Compliance Verification Activity Report: CV1819-277 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1819-277
Start date: 2018-06-06
End date: 2018-06-07

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:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

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:

Maximum interval is 18 month for the completion of these tasks of the annual plan.
 
Site visit:
Sump tank: TNPI indicated that the sump tank level is monitored. There is an alarm triggered at the High (H) level and a station Emergency Shut Down (ESD) is triggered when the High High (HH) level of the tank is reached.
 
Station piping condition was in fair condition with some piping areas showing signs of external corrosion, but nothing significant observed. Station piping was properly supported.
 
Pumps are equipped with seal leak detection pressure switches. Upon seal leak detection, the pump unit is shut down and isolated.
 
The pump building houses two pump units. The pump building is equipped with gas detection. At 20% of the Lower Explosive Limit (LEL), an alarm is initiated. At 40% LEL, a station ESD is initiated.  The pump building is also equipped with fire detection. If a fire is detected, a station ESD is initiated. There is no forced ventilation in the pump building.
 
There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves during a power loss event.
 
The station is equipped with station ESD push buttons located near the site main gate and in the pump building. There is also a pump unit shutdown switch near the pump unit.
 
On the piping connected to a thermal relief valve (TRV065) and the sump tank, it was observed the use of a flexible hose, which is made of steel as required by CSA Z662-15 clause 4.14.3.8 (a). This issue has already been identified in a recent inspection (1819-120) and is being addressed through that activity.
 

Compliance tool used: No compliance tool used

Observation 2 - Belleville Meter Station

Date & time of visit: 2018-06-07 08:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

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:

Maximum interval is 18 months for the completion of these tasks of the annual plan.
 

Compliance tool used: No compliance tool used

Observation 3 - Brighton Pump Station

Date & time of visit: 2018-06-07 10:15

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. 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:

Maximum interval is 18 month for the completion of these tasks of the annual plan.
 
Site visit:
Sump tank: TNPI said that sump tank level is monitored. There is an alarm triggered at the High (H) level and a station ESD is triggered at the High High (HH) level.
 
Station piping condition was in fair condition and station piping was properly supported.
 
The pump building houses one pump units. The pump building is equipped with gas detection. At 20% of the Lower Explosive Limit (LEL), an alarm is initiated. At 40% LEL, a station ESD is initiated.  The pump building is also equipped with fire detection. If a fire is detected, a station ESD is initiated. There is no forced ventilation in the pump building.
 
The pump is equipped with a seal leak detection pressure switch. Upon seal leak detection, the pump unit is shut down and isolated.
 
There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves during a power loss event.
 
The station is equipped with station ESD push buttons located near the site main gate and in the pump building. There is also a pump unit shutdown switch near the pump unit.
 

Compliance tool used: No compliance tool used

Observation 4 - NNC - Valves Upstream of Thermal Relief Valves

Date & time of visit: 2018-06-06 12:20

Discipline: Integrity Management

Categories:

Facility:

Observations:

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

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