Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Kinder Morgan Canada Inc
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
TMEP Spread 2 Construction Inspection (OC-064, AO-003-OC-2 and AO-002-OC-49)
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Observations for Spread 2 Pipeline Integrity Inspection
Date & time of visit: 2021-10-18 15:30
Discipline: Integrity Management
Categories:
Facility:
Observations:
General Observation – Safety
At all visited sites, CER inspectors and TMX representatives reviewed and signed the Site-Specific Orientation forms, including Field Level Hazard Assessment, Work Authorization, Tail Gate Safety Meeting, as applicable.
Observation - Integrity
TMX representatives informed that Midwest Pipeline Inc. (Midwest) was the prime contractor for the Project construction. The CER inspectors met with the TMX Regulatory Advisor, Midwest Quality Assurance Coordinator, and Midwest Quality Assurance Lead to discuss the Project related activities including welding, Non-Destructive Testing (NDT) and coating.
CER inspectors reviewed:
The Welding Procedure Matrix Season 3;
Pipeline Welding Procedure Data Sheets;
Welder Qualification Matrix;
TMW-1A Daily Welding Quality & Progress Inspection Report: The welding record showed that the welding overall repair rate was 3.01%. The overall repair rate was 3.74% for mechanized (automatic) welding SMAW;
Welder Qualification Report;
Inspectors Certificates; and
List of Non-Conformance Reports (NCRs) for Spread 2.
CER inspectors noted that the Welding Procedure Matrix Season 3 did not include High Strength Capacity (HSC) weld procedures and TMX representatives confirmed that no HSC welds were being completed on Spread 2. Additionally, CER inspectors noted that the weld procedures documented in the Welding Procedure Matrix Season 3 had been previously submitted to the CER as per Condition 111.
TMX representatives explained that the repairs have been mainly lack of fusion and none of them required a cut out. TMX representatives confirmed that all welds are 100% visually and non-destructively inspected, using mainly Automatic Ultrasonic Testing (AUT). Where that is not practicable (e.g., on induction bends) the Digital Radiographic Testing (DRT) is used for mechanized welds (SMAW), because they do not have calibration blocks. For manual welds, Time-of-flight diffraction (TOFD) and Real Time Radiographic (RTR) are used.
APPLUS RTD (Applus) was directly contracted by TMX for all NDT activities. Midwest representatives stated that the Project NDT results are quality controlled as follows:
The Project pipe is coated by FBE. Crossing pipes have abrasion resistant layers. TMX has observed coating delamination at the end of five pipes during their storage at the Edson Construction Pipe Yard. The pipes were quarantined for investigation. A third-party investigated into the issue and concluded that the coating imperfections do not require any specific repair. The pipes were installed as regular Project pipes in the field.
CER inspectors inquired if geohazards had been discovered during construction and if the Field changes manual for geohazard mitigation as filed as per Condition 51 had been utilized on Spread 2. TMX representatives confirmed that it had not used the Field changes manual for geohazard mitigation to date.
CER inspectors and the TMX representatives discussed the work plan for the next day.
19 October 2021 Inspection
Edson Construction Site (GPS: 53.5694; -116.5129146)
CER inspectors and the TMX representatives attended the TMX Project Inspectors’ Daily Meeting, at the Spread 2 Construction office. During these meetings, the inspectors discussed the details of ongoing field works, the planned activities for the day, and any potential safety or security issues (i.e., hazards related to equipment, vehicles, weather conditions and work processes) and mitigation measures. Regarding Covid-19, TMX representatives reported that 1153 workers were assigned to Spread 2 on that date, including 5 in isolation and 4 tested positive.
Following the meeting, CER inspectors went in the field to inspect ongoing (active) Project construction sites.
Mainline Coating
GPS: 53.5453150; -116.9784817
CER inspectors observed the following activities that were ongoing at the time of the inspection:
Sandblasting: The sandblaster aims for a qualitative surface finish. The required surface finish is to be cleaned to a near-white finish, or better, as defined by the Project’s specification SSPC-SP 10 (Near-White Blast Cleaning). A Midwest quality control (QC) inspector explained that the Project requires a blasting surface control every 25 welds to verify the adequacy of the blasting. However, they are testing/controlling every weld. CER inspectors observed him conducting some surface profile testing. The QC inspector looks for rust to be removed from the surface, no shadows present, a minimum of 2” of feathering/overlap length of the plant applied coating and takes three surface profile samples from 3 different quadrants of the piping surface. The surface samples are required to be between 2.5 and 4.5 mils.
Girth Weld Coating: The Project requires a Dry Film Thickness (DFT) from 20 mils to 70 mils for all girth welds. The first coated girth weld of the day undergoes X Cut testing. After that, X Cut testing is required for every 50 welds.
Midwest coating supervisor explained that all pipe joints and welds are jeeped 4 times, as follows: after welding, after coating, during bump down (i.e., when the height of wooden skids is getting reduced), and during lowering of the welded pipeline segments.
Mainline Welding
GPS: 53.4837687; -117.4026550
Mechanized welding was ongoing. CER inspectors observed some processes including alignment, preheating, root pass, and temperature verification. When aligning pipe with longitudinal seam welds, the welds are positioned at 10 and 2 o’clock. Workers conducting preheating utilized temperature-indicating sticks to check that the preheat temperature of the pipe is between 80°C and 177°C, to ensure compliance with the prescribed temperature range. CER inspectors noted that the mechanized weld procedures for on Spread 2 require a minimum 50°C preheat. A TMX welding inspector was on site. He explained how he records and reports welding parameters, and how he verifies that preheating temperatures do not reach the maximum limit of 200 degrees Celsius with a temperature probe.
NDT
An Applus crew led by a certified UT technician, CGSB level II, was on site. He explained the calibration process that was ongoing at the time of the inspection. The UT device gets calibrated at the first weld, and after every 10 welds or one hour, whichever comes first. The UT technician explained why and how he rejected the weld number 2-MG-3347 based on Engineering Critical Assessment (ECA), which is the main criteria for the Project’s NDT. However, the criteria of CSA Z662 is used for some more stringent locations such as transitions between pipes with different wall thicknesses.
Back Filling
GPS: 53.4775401; -117.4251795
A Midwest crew was back filling a pipeline segment, following lowering-in. The process involved automated machinery which was separating rocks from good soil (with smaller size rocks that are deemed safe for the pipe), using a continued screening (sifting) system. The good soil was poured on top of the pipe as a first protective layer, while the rocks were removed and put aside. The rest of the back filling was completed with the topsoil originally removed from the excavation.
Tie-in Welding
GPS: 53.4781461; -117.4227749
Both welding inspectors from TMX and Midwest were on site. TMX welding inspector was taking the welding parameters. CER inspectors verified that his last recorded parameters (for the root and hot passes) were within the welding specifications for the pipe being joined (i.e., TMEP-WPS-02).
CER inspectors asked a number of clarification questions regarding the safety of the ongoing excavation:
The location of the permit box was observed to be in the excavation at the top of the trench box. TMX representatives stated that the permit box contained the Excavation Checklist Form and trench box entry documentation. CER inspectors inquired about requirements for the placement of the permit box and TMX representatives referred to the Damage Prevention Plan (01-13283-GG-0000-HS-PLN-0025 R1). Section 5.18 of the Damage Prevention Plan states that “an Excavation Checklist Form shall be on site.” CER inspectors do not find TMX to be in non-compliance with its specification, however consensus was achieved on site that the permit box would be better situated outside of the excavation and was moved immediately by the Midwest foreman. Additionally, TMX representatives commented that placement of Excavation Checklist Forms could be improved and committed to such improvements.
The safety regarding the site delineation, and its access and egress - CER inspectors observed the excavation trench, where welding staff were working, and noted a number of potential safety concerns: see the Notice of Non-Compliance (NNC) for details.
Hinton Pump Station
GPS: 53.2767594; -117.7427681
The entrance of the site indicates the name of the company and the station, the emergency phone number, and several warnings including no smoking. The site is fenced, and two escape gates are installed. When construction is completed, the site will have three escape gates and one main gate. An emergency gate was tested by the CER inspectors and it operated as expected.
The station includes an existing pump station (pump building) with associated equipment and piping, which is part of the existing Trans Mountain NPS 24 pipeline, and the new pump station with associated equipment and piping that was being constructed for the TMX Project. Each station has an individual local control room, which will be unmanned, mainly controlled from the Edmonton Control Center, and will be operated independently from each other. The existing pump station includes two pump units while the new pump station houses three.
Construction crews were installing the new station’s electrical equipment. CER inspectors’ observations include the following:
21 October 2021 Inspection
Edson Construction Site
The CER inspectors and the TMX representatives attended the TMX Project Inspectors’ Daily Meeting, at the Spread 2 Construction office. The inspectors discussed the details of ongoing field works, the planned activities for the day, and any potential safety or security issues (i.e., hazards related to equipment, vehicles, weather conditions and work processes) and mitigation measures. Regarding Covid-19, TMX representatives reported that 1184 workers were assigned to Spread 2 on that date, including 6 in isolation and 5 tested positive.
After the meeting, CER inspectors went in the field to inspect ongoing Project construction sites.
Leak Detection System Installation
GPS: 53.5445147; -117.0195597
Below is the summary of the observations and discussion between CER inspectors and TMX representatives:
Bending
GPS: 53.5190706; -117.3028040
Buoyancy Control GPS: 53.3603439; -117.6446402
Pipe Stock at the Edson Yard
22 October 2021 Inspection
CER inspectors met with TMX representatives at the TMX Edson construction office to discuss outstanding action items and to finalize the plan for the day. TMX representatives informed CER inspectors that on 21 October 2021, the Project poor boy mechanized welding crew recorded a repair rate of 18.75%, which is above the maximum authorized limit of 10% (as per Section 11.2 of the SMAW and Mechanized Welding Specification, document number TMEP-MP3904). TMX representatives stated that they will implement the approved Project corrective action plan for this welding crew until they confirm that they can confidently continue working below the 10% threshold.
CER inspectors requested that TMX provide:
Gainford Pump Station GPS: 53.3827633; -114.7415003
For the new pump station
For the existing pump station
The poor boy welding
GPS: 53.5366012; -113.9482201
On 3 November 2021, following CER inspectors’ request, TMX provided additional details on the controlled welding and its results, including that “according to the SMAW and Mechanized Welding Specification MP3904 Rev. 6, section 11.2: If NDE results indicate a weld defect rate greater than ten percent (10%), based on the Contractor's actual welding rate for each Workday, the Owner reserves the right to cease all welding operations until the Owner is satisfied that the welding problem has been defined and corrected. On resumption of welding operations, the Contractor shall produce a Controlled Welding Section (CWS) of five (5) to twenty (20) welds, which the Owner shall promptly inspect. Midwest was instructed to begin controlled welding until the repair rate was brought down. The contractor welded an initial lot of ten welds. These ten welds were inspected and found to be acceptable (passed AUT and Visual). The following day the contractor completed an additional ten welds, and this lot was inspected and found to be acceptable. After a discussion, between the MWP welding supervisor and the TMEP senior welding inspector (MWP QC/TMEP QA present), it was agreed upon that the contractor could resume full production welding the next day. It was determined that the repair rate had spiked due to excessive wind, which dissipated the shielding gas and lead to failures due to porosity.”
TMX also provided a copy their daily inspection report (i.e., TMW-1A Daily Welding Quality & Progress Inspection Report – Mechanized GMAW) for 21 October 2021 that CER inspectors reviewed.
HDD site
GPS: 53.5313994; -113.8874169
Compliance tool used: No compliance tool used
Observation 2 - IR No 1: Emergency Shut-Down and Unit Shut-Down systems for the Hinton Station
During the inspection of the Hinton pump station, TMX representative stated that there will not be an individual Unit Shut-Down system (USD) for each pump unit. However, Clause 4.14.3.6 of standard CSA Z662 requires that pump units shall have individual emergency shutdown systems originating from suitably located, manually operated stations to bring the units safely to a complete stop as quickly as practical.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Provide the following:
Due date: 2021-12-15
Date closed: 2022-05-04 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 - IR No 2: Alternate source of Power
CER inspectors could not enter the existing station, as that was not in the initial inspection plan and all the process for a safe entry could not be timely completed on the day of the inspection. TMX representatives explained that this station does not include a permanent power generator, and that there is currently a temporary one on site for in case of emergency. They stated that the UPS system for this station is designed to provide 208V 3 phase and enough capacity to ensure a safe shut down of the station as a permanent power generator would do.
Provide the following information:
Observation 4 - IR No 3: Safety Signs at Stations
CER inspectors observed a no smoking warning on the Hinton Pump Station entrance sign but did not observe a similar warning on the entrance sign for the Gainford Pump Station.
CSA Z662 Clause 10.5.4.2 states that signs indicating that smoking is prohibited shall be displayed in hazardous areas.
Provide an explanation of how the signage at the Gainford Pump Station meets the requirements of CSA Z662 Clause 10.5.4.2.
Date closed: 2022-05-05 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.
Observation 5 - IR No 4: Plastic Isolation for Piping
At the Gainford station, CER inspectors identified a location (on the NPS 24 pipe between the discharge of pump #2 and the suction of pump #3), where the isolation plastic material (between the pipe and its metallic support) was not similar to the other plastic materials through the station. CER inspectors are of the view that the type and shape of this plastic material may not be as per design.
Date closed: 2021-12-15 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.
Observation 6 - Notice of Non-Compliance (NNC): Unsafe Excavation
Date & time of visit: 2021-10-19 11:30
Discipline: Safety Management
On 19 October 2021, during the inspection of the trench (excavation ditch) site for the tie-in located at GPS 53.4781461; -117.4227749, where welding staff were working in, CER inspectors observed a number of potential safety concerns including the following:
CER inspectors requested the Project’s procedures for Safe Excavation. These documents were not readily available on site for CER Inspectors’ review. But, TMX representatives committed to provide them later. Midwest crew started to stabilize the ladder by fixing its base with anchor screws. They also started to reinstall the delineation marks while CER inspectors were present.
On 21 October 2021, TMX representatives provided copies of the requested Project’s procedures for Safe Excavation. CER inspectors are of view that the trench did not meet TMX and Midwest's excavation requirements to ensure the safety of workers and equipment.
Compliance tool used: Notice of Non-compliance (NNC)
TMX is required to conduct the following correcting actions in compliance with the Project’s applicable procedures:
Observation 7 - IR No 5: Safety Signs at Stations (Follow up for IR No 3)
IR No 3 requested an explanation of how the signage at the Gainford Pump Station meets the requirements of CSA Z662 Clause 10.5.4.2 and a statement confirming “Signage at the Gainford Pump Station includes no smoking provisions” was received. CER inspectors require additional details regarding the no-smoking sign locations across the station.
Provide a plot plan of the Gainford Pump Station that identifies hazardous areas and the locations of signs indicating that smoking is prohibited.
Due date: 2022-03-31
Observation 8 - Notice of Non-Compliance (NNC) - Safety Signs at Stations (Follow up for IR No 5)
Date & time of visit: 2021-10-22 10:00
On 24 November 2021, CER inspectors issued the Information Request IR3 to Trans Mountain Expansion Project (TMX). CER inspectors stated in its preamble that CER inspectors observed a no smoking warning on the Hinton Pump Station entrance sign but did not observe a similar warning on the entrance sign for the Gainford Pump Station. On 15 December 2022, in response to IR3, TMX stated that “signage at the Gainford Pump Station includes no smoking provisions.” TMX did not provide additional details. On 22 March 2022, CER inspectors issued IR5 to follow up on TMX's response to IR3. CER inspectors requested that TMX provide a plot plan of the Gainford Pump Station that identifies hazardous areas and the locations of signs indicating that smoking is prohibited. On 30 March 2022, in response to IR5, TMX stated that “Trans Mountain’s Gainford Pump Station is a hazardous area, as indicated by front gate signage. Trans Mountain has amended the front gate sign to include prohibition of smoking.” TMX provided a photo of the amended front gate sign. However, TMX did not provide further information such as the requested plot plan to demonstrate that the Gainford Pump Station was in compliance with the requirements of CSA Z662 Clause 10.5.4.2 during the CER inspection. Based on the background above, CER inspectors was of the view that the Gainford Pump Station was not in compliance with the requirements of CSA Z662 Clause 10.5.4.2 before their inspection on 22 October 2021.
TMX was required to install an adequate no smoking warning sign in the Gainford Pump Station to comply with the requirements of CSA Z662 Clause 10.5.4.2.
Due date: 2022-05-02
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