Compliance Verification Activity Report: CV2223-309 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2223-309
Start date: 2023-03-21
End date: 2023-03-22


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

Integrity inspection of Sumas terminal tank construction to verify compliance to the OPR, CSA Z662-19, CLC and OC-065.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Day 1

Date & time of visit: 2023-03-21 08:30

Discipline: Integrity Management




Opening Meeting:
CER Inspection Officers (IOs) and TMEP staff introduced each others’ roles at a roundtable.

TMEP staff described the contracting structure of the project where KLTP is the main contractor overseeing the project and Ganotec, who is overseeing the tank construction, is a subcontractor to KLTP.
HCBI supplied the tank material. CER IOs and TMEP Staff discussed the project organizational chart.

TMEP Staff provided an overview of the construction work being undertaken, which included:

  1. Modifications to Tank TK-104 and containment
  2. Addition of Tank TK-100
  3. Tanks TK-100 and TK-103 containments
  4. Manifold and stormwater system
  5. Fire protection including fire foam tanks, fire lines
  6. Electrical service building

So far, TK-104 is the only complete and operating tank of the three tanks in the scope of the project.

TMEP staff explained that all tank drains require manual operation. TMEP explained that the TK-100 material is stored at another location (Mainland gravel quarry).

CER IOs and TMEP Staff discussed welding inspection scope, performance, and requirements. TMEP explained that its welding inspectors don’t take the welding parameters themselves and that they instead witness the contractor welding inspectors who are responsible for taking the welding parameters at a rate of one weld per welder, per welding procedure, per month. TMEP explained that the Universal Pegasus International (UPI) welding inspectors, who are the Joining Program Welding Specialists hired by TMEP, take parameters when they do welding inspections. TMEP explained that it does not have a requirement to witness a specific number of welding parameter verifications for its inspectors and the UPI welding inspectors. TMEP explained that the TMEP welding inspectors and the UPI welding inspectors sign off on the contractor welding inspectors’ reports. Records were provided by TMEP for welding parameter inspections and they were signed off by TMEP and UPI inspectors. TMEP explained that they had welding performance issues at the beginning of the project. TMEP explained that some welders had to be replaced and that the repair rates have now improved.

TMEP confirmed that 100% of piping welds are inspected on their entire circumference via NDE and that the tank welds receive NDE as per API 650 requirements. 

TMEP explained the field-applied coatings are applied by a subcontractor to KLTP and that coating tests are performed by the subcontractor coating inspectors and that KLTP and TMEP coating inspectors witness a sample of those coating tests.

CER IOs and TMEP Staff went over the inspection plan to inspect the tanks and related infrastructure as well as piping components.

Site Specific and Safety Orientation (10:09 am) 
TMEP provided a Safety orientation. Considerations included muster points, human-machine interference, wildlife precautions, environmental protection precautions, and PPE.

Tank TK-104:
After the site-specific orientation, CER inspectors went to inspect the field activities on site.
The secondary containment of TK-104 has been completed and TK-104 is back in service. TMEP explained that a synthetic liner has been installed underneath the tank bay and has been covered with layers of geotextile, sand, and gravel to protect it from fire. A layer of polyurethane has also been installed behind the shotcrete that was sprayed on certain containment walls. Other containment wall sections were made of pre-fabricated concrete panels. TMEP confirmed that the joints of the pre-fabricated concrete panels were designed to not fail if exposed to fire. TMEP also provided a drawing which indicated the joints were made with fire-resistant materials.

Fire protection system:
Work to install the new fire protection system is in progress. Some piping has been buried and TMEP confirmed that it had been hydrotested. The buried sections of the piping are made of HDPE and the exposed section is made of galvanized steel. The new fire water pond, fire pump building and foam buildings were in progress.

Tank TK-100:
Ganotec explained the construction process for TK-100. Course #5 had its vertical welds completed and is ready to be attached to the completed courses of the tank. Ganotec is preparing to lift the tank to weld course #5 to it. Ganotec explained the lifting process for the tank and TMEP provided a copy of the lift plan. TMEP explained that the lift plan provided by Ganotec has been reviewed by TMEP’s Construction Management Team.

TMEP explained how the plate alignments (peaking and banding) are verified to ensure they meet API 650 requirements. A repair was in progress for a banding. TMEP explained that repair welding performed to correct dimensional deficiencies is conducted using one of the approved welding procedure specifications in the same way that repair welding would be performed to correct volumetric deficiencies identified by NDE. TMEP also explained that the tank shell plate materials, CSA G40.21 Grades 260WT and 300WT, are low alloy carbon steels with low hardenability and high ductility and that these materials are not particularly sensitive to heating cycles.  Accordingly, TMEP indicated that it does not have integrity concerns with repeated weld repairs for the purpose of correcting dimensional deficiencies such as peaking and banding.
The construction of the vapour recovery unit for TK-100 was in progress.

Tank TK-103:
Some piping work was in progress at TK-103 which is currently deactivated. TMEP explained that a nozzle was added to the tank, which only had one nozzle in the past. TK-103 will now have two 16-inch nozzles connecting it to the 20-inch tank line.

Compliance tool used: No compliance tool used

Observation 2 - Day 2

Date & time of visit: 2023-03-22 08:30

Discipline: Integrity Management




CER IOs met with TMEP representatives, including the Joining Program Welding Specialist (JPWS) from UPI, the engineer of record for the Joining Program. There is one UPI JPWS for the facilities in the lower mainland (Burnaby, Westridge, and Sumas). The JPWS explained that UPI’s role in pipeline construction includes auditing both the TMEP and contractor’s welding inspectors, but for facilities, UPI only audits the contractors’ welding inspectors. TMEP explained that the UPI JPWS and the three qualified TMEP welding inspectors conduct oversight of the joining program for the Sumas terminal.

CER IOs and TMEP Staff went over the documentation provided by the company:

The plan for the day includes inspecting brownfield locations for welding and coating. TMEP staff explained that a weld was currently occurring at the manifold.

Manifold Area:

An excavation had been made in preparation for installing a segment of the new TK-100 product line. The excavation was properly sloped and had two means of access/egress.

TMEP and CER IOs walked through the manifold area where the new piping is being installed. This area is considered “brown” as there is product flowing in the existing piping. The new piping installed has not been connected yet to the existing piping.

Some of the new piping had a white coating and some had a grey coating. TMEP explained that the white coating was for above-ground exposure while the grey coating was for the piping that will be heat traced and insulated.

Welding was in progress to join a pipe segment and a bend. The contractor, TMEP, and UPI welding inspectors were on site to verify the welding process. The contractor welding inspector provided a copy of the welding procedure data sheet (WPDS) which identified the welding procedure specification as KIC-1 Rev 3. CER IOs witnessed the welding inspectors verifying the parameters for the root and hot passes. The piping materials, consumables, pre-heat verification temperature stick, and welding parameters were in accordance with the welding procedure. After the inspection, TMEP provided the welder qualification record, which demonstrated that the welder who completed the weld was qualified for that welding procedure.

Coating Materials

CER IOs verified the storage of the field-applied coating materials. The coating materials are stored in an insulated and heated container.  The contractor coating supervisor explained that the above-ground piping exposed to the atmosphere is coated with the Duraplate primer and a Hi-Solids Polyurethane top coat. The below-ground field applied coating is SP-2888. CER verified a sample of coating product containers and they were all not expired.

After the inspection, TMEP explained that it does not apply CSA-Z245.30 for the field application of the coating on the above-ground piping as this standard is intended primarily for the buried and submerged service, as explained in clause 1.1 of CSA Z245.30. Instead, TMEP requires the coating to be applied on the above-ground piping as per the coating manufacturer's instructions, as required by TMEP’s specification TMEP-GC3101. TMEP provided the Product Information and Applications Bulletins from the coating manufacturer and a sample of the coating application report by the coating contractor.

TMEP also provided a qualification record for the coating applicator at the Sumas terminal, which indicated that he is qualified to apply the SP-2888 R.G. Brush Grade Coating, which is the field-applied coating system for the below-ground piping. The coating applicator is also certified NACE Coating Inspector Level 1.

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