Compliance Verification Activity Report: CV2223-101 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1536
• Inspector 2666

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Integrity Management

Rationale and scope:

TMEP Inspection of Spread 4B and pump stations - Observation of work associated with pipe and components on the pipeline or pump stations, such as transportation, loading and unloading, stringing, bending, alignment, welding, lowering-in, and backfill.  In addition, observations of geohazards sites and geohazards mitigation measures, trenchless installation,  water crossings and buoyancy control measures applied, and foundation installation related to infrastructure required for the project operation.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT
• BLACKPOOL

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)
• Pump station

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - TM Pipe suspension Location (SF58)

Date & time of visit: 2022-07-11 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• Pipe Condition
• Integrity Management Program
• Implementation

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER inspectors observed Line 1 pipe suspended at a distance greater than 5 m using three 10 or 12-inch flume pipes with straps that had markings indicating weight load limits of 3335 lbs. The structural integrity of two of the three flume pipes appeared compromised as there were holes of significant size (3” to 4“ diameter) present in the flume pipe and there was some deformation of the flume pipe.
• TM representative indicated that the pipe suspension design was per design recommendations from a third-party contractor. 
• See IR #1

Compliance tool used: No compliance tool used

Observation 2 - Trench box location

Date & time of visit: 2022-07-11 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• Excavations

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER inspectors noted that there was no consistency in fencing along the ditch line as there were sections across the spread where fencing was present, and others where there appeared to be no fencing.
• CER inspectors requested that the company provide the fencing requirement/procedures
• TM representatives stated that trench conditions are inspected by a foreman to determine the requirement for sloping the ditch and access based on the area available for the ROW and the type of soil
• Foam pads are placed under the pipe to support and protect the pipe against objects such as rocks in the soil that may cause dents and gouges. Sand padding is placed on top of the foam pads

Compliance tool used: No compliance tool used

Observation 3 - Pipe Relocation and Lowering

Date & time of visit: 2022-07-11 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• Lower-In

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• TM representative stated that a rock shield is wrapped around the pipe to protect against damage at locations where the ditch area is narrow and un-sloped or shored and there is a risk of gravel/cobbles falling in the ditch and workers are unable to enter the excavation to clear any rocks or cobbles.
• The construction sweep report placed in a tube at the location contained ground disturbance information backdated from 2018 and 2019 and therefore may not be representative of current conditions. TM representative stated that ground disturbance is done again if any ground disturbance activities occur and if a company or an entity such as a utility requires new right-of-way access or crossing.
• CER inspectors observed the pipe being relocated by about 100-150 m before pipe lowering in activity at this location.
• CER inspectors observed pillows placed 3 m to 5 m apart in the ditch under the pipeline to provide support, protect the pipeline from spanning and rocks on the bottom of the ditch, and prevent dents and gouges.

Compliance tool used: No compliance tool used

Observation 4 - Welding location

Date & time of visit: 2022-07-11 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• Safety

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• A trench box was installed at the welding location wherein pipe welding activities were occurring.
• A ladder was installed near the trench box to provide access to the crew working in the trench box. The excavation was approximately 6 m deep and the ladder was secured at the top.  TM indicated that this is considered a confined entry location and confined entry rescuers with a davit are either on location or at most 5 minutes away

Compliance tool used: No compliance tool used

Observation 5 - Clearwater River DPI Entry point

Date & time of visit: 2022-07-12 08:30

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• TM representative stated that a 42-inch casing pipe has been installed and the carrier pipe will be installed through the casing.
• TM stated that the tunnel boring machine (TBM) used for the direct pipe install (DPI) has been stuck below ground approximately 45m from the exit point since May 2022.  The drill encountered refusal and could not pass through.
• TM further stated that they are developing and implementing multiple contingency plans but remain uncertain with respect to the length of time it will take to resolve the issue.
• TM stated that the TBM recovery plan does not require a design change notice (DCN). However, one may be warranted if the execution plan upon recovery deviates from the original plan.
• TM indicated that a worker trained in confined space entry has entered the pipe to go to the drill location to try to determine the reason for the drilling stoppage and that a confirmed rescue team is on site.
• CER inspectors noted that field-applied epoxy coating was applied in October 2021 on the field welds of the section that will be pulled through the casing and noted that prolonged UV exposure may compromise the coating condition since there is no certainty when the drill will be completed.
• For the pipe pulled through the casing, CER inspectors observed that a ½-inch stainless steel cable is used instead of the fibre optic cable because it is more resistant to damage when the pipe is pulled through the casing. Several of these cables are placed around the pipe circumference increasing the probability that one of the cables will not be damaged during the pull.
• CER inspectors noticed that there was no proper signage for Line 1 within the town at the following GPS Locations:
  • Lat: 51.648144, Long: -120.037801
  • Lat: 51.648450, Long: -120.031998
• See IR#2 (progress of TBM recovery), IR#3 (coating exposure) and IR #4 for signage

