Compliance verification activity type: Field Inspection
Team:
Regulated company: Express Pipeline Ltd.
Operating company: Express Pipeline Limited Partnership
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Integrity inspection focused on pipeline monitoring, pressure control, and overpressure protection to verify compliance to the OPR and CSA Z662-19.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Suffield Pump Station
Date & time of visit: 2022-03-15 13:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
The pump station is accessible year-round, it is fenced with several egress gates in addition to the main site access. CER inspectors observed that signs with the company name, emergency phone number, signage warning of hazards and PPE requirements, and non-smoking signs were posted at the site's main entrance. The site has two pump units, both were running at the time of the inspection. The mainline MOP is 8400 kPa. Express explained that the pressure is controlled by controlling the speed of one of the two pump units. CER inspectors verified on the local human-machine interface (HMI) that the station discharge setpoint was 7680 kPa at the time of the inspection. Express explained that the overpressure pressure protection system has three stages of protection. The first level is the maximum allowable discharge setpoint, and this is the highest pressure that the operator can set as the discharge setpoint. The second level is the high discharge cascade shutdown which is set at 104% of the maximum allowable discharge setpoint. If the discharge pressure exceeds this value, the pumps at the station will cascade shutdown. Meaning one pump will be stopped, then there is a time delay and if the high pressure situation still exists the second pump will be stopped. The third level is the high discharge station shutdown which is set at 106% of the maximum allowable discharge setpoint. If the discharge pressure exceeds this value, both pumps are immediately stopped. For the Suffield Pump Station, the maximum allowable discharge setpoint was 7901 kPa, the high discharge cascade shutdown was 8217kPa, and the high discharge station shutdown was 8375 kPa. The station suction is equipped with a densitometer, and pressure and temperature transmitters. On the discharge side, there were a pressure transmitter, a pressure switch, and a thermal relief valve. The thermal relief valve had an upstream isolation valve and it was car sealed in the open position. CER inspectors requested the two most recent inspection records for the thermal relief valve identified with the asset tag #1100080207. The records demonstrated that the valve was inspected annually without exceeding 18 months as per CSA Z662-19 requirements. The station is equipped with two Uninterruptible Power Systems (UPS), one is used for the instrumentation and the other one is for the operation of station isolation valves. An alarm would be generated to the control centre in the event of a power loss and a technician would be sent to verify the situation on-site. The station had redundant satellite communication systems for SCADA. An alarm would be generated to the control centre in the event of a communication loss and a technician would be sent to verify the situation on-site. The station is equipped with station three emergency shutdown (ESD) push buttons located at different locations on site. One is located in the office, one between the pump units, and one near the main gate. Each pump unit is also equipped with pump unit shutdowns. CER inspectors noticed that ESD valves were identified and that direction of flow was indicated on piping. The above-ground station piping appeared to be in good condition, well painted and supported. The pump units are equipped with temperature, pressure, and vibration monitoring devices and automated shutdowns. The pumps have seal leak collection and detection systems. There is a collection system for potential seal leaks which would direct them to a double-wall sump tank. There is a seal leak detection system, and upon seal leak detection the pump unit is shut down and isolated. The pump station sump is equipped with level monitoring and pressure switches. In a high level situation, an alarm is triggered. In a high-high level situation, a station ESD is triggered. The sump reinjection pump is equipped with a pressure relief valve with a setpoint of 1216 psi (8384 kPa). CER inspectors went into the Drag Reducing Agent (DRA) unit building. The DRA unit is equipped with overpressure protection and the building is equipped with a temperature probe that will trigger a unit shutdown if the temperature goes above a certain limit. The DRA unit is also equipped with a unit ESD push button located near the main door.
Compliance tool used: No compliance tool used
Observation 2 - Wild Horse Pump Station
Date & time of visit: 2022-03-16 09:30
The pump station is accessible year-round, it is fenced with several egress gates in addition to the main site access. CER inspectors observed that signs with the company name, emergency phone number, signage warning of hazards and PPE requirements, and non-smoking signs were posted at the site's main entrance. The site has two pump units. The pump units were not running at the time of the inspection. The mainline MOP is 8400 kPa. Express explained that the pressure is controlled by controlling the speed of one of the two pump units. CER inspectors verified on the local HMI that the station discharge setpoint was 7750 kPa at the time of the inspection. For the Wild Horse Pump Station, the maximum allowable discharge setpoint was 8150 kPa, the high discharge cascade shutdown was 8476kPa, and the high discharge station shutdown was 8639 kPa. The station has receiving and launching pig traps. The station suction is equipped with a densitometer, and pressure and temperature transmitters. On the discharge side, there were a pressure transmitter and a pressure switch. The thermal relief valves observed had an upstream isolation valve that was car-sealed in the open position. The station is equipped with two Uninterruptible Power Systems (UPS), one is used for the instrumentation and the other one is for the operation of station isolation valves. An alarm would be generated to the control centre in the event of a power loss and a technician would be sent to verify the situation on-site. The station had redundant satellite communication systems for SCADA. An alarm would be generated to the control center in the event of a communication loss and a technician would be sent to verify the situation on-site. The station is equipped with station three emergency shutdown (ESD) push buttons located at different locations on site. One is located in the office, one between the pump units, and one near the main gate. Each pump unit is also equipped with pump unit shutdowns. CER inspectors noticed that ESD valves were identified and that direction of flow was indicated on piping. The above-ground station piping appeared to be in good condition, well painted and supported. The pump units are equipped with temperature, pressure, and vibration monitoring devices and automated shutdowns. The pumps have seal leak collection and detection systems. There is a collection system for potential seal leaks which would direct them to a double-wall sump tank. There is a seal leak detection system and upon seal leak detection the pump unit is shut down and isolated. The pump station sump is equipped with level monitoring and pressure switches. In a high level situation, an alarm is triggered. In a high-high level situation, a station ESD is triggered. The sump has a booster pump and a positive displacement (PD) pump for reinjecting the content of the sump in the system. The PD pump discharge is equipped with a pressure relief valve with a setpoint of 8390 kPa. There was also a flow meter on the injection line that would shut down the sump pumps if a no-flow condition was detected. CER inspectors went into the Drag Reducing Agent (DRA) unit building. The DRA unit is equipped with overpressure protection and the building is equipped with a temperature probe that will trigger a unit shutdown if the temperature goes above a certain limit. The DRA unit is also equipped with a unit ESD push button located near the main door.
Observation 3 - Corrected Non-Compliance - Wild Horse Pump Station Pressure Transmitter
Date & time of visit: 2022-03-28 10:00
CER inspectors requested the two most recent inspection records for the station discharge pressure transmitter with asset tag #1100080207 and the pressure switch identified as PSH401. The records demonstrated that the pressure switch was inspected annually without exceeding 18 months, as per CSA Z662-19 requirements. However, for the pressure transmitter, the inspection interval exceeded 18 months and this is a non-compliance to CSA Z662-19 clause 10.9.5.2. The pressure transmitter was inspected on 18 March 2020 and 4 October 2021, which means the inspection interval exceeded the 18-month limit by about 16 days.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Enbridge explained that it has identified the cause of this non-compliance as a data entry error made when inputting the inspection interval for this pressure transmitter. A date value was used, rather than an 18 month interval. This error has been corrected in Maximo to prevent reoccurrence.
Due date: 2022-03-28
Date closed: 2022-03-29 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 - Peace Butte Pump Station
Date & time of visit: 2022-03-16 14:30
The pump station is accessible year-round, it is fenced with several egress gates in addition to the main site access. CER inspectors observed that signs with the company name, emergency phone number, signage warning of hazards and PPE requirements, and non-smoking signs were posted at the site's main entrance. The site has two pump units located in a pump building. Pump unit #1 was running at the time of the inspection. The mainline MOP is 8400 kPa. Express explained that the pressure is controlled by controlling the speed of one of the two pump units. For the Peace Butte Pump Station, the maximum allowable discharge setpoint was 8170 kPa, the high discharge cascade shutdown was 8497kPa, and the high discharge station shutdown was 8660 kPa. The pump building is equipped with fire and gas detection. Upon fire detection, a station ESD is initiated, this also includes stopping the building's forced-air ventilation. Upon gas detection, at 10% LEL the pump building ventilation is started and at 20% LEL a station ESD is initiated. The station suction is equipped with pressure and temperature transmitters. On the discharge side, there were two pressure transmitters. The thermal relief valves observed had an upstream isolation valve that was car-sealed in the open position. The station is equipped with an Uninterruptible Power Systems (UPS) capable of maintaining the instrumentation and the operation of station isolation valves. An alarm would be generated to the control centre in the event of a power loss and a technician would be sent to verify the situation on-site. The station had redundant satellite communication systems for SCADA. An alarm would be generated to the control center in the event of a communication loss and a technician would be sent to verify the situation on-site. The station is equipped with station three emergency shutdown (ESD) push buttons located at different locations on site. One is located in the office, one on the outside wall of the pump building, and one near the main gate. Each pump unit is also equipped with pump unit shutdowns. CER inspectors noticed that ESD valves were identified and that direction of flow was indicated on piping. The above-ground station piping appeared to be in good condition, well painted and supported. The pump units are equipped with temperature, pressure, and vibration monitoring devices and automated shutdowns. The pumps have seal leak collection and detection systems. There is a collection system for potential seal leaks which would direct them to a double-wall sump tank. There is a seal leak detection system and upon seal leak detection, the pump unit is shut down and isolated. The pump station sump is equipped with level monitoring and pressure switches. In a high level situation, an alarm is triggered. In a high-high level situation, a station ESD is triggered. The sump has a booster pump and a positive displacement (PD) pump for reinjecting the content of the sump in the system. The PD pump discharge is equipped with a pressure relief valve with a setpoint of 8390 kPa. There was also a flow meter on the injection line that would shut down the sump pumps if a no-flow condition was detected. CER inspectors went into the Drag Reducing Agent (DRA) unit building. The DRA unit is equipped with overpressure protection and the building is equipped with a temperature probe that will trigger a unit shutdown if the temperature goes above a certain limit. The DRA unit is also equipped with a unit ESD push button located near the main door.
Observation 5 - Hardisty Terminal
Date & time of visit: 2022-03-17 13:00
The Hardisty terminal is accessible year-round and it is fenced with several egress gates in addition to the main site access. CER inspectors observed that signs with the company name, emergency phone number, signage warning of hazards and PPE requirements, and non-smoking signs were posted at the site's main entrance. Express explained the relief systems that were installed to protect the terminal piping from the suppliers (Husky, Gibson and Inter Pipeline). Three full flow relief valves have been installed. The relief valves for Gibson and Husky relieve into Tank 105. Tank 105 is an operating tank with dedicated space for a potential relief volume. The relief valve for Inter Pipeline relieves back into an Inter Pipeline tank. Relief valves for Husky and Gibson had a setpoint of 1655 kPa. The relief valve for Inter Pipeline had a setpoint of 1379 kPa. The terminal piping has a MOP of 275 psi (1896 kPa). There were three booster pumps to feed the mainline pump station. The pressure on the discharge of the booster pumps is controlled by a pressure control valve installed on a recirculation loop. The booster pump is equipped with seal leak collection systems draining into a sump tank. The booster pumps were also equipped with ESD push buttons. The mainline pump station has three pump units, two were running at the time of the inspection. The mainline MOP is 8400 kPa. Express explained that the pressure is controlled by controlling the speed of one of the pump units. CER inspectors verified on the local HMI that the station discharge setpoint was 7250 kPa at the time of the inspection. For the Hardisty Pump Station, the maximum allowable discharge setpoint was 8336 kPa, the high discharge cascade shutdown was 8669kPa, and the high discharge station shutdown was 8636 kPa. On the discharge of the station, there was a pressure transmitter, a pressure switch, and a temperature monitoring device. The station is equipped with an Uninterruptible Power Systems (UPS) and a gas generator for power backup. The power backup system maintains the instrumentation and is capable of operating the station isolation valves. An alarm would be generated to the control centre in the event of a power loss and a technician would be sent to verify the situation on-site. The station uses a local phone line system for primary communication and satellite communication for backup. An alarm would be generated to the control center in the event of a communication loss and a technician would be sent to verify the situation on-site. The pump station is equipped with station several emergency shutdown (ESD) push buttons located at different locations on site. CER inspectors noticed that ESD valves were identified, and that direction of flow was indicated on piping. The above-ground station piping appeared to be in good condition, well painted and supported. The pump units are equipped with temperature, pressure, and vibration monitoring devices and automated shutdowns. The pumps have seal leak collection and detection systems. There is a collection system for potential seal leaks which would direct them to a double-wall sump tank. There is a seal leak detection system and upon seal leak detection, the pump unit is shut down and isolated. The pump station sump is equipped with level monitoring and pressure switches. In a high level situation, an alarm is triggered. In a high-high level situation, a station ESD is triggered.
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
