Compliance Verification Activity Report: CV2122-177 - Westcoast Energy Inc.


Compliance verification activity type: Field Inspection

Activity #: CV2122-177
Start date: 2022-03-15
End date: 2022-03-17


Regulated company: Westcoast Energy Inc.

Operating company: Enbridge Inc.

Province(s) / Territory(s):


Related events:

Rationale and scope:

Process Safety: T-South Compressor Stations 4A, 4B, and 6A: Assess implementation of identification, analysis and control of process hazards including established process hazard inventory. Assess completion of preventive maintenance activities on safety systems and safeguards per prescribed frequencies under CSA Z662 and company programs.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - IR 1 - Pre-inspection document request

Discipline: Safety Management




CER Inspection Officers requests documentation in advance of the field inspection.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Process Hazard Identification, Analysis, and Control 

  1. Provide a copy of the process used for identifying and analyzing process hazards related to the T-south reliability and expansion project.
  2. Provide an inventory of the identified process related hazards required by the Canadian Energy Regulator Onshore Pipeline Regulations paragraph 6.5(1)(d) for compressor station 4B and 6A.
  3. Provide a copy of the most recent hazard and operability study (HAZOP) or process hazard analysis for the for compressor station 4B and compressor station 6A.

Safety Critical Equipment

  1. Explain how Westcoast Energy defines and identifies safety critical equipment.
  2. Provide a list of safety critical equipment for compressor stations 4A, 4B, and 6A. This list may be grouped by equipment type rather than supplying a list of each individual item.

Due date: 2022-03-07

Date closed: 2022-03-15
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 - CS-4A, 4B, 6A general observations

Date & time of visit: 2022-03-17 14:00

Discipline: Safety Management





CER Inspectors (IOs) performed field safety inspections on 3 compressor stations involved in the T-South Reliability and Expansion Program (TSRE) over 3 days. TSRE construction was completed in 2021 and the new compressor units at each station were operating at the time of inspection. Prior to the inspection, IOs asked the company to demonstrate how process related hazards were identified, analyzed, and controlled for CS-4A, CS-4B, and CS-6A.

Hazard Identification and Analysis
In their response, the company stated process related hazards were identified and analyzed in accordance with their GTM IMS 2.1-Hazard Identification and Inventory Process and Hazard and Operability (HAZOP) Study Procedure, PSM-P0002-17. Section 3 of this procedure states its applicability to both major projects (such as TSRE) and operations and applies to Canadian assets inclusive of compressor stations and pipeline systems.

The company provided copies of the HAZOP studies for CS-4A, CS-4B, and CS-6A completed May 7-11, 2018, July 24-26, 2018, and May 7-11, 2018 respectively. Each of these studied identified several risk-prioritized recommendations. Through document review and discussions with company staff, IOs verified the timing, team composition, and general methodology of the studies were performed in accordance with the company’s procedure. No items of non-compliance were identified.

Hazard Control
Section 9.5 of PSM-P0002-17 describes the company’s processes for following up on HAZOP recommendations. It states that a formal record and audit trail shall be kept for each recommendation which includes technical reasons for recommendation resolution. IOs selected 6 recommendations from CS-4A, 2 recommendations from CS-4B, and 5 recommendations from CS-6A to verify the company had addressed the recommendations in accordance with their procedure. Verification involved reviewing each of the signed HAZOP Action Sheets, discussions with company operational staff, and field verification were possible. No items of non-compliance were observed.

Process Hazard Inventory
IOs requested a copy of the hazard inventory for CS-4A, CS-4B, and CS-6A. An inventory was provided that included process related and non-process related hazards. The company stated new hazards, such as those identified by operations staff, are entered into a computerized system and tracked until resolution.

IOs requested and received from the company a list of safety critical equipment applicable to CS-4A, CS-4B, and CS-6A. IOs verified completion of preventative maintenance of selected equipment by reviewing maintenance records and through discussions with operations staff. Details of these verification activities can be found below in the station specific observations.

IOs asked company operational staff to demonstrate they had access to written procedures for maintenance tasks such as fuel gas filter change, calibration of fixed gas detectors, and valve maintenance. In all cases, company staff demonstrated they had access to task specific written procedures. Additionally, IOs verified that station operators had access to red-lined as built drawings including P&IDs for each station.


Compressor 4A

  1. Arrived on site at 0945 hours. Orientation completed at Operations building with Operator at the station. CER IOs presented identification at the company’s request.
  2. Compressor station processes dry natural gas. No methanol is used in process at the station.
  3. Signage at the main gate to compressor station was controlled and properly identified with emergency contact information.
  4. No contractors or maintenance work was occurring on site during the inspection. A medic was posted outside the main gate and was later identified as supporting work at adjacent P&G facility. IOs were informed that maintenance is normally performed in the summer months. Coordination for various maintenance work is done through a permit system.
  5. Compressor station was bought by Enbridge from Spectra Energy and work is ongoing to harmonize documentation with Enbridge. Currently, Gas Transmission follows documentation and processes provided by Enbridge. Compressor station expansion was undertaken to increase reliability. 
  6. Facility relies on power from BC Hydro and there are back-up generators in place to maintain operability.
  7. Ongoing Occupational Health monitoring for noise and other health hazards has been performed.
  8. LEL alarm set points are at 25% and 40%.
  9. As there is a P&G facility nearby, prior to blowdown at the compressor station, communication is maintained with P&G.
  10. Station is staffed during the day and supported through remote control station.
  11. Typical tasks performed by an operator include review of shift log, equipment log, process overview, oil/lubricant top ups and field walk downs.  
  12. Operators initiate a man down timer and remain in contact with gas control through a pager system. If there is hazardous work occurring on site, then there are additional operators on site.
  13. Isolations for main valves have been identified; other critical equipment are inspected once per year. Position indicators on process valves were clearly visible.
  14. When performing isolations, a template is followed, however , a new LOTO is created each time an isolation is undertaken.
  15. Back-up batteries are inspected monthly.
  16. Calibration points were available at appropriate location for gas detection. Any upsets or equipment malfunction is managed through internal equipment reporting system. Records of calibration were reviewed for 2 gas detectors in the unit 10 building.
  17. Building smoke or fire detection is tested quarterly. All unit and station shut down equipment is tested annually during outages.

Compressor 4B
  1. Orientation completed through area Operator. CER IOs presented identification at the company’s request.
  2. Unit 10 was identified as a building where double hearing is required.
  3. Working Alone is managed through a man down timer with gas control contact.
  4. The station’s system receives high and low alarms which are triaged. Any changes to the setting of the operator panel is managed by a request to Enbridge’s engineering team. Operators are not able to make changes to alarm settings.
  5. Various type of work is also managed through a permit system.
  6. Maintenance work is primarily contracted and are managed through the permit system.
  7. Safety critical equipment gets tested at least once per year.
  8. Operators were asked to show relevant drawings which they were able to demonstrate. Both as-built and IFC drawings were available to operators in their system.
  9. The approach to managing hazards is through a risk registry which does not include day to day hazards. Routine hazards are managed through field level hazard assessments.
  10. LEL alarms at this station were set at 20% and 40%. These alarms were supplemented with building and area beacon lights to indicate the nature of alarm.

Compressor 6A
  1. Site orientation completed at 1015 with the facility operator. Main gate was adequately labeled and controlled through signage, and security cameras.
  2. Due to pre-construction activity at this station, everyone was required to sign in/out of the station through a site medic. A site COVID assessment was completed with the medic.
  3. During the opening meeting, CER was informed that all compressor stations had AEDs. This comment is in line with observations made at compressor station 4a and 4b.
  4. Permit system was also utilized at this site to manage any work, including walk downs.
  5. IOs verified that operators had access to operational procedures and drawings. Procedures were written to task with various pieces of equipment in scope.
  6. High risk HAZOP recommendations were  reviewed in the meeting and recommended changes were noted in the field.
  7. Inconsistent signage for double hearing was identified and company took action to install correct signage. 
  8. During the walkdown, a bent fixed ladder was observed. CER IO identified the ladder and company proceeded to apply out of service flagging to the ladder. 

Compliance tool used: No compliance tool used

Observation 3 - CNC 1 - Lube oil stored in CS-6A compressor building

Date & time of visit: 2022-03-17 11:45

Discipline: Safety Management




CER Inspection Officer observed two barrels of lube oil stored in the unit 10 compressor building. When asked, company representative stated the 2 barrels represented a year's worth of supply.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Remove the lubricants from unit 10 compressor building beyond that which is required for everyday use and store in a noncombustible structure located a suitable distance from the compressor building.

Due date: 2022-03-17

Date closed: 2022-03-17
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