Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain Pipeline ULC
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Unannounced joint Safety and Environmental Protection inspection of the TMEP Edmonton Terminal. Verify compliance to OPR and company requirements with a focus on contractor oversight.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observation - Environment
Date & time of visit: 2021-03-18 09:30
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Compliance tool used: No compliance tool used
Observation 2 - Tank 4
Date & time of visit: 2021-03-18 10:00
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
TMEP to provide a drip tray to the light tower.
Due date: 2021-03-18
Date closed: 2021-03-18 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 - Light Tower as a Generator
Date & time of visit: 2021-03-18 11:00
Discipline: Safety Management
In the middle of the construction area, a light standard was being used as a generator, however the unit was not properly grounded.
TMEP is required to install a ground pad or a grounding rod with the light tower.
Observation 4 - IM Observations
Date & time of visit: 2021-03-18 14:00
Discipline: Indigenous Monitoring
Additional Observation recorded by IAMC Indigenous Monitors participating in the CER Inspection. Any compliance related observations that require specific regulatory follow-up have been recorded above.March 18, 2021
Observation 5 - Contractor Oversight
-Several TMEP oversight inspectors were interviewed and observed conducting oversight of work activities: working from heights, excavation, mobile crane activities.
-scopes of work appeared to be fully understood.
-hazard control measures were understood and implemented.
-TM oversight inspectors were observed verifying permits, checking contract worker equipment pre-use inspections, FLHA’s.During discussions with TMEP staff, it was identified that there was no direct oversight of radiography work conducted at night by TMEP oversite inspectors. A follow-up CVA will be initiated to explore if this issue is systemic across the project and if compliance with OPR requirements are being met.
Observation 6 - Infection Control Program
-viable program was fully implemented.
-health self-assessments are in use on a daily basis.
-temperature testing program appears fully implemented and effective.
-physical distancing was observed where possible; masks were observed in use by TM staff as well as contractors on site.
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