Compliance Verification Activity Report: CV1920-126 - New Brunswick Power Transmission Corporation

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2773
• Inspector 2648

Regulated company: New Brunswick Power Transmission Corporation

Operating company: New Brunswick Power Corporation

Province(s) / Territory(s):

• New Brunswick

Discipline(s):

• Safety Management

Related events:

• CV1920-125

Rationale and scope:

Verify compliance with NEB requirements for International Power Lines, including compliance to construction safety manual submitted under Condition 11 of Order EP-304. Focus areas to include contractor oversight.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (2)
• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

Facility Types

• International Power Line (IPL)
• Conductors and shields
• Dampers and spacers
• Grounding
• Guy wires
• Insulators
• Poles and towers
• Right of way

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Contractor/Project Safety Plan (CSP)
• SunnyCorner Corporate HSE manual SCI-M-001Rev. 00 2018
• Project-specific plan or procedure
• Locke's Electrical Limited, Safety Manual March 01, 2019
• Standard Operating Procedure or Plan (SOP)
• NB Power Corporate Safety Manual (A98714)
• Standard Operating Procedure or Plan (SOP)
• The International Power Line Project Operations and Maintenance Manual, Woodstock to Houlton, Maine August 2019

Regulatory instrument number(s):

• EP-304

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2019-08-21 17:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Signage
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• General Lighting
• Noise Control
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

Observations:

General Observations:
L0155 & L0163 Line Work, Houlton Staging Area & Substation, and Woodstock Terminal:

• Safety meeting minutes were reviewed by NEB inspectors and content discussed with Company representatives.
• Company representatives were able to demonstrate that employee and management personnel are engaged in the meetings and that safety issues are being discussed and resolution (including identification of responsible parties and timelines) are being managed.
• Company provided an overview of the program used to manage all site tasks (e.g.. inspections, maintenance activities) and ensure that they are completed as required.  A representative sample of these activities were discussed and supporting documentation to demonstrate completion was also reviewed.
• The inspection group reviewed the applicable tailboard document (outlining the identified hazards and controls) prior to proceeding to the substation, terminal and line work sites.
• NEB inspectors observed the contents of one of three sea cans stored on site, which contained orderly inventory of spare parts and pole number signs.
• NEB inspectors observed New Brunswick Power crew installing structures (poles and associated hardware) and equipment for Line 0155 & Line 0163.
• A sampling of training records for crew members involved in structure installation activities (such as Fall Protection Training and High Angle Rescue) were reviewed and verified to be current.
• NEB inspectors reviewed selected sample of completed equipment inspections prior to use on right of way.
• NEB inspectors verified that equipment had inspection stickers to indicate completed inspections.
• NEB inspectors observed that First Aid boxes were in place at the Terminal and Substation offices and appeared to be fully equipped.
• Fire extinguishers observed on site had up-to-date monthly inspection and annual certification tags attached.
• Automated External Defibrillators (AED's) were observed to be located and accessible at all work areas inspected. 
• Office trailer and washroom trailers were present, accessible, sanitary, and well equipped.
• Wooden poles were stored and piled neatly away from traffic areas, on the northern side of the staging area.
• NEB inspectors observed that spill kits were readily accessible at all work sites visited .
• Overall orderly housekeeping was observed at staging area, terminal, substation and on the right of way.
• Elevated work platforms were noted to include railings, toe boards, and swing gates as appropriate.
• Site was noted to be well maintained with no housekeeping concerns observed.
• The company representatives were able to demonstrate an example of making design improvements during planning phase (i.e.. permanent ladder for accessing transformer is designed for easy authorized access by workers but also equipped with anti-climb hardware to prevent unauthorized access).
• Company representatives also identified a potential hazard at the Houlton Substation that they determined to not have been adequately addressed in the original design and were making changes at location to mitigate the potential tripping hazard at the transformer (particularly when accessing the panel door). 
• Site signage was observed as adequate where noted.
• Ladders were noted to be properly stored and secured.
• NEB inspectors observed compressed gas cylinders labeled, secured and stored upright.
• Slings were noted to be in good repair and had labeling present.
• A chop saw and grinder were observed with guards intact at substation site during company inspection.
   

Compliance tool used: No compliance tool used

Observation 2 - CNC #1 - Replace Grounding Belt at Terminal main gate

Date & time of visit: 2019-08-20 14:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Electrical Safety

Facility:

Observations:

Gates along the facility fencing were observed to be functional and grounded, with exception to the main Terminal gate where a worn, frayed grounding belt was observed at the main gate fencing of the Woodstock Terminal.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• EP-304

Relevant section(s):

• Condition #5 of Permit EP-304 states: NB Power must cause the Project to be designed, manufactured, located, constructed, installed, and operated in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related submissions. The NB Power Corporate Safety Manual, as submitted in relation to the approved project, includes the following text: DUTIES The New Brunswick Occupational Health and Safety Act mandates specific duties for various groups and individuals involved in the New Brunswick workplace. Specifically these duties are summarized as follows: EMPLOYER Every employer shall e) ensure that at the place of employment the necessary systems of work, tools, equipment, machines, devices and materials are maintained in good condition and are of minimum risk to health and safety when used as directed by the supplier or in accordance with the directions supplied by the supplier

Company action required:

Company shall replace the grounding belt.

Due date: 2019-08-22

Date closed: 2019-08-22
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 3 - CNC #2 Standing on Mid-Rail of Elevated Work Platform

Date & time of visit: 2019-08-20 13:30

Discipline: Safety Management

Categories:

• Materials Handling
• Mobile Cranes and Hoisting Equipment

Facility:

Observations:

An NB Power employee was observed working from height on a JLG boom lift.  The employee stepped up onto the mid rail of the work platform in order to complete his task.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• EP-304

Relevant section(s):

• Permit EP-304, Condition #5 states that NB Power must cause the Project to be designed, manufactured, located, constructed, installed, and operated in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related Submissions. The NB Power Corporate Safety Manual, as submitted in relation to the approved project, includes the following text: 1.1 GENERAL RULE When risks arising out of, or in connection with the work assigned, are not identified in existing corporate safety rules, NB Power employees and contractors shall refer and adhere to existing Standard Work Methods, Standard Construction Practices, Standard Operating Practices, In-Plant Procedures, General Rules and Operating Regulations, Regulation 91-191 under the New Brunswick Occupational Health and Safety Act, the Occupational Health and Safety Act (Chapter O-0.2) and any other legislation that may apply. Applicable New Brunswick Occupational Health and Safety Act and Regulation 91-191 include: ACT - OCCUPATIONAL HEALTH AND SAFETY ACT (S.N.B. 1983, c. O-0.2) Section 9 Duties of an Employer (1)Every employer shall (a) take every reasonable precaution to ensure the health and safety of his employees; (b) comply with this Act, the regulations and any order made in accordance with this Act or the regulations; and (c) ensure that his employees comply with this Act, the regulations and any order made in accordance with this Act or the regulations. 9(2)Without limiting the generality of the duties under subsection (1), every employer shall (a) ensure that the necessary systems of work, tools, equipment, machines, devices and materials are maintained in good condition and are of minimum risk to health and safety when used as directed by the supplier or in accordance with the directions supplied by the supplier; (b) acquaint an employee with any hazard in connection with the use, handling, storage, disposal and transport of any tool, equipment, machine, device or biological, chemical or physical agent; (c) provide the information that is necessary to ensure an employee’s health and safety; (c.1) provide the instruction that is necessary to ensure an employee’s health and safety; (c.2) provide the training that is necessary to ensure an employee’s health and safety; (c.3) provide the supervision that is necessary to ensure an employee’s health and safety REGULATION - NEW BRUNSWICK REGULATION 91-191 under the OCCUPATIONAL HEALTH AND SAFETY ACT (O.C. 91-1035) Part IX Tools, Section 81 General Duties of an Employer An employer shall ensure that (a) employees are competent in the safe handling and use of tools, (b) employees are instructed to use tools only for the specific purposes for which they are designed, and (c) procedures are implemented for safely supplying tools and materials to employees located in hazardous places.

Company action required:

Ensure employees are both aware of and following any legislated requirements, company requirements and manufacturer operators and safety manuals related to work in elevated work platforms.

Due date: 2019-08-20

Date closed: 2019-08-20
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 - NNC #1 Worker Assigned Task Without Required Training

Date & time of visit: 2019-08-20 15:00

Discipline: Safety Management

Categories:

• Training and Competency
• Training, Competency and Qualification

Facility:

Observations:

An NB Power employee was observed working in an unsafe manner from an elevated work platform.  The activity was immediately stopped by company representatives but during their subsequent incident review, the company realized that the worker did not have all current required training for the assigned task.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• EP-304

Relevant section(s):

• Permit EP-304, Condition #5 states that "NB Power must cause the Project to be designed, manufactured, located, constructed, installed, and operated in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related submissions. The NB Power Corporate Safety Manual, as submitted in relation to the approved project, states: DUTIES The New Brunswick Occupational Health and Safety Act mandates specific duties for various groups and individuals involved in the New Brunswick workplace. Specifically these duties are summarized as follows: EMPLOYER Every employer shall g) provide such information, instruction, training and supervision as necessary to ensure employee health and safety;

Company action required:

The company is required to evaluate and determine potential gaps within their processes that would allow workers to be assigned tasks without first ensuring that they are competent to complete that task.  The company shall then take corrective/preventive actions to address identified gaps.

Due date: 2019-10-11

Date closed: 2019-10-03
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

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: