Compliance Verification Activity Report 1516-164 – Trans Mountain Pipeline ULC

Compliance Verification Activity Report - Trans Mountain Pipeline ULC [PDF 413 KB]

Type of Compliance Verification Activity: Field Inspection

Activity #: 1516-164
Activity start: 10/27/2015
Activity End: 10/27/2015

Related Activity Numbers:

Inspection Officer Number(s): 2083

Incident #:
Landowner Complaint File #:

Company: Trans Mountain Pipeline ULC

Facility Name(s): Edmonton Terminal

Province(s): Alberta

Theme(s): Integrity Management

Compliance Tools Used: Corrected in field (Corrected Non-Compliance) (1)

Purpose

This activity was undertaken to verify compliance with the following regulatory requirements.

 X  NEB Act

 X  Onshore Pipeline Regulations

 X  CSA Standard Z662 Oil and Gas Pipeline Systems

    Other:

    Electricity Regulations

    Processing Plant Regulations

    Pipeline Crossing Regulations Part I

    Pipeline Crossing Regulations Part II

 X  Canada Labour Code, Part II

 X  Canada Occupational Safety and Health Regulations

    Oil and Gas Occupational Safety and Health Regulations

Observations & Discussion

Observations & Discussion
Date visited Location Theme Compliance Confirmed
27-Oct-15 Terminal Office: Pre-Inspection Record Review Integrity Management Yes

Observations

Prior to the field inspection, NEB inspectors reviewed the following tank inspection reports:

-Monthly Tank inspection reports from January 2015 to September 2015 for Tank #26, which has been in service since 2014. Theses inspections are completed by the Trans Mountain Pipeline ULC (TMPU) operators.

-API 653 in-service inspection report for Tank #11, which was built in 1953. These types of inspections are completed in five year intervals by an API 653 certified external inspection company.

-API 653 out-of-service, internal tank inspection report for Tank #18, which has been in service since 1957. These types of inspections are completed in twenty year intervals by an API 653 certified external inspection company.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
27-Oct-15 East Tank Area Integrity Management Yes

Observations

There are 25 tanks in the East tank Area (ETA). Fourteen of them were recently built under the Edmonton Terminal Expansion Project (ETEP). TMPU representatives explained that the tanks carry sweet crude oil and refined products such as gasoline and diesel. The tanks have either fixed roofs with internal floating roofs or external floating roofs.

NEB inspectors observed that a remote impoundment (RI) is used as part of the secondary containment system of the ETA. In conjunction with the common containment area, the RI would accommodate hydrocarbons resulting from an accidental release from a tank and its appurtenances. The surface drainage swales are designed to carry the released hydrocarbons into the RI.

TMPU representatives explained that the RI also has capacity to accommodate water accumulated in the ETA and within the terminal excluding the West Tank Area (WTA) from a 1 in 100 year precipitation event. The water accumulated in the RI is managed by releasing it to the North Saskatchewan River. The water is tested for organic chlorides, dissolved solids, PH, and a visual inspection for hydrocarbons prior to release. In addition, a hydrocarbon detector is also installed in the RI drain valve and would automatically close the RI drain valve if hydrocarbons were detected in the RI water.

In order to address a non-compliance to the Alberta Fire Code 2006 identified in a previous NEB inspection, a steel shroud has been installed over the lock block wall of the RI to protect the liner from a fire. Also, some of the joints of the milepost wall have been sealed with fire resistant caulking.

The tank leak detection system includes level monitoring with radar gauges and alarms and undertank leak detection using monitoring wells. Tank levels are monitored and controlled by the primary control center in Sherwood Park. Overfill protection uses level monitoring with alarms and an independent tank level switch which would automatically close the tank valve if activated.

The undersides of the tank bottoms are protected from external corrosion by cathodic protection.

All tanks in the ETA have automatic fire detection and rim seal fire suppression systems. The fire detection systems use ultraviolet and infra-red fire detectors installed on the top of the tanks. The number of detectors are dependent on the size of the tank. The 400 000 bbl tanks are equipped with fixed foam cannons on the top of the tanks. A mobile foam cannon is onsite for fighting full surface fires on any tank less than 400 000 bbl in the ETA.

Tank #27
NEB inspectors inspected Tank #27. They observed the fire protection system and the leak detection system. For leak detection, the tank has level monitoring and undertank leak detection. The Tank is equipped with a fixed rim seal fire suppression system, and a fixed cannon for a full surface fire. The tank has high level alarms and a high-high level switch which would automatically close the tank valve for overfill protection. The tank shell coating was in good condition and no damage was apparent. The external floating roof of the tank was not coated at the time of inspection. TMPU recently filed a variance with the Board regarding four tanks that do not have their roofs coated, one of which is Tank #27.

NEB inspectors observed extensive development in the ETA as a result of the ETEP (Eg: extension to the previous manifolds and metering facility, addition of tanks, changes to the secondary containment system, addition of new infrastructure such as access roads).

Observations & Discussion
Date visited Location Theme Compliance Confirmed
27-Oct-15 West Tank Area Integrity Management Yes

Observations

The WTA was inspected in the afternoon. Each tank in the WTA was observed to be enclosed within its own dedicated secondary containment dike. TMPU representatives said that water levels within secondary containment dikes are managed by opening manual valves to allow flow through a culvert to the remote impoundment. TMPU explained that secondary containment valves are normally closed, and are only opened after visually confirming the absence of hydrocarbons.

NEB inspectors observed the shell, nozzles, roof and instrumentation on Tank #8. The external coating on the shell, nozzles and roof appeared to be in good condition. TMPU representatives explained that the overfill protection and control monitoring system is identical to other tanks in the East Tank Area, while leak detection is achieved through level monitoring since the tank does not employ an undertank leak detection system. TMPU said that it relies on visual observation for fire detection in the WTA. Tank #8 has a rim seal firefighting foam system. This is a semi-fixed system where a foam trailer needs to be mobilized and connected to the rim seal foam line on the access road near the tank.

Workers were observed excavating a pipe connecting to Tank #7 at the soil-to-air interface. The pipe coating was observed to be degraded. TMPU representatives confirmed that the excavation was planned to address coating deterioration concerns that were identified during a recent aboveground piping inspection. The coating would be repaired with a modern coating system.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
27-Oct-15 Edmonton Terminal Pumps Integrity Management Yes

Observations

Four 2500 HP centrifugal pumps are located in the mainline pump building. The four pumps work in series and move product from the tank farm into the mainline. The building is equipped with fire and gas detection. Upon fire detection, the pump station would be shut down and isolated. All ventilation would also be stopped upon fire detection. Gas detection would activate the building ventilation system at 10% LEL (lower explosive limit). At 20% LEL, building ventilation would stop, and the station would be shut down and isolated. The pump building has a sump with leak detection which would initiate an alarm if activated.

The pump units are equipped with temperature, vibration and seal leak detection. There is a drain system to direct seal leakage to the sump tank. The sump tank is equipped with high level alarms. Each pump unit is equipped with a lockout switch.

There are two station Emergency Shut Down (ESD) push buttons located on opposite sides of the pump building. If pressed, the ESD push buttons would shut down all pump units and isolate the pumps from the terminal and the mainline. A diesel generator provides an alternate source of power capable of operating the station ESD system.

Pressure transmitters monitor pump suction and discharge pressures.

The station’s suction piping has five isolation valves. Two isolation valves are located on the discharge side. TMPU representatives confirmed that all isolation valves would close on a station ESD. A pig launcher is located at the beginning of the mainline, after which the station discharge ties in.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
27-Oct-15 Edmonton Pump Station Integrity Management No

Observations

NEB inspectors noted that a valve on the thermal relief system of the butane line was closed, rendering the thermal relief system for that section of piping inoperative. TMPU representatives indicated that this valve should normally be kept open. However, it appeared that the “car seal” system for the thermal relief valve of the butane line was not working for two of the valves on the thermal relief system, including the one that was closed, because the valves did not have the features to properly accommodate the car seal system and prevent their unintended closure. This is a non-compliance to CSA Z662-15 clause 4.18.2(e). Immediately following the inspection, the company modified the valves in order to properly car seal the valves and prevent their unintended closure. Pictures have been provided to the NEB inspectors confirming that the non-compliance was corrected.


Compliance Summary

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Integrity Management Corrected in field (Corrected Non-Compliance) 10/27/2015
Date/Time visited Location
10/27/2015 Edmonton Pump Station

Observations

NEB inspectors noted that a valve on the thermal relief system of the butane line was closed, rendering the thermal relief system for that section of piping inoperative. TMPU representatives indicated that this valve should normally be kept open. However, it appeared that the “car seal” system for the thermal relief valve of the butane line was not working for two of the valves on the thermal relief system, including the one that was closed, because the valves did not have the features to properly accommodate the car seal system and prevent their unintended closure. This is a non-compliance to CSA Z662-15 clause 4.18.2(e). Immediately following the inspection, the company modified the valves in order to properly car seal the valves and prevent their unintended closure. Pictures have been provided to the NEB inspectors confirming that the non-compliance was corrected.

Regulatory Requirements

CSA Z662-15 clause 4.18.2 (e):

"Systems for pressure control and overpressure protection shall
e) be designed and installed to prevent unauthorized operation of valves or equipment that would make these systems inoperative;"

Corrective Action or Request Required

Immediately following the inspection, the company modified the valves in order to properly car seal the valves and prevent their unintended closure. Pictures have been provided to the NEB inspectors confirming that the non-compliance was corrected.

This notice reflects the observations of non-compliance with regulatory requirements or company commitments, made by the inspection officer during the compliance verification activity. If the corrective actions identified are implemented by the completion date, the matter is considered resolved. Any unresolved compliance matters will be addressed by the inspection officer and may be referred to NEB enforcement staff.

517 Tenth Avenue SW Calgary, Alberta  T2R 0A8
Telephone: 403-292-4800   Toll Free: 1-800-899-1265

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