Compliance Verification Activity Report: CV2021-162 - Plains Midstream Canada ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-162
Start date: 2020-12-08
End date: 2020-12-08

Team:

Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of integrity digs 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 - NNC #1: Determining a Safe Excavation Pressure

Date & time of visit: 2020-12-01 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

On 27 November 2020, in response to an information request for CV2021-162 and in the follow-up discussion with CER staff, Plains indicated that it does not have a process or procedure to determine the safe excavation or working pressure required by CSA Z662-19 clause 10.10.1.4. Plains also confirmed that no pressure restriction had been implemented on the EDS-N pipeline prior to initiating digs on that line. Plains explained that no pressure restriction had been deemed necessary for the operation of the pipeline based on the predicted burst pressures determined as part of the anomaly assessment process that followed the in-line inspection conducted in 2017. Plains also explained that in the absence of a formal process for determining the safe excavation or working pressure, the considerations required by CSA Z662-19 clause 10.2.8 had not been made prior to initiating the digs on the EDS-N pipeline. As such, Plains is non-compliant to CSA Z662-19 clauses 10.10.1.4 and 10.2.8.

Also on 27 November 2020, Plains confirmed that a temporary Management of Change process with the Plains Operations Control Centre to limit the Sarnia pump discharge pressure to 6,000kPa had been implemented and that the work was continuing with the digs that were already in progress at that time.
 
On 30 November 2020, after CER staff asked Plains to confirm if the factors listed in CSA Z662-19 clause 10.2.8 had been considered to establish the 6000 kPa restriction on the EDS-N Pipeline and whether other digs were occurring on other pipelines, Plains confirmed that it would not execute any new digs on CER regulated pipelines in the meantime while the information was being prepared.

On 4 December 2020, Plains agreed to implement a pressure restriction of 80% of the last 90 days high pressures recorded on the NPS 8 Sarnia to St. Clair pipeline and the NPS 12 Windsor to Sarnia pipeline for conducting the digs remaining for 2020 on these lines.  

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

Regulatory requirement:

Relevant section(s):

Company action required:

On 4 December 2020, after meeting and exchanging emails with CER staff, Plains agreed to implement a pressure restriction corresponding to 80% of the past 90 day high pressure for conducting the remaining digs for year 2020. Plains provided the records demonstrating the implementation of the pressure restrictions for conducting the digs.


 
 

Due date: 2021-01-11

Date closed: 2021-01-11
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 - NNC #2: Documented Process or Procedure for the Safe Excavation Pressure

Date & time of visit: 2021-01-31 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Although Plains explained that it uses the PMC Control Room Management (CRM) Change Management Process to implement temporary pressure restriction measures, Plains is also non-compliant to the OPR section 6.5 (1)(q) as it does not have a documented process or procedure to determine and implement the safe excavation pressure required by CSA Z662-19 clause 10.10.1.4 while taking into consideration the factors listed in CSA Z662-19 clause 10.2.8. Establishing and implementing a safe excavation or working pressure is an important component of the process required by the OPR s. 6.5(1)(q) for coordinating and controlling the operational activities of employees and other people working with or on behalf of the company so that each person is aware of the activities of others and has the information that will enable them to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment.
 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Plains is to develop and implement a documented process or procedure to determine and ensure the implementation of a safe excavation pressure that will satisfy the requirement of CSA Z662-19 clauses 10.2.8 and 10.10.1.4. Plains is to provide a copy of the documented process or procedure to demonstrate completion of this corrective action.
 

Due date: 2021-05-31

Date closed: 2021-06-10
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 - Dig Inspection – General Observations

Date & time of visit: 2020-12-08 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER Inspectors met with Plains Construction Supervisor, the project contractor (ClearStream Energy Services) supervisor and the Non Destructive Examination (NDE) inspectors (Acuren) at the dig sites in Sarnia (near Vidal Street) for the NPS 8 Sarnia to St. Clair pipeline. There were four dig sites in the area that were inspected by the CER:  GWD 7870, 7430, 7220 and 4750.
 
The NDE inspectors explained that Magnetic Particle Inspection (MPI) is conducted on the entire surface of the joint that is exposed. They also indicated that Stress Corrosion Cracking (SCC) or other pipe surface cracks had not been identified so far. The target features for these dig sites are external corrosion; a seam weld anomaly was also targeted for one of the digs. The corrosion features are being assessed using Ultrasonic Testing (UT), pit gauges and laser technology. The targeted seam weld anomaly was to be assessed with Phased Array UT (PAUT). The NDE technicians on site had valid Canadian General Standards Board (CGSB) certifications for the NDE techniques being used. A qualified PAUT technician was to be deployed on site for the targeted seam weld anomaly. NDE technicians explained that if grinding in excess of 10% is required, they need to consult with Plains technical services to confirm the plan before proceeding.
 
The NPS 8 Sarnia to St. Clair pipeline was not operating at the time of the inspection and its pressure was about 800 kPa. Plains implemented a pressure restriction on this line on Dec 7th to limit the pressure to 5200 kPa as agreed to with the CER to address the non-compliance regarding the safe excavation pressure that was identified prior to the inspection (see NNC #1).
 
The following documents and records were provided for the inspection:

 
Dig Site GWD 7430
There are two lines in the excavation. One is the NPS 8 Sarnia to St. Clair pipeline and the other one is a decommissioned pipeline, also owned by Plains, currently filled with nitrogen. Preliminary NDE had been completed. MPI had been conducted on the entire exposed pipe and no cracks identified. Corrosion features had been assessed and the maximum depth measured was 52% while the In-Line Inspection (ILI) tool called for 48% depth. Laser assessment had been completed. This dig was on wait for PAUT to be completed on the targeted seam weld anomaly. The line is coated with a blue tape coating. There are two layers of tape coating and it was explained that one of the layer was for rock protection. The coating was disbonded in some areas and, in addition to the targeted feature, some light corrosion patterns were observed along the tape seams where the tape coating was removed for NDE.
 
 
Dig Site GWD 7870
The NDE had been completed at this site and a Petrosleeve had been installed as a repair. This dig was in wait of getting sandblasted and coated. The coating system used on this project is Polyguard RD-6, a mesh-backed tape coating system. New cathodic protection test poles had been installed. Plains explained that they require a Petrosleeve representative be present for the installation of each Petrosleeve. The ILI tool called for a corrosion feature with up to 58% depth and the field NDE measured a 60% depth. No cracks were identified.
 
Dig Site 4750
This site was being hydrovaced to expose the lines in the excavation area. Plains reported that they have six pipelines in this right of way. Plains explained that before beginning the excavations they call the Ontario One Call line to obtain the necessary locates, they develop a ground disturbance management plan, and they hydrovac the site for physically locating all utilities and pipelines.
 

Compliance tool used: No compliance tool used

Observation 4 - Dig Site GWD 7220 - CNC Unproperly Sloped Wall

Date & time of visit: 2020-12-08 10:30

Discipline: Safety Management

Categories:

Facility:

Observations:

Dig Site GWD 7220
There are three lines in the excavation. One is the NPS 8 Sarnia to St. Clair pipeline, another one is the Plains decommissioned pipeline, and the third one is a smaller diameter line, uncoated, approximately 30 cm below the surface. The smaller line is an old line that is exposed at other locations on the right-of-way. It was unexpected as it was not identified in Plains’ drawings. The company contractor indicated that they did not know who the owner of this line is.  They also reported to the CER that they had observed holes in that pipe and that it is used by residents in one area as a walking bridge over a local stream. The exposed NPS 8 pipe had been painted with white paint in preparation for NDE.
 
One section of the trench wall (about 8-10 feet) was not sloped properly. Plains explained that that section of the trench wall could not be sloped properly because of a nest for the endangered Butler’s garter snake that had been identified in the area. Also, it was explained that a trench box was not installed because of the limited work space. The Plains representative explained that he was fairly confident based on its experience that this was not a significant safety hazard due to the soil type but acknowledged that it did not meet the provincial regulatory requirements. Plains decided to install a fence to prevent access to the area not sloped properly until sheet piles could be installed to address the issue. Sheet piles were installed on Dec 9th and pictures were provided to confirm that this was addressed.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Plains decided to install a fence to prevent access to the area not sloped properly until sheet piles could be installed to address the issue. Sheet piles were installed on Dec 9th and pictures were provided to confirm that this was addressed.
 

Due date: 2020-12-09

Date closed: 2020-12-09
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