Compliance Verification Activity Report: CV2021-470 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-470
Start date: 2020-09-14
End date: 2020-09-16

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Integrity inspection of O&M activities for the reactivation segments to verify compliance to the OPR and CSA Z662.

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 - Day 1

Date & time of visit: 2020-09-14 13:30

Discipline: Integrity Management

Categories:

Facility:

Observations:

- The Canada Energy Regulator (CER) inspectors met Trans Mountain (TM) representatives at the TM construction site in Jasper, AB.
- Temperature checks for the CER inspectors were performed as per TM's COVID-19 protocol.
- TM safety orientation was conducted for inspectors.
- The following information was provided by TM representatives during the opening meeting:

- Regarding the cut-out repair slevees, the CER inspectors metioned that it would be beneficial for TM to conduct a systematic evaluation of the defect(s) mitigated by the initial installation of the sleeves, to determine whether any defect has grown during the pipeline operation since the time of sleeve installation.
- TM representatives confirmed that the field data from the dig/repair program will be used in the Engineering Assessment (EA) required to be filed with the Commission as per Reactivation Order AO-005-OC-2.
- A Level 3 vehicle wash was performed as per TM requirements.

Compliance tool used: No compliance tool used

Observation 2 - Day 2

Discipline: Integrity Management

Categories:

Facility:

Observations:

- The CER inspectors and TM representatives met at the construction site for temperature checks as per TM COVID-19 safety protocol and then proceeded to the Stopple Tee site at KP 449.848.
- A tailgate meeting was conducted prior entering the site.
- The Field Level Risk Assessment (FLRA), Job Site Assessment (JSA) and the Damage Prevention Plan for ditch entering were reviewed on site.
- The prime contractor on site was Simpcw Ledcor Limited Partnership (SLLP). The Non-Destructive Examination (NDE) was conducted by Applus + RTD. Both contractors were hired by TM.
- The activity scope at this site was to perform a Non Destructive Examination (NDE) of the Stopple Tee on the NPS24 reactivation pipeline to verify the integrity of the fitting. The NDE consists of visual inspection of the Stopple Tee, lifting lugs, nipples and longitudinal and circumferential welds, full Magnetic Particle Inspection (MPI) and Ultrasound (UT) inspection using shear wave technology (i.e., 0 degree angle beam probe for wall thickness  (WT) measurements and 45 degree angle beam probe for detection of flaws in the circumferential and long seam welds).
- Site and feature location confirmation was determined through an initial survey, identification of the upstream girth weld location and In-Line Inspection (ILI) data.
- The excavation consisted of approximately 25 m NPS24 (deactivated) exposed pipe including the Stopple Tee. The housekeeping of the site was adapted, the dig site was fenced, with ingress/egress points, fire extinguishers, windsock and gas monitoring in place.
- The Stopple Tee was properly supported and contrast painted in preparation for the MPI.
- The pipe Depth of Cover (DoC) was approximately 1.2 m.
- The coal tar coating was removed from the pipe. Approximately 2 m of pipe was coated with white polyken tape coating. It was confirmed that this coating has been applied after pipeline construction but the reason was unknown. The CER inspectors requested TM to provide information regarding the reason for the presence of the white tape coating at this location. Following the inspection day, TM responded that it is reviewing the historical records, but likely, the tape was applied as part of an infrastructure removal operation and the tape was the preferred maintenance-applied coating of the time. TM representatives confirmed that the Electromagnetic Acoustic Transducer (EMAT) ILI tool has the ability to detect coating type and disbondment. TM representatives confirmed that the tape coating will be removed and the pipe segment will be sandblasted followed by visual inspection. It was also confirmed that while performing all on site activities, the Cathodic Protection (CP) of the pipeline is disabled. The coal tar coating exposed at the dig sites was confirmed to be in good condition. The coal tar coating is only removed when required to perform inspection and NDE and when classified as poor condition per TM Coating Evaluation Procedure of Exposed Pipe.
- The girth weld located upstream of the Stopple Tee used for feature identification was exposed and sandblasted. CER inspectors requested details regarding the opportunistic NDE of the girth weld. TM representatives confirmed that inspections other than visual of the girth weld were not part of the scope of work at this site. The only welds subject to NDE would be the circumferential and longitudinal welds of the Stopple Tee. TM confirmed that any piping exposed during an integrity dig other than the targeted features/anomalies will have a visual assessment performed per TM Anomaly Assessment procedure to confirm there are no visible signs of anomalies (i.e. dents, corrosion) and if any anomalies are found during the process, then further assessment will be performed which will expand the scope for given dig site. TM representatives also confirmed that all NPS24 pipeline field joints were radiographically inspected at the time of construction in 1953. It was also confirmed that TM has a program in place to assess the integrity of the girth welds when ILI features are reported. It was mentioned that five previous cut-out joints were subject to a throughout NDE assessment and no issues were identified. Therefore, TM has not found reasons for any additional field inspection of the girth weld daylighted during the dig program. TM confirmed that there are approximately 58 girth welds removed from the pipeline system as result and/or part of the repair of previous dig sites and are undergoing further evaluation to form part of the engineering assessment. The inspectors observed the visual inspection, marking and measurements (location, hardness, WT) and the repair of one out of three arc burns identified on the joint. Two of the arc burns were located in the Heat Affected Zone (HAZ). The NDE technicians confirmed that the 5% Nital etching solution used for arc burns was dated January 2020. The inspectors requested confirmation from TM regarding the testing and effectiveness of the Nital solution as per CSA Z662-19 requirements.  Following the inspection, TM provided a letter from its NDE contractor which  confirms that a new batch of Nital etch solution is created for the NDE kits yearly or any time when the kits run out of solution. The solution is verified for effectiveness at Applus+ RTD facility upon creation prior to the mobilization of the kit, as well as in service on arc burns, as a positive results from the etching process deems the solution is effective.
- Applus + RTD technician was CGSB Level 2 certified for MT and UT inspections.
- The NDE instrumentation was calibrated and valid.
- The arc burn was buffed out in increments of 10% WT and removed at the depth of 27% WT, considered acceptable by TM as per its NDE procedure. Hardness and WT measurements were taken throughout the process of buffing. UT shear wave with a 60 degree beam probe was conducted to verify the presence of any potential underlying anomaly at the location of arc burns.
- TM representatives confirmed that no anomalies were reported by the ILI on the pipe at this dig location.
- TM representatives also confirmed the following actions for the future activities at this site and subsequent sites:

- The CER inspectors noted that the chamfer of some bolts on the flange of the Stopple Tee did not extend beyond the face of the associated nuts (one being below the nut face) and were not consistent throughout the connection as required by the CSA Z662-19. TM representatives confirmed that the flange will be removed for further assessment as per the scope of excavation and then new gasket, bolting and nuts will be installed.
-The CER inspectors noted that it would be likely that a second Stopple Tee has been installed on the pipeline and that the same bolting issue may be present, therefore additional information was requested to TM to confirm the presence of any other Stopple Tee on the pipeline and TM's plan to inspect the flange bolts and nuts to ensure compliance with CSA Z662-19. TM provided the response to inspectors inquiry following the inspection day. TM confirmed that there is another Stopple Tee located at approximately KP 406 which is currently included in the scope of assessment for the NPS24 reactivation process. TM confirmed that is currently assessing the feasibility of utilizing the fitting at KP 406 for future pipeline isolation work and it will make a determination whether to retain a third party contractor to confirm the operatibility of the fitting, or otherwise to remove it from the pipeline system. The CER inspectors note that the response does not clearly address TM's plan to inspect the Stopple Tee flange bolts and nuts for compliance with CSA Z662-19, if it determines that the fitting will remain on the pipeline (IR 1). TM also confirmed that the Stopple Tee at KP 449.848 has been installed in 1980's or 1990's and it was part of a TM mainline isolation operation to allow the removal of infrastructure no longer deemed necessary. Furthermore, TM confirmed that during the execution of field assessments at KP 449.848, it was still assessing the feasibility of utilizing the Stopple Tee for future line isolation work, and it has been determined that the fitting is no longer required, therefore, the recommendation is to replace the Stopple Tee with straight pipe. Since this new information is in contradiction with the information received during the inspection with regards to the follow-up activities involving the fitting, further clarification is required regarding TM's plans with the fitting at KP 449.848 (IR 2).
- The following NDE activities were performed on the Stopple Tee:- The next steps for this site were discussed and TM confirmed that the following activities will take place:- The CER inspectors requested TM to provide the NDE report for this site. TM submitted the 24 hr. NDE report  which was reviewed for the accuracy with inspection observations. 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The response #1 of the CER inspection queries submitted on 22 September 2020 states that:
"Another stopple tee is located within the Reactivation scope of work at approximately kilometer point 406 and is currently being incorporated part of the scope for assessment. TM is currently assessing the feasibility of utilizing this fitting (KM 406) for future line isolation work, and will make a determination whether to retain a 3rd party contractor to confirm the operability of this fitting, or as an alternative, will proceed with removal of the fitting from the system."

The inspection query was for TM to confirm the presence of a second Stopple Tee on the pipeline and the plan to inspect the fitting flange bolts and nuts for compliance with CSA Z662-19 requirements, similar to the observation made for the Stopple Tee inspected at dig site KP499.848. TM response does not clearly address TM's plans to inspect the confirmed Stopple Tee at KP406, if it is determined to be feasible for future pipeline operations.

IR 1.
Confirm whether the Stopple Tee at KP406 has been determined to remain on the pipeline. If yes, provide TM's plan to assess the fitting flange including bolts and nuts for compliance with CSA Z662-19.

 

Due date: 2020-10-05

Date closed: 2020-10-06
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 - Day 2 - IR 2

Discipline: Integrity Management

Categories:

Facility:

Observations:

Observation created following TM response #2.a to inspection Information Request regarding the reason for the installation of Stopple Tee at dig site KP 449.848 and keeping it in the system.

The response states:
"The stopple tee was installed as part of a Trans Mountain mainline isolation operation to allow for the removal of infrastructure no longer deemed necessary. During the execution of this field assessment, TM was still assessing the feasibility of utilizing this fitting for future line isolation work, and it has been determined that it is no longer required, therefore the recommendation is to replace the Stopple Tee with straight pipe."

This new information is in contradiction with the information received during the inspection with regards to the follow-up assessment of the fitting including flange removal and components replacement (Refer to inspection observation - Day 2).

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Confirm TM plans with regards to Stopple Tee at KP 449.848:
1. Further assessment of the fitting including removal of the flange and components (i.e.,. gasket, bolts and nuts) as it was confirmed during the inspection; and/or
2. Removal of the fitting and replacement with a straight pipe.
In addition:
3. Confirm that the action plan for the Stopple Tee at Kp 449.848 is similar to the plan for the Stopple Tee at KP406. If not, provide rationale.

Due date: 2020-10-05

Date closed: 2020-10-06
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

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