Compliance Verification Activity Report: CV2223-080 - Plains Midstream Canada ULC


Compliance verification activity type: Field Inspection

Activity #: CV2223-080
Start date: 2022-09-12
End date: 2022-09-13


Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):


Related events:

Rationale and scope:

Integrity dig inspection to verify compliance to the OPR and CSA Z662-19.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Plains Dig Inspection - Day 1

Date & time of visit: 2022-09-12 13:30

Discipline: Integrity Management




Dig Sites 1170 and 1180
The Plains Construction Supervisor provided a site-specific orientation by reviewing the contractor’s Field Level Hazard Assessment (FLHA) and Tool Box Meeting forms. Plains also had a Project Safety Plan and FLHA. Emergency procedures were explained and Plains indicated that a Table Top exercise was recently conducted on site for a potential release scenario.

There was a muster point on site equipped with a windsock, an air horn, both Plains and the contractor’s Emergency Response Plans, the Project Safety Plan, the Traffic Management Plan, a first aid kit, and a fire extinguisher.

Goal posts and signs warning of the overhead power lines were present at each powerline crossing of the access roads.

The 10-inch line carries NGL from the Empress Gas Plant to Laporte (SK). Plains explained the safe excavation pressure process in place for the digs. The pressure in the line at the time of the inspection was about 4600 kPa. The Plains Construction Supervisor explained that there was a pressure restriction in place to 6600 kPa due to the other dig site 1880 located further downstream. The Plains Construction Supervisor explained that he verifies with the Olds Control Center every morning to confirm the pressure in the line and talks to them at the end of each day to inform them that the work for the day has been completed. He also explained that the information regarding the safe excavation pressure is communicated between him and Plains head office through the Daily Work Report.

Canadian General Standards Board (CGSB) certification was provided for the (Non-Destructive Examination) NDE inspector. The card indicated that the NDE inspector was certified Level II for UT, MT and PT. The card was expired, but he was granted an extension until the end of 2022 by the CGSB due to the difficulty to renew the card during the pandemic. A certificate for his eye examination was also provided.

The contractor provided a certification demonstrating that the compressor was providing adequate air quality to the sandblaster protection mask. Plains explained that filters were in place to ensure the air quality of the sandblasting operation and that no silica was present in the abrasive material. It was also explained that the dead man latch on the sandblast hose nozzle was tested before each use to verify its proper functioning.

Plains provided the Manufacturer Qualified Application Procedure for the coating to be applied on the exposed pipe after the repairs are completed. The coating to be applied is the Polyguard product RD-6. Records were provided to demonstrate that the coating applicators had been qualified to apply the Polyguard coating products. The Plains Construction Supervisor explained that the contractor conducts the QA/QC for the coating application and that he witnesses the QA/QC activities and signs off on the QA/QC report. CER inspectors verified that the coating primer was not passed its expiry date.

Plains explained that Petrosleeves are used for permanent repairs when required. Plains explained that Petroline (the Petrosleeves manufacturing company) employees install and do the QA/QC during the installation of the Petrosleeves. The QA/QC installation report is sent to Plains. The Plains Construction Supervisor explained that he verified the certificates for the Petrosleeve installers.

Sites 1170 and 1180 had been excavated. The excavations were properly sloped with adequate access on each side of the pipe. The pipe is coated with yellow jacket coating and the girth welds are coated with yellow jacket wrap. Approximately 1.5 m of pipe was exposed at each dig site. The NDE contractor had started the coating assessment at site 1170. The pipe is to be NDE’d on a length of 0.5 m on each side of the girth weld.

Fencing was present around the excavations and Plains explained that the fence is closed when the excavation is left unattended.

Dig Site 1880:

The pipe had been exposed. The excavation was properly sloped with adequate access on each side of the pipe. The yellow jacket wrap coating on the girth weld had been damaged by what appeared to be a small rodent. A significant portion of the girth weld coating was missing. The pipe's yellow jacket coating did not appear to have been damaged by the rodent.

Compliance tool used: No compliance tool used

Observation 2 - Plains Dig Inspection - Day 2

Date & time of visit: 2022-09-13 09:30

Discipline: Integrity Management




Dig Site 1880:

CER Inspectors met with the Plains Construction Supervisor. He explained that he confirmed with the Olds Control Center that the pressure in the line was about 5600 kPa prior to beginning work.

A preliminary NDE assessment had been completed on the exposed area. Some external corrosion features were present with the worst features located at the bottom of the pipe. The deepest feature was called by the ILI tool as 59 % deep while the preliminary assessment determined a maximum depth of about 49%. Plains explained that a laser assessment will be completed on the exposed pipe to assess the external corrosion features.

Dig Sites 1170 and 1180:

Both digs had been sandblasted earlier this morning. The blasted area had been plastic wrapped to be protected while waiting for the NDE. The NDE of the exposed pipe at 1170 was in progress at the time of the inspection. The NDE crew was assessing the external corrosion features with a pit gauge.

The NDE crew explained that the entire sandblasted surface will be assessed by magnetic particle testing for potential cracks in addition to the corrosion assessment. They also explained that the seam weld will be assessed with UT for internal features.

The NDE crew explained that the yoke strength for magnetic particle testing was tested before each day of work with a 10 lbs pull test. The NDE crew indicated that a sensitivity test was not conducted for the magnetic particle fluid mix as they used a manufacturer-produced mix. They also explained that UT is calibrated before and after each use and that when a UT assessment lasts more than an hour, it is also calibrated every hour.

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