Compliance Verification Activity Report: CV1920-139 - Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-139
Start date: 2019-09-10
End date: 2019-09-11

Team:

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

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

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Field inspection of the 3 pump stations and 1 station on the Pouce Coupé Northern System (aka Taylor to Belloy - Ref 236). This inspection was completed at the same time as CV1920-306.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Taylor (Northern) Pump Station

Date & time of visit: 2019-09-10 11:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Taylor Northern pump station is part of the Pouce Coupé Northern pipeline system, and carries natural gas liquids (NGLs) from the Taylor Tank Farm to the Belloy Terminal. The pipeline is 173 km in length with nominal pipe size (NPS) 10.

The Maximum Operating Pressure (MOP) for the line is 9930 kPa. The station houses two centrifugal pumps, with one used as a backup. The pressure is controlled by varying the pump speed and over-pressure protection is assured by high pressure alarms, pump shutdowns, thermal relief valves (TRV) and Pressure Safety Valves (PSV). The high pressure shutdown is triggered at a pressure lower than 110% MOP. The PSVs and TRVs relieve to a knock out drum and flare stack.

The inspection / testing frequencies for the pressure control systems, pressure limiting systems, except for the TRVs and PSVs, were set to be tested at an annual frequency (at minimum). This is in compliance with CSA Z662-19 Clause 10.9.5.2, which requires the inspection, assessment and testing of these systems to be conducted at least once per calendar year, with a maximum interval of 18 months. The TRVs and the PSVs were set to be maintained every 10 years and 5 years respectively. The company at the request of the CER inspectors provided the Relief Device Single Data Sheet for a TRV and a PSV for review. The company confirmed that after the scheduled maintenance/service is completed, Pembina's Facility Integrity would review the results and issue a condition report (Z3 notification) with the comments and recommended interval. CER Inspectors requested the documentation of the review and the condition report for the same TRV and PSV. (See Information Request (IR) - Taylor (Northern) Pump Station - TRV and PSV Maintenance Schedule Observation)

The pumps are each housed in separate pump buildings. The pump buildings were installed with gas monitoring. A warning alarm and ventilation is initiated at 20% of the lower explosive limit (LEL), and at 40% LEL, a station Emergency Shutdown (ESD) is triggered. The pump buildings are equipped with fire detection systems that triggers a station shut down when a fire is detected and stops the ventilation. The buildings are equipped with beacons that will light when the station is in an alarm state (Fire, Gas Detection). The company stated that the fire and gas detection systems are checked every 3 months. The building was also equipped with automated louvers to assist with ventilation.

The P-1 pump building was observed to have an ESD button installed inside the building. The button is not easily visible and accessible in the event of an emergency. (See Notice of Non-compliance - Taylor (Northern) Pump Station - ESD button Location Observation)

The P-2 building was observed to be missing labels for the product and flow direction. (See Notice of Non-compliance - Taylor (Northern) Pump Station - P-2 Labelling Observation)

The pumps are equipped with seal leak, vibration and temperature monitoring, and unit shut down devices. Each pump unit was equipped with a switch to allow for local pump shut down.

The station’s instrumentation (e.g. temperature and pressure sensors and transmitters) are checked annually at minimum.
The station has a below ground knock-out drum that is equipped with a level transmitter. The company stated that a third party company conducts inspection of the vessel at a three year frequency.

The valves in the station had open/close position marking on them, and it was confirmed that they are visually inspected for leaks weekly. A valve maintenance program is in place to inspect the mechanics of the valves on an annual basis.

The pump station has several station ESD push buttons which are located outside the P-2 pump and electrical buildings. The ESD functionality is tested at an annual frequency.

The station’s above ground piping paint coating was in good condition. The coating on the soil-to-air interface was observed to be in good condition.  The piping was supported with insulation pads where needed between the pipe support and piping. The piping (except for P-2 suction and discharge) had labeling for direction of flow and product identification. As some of the piping in the station, including the knock out drum, was below ground, cathodic protection (CP) was maintained on the entire system. The company stated that CP rectifier readings are taken monthly and CP surveys are conducted on an annual basis. Piping corrosion assessments including ultrasonic testing (UT) thickness checks on facility piping were conducted periodically. Leak detection on the pipeline is through mass balance, and leak detection for the pipeline system is monitored and controlled through the Sherwood Park Control Centre.

The station is equipped with pigging launching/receiving sites. The company stated that the O-ring gaskets are changed whenever necessary, or annually.

The required name plates were observed on the equipment.

Communication at site is through SCADA and radio. If communication is lost, the local programmable logic controller (PLC) recognizes the loss of communication and is programed to initiate a soft station shut down. If power is lost, the uninterruptible power supply (UPS) will power the PLC and provide SCADA the functionality to initiate a soft shut down of the station. Emergency lighting at the station is powered through the UPS.

The station is fenced and has emergency exit gates with panic bars for easy exit. The entrance of the station has signage with the company name, emergency phone number, warning signs about the presence of ethane and smoking.  Wind socks were installed.

Compliance tool used: No compliance tool used

Observation 2 - IR - Taylor (Northern) Pump Station - TRV and PSV Maintenance Schedule

Date & time of visit: 2019-09-10 11:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The TRVs and the PSVs were set to be maintained every 10 years and 5 years respectively. The company at the request of the CER inspectors provided the Relief Device Single Data Sheet for a TRV and a PSV for review. The company confirmed that after the scheduled maintenance/service is completed, Pembina's Facility Integrity would review the results and issue a condition report (Z3 notification) with the comments and recommended interval.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the records for the review conducted by Pembina’s Facility Integrity and the Condition Reports issued for PSV-0210 and TRV-01.

Due date: 2019-10-11

Date closed: 2019-10-23
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 - Notice of Non-compliance - Taylor (Northern) Pump Station - ESD button Location

Date & time of visit: 2019-09-10 11:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors noted that the P-1 pump building ESD push button was located inside the building. The ESD push button was not readily visible, and may not be readily accessible in the event of an emergency.
 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Relocate the ESD push button to the outside of the P-1 building such that the push button is easily visible and accessible in the event of an emergency.  Provide supporting documentation to confirm implementation.

Due date: 2019-11-29

Date closed: 2019-10-08
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 - Notice of Non-Compliance - Taylor (Northern) Pump Station - P-2 Labelling

Date & time of visit: 2019-09-10 11:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The P-2 building was observed to be missing labels for the product and flow direction.

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

Regulatory requirement:

Relevant section(s):

Company action required:

It was observed that the suction and discharge piping inside the P2 pump building did not have product or direction of flow labelling. The company shall apply pipe labels and provide supporting pictures to confirm that the station piping is clearly labelled to indicate product type and direction of flow.

Due date: 2019-10-11

Date closed: 2019-10-08
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 - Sweetwater Pump Station

Date & time of visit: 2019-09-10 13:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Sweetwater pump station is part of the Pouce Coupé Northern pipeline system that carries natural gas liquids (NGLs) from the Taylor Tank Farm to the Belloy Terminal. The pipeline is 173 km in length with nominal pipe size (NPS) 10.  This station was constructed in 2016 and functions as a booster station.

The Maximum Operating Pressure (MOP) for the line is 9930 kPa.  The station houses two centrifugal pumps, with one used as a backup. The pressure is controlled by varying the pump speed and over-pressure protection is assured by high pressure alarms, pump shutdowns, thermal relief valves (TRV) and Pressure Safety Valves (PSV). The high pressure shutdown is triggered at a pressure lower than 110% MOP. The PSVs and TRVs relieve to a knock out drum and flare stack.

The inspection / testing frequencies for the pressure control systems, pressure limiting systems, except for the TRVs and PSVs, were set to be tested at an annual frequency (at minimum). This is in compliance with CSA Z662-19 Clause 10.9.5.2, which requires the inspection, assessment and testing of these systems to be conducted at least once per calendar year, with a maximum interval of 18 months. The TRVs and the PSVs were set to be maintained every 10 years and 5 years respectively. The company stated that the servicing frequency for TRVs and PSV are generally consistent throughout all the CER regulated stations on the Pouce Coupé Northern pipeline system. (See Information Request (IR) - Taylor (Northern) Pump Station - TRV and PSV Maintenance Schedule)

The pumps are housed in a pump building. The building was installed with gas monitoring. A warning alarm and ventilation is initiated at 20% lower explosive limit (LEL), and at 40% LEL, a station Emergency Shutdown (ESD) is triggered. The pump buildings are equipped with fire detection systems that triggers a station shut down when a fire is detected and stops the ventilation. The buildings are equipped with beacons that will light when the station is in an alarm state (Fire, Gas Detection). The company stated that the fire and gas detection systems are checked every 3 months. The building was also equipped with automated louvers to assist with ventilation.

The pumps are equipped with seal leak, vibration and temperature monitoring, and unit shut down devices. Each pump unit was equipped with a switch to allow for local pump shut down.

The station’s instrumentation (e.g. temperature and pressure sensors and transmitters) are checked annually (at minimum).

The knock out drum was heat traced and insulated.  The company stated that the unit was on a 10 year inspection cycle.

The valves in the station had open/close position marking on them, and it was confirmed that they are visually inspected for leaks weekly. A valve maintenance program is in place to inspect the mechanics of the valves on an annual basis.

The pump station has several station ESD push buttons which are located outside the pump and electrical buildings. The ESD functionality is tested at an annual frequency.

The station piping is all above ground and the station was isolated from the pipeline cathodic protection (CP) system. The above ground piping paint coating was in good condition. The coating on the soil-to-air interface was observed to be in good condition. The piping was supported with insulation pads where needed between the pipe support and piping. The piping had labeling for direction of flow and product identification. Piping corrosion assessments including ultrasonic testing (UT) thickness checks on facility piping were conducted periodically. Leak detection on the pipeline is through mass balance, and leak detection for the pipeline system is monitored and controlled through the Sherwood Park Control Centre.

The station is equipped with pigging launching/receiving sites. The company stated that the O-ring gaskets are changed whenever necessary, or annually.

The required name plates were observed on the equipment.

Communication at site is through SCADA and radio. If communication is lost, the local programmable logic controller (PLC) recognizes the loss of communication and is programed to initiate a soft station shut down. If power is lost, the uninterruptible power supply (UPS) will power the PLC and provide SCADA the functionality to initiate a soft shut down of the station. Emergency lighting at the station is powered through the UPS.

The entrance of the station has signage with the company name, emergency phone number, warning signs about the presence of ethane and smoking.  Wind socks were installed.

The station is fenced and has emergency exit gates with panic bars.  It was observed that the fencing on one side of the station was leaning inwards and falling over (see picture) with potential to hinder an effective escape to a place of safety in case of an emergency. (See Notice of Non-compliance - Sweetwater Pump Station - Fence Observation)

Subsequent to the CER inspection, the company provided supporting documentation indicating that a temporary measure was applied such the the west-side exit door would be accessible in the event of an emergency.

Compliance tool used: No compliance tool used

Observation 6 - Notice of Non-compliance - Sweetwater Pump Station - Fence

Date & time of visit: 2019-09-10 13:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

The station is fenced and has emergency exit gates with panic bars.  It was observed that the fencing on one side of the station was leaning inwards and falling over (see picture) with potential to hinder an effective escape to a place of safety in case of an emergency. (See Notice of Non-compliance - Sweetwater Pump Station - Fence Observation)

Subsequent to the CER inspection, the company provided supporting documentation indicating that a temporary measure was applied such the the west-side exit door would be accessible in the event of an emergency.

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

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Until Pembina applies a permanent fix to the west-side fence, Pembina shall:
    1. routinely monitor the temporary fence to ensure its integrity until the time a permanent fix is conducted; and
    2. provide supporting documentation confirming that the requirement to routinely monitor the temporary fence was added into the manned patrol weekly checks.
  2. Provide a corrective action plan and a timeline for the implementation of a permanent fence and emergency exit that is compliant with the requirements of CSA Z662-19 Clause 4.14.1.4.

Due date: 2019-10-18

Date closed: 2019-10-08
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 - Bonanza Station

Date & time of visit: 2019-09-11 09:15

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Bonanza station is part of the Pouce Coupé Northern pipeline system that carries natural gas liquids (NGLs) from the Taylor Tank Farm to the Belloy Terminal. The pipeline is 173 km in length with nominal pipe size (NPS) 10.  This station used to be a pump station, but eventually the station was gutted and disconnected from the pipeline system.

During the time of the CER inspection, the only operating components at this station were the pipeline risers (below-ground to above-ground, and above-ground to below-ground), the pipeline that ran aboveground in between the risers, and the associated appurtenances (e.g. valves and instrumentation).

The Maximum Operating Pressure (MOP) for the line is 9930 kPa.  The station had actuated block valves that had open/close position marking on them.  The company stated that a valve maintenance program is in place to inspect the mechanics of the valves on an annual basis.
The station’s instrumentation (e.g. pressure transmitters) are checked annually (at minimum).

The station’s above ground pipe paint coating appeared to be in poor condition (see pictures). Surface rust was observed all along the uncoated areas of the pipeline. The below ground yellow jacket coating could be seen near the air-to-soil interface. Surface rust was also observed where the below ground coating ended. CER inspectors requested further information regarding the assessment of pipeline coating and condition at this station. Subsequent to the inspection, the company stated that an inline inspection of the Taylor to Gordondale section of the pipeline was completed in November 2018.  The inspection review of the pipeline segment at this station indicated that no corrosion or geometry features were reported by the inspection tool.  The company further stated that Pouce Coupé's Pipeline Integrity typically does not dispatch inspectors to field locations to look at risers which can be inspected using smart tool technology. The peeling paint was not brought to the attention of the Pouce Coupé's Facility/Pipeline Integrity team as a result of previous inspections, however Pouce Coupé's Operations will endeavour to paint the riser pipes next season. CER inspectors requested further information relating to the Pouce Coupé's Operation and Maintenance activities at the Bonanza Station. (See Information Request below)

The piping appeared to be adequately supported, however the saddles were taken off and the insulation pads were missing between one of the pipe support and piping. (See Information Request below)

The piping had labeling for direction of flow and product identification.

The company stated that CP was maintained on the entire system. Leak detection on the pipeline is through mass balance, and leak detection for the pipeline system is monitored and controlled through the Sherwood Park Control Centre.

The station is fenced and has emergency exit gates with panic bars for easy exit. The entrance of the station has signage with the company name, emergency phone number, warning signs about the presence of ethane and smoking.  Wind socks were installed.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

CSA Z662-19 Clause 9.1.5 states 'Piping that is exposed to the atmosphere shall be inspected for corrosion at the intervals outlined in the operating company’s operating and maintenance (O&M) manuals'.  Provide:

  1. Sections of Pouce Coupé's O&M manual specific to the inspection and assessment of aboveground piping at Pouce Coupé's facilities. Include information on the requirements for the aboveground pipe coating, intervals of inspection and monitoring, and the type of assessment(s) conducted.
  2. Demonstrate that the activities that Pouce Coupé currently undertakes at the Bonanza Station is compliant to the requirements of the company's O&M manuals.
  1. Provide an explanation on how the exisiting pipeline supports and braces on the aboveground pipeline segment at the Bonanza Station is sufficient and meets the requirements of CSA Z662-19 Clause 4.9.2.

Due date: 2019-10-22

Date closed: 2019-11-19
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 8 - Spirit River Pump Station

Date & time of visit: 2019-09-11 11:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Spirit River pump station is part of the Pouce Coupé Northern pipeline system that carries natural gas liquids (NGLs) from the Taylor Tank Farm to the Belloy Terminal. The pipeline is 173 km in length with nominal pipe size (NPS) 10.  This station was constructed in 2016 and functions as a booster station.

The Maximum Operating Pressure (MOP) for the line is 9930 kPa.  The station houses two centrifugal pumps, with one used as a backup. The pressure is controlled by varying the pump speed and over-pressure protection is assured by high pressure alarms, pump shutdowns, thermal relief valves (TRV) and Pressure Safety Valves (PSV). The high pressure shutdown is triggered at a pressure lower than 110% MOP. The PSVs and TRVs relieve to a knock out drum and flare stack.

The inspection / testing frequencies for the pressure control systems, pressure limiting systems, except for the TRVs and PSVs, were set to be tested at an annual frequency (at minimum). This is in compliance with CSA Z662-19 Clause 10.9.5.2, which requires the inspection, assessment and testing of these systems to be conducted at least once per calendar year, with a maximum interval of 18 months. The TRVs and the PSVs were set to be maintained every 10 years and 5 years respectively. The company stated that the servicing frequency for TRVs and PSVs are generally consistent throughout all the CER regulated stations on the Pouce Coupé Northern pipeline system. (See Information Request (IR) - Taylor (Northern) Pump Station - TRV and PSV Maintenance Schedule)

The pumps are housed in a pump building. The building was installed with gas monitoring. A warning alarm and ventilation is initiated at 20% lower explosive limit (LEL), and at 40% LEL, a station Emergency Shutdown (ESD) is triggered. The pump buildings are equipped with fire detection systems that triggers a station shut down when a fire is detected and stops the ventilation. The buildings are equipped with beacons that will light when the station is in an alarm state (Fire, Gas Detection). The company stated that the fire and gas detection systems are checked every 3 months. The building was also equipped with automated louvers to assist with ventilation.

It was observed that flammable liquids (e.g. pump oil, lubricants) were stored in a pail inside the pump building in quantities greater than needed for daily use.  This is a non-compliance to CSA Z662-19 Clause 10.9.1.5. The non-compliance was corrected prior to the completion of the inspection by removing the liquids from inside the pump building. (See Corrected Non-Compliance below)

The pumps are equipped with seal leak, vibration and temperature monitoring, and unit shut down devices. Each pump unit was equipped with a switch to allow for local pump shut down.

The station’s instrumentation (e.g. temperature and pressure sensors and transmitters) are checked annually (at minimum).

The knock out drum was heat traced and insulated.  The company stated that the unit was on a 10 year inspection cycle.

The valves in the station had open/close position marking on them, and it was confirmed that they are visually inspected for leaks weekly. A valve maintenance program is in place to inspect the mechanics of the valves on an annual basis.

The pump station has several station ESD push buttons which are located outside the pump and electrical buildings. The ESD functionality is tested at an annual frequency.

The station piping is all above ground and the station was isolated from the pipeline cathodic protection (CP) system. The above ground piping paint coating was in good condition. The coating on the soil to air interface was observed to be in good condition. The piping was properly supported with insulation pads where needed between the pipe support and piping. The piping had labeling for direction of flow and product identification. Piping corrosion assessments including ultrasonic testing (UT) thickness checks on facility piping were conducted periodically. Leak detection on the pipeline is through mass balance, and leak detection for the pipeline system is monitored and controlled through the Sherwood Park Control Centre.

The station is equipped with pigging launching/receiving sites. The company stated that the O-ring gaskets are changed whenever necessary, or annually.

The required name plates were observed on the equipment.

Communication at site is through SCADA and radio. If communication is lost, the local programmable logic controller (PLC) recognizes the loss of communication and is programmed to initiate a soft station shut down. If power is lost, the uninterruptible power supply (UPS) will power the PLC and provide SCADA the functionality to initiate a soft shut down of the station. Emergency lighting at the station is powered through the UPS.

The station is fenced and has emergency exit gates with panic bars for easy exit. The entrance of the station has signage with the company name, emergency phone number, warning signs about the presence of ethane and smoking.  Wind socks were installed.
 

Compliance tool used: No compliance tool used

Observation 9 - Corrected Non-compliance - Spirit River Pump Station - Storage of Flammable Liquids

Date & time of visit: 2019-09-11 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

It was observed that flammable liquids (e.g. pump oil, lubricants) were stored in a pail inside the pump building in quantities greater than needed for daily use.  This is a non-compliance to CSA Z662-19 Clause 10.9.1.5. The non-compliance was corrected prior to the completion of the inspection by removing the liquids from inside the pump building.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

It was observed that various items were stored inside the pump building (e.g. pump oil, lubricants) that were not required for everyday use.  This is a non-compliance to CSA Z662-19 Clause 10.9.1.5. Pembina to correct this non-compliance by removing the items.

Due date: 2019-09-11

Date closed: 2019-09-11
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