Compliance Verification Activity Report: CV2223-102 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1536
• Inspector 2279

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Integrity Management

Related events:

• CV2223-253

Rationale and scope:

Inspection of TMEP Spread 5B construction activities including pipe storage, transportation, stinging, pipe handling, welding, tie-ins, and HDD

Compliance tool(s) used:

• None

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

• Pipeline
• Pipeline

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 - Day 1 (Laidlaw pipe yard)

Date & time of visit: 2022-05-30 08:00

Discipline: Integrity Management

Categories:

• Pipeline
• Pipe Condition
• Pipe Storage and Handling
• Inspections
• Repairs
• Materials
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Popkum Yard Field Office

Safety orientation:
Received an approximate 30-minute safety orientation. Discussion included:

• TMEP hazard identification process
• Driving hazard
• Communication 
• Blue hat policy
• Joint safety committee 
• Weather
• Exclusion zone

• Discussed inspection schedule and possible sites of inspections, including pipe construction work and yard, mainline, and tie-in welding.
  • Possible Boring/HDD sight.
• Nonconformance Report (NCR) written criteria - Each spread has its criteria to determine what is an NCR. Every two weeks, the TMEP quality assurance representatives meet and share NCR information. There are inconsistencies in NCR criteria between spreads and it is not clear how the leading information or learning is implemented within the project improvements. 

• Received site-specific orientation 
• TM provided a presentation on the repair activities, cleaning process, and pipe evaluation process. 
• TM could not access the site until the end of Feb 2022 due to safety concerns associated with landslide and snow/soil deposition. 
• CER asks for the evaluation and acceptance procedure for the pipe materials impacted by the flooding debris.
• TM indicated there has been a new procedure and acceptability criteria developed for the evaluation of the pipe and coating. 

• Observed the following:
  • pipe cleaning activities through a viewport of a cleaning bay; 
  • hot bend pipe cleaning;
  • already cleaned hot bends. Noticed markings that are evidence that coating is evaluated with pipe out of roundness, wall thickness, and stencilling.
  • the stacked pipe which had debris in and around the pipe,

1. Provide the pipe cleaning procedure, evaluation, acceptance criteria, and mitigation procedure. COMPLETE 3 June 2022
2. Provide the presentation that was given to CER inspectors at the Laidlaw yard.  COMPLETE Presentation provided 9 June 2022

Compliance tool used: No compliance tool used

Observation 2 - Day 2 (KP1048 Tie-in welding, Bonatti Sagit Pipe Yard, Mainline Automatic welding)

Date & time of visit: 2022-05-31 07:30

Discipline: Integrity Management

Categories:

• Pipeline
• Excavations
• Pipe Storage and Handling
• Inspections
• Welding Operations
• Safety

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Popkum Yard
Attended and observed the Macro welding crew Tailgate meeting.
Meeting discussed the following:

• Basic safety issues relevant to recent project observations
• Hazards associated with driving and traffic congestion due to work adjacent to highway
• Fatigue

• Planned inspection of mechanized welding, section welding, and tie-ins
• Discussed welding failure and repair rates
  • Informed that to date there had been 79 repairs out of a total of 905 welds that had undergone NDE
  • A breakdown of the repair rate for the mainline welding which included manual and automatic welding processes was 12.4% (using an internal line-up clamp)
  • Section welds had a 6.8% repair rate (using an external line-up clamp)
  • Tie-in welding had a 6.4% repair rate (using an external line-up clamp)
  • 70% of the repairs were identified as side wall lack of fusion (LOF)
  • Reviewed document TMW-1C Daily Weld Quality and Progress Inspection Report that listed the repair rates
• The NDE contractor coordinates the validation of the repair completion
• TMEP indicated that as per specification for some of the welds there is an 18-hr delay for NDE.
• TMEP indicated that as per specification normally only one repair on the same weld and location on the weld is allowed unless the Owner approves otherwise as specified in procedure MP 3904
• There has been a total of 19 repairs ("R2 repairs") that have been approved on the same weld and location on the weld across the whole project
• The CER inspectors requested the criteria used by TMEP when allowing an R2 (i.e., more than one repair on the same weld at the same location on the weld)
• Viewed a sample repair list for an R2 repair which demonstrated the weld was removed by cutout (TMEP-5B-T-0162R2) after the second unsuccessful repair attempt

• Observed the lineup and welding of a production weld on the slip bore
• Observed weld inspector validating the preheat temperature before welding commenced
• The welding inspector was taking the weld parameters with a gauge from the welding cables at the welding truck
• Inspector stated that weld parameters are taken on one weld per crew every day
• The parameters are taken on three weld passes
• Observed a bell hole that was deep and needed shoring south of the tie-in location where the rope barrier at the ditch edge was not up around part of the excavation where fencing was not installed and a sign warning to stay away had fallen into the excavation and was not visible.
• As the location was near homes, a road, and a trailer park laundromat the CER inspector asked why fencing was not around the entire excavation.
• TMEP agreed that fencing would be appropriate and committed to rectifying the situation and immediately undertook to rectify the situation. Note that once the fencing was installed around the remainder of the excavation a photo was shown to the CER inspector

• Observed two pipe joints being unloading from a trailer
• Observed cold bent pipe and determined that the long seam was placed in the neutral axis and the coating was not damaged
• Examined the bending equipment and observed that the equipment was in good order and should not damage the coating during bending

• Visited the mainline automatic welding
• Welding of two joints had just been completed and 2 of the 3 welding shacks had been used
• While waiting for additional welding, CER inspectors became aware that the mainline automatic welding was under a “Controlled Welding” condition
• The “Controlled Welding” condition was imposed by TMEP because the start of mainline welding identified that there was a 50% repair rate due to LOF based on the first few welds that had been completed (3 repairs on a total of 6 welds)
• This “Controlled Welding” condition allows TMEP and the contractor to identify the root cause of the issue and to rectify any welding issues before allowing welding to proceed
• Since the “Controlled Welding” condition had been in place additional welds had been completed, up to 13, with more repairs identified.
• Of the two welds completed while the CER inspectors were on-site, one weld was acceptable and the other weld had a repair.  TMEP indicated that the weld with the repair would be cut out for further analysis to identify the cause of the continued repairs.
• TMEP state that throughout the project there have been other “Controlled Welding” conditions imposed
• TMEP indicated they are unaware of any requirements to inform the CER of the imposition of "Controlled Welding” conditions or to provide more detailed repair rates other than averages. The CER inspector noted that averages would not illustrate areas where elevated repair rates would lead to a “Controlled Weld” condition being imposed.
• The NDE technician discussed the identified repairs
• The CER inspectors requested more information on the NDE acceptance criteria used and the “Controlled Welding” process

1. The "Controlled Welding" designation process which includes criteria to impose, conduct a root cause analysis, and mitigation and acceptance criteria for removal of the "Controlled Welding" designation
2. Welding inspectors' reports for the day that the "Controlled Welding" was issued on the Kiewit/Bonatti spread mainline mechanized welding.
3. Welding inspector and NDE reports for 31 May 2022 for all mainline welding (e.g., mechanized mainline, tie-in).
4. The NDE acceptance criteria used on Spread 5B.
   1. Confirmation that the weld acceptance criteria are solely based on CSA Z662-19 Clause 7.0 and the values can be referenced from Clause 7.0.

Compliance tool used: No compliance tool used

Observation 3 - Day 3

Date & time of visit: 2022-06-01 08:30

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling
• Inspections
• Welding Operations

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Morning briefing

• Met with the TM staff at the site office and collected the daily work schedule.
• Discussed possible CER inspection sites. 
• Discussed the previous day’s welding evaluation and failure rate.
• CER ask TM to provide clarification on the NDE acceptance criteria.
  • Sought clarification regarding if TMEP is using the workmanship criteria in CSA Z662-19 without variance
• Discussed “Controlled Welding” and sought clarification on the process, criteria when it is implemented, who is responsible, and what actions are required to remove the condition

• KP1063+155 Tie-in welding
• KP1064.1 HDD
• KP1036.3 Tie-in procedure at KP1036.255 is WPDS-11-Rev5
• The welding inspector stated that when he takes welding parameters he takes into consideration the IR drop (the voltage drop due to energy losses due to resistance) due to the length of the welding cables and makes an adjustment to the recorded values.
• The inspector indicated that he does not note on the report that he has adjusted the observed and recorded values
• Observed a counter weight being removed from a side boom.  Inquired if the worker's location near the weight was according to the procedure.

1. For welds that have been repaired more than once, provide the weld inspection and NDE report (three of them) and the criteria used to guide when more than one repair is allowed.
2. Indicate the number of "Controlled Welding" conditions on other spreads and how to assure consistency in imposition, analysis, and removal.
3. Related to weld parameter measurements and specifically how the IR drop is considered during the measurement of field weld parameters to verify compliance with the WPS:
   1. Provide any procedure and or criteria used for IR drop measurement among the various weld inspectors 
   2. Is this procedure used on all TMEP spreads?
   3. Highlight if there is a requirement to record whether IR drop is considered during the weld parameter measurements and in the heat input calculations
4. Provide the side boom counterweight removal procedure. 

Compliance tool used: No compliance tool used

Observation 4 - IR 1 (Laidlaw pipe yard)

Date & time of visit: 2022-06-06 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Pipe Condition
• Pipe Storage and Handling
• Inspections
• Repairs
• Coating
• Evaluation Imperfections
• Procedures

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

See 2022-06-07 11:42 Draft Action items from 06 June 2022 meeting for IR
See CV2223-102 IR1 due June 7, 2022 and 2022-06-04 12:41 APPROVED - PTL Consolidated Guidelines for Procedures on Flood Material Recovery and Reclamation - R0 (05-25-2022) for responses.

Compliance tool used: No compliance tool used

Observation 5 - IR 2 (Daily Action Items)

Date & time of visit: 2022-06-07 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Pipe Condition
• Pipe Storage and Handling
• Inspections
• Welding Operations
• Repairs
• Materials
• Coating
• Evaluation Imperfections
• Procedures

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

This IR provides a summary of the responses to the daily inspection observation action items.
See CV2223-102 Inspection Action Items for the IR
See the attached PDFs for the responses that were outstanding from the daily action items.

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: