Compliance Verification Activity Report: CV2223-095 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-095
Start date: 2023-02-13
End date: 2023-02-16

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Canada Inc

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

[Process Safety] Trans Mountain Burnaby & Westridge Terminal - validate implementation/close out status of high and medium risk HAZOP action items; Pre-startup safety reviews and Management of Change for startup operations of TMEP; 

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Burnaby Terminal

Date & time of visit: 2023-02-14 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) and Indigenous Monitors (IMs) reviewed the Burnaby Terminal Hazard and Operability Study (HAZOP) and the Tank Vapor Adsorption Unit HAZOP with the company representatives. This included evaluating various scenarios, conditions and events in the HAZOP that have health and safety risks that were risk ranked according to the company risk matrix. 

Per the records presented, it appears that the company has completed the implementation of all the recommendations to eliminate and/or mitigate the risks identified by the HAZOP. It is noted that these scenarios, conditions, and events were identified prior to the Issue For Construction (IFC) for the project and any changes thereafter are subject to an internal Management of Change (MOC). An example of this MOC was provided with respect to a piece of equipment where the hazards were found to be no longer applicable due to the equipment no longer being constructed.

HAZOP items were deemed completed once Issued For Construction. The company's commissioning procedure was reviewed during the inspection. No assets had been turned over to Operations during the inspection. The company reported having readiness leads onsite working closely with construction and Operations business units. 

During the site inspection, IOs and IMs observed the safeguards implemented for the highest risk-ranked event from a potential loss of containment. These included the tank bay, retention pond, oil-water separator, and tertiary containment, including hydrocarbon detection, remotely operated valves, and the required actions by operators.  

Compliance tool used: No compliance tool used

Observation 2 - Westridge Marine Terminal

Date & time of visit: 2023-02-15 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officers (IOs) and Indigenous Monitors (IMs) reviewed the Westridge Terminal Marine Vapor Control System Hazard and Operability Study (HAZOP) with the company representatives. This included evaluating various scenarios, conditions, and events in the HAZOP that have health and safety risks that were risk ranked according to the company risk matrix. 

Per the records presented, it appears that the company has completed the implementation of all the recommendations to eliminate and/or mitigate the risks identified by the HAZOP. It is noted that these scenarios, conditions, and events were identified prior to the Issue For Construction (IFC) for the project and any changes thereafter are subject to an internal Management of Change (MOC). 

Walk down of the vapour recovery and control was conducted where the company reviewed major equipment operation. 

Compliance tool used: No compliance tool used

Observation 3 - Asset Transition - Construction to Operations

Date & time of visit: 2023-02-15 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Company representatives provided an overview of the expansion project asset turnover and transition from construction to operations. The company presented records and documentation as examples of what the process entails which includes but is not limited to:

Company representatives also stated and presented an example of the certification issued at each stage of the asset turnover and transition which is required prior to advancing from one stage to the other and acts as an additional quality step. Other quality steps include the completion of change management requests for acceptance of the asset by operations and a transfer, care, custody, and control management of change. 

In addition to dry and wet-commissioning, prior to placing the asset into service, company representatives stated that implementation of all HAZOP action items is verified by the pre-startup safety review stage and punch-list items based on criticality ranking are resolved. Example records demonstrating these steps were presented by the company reps.

Compliance tool used: No compliance tool used

Observation 4 - Indigenous Monitor Observation - Burnaby Terminal

Date & time of visit: 2023-02-14 09:34

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:


Location: Offices on Site at Burnaby Terminal

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (TMX Virtual) KT, DA, LB, LE, VG, MH, BKal, BKan, PL, CS, JW
  • (IM’s) KW, JH

Notes:
  • Introductions of names, roles and titles of all those in attendance both in-person and virtually.
  • TJ request for contact information for those in attendance to be distributed. KT confirmed the request and supplied the contacts at a later time.
  • KW requested information on cultural competency education for all members attending the meeting. Course completion was confirmed by BJ, JV and RL. The name of the course was provided to KW along with a demonstration of select course material.
  • Discussion of documents including the Burnaby Terminal Hazard and Operability Study (HAZOP)
  • During the discussion about safeguards implemented for the potential loss of containment, overflow from secondary containment  or tank bays was identified as being collected in a retention pond before being processed through an oil-water separator, released into tertiary containment for further observation and potential recovery operations, finally and clean water would be discharged into Eagle Creek.
 
Break for lunch
 

Location: Offices on Site at Burnaby Terminal

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  •  (IM’s) KW, JH

Notes:
  • Continued document review.

