Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans-Northern Pipelines Inc.
Operating company: Trans-Northern Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Field inspection of TNPI integrity digs on Dorval Lateral Jet Fuel Line due to results of most recent ILI run per company's verbal notification.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Integrity dig site DL-5.20-2018
Date & time of visit: 2018-08-05 09:10
Discipline: Integrity Management
Categories:
Facility:
Observations:
The tail gate meeting minutes, the task card for the day and the trench rescue plan were reviewed and signed off when arriving on site. The following personnel were on site at the NEB inspector's arrival: TNPI's chief inspector, the on-site inspector, the safety advisor, Somerville personnel (the construction contractor), GasTier personnel (the welding contractor) and NDT personnel (the non-destructive examination (NDE) contractor). The site inspector confirmed that the communication with the Control Centre was made in the morning before the sandblasting activities and confirmation that the pipeline was shut in was received. It was confirmed that the process requires another confirmation before starting welding activities.- The Emergency Response Plan was available on site.- Th pipe joint was not fully exposed. The coating was removed and a pipe segment of ~ 1 m on each side of the targeted feature was exposed and sandblasted.- The trench condition was good, a water pump was continuously draining water, proper ingress/eggres points, proper ventilation and gas monitoring were available.- Th NDE lead technician had proper CGSB level II qualification. The ultrasonic inspection equipment (UT) was calibrated. The NDE activities witnessed included the full circumferential magnetic particle inspection (MPI) of the pipe segment and the UT of the long seam.- The in-line inspection (ILI) targeted feature was a 4mm deep and 85 mm long internal crack-like in the long seam. Two adjacent crack-like ILI reported features were opportunistically marked for assessment and repair. The MPI of the pipe did not reveal any external feature. The shear wave UT inspection was performed on the long seam with 45, 60 and 70 deg probes as well as a fast probe. The pipe wall thickness measured at four positions was of 6.7 - 6.8 mm. A fourth ILI crack-like feature (2.8 mm deep and 43 mm long) located on the same pipe joint at ~3 m from the U/S girth weld was identified on the pipe tally by the NEB inspector. The feature was not exposed for assessment and repair. TNPI engineering personnel initially confirmed that the feature will not be assessed as the excavation focus was on the targeted feature only. It was confirmed that the standard NDE process (i.e. exposing and assessing the entire joint) does not apply for this particular emergency situation. The NEB inspector communicated that it was a good opportunity to assess the feature as the pipe was already excavated and this was the second deepest feature on the pipe joint. TNPI personnel confirmed that the feature's remaining life and pressure failure calculations allow the feature to remain unassesed as it is safe for returning to operations. However, it was later confirmed by the site inspector that this entire joint will be assessed as per TNPI's process. This will include the assessment of all reported ILI features. Confirmation was also received from engineering that this full joint will be assessed once the assessment of all critical features at all dig sites will be completed.- TNPI personnel confirmed that all six emergency dig sites are targeted for excavation by Wednesday 8 August 2018. It was also confirmed that a "SmartBall" leak detection ILI run will be scheduled on this line once the pipeline will return to operations.- The NEB inspector requested the final NDE reports for all six integrity dig sites to be provided once they become available (action item 1 identified).- The NDE inspection of the targeted feature identified an internal linear indication in the long seam of 2.8 mm deep and 77 mm long. It was noted that the dimensions were smaller than the ILI reported dimensions. This feature and two adjacent reported crack-like features were repaired by using a compression reinforcement repair sleeve (i.e. Type A from Petrosleeve). The sleeve was sandblasted prior installation. Proper safety measures were followed during the sandblasting activity including wearing the proper PPE, safety zone, and signage. The Petrosleeve installation sheet was completed by the site inspector. Epoxy base and hardener were mixed and manually applied on the pipe prior the sleeve installation to achieve the appropriate contact, lubrication and sealing. The sleeve was preheated to 100 deg C and properly supported by three sleeve clamps. The temperature readings were taken by the site inspector. The sleeve was properly installed extending ~50mm beyond the length of the defects on each side. Initial and final reading measurements were taken and used to ensure the appropriate compression. The welding electrodes were properly stored and verified as being appropriate for the welding task performed. The NEB inspector noted that the welding procedure was not available on site and therefore the welding activity could not be initially verified. The procedure and welder's qualification were provided by engineering. This was noted as a corrective non-compliance. Welder's certification was also verified. After reviewing the welding procedure, the NEB inspector noted that it applies to both the compression reinforcement repair sleeve and the pressure containment repair sleeve installation. The NDE requirement for the installed sleeve in the procedure provided, includes a 48 hours delay MPI and an UT of the welded sleeve. Field personnel confirmed that only MPI without 48 hours delay time will be performed on the sleeve. Further clarification regarding the MPI timing was required by the NEB inspector from TNPI. The information received from engineering confirmed that the full encirclement sleeve repair procedure (S1) provided is applicable for both, the compression sleeve as well as the pressure containment sleeve. The requirement for 48 hours MPI delay time as well as the UT inspection are applicable to the circumferential welds on the pressure containment sleeves. The weld inspection for longitudinal seam weld of compression sleeve is only carried out by MPI without a delayed time. The information also states that the procedure was identified for revision before these emergency excavations with a targeted finalizing date of 31 August 2018.- Additional five sites were identified for excavation as a result of the recent ILI. The following was noted during the inspection of these sites:a) Site DL5.41 was excavated and the pipe segment was sandblasted being ready for the NDE activities.b) The pipe location for excavation was marked but the work activities were not started at site DL0.15.c) Site 5.64 was excavated and the ongoing activity was manually exposing the pipe segment.d) Site 5.91 was not inspected as it was located in a swamp area with no ongoing activities.e) Site 8.46 had no ongoing activities.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
To provide the welding procedure for the sleeve installation.
Due date: 2018-08-05
Date closed: 2018-08-05 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
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
