Compliance Verification Activity Report: CV1920-197 - TransCanada Keystone Pipeline GP Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2773

Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada Keystone Pipeline GP Ltd

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Safety Management

Related events:

• CV1819-261
• CV1920-503
• INC2020-002

Rationale and scope:

Safety oversight of operations activities at PS 15 Caron and PS 17 Regina Pump Stations. Verify implementation of corrective action plans from CV1819-261 (COSHR Part X and NFC Parts 3 and 4 and Part XIX Hazard Prevention Program for pump stations). Verify compliance with CER Act, OPR Regulations, CSA Z662, CLC Part II, COHSR, and company specific procedures.

Compliance tool(s) used:

• None

Facility details

Facilities:

• PS 15 CARON [KEYSTONE]
• PS 17 REGINA [KEYSTONE]

Facility Types

• Pipeline
• Pump station

Life-cycle Phases

• Operations

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)
• Onshore Pipeline Regulations (OPR)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observations Keystone

Date & time of visit: 2020-02-11 09:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Open Topped Bins, Hoppers and Pits
• Docks, Loading Ramps
• Housekeeping
• Towers, Antennas and Support Structures
• Shelving and General Storage
• Signage
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• General Lighting
• Noise Control
• Signage

Facility:

• PS 15 CARON [KEYSTONE] (Facility)

Observations:

• 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 and appeared to be competent in matters of health and safety.
• 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; garbage placed in correct bins and 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 observed to be 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.
• Industrial shelving storage observed by CER inspectors was shelf load rated, was secured to floor, and there appeared to be no overloading of shelves.
• CER Inspectors observed portable fire extinguishers of appropriate type placed near doors and egress ways and affixed tags had up to date inspections and maintenance recorded.
• Emergency equipment, including adequate eyewash bottles and stations, automated external defibrillator (AED), had up to date inspections recorded on affixed tags.
• Washrooms were observed to be equipped with sanitary supplies, functional, and were clean.
• CER Inspectors observed perimeter fencing and gates in good condition with proper signage, including company and emergency contact numbers and warning signs to deter intrusion. Gates were bonded to perimeter fence.
• Elevated walkways observed during the inspection were of grated slip resistant design, equipped with secure guardrails and handrails. 
• 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.
• A record of PASO testing was reviewed for Caron Station by CER Inspectors and found to be adequate.
• Electrical Work Procedure & Lock out Tag out (LOTO) procedure and an active lock-out work in progress 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. The requirement to use a spotter was communicated to CER Inspectors during the site specific orientation.
• Windsocks indicating wind direction were visible to CER Inspectors and in good condition.
• High voltage electrical panels in the electrical services building (ESB) were observed by CER staff to be labeled in accordance with company specific requirements and applicable legislation.
• A company representative demonstrated a visual inspection of high voltage PPE (40cal/cm2) including a pair of rubber gloves. The employee stated that high voltage PPE is worn when working on medium and high voltage equipment.
• Dedicated hazardous waste buildings were observed by CER staff at both Caron and Regina pump stations. The buildings were clean, equipped with spill kits, and had secondary containment.

Compliance tool used: No compliance tool used

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: