Compliance Verification Activity Report: CV2324-170 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2324-170
Start date: 2023-06-19
End date: 2023-06-23

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

[NGTL West Path Delivery 2023 (includes coating/chemical safety reviews per VAR-001-DJM-001-2022) Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of hazards and appropriate controls relevant to the job tasks via hazard assessments; company oversight of contractors - training & competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.]

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observation > Lundbreck 7.1 km section

Date & time of visit: 2023-06-20 06:00

Discipline: Safety Management

Categories:

Facility:

Observations:

  1. Inspection team comprising of CER Inspection Officers (IO's) and two Indigenous Monitors (IM's) met company representatives for an opening meeting at the Lundbreck yard around 08:30 AM on June 20. 
  2. Company informed the inspection team of one incident at the yard ( incident reference WAML HS 06) with property damage. 
  3. SMJV is the prime contractor for this section. Lundbreck yard had SMJV controlled portion of the yard and Pre-may prime contractor controlled portion of the yard. During the inspection, no stockpiling or pipe handling was observed to be occurring in the yard. 
  4. SMJV follows the latest version of the Canadian model for A&D testing with onsite designated SMJV employees being trained to carry out testing. 
  5. One steep slope was identified by SMJV at KP 0+442 and was redesigned from a slope greater than 21 degrees to a slope between 16 to 20 degrees. 
  6. In the toolcrib, gaps between toolcrib trailers were observed beside ramps connecting each trailer. These gaps were about 8-10 inches wide. In some places these gaps were covered with plywood which likely was not strong enough to prevent a fall. These gap should be covered up with strong enough material to prevent a trip or a fall hazard. 

Compliance tool used: No compliance tool used

Observation 2 - General Observation > Longview 9.1 km section & Turner Valley 22.9 km section

Date & time of visit: 2023-06-21 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

  1. Yard inspection was completed and no compliance concerns were noted. A gas-can with handwritten label was observed. Company representatives applied a workplace WHMIS label. 
  2. Empty acetylene and oxygen bottles were stored in designated locations. All bottles were secured and upright. 
  3. Full acetylene and oxygen bottles were also stored properly. Bottles had regulators and/or bottle gaps. 
  4. Grounding, containment and WHMIS labelling was adequately applied at the fuelling station. 
  5. Workers were able to demonstrate access to SDS. Observed toolcrib worker able to open SDS for acetone stored in the flammable cabinets in the toolcrib. 
  6. Competency assessments were reviewed at WAS 60, and WAS 70 and found to be in line with SSSP requirements. 
  7. Workers completing FLHA's were only selecting applicable hazards and not indicating "N/A" or "NR" for hazards not applicable. This observation was shared with the workers who corrected their practice. 

Compliance tool used: No compliance tool used

Observation 3 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 4 - CNC#1: Tagging of Inoperable or broken tool

Date & time of visit: 2023-06-20 06:00

Discipline: Safety Management

Categories:

Facility:

Observations:

 

  1. At the tool crib, a skill saw was reported to the IOs as out of service. This skill saw had an orange ribbon on it to designate it as out of service. IOs communicated that a proper tag must be applied to ensure that anyone with access could immediately know not to use the saw.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall apply tags indicating that defective or inoperable tool is not to be used. 

Due date: 2023-06-20

Date closed: 2023-06-27
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 - CNC#2: Fire Extinguisher Inspections

Date & time of visit: 2023-06-20 06:00

Discipline: Safety Management

Categories:

Facility:

Observations:

 

  1. During inspection at the Lundbreck yard, a fire extinguisher near the main diesel generator sea-can was found without monthly or annual inspection. Another fire extinguisher was found without updated inspection at the Turner Valley compressor station near a light plant. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company to replace or complete fire extinguisher inspection as per the SSSP. 

Due date: 2023-06-22

Date closed: 2023-06-27
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 6 - NNC#1: Excavation practices and warnings

Date & time of visit: 2023-06-22 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

  1. During the inspection at Longview and Turner valley sections, workers were observed working within 0.3 meters of the edge of the excavation at Road 3, WAS80, and Road 8 (across Turner Valley Compressor Station). Fall hazard arising from worker location was not controlled. 
  2. At Road 8, a large excavation was present with two sides fenced off by orange snow fence. The other two sides of the excavation had no barriers or warning or other safe guarding in place. Control zone around the excavation was not in place. 
  3. Company's Technical Specification TES-CT-EXC-GLE revision 4 requires all excavations to have appropriate safeguarding. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall submit corrective actions which demonstrate that

  1. Safeguards are effective in controlling risks to workers around excavations
  2. Company excavation specifications are consistently enforced at worksites
  3. Actions on safeguards around excavations are implemented
  4. Requisite corrective and preventive actions to protect workers around excavations per the noted observations in the NNC are in place

Due date: 2023-07-31

Date closed: 2023-09-11
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:

- 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