Compliance Verification Activity Report: CV1617-190 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1617-190
Start date: 2017-02-13
End date: 2017-02-15

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Pump Station Inspection - Inspect facilities between Edmonton and Blackpool; Majority of the system has been recently inspected.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Stony Plain Pump Station

Date & time of visit: 2017-02-13 12:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

Stony Plain Pump Station

Sump and Additional ContainmentPump BuildingMCC Room

Compliance tool used: No compliance tool used

Observation 2 - Gainford Pump Station

Date & time of visit: 2017-02-13 14:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The station was fenced with company and emergency number listed at the entry gate. The site contained a decommissioned tank that was not within the inspection's scope.

The station was built in 1957 and has three 2000 horsepower pumps

Staff confirmed with company staff the control logic in the event of an Emergency Shutdown (ESD). Staff observed the pump station ESD. This station is equipped with a backup generator to provide power to operate the valves in the case of a power outage during an ESD.

Staff observed that each pump unit had dual gas detectors, one above and one below grade, as well as fire detectors. Staff confirmed that these detectors were tested on a six month basis.

The sump at this station is a steel tank with secondary containment provided by a concrete vault within a building equiped with gas detection and venting. The sump level is monitored by radar detection with HI and HIHI alarms. Staff confirmed that the sump is inspected on a five year basis with third party inspection of the tank and vault.

Staff confirmed that the station valves in the mainline valve building are tested annually, they have a visible position indicator, and are locked. Staff observed that there is redundant pressure monitoring on the station discharge pressure.

It was observed that the Flammables Storage Shed did not have hazard signage. Company representatives indicated that the signs were at the Jasper station and to be installed.

Compliance tool used: No compliance tool used

Observation 3 - Chip Lake Pump Station

Date & time of visit: 2017-02-15 09:15

Discipline: Integrity Management

Categories:

Facility:

Observations:

The station was fenced with company and emergency number listed at the entry gate. The station is fenced and has two egress gates with panic hardware in addition to the main gate.

The station has the variable frequency drive (VFD) pumps.

Staff confirmed with company staff the control logic in the event of an Emergency Shutdown (ESD). Staff observed ESD push buttons for the pump station. This station is equipped with a backup generator to provide power to operate the valves in the case of a power outage during an ESD.

Staff observed that each pump unit had gas and fire detectors, unit shutdowns, and discharge pressure transmitters. Staff confirmed that the detectors were tested on a six month basis.

Staff inspected the flammable storage shed and MCC building

Compliance tool used: No compliance tool used

Observation 4 - Hinton Pump Station

Date & time of visit: 2017-02-14 13:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Hinton Pump Station

Piping and componentsSump and Additional ContainmentPump BuildingMCC Room

Compliance tool used: No compliance tool used

Observation 5 - Gainford, Stony Plain, and Chip Lake - Non-Smoking Signage

Date & time of visit: 2017-02-13 14:10

Discipline: Integrity Management

Categories:

Facility:

Observations:

It was observed that signs indicating that smoking is prohibited were not displayed at the pump station. This is a non-compliance to CSA Z662-15 clause 10.5.4.2.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company to install signs indicating that smoking is prohibited in hazardous areas.

Due date: 2017-03-28

Date closed: 2017-06-09
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 6 - Gainford Pump Station - Storage of Lubricants

Date & time of visit: 2017-02-13 14:10

Discipline: Integrity Management

Categories:

Facility:

Observations:

It was observed that lubricants, in excess of the requirements for day use, were being stored inside of the pump station building. This is a non-compliance to CSA Z662-15 clause 10.9.1.5.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company to remove lubricants in excess of day use from the pump building.

Due date: 2017-03-28

Date closed: 2017-06-09
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 7 - Chip Lake Pump Station - Pipe Support

Date & time of visit: 2017-02-15 09:15

Discipline: Integrity Management

Categories:

Facility:

Observations:

It was observed that the suction and discharge loops were not isolated from the support structure where the I-beams welded to the sleeve contacted the support.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please confirm if the isolation has been identified as an issue and when it will be remedied.
Alternatively, if the isolation is not to be restored, confirm how this meets the requirements of CSA Z662-15 9.6.1 and 9.6.2.

Due date: 2017-03-28

Date closed: 2017-06-09
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 8 - Hinton Pump Station - Pipe Support

Date & time of visit: 2017-02-14 14:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

It was observed that the second section of pipe before the check valve was not in contact with the support at that location.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please detail how the pipe is adequately supported or provide a timeline for when the support will be remedied.

Due date: 2017-03-28

Date closed: 2017-06-09
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 9 - Chip Lake Pump Station - Pipe Support IR #2

Date & time of visit: 2017-02-15 09:15

Discipline: Integrity Management

Categories:

Facility:

Observations:

Trans Mountain confirmed through a first set of IRs related to pipe support and isolation at Chip Lake Pump Station that isolation was identified as an issue at a support structure.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Confirm whether Trans Mountain has inspected the remainder of the Chip Lake site to ensure that pipe isolation issues are not present elsewhere.
  2. Describe how Trans Mountain evaluates its sites to ensure that isolation is not an issue elsewhere.

Due date: 2017-06-07

Date closed: 2017-06-09
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

Observations (company follow-up required)

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