Compliance verification activity type: Field Inspection
Team:
Regulated company: Kinder Morgan Cochin ULC
Operating company: Kinder Morgan Canada Inc
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Conduct safety inspection of Kinder Morgan Cochin ULC pump stations in Saskatchewan and Alberta to assess compliance with the NEB OPR, CSA Z662-15, Canada Labour Code (CLC) and Canada Occupational Health and Safety Regulations (COHSR).
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Sovereign Pump Station
Date & time of visit: 2017-08-22 09:00
Discipline: Safety Management
Categories:
Facility:
Observations:
NEB inspectors met with the company representatives at the Sovereign Pump Station. The Cochin system transports condensate from the United States to Edmonton, Alberta.NEB inspectors reviewed the Kinder Morgan, Lockout / Tagout, Liquids O & M Procedure (L-0&M 152), which was provided ahead of the inspection, and were satisfied that L-O&M 152 procedure was accessible at Sovereign facility office. There was no facility devices locked out at this pump station at time of inspection. The pump station as one pump unit. Station is fenced with two egress gates in addition to the main site access. Signs with the company name, emergency phone numbers, non-smoking and warning of the presence of flammable products were posted at the site main entrance. Fence was grounded and access/egress gates were bonded to fence. The station is equipped with station Emergency Shut-Down (ESD) push buttons located throughout the station. The station has an Uninterruptible Power System (UPS) and a propane fueled generator as alternate source of power. The generator is capable of operating the station ESD system, and provides power to operate all facilities at the station except the pump unit. There is a transformer on site which is owned, operated and maintained by the company. The transformer area is fenced, with high voltage warning signs and the fence is grounded, with access gate bonded to fence. The pump building is equipped with fire and gas detection. Fire detection triggers a station ESD and gas detection triggers and alarm at 40% LEL and a station ESD at 50% LEL. There is no forced ventilation in the pump building. The pump unit is equipped with a seal leak detection system. When the seal leak detection system is triggered, it stops the unit and isolates the station. There is a 3 Ton crane in the pump building. The company provided the annual certification and monthly check records for this station. It also provided an example record of a pre-use inspection. – need to send email. The office building is where the first aid kit and eyewash station is located. Also, there are electrical panels which had proper clearance in front of them. The panels had warning signs for the high voltage and personal protective equipment (PPE) requirements. Fire extinguishers had valid annual certification and monthly inspection tags. The Variable Frequency Drive (VFD) for the pump unit is located in a separate building. The building was clean and with no obstruction to the electrical panels. The station uses a pumping system for managing pump seal leaks and any piping drainage needs. The pumping system re-injects any liquids that would need to be drained in the mainline system. The product containers in the Chemical storage building were properly labelled and there was secondary containment. The station piping has thermal relief valves at the station isolation valves which discharge in the mainline. Site had two wind socks.
Compliance tool used: No compliance tool used
Observation 2 - Kerrobert Pump Station
Date & time of visit: 2017-08-22 14:15
The pump station as one pump unit.
Station is fenced with two egress gates in addition to the main site access. Signs with the company name, emergency phone numbers, non-smoking and warning of the presence of flammable products were posted at the site main entrance. Fence was grounded and access/egress gates were bonded to fence.
The station is equipped with station Emergency Shut-Down (ESD) push buttons located throughout the station.
The station has an Uninterruptible Power System (UPS) and a propane fueled generator as alternate source of power. The generator is capable of operating the station ESD system, and provides power to operate all facilities at the station except the pump unit.
There is a transformer on site which is owned, operated and maintained by the company. The transformer area is fenced, with high voltage warning signs and the fence is grounded, with access gate bonded to fence.
The pump building is equipped with fire and gas detection. Fire detection triggers a station ESD and gas detection triggers and alarm at 40% LEL and a station ESD at 50% LEL. There is no forced ventilation in the pump building. The pump unit is equipped with a seal leak detection system. When the seal leak detection system is triggered, it stops the unit and isolates the station.
There is a 3 Ton crane in the pump building. The company confirmed that the crane is certified annually, checked on a monthly basis and before any use.
