Compliance Verification Activity Report: CV2122-138 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2480
• Inspector In Training 2761T

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Integrity Management

Related events:

• CV2122-282

Rationale and scope:

<p>TMEP Spread 3/4A Construction Inspection (OC-065, AO-003-OC-2)</p>

Compliance tool(s) used:

• Information Request (IR) (3)

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

Regulatory instrument number(s):

• OC-064
• AO-003-OC-2
• OC-065

Observations (no outstanding follow-up required)

Observation 1 - Valemount Field Office and KP517+80 Bending - day 1

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Pipe Condition
• Inspections
• Documentation
• Record Retention
• Updating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Valemount Field Office 

• CER inspectors attended TMEP's safety orientation, reviewed the daily log, and discussed logistics and the plan for inspection with TMEP staff.

KP 517+80 - Bending

• Site-specific orientation and daily toolbox talk were reviewed and signed off by the CER and TMEP staff.
• Hazards associated with the scope of work and the Emergency Response Plan (ERP) were presented and reviewed.
• TMEP contractor Ledcor Sicim Limited Partnership (LSLP) confirmed that a copy of ERP is available in everyone's vehicle. 
• The CER inspectors observed pipe segment TMEP-S3-LTOB-0965 which was rejected because the bending was performed with the longitudinal weld not located within 30 degrees of the neutral axis.
• TMEP staff confirmed that the number of the rejected pipe segment will remain accounted for in the sequence for the construction pipe tally and a new number will be given to the bend replacement.
• TMEP staff also confirmed that the cold bends are inspected for defects and the following measurements are ensured to be met: pipe bending to start at a minimum of 1.8 m from the edge of the pipe; the bend deflection not to exceed 1.25 deg. by length of OD along the axis, maximum ovality of 5 deg. and the minimum bend temperature of 30 deg. C.
• It was confirmed that for this rejected bend, the 1.8 m straight pipe may be reused by TMEP, but the bent section is considered scrap material.
• The CER inspectors requested the inspection report for the rejected cold bend and the MTR information for the pipe as it was shown by the TMEP staff to be linked through the QR code label system applied on the pipe. (Action Item 1).
• TMEP provided the Daily Bending Report for Bend 0965 on March 3, 2022 (i.e., 63049_ElChecklist.pdf). The report includes the pipe specifications, the proper link to the QR barcode, and confirms the rejection of bend number 0965 due to the location of the long seam weld outside of the 30 deg. from the neutral axis. No follow-up is required on this response.
• TMEP staff confirmed that there have been three cold bends rejected on this spread to date, two of which are due to the longitudinal weld not being located near the neutral axis. NCRs have been issued for these bends.
• The rejected bend at this site still requires the inspection report to be completed and therefore does not have yet an NCR assigned to it. 
• The CER inspectors pointed out that due to the rejection of cold bends for a similar cause, the corrective actions required by the NCRs issued seemed to be insufficient, and therefore, the inspectors requested TMEP to provide additional information for the understanding of the systemic issue generating the non-conformance.
• The following were requested to TMEP: the process for issuing the NCRs, a copy of the NCRs issued for the cold bends rejected, and a description of TMEP's new measures and updated corrective actions to address this issue. (Action Item 2).
• As requested, on March 2, 2022, TMEP provided the Project Non-Conformance procedure 01-13283-GG-0000-QA-PRO-0086 Rev 1 and the CV2122-282 IR3 Non-Conformance document previously submitted to the CER.
• On March 3, 2022, TMEP provided two NCRs which were issued on 31 August 2021 and 25 September 2021.
• Following the review of these documents, the outstanding part of Action Item 2 remains the description of the new measures and the updated corrective actions implemented by TMEP to address the cold bending issue with the long seam outside of the 30 deg from neutral axis as it has been identified for the third time at this site location. (Information Request (IR) 1).
• Since the bending report has been completed and provided, the CER inspectors further request the NCR report for the cold bend TMEP-S3-LTOB-0965.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• OC-064

Relevant section(s):

• Quality Management Plan Trans Mountain must file with the NEB, at least 4 months prior to manufacturing any pipe and major components for the Project, a Project-specific Quality Management Plan that includes: a) material/vendor qualification requirements; b) quality control and assurance of pipe, fittings, and components that ensure all materials meet Trans Mountain’s specifications (i.e., processes, procedures, specifications, random testing, inspection, and test reports); c) mandatory documentation of process conditions during manufacture and verification of the conformance of manufacturer material test reports with Trans Mountain’s requirements; d) mandatory inspection requirements, inspector competency training, and qualifications; e) non-conformance reporting and correction procedures; f) change management process; g) commissioning requirements; and h) material handling requirements during transportation.

Company action required:

IR 1

i. Provide the NCR issued for the cold bend TMEP-S3-LTOB-0965.

ii. Provide the outstanding information requested in the inspection observation pertaining to TMEP new measures and updated corrective actions necessary to address the cold bending non-conformance with the long seam being outside of the 30 deg from neutral axis as it has been identified for the third time on this spread. Explain how these measures and corrective actions align with TMEP Quality Management Plan and how they ensure that this type of non-conformance will be addressed moving forward to avoid reoccurrence.

Due date: 2022-03-31

Date closed: 2022-04-01
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 - Valemount Stockpile Management Site - day 1

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Pipe Storage and Handling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The CER inspectors and TMEP staff undertook the site-specific safety orientation. The ERP was reviewed.
• The ongoing activity at the site was pipe bending. A safety working zone was established.
• The bending machine points of contact with the pipe were observed to be padded with neoprene rubber to avoid damage to the pipe.
• The bending procedure was present on-site and presented by LSLP staff. A highlighted requirement on the procedure emphasized that the pipe should not be bent within 1 m from the girth weld nor within 1.8 m from the end of the pipe. It was confirmed that this was a specific task focus intended to the personnel as a corrective action from the past rejections. 
• LSLP's bending inspector was on-site and presented, upon request, a copy of the past non-conformances including the corrective actions. TMEP's bending inspector was also present on site.
• The latest bending inspection report (ie., 2022-03-01-S3-JN) was presented to inspectors.
• The CER inspectors observed the measurements for pipe ovality being taken and marked, as well as the visual inspection of the coating and pipe condition to ensure it is free of dents, wrinkles and buckles.
• TMEP inspector confirmed that a 5% OD ovality and 1.25 deg. by length of OD along the axis are the maximum allowed. For angles greater than 1.25 deg. up to 1.5 deg., a request for interpretation is issued for decision from the engineering group. 
• The CER inspectors also observed the stockpile at the site. Pipe specifications including material standard, specifications, Grade, OD and wall thickness were stamped on pipes.
• The coating information included the flexibility test requirements as per CSA Z245.
• QR code for MTR information was applied to the pipes. TMEP confirmed that this aligns with the stencilling information. The CER inspectors selected a sample QR code to confirm traceability.
• Some of the pipes were missing the cardboard end caps. TMEP staff confirmed that they are being replaced with plastic material end caps for better resistance to the wind. 
• Pipes were properly supported and the coatings appear to be in good condition. The CER inspectors questioned the process for validation of the pipes coating performance and condition.
• TMEP staff confirmed that there is a process in place for coating testing which was previously presented to the CER and it will also be provided to inspectors. (Action Item 3).
• The presentation received on 3 March 2022 states that starting April 2019 onwards, the activities at stockpile sites will include ongoing monitoring and assessment of pipe per a predetermined schedule.
• The inspectors requested information regarding the validation of coating performance for the pipes in the stockpile at the Valemount stockpile site, to confirm that the coating condition and performance are still valid. (IR 2). 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-19 - Oil and Gas Pipeline Systems

Relevant section(s):

• 9.1.9 Coating systems for buried or submerged piping shall be selected, applied, installed, and inspected to protect the installed pipe, components, and production welds from corrosion damage during service, taking into consideration the potential for coating degradation or coating damage to occur during pipe storage, handling, transportation, and installation.

