Compliance Verification Activity Report: CV2223-104 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2223-104
Start date: 2022-10-26
End date: 2022-10-28


Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):


Rationale and scope:

TMEP Inspection of Spread 6/7A

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Additional Project-specific requirements or conditions:

OC-65 Certificate for line 2 Condition 104 for alignment sheets Condition 70 for Strain Based Design pipeline area Condition 111 for welding Condition 114 for NDE/NDT (delayed NDE)

Observations (no outstanding follow-up required)


Date & time of visit: 2022-10-26 08:55

Discipline: Integrity Management




DAY 1 (spread 7A)
DPI project, site #1 (114 av Fraser Heights, Surrey, BC)
CER IOs asked about the average repair rate for welding activities on Spread 6. TMEP said it is around 7.9%. Some girth welds (GWs) on this site have been repaired (see pictures “DPI site #1 GW repair 1” and “DPI site #1 GW repair 2”).

CER IOS checked and confirmed that the joint marking was effectively indicated on the coating spec (including CSA Standard designation & year of publication: CSA Z245.20-18, and flexibility test temperature FM30C). The pipe joints are coated with an Abrasive Resistant Coating (brown colour) (see Picture “Pipe Marking”).

There is a sticker with both QR and bar codes on each pipe joint (see Picture “QR and bar codes”). TMEP explained that these unique IDs were scanned into Trans Moutain’s Asset management database (Vintri software, see Picture “Trans Mountain Asset data sample”) to ensure traceability of asset data (e.g., pipe number, parameters, and Material Test Report (MTR) info) for future operation.
Several casings on site were stored waiting to be installed for the DPI crossing. (See picture “Casings”).
TMEP mentioned that once the DPI is completed, the casing will be removed and disposed of.

HDD project, site #2 (168 St, Fraser Heights, Surrey, BC)
Welding activities: (see picture “DPI second site welding”)
CER IOs checked:

Non Destructive Examination (NDE) activities:
While the CER IOs were on-site, APPLUS RTD was conducting Automatic Ultrasonic Testing (See Picture “AUT Applus”).
TMEP mentioned that the AUT is the technique used on this project except when the velocity parameter is not known, therefore X-rays are used.
CER IOs checked the following:
CWP 45 bending site (176 St, Anniedale, Surrey BC)
TMEP stated that all field bending for spread 7 is performed at this site. Some factory-produced bends are also shipped to this site before moving them to actual construction sites (See Picture “factory produced bends”).

Bending activities: (see picture “IMG_0047 Bending”)
CER IOs noted the following:
Site #3 (Redwoods golf course, Langley BC)
Direct Pipe Installation (DPI) project site #3 (see picture “DPI Site #3 Golf Course” and “DPI site #3”)
CER IOs checked the DPI activities and noted the following:
Horizontal Directional Bore (HDB) site (see pictures “HDB Site Pull Up”, “HDB Site side booms”)
TMEP said that the crossing will be approximately 225 m at a maximum of 16.5 m deep. The borehole (see picture “HDD Site borehole”) is 40 inches and the hole is not cased.

CER IOs verified the following: Once installed, a resistivity test of the HDD crossing will be performed to detect potential damages. CER IOs observed that during the pull-up coating was repaired and asked TMEP to provide the report at the end of the inspection.

All the coating repairs are noted in a notebook by the coating inspector.

TMEP mentioned that any coating damages that occurs below grade during pullback is measured by coating resistivity after installation, the ratio will provide an estimate of the damages (TMEP follows NACE TM0102, Table 5 acceptance criteria for coating conductance testing).

Four fibre optic cables are attached to the pipeline segment (see Pictures “HDD start_4 fiber optic cables” and “HDD Pipeline - 4 fiber optic cables”). TMEP explained that for standard use, there are two fibre optic cables attached to the pipeline through the golf course (see Picture “Pipeline - 2 fiber optic cables”): one will be used for pipeline monitoring purposes, and the other will be rented out; however, in this case of HDD, a total of 4 are attached for redundancy purpose.

CER IOs also witnessed pulling activities occurring during the inspection (see pictures “HDB pulling #1” and “HDB pulling #2”).

Note: for accuracy, Pictures “HDD start_4 fiber optic cables” and “HDD Pipeline - 4 fiber optic cables”, correspond in fact to HDB site instead of HDD.
DAY 2 (Stockpiles and spread 6)
Stockpiles (see picture “Stockpiles #1”):
TMEP and Michels provided the CER IOs with some explanation of the overall process related to pipe joints management (handling, loading, stockpiling, traceability): In the stockpile area, CER IOs noted pipes joints with standard coating, ARO coatings, casings, valves, bare pipe for welder’s qualification tests, and fibre optics reels. CER IOs also verified that the pipe joints were properly stocked, capped, and marked (see pictures “Stockpile #2”, “Stockpile #3” and “Stockpile #4”).  Some rectangle-shaped coating repairs (see Picture “Rectangle-shaped coating repairs”) were observed at the stockpiles, which were referred to as “manufacturing coating repair”. TEMP clarified that when the coating damage was identified before shipping pipes to the construction sites, the coating repairs were performed by the coating company or its contractor The repairs were executed according to the field coating repair procedures. 

Welding activities (site #1 Chilliwack, Fairway St)
CER IOs verified the following:
CER IOs confirmed with TMEP that the joints installed along the spread (As-Built) aligned with alignment sheets (As-Designed) at KP 1093+531 (see Pictures “Alignment Sheet 1” and “Alignment Sheet 2”). A segmentation list (see Picture “Segmentation list”) was presented to the CER IOs. This list is updated in the field if needed and modifications are reflected in the alignment sheet. So far, TMEP confirmed that there were no deviations from the alignment sheet.

CER IOs also observed that above line 1 and line 2, there was approximately 2-3 m of topsoil pile and an excavator on top of that (see picture “Topsoil + excavator on top of line 1 and 2”). CER IOs asked TMEP to provide their surface loading assessment to ensure that no damage would occur on lines 1 or 2. 

Vedder DPI crossing site (KP 1100+800 – KP 1101) Vedder South Dkye Trail, Chilliwack)
An HDD crossing was in preparation, and TMEP mentioned that the second hook-up was planned for the 28th of October.
Hydrotesting equipment was in place (see picture “Hydrotesting”). The first section pretest was done 2 days ago and the second section 1-hour duration pre hydrotest will be done the 28th of October.
TMEP mentioned that a mainline valve will be installed at this site at the same location as for line 1 and that another valve will be installed on the other side of the crossing (KP 1099+592)

Document review:
CER IOs reviewed the following documentation: And verified that the below WPS and WPDS (see Pictures “TMEP-SA-WPDS-03-rev 5”, “TMEP-SA-WPS-03-Rev 0”, “TMEP-SA-WPDS-04-rev 8”, “TMEP-SA-WPS-04 Rev 1”, “TMEP-SA-WPDS-01-17-2 HSC RP” and “TMEP-SA-WPDS-01-17-2 HSC”) were aligned:
Also, CER IOs checked: CER IOs reviewed TMEP documents related to the evaluation of surface loading as per the observation on spread 6, site #1 Chilliwack, Fairway St (see Pictures “UPI project memo”, “UPI project memo 1”, “UPI project memo 2” and “Design change notice”). The Canadian Energy Pipeline Association (CEPA) software is used. TMEP mentioned that an RFI was issued on the 1st of April 2022 and a Design Change Notice 2021-11-03 only for line 1. The conclusions of the evaluation showed that there was no additional risk to the integrity of line 1.

However, there was no mention of a combination of a soil pile with an excavator. CER IOs requested TMEP to provide further details on how it is addressed.

For line 2, TMEP mentioned that even if line 2 was subject to deformation, it would be captured by the caliper run and the location would be excavated if necessary.

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