Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans-Northern Pipelines Inc.
Operating company: Trans-Northern Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Integrity inspection on pump and meter stations to verify compliance to NEB OPR, CSA Z662-16 and Board Orders AO-002-SO-T217-03-2010 and AO-003-SO-T217-03-2010.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Castleton Pump Station
Date & time of visit: 2018-06-06 12:20
Discipline: Integrity Management
Categories:
Facility:
Observations:
Station overview: TNPI presented the pump station overview. TNPI explained that as a result of the transient over pressure analysis, a new 4 inch bypass was installed recently on the station. It is not yet commissioned and the Piping and Instrumentation Diagram (PID) for the station still needs to be updated and will be completed as the upgrade projects gets completed. Set points checking of equipment in operation:Except for pressure control valve PV-020 (only visible or controlled via SCADA system) that was not observed on site, all the set points were consistent with the set points reported on PID (drawing CA-M-51 rev 01) and were in compliance to the order AO-002-SO-T217-03-2010. NEB inspectors verified a sample of records for the inspection and testing of pressure / temperature transmitters. All tests were done according TNPI maintenance plan. Staff also asked TNPI to show the number of work orders for the station since 2017, 38 work orders were edited and have been executed (closed).Maintenance of pressure control and overpressure protection systems:
Compliance tool used: No compliance tool used
Observation 2 - Belleville Meter Station
Date & time of visit: 2018-06-07 08:30
Station overview: TNPI presented the meter station overview. The HMI at this station is not updated so as to be consistent with PID BV-M-25-1 and 2 but, as modifications are still on going on the station, TNPI said it will be updated later as the upgrade project gets completed. Set points:P-15 and p-20 High (H) is 91 psig which is consistent with PID which is the same for all others set points. NEB inspectors verified a sample of records for the inspection and testing of pressure / temperature transmitters. All tests were done according TNPI maintenance plan. Maintenance of pressure control and overpressure protection systems:
Observation 3 - Brighton Pump Station
Date & time of visit: 2018-06-07 10:15
Station overview: TNPI presented the pump station overview. TNPI explained that as a result of the transient over pressure analysis, a new 4 inch bypass was installed recently on the station. The bypass is in operation. Set points checking of equipment in operation:NEB inspectors verified a sample of set points and they were consistent with the set points on the PID and were in compliance to the order AO-002-SO-T217-03-2010. NEB inspectors verified a sample of records for the inspection and testing of pressure / temperature transmitters. All tests were done according TNPI maintenance plan. Maintenance of pressure control system:
Observation 4 - NNC - Valves Upstream of Thermal Relief Valves
At the Castleton, Belleville and Brighton stations, NEB inspectors noted that the Thermal Relief Valves (TRVs) had valves upstream of them that were not locked, car-sealed or other otherwise designed to prevent their unauthorized closure. TNPI staff explained that they use a tag to indicate that those valves needs to be “normally open”. NEB inspectors observed that the tags color was faded and they were not providing a clear warning. Also, NEB inspectors are of the view that such a tag is not a sufficient control to prevent the unauthorized closure a valve upstream of a pressure relief device and therefore does not comply with CSA Z662-15 clause 4.18.2 (e).
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
TNPI will update its procedures and have TRV isolation valves car sealed at all TNPI facilities by October 31st 2018.
Due date: 2018-10-31
Date closed: 2018-12-03 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
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