Compliance Verification Activity Report: CV1920-450 - Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-450
Start date: 2019-09-17
End date: 2019-09-18

Team:

Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Operating company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Integrity oversight of operation activities McMahon Gas Plant and, if feasible, the Dawson Creek Gas Plant. Inspection conducted in tandem with Safety (CV1920-323)

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Westcoast Facilities Integrity Management Program

Date & time of visit: 2019-09-17 10:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

McMahon Plant
The purpose of the inspection was to review the company's Pressure Equipment Integrity Management Program. Items of interest were boilers, pressure vessels and relief valves.

For introduction, the McMahon Plant consists of 6 processing trains with a design capacity of processing 780 mmscf/d raw gas. Currently, all 6 trains are operational, and typical H2S in raw gas is around 1 %. Plant load, at the time of inspection, was approx. 600 mmscf/d (one processing train was down for maintenance).

Liquids are separated at the Plant inlet, and trucked or railed out.

The acid gas removal system is based on MDEA solvent for each train. The separated acid gas is processed in 3 Sulphur trains which have a combined design capacity of 550 MET. Currently, the B Sulphur Train is deactivated.

The complex has a power generation capacity of 100 MW through cogen units consisting of 3 generators with associated gas/steam turbines. Steam (superheated 450 psi)  from the power generation units is supplied to the McMahon Processing Trains. The boilers in the power units come under the provincial jurisdiction.

The process piping of the plants have changed jurisdiction, from Technical Safety British Columbia (TSBC) to British Columbia Oil & Gas Commission (BCOGC). The boilers, pressure vessels and relief valves remain under the TSBC's jurisdiction.

Following are the salient items of the Facility Integrity Management Program:

During the field inspection a number of pressure vessels and piping components were inspected at random, both at the Processing Trains and the Sulphur Trains. No issues noted. The pressure vessels’ tags were legible, and bore the Canadian Registration Numbers (CRNs) authorizing the pressure vessels’ operation in the province of British Columbia. No signs of stress/movement at supports was noted. The TMLs on the pressure vessels and the pressure piping were clearly marked. No obvious signs of Sulphur spills/leaks were noted at the Sulphur Trains.

It was noted that on the new Amine Still # 3 (SS construction), the TMLs were not marked. CER was given assurance that the TMLs will be identified/marked, and the VISIONS database updated, well before the first inspections (after the installation inspection) becomes due.

Compliance tool used: No compliance tool used

Observation 2 - Integrity Management Program at Dawson Creek Plant

Date & time of visit: 2019-09-18 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Dawson Creek Gas Plant consists of two processing trains. The plant has a design capacity of processing 250 mmscfd raw gas. Separated liquids are trucked out. Acid gas removed is sent to the McMahon Plant for Sulphur extraction through the 16” Willowbrook Pipeline.
 
CER was informed that the integrity management of pressure equipment at the Dawson Creek Plant follows the same program as that of the McMahon Plant, and the VISIONS database is populated with Dawson’s specific equipment. Company submitted that the following activities resulted from the Pressure Equipment Integrity Program in the scheduled outage this year:

Staff understands that the NCRs will be handled per the MOC procedure described above.
 
At the time of inspection, plant load was 214 mmscfd with 978 ppm H2S in the inlet raw gas. Raw gas at battery limit was at 825 psig and 58 deg F conditions.

Field visit consisted of visiting various metering buildings, Train # 1 pump and compressor buildings, glycol and hot oil buildings, and Sales Gas Compressor building.

The buildings were equipped with H2S and lower explosive limit (LEL) detectors with adequate redundancy. They are connected to the field annunciation system, as well as to the DCS in the control room. Staff was given to understand that these detectors are on a quarterly planned maintenance (PM) schedule.

No abnormal vibrations were noted in the piping around the reciprocating pump. Staff was informed that the issue identified last time (in 2015) was adequately resolved by correcting the N2 pressure in the pulsation dampers’ bladders.

Pressure vessels and piping were checked at random and no issues were noted. TMLs were clearly identifiable.

Fire resistant coating on the various support structures appeared in good condition.

Vibration in the thermal expansion joint in the exhaust line of the Sales Gas Compressor turbine appeared minimal. Staff was informed that the earlier problem of failure of these expansion joints was resolved by installing new expansion joints with different design.

Small grass strands were noted at various locations at processing areas. Staff was apprised that the company will review its vegetation control program.

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