Compliance Verification Activity Report: CV2122-327 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-327
Start date: 2021-10-20
End date: 2021-10-20

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company:

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of NGTL’s Berland River compressor station.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Information Request

IR from CER (Information Request sent from CER to company)
IR 2.1 - Ongoing Leaks (Follow up for IR No. 2)

Legislative Requirement : CSA Z662-19 - Oil and Gas Pipeline Systems

Applicable Wording from Legislative Document
10.3.4.1 Operating companies shall perform regular surveys or analyses for evidence of leaks.

Theme and Categories

Integrity Management
  • Facilities
    • Valves
    • Piping
  • Integrity Management Program
    • Hazard Identification
    • Implementation
  • Documentation
    • Record Retention

Due Date : 2022-04-25

Review Response
Acceptable

Follow-up Action
None

Observations (no outstanding follow-up required)

Observation 1 - Berland River Compressor Station

Date & time of visit: 2021-10-20 11:15

Discipline: Integrity Management

Categories:

Facility:

Observations:

Integrity Management – Local Control Centre (Building)
 
The discussions between CER inspectors and NGTL representatives and CER inspectors’ observations are summarized as follows:

Integrity Management – Compressor Unit Buildings and Yard Piping
 
The discussions between CER inspectors and NGTL representatives and CER inspectors’ observations are summarized as follows:

Compliance tool used: No compliance tool used

Observation 2 - IR No 1 – Valve Maintenance Records

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors requested certain information that was not readily available during the inspection. They agreed with NGTL representatives that NGTL provide this information later.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information:

The maintenance records for the last 24 months for the following valves (including inspections, assessments, tests, and repairs):

  1. B2-FBV-0051;
  2. B2-FBV-0050;
  3. GPM30-0-BV;
  4. PM30-C-1SS-BLR; and
  5. For the valve B2-FBV-0050, provide the inspection report which was done on 10 September 2021 for a leak (see reference 25525134). Specify the completed and planned corrective actions (if any).

Due date: 2021-11-22

Date closed: 2021-12-22
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 No 1.1 – Valve Maintenance Scope and Frequency (Follow up for IR No 1)

Discipline: Integrity Management

Categories:

Facility:

Observations:

IR to be issued regarding follow up to IR No 1 – Valve Maintenance Records.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

In response to IR No 1 – Valve Maintenance Records, NGTL submitted an attachment titled CV2122-327 ATTACHMENT 11 Valve Maintenance Records. This attachment disclosed two maintenance plans known as 102246 VLV&Op Insp and Servicing and 102247 VLV&Op Leak Insp/Cycle Test EMER VLV.
 
Request:

  1. Does maintenance plan 102246 VLV&Op Insp and Servicing include partial operation of the valve?
  2. What are the frequencies of maintenance plans 102246 VLV&Op Insp and Servicing and 102247 VLV&Op Leak Insp/Cycle Test EMER VLV?
  3. Confirm that execution of maintenance plans 102246 VLV&Op Insp and Servicing and 102247 VLV&Op Leak Insp/Cycle Test EMER VLV meets the requirements of CSA Z662-19 10.9.6.2. If not, explain how compliance to CSA Z662-19 10.9.6.2 is achieved.

Due date: 2022-04-25

Date closed: 2022-06-06
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 No 2 – Station Leak Detection Survey

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors requested certain information that was not readily available during the inspection. They agreed with NGTL representatives that NGTL provide this information later.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information: 

  1. The station’s leak detection inspection results for the last two leak detection surveys (i.e., those conducted every three months).
  2. Provide the list and summary of corrective actions, including repair for leaks, that resulted from these surveys (if any).

Due date: 2021-11-22

Date closed: 2022-04-08
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 5 - IR No 3 – Station Cathodic Protection Survey

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors requested certain information that was readily available during the inspection. They agreed with NGTL representatives that NGTL provide this information later.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the summary of the station CP system survey result, including but not limited to, the survey date, the minimum potential value recorded for the station, and corrective actions completed or planned (if any).

Due date: 2021-11-22

Date closed: 2021-12-22
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 6 - IR No 4 – Maintenance Interval for PSVs

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors requested certain information that was readily available during the inspection. They agreed with NGTL representatives that NGTL provide this information later.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information:

  1. All preventive maintenance (inspection) schedules for the station’s PSVs. Explain what each inspection activity includes (i.e., the related maintenance plans).
  2. If the 5 years maintenance timeline (as described during the inspection) is confirmed to be the only preventive maintenance interval for the PSVs, demonstrate how that would meet the requirements of the standard CSA-Z662, Clause 10.9.5.

Due date: 2021-11-22

Date closed: 2021-12-22
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 7 - IR No 5 – Set Point for PSVs

Discipline: Integrity Management

Categories:

Facility:

Observations:

During the inspection, CER inspectors observed apparent inconsistencies in some PSV maintenance reports such as for PSV tags # 0-PSV-0009 and B2-PSV-0061. The set pressures (for “Condition Received” and/or “Final Test”), as showed on the Final Inspection Test Reports appears to be higher than 110% of MOP.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information:

  1. A detailed explanation that demonstrates how these set pressures comply with the requirement of the standard CSA-Z662, Clause 4.18.1.2. 
  2. If the compliance with CSA-Z662 cannot be demonstrated as requested in a) above:
    1. Explain the extent of this issue for similar PSVs through the Berland River station. Confirm if PSVs may have similar issues at other NGTL Stations.
    2. Specify if the issue also happened during the previous testing/setting of PSV tags # 0-PSV-0009 and B2-PSV-0061 (i.e., prior to 2017).
    3. Provide the root cause for the issue and propose a corrective action plan (CAP).

Due date: 2021-12-10

Date closed: 2022-04-08
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 8 - IR No 6 – Fuel Gas Supply for Turbines

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors requested certain information that was readily available during the inspection. They agreed with NGTL representatives that NGTL provide this information later.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Explain why the gas supplying the turbines’ fuel gas system was not odorized. If the decision is based on the gas lower explosive limit (LEL) consideration, specify the applicable LEL and the alarm set point (gas concentration) for the electronic gas detectors.     

Due date: 2021-11-22

Date closed: 2021-12-22
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 9 - IR No 7 – Removal of Paint and Cladding

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors observed that the paint is removed from a location on the Unit B discharge check valve. Also, the insulation cladding of the Unit A cooler discharge piping is damaged at the above-ground/below-ground transition area.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information:
 

  1. Explain if NGTL has conducted (or it will conduct) an assessment to determine the extent and potential impact of the removed paint on the Unit B discharge check valve (e.g., to confirm that there is no significant corrosion or other defect). If yes, provide a summary of the assessment result.If no, provide the rationale for not assessing. 
  2. Explain if NGTL has conducted (or it will conduct) an assessment to determine the extent and potential impact of the damaged isolation cladding on the Unit A cooler discharge piping (e.g., to confirm that there is no significant corrosion or other defect)? If yes, provide a summary of the assessment result. If no, provide the rationale for not assessing.  

Due date: 2021-11-22

Date closed: 2021-12-22
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 10 - IR No 8 – Operation of Unit’s Ventilation System

Discipline: Integrity Management

Categories:

Facility:

Observations:

NGTL representatives explained that the compressor unit buildings are equipped with lower explosive limit (LEL) detections and fire eyes. Additional information is required.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide a detailed explanation of how the LEL detectors and fire eyes work with the compressor unit’s ventilation systems. Specify when the ventilation system start working or stop working based on LEL levels and/or fire detection.

Due date: 2021-11-22

Date closed: 2021-12-22
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 11 - NNC No 1 - Open and Closed Positions and the Function of Major Valves

Date & time of visit: 2021-11-03 13:20

Discipline: Integrity Management

Categories:

Facility:

Observations:

The open and closed positions and the function of several major valves within the station (e.g., Unit A discharge valve, valve GPM30-1-BV, valve GPM30-C-1SS-BLR, Unit B cooler isolation valve) were not clearly marked. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

NGTL is required to:

  1. Identify and provide the list of all mainline sectionalizing valves within the Berland River station where the open and closed positions are not clearly marked (if any).
  2. Clearly mark the open and closed positions of all the valves in 1) above to meet the requirement of OPR Section 36 (d). 
  3. Identify and provide the list of all isolating valves, blow-down valves, and other major valves within the Berland River station where the open and closed positions are not clearly marked.
  4. Clearly mark the open and closed positions and function of all the valves in 3) above to meet the requirement of OPR Section 36 (e).

Due date: 2022-05-27

Date closed: 2022-07-20
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 12 - NNC No 2 - Direction of Flow and/or Contents of Piping

Date & time of visit: 2021-11-03 13:20

Discipline: Integrity Management

Categories:

Facility:

Observations:

Many piping segments throughout the station (e.g., piping for the scrubber, areal cooler, Unit A) did not have a marked flow direction and/or contents.

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

Regulatory requirement:

Relevant section(s):

Company action required:

NGTL is required to:

  1. Identify and provide the list of all aboveground piping, within the Berland River station, that are not clearly identified to indicate its function. 
  2. Clearly identify the function of all the piping in 1) above to meet the requirement of the standard CSA-Z662, Clause 4.14.2.11 (b). 

 

Due date: 2022-04-25

Date closed: 2022-06-30
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 13 - NNC No 3 - Follow up for IR No 5 – Set Point for PSVs

Date & time of visit: 2022-04-08 10:50

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors reviewed the information provided on 10 December 2021 by NGTL and during the follow-up meeting with NGTL and its contracting company (Access Valve) on 2 March 2022. NGTL confirmed that for the Berland River Compressor Station instance, where the Maximum Operating Pressure (MOP) is 8275 kPa, the maximum set pressure for PSVs (equivalent to 110% of MOP) should be 9102 kPa as per CSA Z662 Clause 4.18.1.2. TC Energy has been using an accuracy/tolerance of +/-3% for its PSVs in accordance with the ASME Boiler and Pressure Vessel Code Section VIII Division 1 - UG-155(d). Therefore, the company had been considering up to 9375 kPa (i.e., 9102 + 3% of 9102) as a maximum set pressure. TC Energy representatives recognized that allowing +3% on top of 110% of MOP permits certain PSVs to release at a pressure too high that would not meet the requirement of CSA Z662 Clause 10.9.5.5.

TC Energy representatives stated that the company has started to implement a corrective action plan which involves the following:
 

  1. The consideration of +0%/-3% for PSV accuracy, instead of +/-3%. As a result, the maximum set pressure for PSVs at the Berland River C/S will be 9102 kPa (i.e., 110% of MOP).
  2. Updating TC Energy’s relevant procedures.
  3. Identification and correction of all PSVs that currently have their set pressure higher than 110% of MOP at the Berland River C/S and across TC Energy gas pipeline system.

NGTL committed to present to the CER the findings of the investigation and the corrective action plan upon completion, which was expected by 1 April 2022.
 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following:

  1. A copy of the corrective action plan;
  2. A summary result of the investigation including, but not limited to, the extent of the issue across the NGTL pipeline system (e.g., a table showing affected facilities, their number of affected PSVs, confirmation that affected PSVs have been mitigated or expected mitigation dates); and
  3. Confirmation that TC Energy’s procedures have been updated and adequately implemented in TC Energy’s operations. If confirmation cannot be provided, explain why.

Due date: 2022-04-25

Date closed: 2022-07-11
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