Compliance Verification Activity Report: CV2223-100 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2223-100
Start date: 2023-02-22
End date: 2023-02-22


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

Integrity inspection of Edmonton Terminal West Tank Area Expansion Project fire protection system to verify compliance to OPR, CSA Z662-19, CLC, and OC-65.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Discussion Prior to Field Inspection

Date & time of visit: 2023-02-22 09:00

Discipline: Integrity Management




CER inspectors met with Trans Mountain (TM) representatives at the Edmonton Terminal to inspect the fire protection system of the Edmonton Terminal Expansion Project West Tank Area (WTA). Note that a reference to TM is intended to represent Trans Mountain Expension Project (TMEP) or Trans Mountain Corporation (TMC) representatives. Prior to completing the field portion of the inspection, CER inspectors discussed the following items with TM:

Tank Settlement during Hydrotest
In response to IR #1 of the previously conducted CER inspection CV2122-259, TM provided an Addendum Report from Thurber Engineering LTD which recommended the monitoring of the tank settlement during the hydrotest of the new tanks. TM explained that a survey company was hired to monitor the potential settlement of the tanks during the hydrotests. The survey company conducted surveys prior to, during, and after the hydrotests to monitor the settlement. TM explained that the results of the survey were acceptable to API 650 for all the tanks and that no corrective actions were necessary.

Volume of Secondary Containment
TM explained that the construction of the secondary containment is almost but not fully completed yet. Once the secondary containment is completed, TM explained that it will survey the secondary containment areas, develop a 3D model and calculate the volumes of the secondary containments to confirm it conforms to its design (Condition 23) and is compliant with the regulatory requirements. TM explained that there have not been any significant changes to the secondary containment from the final design and therefore no issues are anticipated when the volume is confirmed.
Monitoring of Fire Water and Foam Concentrate Volumes
TM explained that there are two new 12,000-gallon tanks for the foam concentrate of the tanks in the scope of the WTA, but technically only 8,000 gallons are needed. These tanks are not yet filled with foam concentrate. TM explained that the level of the foam concentrate tanks will be verified twice daily by TM staff during the checks that occur during each shift (two shifts per day), as it is for the water reservoir and other existing foam tanks right now. The water reservoir is also equipped with a low-level alarm set at 15 ft and a low-low-level alarm set a 6 ft of remaining water in the pond. TM could not confirm during the inspection what the level heights represented in terms of remaining volume. The new foam concentrate tanks will also be equipped with low-level alarms which will be set at 1.5 ft from the tank bottom, which represents approximately 1,200 gallons.  The alarms for the foam concentrate tanks and the water reservoir are sent to the control center. TM indicated that any foam concentrate that is utilized out of the tanks, for whatever reason, is replaced shortly after. An Information Request (IR) was issued to obtain more information on the set point values of the water level alarms and the purpose of those alarms (See IR #1).

Dry Commissioning

TM explained that the dry commissioning has not started yet. However, the project is in the last stages of construction and it is a matter of weeks before dry commissioning starts.

NCR Number ET-WPC-NCR-0094
TM reported the following Non-Conformance Report (NCR) to the CER as part of Condition 105:

Non-Conformance Description:
Field weld #2 on isometric ET00-P-5264-NPS20-A101 did not undergo radiographic testing prior to backfill contrary to owner requirements and ITP inspection point.

Disposition Details:
Contractor will expose field weld and perform radiographic examination prior to hydrotest. Contractor to ensure all welds receive NDE prior to backfill and will perform an audit of all welds to ensure NDE is complete.

TM explained that the contractor self-identified this non-conformance as part of its quality assurance (QA) process and that the contractor reported it to TM as required. TM explained that the contractor inadvertently backfilled the weld that had not yet been radiographic tested but that the contractor's QA process worked as intended and identified the error. TM explained that the contractor completed the audit of all of the welds and that no other similar issue was identified. TM also conducted its own audit of the welds and also confirmed that there were no other similar issues. TM explained that it was satisfied with the actions taken by the contractor and that no other corrective or preventive actions beyond those already implemented were necessary.

Fire Protection Design Basis, Firefighting Capacity and Fire Pre-Plans 

Compliance tool used: No compliance tool used

Observation 2 - Field Portion of the Inspection

Date & time of visit: 2023-02-22 10:00

Discipline: Integrity Management




Operations/Maintenance Building

Fire Pump Building
Legacy Fire Pump Building Fire Storage Building New Foam Tank Building Foam Pump Building Storage Tanks Cold Storage Building Power Back-up

TM confirmed that the different components of the fire protection systems have an alternate source of power that will ensure they can operate in the event of a primary power loss event. TM explained that the Uninterruptible Power System (UPS) and diesel generator systems provide back-up electricity where needed and that diesel engines can be started manually.

Compliance tool used: No compliance tool used

Observation 3 - CNC #1 - Pallets in Front of Emergency Trailers

Date & time of visit: 2023-02-22 12:00

Discipline: Emergency Management




Cold Storage Building
The emergency response trailers were in apparent good condition but there were some materials on wood pallets that had been stored in front of the trailers, which could have slowed down the deployment of the trailers if needed. This is a non-compliance to CSA Z662-19 clause (d).  TMEP took immediate actions to remove the pallets, and this was addressed during the inspection.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company removed the pallets to address the non-compliance. No further actions required.

Due date: 2023-02-22

Date closed: 2023-02-22
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

Observations (company follow-up required)

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

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program