Compliance Verification Activity Report: CV2223-269 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2927
• Inspector 1906

Regulated company: NOVA Gas Transmission Ltd.

Operating company: NOVA Gas Transmission Ltd.

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Safety Management

Related events:

• CV2223-290
• INC2022-147

Rationale and scope:

Verification to site specific safety plan, contractor oversight and verify whether adequate controls are in place to prevent recurrence. Assess controls in place pertaining to INC2022-147.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (2)

Facility details

Facilities:

• EDSON MAINLINE LOOP - NPS 42

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Canadian Energy Regulator Act (CERA)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Field Inspection of Incident Site

Date & time of visit: 2022-08-25 13:00

Discipline: Safety Management

Categories:

• Workplace Practices
• Job/Task Safety Analysis
• Procedures/Work Instructions
• Contractor Management & Oversight
• Responsibilities and Accountability
• Supervision, Inspection and Monitoring

Facility:

• EDSON MAINLINE LOOP - NPS 42 (Pipeline)

Observations:

• On 25 August 2022, CER Inspection Officers (IOs) inspected the NGTL Edson Mainline Loop Raven River section in response to an incident that NGTL reported to the CER on 24 August 2022 (incident) .
• IOs arrived on site at 12:15 PM MST.
• Company and contractor representatives were present during the inspection.
• The incident scene remained frozen.
• NGTL Construction Manager provided an overview of NGTL's oversight strategy. On the day of the incident, an NGTL welding inspector was assigned to each tie-in crew.
• IOs received a verbal summary of the incident from a contract worker present at the time of the incident. The summary was consistent with what NGTL reported to the CER.
  • A tie-in crew had been working on a test fit for approximately 30 minutes and had trouble lining up the bored pipe with the section suspended from 3 side booms.
  • It was the injured worker's first afternoon with the tie-in crew. He arrived at the site at 11 AM, and the incident occurred at 3:50 PM.
  • The injured worker was not at the tailgate safety meeting but went through the tailgate and FLHA on his own.
• IOs reviewed the contractor's JHA "Tie-Ins". The JHA included controls to "maintain a safe working distance" and "keep hands and body clear of pinch points" when placing the pipe in clamps. IOs noted that the injured worker and NGTL Inspector had signed onto the JHA.
• IOs interviewed the NGTL welding inspector, who was overseeing the work when the incident happened. The Inspector appeared knowledgeable of the contractor's safe work procedures, including the tie-in JHA, but stated he had no oversight responsibilities of the work taking place in the ditch when the injury occurred (see NNC 1).
• IOs observed the contractor performing a tie-in in another location. Work appeared to be completed per the JHA.
• IOs interviewed an NGTL ditching inspector. The Inspector described their role in ensuring the contractor worked safely and confirmed they had stop-work authority.

Compliance tool used: No compliance tool used

Observation 2 - NNC 1 - Communicating Inspector Responsibilities

Date & time of visit: 2022-10-03 17:00

Discipline: Safety Management

Categories:

• Contractor Management & Oversight
• Responsibilities and Accountability

Facility:

• EDSON MAINLINE LOOP - NPS 42 (Pipeline)

Observations:

On 25 August 2022, CER Inspection Officers (IOs) conducted a field inspection in response to a contractor injury NGTL reported to the CER on 24 August 2022. 

During the inspection, IOs spoke with the welding inspector (inspector) assigned to the injured worker's tie-in crew. According to statements obtained:

• the inspector was the sole NGTL representative near the ditch at the time of the incident, and 
• the inspector believed his duties were limited to oversight of welding and had no role in the activities taking place in the ditch when the injury occurred.

On 31 August 2022, CER Inspection Officers (IOs) requested a list of the inspector's duties (IR 2.2). NGTL's response states the inspector's responsibilities include, but are not limited to:

• ensuring the tie-in work meets the requirements of the contractor's lower-in pan and excavation and backfill plan,
• ensuring excavations are safe for entry, and
• ensuring that tie-in activities are executed as per approved industry standards.

Based on NGTL's response to IR 2.2 and onsite interviews, the CER IOs believe that NGTL had not effectively communicated the safety oversight expectations of its company representative (welding inspector) who was positioned near the ditch at the time of the incident.  

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR) 2020-03-16

Relevant section(s):

• • 6.5
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (l) establish and implement a process for making employees and other persons working with or on behalf of the company aware of their responsibilities in relation to the processes and procedures required by this section;

Company action required:

Describe how NGTL will ensure company representatives (inspectors) understand the scope of their safety oversight responsibilities, including the general responsibilities to inspect and monitor the contractor's work as outlined in NGTL's safety management plan.

Due date: 2023-02-10

Date closed: 2023-02-10
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 - NNC 2 - Hazard Identification and Control

Date & time of visit: 2022-08-25 13:00

Discipline: Safety Management

Categories:

• Hazard Management
• Management of Hazardous Energy

Facility:

• EDSON MAINLINE LOOP - NPS 42 (Pipeline)

Observations:

During a field inspection on 25 August 2022, CER Inspection Officers (IOs) were told that on 24 August 2022, the contractor was performing a "test fit" in preparation for a tie-in. The pipe did not align properly, and workers were attempting to free the pipe from external alignment clamps when the pipe moved unexpectedly, pinching a worker between the pipe and the ditch bank resulting in a serious injury.

In IR 1.3, IOs asked if the company had a contingency plan for "test fits." In their response, NGTL stated that if the pipe does not fit properly, the [alignment] clamps are loosened, and the pipe is removed from the ditch per industry standard practice.

NGTL provided the IOs with copies of the FLHA, JHA, and tailgate meeting from the day of injury, all signed by an NGTL representative. Although the FLHA and JHA identify pinch points as a general hazard, hazards and potential challenges related to removing the unwelded pipe from clamps, including the potential for unexpected pipe movement due to stored energy for a large diameter pipe, are not identified. 

During the field inspection, IOs observed two egress points from the ditch, both exiting from the area where the pipe was suspended during the test fit. Although the injured worker's entry into the ditch may have been unexpected, it's not clear how workers already in the ditch would have safely exited without being exposed to the potential movement of the pipe if attempts to free the pipe from the clamps were not successful.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR) 2020-03-16

Relevant section(s):

• • 6.5
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;
      • (e) establish and implement a process for evaluating the risks associated with the identified hazards and potential hazards, including the risks related to normal and abnormal operating conditions;
      • (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards, potential hazards and risks and for communicating those controls to anyone who is exposed to the risks;

Company action required:

1. Describe how NGTL will ensure hazards and potential hazards related to "test fits," including removing the pipe from external alignments clamps, will be identified and controlled on CER-regulated worksites.
2. Describe how NGTL will ensure everyone at CER-regulated construction sites exposed to the hazards identified in #1 is informed of the practices and procedures to be followed for their safety.

Due date: 2022-12-16

Date closed: 2023-02-23
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: