Compliance Verification Activity Report: CV1920-293 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-293
Start date: 2020-02-10
End date: 2020-02-13

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Construction inspection for the NGTL s.58 North Central Corridor Loop (North Star Section 1) Project to construct and operate approximately 31 km of NPS 48 in Northwestern Alberta

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 for Day 1

Date & time of visit: 2020-02-10 15:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The CER inspectors met with the Project Senior Welding Inspector to discuss the Project-related joining procedures on file. She confirmed that all welds are 100% visually and non-destructively examined (using Ultrasonic Testing). 
TC Energy representatives informed that Midwest Pipeline Inc (Midwest) was prime contractor for the project construction. CER inspectors reviewed the following:

  1. The Welder Qualification Register containing the records of all the welders for the mechanical welding and stick welding processes. Each welder was tested to the indicated Welding Procedure Specification (WPS) and a corresponding pass or fail score was assigned. TC Energy’s criteria for the Project was that all welders be required to have, as a minimum, current ASME Section IX pressure certifications and have been tested in 6G position with F3/F4 consumables and all welding passes being tested in the uphill direction.
  2. The Welding Inspection Binder, including the Welding Procedure Data Sheets. This contains the reports on the daily welding activities that are provided to the Senior welding inspector who creates daily summary reports. CER inspectors reviewed the daily welding quality and progress data. At the time of the discussion, the overall welding repair rate was 9.36%, for a total of 791 welds (for both manual and mechanized weldings). The specified maximum repair rate for the the Project was 10%, before the Prime Contractor be required to implement a corrective for the improvement of welding quality. CER inspectors noted that the repair rate had reached up to 20% at times. TC Energy representatives stated that the high repair rate is a concern, and measures are being taken to address the matter. In this regard TC Energy representatives provided a number of related corrective actions that TC Energy had agreed with Midwest to implement. They confirmed that there have been no cracked weld issues before or after the repairs.
     
    Following these discussions, CER inspectors and TC Energy representatives agreed on the plan for the next day.

Compliance tool used: No compliance tool used

Observation 2 - Observations for Day 2

Date & time of visit: 2020-02-11 07:00

Discipline: Integrity Management

Categories:

Facility:

Observations:

The CER inspectors and TC Energy representatives attended the TC Energy Contractors’ Daily Meeting at the TC Energy Project Construction office located near Manning, Alberta. During these meetings, TC Energy and the contractors discuss the details of ongoing field works, the planned activities for the day, and any potential safety issues (i.e. hazards related to equipment, vehicles, weather conditions and work processes) and mitigation measures.
 
After the meeting, the CER inspectors reviewed the Project Emergency Management Plan and signed off the Project Site Specific Orientation form.
 
Review of the Project Coating Documentation:
 
CER inspectors reviewed some coating Qualification Test Records, including the results of the tests conducted to qualify each coating applicator. The main field coating for the Project is liquid epoxy SPC 2888 (used for the mainline, tie-ins, poor boy, repair, and fabrication pipe welds). Others coatings, primers and paints (e.g. Devoe Bar-Rust 236, Devthane 379, Denso Protal 7125, Denso LT Tape, Denso Paste, Denso 7250 SG, Hempel 17410, Hempel 55610, Kema 250/250-12, etc.) were used for areas such as support sleeves, fabrication pipes, structural, flange connections, cad welds, etc.

CER inspectors reviewed the coating Inspection and Testing Plan (ITP) document # 00425-MPI-QM-ITP-0006 dated 27 November 2019.

Discussion with the Project Non-Destructive Testing (NDT) Supervisor:
 
APPLUS RTD (Applus) was directly contracted by TC Energy for all non-destructive testing (NDT) activities. The NDT Supervisor was a certified UT Level II of the Canadian General Standards Board (CGSB). He confirmed the following:

  1. Every Crew Technician have a minimum certification of CGSB Level II.
  2. Automated Ultrasonic Testing (AUT) is performed for the majority of the welds. Radiographic Testing (RT) is performed mainly on fabricated assemblies and on welds that would be particularly difficult to be tested with UT (if any).
  3. The NDT findings for every production weld and every repair weld are reviewed 3 times as follows: 100% by the NDT technicians in the field, 100% by the NDT Supervisor, and 100% by TC Energy’s Auditor who is CGSB Level II in UT and RT.
  4. For the last 5 days prior to the inspection the average repair rate was about 8.36%.
  5. The NDT assessment for the mainline mechanized welding is being done based on CSA Z662, Annex K - Engineering Critical Assessment (ECA). For manual weldings and repairs the assessment was done using CSA Z662 criteria.
  6. The repair method has been grinding and refilling with low hydrogen electrodes, except for one case where the area was cut out following a failed repair and 2 cases where the original seam welds had a manufacturing lamination. Both lamination defects were identified during the UT assessment process of adjacent girth welds (specially using the Time Of Slight Diffraction method).
CER inspectors reviewed the Procedures Techniques Job #4012321 and the NDT Results Reports. These reports show the tested girth weld (GW) number, relevant pipe specifications, and information related to acceptance or rejection. The GW number is used as a tracking means and linked to the weld’s historical data including repair information.

Valve  NCCA100-0BV Site:
 
CER inspectors arrived at this valve construction site around 11:00 AM. A manual welding crew was welding the site piping, including a crossover to the existing North Central Corridor (NCC) NPS 42. CER inspectors and TC Energy representatives completed the site specific orientation and signed the Tailgate Safety Form. A TC Energy welding inspector was present. The relevant copy of the welding procedure was on site. TC inspector confirmed that the welding parameters are taken each day for one welder (out of 2), for every type of pass. CER inspectors were shown some welding parameters taken on previous days. CER Inspectors confirmed that full circumferential welds were being visually inspected. The TC welding inspector was able to show how the parameters were in the range specified in the welding procedure. He said that repair rate for the crew conducting this welding was 0%. CER inspectors requested a sample of the electrode used for the welding; the electrode presented was labeled 8010-G (equivalent to E5510-G which is required in the welding procedure). The CER Inspectors noted that insulating sleeves were placed on the welds to slow down the cooling rate.
 
CER inspectors observer the excavation trench welding staff were working in and noted a number of potential safety concerns including issues related to adequate access and egress, tench wall cutback angle, and delineation and signage - see the Notice of Non-Compliance for details.
 
NDT Site:
 
A NDT crew was conducting UT on a mainline girth weld. The CER inspectors observed a field technician’s process for assessing a potential defect to determine whether GW ML-A0624 should be tagged for repair or not. He also demonstrated how he assessed and rejected GW ML-A0603 for lack of fusion. Relevant copies of ECA (CSA Z662 Annex K - established for the Project) and CSA Z662 – Workmanship assessment criteria for ultrasonic examination of pipeline girth welds were on the site available to the testing technicians. The UT equipment gets calibrated every one hour or at every 10th tested weld, whichever comes first.

Mechanical Mainline Back-End Welding Site:
 
This welding crew was completed welding at GPS Location: 57.131159, -117.778737. CER inspectors and TC Energy representatives completed the site specific orientation and signed the JSA, Tailgate Safety Form, and Field Level Hazard Assessment. A TC Energy welding inspector was present on site and he had just taken welding parameters of a fill pass, which was confirmed to be within the limits specified in the welding procedure. Welding parameters are taken for each pass on every 15th weld. The CER inspectors verified that the TC welding procedures in use was on site. The welds were preheated as specified in the welding procedure and TC inspector confirmed that welds are ground between passes as needed. 
 
Mechanical Mainline Front-End Welding Site:
 
Mechanical Mainline Welding (GPS Location: 57.1332761, -117.787226): TC Energy's welding inspector present on site was taking the welding parameters. This crew was responsible for conducting the root pass (internal pass) and hot pass on the mainline. The welds were preheated as per the procedure requirements. CER inspectors observed a root pass welding process (using a mechanical internal clamp) and hot pass welding process. The CER Inspectors noted that insulating sleeves were placed on the welds to slow down the cooling rate.
 
The Day summary:
 
CER inspectors and TC Energy representatives did the summary of the inspection activities completed during the day. Following these discussions, they agreed on the plan for the next day.       
 

    Compliance tool used: No compliance tool used

    Observation 3 - Observations for Day 3

    Date & time of visit: 2020-02-12 07:00

    Discipline: Integrity Management

    Categories:

    Facility:

    Observations:

    The CER inspectors and the TC Energy representatives attended the TC Energy Contractors’ Daily Meeting, at the TC Energy Project Construction office. During these meetings, TC Energy and the contractors discuss the details of ongoing field works, the planned activities for the day, and any potential safety issues (i.e. hazards related to equipment, vehicles, weather conditions and work processes) and mitigation measures.
     
    After the meeting they went on the Right-of-Way to inspect ongoing field activities.
     
    Meikle River Compressor Station:

    CER inspectors arrived at the Meikle River Compressor Station (GPS location 57.189193, -118.192424) around 10:45 AM, where the Project pipeline will tie-in. The station will also house the pig launcher. Piping installation was in progress. CER inspectors observed the lowering of a bent pipe in the ditch and the alignment in preparation to its connection to the pig barrel. At this location there are some existing operating lines. Therefore hydro-vacuum was being used to carefully expose the existing facilities before trenching for the new final tie-in line. TC energy inspector explained the connection between all the lines and the launcher under construction and the process used to safely install the new line without damaging the existing lines.
     
    CER inspectors observed the excavation site where welding workers were completing the piping assembly and noted a number of potential safety concerns including issues related to adequate access and egress, delineation, and signage - see the Notice of Non-Compliance for details.
     
    Valve NCCA100-0BV Site:
     
    CER inspectors arrived at this valve construction site around 12:05 PM to verify the mitigation implemented by Midwest related to the trench safety. At that time, a NDT crew was conducting RT on the assembly welds completed the day before. However, the test results were not yet available for review. CER inspectors observed that additional ladders were installed in the trench, stairways were reworked to improve the steps, hand rails were added to a stairway, the trench was delineated, and safety warning signs were installed. However, the tench wall cutback angles appeared unchanged (i.e. appeared to be inferior to the minimum requirements of both TC Energy and Midwest).
     
    Mainline Coating Site:
     
    CER inspectors arrived at this coating site at (GPS Location : 57.123203, -117.737937) around 13:50 PM. A TC Energy coating inspector was present. She explained how each girth weld coating is marked and tracked with information such as the weld ID, the applicator ID, and the verified dry film thicknesses as per the coating Inspection and Testing Plan (ITP). She also explained that the potential pipeline segment holidays are identified during three jeeping processes. The first jeeping of all coatings (i.e. plant and field applied coatings) to find the existence of any holiday from transport and hauling, the second jeeping of the entire welded pipeline segment, except the portions above supportive wooden skids, within 24 hours of the lowering-in, and the third jeeping during the lowering process to specifically target the portions previously above supportive wooden skids. CER inspectors observed a number of coating activities including sandblasting, preheating with induction, mechanical/automatic coating application (using liquid epoxy), and newly completed coating visual verification and manual repair (as needed). At CER inspectors’ request, Midwest coating supervisor and a coating quality control worker demonstrated a number their ongoing responsibilities such as how they conduct salt testing, environmental test, and adhesion testing.   
     

    Compliance tool used: No compliance tool used

    Observation 4 - Notice of Non compliance

    Date & time of visit: 2020-02-12 15:47

    Discipline: Safety Management

    Categories:

    Facility:

    Observations:

    During the inspection at Valve NCCA100-0BV construction site (GPS Location: 57.1182909, -117.723487), CER inspectors observed welding personnel working in the trench (excavation ditch). CER inspectors noted a number of safety related concerns including access and egress, trench wall cutback angles, delineation, and signage issues. At the Meikle River Compressor Station (GPS location 57.189193, -118.192424), CER inspectors noted similar safety concerns, including access and egress, and delineation, and signage issues.
     
    CER inspectors are of view that these trenches did not meet a number of TC Energy and Midwest's excavation requirements, including those provided in section 6.6 of the Project's specific Excavation Procedure (Doc. No.: 00425-MPI-CM-PRO-0001, approved on 10 January 2020).

    Compliance tool used: Notice of Non-compliance (NNC)

    Regulatory requirement:

    Relevant section(s):

    Company action required:

    TC Energy is required to conduct the following correcting actions in compliance with TC Energy and Midwest's procedures:

    1. Install appropriated access and egress;
    2. Implement necessary mitigation measures for trench wall cutback angles;
    3. Add necessary delineation and signage;
    4. TC Energy must submit the proofs and completion dates for each inspected excavation sites and for each item/request above; and
    5. Provide the confirmation that TC Energy will ensure that all other excavations related to the Project will be completed in compliance with all applicable requirements.

    Due date: 2020-03-06

    Date closed: 2020-04-27
    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