Compliance Verification Activity Report: CV1920-399 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-399
Start date: 2019-09-26
End date: 2019-09-27

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Integrity Construction Inspection of the Trans Mountain North Thompson 6 Crossing Decommissioning and Replacement Project (XO-T260-005-2019) focused on the new pipeline segment: welding, NDT, coating, and HDD activities.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Observations of Day #1

Date & time of visit: 2019-09-26 11:40

Discipline: Integrity Management

Categories:

Facility:

Observations:

Trans Mountain representatives informed CER inspectors that:

  1. Somerville was the general contractor for the Project and was responsible for activities such as pipeline joining (welding) and Health, Safety and Environmental Management in compliance with Trans Mountain’s standards and oversight.
  2. Trans Mountain had contracted BRODY Inspection (BRODY) to conduct welding inspection, Non-Destructive Testing (NDT), using radiographic (as primary method) or ultrasonic, and coating inspection. Ultrasonic testing will only be used on the final tie in welds if there is product in the line, otherwise radiographic testing will be used. The radiographic records will be archived by Trans Mountain.
  3. Innovative Pipeline Projects (IPP) was contracted to do the Project quality assurance (QA/QC) on behalf of Trans Mountain.
  4. The HDD section of pipe had been entirely pulled through and the tie-in locations to the existing Trans Mountain pipeline were being strung out.
  5. The HDD did not go as initially planned – it was necessary to pull the drill pipe out, restring and then drill at a higher level in order to avoid hard ground (bed rock), although 170 m of the first 36 inch ream was saved. Trans Mountain representatives are of the view that the cavity that was left by the initial drill path was likely filled in by soft ground.
    • The final drilling plan involved a 12 inch pilot hole and passes of 30 inch and 36 inch (reamers).
    • The ground conditions were too soft for a mud motor (it would have sunk) or too hard in the bed rock area to drill through. The HDD tried to stay just above the bed rock.
    • An inadvertent drilling fluid return (IDFR) took place during the first shot at the pilot hole, however the fluid was contained and there was no fluid release into the river.
  6. Above ground hydrotest (pre-test) had been done on the HDD section of pipe (in accordance with CSA Z662 specifications). A final hydrotest will be done on the entire replacement segment (i.e. the HDD and trenched sections) once the segment is buried.
  7. The project did not involve any field bends. Three cold bends were done in the shop by Proline (the bending contractor).
  8. Proline was given the bending criteria by Somerville and the criteria was verified by IPP. Blackgold was contracted to inspect the bending. 
  9. Six pipe joints, initially uncoated, had been coated with plant applied liquid epoxy (applied at a Corrcoat coating plant) and used for the trenched section of the Project. These pipes were pulled from pipes which were manufactured in 1998 and stored since. They had been sandblasted, inspected, coated, and two of the six joints were pre-hydrotested prior to installation.
  10. CER inspectors reviewed the Project Turnover Package, including:

Compliance tool used: No compliance tool used

Observation 2 - Information Request for Day 1 Observations:

Date & time of visit: 2019-09-26 14:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

During the discussions, a number of documents and additional information were not available on site. CER inspectors requested that Trans Mountain provide these information and documents later.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

 CER inspectors requested that Trans Mountain provide the following:

  1. For the shop bending of three pipe joints, provide:
    • Trans Mountain’s bending specifications that were used by Proline; and
    • The proof demonstrating that these bending specifications were followed.
  2. For the six pipe joints that were shop coated with liquid epoxy: Provide the quality control result confirming that all the coating was completed adequately.
  3. Alignment sheet: Provide the as-build alignment sheet of the HDD Section showing the deviation from the originally planned path. Note: this information was provided before the end of the inspection.
  4. NDT process: Explain the review and approval process (QA/QC) of NDT inspection results. Clarify the levels of review conducted by BRODY, Somerville and Trans Mountain.
  5. Drill Pipe Report: Clarify what was meant by the following statement on the drill pipe report: “unable to determine coating condition due to mud and other debris in tube ID”. Note: The statement is unclear as drill pipe should not have coating.

Due date: 2019-11-08

Date closed: 2020-01-17
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 3 - Observations of Day #2

Date & time of visit: 2019-09-27 08:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

Meeting at Trans Mountain’s Blue River Office 

  1. Arrived at the office for the Trans Mountain site specific orientation.
  2. Trans Mountain representatives confirmed that the emergency response plan was on site.
  3. Reviewed the inspection plan for the day and headed out to the North Pad Construction Site (North side of the river).

North Pad Construction Site Inspection 
  1. CER inspectors and Trans Mountain representatives arrived on the site around 9: 00 AM (GPS: 52.0522238, -119.3274937).
  2. They attended the tail gate meeting, reviewed and signed off the Task Analysis Safety Card (TASC) form, the Daily Toolbox Meeting form and the Safe Work Permit.
  3. The pulled through HDD pipe head was visible along with leak detection fiber optic conduits. These conduits would survive the pull through forces and stresses. The fiber optic conduits were from two different fiber optic leak detection companies. There were 6 fiber optic conduits in total: 2 conduits wrapped together with orange material (cable), another 2 conduits were wrapped together in black material and there were 2 separate stainless steel conduits. Four out of the 6 conduits were in acceptable condition after the pull through. Conduit integrity after the pull through was checked using mechanical means – there were no fiber optic cables present in the conduits.
  4. Trans Mountain representatives stated that as part of the decommissioning of the existing pipeline, the cleaning would be done mechanically by pushing a cleaning pig through, using nitrogen. Portions of the segment will be filled with grout during decommissioning, as per the Decommissioning Plan.
  5. A representative of BRODY was onsite, conducting girth weld coating inspection. On CER inspectors' request, he successfully demonstrated how he conducts a number of coating inspection tasks, including the following:
    • Dry coating thickness measurement to ensure compliance with the 40 to 70 mils requirements;
    • Visual inspection, as done on every coating.
    • Salt testing; and
    • Cross cut testing
  6. CER inspectors observed a mechanical excavation that was being conducted to expose the tie-in section of the existing Trans Mountain pipeline. The inspectors discussed the excavation procedures and safety issues with Trans Mountain representatives, including:
    • Trans Mountain representatives explained that the pipeline was initially located. Mechanical excavators are not used to dig above the pipeline, but only to the sides of it. Compressed air is then manually used to blow over the soil above the pipes. All the work was being conducted under the supervision of safety personnel.
    • A sectionalizing valve will be installed upstream of the tie-in point. Trans Mountain will confirm the existing pipe grade in situ, using metallography, and check carbon equivalency for welding.

South Pad Construction Site Inspection 
  1. After inspecting the North Pad, CER inspectors and Trans Mountain representatives went to the south side of the river (South Pad: GPS: 52.06172, -119.31618), arriving around 12:18 PM.
  2. They attended the tail gate meeting, reviewed and signed off the Task Analysis Safety Card (TASC) form, the Daily Toolbox Meeting form and the Safe Work Permit.
  3. CER inspectors observed ongoing manual girth weld welding. They questioned welders and the welding inspector (a BRODY employee) about the welding and welding visual inspection processes to verify the adequacy of these processes as per the established welding procedure (which was available on site) and CSA Z662 requirements. The welders confirmed that no welding repairs had been necessary on the project.

Compliance tool used: No compliance tool used

Observation 4 - Information Request for Day 2 Observations

Date & time of visit: 2019-09-27 12:52

Discipline: Integrity Management

Categories:

Facility:

Observations:

During the discussions, a number of documents and additional information were not available on site. CER inspectors requested that Trans Mountain provide these information and documents later.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

CER inspectors requested that Trans Mountain provide the following:
 

  1. Decommissioning of the replaced/existing pipeline section: Provide a copy of the decommissioning procedure/plan describing:
  1. Two copies of holiday repair results for girth weld coating (documented in Somerville’s report).
  2. A copy of the Project NDT procedure. Note: BRODY representatives stated that BRODY had been using their own procedure (approved by a Trans Mountain engineer).

Due date: 2019-11-08

Date closed: 2020-01-29
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 5 - Information Request - NDT and Coating Inspection Processes

Date & time of visit: 2019-09-27 12:52

Discipline: Integrity Management

Categories:

Facility:

Observations:

During the inspection, CER inspectors observed that BRODY was the contractor conducting the coating inspection. BRODY was also the contractor conducting welding inspection and the NDT of welding. However, Trans Mountain's representatives on site could not provide a number of clarifications regarding the completion of the Project's overall coating, coating inspection and the review of NDT results. These clarifications were related to the specific roles and responsibilities of each companies intervening in the pipeline construction (i.e. Trans Mountain, BRODY and Somerville) in order to ensure that potential conflicts of interest would be avoided.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Trans Mountain is required to provide the following:

  1. the documented quality assurance report for the coating application and inspection, demonstrating that the coating already completed before the CER inspection met the Project specifications (and not subject to bias or underperformance due to conflicts of interest otherwise avoided by adhering to section 54 of the Onshore Pipeline Regulations (OPR));
  2. the demonstration that it has implemented an effective process to ensure that the remaining portion of the Project coating will be completed in compliance with the requirements of section 54 of the OPR.
  3. the documented quality assurance report for the welding, NDT and NDT inspection, demonstrating that all related works already completed before CER inspection met the Project specifications (and not subject to bias or underperformance due to conflicts of interest otherwise avoided by adhering to section 54 of the OPR);
  4. the demonstration that it has implemented an effective process to ensure that the remaining portion of the Project welding and NDT will be completed in compliance with the requirements of section 54 of the OPR.

Due date: 2019-11-08

Date closed: 2020-01-13
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