Compliance Verification Activity Report: CV2122-335 - Plains Midstream Canada ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-335
Start date: 2021-11-04
End date: 2021-11-04

Team:

Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Field inspection of Plains Storage Facility operations to verify compliance to the OPR and CSA Z662-19.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Safety Observations

Date & time of visit: 2021-11-04 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

  1. CER Inspectors arrived on site at Plains Midstream Canada’s (PMC) operations located at 4200 Matchette Rd on November 4, 2021  0830 AM.
  2. CER Inspectors completed site specific orientation. AED location in the main building was identified. All operators were trained to use AED. Additionally, workers were required to use a four head gas monitor.
  3. CER Inspectors reviewed with the company facilities and equipment under the jurisdiction of the CER.
  4. CER Inspectors were informed that the operators were responsible for rail loading operation, monitoring the SCADA system in the site control room, and perform routine rounds in the facility, among other duties.
  5. The facility is fenced off and has security cameras in place for some of the locations.
  6. During the opening meeting, PMC reviewed facility process flow, maximum operating pressures, fluids stored in caverns, key process equipment, and maintenance.
  7. Operators presently work 6 days per week for up to 8 hours per shift. The facility is put on standby for one day per week. There are no control room operators or other Operators located on premises during this time. Prior to transitioning the facility to standby state, the caverns are isolated and head operating pressures reduced. Specific isolations are carried out to facilitate standby state. The procedure was developed after a MOC was completed by PMC and draft procedure was developed in consultation with area Operators.
  8. PMC shared that the decision to allow the facility to be put on standby for one day per week had been assessed through a Management of Change (MOC) process. A redlined procedure was shared with the CER Inspectors indicating steps needed to facilitate standby state of the Plant. PMC was in process of converting redlined procedure to a controlled document during the inspection. MOC# 108670 was provided to capture company’s assessment.
  9. CER Inspectors were informed that Pumps 341 and 342 can be remotely  monitored from Olds Control Centre and remain in operation when the remainder of the facility is on standby without any operators onsite. These pumps form part of the WSP supply system.
  10. PMC shared with CER Inspectors that company management was in process of hiring additional staff to address coverage issues. During the inspection a trainee was present at the facility.
  11. CER Inspectors were informed by an operator of an increase in traffic from Main gate to facility office. Inspectors note that there is a locked gate installed at the facility entrance which is opened by the control room operators. 
Operator interview
  1. PMC facility has operators working an 8-hour shift. There is one operator on site for six days per week. An operator explained that at the start of each shift, the operator on shift is expected to perform a unit check (field check), rail car loading (as required based on frequency of 1-2 times per month) and perform duties of a control room operator.
  2. Operator indicated that the draft standby facility operation procedure had been reviewed and signed off. This procedure was developed by PMC in consultation with the operators as part of the MOC process.
  3. Operator indicated that although a MOC had been performed, it was challenging to effectively accomplish duties of a control room operator given other tasks such as rail car loading and unit checks. Additionally, adequate consultation may not have occurred with Operators during the MOC process.
  4. Further discussion indicated that the Operator was concerned about facility’s return to normal operating state after leaving it on standby for a day, despite a signed off MOC and a draft procedure. PMC management were notified of this concern and to address it by further consulting the impacted operators. 
  5. During the interview, discussion occurred on ability to safely execute work with appropriate training. Concerns around task demand for rail loading were further reviewed. A Company representative (supervisor) shared changes on additional alerting or warning systems the company was evaluating for installation. Additional concerns expressed by the Operator were reviewed. 

Compliance tool used: No compliance tool used

Observation 2 - Integrity Observations

Date & time of visit: 2021-11-04 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Windsor Terminal Discussion
CER inspectors confirmed the facilities under the CER jurisdiction with Plains Midstream Canada (PMC) staff. PMC explained the normal product flow at the facility, including the operation of the four pipelines connected to the facility and the four storage caverns regulated by the CER. The breakdown between the different design codes (CSA Z662, CSA Z341 and ASME B31.3) were also discussed.
 
PMC explained that most of the facility was built in the 70s, except for the Windsor to Sarnia Pipeline (WSP) pump station which was built in 2016.
 
The caverns normally operate at lower pressures than the pipelines feeding into the facility. When pipelines are shipping to caverns, pressure control is achieved by pressure control valves (PCVs). When product is added into a cavern, brine is displaced out of the cavern toward the brine production ponds. Before reaching the ponds, the brine goes through a separator and potentially entrapped hydrocarbons are sent to a flare. The brine then continues to the burn pit to remove potential traces of hydrocarbons that could have been left before going in the production pond.


Cavern I-4 Wellheads
The cavern is a dual completion wells, one for the brine and the other one for the product (butane). The brine line is equipped with an emergency shutdown valve (ESV) which would be triggered by a High-High pressure detection. The product line is also equipped with an ESV. There are gas detectors nearby the product wellhead. PMC explained that the LEL gas detector would trigger alarms at the facility control room at 10% LEL and 20% LEL. PMC explained that it is planning to make the gas detection system near the cavern to automatically initiate an emergency shutdown of the facility following a gas leak detection.
 

Pump Station Area (P-310, P-320, P-330, P-340)
Of the four pumps at this location, only P-310 is operating, while sitting in P-320’s location. PMC explained that P-320 and P-330 are being repaired and that P-340 is no longer in use. The pumps are located outside and are protected by a roofed structure. There was a gas detector on the cable trays located in proximity of the pumps.
 
P-310 was in operation at the time of the inspection. The pump unit is equipped with temperature and vibration monitoring devices on the bearings as well as pressure switches to monitor for seal leaks. There are collection systems to redirect seal leaks to the flare stack. PMC explained that if a seal leak is detected, the pump unit is automatically shut down and isolated. The pump unit suction and discharge pressures are monitored. Pressure control on the discharge of the pump unit is achieved with a PCV. There was a unit stop push button near the pump unit.

WSP Pump Station
This pump station has two pump units which are remotely monitored and operated by PMC’s control room located in Olds, Alberta. The pump units are under a roofed structure with partial walls. There are gas and fire detection devices to monitor the pump units. The pump units are equipped with temperature and vibration monitoring devices on the bearings as well as pressure switches to monitor for seal leaks. There are collection systems to redirect seal leaks to the flare stack. PMC explained that gas, seal leak or fire detection would trigger a pump station shutdown and isolation. Pressure is monitored on each pump unit and the station suction and discharge pressures are also monitored. Pressure control on the discharge of the pump unit is achieved by controlling the speed of the pumps. There was a plant emergency shutdown (ESD) button near the pump units.
 
There is a pressure relief valve (PSV303) just upstream of the pump station. The set point of the PSV on its tag indicated 1060 psi and was last inspected in 2018. PMC explained that relief valves are inspected and tested on a five year frequency. There was also a pressure transmitter located downstream of the PSV.
 
 
Cavern E-1 Wellheads
The cavern is a dual completion wells, one for the brine and the other one for the product (butane). The brine line is equipped with an emergency shutdown valve (ESV) which would be triggered by a High-High pressure detection. The product line is also equipped with an ESV. There are gas detectors nearby the product wellhead. PMC explained that the LEL gas detector would trigger alarms at the facility control room at 10% LEL and 20% LEL.
 
 
Flare Stack Area
The flare line supports appeared to be in good condition. The coating on the steel components of the supports was in good condition and the visible portion of concrete bases also appeared to be in good condition. PMC explained that there are 3 pilots on the flare stack and that they are monitored with thermocouples. Alarms are generated at the local control room when the temperature of any of the thermocouples gets below its setpoint (as an indicator of an igniter being potentially extinguished). PMC explained that there is an automatic re-igniter on the flare stack as well as a manual back-up re-igniter that staff could use the re-ignite an extinguished flare pilots. 

There is a large pressure vessel upstream of the flare stack where potential hydrocarbons liquids are to be retained during a flare event. The vessel is equipped with a level switch which would automatically trigger a Plant ESD if the level reaches 50% of the vessel volume. Several gas detector devices were located in the area near this vessel.

Burn Pit
There were two lit pilots located on the outlet of the “gooseneck” pipe that returns the brine to the production ponds.  The last segment of the gooseneck pipe that is open to the burn pit showed some signs of external corrosion but its structure did not appear to be compromised when observed from distance. The vertical riser of the gooseneck pipe and its support appeared to be in good condition. The burn pit is a hazardous area and can only be accessed under a special permit approval. There is a chain and several signs warning of the danger and indicating to not enter the area of the burn pit. PMC explained the hazard associated with the burn pit area and the procedure to follow as part of the onsite orientation. PMC explained that this orientation is also provided to contractors and visitors coming onsite.
 
Dehydrators
The dehydrators uses calcium chloride pellets to remove traces of water in the product coming out of the caverns. PMC explained that the product quality is confirmed with manual sampling and testing. The dehydrator vessels are protect by PSVs and PMC explained that all product PSVs are inspected and test every five years. PMC explained that pressure vessels are inspected as per API 510.


 

Compliance tool used: No compliance tool used

Observation 3 - Integrity Information Request - Assessment of the Production Ponds Berms

Discipline: Integrity Management

Categories:

Facility:

Observations:

PMC explained that they used to have erosion issues when only one of the two ponds located on either side of the flare stack was used for production. PMC indicated that they hired Golder and Associates to assess the condition of the berms and that recommendations were implemented to mitigate the erosion issues. CER inspectors observed that waves breakers were in place. PMC indicated that it was one of the recommendations from Golder. PMC explained that they now use the two ponds instead of only one and that they maintain similar levels between the two ponds to prevent further damage to the berm separating the two ponds. Some slumping and erosion were observed on the berm between the two ponds, where the flare line supports are located, but PMC staff indicated that this had been stabilized with the changes implemented. PMC also explained that Golder confirmed that the integrity of the berms had not been compromised by the erosion that occurred.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide a copy of the Golder and Associates report that was conducted to assess the condition of the production brine ponds berms. Explain if the recommendations made in that report were implemented. If some recommendations have yet to be implemented, please explain why and, as applicable, the timeline for implementing them.

Due date: 2022-03-18

Date closed: 2022-03-25
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 - Integrity Information Request - Potential Leak at BV389

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors observed that BV389 was frosted, suggesting a potential leak. PMC verified with a four head monitor around the valve and no LEL was measured. BV389 is located on a drain line going to the flare stack.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

PMC to confirm if there was a leak causing the frost on BV389 and, as applicable, PMC’s plan and timeline to repair the leak.

Due date: 2022-03-18

Date closed: 2022-03-25
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 - Integrity Information Request - Response to Flare Stack Alarms

Discipline: Integrity Management

Categories:

Facility:

Observations:

During the inspection, when CER inspectors met with the control room operator, there were several alarms coming on and off regarding two of the pilots on the flare. The control room operator indicated that he believed the alarms were false alarms caused by the wind. He also indicated that he had not been in the field to verify if these alarms were false alarms or not.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Explain what procedure should have been followed by the control room operator regarding the flare alarms observed during the inspection. Please provide a copy of the applicable procedure and explain if the operator acted in conformance with the procedure. Also explain if PMC has a process or procedure for removing repetitive false alarms and whether this could be applied to the alarms witnessed during the inspection.

Due date: 2022-03-18

Date closed: 2022-03-25
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 6 - Integrity Information Request - Operating an Unmanned Site

Discipline: Integrity Management

Categories:

Facility:

Observations:

PMC explained that one day per week, the facility is not manned. Since most of the facility is only monitored by the local control room, PMC explained that it reduces its operation to only operating the WSP pipeline and pump station on the day that the facility is unmanned. The WSP pipeline and pump station is monitored and operated by the control center in Olds, AB, which operates 24 / 7. PMC explained that all the caverns and the other pipelines are isolated when the facility is unmanned. PMC explained that a Management of Change (MOC) was conducted for this change and that an interim procedure was developed for that. The procedure was developed with and signed off by the local control room operators. Copies of the MOC and interim procedures were provided.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. PMC indicated that the flare equipment is not monitored by the Olds control center. Please explain if PMC has plans to provide the Olds control center the ability to monitor the flare and its related equipment in the future.
  2. Explain if potential new hazards or risks associated with a unmonitored flare and burn pit have been considered during the implementation of the MOC process. 
  3. Explain what controls are in place in the scenario that the flare or burn pit pilots were to extinguish when the site is unmanned? For example, are there any automatic ESDs for such event?

Due date: 2022-03-18

Date closed: 2022-03-28
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 7 - CV2122-335 Follow-up Meeting

Date & time of visit: 2022-02-14 10:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Following the IR responses received by plains after the inspection, CER staff conducted a virtual meeting with to obtain further details on 14 February 2022. Further IRs have been issued after the meeting the responses were provided on 18 March 2022. See attached CV2122-335 Follow-up Meeting Minutes and IR responses for further details.

Compliance tool used: No compliance tool used

Observation 8 - Notice of Non-Compliance - Inadequate Monitoring of Flare Stack

Date & time of visit: 2022-03-28 13:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Based on the information request responses and the information provided in the follow-up meeting, CER inspectors have determined that Plains was in non-compliance with the OPR section 37(a) during the unmanned operations because Plains did not adequately monitor the flare system. When the facility was unmanned, and although most of the facility was shut down and isolated, the Olds Control Center (OCC) could not know if the flare system was functioning properly or not while the Windsor-Sarnia pipeline and pump station connected to the flare system were in operation.

Plains also explained in the 18 March 2022 IR responses that the OCC will have monitoring ability of the flare by 15 April 2022 and that Plains will provide the evidence of implementation.

This observation was added after closing the "Integrity Information Request - Operating an Unmmaned Site" IR to capture the non-compliance and corrective actions.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Plains to provide the OCC with the monitoring ability of the flare by 15 April 2022. Plains to provide the evidence of implementation when completed.
 

Due date: 2022-04-22

Date closed: 2022-04-20
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:

- 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