Compliance Verification Activity Report: CV2122-168 - Trans-Northern Pipelines Inc.


Compliance verification activity type: Field Inspection

Activity #: CV2122-168
Start date: 2022-03-07
End date: 2022-03-10


Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):


Rationale and scope:

Integrity inspection of TNPI integrity digs to verify compliance with the OPR and CSA Z662-19.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Additional Project-specific requirements or conditions:

TNPI pipeline system is operating under pressure restriction as imposed by the Safety orders selected above. The pressure restrictions on each pipelines are listed in Schedules A,B, C, and D of the attached Safety Orders.

Observations (no outstanding follow-up required)

Observation 1 - Day 1

Date & time of visit: 2022-03-07 13:00

Discipline: Integrity Management




Dig Site OL-5.36:

CER inspectors met with TNPI representatives at the Ottawa Lateral (OL) 5.36 dig site. Sommerville is the contractor for the project and a Sommerville representative provided a site orientation.
The site had been excavated and non-destructive examination (NDE) was in progress. The coating had been removed on a section of about 8m, starting 2m downstream of girth weld GW6390. Although GW6390 was excavated, it was not part of the assessment area. The girth weld downstream of GW6390 was not exposed and not assessed either.

The original external coating on the pipe was coal tar. CER inspectors observed that the coal tar on girth weld GW6390 was disbonded. TNPI representatives explained that the exposed pipe will be recoated with a primer followed by a mastic cold tape (i.e. Kema tape). The new coating will be applied such that it will cover the damaged coating on girth weld GW6390.

The exposed pipe had two temporary pipe supports and TNPI explained that the maximum span length that is allowed is 7 m.
NDT Group is the company contracted to provide NDE services for the project. NDE staff explained that the visual inspection and the magnetic particle inspection (MPI) had been conducted on the entire surface (360 degrees) of the exposed pipe. No features were identified during these inspections. At the time of the inspection, phased array ultrasonic testing (PAUT) was in progress on the Electric Resistance Welded (ERW) pipe seam.

The dig’s main target was a crack-like feature on the long seam weld. According to NDE staff, visual inspection confirmed that the location of the crack-like feature detected by the in-line inspection (ILI) tool was correct.

NDE staff informed CER inspectors that the NDE results are sent to TNPI’s Engineering Department. The Engineering Department then decides whether repairs are necessary and if so, determines the type of repair methods. CER Inspectors requested a copy of the NDE report that includes the NDE results and a description of the repair methods (if any). The NDE report was sent to CER inspectors on the following day. The TNPI representative stated that if the crack-like feature on the long seam weld required repair, a compression-type sleeve (i.e. Petrosleeve) will most likely be installed.

CER inspectors verified that the NDE staff had adequate Canadian General Standards Board (CGSB) certification for the NDE being conducted.
TNPI explained that safe excavating pressures (SEPs) are established during the planning of the integrity digs and that the SEPs are documented in the work plans for the digs to be completed. A copy of the work plan for this dig was provided on the following day. TNPI explained that the field crew contacts the Line Control to confirm the line pressure prior to beginning work each day. The OL was not operating at the time of the inspection and this section of the line is under a slight negative pressure when down.
The excavation was properly sloped and had adequate access and egress. The company explained that the excavations are fenced when not attended. TNPI representative also mentioned that the weather is monitored closely to determine whether dig sites require any adjustments (i.e. removal of protective tarps in the event of heavy snowfall or high winds).

Compliance tool used: No compliance tool used

Observation 2 - Day 2

Date & time of visit: 2022-03-08 10:00

Discipline: Integrity Management




Dig Site OL-5.12:

TNPI representative explained that the dig sites are numbered based on mileposts from Farran’s point.

Before entering the dig site, which was covered with a protective structure and tarp, a Somerville foreman verified the atmosphere inside the enclosure with a gas monitor. Since the monitor did not detect any lower explosive limit (LEL), carbon monoxide or oxygen deficiencies, CER inspectors were allowed to enter.

CER inspectors observed that the NDE activities were complete and asked for a copy of the NDE report for this site which was sent to CER inspectors on the same day.

Based on the markings made on the pipe, it was apparent that the locations of the features detected by the ILI tool were closely matching the field NDE. CER inspectors were informed that the ILI tool identifies the location of GWs within a meter. CER inspectors were informed that this site was ready to be repaired but because the operating pressure was not within the range recommended by the sleeve manufacturer
 the repair could not proceed. The installation of compression sleeves requires to be done while the pipeline is operating within the recommended pressure range.

The NDE Interim Report and Repair Recommendations were provided for this dig. Note: NDE staff explained that this report is considered an Interim Report, the final NDE report is completed after repairs are done and is normally available a few weeks after the dig is entirely complete.

There were five target features for this dig and a total of eight linear indications in the seam weld were identified by the NDE. Six of the indications were connected to the internal diameter of the pipe and two were sub-surface. The repair plan is to install three compression sleeves.

CER inspectors were informed that certified Somerville employees perform the sleeve installation. A TNPI Welding Inspector supervises the welding of the sleeve and verifies the compression of the sleeve once installed. The NDE staff assesses the integrity of the installed sleeve (i.e. MPI of the sleeve’s weld).

CER inspectors were told that the new coating that will be applied on the pipe will be visually checked. According to the TNPI representative, there is no appropriate test for tape-like coating. Furthermore, TNPI representative stated that the new coating will be installed such that it covers at least 3 inches of the original coating on the GW. CER inspectors observed plastic wrap around parts of the pipe and the TNPI representative explained that the wrap was to contain the asbestos within the old coating.
Dig Site OL-4.86:
CER inspectors attended a site-specific meeting before getting close to the dig site.

Excavation was in progress at this dig site. CER inspectors were informed that Somerville staff were currently hand digging the pipe.

A TNPI inspector was on-site to monitor the work. The inspector indicated that he was a certified NACE Level II Coating inspector. He indicated that the coating Quality Assurance and Quality Control (QA/QC) is conducted by the contractor but that he witnesses the QA/QC activities. TNPI provided the Manufacturer’s Qualified Application Procedure (MQAP) for the field-applied coating (Kema tape and primer) and the coating applicators qualification records for two of the coating applicators working in this area.

An example of coating QA/QC report was also provided. The report was signed by a TNPI inspector. CER inspectors were informed that the original coating is made up of rock shield and coal tar and it is carefully taken off with brass hammers and scrapers. Staff removing the coating wear PPE to mitigate the asbestos hazard. The removed coating is captured in tarps placed underneath the pipe. Because the coating includes asbestos, it is contained and taken off-site by a specialized vendor.

The TNPI inspector also explained the excavation requirements for exposing the line and the information provided was consistent with TNPI’s “Excavating and Excavations Greater Than 1.2 M” procedure provided to CER inspectors before the inspection.
Dig Site OL-5.36:
CER inspectors returned to this site to observe the measurement of carbon equivalent (CE) content on the pipe body. While waiting for the measurement to begin, NDE staff confirmed that the ILI tool’s reporting threshold is equal to 40 mm in length and 1 mm in depth.

NDE staff informed CER inspectors that the NDE results were done and sent to TNPI’s Engineering Department. NDE staff was waiting for the recommendations from Engineering for the repairs to be performed.

NDE staff explained that to take the CE content measurement, an area on the pipe is required to be prepared. The area must be removed of impurities by grinding before it can be tested by the Laser-Induced Breakdown Spectroscopy (LIBS) meter. At least 3 measurements are taken in the ground spot. Once the CE content measurement was complete, NDE staff verified the integrity of the area that was tested. NDE staff etched the surface to rule out the presence of hard spots and none were identified. NDE staff proceeded with MPI to make sure there were no cracks and none were identified. NDE staff also performed UT measurements to determine the extent of wall thickness removed by the testing. In this case, wall thickness went from 5.1 mm (parent metal) to 4.9 mm in the tested area. The results are sent to TNPI’s Engineering Department as a grind feature and Engineering decides if some type of repair is required. According to NDE staff, it is extremely rare that repairs are necessary after CE content measurement because the metal loss is considered insignificant. The CE content measurement was done by an NDT group employee.
The interim NDE report for OL-5.36 was provided. There were 10 target features for this dig and a total of 17 linear indications in the seam weld were identified by the NDE. The repair plan is to install six compression sleeves for the linear indications that need to be repaired according to TNPI requirements. There were four linear indications in the seam weld that were 0.8 mm in depth or less which is not injurious according to TNPI’s fatigue analysis. These features will be monitored by TNPI integrity.

Compliance tool used: No compliance tool used

Observation 3 - Day 3

Date & time of visit: 2022-03-09 08:00

Discipline: Integrity Management




Dig Site OL-5.36:

When CER inspectors arrived at dig site OL-5.36, the crew was preparing for the installation of the sleeves. The TNPI inspector informed CER inspectors that the operating pressure of the pipeline was currently 165 psi and as a result, the sleeve installation was allowed to proceed.

The TNPI inspector explained the QA/QC activities that he conducts during the installation of the compression sleeves and the information that he enters into the system for the installation of the sleeves. A copy of the PETROSLEEVE Installation QC Report was provided.
For the welding of the sleeves, the NDE company (NDT Group) is responsible for verifying that the welding parameters are in accordance with the welding procedure. CER inspectors confirmed that the correct welding procedure was being used. The NDE inspector explained that, at a minimum, two full sets of parameters are verified per welder per day.
Six sleeves were to be installed to repair the defects found during the NDE at this site. The TNPI representative informed CER inspectors that the length of the sleeves can be cut to fit the repair area but that the sleeves’ thickness is all the same (i.e. thickness is standard). Two sleeves were cut in two to generate four pieces such that 4 halves and 2 full sleeves were installed on the pipe.

CER inspectors observed the serial number on the sleeves, the first number corresponds to the diameter, the next is the grade of pipe, the following is the year of manufacturing and the last is the serial number. CER inspector witnessed the installation of one of the sleeves and left this dig site to observe the NDE conducted at dig site OL-4.86.
Upon the CER inspectors' return to this dig site, CER inspectors were informed that four more sleeves had been installed since their departure.

While CER inspectors were at dig site OL-4.86, the TNPI representative was alerted by Line Control that the pressure in the line had to be cut because of some disruption elsewhere in the system. As a result, the sleeve installation had to be put on hold until pressure could be restored. Once the TNPI representative received confirmation that the pressure was back up in the line, the installation process restarted.

CER inspectors were present for the last sleeve to be installed at this site. CER inspectors watched the crew apply epoxy, remove excess epoxy, place the top and the bottom parts of the sleeve on the pipe as per mapping. The crew proceeded with torquing, grinding, heating with a torch, torquing again the sleeve and subsequently welding the top and the bottom parts of the sleeve together. Welding parameters were verified by the NDE inspector for the first sleeve installation witnessed by the CER inspectors. The recorded parameters were within the welding procedure allowance.

CER inspectors noticed that the welding rods used (size 3/16”) were one size greater than the recommended rod size listed in the welding procedure (1/8” and 5/32”) for the thickness of the sleeves used (0.375”). The NDE inspector explained that this change has been approved by TNPI and that it is in compliance with CSA Z662-19 Table 3 of clause 7.6.5. A copy of the TNPI approval for this change was provided. After the installation of the sleeves, the NDE inspectors conducted visual and MPI inspections of the sleeves’ seam welds.
Dig Site OL-4.86:
At dig site OL-4.86, the NDE was about to be started. The NDE staff demonstrated the calibration of the magnetic yoke used in MPI which involved lifting a weight to establish that there is sufficient magnetic field to perform the inspection. The calibration also involves verifying the sensitivity of the magnetic particle mixture (i.e. the mixture is right).

At this dig site, NDE was to be performed on 3 m of pipe (the area between 4m to 7m from the upstream GW) but none of the pipe joint’s GWs were included in the assessment area. CER inspectors observed the NDE staff spraying the white paint on the surface of the assessment area.

NDE staff explained that the long seam weld is found with visual inspection and its location is confirmed using UT. NDE staff calibrated the LIBS meter before starting to take CE measurements on the pipe surface. TNPI representative explained that LIBS has been used for the past 18 months on TNPI projects. CER inspectors were informed that before solely using the LIBS meter to measure CE content, TNPI’s protocol was to simultaneously use the older method which involved removing metal flakes from the pipe surface and sending it to a laboratory for testing. Once TNPI determined that both tests generated similar results, it opted to use the more modern LIBS technique for CE measurement moving forward.

CER inspectors left the dig site to observe the compression sleeve installation occurring at dig site OL-5.36. Upon the CER inspectors' return to this dig site, the NDE was complete. NDE staff explained that 2 of the 17 linear indications identified were found on the outer surface of the pipe. These two external linear features were not detected by the ILI tool. NDE staff were at the stage of drafting the Interim NDE Report for TNPI’s Engineering Department.

Compliance tool used: No compliance tool used

Observation 4 - Day 4

Date & time of visit: 2022-03-10 09:00

Discipline: Integrity Management




Dig Site OL-4.17:

CER inspectors arrived in the vicinity of dig site OL-4.17 and a TNPI representative provided a site orientation. The site was beside two other dig sites OL-4.13 and OL-4.14 which were entirely covered in water and crews were attempting to remove the water such that the pipeline could be exposed and assessed.

At dig site OL-4.17, NDE was in progress. The NDE assessment area was 3m long between GW 5010 and GW 5020. GW 5020 was excavated as a reference point but GW 5010 remained buried.

The NDE staff informed CER inspectors that a sub-surface lamination was detected by UT. The preliminary assessment indicated that the lamination was running all the way through the exposed pipe longitudinally, was planar, not sloping and located at 2.6mm from the surface (i.e., at 50% of pipe’s wall thickness or mid-wall). The ILI tool reported the lamination as an external metal loss feature. NDE staff explained that ILI tools typically report laminations correctly and that it is rare for ILI tools to report laminations as a metal loss.

NDE staff also stated that the point where the ILI tool reported the metal loss feature is precisely where the UT signal from the lamination is the strongest, as the probe is moved away on either side of this point, the signal becomes weaker. A second lamination was found lower than the first lamination (i.e. two laminations run parallel to each other). TNPI provided a copy of the Interim NDE report and repair recommendations after the inspection.

NDE staff informed CER inspectors that, other than the features reported by the ILI tool and the two identified laminations, only internal or sub-surface linear indications in the seam weld were found. No dents and no corrosion were detected in the NDE assessment area.
Dig Site OL-5.36
CER inspectors drove to dig site OL-5.36 and observed that the excavation was entirely filled with water. TNPI representatives explained that more powerful pumps would be installed to remove the accumulation of water from the trench such that the pipe could be dried and that workers could proceed with the coating installation.

Dig Site OL-4.86
CER inspectors walked to dig site OL-4.86 and met with the TNPI inspector. The TNPI inspector told CER inspectors that the installation of three sleeves (2 full sleeves and 1 half sleeve) was in progress and almost done at this site. The inspector stated that before starting the repair he received confirmation from Line Control that the pipeline was operating at a pressure of 330 psi until 2 pm.

Once the repair was done, the TNPI inspector took measurements to determine the extent of compression (i.e., the distance between specific points before and after clamp torque is applied on sleeves).

The NDT group employee in charge of conducting MPI on the sleeves’ welds asked the welders to grind some of the sharp edges found on the sleeves to prevent the final coating to be damaged when applied. After this was done, he proceeded with the MPI. The MPI revealed a small linear indication on a sleeves’ longitudinal weld and another on a sleeve’s circumferential weld. The welders ground the indication out from the longitudinal weld and performed another weld pass on the circumferential weld as a repair.  

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