Compliance tool used: No compliance tool used

Observation 6 - Clearwater River DPI Exit point

Date & time of visit: 2022-07-12 10:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER inspectors observed the exit trench and the three H-piles that were installed to excavate to the depth of the TBM to fix the TBM obstruction. A 72-inch casing was installed at the DPI exit location in an attempt to connect with the TBM head so that it can be accessed and repaired.
• TM representative stated that the 72-in casing was offset compared to the TBM machine and that the casing hit refusal about 45 cm away from the head of the TBM machine, resulting in an unsuccessful attempt.
• TM representative stated that the company is considering other options on how to proceed and indicated that an open cut is not being considered due to the significant progress of the DPI installation and the associated challenges of an open cut.
• Note: associated with IR #2 (TBM recovery)

Compliance tool used: No compliance tool used

Observation 7 - HDD under the Town of Clearwater entry point

Date & time of visit: 2022-07-12 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER Inspectors observed the HDD casing installation. A telescope casing was being installed at this location.
• TM representatives stated that hammering starts after 9 am and ends by 8 pm per the requirements of the noise management plan. Noise reducing walls used to suppress and mitigate sound from the hammering activities to the surrounding area were present at the site.
• Three different casing diameters are being pushed into the ground at this location. The first casing is 84 inches, the second is 72 inches, and the third is 60 inches. The first casing extends from the surface to a depth of 37 m, the second casing extends from the surface to 73 m, and the third casing will extend to the depth of 105 m.
• TM representative stated that an HDD intersect method is being applied at this HDD installation
• TM representative stated the HDD installation was selected to go through the town rather than ditching and back-filling in order to minimize the disturbance to town residents.
• During a drive to the exit point CER inspectors noted that pipeline markers identifying the presence of Line 1 in the residential subdivision appeared absent.
• CER inspections noted that the noise abatement walls significantly reduced the noise near the closest houses. However, since this was outside of the inspection scope, no means of measuring the decibels near the house was available to confirm the requirements were being met and no follow-up with TM was conducted
• See IR#4 (signage/pipeline markers) and IR#5 (HDD contingency plan)

Compliance tool used: No compliance tool used

Observation 8 - SF 57 - North of Clearwater - welding

Date & time of visit: 2022-07-12 14:00

Discipline: Integrity Management

Categories:

• Pipeline
• Welding Operations

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER Inspectors observed welding activities on the pipe in the excavation ditch. The welding inspector presented inspection reports/logs identifying how the welding meets the welding parameters in the welding procedure specifications. This included heat inputs, travel speed, preheat temperatures, etc. The welding inspector also stated that pipeline alignment is measured before welding to prevent pipe misalignment.
• Welding electrodes were stored in a hermetically sealed canister to protect against moisture before the canisters were opened and placed into the rod oven for welding.
• An electrode heater was observed in the excavation and plugged in. Electrodes were also outside the heater in a pail, however, as long as they are used within the allowed time frame the process complies with requirements.
• The welding inspector stated that each weld takes approximately 3.5 and 4 hours to complete

Compliance tool used: No compliance tool used

Observation 9 - SF 57 - South of Clearwater

Date & time of visit: 2022-07-12 14:00

Discipline: Integrity Management

Categories:

• Pipeline
• Inspections
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER inspectors observed several sections of pipe (Evraz 11.7 mm WT spiral weld pipe) that had multiple coating repairs on the extrados of a cold bend. The damage to the pipe appeared to be from the bending machine. CER inspectors requested documentation showing that the damages were noted, an analysis performed to determine the root cause, and the corrective and preventive actions to stop the damage from occurring. 
• TMEP indicated that they had observed some coating lying beside the pipe which appeared to have disbonded from a hot bend.  TMEP indicated that a root cause analysis (RCA) and testing had been conducted and a report detailing the RCA and testing results had been generated. 
• Automatic ultrasonic testing (AUT) was performed on completed welds on sections of pipe including surface prep and visual inspection. The NDE inspector stated that equipment is calibrated after every NDE on each weld.
• A sample AUT report was presented indicating inspection results and acceptance or rejection of the weld. The NDE inspector stated that acceptance criteria are per CSA Z662-19.
• See IR #6 (coating repairs and root cause analysis report)

Compliance tool used: No compliance tool used

Observation 10 - Blackpool slope

Date & time of visit: 2022-07-12 15:00

Discipline: Integrity Management

Categories:

• Pipeline
• ROW

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• TM representative stated that the slope classification includes Class 1 (inclination <16 degrees), Class 2 (inclination that ranges from 16 degrees to 22 degrees), and Class 3 (inclination >22 degrees).
• TM representative stated that the slope at the Blackpool location has three sections to it, the lower section is a Class 2, the middle section is a Class 3 and the upper section is a Class 2. The upper Class 2 section was being graded to Class 1 at the time of the inspection. The slope was graded to allow for work to proceed safely.
• TM representatives indicated that the Blackpool slope is not considered to be a geohazard location
• CER inspectors observed that the slope soil type is a mixture of crushed sand gravel with traces to no clay. There were no apparent signs of slope instability or movement.

Compliance tool used: No compliance tool used

Observation 11 - Blackpool pump station

Date & time of visit: 2022-07-13 09:00

Discipline: Integrity Management

Categories:

• Integrity Management Program
• Implementation

Facility:

• BLACKPOOL (Facility)

Observations:

• TM stated that construction activities were recently completed at the station and dry commissioning activities are currently being undertaken and are nearing completion. Dry commissioning includes verification of electrical wiring to “as-builts”, function testing of equipment and instrumentation, SCADA system checks, etc.
• Station appeared tidy, indicative of good housekeeping practices.
• The station windsock did not appear readily visible from the south and east sides of the station.
• Panic gates for egress were present on station fencing. However, such gates were not present on the perimeter fence to provide easy access in the event of an emergency at the location of the muster point
• See IR#7 (Station commissioning), IR#8 (windsock visibility) and IR#9 (station exits)

Compliance tool used: No compliance tool used

Observation 12 - Boring location

Date & time of visit: 2022-07-13 15:00

Discipline: Integrity Management

Categories:

• Pipeline
• Excavations
• Lower-In

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• Boring trenches were being prepared for equipment to be lowered in to complete two slip bore installations at this location. Another slip bore installation had already been completed at this location.
• All slip bore trenches were 4 to 5 m deep and shored except for one trench across the highway which was adjacent to the slip bore location.
• The trench had a side slope steeper than 45 degrees and a soil type consisting of clean sand with no clay content.
• There were signs that workers had been in the non-shored section of the ditch connecting the side boom and the weld grounding clamps. Bannister staff indicated that they had been accessing the un-shored component of the excavation for the past week.
• CER staff requested the documentation that verified that the excavation was safe for entry. The documentation reviewed did not verify that the excavation was safe to enter and was not signed off by any person competent to make that decision.
• Bannister staff indicated that they were unaware who from TM or Bannister was responsible for determining that the excavation was safe for entry. After discussing the situation with the responsible TM staff, the CER inspectors requested that no workers enter the ditch until a trench box was installed in this excavation and refrain from accessing the trench until it is protected from failure.
•  The CER inspector observed the TM Safety representative tell the crew that a trench box must be installed before anyone could enter the unshored portion of the excavation to ensure the safety of the workers. TM staff corrected the issue by removing the ladder and preventing anyone from accessing the excavation until the trench box is delivered and installed.
• CER requested that TMEP provide a demonstration that the weld ground clamps and the side boom connection were still attached with the shoring installed to demonstrate that no one had entered the unsafe excavation. TMEP committed to providing this demonstration.  Based on TMEP’s commitment, the CER inspectors were satisfied with this solution. 
• CER indicated that entering this unsafe ditch was a non-compliance and if TMEP was able to provide the demonstration that no one entered the excavation through a photograph then it would be considered a corrected non-compliance. 
• As a follow-up at the end of the day, CER inspectors asked TMEP to provide any other actions taken to prevent this non-compliance from occurring at other locations, for example, proof of discussion at tailgate meetings, and a safety bulletin.
• Coating repair patches were observed, similar to the Shoefly 57 location, to be prevalent on a section of pipe indicating abrasion potentially due to bending or other means. This pipe was a 14.7 mm WT long seam pipe.
  See IR#10 (coating repairs - Boring location)

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR) 2020-03-16

Relevant section(s):

• • 6.5
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;
      • (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards, potential hazards and risks and for communicating those controls to anyone who is exposed to the risks;

Company action required:

Company shall demonstrate that no persons enter unsafe excavation until a trench box is installed in the ditch/trench, refrain from accessing the ditch/trench until it is properly protected from failure and provide photo evidence that no person entered the ditch/trench

Due date: 2022-07-13

Date closed: 2022-07-26
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 - Backfilling and Pipe lifting

Date & time of visit: 2022-07-13 16:00

Discipline: Integrity Management

Categories:

• Pipeline
• Backfilling
• Procedures
• Integrity Management Program
• Implementation

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• Pipe had been lowered into the ditch, tied in, and backfilled at both ends before arrival at the site
• TM crew had already shaded a small amount of backfill sand into the excavation. TM representative stated that the sand is placed on top of the pipe then the pipe will be lifted to allow the sand to flow under the pipe to fill the gap between the pipe and the underlying ground.
• CER inspectors observed an approximately 30 m section of exposed pipe which was welded and backfilled at both ends in the ditch being lifted by side booms to have soil flow underneath the pipeline to provide support. It appeared the pipe was lifted approximately 30 cm at approximately the midpoint of the section.
• TM was unable to provide a lift plan relevant to tied-in and backfilled pipe. Since there was no lift plan the TM inspectors were unable to tell the CER inspectors the maximum lift height with respect to the axial strain being applied on the pipe due to the lift.
• CER inspectors observed the operation and had concerns over the pipe strain that the pipe would experience due to this practice and the lack of a pipe lift plan that specifies the allowed lift height.
• see IR#10 (coating repairs) and IR#11 (lift plans)

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: