Compliance Verification Activity Report: CV2223-115 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2879
• Inspector 2279

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Integrity Management

Related events:

• CV2122-360
• CV2122-376

Rationale and scope:

Inspection of the TMEP Fraser River HDD

Compliance tool(s) used:

• None

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 - Day 1 - Spread 7 Office

Date & time of visit: 2022-10-26 11:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• TMEP personnel advised that the surface casing at the north side had been installed
  • 45 m of 72” (1828.8 mm) casing was installed and that is as per the Exit Side (none as North Site) Surface Casing Project Execution Plan
  • 78 m of 60” (1524 mm) casing was installed until the refusal criteria were met as per the Exit Side Surface Casing Project Execution Plan (target was 90 m)
  • 118.5 m of 54” (1371.6 mm) casing was installed until the refusal criteria were met as per the Exit Side Surface Casing Project Execution Plan (target was 130 m)
• Although the 54” casing did not meet the target, TMEP believes that the casing has been extended far enough to support the borehole.
• The target exit angle of the casing was 9° and the installed casing was determined to be 9.8° and accepted by TMEP
• Pilot hole drilling on the north side started on 21 October 2022
• Once passed the surface casing by approximately 100 m, the drilling contractor had trouble maintaining the hole
• The string was tripped out and the bit was changed out to mitigate the issue
• As of noon, approximately 575 m of the pilot hole had been completed
• TMEP stated that the drill bit was currently 0.03 m off target and that the tolerance was ±2m
• TMEP indicated that a gyro steering tool was being utilized to track and direct the drill bit
• TMEP confirmed that the pipe section for the crossing had been hydrostatic pressure tested before the first installation and once it was pulled back out, caps were welded on, and the pipe section was pressurized to 15 psi (103 kPa) with nitrogen
• Excavators and a bulldozer were used to pull the pipe section back out
• Currently, there are two HDD rigs set up; one on the north side and one on the south side

Compliance tool used: No compliance tool used

Observation 2 - Day 1 - North Side HDD Site – CWP 62

Date & time of visit: 2022-10-26 14:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The location is well supported and secured by rig mats
• CER Inspection Officers (IOs) observed several fire extinguishers throughout the work site
• CER IOs observed the addition of and drilling of joint #65
• The drilling superintendent and the gyro steering tool technician (steering hand) believe that they met the existing borehole and were currently slowly easing into it
• Indicators for the belief of meeting the existing borehole were negligible to zero mud return, minimal required torque, and minimal required push
• The steering hand indicated that the gyro steering tool measures the position of the steering tool in real-time ("measurement-whilst-drilling") with an accuracy of ±2% and has no issues with magnetic interference since it utilizes gyro technology
• The gyro steering tool is positioned around 5 to 6 m behind the drill bit
• The drilling superintendent stated that a 12-1/4" (311 mm) bit is used with a 2° bent sub to control the direction
• The rig manager stated that the mud technician would check the mud viscosity, weight, sand content, and acidity (pH) along with freshwater acidity
• The rig manager confirmed that drilling fluid products safety data sheets were readily available, both in hardcopy and electronic copy
• The rig manager showed the CER IOs the 11 new 7-5/8” (193.7 mm) heavy wall drill pipe that will be used next to the pipe section during pull-through
• TMEP stated that the abrasion-resistant overcoat on the pipe section to be pulled into the bore was 40 to 45 mils (1.0 to 1.1 mm) thick
• After being removed, the pipe section coating was checked for holidays (jeeped), will be jeeped again before pull-through, and then jeeped while being pulled through
• The pipe section pulled through will be approximately 1368 m long
• CER IOs observed lengths of the 6” (152.4) high-density polyethylene pipe on site to be used as buoyancy control inside the pipe section

Compliance tool used: No compliance tool used

Observation 3 - Day 2 - Spread 7 Office

Date & time of visit: 2022-10-27 13:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER IOs requested the Daily Report, the Mud Log – EDFP Volumes and Properties Report, the Inadvertent Fluid Release Monitoring Report, and the Steering Report, as per the HDD Project Execution Plan for 25 and 26 October 2022
• TEMP showed the daily report and ran down the report contents which included:
  • daily drilling activities, including the day's drilling progress
  • drilling fluid properties
  • drilling fluid products used
  • volume of drilling products used
• CER IOs observed no non-compliances in the requested reports
• TMEP confirmed that the drill string and drill bit entered into the original borehole yesterday with the drill bit approximately 903 m from where it entered on the north side  
• Currently, the drilling crew was rigging up and preparing to drill the south side into the original borehole and tag to the drilling bit seated at approximately 903 m from the north side
• Once tagging is confirmed, both the drilling strings will be pushed/pulled to the south side
• TMEP discussed the tentative plan for reaming, wash run, and pulling strategy, but this is subject to observed ground/soil conditions and may change accordingly
• The current tentative plan is:
  • Ream 32” (812.8 mm) to the north side
  • Ream 48” (1219.2 mm) back to the south side
  • Swab 42” (1066.8 mm) to the north side
  • Pull pipe section through with a 38” (965.2 mm) reamer to the south side
• TMEP stated that it could have drilled concurrently from each side, but a steering hand was not available for months, so it proceeded with available personnel and drilled from one side
• TMEP said that the drilling crew is operating 24 hours a day, 6 days a week

Compliance tool used: No compliance tool used

Observation 4 - Day 3 - Spread 7 Office

Date & time of visit: 2022-10-28 10:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• TMEP advised that drilling has start during night shift
• Drilling has progressed 195 m, with approximately 200 m left and are anticipating to intersect with the north side pilot hole today

Compliance tool used: No compliance tool used

Observation 5 - Day 3 - South Side HDD Site – CWP 61

Date & time of visit: 2022-10-28 10:33

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• The location is well supported and secured by rig mats
• CER IOs observed several fire extinguishers throughout the work site, and one was checked to find an up-to-date inspection record 
• The rig is at 19° and this is close to the as-built entry angle of 17.58° as per the Plans and Profiles drawing
• The rig manager pointed out the 16” (406.4 mm) diameter wash-over casing, that was installed to a surface depth of 79 m
• The rig manager also stated that the wash-over casing will be pulled out before commencing reaming operations
• IOs observed various reamers including 30” (762 mm), 48” (1219.2 mm) and 54” (1371.6 mm) reamers and a 44” (1117.6 mm) swab on site
• The rig manager stated that there were approximately 116 m of drilling to go and that they were paused as the steering hand had gone to the north side to activate/power up the gyro steering tool for tracking and connection purposes
• The drilling superintendent commented that the drilling was like the previous drilling as they believe they were in the original borehole
• The drilling superintendent stated that the gyro steering tool will take directional readings with active circulations during the tag and pull/push activities from both sides
• The rig manager and the drilling superintendent commented that swabbing of the hole would be done until torque values were found to be within an acceptable range when the time for swabbing comes
• The drilling rig is equipped with two generators, two pumps, and a solids control unit
• The drilling rig appears to have built-in redundancy for power and fluid pumping capacity
• According to the rig manager, the rig has enough capacity to overcome the pull and torque during the reaming operations and has hydraulic motors at the site if more pull is needed
• CER IOs understood that the TMEP and Drilling Contractor might make changes to planned reaming, swabbing, and pulling activities based on the ground situation and operational conditions
• CER IOs suggested that TMEP should provide justification and explanation for any change made to the drilling execution plan

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: