Compliance verification activity type: Field Inspection
Team:
Regulated company: ExxonMobil Canada Properties
Operating company: ExxonMobil Canada Properties
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Goldboro Gas Plant integrity inspection
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Additional Project-specific requirements or conditions:
Observation 1 - Plant Field Inspection
Date & time of visit: 2017-03-09 10:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
· Plant was operating at 3317 E3M3/D load (maximum rate is 17,000 E3M3/D) at the time of inspection. The Plant’s inlet operating pressure (from the Sable Offshore Pipeline) was 6700 kPa and the discharge pressure (to the Maritimes & Northeast Pipeline) system was 8460 kPa. No operational concerns were noted.· Surface Water Run-off Pond: Water level was low as illustrated in Figure 1 (see the attached file: CVA 1617-094 - Exxon Mobile Goldboro Gas Plant Inspection - Photos). EM provided that the groundwater around the pond is periodically monitored for any leaching, and no indication has ever been recorded. The contained water is analyzed for pH, suspended solids and hydrocarbon content and only discharged if within the specifications.· Coating degradation on process equipment’s support structure (Figures 6 and 7), finger-type slug catcher (Figures 2, 3 and 4) and fittings (Figure 5) was observed to be widespread at the site. EM provided assurance to NEB that all necessary fitness for service assessments have been made and the equipment/structure is good for the expected short-term service. EM provided Maintenance plans to NEB that identified works scheduled for completion by 2019.· NEB observed data on randomly selected pressure vessels’ nameplates (Figures 8 and 9), and inspection tags on PSVs. Most of the salient data on the nameplates was legible, and no abnormality was observed on the PSVs inspection tags.· NEB had a discussion on the two Rich MEG (mono-ethylene glycol) Storage Tanks at the site. The tanks were installed in 2003 (i.e., after the site’s commissioning in 1998), and first exhaustive/internal inspections are not yet due. Current reliance is on periodic visual inspections and application of cathodic protection (CP). EMC stated that annual CP surveys are conducted, records kept, and no abnormality has been observed. The tanks relieve to the atmosphere through flame arrestors and charcoal filters. Pressure/Vacuum vents are additionally provided.· NEB Staff inspected the 2” drain nozzle weld of the De-Ethanizer Reboiler, E1235 (an ASME Sec VIII Div 1 pressure vessel) (Figure 10) that required repairs in the last turnaround. A flaw was observed when the vessel underwent internal inspection (as per a 10 year cycle program) last year. The repair and the repair procedure were approved and overseen by the Nova Scotia Department of Labour in their capacity of the Authorized Inspection Agency.· NEB observed the recent attempt to repair the manway nozzle weld of the now deactivated Desiccant Tower, D1110 (an ASME Sec VIII Div 2 Pressure Vessel) (Figure 11). In the original Fitness for Service Assessment submitted to the NEB on 26 October, 2016, this crack was reported to be 2 mm in depth. Upon excavation by grinding, the crack was still observed after excavating 50 mm deep (more than half the wall thickness). EM made the decision to deactivate the vessel. As part of the deactivation measures, a N2 pad has been applied to the isolated vessel, and the pressure is monitored via Distributed Control System and field logs (once/24 hr) as well. NEB was provided a copy of the last 4-week DCS trend of PDI-1115 (which has been converted into a Pressure Transmitter to represent the pressure in the vessel). Pressure has been steady in the range of 48 – 60 kPag depending on the ambient.· NEB observed cracked cladding on one elbow of a process line exposing the insulation blocks underneath (Figures 12 and 13). EM was requested to investigate, and report for any Corrosion Under Insulation along with other findings (see the list of action items).· During the walkthrough, NEB observed the Thickness Monitoring Locations (TMLs) of process piping and pressure vessels (Figure 14). All appeared to be appropriately located. However, the database/management records of these TMLs were not reviewed during this inspection.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
During the Plant Field Inspection and the Closing Meeting, EM committed to file the required information regarding the following Action Items:1) Confirmation and detail of how the company’s adopts common preventive maintenance schedules for equipment with different manufacturing performance (such as regulatory items), based on their service (i.e. utility, regulatory, etc.), while ensuring that the reliability of any item in the set is not overestimated; and2) Result of the assessment and mitigation that will be conducted related to the cracked cladding on one elbow of a process line.
Due date: 2017-06-30
Date closed: 2017-10-10 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
