Compliance Verification Activity Report: CV2223-153 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-153
Start date: 2022-05-19
End date: 2022-05-19

Team:

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Integrity and Emergency Management inspection of the Toronto Airport Terminal to verify compliance to the OPR, CSA Z662-19 and CLC.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Toronto Airport Terminal

Date & time of visit: 2022-05-19 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Introduction

Trans Northern Pipeline Inc (TNPI)’s Toronto Airport Terminal includes:


TNPI’s Toronto Airport Terminal transfers product (jet fuel) from the two (2) tanks to Menzies Aviation that in turn, provides fueling services for Pearson International Airport. The terminal receives Jet A-1 fuel from TNPI’s Airport Junction station. The refined product can come from the Nanticoke refinery or the Sun Canadian pipeline.


Coordination with local first responders

The TNPI facility is within the borders of the Mississauga Fire and Emergency Services (MFES) service area and near the border of the Greater Toronto Airport Authority Fire and Emergency Services.  As a result, TNPI invites both services, and the City of Toronto, to a pre-fire exercise which is usually held annually in September or October at the GTAA’s Fire and Emergency Services Training Institute (FESTI).  Due to COVID-19, the 2020 session did not occur and the 2021 session was held virtually. An in-person event is planned to resume this fall where the Fire Services, Peel and Mississauga Emergency Management, and Menzies (fuel distributor) will be invited. 

In the interim, TNPI has recently (May 3-6 and 10) brought in several platoons from MFES Station 119 for site familiarization, including access, emergency shutdown (ESD) buttons, and a system overview.  MFES indicated that they will not use TNPI fire suppression resources on the tank fire but will conduct fire prevention operations by cooling the adjacent tank.

TNPI has a contract with Fire Master in Alberta. Their contract with Fire Master allows for direct support to the municipal fire chief at site. Fire Master can mobilize additional equipment to site in 12-20 hour.  In the interim, TNPI reported that there are other contractors in the Greater Toronto Area which have foam and application equipment (e.g., Accuworx - A GFL Company).

Site Entrance Signage

CER inspectors noted that the site entrance signage included the company name, an emergency phone number, and warning signs. Although the non-smoking sign was posted on the site office’s outer wall, an overgrown tree bush partially covered it making the sign difficult to see clearly. TNPI representatives assured that the bush would be trimmed down shortly.


Access, control of access, and evacuation

CER inspectors acknowledged that the TNPI Toronto Airport Terminal is accessible to personnel all year-round. Given the terminal’s proximity to urban development as well as industrial and commercial businesses, the roads that give access to the site are well maintained and snow plowed during the winter months.

The site is fenced and prevents unauthorized entry by way of pad locks installed on each gate. The site contains a total of three (3) gates. In the event that the fire department needs access to the site, they have been instructed to cut the gates. TNPI representatives informed CER inspectors that panic gates will be installed on all three (3) gates by 2023. In the meantime, all gates are unlocked as soon as someone is present at the Terminal.

The Terminal is unmanned but TNPI stated that a maintenance crew visits the terminal every week to perform a site inspection, drain water, and check general condition of the valves and integrity of the piping.


Piping and Valves

Pressure relieve valves are located upstream and downstream of the terminal pressure control valve to protect the station piping and pressure vessels. Valves on the pressure relief lines were locked in the open position to ensure an open flow path to the two relief tanks located on site. The relief tanks are located in the same secondary containment as the two storage tanks. TNPI explained that the 75 horsepower (HP) centrifugal pump unit discharge is not equipped with pressure relief devices as the pump is not capable of over pressurizing the piping.

There is a meter that is used for measurement and is part of the leak detection system. There is also a proving loop to validate the meter.

The station has several pressure vessels (coarse filters, clay filters, and oil/water separators) and TNPI explained that they are inspected against the requirements of American Petroleum Institute Pressure Vessel Inspection Code (API 510) by API 510 certified inspectors. TNPI representatives informed CER inspectors that all pressure vessels are due for an inspection.

The above ground station piping and vessels were coated with paint. Some signs of external corrosions were apparent and TNPI explained that as part of their re-coating program they have identified that some piping and vessels will need to be re-coated this year.

TNPI explained that three (3) integrity digs were conducted on the station’s below ground piping that is not piggable. The digs were completed in February 2021 after the completion of a Direct Current Voltage Gradient (DCVG) survey. During the integrity digs, visual inspections, ultrasonic testing (UT), and magnetic particle inspection were conducted on the piping. According to TNPI, no issues were discovered during these digs. TNPI representatives stated that the next focus will be on the integrity of the piping at the surface to air interface. Inspections at these locations will be done using the guided wave ultrasonic method.


Station Isolation

ESD push buttons are located at the station building, adjacent to the main gate, and at the two (2) additional terminal gates. TNPI explained that activation of the ESD will shut down and isolate the station.  


Storage Tanks Fire Protection System

The storage tanks were constructed in 1971 and they have a diameter of 27.43m. The tanks have steel cone roofs and aluminum internal floating roofs (IFR). The IFRs are equipped with foam dams. Each tank has a flame detector and a thermal detector for fire detection. The tanks are equipped with a fixed rim seal fire protection system that will automatically foam a tank if the two (2) fire detectors are triggered.  The automatic fire protection system can be switched to manual for local operation of the system.

TNPI explained that there is enough foam onsite for one tank rim seal fire (i.e. the Terminal is equipped with a 625 liter (165 US gallon) foam tank). TNPI also explained that the foam and fire protection systems are tested annually as per National Fire Protection Association’s Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems (NFPA 25). The last annual inspection was conducted by Johnson Controls  - Tyco Integrated Fire & Security and was conducted on 17 November 2021. The inspection reports noted that the fire detection system on Tank #2 could not be tested because the stairs were under safety review. TNPI indicated that the stairs have now been repaired and that TNPI has a plan to complete the testing of the fire detection devices on Tank #2 this year.

TNPI informed CER inspectors that they are currently facing a health and safety issue related to fall protection on the tank roofs. The foam makers and injectors all around the tanks’ roofs are difficult to reach during inspections. TNPI is addressing this right now to find an alternative such as a man basket.

CER inspectors went to look at Tank #1’s cone roof. The roof was in apparent good condition.

Due to new ECCC regulations restricting certain toxic substances, such as per- and perfluoroalkyl substances (PFASs), there will be complete change out of the fire-fighting foam at site.  TNPI is working with other companies and municipalities to try and align product type for compatibility purposes.  TNPI is planning meetings with suppliers to discuss options to transition away from aqueous film-forming foam which contain certain PFASs.

Secondary Containment Area

CER inspectors walked in the secondary containment around the tanks.

TNPI informed CER inspectors that the shared containment volume is well over the minimum required by code (110% of the largest tank plus (+) 10 % of the other tanks) since the secondary containment was originally built for four storage tanks. The secondary containment was clear of debris, water and vegetation. Bentonite clay installed underneath the gravel provides an impermeable barrier to the secondary containment area.

CER inspectors observed one of the three (3) fire hose cabinets located at different places around the Terminal. It was in apparent good condition.

CER inspectors notes that sensors were covered with plywood to prevent it from sunlight. TNPI explained that the sunlight affects the sensors’ sensitivity and the plywood was placed on top of the sensors to protect it from the sun.

CER inspectors asked TNPI if there are any concerns with strain on the piping that is located on supports. TNPI explained that there is a 3D plan of the facility that was created by TD Williamson by laser scanning the facility. This plan can be sent to an engineering consultant to analyse stresses and to determine the need for re-scans.

The water that accumulates in the containment area is drained out weekly. None of the valves used to remove water are remotely operated, they are manual and locked with a key. Drainage of liquids is checked regularly, if there is any accumulation of liquids they are pumped out and sent to the city sewage. There is an oil water separator (OWS) connected to the drainage pipe. CER inspectors asked TNPI who takes care of the drain, TNPI answered that the maintenance crew that comes to the terminal on a weekly basis can open the drain to let water out or a TNPI skilled trades person can also do it. TNPI confirmed that the drain pipe going through the tank secondary containment wall and the first valve that is kept normally closed are made of cast iron and are non-combustible, which satisfies the requirement of the fire code.


Overfill Protection

The tanks are equipped with level monitoring and a high level switch to prevent overflow. An alarm to the control room would be triggered at a high level. At a high-high level, the station is shut down and isolated. The high level switch physically installed inside the tank also triggers a station shutdown and isolation when activated.


Tank Shell and Base

TNPI explained that the external side of the tank bottoms is protected by cathodic protection (CP). There is no leak detection system installed under the tank; leak detection is done by volume monitoring. CER inspectors noted that some CP wires were sticking out of the ground next to one of the tanks. TNPI representatives assured that someone would cover them with gravel shortly.


The tank shell was in apparent good condition. Some gravel was noted to cover the chimes of the two tanks. TNPI explained that this was already identified as a potential hazard and TNPI indicated that the gravel will be removed from the chimes. CER inspectors performed a spot check by removing a bit of gravel at one location on the chime and the chime did not show any signs of external corrosion.
 

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

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 2 - NNC No.1

Date & time of visit: 2022-05-19 12:00

Discipline: Integrity Management

Categories:

Facility: TORONTO AIRPORT TERMINAL - Facility

Observations:

The storage tanks fire protection system is powered by electricity. TNPI explained that they don’t have an alternate source of power capable of operating the fire protection system in the event of a power loss. This is a non-compliance to the OPR section 12 (c) and as a result a Notice of Non-Compliance (NNC) is issued to address this non-compliance.

Update: On 30 June 2022, TNPI submitted the response to IR No.1.1 through which it was confirmed that the facility does not have a back up emergency power generator and that the Uninterruptible Power System (UPS) is not adequate to operate the manually operated valves (MOVs) during a power loss. TNPI is therefore also non-compliant to the OPR section 12(a). 

TNPI also submitted on 30 June 2022 a corrective action plan (CAP) to address this NNC. The CAP will address the non-compliances to the OPR section 12 (a) and (c) identified. However, CER inspectors have further questions regarding the timeline to complete the CAP.
 

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

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

On 29 March 2023, TNPI provided the following update:

TNPI will install an emergency generator sized for the existing facility on or before the end of Q3 2023. This emergency generator will supply power to operate motor control valves for facility isolation/shutdown and the existing fire protection system. The reason for the faster turnaround is that TNPI has determined that the generator installed will be reevaluated once the new foam system design has been confirmed.

 

Due date: 2023-09-30

Observation 3 - NNC No.2 - Storage Tank Fire Protection System.

Date & time of visit: 2022-09-16 12:00

Discipline: Emergency Management

Categories:

Facility: TORONTO AIRPORT TERMINAL - Facility

Observations:

CER staff reviewed the information provided in response to IR 1.3 and virtually met with TNPI on 9 September 2022 to obtain clarifications on the information provided and to explain CER staff views on this matter. TNPI’s responses and supporting documentation provided did not demonstrate that it has an adequate fire protection system for the storage tanks at the Toronto Airport terminal.

Although the design of the internal floating roof and fire protection system may have met the standards applicable at the time of construction, such combination of roof and fire protection system is no longer considered adequate for fire protection according to NFPA 11.  CER staff notes that NFPA 11 is not a mandatory standard, but it is the industry reference and it is considered a good engineering practice by the National Fire Code of Canada. 

In the event of a tank fire, TNPI indicated that the following would occur:
"TNPI will activate its emergency response plan and identify an Incident Commander. The TNPI Incident Commander will liaise with the appropriate personnel of the responding fire service and coordinate required Subject Matter Expertise (Firemaster Oilfield Services Inc.) and activate additional suppression resources; coordinated through service level agreements or directly with regional response contractors in the event that the incident has the potential to surpasses the capacity of the facility suppression system. Per agreements described in the Trans-Northern Pipelines Emergency Response Plan with QM Environment TNPI will request industrial fire- fighting capacities from Accuworx (Mississauga, ON) to support the facility and municipal response."

The Toronto Airport Site Specific Emergency Response Plan (SSERP) includes a reference to QM Environment and Accuworx as stated above, but it does not provide any details on the capacity of those responders to address a tank fire. The pre-fire plan in Appendix C of the SSERP lists the resources available from the Tank Fire Specialist (Firemaster Oilfield Services Inc.) but no information is listed for the resources of QM Environment and Accuworx. TNPI has not provided a clear demonstration that a response involving the local fire service and external contractors, including regional response contractors such a QM Environment and Accuworx, would allow TNPI to extinguish a tank fire in a timely manner should the existing fixed fire protection system failed to extinguish a storage tank fire. Therefore, TNPI did not demonstrate that its emergency management program can adequately manage and mitigate conditions during a potential tank fire at the Toronto Airport terminal. 

Based on this information, and considering the risk associated with a potential tank fire at the Toronto Airport terminal due to its proximity to major highways and the Toronto Airport, CER staff has determined that TNPI is non-compliant to the OPR section 32 and a corrective action plan will be required.  

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

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

On 29 March 2023, TNPI provided the following update:


TNPI is working with a leading designer and constructor of tanks and storage facilities, to evaluate alternatives to address the fire protection systems for the storage tanks at the TA terminal.

The scoping study is being finalized to determine the lead case to address the NNC, after which TNPI will progress into FEED and detailed engineering. The study has taken additional time to complete to assess design and execution complexities associated with existing and new environmental and permitting regulations for each alternative being considered.

Over the next three months, TNPI expects to finalize the scoping study and preliminary execution documents and commence detailed engineering. Another update can be provided by June 30, 2023.
 

Due date: 2023-06-30