Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: NOVA Gas Transmission Ltd.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
INSPECTION: Construction inspection for the Tower Lake Section (32 km of NPS 30 pipe); multi-discipline inspection with Safety and Integrity to verify compliance (CSA Z662, OPR, and CLC) with respect to the following activities: bending, welding, coating, the HDD of the Kiskatinaw River, the HDD of un-named creek, and the setup of watercourse & road crossings including stockpile site.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Safety Observations
Date & time of visit: 2017-08-08 14:00
Discipline: Safety Management
Categories:
Facility:
Observations:
The Tower Lake Section consists of 32 km of NPS 30” pipe as well as meter stations Tower Lake Receipt Meter station and Dawson Creek North Receipt meter station and Dawson Creek North No. 2 Receipt meter station. Nova Gas transmission Ltd. (NGTL) has contracted Banister Pipeline Corporation (Banister) as the prime contractor for the 32 km pipeline install and AECOM as the prime contractor for the meter stations.The inspection did not include inspection of the meter stations as there was minimal work being conducted at these sites at the time of the inspection. Piles had been driven awaiting the install of the buildings. However, it was noted that the AECOM Site Specific Safety Plans (SSSP) was available on site for reference.National Energy Board (NEB) staff received a comprehensive 2.5 hour on site Banister orientation the include expectations of both Banister and NGTL to meet the commitments that were made in the submission to the NEB. NEB powers, responsibilities and forms of enforcement as well discussion about the Canada Labour Code and other responsible regulatory agencies. General Observations.All crews had a current Emergency Response Plan (ERP) available on the various sites, a automated external defibrillator, first aid kits and sufficient cold water. Medical aid on site consosited of 2 British Columbia Primary Care Paramedics, 4 Occupational First Aiders, ( 4 on days and 2 on nights) with 6 Medical Treatment Vehicles. A daily Tailgate/Field Level Hazard Assessment (FLHA) was presented to NEB staff at each site by the foremen for review of the hazards and was noted to be complete in identifying hazards and controls. Pilons are used to ensure 360 degree walkarounds on vehicles as required in the SSSP. Pipe yard (-120.62338296, 55.9898355648).The daily equipment check had been satisfactorily completed on the excavator equipped with a deck hand to minimize human handling of the pipe and thereby reducing the risk of pinch points and eliminating the need for tag lines for pipe handling. Environmental clearance sticker was on the equipment as well as sticker warning for requirement for three point contact for equipment mounting and dismounting as per the message given at the Orientation.Loader on the site had an environmental (cleanliness) sticker that was present alongside a sticker that showed how to properly mount and dismount the equipment (three point contact). Loader had a daily equipment check available, but it was not sufficiently or correctly completed as some items had not been identified as needing mechanical attention. One light lens was broken, windshield was cracked (See Corrected Non-Compliance 1).Safe work was observed, washrooms were available for crew as site was remote. Secondary containment and drip tray were available for refueling, sufficient water available (as hot outside) and site was clean and appropriately sized and gravel based. Signage was appropriate. Pipe was chalked and direct contact between pipes was eliminated by rope banding separators.Kick-Off (-120.66193036, 55.99935201) Tower Lake Receipt Meter Station.Ditch was appropriately signed as OPEN DITCH and fenced. Although no one was working in the ditch, egress ladders were appropriately spaced (mentioned in orientation) and extended above the ditch top. Traffic signage was satisfactory for road entry as well as on the main road prior to chest of equipment crossing and signage for flag person should equipment be traversing the main road. Piles were in place for the Tower Lake Receipt Meter station. Buses were used for transporting the crew and shelter from the hot sun (25 degrees C) and sufficient water was available as well as washrooms on site. Excavator had environmental check and sticker completed. Fire extinguisher on the crew bus was not current with the monthly check and last check was July 2017 (See Corrected Non-Compliance 1).Poor Boy Welding and Grinding 30+800.Guards were on grinders, double eye protection was being utilized. Equipment checks had been completed, however, back-up alarm on side boom only sounded once and had been checked off as functioning on the equipment check list (See Corrected Non-Compliance 1). Washrooms were available and water for crew was on crew bus.Coating Crew 30+500.Induction coil was being used during the coating operations and safe work procedures were observed. MSDS sheets were available and appropriate PPE to match MSDS was being worn by crew.Kiskatinaw River HDD Drill 26+200Direct Horizontal Drilling rig 13 sub-prime to Banister was conducting an intersect (drill from entry and exit) for the Kiskatinaw river.All safety equipment was in place, environmental checks had been done on the equipment and spill kits and MSDS sheets were available.Environmental inspection and sign-off of rig equipment had been conducted.Housekeeping on the rig was very good, rig was clean and appropriate signage was in place. Mechanized Welding 28+700Seven booms were employed for the mechanized welding.Double eye protection was observed, Guards were on grinders. Space was tight on the ROW but proper safe work procedures were observed.Crew bus was following the booms and water and resting area was available for crew.Jeeping of coating on the welds 29+900Safe work was observed.Horizontal Directional Drilling at Unnamed Creek 29+900Direct Horizontal Drilling Rig 19 was in the process of reaming through. Environmental inspection and sign-off of rig equipment had been conducted.Lock Out Tag Out Board was present and organized.Field bending 21+500A daily Tailgate/Field Level Hazard Assessment (FLHA) was presented to NEB staff for review of the hazards and was noted to be deficient in identifying hazards and controls. Hazards and controls did not match up. A hazard such as Trips and Falls had a control listed as drink more water. Not all hazards were identified and form was generally viewed to be incomplete and improperly completed (See Corrected Non-Compliance 2)Medical Treatment Vehicle and First Aid Responder at Braden Side Road and Sho-fly 1First aid responder was an Occupational First Aider (OFA). Medical treatment Vehicle was fully equipped. OFA understood the triage procedures, had good communications, and a copy of the emergency Response Plan that was current. After discussion with OFA it was determined that the Journey Management (JM) for the medical personnel had been changed. Medic does a hand off, but upon the return home, JM was no longer in place. (See Corrected Non-Compliance 3).Coating 55.96808114 -120.65964402Access road had been water as road was dry and dusty. This was actually an extra work space for the unnamed creek pull. at Shu-fly #2. FLHA was a good quality and was adequately filled in. Crew was wearing recommended PPE as required on the MSDS sheets for the product.(SP-2888 coating). "North" repirators were being used with OV/P100 vapour filters. Double gloves were also being worn by the crew as well as Tyvek suits.Sand Blasting Area of grit ( green diamond 20-50 grit size) blasting was sufficiently isolated from the other operations on the line. Blaster was wearing a hooded suit with filtered air supply.
Compliance tool used: No compliance tool used
Observation 2 - CNC Equipment checks not being done properly
Date & time of visit: 2017-08-09 14:00
At Pipe Yard Loader had a daily equipment check available, but it was not sufficiently or correctly completed as some items had not been identified as needing mechanical attention. One light lens was broken, windshield was cracked.Fire extinguisher on the bus was not current with the monthly check and last check was July 2017.At Kick-offFire extinguisher on the crew bus was not current with the monthly check and last check was July 2017. Needed to be checked by end off August, but this was 2nd week of August. Poor Boy Welding and Grinding 30+800.Equipment checks had been completed, however, back-up alarm on side boom only sounded once and had been checked off as functioning on the equipment check list.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Items were corrected while staff was present, however, company shall discuss with management at the Environmmental Management Safety (EHS) Meeting the items that were identified and a list of senior staff present at the meeting as well as a poster on how to properly inspect and frequency of inspections. NEB inspector was satisfied with the response.
Due date: 2017-08-09
Date closed: 2017-08-09 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 - CNC Tailgate/FLHA (Field Level Hazard Assessments) not being done properly
Date & time of visit: 2017-08-10 12:00
A daily Tailgate/Field Level Hazard Assessment (FLHA) was presented to NEB staff for review of the hazards and was noted to be deficient in identifying hazards and controls. Hazards and controls did not match up. A hazard such as Trips and Falls had a control listed as drink more water. Not all hazards were identified and form was generally viewed to be incomplete and improperly completed
Company shall discuss with management at the Environmmental Management Safety (EHS) Meeting the items that were identified and a list of senior staff present at the meeting. Crew should all participate in FLHA, add new hazards as conditions change and review with changes to crew or additional personnell entering the site that the FLHA encompasses. NEB staff requested that a new FLHA be completed and that a follow-up on several different days be conducted.
Due date: 2017-08-10
Date closed: 2017-08-10 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 - CNC Journey Management not being done properly
After discussion with Occupational First Aider (OFA) it was determined that the Journey Management (JM) for the medical personnel had been changed. Medic does a hand off, but upon the return home. Although medic was of the opinion JM consisted of communication to a dispatcher on site, that this procedure had been stopped and JM for returning to residence at end of the shift was no longer in place.
Reinstate the JM for the medics returning from the field to their residence.
Observation 5 - Pipe stockpile yard
Date & time of visit: 2017-08-09 12:00
Discipline: Integrity Management
The pipe stockpile yard including the pipe spools and fittings was inspected. The pipe coating condition was verified, as well as the proper markings (e.g.. size, WT, OD, grade, heat number, specification, date of manufacture and coating (i.e... April 2017)). Pipe spools were properly supported. The pipe handling was performed with proper hand hooks with points of contact padded with neoprene rubber. The pipe information (i.e.. size, grade, WT, coating) was consistent with the NEB approved materials for the project. The applicable mill test reports (MTRs) for fittings C#53 and C#59, and the pressure testing results for fitting C#153 were requested for review. The information were provided later at the field office. Some pipe spools were observed having missing end caps. Company representatives confirmed that some loose end caps were removed from the pipes. The inside condition of the pipes was verified and determined as being acceptable with no signs of internal corrosion. The pipe stockpile was moved to the ROW during the inspection. One pipe was put aside in the yard for coating repair as this was damaged.
Observation 6 - Pipeline welding
Date & time of visit: 2017-08-09 13:00
The NEB inspectors verified the pipeline welding activity at KP32+200. Banister's personnel were conducting the shielded metal arc welding (SMAW) activity. TCPL welding inspector was on-site monitoring the activities and taking welding parameters. The welding inspector and the welders have a copy of the Welding Procedure Specifications (WPS). The WPS including the welding process, the joint geometry, the base material specifications, filler, welding position, temperature, and travel speed, were verified by the NEB inspectors. It was confirmed that the Procedure Qualification Records (PQR) is available at the field office. This was later reviewed by the NEB inspectors. Welding inspector's binder on-site including the welder's qualifications, refers to the PQR. NEB inspectors verified the welding parameters taken for the day of inspection. It was confirmed that the parameters are taken once a day for each welder. No repair welds were done at the site to date. The welding inspector confirmed that all welders were qualified for the WPS and the repair procedures they were using. NEB inspectors verified welding qualification records (log) on-site, specifically the WPS and the repair procedures that the welders were qualified for (i.e.. welders #7 and #19). The external clamps were properly used and not released until at least 50% of the root bead was complete. The pipe coating was protected from weld spatter during the welding. The welding inspector confirmed that the pipe alignment is checked for each weld and it is minimal (<1.6 mm) and the time delay for the NDE of the girth welds welding is 24 hrs. The welding consumables and their storage were in accordance with the WPS.The NEB inspectors also observed the nearby launcher site (kick off site) and the downstream crossing of road #1 as prepared for hydrostatic testing (to be conducted by the end of the month). The depth of cover at the crossing was appropriate. The results of the abrasive coating inspection after the bore activity were requested for review.
Observation 7 - Pipeline field applied coating inspection
The pipeline field coating inspection process at KP30+700 was verified. The SPC2888 liquid epoxy was applied on the girth welds. The TCPL coating inspector was on-site and verified the coating thickness and adhesion. Measurements were taken on five points around the circumference. It was noted that a girth weld was rejected by the automatic ultrasound testing (AUT) inspection due to a lack of cross penetration (LCP). The coating repair log which included the visual inspection, measurements taken, and holidays information results was verified. The coating application quality control form that the TCPL inspector uses on-site, the production quality control plan, and TCPL's procedure TES-COAT-EPU were also verified.
Observation 8 - Horizontal Directional Drilling (HDD) at the Kiskatinaw river crossing
Date & time of visit: 2017-08-09 15:00
Direct Horizontal Drilling was performing the HDD activity at the exit point of Kiskatinaw river crossing at KP26+200. The on-going process at the time of inspection was the reaming of the 30 inch bore. The drilling execution plan and the procedure could not be provided for review as they were located at the entry drilling point site. The 18.8 mm WT pipe used for the HDD was coated with abrasive coating and jeeped prior to installation. It was confirmed that the direction and the angle of the bore were not deviated from the limits of the borehole.
Observation 9 - Non-destructive Examination (NDE)
Date & time of visit: 2017-08-09 15:30
The NEB inspectors verified the NDE activities on the 18.8 mm WT welded pipe segments used at the Unnamed creek crossing. Stanley Inspection - third party contractor for TCPL was performing the AUT inspection of the girth welds. The inspection of girth weld ML-086 was witnessed. The AUT machine was calibrated prior the girth weld inspection. It was confirmed that the calibration process is performed prior to each girth weld inspection. The NDE technician was CGSB Level II certified. The joint was properly cleaned and cooled down prior the AUT inspection. The inspection was performed on the entire circumference of the joint. The ML-049 joint inspection report which included the lack of cross penetration (LCP) was reviewed. This weld was rejected and subsequently repaired. The following documentation were verified on-site: the Engineering Critical Assessment including the acceptability criteria, the standard in place being used for the NDE activities (i.e.. CSA Z662-15), and Stanley Inspection's procedure approved by TCPL.
Observation 10 - Field applied coating jeeping
Date & time of visit: 2017-08-10 09:30
The NEB inspectors verified the process of jeeping the field applied coating on a girth weld at KP29+900. The jeeping equipment was calibrated. The TCPL inspector was on-site. The coating density measurements were taken and marked on the joint.
Observation 11 - HDD at the Unnamed creek crossing
Date & time of visit: 2017-08-10 11:00
Direct Horizontal Drilling was reaming the 30 inch bore at the entry point of the Unnamed creek crossing (SE-36-80-18W6). The final bore will be 42 inch. The HDD execution plan including the procedure and drawings were reviewed (TES-PROJ-HDD). The frac-out emergency response plan was in place. The proper pipe of the correct WT and abrasive coating was used for drilling. It was confirmed that pipe jeeping is performed prior to pulling through. It was noted that the exit angle was modified from 12 deg to 13.8 deg. The 14 inch drill bit initially used as per drilling execution plan was replaced with a 12.25 ich drill bit due to operation challenges. TCPL on-site inspector confirmed the execution plan was modified accordingly, but a copy was not available on-site at the time of inspection. The drilling parameters were continuously monitored and recorded. There were no pulling through activities at the time of inspection, however recorded parameters from previous days were shown to the NEB inspectors.
Observation 12 - Pipe bending
Date & time of visit: 2017-08-10 13:00
The pipe bending inspection was conducted at KP21+500. The activity included the bending of NPS30 10mm WT spiral weld pipe. Banister was performing the bending. TCPL's bending inspector on-site conducted visual inspection on the pipe coating, the inspection for ovalities, wrinkles and ripples. The bending procedure was reviewed. The pipe spools were properly handled using points of contact padded with neoprene rubber. The NEB inspectors noted a heavy wall pipe spool coated with System 2B fusion bond epoxy (FBE) coating on-site. The bending inspector confirmed that such pipe spools are only used for the road crossings and are not subject to bending (also confirmed by the bending procedure). A bending inspection report was reviewed on-site including requirements for the bending distance from the end of the joint or from the girth weld, pipe bending deflection, and ripples and ovalities size.
Observation 13 - Field office
Date & time of visit: 2017-08-10 16:00
The NEB inspectors followed-up on field activity inspections by verifying few procedures and other documentation. While reviewing the drawings related to fittings C#53 and C#59, NEB inspectors noted that the project name was inaccurate marked on the drawings, however the drawing numbers were correct. TCPL staff confirmed that the fabrication company responsible for this documentation was already notified (a 6 July 2017 email notification was presented to the NEB inspectors). The appropriate change to the drawings will be made on the turn over package to TCPL. This non-compliance has been corrected. The documentation also confirmed that the fittings were manufactured by Canadoil Forge Ltd., in Quebec.The NDE procedure for AUT was reviewed and explained by TCPL staff, including the imperfection acceptance criteria. TCPL staff also confirmed that all AUT inspection reports are verified daily by Stanley senior technician followed by the TCPL auditor, at the field office.The frequency of welding parameter readings was clarified. TCPL staff presented documentation showing that the parameters are taken more often than the specification requirements.The NEB inspectors also verified the spool receiving damage report (TEF-INSP-WELD-SPDMG) for spool C#153, the PQR including welders' #7, and #19 qualifications, the hydrostatic test results for fittings C#53 and C#59, and the pipeline construction specification (TES-PROJ-PCS) for end caps requirements.
TCPL has to modify the fitting drawings to include the appropriate project name and pipe size for the Tower Lake section of the project.
Observation 14 - Field coating application
Date & time of visit: 2017-08-11 08:30
A fully automated spray technology was used for the field coating application on the girth welds at the Unnamed river crossing section. The pipe was initially preheated using the liquid propane torch to remove the moisture, then sandblasted, preheated again prior to coating application using the induction coil heat, followed by temperature verification, and then coated. TCPL procedure requires a coating application of 40-70 mls, and the target application was 50-60 mls. Manual quality control touch-up repairs were made on the coating following the visual inspection as required. The TCPL coating inspector was on-site. The inspection and test plan, the testing equipment calibration, and the shop and field testing procedures were presented to the NEB inspectors. The applicators' qualifications performing the coating were verified against the product used (i.e. specialty polymer coating SPC 2888). The coating inspection included visual inspection, thickness, cure testing, and jeeping. All inspection results were logged. An abrasive coating inspection report after a bore crossing was presented to the NEB inspectors as previously requested.
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