Compliance Verification Activity Report 1516-495 – Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Type of Compliance Verification Activity: Field Inspection

Activity #: 1516-495
Activity start: 2016-03-07
Activity End: 2016-03-07

Related Activity Numbers:

Inspection Officer Number(s): 1536, 2666T, 2556T

Incident #:
Landowner Complaint File #:

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

Facility Name(s): McMahon 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
2016-03-07 McMahon Gas Plant Integrity Management No
Observations

Westcoast stated that as part of development of an Integrity Management Program for pressure piping, approximately 400 Thickness Monitoring Location (TML's) were identified. Based on a risk assessment of each piping circuit performed in 2000, 200 TMLs have been installed. Baseline surveys were conducted in 2015 across these TMLs and another survey will be conducted this year to assess thickness reductions, if any. Westcoast also stated that, in addition to scheduled piping inspections, spot checks are conducted across the plant arising from issues that may have been identified in other Westcoast facilities.

No documentation to verify both the internal and external condition of piping in Butane Propane Loading (BPL) area since its installation over 50 years ago is available. This is because Westcoast considers the piping low risk with no visible external corrosion. Internal corrosion is also considered low based on BPL vessel inspection results. However, Westcoast was unable to demonstrate accuracy of assumption with any TML data. BPL vessels qualify for a 10-year inspection cycle based on company's assessment of ABSA AB506 guidelines. Additional information has been sought to validate this assumption.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-07 McMahon Gas Plant Integrity Management Yes
Observations

All 2 inch, 3 inch and 4 inch WKM ASA 300# valves in similar service to the valve identified in May 9 2015 Butane release incident have been taken out of service. 13 valves were replaced and the remainder were removed from service and associated piping was blinded. Gap measurements between the body and bonnet of 6 inch and 8 inch valves of similar design and service are conducted monthly and assessed against manufacturer maximum recommendation of 1/16 inch. NEB Inspectors verified that the valves were replaced and Westcoast demonstrated how the bonnet of an 8 inch valve is inspected.

Westcoast only considers Emergency Shutdown Valves (ESD) and the new Electronic Isolation Valves (EIV) that will be installed in the BPL area as critical valves. Therefore, the inspections on all other valves in the site have a different inspection frequency.

NEB Inspectors verified that new temporary LEL detectors with remote alarm to alert operators of potential hydrocarbon leaks have been installed in proximity to Butane and Propane storage vessels. Remotely operated automated isolation valves for each vessel in Butane Propane Loading (BPL) scheduled for installation Q3 2016.

A Process Hazard Analysis (PHA) was conducted between October 13-15, 2015 on BPL Area. Westcoast stated that all findings and recommendations have been accepted. However, Westcoast has not signed off on any identified risks with the exception of high risks. Westcoast stated that a new PHA protocol will be developed by the end of 2016.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-07 McMahon Gas Plant Integrity Management No
Observations

No integrity management program exists for buried piping at the facility; Westcoast is developing such a program for completion at an anticipated future date. Buried piping is cathodically protected but no formalized plan is yet in place for monitoring and assessing integrity threats to any buried piping.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-07 McMahon Gas Plant - Flare Pits Integrity Management No
Observations

Portions of flare header piping to flare pits are buried/below ground. As a follow up to INC 2015-071 where black staining was discovered in two spots on the ground inside flare pit area, Westcoast stated that integrity digs were conducted to assess coating damage and subsequent repairs were conducted. Westcoasts' ongoing investigation reveals that gas passing through a cut and uncapped section of a buried 12 inch line in proximity to buried flare piping may have impacted the integrity of the flare piping.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-03-07 McMahon Gas Plant Integrity Management No
Observations

Vegetation was observed within the flare pit thereby causing potential for grass fires. Westcoast stated that the vegetation management program does not address grass removal and that the program will be re-assessed.

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 08/04/2016
Date/Time visited Location
2016-03-07 (Time Unspecified) McMahon Gas Plant
Observations

Westcoast stated that as part of development of an Integrity Management Program for pressure piping, approximately 400 Thickness Monitoring Location (TML's) were identified. Based on a risk assessment of each piping circuit performed in 2000, 200 TMLs have been installed. Baseline surveys were conducted in 2015 across these TMLs and another survey will be conducted this year to assess thickness reductions, if any. Westcoast also stated that, in addition to scheduled piping inspections, spot checks are conducted across the plant arising from issues that may have been identified in other Westcoast facilities.

No documentation to verify both the internal and external condition of piping in Butane Propane Loading (BPL) area since its installation over 50 years ago is available. This is because Westcoast considers the piping low risk with no visible external corrosion. Internal corrosion is also considered low based on BPL vessel inspection results. However, Westcoast was unable to demonstrate accuracy of assumption with any TML data. BPL vessels qualify for a 10-year inspection cycle based on company's assessment of ABSA AB506 guidelines. Additional information has been sought to validate this assumption.

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 to provide evidence of inspection history on piping circuits in the Butane Propane Loading (BPL) area and plans for future inspections to validate assumptions that the piping in the BPL area is fit for purpose.
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) 29/04/2016
Date/Time visited Location
2016-03-07 (Time Unspecified) McMahon Gas Plant
Observations
No integrity management program exists for buried piping at the facility; Westcoast is developing such a program for completion at an anticipated future date. Buried piping is cathodically protected but no formalized plan is yet in place for monitoring and assessing integrity threats to any buried piping.
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 to provide a list of all buried piping within the facility with specifications including date of installation, diameter, wall thickness, coating type; products carried within such piping, dates of last inspection and next inspection, the type of inspection conducted, the findings from the most recent inspections.

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 all 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 08/04/2016
Date/Time visited Location
2016-03-07 (Time Unspecified) McMahon Gas Plant - Flare Pits
Observations
Portions of flare header piping to flare pits are buried/below ground. As a follow up to INC 2015-071 where black staining was discovered in two spots on the ground inside flare pit area, Westcoast stated that integrity digs were conducted to assess coating damage and subsequent repairs were conducted. Westcoasts' ongoing investigation reveals that gas passing through a cut and uncapped section of a buried 12 inch line in proximity to buried flare piping may have impacted the integrity of the flare piping.
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 to provide a summary report of the integrity digs and inspections conducted on the buried flare piping per INC 2015-071 inclusive of repair details, coating type and length of piping exposed.
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    
Date/Time visited Location
2016-03-07 (Time Unspecified) McMahon Gas Plant
Observations
Vegetation was observed within the flare pit thereby causing potential for grass fires. Westcoast stated that the vegetation management program does not address grass removal and that the program will be re-assessed.
Regulatory Requirements
 
Corrective Action or Request Required
 
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

Date modified: