Compliance Verification Activity Report: CV2223-100 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2083
• Inspector 2879

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Integrity Management

Rationale and scope:

Integrity inspection of Edmonton Terminal West Tank Area Expansion Project fire protection system to verify compliance to OPR, CSA Z662-19, CLC, and OC-65.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

• EDMONTON

Facility Types

• Pipeline
• Terminal

Life-cycle Phases

• Construction
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• OC-065

Observations (no outstanding follow-up required)

Observation 1 - Discussion Prior to Field Inspection

Date & time of visit: 2023-02-22 09:00

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• EDMONTON (Facility)

Observations:

CER inspectors met with Trans Mountain (TM) representatives at the Edmonton Terminal to inspect the fire protection system of the Edmonton Terminal Expansion Project West Tank Area (WTA). Note that a reference to TM is intended to represent Trans Mountain Expension Project (TMEP) or Trans Mountain Corporation (TMC) representatives. Prior to completing the field portion of the inspection, CER inspectors discussed the following items with TM:

Tank Settlement during Hydrotest
In response to IR #1 of the previously conducted CER inspection CV2122-259, TM provided an Addendum Report from Thurber Engineering LTD which recommended the monitoring of the tank settlement during the hydrotest of the new tanks. TM explained that a survey company was hired to monitor the potential settlement of the tanks during the hydrotests. The survey company conducted surveys prior to, during, and after the hydrotests to monitor the settlement. TM explained that the results of the survey were acceptable to API 650 for all the tanks and that no corrective actions were necessary.

Volume of Secondary Containment
TM explained that the construction of the secondary containment is almost but not fully completed yet. Once the secondary containment is completed, TM explained that it will survey the secondary containment areas, develop a 3D model and calculate the volumes of the secondary containments to confirm it conforms to its design (Condition 23) and is compliant with the regulatory requirements. TM explained that there have not been any significant changes to the secondary containment from the final design and therefore no issues are anticipated when the volume is confirmed.
 
Monitoring of Fire Water and Foam Concentrate Volumes
TM explained that there are two new 12,000-gallon tanks for the foam concentrate of the tanks in the scope of the WTA, but technically only 8,000 gallons are needed. These tanks are not yet filled with foam concentrate. TM explained that the level of the foam concentrate tanks will be verified twice daily by TM staff during the checks that occur during each shift (two shifts per day), as it is for the water reservoir and other existing foam tanks right now. The water reservoir is also equipped with a low-level alarm set at 15 ft and a low-low-level alarm set a 6 ft of remaining water in the pond. TM could not confirm during the inspection what the level heights represented in terms of remaining volume. The new foam concentrate tanks will also be equipped with low-level alarms which will be set at 1.5 ft from the tank bottom, which represents approximately 1,200 gallons.  The alarms for the foam concentrate tanks and the water reservoir are sent to the control center. TM indicated that any foam concentrate that is utilized out of the tanks, for whatever reason, is replaced shortly after. An Information Request (IR) was issued to obtain more information on the set point values of the water level alarms and the purpose of those alarms (See IR #1).

Dry Commissioning
TM explained that the dry commissioning has not started yet. However, the project is in the last stages of construction and it is a matter of weeks before dry commissioning starts.


NCR Number ET-WPC-NCR-0094
TM reported the following Non-Conformance Report (NCR) to the CER as part of Condition 105:

Non-Conformance Description:
Field weld #2 on isometric ET00-P-5264-NPS20-A101 did not undergo radiographic testing prior to backfill contrary to owner requirements and ITP inspection point.

Disposition Details:
Contractor will expose field weld and perform radiographic examination prior to hydrotest. Contractor to ensure all welds receive NDE prior to backfill and will perform an audit of all welds to ensure NDE is complete.

TM explained that the contractor self-identified this non-conformance as part of its quality assurance (QA) process and that the contractor reported it to TM as required. TM explained that the contractor inadvertently backfilled the weld that had not yet been radiographic tested but that the contractor's QA process worked as intended and identified the error. TM explained that the contractor completed the audit of all of the welds and that no other similar issue was identified. TM also conducted its own audit of the welds and also confirmed that there were no other similar issues. TM explained that it was satisfied with the actions taken by the contractor and that no other corrective or preventive actions beyond those already implemented were necessary.

Fire Protection Design Basis, Firefighting Capacity and Fire Pre-Plans 

• TM explained the new foam solution and fire water headers for WTA. The system consists of four headers: South, West, Center and East to deliver foam solution and water to the tanks, hydrants, and fixed monitors located on site. The headers can be filled with either foam solution or water depending on the need.

• TM explained that the below-ground portion of the new foam solution and fire water piping is made of High Density Polyethylene (HDPE). The above-ground portion of the piping is made of galvanized steel. The hydrotesting of the HDPE piping is mostly complete.

• TM explained that tanks 20 and 21 have metal foil covered foam internal floating roofs (IFRs) but that these roofs were planned to be replaced by steel pontoon IFRs before returning to service (the tanks are currently empty of product). The latest version of the Fire Pre-Plan provided to the CER includes calculations for extinguishing rim seal fire on these two tanks, but this is not an adequate tactic for the current IFRs in these tanks. TM explained the rim seal calculations for these two tanks had been made in anticipation that the IFRs would be replaced, that the Fire Pre-Plan is currently being revised, and that if the tank roofs are not replaced as planned, then the Fire Pre-Plans will be revised to remove the rim seal fire tactic for these two tanks. An IR was issued to obtain more information on the revision of the Fire Pre-Plans (see IR #2 and on the replacement of the IFRs for tanks 20 and 21.

• TM explained that valve sequencing and operation for sending the foam solution to the tanks are automated. After confirmation by field staff of a tank fire, the Control Center Operator (CCO) will confirm the fire alarm and this will trigger the necessary valves to open to allow the foam to be delivered to the tank. The opening of the valves will create a pressure drop in the fire protection system, which will trigger the fire pumps to start sending foam solution to the tank on fire. Field staff located in the fire pump building will manually stop the flow of the foam at the necessary time: 20 minutes (min.) for a rim seal fire, 65 min. for a full surface fire.

• CER inspector noted a discrepancy between the foam application time for a full surface fire between the Design Basis (55 min.) and the Fire Pre-Plans (65 min.). TM explained that NFPA 11’s required application time with a fixed fire protection system for such fire is 55 min., but that for consistency, it will use an application time of 65 min. as this is the required application time for their mobile system.  

• CER inspector noted that the Fire Pre-Plans did not include a description of the more recent fire water pumps that were installed for the previous expansion and that will be used for the WTA. TM confirmed that section 3.4 (fire pumps) of the June 2022 fire pre-plan only referenced legacy fire pumps. TM also indicated that some of the additional fire suppression equipment listed in section 3.1.2 will also need to be updated. TM explained the fire pre-plan is in the process of being updated and will include the fire pumps added as part of the TMEP. An IR was issued to obtain more information on the revision of the Fire Pre-Plans (see IR #2).

• TM confirmed that the extra 1700 ft of hose and the 4 SCBA bottles that needed to be added according to Table 3 of the Firefighting Capacity at Edmonton Terminal document filed with the CER for Condition 118 have been acquired and will be ready to use when the tanks will be put in operation.

• TM explained that the tank spacing requirements have been incorporated in the design of the terminal and that the location of the tanks is as per the design and has been verified by survey.

• TM indicated that all tanks, new and existing, in scope of the WTA are currently empty of product.

Compliance tool used: No compliance tool used

Observation 2 - Field Portion of the Inspection

Date & time of visit: 2023-02-22 10:00

Discipline: Integrity Management

Categories:

• Facilities
• Aboveground Tanks and Pressure Vessels

Facility:

• EDMONTON (Facility)

Observations:

Operations/Maintenance Building

• The building houses three trailers with firefighting hoses and a foam bladder system.
• The building is heated and was warm at the time of the inspection.
• One of the trailers was recently acquired and has 18 X 30-meter lengths of new 6-inch hoses.
• Another older trailer has 20 X 30-meter lengths of 6-inch hoses.
• TM explained that checks are conducted monthly on the trailers and their equipment to ensure their readiness and that the hoses are hydrotested annually.
• TM explained that the proportioner of the bladder system is tested annually to verify that it produces a 3% foam solution and the foam concentrate is also sampled and tested annually to verify its quality. The foam concentrate for this system is AFFF-LT 3%.
• The three trailers appeared to be in good condition and ready to be used.

• The test header is located on the outside of the building and TM indicated that a flow test is conducted annually.
• The building houses two 5000 GPM vertical shaft fire pumps, both driven by diesel engines. One pump unit can be used as the backup to the other. Each engine has a dedicated diesel tank. The fuel volumes are verified during the shift checks and the tanks are equipped with a low-level fuel alarm to warn the control center.
• The diesel engine exhausts are piped through the roof to vent outside the building.
• TM explained the building is checked twice daily to verify the condition of the equipment.
• TM explained the pumps are run weekly for 30 minutes.
• The building is heated and was warm at the time of the inspection.
• The building is equipped with a low-temperature alarm.
• The building is equipped with a sprinkler system.
• The building was clean and the equipment was in apparently good condition.

• CER inspectors observed that an extension cord was being used to feed the heat tracing system for the pressure sensing line connected to the fire pump controller. TM indicated that the extension cord is only temporary and that it will be hardwired as a permanent solution within a month.
• The building has fans and louvres for ventilation. The louvres and fans are regulated only by temperature controls in the building. TM explained that when the temperature reaches 24 degrees Celsius, the louvres open up and the fans turn on and will not let the temperature in the building reach 49 degrees Celsius.  TM also indicated that the square footage of the building provides enough air flow movement for the engine combustion and the engines are exhausted through the roof of the building to remove hazardous vapours. These engines have heat exchangers that cool with the water of the fire protection system and no air is required for the radiator cooling.
• The fire water control valves in the building are of the outside stem & yoke (OS&Y) type. They were not locked, sealed or otherwise supervised.  TM indicated that their procedure requires them to be car sealed in their normal operating position. This was addressed while CER inspectors were on site.

• The legacy fire pump building houses the fire protection system for tanks that were outside the scope of this inspection. The inspection in this building was limited to the water reservoir level monitoring and the fill line.
• TM staff verifies and adjusts the water reservoir level through this building. There is a hatch that opens on the building cistern where a red painted line indicates the required water level. If water needs to be added, there is a fill line to supply water from the city to fill the reservoir.
• At the time of the inspection, the water level was slightly below the bottom of the red line and TM indicated its staff would ensure it is properly filled up during the twice-daily checks.
• The building is heated and was warm at the time of the inspection.

• There are 7 SCBAs ready to use for TM’s staff and 4 SCBAs for the contracted third party hired to respond to tank fires. Newly bought SCBAs that were needed following the expansion were still in boxes. TM explained that they would be ready for when the WTA goes into operation.
• The bunker gears and an emergency response truck of the third-party responder are also located in this building.
• Extra hoses were located in this building.
• The building is heated and was warm at the time of the inspection.

• Two new 12,000-gallon tanks have been installed in this building. These tanks will store AFFF 3% foam concentrate for the WTA. TM explained that this foam concentrate is not rated for low temperatures but the building will be heated to ensure the foam concentrate is maintained at an adequate temperature.
• Construction was still in progress and the tanks have not been filled yet.
• The tanks are connected to the foam injection pumps located in the pre-existing foam pump building located just beside it via stainless steel piping.

• This building houses two 3,000-gallon tanks of foam concentrate, two foam concentrate injection and proportioning systems, and manifolds for sending the foam solution or water to the storage tanks. The two tanks are checked and maintained to approximately 2,500 gallons.
• The two foam injection pumps are electric driven and are also powered by an alternate source of power (diesel generator) to ensure they can operate during a power loss event. TM explained the pumps are run monthly for 10 minutes.
• The valves on the manifolds are all motor operated, with position indicators, and can also be manually operated.
• The building has a fire and smoke detection system that would alarm the control center.
• The building is heated and was warm at the time of the inspection.
• The building was clean and the equipment was in apparently good condition.
• TM explained that the proportioners are tested annually to verify that it produces a 3% foam solution and the foam concentrate is also sampled and tested annually to verify its quality.

• Work was in progress on the fire protection system piping pump out location beside tanks 10 & 23. This location will be used to drain the system as it will operate as a dry system.
• CER inspectors observed that the below-ground piping was HDPE pipe and the above-ground was made of galvanized steel.
• CER inspectors observed high-volume hydrants and fixed monitors located beside the access road in proximity to the storage tanks.

• The foam chambers on the new tanks are positioned above the tank wind girder and mounted horizontally. CER inspectors noticed some snow accumulation on the screens for the air intake of the foam chambers. TM explained that to ensure that snow does not build up on the wind girders of the four new tanks and cover the foam chamber screens, Trans Mountain operations staff will perform daily checks during the winter months and clear all snow that has accumulated.

• For the existing tanks in the scope of WTA, the new foam chambers are located just below the wind girder and did not appear to accumulate snow.
• CER inspectors went on top of Tank #1, which was recently erected as part of the WTA. Outside stem and yoke (OS&Y) valves were observed just upstream of the foam chambers. TM explained these can be closed during maintenance (such as during flushing activities) and will be kept car sealed open during normal operation.
• A radar level gauge and a level switch are accessible from the platform on the tank roof. TM explained that an alarm would be triggered at a high-level event and that the pumping to the tank would be shut down and the tank valve would be automatically closed on a high-high-level event.

• The foam cannon trailer that is used for the fire protection mobile system is located in this building.
• There are also two trailers with 8 totes of AFFF-LT 3 % foam concentrate on each trailer. Each tote contains 265 gallons.
• TM explained that monthly checks are conducted on the fire protection equipment in this building and the foam concentrate is tested annually to verify its quality.

Compliance tool used: No compliance tool used

Observation 3 - CNC #1 - Pallets in Front of Emergency Trailers

Date & time of visit: 2023-02-22 12:00

Discipline: Emergency Management

Categories:

• General
• General

Facility:

• EDMONTON (Facility)

Observations:

Cold Storage Building
The emergency response trailers were in apparent good condition but there were some materials on wood pallets that had been stored in front of the trailers, which could have slowed down the deployment of the trailers if needed. This is a non-compliance to CSA Z662-19 clause 10.2.7.2 (d).  TMEP took immediate actions to remove the pallets, and this was addressed during the inspection.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• CSA Z662-19 - Oil and Gas Pipeline Systems

Relevant section(s):

• 10.2.7.2 Operating companies shall maintain appropriate firefighting equipment. Such equipment shall be a) plainly identified; b) maintained in proper operating condition; c) regularly checked and certified; d) readily accessible; and e) positioned as specified in NFPA standards.

Company action required:

The company removed the pallets to address the non-compliance. No further actions required.

Due date: 2023-02-22

Date closed: 2023-02-22
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: