Compliance Verification Activity Report: CV1920-190 - Trans Québec and Maritimes Pipeline Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2648

Regulated company: Trans Québec and Maritimes Pipeline Inc.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Quebec

Discipline(s):

• Safety Management

Rationale and scope:

Safety oversight of operations and construction activities at TQM East Herford Compressor Station facility [-Assess compliance with the OPR (Safety Management Program) and CLC requirements. - Hazard and risk identification to prevent incidents - 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:

• None

Facility details

Facilities:

• EAST HEREFORD [PNGTS]

Facility Types

• Pipeline
• Compressor station

Life-cycle Phases

• Construction
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Pipeline Damage Prevention Regulations – Authorizations
• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Operations

Date & time of visit: 2019-06-18 15:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Overhead Cranes
• Conveying Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Permanent Structures
• Housekeeping
• Shelving and General Storage
• Signage
• Lighting
• General Lighting
• Training and Competency
• Training, Competency and Qualification

Facility:

• EAST HEREFORD [PNGTS] (Facility)

Observations:

• The NEB verified that the facility signage contained the appropriate information such as the facility and company name, emergency number, any other required safety information and no trespassing signs.
• The NEB inspected the Meter Run building and reviewed the 2T crane inspection log dated March 2019
• The NEB observed that all of the excess pipe in the yard was placed out of the way of foot and equipment traffic and was labelled with bright paint as "scrap"
• The NEB noted that all bottles of compressed gas were stored in an appropriate manner and labeled 'full' or 'empty'
• The NEB inspected the A1 Compressor building and reviewed the 4T crane inspection log dated May 2019
• The NEB noted that all fire extinguishers, eye wash stations, and first aid kits, where observed, had been inspected as required
• The NEB were told that Safety Data Sheets (SDS) for the hazardous products on site were available online
• The site hazard inventory was shown to be available on line
• The NEB were shown the lock out tag out (LOTO) station, and walked through the LOTO process. NEB inspector reviewed the completed 'Formulaire de plan d'isolement energetique pour le verouillage et l'etiquetage' for work order for the energy isolation tasks were for the installation of "Nouveau unite Solar". Also looked at the 'Formulaire de plan d'isolement energetique pour le verouillage et l'etiquetage' for work order for energy isolation tasks were for the "STN/Compressor A1 isolation pour modifications des conduits pour nouvelles unites solar". The NEB were shown the LOTO on these corresponding sections of pipe in the yard.
• The NEB was shown the online verification of the completed training for the Operations technicians who work at this station in the positions of Control Technicians, Mechanic Technicians, and Electrical Controls Technician.
• The NEB noted that the general housekeeping for the entire site was impeccable during a time of construction activities that touched the site at large
• The NEB were told and shown where the site was delineated by pylons to mark the hot and cold zones and the requirements for hot work permits to be in place. The NEB spoke with the construction team who were aware of the different zones and requirements to obtain permits from the station operations staff.
• The NEB observed that there appeared to be good communication flow and information sharing between the operations staff and those undertaking the construction. The NEB were further told that both groups have been working collaboratively to ensure the job is completed appropriately.  Morning meetings are held each day with all operations and construction staff in attendance.
• The NEB observed that the electrical room doors were labelled with warning signs; all electrical panels were secured and labeled appropriately; and all battery banks had a protective shield in place
• The NEB were told that due to the station location and its proximity to the CA/US border, there is a memorandum of understanding in place with the fire station on the US side of the border to act as their first responders in case of medical emergency
• The NEB observed that the operations spill kits were positioned throughout the site in yellow containers.

Compliance tool used: No compliance tool used

Observation 2 - Construction

Date & time of visit: 2019-06-19 08:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Limits of Exposure
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Temporary Structures
• Scaffolding and Temporary Ladders
• Signage

Facility:

• EAST HEREFORD [PNGTS] (Facility)

Observations:

• The NEB were given a construction site specific safety briefing by MACO
• The NEB reviewed the French site specific safety plan(SSSP) submitted to the NEB and skimmed the revised SSSP in English on site. The SSSP has been stamped that it was reviewed and accepted by TransCanada on 5/22/2019
• MACO is the contractor responsible for the construction work at the station. The NEB were told and observed:
  • MACO does an overarching daily FLHA (AST in French) with the entire construction crew each morning. Each job task is then required to fill out a more detailed daily FLHA (AST in French). For example the fire watch at the welding tent had a separate AST for fire watch and the welding crew had one for welding. The NEB observed that the daily AST and the task specific ASTs for each activity on the site were located in plastic tubes at each specific location where there was a different activity happening.
  • MACO holds a daily brief with all construction personnel each morning before work commences and a separate safety meeting each Wednesday afternoon. The NEB participated in the Wednesday safety meeting.
  • All MACO construction spill kits are in blue barrels throughout the site
  • Construction fire extinguishers fixed to the perimeter fencing through the job site
  • MACO has placed orange anti-impalement caps on any fence post or protruding metal rebar observed throughout the construction site where an individual could be harmed
  • The NEB observed all areas of open excavation to have snow fencing and specialty doors with the word danger at the entry point
  • The NEB noted that all active work areas where electrical work was being done was taped off with red danger tape and multiple information labels were stuck on the tape and contained the hazard, the date range, and the responsible contact person
  • The NEB observed that the crew had different color hard hats to make them distinguishable
  • The NEB observed that the erected scaffolding had been inspected daily by the foreman at that location. The NEB were told that the foreman and the welder working on the scaffolding were trained and had tickets with respect to scaffolding
  • The NEB looked at the third party crane log #80551 June 2019 for the 50-33 L Grave J6t3-6351
  • The NEB were told and observed that each time a piece of equipment was moved, a single spotter wearing a yellow high-visibility vest was directing the operator. The crane operator told the NEB that they communicate using industry recognized hand signals. The NEB observed this happening when a section of pipe was being lifted and seated, and again when a generator was being relocated.
  • The NEB were told that the maximum weight for manual lifting was 50lbs. The NEB observed crew members assisting each other when transferring bags of stone dust as well as large nuts.
• The NEB were shown some of the Info Excavation tickets for the constructions activity - 2018391483, 2018391454, 2018391458
• The NEB reviewed the 'General Work Permit' dated 2019/5/13 to 2019/08/10 related to the project work #M.000673 East Hereford Project - Station 654

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: