Compliance Verification Activity Report 1516-221 – Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Type of Compliance Verification Activity: Field Inspection

Activity #: 1516-221
Activity start: 2016-03-03
Activity End: 2016-03-03

Related Activity Numbers:

Inspection Officer Number(s): 1950, 2666T

Incident #: INC 2013-110, INC 2015-110
Landowner Complaint File #:

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

Facility Name(s): Fort Nelson Gas Processing Plant

Province(s): British Columbia

Theme(s): Integrity Management

Compliance Tools Used: Information Request (3)
Notice of Non-Compliance (NNC) (1)

Purpose

This activity was undertaken to verify compliance with the following regulatory requirements.

 X  NEB Act

    Onshore Pipeline Regulations

    CSA Standard Z662 Oil and Gas Pipeline Systems

    Other:

    Electricity Regulations

 X  Processing Plant Regulations

    Pipeline Crossing Regulations Part I

    Pipeline Crossing Regulations Part II

Observations & Discussion

Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-03 Fort Nelson Gas Plant Integrity Management No
Observations

Frost heave was identified on concrete footing supporting the overhead six inch flare line. Westcoast stated that repairs are to be completed by Q3 2016 per results of completed structural integrity analysis. Westcoast stated that a pipe stress analysis of overhead flare line has been completed.

Westcoast stated that Train E&F MDA storage tank piping has taken out of service and is currently undergoing repair as part of Train E&F turnaround activity. Deflection/bending on the pipe was identified during 2015 NEB facility inspection.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-03 Fort Nelson Gas Plant Integrity Management No
Observations

Westcoast stated that a preventative maintenance (PM) program in place for critical isolation valves but there is currently no PM program for gate valves. Westcoast stated that a greasing program is being adopted for gate valves and is to be implemented by end of Q1 2016.

Prior personal safety incident due to inadequately maintained steam service gate valve and process safety incident due to sour gas release from leaking isolation plug valve.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-03 Fort Nelson Gas Plant Integrity Management No
Observations
There is no integrity management program for buried piping at the facility; Westcoast stated that it is developing such a program for completion at an anticipated future date.
Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-03 Fort Nelson Gas Plant Integrity Management No
Observations

The flare pit area was inspected as a follow up on previous incident INC 2015-110 reported on 2015-09-16 which was identified as a gas release due to corrosion (Internal and External) and loss of wall thickness on 10 inch Sahtaneh flare line. Westcoast stated that integrity digs and inspections to assess condition of buried flare line piping were performed as part of its incident investigation.

Westcoast stated that Cathodic Protection (CP) is maintained on buried portion of flare piping and annual CP surevys are conducted.

Does this observation specifically reference the Canada Labour Code or its regulations? No

Compliance Summary

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Integrity Management Information Request 30/09/2016
Date/Time visited Location
2016-03-03 (Time Unspecified) Fort Nelson Gas Plant
Observations

Frost heave was identified on concrete footing supporting the overhead six inch flare line. Westcoast stated that repairs are to be completed by Q3 2016 per results of completed structural integrity analysis. Westcoast stated that a pipe stress analysis of overhead flare line has been completed.

Westcoast stated that Train E&F MDA storage tank piping has taken out of service and is currently undergoing repair as part of Train E&F turnaround activity. Deflection/bending on the pipe was identified during 2015 NEB facility inspection.

Regulatory Requirements
National Energy Board Processing Plant Regulations section 41:
A company shall develop and implement a processing plant integrity program that sets out management systems, records systems and methodologies for monitoring the processes and components and for mitigating identifiable hazards at the plant.
Corrective Action or Request Required
Westcoast shall provide confirmation of completed repairs conducted on the concrete footing supporting the overhead six inch flare line.
Does this observation specifically reference the Canada Labour Code or its regulations? No
Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Integrity Management Information Request 31/03/2016
Date/Time visited Location
2016-03-03 (Time Unspecified) Fort Nelson Gas Plant
Observations

Westcoast stated that a preventative maintenance (PM) program in place for critical isolation valves but there is currently no PM program for gate valves. Westcoast stated that a greasing program is being adopted for gate valves and is to be implemented by end of Q1 2016.

Prior personal safety incident due to inadequately maintained steam service gate valve and process safety incident due to sour gas release from leaking isolation plug valve.

Regulatory Requirements
National Energy Board Processing Plant Regulations section 41:
A company shall develop and implement a processing plant integrity program that sets out management systems, records systems and methodologies for monitoring the processes and components and for mitigating identifiable hazards at the plant.
Corrective Action or Request Required
Westcoast shall provide the most recent inspection/maintenance report for leaking inlet separator isolation plug valve identified per INC 2015-098
Westcoast shall provide the frequency, scope of preventative maintenance performed on critical valves identified in site Preventative Maintenance (PM) program and rationale behind valve inspection intervals.
Westcoast shall provide a copy of the greasing program to be adopted for maintenance of gate valves.
Does this observation specifically reference the Canada Labour Code or its regulations? No
Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Integrity Management Notice of Non-Compliance (NNC) 31/05/2016
Date/Time visited Location
2016-03-03 (Time Unspecified) Fort Nelson Gas Plant
Observations
There is no integrity management program for buried piping at the facility; Westcoast stated that it is developing such a program for completion at an anticipated future date.
Regulatory Requirements
National Energy Board Processing Plant Regulations section 41:
A company shall develop and implement a processing plant integrity program that sets out management systems, records systems and methodologies for monitoring the processes and components and for mitigating identifiable hazards at the plant.
Corrective Action or Request Required
Westcoast shall develop a Corrective Action Plan (CAP) for implementing a program to monitor and assess integrity threats to high and medium risk buried piping until such a date that the Pressure Equipment Integrity Management Program has been updated to include an assessment and inspection program for buried piping.
Does this observation specifically reference the Canada Labour Code or its regulations? No
Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Integrity Management Information Request 31/03/2016
Date/Time visited Location
2016-03-03 (Time Unspecified) Fort Nelson Gas Plant
Observations

The flare pit area was inspected as a follow up on previous incident INC 2015-110 reported on 2015-09-16 which was identified as a gas release due to corrosion (Internal and External) and loss of wall thickness on 10 inch Sahtaneh flare line. Westcoast stated that integrity digs and inspections to assess condition of buried flare line piping were performed as part of its incident investigation.

Westcoast stated that Cathodic Protection (CP) is maintained on buried portion of flare piping and annual CP surevys are conducted.

Regulatory Requirements
National Energy Board Processing Plant Regulations section 41:
A company shall develop and implement a processing plant integrity program that sets out management systems, records systems and methodologies for monitoring the processes and components and for mitigating identifiable hazards at the plant.
Corrective Action or Request Required
Westcoast shall submit a summary report of integrity digs/assessments performed on the buried flare line piping and other buried process piping if available.
Does this observation specifically reference the Canada Labour Code or its regulations? No

This notice reflects the observations of non-compliance with regulatory requirements or company commitments, made by the inspection officer during the compliance verification activity. If the corrective actions identified are implemented by the completion date, the matter is considered resolved. Any unresolved compliance matters will be addressed by the inspection officer and may be referred to NEB enforcement staff.

517 Tenth Avenue SW Calgary, Alberta  T2R 0A8
Telephone: 403-292-4800   Toll Free: 1-800-899-1265

 

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