Compliance Verification Activity Report: CV2324-066 - Many Islands Pipe Lines (Canada) Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2523

Regulated company: Many Islands Pipe Lines (Canada) Limited

Operating company: Many Islands Pipe Lines (Canada) Limited

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Integrity Management

Rationale and scope:

Operations Inspection of the Many Islands Pipe Lines (Canada) Limited's Macklin Compressor Station.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (4)

Facility details

Facilities:

• MACKLIN

Facility Types

• Pipeline
• Compressor station

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-23 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Inspection Observations

Date & time of visit: 2023-11-23 08:40

Discipline: Integrity Management

Categories:

• Facilities
• Compressor Station

Facility:

• MACKLIN (Facility)

Observations:

CER inspectors’ observations and related discussions between CER inspectors and Many Islands representatives are summarized as follows:

• At CER inspectors' arrival, the company conducted site-specific safety orientation.
• The station is part of the Many Islands’ mainline NPS 16 Unity Pipeline. The station receives non-sour natural gas and discharges it back into the line.
• The station includes three reciprocating pump units, each driven by a natural gas-powered engine. It also includes an ultrasonic gas metering unit.
• Station equipment maintenance planning, scheduling, execution, reporting, and recording are done using SAP [Many Islands: please confirm software name] software.
• Facility was fenced with multiple emergency exits.
• Facility appeared tidy.
• Signage was present on the facility fencing and included emergency contact information, a no-smoking sign, and the presence of hazards.
• The station has four gates, however only the main gate has an ESD.
• The open and close positions and identification numbers were marked on observed isolation, blowdown, and Emergency Shutdown (ESD) valves.
• CER inspectors reviewed certain station process & Instrumentation diagrams (P&ID).
• The station is continuously monitored (24/7) by the Many Islands Control Centre in Regina, SK. A local control computer (system) in the office building allows some controls such as ESD and reading access for the unit’s main operating data.
• There is a bump testing and calibration station for four-head gas monitors in the office building. Two Many Islands employees were wearing such monitors during the inspection.
• Several fire extinguishers were installed across the station. CER inspectors randomly verified some fire extinguishers and observed that they had up-to-date monthly and yearly inspection records. 
• There was a first aid kit.
• One ESD push-button was installed at the main gate, one at the door of the local control center, and two at each compressor unit building (one at each door). In addition, each compressor unit has a unit shutdown push-button installed in its building.
• The station is equipped with a backup natural gas-powered generator of 350 kW, capable of ensuring the station’s continued operation by providing power to the coolers and critical safety equipment. Upon commercial/grid power loss, the station will switch to the backup generator until the grid power returns. Upon generator power loss, the station would transfer to the Uninterruptible Power System (UPS), installed in the MCC building, which is capable of producing the necessary power for lighting, critical control system, and ESD system. The UPS is tested annually and will run for 4 hours minimum. The generator is run-tested weekly and generally inspected (including load-tested) twice a year.
• A portion of the station gas is odorized for the backup generator, compressor engines’ fuel gas, some area distribution lines’ block valves, and other site utility needs. 
• Many Islands representatives stated that:
  • the facility has a maximum operating pressure (MOP) of 7067 kPa.
  • the set pressure control limit is 6691 kPa. A compressor unit will start to slow down at 5 kPa more and activate the ‘unloaders’ and the engine slows down to 1200 rpm
  • The first set point for bypass gas circulation around a unit (through PCV) is 6741 kPa (i.e., 50 kPa above the pressure control limit).
  • At 6791 kPa (i.e., 50 kPa above the bypass point), alarms are sent to gas control for operators’ monitoring.
  • At 6895 kPa, the station is shut down.
  • At 7240 kPa, the Pressure Safety Valves (PSV) open to release the pressure.
• CER inspectors noted that this set pressure for the PSVs (overpressure protection system) is significantly lower than the maximum 110% of MOP (required by clauses 4.18.1.2 and 10.9.5.5 of CSA Z662). Many Islands’ representatives stated that all the set points for pressure control and overpressure protection are per the company’s procedure and work practice and there were no integrity reasons or concerns. 
• ​​​Many Islands representatives stated that the shutdown temperature was: 
  • 746 °F for a unit discharge gas temperature would trigger an alarm. 
  • 749 °F would trigger the unit shutdown.

• There was a locked-out and tagged-out (LOTO) box on site. The Many Islands’ safety supervisor explained the station’s LOTO process adequately.
• Many Islands representatives stated that the station’s main valves (that may be necessary for emergency purposes), such as isolation valves V001 to V006 and emergency shutdown valves (e.g., ESDV 901 and ESDV 902), have a one-year inspection and maintenance program where they are greased and partially operated, or function tested.
• There were signs of a glycol leak on the engine of compressor unit 3. Many Islands representatives said that the leak was from thermal expansion when the engine was off and the leak stops when the engine is running. They confirmed that adequate monitoring, including a low glycol alarm and a minimum of three visual inspections per week, of the glycol level is in place to ensure safe service.
• There were also signs of a lube oil leak on the engine of compressor unit 3. Many Islands representatives confirmed that the leak was not affecting fitness-for-service and that proper monitoring was in place as well.
• Each compressor unit has a 2000-hour service program which also involves inspection of associated isolation valves and ESDVs. 
• Fire eyes and gas leak monitors are present within the compressor unit buildings. The company stated that the set point for lower explosive limit (LEL) alarms is 20% LEL, whereas an automatic unit shutdown occurs at 40% LEL. The detection of a fire also triggers an automatic unit shutdown.
• Forced air ventilation system with louvre and ventilation fans is present in each compressor building. The systems run automatically on gas detection and stop upon fire detection.
• There is no cathodic protection system installed for the station piping. The company representatives stated that such a system was unnecessary because almost all piping is above ground. Also, there is an annual corrosion inspection program.
• There was a barrel/tank of engine lube oil stored in the compressor unit 3 building at the time of the inspection. Many Islands representatives recognized that the lubricant quantities were greater than those required for everyday use. See the Notice of Non-Compliance for additional follow-up.
• There were some stored soaker pads and cleaning rags in each compressor unit building. CER inspectors recommended that the company reduce the quantities of these materials to the necessary needs only. Following the inspection, on 29 November 2023, Many Islands confirmed that the clean rags and unused soaker pads had been removed.
• The company has a Forward Looking InfraRed (FLIR) Camera program which inspects for gas leaks every four months.
• The pressure vessels have a 10-year inspection interval.
• CER inspectors requested and reviewed the last maintenance records for several devices, including the following:
  • ESDV 901 and ESDV 902: see sheet Macklin A ESD Form on the file named L07 - ESD- System Check - Boost - 05-05-2022. The last function test was done on 12 May 2022.
  • Unit 3 discharge valve ESDV PV-AI-1304.
  • Blowdown valves V-H915 and V-H925: see sheet Macklin A ESD Form on the file named L07 - ESD- System Check - Boost - 05-05-2022. The last function test was done on 12 May 2022.                     See the information request IR No 1 for additional details.
  • Station PSV # PS16-04-PSV-H910: the document named PS16-04-PSV-H910_12-18-2021. See the information request IR No 2 for additional details.
• CER inspectors requested the MOP for the fuel gas entering the compressor unit engines. Many Islands submitted that “the engine manufacturer rates the engine fuel gas system to 60 PSIG as per the attached ‘Macklin Waukesha 7044 S4 Fuel System’ document. The engine manufacturer Waukesha requires that additional pressure regulators be installed if fuel pressure at the engine exceeds 60 PSIG. Pressure control valve PCV-A#-100, set at 50 PSIG, on attached P&ID (E002586-03-115, Sheet 1) fulfils this requirement.  Downstream of the PCV-A#-100, there are two additional regulators (PV-A3-5102, PV-A3-5103) which further reduce the pressure to 5-15 inches of water column (0.18 PSIG to 0.54 PSIG) and thus provide an extra safety layer to protect the engine from pressure higher than 60 PSIG. Additionally, when stopping the engine, valves SDV-A#-100 and SDV-A#-101 close. Valve UY-A#-5104 opens to vent gas from the manifold. These controls ensure that the normal and maximum operating pressure of the fuel gas system is not exceeded. See IR No 3 for additional details.
• CER inspectors requested Many Islands to identify the unit 3 engine’s crankcase explosion door or a suitable crankcase ventilation. Many Islands submitted that “the compressor engines are not fitted with an explosion door. CSA Z662 allows either explosion doors or suitable crankcase ventilation as per clause 4.14.2.10-b. The Macklin Compressor Station engines are fitted with a closed crankcase ventilation kit. This crankcase breather places the crankcase in a light vacuum during operation." 
• CER inspectors requested and reviewed the station’s FLIR Camera procedure/program and the last leak detection report. See IR No 4 for additional details.
• CER inspectors requested Many Islands to provide its procedure for the station's external piping corrosion inspection and the last corrosion inspection report. See IR No 5 for additional details.
• CER inspectors requested Many Islands to provide its procedure for pressure vessel inspection and the report for the last inspection on the horizontal inlet filter separator. See IR No 6 for additional details. 
• Labels indicating product and flow direction were present on some observed main piping. CER inspectors recommend Many Islands to verify all the station’s piping to identify the need for additional labels and flow direction as necessary (per CSA Z662, 4.14.2.11(b)).

Compliance tool used: No compliance tool used

Observation 2 - Notice of Non-Compliance NNC 1 - Lubrication Oil Storage in the Compressor Unit 3 Building

Date & time of visit: 2023-11-23 08:40

Discipline: Integrity Management

Categories:

• Facilities
• Compressor Station

Facility:

• MACKLIN (Facility)

Observations:

There was a barrel/tank of engine lube oil stored in the compressor unit 3 building at the time of the inspection. Many Islands representatives recognized that the lubricant quantities were greater than those required for everyday use.
 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• CSA Z662-23 - Oil and Gas Pipeline Systems

Relevant section(s):

• Clause 10.9.1.5 Storage of fuels and lubricants: Fuels and lubricants for operation of equipment in quantities greater than those required for everyday use, and other than those normally used in compressor and pump buildings, shall be stored in a separate structure built of noncombustible material located a suitable distance from the compressor or pump building. Aboveground storage tanks for such fuels and lubricants shall be protected as specified in the applicable code.

Company action required:

Many Islands was asked to remove any extra quantity of lubricants from the compressor unit buildings (as applicable) to comply with the requirements of CSA Z662, Clause 10.9.1.5.

On 29 November 2023, following the inspection, Many Islands representatives confirmed by email that the oil storage tank was removed from the compressor unit building on 27 November 2023.
 

Due date: 2024-01-19

Date closed: 2024-01-18
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 - Notice of Non-Compliance NNC 2 - Maximum Pressure for Unit Engine Fuel Gaz (follow-up for IR No 3)

Date & time of visit: 2023-11-23 11:00

Discipline: Integrity Management

Categories:

• Facilities
• Overpressure Protection
• Compressor Station

Facility:

• MACKLIN (Facility)

Observations:

In response to CER Information Request IR No 3, Many Islands stated that “the role of this PSV-A#-5102 is to provide over-pressure protection of the engine. Upon subsequent review of manufacturers literature, we agree that we need to implement a pressure protection solution that would protect the weakest component and the engine ie 75 psig (see attached document). We will expect to implement this corrective action at Macklin before Fall 2024. This corrective action will be applied to all MIPL facilities as required.”

CER inspectors are of the view that the current set up of the pressure control and overpressure protection system for the fuel gas entering the Macklin Stations’ compressor unit engines does not meet the requirements of CSA Z662, Clauses 4.14.2.10 d) and 4.18.1.2. MIPL committed to implement their corrective action at Macklin Station before Fall 2024 (i.e., to install pressure protection solutions that would limit the unit engines’ fuel gas pressure at 75 psig). In addition, this corrective action will be applied to all MIPL facilities as required.
 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• CSA Z662-23 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662, Clause 4.14.2.10 d): The pressure-control devices for the fuel gas system for compressor stations shall limit fuel gas pressure such that i) the normal operating pressure of the system is not exceeded by more than 25%; and ii) the maximum operating pressure of the system is not exceeded by more than 10% or 35 kPa, whichever is greater. CSA Z662, Clause 4.18.1.2: Where failure of the pressure-control system, or other causes, can result in the maximum operating pressure of the piping being exceeded, overpressure protection shall be installed to ensure that the maximum operating pressure is not exceeded by more than 10% or by 35 kPa, whichever is greater.

Company action required:

Following MIPL’s response to IR No 3, CER inspectors conducted further discussions with MIPL representatives. As the results, MIPL committed to complete the corrective action as follows:
 

1. For the Macklin Station: MIPL will complete the corrective action to meet the requirements of CSA Z662. In addition, MIPL will submit a confirmation (including a summary of the completed action) to the CER by 30 April 2024; and
2. For other MIPL facilities MIPL will complete the corrective action to meet the requirements of CSA Z662. MIPL will also provide the list of these facilities and the completion confirmation (including a summary of the completed action) by 30 September 2024.

Due date: 2024-09-30

Date closed: 2024-12-23
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 4 - Notice of Non-Compliance NNC 3 - Corrosion Inspection Procedure (follow-up for IR No 5)

Date & time of visit: 2023-11-23 11:00

Discipline: Integrity Management

Categories:

• Facilities
• Piping
• Compressor Station

Facility:

• MACKLIN (Facility)

Observations:

In response to CER Information Request IR No 5, MIPL stated that its “Plant Integrity Management Program was recently merged into a single overarching Integrity Management Program. During this process, some content within the original program was identified as being more suitability contained within a procedure, or other document types. Details relevant to the procedure for external piping corrosion inspection requested by the CER are included within this content. Along with supplemental information, these details will be incorporated into a new procedure(s) meeting the requirements of CSA Z662-23 10.9.1.3. A corrective action plan for this work is in place to ensure publication of this document by September 30, 2024.”

CER inspectors are of the view that MIPL did not demonstrate compliance with CSA Z 662, Clause 10.9.1.3 regarding the Macklin Station’s corrosion inspection procedure.
 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• CSA Z662-23 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662, Clause 10.9.1.3: For stations where corrosive or potentially corrosive conditions exist, procedures shall be established for periodic inspections at sufficiently frequent intervals to enable corrosion to be discovered before serious impairment of the strength of the piping or equipment has occurred. Where needed, repairs or replacements shall be made promptly.

Company action required:

Following MIPL’s response to IR No 5, CER inspectors conducted further discussions with MIPL representatives. During that meeting, MIPL committed to complete its station corrosion inspection procedure (that meets the requirements of CSA Z662) and submit a copy to the CER by 30 June 2024.
 

Due date: 2024-06-30

Date closed: 2024-12-23
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 5 - Notice of Non-Compliance NNC 4 - Pressure Vessel Inspection Procedure (follow-up for IR No 6)

Date & time of visit: 2023-11-23 11:00

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels
• Compressor Station

Facility:

• MACKLIN (Facility)

Observations:

In response to CER Information Request IR No 6, Many Islands stated that “MIPL’s Plant Integrity Management Program was recently merged into a single overarching Integrity Management Program. During this process, some content within the original program was identified as being more suitability contained within a procedure, or other document types. Details relevant to the procedure for pressure vessel inspection requested by the CER are included within this content. Along with supplemental information, these details will be incorporated into a new procedure(s) meeting the requirements of CSA Z662-23 clauses 10.9.2.8 and 10.3.2.5. A corrective action plan for this work is in place to ensure publication of this document by September 30, 2024.”

CER inspectors are of the view that MIPL did not demonstrate compliance with Clauses 10.9.2.8 and 10.3.2.5 of CSA Z662 regarding the Macklin Station’s pressure vessels inspection procedure.

 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• CSA Z662-23 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662, Clause 10.9.2.8: Pressure vessels shall be inspected as specified in API 510 (STD) to determine that they are being maintained in proper operating condition. Repair and alteration shall be as specified in CSA B51. CSA Z662, Clause 10.3.2.5: Operating companies shall operate and maintain their pipeline systems in accordance with documented procedures that meet the requirements of Clause 10.5.

Company action required:

Following MIPL’s response to IR No 6, CER inspectors conducted further discussions with MIPL representatives. MIPL committed to complete its pressure vessel inspection procedure (that meets the requirements of CSA Z662) and submit a copy to the CER by 30 June 2024.
 

Due date: 2024-06-30

Date closed: 2024-12-23
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

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: