Compliance Verification Activity Report: CV2122-090 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2391
• Inspector In Training 2881T

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Canada Inc.

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Damage Prevention

Related events:

• DPR2021-039
• DPR2021-071
• DPR2022-050
• DPR2022-049

Rationale and scope:

Verify compliance to the requirements contained within the Onshore Pipeline Regulations (OPR) and the CER Damage Prevention Regulations - Obligations of Pipeline Companies (DPR-Obligations) with a focus on third party oversight procedures. Field inspection included document review and site inspection of active third party crossing activity.

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• Mainline

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Damage Prevention Program Pre-Inspection IR

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Manage and Mitigate

Facility:

• Mainline (Pipeline)

Observations:

As part of the scope of this field inspection which includes document review, the CER IOs require information pertaining to the TQM Damage Prevention Program as required pursuant to section 47.2 of the OPR. 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 47.2 A company shall develop, implement and maintain a damage prevention program that anticipates, prevents, manages and mitigates damage to its pipeline and meets the requirements set out in section 16 of the National Energy Board Pipeline Damage Prevention Regulations — Obligations of Pipeline Companies.

Company action required:

IR#1 - Sent 20 Oct 2021

• Refer to the Documents Section in the link provided for the full text of this Pre-Inspection Information Request.
• Indicate which documents within your company’s Damage Prevention Program or related program address the applicable regulatory requirements.
  • Include details such as document name and applicable sections and/or page numbers.
  • Please do not attach documents at this time. All responses must be entered into the template provided. 
• Follow the instructions provided in the Documents Section to upload and submit your company response by the specified due date.

Due date: 2021-10-29

Date closed: 2022-05-05
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 2 - Oversight of 3rd Party Excavation for Watermain Installation

Date & time of visit: 2022-05-02 07:30

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Locate Markings
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Damage Prevention Program
• Manage and Mitigate
• Locates and Information
• Locate Requests
• One-call Centre
• Ground Disturbance
• Authorization and Consent
• Facility
• Authorization and Consent

Facility:

• Mainline (Pipeline)

Observations:

CER IO arrived at site at 7:30am (Pacific Time) and attended the safety meeting led by the Trans Mountain (TM) Pipeline Inspector who went through the Safety Meeting for Ground Disturbance/Proximity Installation and Pipeline Protection Inspection Security Checklist and had everyone present sign the document (i.e., prime contractor, hydrovac personnel and CER):

• The safety meeting discussion included information about the presence of test taps in the area, the product in the pipeline and its casing, as well as instructions to be followed during hydrovacing such as using a plastic tip on the end of the suction hose and reducing the water pressure upon reaching the depth as marked on the suction hose (with black tape). The backfill materials (washed/clean sand) and clearance requirements (minimum 30cm) were also discussed. 
• The Proximity Installation Permit number was referenced on the document.
• CER IO noted that the potential hazard of rocks falling onto the pipe was not mentioned during the safety meeting, but watching for this type of hazard was specifically addressed while the TM Pipeline Inspector witnessed the hydrovacing and ensured that loose rocks that had the potential to fall onto the pipeline were dealt with accordingly.

• Pipeline was located and marked prior, with Pipeline 7.5m zone marked with pink paint.
• CER IO observed TM representative instruct the hydrovac personnel to vacuum to a depth of 1.9 m at which point the water pressure was to be reduced to prevent damage to the pipe. The hydrovac suction hose was taped at 1.95m as a visual indicator for reducing the water pressure of the water wand.
• CER IO observed pipe being exposed safely with hydrovac under TM Pipeline Inspector supervision, followed by backfilling with 1m of cover with fine, clean sand. The backfill material for the waterline was road haul mulch and the clearance between the Trans Mountain pipeline and the waterline was 1m. The TM Pipeline Inspector took measurements throughout the hydrovacing and backfilling process.
• TM representative described that there was a distance of 13.2m on the south side and a 7.82m from the north side between the two Isolation valves on the waterline above the Trans Mountain pipeline. 
• Following backfilling over the pipeline and watermain, CER IO observed the packer and roller equipment being deployed to compact the road base, followed by laying of asphalt and rolling for a flat road surface.  
• CER IOs observed the Trans Mountain Inspector refresh markings with yellow paint over the pipeline and pink marking at 7.5m after completion of the work, as another underground line will be placed in the future outside the Trans Mountain right-of-way.

• Proximity installation permit (fully executed crossing agreement). Trans Mountain confirmed that this permit included the watermain installation as well as services connections (which work is to be completed at a later time but within the 2-year validity period of the permit).
• 30m (100 ft) Ground Disturbance Prescribed Area Permit. 
• Trans Mountain Proximity Installation Field Report - this document allowed the Trans Mountain Pipeline Inspector to record field observations such as the clearance between the foreign facility and the pipe, the condition of the pipe at the time of backfilling as well as the method of ground disturbance (e.g., hydrovac). It also captured the third party's compliance with the measures set out in the CER Damage Prevention Regulations - Authorizations. 
• Coating Evaluation and Backfill Report.
• Safety Meeting for Ground Disturbance/Proximity Installation and Pipeline Protection Inspector Security Checklist.

Compliance tool used: No compliance tool used

Observation 3 - Sites of Previous DPR Contraventions and Active Developments

Date & time of visit: 2022-05-03 09:30

Discipline: Damage Prevention

Categories:

• Damage Prevention Program
• Monitoring
• Processes and Standards
• Pipeline Identification
• Signs
• Locate Markings
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Reporting

Facility:

• Mainline (Pipeline)

Observations:

Site visit of location of recent DPR contravention in Abbotsford, BC:

IOs accompanied Trans Mountain representatives to the site of a recent damage to pipe which was discovered by the pipeline company in April 2022 in Abbotsford. Upon arrival at the site, CER IOs observed the following:

• Pipeline was marked with yellow pin flags throughout the land, going on an approximately 45-degree angle, towards the northeast;
• The right-of-way (RoW) was marked with either pink pin flags or barricaded by an orange snow fence to restrict access;
• Pipeline company signage was present at the roadway crossing; and
• A number of holes caused by the installation of round wooden posts (wheel chocks) along the middle of the land in an East-West direction were observed. All wooden posts had been removed and the location where the pipeline was damaged had already been backfilled.

• The pipeline which runs under the roadway was marked with yellow paint along Cottonwood Avenue, where a few warning “pucks” were placed on the asphalt. 
• Pink paint, pin flags and ribbons were observed as marking the RoW closer to the new housing development at the corner of Cottonwood Avenue and Fairview Street.
• 3 other apartments building were being constructed, at different stages of construction.

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: