Compliance verification activity type: Field Inspection
Team:
Regulated company: TEML Westspur Pipelines Limited
Operating company: TEML Westspur Pipelines Limited
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Safety inspection of pump stations and terminals to assess compliance to the NEB OPR and CSA Z662-15.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations - Alida Terminal
Date & time of visit: 2018-05-23 09:10
Discipline: Safety Management
Categories:
Facility:
Observations:
NEB Inspectors observed signs with the company name, emergency phone numbers, non-smoking, hazards associated with the presence of hydrocarbons, and required PPE were posted at the site main entrance. NEB inspectors verified the location of the wind sock and muster station that was described during the site-specific orientation. NEB inspectors verified the terminal is fenced with egress gates in addition to the main site access. The Alida Terminal has crude oil storage tanks, a truck off-loading facility and a pump station. A Natural Gas Liquid (NGL) line also goes through the terminal but the NGL pumps have been disconnected from the NGL line. The mainline pumps are housed in a pump building. The pump building is equipped with gas detection. At 10% of the Lower Explosive Limit (LEL), an alarm is initiated and the building ventilation is started. At 20% LEL, a station emergency shut-down (ESD) is initiated. A station ESD shuts down the pump building and isolates the station. The pump building is also equipped with fire detection devices. If a fire is detected, a station ESD is initiated, the ventilation in the pump building is stopped, and the CO2 Fire suppression system is initiated. The pump building had appropriate signage (danger, no smoking, no open flame, no spark, hearing protection required). The company explained the CO2 suppression system was inspected twice a year by a third party contractor. The CO2 bottles were appropriate labeled and secured. TEML representative confirmed the CO2 suppression system had both an audible and visual alarm (red flashing light). There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves, operating the SCADA system, and the lighting during a power loss event. The station is equipped with station ESD push buttons located throughout the station, including one located near the main entrance / exit of the station. The MCC building had warning signs on exterior to not enter building when red light is flashing. TEML representatives explained the red beacon was used at the MCC building to alert persons in the area that the MCC breaker was about to engage. Warning signage was in place (high voltage, authorized personal only). Fire extinguishers were in place and had been inspected recently. NEB inspectors observed good housekeeping and several signs to warn of the hazards throughout the terminal.
Compliance tool used: No compliance tool used
Observation 2 - CNC - Alida Terminal - Pump building Cranes
Date & time of visit: 2018-05-23 09:30
There were a 3 ton and 5 ton overhead cranes present in the building. Overhead crane was tagged to indicate that pre-use inspection must be completed and log book to be filled in prior to use. TEMLs procedure for lifting operation (2.9 Lifting Operations of Section 2: Health and Safety) also required the use of a log book to record inspections, operations and maintenance. There was no log book present on site to make those records. Therefore, TEML could not demonstrate that it was implementing its controls for the safe use of the cranes and this is a non-compliance to the OPR section 6.5 (1)(f).
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The deficinency noted by the NEB Inspectors was corrected by 4 June 2018, before the inspection report was completed. The company provided the crane pre-use inspection forms to the workers.
Due date: 2018-06-04
Date closed: 2018-06-04 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 3 - NNC - Alida Terminal - Direction of flow on Above Ground Piping
NEB inspectors observed that some arrows were present, but others were faded and several marks were missing to properly indicate the direction of flow and therefore the function of the above ground pump station piping. This is a non-compliance to CSA Z662-15 clause 4.14.3.8 (c).
Compliance tool used: Notice of Non-compliance (NNC)
Company added arrows for direction of flow on the piping. The company adressed the non-compliance to CSA Z662-15 clause 4.14.3.8 (c).
Due date: 2018-06-29
Date closed: 2018-06-25 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 - NNC - Alida Terminal - Storage Tank Secondary Containment Drainage System
Discipline: Integrity Management
NEB staff observed that TEML uses drains made of flexible hoses that are made of combustible materials to drain the water that accumulates in the secondary containment. The pipe going through the wall of the secondary containment is made of steel and the flex hose is attached to it. There is no valve between the steel pipe and the flex hose. The flex hose is maintained in a vertical position such that the end of the hose is higher than the secondary containment wall and liquids can’t escape the berm unless the hose is lowered. However, since the hose is combustible, if there was a release of oil in the secondary containment and a fire ignited, the hose could fail and allow oil and fire to be released outside the secondary containment. This is a non-compliance to the NEB OPR s.13 (c).
TEML installed a gate valve upstream of the flex hose and the gate valve is to remain closed except when draining the water out of the secondary containment. TEML addressed the non-compliance to the NEB OPR s.13 (c).
Observation 5 - General Observation - Steelman Terminal
Date & time of visit: 2018-05-23 13:45
NEB Inspectors observed signs with the company name, emergency phone numbers, non-smoking, hazards associated with the presence of hydrocarbons, and required PPE were posted at the site main entrance. NEB inspectors verified the location of the wind sock and muster station that was described during the site-specific orientation. NEB inspectors verified the terminal is fenced with egress gates in addition to the main site access. Company representatives were able to point out the egress. The Steel Terminal has crude oil storage tanks, a truck off-loading facility and a pump station. The mainline pumps are housed in a pump building. The pump building is equipped with gas detection. At 10% of the Lower Explosive Limit (LEL), an alarm is initiated and the building ventilation is started. At 20% LEL, a station emergency shut-down (ESD) is initiated. A station ESD shuts down the pump building and isolates the station. The pump building is also equipped with fire detection devices. If a fire is detected, a station ESD is initiated, the ventilation in the pump building is stopped, and the CO2 Fire suppression system is initiated. There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves, operating the SCADA system, and the lighting during a power loss event. The station is equipped with station ESD push buttons located throughout the station, including one located near the main entrance / exit of the station. The MCC building had warning signs on exterior to not enter building when red light is flashing. TEML representatives explained the red beacon was used at the MCC building to alert persons in the area that the MCC breaker was about to engage. Warning signage was in place (high voltage, authorized personal only). Fire extinguishers were in place and had been inspected recently. NEB inspectors observed good housekeeping and several signs to warn of the hazards throughout the terminal.
Observation 6 - CNC - Steelman Terminal - Drill Press in Old Machine Shop
Date & time of visit: 2018-05-23 14:00
The drill press in old machine shop was not properly secured to the ground. The drill press could tip over and this was a hazard to the safety of the employees that was not properly mitigate. This is a non-compliance to the NEB OPR s. 6(a). This issue was addressed prior to the completion of this report.
The company secured the drill press and adressed the non-compliance before the completion of this report.
Due date: 2018-05-31
Date closed: 2018-05-31 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 7 - CNC - Steelman Terminal - Emergency Light in Old Machine Shop
A battery powered emergency light did not turn on when company personal attempted to turn it on. This is a non-compliance to the NEB OPR s.12 (b). The battery was replaced prior to the completion of this report.
Company replaced the battery prior to the completion of this report.
Due date: 2018-05-28
Date closed: 2018-05-28 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 - CNC - Steelman Terminal - Gas Cylinders in Old Storage Building
Old storage building (cold storage) had compressed gas cylinders that were not securely stored. This was a hazard to the safety of the employees that was not properly mitigate. This is a non-compliance to the NEB OPR s. 6(a). This issue was addressed prior to the completion of this report.
Company secured the cylinders prior to the completion of this report.
Observation 9 - CNC - Steelman Terminal - Direction of flow on Above Ground Piping
NEB inspectors observed that most of the piping was not marked to indicate the direction of flow and therefore the function of the above ground pump station piping. This is a non-compliance to CSA Z662-15 clause 4.14.3.8 (c). This issue was addressed prior to the completion of this report.
Company adressed the non-compliance prior to the completion of this report.
Observation 10 - CNC - Steelman Terminal - Manhole cover for sump in the secondary containment area left open
A manhole to access a sump in the secondary containment of the storage tank had the cover partially removed that was also blocking the confined space sign. There was a hose, an electrical cord and a couple of tied rope hanging in the sump. Company confirmed the pump had not been run for a long time. The open manhole was unattended and there was no warnings or barriers to mitigate this hazard. This is a non-compliance to the NEB OPR s. 6(a). This issue was addressed prior to the completion of this report.
Company adressed the non-compliance prior to the completion of this report. The company put the cover back on the manhole.
Observation 11 - General Observations - Bryant Booster Station
Date & time of visit: 2018-05-24 08:00
The Bryan Booster Station has two pump buildings, each housing two pump units. The pump building is equipped with gas detection. At 10% of the Lower Explosive Limit (LEL), an alarm is initiated and the building ventilation is started. At 20% LEL, a station emergency shut-down (ESD) is initiated. A station ESD shuts down the pump building and isolates the station. The pump building is also equipped with fire detection devices. If a fire is detected, a station ESD is initiated, the ventilation in the pump building is stopped, and the CO2 Fire suppression system is initiated. NEB Inspectors observed signs with the company name, emergency phone numbers, non-smoking, hazards associated with the presence of hydrocarbons, and required PPE were posted at the site main entrance. NEB inspectors verified the location of the wind sock and muster station that was described during the site-specific orientation. NEB inspectors verified the terminal is fenced with egress gates in addition to the main site access. Company representatives were able to point out the egress. Company representative confirmed the phone number on the sign was still active and accurate after the transfer of ownership. There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves, operating the SCADA system, and the lighting during a power loss event. The station is equipped with station ESD push buttons located throughout the station, including one located near the main entrance / exit of the station. NEB inspectors observed good housekeeping. Emergency air packs stored in the ESB 1 / MCC 1 building – operator confirmed each operator carries their own masks that they are fit tested for.
Observation 12 - CNC - Bryant Booster Station - Direction of flow on Above Ground Piping
Date & time of visit: 2018-05-24 09:00
NEB inspectors observed that most of the piping was not marked to indicate the direction of flow / function of the above ground pump station piping. This is a non-compliance to CSA Z662-15 clause 4.14.3.8 (c). This issue was addressed prior to the completion of this report.
Company adressed the non-compliance prior to the completion of this report. The company put arrows for direction of flow on the piping.
Due date: 2018-05-24
Date closed: 2018-05-24 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 13 - CNC - Bryant Booster Station – Faded Signage
A “High Voltage” sign on the gate to the high voltage transformer and a H2S sign on one of the pump buildings needed to be replaced as it was too faded to properly warn of the hazards. This is a non-compliance to CSA Z662-15 clause 10.5.4.3. This issue was addressed prior to the completion of this report.
Comapny is require to ensure that warning signs are posted at locations where hazards or toxic substances can be encountered and the company must ensure these signs are legible. Company adressed the non-compliance prior to the completion of this report.
Observation 14 - CNC - Bryant Booster Station – Fire Extinguisher
In the ESB 2 / MCC 2 building, a fire extinguisher was on the floor. Extinguisher needs to be mounted on the wall in order the prevent damage to the bottom of the fire extinguisher. This is a non-compliance with CSA Z662-15 clause 10.2.7.2 (e). This issue was addressed prior to the completion of this report.
Company must ensure that extinguishers are mounted on the wall in order the prevent damage to the bottom of the fire extinguisher. Company adressed the non-compliance prior to the completion of this report.
Observation 15 - CNC - Bryant Booster Station – First Aid
In the ESB 1 / MCC 1 building, a first aid kit and the eye wash bottles were both expired. This is a potential hazard to the safety of the employees and this is a non-compliance to the NEB OPR s. 6(a). This issue was addressed prior to the completion of this report.
Observation 16 - NNC -Bryant Booster Station – Storage of fuels and lubricants
In the two pump buildings, there was Varsol stored in quantities larger than what is necessary for everyday use and this is a non-compliance to CSA Z662-15 clause 10.9.1.5.
Company removed excess quantity of varsol and only quantities needed for everyday use will remain in the pump building. TEML adressed the non-compliance to CSA Z662-15 clause 10.9.1.5.
Observation 17 - CNC - Bryant Booster Station – Identification of Product
In the pump building P1000, one of the valve handle was blue instead of red as per TEML requirement for identifying their product in the pipe. The operator confirmed the station uses the same TEML colour coding (red for oil, blue for NGL) and the operator confirmed there is no NGL at this station. This is a non-compliance to CSA Z662-15 clause 4.14.3.8 (c). This issue was addressed prior to the completion of this report.