Company action required:

IR 2

In accordance with the statement included in the Stockpile Site Inspection Presentation regarding the ongoing monitoring and assessment of pipe, provide information demonstrating that the pipe coating condition at the Valemount stockpile site has been confirmed to be free of any degradation due to storage, handling or transportation and that the coating performance is still valid. 

Due date: 2022-04-29

Date closed: 2022-05-16
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 - KP527+564 Coating - day 1

Date & time of visit: 2022-03-02 13:10

Discipline: Integrity Management

Categories:

• Pipeline
• Pipe Condition
• Inspections
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The CER Inspectors observed the process of pipe surface preparation for coating by sandblasting.
• A safety zone was established, signs installed and proper PPE was used. Girth weld TMEP-3-SC-0669 was sandblasted and wrapped in plastic foil for protection of contaminants until the coating application.
• The pipe was preheated using an induction coil and the temperature was checked. Minimum four readings per quadrant using a surface contact thermometer were taken by the QA representative who confirmed the minimum temperature of 76 deg. C.
• TMEP staff confirmed that the dew point is checked every four hours or if the climate changes to ensure the pipe surface is at least 3 deg. above the dew point.
• The two-part epoxy liquid coating SP-2888 applied was extended two inches over each side of the uncoated steel pipe area (i.e., 50 mm overlap length). Five dry film thickness measurements requiring 20-40 mils were taken, and the average measurement was marked on the pipe. The coating holiday inspection, hardness test, and visual inspection were performed. No holidays were detected.
• Two adhesive tests (x-cuts) were performed and the coating quality was accepted. TMEP confirmed the requirement of one adhesive test per 50 coating applications or one per shift for each applicator. The adhesive test areas were repaired following a similar approach including surface preparation, preheating, brushing, and testing. Proper coating repair was confirmed. 
• The CER inspectors requested documentation (Action Item 4) including the coating application and repair procedures/coating manufacturer's specifications, coating applicators' qualifications, and the coating inspection report for girth weld TMEP-3-SC-0669, which were provided on 3 March 2022. The documentation was reviewed against the observations and the results of the inspection report for compliance. No follow-up is required on this response.

Compliance tool used: No compliance tool used

Observation 4 - KP528+280 Trench - day 1

Date & time of visit: 2022-03-02 14:15

Discipline: Integrity Management

Categories:

• Pipeline
• Excavations
• Backfilling
• Safety

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• There were no ongoing activities at this site. 
• Imported sand (< 25 mm) to be used for bedding and padding was stored away from the trench. 
• The pipe segments were properly supported with PipePillo supports and the HIFI leak detection system was observed to be installed on the top of the pipe.
• The trench had sufficient depth to provide the required depth of cover for the pipe.
• The ingress/egress paths have ladders installed.
• The trench entry form was reviewed by the inspectors. The form included three names of personnel entering the ditch in the day and it was signed off and dated by the TMEP inspector.
• TMEP staff confirmed that the next steps at this site will consist of removing the trench box and backfilling the pipe. 

Compliance tool used: No compliance tool used

Observation 5 - KP528+498 Tie-In welding - day 1

Date & time of visit: 2022-03-02 15:00

Discipline: Integrity Management

Categories:

• Pipeline
• Welding Operations

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The CER and TMEP staff attended the safety orientation and signed off the required safety forms. The ERP was confirmed to be in place.
• The ongoing activity at the site was the preparation for the tie-in welding (weld number TMEP-3-T-0426).
• TMEP confirmed that the pipe prepared for welding is not high strain capacity (HSC) pipe. It was confirmed that HSC pipe has not yet been welded on spread 3/4A.
• Proper communication, eye contact, and signalling with the side boom operators were observed when staff were walking around the stationary equipment.

Compliance tool used: No compliance tool used

Observation 6 - KP528+498 Tie-In welding - day 2

Discipline: Integrity Management

Categories:

• Pipeline
• Welding Operations

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The CER inspectors and TMEP staff met at Valemount Field Office and discussed the plan for the day which included the inspection of the tie-in welding at KP 528+498.

KP 528+498

• The CER and TMEP personnel arrived on site, attended the site-specific safety orientation, and signed off the field hazard assessment form.
• The trench entry form was reviewed and it was noted to be signed off and dated. 
• The ongoing activity at the site was the cleaning of the root pass using power tools.
• TMEP staff confirmed that due to past higher welding repair rates, the decision was made to clean/grind deeper between passes. This has led to a reduction in the repair rate.
• The pipe was preheated to a min 121 deg. C in preparation for the hot pass welding and the temperature was checked by the LSLP QA representative and the CSA W178 qualified TMEP inspector.
• The time interval between passes was checked.
• TMEP senior welding inspector confirmed that the pipe alignment is completed to a maximum offset of 1.6 mm and the long seam is located at the top side of the pipe.
• It was confirmed that the welders and the welding inspectors have a copy of the Welding Procedure Specification (WPS) on site. It was confirmed that the repair welding procedure is available on site.
• External clamps were observed on the pipe and it was confirmed that they are removed only after 50% of the root bead circumference is completed.
• Splash mats were used for pipe coating protection during the welding process.
• Two welders, one on each side of the pipe, were conducting the hot pass and the first fill welding.
• The TMEP inspector and the contactor's QA representative were taking the welding parameters and recording them in the parameter spreadsheet on the tablet.
• The preheating temperature was constantly taken to ensure it does not fall below 121 deg. C.
• The remaining fill/cap required temperature was confirmed to be a minimum of 50 deg. C and max 200 deg. C.
• Welding electrodes were stored in containers and kept dry at 149 deg. C. The inspectors confirmed the electrode used for the first fill was class 8045 P2 as per Welding Procedure Data Sheet (WPDS) (TMEP-WPDS-04 Rev. 7A) provided by TMEP. The inspectors checked a record of welding parameters taken by the welding inspectors for the root bead. The parameters: Amps 133, Volt 24, travel speed 215 mm/min and heat input 0.89 KJ/mm were within the specifications.
• TMEP staff confirmed that:
  • parameters for tie-in welding are taken on any two passes of one weld as per the welding specification;
  • arc burns or cracks identified during the welding inspection are removed by cut-out;
  • the welding visual inspection acceptance criteria are based on CSA Z662 for production welds.
• The CER inspectors inquired about the past non-conformances reported to the CER regarding the cleaning condition of the pipe ends and how that is being addressed for the tie-in pipe welding. TMEP staff clarified that the issue was identified on the mechanized mainline pipe welding, not for tie-ins. 
• Following the Manual Shielded Metal Arc Welding (SMAW), field personnel prepared the pipe and the welding shack for the Mechanized Flux Cored Arc Welding (FCAW) using the CRC-Evans M300C machine. 
• The CER inspectors requested TMEP to provide welders' qualifications, records of the welding repair rates, and a copy of the WPS. (Action Item 5).
• TMEP provided qualification records for welders #18 and #58 which were reviewed to meet the standard requirements.
• The Welding and Quality Inspection Report of 2 March 2022 including the information related to repaired welds was also provided and discussed at the field office. 
• TMEP also provided the Welding Procedure Data Sheet (WPDS) TMEP-WPDS-04 Rev. 7A, approved by TMEP on 24 November 2021 and which references WPS TMEP-WPS-04 Rev. 1.
• TMEP also provided the SMAW and Mechanized Welding Specification TMEP-MP3904 Rev. 6, issued for use on 28 September 2021. The CER inspectors note that TMEP-MP3904 Rev. 6 was filed with the CER on 24 November 2021 (C16285).
• The WPDS was reviewed for conformance against the TMEP-WPS-04 Rev. 1 previously filed by TMEP with the CER on 26 July 2019 (C00700). The CER inspector's review concluded that TMEP-WPDS-04 Rev. 7A references the proper WPS and the supporting Procedure Qualification Record (PQR) revisions and it includes the appropriate welding requirements.
• It was noted that TMEP-WPDS-04 Rev. 7A references the previous revision of the welding specification TMEP-MP3904 Rev. 5, although the WPDS was approved after the welding specification TMEP-MP3904 Rev. 6 was issued. (IR 3).

Compliance tool used: Information Request (IR)

Regulatory requirement:

• OC-065

Relevant section(s):

• 4. Engineering and safety Trans Mountain must cause the Project to be designed, located, constructed, installed, and operated in accordance with, at a minimum, the specifications, standards, policies, mitigation measures, procedures, and other information included or referred to in its Project application or to which it otherwise committed on the record of the OH-001-2014 proceeding. 111. Joining Programs Trans Mountain must develop Joining Programs and file them with the NEB at least 45 days prior to commencing welding of, respectively: a) field circumferential production, tie-in, and repair pipeline welds, including the tie-in welds between existing segments and Line 1 or Line 2; and b) terminals and pump stations. The Joining Programs must include: i) welder qualification requirements; ii) requirements for welding inspector qualifications and duties; iii) welding procedure specifications; iv) non-destructive examination (NDE) specifications; v) procedure qualification records for welding procedure specifications and NDE specifications; vi) a quality assurance program for field welds and welding procedures; and vii) any additional information that supports the Joining Program

Company action required:

IR 3

i. Clarify the inconsistency between SMAW and Mechanized Welding Specification TMEP-MP3904 Rev. 5 referenced in the Welding Procedure Data Sheet (WPDS) TMEP-WPDS-04 Rev. 7A and the latest welding specification TMEP-MP3904 Rev. 6 which is issued for use and explain why TMEP-WPDS-04 Rev. 7A has not been updated accordingly.

ii. Explain TMEP's process in place to keep WPDS revisions for the project up to date to ensure similar inconsistencies will not occur in the future.

iii. Confirm the welding specification TMEP-MP3904 revision number currently in use for the project.

iv. Confirm that TMEP-MP3904 revision from the response iii. aligns with the Welding Procedure Specification (WPS) TMEP-WPS-04 Rev. 1 and TMEP-WPDS-04 Rev. 7A. 

v. Confirm whether TMEP-MP3904 Rev. 5 currently referenced in TMEP-WPDS-04 Rev. 7A, has been filed with the CER as required by Condition 111 of the Certificate OC-065. If not, provide rationale.

vi. Provide a comparison table among TMEP-MP3904 Rev. 4, Rev. 5 and Rev. 6, explaining the changes from one revision to another including rationale. 

Due date: 2022-05-13

Date closed: 2022-05-16
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 - KP528+805 - day 2

Date & time of visit: 2022-03-03 10:45

Discipline: Integrity Management

Categories:

• Pipeline
• Welding Operations

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The CER inspectors observed LSLP personnel working on the pipe alignment in preparation for the tie-in welding.
• The trench had proper ingress/egress paths and ladders installed.
• The trench entry form was dated and signed off by the TMEP inspector.
• Proper fire extinguisher was observed located at the site.
• Proper radio and visual communication with side boom operators were observed during the pipe alignment activity and when personnel were walking around the equipment on site. 

Valemount Field Office:

• The CER and TMEP staff reviewed the inspection of the day and the documentation requested.
• TMEP staff presented information regarding the welding repairs from the KPI trend for repair, and the record summary for welding repairs for spread 3/4A. The information confirmed the decreasing trend for repairs from 21% in August 2020 to 3.1% in February 2022. The Daily Welding Quality & Progress Inspection Report for spread 3/4A as of 2 March 2022 including the welding repairs rate was also presented. 

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: