Compliance Verification Activity Report: CV2223-065 - Maritimes & Northeast Pipeline Management Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2083
• Inspector 2349

Regulated company: Maritimes & Northeast Pipeline Management Ltd.

Operating company: Enbridge Inc.

Province(s) / Territory(s):

• New Brunswick

Discipline(s):

• Integrity Management

Rationale and scope:

Construction integrity inspection of Saint John Lateral Reversing Falls Bridge Replacement Project.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Saint John lateral

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• 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

Observations (no outstanding follow-up required)

Observation 1 - OBSERVATION No.1: Day 1 – Part 1

Date & time of visit: 2022-09-19 08:30

Discipline: Integrity Management

Categories:

• Pipeline
• Excavations
• Pipe Condition
• Inspections
• Welding Operations
• Repairs
• Materials
• Coating
• Evaluation Imperfections

Facility:

• Saint John lateral (Pipeline)

Observations:

OPENING MEETING AND PROJECT UPDATE

CER inspectors met with Enbridge representatives at the construction trailer on Enbridge’s Saint John Lateral Reversing Falls Railway Bridge Replacement project (the project) site. CER inspectors received the Enbridge and Somerville orientations. Note: Somerville is the prime contractor for the project. After the opening meeting, CER inspectors obtained a project update and discussed the following items with Enbridge representatives:

1. The Maritimes & Northeast Pipeline (M&NP) pipeline will remain in operation during the entire length of the project.
2. Enbridge determined that no pressure restriction was necessary for the work to be completed during the project.
3. The pipeline was operating at about 3275 kPa (475 psi) on the morning of the CER inspection. Note: The authorized maximum operating pressure (MOP) for the M&NP pipeline is 4480 kPa (650 psi).
4. The method selected by Enbridge to perform the pipeline replacement without stopping the flow of product is a technology developed by the STATS Group involving temporarily isolating the existing pipeline segment and re-directing the flow of product into a temporary pipeline until the new pipeline is built.   
5. In order to achieve this hot tap and plugging intervention, two split tees and purging & equalization (P&E) fittings had to be installed directly on the existing pipeline segment.
6. At the time of the CER inspection, the two split tees and P&E fittings had already been welded onto the existing pipeline by the STATS Group. Note: At the time of the CER inspection, the STATS Group personnel were no longer at the project site.
7. Non-destructive examination (NDE) with magnetic particle inspection (MT) and ultrasonic testing (UT) was completed on the existing pipeline prior to welding the fittings.
8. Carbon equivalent (CE) measurements were also completed and confirmed to be within the welding procedure’s criteria.
9. Acuren was contracted by Enbridge to conduct the NDE and CE measurements.
10. At the time of the CER inspection, activities occurring at the project site were mostly civil work.
11. An overview of Enbridge’s quality assurance and control (QA/QC) activities as well as the oversight of the project was provided.
12. Enbridge has two qualified inspectors responsible for the welding and coating activities for the project.
13. Enbridge’s welding inspectors:
    1. Conduct quality checks on all welding activities.
    2. Witness the Somerville welding inspector’s verifications.
    3. Sign off on a certain number of welding inspections done by the Somerville welding inspector.

13. 1. 1. For production welding (i.e. the welds not performed on the operating pipeline), an Enbridge welding inspector is required to record the welding parameters of a full weld at least once a day. Different welders are selected to verify the welding parameters every day.
       2. For in-service welding (i.e. the welds performed on the operating pipeline at the project’s construction site), an Enbridge welding inspector is required to witness the welding and verify the welding parameters for 100% of the welds.
14. For the coating activities, Enbridge’s coating inspectors do not conduct the inspection and testing themselves, but witness and sign off on Somerville’s coating inspections and testing. Note: At the time of the CER inspection, there were no coating activities taking place.
15. The STATS Group will return to the project’s site to conduct the hot tapping and stop flow operations. Note: This stage of the project is scheduled to take place later next month (i.e., October).
16. Enbridge representatives explained that for this project:
    1. The STATS Group’s welding procedures were followed to weld the two split tees and P&E fittings onto the existing operating pipeline. 
    2. The Somerville procedures are used for the other welding on the project site and at the fabrication yard.
    3. Enbridge reviewed and approved all the abovementioned procedures for the project.
    4. The STATS Group provided its own welders for the installation of the two split tees and P&E fittings.
    5. The STATS Group welders were qualified prior to coming to the project’s site and Enbridge reviewed the qualification records for each welder prior to the beginning of the welding work.
17. Stantec was hired as the engineering firm for the project.
18. Stantec reviewed the material testing records (MTRs) for the project.
19. The Enbridge Chief Inspector also reviewed the MTRs to ensure the materials satisfied the welding procedures.
20. CER inspectors also reviewed the following sample of documentation and records for the project:
    1. Provided to CER inspectors prior to the inspection:
       1. The coating Manufacturer’s Qualified Application Procedures (MQAPs).
       2. The welding procedure specifications (WPS)
       3. The procedure qualification records (PQR)
    2. Provided at the time of the CER inspection:
       1. The chief inspector’s valid National Association of Corrosion Engineers (NACE) Level I Coating Inspector and Canadian Welding Bureau (CWB) Level II Welding Inspector certifications.
       2. The STATS Group’s welders and welding inspector qualification records.
       3. The Canadian General Standards Board (CGSB) certifications for the NDE inspectors.
       4. The CE testing records for the pipe to which the split tees and P&E fittings were welded onto.
       5. The MTRs for the split tees and P&E fittings.

1. The split tees and P&E fittings were welded on the operating line.
2. The downstream location where the existing pipeline is to be isolated (i.e., hot tapped and plugged) used to be underground but at the time of the CER inspection, it was exposed and within a trench box.
3. The upstream location where the existing pipeline is to be isolated (i.e., hot tapped and plugged) runs aboveground along the bridge. At the time of the CER inspection, a scaffold was built to access the pipe.
4. A new pipe support was installed for the new pipe riser that will be part of the new replacement pipeline.
5. The heat number on the split tees installed at the upstream location where the existing pipeline is to be isolated matched the heat number on the MTR provided at the construction trailer.
6. There is still a significant amount of backfill that will need to be completed prior to Enbridge being able to start the construction of the temporary 10-inch line and of the permanent 16-inch replacement line.

Compliance tool used: No compliance tool used

Observation 2 - OBSERVATION No.2: DAY 1 – Part 2

Date & time of visit: 2022-09-19 13:30

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Pipe Condition
• Pipe Storage and Handling
• Inspections
• Welding Operations
• Materials
• Coating
• Evaluation Imperfections

Facility:

• Saint John lateral (Pipeline)

Observations:

In the afternoon, CER inspectors inspected the work at the Lorneville fabrication yard in Saint John. The fabrication yard’s Safety Inspector conducted a safety meeting and informed attendees of the hazards to be aware of at this site. All attendees signed the safety meeting report.

WELDING INSPECTOR

1. He is responsible for the quality assurance (QA) of the Somerville contractors involved with welding and coating on this project.
2. Most welders are very experienced and the less experienced crew members are acting as helpers on this project.
3. All of the material ordered for the project is delivered at the fabrication yard and is inspected by Somerville and Enbridge representatives.
4. Some of the welders were in the process of being qualified to the welding procedure.

1. Larger fittings (i.e., bends and elbows) are stored outside while smaller fittings (i.e., bolts and flanges) are stored in a container.
2. One flange was delivered without a heat number and as a result, was quarantined. Note: It was explained to CER inspectors that this fitting cannot be used on the project because it was not possible to link this fitting to its associated Material Testing Records (MTRs).
3. Materials received at the fabrication yard are inspected at the time of delivery and reports are written up to record all observations.
4. Stantec, as part of its mandate to review the MTRs, discovered that some of the fittings were delivered without undergoing a stress relief heat treatment. Five (5) fittings with this heat treatment issue were in quarantine. A notification was sent to Enbridge as a warning and Stantec is responsible for ensuring that these fittings receive the proper stress-relief heat treatment before installation.
5. Welding inspections are conducted by the Enbridge welding and coating inspector to record the welding parameters and are done at a frequency of one per day, alternating welders each day (approximately 10 percent of production welds). The welding inspector indicated that a welding inspection was performed on the morning of the CER inspection.
6. The welding procedure specifications (WPS) for the production welds on the replacement pipe are established and qualified as specified in the ASME Boiler and Pressure Vessel Code, Section IX, as opposed to CSA Z662-19 Clause 7. According to CSA Z662-19 Clause 7.2.5 e), ASME Boiler and Pressure Vessel Code, Section IX may be used provided that piping welds are maintenance welds. CSA Z662-19 Clause 10.13.1.1 considers the replacement of portions of a pipeline as maintenance welding.
7. The non-destructive examination (NDE) of the welds is done with radiographic testing (RT) using gamma rays.

1. All welds performed to qualify welding inspectors are destructively examined with the use of a bending test.
2. During the welder’s qualification, the Enbridge welding and coating inspector recorded the welding parameters and performed other necessary checks (i.e., alignment, internal condition of weld, etc.).
3. The welder is qualified after:
   1. Performing a weld on a 5 cm (2 inch) outside diameter pipe oriented at 45 degrees.
   2. Completing a girth weld on a 40 cm (16 inch) outside diameter pipe.
   3. The produced welds successfully pass a bending test and an NDE test respectively.

1. The MTR for pipe with heat number 539233. Note: On day 2, Enbridge representatives provided the CER inspectors with the requested MTRs.
2. The MTRs for three (3) elbow fittings stamped with the following unique identifiers:
   1. 241058-011
   2. 241058-120
   3. 241058-130

3. A description of how Stantec was able to determine that the quarantined fittings did not receive the stress relief heat treatment. Note: On day 2, Enbridge representatives explained that:
   1. During Stantec’s review of the delivered materials, a certificate was noticed to be missing for the fitting in question implying that a stage in the heat treatment process (i.e., the final stress relief) was not performed on that fitting.
   2. Since the fitting was not properly stress-relieved, the concern is that when it is cut, the dimensions will change.
   3. A local fabrication shop was contacted and arrangements were made to stress relieve the fittings if the fittings are needed on the project.
4. The report generated by the Enbridge welding and coating inspector for the following:
   1. Welder qualification witnessed on that day. Note: On day 2, Enbridge representatives provided the welding parameter form taken during the welder qualification witnessed on the previous day.
   2. The welds done on the split tees and P&E fittings. Note: On day 2, Enbridge representatives provided the welding parameter form taken during the welding of these fittings.

Compliance tool used: No compliance tool used

Observation 3 - OBSERVATION No.3: DAY 2

Date & time of visit: 2022-09-20 08:30

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Pipe Condition
• Pipe Storage and Handling
• Inspections
• Welding Operations
• Repairs
• Materials
• Coating
• Evaluation Imperfections

Facility:

• Saint John lateral (Pipeline)

Observations:

SAFETY MEETING

The CER inspectors met with Enbridge representatives at the Lorneville fabrication yard. The fabrication yard’s Safety Inspector conducted a safety meeting and informed attendees of the hazards to be aware of at this site. All attendees signed the safety meeting report.

PROJECT UPDATE

CER inspectors were informed that:

1. Yesterday’s qualification welds passed the bending testing and as such qualified the welder for the project. Note: The CER inspectors were provided with the bending test samples and noted the qualified welder’s provincial identification number written on the samples.
2. Enbridge representatives stated that for a weld to pass the bending test, it can’t demonstrate any signs of damage or defects (i.e., breaks, cracks, tears, etc.) larger than 1/8 inch (approximately 3 mm).
3. Production welds were going to be conducted on that day.

1. The parameters recorded in the welding parameter forms provided for the following welds, complied with all of the requirements of the welding procedure specifications (WPS):
   1. Pipe welded during the welder qualification witnessed on the previous day.
   2. The welds done on the split tees and P&E fittings.
2. In the provided welding parameter forms, CER inspectors noted a difference in the terminology used for current polarity. In the welding parameter forms, the term direct current electrode positive (DCEP) is entered while in the WPS, the term direct current reversed polarity (DCRP) is used. Enbridge representatives explained that there are different ways of referring to the polarity of the welding rod but in both cases (i.e. DCEP or DCRP), the welding rod is the polar positive.
3. The MTR for pipe with heat number 539233 included the various certificates of testing required by CSA Z245.1-18 for steel pipe manufacturing.
4. The MTRs for the three (3) elbow fittings stamped with the following unique identifiers included the various test results required by CSA Z245.11-17 for steel fittings:
   1. 241058-011
   2. 241058-120
   3. 241058-130
5. CER inspectors noticed that in the MTR for:
   1. Fittings 241058-011 and 241058-120, the heat treat condition is entered as normalize.
   2. Fitting 241058-130, the heat treat condition is entered as quench and temper.
6. CER inspectors asked Enbridge representatives to provide a rationale for the different heat treat conditions for these three (3) fittings. After the CER inspection, Enbridge sent an email to CER inspectors stating that:

1. The elbows are considered to be fittings within CSA Z245.11 and must undergo heat treatment. 
2. CSA Z245.11 allows for one or multiple of the following:
   1. 1. Stress Relieving
      2. Normalizing
      3. Normalizing and Tempering
      4. Quenching and Tempering
3. The elbows have all undergone either Normalizing or Quenching and Tempering, and are therefore code compliant to CSA Z245.11.

7. The material received by Enbridge demonstrates good traceability and Enbridge has adequate documentation control practices and as such, CER inspectors have no outstanding concerns regarding the reviewed documentation.

1. The helper was:
   1. Constantly adjusting the amperage according to the direction of the welder
   2. Verifying the pre-heat temperature with the correct heat stick (i.e. 300 ^°F or 150 C) after heating the weld with a gas torch.
   3. Handing the correct electrode rod (i.e., 6010) to the welder for the root pass.
   4. Grinding the weld created after each welding rod was fully consumed before the welder started welding with a new rod.
2. Spacers were in place during the root pass.
3. The pipe segments and fittings rested on supports that provided the necessary alignment while welding the different components together (i.e., no clamps were used).
4. The welder performed tack welds to provide stability to the assembly before proceeding with the root pass.
5. With the use of a small mirror, the welder verified the internal condition of the root pass before fully closing it.
6. The welding was conducted in a sheltered area to protect from the rain and wind.

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: