Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain Pipeline ULC
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Process Safety at Trans Mountain Edmonton Terminal - Evaluate the implementation and close-out status of HAZOP action items; TMEP Asset turnover, including pre-commissioning, commissioning, pre-startup safety reviews, and Management of Change for startup operations; Assessing completion of preventive maintenance (inspection and testing) activities on safety systems and safeguards (i.e., pressure-relieving devices; emergency, fire, gas and release protection systems; sensors, alarms and interlocks) per prescribed frequencies under CSA Z662 and company programs.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - TMEP HAZOP
Date & time of visit: 2022-05-10 09:00
Discipline: Safety Management
Categories:
Facility:
Observations:
Trans Mountain (herein referred to as "TM") conducted a Hazard and Operability Study (HAZOP) for the Edmonton Terminal as part of the TM Expansion Project (TMEP) for the purpose of identifying and addressing new hazards associated with the project. Items within the HAZOP were reviewed with the CER inspection team which included a register used to track the status of HAZOP recommendations. TM stated that TMEP Engineering and TM Operations are responsible for the implementation of the HAZOP recommendations. TM also stated that items are not considered closed until operating procedures (if required) have been developed and/or operational documents have been updated to reflect the implemented items. The inspection team noted that TM's HAZOP tracking/resolution log used the term "Complete" or "Closed" for items where action items have been developed but the recommendation has yet to be implemented/executed. The team informed TM that it should consider revising its terminology on the log given that the "Complete" or "Closed" status for such items implies implementation and execution have been conducted.
Compliance tool used: No compliance tool used
Observation 2 - TMEP Asset Turnover
Date & time of visit: 2022-05-11 09:00
Trans Mountain (herein referred to as TM) stated that over the course of the Expansion Project (herein referred to as TMEP) TM's Operations maintain continuous communication and interface with the TMEP team and its general contractor(s) (herein referred to as GCC). TMEP stated that the asset turnover includes but is not limited to:
Observation 3 - Signage - Pumphouse
Date & time of visit: 2022-05-11 15:30
No H2S warning sign was present on the entrance to and inside the pump-house building.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Company shall post H2S warning signage at the pump house.
Due date: 2022-06-13
Date closed: 2022-07-19 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 - Indigenous Monitor Observations
Date & time of visit: 2022-05-11 16:00
Discipline: Indigenous Monitoring
Indigenous Monitor Observation Report CV 2223-094
Jonathan Wright – Sucker Creek First Nations Indigenous Monitor
May 10th to 11th, 2022
Glossary
CER – Canadian Energy Regulator
IM – indigenous Monitor
IR – Information Request
NNC- notice of Non-Compliance
CNC- Corrected Non-Compliance
FN – First Nations
TLU – Traditional Land Use
HDD – Horizontal Directional Drill
DTA – Department of Transportation of Alberta
KP – Kilometre Point
Introduction:
The inspection took place on May 10th & 11th at the Sherwood Park terminal in Sherwood Park, Alberta. Was attended by a Sucker Creek Indigenous monitor and three CER inspection officers. We investigated the safety of the terminal and its workers.
All safety related inquiries and observations are the same as made by the CER inspection officers and I have no other observations to add safety wise.
Observations/inspection: tributary to North Saskatchewan and remote impoundment.
We look at the leak detection methods, protocols, spill ways, manholes and remote impoundment valves. Also look into migratory bird mitigations and protection measures.
Approach:
· Identified by operations that their hydrocarbon detector is also installed on the intake from pipeline alley to the trib. To the North Sask. So that if there is a release upstream from another facility, they are able to detect it and divert the flow to their remote impoundment as an extra protection measure.
· We inspected the intake valves to the remote impoundment and noted that all valves have hydrocarbon detectors in place and are on an automatic shutoff if detected. Also observed that all valves are locked in place with the LOTO tag system to ensure that no accidental or unnotified swinging of valves would occur. Also noted that only operations are allowed to swing valves.
· Was also informed by operations that intake valve from other companies is locked shut and all water to be placed into their remote impoundment must be tested prior.
· The lining of the remote impoundment is also inspected regularly by operations and a third party by request to ensure its integrity is maintained and no chance of accidental release of water in the ground.
· All water in tested by third party prior to any release to the tributary. Water is first tested by third party; a field test is administered by operations and a visual inspection in conducted before any release is conducted. Also, there is a hydrocarbon detector on the outtake valve as an extra security measure.
· Noted some migratory birds were in pond, not a regular occurrence, no hazard was present for birds, migratory act was known by operations and was indicated to me that normally remote impoundment water level is kept low to ensure fowls don’t use pond as a hub.
· Noted that some safety signage was down around remote impoundment, indicated that it was down due to winter snow removal maintenance or spring thaw. Operations noted the sign down, which was still visible just not in a fixed position and will rectify as soon as possible – no enforcement tools issued.
· Also indicated by operations that the remote impoundment is capable of holding the volume of one 400,000 bbl tank and 10% of the volume of the other 24 tanks on the east tank farm and a 100 flood event.
Outcome/recommendations:
· Was very impressed with the overall attention to leak and hydrocarbon detection measures and protocols in place to ensure noncontaminated water enters the tributary.
· Possible add signage down to deficiency list so it is not put on the back burner and forgotten about.
Observations/Inspection: erosion control measures at drainages in the facility
While walking the grounds during the inspection we stopped to inspect erosion control measures of the drainage ditches around the tank farm and ones that go towards the remote impoundment.
While inspecting facility and remote impoundment was able to have a detailed look at the improved erosion control measures in place around the tank farms and around the remote impoundment. Please note that the new measures in place are a great improvement that those indicated in the 2019 CVA. Was very pleased to see the improvements in place.
Add erosion control measures to operations checklist if not already to ensure continued integrity and performance especially after heavy rain events or tank releases.
Conclusion:
I found it to be a very informative and great inspection. The TMX construction staff and operations staff were very helpful, informative and friendly. I have no issues to note on this inspection and hope that you continue the great work that is being down at the facility.
I look forward to the next inspection and the continued partnership between TMX and the IAMC.
Sincerely
Jonathan Wright
Sucker Creek Indigenous Monitor
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
