Compliance Verification Activity Report: CV2223-106 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-106

Start date: 2022-09-21

End date: 2022-09-23

Team:

Inspector 2769
Inspector 2879

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

British Columbia

Discipline(s):

Integrity Management
Standard Condition

Rationale and scope:

Inspection of TMEP Sumas Terminal Construction

Compliance tool(s) used:

Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

SUMAS

Facility Types

Pipeline

Terminal

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 - INSPECTION REPORT

Date & time of visit: 2022-10-21 14:00

Discipline: Integrity Management

Categories:

Facilities

Aboveground Tanks and Pressure Vessels
Buildings (Ventilation)
Piping

Pipeline

Pipe Storage and Handling
Welding Operations
Coating

Documentation

Record Retention

Facility:

SUMAS (Facility)

Observations:

Construction progress:
Pertaining to the site inspection, TMEP presented an overview of the construction progress (the primary contractor is Kiewit Ledcor Trans Mountain Partnership (KLTP) and TMEP with the role of oversight):

Pipelines:
- New manifold addition in the terminal to interconnect the new line 2 to the tanks,
- Tanks 103 and 104 can receive the full flow of the new line 2,
- The existing line to Tank 103 is deactivated.
- The new pipelines (Line 2 / 24-inch) to connect Tank 100 will be constructed within the terminal in several sections.
- There are two sections of line 2 36" pipeline that will be constructed within the facility fence line.
Fire and Foam system:
- Fire water building is about half constructed (see picture “Fire Water building foundations”),
- Only the foundation of the Fire water pump building is completed,
- The foam and electrical building are not completed.
Tank 103/100:
- Tank 103 is deactivated since mid-April 2022 (drained, cleaned, and emptied),
- The Cleaning of tank 103 after its deactivation took 2 months,
- During the cleaning of tank 103, the work on tank 100 started,
- Tank 100 is anticipated to be completed by July 1, 2023,
- Currently there has been no secondary containment liner installed for the tank 100/103 scope. Tank 104 scope has been completed and the secondary containment was completed for that area.
- The floor of Tank 100 is currently under construction,
- Hydrotest is to be completed for both tanks 103 and 100. TMEP is still contemplating the best solution to minimize the use of water and how to source it.

Tank 104:
- All the work on Tank 104 is completed, and the tank is reactivated,
- Tank 104 secondary containment is not shared with other tanks, the retaining wall is designed to retain 10% of the total containment,
- This tank was not been hydrotested as part of the reactivation

Manifold:
- 90 % of the manifold is completed (piping installed),
- Relief manifold: most of the piping is installed and pipe racks were being installed at the time of the inspection.

Overall:
- Retaining wall: 6 casings of 6 meters depth are built, 3 to 5 meters are between each casing (see pictures Retaining wall #1 & #2),
- All the gravel slopes (see pictures Gravel Slopes #1 & #2) around the tanks are completed at 90%,
- Firefighting capabilities have been maintained even if hydrants have been removed or deactivated during the construction, temporary 5-inch hoses will supply water in case of incidents,
- A new security system has been installed to monitor the perimeter of the terminal, it allows detection of intrusion (visual and infrared detection) and is used to identify major events on site (e.g., leaks, fire,…).

Transfer of custody and management of change from project to operations:
IOs discussed the process/procedure established by TMEP with respect to the transfer of custody from the project to operation. TMEP said that it is part of their Dry and Wet Transfer Commissioning and that operations personnel have already been involved at various stages of the project (a month before going “online”).
TMEP mentioned that operations personnel reviewed the installation design package before construction was started. Also, operations personnel did have a few minor requests for change during the construction to allow for better ergonomics (installation design such as the position of valves, etc.).

Site inspection:

Manifold (see pictures Manifold #1, #2 and #3)

The work consists of an extension of the existing manifold to receive the new line 2.

The installation (launchers/receivers) for the new line 2 will allow the line inside the terminal to be piggable like the existing ones. Also, TMEP said that the connection work of the new line 2 will comply with the requirements of the ASME IX code (TMEP confirmed that it is consistent with the welding procedure specification (WPS) of new line 2 spreads).

A full-bore ball valve (see picture “Manifold full-bore valve”) is installed at the connection point with the new line 2 that can be used to isolate the terminal.
IOs asked about flange bolting. TMEP said that every flange has its own document for bolting which indicates the torque values and the sequencing of the bolts torqued.
IOs observed that flange connections that had been torqued were tagged and labelled accordingly and were showing appropriate stud thread engagement.
IOs noted one incomplete flange connection that was red tagged and stated that it “need re-facing flange face.”
The piping spools being installed have not been pressure tested yet but will be after installation.
The pre-commissioning of the manifold is tentatively planned for 1 July 2023.

IOs asked about the results of the Non-Destructive Examination (NDE) executed on the welded joints in the manifold. TMEP said that only one repair has been done (out of approximately 40 welds). The repair executed a week ago was due to a lack of penetration. The records of the repair NDE were provided by TMEP and the results of the x-ray interpretation were clearly indicating the lack of penetration (FW-101) and the results of the x-ray after the repair (FW-101R1) showed it was properly executed with no flaws.

Fire water building:

A permit to enter the excavation of the fire water building was readily available and noted to be signed off appropriately and dated for today.

Air quality monitoring system: (condition 44)

Additional emissions will be controlled by the new system,
Air quality is monitored continuously and is managed by a service provider which reports to TM (operations control room) in case of detection of an anomaly.

Tank 100 construction site (see picture “Tank 100 #1”):
TMEP said that:

The construction of Tank 100 is executed by the company Ganotec,
The cathodic protection (CP) system is installed (see pictures “CP As-built” and “CP grid”),
The leak detection system is in place,
The secondary containment liners are 300 mm deep and composed of 3 functional layers: 1 layer to protect from underground puncture (note the liners on top and the bottom are composed of 3 layers: 1 geogrid + fabric, 1 membrane, 1 geogrid + fabric), 1 layer to prevent leaks and 1 last layer to protect from aboveground damage (see pictures Liner #1 & #2).
The secondary containment liners are joined using heat and pressure
The distance between Tank 100 and other tanks is verified through 3D modelling and with lasers. TMEP did a demonstration of their 3D model during the inspection. The interior of the tanks will be 100% laser scanned.

Tank floor plates welding activities (see picture “Tank 100 Plate welding #1”)

Plates are 7.9 mm thick,
The overlap between the plates is 1” to 1-1/2” (see picture “Plates overlap”) and welding of the plates is subject to quality checks done by the joining program inspector,
Plate welds are visually inspected and tested with a vacuum box using negative pressure to detect any bubbling along the weld indicating a through-wall flaw on the weld.
When lifting lugs are removed from the floor plates, the surface is ground smooth and then checked using magnetic particle inspection,
NDE is audited independently by the joining program inspector,
IOs verified if welding consumables were stored adequately. Low hydrogen rods (E7018) are stored in a shack (see picture “E7018 storage”) and when unsealed are maintained at 135C using portable welding rod ovens. In the shack was also a storage oven temperature log. IOs noted that it had an entry for the start of today for one furnace for 301 F (149 °C).
Floor plates were properly stored and each plate is checked regularly by KLTP (under its quality program) and checked again before installation by the TMEP supervisor.

Also, TMEP said that they were dealing with an NCR (#416) related to gaps between sand bedding (see picture “Sand bedding annular rings”) inside the tank ring beam and foundation and the sketch plates connected to the annular rings (see picture “NCR #416 Gap plates and sand Tank 100”). A request for interpretation (RFI) is in process to confirm the validity of the proposed solution.

Tanks’ shell welding:
X-ray will be done for the butt welds on the tank annular,
Every section underneath the shell will be X-rayed 100%.

Pipeline welding activities on new line to connect to Tank 100:
CER IOs inspected joint welding activities of line 2. The WPS used was the KE-068 (Facilities Welding) WPS and the consumables used were E6010 for the root pass and E8010-G hot pass / E8018-C3 fill & cap.
TMEP/the welders had paper copies of the WPS, WPDS, and the weld traveller form on hand. IOs reviewed a manual welding parameter sheet which contained only parameters for the root pass as the hot pass was currently in process.
CER IOs observed that the field welding procedure data sheet (WPDS) reflects effectively the WPS. Welders’ qualifications and certificates were also in conformance.
CER IOs noted that some pipelines stored next to the welding had numerous coating repair patches (see picture “Stored pipes with many patches”) and asked TMEP to follow up on this.

Stormwater management:
CER IOs asked if the drain valves were automatic. TMEP said that the valves to drain the water (if necessary) are operated manually, the main reason is that according to TMEP potential sheen on the water can only be detected visually.
Tanks 103 and 102 secondary containments are equipped with water level indicators. Once the water has flowed up to the terminal disposal valve, the valve can be opened only if there is less than 15 ppm of hydrocarbons detected in it (a detector is installed on this valve).
When water is on the roof of the tanks and needs to be drained, TMEP said that 3 verifications of the presence of contamination are done: before draining the roof, before opening the tank secondary containment drain valve and before opening the terminal disposal valve. For any water outside of the tank’s secondary containment, the water is discharged close to the manifold,
TMEP uses water treatment to treat muddy water.

Tank 104:
TMEP said that tank 104 , 102 and 100 are used as storage tanks and relief tanks. Therefore, they are equipped with a relief system including a bypass (heat traced) (see picture “Relief Tank system”).
Foam system:
The current foam system (see pictures Foam system #1, #2 and #3) is used only for tanks 104, 101, and 102 since they are currently active,
A new foam system with separate capacities will be used for tanks 100 and 103.

Review of documentation and records:
IOs verified Ganotec’s documents for the tank 100 construction (see picture “Ganotec documents”)

In Binder #3: Standard of acceptability API 650, CER IO checked:

The visual examination reports of annular rings,
Magnetic particle examination (MPE) reports of annular rings,
Radiography report,
Beam alignment and CP layout,
Calibration certificates (thermometers, clamp meters, arc welding equipment such as Red D-Arc Lincoln Flextec 350X)

Also, CER IOs checked the WPS related to plate welding, (KIC-1 rev3) and found that the WPDS at the tank 100 construction site did not reflect the WPS (see picture “Tank 100 WPDS”) in the matter of minimum pre-heat temperatures:

WPS KIC-1 rev 3 (amended to reflect ASME Section IX) indicates that the minimum preheat temperature shall be 38 °C.
The WPDS PSR408A indicates minimum preheat temperature shall be 0 °C in reference to API 650.

CER IOs discussed this Non Compliance with TMEP that whatever is the correct value for minimum preheat temperatures, the 2 documents must be aligned.
CER IOs also asked TMEP to provide records of the minimum temperature measurements, TMEP couldn’t provide them as it was not recorded. The reason for the minimum temperature not being recorded is that, or and the welding activities completed so far , the minimum temperature of 10 °C was accounted for instead of the 0 °C in the WPDS.

CER IOs checked the document “RT-GP-001-TMEP-REV-001” which indicates the General Radiographic Examination Procedure. In the document “Radiographic Examination Report” (see picture “Radiographic Examination Report”), it is reported in the table that the for the x-ray, the selected wire is B7. However, according to the procedure RT-GP-001-TMEP-REV-001, the wire B8 should have been considered instead (different range of wall thickness).
IOs requested TMEP to provide during the inspection further explanation about the wire selection for the x-ray performed on floor plates welding for Tank 100. TMEP provided it as requested (see Closing meeting remarks).

Compliance tool used: No compliance tool used

Observation 2 - NNC: Tank 100 bottom plates welding WPS and WPDS not aligned

Date & time of visit: 2022-10-21 14:30

Discipline: Integrity Management

Categories:

Facilities

Aboveground Tanks and Pressure Vessels

Facility:

SUMAS (Facility)

Observations:

CER IOs checked the WPS related to plate welding, (KIC-1 rev3) and found that the WPDS at the tank 100 construction site did not reflect the WPS (see picture “Tank 100 WPDS”) in the matter of minimum pre-heat temperatures:

WPS KIC-1 rev 3 (amended to reflect ASME Section IX) indicates that the minimum preheat temperature shall be 38 °C.
The WPDS PSR408A indicates minimum preheat temperature shall be 0 °C in reference to API 650.

CER IOs discussed this Non Compliance with TMEP and said to TMEP that whatever the correct value for minimum preheat temperatures, the 2 documents must be aligned.

Note: the CER IOs also asked TMEP to provide records of the minimum temperature measurements, TMEP couldn’t provide them as it was not recorded. The reason for the minimum temperature not being recorded is that, or and the welding activities completed so far , the minimum temperature of 10 °C was accounted for instead of the 0 °C in the WPDS.

Compliance tool used: Notice of Non-compliance (NNC)

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,
    - (o) establish and implement a process for preparing, reviewing, revising and controlling those documents, including a process for obtaining approval of the documents by the appropriate authority;

Company action required:

TMEP shall confirm that:
- the minimum preheat temperature during welding activites of the Tank 100 bottom plates complies with applicable specifications (WPS or updated WPS) and,
- that its documentation (i.e., WPS and WPDS) will be aligned, including the reference of documents to be updated, date of completion and the list of the modifications.

Due date: 2022-11-04

Date closed: 2022-11-25
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

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