Compliance Verification Activity Report: CV1819-058 - Enbridge Pipelines (NW) Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2696

Regulated company: Enbridge Pipelines (NW) Inc.

Operating company: Enbridge Pipelines (NW) Inc.

Province(s) / Territory(s):

• Northwest Territories

Discipline(s):

• Integrity Management

Rationale and scope:

Field inspection of HDD as part of Line 21 replacement project [Field inspection of HDD and Valve Replacement as part of Line 21 replacement project]

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• LINE 21 REPLACEMENT HDD

Facility Types

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

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XO-E102-002-2018

Observations (no outstanding follow-up required)

Observation 1 - South Site (HDD pipe entry point):

Date & time of visit: 2018-08-08 08:00

Discipline: Integrity Management

Categories:

• Pipeline
• Bends and Elbows
• Excavations
• HDD/Drilling
• Pipe Condition
• Materials
• Coating
• Procedures

Facility:

• LINE 21 REPLACEMENT HDD (Pipeline)

Observations:

• NEB inspectors received the contractor's Visitor Orientation and completed the site specific safety orientation at the contractor's Yard office.  NEB inspectors were also provided with a copy of the Project’s Emergency Response Plan.
   
• Company had completed the final reaming (20 inch) process, and was in the process of conducting its first swab run of the borehole during the NEB inspection.  Company stated the plan was to conduct two swab runs but more was possible depending on the observations made during the swabs.
   
• Intersect method of HDD was followed.  Company stated that the final borehole was within 3 meters radius of design.
   
• Company stated that the pipe would be installed to 143 m below river bed.  Drilling to this depth was due to the no drill zone that was identified during the design stage of the project.
   
• Surface casing was installed on the South Side entry (~90 m). Company stated the purpose of the casing was to stabilize the borehole and prevent returns to surface.  The casing was removed when the borehole stability was confirmed, prior to reaming.
   
• Returns to surface was observed at 4 locations near the entry point at the South site.  The areas of surface returns were fenced by silt fences and isolated. The return to surface fluid at these four locations was collected and treated along with the drilling fluid return material.
   
• Drilling fluid returns were treated on site and separated using a separation unit.  The separation unit separated the drilling fluid to slurry, sand, gravel, and fines.  The slurrywas then mixed with additives and soil to form a mix-bury mixture.  The mix-bury mixture was stored in bins on-site and samples from each bin was sent for testing to confirm the soil to mix ratios and adequacy for site burial.  Once confirmation on the adequacy of the mixture was received, the mixture was disposed of by burial on site.  Excavations were being made on site to dispose of the approved mix-bury material at the time of the NEB inspection.
   
• The valve replacement area was being hydrovaced. 
• An area where several driven steel pipes were pushed into the ground was observed.  Company stated that these pipe piles are foundation for a radio tower and an electrical station that were to be placed at this site to aide with the valve’s remote operation.
   
• NEB inspectors observed the pipe on the south side laydown area.  All the joints were welded and girth welds coated.  The pipe was supported on rollers throughout.  Company stated that the lift plan for pipe pullback was to be finalized by the Engineering Department that day.  Security pipe was also observed in the area.
   
• The line pipe observed was manufactured and coated in Canada.  It had a nominal pipe size (NPS) of 12, minimum wall thickness of 12.7 mm, Grade 359, and rated for sour service.  The coating was observed to be Fusion Bond Epoxy (FBE) with Abrasion Resistant Overcoat.  All the required marking on the pipe body were compliant to the requirements of CSA Z241.1 and CSA Z245.20.
   
• The girth welds were observed to be coated with Epoxy.  The pipe was marked with coating thickness measurements.  It was confirmed that the required coating quality assurance activities such as testing for adhesion, hardness, dry film thickness and visual were performed. Hardness testing was completed on each crew at the frequency of 1 for every 25 welds. Thickness measurements were performed for each weld location along the entire circumferential profile of the pipe after the coating application was complete (one on each quadrant, and one on the bead).  Adhesion tests were conducted for 1 in every 25 welds (one X-cut on the substrate and one on the overlap).
   
• Company confirmed that the line pipe was holiday tested twice already, and would be holiday tested again immediately prior to pull back.  The identified areas of repairs was to be repaired to company’s field coating specifications and CSA Z245.30.
   
• Company confirmed that the above grade pre-pull hydrostatic testing was completed for all the pipe approximately two weeks prior to the NEB inspection, meeting the requirements of CSA Z662 Clause 8.  No failures were encountered during pressure testing.  Company confirmed that pipe will be re-tested in place subsequent to the completion of pipe pull back.
   
• The site contained water storage tanks to store water and use as needed for site operations (including hydrostatic testing).  Company stated that they have an allowance to pump 300 m3 from the Mackenzie River per day.
   
• Company stated that once pull back was completed a deformation tool would be run, prior to the beginning of operations.
   
• Pullback was anticipated to begin on 10 August. (See Information Request #1).
   
• NEB inspectors inquired about welding and non-destructive examinations (NDE) conducted for the girth welds on the line pipe.  Company confirmed that the shielded metal arc welding (SMAW) process was utilized for welding.  Company stated that the repair rate was zero.  Automatic ultrasonic testing (AUT) was conducted for the mainline welds by a Level 2 inspector, as per requirements.  X-ray testing would be utilized for the tie-in welds.
   
• The HDD replacement segment was planned to be tied in to the existing pipeline at the North and South side through the use of lateral and over-bend induction bends.  NEB inspectors observed these induction bends at the site and the transition pups (12.75mm WT to 6.35mm WT) to allow tie-ins to the existing pipe. 
   
• NEB inspectors reviewed the Material Test Records (MTR) of two pipe joints that were observed in the field and the Induction Bends.  Third party verification was conducted by Acuren on the induction bends.  The Inspection Test Plan for the induction bends was also reviewed.
   
• NEB inspectors conducted a review of the Project related joining procedures, procedure qualifications and welder qualifications on file at the Field Office.  Review performed on the welder qualifications indicated that the certifications met the requirements specified in CSA Z662-15.
   
• NEB inspectors inquired about the coating plans for the tie-in locations. Company stated that epoxy coating would be applied.  Denso LT Tape would then be applied and covered with Denso Glass Outerwrap.  (Epoxy is applied up to the existing Yellow Jacket coating; Denso LT tape is applied to one foot over the epoxy and one foot over the existing.)

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
  • 6.Transportation, handling, and installation
    • 6.2 Activities on pipeline rights-of-way
      • 6.2.11 Horizontal directional drilling (HDD)
        • 6.2.11.4 Evaluation of pipe and coating integrity shall include
          a) prior to pull back, visual and nondestructive inspection of all girth welds as specified in Clause 7.10;
          b) visual inspection of the pipe and coating for damage where it exits the drill hole upon completion of the pull back; and
          c) post-installation pressure test of the drag section as specified in Clause 8.
          Note: Consideration should be given to
          a) pre-test of the drag section;
          b) post-installation coating survey; and
          c) in-line inspection.

Company action required:

Company to provide:

1. Dates for when pipe pull back was completed, or is anticipated to be completed;
2. Details on the inspections conducted on pipe and pipe coating after the completion of pipe pull back, along with the acceptance criteria for each;
3. Details on the results of the inspections conducted in 2. above; and
4. Pictures of the pipe pullback operations, and pipe and pipe coating after the completion of pullback.

Due date: 2018-09-07

Date closed: 2018-10-22
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 - South Mackenzie River Slope

Date & time of visit: 2018-08-08 11:00

Discipline: Integrity Management

Categories:

• Pipeline
• Inspections
• ROW

Facility:

• LINE 21 REPLACEMENT HDD (Pipeline)

Observations:

• Company stated that the south slope was being monitored by a contractor employee and that a report was prepared and submitted to the Company daily. The report contains photos, data, and an assessment of any changes that are observed along the slope visually and by the instrumentation on the slope.
   
• A crack in ground surface was observed during a walk along the crest of the south slope. The crack was fenced and was being monitored during construction. Company stated that this crack was pre construction and monitoring of the slope was conducted to ensure none of the vibration due to the HDD are transferring or affecting the slope stability.
   
• A contractor employee present along the slope for slope monitoring purposes.The presence of digital monitoring equipment powered with a solar panel was also noted.
   
• Due to a bear scare alert that was ongoing at the time of the inspection, NEB inspectors and company personnel were not allowed to walk the south slope.
   
• When NEB inspectors enquired about the slope monitoring and stabilization after the completion of construction, company stated that the slope will be monitored on annual basis. However, slope stabilization would not be implemented since the sensitive condition of the slope would prevent any construction equipment from travelling along the slope. In addition, after considering all stabilization options none were deemed adequate at this location.

Compliance tool used: No compliance tool used

Observation 3 - North Site (HDD pipe exit point)

Date & time of visit: 2018-08-08 15:00

Discipline: Integrity Management

Categories:

• Pipeline
• HDD/Drilling
• ROW

Facility:

• LINE 21 REPLACEMENT HDD (Pipeline)

Observations:

• Company stated that swabbing process is ongoing and that the drill path appears to be clear and that they might need another swab to ensure the safe pullback operation.  Approximately 290 m remained to be swabbed.
   
• NEB inspectors observed the induction bends at the site as well and the transition pups (12.75mm WT to 6.35mm WT) to allow tie-ins to the existing pipe.
   
• When NEB inspectors enquired about the pullback force anticipated, company stated that the pullback force was expected to be in the range of 270,000 lb and the rig capacity was approximately 840,000 lb.
   
• Mix-bury operation was ongoing at this location as well to treat the drilling fluid return.
   
• No return to surface was encountered at this location.
   
• Drilling fluid returns were treated on site and separated using a separation unit. The separation unit separated the drilling fluid to slurry, sand, gravel, and fines. The slurry was then mixed with additives and soil to form a mix-bury mixture.  The mixture was stored in bins on-site and samples from each bin was sent for testing to confirm the soil to mix ratios.  Once confirmation on the adequacy of the mixture was received, the mixture was disposed of by burial on site.  Excavations were being made on site to dispose of the approved mix-bury material at the time of the NEB inspection.

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: