Compliance Verification Activity Report: CV1718-092 - Plains Midstream Canada ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector In Training 2331T
• Inspector 2523

Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Integrity Management

Related events:

• CV1819-110

Rationale and scope:

To verify compliance with the OPR and the Standard CSA Z662-15, and to follow up the corrective actions from the Board’s Notice of Non-Compliances identified in the compliance verification activities CVA 1415-225 and referenced in CVA 1516-368.

Compliance tool(s) used:

• Information Request (IR) (5)
• Notice of Non-compliance (NNC) (2)

Facility details

Facilities:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE]

Facility Types

• Pipeline
• Pump station

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Pigging
• Pressure Control
• Overpressure Protection
• Valves
• Buildings (Ventilation)
• Emergency Shutdown System
• Piping
• Flare and Drain System
• Electrical Workmanship
• Batteries and UPS

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

• The station is located in the Plains Midstream Fractionation Plant near Sarnia, Ontario. The following two Plains bi-directional pipelines are connected to the pump station: the 8” Kalkaska line and the 10” Eastern Delivery System (EDS) line. The station can be operated 24/7 locally from the station Motor Control Center (MCC) building and the Control Room to ship HVP NGL products such as Ethane, Propane and Butane. Station MOP is 1440 psi. PSV set pressure is 1440 psi.
   
• Asset Management: the station equipment maintenance information is managed using IBM Maximo software.
   
• Incident history: company representatives confirmed that the station did not experience any leaks or other incidents in recent years.
   
• Emergency Preparedness Plan: includes first aid and 911 call in case of emergency situation involving personnel.
   
• Fire and gas detection calibrations occur semi-annually for the MCC building.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 3. Safety and loss management systems
    • 3.1 General
      • 3.1.2 The safety and loss management system shall cover the life cycle of the pipeline system and shall include the following elements:
        a) clearly articulated policy and leadership commitment to the development and implementation of the safety and loss management system;
        b) an organizational structure with well-defined responsibilities and authorities that supports the effective implementation of the safety and loss management system;
        c) a process for the management of resources, including:
        i) the establishment of competency requirements;
        ii) a training program that includes a process for evaluating the effectiveness of the training provided and for maintaining training records; and
        iii) contractor selection and performance monitoring that ensures services are performed in a manner that conforms to the requirements of the safety and loss management system;
        d) an internal and external communication process that supports the effective implementation of the safety and loss management system;
        e) a document and records management process for the effective implementation of the safety and loss management system, including
        i) procedures for the control and distribution of documents; and
        ii) procedures for the control of records;
        f) operational controls, as applicable, for
        i) risk management;
        ii) design, material selection, and procurement;
        iii) construction;
        iv) operations and maintenance;
        v) pipeline system integrity management;
        vi) engineering assessments;
        vii) emergency preparedness, response, and recovery;
        viii) security management; and
        ix) deactivation and abandonment;
        g) a process for the management of change that includes
        i) the identification of changes that could affect the safety and loss management system;
        ii) assigning responsibilities and authorities for the review, approval, and implementation of changes;
        iii) documentation of reasons for the changes;
        iv) analysis of implications and effects of the changes;
        v) the documentation and communication of changes to affected parties; and
        vi) the timing of changes; and
        h) a process for continual improvement, including
        i) development of measurable objectives and targets;
        ii) a process for the reporting, collection, evaluation, and trending of data related to hazards, incidents, and near misses, including the communication of any findings and actions;
        iii) a process for learning from events;
        iv) performance monitoring against objectives and targets;
        v) conformance monitoring, including periodic audits, to assess conformance with the requirements of the standard and the safety and loss management system;
        vi) procedures for the control of non-conformances, including procedures for defining responsibility and authority, for handling and investigating non-conformance, taking action to mitigate any impacts, for initiating and completing corrective and preventive action, and for evaluating the effectiveness of any actions taken; and
        vii) management reviews of the safety and loss management system at planned intervals to ensure its continuing suitability, adequacy, and effectiveness. The management review shall include an assessment of opportunities for improvement and the need for changes to the safety and loss management system, its policy and objectives.
        Notes:
        1) Annex A sets out a recommended practice and provides additional guidance for a safety and loss management system.
        2) CSA Z246.1 provides guidance on developing security management systems.

Company action required:

NEB Staff observed that the station operators (in the Control Room) could not provide reasonably fast and consistent answers to a number of questions regarding the day-to-day operation of the station such us the description of the pipelines entering and exiting the station and the control levels/hierarchy of the station’s control locations (i.e. the MCC Building, Control Room, Windsor Control Center, etc.).

Provide the following:
 

1. Relevant copies of the Plains’ procedures related to the operation of the station (i.e. start up and shutdown in normal and emergency situations, systems and levels of control, etc.).
2. Confirmation whether or not the operation of the station has ever been audited (i.e. by a third party for instance)?
   If the answer is yes, please provide a copy of the last audit report.

Due date: 2017-05-31

Date closed: 2017-06-29
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 - Station power system (General)

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Emergency Shutdown System
• Electrical Workmanship
• Batteries and UPS

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

• The Station is composed of two 4-stage centrifugal pump units (P210 and P220) of 700 HP electric power each. At the time of the inspection, both pump units were out of service for planned maintenance overhaul. Pump units did not appear to have unit ESD systems.
   
• Alternate Source of Power (ASP): In compliance with the requirements of OPR section 12 and CSA Z622-15 section 4.14.3.3, following the Board’s Notice of Non-Compliance (NNC) issued during the inspection CVA 1415-225, one ASP of 60 KW, 480V was installed on 24 November 2016. The ASP is inspected and function tested monthly. One manual Emergency Shutdown System (ESD) push-button was installed. The station also has one ESD in the MCC room and one in the Control Room. Each component of the ESD system are function tested at least once per year. Valves involved in emergency shutdown are inspected, lubricated and tested in a semi-annual basis. A UPS with the capacity of XXX? h is available for maintaining essential electrical lightning and control service during power outage from both electrical grid and the ASP.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 4. Design
    • 4.14 Design of compressor stations over 750 kW and pump stations over 375 kW
      • 4.14.3 Design of pump stations over 375 kW
        Note: While the requirements of this Clause apply to the design of stations over 375 kW, consideration should also be given to applying these requirements to the design of smaller stations.
        • 4.14.3.9 Additional safety and protective devices shall be subject to the following requirements:
          a) Pump unit prime movers other than electrical induction or synchronous motors shall have automatic devices to shut down the units before the speed of either the prime movers or the driven units exceeds the maximum safe speed established by the respective manufacturers.
          b) Crankcases of gas engines in pump stations shall be equipped with explosion doors or suitable crankcase ventilation.
          c) Mufflers for gas engines in pump stations shall have vent slots or holes in the baffles of each compartment to prevent gas from being trapped in the mufflers.
          d) Pump units shall have shutdown or alarm devices that operate in the event of inadequate cooling or lubrication of the units.
          e) Thrust loads and moments imposed on mechanical equipment shall not exceed the manufacturer’s recommended values or, where such recommended values are not available, the limits specified in API 610 for pumps.
          f) Positive displacement pumps that have the capability of overpressurizing the station piping shall have an automatic high-pressure unit-shutdown device. The high-pressure-sensing point shall be located between the pump and the first block valve on the discharge side of the pumping unit.
          g) Centrifugal pumps that have the capability of overpressurizing the station piping shall have an automatic high-pressure unit-shutdown device. Sensing points shall be located where the shutoff head of the pumps exceeds the pressure rating of the piping.
          

Company action required:

During the inspection, NEB Staff requested the description of the station UPS and to demonstrate how the design of the pump unit meets the requirements of Z662-15, clause 4.14.3.9 d) which states that pump units shall have shutdown or alarm devices that operate in the event of inadequate cooling or lubrication of the units. Plains representatives committed to provide the responses as action items.

Please provide the following:

1. The capacity of the UPS; and
2. Year of installation for both pump units and a copy of the Process & Instrumentation Diagram related to instrumentation sensors (i.e. temperature and vibration elements, etc.);

Due date: 2017-05-31

Date closed: 2017-11-08
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 3 - Station power system (Information Request)

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Emergency Shutdown System

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

NEB Staff observed that the station pump units appeared to have no individual emergency shut down systems originating from suitable located, manually operated stations in order to bring the units safely to a complete stop as quickly as practical. NEB Staff requested Plains to demonstrate that the station pump units compliy with this requirement.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 4. Design
    • 4.14 Design of compressor stations over 750 kW and pump stations over 375 kW
      • 4.14.3 Design of pump stations over 375 kW
        Note: While the requirements of this Clause apply to the design of stations over 375 kW, consideration should also be given to applying these requirements to the design of smaller stations.
        • 4.14.3.6 Pump units shall have individual emergency shutdown systems originating from suitably located, manually operated stations in order to bring the units safely to a complete stop as quickly as practical. The electrical, hydraulic, and pneumatic circuits to the normal unit shutdown auxiliaries shall be maintained.

Company action required:

Demonstrate how the station pump units comply with the requirement of CSA Z662-15 section 4.14.3.6.

Due date: 2017-05-31

Date closed: 2017-05-15
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 4 - Station piping (General)

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Piping

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

• The below ground piping is coated with XXX? and above ground piping with XXX?.
• There is a three year program to inspect and mitigate soil to air interface coating/protection.
• Some pipe supports did not appear to have appropriate isolation between the pipe and the support.
• Some piping did not have clear signs indicating its function.
• Major valves were not labelled with their function and open/close positions were not clearly marked.
• Few flanges had packing and tape around them, however some tape appeared to be peeling away.
• Cathodic Protection (CP) System: The station has a CP System which maintenance program includes monthly rectifier, bi-monthly critical bond check and yearly annual survey.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.3 Application and inspection of external protective coatings for buried or submerged piping
      • 9.3.3 Except as allowed by Clause 9.3.4, coated piping shall be inspected during or after installation to detect coating defects.

Company action required:

Tape wrapping of flanged connections

NEB Staff observed that a number of the station piping flanged connections were tape wrapped/covered. Plains representatives committed to file additional details regarding the reason of this wrapping.

Provide a detailed description of the rationale of these wraps. Specify if Plains has recorded any corrosion issues due to water and/or moisture insertion underneath the wraps. Also specify if Plains has implemented any inspection program to verify the integrity of the area underneath the wraps.

Due date: 2017-05-31

Date closed: 2017-11-08
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 5 - Station piping (Information Request related to CP System survey report)

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Piping

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

NEB Staff observed that isolation in between the pipe and the pipe supports was missing or misplaced. NEB inspectors are of the view that this may trigger insufficient protection against potential electrical contact between the piping and its supports, and affect the effectiveness of the CP system.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.6 Electrical Isolation
      • 9.6.2 Electrical contact between pipe and other metallic structures shall be considered in the design and
        maintenance of the cathodic protection system.

Company action required:

Provide the following information:

1. The last annual CP System survey report of the station, including the measurement dates, values, mitigations (if any) and results; and
2. The schedule (plan) for inspection of potential atmospheric corrosion and other potential issues related to piping at the station.

Due date: 2017-05-31

Date closed: 2017-11-08
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 6 - Station piping (Notice of Non-Compliance related to the open and close positions of valves)

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Valves
• Piping

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

NEB Staff observed that the open and close positions and the function were not clearly marked on isolation valves and other major valves within the station.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 36. A company shall
    • (e) clearly mark the open and closed positions and the function of isolating valves, blow-down valves and other major valves within a pipeline station; and

Company action required:

Plains is required to clearly mark the open and closed positions and the function of isolating valves and other major valves within the station.

Due date: 2017-05-31

Date closed: 2017-11-08
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 7 - Station piping (Notice of Non-Compliance related to identification of station piping)

Date & time of visit: 2017-04-27 15:00

Discipline: Integrity Management

Categories:

• Facilities
• Piping

Facility:

• AMOCO CANADA SARNIA FRACTIONATION PLANT AND PUMP STATION [SARNIA DOWNSTREAM SYSTEM (SDS) - 8" LPG PIPELINE] (Facility)

Observations:

 
NEB Staff observed that a number of the station piping was not clearly identified to indicate its function.

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

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 4. Design
    • 4.14 Design of compressor stations over 750 kW and pump stations over 375 kW
      • 4.14.3 Design of pump stations over 375 kW
        Note: While the requirements of this Clause apply to the design of stations over 375 kW, consideration should also be given to applying these requirements to the design of smaller stations.
        • 4.14.3.8 Pump station piping shall be subject to the following requirements:
          a) Pump station piping other than instrument, control, and sampling piping shall be made of steel.
          b) The designer shall avoid dead-ended piping unless corrosion is mitigated in such piping sections. Consideration shall be given to sizing piping to maintain a flow velocity sufficient to minimize the accumulation of water and sediment.
          c) Emergency valves and controls shall be clearly identified by signs. Aboveground piping shall be clearly identified to indicate its function.
          d) Each type of piping system or a portion of a piping system within pump stations may be designed as specified in ASME B31.3, provided that the code or standard is so used in its entirety and design code or standard breaks are specified.
          Notes:
          1) All other requirements in Clause 4 relating to pump station design are applicable.
          2) Examples of types of piping systems included are those for main service fluids, lubricating oil, water, steam, processing, and hydraulic fluids.
          

Company action required:

Plains is required to clearly identify aboveground piping to indicate its function (where the identification is missing or damaged).

Due date: 2017-05-31

Date closed: 2017-11-08
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.

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: