Compliance Verification Activity Report: CV2021-261 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-261
Start date: 2020-10-19
End date: 2020-10-23

Team:

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Carryover from FY1920 [Toronto Airport Terminal]. Workplace hazard Identification, analysis and control; safety management of operational activities; Process Safety Focus - Process hazard and risk identification, analysis and controls; Adherence to safe work place and operating practices and procedures; Management of Change (MOC) process implementation - temporary and permanent facility changes;

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General

Date & time of visit: 2020-11-03 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

The terminal consists of 2 internal floating roof tanks each with a capacity of approximately 7000 cubic meters for storage of Jet A fuel.

Compliance tool used: No compliance tool used

Observation 2 - Toronto Terminal - Fire system

Discipline: Safety Management

Categories:

Facility:

Observations:

Multiple portable fire extinguishers were available at the facility and were current on their monthly inspection requirements. TNPI stated that inspection and tests of the fire suppression system are conducted annually by an external 3rd party and provided documentation of the most recent inspection (2019). The results indicate that the system was tested in accordance to NFPA 25 requirements and deemed functional. Elements of the system tested included (but not limited to)

The electronic work order used to initiate, track and close the fire system inspection was also presented.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Confirm that noted deficiencies in the 2019 Fire Suppression System Inspection and Test Report, including the replacement of west Hose Cabinet angle valve, has been resolved. If yet to be resolved, provide rationale and expected date of resolution.

Due date: 2020-11-30

Date closed: 2021-03-01
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 - Process Hazards and Management of Change - TNPI system

Discipline: Management System

Categories:

Facility:

Observations:

TNPI presented a copy of the Process Hazard Analysis Hazard Operability Study performed in 2017 on the TNPI East system which identifies potential hazardous events and scenarios, the level of risk, mitigations and recommendations to address such hazards. Company representatives stated that the recommendations are in progress, and follow a risk based approach with all high risk items being already completed. The company presented and also stated that action items for the study are tracked through its internal system with assigned responsibilities and expected dates of completion. It also stated that it will revalidate the study in 2022 as part of a 5 year cycle.

In assessing implementation of recommendations from the study, the Management of Change (MOC) for the increase of Pressure Relief Valve (PRV) pressure set points and modifications of Surge Relief Valves (SRV) as part of the over pressure protection project was presented and reviewed. The MOC identified stages of initiation, pre-approvals, evaluation and analysis (inclusive of performing risk assessments, stakeholder communication, implementation plan and approval), implementation and follow-ups for each proposed change, tasks and action items assigned to responsible personnel, and metrics to track overdue action items.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide a copy of the most recent Process Hazard Analysis performed for the system inclusive of

Due date: 2020-11-30

Date closed: 2021-03-01
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: No

Observation 4 - Toronto Terminal - Inspection, Measurement and Maintenance

Discipline: Integrity Management

Categories:

Facility:

Observations:

TNPI stated that its maintenance program for equipment, including mechanical, electrical and instrumentation system is maintained in its CMMS database. The maintenance for such equipment is frequency driven (e.g., monthly, semi-annually, annually) with the system providing notifications of when any inspection, testing and calibrations need to be undertaken with resulting work orders created in order to complete the tasks.

Notifications for overdue items which may result in a backlog are sent to supervisors and managers. The company also stated that backlogs for maintenance actions are prioritized for completion based on supervisory judgement but it is currently developing a risk based prioritization system to address such backlogs. Further, deferrals are subject to an MOC process that require management approval and sign-off which is also tracked electronically via an internal database (IFS).

Sample records of recent monthly routine tank inspections were presented and reviewed and indicate that such inspections remain current. These inspections assess the condition of the tank foundation, shell, roof and appurtenances such as valves, piping, sample points, access points, dike etc. and check for items such as distortions, signs of product leakage, paint condition, corrosion, etc.

Company presented sample work order records of instrumentation calibrations which are performed either annually or semi-annually. The records indicated actions were completed with the exception of differential pressure level transmitter for which action needs to be undertaken and is currently being tracked.

Company presented sample records of the most recent annual pressure relief device testing (primarily pop-test) and certification which appeared complete and with resolution of test findings where repairs were required.


 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. State the proposed date to complete the repairs of the faulty Tank #1 delta pressure level transmitter and the current mitigations required until such repairs are completed.

Due date: 2020-11-30

Date closed: 2021-03-01
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 5 - Integrity Dig

Discipline: Integrity Management

Categories:

Facility:

Observations:

Integrity dig performed on the NPS 10 TNPI mainline based on results from recent In-line inspections (ILI). Company representatives stated due to the corrosion feature identified from the ILI and validated by the dig, a compression sleeve was installed as the repair method and the pipe was re-coated with a KEMA tape coating and bitumen based primer and that the coating was wrapped with a 55% overlap. Company also stated that NDE in the form of phased array ultrasonic tests and magnetic particle inspections were performed on the pipe.

Company representatives stated that the safe excavation pressure for the pipe as the work was performed was 600 psi vs. a normal operating pressure of 650 psi. Records were presented to demonstrate the daily communication with the control center with respect to recording the safe excavation pressure prior to commencing work, the nature of work being undertaken on the pipeline and persons present at the worksite. It was also stated that due to the potential for induced current and resulting arc flash to occur as the work is being undertaken near overhead powerlines, valves and exposed steel are tested for voltage readings over the course of the work activities.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Demonstrate how the safe excavation pressure of 600 psi for the pipeline was determined, consistent with the requirements of CSA Z662-19 Clause 10.2.8

Due date: 2020-11-30

Date closed: 2021-03-01
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 - Castleton & Bowmanville Pump Stations

Discipline: Integrity Management

Categories:

Facility:

Observations:

TNPI stated that the stations are remotely monitored from the TNPI control room but inspections performed by maintenance personnel on a 10 day frequency to check the condition of the fencing, piping, station equipment and  signs of loss of containment.

Emergency back-up generator was present in each station and serve to isolate the stations by closing the station inlet and outlet block valves as well as the pump suction and discharge valves in the event of a power failure. The work orders and records of the most recent (2020) annual preventative maintenance (PM) performed on the generator (Castleton) presented by TNPI indicate that the PM is up to date.
TNPI stated it has implemented a process for identifying and tagging equipment deemed as safety critical which are ranked High, Medium or Low. Equipment in the stations was tagged to identify their safety criticality ranking.

The stations are equipped with sump tanks and TNPI stated that the tank levels are monitored at the control room via level transmitters and alarms. TNPI also stated that the tanks are inspected on a prescribed frequency of 3 years (for single wall tanks). Work order records presented indicate that inspections for the sump tanks are overdue but MOC have been created for extensions and to complete the tasks within a 30 day period.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide confirmation that outstanding sump tank inspections in the Castleton (and Bowmanville if applicable) station has been completed by the planned due date of November 24, 2020 

Due date: 2020-11-30

Date closed: 2021-03-01
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 - Integrity Dig - IR#2

Discipline: Integrity Management

Categories:

Facility:

Observations:

Per "Integrity Dig" observations and company response to information request on the subject

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide a copy of the procedures used to determine the safe excavation pressures for in-service pipelines.

Due date: 2020-12-09

Date closed: 2020-12-10
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: No

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