Location: Outside of Offices on Site at Burnaby Terminal

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Site walk commenced.
  • Observed the safeguards implemented in the event of a potential loss of containment.
  • Bird nest observed on site, placed amongst open sided structure roofing.

Notes:
  • Concluded site walk.
  • TJ conducted a wrap up of the day’s events including any documents and information requested.

Compliance tool used: No compliance tool used

Observation 5 - Indigenous Monitor Observation - Westridge Marine Terminal

Date & time of visit: 2023-02-15 09:18

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Time Indigenous Monitors Comments and Observations

9:18
















 

 

12:03








 
 

12:13









 

 

12:13







 
 

12:26








 
 

12:30









 
 

12:31










 
 

12:37









 
 

12:46











 
 

12:51








 
 

12:56













 
 

13:10







 
 

13:22









 
 

13:24










13:31








 
 

13:35








 
 

13:39








 
 

13:44









 
 

13:50
Location: Offices on Site at Burnaby Terminal

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Introduction of names, roles and titles of those in attendance.
  • Began discussion of documents including Hazard and Operability Study (HAZOP) and field level hazard policies.
  • Discussion on the use of ALARP in documentation and the associated regulatory definition of the term. Using ALARP likely requires what is deemed “Reasonably Practicable” to be clarified within the working document. JV took acknowledged the usage of ALARP.
  • It was noted by AR that the likelihood of three ships all being moored and unloading at the same time has a 2-3% chance of occurring annually. For clarity, KW reiterated the fact that 2-3% equates to roughly seven to ten times within a calendar year if the facility is running every day. AR confirmed this to be correct.
  • Discussion on shuttling logistics for site visit to Westridge Marine Terminal (WMT)

Location: Office Near WMT Site

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Safety Tailgate commenced
  • Concluded at 12:11

Location: First Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • JL led the site walk and provided overviews at each location in the site walk.
  • VS requested information on whether the scaffolding and grating had been welded or another construction technique had been used.  Scaffolding appeared to be clipped into purpose-built slots.

Location: Second Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.

Location: Third Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
  • Observed silt fencing in place within marine environment.

Location: Fourth Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
  • JH requested information on pile driving operations completion. JL confirmed that more pile driving to occur in the future.
 

Location: Fifth Stop on Site Walk


Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Explanation of pile driving equipment and techniques provided to those in attendance which involved a description of the bubble curtain technique used on site to reduce the noise transference into the marine environment during pile driving operations.

Location: Sixth Stop on Site Walk


Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
 
  • Overview and explanation of a monitoring system located within the vicinity.

Location: Seventh Stop on Site Walk (Birth #1)


Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
  • Observed ongoing cleaning and housekeeping duties underway within direct vicinity of the location.
     

Location: Eighth Stop on Site Walk (Birth #2)

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
  • JL provided a description of the docking protocols for vessels unloading product.

Location: Ninth Stop on Site Walk (Birth #2)

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
  • KW requested information on reasoning behind why the Emergency Stop button, which is attached to the docking equipment on site, does not have a cover on it to prevent accidental engagement. The explanation provided by JL and agreed on by those in attendance was that the Emergency Stop button should remain accessible to staff at all times in the event an emergency situation occurs during regular operations. KW acknowledged the sound reasoning of this decision.

Location: Tenth Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Backup Power Bank location highlighted for those in attendance.

Location: 11th Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  •  (IM’s) KW, JH


Notes:
  • Overview of equipment, structures and building facilities within vicinity. Of particular note was the foaming and watering systems.

Location: 12th Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
 

Location: 13th Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (TMX Virtual) KT, DA, LB, LE, VG, MH, BKal, BKan, PL, CS, JW
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
 

Location: 14th Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (TMX Virtual) KT, DA, LB, LE, VG, MH, BKal, BKan, PL, CS, JW
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
 

Location: 15th Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (TMX Virtual) KT, DA, LB, LE, VG, MH, BKal, BKan, PL, CS, JW
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
 

Location: 16th Stop on Site Walk

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (TMX Virtual) KT, DA, LB, LE, VG, MH, BKal, BKan, PL, CS, JW
  • (IM’s) KW, JH

Notes:
  • Overview of equipment, structures and building facilities within vicinity.
 
 

Location: Office Near WMT Site

Attendance:
  • (CER) TJ and VS
  • (TMX In-Person) JV, RL, BJ, AR, DB, AF, JL
  • (TMX Virtual) KT, DA, LB, LE, VG, MH, BKal, BKan, PL, CS, JW
  • (IM’s) KW, JH

Notes:
  • Concluded site walk.
  • TJ conducted a wrap up of the day’s events including any documents and information requested.

 

Compliance tool used: No compliance tool used

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