Compliance verification activity type: Field Inspection
Team:
Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Operating company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Opportunistic inspection of the Aitken Creek gas plant total outage, scheduled to occur starting 10 June 2017 for 21 days. Focus on the contractor management program, oversight of contractors, permitting and LOTO. Review integrity aspects of plant turnaround with respect to MOC's, QA/QC process for materials and contractor work, pressure vessel and piping inspections.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Valve Maintenance Program
Date & time of visit: 2017-06-20 11:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
Enbridge stated that preventative maintenance is conducted annually on the plant emergency shutdown valves and blowdown valves in the form of greasing, cleaning and stroke checks. However preventative maintenance is not performed on control and manual valves as there is no valve integrity management program. As a result, the control and manual valves were not part of the plant turnaround maintenance activities.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Due date: 2017-09-06
Date closed: 2017-11-15 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 2 - Contractor Quality Assurance
Date & time of visit: 2017-06-20 13:00
Enbridge stated that it uses British Columbia Safety Authority (BCSA) licensed contractors whose Quality Assurance/Quality Control program have been reviewed and validated by BCSA. As part of its internal process, Enbridge utilizes Individual Test Plans (ITPs) which is a checklist that identifies the work requirements, activities and scope of work that is signed off by both company and contractor representatives at the completion of each of stage of work indicating review and acceptance of the work performed by the contractor. Enbridge provided documentation of an ITP with respect to an ongoing work activity at the plant which included sign off by both company and contractor representatives per the various stages of completed work activities
Compliance tool used: No compliance tool used
Observation 3 - Scope of Turnaround activities
Date & time of visit: 2017-06-20 09:00
Enbridge provided documentation outlining the scope of turnaround activities which included cleaning, inspection and non-destructive examinations (NDE) on heat exchangers, pressure vessels and cleaning of equipment filters. Process piping was not included in the scope of in activities as it follows a maximum 5 year inspection frequency consistent with the Process Equipment Integrity Management Program (PEIMP) and API 570 requirements.Further to the process piping, Enbridge presented and stated that Condition Monitoring Location (CML) baseline surveys were performed on piping circuits in 2015 to establish baseline readings. Enbridge stated that a CML survey is to be completed before the end of 2017 to establish corrosion rates on the piping circuits. A risk ranking of piping consistent with API 570 standard was performed in 2016.Boilers inpsections were conducted in 2015 by a certified 3rd party inspector and were not included within the scope of the turnaround activities as it follows a 3 year inspection frequency per the PEIMP and ABSA AB-506 . The inspection reports indicated the boilers were fit for continued service.Inspection and testing of pressure relief devices (PRD's) such as pressure relief valves were included as part of the scope of turnaround activities. Enbridge presented copies of travel sheets which are used to track the removal/disassembly, testing, inspection, evaluation and assembly/replacement of these PRDs.A vessel inspection report and ultrasonic thickness examination report on the external and inspection performed by a certified 3rd party inspector on the Amine Drain Drum was presented which found the vessel fit for service and recommended a weld overlay repair based on identified corrosion pitting. Repairs were scheduled to be completed prior to start-up of the plant.Calibration certificates of instrumentation used to perform NDE was presented indicating a pass and calibration as recent as June 1, 2017.
Compliance tool used: Information Request (IR)
Due date: 2017-09-05
Date closed: 2017-10-12 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.
Observation 4 - Non-coated above ground raw sour gas piping
A section of the raw sour gas line in the plant from the inlet separator to the amine contactor was neither insulated nor coated (whereas the portion feeding raw gas into the plant was coated with paint) thereby exposing the bare piping to the atmosphere. As a result, the exposed bare piping is susceptible to atmospheric (external) corrosion.
Observation 5 - Management of Change - installation of new long recycle piping
Enbridge initiated a management of change (MOC) as part of the project to install a new recycle line downstream of sales compressor, including a sales compressor bypass. The line is expected to be in operation as part of the plant start-up. Enbridge presented documentation on the MOC which identified MOC documents, action items, scoping details, ranking details and risk screening information.
Observation 6 - General Safety Observations
Date & time of visit: 2017-06-20 10:30
Discipline: Safety Management
A site inspection was performed immediately following meeting and site orientation.
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
