Compliance Verification Activity Report: CV2324-093 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2408
• Inspector 2648

Regulated company: Trans Mountain Pipeline ULC

Operating company:

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Safety Management
• Indigenous Monitoring

Rationale and scope:

[TMX Spread 5A and 5B - 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:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

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

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Spread 5B Miners Tunnel

Date & time of visit: 2023-07-18 10:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Training and Competency
• Training, Competency and Qualification
• Workplace Practices
• Hot Work
• Safe Work Permits
• Duties and Responsibilities
• Job/Task Safety Analysis
• Procedures/Work Instructions
• Access to hazardous areas
• Contractor Management & Oversight
• Supervision, Inspection and Monitoring
• Hazard Management
• Management of Hazardous Materials & Substances
• Occupational Hazard Inventory
• Equipment, Tools, Machinery
• Motor Vehicles and Mobile Equipment
• General
• Signage
• Personal Protective Equipment
• General

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Spread 5B: Location 1029

• Per the SSERP monthly tunnel emergency responses done. CER were provided with reports to review from May and June and were able to see corrective actions were put in place.
• Ventilation is approximately 37-38000CFM with the ventilation fans.
• 150 hp fan for ventilation observed to be in an area away from equipment exhaust
• Workers identified that the main Hazard to laying the concrete was concrete burns from the chemical mixture in the concrete. CER did not observe concrete burns to be in the CHRR or UHRR. CER discussed with TMEP Regulatory post inspection and were advised it would be added.
• Workers identified that fire was also a concern inside the tunnel and it was not identified on the UHRR and CHRR. CER discussed with TMEP Regulatory post inspection and were advised it would be added.
• Silica present in the tunnel and silica plan available.
• Flags hanging from tunnel walls used as a way of determining if ventilation stops or when there’s a change in direction. This method of alarm/notification was called into question. Provincial regulator addressed this with the contractor on site. 
• Methods of communication in the tunnel were by hard-wired telephones in the tunnel, two way radios, and cell phones.
• CER were told that all welding had a two-hour/10m radius fire watch before, during, and after, in addition to wetting the area.
• Minimum of 2 workers per crew have S100 fire training
• Workers in the tunnels were equipped with 'Scan Link' alarming strips in their hard hats that would alarm if equipment was in proximity to them in the tunnel operations.
• Board placed at the safety shack near the tunnel entry with all of the crews photo ID tags on the board for each crew. CER were told and observed ID tags moved to show when a person was in or out of the tunnel.
• Work area and pedestrian travel area was separated to ensure that pedestrian traffic did not enter the work area.
• CER were told that medics were a sub contractor for this spread and Team5B did not proactively communicate with the medics to ensure their well-being through the work shift. It was the expectation that the medics had their own channels for daily check-ins.
• Observed task lighting in the tunnels and told that it was of sufficient lumen for the tasks being conducted. All workers in the tunnels wore head lamps as well.

Compliance tool used: No compliance tool used

Observation 2 - Spread 5A Jacko Lake

Date & time of visit: 2023-07-19 09:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Training and Competency
• Training, Competency and Qualification
• Workplace Practices
• Working at Heights
• Hot Work
• Confined Space
• Safe Work Permits
• House Keeping
• Duties and Responsibilities
• Job/Task Safety Analysis
• Procedures/Work Instructions
• Scaffolding, temporary stairs, ramps and platforms
• Access to hazardous areas
• Contractor Management & Oversight
• Supervision, Inspection and Monitoring
• Hazard Management
• Management of Hazardous Energy
• Occupational Hazard Inventory
• Equipment, Tools, Machinery
• Use, Operation, Repair and Maintenance of Mechanical & Critical Lifting Equipment
• Motor Vehicles and Mobile Equipment
• General
• Signage
• Personal Protective Equipment
• General

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• Working around heavy equipment, Thumbs up only.
• There are firefighting tools at all smoking locations.
• HSE meet to talk every Wednesday at 3 PM or at 1 PM.
• Electrolyte packs offered to all employees.
• Inside they tunnels they use airhorns and cell phones as there is Wi-Fi in the tunnels

•  
• Observed scaffolding stairs didn’t have sufficient inspection tag information as the date was not accurate advising the stairs were safe for use.
• Observed demobe of the equipment at the pad.
• Shaft designated as confined space. CER spoke with Confined Space attendant about their duties, roles, responsibilities.
• All hardhats required to have a helmet lanyard and nothing in hands or shirt/vest pockets when looking into the shaft as falling objects was a hazard for workers below.

• Pad 6:
  • 2 hours spark watch
  • Observed sheet piles being installed to create a new bell hole for tunnel drilling.
  • Mobile equipment onsite was equipped with the required secondary means of egress. Cranes on site were not considered mobile equipment, therefor, window breaks were not required.
  • CER participated in the toolbox talk that occurred from day shift to night shift. CER spoke with the night foreman regarding the communication between the night and day shift. CER were told that both foreman always go through the previous shift activities, if issues occurred or not, and any required safety information for the crossover.
  • During the meeting, working overnight, fatigue, significant change in temperature and requirement for dry clothing was discussed.
  • Light plants were available and installed each night to ensure adequate task lighting.
  • Crews were told that bears were observed in the area earlier in the day and reviewed locations to move to should bears enter the work area.
• Pad 3:
  •  shaft 33.5 m deep half foot to 1 foot of water in the shaft.
  •  the Tunnelling Company are the subcontractor and TM is taken over this site from the previous GCC.
  • TM has safety coaches to improve the level of safety to help creative a positive culture with the workers. The coaches are in addition to formal inspections.
  • Ventilation is 50 CFM per worker in the tunnel.
  • No passive air. Ventilation two fans facing each other offset for changes in air direction.

Compliance tool used: No compliance tool used

Observation 3 - Cartwright

Date & time of visit: 2023-07-20 09:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Limits of Exposure
• Workplace Practices
• Safe Work Permits
• Job/Task Safety Analysis
• Procedures/Work Instructions
• Contractor Management & Oversight
• Supervision, Inspection and Monitoring
• General
• Personal Protective Equipment
• General

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Cartwright location top KP 844.114 the bottom KP843.68 grade is between 16 to 20%

• UTV owner manual slope limits 15°. UTV only operated on the road between the top and bottom of the slope.
• Workplace lighting for overnight work.
• Electrolyte packs offered to all employees.
• Wooden stairs built along the side edge of the ROW to assist the workers at this steep location.
• Observed workers using two different hand operated vibrating ground compaction machines to compact the ground near the valve at KP834.68. Machines in question indicated the noise produced by the machines were 107dB and 109dBb. Project documentation required double hearing protection where noise levels were at or above 105dB. Workers were all wearing single hearing protection at the time of the inspection. When questioned if it should be double based on the levels indicated on the machines no one at sight was able to answer. Company stopped work until double hearing protection was provided for the workers. Company reviewed conducted noise level testing and determined the noise level to be below 105dB and in the range of single hearing protection requirements. The CER has concerns that none of the individuals at the site were aware of the dB levels that required double hearing protection and that occupational were not known.
• CER spoke with the medic situated at KP844.114 about their job. Medic indicated they were in constant communication with the crews nearby. The medic walked CER through their daily inspection. Medic truck at this location had zero bottles of eye wash or saline for use in the event of an injury. Company issued a PAR to ensure that all medic trucks were properly inspected and had the required supplies on board.
• Observed large bags filled with dirt placed between the edge of the work area and the train tracks. The type of bags used created a wall designed to stop debris or equipment if it rolled down the slope.

Compliance tool used: No compliance tool used

Observation 4 - CNC-Eye Wash Medic truck

Date & time of visit: 2023-07-20 12:00

Discipline: Safety Management

Categories:

• Contractor Management & Oversight
• Supervision, Inspection and Monitoring

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

 Medic truck at this location had zero bottles of eye wash or saline for use in the event of an injury.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR) 2020-03-16

Relevant section(s):

• • 6.5
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (l) establish and implement a process for making employees and other persons working with or on behalf of the company aware of their responsibilities in relation to the processes and procedures required by this section;

Company action required:

Company created a PAR to ensure that all medic srucks on the spread were inspected and had appropriate supplies on board. 

Due date: 2023-07-20

Date closed: 2023-10-27
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

Observations (company follow-up required)

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