Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans-Northern Pipelines Inc.
Operating company: Trans-Northern Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
[Process Safety - Field verification follow-up to HAZOP action item implementation; assessing the 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; Completeness and accuracy of records (e.g., P&IDs, equipment inventory, labelling and consistency with facility operating/field assets etc.)]
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General observations
Date & time of visit: 2022-07-21 16:00
Discipline: Safety Management
Categories:
Facility:
Observations:
Farrans Point Terminal (19 July 2022)
IOs verified calibration and maintenance records for the level gauges on Tank 2. TNPI's asset management system tracks maintenance intervals and creates work orders when tasks are due. IO also observed that detailed procedures for the calibration of the tank gauges were available to an instrumentation technician who had performed the task recently.
TNPI stated that fuel products arriving at the terminal include gasoline, diesel, and fuel oil via the Montreal East pipeline at an average pressure between 400 – 500 psi. IOs requested copies of the product SDSs. The company was unable to view the SDSs on their internal system due to a technical issue but demonstrated the sheets were readily available on the internet. TNPI confirmed later that day that the technical issue had been resolved.
IOs observed surge relief piping had been recently installed and requested a copy of the MOC documents (see IR 2)
IOs observed the V-600 valve vault was missing the required confined space warning signage (see AVC 1).
Maitland Station (20 July 2022)
IOs reviewed the energy isolation plan that had been prepared for the installation of the pig launcher which was planned for the following day. The review included a Job Specific Execution Plan (JSEP), Equipment Lockout Record (ELR), station drawings, and TNPI's Lockout and Energy Isolation Procedure, Rev 7.
Valves listed in the JSEP and ELR were easily identifiable in the yard using asset labels and/or safety-critical equipment tags.
Electrical isolation points listed in the JSEP and ELR were also easily identifiable in the MCC by labelling.
TNPI supervisor stated each field services worker has a personal lock with a unique key which is used during lockouts.
IOs observed the JSEP and ELR did not provide for adequate isolation from pressure downstream of the work activity. Following this observation, the company discovered that a step had been missed in the JSEP. On 21 July 2022, a company representative confirmed the JSEP was amended and re-approved before starting the work.
The ELR did not provide for double block and bleed (DBB) isolation downstream or upstream of the work activity (although the JSEP stated the station bypass valve V-070 should be closed, it was not identified as a lockout point on the ELR). TNPI's Lockout and Energy Isolation procedure requires approval from a professional engineer when DBB, blanking, or blinding is not possible. The supervisor tasked with overseeing the work activity confirmed to the IO that the JSEP has been approved as required.
While speaking with the company supervisor, IO learned that workers do not lock/seal bleeds in the open position as required by TNPI’s Lockout and Energy Isolation Procedure. This practice was also confirmed by the Field Services Supervisor (see NNC 2).
Pressure transmitters perform an automatic trip/shutdown of upstream pump stations based on set points in the event of a mainline inlet overpressure/high delivery pressure. The transmitters provide a warning alarm on the high set point value and will execute a shutdown logic if no action is taken within several seconds of the high-pressure warning alarm. The shutdown also executes at the high-high set point value.
TNPI stated that the pump house exhaust fans run continuously over the summer months and automatically come online based on lower explosive limit (LEL) detection to disperse vapours due to a hazardous atmosphere. The exhaust fans automatically shut down in the event flame detector alarms are triggered to not promote the growth of the flames.
No automated alarms (either visual or auditory) were present in the pump building. IOs are of the view that the potential for exposure to a hazardous substance within the building exists due to the potential for loss of containment resulting in the release of a hazardous substance (see IR 1).
Iroquois Station (20 July 2022)
IOs completed a walk down of Iroquois Station including the pump building and yard piping.
Station drawings appeared to have been updated after the recent installation of the over-pressure protection station bypass.
The windsock present at the Iroquois station did not appear to be effectively placed for easy visual identification. IOs recommend that TNPI re-evaluate the windsock placement to ensure that it is effective for emergency response purposes.
Integrity Digs at MP 112.69 and MP 113.57 (21 July 2022)
Company representative stated that TNPI Inspectors are always present to oversee work performed by Contractors.
The contractor foreman and excavator operator confirmed that TNPI representatives are always present to oversee work activities.
IO inquired about an injury to a contractor in June 2022. A review of the incident investigation shows TNPI participates in the contractor investigation and performs its own independent investigation.
Written work procedures were readily available including emergency response plan and excavation procedures. The contractor's emergency response plans did not appear to identify communication with line control and the responsibility in the event of a spill and ignition scenario. However, TNPI stated that its ERP identifies the communication with line control and requisite actions in the event of such scenarios.
The excavator operator appeared to have good knowledge of company safe work procedures related to excavation, back-filling, and damage prevention.
A non-destructive testing contractor was on site to perform magnetic particle and visual inspection of the welds. IO observed the contractor had valid CGSB MT Level 2 and CWB Level 2 certifications. The magnetic yoke was calibrated with a lift test completed earlier in the day. The NDT technician stated job parameters, including applicable acceptance criteria were received directly from the company.
KEMA tape wrap with a 2 cm overlap is used as the repair coating on the pipe with a visual inspection performed to ensure the absence of coating gaps. TNPI stated visual acuity tests are not required of inspectors to perform the visual inspection of the coating.
TNPI stated that pre-dig surveys, line-locates, and one-calls are performed prior to conducting ground disturbance activities to expose the pipe. The survey information contains measured depth of cover upon pipe exposure. Mitigations such as additional overburden may be applied upon back-filling in the event where the depth of cover is lower than the required minimum.
Safe excavation pressure (SEP) for ditch entry is provided to the workers by the company’s engineering department. TNPI inspectors maintain communication with control room operators to verify line pressure prior to ditch entry. SEP is evaluated as the lower of 50% of licensed or 72% of the minimum predicted failure pressure of the features at the target location (see IR 4).
Prescott Block Valve (21 July 2022)
IOs observed the Prescott block valve vault. Observations were made from the perimeter fence. The site is fenced, locked, equipped with signage indicating hazards and emergency contact information, and easily accessible from a public road.
The company stated block valve vaults are inspected at a prescribed biweekly frequency and include checking for the presence of liquids such as water that may be present due to rain and fuel products due to potential leaks. It was also stated that the vaults are equipped with level alarms that automatically shut flow in the pipeline in the event liquid levels beyond the alarm set points are reached.
The company stated the valve vaults are a confined space, but the vault was missing the required signage (see AVC 1).
Other
Compliance tool used: No compliance tool used
Observation 2 - CNC 1 Farrans Point valve position indicator
Date & time of visit: 2022-07-19 13:30
The sight glass on the west pig launch discharge valve (V575) was stained with product and therefore blocking the visibility of the valve open/closed position.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Ensure the open and closed position indicator on V575 is clearly visible.
Due date: 2022-07-21
Date closed: 2022-07-21 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 - Warning signage on pump house buildings
Date & time of visit: 2022-07-20 13:00
IOs observed the entrances to pump house buildings at Farran's Point, Maitland station, and Iroquois station do not have hazard or toxic substance warning signs. Piping in the pump houses contains low vapour pressure hydrocarbons including diesel, gasoline, and distillate. See IR#6
Observation 4 - NNC 2 - Lockout & energy isolation
Date & time of visit: 2022-07-20 11:30
IO learned through discussion with a TNPI supervisor that bleeds are not secured in the open position when performing energy isolation contrary to the company's internal Lockout and Energy Isolation Procedure, Rev. 7. This practice was also confirmed by another company supervisor. Both supervisors were unaware of the company's requirement for securing bleeds in the open position.
Compliance tool used: Notice of Non-compliance (NNC)
Provide a corrective action plan with target completion dates to ensure all workers involved in energy isolation and lockout are trained on the company's internal procedure(s), specifically regarding bleeds.
Due date: 2022-08-12
Date closed: 2022-08-17 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.
There are no observations with outstanding follow-up
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
Observation 5 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
This information has been redacted pursuant to Section 144(5) of the Canada Labour Code
