Compliance Verification Activity Report: CV1819-307 - Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1819-307
Start date: 2019-03-18
End date: 2019-03-21

Team:

Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Operating company: Westcoast Energy Inc. carrying on business as Spectra Energy Transmission

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

To assess compliance with the Onshore Pipeline Regulations (OPR), including company-specific program requirements and corrective action plans (CAP) implementation for previous identified non-compliance. Inspection of facilities: Aitken Creek processing facility, Sunset Creek compressor station 16, Nig Creek booster station 9, Beg Jedney booster station 18 and Cypress compressor station N4. Focus on management of change with respect to new policies following Enbridge merger.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Compliance and Safety General Observations

Date & time of visit: 2019-03-20 16:30

Discipline: Safety Management

Categories:

Facility:

Observations:

General observations for sites visited:
• Company representatives delivered a site specific orientation to NEB staff at all sites, which included a description of emergency procedures, alarm types and muster areas.
• Perimeter fencing appeared to be maintained in good condition with proper signage, including company and emergency contact numbers and warning signs to deter intrusion.
• NEB inspectors observed that personnel wore required Personal Protective Equipment (PPE).
• NEB inspectors observed specialized electrical PPE (gloves, clothing) for working on electrical systems where arc flash and shock hazards are present, stored in protective canvas bags that reside in either metal cabinets, lockers, or on a shelf.
• 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 oily rags in oily rag bins; and bins not over-filled.
• Flammable storage cabinets were manufactured cabinets equipped with bungs and were properly bunged. 
• Battery rooms were inspected by NEB inspectors and found to be neat and tidy, ventilated, and with all Uninterrupted Power Supply (UPS) panel screws in place and securely fastened.
• Propane gas tanks were located outside in secure rack and compressed gas cylinders stored upright with caps on and chained or strapped to permanent structure wall bracket or railing.
• Extension and step ladders were safely stowed such that they did not pose a tripping hazard or danger from falling.
• 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 eyewash, automated external defibrillator (AED), fire blankets and self-contained breathing apparatus (SCBA) had up to date inspections recorded on affixed tags.
• Emergency Showers observed by NEB inspectors were equipped with activation alarms that alarm at main control desk.
• Walkways were cleared of snow and slip resistant by design or by adding aggregate, and with secure handrails and guardrails.
• Driveways and parking areas were graded and aggregate applied.
• Company representatives informed NEB inspectors that the company specific requirement for a positive air shut off (PASO) on diesel engines entering a facility was still in place and prior-entry checking of each such vehicle PASO was being performed.
• Critical infrastructure was protected by placing of concrete barriers to mitigate potential of equipment/vehicle unintentional contact with site infrastructure, and company representatives stated that spotters are used in accordance with the company's spotter program.
• Pipe assemblies were marked by labeling to identify product and direction of flow.
• Metal pails and buckets that had been placed in hazardous areas, were observed by NEB inspectors to be grounded or bonded to a steel structure. 
• NEB inspectors observed secondary spill containment and adequate spill containment kits in place to deal with a spill at loading docks and other areas throughout the facility where a potential for a spill had been determined by the company.
• Permanent vertical ladders observed were secure, with protective railing and swing gate at top on active plant facilities. One vertical ladder was "tagged out of service" at Nig Booster Station due to assembly mounting bracket changes being required for vertical life line installation.
• Overhead cranes observed were with proper current maintenance and pre-use records indicating they were safe to operate.
• Lock Out Tag Out (LOTO) in control rooms and processing areas was competently explained by employees and was in accordance with the LOTO process.
• NEB inspectors observed that fall protection equipment (harnesses, lanyards) appeared to be in good condition, were stored in a dry area (locker), and were with completed inspection documentation and legible tags. 
• Vehicles were observed by NEB staff to be operated in a safe manner during inspection at all sites.
• Mobile equipment observed by NEB inspectors appeared to be in good condition, and parked securely,
• Mobile equipment had operator logbooks onboard which inspectors examined and found to be complete, with signed entries of pre-use checks.
• Mobile equipment checked was equipped with a suitable type ABC fire extinguisher, spill kit, and back-up camera.
• Windsocks were strategically placed for visibility throughout the facilities.
• Hazard warning signage was affixed on building entry doors and first aid signs at stations.
• Machine guards were in place on rotating equipment (Drills, Equipment and Grinders) and equipment was securely attached to prevent it from falling.
• Administrative controls identifying eye protection must be worn were conspicuously posted adjacent to rotating equipment and a protective face visor was readily accessible.
• Industrial shelving storage observed by NEB inspectors was shelf load rated, secured to wall structure, or secured by anchoring to concrete floor, and there was no apparent overloading of shelves.
• Containers of hazardous substances were labeled, including drums, pails and jugs.
• Compressed air hoses were equipped with whip checks.
• Washrooms were functional and sanitary.
• Secondary containment for hazardous materials appeared to be appropriate.
• Employees, including occupational health and safety work place committee representatives, participated in inspections.
• Employees accompanied the NEB inspection team, providing helpful explanations of work processes, and demonstrated competency when queried on matters pertinent to their role.


Management of Change:
• NEB inspectors were provided an explanation of the company's Management of Change (MOC) process, as well as the Procedure Management of Change (PMOC) process. The company representatives explained that the MOC was applied to process changes related to material and physical components (operational functions) and the PMOC was applied to safe work procedures.
• The company’s Manager of Gathering for the area provided NEB inspectors with an overview on how the PMOC process works and showed inspectors how this is accessed on its SharePoint site where this process and related documents reside. The company representative also demonstrated how the MOC or PMOC communication system process works for sharing of information throughout the management system to all parties involved in a management of change process or procedure, and through to the implementation stage.
• NEB inspectors also observed the PMOC Permitting Process for Contractor Damage Prevention on the company’s SharePoint site, and a company representative demonstrated how the PMOC stages are navigated while answering all of the NEB inspectors’ questions about this process.
• The company’s Supervisor, Safety, Gas Transmission Canada, provided the NEB inspector an overview on the six stages to the PMOC process, discussing the PMOC by way of examples of a particular Health and Safety manual and replacement of one of the standards used in the safety program. The PMOC process at the implementation stage engaged the Occupational Health, Safety & Environment (OHSE) Committees in the process, such that there is a continuous feedback loop involving the OHSE workplace committees.




     

Compliance tool used: No compliance tool used

Observation 2 - Cypress N4 Compressor Station

Date & time of visit: 2019-03-19 13:25

Discipline: Safety Management

Categories:

Facility:

Observations:

• Company representatives confirmed a working alone policy and process is in place for the facility, which is manned 24/7. Company representatives also confirmed that the site has 24/7 communication with Gas Control.
• NEB inspectors observed bonding cables in electrical room for Building #10 not securely fastened to electrical ground bar per CSA electrical standard Z462-08.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company is to demonstrate it is in compliance with the Z462-18 standard with respect to bonding cables to ground bar and the remaining bonding cables in terms of adequate tightness.
 

Due date: 2019-03-19

Date closed: 2019-03-19
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 - Beg Jedney Booster Station 18

Date & time of visit: 2019-03-19 14:20

Discipline: Safety Management

Categories:

Facility:

Observations:

NEB Inspectors observed the Inlet Separator (scrubber) building was missing a "Hearing Protection Required" sign on exterior side of entrance door. Company staff confirmed it had recently been removed as the company was in the process of removing redundent signage.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company is to demonstrate it is in compliance with NEB OPR 6 (a) with respect to hearing protection signage on exterior side of inlet separator (scrubber) building access doors.

Due date: 2019-03-19

Date closed: 2019-03-19
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 - Aitken Creek Processing Plant

Date & time of visit: 2019-03-20 12:45

Discipline: Safety Management

Categories:

Facility:

Observations:

• An emergency medical resource, with Level 3 credentials was observed working out of a Mobile Treatment Centre vehicle on site, as appropriate for the number of workers observed on site, and in accordance with the number provided by company representatives .

• NEB inspection officers observed that 1000 gallon propane tank and a steel loading dock that were were not bonded to an earth ground per CSA electrical standard Z462-08.

 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

 Company shall submit photographs illustrating corrective measures were completed to achieve compliance. 

Due date: 2019-03-22

Date closed: 2019-03-22
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 - Nig Creek Booster Station

Date & time of visit: 2019-03-20 10:30

Discipline: Safety Management

Categories:

Facility:

Observations:

NEB inspectors observed a vertical ladder that did not have a gate at the top of the platform.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Company action required:

Spectra Energy Transmission West (SETW), Fall Protection Standard - Issue August 2015 is to ensure safety of workers during tasks that have a potential risk for falls to lower levels. Company shall submit photograph illustrating corrective measures to achieve compliance were taken.

Due date: 2019-03-21

Date closed: 2019-03-21
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 - Sunset Creek - Compressor Station 16

Date & time of visit: 2019-03-21 10:45

Discipline: Safety Management

Categories:

Facility:

Observations:

CS 16 - Sunset Creek
• NEB inspectors observed two flammable storage cabinets that had been modified to enable bonding to a metal structure grounding point in work shop building to mitigate a potential electrical static hazard.
• NEB inspectors confirmed with company operators that Naturally Occurring Radioactive Materials (NORM) testing is being performed prior to work taking place in areas where NORMs may be present and that the testing is being recorded and logged. Also, the site specific external assessment for NORMs was observed and is readily accessible electronically.     

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