Montreal Pipe Line Ltd.

(MPLL)
Section 43 of National Energy Board (NEB) Onshore Pipeline Regulations Application to
increase Maximum Operating Pressure (MOP) of three pipe segments within North Tank Field
(Project)

NEB File No.: OF-Fac-Oil-M253-2014-02 01

Filed: 30 September 2014

Information Request No. 1

Table of Contents
Information Request No. 1.......................................................................................................... 2
General Matters........................................................................................................................... 3
1.1 Clarification - applicable standards and regulations .......................................................... 3
Engineering Matters.................................................................................................................... 2
1.2 Design of pump stations and tank farm................................................................................. 5
1.3 Clarification of pipeline segments for MOP increase .......................................................... 5
1.4 Clarification – Exhibit 5........................................................................................................ 5
1.5 Engineering and Operations ................................................................................................ 6

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 Montreal Pipe Line Ltd. (MPLL)
Section 43 of National Energy Board (NEB) Onshore Pipeline Regulations Application to increase
Maximum Operating Pressure (MOP) of three pipe segments within North Tank Field (Project)

NEB File No.: OF-Fac-Oil-M253-2014-02 01

Filed: 30 September 2014

Information Request No. 1

General Matters
1.1 Clarification - applicable standards and regulations
Reference:
i) MPLL, Application, Exhibit 1: Application Narrative, Section 4.1 Project
Description, page 3 of 4 (PDF page 5 of 76), A4C5S8
ii) MPLL, Application, Exhibit 1: Application Narrative, Guide F, page 4 of 4
(PDF page 6 of 76), A4C5S8

Preamble: Reference i) states that all testing performed on the segments was conducted in
conformance to the latest edition of Canadian Standards Association (CSA)
Standard Z662, Section 8, Pressure Testing and Part 5, Pressure Testing, of the
NEB Onshore Pipeline Regulations 1999.

Reference ii) states that all pressure testing performed on the segments was
conducted in conformance to the latest edition of CSA Standard Z662, section
8, Pressure Testing and Part 5, Pressure Testing, of the NEB Onshore Pipeline
Regulations 1999.

In June 2011, the CSA published the CSA Standards Z662-11 Oil and Gas
Pipeline Systems and on 10 April 2013, the Onshore Pipeline Regulations,
1999 were amended and renamed the NEB Onshore Pipeline Regulations.
Companies should rely on and refer to the current standards and regulations.

Request: Please confirm that all testing referred to in References i) and ii) was
performed on the pipe segments in conformance to the CSA Standards Z662-
11 Oil and Gas Pipeline Systems, and in conformance to the NEB Onshore
Pipeline Regulations.

Answer: The testing was performed in accordance to the CSA Standards Z662-11 and
in conformance to the NEB Onshore Pipeline Regulations

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Engineering Matters
1.2 Design of pump stations and tank farm

Reference: i) CSA Z662-11, Clause 4.14.3.8 and Clause 4.15

ii) MPLL, Application, Exhibit 1: Application Narrative, pages 1-4 of 4
(PDF pages 3-6 of 76), A4C5S8

Preamble: In Reference i) (CSA Z662-11), Clause 4.14.3.8 states that pump station
piping may be designed as specified in ASME B31.3, and Clause 4.15 notes
that API 2610 provides guidance relating to the design, construction,
operation, inspection, and maintenance of petroleum terminal and tank
facilities.

Exhibit 1 (Reference ii)) does not state clearly what standard was originally
used to design the piping system within the pump station at the MPLL North
Tank Field.

Request: Please clarify the following:

a) The standard or code (including edition) to which the MPLL North Tank
Field was originally designed (including design factors), including but not
limited to:
a.1) Aboveground tanks;
a.2) Pump station piping;
a.3) Fittings and flanges; and
a.4) Pressure relief device.
b) If the original design factor was specified differently from the current
CSA, please provide a rationale and documentation demonstrating that the
CSA Z662-11 design factors used in the engineering assessment are the most
appropriate.

Answer: a.1) The above ground tanks are not included in the application for
increase in MOP as they are not impacted by the increase in system
operating pressure.

a.2) MPLL North Tank Field (NTF) pipe including the pump system:
• Existing: CSA Standards Z662-96 Oil and Gas Pipeline Systems
• New 2014 : CSA Standards Z662-11 Oil and Gas Pipeline Systems

a.3) Fittings and flanges:

• Existing: CSA Standards Z662-96 Oil and Gas Pipeline Systems
• New 2014: CSA Standards Z662-11 Oil and Gas Pipeline Systems

a.4) Pressure relief devices: CSA Standards Z662-11 Oil and Gas
Pipeline Systems

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 b) The original design factors specified for the 1998 and 2001 NTF
projects per CSA Standard Z662-96 (projects approved by National
Energy Board Orders XO-M3-22-98 “Line 9 Tank Facilities” and
XO-M003-10-2001 “Construct Two New Tanks”) have not changed.
GCM consultants compared the factors identified in the CSA Z662-
96 to the CSA Z662-11 revision and used the same factors in the
2014-2015 engineering assessment (Exhibit 9 Rev1)
Engineering Matters
1.3 Clarification of pipeline segments for MOP increase
Reference: i) MPLL, Application, Exhibit 1: Application Narrative, Chapter 3, Clause 3.1,
page 1 of 4 (PDF page 3 of 76), A4C5S8
ii) MPLL, Application, Exhibit 6: Pressure Test documentation, Hydro test 18 and
24 inch pipe at North Tank Field, PDF pages 24-38 of 76, A4C5S8
iii) MPLL, Application, Pipe pressure test drawings, Exhibits 2, 3 and 4, (PDF
pages 7 to 9 of 76), A4C5S8

Preamble: In Reference i), MPLL described three pipeline segments for which it is requesting
to increase the MOP: Tank 663 NPS 30 fill line, Tank 665 NPS 30 fill line and
NPS 24 pipe connecting the Montreal Enbridge Terminal to the MPLL terminal
pipe system.

In Reference ii), MPLL provided hydrostatic testing documentation for the NPS 18
and NPS 24 line segments.

The pipeline segments for which hydrostatic testing documentation was provided
are not included in Reference i).

It is not clear how the pipe pressure test drawings provided in Reference iii) relate
to References i) and ii). Clarification is required as to which pipeline segments are
included in MPLL’s request for an increase in MOP.

Request: Please provide the following:

a) If MPLL intends to increase the MOP to 275 psi on the NPS 18 and NPS 24
hydrostatically-tested line segments [Reference ii)], identify (highlight) those lines
in the drawings submitted in Exhibits 2, 3 or 4, and provide detailed sketches of
those lines;
b) Clarify whether the lines tested from pump valves 657, 658, 659 to the Blind
flange Enbridge property line will be increased to an MOP of 275 psi; and
c) Detailed sketches of the NPS 12 line segments (Exhibit 3) tested in Reference
ii), and clarify if the NPS 12 lines will be increased to an MOP of 275 psi.

Answer: a) See Exhibit 2 Rev 1 and 2B Rev. 1: Yes, the application requests
increasing the MOP for the C235-24-A segment to 275 psi. The segment
of NPS 24 pipe is highlighted in blue on the attached drawings D-4251 and
D-4205.

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 b) No, this application does not request an increase in MOP of the NPS 18
pipe segments identified on MPLL drawing D-4251 as C-120-18”-AA and
C-118-18”-AA.

c) Yes, this application is requesting the MOP increase to 275 psi for the
following pipe segments highlighted in Exhibit 3 Rev 1 and 3B Rev1 (MPLL
Drawing D-4252 and MPLL drawing D-4204):
• C216-12”-A NPS 12 spool piece TP15 to TP14
• C215-12”-A NPS 12 connector pipe TP11 to TP12
• C214-18”-A NPS 18 M-605 crude pump discharge
• C214-12”-A NPS 18 M-605 crude pump discharge
• C213-18”-A NPS 18 M-605 crude pump suction
• C221-18”-A NPS 18 M-600 crude pump discharge

Engineering Matters
1.4 Clarification – Exhibit 5
Reference: i) MPLL, Application, Exhibit 5: Pressure Test documentation, TK 663 Fill lateral
between valves Y663, 653, 673 at North Tank Field, page 2 of 14 (PDF page 11 of
76), A4C5S8
ii) Guidance Notes for the National Energy Board Onshore Pipeline Regulations,
Section 23, subsection (b)

Preamble: Reference i) provides a Specified Minimum Yield Strength (SMYS) of 40,000 psi for
the pipe fitting B16.5-A105-Class 150.

Reference ii) states that the pressure testing program should include the
specifications of the pipe and components of the pipeline to be tested.

Clarification of the SMYS for this pipe fitting is required.

Request: Please confirm and justify the use of the following:

a) Material specification of the pipe fitting B16.5-A105-Class 150 (i.e. 40,000 psi
rather than 36,000 or 30,000 psi) in Reference i)

Answer: When reviewing components of the system for pressure testing, MPLL
confirmed that system weld neck flanges have hub wall thicknesses per B16.5-
2003 Section 2.7. Ratings for weld neck flanges covered by the standard is
based on their hubs at the welding end having a thickness of at least equal to
that calculated for a pipe having 276 MPa(40,000 psi) specified minimum yield
strength. The value of 40,000 psi was entered in the SMYS column of the
pressure test document. This value was not used for calculating the maximum
test pressures. Pressure test value for the flanges is based on B16.5-2003 Section
2.6 “System Pressure Testing”. The pressure test documents (Exhibits 5 Rev1, 6
Rev1, 7 Rev1, 8 Rev1 & 9 Rev1) are updated to reflect the 36,000 psi yield
strength for the flanges.

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1.5 Engineering and Operations

Reference: i) MPLL, Application, Exhibit 9: Engineering Assessment by GCM Consultants,

Section 2 Assumptions, page 1 of 5 (PDF page 72 of 76), A4C5S8
ii) CSA Z662-11, Clause 3.3 Engineering Assessment, and Clause 10.4.2 Pipeline
Systems.

Preamble: Reference i) assumes that no hydraulic shock will be observed in future operations,
that the lines will be under non-sour service, and that pressure control and
overpressure protection systems will be adjusted for the new 275 psi MOPs.
Reference ii) states that engineering assessments shall be conducted for the purposes
of design or material qualification, and records shall be maintained for the life of the
pipeline systems.
MPLL’s application does not demonstrate an assessment of all of the hazards to
which this piping MOP increase may be subject, nor has the application provided
evidence to substantiate the assumptions made in Reference i).

Request: a) Please provide the following:

a.1) Documentation demonstrating that all pipe fittings are fit for service at the
proposed MOP;
a.2) A summary of the LRUT inspection of the buried pipeline segment at the road
crossing section, including the engineering assessment of integrity hazards
encountered;
a.3) Documentation demonstrating that it is impossible for hydraulic shock to occur
during future operations. If this demonstration is not possible, please provide the
hydraulic analysis and engineering assessment for potential surge pressure at an
MOP of 275 psia
a..4) Documentation demonstrating that the pressure control devices and overpressure
protection are fit for service at an MOP of 275 psi.; and
a.5) Documentation demonstrating that MPLL has considered the risk of sour product
in its integrity program.

b) Please demonstrate the following:

b.1) That MPLL has identified and addressed all possible hazards (i.e.
internal/external corrosion, overpressure, etc.), and assessed the degree of risk
associated with these hazards of all facility equipment within the MPLL North Tank
Field (i.e. pipeline section located on the road, piping, fittings, flanges, PSV, etc.) to
withstand the pressure increase at 275 psi.
b.2) That MPLL has conducted an Engineering Assessment of the underground
pipeline crossing and has confirmed that it is suitable for continued service with the
new MOP of 275 psi.; and
b.3) That MPLL has appropriately considered the integrity hazard due to the quality
of the product being shipped and stored within the MPLL North Tank Field facility.

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Answer a.1): Design specifications for fittings, flanges, valves and pipe were submitted in the
applications and approved in the National Energy Board Order XO-M003-10-
2001 “Construct two new Tanks” and Board Order XO-M3-22-98 “Line 9 Tank
Facilities”. In 2014 & 2015 GCM Consultants verified the existence of design
specifications and Material Test Reports for the pipe segments installed in1998
and 2001 to confirm the fittings are fit for the requested increase in MOP
service (see the attached engineering assessment).

Answer a.2): In September 2014, TISEC Inc. performed a Long-Range Guided-Wave

ultrasonic inspection (LRUT) on the NPS 24 underground crossing of 45 feet
travelling from Enbridge to MPLL. The piping in the underground crossing is
coated with a high density epoxy. The LRUT inspection did not show any
indication of wall loss for the pipe inside the inspection range. GCM
Consultants considered the report as part of their engineering assessment.

Answer a.3): Yes, GCM Consultants completed a hydraulic surge analysis of the proposed
NTF system operation. New 12 inch Flex-flo surge relief valves were
recommended to protect the NTF pipe system. Two sets of valves are installed
at Manifold 1 with one valve installed on the NTF 24 and two valves installed in
the NTF 30.

Answer a.4): GCM Consultants analyzed the sizing of the thermal relief valves as part of the
engineering assessment. New valves were specified for pipe segments operating
at the higher MOP.

Answer a.5): Yes, MPLL considered sour service for the NTF facilities. According to CSA
Z662-11, Clause 16.2.1(b), a liquid pipeline is considered to be in sour service
when the partial pressure of H2S is greater than 0.30 kPa (0.05 psia) at the
design pressure. This clause refers to NACE MRO 175/ISO15156, Part 2,
Annex C, to calculate the partial pressure in a pipeline.
MPLL uses a nomination procedure, as described in answer b.2, that restricts
the level of H2S to 250 PPM for all products proposed for future shipments. As
determined using the NACE calculation procedure, the maximum partial
pressure of H2S proposed for the NTF pipe system is 0.013kPa which is
significantly lower than the partial pressure of H2S required for a pipeline to be
deemed in sour service (0.30 kPa)

Answer B.1 and MPLL conducted a formal risk assessment for the pipe system which is
B.3): consistent with the guidelines presented in CSA Z662-11 Appendix B. GCM
Consultants acted as the facilitator. GCM Consultants design team, members of
MPLL operations, MPLL safety management, and MPLL engineering
participated in the assessment. All potential risks identified were assigned a
risk category and mitigation strategy.

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Answer B.2): Yes, MPLL considered the integrity hazards associated with the products being
handled at the North Tank Field. MPLL historically applies a nomination
procedure for all products proposed for shipment. Crude oil acceptance criteria
are in place to restrict the characteristics of the crude oil to be within ranges
that are acceptable from the perspective of piping integrity and operating
integrity. MPLL’s acceptance criteria effectively prohibit the handling of crude
oils that would present unacceptable integrity hazards.