Compliance Verification Activity Report: CV1920-177 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-177
Start date: 2019-07-30
End date: 2019-07-31

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Integrity inspection of Trans Mountain Burnaby Terminal, Sumas Terminal, and Sumas Pump Station to verify compliance to the NEB OPR, CSA Z662 and Canada Labour Code.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Burnaby Terminal

Date & time of visit: 2019-07-30 08:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

Presentation Discussion:

Trans Mountain provided a presentation covering NEB staff’s topics of discussion conveyed prior to the meeting, including:

Tanks were originally designed and constructed to either API 12C (1953 construction) or API 650 (1988 construction). Trans Mountain stated that it complies with API 653 for tank inspection and maintenance.
 
Third party seismic hazard assessments of the terminals were conducted since original construction, resulting in a number of upgrades to secondary containment dikes and piping. Secondary containment dikes have been upgraded to survive a one-in-2500 year seismic event, in accordance with the British Columbia Building Code. Buildings and retaining walls have also been reinforced to increase their resistance to seismic loading. Tank connection piping has been upgraded where determined to be necessary to permit increased flexibility during seismic activity, reducing the risk of an accidental release. Operationally, Trans Mountain has also reduced tank levels to minimize the potential for overtopping due to liquid sloshing effects following seismic activity. Trans Mountain also explained that additional evaluations would be conducted by field operations staff following a seismic event. Any integrity related findings would be passed on to Trans Mountain’s facility integrity staff to determine if further integrity actions are required.  Trans Mountain indicated that it installed high density polyethylene piping in its fire water distribution system, providing increased flexibility over the previously installed ductile iron piping. Trans Mountain indicated that an assessment for seismic loading has not yet been conducted for the Sumas Terminal.
 
The existing ductile iron foam solution piping on Tanks 88 and 90 were replaced with galvanized steel for increased corrosion resistance. Replacement of the foam solution piping on Tank 87 is currently in the design stage.
 
Trans Mountain provided details on its integrity evaluations following the Board’s Safety Advisory issued regarding mechanical properties of Hyundai pipe, confirming its use in the recently installed Suncor Lateral relocation work. Trans Mountain confirmed it had assessed the pipe’s properties (notch toughness) from pipe mill heat runs representing the installed pipe, as obtained through a third party. Preliminary results indicate that the pipe meets mechanical property requirements. Seam welds on Hyundai pipe field bends were also inspected with ultrasonic testing with no issues identified. Trans Mountain also confirmed that the Hyundai pipe installed successfully passed the hydrotest. Trans Mountain confirmed that the Suncor Lateral operates at low stress levels (17% SMYS), resulting in a low risk of failure. Trans Mountain indicated that it would be completing further testing on surplus pipe, representative of the pipe installed on the Suncor Lateral. Test results would be included in an engineering assessment of the lateral and incorporated into Trans Mountain’s Integrity Management Program.     
 
 
Manifold Area:
 
The NPS 24 mainline delivers product to the Burnaby Terminal. The terminal piping is operating at a lower pressure and is protected against overpressures from the mainline by one of two relief valves. One is set to 2400 kPa when mainline flow is being directed to the Suncor Delivery Lateral, and one is set to 1300 kPa when mainline flow is directed through the Crude Meter Bank. The pressure relief line relieves into Tank 99. A manual valve located just upstream of the pressure relief valve was locked in the open position to ensure an open path.
 
Refined products that come from the mainline are re-routed to the Suncor Lateral and not stored onsite. There is a prover loop for the refined products and flow meters upstream of the Suncor Lateral.
 
There is also a prover loop for the crude oil delivered from the terminal. The crude oil flows through the Crude Meter Bank before delivery to either the Parkland Refinery or the Westridge Marine Terminal. The Crude Oil Meter Bank can also be used to transfer products between the tanks. The crude oil stored onsite can be shipped to the Westridge Terminal via the Westridge Meter Bank. The two meter banks use centrifugal pumps for product transfer. The company representatives explained that these pumps are not capable of overpressuring the piping, and therefore there are no overpressure protection systems downstream of those pumps.
 
The aboveground piping coating appeared to be in good condition and the piping also appeared to be properly supported. The piping was labeled with the product name and direction of flow.
 
There are thermal relief valves for the aboveground piping to protect against overpressures from thermal expansion. The thermal relief valves relieve to Tank 99.
 
A biocide injection system was also observed to be recently installed to mitigate potential internal corrosion on the Westridge Delivery Line.
 
 
Tank 88:
 
Tank 88 was constructed in 1988 to API 650: Welded Steel Tanks for Oil Storage (Edition 7).  The tank has a dome roof with an aluminum internal floating roof. The tank is equipped with two independent overfill protection systems: one uses a radar level gauge and the other uses a displacement level switch monitoring system. Trans Mountain indicated that the overfill protection system is designed in compliance with API RP 2350: Overfill Protection of Storage Tanks in Petroleum Facilities. If an overfill situation is detected (High-High alarm from radar or level switch tripped), the tank is isolated.
 
The tank is coated externally for corrosion protection. The tank bottom underside is protected from external corrosion using a Cathodic Protection (CP) system. The internal side of the tank bottom is coated with an epoxy coating. The tank does not have an under-tank leak detection system. However, a product leak that would travel to the perimeter of the tank could be detected using several ports located around the tank. Level monitoring is used for leak detection on the tanks. Following the inspection, Trans Mountain clarified that leak detection via level monitoring is algorithm-based. 
 
The tank has heat detector wires located between the foam dam and tank wall for fire detection. Any detection from both wires would initiate fire suppression consisting of a semi-fixed rim seal fire protection system. Trans Mountain later clarified the following on August 20 2019: 
The tank has its own secondary containment which Trans Mountain indicated meet the volumetric requirements of CSA Z662.
 
All the tanks in the terminal are inspected daily, weekly, monthly, and annually by operations staff. The API 653 in-service inspections are completed by qualified third party inspectors every five years. The API 653 out of service inspection for Tank 88 was completed in 2016.
 
The tank shell coating appeared to be in good condition and no apparent signs of damage or deformation were observed. The internal floating roof was clean with no accumulation of product, water, or debris. The grounds attached to the bottom of the tank observed were in good condition.
 
There is a sump in the secondary containment to drain rain water accumulation. The sump drain system is kept normally closed and is only opened under the supervision of an employee after visual confirmation that no product is present in the water. There are also oil detection (Agar) and conductivity probes installed to prevent the release of any product when draining the secondary containment area.
 
It was observed that the foam piping systems at Tanks 88 and 90 have been replaced by a new galvanized piping system.
 
 
Tank 74
 
Tank 74 was constructed in 1953 to API 12C: Specifications for Welded Oil Storage Tanks.  The tank has an external floating roof. The tank is equipped with two independent overfill protection systems: a radar level gauge and a displacement level switch monitoring system. Trans Mountain indicated that the overfill protection system is designed in compliance with API RP 2350: Overfill Protection of Storage Tanks in Petroleum Facilities. If an overfill situation is detected (High-High alarm from radar or level switch tripped), the tank is isolated.
 
The tank is coated externally for corrosion protection. The tank bottom underside is protected from corrosion using a CP system. The internal side of the tank bottom is coated with an epoxy coating. The tank does not have an under tank leak detection system; however, a product leak extending to the perimeter of the tank could be identified using several ports located around the tank. Level monitoring is used for leak detection on the tanks. Following the inspection, Trans Mountain clarified that leak detection via level monitoring is algorithm-based.
 
The tank has three fire eyes installed for fire detection.
 
The tank has its own secondary containment which Trans Mountain indicated meets the volumetric requirements of CSA Z662.
 
The tank shell coating appeared to be in good condition, and no apparent signs of damage or deformation were observed. The internal floating roof was clean with no accumulation of product, water, or debris. The observed grounding connections attached to the annular plate of the tank were in good condition.
 
There is a sump in the secondary containment to drain rain water accumulation. The sump drain system is kept normally closed and is only opened under the supervision of an employee after visual confirmation that no product is present in the water. There are also oil detection (Agar) and conductivity probes installed to prevent the release of any product when draining the secondary containment area.
 
The tank roof drain outlet is heat traced and operated year round to drain precipitation accumulation from the roof. The roof drain water is visually monitored during the drainage and is released to the secondary containment where it can be later drained via the sump drainage system. 
 
The API 653 in-service inspection for this tank was completed in 2019.
 
The tank has been assessed for seismic hazards, and as a result, the piping system has been upgraded to include additional flexibility to withstand a 1-in-2500 year seismic event.
 

Compliance tool used: No compliance tool used

Observation 2 - Sumas Terminal

Date & time of visit: 2019-07-31 08:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

Update on Day 1 Presentation Discussion:

Trans Mountain provided further information on action items from the previous day’s meeting and inspection at the Burnaby Terminal.
 
With respect to Trans Mountain’s response procedures following seismic events:

Trans Mountain also confirmed that ongoing construction activities observed at the Burnaby Terminal during the previous day’s inspection were related to NEB authorizations concerning facility piping and ancillary infrastructure relocations, decommissioning work, fence installations, and associated roadwork upgrades.
 
Trans Mountain also clarified that seismic piping upgrades remain outstanding on three tanks at the Burnaby Terminal (Tanks 72, 84, and 85).
 
Sumas Terminal

The Sumas Terminal is an unmanned terminal,  however routine inspections are carried out daily year-round. The tanks are also inspected monthly by operations staff. The API 653 in-service inspections are completed by qualified third party inspectors every five years. Staff reviewed the latest API 653 in-service inspection report for Tank 102, the API 653 out-of-service inspection report for Tank 104, and 2019 monthly inspection reports for Tank 122. Trans Mountain confirmed the recommendations provided in the reports are being addressed.
 

Tank 103
 
Tank 103 was constructed in 1957 to API 12C: Specifications for Welded Oil Storage Tanks.  The tank has a dome roof with a steel internal floating roof. The tank is equipped with two independent overfill protection systems. One system uses a radar level gauge while the other uses a level switch monitoring system. Trans Mountain indicated that the overfill protection system is designed to comply with API RP 2350: Overfill Protection of Storage Tanks in Petroleum Facilities. If an overfill situation is detected (High-High alarm from radar or level switch tripped) then the pipeline is automatically shut down and the tank is isolated.

The tank is coated externally for corrosion protection. The tank bottom underside is protected from external corrosion using a CP system. The internal side of the tank bottom is coated with an epoxy coating. The tank does not have an undertank leak detection system. Level monitoring is used for leak detection on the tanks.
 
The tank has heat detector wire located between the foam dam and tank wall for fire detection. Any detection would initiate an investigation by operating staff before deploying foam.
 
The tank has its own secondary containment which Trans Mountain indicated meets the volumetric requirements of CSA Z662.
 
The tank shell coating appeared to be in good condition and no apparent signs of damage or deformation were observed. The internal floating roof was clean with no accumulation of product, water, or debris. The observed grounding connections attached to the bottom of the tank were in good condition.
 
There is a manual drain valve to drain rain water accumulation from the Tank 103 secondary containment. The sump drain system is kept normally closed, and is only opened after visual confirmation that no product is present in the water. There are also oil detection (Agar) and conductivity probes installed to prevent the release of any product when draining the site secondary containment areas.
 
The tank roof drainage outlet is heat traced and operated year round to drain precipitation. The water is visually inspected and is released to the secondary containment where it would accumulate in the sump. 
 
Tank 101
 
Tank 101 was constructed in 1953 to API 12C: Specifications for Welded Oil Storage Tanks.  The tank has an external floating roof. The tank is equipped with two independent overfill protection systems. One system uses a radar level gauge while the other employs a level switch monitoring system. Trans Mountain indicated that the overfill protection system is designed in compliance with API RP 2350: Overfill Protection of Storage Tanks in Petroleum Facilities. If an overfill situation is detected (High-High alarm from radar or level switch tripped) then the pipeline is automatically shut down and the tank isolated.
 
The tank is coated externally for corrosion protection. The tank bottom underside is protected from corrosion using a CP system. The internal side of the tank bottom is coated with an epoxy coating. The tank does not have an undertank leak detection system. Level monitoring is used for leak detection on the tanks.
 
The tank has its own secondary containment which Trans Mountain indicated meets the volumetric requirements of CSA Z662.
 
The tank shell coating appeared to be in good condition, and no apparent signs of damage or deformation were observed. The external floating roof was clean with no accumulation of product or debris. Minor water accumulation was observed. The observed grounding connections attached to the annular plate of the tank were in good condition.
 
There is a sump in the secondary containment to drain rain water accumulation. The sump drain system is kept normally closed and is only opened under the supervision of an employee after visual confirmation that no product is present in the water. There are also oil detection (Agar) and conductivity probes installed to prevent the release of any product when draining the secondary containment area.
The tank roof drainage outlet is heat traced and operated year round to drain precipitation. The water is visually inspected and is released to the secondary containment where it would accumulate in the sump.

Compliance tool used: No compliance tool used

Observation 3 - Sumas Pump Station

Date & time of visit: 2019-07-31 12:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Sumas pump station is used to transfer product to the Sumas Terminal, the Puget Sound pipeline and the mainline to the Burnaby Terminal. There are four pump units housed in a partially open building. The pumps are centrifugal, and pressure is controlled with pressure control valves. The discharges of the pump station are protected by high pressure alarms and a High-High pressure shut down systems.
 
The mainline upstream of the station is protected by a pressure relief valve which relieves to Tank 101 at the Sumas Terminal. Valves upstream and downstream of the pressure relief valve were locked in the open position to ensure an open path.
 
There is a pump station emergency shutdown (ESD) push button located near the main entrance / exit of the station and one in the control room. A station ESD shuts down all pump units, create an open path for the mainline to flow toward Burnaby, and isolates the station from the mainline. The company representative explained that the station is equipped with a back-up generator capable of operating the station ESD system. The pump units are equipped with unit ESD push buttons located by the units. A unit ESD shuts down and isolates the pump unit.
 
The pump building is equipped with fire and gas detection. Upon fire detection, a station ESD is initiated. For gas detection, at 10% Lower Explosive Limit (LEL), an alarm is generated, and at 20% LEL a station ESD is initiated.
 
The pump units are equipped with a system to collect potential seal leaks. A seal leak would flow to the pump station sump tank. There is a flow switch to detect a seal leak, which would trigger a unit ESD if tripped. The pump units are also equipped with temperature and vibration monitoring and protection systems.
 
The sump tank is equipped with level monitoring. There is a High level alarm, and at High-High level a station ESD is initiated. The sump tank is double-walled, and the interstice is monitored. The sump content can be re-injected into the pipeline system.
 
The aboveground piping coating appeared to be in good condition and the piping appeared to be properly supported. The piping was labeled with the product name and direction of flow.
 
There are thermal relief valves for the aboveground piping to protect against overpressures from thermal expansion. The thermal relief valves drain in the pump station sump tank.
 

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:

- 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