Compliance Verification Activity Report: CV2122-137 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-137
Start date: 2021-10-18
End date: 2021-10-22

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:

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 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: 

     i.  Every crew NDT technician have a minimum certification level II from the Canadian General Standards Board (CGSB).   
     ii.  A level III from Applus completes 100% review for all welds.
     iii.  A second level review is done by a TMX inspection. He reviews 100% of the NDT for repairs. He also randomly reviews the rest of the NDT results.
     iv.  A third review is done by UPI NDE, which is a third-party engineering company contracted by TMX. It conducts 100% review for all welds.
 
The number of Non-Conformance Reports (NCRs) for Spread 2 is currently 15; with TMX raising 2 NCRs and Midwest Pipelines raising 13 NCRs. TMX representatives were able to produce NCR report NCR-012 on request, which involved the excavation of the Pembina River HDD drag section for installation of trench box resulting in damage to the AC mitigation wire. CER inspectors noted that NCR-012 was reported as S2-MWP-NCR-012 in the March 2021 Condition 105 Quality Assurance Verification filing (C12317). CER inspectors additionally noted that NCR-012 utilized the Request for Interpretation procedure (RFI) and that the corrective action referred to a Quality Bulletin that TMX representatives were also able to produce.   

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  

GPS: 53.5453150; -116.9784817 

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: 

  • All the three pumps were physically installed. The instrumentation and control system was being connected/installed. 
  • The pumps’ suction and discharge piping and yard piping was installed and pressure tested. No pipes were labelled properly yet as it was not part of the ongoing construction scope and will be done as part of another work scope. 
  • A number of bolted piping flanges were observed to have the entire stud chamfer extended beyond the face of the associated nuts and were reasonably consistent throughout the connection. Additionally, serialization tags on completed flanged up joints were observed. 
  • Plastic materials were installed between the piping and its metallic supports for isolation. 
  • The facility will be equipped with one pump building Emergency Shut-Down (ESD) push-button system outside each door of the building and one in the yard near the exit gate. There will not be an individual Unit Shut-Down system (USD) for each pump unit: see the Information Request IR No 1). One main ESD push-button will be installed in the yard (near the main gate) for the entire station (i.e., for both the existing and new pump stations).
  • There is an alternate source of power (power generator) of 87 KW for the new pump station. TMX representatives confirmed that it is capable of operating the station’s emergency shut-down system and emergency lightning, and maintaining any other service essential to the safety of personnel and the public or the protection of the environment. 
  • The local control center for the new station includes an Uninterruptible Power Supply (UPS) system and associated batteries which would provide the essential electrical power in emergency situations where both the gride and power generator become unavailable.  
  • CER inspectors could not enter the existing pump station, as that was not in the initial inspection plan and all the process for a safe entry could not be  completed timely 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. They stated that the UPS system for this station is designed to provide 208 Volts 3 phase and enough capacity to ensure a safe shut down of the station as a permanent power generator would do (see IR No 2).  
  • The louver and ventilation system is integrated with both the Lower Explosive Limit (LEL) and Fire alarms to ensure a safe ventilation or shut down of the pump building as required.
  • Three new Variable Frequency Drive (VFD) buildings were observed and had ESDs outside of man door entrances. One VFD budling was entered and observed to have emergency lighting. 

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: 

  • TMX supervisor was on site. 
  • TMX has planned to install a fiber optic real-time leak detection system along the entire Project pipeline, using a technology developed by Hifi Engineering Inc. (HIFI)
  • ​In all pipeline locations, except Horizontal Directional Drillings (HDDs) and concrete coating segments: 2 fiber optic lines were being installed. One line will be used for leak detection and the other for telecommunication. Each line will be in an independent high-density polyethylene (HDPE) conduit. Both conduits are wrapped together in a HDPE tube for additional protection.  
  • At HDD locations, the construction crew encapsulates 6 HDPE conduits (each containing one fiber optic) in a stainless-steel tubing, so that at least 2 conduits will survive the back-and-forth pulling forces. However, TMX representatives stated that none of the 6 conduits survived at the Lobstick River crossing HDD. TMX is working on drilling a special HDD for the leak detection system, in parallel with the pipeline. HIFI has already determined the optimal drilling distance from the pipeline. 
  • For concrete coating pipeline locations (for buoyancy control or pipe protection at open-cut crossings), 2 independent sets of 2 conduits (each set is similar to those for regular pipeline locations) are installed before the concrete pouring, to ensure the survivability of at least 2 conduits.                  

Bending 

GPS: 53.5190706; -117.3028040                                               

  • TMX and Midwest inspectors were on site. 
  • The maximum deflection allowed in any length along the axis equal to the outside diameter of the pipe (NPS 36) is 1.25° as per TMX specification and the crew was currently bending to 1°. Minimum allowable ambient temperature is -30°C for bending as per TMX specification. 
  • Midwest QC personnel verifies each bent pipe against the design specifications for the Project. Pipe ovality is checked using calipers and the difference between the maximum and minimum diameters is not to exceed 5% of the specified outside diameter of the pipe. Coating is checked visually for anomalies after bending and the longitudinal pipe weld is to be near the neutral axis and within ±30°. In addition, TMX conducts a statistical QC. Both companies document their results in daily reports. CER inspectors requested that a Midwest staff demonstrate his QC process for a specific bent pipe. CER inspectors requested and reviewed a copy of TMX’s daily report for 20 October 2021.  

Buoyancy Control 

GPS: 53.3603439; -117.6446402                                               

  • The Project uses three techniques to ensure buoyancy control, based on sites’ conditions and locations: screw anchor, bag weight, and concrete coating. 
  • This was a concrete coating site. 
  • The concrete wall thickness (WT) depends on the pipe WT at each location.
  • For open-cut crossings, the Project uses thinner WT concrete coatings, for pipe protection only.
  • The curing time is 28 days, during which the temperature must be maintained between 10 and 40 degrees Celsius. A hot air flow was being used in conjunction with hoarding to ensure an adequate temperature on the concrete coating, as it was a cold period. The required minimum strength is 35 MPa.   

Pipe Stock at the Edson Yard 

  • The yard is used to store pipe, valves, HIFI leak detection equipment, etc., for all of the TMX Project (i.e., all spreads).
  • Every received or delivered item gets barcode scanned for traceability. 
  • From 2017 to 2018, some pipes got settled in mud. They were removed from the mud, cleaned, inspected, and damaged coating repaired (with patch) between 3-9 o’clock positions. A total of 475 pipes were affected. 65 of those pipes had some corrosion pitting at the non-coated ends. The pitting got assessed, confirmed to be less than 10% WT, and repaired by grinding.
  • 10 pipe joins were quarantine due to “minor” spots of removed coating or scratches that were identified on them during the receipt QC process. TMX representatives stated that these imperfections happened probably during transportation. The pipes are waiting for further decision, including assessment and/or repair.
  • CER inspectors and TMX representatives made the work plan for the next day. 


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:  

  • A copy of the TMX inspection report for the poor boy mechanized welding crew for 21 October 2021;
  • ​TMX corrective action plan for bringing the repair rate below 10%; and
  • The results of this corrective action plan  
           (see "The poor boy welding" below for more details) 

Gainford Pump Station 
GPS: 53.3827633; -114.7415003                                               

  • Site Safety Orientation: Each station worker gets rapid tested for covid weekly. The start of the shift (Tuesday), then on Sunday.. The last covid case was on 7 October 2021.  
  • The entrance of the site indicates the name of the company and the station, the emergency phone number, and several warnings (see IR No 3). The site was fenced, and two escape gates were installed.
  • The station includes the existing station and the new station that was being built for the Project. Both stations will be operated separately either from the TMX’s Edmonton Control Center or from the local control room (Operator Building) at the Gainford Pump Station. 

For the new pump station 

  • All the three pumps were physically installed. The instrumentation and control system was being connected/installed. 
  • The pumps’ suction and discharge piping and yard piping was installed and pressure tested. No pipes were labelled properly yet as it was not part of the ongoing construction scope and will be done as part of another work scope. A number of bolted piping flanges were observed to have the entire stud chamfer extended beyond the face of the associated nuts and were reasonably consistent throughout the connection. Additionally, serialization tags on completed flanged up joints were observed.
  • One flange was randomly selected to confirm documented gasket material to gasket material installed. The associated tag documented the gasket to be 316 stainless steel and the installed gasket was observed to have green striping suggesting that it was 316 stainless steel. 
  • TMX representatives confirmed that there is a minimum temperature for pipe installation but it has not been an issue as the weather has remained warm and above the minimum requirement.
  • There is an alternate source of power for the new pump station. 
  • One VFD runs the three pumps. An ESD was observed outside of the man door entrance. 
  • The Electrical Services Buildings includes the MCC, UPS, etc. An ESD was observed outside of the man door entrance and emergency lighting and a smoke alarm were noted inside the building.
  • A louver and ventilation system is integrated with both the LEL and Fire alarms. In case of gas leak above 10% of LEL, the ventilation fans start, and the louvers open to exhaust the gas outside the building. If the rate of gas inside the building becomes more than 20% of LEL or if a fire is detected, the ESD shuts the building down, the fans stop, and the louvers close.
  • Plastic materials were installed between the piping and its metallic supports for isolation. CER inspectors identified a location (on the NPS 24 pipe between pump #2 discharge and pump #3 suction) with a plastic material that is not similar to the other plastic materials throughout the station. It appears that the type and shape of this plastic material are not as per design (see IR No 4).
  • This new station is designed to be constructed and operated similar to the Hinton one. As such, they will have similar ESDs, USDs, alternate source of power, and UPS.
  • The anode bed for the CP system was buried and connected to both downstream and upstream piping at the time on the inspection.   

For the existing pump station 

  • This pump station includes 2 pump units. 
  • The main valves at the station are inspected annually, and function tested semi-annually. 
  • The Pressure Safety Valves are inspected and function tested annually, but not more than 18 months.  

The poor boy welding 

GPS: 53.5366012; -113.9482201 

  • This welding crew was conducting mechanized welding on a pipeline segment of 1310 meters long that will be installed at the Industrial Avenue HDD in Spruce Grove, AB.
  • A controlled welding program was implemented as part of the corrective action plan to mitigate the 18.75% repair rate from the day before. 

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. 

  • An Applus NDT crew was working. A level II technician was doing regular AUT. Relevant copies of the Project ECA and CSA Z662 were available with him.
  • ​TMX welding inspector was on site, taking welding parameters (including Temperature) as per procedure. Welders were grinding and cleaning between passes.
  • CER observed a series of fill, cap and hot passes. 

HDD site 

GPS: 53.5313994; -113.8874169 

  • A total of 800 m of HDD drilling was being conducted and the rig was typically running 24 hours a day.  
  • The HDD technicians stated that for pipe outside diameter (OD) of 914 mm, the final hole will be 48”. They have used successive reamers of 12.5” (pilot hole); 36”; and 48” passes.
  • The HDD technicians check the drilling mud for weight, viscosity and sand content.
  • The crew has estimated a pulling force of 150,000 LB for the pipe segment installation. The maximum capacity for the rig is 400,000 LB.
  • Approximately, 250 m was completed regarding the last pass of 48” at the time of the inspection.
  • Two frac-outs were recorded so far at the 560 m and 621 m distances, both occurred during the drilling of the pilot hole. Midwest workers, known as Inadvertent Fluid Release (IFR) Monitors, identified both. No environmental concerns were identified, as the site was an industrial area and there were no water or other receptors. The HDD technicians stated that IFR monitors look at least once every 4 hours or when needed for IFRs. 



 

Compliance tool used: No compliance tool used

Observation 2 - IR No 1: Emergency Shut-Down and Unit Shut-Down systems for the Hinton Station

Discipline: Integrity Management

Categories:

Facility:

Observations:

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:  

  1. Confirm if individual USD will be installed for each pump unit. If the response is NO, demonstrate how the station will meet the requirements of CSA Z662, Clause 4.14.3.6. 
  2. A detailed description of the number of Emergency Shut-Down (ESD) for the entire pump building and USD that will be installed for the new pump building. Provide a map/drawing that show the location of each of them.

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

Discipline: Integrity Management

Categories:

Facility:

Observations:

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.    



 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information: 

  1. A written confirmation that the UPS system at the existing Hinton pump station is designed to provide enough electrical power, so it is capable to safely replace an alternate source of power as required by the CER Onshore Pipeline Regulations (OPR), section 12.
  2. A detailed description of this UPS system, including but not limited to, the output voltage, amperage, and wattage.  
  3. The minimum electricity requirement (in term of wattage, voltage, and amperage) to ensure a safe shutdown of the station, if needed.   

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 4 - IR No 3: Safety Signs at Stations

Discipline: Integrity Management

Categories:

Facility:

Observations:

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.



 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide an explanation of how the signage at the Gainford Pump Station meets the requirements of CSA Z662 Clause 10.5.4.2. 

Due date: 2021-12-15

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 5 - IR No 4: Plastic Isolation for Piping

Discipline: Integrity Management

Categories:

Facility:

Observations:

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.



 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following: 

  1. Confirm that this plastic material complies with the design, construction, and operation specifications of the station; and that it would meet the station’s CP system requirement.
  2. ​If the request in 1. above cannot be confirmed, then confirm that the plastic material will be appropriately replaced. Otherwise, demonstrate that the plastic material would not affect the integrity of the station.  

Due date: 2021-12-15

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 6 - Notice of Non-Compliance (NNC): Unsafe Excavation

Date & time of visit: 2021-10-19 11:30

Discipline: Safety Management

Categories:

Facility:

Observations:

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:    

a)   Inadequate access and egress: A ladder was inappropriately installed at the main entry side of the excavation on unstable soil (trench wall). CER inspectors observed occurrences where the base of the ladder got displaced and/or lifted while workers were walking on the ladder. They also observed instances where workers had to access and egress the trench by directly walking (climbing or descending) on the unstable trench wall, avoiding the unstable ladder.

b)   ​Inadequate marking of the excavation: the delineation mark for the trench was removed when CER inspectors arrived on site, even though the pots were still in place. Midwest representatives stated that they typically remove the delineation marks or safeguards when workers are working in and out the trench, and they replace them when leaving the site (e.g., by night). CER inspectors was of the view that the absence of delineation marks or safeguards was a danger for worker or equipment, as those could fall into the excavation.    

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)

Regulatory requirement:

Relevant section(s):

Company action required:

TMX is required to conduct the following correcting actions in compliance with the Project’s applicable procedures: 

  1. For the tie-in located at GPS 53.4781461; -117.4227749: Confirm that the identified issues were appropriately mitigated; and
  2. For the remaining excavations for the Project: Confirm that TMX Energy will ensure that all other excavations related to the Project will be completed in compliance with all applicable safety requirements. 

Due date: 2021-12-15

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 7 - IR No 5: Safety Signs at Stations (Follow up for IR No 3)

Discipline: Integrity Management

Categories:

Facility:

Observations:

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.



 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

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

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 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

Discipline: Integrity Management

Categories:

Facility:

Observations:

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.



 

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

Regulatory requirement:

Relevant section(s):

Company action required:

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

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

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