Compliance Verification Activity Report: CV2021-523 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-523
Start date: 2021-03-30
End date: 2021-03-30

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: NOVA Gas Transmission Ltd.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

NGTL 2021 - Edson ML Loop #4 (Nordegg Compressor Station unit Addition and Brewster Section). Safety inspection of construction practices including but not limited to: field implementation of construction safety manual and project specific safety plans for ongoing construction activities and worker tasks including identification of potential hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight of contractors - 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 Observations: Nordegg Compressor Station Unit Addition

Date & time of visit: 2021-03-30 17:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Opening Meeting

  • IO’s signed in and out of the site via QR code which was explained to be an effective COVID-19 control. Electronic collection of name, contact information and COVID-19 symptom declaration. The contactless method allowed site management immediate access to a roster for all workers and visitors on site, including arrival and departure times. System applications include contact tracing and emergency head counts. 
  • Inspection Officers were provided with a COVID-19 orientations, site orientation and daily Field Level Hazard Assessment from Strike Safety Specialist/Assistant Construction Manager. 
  • Company representatives described an active hazard and incident reporting system that included positive safety observations, hazard and incident and near miss reporting.  
  • Project has a medical service provider on site as a dedicated resource supporting the COVID-19 – Emergency Response Pandemic Plan. 
  • Regarding camp operation and care for mental health of workers TC management described the weekly purchase of MMA events as an example of the company supporting worker down time and interests. 
  • TC Energy representatives consist of 4-5 employees on site at most times with up to 10 present during 3-4 day cross over between shifts. Length of cross over described to facilitate communication and awareness of site status and situation. 
  • The site is busy and congested. When asked about coordination amongst contractors, company representatives described a daily coordination meeting facilitated by Strike and including all contractors. TC management conduct another coordination meeting at 3pm daily. 
  • Criteria for determination of what constitutes a complex lift was discussed. It was observed that non-complex lifts do not require a lift plan and that a Strike representative had developed an ad hoc form which is completed for lifts in excess of 1000lbs. (See IR 1) 

Document review included: 

  • Review of Strike observation cards. Dozens of examples were provided. Cards are received by TC energy and reviewed for quality. Top quality cards are entered into a draw which is meant to promote program participation and quality submissions at the same time. 
  • A review of the documentation package for a complex lift occurred; included in the comprehensive package was daily rigging inspection, lift plan, daily tailgate, safe work permit, hazard identification assessment and control form and crane permit to practice drawings. 

Field Inspection: 

  • Signage and barricades were appropriately placed and laydown and staging areas were very well organized. 
  • Positive air shut off test stickers were observed on several pieces of equipment near the brown field excavation. The test dates were all observed to have occurred in the current month. 
  • Practice of spotters being used while vehicles were in use was observed on several instances. 
  • Lifting, hoisting and winching equipment was demonstrated to be part of well implemented inspection prorgram. All equipment observed was confirmed to be inspected in December of 2020.
  • A complex lift was observed. The lift had been delayed on consecutive days due to high winds. CER inspectors observed the pre-lift meeting and noted the contigency plan to abort the lift if winds became a factor. Winds did become a factor in the execution of a safe lift aand the lift was aborted as per the contingency plan discussed.

Compliance tool used: No compliance tool used

Observation 2 - General Observations 2

Date & time of visit: 2021-03-30 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations 2

Compliance tool used: No compliance tool used

Observation 3 - IR 1: Clarity on Lift Planning Requirements

Discipline: Safety Management

Categories:

Facility:

Observations:

Inspection officer inquired into why only critical lifts required a lift plan. Reply included the description of an ad hoc form that was being used for non-critical lifts over 1000lbs. 

Requirement: TC Energy Hoisting, Lifting, Towing and Winching Procedure - If the lift is deemed critical, the completion of the Critical Pre Lift-Check Sheet is a mandatory requirement. The Job safety analysis procedure process must be completed for all critical lifts.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

IR 1 request:  

  • Please confirm that the Strike lifting practice is meeting or exceeding the TC Energy Hoisting, Lifting, Towing and Winching Procedure. Comment specifically on the requirements included in the Strike Lift Plan document and those required in the TC procedure for critical lifts. 
     

  • Provide a copy of and comment on the appropriateness of the use of the ad hoc form being utilized by Strike for non-critical lifts over 1000lbs. Consider in your response consistent implementation of the document and document control. 

Due date: 2021-04-23

Date closed: 2021-05-03
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 4 - IM Observation

Date & time of visit: 2021-03-30 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Additional Observation recorded by Indigenous Monitors participating in the CER Inspection. Any compliance related observations that require specific regulatory follow-up have been recorded above.

Observations:

Nordegg Compressor Station Construction Site
  • Upon arrival at the site, attended the orientation/safety meeting conducted by TC Energy and Strike (Contractor)
  • Drip trays in place under all equipment observed
  • Scaffolding around construction was found to be inspected, signed off and tagged
  • Crane required to lift roof unit module in place was on site
  • Used oil / contaminated container storage was labelled correctly with secondary containment in place
  • Security in place around roof unit module lift and crane
  • Roof unit module lift cancelled during the inspection due to windy conditions
 Brewster Pipeline Tie-in Site
  • attended orientation and Covid declaration meeting
  • Security with signage in place

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