Compliance Verification Activity Report: CV2122-183 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-183
Start date: 2021-10-12
End date: 2021-10-15

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

NGTL 2021 - Brewster Section: Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations - Day 1

Date & time of visit: 2021-10-13 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations - Day 1 

North Saskatchewan River HDD

Location KP15 + 050

Pipeline Coating Crew(s)  Trench Box Observation - (See CNC-2)Excavation Checklists and Trench Safety Side-Boom Crane oil leak 

Compliance tool used: No compliance tool used

Observation 2 - General Observations - Day 2

Date & time of visit: 2021-10-14 06:30

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations - Day 2 

Jackfish/Brewster 
KP 27 + 950 Lowering In and Welding KP 40 + 038 

Compliance tool used: No compliance tool used

Observation 3 - Indigenous Monitor Observations

Date & time of visit: 2021-10-13 08:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Legal Disclaimer re the Written Observations/Report provided by the Indigenous Monitors.
The following section contains independent observations made by an Indigenous Monitor who accompanied the Canadian Energy Regulator Inspection Team during this CVA, as part of the CERs’s commitment to the NGTL IAMC’s Indigenous Monitoring Program. They are reproduced and publicized within my report for greater transparency. They are not my conclusions but represent one source of information among others I have considered throughout the CVA along with my own direct observations and information received from the company.

Indigenous Monitor Observations


INDIGENOUS MONITORING INSPECTION REPORT FOR THE CANADA ENERGY REGULATOR COMPLIANCE VERIFICATION INSPECTIONS: NGTL 2021
CV2122-183: Safety Program Inspection Prepared for: Canada Energy Regulator Calgary, Alberta Prepared by:**** ******* In association with: Apeiron Environment Limited Calgary, Alberta October 27, 2021
TABLE OF CONTENTS
1.0 INTRODUCTION 3
2.0 OBSERVATIONS 3
2.1 COVID-19 Safety Practices and Safety Plans 3
2.2 Construction Safety Practices and Safety Plans 3
4.0 SUMMARY 5
1.0 INTRODUCTION The week of October 13th, the Canadian Energy Regulator (CER) conducted a Safety Program Compliance Verification Activity (CVA). The emphasis of the inspections scope is the proponent’s safety program requirements, other issues of non-compliance related to other program requirements will be appropriately addressed. Also, provided from an environmental perspective was the opportunity to view construction activities and environmental compliance activities.
2.0 OBSERVATIONS

2.1 COVID-19 Safety Practices and Safety Plans At each daily pre-inspection opening meeting, we discussed the importance of examining COVID-19 Protocols and safety protocols of employees working on the RoW. During the orientation meeting, reviewed the planned visits, Contractor reviewed orientation check list. The Contractor emphasized the speed limits: while passing workers and equipment the speed limit is 10km/hour, when on the RoW the speed limit is 30km/hour. At the introductory meeting, all participants took a Covid19 Rapid Test. We also reviewed the Prime Contractors safety protocols. There are 4 medics on the project. Management staff are tested once a week, and all other workers tested periodically. All employees and contractors adhere to the statement “the pipeline is a guest of the community”.

2.2 Construction Safety Practices and Safety Plans The Construction Safety orientation meetings discussed practices for slippery matting, line of sight, PPE, radio contact, ladder safety, and the use of spotters. Also reviewed the speed limits on the RoW. There was opportunity to visit some active construction sites, during this visit. The first day, we visited HDD site at KP5+100 and KP 19+400. At KP 19+400 this was an open excavation site. All signage was in place. At the site discussed HDD safety. At KP 15+50 inspected pipe coating, spoke to the crew, and reviewed the MSDS sheets for the chemicals being used. Inspected the auto welding, cribbing crouching and the fire extinguishers. *See Photo 1* The next visit was a wet land and trench box and inspect their overall condition. Trench boxes were all in good shape. Trenches were all sloped to specifications, and all signage in good shape. *See Photo 2* The opportunity to inspect a couple of TLU sites along the RoW. All signage and fencing were present. Participating in a smudging at one of the sites, lead by one of the First Nation monitors. At KP 29+750 inspected hot line crossing, all signage in place. At KP 28+500 inspected a boom cat. If there is any lift cable defects the unit is shut down and repaired. The final inspection was a puling bore unit at KP 40+038

3.0 NON-COMPLIANCES/COMPANY FOLLOW-UP REQUIRED
There were two non-compliance issues. One CNC was issued to the coating crew, the correction was made. The second CNC issued for the trench box, and was corrected.

4.0 SUMMARY
Overall, my experience conducting this COVID-19 Safety Inspection with CER Inspection Officers’ provided me an excellent opportunity to expand my skills as an Indigenous Monitor (IM).  The overall experience has provided me with the tools and knowledge to analyze and inspection pipeline safety protocols in the workplace.
With clearly defined direction and detailed discussion inclusive of opportunities of Indigenous engagement, I felt fully engaged in this inspection. 
Overall there as good housekeeping on the RoW, not any litter. There is a saying to do with the litter “you see it, you own it”.
One improvement that could be looked into is the General Industrial Hygiene (noise and smoking).
It was a good inspection overall, and the proponent and prime contractor are doing a excellent job with workplace safety and Covid19 protocols.
 

Compliance tool used: No compliance tool used

Observation 4 - CNC - 1 - Pipeline Coaters Crew

Date & time of visit: 2021-10-14 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CNC - 1 - Pipeline Coaters Crew 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Ensure Coating Crew workers meet the requirements of a Fit Test program specific to a clean shaven policy, where the users respiratory protective mask seal meets the face; as per CSA Z94.4--2, Selection, Use and Care or Respirators

Due date: 2021-10-14

Date closed: 2021-10-14
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 - Trench Box Components

Date & time of visit: 2021-10-13 11:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CNC - 2 - Trench Box Components 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

- Replace or repair the wire-lock clevis pin on the trench box

Due date: 2021-10-13

Date closed: 2021-10-14
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

There are no observations with outstanding follow-up

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

Observation 6 - Mainline and Tie-In Welding work processes

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

  1. Provide to the Inspection Officer for review, a representative sample of a carbon steel pipeline welding fume exposure assessment survey that demonstrates Craft Welders, and support worker's, breathing zone exposure levels during routine pipe welding activities; specific but not limited to workers conducting and participating in the welding activities inside pipeline welding shacks. 
    1. Suggested (but not required) factors to consider in the survey:
      1. Type of welding process (manual or automated), the size and thickness of pipe, duration of weld time, and material being welded
        1. Type of welding rod (include the applicable Safety Data Sheet) 
      2. Conditions at time of survey - ambient weather information, number of persons inside the shack, and details whether the shack is partially or fully enclosed, has general ventilation or not
  2. Additionally, the CER Inspection Officer has observed on many occasions, that to ensure the integrity and quality of the welding process, the door and openings of the welding shack will often be fully closed to prevent airborne contaminants, wind etc. from impacting the weld process:
    1. If available, provide information on whether the shack door or openings remain fully or partially open during exposure survey time frames, as this may impact survey results 

Due date: 2022-03-25