Compliance verification activity type: Field Inspection
Team:
Regulated company: Westcoast Energy Inc.
Operating company: Westcoast Energy Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Joint safety and damage prevention inspection on CER regulated assets impacted by the BC Floods. Verify compliance with OPR, DPR and maintenance safety manual.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observation
Date & time of visit: 2021-12-14 13:00
Discipline: Safety Management
Categories:
Facility:
Observations:
CER IOs arrived at Othello station at 10:13 AM on December 14th. According to company representative, Othello station typically has 3 FTE 8 hr/ 5 days with staff on-call on the weekend. IO received a general orientation and a description of the work being conducted on segments of exposed pipe that was impacted by recent flooding. IO's commended company for including a land acknowledgement in their orientation checklist.
Welders were observed cutting and welding without respiratory protection. CER IO's inquired about the assessment of respiratory hazard associated with cutting and welding and the exclusion of respiratory protection in applicable controls (See "field IR response" attached). Company has responded describing the risk asessment process used to determine appropriate controls. CER IOs inquired about the company requirements for tags used as part of the Lockout-Tagout program. It was observed that 2 different types of tags were in use on the lock box. An Information Request was submitted in relation to this observation. (See "field IR response" attached). CER IOs were informed that the Operations Technicians assigned to provide oversight of the activities were not required to provide daily reports as part of their duties. If this work had been handed over to the Core Projects team, a daily report would have been required from those assigned to provide oversight. The IOs consider this as a potential improvement towards ensuring adequate supervision is provided as required under OPR s.6.5(1)(k). The personnel observed on site fulfilling the required supervision role were observed to be well engaged with contractor and 3rd party (primarily related to Ministry of Transportation and Infrastructure) activities, but the completion of a daily report would be helpful in assessing whether they were fulfilling the OPR requirements. An IR related to completion of oversight activities was submitted (See "field IR response" attached).The response is under review. Company has indicated that they are currently implementing the new IMS 5.3-Contractor Management Process, in which section 2.4 Contract Oversight outlines the overall contractor oversight requirements. Process to be verified in future Compliance Verification Activities. December 15 – 2021 – CER onsite at 7 AM to attend tailgate meeting CER IOs submitted COVID Site Access Health Assessment form. Onsite First aid attendant conducted temperature taking of all people at the safety tailgate. Company representatives led a safety tailgate meeting to discuss the work happening at the site that day. This discussion also included a Land Acknowledgement and reminder about the Harassment and Violence Policy in effect onsite. Hazards discussed at tailgate include:
Several competency related documents were observed and apparent deficiencies noted (See "field IR response" attached).The response is under review. Company has indicated that they are currently implementing the new IMS 5.3-Contractor Management Process, which includes the GTM Contractor Management Process – Scope Management Process Guide. In Step 9 (Assemble Contractor Technical Qualifications/Competencies) of the guide, the planner identifies and assembles the qualifications and competencies for the Contractors performing the work prior to releasing a service requisition. The GTM Canadian Contractor Competency Control Work Instruction outlines the how GTM Canada Business Units will execute the minimum requirements related to competencies as stated in the GTM IMS 5.3 Contractor Management Process. New processes to be verified in future compliance verification activities.
During welding operation on Dec 16th a component of the welding machine appeared to short causing uncontrolled release of sparks for about 20 seconds. The power was cut to the device and issue resolved. (See IR 1) Based on information provided during the inspection, the CER IOs understand that station valves will be locked out until such time as the 8AL1 line will be returned to service (See IR 2)
Compliance tool used: No compliance tool used
Observation 2 - Damage Prevention Observations
Discipline: Damage Prevention
Damage prevention-related observations
Observation 3 - IR 1 - Incident Report
A component of a welding machine appeared to short, causing uncontrolled sparks from the back of the welding truck.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Verify that all process requirements for incident investigation and reporting were met with respect to the incident that occurred on Dec.16th with the welding machine. Describe how the requirements were met in this instance and provide a copy of the incident report.
Due date: 2022-01-15
Date closed: 2022-01-18 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 - IR 2 - Valve Closures
Based on information provided during the inspection, the CER IOs understand that station valves will be locked out until such time as the 8AL1 line will be returned to service (at least until sometime in January 2022). It is acknowledged that valve leakage is possible during this time.
As it is acknowledged that valve leakage is possible during this time, the following information is requested: Provide details of the monitoring program in place to ensure that the section of pipeline taken out of service remains in a zero-energy state and that any valve leakage that may occur is identified and mitigated as appropriate.
Due date: 2021-12-31
Date closed: 2022-01-25 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.
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
