Compliance verification activity type: Field Inspection
Team:
Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Operating company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Fort Nelson Gas Plant: Follow-up to non-compliances identified in 1516-221 & to corrective actions implemented as per INC2013-160 [Follow-up to discuss how company addresses buried piping, maintenance, and verify that repairs had been made on concrete footing supporting overhead flare line (identified during 1516-221); Follow-up to corrective actions implemented for INC2013-160]
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Discussion - Buried Piping Inspection Program
Date & time of visit: 2017-09-27 09:30
Discipline: Integrity Management
Categories:
Facility:
Observations:
Westcoast stated that the buried piping integrity digs will be occurring only on the high risk lines (raw gas inlet and sour gas lines) related to the operation of the E & F process trains as the C, D, G and H trains are planned for deactivation upon completion of the 2017 maintenance turnaround, and a Train C& D sweet gas line. It also stated that cathodic protection (CP) surveys are conducted annually on the buried piping as part of integrity management. NEB inspectors note that the integrity digs are a corrective action identified from the 03 March, 2016 integrity inspection.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
1. Westcoast shall provide procedure(s) that demonstrate how maximum safe operating/dig pressures are determined and implemented for in-service piping undergoing integrity evaluations, including hazards such as whether minimum allowable wall thickness is taken in to consideration prior to conducting sand blasting activities.2. Westcoast shall demonstrate that the written comments identified for line number "HCD-4-F3S-314 to East Flare Pit" were addressed per the highlighted sections in the buried piping inventory from 2015 integrity digs.3. Westcoast shall confirm if the buried high risk raw gas and sour gas lines will remain charged under pressure with the gas while the C, D, G and H trains are in a deactivated state.4. If the C, D, G and H trains buried high risk raw gas and sour lines are to remain charged under pressure, Westcoast shall demonstrate how it has determined that the lines are no longer considered high risk due for inspection per it's original 5 year inspection plan and how it will address this risk.5. Westcoast shall provide a copy of the most recent CP survey reports including comments and recommendations noted in the report.
Due date: 2017-11-17
Date closed: 2017-12-15 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Reason closed: Requirement met
Compliance achieved: Yes
Observation 2 - Notice of Non-Compliance: Buried Piping Inspection Program
Date & time of visit: 2017-09-27 12:00
See "Discussion - Buried Piping Inspection Program" and IR response by Enbridge/Westcoast.
Compliance tool used: Notice of Non-compliance (NNC)
Enbridge/Westcoast shall develop a procedure shall that details how safe excavation pressures are established and highlight any mitigation actions that are implemented to deal with uncertainties such as, but not limited to, not knowing the integrity condition of the piping and/or its attributes such as coating, grade, etc. The procedure will lead to the development of a documented assessment endorsed by a person competent in buried piping inspections that demonstrates the piping is safe to enable personnel to perform excavation or evaluations (such as sand blasting) at the specified pressure. In addition, the procedure and assessment would also include consideration for abnormal or upset conditions.Refer to communication Re: FNGP Buried piping evaluation issue between Joe Paviglianiti and Ryan Sporns as dated December 14, 2017.
Due date: 2018-02-09
Date closed: 2018-03-01 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Observation 3 - Buried Piping Inspection Program - IR Round 2
1. Westcoast shall file its formal deactivation plan to the NEB at a reasonable future date.2. Westcoast shall provide the date in which it will complete the inspections and the integrity evaluation of the C, D, G and H high risk buried piping as committed to under its Corrective Action Plan (CAP) per CVA 1516-221 in order to remain in compliance. In addition, , Westcoast shall provide a Fitness For Service (FFS) assessment that demonstrates that the integrity and condition of the piping(s) is suitable beyond the date identified in its original CAP committement and unitl the piping will be inspected.Note: Westcoast's CAP committment related to the original Notice of Non-Compliance (NNC) identified during NEB inspection CVA 1516-221 indicated that inspection of the high risk buried piping would be completed by end of Q4 2017. This CAP committment has not been met.3. Westcoast shall confirm whether all the recommendations identified in the "FNGP 2017 CP SURVEY REPORT" were implemented. If the recommendations were not implemented, provide rationale.
Date closed: 2018-10-26 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Observation 4 - Discussion - Valve Maintenance
Date & time of visit: 2017-09-27 10:00
NEB inspectors noted several valves that were identified as not being serviced based on comments in September 2015 service report from Cameron valves. Several valves within the report were also identified for repair at the next shutdown (s/d) opportunity, e.g., Tag # 254 and #255 (“F – Cont. LCV Downstream” and “E – Regen FCV Upstream”). Also noted were several valves identified as not being serviced in the E & F and G & H trains per the 2017 Cameron Valve service report.
Observation 5 - Valve Maintenance - IR Round 2
Date & time of visit: 2017-09-27 00:00
See "Discussion - Valve Maintenance" and IR response by Enbridge/Westcoast.
1. Westcoast shall provide an explanation stating why the valves in question were not serviced during better weather conditions and provide a date when the servicing will be completed.
Observation 6 - Discussion Point - C & D Amine Still Ooverhead Condensers: – INC 2013 – 160
In the last inspection of the condensers done in 2013, the count of plugged tubes was:
Observation 7 - Discussion Point - Deactivation/Turnaround
Westcoast stated that it utilizes its management of change (MOC) process in executing the deactivation of its process trains, and that the MOC will capture identified items to be reviewed, including the required actions prior to future reactivation of equipment in the trains. Westcoast stated that the plant will be undergoing turnaround maintenance, scheduled to begin in October 2017, and that turnaround activities, including equipment scheduled for maintenance and repair are tracked via SAP.
Observation 8 - Discussion Point - Integrity Management Program
Westcoast stated that it adopts the 2009 version of ABSA AB-506, Inspection & Servicing Requirements for In-Service Pressure Equipment, for its Integrity Management Program (IMP).
Observation 9 - Integrity Management Program - IR Round 2
See "Discussion - Integrity Management Program" and IR response by Enbridge/Westcoast.
Westcoast shall provide the assessment, referenced in the IR response related to the the requirements of AB-506 section 11.3, that demonstrates that the 4 year inspection interval for its sour service vessels is acceptable.
Observation 10 - Discussion Point - Hazard Identification
Westcoast stated that an initial Hazard Operability (HAZOP) Assessment has been recently completed across the plant with the exception of the effluent and power house areas. It further stated that the HAZOPs are facilitated by an external consultant and requires the attendance of plant subject matter experts (SME’s) e.g., engineers and operations personnel.
Date closed: 2018-11-02 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Observation 11 - Notice of Non Compliance: Hazard Identification
Westcoast has not mitigated a high risk hazard identified in the 12 January 2017 HAZOP report (#62) as the status of the recommended action item remains open as indicated in the HAZOP Status Report.
1. For all Level I, II and III items, Westcoast shall provide a timeline for implementation of the HAZOP recommendations per the original request from the NEB Inspection Officer. See "Discussion Point - Hazard Identification".2. Westcoast shall describe the factors taken into consideration to reduce the risk ranking of #61 from Level I to Level II.
Observation 12 - Field observations - Maintenance Tags
Date & time of visit: 2017-09-27 13:00
NEB inspectors noted maintenance tags on equipment that were out of date and illegible
Observation 13 - Notice of Non Compliance: Maintenance Tags
Westcoast has failed to demonstrate the implementation of an effective records systems for monitoring components and mitigating identifiable hazards in the facility.See "Field Observations - Maintenance Tags" and IR response by Enbridge/Westcoast.
Westcoast shall confirm and provide evidence that all maintenance tags identified for removal have been removed and that its computerized maintenance management system used for tracking, prioritizing and planning has been updated to reflect the actions identified on the maintenance tags.
Due date: 2018-06-29
Observation 14 - Maintenance Tags - IR Round 2
See "Field Observations - Maintenance Tags" and IR response by Enbridge/Westcoast.
Westcoast shall provide a copy of the C & D worklist.
Observation 15 - Field observations - Coating loss and external corrosion
Poor coating and external corrosion was observed on air to soil interface piping. Coating loss and corrosion was observed on several above ground process pipes.
1. Westcoast shall provide the procedure used to evaluate and address corrosion and piping integrity on air to soil interface piping locations and demonstratte how this procedure has been implemented.2. Westcoast shall demonstrate how it addresses external corrosion on its above ground process piping where there has been loss of coating.
Date closed: 2018-10-31 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Observation 16 - Notice of Non Compliance - Coating loss and external corrosion
Westcoast does not have a formalized procedure specific to evaluating and addressing corrosion on piping air to soil interfaces.Westcoast has not fully implemented its Standard Operating Procedure (SOP) for the inspection of above ground process piping that includes the requirement for external visual inspection to capture hazards such as external corrosion.See "Field Observations - coating loss and external corrosion" and IR response by Enbridge/Westcoast.
1. Submit a copy of the final Underground Piping Inspection Requirements Procedure. Westcoast shall provide evidence of completed implementation of its Underground Piping Inspection Requirements Procedure that demonstrates that the pipe air to soil interfaces have been evaluated. In addition,2. Provide the final revised Standard Operating Procedure (SOP) for inspection of above ground process piping that includes requirements to capture hazards such as external corrosion. Westcoast shall provide evidence of a completed implementation of its SOP that demonstrates that the inspection of above ground process piping is being conducted.
Observation 17 - Field observations - Thickness Monitoring Locations
No Thickness Monitoring Locations (TML’s) were identified on the C & D inlet raw gas feed line and the inlet separator. It was not confirmed if the TML's were present in the E & F trains inlet raw gas feed line and inlet separator.
1. Westcoast shall demonstrate how it monitors the integrity, including wall thickness and corrosion rate, of the C & D inlet raw gas feed line.2. Westcoast shall provide a copy of the most recent inspection report of the C & D inlet raw gas feed line and inlet separator.3. Westcoast shall complete the actions identified in 1) and 2) for the E & F inlet raw gas feed line and inlet separator.
Observation 18 - Notice of Non Compliance: Thickness Monitoring Locations
See "Field Observations - Thickness Monitoring Locations" and IR response by Enbridge/Westcoast.Westcoast has not demonstrated that it can effectively measure the remaining wall thickness which is used to evaluate the integrity of the piping.
1. In light of the fact that Westcoast does not have an effective TML monitoring program for the C/D inlet raw gas piping, Westcoast shall demonstrate that the C/D inlet raw gas piping integrity is currently acceptable for its current service by 9 February 2018.2. Westcoast stated it will improve its preventative maintenance program with respect to the corrosion surveys by end of 2018. "The TML data includes a negative corrosion rate for the inlet raw gas feed line due to varying locations for TML readings, coating interference, external corrosion interference, equipment accuracy, and taking only one data point at each TML instead of using a grid. The PMs outlining the requirements for corrosion surveys are being updated for active equipment at FNGP by the end of 2018. These known issues will be addressed as part of this improvement effort." Considering that corrosion surveys are a key component to evaluating piping integrity, Westcoast shall provide the revised PM that demonstrates Westcoast has incorporated relevant and effective TML data measurement and collection requirements by 29 June 2018.
Observation 19 - Field Observation - Corrosion on FX inlet separator valve
External corrosion was observed on the body, including severe corrosion the body bolts and nuts, and the adjacent flange of the FX Train inlet separator isolation valve.
Observation 20 - Notice of Non Compliance: Corrosion of FX inlet separator valve
See "Field Observation - Corrosion of FX inlet separator valve" and IR response by Enbridge/Westcoast.Note the valve referenced in the inspection has been isolated and is currently not in service.
Westcoast's current valve inspection practices did not identify or evaluate corrosion on the body and bolted body connections. Westcoast states that the requirement to inspect external corrosion of the valve bodies, flanges and bolting is part of its Valve Integrity Program currently being developed under it Asset Strategy Development Process due for completion by 2018. Note that the NEB recommends that Westcoast consult with the manufacturer when developing the acceptability criteria.
Observation 21 - Field Observation - Integrity dig
A dig site with two exposed pipes from a recently completed buried piping integrity inspection in the E & F Trains was observed.
1. Westcoast shall provide results of the dig inspection and confirm if a 360º inspection was performed on the pipe.
Observation 22 - Field Observation - Quick opening and closure devices
No local pressure monitoring device such as a pressure gauge was present on the C & D sales gas dust filter. It appeared that the bleeds on the quick opening closures were different on each filter
Observation 23 - Notice of Non Compliance: Quick opening and closure devices
See "Field Observations - Quick opening and closure devices" and IR response by Enbridge/Westcoast.Enbridge/Westcoast failed to provide procedures as requested.
1. Westcoast shall develop a procedure and submit it to the NEB by the date specified.2. Westcoast shall provide the job specific task records of the last time this quick opening closure devise was opened. This documentation shall demonstrate how the operations group prepares and proves there is zero energy before opening of the quick opening closure.3. Westcoast shall provide the job specific task records for the opening of another quick opening component at the FNGP to enable comparison.
Observation 24 - Field Observation - Sealed vent piping
NEB inspectors noted a piece of piping vertically shooting from the ground which appeared to be covered and improperly sealed with duct tape and gunny sack. A second adjacent piece of pipe appeared to be properly sealed with a lid cover.
Westcoast shall provide a description of the material used to seal and cover the vertical vent pipe piece and confirm if the material used is appropriate.Westcoast shall confirm if the pipe is in an active state and the purpose of the pipe.
Date closed: 2018-11-08 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Observation 25 - Field Observation - Deactivation activities
NEB inspectors visually observed the blinded C & D acid gas reflux accumulator piping and the blinded C & D raw gas inlet line, which are part of the deactivation activities.
Compliance tool used: No compliance tool used
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program