Compliance Verification Activity Report: CV1920-175 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-175
Start date: 2019-12-03
End date: 2019-12-06

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Spread 1 - TMX Project. Safety oversight of construction activities - worker safety [- Assess compliance with the OPR (Safety Management Program), CLC requirements and construction safety manuals/project specific safety plans. - Contractor oversight, pipe handling, and hoisting and rigging

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Cleaning Stations

Date & time of visit: 2019-12-05 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Two cleaning stations were observed close to KP36.3 and KP46.6 which included a bay for rough cleaning, a catch basin that is emptied nightly that has double containment, electric chisels, and air compressor with a wand for the purpose of equipment cleaning. During the inspection, the cleaning stations were active, as soil stripping activities were ongoing on the RoW.  At the cleaning station close to KP46.6 the CER observed staff not wearing their face shield as intended during the pressure washing. CER and Indigenous Monitors were told that double protection was required to be worn during washing activities. This requirement was also written on the FLHA signed by workers and visitors. Due to issues with the face shield fogging up, the Forman was addressing the issue by replacing the plastic face shields with mesh face shields. 

 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the workers with mesh face shields.

Due date: 2019-12-05

Date closed: 2019-12-05
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

Observation 2 - General Safety- Spread 1

Date & time of visit: 2019-12-05 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Throughout its Spread 1 inspection CER observed repeated demonstration of a Safety Culture as defined by the CER in its National Energy Board report on Advancing Safety in the Oil and Gas Industry - Statement on Safety Culture. Example of such demonstration were:

Compliance tool used: No compliance tool used

Observation 3 - Pipe Yard Loading of truck and Stringing

Date & time of visit: 2019-12-05 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Pipe yard:

Stringing near KP46:

Compliance tool used: No compliance tool used

Observation 4 - Bending

Date & time of visit: 2019-12-04 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 5 - Overhead Powerlines

Date & time of visit: 2019-12-05 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspectors and Indigenous Monitors observed the following:

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

Regulatory requirement:

Relevant section(s):

Company action required:

Due date: 2020-01-17

Date closed: 2020-01-20
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 - Hand-Arm Vibration

Date & time of visit: 2019-12-05 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER observed crews at the cleaning stations use electric chisels and pressure washing equipment to clean the heavy equipment. The CER were told that gloves designed for vibration were available for those who choose to wear them, however, it was at the workers discretion. SAEG advised that it would conduct an assessment to determine if additional controls need to be put in place to ensure the health and safety of the workers.  

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Conduct an assessment to determine if additional controls need to be put in place to ensure the health and safety of the workers.  

Due date: 2020-02-28

Date closed: 2020-02-27
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 7 - Spread 1 of the Trans Mountain Expansion Project (TEMP) - IAMC General Observations

Date & time of visit: 2019-12-05 16:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Opening Meeting at Best Western Hotel, Sherwood Park.

Right of Way Inspection

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