities are either appropriate or require improvements.
Measuring results is a developing science at Enbridge and the following
summarizes how performance is currently evaluated:
Objective Performance Metrics

The pipeline Pipeline safety is the underlying purpose of the entire integrity management
system will be program and achievement is measured in terms of the success of its component
safe. programs and systems.
The primary metrics are those associated with the results of audits including
those conducted formally by regulatory agencies and the Enbridge Audit
Group or, informally, within the context of management systems which require
constant review of procedures through analysis of operational data.
The pipeline This objective describes the overall impression of the value pipelines bring to
system will be society.
perceived to be
safe. Useful metrics considered by Enbridge include public opinion polls conducted
by regulators or pipeline industry consensus groups, stakeholder feedback, and
benchmarking studies.
Minimal This parameter is evaluated on an ongoing basis during a variety of Company
customer planning forums that examine the impact of integrity programs and issues on
impact throughput and customer shipping requirements. Other logistics departments
lead these forums with participation by Pipeline Integrity personnel.
Achieve zero Leak history is monitored on an ongoing basis and trends are developed.
failures
Long-life asset This is a high-level objective that is manifest through the demonstration of
proper integrity management decisions rooted in fitness-for-purpose results,
defect growth rates, and frequency of resource implementation.
Use best This is a high level objective that is intrinsic to the overall process
technology implemented by engineers and technologists to conduct the necessary utility
analysis when making choices for the use of integrity tools.
Identify defects Metrics associated with this objective are related to the trending of defect
through depths or the pressure retaining capabilities of trended defects.
monitoring
Ensure cost Metrics associated with this objective includes cost-per-dig, operating cost
effectiveness management, and the ability to benefit from supply chain management.

7.6 Risk Assessment
Pipeline integrity risk management at Enbridge Pipelines is achieved through

hazard prevention. Monitoring and mitigation treatments are applied at a
frequency and extent that manages corrosion, cracking and other forms of
damage prior to exceeding fitness-for-purpose tolerances (pipeline condition is
regularly revalidated). Not only are the revalidation intervals set to ensure
defects are managed well before there is a risk related to a breach in the pipeline,
but also to ensure that program efficiency objectives are met. Exceeding these
program efficiency tolerances poses a variety of business risks that may result in
unscheduled and unbudgeted allocation of resources. For example, if tolerances
are exceeded, there is a potential that a pressure restriction may be applied,
thereby limiting operational flexibility and shipment delivery times. Or, it may
be necessary to divert funds from other planned Company activities to address a
reprioritization of maintenance plans.
In developing plans for integrity resource allocation, the qualified Engineer or

Technologist will begin by reviewing operational data that describes pipeline
condition. From this information, a decision will be made regarding the
selection, schedule and implementation of the appropriate integrity management
tool. This decision will consider the type, quantity and quality of information
currently available. To further establish the schedule and type of resources to be
applied, the Engineer or Technologist will consider the consequences associated
with exceeding tolerances and will integrate such information accordingly.
The typical approach for establishing integrity management strategies is rooted in

an understanding of defect growth rates but also incorporates a variety of
probabilistic analyses, fault tree evaluations, and relative risk rankings. Intrinsic
to this approach is data sensitivity analyses, which refine engineering calculations
describing defect growth rates. The data sensitivity analyses provide a
mechanism for identifying data sets that require improved precision thereby
driving the continuous improvement of the tools that are used to gather the defect
occurrence data. Not only is the defect management approach applicable to all
operating pipelines, but can also be used to assess risks associated with
reactivation of deactivated pipeline segments, or lines where defect occurrence
has not been delineated through in-line inspection.

SECTION 8.0 SUMMARY OF COMMITMENT
8.0 SUMMARY OF COMMITMENT
Maintaining a safe and reliable pipeline system is a top priority for Enbridge. The
Company’s strong safety record reflects the continuing commitment to build safe
pipelines and maintain their integrity throughout their operating life. Enbridge
endeavors to be an industry leader in the area of pipeline integrity as demonstrated by
the following:
• Implementing rigorous integrity maintenance programs.

• Participating in the development of national standards.
• Assisting with the development of industry recommended practices.
• Participating in forums for sharing and exchanging knowledge.
• Pursuing and supporting research.
This framework document is intended to communicate that Enbridge pipelines are

operated and maintained in a way that ensures pipeline reliability and safety. In
adopting the practices described in this document, the Enbridge employees are
accepting an important and demanding set of responsibilities. However, in fulfilling
these obligations, the Company derives significant benefits by succeeding in goals
regarding regulatory compliance, self-regulation, and public confidence. Through an
innovative pipeline integrity program, the Company achieves good standing in the
community in which it operates and with those with whom it does business.

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A0V5U9 - Response To NEB IR 2 Southern Access Upstream Expansion Appendix A

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TABLE OF CONTENTS

1.0 FOREWORD ................................................................................................................... 2

3.0 POLICY AND GOALS ................................................................................................... 5

7.0 MANAGEMENT SYSTEMS ................................................................................................ 22

8.0 SUMMARY OF COMMITMENT .......................................................................................... 29

Enbridge Pipeline Integrity Management Program

Integrity Management Program

Objectives Plans & Procedures & Management

Enbridge Pipeline Integrity Management Program Page 2

• Demonstrate corporate commitment and policy.

Excavation & repair

Enbridge Pipeline Integrity Management Program Page 3

Enbridge Pipeline Integrity Management Program Page 4

3.0 POLICY AND GOALS

Enbridge Pipeline Integrity Management Program Page 5

3.1 Principal Objectives

The pipeline system will be safe and perceived to be safe.

Enbridge will strive to achieve zero failures.

Continuously Improving Performance

2 Innovation better performance, sa me resource allocation

3 Innovation equal performance, fewer resources

Enbridge Pipeline Integrity Management Program Page 6

The pipeline will be reliable with minimal customer impact.

The pipeline system will be maintained as a long-life asset.

Preventative Maintenance at Set Intervals

Pipeline Strength Tolerance

Enbridge Pipeline Integrity Management Program Page 7

Liquid Pipeline Operating Pressure

Likelihood of Defect Occurrence

x x x x Unlikely (Moderate deterioration - repaired in a

Rare (Unacceptable occurrence - MOP reduced

Distance from Pump Station

Life cycle management approaches will guide resource allocation.

Enbridge Pipeline Integrity Management Program Page 8

Resources will be optimized to ensure efficiency.

Resource allocation must be conducted strategically to make best use of manpower,

Strategic financing of maintenance expenditures is part of running an effective program.

Historic and Forecasted Expenditures

Average Capital Spending

Average Operating Spending

Enbridge Pipeline Integrity Management Program Page 9

Innovative technology will be used to enhance pipeline integrity.

External Corrosion Defect Identification Tools

1 Cathodic Protection Survey 4 Standard Resolution In-Line Inspection

Enbridge Pipeline Integrity Management Program Page 10

Group Integrity Management Program Responsibilities

Materials Technology Integrity Programs Integrity Analysis

Engineers Supervisor, Engineers Supervisor, Engineers

Enbridge Pipeline Integrity Management Program Page 11

• Metal loss such as corrosion or gouging.

5.1 Planning Horizons

2. Medium-term plans that identify annual programs.

3. Project management planning.

Enbridge Pipeline Integrity Management Program Page 12

5.2 Planning Tools

A variety of planning mechanisms are utilized to facilitate the planning processes.

Operational Reliability Assessments

Formal strategy planning meetings are conducted on a regular basis. Operational

The Operational Risk Management Initiative

5.3 Planning Sequence

Enbridge Pipeline Integrity Management Program Page 13

Develop Long Range Plan

Submit annual budget