Compliance Verification Activity Report: CV2021-224 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-224
Start date: 2020-07-13
End date: 2020-07-17

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

TMX Project Valemont Work Camps - Condition compliance to contractor worker code of conduct in camps; Contractor community orientation program; Contractor overarching disciplinary policy; Contractor awareness program. Compliance to Conditions 59, 64 and 73. Assess implementation of COVID-19 safety and hygiene measures

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Additional Project-specific requirements or conditions:

CER Condition 73 CER Condition 64b CER Condition 59

Observations (no outstanding follow-up required)

Observation 1 - Trans Mountain Expansion Project, CER Condition 73 - Traffic Controls Plans for Public Roadways; Valemount ATCO Camp Spread 3.

Date & time of visit: 2020-07-13 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Pursuant to Trans Mountain Expansion Project, CER Condition 73 - Traffic Controls Plans for Public Roadways;  - please file the applicable contractor's (Ledcor/Sicim) Traffic Management Plan applicable to Spread 3.  

Compliance tool used: No compliance tool used

Observation 2 - Trans Mountain Expansion Project, CER Condition 59 Worker Accommodation Strategy - Camp Health and Medical Services Plan.

Date & time of visit: 2020-07-13 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Pursuant to the Trans Mountain Expansion Project (TMEP), CER Condition 59 Worker Accomodation Strategy, TMEP is required to develop an appropropiately scaled Health and Medical Services Plan for all camp operations.

Compliance tool used: No compliance tool used

Observation 3 - General Observation of Valemount Industrial Work Camp

Date & time of visit: 2020-07-15 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

