Compliance Verification Activity Report: CV2223-142 - TransCanada Keystone Pipeline GP Ltd.


Compliance verification activity type: Field Inspection

Activity #: CV2223-142
Start date: 2022-07-06
End date: 2022-07-06


Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):


Rationale and scope:

Dig Inspection for Keystone

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Inspection Report

Date & time of visit: 2022-07-18 15:00

Discipline: Integrity Management




Safe Excavation/Evaluation Pressure (SEP):
TransCanada Keystone Pipeline GP Ltd. (TCK) supporting document:
- Attachment 1- 2021 Safe Dig Pressure Tech Memo KS5 Additional Digs Rev 1.pdf

CER inspector asked TCK to provide actual pressure within the line.
This pressure is verified daily by the TCK supervisor after calling TCK OCC (Oil Control Center). During the inspection, the pressure was communicated to be 2773 kPa.
In the Excavation procedure checklist (see IMG_0746.JPEG), the safe excavation pressures indicated were 8432 kPa (for GW 50540) and 8122 kPa (for GW 62000).

Safety Management:
- TCK's general supervisor presented its JSA and FLHA and checked the emergency response procedure (ERP) (a more recent one was in place at the time of inspection, TCK will provide the CER with this updated document).
- The ditch areas had temporary fencing erected to control access
- Excavation ingress/egress was via two temporary staircases
- The excavation slope appeared to be within the requirements
- The exposed pipe section appeared to be properly supported with timbers as required
Specific to dig site GW50540: 
- CER inspector asked TCK to provide the actual Depth of Cover (DoC) for the daylighted pipeline. TCK said the minimum DoC was 1.4 m with a trench depth of 2.8 m.

Emergency Procedures:
TCK supporting documents:
- Attachment 2 - E025686 GWD 50450 Emergency Response Plan.pdf
- Attachment 3 - E025686 GWD 62000 Emergency Response Plan.pdf

During the inspection, the ERP available at each dig site was an updated version of the above. TCK provided the updated documents on the 7th of July (see Attachments 6 and 7).
TCK said that the ERPs are communicated to each contractor prior to the start of work and are readily accessible and contained in a hermetic red cylinder attached to each dig fence (see picture IMG_0740.jpeg)

Right-of-way (ROW) Condition:
From the adjacent roads, wood mats have been installed by TCK to facilitate access to the dig sites (see pictures IMG_0737.JPEG and TC_00515.JPG). At the start of the “mat path”, staff was instructed to spray decontaminant on their safety boots.

Pipeline Identification:
Signs indicating the presence of an oil pipeline were in place at each side of the road crossing next to dig sites (see pictures IMG_0749.JPEG and TC_00532.JPG).
CER inspectors noted the presence of a parallel Enbridge oil pipeline (see pictures IMG_0743.JPEG and TC_00531.JPG).
Warning signs on the mat paths were also visible (see picture IMG_0745.JPEG).

Applicable Procedures and available documents on site:
Upon the CER inspector's request, TCK's general supervisor presented several binders that are readily accessible to personnel working at the dig sites (see picture TC_00537.JPG).

CER inspector verified the contents of the binder, and confirmed that the following documents were available:

Record keeping is done by TCK Quality Assurance (centralized), retention depends on the nature of the documents.

TCK provided the CER inspector with the NDE personnel qualifications and the list of the tools used for NDE with their calibration certificates (e.g., see picture IMG_0739.JPEG for laser scan).

The TCK's general supervisor confirmed that a safety data sheet that detailed the contents of the product in the pipe was available onsite.

Pipeline and Feature locations:
TCK explained the method used to locate the features and ensure the dig is performed at the correct location. TCK excavation procedure was available on site.  TCK stated that it excavates the full joint plus a minimum of 500 mm upstream/downstream and this was observed by CER inspectors.

For both sites, the soil type mentioned in the records is TYPE C which is found in the field to be a mix of sand and clay (see pictures TC_00526.JPG and IMG_0740.JPEG

Assessment Data:
TCK supporting document:
- Attachment 4 - Liquid Pipeline Defect Assessment and Repair Procedures Rev 02.pdf
A dig sheet was provided to the CER inspector with all the relevant information and reference to TCK supporting procedures.

NDE Activities:
Specific to GW50540, during the inspection Acuren performed:

- A Wall Thickness baseline verification every metre along the seam weld - an average of 9.8 mm was measured.
To prepare for NDE activities, the previous coating (fusion bond epoxy) was sandblasted and removed along the entire longitudinal weld of the pipe joint and to approximately a foot on either side by Barrier Group. CER inspectors observed the pipe joint in this condition.

- A 3D laser scanning to measure roof topping. TCK is using an HandyScan tool and the Rapid 3D company for modelling.
- Phased Array/TOFD (Time of Flight Diffraction) of the EMAT ILI (Inline Inspection) calls. Acuren verbally indicated that it did not find any cracking or linear features. One explanation is that the EMAT may call seam weld offsets (known as a potential finding on this pipeline) as crack-like features, but this will be formally documented by the company and confirmed by CER inspectors when the NDE Reports for KS5 GWD 50450 are submitted as requested via IR.

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:

- 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