Observation 18 - NNC - Bryant Booster Station – Lighting
The pump building P1000 had poor lighting as two of the main lights were burnt out. This is a hazard to the safety of the employees and this is a non-compliance to the NEB OPR s. 6(a).
TEML replaced the burnt out lights. TEML addressed the non-compliance to the NEB OPR s. 6(a).
Observation 19 - CNC - Bryant Booster Station - Oily rag storage
One of the pump buildings had oily rags which were improperly stored in regular garbage can. This is a fire hazard and this is a non-compliance to the NEB OPR s. 6(a) and (b). This issue was addressed prior to the completion of this report
Observation 20 - General Observation - Midale Terminal
Date & time of visit: 2018-05-24 09:45
The Midale Terminal has crude oil storage tanks, a truck off-loading facility and a pump station. NEB Inspectors observed signs with the company name, emergency phone numbers, non-smoking and required PPE were posted at the site main entrance. NEB inspectors verified the location of the wind sock and muster station that was described during the site-specific orientation. NEB inspectors verified the terminal is fenced with egress gates in addition to the main site access. Company representatives were able to point out the egress. The mainline pumps are house in a pump building. The pump building is equipped with gas detection. At 10% of the Lower Explosive Limit (LEL), an alarm is initiated and the building ventilation is started. At 20% LEL, a station emergency shut-down (ESD) is initiated. A station ESD shuts down the pump building and isolates the station. The pump building is also equipped with fire detection devices. If a fire is detected, a station ESD is initiated, the ventilation in the pump building is stopped, and the CO2 Fire suppression system is initiated. There is back-up diesel generator onsite which is capable of operating the ESD system, including closing the station isolation valves, operating the SCADA system, and the lighting during a power loss event. The station is equipped with station ESD push buttons located throughout the station, including one located near the main entrance / exit of the station. NEB inspectors observed good housekeeping, adequate lighting, and appropriate signage throughout the terminal.
Observation 21 - CNC - Midale Terminal - Shop Cranes
Date & time of visit: 2018-05-24 12:00
There were a 1 ton overhead cranes present in the shop building. Overhead crane was tagged to indicate that pre-use inspection must be completed and log book to be filled in prior to use. TEMLs procedure for lifting operation (2.9 Lifting Operations of Section 2: Health and Safety) also required the use of a log book to record inspections, operations and maintenance. There was no log book present on site to make those records. Therefore, TEML could not demonstrate that it was implementing its controls for the safe use of the cranes and this is a non-compliance to the OPR section 6.5 (1)(f).
The company addressed the non-compliance prior to the completion of this report.
Observation 22 - CNC - Midale Terminal - compressed air hose
NEB staff observed that the compressed Air hose did not have a restraining device available to be attached to a tool. This is a hazard to the safety of the employees and this is a non-compliance to the NEB OPR s. 6(a).
The non-compliance was addressed prior to the completion of this report.
Due date: 2018-05-30
Date closed: 2018-05-30 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 23 - CNC - Midale Terminal - Drill Press not Secured
The drill press in the maintenance shop was not properly secured to the ground. The drill press could tip over and this was a hazard to the safety of the employees that was not properly mitigate. This is a non-compliance to the NEB OPR s. 6(a). This issue was addressed prior to the completion of this report.
Observation 24 - CNC - Midale Terminal - Fire Extinguishers in Maintenance Shop
The maintenance shop building only had BC rated extingushers while their were combustible materials in the building. Not having the properly rated fire extinguishers is a hazard to the safety of the employees. This is a non-compliance to the NEB OPR s. 6(a).
The company adressed the non-compliance prior to the completion of this report.
Observation 25 - IR - Steelman Terminal - Secondary Containment Wall
NEB inspectors observed that one of the secondary containment wall for the above ground storage tanks was made of a steel structure and the wall was also using a liner which was exposed above ground. The steel wall was made with plates which were bolted together at the joints. There were also screws goind through the steel plates where the liner was attached. NEB inspectors have issued an information request to TEML to verify compliance to the NEB OPR s. 13 (c).
Compliance tool used: Information Request (IR)
Due date: 2019-03-31
Date closed: 2019-03-20 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.
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
