Compliance Verification Activity Report: CV2223-111 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2083

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Integrity Management

Rationale and scope:

Electrical inspection of Trans Mountain Expansion Project to verify compliance to NEB Certificate OC-065 Conditions 30 and 101.

Compliance tool(s) used:

• None

Facility details

Facilities:

• KAMLOOPS
• BLACK PINES
• KINGSVALE

Facility Types

• Pipeline
• Electrical facility
• Pump station

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16

Regulatory instrument number(s):

• OC-065

Observations (no outstanding follow-up required)

Observation 1 - Kamloops Pump Station

Date & time of visit: 2022-10-17 13:00

Discipline: Integrity Management

Categories:

• Facilities
• Electrical Workmanship
• Batteries and UPS

Facility:

• KAMLOOPS (Facility)

Observations:

The Kamloops pump station has two separate pump stations, one for Line 1 and one for Line 2. The inspection scope was limited to the new Line 2 pump station electrical equipment. Line 2 has its own substation feed four 4.16 kV Variable Frequency Drives (VFDs) used to control 4x 5000 HP motors and the four new pumps from a 15/125 MVA, 138/4.16 kV transformer Line 2 also feeds a 4.16kV/600V Station Service Transformer (SST).

CER staff inspected the Substation and observed the following:

1. Fencing: Fencing of appropriate height (min 1.8 m) and equipped with three strands of barbed wires.
2. Signage: Appropriate warning signs, carrying the words “Danger – High Voltage,” were posted adjacent to the gate lock, at all outside corners, and at appropriate spacing (e.g., not exceeding 15 m).
3. Grounding of the equipment and fencing:
   1. Ground electrodes were observed at the corner of the substation.
   2. Grounding wires were observed for every piece of equipment observed at the substation.
   3. Grounding wires were observed on the fencing at appropriate distances (i.e., not exceeding 12 m intervals)
4. Equipment layout for Isolation Switches, Circuit Breaker, Main Transformer and SST, Current Transformer (CT) and Potential Transformer (PT), Neutral Ground Resistor (NGR), Lighting Arrestors, Metering Cabinet, and incoming and outgoing cable connections.
   1. CER Staff observed that the equipment layout was consistent with the single-line diagram (SLD) provided by the company.
   2. CER staff verified the NGR settings (160 Ohm, 15 A) which were consistent with the specifications provided by the company.
   3. TMEP Staff provided drawing details for the transformer oil containment system which CER Staff was satisfied with.

1. MFR Relay Settings: CER staff verified the MFR4 & MFR9 settings which were consistent with the specification provided by the company (Figure 1 - Kamloops MFR4 and Figure 2 - Kamloops MFR9). Furthermore, simulation results and secondary injection testing results were reviewed by CER staff. There was no concern from CER staff regarding the simulation and test results reviewed.
2. UPS and Battery: According to CSA 22.1-18 Section 26-506 Storage-battery rooms shall be adequately ventilated, and storage batteries shall not be subjected to an ambient temperature greater than 45°C. Temperature control devices and building vents were observed. However, CER Staff could not observe the ventilation system specific to the batteries and UPS because both are enclosed within cabinets.
   CER staff requested the following information:
   1. Statement of appropriate ventilation from the manufacturer: In an email dated 28 October 2022, TMEP provided a statement from EPCOR Technologies stating that the SESB building's ventilation exceeds the requirements of CSA 22.1-18 Section 26-506.
   2. Description of preventive maintenance program: In an email dated 28 October 2022, TMEP provided:
      1. the UPS Operation and Maintenance Manual,
      2. a record of the D365 tracking system log of UPS readings and checks.
      3. a statement that the D365 tracking system generates annual work orders to inspect and test the UPS equipment.
   3. CER staff have no further concerns about the batteries. Nevertheless, CER staff recommends TM keep up with the maintenance and ventilation and follow the recommendations of Safety Advisory SA 2014-01 to prevent any incidents.
3. There was sufficient space in the aisles in front of the electrical panels (min. 1 m consistent with CSA22.1-18 s.2-308(1)) and nothing blocking their access. The building had adequate access and egress. The panels had labels warning of the high voltage and arc flash hazards and there were also signs on the outside of the building doors warning of the high voltage hazard.

1. Grounding: A ground bar was present.
2. Arc Flash Hazard Signage: According to CSA 22.1-18 Rule 2-306: Electrical equipment […] shall be field marked to warn persons of potential electric shock and arc-flash hazards. At the time of the inspection, TMEP staff stated that permanent arc flash warning labels were being printed and would be posted in the next weeks. Therefore, the permanent warning labels could not be observed at the time of the inspection. At the time of the inspection, TMEP Staff committed to providing a picture of the warning labels once they are posted. In an email response dated 22 November 2022, TMEP provided pictures of arc flash labels in place. CER staff have no further concerns regarding the arc flash labels.
3. Lock Out/Tag Out: Locks and Tags were present on equipment indicating safety procedures were observed regarding energized equipment (Figure 3 - Kamloops ESB Lock Out - Tag Out).
4. The ESB building is equipped with a battery-powered UPS system and a diesel generator as a backup power system. Trans Mountain explained that the power backup system maintains the station instrumentation and the emergency shut-down system in operation during a power loss event. The diesel generator was grounded and equipped with a positive air shut-off.

1. Lock Out/Tag Out: Locks and Tags were present on equipment indicating safety procedures were observed regarding energized equipment. CER Staff decided to inspect the inside of one VFD panel, which required performing a Lock Out/Tag Out procedure.
2. Wiring: The copper wiring showed no sign of stranding
3. Fuses: They are of Shawmut 900 A type, which is consistent with the specification provided by the company (Figure 4 - VFD Fuse).
4. Arc Flash Hazard: Temporary warning signs with the arc flash rating and minimum working distances were present (Figure 5 - Arc Flash Label).

1. Pumps: Four 5000 HP Pumps.
2. Nameplates and Warning Signages were present.
3. Grounding: CER staff checked the grounding resistance at 3 sample points resulting in measurements between 0.1 Ohm to 3 Ohm, which is consistent with the requirement of CSA 22.1-18 (i.e., less than 15 Ohm)

Compliance tool used: No compliance tool used

Observation 2 - Black Pines Pump Station

Date & time of visit: 2022-10-18 13:00

Discipline: Integrity Management

Categories:

• Facilities
• Electrical Workmanship
• Batteries and UPS

Facility:

• BLACK PINES (Facility)

Observations:

Black Pines pump station has two new lines, Line 1 and Line 2. The station is fed from a 15/25 MVA 138/4.16 kV transformer. Line 1 feeds 2 x 2500 hp pump motors and Line 2 feeds 2 x 5000 hp pump motors through respective VFDs. 4.16 kV bus supplies to a 4.16 kV/600 V SST. The scope of the inspection was to check the substation yard, VFDs and respective protection systems, UPS system, pumps stations, emergency generator and electrical grounding in all these facilities.

CER Staff inspected the VFD Building and observed the following:

1. Lock Out/Tag Out: CER inspected the inside of a VFD cabinet, therefore a lockout/tag out procedure was performed.
2. Grounding: CER Staff performed a ground resistance check resulting in a measurement of 0.1 to 0.2 Ohm, which is consistent with the requirement of CSA 22.1-18 (i.e., less than 15 Ohm).
3. Bend Radius: According to the requirements of CSA 22.1-18 Section 36.102, The minimum bending radii measured at the innermost surface of the bend for permanent training of cables during installations shall be consistent as required in CSA C22.1 s. 12-712. CER Staff requested TMEP staff to verify the compliance of the bend radii within the VFD building with the requirements of CSA 22.1-18 Section 36-102. In an email response dated 8 December 2022, TMEP stated the VFD is designed as per UL347A, which is equivalent to CSA C22.2 No 274. TMEP further stated that similar designs are widely used in industry and also on Trans Mountain Line 1 without any issues. CER staff have no further concerns regarding the bend radii.
4. Fuses: They are of Shawmut 900 A type, which is consistent with the specification provided by the company.

1. Fencing: According to CSA 22.1-18 Section 26-304, fences, excluding barbed wire, shall be not less than 1.8 m high. However, CER Staff observed wooden stairs adjacent to the fence (Figure 6 - Black Pines Substations Stairs). At the top of the stairs, the height of the fence appeared to be less than 1.8 m high and the stair railing would also make it easier for a person to go over the fence. CER Staff requested the stairs to be removed. In an email dated 07 November 2022, TMEP confirmed the stairs have been removed (Figure 7 - Black Pines Substation Stairs removed). CER Staff have no further concerns about the stairs.
2. Signage: According to CSA 22.1-18 Section 36-006 Warning signs carrying the words “Danger – High Voltage” shall be posted on a station fence immediately adjacent to the locks on all access gates. However, at the time of the inspection, no warning sign was observed on the substation gate. CER Staff recommended TMEP Staff post warning signs on the Substation Gate according to the requirements of CSA 22.1-18 Section 36-006. In an email dated 28 October 2022, TMEP committed to adding a sign. And in an email dated 19 December 2022, TMEP provided pictures showing a warning sign posted at the substation gate. CER Staff have no further concerns about the signage.
3. Grounding of the equipment and fencing:
   1. Ground electrodes were observed at the corner of the substation.
   2. Grounding wires were observed for every piece of equipment observed at the substation.
   3. Grounding wires were observed on the fencing at apparent appropriate distances (i.e., not exceeding 12 m intervals)
4. Equipment layout: CER Staff observed that the equipment layout was consistent with the SLD provided by the company.

1. MFRs: CER Staff observed MRF cabinets for line 1 and 2 VFDs and SST.
2. UPS and Battery: According to CSA 22.1-18 Section 26-506 Storage-battery rooms shall be adequately ventilated, and storage batteries shall not be subjected to an ambient temperature greater than 45°C. Temperature control devices and building vents were observed. However, CER Staff could not observe the ventilation system specific to the batteries and UPS because both are enclosed within cabinets. CER staff requested the following information.
   1. Statement of appropriate ventilation from the manufacturer: In an email dated 28 October 2022, TMEP provided a statement from EPCOR Technologies stating that the SESB building's ventilation exceeds the requirements of CSA 22.1-18 Section 26-506.
   2. Description of preventive maintenance program: In an email dated 28 October 2022, TMEP provided:
      1. 1. the UPS Operation and Maintenance Manual,
         2. a record of the D365 tracking system log of UPS readings and checks.
         3. a statement that the D365 tracking system generates annual work orders to inspect and test the UPS equipment.
   3. CER staff have no further concerns about the batteries. Nevertheless, CER staff recommends TM keep up with the maintenance and ventilation and follow the recommendations of Safety Advisory SA 2014-01 to prevent any incidents.

1. Pumps: Two 2500 HP Pumps and Two 5000 HP Pumps.
2. Nameplates and Warning Signages were present.
3. Grounding was observed.

1. Grounding: A ground bar was present.
2. Arc Flash Hazard Signage: According to CSA 22.1-18 Rule 2-306: Electrical equipment […] shall be field marked to warn persons of potential electric shock and arc-flash hazards. At the time of the inspection, TMEP staff stated that permanent arc flash warning labels were being printed and would be posted in the next weeks. Therefore, the permanent warning labels could not be observed at the time of the inspection. At the time of the inspection, TMEP Staff committed to providing a picture of the warning labels once they are posted. In an email response dated 22 November 2022, TMEP provided pictures of arc flash labels in place. CER staff have no further concerns regarding the arc flash labels.
3.  Lock Out/Tag Out: Locks and Tags were present on equipment indicating safety procedures were observed regarding energized equipment.

Compliance tool used: No compliance tool used

Observation 3 - Kingsvale Pump Station

Date & time of visit: 2022-10-19 09:30

Discipline: Integrity Management

Categories:

• Facilities
• Electrical Workmanship
• Batteries and UPS

Facility:

• KINGSVALE (Facility)

Observations:

Kingsvale pump station is a common facility for the existing Line 1 and new Line 2 pump stations. The facility is fed from a 15/20/25 MVA 138/4.16 kV transformer which feeds both Line 1 and Line 2 through their independent medium voltage switchgear.
Line 2 feeds 3 x 5000 hp motors through their respective VFDs. The 4.16 kV bus also feeds a 4.16 kV/600V SST. The scope of the inspection was to inspect the substation yard, Line 2 VFDs, protection system of the associated motors, UPS system, the motors and the associated pumps, grounding system and emergency generator.

CER Staff inspected the VFD Building and observed the following:

1. Grounding: CER Staff performed a ground resistance check resulting in a measurement of 0.03 Ohm, which is consistent with the requirement of CSA 22.1-18 (i.e., less than 15 Ohm).

1. Bend Radius: According to the requirements of CSA 22.1-18 Section 36.102, The minimum bending radii measured at the innermost surface of the bend for permanent training of cables during installations shall be consistent as required in CSA C22.1 s. 12-712. CER Staff requested TMEP staff to verify the compliance of the bend radii within the VFD building (Figure 8 - Kingsvale VFD Building Cables) with the requirements of CSA 22.1-18 Section 36-102. CER Staff requested TMEP staff to verify the compliance of the bend radii within the VFD building with the requirements of CSA 22.1-18 Section 36-102. In an email response dated 8 December 2022, TMEP stated the VFD is designed as per UL347A, which is equivalent to CSA C22.2 No 274. TMEP further stated that similar designs are widely used in industry and also on Trans Mountain Line 1 without any issues. CER staff have no further concern regarding the bend radii.
2. Fuses: Were of Shawmut 900 A type, which is consistent with the specification provided by the company.

1. Grounding: A ground bar was present.
2. Arc Flash Hazard Signage: According to CSA 22.1-18 Rule 2-306: Electrical equipment […] shall be field marked to warn persons of potential electric shock and arc-flash hazards. At the time of the inspection, TMEP staff stated that permanent arc flash warning labels were being printed and would be posted in the next weeks. Therefore, the permanent warning labels could not be observed at the time of the inspection. At the time of the inspection, TMEP Staff committed to providing a picture of the warning labels once they are posted. In an email response dated 22 November 2022, TMEP provided pictures of arc flash labels in place. CER staff have no further concerns regarding the arc flash labels.
3.  Lock Out/Tag Out: Locks and Tags were present on equipment indicating safety procedures were observed regarding energized equipment.

1. Pumps: Three 5000 HP Pumps.
2. Nameplates and Warning Signages were present.
3. Grounding was observed.

1. Fencing: According to CSA 22.1-18 Section 26-304, fences, excluding barbed wire, shall be not less than 1.8 m high. However, CER Staff observed wooden stairs adjacent to the fence (Figure 9 - Kingsvale Substation Stairs). At the top of the stairs, the height of the fence appeared to be less than 1.8 m high, and the stair railing would also make it easier for a person to go over the fence. CER Staff requested the stairs to be removed. In an email dated 28 October 2022, TMEP confirmed the stairs were removed (Figure 10 - Kingsvale Substation Stairs Removed). CER Staff have no further concerns about the stairs.
2. Signage: According to CSA 22.1-18 Section 36-006 Warning signs carrying the words “Danger – High Voltage” shall be posted on a station fence immediately adjacent to the locks on all access gates. However, no warning sign was observed on the substation gate. CER Staff recommended TMEP Staff post warning signs on the Substation Gate according to the requirements of CSA 22.1-18 Section 36-006. In an email dated 28 October 2022, TMEP committed to adding a sign. And in an email dated 19 December 2022, TMEP provided pictures showing a warning sign posted at the substation gate. CER Staff have no further concerns regarding the gate signage.
3. Grounding of the equipment and fencing: One grounding cable was not buried representing a tripping hazard. CER Staff requested the cable to be buried. In an email dated 31 October 2022, TMEP provided a picture showing that the cable has since been buried (Figure 11 - Kingsvale Substation Cable (Buried)).
4. Equipment layout: CER Staff observed that the equipment layout was consistent with the SLD provided by the company.

1. MFRs: CER staff verified the MFR6 settings which were consistent with the specification provided by the company (Figure 12 - Kingsvale MFR6).
2. UPS and Battery: According to CSA 22.1-18 Section 26-506 Storage-battery rooms shall be adequately ventilated, and storage batteries shall not be subjected to an ambient temperature greater than 45°C. Temperature control devices and building vents were observed. However, CER Staff could not observe the ventilation system specific to the batteries and UPS because both are enclosed within cabinets. CER staff requested the following information.
   1. Statement of appropriate ventilation from the manufacturer: In an email dated 28 October 2022, TMEP provided a statement from EPCOR Technologies stating that the SESB building's ventilation exceeds the requirements of CSA 22.1-18 Section 26-506.
   2. Description of preventive maintenance program: In an email dated 28 October 2022, TMEP provided:
      1. the UPS Operation and Maintenance Manual,
      2. a record of the D365 tracking system log of UPS readings and checks.
      3. a statement that the D365 tracking system generates annual work orders to inspect and test the UPS equipment.
   3. CER staff have no further concerns about the batteries. Nevertheless, CER staff recommends TM keep up with the maintenance and ventilation and follow the recommendations of Safety Advisory SA 2014-01 to prevent any incidents.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: