Compliance Verification Activity Report: CV2223-092 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-092
Start date: 2022-06-28
End date: 2022-06-29

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Unannounced safety inspection of TMX Darfield-Black Pines reactivation segment on 28 June 2022. Short notice safety inspection spread 4b on 29 June 2022. Verification of company oversight of contractors and field implementation of the TMEP Health and Safety Management Plan and the project specific safety plans. Verification of site-specific HDD noise mitigation plan (condition 74) at Clearwater HDD exit site.

 

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Darfield-Black Pines Reactivation Segement

Date & time of visit: 2022-06-28 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) and TMX-IAMC Indigenous Monitors performed an unannounced field safety inspection of Trans Mountain Expansion Project (TMEP) Darfield-Black Pines reactivation. The scope of the inspection was limited to one work site and focused on verifying TMEP is meeting their obligations for safety oversight described in the TMEP Health and Safety Management Plan (HSMP) and Project Specific Safety Plan (PSSP).

Contractor Oversight Findings:

Work Site Observations:

Compliance tool used: No compliance tool used

Observation 2 - Spread 4b - General Observations

Date & time of visit: 2022-06-29 10:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection officers and Indigenous Monitors met with Trans Mountain and Bannister representatives at spread 4b yard. 

Discussion revolved around the scope of work and nature of the section which included all phases of pipeline construction in the immediate vicinity of home owners and businesses in the region. Trans Mountain described a good relationship with the surrounding communities which is fostered through community engagement with key stakeholders including indigenous communities, the district of Clearwater and landowners.

In terms of contractor safety oversight, TMEP has a full-time health & safety lead and four full time field safety inspectors (FSI) assigned to spread 4b. CER Inspection Officers (IO) reviewed a sample records and incident investigations which indicate TMEP FSIs are in the field daily. Both the HS Lead and FSI who attended the inspection appeared to have good knowledge of the PSSP and HSMP requirements. IOs observed the TMEP FSI interacting with contracted workers and communicating the requirements of the PSSP during the field inspection.

During the field inspection, IOs observed a TMEP Inspector present at each work site. Contractor workers verbally verified that TMEP FSIs are routinely present in the field performing safety inspections. IOs observed the commitments made in the Fire Prevention and Mitigation Plan (section 36 of the PSSP) were implemented in terms of fire extinguishers and  designated smoking areas. Some items of non-compliance were observed with respect to emergency preparedness, JSA review, and document control. Work was observed in close proximity to 138kv power lines and associated hazards were discussed (see NNC1)

Compliance tool used: No compliance tool used

Observation 3 - Spread 4b - Noise Mitigation Clearwater HDD

Date & time of visit: 2022-06-29 13:00

Discipline: Safety Management

Categories:

Facility:

Observations:

IO's visited exit site for planned 1.26 km horizontal directional drill where casing hammering had commenced.

Compliance tool used: No compliance tool used

Observation 4 - CNC 1 - 4b Shoefly 25 - JSA review

Date & time of visit: 2022-06-29 13:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officer (IO) asked a straw boss who had been overseeing jeeping activities at shoefly 25 for a copy of the jeeping JSA. The straw asked his foreman who presented a copy of the JSA but stated he had had not yet reviewed the JSA with workers who performed the task earlier that day. The foreman also stated jeeping was not typical scope of work for his crew.

Additionally, the jeeping JSA had been recently updated as a corrective action to an incident that occurred on 30 May 2022. The copy provided by the foreman was not the most recent copy.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Ensure the workers tasked with jeeping have reviewed the relevant JSA prior to performing the work. Ensure the most recent revision has been provided to all foreman responsible for overseeing jeeping work.

Due date: 2022-06-30

Date closed: 2022-06-29
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 5 - CNC 2 - 4b Shoefly 25 - Emergency Preparedness

Date & time of visit: 2022-06-29 13:00

Discipline: Safety Management

Categories:

Facility:

Observations:

When asked by the Inspection Officer, a straw boss on shoefly 25 was unable to contact the medic by radio due to lack of knowledge on how to switch the radio to the proper channel. Given the straw’s roles and responsibilities defined in the PSSP, this presents an unreasonable risk to workers under the straw’s supervision in the event of an emergency.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Ensure the Straw Boss has been trained on proper use of the radio inclusive of switching channels and zones.

Due date: 2022-06-30

Date closed: 2022-06-30
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 6 - CNC 3 - 4b - Construction Safety Manual

Date & time of visit: 2022-06-29 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

An outdated revision of the Trans Mountain HSMP was posted in the spread 4b safety trailer. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action required:

Update documents observed on bulletin board in safety trailer.

Due date: 2022-06-29

Date closed: 2022-07-07
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 7 - NNC 1 - Hazard Recognition, Evaluation and Control - Induced Voltage

Date & time of visit: 2022-06-29 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Work was observed on the reactivation segment and spread 4b in close proximity to 138kv overhead power lines. When asked how risk related to induced voltage was managed, TMEP safety inspectors demonstrated minimal awareness of this hazard and provided no assurance to CER Inspection Officers that they were able to effectively oversee those required to monitor for, assess, and control induced voltage from overhead power lines.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Develop an action plan to raise the awareness and competency of TMEP field safety staff of the requirements to adhere to principles and practices of electrical coordination between pipelines and electrical supply lines (i.e. CSA C22.3 No.6).

Submit the action plan to the CER with supporting material and implementation targets for the entire project.

Due date: 2022-08-15

Date closed: 2022-10-03
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 8 - NNC 2 - CSA C22.3 No.6, Clause 7

Date & time of visit: 2022-08-24 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

In a recent response to a CER information request TMEP has submitted that "Trans Mountain has conducted an internal review of the requirements in CSA-C22.3 No. 6 and has identified that the induced voltage monitoring program as identified has not been fully implemented."

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

1. Conduct a quantitative risk analysis of the potential for injury to workers due to electrostatic and electromagnetic induced voltages on piping during pipeline construction in proximity to high voltage power lines.
2. Develop a program to ensure GCC’s are in compliance with CSA C22.3 No. 6 Clause 7, project wide.
3. Develop an action plan to raise the awareness and competency of TMEP oversight inspectors on the requirements of the program described in item 2.

Submit items 1-3 to the CER with implementation targets for the entire project.
 

Due date: 2022-11-11

Date closed: 2022-11-15
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