The office building is where the first aid kit and eyewash station is located. Also, there are electrical panels which had proper clearance in front of them. The panels had warning signs for the high voltage and personal protective equipment (PPE) requirements.
Fire extinguishers had valid annual certification and monthly inspection tags.
The Variable Frequency Drive (VFD) for the pump unit is located in a separate room of the office building. It was clean and with no obstruction to the electrical panels.
The station uses a pumping system for managing pump seal leaks and any piping drainage needs. The pumping system re-inject any liquids that would need to be drained in the mainline system.
The station piping has thermal relief valves at the station isolation valves which discharge in the mainline.
The product containers in the Chemical storage building were properly labelled and there was secondary containment.
Observation 3 - Hayter Pump Station
Date & time of visit: 2017-08-22 16:15
There are no observations with outstanding follow-up
Observation 4 - Fabyan Pump Station
Date & time of visit: 2017-08-23 09:30
There is a new transformer on site which is owned, operated and maintained by the electricity provider. The power is coming underground to the station.
The pump building is equipped with fire and gas detection. Fire detection triggers a station ESD and gas detection triggers an alarm at 40% LEL and a station ESD at 50% LEL. There is no forced ventilation in the pump building. The pump unit is equipped with a seal leak detection system. When the seal leak detection system is triggered, it stops the unit and isolates the station.
There is a 3 Ton crane in the pump building. The company confirmed that the crane is certified annually, checked on a monthly basis and prior to any use.
The Variable Frequency Drive (VFD) for the pump unit is located in a separate building. It was clean and with no obstruction to the electrical panels.
The station uses a pumping system for managing pump seal leaks and any piping drainage needs. The pumping system re-injects any liquids that would need to be drained in the mainline system.
Site had two wind socks.
Observation 5 - Fabyan Pump Station - Overhead High Voltage Cable Tray
The site had overhead power lines located in a cable tray which had its warning signage for “High Voltage” and clearance height faded to the point it was not effective anymore. This is a non-compliance to CSA Z662-15 clause 10.5.4.3. The company indicated that they had already identified this issue and that a lift would be on site Monday, August 28th, 2017 to correct deficiency.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Kinder Morgan is in the process of purchasing weather stickers that will be applied over the existing faded signage. This will be completed by 20 October 2017.
Due date: 2017-10-20
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.
Reason closed: Requirement met
Compliance achieved: Yes
Observation 6 - Vegreville Pump Station
Date & time of visit: 2017-08-23 11:45
There is a 3 ton crane in the pump building. The company confirmed that the crane is certified annually, checked on a monthly basis and before any use.
The product containers in the Chemical storage building were properly labelled and there was secondary containment.Site had two wind socks.
Observation 7 - Overpressure Protection - Thermal Relief Valve for Station Piping
Date & time of visit: 2017-08-23 18:00
Discipline: Integrity Management
The thermal relief valves protecting the Sovereign, Kerrobert and Vegreville stations’ piping had manual valve up and downstream of them and these valves had no means to prevent their unintended closure and render the overpressure protection system inoperative. This is a non-compliance to the CSA Z662-15 clause 4.18.2 (e).
Kinder Morgan will tag the manual valves up and downstream of the thermal relief valves protecting the Sovereign, Kerrobert and Vegreville stations’ piping to prevent unauthorized operation of valves or equipment that would make these systems inoperative. This will be completed by 30 September 2017.
Due date: 2017-09-30
Date closed: 2017-10-11 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 8 - Overpressure Protection for Injection System
At the Kerrobert, Hayter, Fabyan and Vegreville pump stations, the pressure safety valves and pressure switch providing overpressure protection for this system had manual valves upstream of them and these valves had no means to prevent their unintended closure and render the overpressure protection system inoperative. This is a non-compliance to the CSA Z662-15 clause 4.18.2 (e).
Kinder Morgan will tag the manual valves associate with the pressure safety valves and pressure switches providing overpressure protection for our injection systems located at our Fabyan, Hayter, Kerrobert and Vegreville pump stations. This will prevent unauthorized operation of valves or equipment that would make these systems inoperative.This will be completed by 30 September 2017.
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
Observation 9 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
This information has been redacted pursuant to Section 144(5) of the Canada Labour Code
Observation 10 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 11 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
