Compliance verification activity type: Field Inspection
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 construction inspection of TMEP Spread 1 to verify compliance to Certificate OC-065, the Onshore Pipeline Regulations and CSA Z662-19.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Construction Office
Date & time of visit: 2020-01-20 08:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
CER inspectors met Trans Mountain Expansion Project (TMEP) representatives at the Spread 1 construction office. CER inspectors received the TMEP and SA Energy Group (SAEG) visitor orientations. The Spread 1 TMEP Project Manager provided an update on the progress of the project. SAEG is the prime contractor for the project. TMEP has several field representatives to provide oversight and ensure quality for the project, including a management team, welding and coating inspectors, and other field inspectors. Some of the organizational charts for the project that were filed as part of Condition 88 of Certificate OC-065 were reviewed and the information provided by TMEP representatives was consistent with those charts. TMEP representatives explained that Applus+ RTD was the NDE contractor for the project and that it had been hired directly by TMEP. TMEP representatives explained that they have access to Qualified Registered Professionals (QRP) for field assessment of geohazards. This service is provided by Stantec. Specialized QRP service has been provided by BGC, who has done the initial assessment of geotechnical areas. The project manager also explained that, based on the experiences of other drills completed in the area by other companies, some changes to the Horizontal Directional Drillings (HDDs) of the North Saskatchewan River and the Calgary Trail crossings were being assessed by Thurbur Engineering, serving as independent specialized QRP. TMEP explained that these changes will follow the required Management of Change (MOC) process and the Field Change Manual (filed in accordance with condition 51 of Certificate OC-065). The Senior Welding Inspector explained that there is currently one main gang and two tie-in welding crews on the project. It was explained that the welding inspectors are aiming to complete three weld pass parameters verifications per day. It was confirmed that the welding inspectors had access to all the welding procedures and qualification records. TMEP representatives stated that all the welding procedures using Annex K repair criteria had been qualified with project pipe. It was also clarified after the inspection that the welding procedures for the strain based design sections (using high strain capacity pipe) have also been qualified using project pipe. A sample of the following documents and records were provided and reviewed:
Compliance tool used: No compliance tool used
Observation 2 - Welding Procedures - NNC
Date & time of visit: 2020-01-21 08:00
Welding data sheets for the welding occurring at the time of this inspection were provided by the company. Among these data sheets, three are SAEG procedures (SARP-UP-002, SABW-003, and SAFC-DN-001) that have not been filed with the CER. TMEP representatives explained that these welding procedures have been approved by TMEP and have been issued for use in the field. They also explained that SAEG welders preferred to use the SAEG procedures, since they are familiar with them. As these welding procedures and their supporting qualification records have not been filed with the CER for at least 45 days prior to commencing welding with these procedures, TMEP is in non-compliance with Condition 111 of Certificate OC-065. When TMEP representatives were informed of the non-compliance, they agreed to immediately stop using the SAEG procedures. Six welds had been subjected to SAEG procedure SAFC-DN-001 and these welds were quarantined, pending a response by the CER on the acceptance of these welds. A Notice of Non-Compliance was issued to address this non-compliance.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The company decided to remove the welds made to the SAEG procedure from the pipeline. The company indicated on January 28th that 5 of the welds had been cut out and re-welded with approved TMEP welding procedures. CER inspectors request that the company send a confirmation that the remaining weld made with the SAEG procedure has also been removed.Company confirmed on 7 Fecruary 2020 that the 6th weld subjected to SAEG procedure SAFC-DN-001, was cut out and was re-welded using approved TMEP welding procedures. On February 3, 2020, Trans Mountain filed the omitted SAEG procedures with the CER for review and approval (Filing ID C04519).
Due date: 2020-02-14
Date closed: 2020-02-10 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 - Approval of SAEG Welding Procedures
Welding data sheets for the welding occurring at the time of this inspection were provided by the company. Among these data sheets, three are SAEG procedures (SARP-UP-002, SABW-003, and SAFC-DN-001) that have not been filed with the CER. TMEP representative explained that these welding procedures have been approved by TMEP and been issued for use in the field.
Compliance tool used: Information Request (IR)
CER inspectors request that Trans Mountain explains how the use of the SAEG welding procedures had been approved by Trans Mountain prior to their use and to provide the necessary records to support the explanations.
Due date: 2020-02-21
Date closed: 2020-03-10 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.
Observation 4 - Flint Stockpile Yard
Date & time of visit: 2020-01-20 14:30
Prior to heading onto the Right-of-Way (ROW), CER inspectors’ rental car was washed and treated with dilute bleach (also referred to as a biological car wash) to avoid the transfer of biological threats onto the ROW. CER inspectors visited the Flint-Enoch pipeline stockpile storage yard, where they were met by the Flint yard manager and his assistant, who provided us with a yard safety orientation. CER inspectors observed welded double joint pipeline lengths lifted onto a flatbed truck with a hoe. The hoe used Teflon pads to avoid damaging the FBE-coated pipe. Ropes around the pipe mostly avoided contact between the stacked pipes. Pipes observed appeared to be properly piled to prevent damage to the pipe and coating, and to ensure the safety of the workers. TMEP representatives explained that the non-compliance regarding to coating markings identified during inspection CV1819-447 has been addressed. CER inspectors observed a sample of pipes that had the markings on the coating corrected. Other products stored in the yard included, High Density Poly Ethylene (HDPE) pipe and stainless steel conduit for fibre optic cable which will be used for leak detection. The traceability of the pipe lengths was described to the CER inspectors by the Flint yard manager: When the yard receives coated pipes, these are inspected by an independent inspection company. The inspectors look for gouges, scrapes, coating damage and those lengths requiring repair are moved to a separate area. Another contractor is called in to repair the pipe with defects based on Trans Mountain’s specifications and reports the results back to Trans Mountain. This contractor is only repairing the storage pipe and is not involved elsewhere on the Project. The pipe is then inspected again. Information on the pipe that has passed inspection is obtained from the stamp on the outside of the pipe and the stamp on the inside of the pipe, in addition to the barcode (four copies of the barcode on each pipe length). This information is checked against the master list that TMX has received from the supplier to ensure the pipe meets specifications. This information is also linked to pipe Material Testing Reports (MTRs), which are electronically available. If the information matches, the ownership is transferred from the supplier to Trans Mountain.When the pipeline lengths leave the yard, the bar code is scanned. The information of one repaired pipe length was noted. TMEP provided the records demonstrating the traceability of the coating repair for this pipe length.
Observation 5 - Leak Detection System – KP 48.600
Date & time of visit: 2020-01-21 09:00
CER inspectors observed the HDPE dual conduit that will be used for the fiber optic leak detection system at a bell hole located at KP48.600. Clamps to install the conduit had been glued to the pipe with liquid epoxy coating. TMEP explained that the fiber optic will be passed in the conduit at a later time. TMEP also explained that the stainless steel conduits observed in the yard the previous day will be used at crossings for redundancy as HDPE conduit may not survive the pull force. After the inspection, TMEP explained that bare stainless steel tubes have been used at three crossings to date on the project and that wires will be installed on these tubes such that continuity tests can be conducted to monitor for metal to metal contact between the pipeline and stainless steel tubes over the life of the pipeline. Although the probabilities are very low, if there is any continuity established, additional cathodic protection will be added to mitigate potential corrosion. TMEP also explained that going forward, continuity testing will be conducted on all stainless steel tubing used. TMEP is pursuing the option of using HDPE coated stainless steel tubes to reduce the potential for metal to metal contact, however this will depend on the market availability of such a product.
Observation 6 - Coating Repairs and Weld Traceability Records – KP 45.900
Date & time of visit: 2020-01-21 09:45
Coating repairs were happening at KP 45.900. The contractor and TMEP coating inspectors were on site. The TMEP coating inspector explained his role and confirmed that although he does not conduct the coating tests (X-cut, salt, profiles, etc.) himself, he witnesses the tests conducted by the contractor coating inspector. The TMEP coating inspector also confirmed that he witnessed the coating applicator qualification tests. The coating repairs observed had been completed by a coating applicator that was on the list of qualified applicators. TMEP provided the following records to demonstrate the traceability of materials for weld TMEP-1-MG-0063, which was inspected to the Annex K criteria:
CER inspectors request the Trans Mountain provide the following records related to weld TMEP-1-MG-0063:
Due date: 2020-05-15
Date closed: 2020-05-20 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.
Observation 7 - Pipe Bending – KP 19.000
Date & time of visit: 2020-01-21 11:00
CER inspectors verified the cold pipe bending occurring at KP 19.000. TMEP had a pipe bending inspector on site and he explained how he ensured that the pipe is bent according to procedures and how he inspected the pipe after the bending. CER inspectors observed a pipe that had been bent. The longitudinal seam weld was located in the neutral axis of the bend and there was no circumferential weld in the bent section. No apparent damage to the pipe or coating was observed. The bending inspector indicated that the bend deflections are not to exceed 1.25 degrees by length of outside diameter and that out-of-roundness is not to exceed 5% of the specified outside diameter, which satisfies the CSA Z662-19 criteria. The bending inspector indicated that the minimum bending temperature was -30 degrees Celsius, which is consistent with the information previously provided by TMEP representatives.
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
