Compliance Verification Activity Report: CV2021-089 - ExxonMobil Canada Properties

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2648

Regulated company: ExxonMobil Canada Properties

Operating company: ExxonMobil Canada Properties

Province(s) / Territory(s):

• Nova Scotia

Discipline(s):

• Safety Management

Rationale and scope:

Safety oversight of Goldboro gas plant abandonment activities - assess compliance to legislated requirements, Construction Safety Manual and project specific safety plans;

Compliance tool(s) used:

• None

Facility details

Facilities:

• Sable Offshore Energy Project

Facility Types

• Processing
• Gas plant

Life-cycle Phases

• Decommissioning & Abandonment

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• National Energy Board Processing Plant Regulations (PPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Contractor/Project Safety Plan (CSP)
• Exxon CSM
• Project-specific plan or procedure
• Contractor (Golder) PSSP
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• ZO-E086-002-2019

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2020-07-10 13:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage
• Noise Control
• Monitoring/Evaluation
• Training and Competency
• Training, Competency and Qualification

Facility:

• Sable Offshore Energy Project (Facility)

Observations:

• Upon arrival to the facility the inspection officer was required to complete a temperatue screening process as well as a pre-access COVID-19 screening questionnaire
• The inspection officer was provided with a site safety orientation by Exxon's contractor representative (Site Supervisor)
• In addition to the safety orientation, the site supervisor also provided an overview of the primary safety program documents relevant to the project (including the ExxonMobil Canada Properties (EMCP) Safety Manual, Covid-19 Management Plan, and contractor Safety Plan
• The site supervisor was able to demonstrate an understanding of the documents and the roles and responsibilities of those involved to ensure conformance to the plans.  Some of the key items covered included:
  • EMCP Operations Integrity Management System (OIMS)
  • The EMCP Life Saving Actions (LSA) program
  • Work Permit procedures
  • Project communication plans and reporting requirements including daily execution monitoring reports, weekly progress reports, and incident reporting and management
  • Risk Assessment, project management readiness reviews, hazard identification and mitigation
  • Training and competency requirements
  • Short Service Worker (SSW) program
  • Loss Prevention System (LPS)
  • Incident Management and Response
  • Personal Protective Equipment
  • Traffic Management Plan
• Many of the topics covered above were further verified during the subsequent site inspection with representatives from EMCP and their contractor, including:
  • Traffic management as well as personnel management within the worksite.  Traffic flow direction was well established and the worksite was delineated into separate Demolition Zones with fencing, signage and personnel in place to ensure only those required for the task were permitted into a zone.  The inpsection officer observed the effective use of the plan, including the use of radio checks and movement of physical barriers to allow the inspection party to proceed into the various zones when determined safe to do so
  • Spotters were in place to oversee the work being conducted by equipment operators and to ensure all other personnel were kept outside areas of potential danger
  • Site signage and physical barriers were observed to be well established and in accordance with the safety plan
  • Use of appropriate PPE by all workers within the facility
  • Workers involved in the SSW program were observed and the program appeared to be implemented as detailed in the safety plan
  • Tailgate meeting records, Job Loss Analyses (JLAs), Hazard IDs, etc were available and in accordance with the safety plan where checked
  • Work permits were avaialble for review and were being utilized in accordance with the safety plan where checked
  • Hand sanitizer was avaialbe on site and within rest room facilities provided for personnel
  • Personnel were aware of and maintained appropriate physical distancing in accordance with the Covid-19 preventive measures
  • Where asked, site personnel were able to describe their job function and responsibilities on the project, including awareness of and obligation to address safety issues
  • A sampling of training records was reviewed during the inspection
  • Spot checks were completed of equipment daily inspection logs and certifications and they were determined to be in order
  • The site was observed to be well maintained, with debris being stored to mitigate potential hazards

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: