Compliance Verification Activity Report: CV1920-213 - TransCanada PipeLines Limited

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-213
Start date: 2019-11-25
End date: 2019-11-29

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:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

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

Discipline: Safety Management

Categories:

Facility:

Observations:

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

Discipline: Safety Management

Categories:

Facility:

Observations:

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.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

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.

Reason closed: Requirement met

Compliance achieved: Yes

There are no observations with outstanding follow-up

Observation 4 - IR#5: Pipe Exposure threat Assessment

Date & time of visit: 2019-11-28 15:45

Discipline: Damage Prevention

Categories:

Facility:

Observations:

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.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide the results of the 'pipe exposure threat assessment' for review.

Due date: 2020-01-17

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.

Reason closed: Requirement met

Compliance achieved: Yes

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

Observation 5 - IR#7: LOTO TOP and forms

Date & time of visit: 2019-11-27 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

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. 

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

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. 

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 6 - NNC#1: Crane inspection

Date & time of visit: 2019-11-27 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

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)

Regulatory requirement:

Relevant section(s):

Company action required:

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

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 7 - IR#8: LOTO incident or near miss

Date & time of visit: 2019-11-27 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

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.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

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.

Due date: 2020-01-31

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 8 - TH-001-2019 amended 1a

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Based on the corrective action plan (CAP) provided to the CER, TC Energy is to identify where all naming and tagging inconsistencies that could impact LOTO exist and correct the deficiencies:
    1. Ensure that the relabeling of equipment, review and redlining of associated drawings, and initiation of any changes required to the SCADA systems as a result of the historic tie-over and crossover valve project is completed at all of the TC Energy owned or operated federally regulated facilities in Canada no later than 31 March 2020 and provide the CER with verification and evidence no later than 17 April 2020;

Due date: 2020-04-17

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 9 - TH-001-2019 amended 1b part 1

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Based on the corrective action plan (CAP) provided to the CER, TC Energy is to identify where all naming and tagging inconsistencies that could impact LOTO exist and correct the deficiencies:
    • Provide the CER with verification and evidence that any other labelling inconsistencies at all of the TC Energy owned or operated federally regulated facilities in Canada have been identified no later than 31 December 2020 

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.

Reason closed: Requirement met

Compliance achieved: Yes

There are no observations with outstanding follow-up

Observation 10 - TH-001-2019 amended 2

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 11 - TH-001-2019 amended 3 part 1

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

3. The following actions shall also be taken:

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 12 - TH-001-2019 amended 3 part 2

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 13 - TH-001-2019 amended 4

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

 
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;

Due date: 2020-06-30

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 14 - TH-001-2019 amended 5

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 15 - TH-001-2019 amended result of 4 and 5

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

TC Energy shall provide the CER with the results of ‘Preventive Actions’ 4 and 5 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.

Reason closed: Requirement met

Compliance achieved: Yes

There are no observations with outstanding follow-up

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 16 - 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 17 - 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 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

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 20 - 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 21 - 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 22 - 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 23 - 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 24 - 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 25 - 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 26 - TH-001-2019 amended 1b part 2

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility: STN 75 - NIPIGON [LINE 100-1] - Facility

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

  1. Based on the corrective action plan (CAP) provided to the CER, TC Energy is to identify where all naming and tagging inconsistencies that could impact LOTO exist and correct the deficiencies:
    • Provide the CER with verification and evidence that any other labelling inconsistencies at all of the TC Energy owned or operated federally regulated facilities in Canada have been identified no later than 31 December 2020 and relabeling of equipment, back drafting of drawings and any changes that may be required to the SCADA systems be corrected no later than 31 Dec 2021. 

Due date: 2021-12-31

Observation 27 - TH-001-2019 amended Quarterly reports until 31 Dec 2021

Date & time of visit: 2020-02-27 08:00

Discipline: Safety Management

Categories:

Facility: STN 75 - NIPIGON [LINE 100-1] - Facility

Observations:

IOO was issued to resolve the systemic issue. See IOO-TH-2019- Amended on file.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

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.

 

Due date: 2020-12-31