Compliance Verification Activity Report: CV2223-105 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2480
• Inspector 2918

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Integrity Management

Rationale and scope:

TMEP construction inspection of Spread 7B

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (2)

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• OC-065

Observations (no outstanding follow-up required)

Observation 1 - Construction Work Package (CWP) 061 - day 1

Date & time of visit: 2023-02-14 13:30

Discipline: Integrity Management

Categories:

• Pipeline
• Ditching
• Excavations
• Backfilling
• Pipe Condition
• Materials
• ROW
• Procedures
• Crossing of Existing Pipelines
• Documentation
• Record Retention

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER and TMEP staff reviewed the activity tasks to be performed at the site, the identified hazards and safety measures, and signed off the safety documentation including Foreman's Safely/Quality Meeting Record, Safe Work Practice Form and Operations Start Card. The Daily Ground Disturbance for spread 7B was in place and completed. It was confirmed that the safety forms would be updated accordingly if work activities or tasks change or are added to the day. It was also confirmed that all personnel on site are required to sign the "lign of sight" form.
• TMEP contractor on site was Kiewit Ledcor Trans Mountain Partnership (KLTP).
• KLTP representative confirmed that no third-party utilities were present on site. 
• Pipeline alignment sheets for this site were reviewed. The following information was confirmed by KLTP and TMEP staff:
  • no presence of AC interference hazard requiring mitigation
  • no "hold areas" were identified at the site as per alignment sheets. It was clarified that "hold areas" are related to overhead hazards
  • no unrecognized geotechnical hazards were identified. It was confirmed that if geotechnical condition changes are found, the geotechnical engineer would be contacted for further assessment.
• Pipe backfilling activity has started at the site, but it was paused at the time of inspection. 
• TMEP staff confirmed that pipe jeeping is completed by KLTP prior to backfilling. The inspection is performed by KLTP and TMEP inspectors. 
• It was confirmed that soil compaction tests are completed by KLTP and validated by the TMEP inspector who issues a daily report.
• The "Hifi" fibre optic sensing leak detection system was installed on the top of the pipe.
• The pipe depth-of-cover (DoC) was observed and confirmed by KLTP to be a minimum of 2.5 m.
• The last daily report issued at the site was presented. 
• Spoil piling on the top of the pipe along with a loaded truck crossing the pipe during the spoil piling activities were observed. CER inspectors requested the assessment performed to confirm that the pipe integrity would not be affected by the equipment crossing and the presence of spoil piping on top of the pipe. TMEP confirmed that it used CEPA Final Report No. 05-44R1 for surface loading calculations. Page 58 of the Damage Prevention Plan document provided (01-13283-GG-0000-HS-PLN-0025) included the results for the minimum pipe DoC required for the loaded equipment to be safely used at this site. The minimum DoC calculated was 0.9m and 1.0m respectively for the type of equipment used, which was below the DoC observed and then further confirmed by TMEP based on its measurements (i.e., min. 2.5m). CER inspectors also requested further assessment calculations for the spoil pile over the pipe (Information Request (IR) 1). 
• Backfilling procedure TMEP-3120 section 20.0 was on site. KLTP staff explained the backfilling process confirming the use of the fine-grained material for > 600mm above the pipe with the required compaction followed by the native topsoil (subgrade/restoration). 
• Excavation activity was ongoing at the site during the inspection. The excavation procedure was available on site. The spoil pile was away from the ditch and a spotter was present on site. The trench was confirmed to be excavated at a 4:1 ratio with 3/4" rock on the sides to prevent sluffing.
• Pipe joints prepared for installation were also observed on site. They were properly supported by pillows and have the night caps installed. Tag lines for lifting and handling were attached to the pipe. 
• KLTP staff explained the process to ensure that the right pipe joints are being installed. That includes verification of the numbers marked on the pipe against the last pipe joint installed and the comparison with the alignment drawings. 
• It was confirmed that the pipe joint numbers are issued by KLTP and KLTP and TMEP QA/QC representatives perform the final verifications to ensure the proper pipe joints are installed.  

Compliance tool used: No compliance tool used

Observation 2 - CWP 080 and 081 - day 1

Date & time of visit: 2023-02-14 15:10

Discipline: Integrity Management

Categories:

• Documentation
• Record Retention

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

- 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.

Compliance tool used: No compliance tool used

Observation 3 - CWP 088 - day 1

Date & time of visit: 2023-02-14 16:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling
• Documentation
• Record Retention

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The ongoing activity at this site was the Direct Pipe Installation (DPI) - i.e., tunnelling of the NPS 42 casing before the NPS 36 pipe installation. The distance achieved was 184 m of 410 m. 
• KLTP was the general contractor on site.
• The Trenchless Company (TRE) was the drilling contractor for TMEP.
• The following safety forms were reviewed and signed off: TRE Safety Hazard Form, KLTP Work Authorization Form including daily activities, Foreman's Safety/Quality Meeting Report identifying the safety hazards at the site and Operations Start Card including the field level assessment.
• NPS 36 pipe joints welded with joint coating inspection completed were observed at the site. 
• The lifting and handling plan approved by TMEP for each section of drilling was in place with the TMEP inspector and KLTP staff. The plan was confirmed as being reviewed at the beginning of each shift including the lift points, lifting equipment distance, and equipment verifications prior to starting the activity. 
• The monitoring of tunnelling activities (e.g., distance, path, volumes, pressures, etc.) was observed and explained. Monitoring parameters were input from the drilling plan. The drilling rate was identified as 30 mm/min. TRE indicated that drone flights with an IR camera are flown over the DPI site to identify potential material breach points above ground.
• The clay formation was observed to be discharged from the process and sorted out from the drilling fluid. 
• TMEP inspector was on site. The last parameters inspection report, including the pump rates, distance, push forces, steering data and mud parameters, was presented. Parameters were compared by the TMEP inspector against the drilling execution plan located on-site in a digital form.
• CER inspectors requested information regarding the contingency plan for tunnelling activities. TMEP provided the Project Execution Plan for the DPI including contingency measures and plans at different stages of activity and possible scenarios. These included: spare parts and equipment, mitigation plans for inadvertent returns to surface, tunnel collapse, extraction of the Micro Tunnel Boring Machine (MTBM), lodged pipeline, loss of MTBM or buckling pipeline, loss of slurry circulation and slurry pump failure. 

Compliance tool used: No compliance tool used

Observation 4 - CWP 061 - day 2

Date & time of visit: 2023-02-15 09:20

Discipline: Integrity Management

Categories:

• Pipeline
• Ditching
• Excavations
• Pipe Condition
• Welding Operations
• Procedures
• Safety
• Documentation
• Record Retention
• Updating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER and TMEP staff met at the field office, discuss the plan for the day and decided to start with site CWP 061.
• The scope of work at site CWP 061 was the welding of pipe joint # 64.
• The Damage Prevention Plan was signed off by the personnel: welders, foreman and inspectors, involved in welding activities before entering the ditch.
• The Operators Start Card, Foreman's Safety/Quality Meeting Record and Safe Work Permit were reviewed by CER and TMEP staff and signed off.
• The welding activity was not started at the time of the CER and TMEP staff arrival. 
  • The pipe joints were in the trench, in position to be lined up for welding.
  • 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. KLTP and TMEP staff consulted the office and confirmed that two additional ladders will be installed on the other side of the trench for each pipe joint working area before proceeding with any activity. Ladders were provided to the site from CWP 080 and properly installed.
    CER inspectors noted this corrective measure as a corrected non-compliance (CNC 1) and notified TMEP that a non-compliance is still being considered until appropriate documentation will be provided to field personnel to address similar non-compliance situations. The documentation must provide the necessary information and requirements regarding the proper preparation of trench entry and exit access points including the proper use of ladders. This was addressed later during the close-out meeting at the field office.
• Welders Operators Start Card field assessment was reviewed and signed off by CER and TMEP staff.
• Welding Procedure Data Sheet (WPDS) TMEP-SA-WPDS-01-14.7-HSC Rev. 6 and the corresponding WPDS TMEP-SA-WPDS-01-14.7-HSC RP Rev. 5 for repair welding were on site with welders and welding inspectors. 
• NPS 36 High Strain Capacity (HSC) 14.7mm wall thickness (WT) pipe joints #64 and #65 NPS 36 were prepared for welding.
• CER inspectors requested the Mill Test Report (MTR) for pipe joints #64 and #65 to confirm the longitudinal yield and tensile strengths as per the Procedure Qualification Records (PQR). (IR 2) 
• CER inspectors observed the pipe alignment process and the external clamp installation. 
• Welders' certificates were valid. CER inspectors requested welders' qualifications for welding procedure specifications (WPS) TMEP-SA-WPS-01-14.7-HSC Rev. 0 applicable for these pipes welding. (IR 3)
• KLTP and TMEP welding inspectors were on site, both inspecting the welding process (i.e., Metal Cored Arc Welding) and taking welding parameters. 
• Pipe joints were properly aligned with the long seam positions alternating from approximately 1 to 2 o'clock to 10 to 11 o'clock. 
• The pipe misalignment (i.e., a maximum offset of 1.6mm) was verified by the TMEP inspector after the line-up clamp installation. Proper pipe alignment was confirmed. 
• The metal cored wire was verified by the TMEP inspector and confirmed as per WPDS: MegaFill 240M Class E80C-Ni1, 1.2mm.  
• The following actions were observed during the welding process:
  • wind protection wrap was installed;
  • pipe surface was cleaned;
  • external line-up clamp was removed after 50% of the circumferential root bead was completed; 
  • the slag was removed between beads;
  • the pipe coating was protected;
  • preheat temperature was verified by the TMEP inspector using a calibrated digital thermometer.
• Welding inspectors confirmed that IR drop (the voltage drop due to energy losses due to resistance) is considered if the welding parameters are taken from the top of the ditch, but it is minimal in comparison with the ditch measurements. TMEP staff confirmed that additional information regarding to a similar request was previously provided to the CER. 
• Interpass temperature measurements taken by the TMEP inspector at four positions were: 72^° C, 89^° C, 95^° C, and 81^° C.
• Welding parameters: amperage, voltage, travel speed, wire feed, oscillation and heat input were taken/calculated in the ditch by the TMEP inspector for each pass, and recorded. 
• TMEP staff confirmed that there is no requirement for a delayed non-destructive examination (NDE) of this joint pipe. CER inspectors requested TMEP staff to provide the delayed NDE requirements for the project welding to confirm their statement. (IR 4)
• CER and TMEP staff returned to the field office where TMEP provided documentation described in the observations. A close-out meeting was conducted and the observations and remaining action items were reviewed. The following immediate actions were confirmed by TMEP to address the findings at CWP 061:
  • TMEP developed and provided a Daily Safety Bulletin issued for trench access and egress preparation;
  • This will be discussed at the PTI meeting in the afternoon of 15 February 2023 (end-of-day meeting with the foreman at CWP 061);
  • The Safety Bulletin will be issued in the evening of 15 February 2023 and it will be discussed at all tailgate meetings at the start of all night shifts and the 16 February 2023 morning meetings. 
  • Ensure that all foremen were immediately informed of this correction. 
• CER inspectors noted these corrective actions as CNC 2.  

Compliance tool used: No compliance tool used

Observation 5 - CNC 1

Date & time of visit: 2023-02-15 11:00

Discipline: Safety Management

Categories:

• Workplace Practices
• Scaffolding, temporary stairs, ramps and platforms

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

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:

• OC-065

Relevant section(s):

• Engineering and safety Trans Mountain must cause the Project to be designed, located, constructed, installed, and operated in accordance with, at a minimum, the specifications, standards, policies, mitigation measures, procedures, and other information included or referred to in its Project application or to which it otherwise committed on the record of the OH-001-2014 proceeding.

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

Discipline: Safety Management

Categories:

• Workplace Practices
• Scaffolding, temporary stairs, ramps and platforms

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

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.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• OC-065

Relevant section(s):

• Engineering and safety Trans Mountain must cause the Project to be designed, located, constructed, installed, and operated in accordance with, at a minimum, the specifications, standards, policies, mitigation measures, procedures, and other information included or referred to in its Project application or to which it otherwise committed on the record of the OH-001-2014 proceeding.

Company action required:

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. 
 

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

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: