Compliance Verification Activity Report: CV2223-081 - Plains Midstream Canada ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-081
Start date: 2023-01-19
End date: 2023-01-19

Team:

Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Integrity and emergency inspection for tank fire protection at Regina terminal to verify compliance to the OPR and CSA Z662-19.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Preparedness and Response Discussion

Date & time of visit: 2023-01-19 08:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

On 19 January 2023, CER inspectors met with Plains Midstream Canada (PMC) representatives at the Regina Terminal Office to inspect the terminal and discuss current tank fire preparedness and response plans.

PMC discussed its current site safety measures and equipment in place at the four-tank terminal. Basic safety equipment was present including fire extinguishers, SCBAs, First Aid kits, personal air monitors, and fixed gas monitors throughout the site. CER Officers asked what the current plan would be should a tank fire occur, and PMC’s response was to evacuate the site if needed, call 911 dispatch and the Regina Fire Department would respond to extinguish a fire.

PMC also stated that they are part of the Area 6 Cooperative group that would also supply resources to fight a tank fire. They were not certain what resources the cooperative or the fire department would be able to supply, the tactics they would use, or what limitations or restrictions those resources may face when responding.

The site has a camera system that can be viewed remotely by PMC’s security staff, but not from the Olds control center. The site also has fire eyes in various locations however PMC explained that none are pointed at the tanks.  

PMC’s Prairie Emergency Response Plan (ERP) outlined that it would only be acceptable for workers to fight incipient fires and execute control measures for incidents if the risk was deemed low by those on scene. PMC staff explained that they are trained to use 30 lb fire extinguishers and that if a fire were beyond the extinguisher’s capability, they would consider that beyond the incipient fire stage and call for the fire department.

In addition, the Prairie ERP also states that the role of emergency services, such as fire departments, would be to “assist with fire protection outside of company property, off-site and/or outside of EPZ where trained personnel are available.” PMC staff understood this to apply to other pipeline-related emergencies such as spills or ruptures, and not be the case for tank fire response. CER inspectors explained that this would need to be clarified and that tank fire response specifics must be included or written in a separate ERP/Fire Plan if the response and expectations differ from other PMC ERPs or emergency procedures and tactics.

The Prairie ERP also stated that “Professional oilfield firefighters should manage extensive fires or uncontrolled facility fires”. PMC staff in attendance were not certain if formal contracts existed with any industrial firefighting companies or instructions to contact them in event of a fire.

The terminal does not have staff present 24/7; for after-hours emergency access, their emergency number is posted on the fence signage. PMC indicated that it has a staff member on call 24/7 and within 10 minutes response time to the site. PMC’s staff will need to open the gates for the fire department or other responders to enter the terminal in the event of an incident. CER Officers note that other potential response scenarios could involve the fire department responding before PMC staff and the timeliness of the response would be impacted by the current site access arrangements.  

Compliance tool used: No compliance tool used

Observation 2 - Field Inspection

Date & time of visit: 2023-01-19 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Tank 124

Tank 124 is in a shared secondary containment system with three other tanks. The tank has an outdoor booster pump skid located within the secondary containment beside the tank. The positive displacement booster pump has a 125 HP electrical drive. There is a pressure control valve and a pressure relief valve to provide pressure control and overpressure protection. The skid is equipped with fire and gas (LEL and H2S) detection. Plains explained that fire and gas detection would trigger a station ESD which would shut down and isolate the entire facility. There is a unit ESD push button located on the skid that would shut down and isolate the booster pump unit if pushed. There is also a pump seal leak detection system which would trigger a unit ESD if a seal leak was detected. The pump unit is also equipped with temperature and vibration monitoring and shutdown systems. The booster pump skids for the other three tanks also have the same protection devices and logic except that they don’t have fire detection.

For overfill protection, Tank 124 has two radars for level monitoring and a hi-hi level independent mechanical switch. The radars would generate a hi-level alarm at a hi-level, and a hi-hi level alarm and initiate tank isolation at a hi-hi level. The mechanical switch would also generate a hi-hi level alarm and initiate tank isolation.

Tank 121

CER inspectors went to the platform atop the tank to observe the tank roof and the overfill protection equipment. The roof is a steel pontoon external floating roof. The roof coating and rim seal appeared to be in good condition. There was some snow and water on the roof. Plains explained that the roof drain is currently winterized (plugged and filled with antifreeze). For overfill protection, Tank 121 has a radar and a float gauge for level monitoring and a hi-hi level independent mechanical switch. The radar or float gauge would generate a hi-level alarm at a hi-level, and a hi-hi level alarm and initiate tank isolation at a hi-hi level. The mechanical switch would also generate a hi-hi level alarm and initiate tank isolation.

Mainline Pump Skid

The pump station has a positive displacement pump unit with a 600 HP electric drive. The pump unit is outside, sitting on a concrete block, with a heated cover over the pump. There is a pressure control valve and a pressure relief valve to provide pressure control and overpressure protection. The skid is equipped with fire and gas (LEL and H2S) detection. Plains explained that fire and gas detection would trigger a station ESD which would shut down and isolate the entire facility. There is a unit ESD push button located beside the pump unit. The unit ESD would shut down and isolate the booster pump unit. There is also a pump seal leak detection system which would trigger a unit ESD if a seal leak was detected. The pump unit is also equipped with temperature and vibration monitoring and shutdown systems.  There is a station ESD push button located at the back of the office building, at a safe distance from the tanks, piping, and pump station.

Power Back-up

The site has a battery-powered uninterruptible power supply (UPS) and a diesel backup generator. These alternate sources of power allow the company to maintain the instrumentation on-site and operate the emergency shutdown system for the station in the event of a power loss.

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

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

Observation 3 - Notice of Non-Compliance to OPR Section 32

Date & time of visit: 2023-03-16 16:16

Discipline: Emergency Management

Categories:

Facility: REGINA - Facility

Observations:

Based on the information gathered during the field inspection CV2223-081on January 26th, 2023 and the Information Request #2 responses provided by PMC February 10th, 2023, CER Officers have determined that PMC does not have specific procedures or plans in place for anticipating, managing, and mitigating a tank fire event at its Regina facility. In addition, PMC has not demonstrated that it has access to the necessary resources for responding to such event. Without procedures, plans, and assurance that the resources are in place, CER Officers are of the view that PMC may not be able to respond effectively during a tank fire emergency. CER Officers have determined that PMC is non-compliant to the OPR section 32 and a Notice of Non-Compliance is issued to address the non-compliance.
 

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

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

PMC is to provide the CER Officers:
 

  1. By April 15th, 2023, a detailed corrective action plan to include tank fire response in its Emergency Management Program and describing the actions to be taken with completions dates for:
      1.  
    1. a) Developing plans or procedures to safely respond to and extinguish potential tank fire events, including but not limited to fire scenarios such as a rim seal fire, a full surface tank fire, a pool fire in the secondary containment, and other potential fire scenarios as determined by PMC via hazard identification and risk assessment.
    2. b) Determining the resources (water, foam concentrate, firefighting equipment, personnel, etc.) required for implementing the plans or procedures identified in (a).
    3. c) Demonstrating that PMC has access to the necessary resources identified in (b), including providing any necessary agreements with third parties to support such demonstration, as applicable.
    4. d) Training staff and contractors on tank fire response procedures. 
    5. e) Providing continuing education to responding agencies related to PMC’s tank farm fire response.
    6.  
  2. Confirmation and documentation demonstrating that the actions listed in 1 (a) to (e) above have been completed by their respective completion dates.
 
  1. By April 15th , 2023, confirmation that PMC has undertaken interim measures to reduce the risk of a tank fire event before the above actions in 1 and 2 are completed. The interim measures, and documented evidence of their completion, shall include but are not limited to: 
  1. a) PMC will secure the services and resources to respond to a fire event should one occur in the interim period. Documentation should include the qualifications, training, and resources of the service provider and the type of service arrangement.  
  2. b) PMC will review the controls in place at the Regina terminal for minimizing the likelihood of a tank fire event to ensure they are adequate and functioning properly.

16 May 2023 Update:
On 12 May 2023, Plains provided a revised corrective action plan (CAP) to address the company actions requested above. CER inspectors are satisfied with the 12 May 2023 revised CAP which includes the following actions and timelines. For more details on the CAP, see attached CV2223-081-NNC Corrective Action Plan (CAP) Response - Revised May 12, 2023.

Corrective Action Plan Schedule:
 
Date Item
May 11, 2023 Plains held kick-off meeting with Co-Op, Regina Fire & Protective Services to discuss
resources, training requirements, equipment access and necessary agreements
May 30, 2023 Plains HAZOP review scheduled for Regina Facility
June 30, 2023 HAZOP Report finalized
September 1, 2023 Based on the HAZOP, identification of resources, training requirements, equipment
access and necessary agreements to complete the development of the plan or
procedure
October 27, 2023 Plan or procedure finalized
December 27, 2023 Necessary training as identified in the plan or procedure completed
End of Quarter 1 2024 Tabletop exercise to be held with stakeholders identified in the plan or procedure


Plains has scheduled a Hazards and Operability Study (HAZOP) for the Regina facility with respect to potential
tank fire events on May 30, 2023, with the final report to be completed by June 30, 2023. In parallel, Plains
will continue working with Consumers Co-Operative Refinery Limited (Co-Op), and Regina Fire & Protective
Services to discuss resources, training requirements, access to equipment and necessary agreements for third
party support (please see detailed scheduled below). Plains is anticipating the completion of the appropriate plan
or procedure (i.e. Fire Safety Plan) to safely respond and extinguish potential tank fire events by October 27,
2023.

Confirmation and documentation demonstrating the completion of the corrective action plan mentioned above
will be submitted to the CER on the 15th of each month commencing June 15, 2023.



 

Due date: 2024-03-31