Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
NGTL 2021 - Karr Section: Work camps and temporary accommodation and RoW; Assess field implementation of worker accommodation strategy per Condition 7; company implementation COVID-19 safety protocols. NGTL 2021 - Karr Section: The Karr section consists of approximately 57 km of 1,219 mm (NPS 48) outside diameter (OD) pipeline, mainline block valves, associated crossover assemblies and launcher/receiver assemblies. The Karr Section begins at NW 28-63-01 W6M and ends at NE 26-67-05 W6M. Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight of contractors - training & competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observations -1 - Karr Worker Camp
Date & time of visit: 2021-07-06 09:30
Discipline: Safety Management
Categories:
Facility:
Observations:
Observations -1- Karr Camp and TC Energy/SMJV Field Office
Compliance tool used: No compliance tool used
Observation 2 - General Observations - 2 - Karr Laydown Yard
Date & time of visit: 2021-07-06 12:00
General Observation - 2 - Karr Laydown Yard
Observation 3 - General Observations - 3 - Karr Spread, Gold Creek Compressor Station Construction
Date & time of visit: 2021-07-07 08:00
General Observations - 3 - Karr Spread, Gold Creek Compressor StationGold Compressor Station
Observation 4 - General Observation - 4 - Excavation Safety and Pipeline Crossings
Date & time of visit: 2021-07-07 11:00
Road 27 – Hotline Crossing
Observation 5 - General Observation - 5 - HDD of Smokey River
Date & time of visit: 2021-07-07 10:30
HDD of Smokey River
Observation 6 - IR 1 - Indigenous Monitoring
Discipline: Indigenous Monitoring
Pre-inspection information request.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Company action required:
Please have hard copies of the following available for review during the morning meeting prior to inspecting the right of way on Wednesday July 7th.
Due date: 2021-07-07
Date closed: 2021-07-23 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 2 - On-Water and Near-Shore Safety Plans
IR - 2 - Smoky River HDD
Relevant section(s):
Please provide to the Inspection Officer for review, the available On-Water Safety Plan, specific to water monitoring at the Smoky River HDD site.
Due date: 2021-07-20
Date closed: 2021-07-21 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.
Observation 8 - NNC - 1 - Royal Camps. Karr Camp, site and grounds, visible litter and garbage
Date & time of visit: 2021-07-07 14:00
NNC-1
Compliance tool used: Notice of Non-compliance (NNC)
TC Energy is to ensure the Karr Camp site and grounds are cleaned up of all litter, waste and garbage; and are to provide to the CER Inspection Officer for review, an applicable process, procedure, standard or checklist, that demonstrates a regular and routine program of oversight of the Royal Camp yard and grounds is occurring, and that site inspections are documented which prevent, eliminate and manage waste, litter or garbage that may accumulate and spread around the Royal Camp, Karr Camp site area.
Due date: 2021-08-13
Date closed: 2021-08-26 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.
Observation 9 - IR 3 - Electrical Safety
An electrical panel was observed to be modified.
Describe how the modification to the electrical panel meets all TC specifications including commitments to industry standards (e.g.. CSA-Z462 follow CSA-C22.1-18, Canadian electrical code). Include in your response:
Due date: 2021-08-30
Date closed: 2021-09-02 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.
Observation 10 - IR 4 - Fire Safety
Fire hoses left in cabinets at the Karr camp were described as non-functional.
Describe how the Karr camp is compliant with all fire suppression requirements. Consider in your response the fire hoses that have been left in fire cabinets but described as non-functional by camp management. Include descriptions of primary and secondary fire suppression equipment/methods.
Observation 11 - CNC 1 - Housekeeping at SMJV Laydown Yard
Date & time of visit: 2021-07-06 11:30
Discipline: Environmental Protection
A dumpster was opened and garbage was extracted by birds on site.
Compliance tool used: Corrected Non-compliance (CNC)
IO requested company collect and dispose of the garbage.
Due date: 2021-07-06
Date closed: 2021-07-20 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.
Observation 12 - CNC 2 - Fasteners in Breaker Panel
Date & time of visit: 2021-07-06 11:00
Fasteners were observed to be missing from a breaker panel.
IO requested fasteners be replace where missing.
Observation 13 - CNC 3 - Safe Equipment Storage
Side boom arms were stacked in what appeared to be a position susceptible to collapse.
IO requested equipment stack be adjusted to a more stable position.
Observation 14 - CNC 4 - Personal Protective Equipment
Date & time of visit: 2021-07-07 09:00
Hydrovacing worker was observed to be working without required fall protection.
IO requested worker be advised to don fall protection equipment as per company requirement.
Observation 15 - CNC 5 - Unprotected Excavation
Date & time of visit: 2021-07-07 10:00
A group of worker were observed adjacent to an unprotected excavation edge.
Company was directed to mark a safety zone around the excavation with spray paint and advise workers of the hazard of congregating unnecessarily at excavation edge.
Observation 16 - General Observations - Indigenous Monitoring
Date & time of visit: 2021-07-07 17:00
Additional Observation recorded by Indigenous Monitors participating in the CER Inspection. Any compliance related observations that require specific regulatory follow-up have been recorded in stand alone observations.Indigenous Monitor Observation Report CV 2122-190Jonathan Wright – Sucker Creek First Nations Indigenous MonitorJuly 6th and july 7th, 2021 GlossaryCER – Canadian Energy RegulatorIM – indigenous MonitorIR – Information RequestNNC- notice of Non-ComplianceCNC- Corrected Non-ComplianceFN – First NationsTLU – Traditional Land UseHDD – Horizontal Directional DrillDTA – Department of Transportation of AlbertaKP – Kilometre Point Introduction:Inspection was completed on July 6th and 7th on the KARR section of the NGTL pipeline. Inspection was completed by two safety inspectors from the CER and two Indigenous Monitors from Sucker Creek First Nation & Montana First Nation. The CVA consisted of inspection of the Karr camp, the ROW, the company IM program and because it was the kickoff of the pipeline construction period, we looked in the chance find protocol & TLU site mitigations, awareness and training. Observations/Inspection: Karr Camp KP 44We walked the grounds of the camp to ensure safety measures were in place for the protection of its residents. We also looked at environmental protection measures, wildlife mitigations and socio-economic concerns. Approach:
Observation 17 - IR 6 - Cultural Resource Discovery Contingency Plan (CRDCP)
NGTL notes the ACPP Plan, as filed with the CER per Condition 10 of the Project, denotes involvement of ACPP participants where the Cultural Resource Discovery Contingency Plan (CRDCP) is implemented.
Provide a copy of the Cultural Resource Discovery Contingency Plan (CRDCP).
Due date: 2021-08-20
Date closed: 2021-09-03 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.
Observation 18 - IR 7 - Berm Mitigation and Water Erosion Control
IM Identified one section of Karr Camp perimeter that appeared to have insufficient berm mitigation and water erosion control. IM also noted at the same location that it was becoming a natural drainage area, so in an instance of a major spill or flood it would be the weak point of area of drainage. Also noted that at the opposite end of the perimeter had excellent textbook drainage & beam mitigations.
Provide evidence that mitigations are suffecient or evidence of corrective measures.
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