Compliance Verification Activity Report: CV1920-480 - TransCanada PipeLines Limited, Trans Québec and Maritimes Pipeline Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-480
Start date: 2019-12-11
End date: 2019-12-12

Team:

Regulated company: TransCanada PipeLines Limited, Trans Québec and Maritimes Pipeline Inc.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of meter stations and integrity inspection of the pipeline under the St. Lawrence River for compliance to OPR and CSA Z662 requirements.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Saint-Augustin-de-Desmaures - North Entrance (Saint Lawrence River Tunnel)

Date & time of visit: 2019-12-11 09:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Inspectors noted an area that was tape-wrapped with a rectangle cut out near the entrance of the tunnel.

Please provide a response to the following:

  1. An explanation of why there is a section of the tape-wrapped coating cut out from the surface of the pipe
  2. An overview of the coating system evaluation frequency for the pipe in the tunnel, including the last inspection report 
  3. An explanation why the pipe was tape-wrapped in this location

Due date: 2020-05-29

Date closed: 2021-01-20
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 2 - Portneuf MS

Date & time of visit: 2019-12-11 13:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

MLV 23
 

Compliance tool used: No compliance tool used

Observation 3 - Deschambault MS

Date & time of visit: 2019-12-11 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 4 - Saint Augustin MS

Date & time of visit: 2019-12-12 10:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 5 - Valve site AV24

Date & time of visit: 2019-12-12 11:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

There appears to be some piping which may be classified as a deadleg where there may be an accumulation of product which can lead to increased corrosion. The company indicated that this line was supposed to be connected to a meter station, however this has yet to come to fruition.

Please provide the following:

  1. A plot plan of the piping at this valve site
  2. An explanation whether this piping may be classified as a deadleg
  3. If yes, provide a description of the plan to manage the integrity of this section of pipe and the last corrosion inspection report

Due date: 2020-05-29

Date closed: 2021-01-20
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 6 - Saint-Maurice MS

Date & time of visit: 2019-12-12 13:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

One of the pipe supports appeared to be out of place in the meter building.

Please provide confirmation that the pipe supports are adequately in place to support the pipe and valve within the meter station building

Due date: 2020-03-27

Date closed: 2020-07-28
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 7 - Pointe du Lac MS

Date & time of visit: 2019-12-12 14:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 8 - NNC 1 - Piping Identification

Date & time of visit: 2019-12-11 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER Inspectors noted several locations where the pipe has not been labelled to identify the direction of flow.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide confirmation that the company has implemented the signage requirements of the piping at the sites visited, including direction of flow.

Due date: 2020-05-29

Date closed: 2021-01-20
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 9 - NNC 2 - Coating condition

Date & time of visit: 2019-12-11 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER inspectors noted several instances where the condition of the coating of piping exposed to the atmosphere appeared to be deteriorating

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide the re-coating schedule for the above ground outdoor piping at all sites applicable and the rationale for the selected timelines.  
  2. Provide a corrosion assessment for the above ground outdoor piping
  3. Provide the above ground piping inspection procedure

Due date: 2020-05-29

Date closed: 2021-01-15
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 10 - NNC 3 - Open/Closed Positions of valves

Date & time of visit: 2019-12-11 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER Inspectors noted several instances where the open/closed positions of major valves were not clearly marked.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the schedule for when the deficient valves will have adequate indicators for open/closed positions.  Including AV 24.

Due date: 2020-05-29

Date closed: 2020-11-17
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 11 - Information Request - Taped Flanges

Date & time of visit: 2019-12-11 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

CER Inspectors noted that tape positioned around the circumference of several bolted flanges for leak detection purposes was left in place.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide an explanation of how periodic inspections of the area under the tape can be conducted if the tape is left in place around the circumference of bolted flanges
  2. Provide confirmation that all applicable flanges are accessible for visual inspection.

Due date: 2020-02-28

Date closed: 2021-01-20
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 12 - IR 2.1 - Coating of Pipe in Tunnel

Discipline: Integrity Management

Categories:

Facility:

Observations:

Follow-up IR in regards to the coating of the pipe located in the tunnel.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

TC Energy submitted evidence of monthly visual inspections for the pipe in the tunnel documented in TC/SAP for June-July 2020. The table indicated that Facility Integrity Inspections were conducted on 30 June 2020 and 31 July 2020, whereby one of the actions was to "complete & Attach Required Form(s)".

For the Facility Integrity Inspection conducted in November, 2019, please submit the completed required forms for the visual inspection of the pipe in the tunnel.

Due date: 2021-02-12

Date closed: 2021-02-12
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 - IR 2.2 - Donnacona Sales Tap dead legs

Discipline: Integrity Management

Categories:

Facility:

Observations:

Follow-up IR in regards to Donnacona Sales Tap dead legs

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

TC Energy has identified 2 sections of pipe as permanent dead legs since they have no current or probable future process flow. The OPR details clauses regarding pipe deactivation, decommissioning and abandonment. More specifically, OPR 44 (1) states that if a company has maintained a pipeline or part of one in a deactivated mode for 12 months or more or has not operated a pipeline or part of one for 12 months or more, the company shall submit an application for deactivation to the Commission.

TC Energy stated that the integrity of these dead legs section of pipes is being managed through external and internal piping inspection, but TC Energy has not specifically performed inspections on these dead legs.  Please provide the company's plan to address these specific dead legs.

TC Energy indicated that while they have not specifically performed inspections on the dead legs at the Donnaconna Sales Tap, they have opportunisitically inspected dead legs and drip assemblies in the past and have not found any signs of internal corrosion. TC Energy also stated that the risk of internal corrosion is managed by monitoring the dead legs for evidence of persistent problems or upsets. Data on problems and upsets is incorporated into the threat identification process in accordance with TEP-IN-IC-G(Rev05).

Provide TC Energy's specific program in regards to managing and monitoring the integrity of dad legs.

Due date: 2021-04-02

Date closed: 2021-04-02
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