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 construction inspection of Spread 7B
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
IR from CER (Information Request sent from CER to company) IR 1 Surface Loading at CWP 061
Legislative Requirement : CSA Z662-19 - Oil and Gas Pipeline Systems
Applicable Wording from Legislative Document 4.3.1.1 There is a commentary available for this Clause. The designer shall be responsible for determining supplemental local stress design criteria for structural discontinuities, high-temperature thermoelasticity, and fatigue evaluations; structural limits for denting, wrinkling, secondary tensile loading, and bending stresses in buried pipelines; and structural stability. Notes: 1) The design requirements of this Standard do not provide criteria for all design conditions. 2) For stress conditions not covered by Clause 4.3 and Clauses 4.6 to 4.10, reference should be made to Annex C or to the alternative rules in the ASME Boiler and Pressure Vessel Code (Section VIII, Division 2). Attention should be focused on the nonlinear nature of piping under certain loading conditions, and it should be recognized that linear elastic stress analysis methods used for the usual flexibility analysis might not be sufficient to analyze deformations and related failure or damage conditions. 3) This Standard does not provide criteria for nonlinear deformation conditions. 4.3.1.2 Designers shall provide adequate protection to prevent unacceptable damage to the piping from unusual or special external conditions. Note: Examples of such protection include increasing the pipe wall thickness, using additional cover, constructing revetments or other suitable mechanical protective devices, providing erosion protection, installing anchors, replacing potentially unstable soil with stable soil, using insulating materials, using refrigeration or heat tracing, using special construction procedures to reduce surface disturbance, and using right-of-way revegetation. Grade and above-grade installations are additional alternatives.
Theme and Categories
Due Date : 2023-03-10
Review Response Acceptable
Follow-up Action None
IR from CER (Information Request sent from CER to company) IR 2 MTRs and PQRs for CWP 061
Legislative Requirement : Canadian Energy Regulator Act (CERA)
Sections of the Act
Review Response Unacceptable
Follow-up Action Issue another IR
IR from CER (Information Request sent from CER to company) IR 3 - Welders Qualifications
IR from CER (Information Request sent from CER to company) IR 4 - NDE
IR from CER (Information Request sent from CER to company) IR 5 - Follow up on response to IR 2
Due Date : 2023-03-20
Observation 1 - Construction Work Package (CWP) 061 - day 1
Date & time of visit: 2023-02-14 13:30
Discipline: Integrity Management
Categories:
Facility:
Observations:
Compliance tool used: No compliance tool used
Observation 2 - CWP 080 and 081 - day 1
Date & time of visit: 2023-02-14 15:10
- Activities at this site were stopped at the time of CER and TMEP staff arrival due to issues encountered regarding the alignment of the pipe joint and the hot bend. A TMEP technical assessment was ongoing. - The safety hazard forms issued for the day were reviewed. These included: KLTP Daily Shoring Box Inspection Sheet issued for 34 trench boxes signed off by the foreman, Ground Disturbance form, Operators Start Card and Foreman's Safety/Quality Meeting Record. All documents listed the hazards and tasks required for the daily activities and were signed off. The foreman indicated that individual inspections are completed for individual trench boxes.
Observation 3 - CWP 088 - day 1
Date & time of visit: 2023-02-14 16:00
Observation 4 - CWP 061 - day 2
Date & time of visit: 2023-02-15 09:20
Observation 5 - CNC 1
Date & time of visit: 2023-02-15 11:00
Discipline: Safety Management
Two ladders (one for each pipe joint) were installed on the same side of the trench as entry and exit points. KLTP foreman stated that each ladder serves for both entry and exit purposes and they are installed in accordance with the Worksafe BC Regulation, section 20.87 (2), which was digitally available on site. CER inspectors noted that the requirement was interpreted incorrectly and notified KLTP and TMEP staff that ladders must be installed on both sides of the trench at the working area allowing workers from each side of the pipe joints to exit the trench in case of emergency. It was also noted that this is considered a non-compliance considering the work has not been started.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Ladders must be installed on both sides of the trench at the working area allowing workers from each side of the pipe joints to exit the trench in case of emergency while working on the pipe.
Due date: 2023-02-15
Date closed: 2023-02-15 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 - CNC 2
Date & time of visit: 2023-02-15 14:00
CER inspectors notified TMEP that a non-compliance was being considered until appropriate information and documentation are provided to field personnel to address potential future similar situations of improper trench entry and exit access.
Appropriate information and documentation is required to be provided to field personnel to ensure similar future situations of improper trench entry and exit access will be avoided. The documentation must include the necessary requirements regarding the proper installation of ladders at the entry and exit access points.
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