Compliance Verification Activity Report: CV1920-294 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2696
• Inspector In Training 2751T
• Inspector In Training 2879T

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Integrity Management

Rationale and scope:

Construction inspection for the NGTL West Path Delivery Project to construct and operate approximately 21.5km NPS42 pipeline near Cochrane. Project includes 2 compressor stations and 2 HDDs (Bow River and the proposed Springbank Off-Stream Reservoir)

Compliance tool(s) used:

• None

Facility details

Facilities:

• WESTERN ALBERTA M/L LOOP - NPS 42

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XG-N081-005-2019

Observations (no outstanding follow-up required)

Observation 1 - 25 October 2019 - Observations

Date & time of visit: 2019-10-25 09:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling
• Pipe Condition
• Pipe Storage and Handling
• Coating
• Procedures

Facility:

• WESTERN ALBERTA M/L LOOP - NPS 42 (Pipeline)

Observations:

Documentation Review (Field Office): 

• CER inspectors reviewed the Project related joining procedures on file at TC Energy’s (TC) Field Office. Review performed on the welder qualifications indicated that the certification met the requirements specified in CSA Z662-19. TC provided a list of qualified welders which also reported the Welding Procedure Specification (WPS) each welder was qualified to, and the ultrasonic test results documents.
• The Company stated that 9 of the initial 37 welds required repairs. Due to the high rate of repairs, TC reviewed the work of each welder and made changes to their welding personnel. Since these changes were implemented, of the over 80 welds undertaken, 3 repairs were performed. TC stated that the repairs were due to stacked flaw and attributed to operator error. Any repairs undertaken were assessed to the standards of acceptability for ultrasonic inspection in CSA Z662-19 Clause 7 (workmanship criteria) for that weld area.
• CER inspectors reviewed the engineering critical assessments (ECA), visual inspection records, and non-destructive examination (NDE) records summary. 
• TC stated that 100% low hydrogen process was used for the mainline automated welding. Therefore, there was no delay required prior to automated ultrasonic testing (AUT) of the welds. For the tie-in welds, phased array ultrasonic testing (PAUT) was conducted after the delay time as per TC’s welding specification. TC also stated that as per TC Energy’s welding specification TES-WELD-PL, the 24 hour NDE delay requirement may be waived if low hydrogen welding electrodes are used for the fill and cap passes, and the request has been approved by TC welding and materials engineers. The project has used a -45°C welding procedure for the bulk of the project which is cellulosic root, hot pass, and the remainder low hydrogen electrodes. Welds completed with full cellulosic are subject to the full 24 hour delay. The Senior Welding Inspector tracks and logs all welds on the project and all welds receiving a 12 or 24 hour delay are tracked.
• The ECA for the weld acceptance criteria was provided to the CER inspectors. 

• When the CER inspectors arrived on site, the crew was in the process of a ‘pipe push’ using track boring equipment. The following additional observations were made:
  • The pipe was being holiday tested as it progressed into the bore.
  • Free end of the pipe casing was properly supported by slings off of two side booms.

• When the CER inspectors arrived on site, the coating crew was waiting for the applied coating to adequately cure. The company stated the following:
  • For the sandblasting process, company confirmed that blotter tests are conducted every morning, and if there is a change in crew.
  • Prior to the application of coating, the pipe was heated to approximately 110°C. The pipe is then re-blasted when it cools to 80°C prior to coating. Temperature was measured using a contact thermocouple.
  • The required coating quality assurance activities such as testing for atmospheric conditions, salts, profile, visual, dry film thickness (DFT), adhesion (X-cut), hardness, and holiday detection were confirmed to be performed at pre-determined frequencies.
  • A minimum of 2 inch overlap on substrate coating was utilized for the girth weld, in accordance to company procedures and CSA Z245.30.
  • DFT was measured at several locations and 5 measurements including the averages at the 12, 3, 6, 9 O-clock positions were recorded on the pipe. The acceptable range for DFT measurements for the girth welds between single layer FBE coated pipe joints were between 25 (min) and 70 (max).
  • DFT gauge was calibrated every morning.
  • Holiday testing equipment was verified daily. The unit's Certification of Calibration indicated that the unit was last calibrated on 13 August 2019.

• Holiday testing was observed to be conducted on the completed cured coating section. The result of the holiday testing was recorded directly on the coating.
• Girth welds coated with markings indicating the results of DFT and Shore-D. Additional markings indicated successful AUT and visual inspection results.
• Both the Contractor and the third party company inspectors were present at the site during the inspection. The contractor inspector was qualified to NACE Level 3 and third party company inspector was qualified to NACE Level 2.

• CER inspectors inspected the stockpile site where the following observations were made:
  • The site contained pipe of nominal pipe size (NPS) 42 of varying wall thicknesses.
  • Pipe joints were roped, and well supported.
  • Pipes with the single layer FBE coating were double joints spiral welded. The heavier wall, dual coated FBE (abrasion resistant overcoat) pipes were long seam welded with approximately 18 meters joint length.
  • The stockpiled pipe were a combination of line pipe that was manufactured and coated in Canada, and manufactured and coated in India.
  • Manufacturer applied coating appeared to be in acceptable condition. Internal coating was observed on the pipe purchased from India.
  • Company stated that all the pipe had been inspected once it had arrived at the stockpile site.

• The work site entrances indicated a number of safety warning signs.
• The workers were observed wearing proper personal protective equipment as required by the type of work.
• The excavation areas were fenced or delineated when applicable. Access and egress of open excavations were adequate at the time of inspection.
• Field Level Hazard Assessments were present at all sites.
• The construction activities such as welding, coating, NDE, bending, etc. were halted late morning as a result of high winds.

Compliance tool used: No compliance tool used

Observation 2 - 5 November 2019 - Observations

Date & time of visit: 2019-11-05 09:00

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Excavations
• Lower-In
• HDD/Drilling
• Inspections
• Welding Operations
• Materials
• Procedures

Facility:

• WESTERN ALBERTA M/L LOOP - NPS 42 (Pipeline)

Observations:

UT Review (Field Office): 

• TC’s NDE Technologist reviewed the ultrasonic testing (UT) technology and procedures with the CER inspectors.
• UT Quality was contracted directly by TC to perform NDE.
• A review of the differences between the AUT and the PAUT methods of NDE were provided.
• The Project used an ECA for the mainline girth welds for pipe of wall thickness (WT) 11.5 mm, 14.6 mm and 22.0 mm. The transition welds are required to be assessed to the workmanship criteria. 

• This is the Rocky View Section’s starting tie-in location. The fittings/fabricated ends to be used for the tie-ins were noted to be adequately supported.
• The tie-in location to the Foothills pipeline nearby was exposed. TC confirmed that the pipe material at the tie-in location would be tested to ensure that it was suited for welding. The tie-in was planned to be performed during the January 2020 outage.
• Signs are observed to identify the presence of existing pipelines.
• A hydrovac excavation was conducted at a pipeline crossing nearby (51.03434,-114.47292). TC stated that the procedure requires that no mechanical excavation be performed 1.5 m from foreign lines.

• TC stated that a welding inspector was assigned to each welding crew. The welding inspector was present on site at the time of the CER inspection.
• Welding was being conducted to the PL-BG-GW-08 welding procedure.
• Cellulosic rods were being used for the all the weld passes. 
• TC discussed the procedures for sign-off, storage and discard of the weld rods.
• CER inspectors noted the welder numbers of the welders performing the welding, and verified their qualifications to meet appropriate qualification requirements.

• The 333 m of NPS 42 pipe joints for lowering in the ditch was properly supported. TC confirmed that the pipe section was pre-tested for holidays.
• TC confirmed that the lift plan was discussed with all the operators. A total of 6 side booms were being used for the procedure. Each side boom had a spotter assigned. Communication between crew members was performed using radio.
• TC stated that the pipe roller cradles were visually inspected and operationally checked daily and before being used in a lift. The trench bed was checked for rocks prior to lowering in.
• The trench was observed to be approximately 2.5m deep. The depth of cover for the section was to be a minimum of 1.2 m.
• Lowering in activities were stopped as workers determined the conditions to be too slippery to continue safely.
• TC confirmed that holiday detection is performed before lowering in and is only valid for 24 hours. Since work was stopped, the pipe joints to be lowered in would likely need to be checked again when work resumes.

• AUT was conducted for the entire circumference of the girth weld by a CGSB Level 2 inspector, as per requirements.
• Annex K of CSA Z662-19 was used as the acceptance criteria for welds. Two welds NDE’d during the CER inspection were tagged for repair. The defect was due to lack of fusion - lack of cross penetration. The dimensions and the location of the defect were indicated directly on the pipe.
• The AUT calibration process was observed. Company stated that calibrations are performed every five welds and after each repair.
• Relevant copies of CSA Z662-19 and company procedures were on site, available to the testing technicians.
• CER inspectors verified NDE technician’s certifications in the field.

• The repair rate for the main gang crew was around 2.7% at the time of the CER inspection.
• Company's front end welding inspector was present on site. Visual inspections were conducted on the entire circumference of the weld each day.
• Welding parameters were to be taken at a minimum of one in ten welds. CER inspectors confirmed the parameters were being recorded and reviewed the parameter records of a recent weld.
• The weld areas were observed to be preheated as per the procedure requirements and verified by the welders using a temperature stick. The adjoining pipes were observed to be positioned and aligned with internal clamps. Internal welding machine was used for the root pass. External passes (hot, fills and cap) were performed by a sequence of welding shacks.
• A thermal sleeve was placed on the weld area to slow down cooling rate until the subsequent shack was positioned and ready to conduct the next pass.
• Each weld was referenced with welder identification numbers for future traceability.
• CER inspectors noted the welder numbers of the welders performing the welding, and verified their qualifications to meet appropriate qualification requirements.

• A company inspector on site verified the bending angle, coating conditions, the presence of any ovality, wrinkles, ripples, buckles and/or any other resulting damage from bending.
• It is observed that the girth welds were clearly marked. TC confirmed that girth welds are not allowed to be bent cold.
• TC confirmed that field bend maximum angles were fixed at 1 degree per pipe diameter, therefore reducing the risk of uncontrolled deformation (buckling) during the bending process.
• It was also confirmed that bending operations do not occur at temperatures below -30°C.

• Drilling activities had been suspended due to a generator failure. CER inspectors inquired about the directional drilling tracking accuracy and deviations from the original planned drill path.
• The tracking system contractor confirmed that deviations in the drill path were monitored to ensure that that the operation would be within the design limits. 

• CER inspectors noted heat numbers of random pipes from different manufactures on the work site and the company provided material test records for each heat number identified. Records reviewed include chemistry composition, strength properties and impact/notch toughness properties.
• CER inspectors noted random welder numbers working on site and the company provided qualification records for each welder number identified. Records reviewed include what specific weld procedures a welder was qualified for, the test records for each individual weld procedure and a corresponding pass or fail score.

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: