Compliance Verification Activity Report: CV1920-196 - TransCanada Keystone Pipeline GP Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-196
Start date: 2019-10-21
End date: 2019-10-24

Team:

Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Safety inspection of operations activities at Hardisty Terminal, including for compliance with the Canadian Energy Regulator Act and regulations (OPR, Safety Management Program), and the Canada Labour Code Part II Occupational Health and Safety and regulations.

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: 2019-10-24 10:55

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations for sites visited:
• Company representatives delivered a site specific orientation to CER staff at all sites, which included a description of emergency procedures, alarm types and muster areas.
• Employees, including occupational health and safety work place committee representatives, participated in inspections.
• Perimeter fencing and gates appeared to be maintained in good condition with proper signage, including company and emergency contact numbers and warning signs to deter intrusion.
• CER inspectors observed that personnel wore required Personal Protective Equipment (PPE).
• 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 of manufactured type, in good condition, and were equipped with bungs in place. 
• Battery areas were inspected by CER inspectors and found to be neat and tidy, with protected plexi-glass installed to protect from outward working area.
• Compressed nitrogen gas cylinders were 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 both eyewash bottles and stations, automated external defibrillator (AED), fire blankets had up to date inspections recorded on affixed tags.
• Eye wash stations maintenance observed, including extended flow eyewash suspected to have leaked being actioned immediately for further examination and to make any necessary repair, and other stations of eyewash bottles recently placed were mounted and bottles added.
• Toilet rooms were functional, sanitary and equipped..
• Elevated walkways were of grated slip resistant design, equipped with secure guardrails, handrails, swing-gates, and toe boards.
• Toe board maintenance was observed preventing excessive gaps from developing..
• Driveways and parking areas were graded and aggregate applied.
• Company representatives informed CER inspectors that the company specific requirement for a positive air shut off (PASO) on diesel engines entering a facility was in place and confirmed prior to vehicle entry to hazardous locations.
•Electrical Work Procedure & Lock out Tag out (LOTO) procedure and an active lock-out work in progress was was competently explained by Company employees and verified by CER inspectors to be in accordance with the LOTO process.
• 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.
• Overhead and jib cranes observed were with proper current maintenance and pre-use records indicating they were safe to operate.
• Vehicles were observed by CER staff to be operated in a safe manner during inspection at all sites.
• Mobile equipment observed by CER inspectors appeared to be in good condition, was parked securely, and operator logbooks was onboard 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 Positive Air Shutoff switch (PASO) switch.
• Heavy Mobile Equipment procedure was examined and operator training verified in discussion with operator.
• Supervisor presented performance evaluation guide - technical task, and explained process of job site observation and refresher instruction to ensure competency of terminal technicians.
• PASO switch was tested for functionality on the equipment and verified by the CER Inspector to be in working order.
• 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, including portable compressor.
• Industrial shelving storage observed by CER inspectors was shelf load rated, was secure to 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.
• Secondary containment for hazardous materials appeared to be appropriate in waste storage building and laboratory.
• Employees accompanied the CER inspection team, providing helpful explanations of work processes, and demonstrated competency when queried on matters pertinent to their role.

Compliance tool used: No compliance tool used

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 2 - 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

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 3 - 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 4 - 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 5 - 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 6 - 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 7 - 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