Compliance Verification Activity Report: CV2021-216 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-216
Start date: 2020-08-26
End date: 2020-08-27

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Spread 1 – Unannounced TMX construction inspection; hazard identification and controls and worker safety measures for ongoing HDD, pipe stringing, welding, tie-in, and grouting activities. Assess traffic control measures and compliance to conditions 64a and 64b. Assess company actions and implementation of mitigation measures with respect to worker and community protections against COVID-19.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2020-08-27 16:30

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations

 
Beacon Industrial Park Construction YardRosenthal HDD (Shoofly 40)

Shoofly 27a

 
Shoofly 29 – Saskatchewan River HDD Site
Shoofly 22a

Compliance tool used: No compliance tool used

Observation 2 - IR#1 - Stringing

Discipline: Safety Management

Categories:

Facility:

Observations:

A section of welded pipe was observed at the Rosenthal HDD site supported by nine wooden skids.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide evidence the strung pipe is supported in accordance with section 8.2.10 (Trans Mountain Contractor Safety Manual) that was filed as part of C07328-1 1 Condition 64a Health and Safety Management Plan (HSMP) Rev4 July 14 2020 - A7H5Z5 on 5 Aug 2020.

Due date: 2020-09-28

Date closed: 2020-09-08
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 - IR#2 - Noise Exposed Workers

Discipline: Safety Management

Categories:

Facility:

Observations:

Workers performing grouting and drilling operations were observed working in close proximity to heavy machinery (within 3 meters) without hearing protection. During the site specific orientation for this worksite, CER Inspectors asked the site foreman if hearing protection was required. The foreman stated that ear plugs were available for those workers who wanted to wear it, but it wasn't required PPE.


 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

With respect to workers performing grouting and drilling operations on Spread 1, provide the following information:

  1. If workers are exposed to noise levels that exceed the threshold for hearing protection specified in the Project Specific Safety Plan,
  2. if noise levels at this worksite require the employer to perform a noise exposure assessment and/or implement a noise management program in accordance with Part 16 of the Alberta Occupational Health and Safety Code, and
  3. how noise exposure was measured or determined to provide the answer to (1) and (2).

Due date: 2020-09-25

Date closed: 2020-09-21
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 4 - IAMC Observation - Ermineskin First Nation

Date & time of visit: 2020-08-27 16:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

CER
IAMC-TMX
SPREAD 1
Safety  Inspection
August 25-27,2020 

Spread 1 Safety Inspection 

August 25-27, 2020

Mob to SA Energy Yard with the CER IO's and IAMC monitors unannounced inspection, SA Energy workers and TMX workers were all wearing masks and practicing physical distancing.

CER staff and monitors were asked to show a completed TMX-COVID 19 self-declaration screening form before entering the yard in accordance with the TMX-COVID-19 Response Plan 

Temperature screenings were done not only for us but every worker in the morning and after they get off work great practice measures to stop the spread of COVID-19 before we hit the Right of Way (ROW) Biosecurity level 3 wash was done 
 

Right Of Way Inspection:

ShooFly 29- Saskatchewan River HDD Site 

Beacon Industrial Park Construction Yard 

ShooFly 27A 

Shoofly 30 


 

Compliance tool used: No compliance tool used

Observation 5 - IAMC Observation - Lac Ste. Anne Métis

Date & time of visit: 2020-08-27 12:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

The observation is contained within the attached file.

Compliance tool used: No compliance tool used

Observation 6 - IR#3 - Contractor Pipe Cribbing Program

Discipline: Safety Management

Categories:

Facility:

Observations:

A copy of the  SAEG Pipe Cribbing Program which contains a recommendation that pipe (>30'' diameter) is supported  first, third, and fifth cribbing from any loose ends, and then every fifth set of cribbing thereafter (Section 9.5). While the spacing of cribbed joints in this recommendation is the same spacing required by Trans Mountain, it is unclear if contracted workers are held to this standard and how it is enforced. The SAEG pipe cribbing program does not appear to meet the requirements of the Trans Mountain Contractor Safety Manual.

CER notes the company has indicated this discrepancy will be documented for correction on the next Gap Assessment and revision update.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

CER notes that Trans Mountain will address the discrepancy between the Trans Mountain Health and Safety Management Plan (HSMP) and the PSSP during the next 'gap assessment and revision update'. Provide information on how this discrepancy will be communicated to the Contractor in the interim, and ultimately how Trans Mountain will ensure skidding and cribbing activities meet the requirements of the HSMP.

Due date: 2020-10-16

Date closed: 2020-10-16
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

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