Compliance Verification Activity Report: CV2324-270 - PKM Cochin ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2523

Regulated company: PKM Cochin ULC

Operating company: PKM Cochin ULC

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Integrity Management

Rationale and scope:

Operations Inspection of the PKM Cochin ULC Hayter Pump Station.

Compliance tool(s) used:

• None

Facility details

Facilities:

• HAYTER PS

Facility Types

• Pipeline
• Pump 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: 2023-11-22 07:55

Discipline: Integrity Management

Categories:

• Facilities
• Pump Station

Facility:

• HAYTER PS (Facility)

Observations:

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

• At CER inspectors' arrival, the company conducted site-specific safety orientation.
• 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.
• Labels indicating product and flow direction were present on observed piping. However, some labels were damaged (from wear and tear) in the strainer’s area. Cochin representatives committed to replacing the damaged labels by 29 November 2023. On 7 December 2023, Cochin confirmed that it replaced the damaged labels. They also committed to inspect and replace all such damaged labels at all 10 Cochin’s Canadian pump stations by the end of 2023.
• The open and close positions, functions, and identification numbers were marked on isolation valves.
• CER inspectors reviewed the Pembina Safety Program SP09 Benzene Standard version 1.1 dated 30 September 2023 and the Condensate Non-toxic (UN 1267 PGI) Safety Data Sheet dated 7 December 2020. Based on this information, the station processes sweet condensate with a Benzene concentration of 0.1 to 1.5 %.
• The station is continuously monitored (24/7) by the Cochin Control Centre in Sherwood Park, AB. There is a local control computer in the office building which allows some basic controls such as emergency shutdown (ESD) and the reading access for the unit’s main operating data.
• There is a bump testing station for four-head gas monitors. One Cochin employee was wearing such a monitor during the inspection.
• Several fire extinguishers were installed across the station. CER inspectors randomly verified that several of them had up-to-date inspection records. 
• ESDs were also present at 3 gates and at both doors (one inside and the other outside) of the pump building.
• The station is part of the Cochin NPS 12 Pipeline, which receives condensate from the US.
• The station includes one centrifugal pump unit (model Byron Jackson Products BHP 3087) driven by an induction motor (type FODS, 3000 HP). The pump unit was operating at the time of the inspection.
• Eyewash and first aid kits were available.
• Station equipment maintenance planning, scheduling, execution, reporting, and recording are done using a software.
• The station is equipped with a backup natural gas-powered generator capable of ensuring the station’s isolation and critical safety needs during emergency situations. Upon commercial power loss, the station will switch to the backup generator. Upon generator power loss, the station would transfer to the UPS, which is capable of producing the necessary power for lighting and the local control computer. The UPS is tested annually. The generator is run-tested monthly and load-tested annually.
• Cochin representatives stated that:
  • the facility has a maximum operating pressure (MOP) of 1440 psi, 
  • the set pressure control limit is 1100 psi, and
  • Station overpressure limit is 1150 psi (which triggers an emergency shutdown).
•  The Local Control Centre/building houses a MCC and a VFD for the pump motor.
• CER inspectors requested and obtained that Cochin representatives explain the locked-out and tagged-out (LOTO) procedure
• CER inspectors reviewed certain station Process & Instrumentation Diagrams (P&IDs).
• Fire eyes and gas leak monitors were present within the pump unit building.  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.
• The pump unit has shutdown and alarm devices that operate in the event of inadequate cooling or lubrication of the unit. It also has continuous monitoring alarms for speed, vibration and seal leaks. All such devices are inspected and tested annually.
• The station does not have a sump tank. Cochin representatives stated that such a sump tank is not required because:
  • On the pump unit, there are installed seal leak detection and collection means (e.g., the pump’s double wall construction, leak collection tray), and 
  • In the station’s yard, potential leaks would be detected by the mainline leak detection system which has two pressure detection devices on the yard piping (one upstream and one downstream of the station isolation valves).   
• Strobe/beacon lights used to indicate and warn against the presence of a hazardous atmosphere in the pump building were located on the compressor building.
• The pump building has no active ventilation system with louvres and fans. Instead, one side of the building is made with a steel mesh screen for passive/natural ventilation.
• The station houses two pressure transmitting/monitoring devices at the station isolation point (PT 05 at the upstream side and PT 01 at the downstream side).
• The yard piping includes two Pressure Safety Valves (PSV 30 and PSV 31) to protect against potential overpressures due to temperature. There are also two regular PSVs in the Drain Down Skid building. Each PSV is tested annually (pop test) and sent for calibration if found out of specification.
• The CP system’s readings (for the rectifier and key protection data) are automatically sent out weekly via a satellite device. In case of abnormal reading, an alert is issued for action. In addition, a pipe-to-soil survey is conducted annually. An atmospheric corrosion inspection is conducted at the same time.
• There is a drag-reducing agent (DRA) injection site, housing two tanks.

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: