Compliance Verification Activity Report: CV1920-306 - Pembina Energy Services Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-306
Start date: 2019-09-10
End date: 2019-09-10

Team:

Regulated company: Pembina Energy Services Inc.

Operating company: Pembina Energy Services Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Field inspection of Taylor station on the Taylor to Boundary Lake pipeline (Ref 146). This inspection was completed at the same time as CV1920-139.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Taylor Liquids Gathering System (LGS) Pump Station

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

Discipline: Integrity Management

Categories:

Facility:

Observations:

The Taylor Liquids Gathering System (LGS) pump station is part of the Taylor to Boundary Lake Pipeline system, and carries natural gas liquids to Boundary Lake. The pipeline is 60 km in length with nominal pipe size (NPS) 8. The pump station is fed by the Stoddart Gas Plant (4”) and the AltaGas line – from the Younger Gas Plant (6”).

The Maximum Operating Pressure (MOP) for the line is 8275 kPa.  The station houses three centrifugal pumps. The pressure is controlled by varying the pump speed and over-pressure protection is assured by high pressure alarms, pump shutdowns, thermal relief valves (TRV) and Pressure Safety Valves (PSV). The high pressure shutdown is triggered at a pressure lower than 110% of MOP. The PSVs and TRVs relieve to an aboveground knock-out drum and flare stack. Subsequent to the inspection CER inspectors noted that PSV 619 in DWG A7005.01-2B-00008 Rev. 6 is documented as having a set point of 14000 kPa, higher than the licensed MOP of 8275 kPa in Order OPLO-N62-71-98. CER inspectors requested further information on this PSV's set point. (See Information Request (IR) below)

The inspection / testing frequencies for the pressure control systems, pressure limiting systems, except for the TRVs and PSVs, were set to be tested at an annual frequency (at minimum). This is in compliance with CSA Z662-19 Clause 10.9.5.2, which requires the inspection, assessment and testing of these systems to be conducted at least once per calendar year, with a maximum interval of 18 months. The TRVs and the PSVs were set to be maintained every 10 years and 5 years respectively. The company stated that the servicing frequency for TRVs and PSVs are generally consistent throughout all the CER regulated stations on the Taylor to Boundary Lake Pipeline system and Pouce Coupé Northern pipeline system. (See CV1920-139: IR - Taylor (Northern) Pump Station - TRV and PSV Maintenance Schedule Observation for further details. CV1920-139 - Taylor (Northern) Pump Station inspection was conducted immediately after the Taylor (LGS) Pump Station inspection.) 

The pumps are housed in a pump building. The pump building was installed with gas monitoring. A warning alarm and ventilation is initiated at 20% of the lower explosive limit (LEL), and at 40% LEL, a station Emergency Shutdown (ESD) is triggered. The pump building is equipped with a fire detection system that triggers a station shut down when a fire is detected and stops the ventilation. The building is equipped with a beacon that will light when the station is in an alarm state (Fire, Gas Detection). The company stated that the fire and gas detection systems are checked every 3 months. The building was also equipped with louvers to assist with ventilation.

It was observed that flammable liquids (e.g. pump oil, lubricants) were stored in a pail inside the pump building in quantities greater than needed for daily use. This is a non-compliance to CSA Z662-19 Clause 10.9.1.5. The non-compliance was corrected prior to the completion of the inspection by removing the liquids from inside the pump building. (See Corrected Non-compliance - Taylor (LGS) Pump Station - Flammable Liquids Stored in Pump Building)

The pumps are equipped with seal leak, vibration and temperature monitoring, and unit shut down devices. The pump seal pots are equipped with level monitoring and high pressure trips that relieve to the knock out drum and flare stack. Each pump unit was equipped with a switch to allow for local pump shut down.

The station’s instrumentation (e.g. temperature and pressure sensors and transmitters) are checked annually at minimum.

The valves in the station had open/close position marking on them, and it was confirmed that they are visually inspected for leaks weekly. A valve maintenance program is in place to inspect the mechanics of the valves on an annual basis.

The pump station has several station ESD push buttons which are located outside the pump and electrical buildings. The ESD functionality is tested at an annual frequency.

The station’s above ground piping paint coating was in good condition. The coating on the soil to air interface was observed to be in good condition.  The piping was supported with insulation pads where needed between the pipe support and piping. The piping had labeling for direction of flow and product identification. As some of the piping in the station was below ground, cathodic protection (CP) was maintained on the entire system. The company stated that CP surveys are conducted on an annual basis. Piping corrosion assessments including ultrasonic testing (UT) thickness checks on facility piping were conducted periodically. Leak detection on the pipeline is through mass balance and leak detection. The pipeline system is monitored and controlled through the Sherwood Park Control Centre.

The station is equipped with a pig launcher site. The company stated that the O-ring gaskets are changed whenever necessary, or annually.

The knock-out drum was stainless steel and constructed in 1997. It was previously insulated but the insulation was taken off to help with the flashing off of the lighter components. The company stated that the unit was on a 10 year inspection cycle.

The required name plates were observed on the equipment.

Communication at site is through SCADA and radio. If communication is lost, the local programmable logic controller (PLC) recognizes the loss of communication and is programed to initiate a soft station shut down. If power is lost, the uninterruptible power supply (UPS) will power the PLC and provide SCADA the functionality to initiate a soft shut down of the station. Emergency lighting at the station is powered through individual battery packs.

The station is fenced and has emergency exit gates with panic bars for easy exit. The entrance of the station has signage with the company name, emergency phone number, warning signs about the presence of ethane and smoking. Wind socks were installed.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The Leave to Open Order OPLO-N62-71-98 lists an MOP of 8275 for Segment A of the pipeline.  It was observed that PSV 619 in DWG A7005.01-2B-00008 Rev. 6 is documented as having a set point of 14000 kPa.

  1. Provide an explanation on how the setting of PSV 619 meets the requirements of CSA Z662-19 Clause 4.18.1.2 and 10.9.5.5.
  2. If applicable, provide a corrective action plan and timeline for implemention for correcting the set point for PSV 619.  Also provide details on any temporary mitigation measure(s) required in the interim.

Due date: 2019-10-11

Date closed: 2019-10-08
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 2 - Corrected Non-compliance - Taylor (LGS) Pump Station - Flammable Liquids Stored in Pump Building

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

Discipline: Safety Management

Categories:

Facility:

Observations:

It was observed that flammable liquids (e.g. pump oil, lubricants) were stored in a pail inside the pump building in quantities greater than needed for daily use. This is a non-compliance to CSA Z662-19 Clause 10.9.1.5. The non-compliance was corrected prior to the completion of the inspection by removing the liquids from inside the pump building. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Pembina corrected this non-compliance by removing the items prior to the completion of the CER inspection.

Due date: 2019-09-10

Date closed: 2019-09-19
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

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