Compliance Verification Activity Report: CV1819-447 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector In Training 2062T
• Inspector 2696

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• Alberta
• British Columbia

Discipline(s):

• Integrity Management

Related events:

• CV1920-181

Rationale and scope:

Inspection of one-two of four stockpile locations between Edmonton to Burnaby. Follow-up to Condition 105, which addresses non-conformances (NC) with design, materials and construction. Examine documentation for NCs identified and extent of NCs during transportation, handling, or stockpiling in comparison to quantities received. Inspect measures taken to prevent future NCs. Review of coating repair procedure prior to inspection (to determine compliance with CSA Z245.30 Field-applied external coatings for steel pipeline systems). Verification that repairs are completed according to the procedure, by qualified applicators.

Compliance tool(s) used:

• Information Request (IR) (4)
• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Plans And Procedures
• Project-specific plan or procedure
• TMEP FBE Plant Applied Coating Specification (TMEP-GC3105, Revision 7)
• Project-specific plan or procedure
• Coatings Contractor - Procedure for Repair of External Fusion Bond Epoxy Coating with Two-Part Liquid Epoxy
• Project-specific plan or procedure
• Inspection and Testing Plan - Installation Contractor - 36" Pipe - Repair of External Fusion Bond Epoxy Coating with Two-Part Liquid Epoxy
• Manufacturer’s manual
• Specialty Polymer Coatings, Inc. Manufacturer’s Qualified Application Procedure for SPC SP2888R.G. MQAP Rev 1.1
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• OC-064

Observations (no outstanding follow-up required)

Observation 1 - Day 1 - Kamloops Stockpile Site

Date & time of visit: 2018-05-30 10:00

Discipline: Integrity Management

Categories:

• Pipeline
• Pipe Condition
• Pipe Storage and Handling
• Inspections
• Repairs
• Materials
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

The following procedures were provided prior to the inspection:

- Coating's Contractor - Procedure for Repair of External Fusion Bond Epoxy Coating with Two-Part Liquid Epoxy
- Inspection and Testing Plan (ITP) – Pipe Supplier - 36" Pipe - Repair of External Fusion Bond Epoxy Coating with Two-Part Liquid Epoxy
- Specialty Polymer Coatings, INC. (SPC) - SP-2888® R.G. Brush Grade Application Specification / Steel Substrate
- Hauling Contractor’s Project Specific Safety Plan

 

• NEB Inspectors attended the site specific safety training.
   
• Trans Mountain Pipeline ULC (TM) reported a 58.7% rejection rate for the Fusion Bonded Epoxy (FBE) coated pipe joints inspected at this site.  The non-conformances were reported in the Condition 105 filings as handling damage on pipe coating.  All the reported non-conformances at this site were on the pipe joints from one manufacturer.
   
• TM stated that the Transfer Care Custody and Control (TCCC) had not taken place at this location yet.  TM stated that TCCC would be complete only after the pipe joints were fully repaired in accordance with approved procedures, and inspected to comply with specified quality control criteria, and to have subsequently have no coating holidays.
   
• TM personnel provided NEB Inspectors an overview of the TCCC process (including supply chain), and provided information on the TM and contractor oversight through each phase of the process.
   
• The nominal pipe size 914 mm (NPS 36), double-jointed pipes were shipped pre-coated from the pipe manufacturer’s site to the Fraser Surrey Docks (FSD).  The pipe joints were then loaded onto rail cars, and shipped to the Kamloops stockpile site.  The site has direct access to the rail line.  The hauling company, contracted by the pipe supplier, stockpiled the pipe joints at the site.
   
• TM stated that it independently contracted a third party inspection company to maintain quality assurance and quality control oversight through all stages of the TCCC.
   
• TM stated that three out of four vessel shipments from this manufacturer were received.  (See Information Request # 1).
   
• TM stated that the damage to the pipe joints were a result of handling at the FSD.  (See Information Request # 2).
   
• TM stated that the pipe supplier conducted an investigation to determine the root cause of the reported handling damages.  TM committed to providing the report to the NEB upon receipt and TM review.  (See Information Request #3).  TM stated that the root cause was expected to be the result of a number of contributing factors, including the use of improper equipment to handle pipe joints at the FSD, and lack of training or experience of the workers at the FSD.
   
• NEB inspectors observed the pipe handling, and inspection process at this site:
   
  • The damage to the coating appeared to be superficial and as a result of poor handling.
     
  • Both single layer (system 1A) and dual layer (system 2B) fusion bond epoxy coated pipe joints were stockpiled.
     
  • The joints were observed to be handled using padded mechanical forks at the center, in accordance to the hauling contractor’s procedures.
     
• As part of receiving inspection, visual inspection was conducted on each pipe joint by two inspectors at the three o’clock and the nine o’clock positions.  The inspectors were marking the identified FBE coating damages for repair directly on the pipe.  The joints were then turned twice, a quarter turn each time and inspected, to ensure inspection of the entire circumference of the joints.
   
• NEB inspectors observed stages of the repair process at this site:
   
  • The coatings contractor stated that the repairs were performed to the TM specification FBE Plant Applied Coating Specification (TMEP-GC3105, Rev. 7), which complies with the requirements of CSA Z245.20 (Plant-applied external fusion bond epoxy coating for steel pipe) standard.
     
  • The coating contractor stated that although they were qualified to both CSA Z245.20 and CSA Z245.30 (Field-applied external coatings for steel pipeline systems) standards, the CSA Z245.20 standard was being utilized for the repair, as required by TM specifications.
     
• The SP-2888 R.G. system of coating was utilized for repair.  (See Information Request #4).
   
• NEB inspectors observed the coating contractors conducting surface preparation using sandpaper.  Surface preparation was conducted to accommodate for 25 mm overlap from any edge of the holiday, in accordance to the Inspection and Test Plan (ITP).
   
• The completed coating repairs were tested for dry film thickness, hardness (Shore D) and holiday tested with wand.
   
• NEB inspectors requested further details on the applicability of the CSA Z245.20 standard at the stockpile location.  TM personnel referred the technical questions related to coatings and repairs to the TM subject matter expert (SME).  The SME was not available on site during the NEB inspection.  TM offered to arrange a meeting with the SME subsequent to the inspection.
   
• The pipe supplier stated that since the damage to pipe was small in nature, the CSA Z245.20 standard was more appropriate.  The pipe supplier stated that there was no limit to the number of repairs that was allowed at the site.
   
• NEB inspectors noted that CSA Z245.20-14 Table 9 limits the holiday repair of 914 mm (NPS 36) pipe to a frequency of less than or equal to 0.7/m2, and maximum area of less than 250 cm2.  If either of the limits (frequency or maximum area) are exceeded, the Standard requires that the coating be stripped and recoated in accordance to Clause 8.3 of CSA Z245.20-14.
   
• TM stated that the limits specified in CSA Z24.20-14 Table 9 are only applicable for pipe in the coating application plant during the final visual inspection, dry film thickness measurement and holiday testing.  TM stated that there is no defined limit once the pipe leaves the coating plant, into their own yard or is moved to a stockpile yard. (See Information Request # 1 within the ‘Teleconference with Trans Mountain and NEB’ Observation).
   
• NEB inspectors requested the TM specification for coating repairs, and requested that a teleconference be set up with TM Coating’s SME.

• General observations:
   
  • NEB inspectors noted that the stencil on the pipe joints did not contain all the required markings as per CSA Z245.20-14 Clause 9.2.1.  TM committed to determine and implement the corrective actions needed for all the non-compliant pipe in the various stockpile sites, and the pipe contained in vessel #4.  (See Notice of Non-Compliance #1)
     
  • The pipe joints were roped, properly stored with end caps, and well supported.
     
  • The following Non-Conformance Report (NCR) was reviewed: 01-13283-SG-M000-QA-NCR-1100 R0.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.2 Selection of external protective coatings for buried or submerged piping
      • 9.2.1 The company or operating company, whichever is applicable, shall be responsible for performing and documenting coating system evaluations and selections. Only those competent in the application of corrosion control through coatings and cathodic protection shall perform such evaluations and selections.
      • 9.2.2 For the coating system being considered, the factors given in Column 1 of Table 9.1 shall be evaluated as applicable to identify the coating properties and characteristics necessary for satisfactory coating performance and to identify situations along the pipeline where coating performance problems are likely to occur. Particular attention shall be given to situations such as
        a) installations involving bored crossings, horizontal directional drills, padding, backfilling, or bending;
        b) soil-induced stresses (e.g., axial, transverse, and shear) imposed on the coating system;
        c) exposure to high and variable operating temperatures; and
        d) the possibility of changes to service conditions.
        For bends, the combination of bending temperature, coating thickness, coating composition and degree of bend shall be considered and demonstrated to be suitable in preventing damage to the coating during the bending process.
      • 9.2.3 Attention shall be given to the selection of coating systems and application methods to be used in situations where the presence of piping surface contour changes creates a potential for gaps or poor adhesion between the coating and the piping. Such situations include, but are not limited to the presence of
        a) submerged-arc seam welds;
        b) circumferential pipe-to-pipe and pipe-to-component welds; and
        c) reinforcement and pressure-containment repair sleeves.
        Note: Coatings that do not remain bonded to the piping can cause electrical shielding that jeopardizes the effectiveness of cathodic protection and creates conditions for metal loss and environmentally assisted cracking.
      • 9.2.4 Selected coating systems shall
        a) have properties and performance characteristics (see Table 9.1) that are required for satisfactory coating performance and that are resistant to the coating performance problems in the situations as specified in Clause 9.2.2;
        b) be repairable under field conditions;
        c) have been tested and evaluated as specified in Clauses 9.2.5 and 9.2.6; and
        d) except for newly developed coating systems used on an experimental basis, have a history of satisfactory performance in situations similar to those specified in Clauses 9.2.2 and 9.2.3.
      • 9.2.5 Except as allowed by Clause 9.2.7, selected coating systems shall have been tested for the properties and characteristics required for satisfactory performance [see Clause 9.2.4 a)], using the primary test methods given in Table 9.1, unless analysis demonstrates that alternative test methods are more appropriate. The coating test parameters shall meet the following requirements unless analysis demonstrates that alternative parameters are appropriate:
        a) Except for flexibility, all tests shall be conducted using the minimum or nominal coating thickness specified for the coating system.
        b) Testing for flexibility shall be conducted at, or below, the minimum pipe bending temperature, using the maximum coating thickness specified for the coating system.
        c) Testing for peel adhesion shall be conducted at, or below, the minimum installation temperature and at, or above, the maximum operating temperature.
        d) Testing for gouge resistance and for impact resistance shall be performed at, or below, the minimum installation temperature and at the maximum installation temperature.
        e) Testing for cathodic disbondment and for adhesion shall be performed at, or above, the maximum operating temperature.
        f) The immersion time for cathodic disbondment testing and adhesion testing shall be at least 28 days.
        Notes:
        1) When selecting maximum testing temperatures, consideration should be given to upset operating conditions and to solar heating of the coated pipe.
        2) Annex L provides information on test methods for the evaluation of coating properties and characteristics that may be considered as alternative or supplemental test methods to the primary test methods given in Table 9.1.
        3) Each company or operating company should review the applicator’s application procedure and consider the need for testing of the coating system applied by each applicator.
      • 9.2.6 Results of the testing specified in Clause 9.2.5 for the coating system being considered shall be evaluated on the basis of acceptance criteria established by the company or operating company, whichever is applicable. Consideration shall be given to the relationships between testing results, performance history, and service conditions for the coating systems being considered.
        Note: Where acceptance criteria are included in the referenced testing method (e.g., CSA Z245.20, CSA Z245.21, CSA Z245.22, or CSA Z245.30), the company should evaluate their suitability.
      • 9.2.7 For coating systems not addressed in Table 9.1, the required testing methods and evaluation of test results shall be determined by the company or operating company, whichever is applicable.
        Note: The test methods identified in Table 9.1 and Annex L should be considered for such coating systems.
      • 9.2.8 Where an abrasion or foam insulation coating is applied over an anti-corrosion coating, the anticorrosion coating shall be as specified in Clause 9.2. The company or operating company, whichever is applicable, shall specify
        a) the required gouge and impact resistance of the abrasion coating and the adhesion required between the abrasion coating and the anti-corrosion coating; or
        b) the axial shear strength required between the foam insulation and the anti-corrosion coating.
    • 9.3 Application and inspection of external protective coatings for buried or submerged piping
      • 9.3.2
        • 9.3.2.1 Plant applied protective coating of the external surface of pipe shall be as specified in CSA Z245.20, CSA Z245.21, or CSA Z245.22.
        • 9.3.2.2 Field applied protective coating of the external surface of piping shall be as specified in CSA Z245.30.

Company action required:

1. 1. Provide the quantity (number of joints and length) of double-jointed pipes:
   • a) Ordered from the manufacturer which experienced high rejection rates at stockpile sites as a result of coating contact damage;
   • b) Expected in the fourth shipment; and
   • c) Received to-date from this manufacturer at each stockpile site.
      
2. 2. Provide TM’s planned measures to avoid future pipe coating non-conformances due to handling damage; and provide information on the measures implemented to-date.
    
3. 3. Provide the completed report of the investigation conducted to determine the root cause of the reported handling damages.
    
4. 4. TM’s Plant Applied Spec., Section 8.0, specifies Specialty Polymer Coatings Inc. SP-2888 as an acceptable material for performing coating repairs.  Provide details on the analysis conducted, and documentation of the qualification testing performed to determine material acceptability for repairing FBE plant applied coating.

Due date: 2018-07-25

Date closed: 2019-01-30
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 - Day 2 - Canfor Stockpile Site

Date & time of visit: 2018-05-31 09:00

Discipline: Integrity Management

Categories:

• Pipeline
• Pipe Condition
• Pipe Storage and Handling
• Coating
• Procedures

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• NEB Inspectors attended the site specific safety training.
   
• Trans Mountain Pipeline ULC (TM) reported a 7.9% rejection rate for the pipe joints inspected at this site.  The non-conformances were reported as handling damage on pipe coating.  All the reported non-conformances at this site were on the pipe joints from one manufacturer.
   
• TM stated that the Transfer Care Custody and Control (TCCC) had taken place at this location and all the repairs were completed.  No stockpiling activities were taking place at this site during the time of the NEB inspection.
   
• TM personnel provided NEB Inspectors an overview of the TCCC process (including supply chain), and provided information on the TM and contractor oversight through each phase of the process.
   
• The nominal pipe size 914 mm (NPS 36), double-jointed pipes were shipped pre-coated from the pipe manufacturer’s site to the Fraser Surrey Docks (FSD).  The hauling company, contracted by the pipe supplier, hauled the joints and stockpiled it at the site.
   
• TM stated that it independently contracted a third party inspection company to maintain quality assurance and quality control oversight through all stages of the TCCC.
   
• General observations:
   
  • NEB inspectors noted that the stencil on the pipe joints did not contain all the required markings as per CSA Z245.20-14 Clause 9.2.1.  TM committed to determine and implement the corrective actions needed for all the non-compliant pipe in the various stockpile sites, and the pipe contained in vessel #4.  (See Notice of Non-Compliance #1).
     
  • NEB inspectors observed both single layer (system 1A) and dual layer (system 2B) fusion bond epoxy coated pipe joints were stockpiled.
     
  • The pipe joints were roped, properly stored with end caps, and well supported.
     
  • NEB inspectors observed two spiral welded pipe joints that had coating contact damage along the spiral welds.  TM stated that these joints were not accepted as part of the TCCC.  (See Information Request #1).
     
  • TM personnel referred the technical questions related to coatings and repairs to the TM subject matter expert (SME).  The SME was not available on site during the NEB inspection.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.3 Application and inspection of external protective coatings for buried or submerged piping
      • 9.3.2
        • 9.3.2.2 Field applied protective coating of the external surface of piping shall be as specified in CSA Z245.30.

Company action required:

1. 1. Provide the repair procedure to be followed, and the acceptance criteria for the joints that were observed to have coating contact damage along the spiral weld.

Due date: 2018-07-25

Date closed: 2019-01-30
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 - Teleconference with Trans Mountain and NEB

Date & time of visit: 2018-06-07 13:30

Discipline: Integrity Management

Categories:

• Pipeline
• Repairs
• Procedures

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• NEB inspectors and personnel from TM, including TM Coating’s SME, attended a teleconference at 1:30 P.M (MST) on 7 June 2018.  Prior to the call, NEB inspectors outlined the uncertainty on which standard was adhered to for conducting the repairs, and requested that TM provide all the documentation referenced in the Inspection and Testing Plan (ITP) – Pipe Supplier - 36" Pipe - Repair of External Fusion Bond Epoxy Coating with Two-Part Liquid Epoxy (ITP) document previously provided to the NEB by TM.  NEB inspectors also requested that TM provide TM’s Field Applied Coating Specification, if one existed.
   
• In response to NEB inspectors request, TM provided TM’s FBE Plant Applied Coating Specification - Revision 7 (TM’s Plant Applied Spec.), and the Manufacturer’s Qualified Application Procedure for SP-2888®R.G. Brush Grade, Spray Grade and Cartridges (MQAP Identifier – SP-2888 R.1.1) (MQAP).  TM stated that their Field Applied Coating Specification was still under development.
   
• During the call NEB inspectors outlined the concerns on which Standard was being adhered to for the repairs that were being conducted.  It appeared that the repair process followed by the coatings contractor was a blend of the requirements between the two standards (CSA Z245.20 and CSA Z245.30):
   
  • The ITP document referenced both TM’s Plant Applied Spec. and the MQAP.  TM’s Plant Applied Spec. was written in accordance to CSA Z245.20, while the MQAP was written in accordance to CSA Z245.30.
     
  • NEB inspectors noted that the requirements related to repairs are different depending on the standard being followed.  For instance, the repair overlap is a specific example where differences in requirements exist.  TM’s Plant Applied Spec states 25 mm of overlap, while the MQAP states 50 mm for holidays greater than 150 mm, and 25 mm for pinholes and holidays less than 150 mm.  The requirement in CSA Z245.30 is a minimum overlap of 50 mm.
     
  • NEB inspectors stated that the legal requirement for conducting repairs at the stockpile sites was CSA Z245.30.
     
• TM Coating’s SME stated that the repairs were being conducted in accordance to CSA Z245.20.  TM provided the following justification:
   
  • TM stated that the scope of CSA Z245.30 applied to uncoated steel pipe in a pipeline system site (i.e. right-of-way).
     
  • TM stated the testing requirements of CSA Z245.30 applied to larger areas of coating, such as field girth welds, and not the smaller sized coating defects that TM was seeing at the stockpile sites.
     
  • TM stated that CSA Z245.20 would be applicable if repairs to coating were being performed at the manufacturer’s yard.
     
  • TM stated that the MQAP is typically applicable to repair damaged FBE and liquid coatings for both CSA Z245.20 and CSA Z245.30 standards.
     
• NEB inspectors re-iterated that CSA Z245.30 defined ‘field applied coatings’ as ‘anti-corrosion coatings applied either at a pipeline system site or at another location not covered by the CSA Z245.20 Series’, and that this was the legal requirement at the stockpile site, in accordance to CSA Z662-15 Clause 9.3.2.2.
   
• NEB inspectors stated that according to the MQAP, the method of conducting surface preparation differed depending on whether the coating holidays were less than or greater than 150 mm (6”) in diameter.  For coating holidays greater than 150 mm (6”) in diameter, the MQAP requires that the surface be blast cleaned, and specifies a repair overlap of 50 mm (2”).  Although the MQAP was referenced in the ITP, this difference in process was not reflected in the tasks outlined in the ITP.  The ITP only required a repair overlap of 25 mm regardless of the size of coating defect.
   
  • NEB inspectors also noted that TM’s May 2018 filing updates of Condition 105 contained coating defects larger than 150 mm (6”) in diameter.  NEB inspectors stated that specific Non-Conformance Reports that reflect repairs performed on larger coating holidays (150 mm (6”)) will be requested. (See Information Request #1).
     
• NEB inspectors agreed to consult CSA regarding the applicability of CSA Z245.20 or CSA Z245.30 for the coating repairs performed on pre-coated pipe at stockpile sites, but acknowledged that the process may take months to carry out.  (See Information Request #2).  NEB inspectors informed TM that the intent of consulting CSA was to obtain an opinion.
   
• TM provided the following NCRs subsequent to this meeting: 01-13283-SG-M000-NCR-0445 R1; NCR # 01-13283-SG-M000-NCR-0445 R0.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.3 Application and inspection of external protective coatings for buried or submerged piping
      • 9.3.2
        • 9.3.2.1 Plant applied protective coating of the external surface of pipe shall be as specified in CSA Z245.20, CSA Z245.21, or CSA Z245.22.
        • 9.3.2.2 Field applied protective coating of the external surface of piping shall be as specified in CSA Z245.30.

Company action required:

1. 1. TM stated that all coating repairs performed to date comply with the CSA Z245.20 Standard.  CSA Z245.20 Table 9 limits the holiday repair of 914 mm (NPS 36) pipe to a frequency of less than or equal to 0.7/m2, and maximum area of less than 250 cm2.  If either of the limits (frequency or maximum area) are exceeded, the Standard requires that the coating be stripped and recoated in accordance to Clause 8.3. Provide:
    
   • a) Confirmation that any repairs conducted to date were conducted in compliance to the limitations (frequency or maximum area) specified in Table 9 of CSA Z245.20.
   • b) The procedure for the repairs conducted for the instances where the coating defects were larger than 150 mm (6”) in diameter. Include information on surface preparation, and the repair overlap.
   • c) The Non-Conformance Report for NCR Number: 01-13283-SG-M000-QA-NCR-0298. The Disposition Detail column states “Pipe repaired in accordance with the requirements of the Procedure for Repair of External Fusion Bond Epoxy Coating with Two- Part Epoxy (March 20th, 2018), and associated Inspection & Test Plan (March 23rd, 2018).”
   • d) The production coating test results (requirement of CSA Z245.20 Table 4 (for System 1A) and Table 8 (for System 2B)) for the batch consisting of the following pipe numbers: L317M19314 / L317M19281 and L317L15276 / T317L15263.
      
2. 2. TM stated that all coating repairs performed to date comply with the CSA Z245.20 Standard.
   • a) Demonstrate that the procedures followed by TM to conduct the repairs is relevant at the stockpile site considering that CSA Z245.20 is a plant-applied specification, intended for use in a controlled environment;
   • b) Considering that CSA Z245.30 is the legal requirement with respect to coating quality test requirements, and TM’s ITP references CSA Z245.30 through the MQAP, provide details of the tests that TM will undertake to validate the plant applied procedures, accounting for the variability between plant and field conditions (e.g. dust, weather dependent factors, etc.).  Refer to Table 6 of CSA Z245.30-14 for information on the testing requirements of this standard.

Due date: 2018-07-25

Date closed: 2019-01-30
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 4 - Notice of Non-Compliance #1: Incomplete Markings on Pipe Coating

Date & time of visit: 2018-06-07 09:00

Discipline: Integrity Management

Categories:

• Pipeline
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• NEB inspectors noted that pipe joints did not contain all the markings on the coating, as required by CSA Z245.20 Clause 9.2.1.The following requirements were observed to be lacking:
  • CSA Standard designation and year of publication (Z245.20-14);
  • Flexibility test temperature - the temperature shall be marked using the designation “FM30C” for the –30 °C test, “FM18C” for the –18 °C test, or “F0C” for the 0 °C test.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.3 Application and inspection of external protective coatings for buried or submerged piping
      • 9.3.2
        • 9.3.2.1 Plant applied protective coating of the external surface of pipe shall be as specified in CSA Z245.20, CSA Z245.21, or CSA Z245.22.

Company action required:

TM shall correct the markings on all pipe joints to ensure compliance with the requirements of CSA Z245.20 Clause 9.2.1, and provide supporting documentation confirming the change.
 

Due date: 2019-12-31

Date closed: 2019-08-16
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 5 - Information Request - Round 2

Date & time of visit: 2019-01-30 16:00

Discipline: Integrity Management

Categories:

• Pipeline
• Coating

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Having reviewed the information provided by TM, NEB inspectors continue to be of the view that CSA Z245.30-14 is the legal requirement at a stockpile site.  A review was also conducted on the responses received to the Request for Interpretation submitted by the NEB to CSA regarding this matter.  The Electronic Ballot Report (File Number: K110; Ballot Number: 4578) indicated that the majority were in agreement that the CSA Z245.30 code was applicable to a stockpile location. 

Secondly, NEB inspectors notes that CSA Z245.30-14 allows for repairs to be conducted as per the MQAP, and Clause 5.3.3 allows the company in consultation with the manufacturer, to approve any modification of the MQAP provided that it has ensured that the modification will not have any deleterious effects on the performance of the new or existing anti-corrosion coatings. NEB inspectors consulted SPC (the repair coating manufacturer) seeking comments on TM’s ITP and repair procedures used to conduct field repairs to-date.  The response received indicated that the procedures are likely adequate, provided that the repairs of the larger size were prepared using a mechanical method.  NEB inspectors note that the ITP did not clearly specify the requirement to use mechanical methods to perform surface preparation for the repairs of the larger size, as required by the MQAP (Section 7.0 Surface Preparation, PDF Page 8 of 21).
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 9. Corrosion control
    • 9.3 Application and inspection of external protective coatings for buried or submerged piping
      • 9.3.2
        • 9.3.2.2 Field applied protective coating of the external surface of piping shall be as specified in CSA Z245.30.

Company action required:

1. In order to validate the coating repairs conducted to-date, TM shall conduct the adhesion pull off tests that it committed to in response to NEB IR 2b - Observations: Teleconference with Trans Mountain and NEB.  The tests shall be conducted using production samples or panels (i.e. samples from current TM stockpiles).  The size of the damages shall be representative of the damages TM observed to date (i.e. the smaller and larger sized damages).  Subsequent to conducting the tests, TM shall provide the following to the NEB:
   1. the number of samples and the size of the damages with rationale for selecting these parameters (i.e. number of samples and damage size);
   2. an updated outline of the testing procedure;
   3. acceptance criteria for test results;
   4. results of the tests; and
   5. pictures to confirm test results.
       
2. For the larger sized repairs (i.e. where the repair size met or exceeded the 6” diameter damage (28 square inches)):
   1. Provide the percentage of repairs conducted to-date;
   2. confirm that the repair area was mechanically prepped using a surface grinder or by abrasive blasting as required by the SPC MQAP;
   3. if the response to b. is Negative, provide any additional tests that TM will conduct to validate the repairs; and
   4. provide a rationale for selecting the tests in response to c.  If no additional testing will be undertaken, provide a rationale.
       
3. Prior to conducting any further repairs on the material that will arrive in the next shipment(s), TM shall develop a field applied coating specification that is in compliance to CSA Z245.30-14 and include methods for conducting repairs that are representative of the handling damages observed by TM to-date.

Due date: 2019-05-31

Date closed: 2019-08-07
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

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: