Compliance Verification Activity Report 1617-164 – Plains Midstream Canada ULC

Type of Compliance Verification Activity: Field Inspection

Activity #: 1617-164
Activity start: 2016-04-07
Activity End: 2016-04-08

Related Activity Numbers:

Inspection Officer Number(s): 2524/2480

Incident #:  
Landowner Complaint File #:  

Company: Plains Midstream Canada ULC

Facility Name(s): Wascana Pipeline

Province(s): Saskatchewan

Theme(s): Integrity Management

Compliance Tools Used: Corrected in field (Corrected Non-Compliance) (2)
Notice of Non-Compliance (NNC) (1)

Purpose

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

 X  NEB Act

 X  Onshore Pipeline Regulations

 X  CSA Standard Z662 Oil and Gas Pipeline Systems

    Other:

    Electricity Regulations

    Processing Plant Regulations

    Pipeline Crossing Regulations Part I

    Pipeline Crossing Regulations Part II

Observations & Discussion

Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-04-07 Girth Weld 81940 Integrity Management Yes
Observations

Attended the site specific orientation and reviewed and signed tailgate documentation

Site Supervisor stated that communication had occurred between the control room and site to ensure a safe working pressure.

The emergency response plans were available on site.

The pipeline was exposed, the excavation was dry and banks were sloped appropriately with proper access and egress.

The pipeline appropriate depth of cover was confirmed by company.

The pipe was sandblasted, the magnetic particle inspection (MPI) was conducted on its entire circumference, and the ultrasonic inspection was conducted along the long seam at locations where long seam features were identified by MPI.

The pipe surface appeared to be in good shape with no visible pipe body cracking. One corrosion spot that did not require any repair was identified.

The exposed pipe was properly supported.

According to the non-destructive examination (NDE) field contractor the tape coating appeared to be in good condition when it was exposed.

The feature identified by the in-line inspection (ILI) tool was found and comparable between the field and ILI measurements.

The target feature was characterized as crack like by the ILI vendor and lack of fusion on the long seam by the NDE field contractor.

The target feature was located approximately 10.5 m downstream of girth weld 81940 confirming the location in the ILI data. The field location was confirmed using GPS coordinates and long seam orientation. The pipe was exposed for approximately 12 m from girth weld 81940.

Approximately 30 additional features along the seam weld were identified by NDE field contractor using magnetic particle inspection (MPI) and ultrasonic testing (UT) and were marked on the pipe. All these features were characterized as lack of fusion on the long seam weld. These features were not reported by the ILI tool. Final measurements and corresponding repairs will be provided in the final NDE report.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-04-07 Girth Weld 100600 Integrity Management Yes
Observations

Attended the site specific orientation and reviewed and signed tailgate documentation.

Site supervisor stated that communication had occurred between the control room and site to ensure a safe working pressure and the pressure was confirmed that day by phone call.

The pipeline was exposed, the excavation was dry and banks were sloped appropriately. Depth of cover appeared adequate. The exposed pipe was properly supported.

The target feature was located approximately 10.5 m downstream of girth weld 100600 confirming the location in the ILI data. The pipe was exposed for approximately 12 m from girth weld 100600.

The tape coating appeared to be in good condition. The tape coating was removed and sand blasting started. Proper safe working procedures were followed.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-04-08 Girth Weld 81940 Integrity Management Yes
Observations

Attended the site specific orientation and reviewed and signed tailgate documentation. The pipe safe working pressure was confirmed to be 2500 Kpa.

Plains decided to install steel compression reinforcement sleeves on all features identified on this exposed section of the pipe and the NDE personnel marked the sleeve locations. The sleeves extended 50mm beyond the defects.

The coating (RD6) manufacturing application specifications were reviewed.

Welding procedures reviewed and were being followed.

Petroline was the third party contractor on site for sleeves installation. Reviewed Petroline’s standard operating procedures related to sleeve installation, welding procedure for sleeve installation, and verified parameters and welder qualifications.

Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-04-07 Girth Weld 81940 Integrity Management No
Observations
NEB inspectors noted that one Plains employee wasn’t wearing all the proper PPE and during the site specific safety meeting the Plains site representative didn’t following procedure explaining the type of personal protective equipment (PPE)required for this site. This is a non-compliance to NEB OPR Sec 19(b), and was addressed immediately onsite.
Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
2016-04-07 Girth Weld 100600 Integrity Management No
Observations
Proper access and egress was available for the trench but a snow fence that was installed around the top of the trench was closed on three of the access/egress points thereby reducing the only available access/egress point to one. This is a non-compliance to CSA Z662-15 clause 10.2.6.2. This was fixed immediately onsite.
Does this observation specifically reference the Canada Labour Code or its regulations? No
Observations & Discussion
Date visited Location Theme Compliance Confirmed
016-04-08 Girth Weld 81940 Integrity Management No
Observations
NEB inspectors noted that Plains did not have the appropriate sleeve installation procedures onsite for the sleeves being installed.
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 Corrected in field (Corrected Non-Compliance) 4/7/2016
Date/Time visited Location
2016-04-07 (Time Unspecified) Girth Weld 81940
Observations
NEB inspectors noted that one Plains employee wasn’t wearing all the proper PPE and during the site specific safety meeting the Plains site representative didn’t following procedure explaining the type of personal protective equipment (PPE)required for this site. This is a non-compliance to NEB OPR Sec 19(b), and was addressed immediately onsite.
Regulatory Requirements

NEB OPR Sec 19

A company shall, during the construction of a pipeline, take all reasonable steps to ensure that

(b) all persons at the construction site who are not involved in the construction of the pipeline are informed of the practices and procedures that are to be followed for their safety.

Corrective Action or Request Required
Site representative for Plains described any specific required PPE and ensured all personnel was using the appropriate PPE for the job.
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 Corrected in field (Corrected Non-Compliance) 4/7/2016
Date/Time visited Location
2016-04-07 (Time Unspecified) Girth Weld 100600
Observations
Proper access and egress was available for the trench but a snow fence that was installed around the top of the trench was closed on three of the access/egress points thereby reducing the only available access/egress point to one. This is a non-compliance to CSA Z662-15 clause 10.2.6.2. This was fixed immediately onsite.
Regulatory Requirements

CSA Z662-15

10.2.6.2
Clear, unobstructed paths shall be provided as escape routes for all personnel performing work in trenches and the areas adjacent to work sites shall be kept clear of unnecessary equipment.

Corrective Action or Request Required
Plains site representative opened the snow fence to provide proper access/egress for the trench.
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) 5/16/2016
Date/Time visited Location
2016-04-08 (Time Unspecified) Girth Weld 81940
Observations
NEB inspectors noted that Plains did not have the appropriate sleeve installation procedures onsite for the sleeves being installed.
Regulatory Requirements

NEB OPR Sec 27

A company shall develop, regularly review and update as required, operation and maintenance manuals that provide information and procedures to promote safety, environmental protection and efficiency in the operation of the pipeline and shall submit them to the Board when required to do so.

Corrective Action or Request Required
Plains will, for the remaining of the dig sites, update its operation and maintenance manual to require keeping the appropriate sleeve installation procedures onsite for the sleeves being installed.
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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