Compliance Verification Activity Report: CV1920-228 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-228
Start date: 2019-09-11
End date: 2019-09-11

Team:

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of O&M Digs.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Dig site MP-328.91-2019

Date & time of visit: 2019-09-11 10:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

- The visitor orientation, log form, and the daily toolbox were reviewed and signed off.
- The line was shut down at inspectors' arrival. TNPI field personnel confirmed the line was shut down with the control center prior to commencing work at the site.  
- TNPI staff confirmed that the pipe sandblasting activity occurred the day before while the pipeline was still operating at a low pressure (i.e. discharged pressure of 275 psig at Cummer Junction and 300 psig at Bowmanville station). CER inspectors requested a copy of TNPI's sandblasting procedure confirming that all risks to excavation personnel were considered when this type of activity occurs based on pipeline wall thickness and other specifications, operating stress level, the severity of the anomaly targeted for excavation, and dimensional uncertainty and tolerances associated with. In particular for this dig site, the procedure (or other documented evidence) should include the results of the analysis performed to ensure a safe sandblasting activity.  
- The construction contractor on site was Somerville and the non-destructive examination (NDE) contractor was NDT Group.
- The emergency response procedure was available on site and reviewed.
- The excavation site was in good working conditions including proper access, signage, ditch support, ingress/egress points, gas monitoring, firefighting equipment and documentation.    
- The pipe joint was fully exposed and supported. The depth of cover (DoC) was approximately 3 ft.
- The pipe joint was identified using the GPS survey coordinates, exposing the upstream girth weld, and measuring the length of the joint. A middle joint verification was also performed.
- The on-going activity at the site at the time of inspection was the NDE of the pipe - i.e. feature identification and marking.
- The in-line inspection (ILI) vendor's pipe tally (i.e. 2017 magnetic flux leakage (MFL) features list) and the dig sheet for this joint were reviewed. The targeted anomaly was an external metal loss (i.e. pitting - 67% WT (5.2 mm) depth, 23 mm axial length and 14 mm circumferential length). The pipe specifications are: 273.1 mm outside diameter (OD), Grade X46, API 5L, 7.8 mm WT, low-frequency electric resistance welded (ERW).
- Features marked on the pipe included metal loss anomalies (corrosion) and puddle welds (some of these were reported by the ILI and included in the features list).
- Magnetic particle inspection (MPI) was performed on the entire circumference of the exposed pipe joint.
- The NDE lead technician was CGSB Level 2 MT and UT certified.
- The upcoming NDE activities on the pipe joint were also discussed. The technicians confirmed that these will include the following:
          - The full pipe joint laser scan for the metal loss anomalies' assessment; 
          - An ultrasonic (UT) phased array inspection for the entire long seam and the upstream and downstream girth welds;         
          - The wall thickness (WT) measurements at the location of anomalies identified and the nominal WT measurements at the girth welds;
          - Puddle welds inspection by MPI and phased array or manual UT to verify any potential interaction with other threats.
- TNPI committed to provide the final NDE report for this site when it becomes available as requested by the inspectors.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide a copy of TNPI's sandblasting procedure demonstrating that all risks to excavation personnel are considered when this activity occurs, based on pipeline specifications, operating stress level, the severity of the anomaly targeted for excavation, and the dimensional uncertainty and tolerances associated with it. In particular for this dig site, the procedure (or any other documented evidence) should include the results of the analysis performed to ensure safe sandblasting activity.   Confirm that the minimum wall thickness (WT) of 2 mm or 20% WT whichever is greater, required for the safe grit blasting of pipe with anomalies greater than 70% WT determined by the engineering assessment is applicable to all types of pipe grades, WT and outside diameters of TNPI’s pipeline system. If not, provide the minimum WT for each type of pipe where this is not applicable and the excerpts from the safe grit blasting procedure including the appropriate values.

Due date: 2019-11-15

Date closed: 2019-11-15
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: No

Observation 2 - Dig site MP-328.88-2019

Date & time of visit: 2019-09-11 11:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

- The site was located in the vicinity of site MP-328.91-2019.
- The excavation site was in good working condition including proper access, signage, ditch support, ingress/egress points including ladders, gas monitoring, firefighting equipment and documentation.    
- The pipe joint was fully exposed and supported with an adequate depth of cover (DoC).
- There were no on-going activities at the site at the time of inspection.
- The targeted anomaly was an external metal loss of 73% WT depth, 28 mm axial length, and 20 mm circumferential length.
- The pipe coating was Polyken tape with no noted disbondments.
-  Features marked on the pipe included metal loss anomalies (corrosion) and puddle welds (18 were reported by the ILI and included in the features list). One puddle weld was identified as interacting with a potential lack of fusion after the preliminary magnetic particle inspection (MPI).
- Carbon equivalent (CE) probes were taken at each joint to perform a weldability test for future pressure containment sleeve installation, if required.
- TNPI committed to provide the final NDE report for this site when it becomes available as requested by the inspectors.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

 Provide a copy of the final non-destructive examination (NDE) report for all dig sites inspected: MP-328.88-2019, MP-328.91-2019, MP-323.51-2019 and MP-323.59-2019.
 

Due date: 2019-11-15

Date closed: 2019-11-18
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 3 - Dig site MP-323.59-2019

Date & time of visit: 2019-09-11 14:20

Discipline: Integrity Management

Categories:

Facility:

Observations:

The visitor orientation and log form, the safe work permit, and the JSA were reviewed and signed off.
- The line was shut down at inspectors' arrival. 
- The emergency response procedure was available on site and reviewed.
- The excavation site was in good working condition including proper access, signage, ditch support, four ingress/egress points, gas monitors with proper validation and testing, firefighting equipment, and documentation.    
- The pipe joint was fully exposed and supported. The depth of cover (DoC) was approximately 3 ft.
- The on-going activity at the site at the time of inspection was the NDE of the pipe (i.e. documentation of identified features).
- The targeted anomaly was an external metal loss (i.e. 67% WT (5.2 mm) depth, 5 mm axial length and 10 mm circumferential depth) located at the bottom of the pipe. Six puddle welds were identified by the in-line inspection (ILI) and marked on the pipe joint. No metal loss (i.e. corrosion) was identified on the puddle welds.
- The magnetic particle inspection (MPI) and the laser scan were performed on the entire circumference of the exposed joint.
- The long seam was located at the top of the pipe. Six external linear indications were identified following the MPI.
- Arc burns were also identified at both girth welds. They were marked and inspected. No external cracks were identified following the MPI.
- The NDE lead technician was CGSB Level 2 MT and UT certified.  
- The upcoming NDE activities on the pipe joint were also discussed. The technicians confirmed that these will include the following activities:
          - An ultrasonic (UT) inspection for the entire long seam and the upstream and downstream girth welds and the puddle welds;  
          - A lamination scan for identification of any potential threat interactions;
          - 20 points of manual verification of the laser scan findings.
- It was confirmed that the laser scan generates a full report for imperfections identified, however the engineering group also makes the calculations (i.e. modified B 31.G) for the repair criteria, as per CSA Z662 requirements.
- All puddle welds and arc burns are subject to engineering solutions for repair (e.g. sleeve installation). The NDE technicians confirmed that if pressure containment sleeves will be installed, the circumferential welds will be inspected by UT.
- It was also observed that the targeted anomaly for excavation was noted in the feature list as a "CISL" (i.e. Circumferential Slotting). It was noted that the reported size of this metal loss anomaly is comparable with another anomaly from a previously inspected dig site, but the classification was noted different in the feature list. Additional information was required regarding the ILI criteria for classification of the metal loss anomalies as reported by the ILI vendor.
- TNPI committed to provide the final NDE report for this site when it becomes available as requested by the inspectors.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the in-line inspection (ILI) criteria for the classification of each metal loss anomaly type as reported in the ILI feature list: Axial Grooving (AXGR), Axial Slotting (AXSL), Circumferential Grooving (CIGR), Circumferential Slotting (CISL), PITTING, and Pinhole). Include the dimensions and ILI tool tolerances for depth, length and width sizing for each category.

Due date: 2019-10-23

Date closed: 2019-10-24
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 4 - Dig site MP-323.51-2018

Date & time of visit: 2019-09-11 15:45

Discipline: Integrity Management

Categories:

Facility:

Observations:

- The excavation site was in good working condition including proper access, signage, ditch support, ingress/egress points, gas monitoring, firefighting equipment and documentation.    
- The pipe joint was fully exposed and supported. The depth of cover (DoC) was approximately 3 ft.
- Five compression sleeves (Petrosleeve) Type A, were installed on the pipe for anomaly repairs. The anomaly targeted for excavation at this site was a mid-wall lamination reported by the in-line inspection (ILI) as being surface breaking. The lamination was repaired by installation of a Type A sleeve.
- The upcoming activities were confirmed as the magnetic particle inspection (MPI) of the longitudinal sleeve weld and re-coating.
- TNPI committed to provide the final NDE report for this site when it becomes available as requested by the inspectors.
- Overnight site security matters were discussed. The site was confirmed to be protected overnight with metal fence on two sides towards the access road. Consideration for site monitoring methods  were suggested by inspectors.

 

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