Compliance Verification Activity Report: CV2021-163 - Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-163
Start date: 2021-03-02
End date: 2021-03-05

Team:

Regulated company: Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Operating company: Pembina North Limited Partnership

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Spirit River and Taylor pump stations - Assess completion of preventive maintenance, inspection and testing on safety systems and safeguards per prescribed frequencies under CSA Z662 and company programs; Assess implementation of identification, evaluation and control of process hazards including established process hazard inventory; Assess control of hazardous energy including LOTO.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - 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

Observation 2 - General Observations

Date & time of visit: 2021-03-05 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

  • Company representatives provided a brief safety orientation at the office in Fort St. John (first aid, muster locations, and exists). 
  • IOs observed first aid kit, AED, and fire extinguishers in the Fort St. John office. 
  • Company representatives delivered a site specific orientation to CER staff at all sites, which included a description of emergency procedures, alarm types and muster areas. Company representatives provided CER Inspection Officers an escorted tour throughout the pump stations and participated in inspections. 
  • Perimeter fencing appeared to be maintained in good condition with proper signage, including company and emergency contact numbers and warning signs to deter intrusion. All perimeter emergency man gates were accessible and gates functional.
  • CER Inspectors observed that personnel wore required personal protective equipment (PPE). 
  • General housekeeping appeared adequate, as indicated by such observations as: floors clear of tripping hazards; equipment and tools properly stored; waste material segregated; only garbage in garbage bins; and bins not over-filled.
  • Flammable storage cabinets were of manufactured type and were had bungs in place.
  • Safety Data Sheets (SDS) were provided for C2 (Ethane) and C3 (Propane).
  • Battery areas were inspected by CER Inspectors and found to be neat and tidy, with protected plexiglass installed to protect from outward working area.
  • Compressed nitrogen gas cylinders were stored upright with caps on and chained or strapped to permanent structure wall bracket or railing.
  • Extension ladders were safely stowed such that they did not pose a tripping hazard or danger from falling.
  • Portable fire extinguishers of appropriate type were placed near doors and egress ways and affixed tags had up to date annual inspections and maintenance recorded.
  • Emergency equipment, including both eyewash bottles and stations, automated external defibrillator (AED), fire blankets had up to date inspections recorded on affixed tags.
  • Elevated walkway “catwalks” were of a grated slip resistant design, equipped with handrails.
  • Pump Station sites were graded and aggregate applied providing unobstructed access to areas.
  • Electrical Work Procedure & Lock out Tag out (LOTO) procedure was explained and an active lock-out work in progress was explained by Company employees and was verified by CER inspectors to be in accordance with the LOTO process.
  • Critical infrastructure was protected by placing of concrete barriers to mitigate potential of equipment/vehicle unintentional contact with site infrastructure.
  • Pipe assemblies were marked by labeling to identify product and direction of flow.
  • Overhead cranes observed were with proper current maintenance and pre-use records indicating they were safe to operate. 
  • Sound level measurement recordings (dba) 2021 records were reviewed, and administrative measures (signage) were placed prior to building access points where workers require hearing protection. 
  • Vehicles were observed by CER staff to be operated in a safe manner during inspection at all sites.
  • Windsocks were strategically placed for visibility throughout the facilities.
  • Hazard warning signage was affixed on building entry doors and first aid signs at stations. 
  • Washrooms were functional and sanitary. 
  • Employees accompanied the CER inspection officers providing helpful explanations of work processes, and demonstrated competency when queried on matters pertinent to their role. 

Compliance tool used: No compliance tool used

Observation 3 - Taylor Pump Station

Date & time of visit: 2021-03-02 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

  • CER Inspection Officers (IOs) participated in a field level hazard assessment and site-specific orientation prior to entering the facility.
  • The perimeter of the facility was fenced. Warning signs were posted at the entrance; ‘no smoking’, product identifier, emergency phone number, required PPE.
  • Above ground piping inside the station was protected from traffic collision with concrete barriers.
  • The office/MCC building had first aid kit, emergency eye wash, and fire blanket, all of which were checked monthly.
  • IO reviewed a completed lock-out form ‘P-201 R+R’ dated 18 Dec 2020.
    • The Pembina Lockout/Tagout/Blind List appeared to be filled out correctly.
    • IOs visually verified (lock number, isolation point identifier) each of the 10 isolation points identified on the form.
    • Locks were individually keyed.
    • Unit suction, unit discharge, and flare line header had blinds installed in addition to the valves being locked closed.  
  • IOs observed two fixed gas detectors inside the P201 building, AIT-2001A and AIT-2001B. Attached to each detector was a record of preventative maintenance dates which is performed at 3-month intervals. IO reviewed preventative maintenance records for both detectors dated 4-Dec-2020.

Compliance tool used: No compliance tool used

Observation 4 - Spirit River Pump Station

Date & time of visit: 2021-03-10 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

  • IOs participated in a field level hazard assessment (FLHA) and site-specific orientation prior to starting the inspection.
  • The perimeter of the facility was fenced. Warning signs were posted at the entrance. 
  • Panic gates were functional providing means of emergency egress.
  • Above ground piping, knock out drum, and flare stack were protected from traffic collision with concrete barriers.
  • IOs observed two windsocks in good condition upon entering the facility.
  • The office/MCC building had first aid kit, emergency eye wash, and fire blanket, all of which are checked monthly.
  • IOs observed a caged fixed ladder near the flare stack, the top entrance of which was protected by a swing gate.
  • Rotating blades on exhaust fans were guarded.
  • ‘HEARING PROTECTION REQUIRED’ signs were posted near the entrance to the pump building.
  • Washroom facilities have running water, soap, and disinfecting wipes. A ‘NON-POTABLE’ warning sign is located above the sink in the washroom. Drinking water is provided in the office. 
  • Lube oil is stored in an outdoor flammable cabinet which is bonded to ground.
  • The knock-out truck out station had ground cables and signs reminding truck operators to attach the grounding cables prior to fluid transfer (see CNC 6).
  • IOs observed two fixed LEL detectors (AIT-610 and AIT-611) within the pump building. The sensors were located near the floor beneath each pump. A tag was affixed to each sensor listing the dates of inspection which appeared to occur at 3-month intervals.
  • IOs also observed 3 fire eyes within the pump building (AT-011, AT-012, and AT-013). The associated tags recorded dates of ‘function test’ last performed July 15, 2020.

Compliance tool used: No compliance tool used

Observation 5 - CNC 1: Taylor Pump Station Emergency Shower

Date & time of visit: 2021-03-02 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) observed an emergency shower positioned adjacent to a low voltage electrical panel. The company advised that the shower was obsolete and should have been tagged out of service or removed.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall make the shower inoperable or remove the electrical hazards.

Due date: 2021-03-03

Date closed: 2021-03-03
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 6 - CNC 2: Taylor Pump Station Fence Grounding

Date & time of visit: 2021-03-02 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOs observed that two of the copper strands on the grounding conductor between the perimeter fence entrance gate and the ground clamp were broken. IOs further observed other gates had not been bonded to ground.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall bond gates to ground.

Due date: 2021-03-05

Date closed: 2021-03-05
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 7 - CNC 3: Taylor Pump Station Lock-Out/Tag-Out

Date & time of visit: 2021-03-02 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOs observed a lock-box containing one key in the motor control center (MCC) building. The box was sealed but no associated lock-out form could be found. Upon further inquiry, IOs learned the lockbox contained a key for legacy keyed-alike 'red' isolation locks.

Company representatives stated the red isolation locks were replaced with unique-keyed blue locks in 2018. IOs observed, however, that legacy red locks were still used to lock isolation devices within the MCC. Company representatives were not able to verify control of keys for these legacy locks.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall replace the keyed alike locks with individually keyed locks in accordance with Pembina's Isolation from Energy Sources Standard.

Due date: 2021-03-03

Date closed: 2021-03-03
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 8 - CNC 4: Taylor Pump Station Signage

Date & time of visit: 2021-03-02 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) observed a faded 'DANGER - OVERHEAD POWER LINES' sign outside the entrance of Taylor Pump Station.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall replaced the faded warning sign.

Due date: 2021-03-05

Date closed: 2021-03-05
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 9 - CNC 5: Spirit River Pump Station Switching Gear Panels

Date & time of visit: 2021-03-03 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) observed several 4160 volt switching gear rear panels within the motor control center (MCC) that had missing or loose bolts.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall replace missing bolts and securely fasten the loose ones.

Due date: 2021-03-05

Date closed: 2021-03-05
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 10 - CNC 6: Spirit River Pump Station Warning Sign

Date & time of visit: 2021-03-03 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) observed that a warning sign 'NOTICE - TRUCKERS ATTACH GROUND CABLES' located at the knock-out drum truck out box had fallen off and wasn't visible.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall replace the warning sign.

Due date: 2021-03-05

Date closed: 2021-03-05
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 11 - CNC 7: Taylor Pump Station Switching Gear Panels

Date & time of visit: 2021-03-02 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) observed several 4160 volt switching gear rear panels within the motor control center (MCC) that had missing or loose bolts.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall replace missing bolts and securely fasten the loose ones.

Due date: 2021-03-05

Date closed: 2021-03-05
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 12 - NNC 1: Spirit River PHA Validation

Date & time of visit: 2021-03-03 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IO reviewed Hazard and Operability (HAZOP) Studies:

There was no evidence that the Spirit River Pump Station HAZOP had been relvalidated after 5 years as required by section 4.4.3.2 of the Pembina Engineering Specification: Process Hazards Analysis (PHA) ESS 7.01 Version 4.0.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide evidence that the process hazard analysis for Spirit River Pump Station has been revalidated in accordance with Pembina's standard.

Due date: 2021-04-16

Date closed: 2021-04-27
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 13 - NNC 2 - Control of Process Hazards

Date & time of visit: 2021-03-05 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) requested evidence that process hazards had been identified, evaluated, analyzed, and controlled for Taylor, Sweetwater, and Spirit River pump Stations. The company provided the following documents:  

  • Pembina Engineering Specification – Process Hazards Analysis (PHA) ESS 7.01, June 2020 
  • HAZOP & LOPA for Taylor Pump Station, November 2016 
  • HAZOP Sweetwater Pump Station, November 2015 
  • HAZOP Spirit River Pump Station, April 2014 

IOs selected a sample of recommendations and parking lot items from the Hazard and Operability Analysis (HAZOP) to verify the effective implementation of the Pembina Engineering Specification: Process Hazards Analysis (PHA) ESS 7.01, hereafter referred to as ‘PHA standard’. 

IOs found no evidence that recommendations and parking lots items identified in the HAZOP studies had been managed according to section 10 ‘Managing PHA Recommendations’ of the PHA standard:

  • There was no documented evidence that PHAs had been reviewed by the Operations Manager, 
  • action plans that address PHA recommendations were not available, 
  • records of measures taken to resolve parking lots items were not available, 
  • no evidence indicating the Company has implemented an effective means of tracking recommendations that indicate the status of action items, 
  • no evidence that recommendations had been documented on the Corrective Action Request and Close Out (CARC) form referenced in section 10.5 of the PHA standard,
  • no evidence that employees who perform or oversee work in the process affected by PHA recommendations had been informed of actions required to be implemented to address PHA recommendations, 
  • workers responsible for overseeing maintenance work at the facilities were not aware of the status of PHA recommendations or associated action plans, and
  • workers were uncertain of who in the company would have this information, if it existed. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

The Company shall demonstrate to the Inspection Officer effective implementation of the processes used to identify, analyze, evaluate, control and communicate process hazards and potential process hazards (hazards) for all CER regulated Pouce Coupé Pipe Line Ltd. facilities. The response must include, at a minimum: 

  • Evidence that hazards have been identified in accordance with the PHA standard, 
  • an inventory of the identified hazards, 
  • evidence that hazards have been evaluated and risk prioritized in accordance with the PHA standard, 
  • a description of controls to prevent, mitigate, and manage the hazards, and
  • evidence that hazards have been communicated to anyone who is exposed to the risks.

Due date: 2021-05-21

Date closed: 2021-05-20
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 14 - IR 1 - Fire Eyes Inspection Frequency

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers observed three fire eyes in the pump building at Spirit River Pump Station last inspected on 15 July 2020.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the company established inspection and/or maintenance interval for fire eyes.

Due date: 2021-03-12

Date closed: 2021-03-12
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