Compliance Verification Activity Report: CV1920-135 - Plains Midstream Canada ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-135
Start date: 2020-03-03
End date: 2020-03-03

Team:

Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

To assess compliance with the Onshore Pipeline Regulations, Safety Management Program; and applicable Canada Labour Code Part II Occupational Health and Safety requirements, at PTC Mainline Pump Stations: Manson, Rapid City, MB; and PTC Red Jacket Storage Facility SK. Focus areas: Hazard and risk identification to prevent incidents; Arc Flash; and pertinent IOGP Life Saving Rules (Bypassing Safety Controls, Confined Space, Driving, Energy Isolation, Hot Work, Line of Fire, Safe Mechanical Lifting, Work Authorization and Working at Heights).

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 Safety

Date & time of visit: 2020-03-03 18:00

Discipline: Safety Management

Categories:

Facility:

Observations:

The CER observed the following during its inspection of the Manson and Rapid City Pump Stations:

The CER observed the following during its inspection of the Red Jacket Storage Facility:

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

Observation 2 - IR#3: Process Safety Management, Process Hazard Analysis and Management of Change

Date & time of visit: 2020-03-03 10:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide a copy of the available Red Jacket Facility HAZOP (2015) close out or completion report, noting status of the HAZOP recommendations.
  2. Provide a copy of the Plains Midstream corporate level, Process Safety Management process/ guidance document
  3. Provide a copy of the Plains Midstream corporate level, Management of Change process/ guidance document

Due date: 2020-03-31

Date closed: 2020-03-10
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#4: Pressure Safety Valve, outlet piping

Date & time of visit: 2020-03-03 14:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Pipeline Pressure Safety Valve (PSV) downstream outlet piping (off the discharge port) was observed to be vertically orientated, and without provision for natural drainage at both the Manson and Rapid City pump stations. Accumulation of water/ice or debris within the discharge piping may contribute to adverse affect of relief device performance, by potentially blocking the discharge piping and inhibiting over pressure protection of the pipeline.
CER Inspector observed that 'tape' was used on three PSV's outlet piping, covering the outlet to prevent entry of debris or liquids (rain/snow etc). Upon inspection of the tape on several pipes, it was observed that one peice of tape was deteriorated and in need or replacement.


 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Plains Midstream to provide documented assurance from a designated competent authority, explaining how the application of tape is the approved method of protection for PSV discharge outlet piping.
Include in the response: the inspection criteria for PSV discharge outlet piping openings, for all PSV's along the entirety of the PPTC pipeline, that ensures PSV outlets remain protected and safe from obstruction.

  Install standard caps designed for the purpose, and inform inspector when completed.

Due date: 2020-06-01

Date closed: 2020-06-19
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

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

Observation 4 - NNC#1: Pigging Task Hazard Inventory

Date & time of visit: 2020-03-03 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

The CER reviewed the Plains Task Hazard Inventory(THI) for pigging and found that the residual risks in the document were not reduced after controls were identified. In addition, the THI was generic for all of Plains’ assets and did not address site specific controls to address the hazards. This oversight demonstrates a breakdown in Plains process for preparing, reviewing, and revising documents required for the company to meet its obligations under section 6 of the OPR.

 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Plains to ensure that the Pigging THI reflects the appropriate residual risk and that appropriate controls are in place to address site specific tasks.  The company will advise the Inspector that this has been completed.
 

Due date: 2020-05-04

Date closed: 2020-04-27
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

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

Observation 6 - 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

Observation 7 - 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

Observation 8 - 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

Observation 9 - 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

Observation 10 - 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

Observation 11 - 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

Observation 12 - 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