Compliance Verification Activity Report: CV2223-114 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2223-114
Start date: 2022-11-17
End date: 2022-11-18


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

Integrity Inspection of TMEP Reactivation Segments to verify compliance with the OPR, CSA Z662, and Certificate OC-065.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Document review and hydrotest progress

Date & time of visit: 2022-11-17 09:00

Discipline: Integrity Management




1-    Update on the progress of the hydrotests of the reactivation segments:
TMEP representative stated that of the eleven (11) test sections planned, eight (8) have been pressure tested (sections 1 to 6 and sections 10-11); test section 8 is being filled while test sections 7 and 9 have not yet started.

TMEP indicated that there have been no leaks and no unsuccessful pressure tests for the eight test sections completed.

The test medium for test section 8 is a mix of methanol (23%) and water (77%). TMEP representative explained that for the drawdown of the test medium, the JHA identified fire from ethanol vapour as a possible hazard, the control is the elimination of ignition sources.

TMEP indicated that the sections are tested as follows: a 4-hour strength test followed by a 4-hour leak test and by a 16-hour pressure hold at the maximum operating pressure (MOP).

2-    Update on the progress of valve installations.
Fourteen (14) of the valves have been installed. Seven (7) valves are remaining to install. 

3-    Confirmation if the valve types and locations correspond to filings submitted to CER by TMEP:
TMEP representative confirmed that all valves’ locations and types are the same as filed with the CER except for the valve at KP470.472 (remote block valve). TMEP representatives explained that after analysis, the valve was deemed unnecessary; this valve has been removed from the scope of reactivation and will be installed at KP975 by operation.

4-    Valves hydrotesting:
TMEP representatives explained that most valves were or will be field hydrotested except for six (6) check valves and two (2) block valves.  TMEP explained that the check valves were not installed prior to the hydrotests because the pigs that are used in the hydrotest activities could get stuck in them and that the two block valves were not installed because they are located at test point locations. TMEP representative stated that the valves not tested in the field were tested by the valves manufacturer (Valitalia) and the test was witnessed by a TMEP representative (Killick Group). TMEP provided an example of a test record for valve KP390-1, which confirmed that the test meets the requirements of CSA Z662-19 section  The test record was signed off by a TMEP representative.

Compliance tool used: No compliance tool used

Observation 2 - Welding of a final tie-in

Date & time of visit: 2022-11-17 12:00

Discipline: Integrity Management




CER inspectors observed the welding of a final tie-in at the intersection of pressure test sections 2 and 3, located at KP 325.804.

TMEP’s Senior Welding Inspector and the contractor (Simpcw Ledcor Limited Partnership) Quality Control inspector were on site to inspect the welding activities.

CER inspectors verified the welding consumables used for the weld:

The welding consumable used conformed with the welding procedure used (WPS-101-Rev5).

The joint being welded was on new heavy wall joints (12.7mm) that were used as security pipe for the pressure test heads. TMEP explained that for the welds to the original pipe, the original pipe is inspected by non-destructive examination (NDE) to confirm that no features that could be detrimental to the weld are present. The original pipe is also tested for the carbon equivalent. TMEP explained that all the carbon equivalent testing results completed to date were below 0.5%.

The Material Testing Report (MTR) for the new heavy wall joints (heat number 6-0338) was provided. These joints were coated with fusion bond epoxy. The field-applied coating for the new pipes is SP 2888 and the one for the welds between the original pipe coated with coal tar is Stopaq.  A copy of the Stopaq manufacturer’s qualified application procedure (MQAP) was provided to the CER inspectors.

TMEP’s Senior Welding inspector explained that parameters are verified for all welds, including temporary welds. He does 50% of the parameters and the contractor Quality Control inspector does the other half. They also ensure to cover the two welders used for the welding.

TMEP explained that the non-destructive examination (NDE) is conducted by Applus+ RTD, which has been hired by TMEP. Ultrasonic testing (UT) is used for the NDE of the welds. The NDE is completed right after the welding and after a 48-hour delay.

An external clamp was used to align the two joints for the tie-in. The pipe joint was pre-heated to a minimum of 250° Fahrenheit prior to starting the root pass. After completing at least 50% of the root pass, the external clamp was removed. CER inspectors left the site after the hot pass was started.

CER inspectors observed that the valve at KP 324.050 had been installed. This valve was hydrotested as part of the pressure test for test section #2.

A copy of TMEP’s Senior Welding inspector welding inspection report was provided the next day to CER inspectors. The information recorded in the report confirmed that the welding was conducted according to the welding procedure.

Compliance tool used: No compliance tool used

Observation 3 - Test point of Hydrotest Section 8

Date & time of visit: 2022-11-18 09:30

Discipline: Integrity Management




CER inspectors went to the test point of hydrotest Section 8 located at KP 433.588. Section 8 was being filled with water and methanol (23%) in preparation for the hydrotest. The section was filled to about 70% at the time of the inspection.

Water was pumped directly from the river into a storage tank. There was a fish screen to protect the fish from being sucked into the pump. The water was then filtered with 50 microns filters before being injected with methanol and pumped into Section 8. A worker was monitoring the pump rates for water and methanol to ensure a proper mixture of the test medium. The test medium was being pumped at a pressure close to 400 psi (2757 kPa). TMEP indicated that the pump used for filling the test section had a maximum discharge pressure of 600 psi (4137 kPa).

A TMEP inspector was onsite to monitor the hydrotest activities. The test head with a minimum of 12 m of heavy wall pipe was welded to Section 8 for the hydrotest. The TMEP inspector indicated that the test head had been pretested to 9200 kPa prior to being welded in place and that he was present for that test. The test head had markings indicating a maximum working pressure of 25,530 kPa, which is significantly higher than the maximum pressure anticipated at this test point during the hydrotest, which will be 8,429 kPa.

The TMEP inspector explained that he will be witnessing the hydrotests, will verify the calibration records for the test equipment, and will sign off on the test records. The test equipment had not yet arrived on site.

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