Compliance Verification Activity Report: CV2021-265 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-265
Start date: 2020-11-19
End date: 2020-11-19

Team:

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Integrity and Emergency Inspection of Farans Point Terminal for Tank Fire Protection.

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 Observations

Date & time of visit: 2020-11-19 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The inspection scope was focused on the storage tanks, the secondary containment system and the fire protection system and equipment and is in support of the previously completed Information Exchange Meeting CV2021-266.
 
CER inspectors verified the Fire Pump Building. The building houses the fire pump, water supply, a 3785 L foam bladder system, and the related piping and foam proportioning system as well as a reserve of Foam concentrate of 18 barrels of 205 L each. The foam concentrate is AR-AFFF 3X3. TNPI explained that Levitt-Safety is conducting most of the maintenance and testing activities on the fire protection system. TNPI staff are responsible for conducting test runs on the fire pump every week and ensuring a proper supply of diesel for the pump engine. After each test run, the fire pump control panel generates a self-assessment printed report to inform TNPI of the results of the test. At the time of the inspection the diesel level in the pump engine tank was almost full and the company started the pump to demonstrate that it was operable.
 
The fire protection piping was in good condition and valves had position indicators, including remote position indicators for the critical valves that are monitored by the control room.
 
TNPI explained that the fire protection system outside of the fire pump building is currently winterized but that it remains operable if a fire event was to occur during the winter. The fire pump building is heated and does not have to be winterized.
 
TNPI explained that the foam concentrate in the bladder system is tested annually to confirm that it is still adequate for use.
 
CER inspectors then inspected the storage tanks, secondary containment system and the fire protection system in the yard.
 
The foam solution and fire water piping in the yard was in apparent good condition and properly supported. Each tank has two foam makers. Tanks' coating was in good condition and there was no apparent damage to the tanks' shell and base. TNPI explained that the tanks have two radar level monitors and that alarms would be triggered at a high level and at a high-high level. There is also a high-high level mechanical switch. On a high-high level condition, pumping to the tank would be automatically stopped and the tank valve would be closed. Each tank is also equipped with under-tank leak detection ports. These ports are checked quarterly for verifying the presence of hydrocarbons. TNPI also explained that there are several places on each tank top to verify the tank roof position. This is a manual operation.
 
There is a road going around the secondary containment system that can provide firefighters access to all tanks. There are nine foam/water fire hose cabinets located along the perimeter on the facility and five water fixed monitors for tank cooling. CER inspectors verified one fire hose cabinet and one water monitor and they were in apparent good condition. TNPI explained that the fire hose cabinets and water monitors are checked on a monthly basis.
 
TNPI explain that the valves for the secondary containment drainage system are kept normally closed. When drainage is required, they are manually opened and the water goes to the oil/water separator before being discharged.

Compliance tool used: No compliance tool used

Observation 2 - IR – Foam Concentrate Drums in Fire Pump Building

Discipline: Integrity Management

Categories:

Facility:

Observations:

Of the 18 foam concentrate drums, most appear to be dated 2004 except for two of them that were dated 2016. At the time of inspection, TNPI could not confirm if the foam concentrate in the drums had an expiry date or whether it was tested on a regular basis to confirm that it is still usable. Although not mandatory, the industry recognized standard NFPA 11 (2016) section 12.6 requires that foam concentrate be inspected at least annually and that samples be sent for quality condition testing.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please confirm that the foam concentrate stored in the containers is still adequate for use and explain how TNPI made that determination.

Due date: 2020-12-22

Date closed: 2021-01-05
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 - IR – Preventing Unintended Movement of Valves in Fire Pump Building

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER staff noticed that none of the valves in the fire pump building were either car sealed or locked in their position. For a fire protection system, having the right valve positioning at the time it is needed is essential to ensure its effectiveness, especially considering that this is an automatic fire protection system at a site not always manned. Although not mandatory, the industry recognized standard NFPA 11 (2016) section 4.7.6.5 requires that all valves required for an automatic foam system be supervised in the operating position by either an electrical method, or be locked or sealed.
 
TNPI explained that the valves in the fire protection system in the fire pump building are not sealed or locked because the building is locked at all times, that the valves are maintained by a third party contractor that follows NFPA guidelines, and that critical valves have position sensors that monitor if any of the valves are moved off seat, and if so the fire panel would create an alarm to trigger investigation.
 
CER inspectors noted that although the fire pump building is normally locked, TNPI staff have access to the building and that once in the building, TNPI staff have access to the fire system valves and piping.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Explain if all the valves required for the automatic foam system to operate are the “critical” valves referred to by TNPI and that all these valves are therefore equipped with monitoring position sensors.

Due date: 2020-12-11

Date closed: 2020-12-16
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 - IR – Clarification on the Secondary Containment System

Discipline: Integrity Management

Categories:

Facility:

Observations:

In response to the information request for Information Exchange Meeting CV2020-266, TNPI answered that it had single secondary containments for its tanks. Based on what was observed during the inspection, it appears the containment system may actually be a shared containment system. A single vs shared containment system represents a different fire hazard in the event of a large release in the containment system.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please confirm if each tank has its own containment system that can individually contain 110% of the volume of each tank or if this is a shared containment system that can contain the volume of the largest tank and 10% of the aggregated volume of the other tanks in the shared containment system.

If this is a shared containment system, explain if TNPI plans to re-analyse the fire hazard for a potential release in the secondary containment.

Due date: 2020-12-11

Date closed: 2020-12-16
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

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 5 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code