Compliance verification activity type: Field Inspection
Team:
Regulated company: TransCanada PipeLines Limited
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Safety oversight of operations activities on TCPL Mainline - worker safety [-Assess compliance with the OPR (Safety Management Program) and CLC requirements. - Contractor oversight - Arc Flash - IOGP Life Saving Rules (Bypassing Safety Controls, Confined Space, Driving, Energy Isolation, Hot Work, Line of Fire, Safe Mechanical Lifting, Work Authorization and Working at Heights)]
Compliance tool(s) used:
Facilities:
Facility Types
Regulatory requirements that apply to this activity:
Observation 1 - General Observations
Date & time of visit: 2019-11-26 10:00
Discipline: Safety Management
Categories:
Facility:
Observations:
Compliance tool used: No compliance tool used
There are no observations with outstanding follow-up
Observation 2 - IR#2: lack of means to identify wind direction
Date & time of visit: 2019-12-26 15:45
It is noted the SDS sheet for Natural Gas (Sweet) instructs workers to stay upwind during an accidental release of natural gas. None of the compressor stations visited during this inspection have a means to easily identify wind direction. The company shall provide evidence that the lack of windsocks or other means to identify wind direction does not pose an unreasonable risk to people working within the station and how the requirement of clause 10.2.9.4 of CSA Z662-19 is met.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
The company shall provide evidence that the lack of windsocks or other means to identify wind direction does not pose an unreasonable risk to people working within the station and how the requirement of clause 10.2.9.4 of CSA Z662-19 is met.
Due date: 2020-01-17
Date closed: 2020-01-17 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
Observation 3 - IR#3: arc flash risk assessments
Date & time of visit: 2019-11-28 15:45
IR#3: Provide evidence that arc flash risk assessments have been completed in accordance with CSA Z462 clause 4.3.5 and in accordance with the company's internal procedures.
Provide evidence that arc flash risk assessments have been completed in accordance with CSA Z462 clause 4.3.5 and in accordance with the company's internal procedures.
Due date: 2020-01-31
Date closed: 2020-05-13 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.
Observation 4 - IR#5: Pipe Exposure threat Assessment
Discipline: Damage Prevention
CER inspectors were told that TC Energy had recently conducted a 'Pipe Exposure threat Assessment'. Please provide the results of the assessment for review in lieu of conducting field locates during the inspection.
Please provide the results of the 'pipe exposure threat assessment' for review.
Date closed: 2020-01-24 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.
Observation 5 - IR#7: LOTO TOP and forms
Date & time of visit: 2019-11-27 15:00
The CER inspectors were told that the LOTO TOP and accompanying LOTO Energy Isolation Plan Form were currently being revised from their 2016 versions. Given the nature of the Identification AVC, please provide the proposed revisions to the LOTO TOP and accompanying forms currently under review.
Observation 6 - NNC#1: Crane inspection
At CS86 and CS95 CER inspectors noted that inspection reports of critical equipment (cranes) are not being reviewed and corrected. At CS86, a July 2019 crane inspection report had findings and actions identified as an 'undetermined condition' that remained unresolved. At CS95, a July 2019 crane inspection report had findings and actions identified as a 'Safety Risk' that remained unresolved. During the inspection, TC Energy locked out the crane until its status could be verified.
Compliance tool used: Notice of Non-compliance (NNC)
CER has requested that TC Energy immediately communicate this hazard to all potentially impacted personnel no later than the close of business 29 November 2019; provide interim measures to control the hazard by 6 December 2019, and to provide a long-term solution to mitigate this hazard exposure relevant to all similar Canadian facility locations within 90 days.
Due date: 2020-02-28
Observation 7 - IR#8: LOTO incident or near miss
During the inspection at Station 86, TC Energy electrical staff told the CER that the wrong equipment had been isolated during an incident. Please provide the specific details of this event.
Date closed: 2020-01-09 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.
Observation 8 - TH-001-2019 amended 1a
Date & time of visit: 2020-02-27 08:00
IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.
Compliance tool used: Inspection Officer Order (IOO)
Due date: 2020-04-17
Observation 9 - TH-001-2019 amended 1b part 1
Due date: 2020-12-31
Date closed: 2021-01-15 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.
Observation 10 - TH-001-2019 amended 1b part 2
Due date: 2022-03-31
Date closed: 2022-04-07 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.
Observation 11 - TH-001-2019 amended 2
2. Until such time as safe working conditions are restored at facilities where naming and tagging inconsistencies may be present, ensure that all those required to conduct LOTO activities are informed of potential hazards due to the inconsistencies and any additional measures determined appropriate to address those hazards. TC Energy shall provide the CER with its measures to address this requirement no later than 31 March 2020;
Due date: 2020-03-31
Date closed: 2020-05-14 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.
Observation 12 - TH-001-2019 amended 3 part 1
3. The following actions shall also be taken:
Observation 13 - TH-001-2019 amended 3 part 2
3 The following actions shall also be taken:
Due date: 2020-06-30
Date closed: 2020-07-14 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.
Observation 14 - TH-001-2019 amended 4
4. Conduct a root cause investigation to identify immediate/direct and basic/root causes and proposed corrective and preventive actions no later than 30 June 2020;
Date closed: 2020-07-03 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.
Observation 15 - TH-001-2019 amended 5
5. Develop a detailed Corrective and Preventive Action Plan (CAPA) to address the root cause investigation findings; the CAPA plan must include implementation dates for each planned corrective and preventive action no later than 30 September 2020.
Due date: 2020-09-30
Date closed: 2020-10-30 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.
Observation 16 - TH-001-2019 amended result of 4 and 5
TC Energy shall provide the CER with the results of ‘Preventive Actions’ 4 and 5 no later than 30 September 2020.
Observation 17 - TH-001-2019 amended Quarterly reports until 31 Dec 2021
TC Energy shall provide the CER with quarterly progress reports commencing 31 March 2020 that address each of the actions required in this order. The quarterly progress reports shall continue until such time as all activities generated from the order have been completed.
Date closed: 2022-04-08 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.
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 18 - 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
Observation 19 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 20 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 21 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 22 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 23 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 24 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 25 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 26 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
Observation 27 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail
