Compliance Verification Activity Report: CV2021-215 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-215
Start date: 2021-03-18
End date: 2021-03-18

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:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

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

Discipline: Environmental Protection

Categories:

Facility:

Observations:

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

Categories:

Facility:

Observations:

In the middle of the construction area, a light standard was being used as a generator, however the unit was not properly grounded.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

TMEP is required to install a ground pad or a grounding rod with 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 4 - IM Observations

Date & time of visit: 2021-03-18 14:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

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

Compliance tool used: No compliance tool used

Observation 5 - Contractor Oversight

Date & time of visit: 2021-03-18 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

-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.

 

 

 

 



 

Compliance tool used: No compliance tool used

Observation 6 - Infection Control Program

Date & time of visit: 2021-03-18 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

-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.

 


 

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:

- 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