Compliance Verification Activity Report: CV2324-201 - Westover Express Pipeline Limited

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2324-201
Start date: 2023-12-13
End date: 2023-12-13

Team:

Regulated company: Westover Express Pipeline Limited

Operating company: Westover Express Pipeline Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Safety and Integrity inspection of Westover Express to verify compliance with the OPR, CSA Z662, and CLC.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - NNC - No Smoking Signage

Date & time of visit: 2023-12-13 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Signage indicating that smoking is prohibited was not visible at Station 566 and 572. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Ensure signs indicating that smoking is prohibited are displayed in hazardous areas for all stations and remote sites on line 10.

Due date: 2024-02-02

Date closed: 2024-01-30
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 2 - Safety

Date & time of visit: 2023-12-13 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officer (IO) met with WEX representatives at their administration officers in Ancaster, ON. IOs explained the purpose and scope of the inspection, which included a review of documents sent to the CER before the inspection and a site inspection of Line 10 facilities. 

IO reviewed the company’s confined space standard operating procedures prior to the inspection. Company representatives told IOs that the inventory of confined spaces includes two pits at Welland River East and West. Although no work in confined spaces was observed during the inspection, WEX representatives provided an overview of their procedures. They stated that no workers had entered a confined space since the company acquired operational control of Line 10 in September 2023.

Company representatives explained WEX’s safe work permit process, explaining that supervisors, managers, and the safety manager have permit-issuing authority.

IOs asked how WEX manages and tracks preventative maintenance and inspection tasks on critical equipment. WEX representatives explained that they had adopted the maintenance and inspection frequencies from Line 10’s previous owner, Enbridge, and that these frequencies may be assessed and modified in the future. Company representatives provided a demonstration of their process for tracking maintenance and inspection tasks and record keeping. The process is still in development.

IO reviewed WEX’s Control of Hazardous Energy Standard prior to the inspection. Upon inquiry, WEX representatives stated they had not performed any energy isolations since acquiring Line 10 other than locking the Line 10 unit 3 pump motor.

Westover Electrical Switchgear Building 10-ESB-2
GPS 43.330, -80.094

Westover Pump Units, Station Piping, and Sump
GPS 43.329, -80.093 Station 566 - Smithville
GPS 43.096, -79.620 Station 572 – NX
GPS 43.001, -79.031

Compliance tool used: No compliance tool used

Observation 3 - 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 4 - Integrity - Line 10 Pump Station and Valve Sites

Date & time of visit: 2023-12-13 08:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

Office
CER inspectors met with Westover Express Pipeline Limited (WEX) representatives at the WEX Ancaster office to conduct the opening meeting and discuss the information provided prior to the inspection. WEX explained the process flow and the piping and instrumentation diagrams provided. WEX explained that only two and the three pumps at the Line 10 pump station are used, and the one not in use has been locked out. A pressure control valve is used for pressure control at the discharge of the fixed-speed centrifugal pumps. There are redundant pressure transmitters to monitor the suction, case, and station discharge pressures. The MOP for line 10 at the discharge of the pump station is 540 psi, and the maximum setpoint value for the pressure control is 520 psi. For overpressure protection, there is a high-pressure alarm set at 540 psi and a high-high pressure shutdown set at 560 psi.

WEX explained that pipeline inspection, testing, and maintenance records have not been provided yet by the previous pipeline owner (Enbridge). However, WEX indicated that they hired two independent third parties to assess the results of the past In-Line Inspections to assess the integrity of the pipeline system before taking ownership of Line 10. WEX explained that they have hired a contractor to conduct the inspection and testing of the pressure control and overpressure protection equipment with the goal of completing this work by the end of the year.

WEX explained that all the mainline valves were stroked to confirm that they can fully close and open and that they hold pressure. This was completed last September.

Line 10 Pump Station

After the meeting, CER inspectors completed the site inspection. The Line 10 pump station is located within the Enbridge Westover Terminal, except for the Line 10 ESB building which is located just outside the terminal in a separate fenced area.

The Line 10 ESB Building site is fenced and the main entrance has signs with the company name, emergency phone number, and signs warning of the potential presence of high pressure petroleum product. The building is equipped with smoke and heat detection. The building hosts the uninterruptible power system (UPS) for power backup. There also is a diesel generator outside the ESB building and WEX confirmed that the generator provides sufficient power to maintain the instrumentation and operate the station emergency shutdown (ESD) system, which includes closing the station isolation valves.  The generator is checked weekly and run monthly. There is gas detection outside the ESB building.

CER inspectors observed the redundant pressure transmitters to monitor the station's suction, discharge, and mainline pressures. There are thermal relief valves installed throughout the station to protect from overpressures due to thermal expansion when sections of the piping are isolated. The thermal relief valves discharge to a sump.

The piping coating was in good condition and arrows were present to indicate the direction of flow.

Two ESD push buttons were observed on the exterior wall of the previous owner's Line 10 ESB building, which is located close to the Line 10 pump station.

The Line 10 pump units are equipped with vibration and temperature monitoring and protection devices. The units have seal leak containment and detection systems. Any seal leak would drain to a fibreglass sump tank. The sump tank is equipped with level monitoring and a high-high level switch. A high-high level in the sump tank would trigger a station shutdown and isolation. The pump units are equipped with unit shutdown push buttons.

Line 10 starts at the Westover terminal and there is a pig launcher on site. There is also instrumentation, including a flow meter, used for the leak detection system of Line 10.

Smithville Valve Site

The valve site is fenced and the main entrance has signs with the company name, emergency phone number, and signs warning of the potential presence of high pressure petroleum product. The site hosts an electrical building, a few isolation valves and a bypass equipped with a flow meter and other instrumentation. WEX explained that this flow meter is not used for leak detection but is used to track the batches in the line. The coating on the above-ground piping and valves was in good condition.

West Niagara Valve Site

The valve site is fenced and the main entrance has signs with the company name, emergency phone number, and signs warning of the potential presence of high pressure petroleum product. The site hosts an electrical building, a few isolation valves, a pig receiver, and a pig launcher. This is the last valve site on the Canadian side of Line 10. The mainline isolation valves before crossing the Niagara River are motorized and operable from the control room. The coating on the above-ground piping and valves was in good condition.

Compliance tool used: No compliance tool used

Observations (company follow-up 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