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

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-138
Start date: 2022-03-01
End date: 2022-03-04

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

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

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

Discipline: Integrity Management

Categories:

Facility:

Observations:

Valemount Field Office 

KP 517+80 - Bending

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

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:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

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. 

IR 5

Provide TMEP's rationale for determining that the testing conducted at the Edson stockpile is representative for the Valemount stockpile and the remaining stockpile locations for the project, giving consideration to the different plants (pipe manufacturers) where the FBE was applied, as per the CER records. 



 

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:

Facility:

Observations:

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:

Facility:

Observations:

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:

Facility:

Observations:

Compliance tool used: No compliance tool used

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

Discipline: Integrity Management

Categories:

Facility:

Observations:

KP 528+498

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

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. 

IR 4

i. Clarify whether changes to the SMAW and Mechanized Welding Specification TMEP-MP3904 Rev. 6 regarding the Alignment and Fit-up which are listed in the response f) to Information Request (IR) 3, are considered changes which impact the implementation of welding in the field.
ii. Describe TMEP's management of change process in place as required by CSA Z662-19 Clause 3.1.2 to maintain the Welding Procedure Data Sheet (WPDS) up to date including the appropriate requirements and reference the appropriate revisions of the welding specification.
iii. Explain how changes mentioned in request i) above, have been communicated to, and applied by the field personnel during the welding process.  IR 6

Provide evidence to support the statement in the IR 4 response c), demonstrating that the process described has been implemented at the field level and, therefore, all relevant TMEP and GCC field personnel have been informed and have applied the changes to the alignment and fit up for welding process included in TMEP-MP3904 Rev. 6. 

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:

Facility:

Observations:

Valemount Field Office:

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