General observations
• TransMountain provided CER Inspectors and Indigenous Monitor a copy of the TransMountain Pipeline ULC TransMountain Expansion Project CER Conditions 59 & 60 Temporary Worker Accommodation Valemount Area, report on TransMountain Covid -19 Preparedness and Planning report prior to safety inspection July 14th, 2020 start date. This report was perused by the CER inspectors and Indigenous monitor prior to starting safety inspection and observations during the inspection were validated with the report and Covid -19 protective measures appeared to have been implemented.
• Perimeter fencing and two gates appeared to be maintained in good condition with proper signage, including company and emergency contact numbers and warning signs to deter intrusion.
• CER inspectors and Indigenous Monitor were met at entrance gate to Valemount Industrial Work Camp by TransMountain representatives and each CER inspector & Indigenous Monitor were provided with a TransMountain Covid-19 Self declaration Questionnaire to complete and signoff and present to TransMountain (TM) Representative from a safe distance. TM representative verified that all check boxes on the the self-declaration form indicated a NO response and the form was signed prior to allowing access through the Work Camp gate. The T.M. representative inside the gate directed CER inspectors and Indigenous Monitor to the temperature checking area. The Covid -19 self-declaration form remained in the possession of the CER inspection and Indigenous Monitor for the duration of the inspection. The person completing, would be required to show T.M. representative again when leaving and/or accessing the camp. Form remained the property of the person completing the form.
• CER inspectors and Indigenous Monitor observed that T.M. representative and medical personnel wore Personal Protective Equipment (PPE) which included either N95 or surgical face masks at entrance to camp, and that medical personnel, with Occupational First Aid designation for British Columbia held an OFA3 (occupational first aid-level 3, British Columbia designation) took temperature checks of all workers entering the camp and exiting the camp and recorded the worker temperatures at that point of time. Temperature check range to allow camp access is between 35.8 and 38 Celsius range. Ranges above 37.5 C, supervisor is notified and three retests are required for that worker at .30 minute intervals.
• 25KV Overhead power line was identified by marker clearance banners at the safe clearance measure below the power lines along with administrative signage identifying both the electrical hazard and voltage of the line, 25 KV prior to crossing under the electrical lines at the Valemount Work Camp entrance point.
• TransMountain Company representatives delivered a site specific orientation to CER staff at Valemount Industrial Work Camp, which included a description of emergency procedures, alarm types and muster areas (i.e. A & B). Administrative controls (signage) identifying First Aid office were observed by CER Inspectors and Indigenous Monitor throughout the camp.
• CER Inspectors and Indigenous Monitor were provided a Field Level Risk Assessment (FLRA) for the Valemount Industrial Work Camp that was delivered by the TransMountain representative, prior to the inspection commencing.
• CER Inspectors and Indigenous Monitor observed TransMountain staff and workers in the camp practicing good hygiene practices, such as, wearing of surgical or cotton face masks and maintaining 2 metre (6 feet) distancing.
• CER Inspectors and Indigenous Monitor were provided a copy of the Valemount Camp Guest Welcome Package that is provided to all workers, and examined the Covid -19 measures which appeared to be stringent, complete, and current (i.e. July 13th, 2020 - Revision 2.0.
• General housekeeping appeared adequate, as indicated by such observations as: floors clear of tripping hazards; equipment and tools properly stored; waste material segregated; only garbage in garbage bins; only wood material in designated bins, bins identified with signage on what is allowed to be placed in bin and bins not over-filled.
• CER Inspectors and Indigenous Monitor observed hand sanitizing dispensers placed throughout the camp and workers using the dispensers to sanitize hands on a regular basis when passing through the dorm corridors.
• CER Inspectors and Indigenous Monitor observed Camp kitchen staff to be wearing disposable surgical masks, nitrile gloves and hairnets.
• CER Inspectors and Indigenous Monitor observed that the Camp worker eating area, had worker traffic flow markings on the tiled floor to identify worker direction, thus mitigating on-coming worker contact, and eating areas "tables" were spaced 2 metres apart with allocated chairs per table to maintain safe distancing between workers.
• Extension and step ladders were safely stowed such that they did not pose a tripping hazard or danger from falling.
• Extension ladders in use were secure, as they were tied off at both top and bottom of ladder.
• CER Inspectors and Indigenous Monitor observed horizontal life lines erected on top of several of the dorm trailers, which TransMountain provided documentation showing the Travel Restraint System unit serial numbers, date system was certified, and next inspection date. High Engineering Ltd. professional engineer had stamped the HLL (horizontal lifeline) systems in May of 2020.
• Portable fire extinguishers of appropriate type were placed near doors and egress ways and affixed tags had up to date inspections and maintenance recorded.
• Emergency equipment, including both eyewash bottles and stations through-out camp dorms and common meeting areas, automated external defibrillator (AED), fire blankets had up to date inspections recorded on affixed tags. One eye wash station was observed in kitchen area to be missing, but was observed to be equipped with an eye wash bottle in a timely manner.
• CER Inspectors and Indigenous Monitor  were provided the Valemount Lodge Housekeeping reference manual for the Valemount Camp, which is a joint venture between Simpcw Resources Group and ATCO which is a procedural based document detailing the requirement for cleaning staff to complete a FLHA, review Safe Work Practices and Procedures for each cleaning task prior to starting work. This manual encompasses work procedures such as, completing a walk down, room cleaning, steps required before entering a room, how to strip a room to ensure effective cleaning of all items in the room: bed, desk, closet, sink and towel rack, walls and baseboards, doors, shower, toilet. bathroom floors, heater/AC unit, etc. 
• CER inspector examined ATCO Emergency Management Drill report that was conducted on July 7th, 2021 at the Valemount Camp, the results of the evacuation exercise were positive, with all personnel in the Camp being accounted for at the South Muster Point in 6 minutes after the evacuation was invoked.
• CER Inspectors and Indigenous Monitor observed cleaning products during inspection and verified that Safety Data Sheets were readily available to staff using those products. Also, no decanting of any products was observed, all cleaning products were in the manufacturer dispensing containers.
• Access/Egress steps to Dorms were equipped with handrails, steps & risers, being constructed of material in good condition.
• Parking area for camp contained within perimeter fencing was well graded and aggregate applied.
• Vehicles were observed by CER inspectors and Indigenous Monitor to be operated in a safe manner during inspection at all sites.
•Mobile equipment observed by CER inspectors and Indigenous Monitor appeared to be in good condition, was parked securely, and operator logbooks was onboard and found to be complete, with signed entries of pre-use checks.
•Mobile equipment checked was equipped with a suitable type ABC fire extinguisher, and spill kit.
• Hazard warning signage was affixed to danger control zone marked with red flagging ribbon that was placed on the outside the excavated area in the parking area to identify and mitigate the hazard.
• Machine guards were in place on rotating equipment (chop saw).
• Industrial shelving storage observed by CER inspectors and Indigenous Monitor was secure to wall, and there was no apparent overloading of shelves.
• Dorm washrooms were functional and sanitary. Four (4) portable toilets on site were operational, clean, and equipped with sanitary hand disinfectant.
• TransMountain employees accompanied the CER inspection team, maintained safe distancing Covid -19 measures and wore either disposable surgical or cotton face masks; these employees provided helpful explanations of camp work processes, and demonstrated competency when queried on matters pertinent to their role. Also, a demonstration was provided to the CER inspectors and Indigenous Monitor for a room in the Dorm, on how performing the cleaning measures that are completed prior to a room being occupied by a worker and when a guest leaves the camp.

• CER inspector examined the Camp Audit conducted on July 9th, 2020 for Food Preparation & Service, Office Front Desk, Housekeeping and Janitorial, Recreation Fitness, Waste Management and Maintenance observed a pass score for all areas audited. Also the Camp Audit conducted on July 12th, 2020, the CER inspector noted that the Occupancy and Fire Permits were in place, and the Food Safety Regulatory Bodies pass score for all regulations were met, as per the Health Inspector on July 12th.
• CER inspector checked with TransMountain representative that Coolers, Freezers, and Dishwashing temperatures are maintained to required operating temperatures and checked twice a day with temperatures, inspector verified the records. CER inspector confirmed that the temperature checks are being done, and the record is kept and posted by the cooling/cleaning kitchen appliances.
 

Compliance tool used: No compliance tool used

Observation 4 - CNC 1 - Vertical Ladders

Date & time of visit: 2020-07-14 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER inspectors observed that vertical ladders accessing the top's of the four (4) fire  water tanks did not have any anti-climb controls to prevent unauthorized or untrained workers from climbing the ladders.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall install an anti-climb barricade to prevent unauthorized/untrained workers from climbing the vertical ladders.

Due date: 2020-07-15

Date closed: 2020-07-15
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 5 - CNC 2 - Propane Vaporizers

Date & time of visit: 2020-07-14 14:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER inspectors observed that two (2) metal structures securing the two propane vaporizers was not grounded to an earth ground.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall bond propane vaporizer metal structures to an earth ground as per section 3.24 Electrical Safety, Grounding Program covering electrical systems and equipment. Company shall bond metal structure supporting Propane Vaporizers to an earth ground.

Due date: 2020-07-15

Date closed: 2020-07-15
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 6 - CNC 3 - Waste Water Tanks

Date & time of visit: 2020-07-14 14:45

Discipline: Safety Management

Categories:

Facility:

Observations:

CER inspectors observed that steel structure supporting the Waste Water tanks did not appear to have an earth ground.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall bond Waste Water Tanks metal structure to an earth ground per 3.24 Electrical Safety Grounding Program covering electrical systems and equipment. 

Due date: 2020-07-15

Date closed: 2020-07-15
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 7 - CNC 4 - Portable Light Plant

Date & time of visit: 2020-07-14 14:50

Discipline: Safety Management

Categories:

Facility:

Observations:

CER inspectors portable light power plant was not grounded to an earth ground.  

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall bond light plant (generator) to an earth ground.

Due date: 2020-07-15

Date closed: 2020-07-15
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

There are no observations with outstanding follow-up

Observation 8 - CNC 6 - Wheel Chocks

Date & time of visit: 2020-07-14 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER inspectors observed wheel chocks missing from portable light power plant.


 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall place wheel chocks on portable light power plant trailer.

Due date: 2020-07-15

Date closed: 2020-07-15
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 9 - Indigenous Monitor Observations

Date & time of visit: 2020-07-15 14:30

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Valemount Camp Inspection
 
Pre-Inspection:
-07/03/2020 Invite received
- 07/06/2020 Confirmation of IM participation
- 07/09/2020 C.E.R Inspection Officers (I.O) IAMC monitors (I.M) Introduction.
- 07/12/2020 Camp Overview map and Trans Mountain document related to their Covid-19 safety plan (dated July 3). As well as existing BC Ministry of Health, Public Health Order applicable to Industrial Camps and Covid-19.
 
Inspection:
07/14/2020

 
Traffic safety

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:

- 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

Observation 10 - 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